1

2

3 NATIONAL INDIAN GAMING COMMISSION

4 REGULATION REVIEW

5 TRIBAL MEETING

6 at

7 ONEIDA CASINO

8 2020 Airport Drive

9 Green Bay, Wisconsin

10

11

12

13

14

15 JUNE 7, 2012

16

17

18

19

20

21 Reported by: Annick M. Trimble, RPR

22

23 (Start time: 9:05 a.m.)

24

25

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1 TRANSCRIPT OF PROCEEDINGS

2 MR. LITTLE: My name is Dan Little.

3 I'm the associate commissioner with the

4 National Indian Gaming Commission. I want to

5 welcome you all to our regulatory review on

6 Group 3, which includes Part 547 and Part 543,

7 the class of minimum technical standards group.

8 I'm here on behalf of chairwoman, Tracie

9 Stevens, and vice-chairman, Steffani Cochran,

10 who send their regards and wish everyone the

11 best of luck and send their hellos.

12 I'm also joined by some NIGC staff that I

13 wanted to point out. Helping check us in here

14 today was Ben Buck. He's from the -- from the

15 regional office. Linda Durbin, she is, I

16 think, out and about in the hallway. Michael

17 Hoenig, the office of general counsel. Paxton

18 Myers, the chief of staff. Nimish Purohit is

19 over here. He's with our division of

20 compliance. Who else have we got? Jennifer

21 Ward, who's also with our office of general

22 counsel. Rest West, he's with our division of

23 compliance, and then Sarah Murray who is the

24 counselor to the chairwoman.

25 MS. MURRAY: Good morning.

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1 MR. LITTLE: I think I got everybody.

2 But before we get started I want to turn the

3 meeting over to chairman Ed Delgado with the

4 Oneida Tribe of Wisconsin to make some opening

5 remarks. Chairman?

6 AUDIENCE MEMBER: No, I am not the

7 chairman. Is this on?

8 MR. LITTLE: Did he have to step out?

9 (A discussion held off the record.)

10 AUDIENCE MEMBER: Well, in either

11 case I think I can talk loud enough.

12 Unfortunately our chairman had another

13 obligation. He was here this morning and he

14 wanted to welcome everybody. Welcome,

15 everybody. Thank you for coming, and on behalf

16 of the business committee of the Oneida Tribe

17 of Indians and the Oneida Tribe of Indians he

18 just wanted to say thank you and welcome, so he

19 apologizes he had to step out, but he just

20 asked me to make a couple remarks.

21 MR. LITTLE: That's unfortunate,

22 because I did get a chance to see the chairman

23 a couple seconds ago, so on behalf of the

24 commission we're very proud to be here in

25 Oneida Country, and we're very happy and glad

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1 that the tribe allowed us to come here today,

2 so thank you very much.

3 You know, when this commission got

4 together, it's been about two years now, we

5 kind of established four major priorities, and

6 those were our consultation and relationship

7 building, training technical assistance, HC

8 operations, and the last one is regulatory

9 review, and basically everything that we've

10 done over the last two years has basically been

11 focused on those as our priorities.

12 The last priority, the regulatory review,

13 is what we're here to talk about today. We set

14 out in the fall of 2010 with a notice of

15 inquiry and basically sent out to the tribes

16 requesting information on what regulations that

17 the -- of the NIGC needs to be looked at and

18 how they should be reviewed and what time

19 frame. From that we did consultation in the

20 winter of 2011 and in April of 2011 we

21 published our Notice of Regulatory Review,

22 which included about 14 regulations that we

23 determined were of importance that needed to be

24 looked at.

25 Today we're going to talk about the Parts

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1 547, the technical standards for Class II

2 gaming, and Part 543, the MICS for Class II

3 gaming.

4 Just kind of a little recap on some other

5 regulations that we've already reviewed. Part

6 514, the fees, that's actually went final.

7 523, the repeal, went final also. And then we

8 have the Notice for Proposed Rulemaking for

9 Parts 542, 518, 547, 556, 558, 559, 571, 573,

10 and then 580 through 585 of the appeals.

11 We're very proud of the work that -- that

12 the commission has done. Always need to

13 recognize our staff because they work very hard

14 on it while we had some members of the

15 commission get to go on and, you know, talk

16 about all these regulations that we've gone to

17 either final rule or proposed rule. It's

18 actually the brilliant staff that does all the

19 work and, you know, helps bring us to where we

20 are today. But there's also a flip side of

21 that coin, and that is the tribes, and we're

22 very grateful to all the input, all the

23 information, all the time and effort that the

24 tribes have spent to come out, provide

25 information, provide comments, and to really

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1 make this a two-way dialog, and that's

2 particularly why we're here today, is on June 1

3 we did publish a Notice of Proposed Rulemaking

4 for these two parts. This is on the heels of a

5 discussion draft that was -- that was published

6 in mid March and the comment period ended in,

7 at the end of May, and from that we received

8 over -- over 100 comments, good comments, and

9 you know, as many of you might may know, prior

10 to coming on the commission I worked for the

11 Mashantucket Pequot for over a decade, and so I

12 was kind of on the other side. I was on the

13 side of the tribes when it came down to, you

14 know, following the NIGC, following the

15 rulemaking process, and you know, I knew a lot

16 of times tribes, you know, were a very good

17 core group, got together and provided comments.

18 What I really enjoyed about the discussion

19 draft that we just went through was that just

20 the time and the energy and the effort that the

21 tribes put in to provide detailed, really

22 helpful comments that when we review them and

23 we use greatly when we put together these

24 Notice of Proposed Rules, so I want to thank

25 all the tribes, I want to thank the National

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1 Indian Gaming Association for all the efforts

2 they did kind of leading up that effort, and a

3 lot of the other regional gaming associations

4 out there that did a lot of hard work for their

5 tribes, and you know, at the end of the day our

6 goal here is to -- is to get a regulation that,

7 while everybody may not be happy with it, it's

8 what works best, and we do that through good

9 consultation and good communication, so I want

10 to thank all the tribes for participating

11 throughout the whole process and not only for

12 being here today.

13 We're going to start off with the

14 PowerPoint presentation here, and just kind of

15 a couple recap things here, you know, these --

16 this consultation is meetings between tribal

17 government and the federal government, you

18 know, only tribes, tribal associations

19 designees can participate, and these meetings

20 are not open to the public.

21 One of the things that I know we've talked

22 about, I know the chairwoman has talked about

23 extensively, is our commitment to Executive

24 Order 13,175. This is consultation and

25 coordination with Indian tribal governments.

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1 This is very important to us, because like I

2 said earlier, when I worked for a tribe and,

3 you know, I was -- I was on -- I'm basically on

4 your side of the table, often times we kind of

5 felt that there wasn't good consultation, and

6 consultation means you listen to the tribes and

7 you understand what their issues are, and then

8 the commission must take that information when

9 making their deliberations and making policy

10 changes, so this commission is very committed

11 to Executive Order 13,175 and all the parts of

12 it, number one, encouraging Indian tribes to

13 develop their own policies to achieve program

14 objectives, very, very important, you know,

15 when -- where possible defer to Indian tribes

16 to establish standards, and then the third one

17 is in determining whether to establish Federal

18 standards, consult with tribal officials as for

19 the need, and that's what I think we've done

20 and we're very proud of that.

21 As, you know, you probably heard this

22 before and it's worth repeating, the commission

23 is committed to a clear and transparent

24 process. We have a transcriptionist here. As

25 soon as the recording or the record is

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1 available it'll go up on our line so -- or

2 online, so you can review it at our website at

3 nigc.gov.

4 All the comments that are submitted,

5 written comments that are submitted, are

6 online. You can probably see those if you have

7 reviewed for the discussion draft. Those are

8 online, and then we'll do the same thing with

9 the Notice of Proposed Rulemaking, and I think

10 most importantly is every comment will be

11 reviewed, and I said it very seriously, we read

12 every comment that came, and I have a big book

13 on my desk that lists every single comment that

14 was submitted for the discussion draft. If a

15 tribe or an organization takes the time to

16 write out a letter I think it's only -- it's a

17 right thing to do for the commission to

18 actually read them, so we do read them, we do

19 review them. I know the staff reviews them, so

20 they're very important, so we want to thank you

21 again on that.

22 And the other thing is any proposed rule

23 or final rule will include a summary of the

24 comments, and you'll see that in the two Notice

25 of Proposed Rules we've got extensive comments,

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1 and it gives you an idea of our thinking and

2 logic behind making decisions that we made, so

3 just want to thank you once again for those

4 thoughtful and considerate comments.

5 The next slide, basically, like I said

6 earlier, we're going to talk about Group 3 of

7 the regulatory review agenda, and those include

8 Part 547, minimum standard technical standards

9 for gaming equipment used in with the play of

10 Class II games, and then Part 543, minimum

11 internal control standards for Class II gaming.

12 Now, after we go through the agenda here

13 I'm going to turn it over Michael Hoenig and

14 he's going to talk about Part 547 and then Jen

15 Ward is going to talk about Part 543.

16 Before we get started I would like, and I

17 think we can get one of the staff to grab a

18 mike, I just want to have everybody go around

19 the room and introduce themselves, just a name,

20 organization that you represent, it would be

21 helpful.

22 MR. CHAPMAN: My name is Daniel

23 Chapman, Lac du Flambeau, gaming commission

24 director.

25 MS. HAZEN: My name is Yolanda Hazen.

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1 I'm from Lac Vieux, and I'm gaming review

2 commissioner.

3 MR. CHAPMAN: Good morning. My

4 name's Duane Chapman. I'm from Lac du

5 Flambeau, internal auditor.

6 MR. EMERSON: David Emerson. I'm the

7 slot director here at Oneida.

8 MR. HENZLEY: Harvey Henzley, Oneida

9 tribal internal.

10 MS. MARTIROSYAN: Good morning. My

11 name is Marina Martirosyan, gaming and

12 compliance specialist.

13 MS. HAWIKA: Ann Hawika, gaming

14 compliance specialist for Oneida.

15 MR. SUJERAK: Good morning. My name

16 a Chad Sujerak. (Phonetic.) I'm from Oneida,

17 gaming compliance specialist.

18 MR. SCHREIBER: Good morning. James

19 Schreiber, Forest County Potawatomi gaming

20 commission compliance.

21 MR. GEORGE: Good morning. I'm

22 George Junior, gaming commission chairman for

23 the Potawatomi.

24 MR. BASINA: Good morning. Milo

25 Basina, compliance for Forest County

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1 Potawatomi.

2 MR. DECORAH: Morning. Joseph

3 Decorah from the Ho-Chunk Nation Gaming

4 Commission.

5 MR. WHITE: Ron White, Lac Vieux

6 Desert, gaming regulator.

7 MR. TAHSUDA: John Tahsuda, Oklahoma

8 Gaming Association.

9 MR. REYNOLDS: Bill Reynolds, St.

10 Croix Gaming Commission.

11 MR. CORNELIUS: William Cornelius,

12 attorney for the Oneida gaming commission.

13 MS. VANCHISM: Tammy VanChism, I work

14 for the Oneida gaming commission.

15 MR MCLESTER: Eric McLester, gaming

16 management at Oneida.

17 MR. OLUJIC: Good morning, again.

18 Jack Olujic, assistant general manager of

19 finance for Oneida Casino.

20 MR. ORCUTT: Morning. I'm Rob

21 Orcutt, attorney for the Oneida Casino.

22 MS. DURBIN: I'm just staff. Linda

23 Durbin, NIGC.

24 MR. BUCK: Ben Buck, compliance

25 officer, NIGC.

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1 MR. GILES: Jason Giles, National

2 Gaming Association.

3 MS. HER MANY HORSES: Danielle Her

4 Many Horses, National Indian Gaming

5 Association.

6 MR. STEVENS: Good morning,

7 everybody, I'm Ernie Stevens, and I want to say

8 welcome to all of you folks for coming here

9 today. I think it's very important and

10 somewhat historic to be able to sit here, put

11 our minds together, and on behalf of my Oneida

12 relatives and team here I'm very proud of what

13 we've done here as it relates to compliance,

14 and I could go forever and tell you about the

15 first gaming commission and, you know, talk

16 about Eric's dad, talk about my dad and so many

17 great things have happened, but the fact, if we

18 fast-forward and I keep you all morning and

19 keep this mike all morning, is that this is

20 a -- like our brothers and sisters in the north

21 and throughout Wisconsin, this area, they're

22 very a fluid, hardworking operation here and

23 compliance has been our priority from Day 1,

24 and Eric and I are and our parents, our dads,

25 were the ones that started the, you know, put

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1 the hammer down from the start and we look out

2 for our gaming operations and overseeing the

3 compliance and all the team.

4 I think my father created the -- I was --

5 I got to be on the council, I got to be the

6 chairman of the audit committee, you know, I

7 don't barely work the adding machine, you know,

8 but because my dad started it and my son is

9 chairman of the committee now, he's a tribal

10 councilman, so we we're very proud of what we

11 have here at Oneida. We're very excited to

12 have all our guests and our relatives here, but

13 most importantly to have the National Gaming

14 Commission here. It's real vital so we can be

15 able to project our voice to you and vice

16 versa, so on behalf of us in this region we

17 take great pride, not just in compliance, but

18 the overall service to our customers and most

19 importantly to our community. As I've said

20 many times to Senator McCain, Senator Jordan,

21 that our compliance, our integrity, everything

22 we do starts from within the heart of our

23 community, and that's where we sit right now,

24 so welcome to you.

25 MR. LITTLE: Thank you, Chairman

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1 Stevens. It's always nice to come up here, and

2 I probably should have mentioned earlier, boy,

3 it's a nice hotel here. I really enjoy it. I

4 think the last time I was here about four years

5 ago before I came on the commission and

6 actually kind of missed those preregulator

7 days, because boy, this casino's got some hot

8 craps tables, so -- but unfortunately I had to

9 take a look at it last light. Actually, a nice

10 crowd in the casino, so it was actually great

11 to see that this casino is doing well and got a

12 wonderful facility and you've got a great

13 hotel, so I really appreciate the

14 accommodations.

15 A couple quick things I just want to -- I

16 want to invite any of the tribal leaders or

17 gaming commissioners to come have a seat at the

18 table. We have seats here for, you know, folks

19 that want to make comments or if you want to

20 have a seat, so I invite you to come up and sit

21 with us.

22 And then the last thing before I turn over

23 to Michael Hoenig is we have an agenda that

24 we're going to try to stick to; however, in

25 past consultations we've gone through the

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1 agenda a little rather more quickly. We will

2 work until -- we'll continue along on the

3 agenda until the lunch break. If there's no

4 other comments after lunch we'll come back in

5 the event there was some folks that decide to

6 be here after lunch, but we may end early, so

7 if you're a tribal leader, you have, I know you

8 all have busy schedules, some have traveled

9 long distances, if you only can be here for a

10 short period of time and you've got a prepared

11 statement that you want to either submit to the

12 record, you can do that at any time, and

13 actually, if anyone would like to do that right

14 now, I open the floor up to any prepared

15 statements or comments.

16 Okay. So with that, like I said, if you

17 do have any you can come and you can just come

18 up to the mike at any time, make your

19 statement, and then if you need to, if you need

20 to leave we can certainly understand that, so

21 like I said, so if we move through the agenda

22 quicker than is scheduled we probably will end

23 early, so I just want to make sure everybody

24 has their comments in there, you know, if

25 possible before lunch. We will come back after

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1 lunch, but if there's no one, nothing else to

2 cover then we'll probably end, so with that if

3 there's no comments I'll turn over to Michael

4 to continue with the -- with the PowerPoint

5 presentation.

6 MR. HOENIG: Good morning, everybody.

7 My name is Michael Hoenig. I'm with the office

8 of general counsel. As Commissioner Little

9 just said, we're going to talk about 547 and

10 543, the minimum internal control standards and

11 the technical standards. As I go through the

12 PowerPoint if anybody has any questions or

13 comments please feel free to interrupt me, and

14 if I don't see hands go up you can literally

15 interrupt me because I'm looking up there and

16 down at a piece of paper.

17 The vote rules, 547 and 543, were

18 published in the Federal Register on June 1,

19 2012, and I believe the Federal Register link

20 is up on their website, I think that's correct,

21 yes, so you can access it there or you can find

22 it in the Federal Register. The comment period

23 closes on July 31, 2012, so get your comments

24 in by then, and there's instructions in the

25 Federal Register on where to submit comments

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1 and how you can submit comments.

2 So let's get into 547. We had issued a,

3 or published a discussion draft some time ago.

4 We reviewed those comments and then based on

5 those comments we put out the Notice of

6 Proposed Rulemaking, so this will talk about,

7 this PowerPoint is going to talk about the

8 changes that have happened from the discussion

9 draft as well as some of the just general

10 changes, the high points of the 547 draft that

11 you'll see, you'll notice.

12 So the first thing to talk about is just

13 the proposed rule generally. It

14 reorganizations the first five sections, so

15 547.1, that's going to stay the same, but 547.2

16 is now the definitions section. We thought it

17 made sense to put all the definitions right up

18 at the front. 547.3 is now the implementation

19 section which talks about how you implement the

20 technical standards. 547.4 is now the rules of

21 general application, so this is kind of the

22 broad rules that are going to apply to

23 everything in the reg. And 547.5 is the

24 general compliance section, so that's going to

25 have all the -- the general compliance parts.

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1 That's where you're going to get into the

2 grandfathering and the compliance for all

3 machines.

4 So in the definitions section we made some

5 changes there. There is a new definition for

6 EPROM, which I don't have in front of me.

7 Nimish, can you tell us what an EPROM is,

8 because I can't remember what that stands for.

9 MR. PUROHIT: It's programmable

10 readable media, electronic, so it's a standard,

11 gaming industry standard terminology for

12 government around the casinos, and it's just

13 been put into the class detect standards.

14 MR. HOENIG: Thank you. For some of

15 the more technical stuff I'm going to be

16 turning it over to this guy here.

17 So we also added advertised top prize,

18 audit mode, definitions for enroll and

19 unenroll, which we have comments about that.

20 We reinserted the definition of electrostatic

21 discharge based on public comments. That got

22 dropped somehow, so we made sure it was put

23 back in there since it is used throughout the

24 reg. We amended the definition of

25 electromagnetic interference, also based on

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1 some comments that we got. We removed a

2 definition that we had put into the discussion

3 draft. In the discussion draft we had added,

4 we wanted to see what folks would think of a

5 definition for proprietary Class II system

6 component, and then with that we added the term

7 proprietary to the definitions of casual system

8 and voucher system, and I'm going to let Nimish

9 talk a little bit about why we did that and

10 then why we took it back out.

11 MR. PUROHIT: Thanks, Mike. So a

12 little quick little history. I came on board,

13 joined NIGC a little after the first round was

14 drafted in 2008, and we had several questions

15 from then until fairly recently by tribal

16 regulatory authorities and tribal operators

17 asking us that hey, we have a common

18 back-of-the-house system that we're putting in

19 to all these different Class II systems that we

20 have, so you know, your accounting systems,

21 they're all coming back to the house ones, do

22 those back-of-the-house systems need to be

23 tested to these standards, and the answer at

24 that time and now is that they don't because

25 they're just being added on, as an accounting

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1 functionality, as a marketing functionality, so

2 what we tried to do with this approach and what

3 I was trying to address were those concerns,

4 that if you have something that is a common

5 back-of-the-house system that does not need to

6 be tested to this, it only needs to be tested

7 to the Tribal Gaming Regulatory Authority's

8 requirements to whatever your specific

9 back-of-the-house system is, so that was kind

10 of the goal and the objective with adding the

11 word proprietary, and then based on the

12 comments we got it was realized that the

13 definition and also the interpretation of that

14 might be taken in other ways, so that's why the

15 commission chose to remove it.

16 MR. HOENIG: Last thing for

17 definitions section is the definition of agent.

18 It does not include a computer systems, and

19 that's kind of been the carryover discussion,

20 that's carried over from the discussion draft.

21 So moving onto 547.3, that is the who is

22 responsible for implementing these standards,

23 so the implementation section. This was moved

24 over from 547.5. It sets out that these are

25 minimum standards, that the Tribal Gaming

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1 Regulatory Authorities can implement standards

2 that are stricter. This is just the minimum

3 that has to be done. We -- it still has

4 language in the existing 547, and that was also

5 in the discussion draft, which is no limitation

6 on technology, so you know, this is not meant

7 to limit technology. Only applicable standards

8 apply, so if there is a standard in here that

9 doesn't apply to a particular machine or a

10 particular component it's not applicable so it

11 doesn't need to be tested. And this has no

12 affect on state jurisdiction.

13 Next is 547.4, what are the rules of

14 general application for this part, and this is

15 moved down to 547.5 from 547.5, sets up the

16 fairness standards and what the discussion

17 drafted, and this draft, the Notice for

18 Proposed Rulemaking, also does, was to remove

19 the minimum odds requirement. The current 547

20 that's in effect right now had a minimum odds

21 requirement of 100 million to one; is that

22 right?

23 MR. PUROHIT: Progressive.

24 MR. HOENIG: So that's been taken out

25 and we'll see a little later in a later slide

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1 in replace of that, to replace that there is a

2 notification requirement which we'll get to in

3 just a few minutes. This requires the test lab

4 to calculate and to verify the mathematical

5 expectations and report those to the Tribal

6 Gaming Regulatory Authority. That requires the

7 test results to be submitted to the Tribal

8 Gaming Regulatory Authority, but the Tribal

9 Gaming Regulatory Authority may also request

10 and manufacture to submit those mathematical

11 expectations so that they have the actual

12 expectations, not just the test results also.

13 All gaming equipment and software has to be

14 approved by the Tribal Gaming Regulatory

15 Authority before it can go on the floor, and

16 equipment must perform according to design and

17 operating specifications, and this kind of

18 gives the TGRA a -- the ability to make sure

19 that they have those design specifications or

20 those operating specifications so that they can

21 ensure that the machine or the game that

22 they've put on the floor is operating as it was

23 designed to operate.

24 547.5, how does a tribal government or

25 TGRA comply with this part? So the big thing

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1 here is the grandfathering provision. In the

2 discussion draft we had made some changes to

3 the grandfathering provision and we got a lot

4 of comments about that. In fact, that was

5 probably the most of any comments we got. What

6 we've done in the proposed rule is just take it

7 back, reset it. The commission decided that it

8 needed some more information before it knew,

9 before it could decide exactly what it wanted

10 to do with the grandfathering provision, so in

11 the Notice of Proposed Rulemaking you'll see

12 it's almost exactly as it is the current 547.

13 There are a few small changes just so it didn't

14 conflict with other parts of the regulation,

15 but with grandfathering the commission is

16 requesting more information to make an informed

17 decision.

18 So you'll see in the Notice of Proposed

19 Rulemaking in the preamble there's some

20 questions set out, how many Class II gaming

21 systems will be affected at the current date

22 that they have to be taken off the floor or

23 brought into compliance is November 10, 2013,

24 and if that current date is extended how many

25 Class II gaming systems will be affected?

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1 What will be the regulatory or other

2 impacts of extending the period by three to

3 five years past November 10, 2013 or just

4 removing the time period completely? How many

5 Class II gaming systems could be potentially

6 submitted to labs if the 120-day period is

7 modified, so initially any game that was going

8 to be grandfathered had to be submitted for

9 testing within 120 days of November 8, 2008, so

10 if -- November 10? Thank you. If it wasn't

11 submitted within that 120 days that's it, it

12 couldn't qualify as grandfathered, so if that

13 120-day requirement is lifted or if the

14 commission were to set out a new time period

15 for submission what affect would that have?

16 What would be the regulatory and other

17 impacts of allowing the limited submission

18 period for the systems that did not meet the

19 original deadline? If 547 were amended in this

20 fashion to apply only to modifications what

21 specific impacts would the amendment have on

22 tribal gaming operations? One of the options

23 or one of the possibilities that are discussed

24 in the Notice of Proposed Rulemaking is to

25 require modifications to be brought into

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1 compliance instead of requiring the whole

2 machine, so there wouldn't be a time period

3 that a game would, the grandfathering provision

4 would expire, but as modifications are made

5 those modifications have to be compliant.

6 Similarly, what would be the impact if

7 the -- this were required of not only

8 modifications but also repairs and replacements

9 for grandfathered Class II gaming systems, so

10 what impacts would that have on the tribal

11 gaming operation.

12 This 547.5 also amends the test lab

13 certification requirement from the discussion

14 draft based on public comments, test labs must

15 note compliance with standards set forth by the

16 TGRA rather than just being able to quote

17 applicable federal laws and regulations.

18 We got some comments that that was setting

19 a really difficult standard, so now it's just

20 whatever the TGRA requires, that's what it has

21 to be tested to.

22 So there's no substantive changes to

23 Section 547.6, so we're going to skip that and

24 go onto 547.7, which is the technical, the

25 minimum technical hardware standards. The

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1 player interface must be labeled with serial

2 number and date of manufacture. This was a

3 change from display, based on public comments.

4 There was some confusion about displayment, did

5 it need to be on the actual display, the

6 machine display, or could it be on the side, so

7 we changed that to say labeled.

8 And it also removes other efforts as to

9 underwriter's laboratory. That's something

10 that we did in the discussion draft and this

11 carried over into this draft.

12 So next is 547.8, what are the minimum

13 technical software standards applicable to

14 Class II gaming systems, so we removed all the

15 references to entertaining displays. That was

16 in the discussion draft, it's been carried over

17 to here. Entertaining displays are not the

18 game. That bingo card is the game and so last

19 game recall, things like that, there's no

20 requirement that the entertaining display be

21 shown.

22 Provides fair changes in rules, but those

23 changes can't be automatic and they have to be

24 disclosed to the player.

25 And then there are no substantive changes

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1 to Section 547.9, .10, .11, so we're going to

2 skip those as well and go over to 547.12, what

3 are the minimum technical standards for

4 downloading on the Class II gaming system, so

5 this removes the TGRA authorization requirement

6 for downloads, and I was just talking to Nimish

7 about this, and the reason for that is it's

8 still necessary, but this isn't the place for

9 it, so it's been moved over to the minimum

10 internal control standards, because that's a

11 control.

12 Requires the Class II gaming system to be

13 capable of providing download information, and

14 downloaded software must be capable of being

15 verified by the Class II gaming system. We put

16 in the capable of, these are all testable

17 standards now.

18 547.14, what are the minimum technical

19 standards for electronic random number

20 generators, so I'm going to let Nimish talk

21 about this a little bit, but we've made a

22 change. There was a requirement that it have a

23 specific unbiased algorithm. That's been

24 changed. I'm going to let Nimish talk a little

25 bit about that.

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1 MR. PUROHIT: Thanks. Mike was

2 telling me don't get into hieroglyphics today

3 because random number generators are pretty

4 technical, so I'll try not to do that. The

5 requirements in here and what the bias was

6 referring to is in actually addressing that

7 when the initial version of 547 went out in

8 2008 there was a bulletin, 2008-4 or -3, I

9 forget which one, I'm sorry, but there was a

10 bulletin that was subsequently issued that

11 talked about that the bias in there of one in

12 100 million is overly strict and it doesn't

13 necessarily apply to random number generators

14 used in Class II gaming systems for bingo ball

15 draws, and because of that and what the

16 comments that were received and from both

17 experience as someone that used to analyze this

18 when I worked for an independent test lab and

19 also conversations with the mathematicians at

20 the independent test labs, we came up with a

21 general approach which was proposed to the

22 Tribal Advisory Committee and said instead of

23 specifying bias the requirement, which is

24 testable and designable, is that there is a

25 bias in the random number generator for the

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1 scaling algorithm, which is if you look at it

2 in context, that's where this is, that it has

3 been reported to the Tribal Regulatory

4 Authority who then makes a decision on whether

5 or not that bias is allowable for their

6 jurisdiction. So that's kind of the approach

7 that we went with. It's not a bias in the

8 random number generator, as many of the

9 comments suggested. It's actually, when you

10 look at it in context, it's a bias for the

11 scaling and the mapping section, so if there is

12 any comments on the specificity of how this is

13 unclear language or ambiguous I will reiterate

14 the Commissioner Little's comments on please

15 let us know how we can specify that.

16 MR. HOENIG: And this is actually in

17 the Notice of Proposed Rulemaking, in our

18 reamble there is -- this is one of the sections

19 where we do ask a very specific question,

20 because some of the comments we got were saying

21 well, that's impossible, we can't report every

22 single bias, and so the question is well, why

23 is this an impossible standard and be more

24 specific, so any information on that is greatly

25 appreciated.

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1 In the RNG there's also, or in the

2 section, I should say, there's also mandatory

3 testing for the RNG. Again, this was something

4 that was put into the discussion draft.

5 Through our discussions at the Tribal Advisory

6 Committee it was decided that these are

7 actually mandatory and necessary tests, so they

8 are set up as mandatory. It's the Chi-Square

9 Test, the Runs Test, Serial Correlation Test,

10 and any additional test at the discussion of

11 the TGRA can be mandatory, and then there are

12 also listed in there some optionals tests.

13 No substantive changes to 547.15, so we'll

14 move onto 547.16, the minimum standards for

15 game artwork glass and rules, and earlier I

16 talked about a new notification requirement.

17 This was in the discussion draft that was being

18 carried over to here, and that is the game has

19 to have this additional disclaimer if the odds

20 are above one in 100 million, and there's no

21 odds requirement. It's simply that if the odds

22 of hitting any advertised top prize exceeds 100

23 million to one the player interface must

24 display notification of such. On the

25 discussion draft we had the word continually in

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1 there which created some problems, and so we've

2 taken that out. It just has to be -- there has

3 to be a notification at some point in the game.

4 It can be on the rules page, etc. And that's

5 it for 16.

6 Lastly is 547.17, and this is how to --

7 how does a TGRA apply to implement an alternate

8 standard those required by this part, so this

9 used to be called the variance section. When

10 we get to 543 we'll talk a little bit about why

11 that was confusion -- confusing there, since

12 variance was used, I think, two or at least

13 three different ways in 543, so we just made a

14 universal change. Instead of calling it a

15 variance it is an alternate standard. The TGRA

16 must submit the alternate standard within 30

17 days of its approval. The chair then, the

18 chair of the NIGC then has 60 days to approve

19 or object. And we've heard from some of our

20 staff in the field that actually go out and

21 check these things out that sometimes 60 days

22 is more than enough time and sometimes it's not

23 nearly enough time, so the chair has the option

24 to extend that 60 day period, if necessary.

25 No alternate standard may be implemented

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1 unless approved by the TGRA or the chairs.

2 There were some comments that were saying we

3 should be able to implement this as soon as

4 it's approved by the TGRA. We agree and the

5 discussion draft and this draft both made clear

6 that the alternate standard can be implemented

7 as soon as it's approved by the TGRA, so the

8 TGRA approves and then it's submitted to the

9 chair.

10 And finally, any appeal of the objection

11 to the alternate standard is going to be

12 included as part of our general fee regs, which

13 are subpart H, and I think those have been, at

14 least they're proposed to have been on the

15 proposed notice as well so you can see how the

16 appeals process works. This used to have its

17 own separate appeals process, which is a little

18 confusing, so in consolidating all the appeals

19 process to make them all uniform that section's

20 been moved there, and that is it for 547, so if

21 there's any questions.

22 MR. LITTLE: Okay. Thanks, Mike and

23 Nimish. Is there any question -- is there any

24 comments that anybody wants to make regarding

25 Part 547? I mean, it can be on any of the

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1 sections or anything that we talked about. The

2 commission does understand that these were just

3 published on June 1, so I know many of you may

4 not have had time to, you know, thoroughly, you

5 know, prepare statements or comments, so like I

6 said earlier, the comment period is open ---

7 the comment period is open until July 31.

8 You're more than welcome to submit written

9 comments before that time, and then also

10 there's four other consultations scheduled,

11 Oklahoma City next week and we have Arizona, I

12 think, the last week of this month and then

13 California and Washington state in July, so

14 there will be some other opportunities there.

15 Mike had talked about the grandfathering

16 provision, and I think that it's been the major

17 focal point for a lot of the comments for

18 PowerPoint 547, and we've heard a lot of

19 discussion and if you notice in the discussion,

20 I mean, excuse me, in the Notice of Proposed

21 Rule we asked some specific questions, so if

22 you can review those questions and like we

23 really need to know what is the actual impact

24 of this grandfather sunset provision if it does

25 go into effect next year, what will be the

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1 impact, how many systems will be affected, and

2 then, you know, another follow-up question is

3 on the 120-day rule where a tribe would have

4 had to submit a system to the testing lab

5 within 120 days of enactment of this

6 regulation, how many systems and devices were

7 affected that were not brought in, were not

8 tested or not gotten to the testing lab in

9 time, if that was removed. We're just trying

10 to understand what is the actual overall. We

11 did make -- we did request these questions in

12 the past and we never really got a good

13 thorough understanding of what is the actual.

14 We've heard numbers as high as 4 and 6,000, but

15 those weren't something that somebody actually

16 pointed the finger at to say this is the actual

17 impact of this is how many devices or systems

18 are affected, so it would be really helpful to

19 hear about that, because this is important.

20 You know, the commission fully understands the

21 importance of a Class II industry.

22 While many of you do operate Class III

23 facilities we understand that this is important

24 to all tribes regardless on what type of gaming

25 they participate in, and it's important to have

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1 a robust Class II industry, so we understand

2 that we want to make sure that whatever we do

3 with these grandfathered games we're not doing

4 something that's going to have an adverse

5 impact or is going to do something that, you

6 know, is not, you know, is not thoroughly

7 thought out or we don't have all the

8 information necessary, so another part of that,

9 the question that we had asked was about the

10 modifications, and we've heard that the current

11 regulation does allow for modifications that

12 are equal to or exceed the standard, and during

13 the discussion draft we had a consultation in

14 Kansas and one of the commenters had said that

15 it was his -- his thought, and I'm taking this

16 from memory, that when they established the

17 five year grandfather sunset provision that I

18 guess the commission felt that the market would

19 have worked its course and the systems would

20 have worked their way through the normal, you

21 know, market demand; however, I'm not sure if

22 the, you know, economic conditions that we've

23 all been through over the last few years was

24 brought into consideration, so we have the

25 systems that are still being used and it is in

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1 the minds of many of the tribes that these are

2 still viable gaming devices and systems that

3 they want -- that you want to use, so we want

4 to make sure that if these are -- if we can

5 protect the integrity of the gaming operation

6 and protect the patrons we want to make sure

7 that, you know, you're still all able to use

8 those. However, we want to make sure that, and

9 I think we've heard and I'm actually interested

10 in hearing if there are some certain areas

11 where tribes still have these grandfathered

12 games cannot become fully compliant, you know,

13 I think the commission feels that the end

14 result that we want these systems to become

15 fully compliant, but we want to make sure that

16 there's no undue hard, you know, economic

17 conditions we're creating by systematically

18 just eliminating them after the five -- as the

19 sunset provision comes to a close here next

20 year, so we're really, really interested in

21 hearing from you what is going to be the

22 economic impact, what are the specifics of how

23 many systems will be affected. So if you're

24 using these, any grandfathered games or

25 systems, please, you know, please let us know

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1 so we can -- we can have a better

2 understanding.

3 Are there any -- does anyone want to

4 comment on that or any other parts? I know

5 we -- during the discussion drop I think a lot

6 of these, you know, the changes we made to

7 entertaining displays or the odds as far as

8 removing the cap on the odds there was some

9 comments that we submitted that tribes were

10 concerned on how, the discussion drafts, it's

11 here in the Notice of Proposed Rule, will

12 require that the patron be notified or be

13 displayed on the system that the odds could

14 exceed one in 100 million, and there was some

15 concern that well, this would require that all

16 the systems to be retested. Well, currently my

17 understanding there's no -- there should be no

18 systems out there that have odds that exceed

19 one in 100 million, so it would require

20 reprogramming anyway, so that doesn't

21 necessarily going to be a hardship, so we

22 appreciate more comments on that if you have

23 any.

24 Are there any other things? Any of the

25 staff have questions they want to throw out to

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1 get folks thinking about or, like I said, you

2 don't necessarily have to speak today. If you,

3 you know, want to take everything in, review

4 all the information. Yes, sir. Could you come

5 up to the microphone and just state your name

6 and the organization you're with?

7 MR. CHAPMAN: Daniel Chapman, Lac du

8 Flambeau. With respect to the -- I haven't had

9 a chance to look at the published, has the

10 manufacturers made comment, any manufacturers

11 made comment to this proposed regulations

12 commission?

13 MR. LITTLE: They've commented on the

14 discussion drafts, and I think, I don't think

15 there's been any substantive comments. I think

16 we got some.

17 MR. PUROHIT: There's one that comes

18 to mine, Commissioner Little, if I may, there

19 is a -- and you can take a look, there's a

20 company called Fortunate. They submitted

21 something, and that was to, from their point of

22 view, because the Class II system also extends

23 to handheld devices, such as your bingo

24 winders, such video devices, etc., so they're

25 asking during the discussion draft when the

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1 comments came in that there needs to be some

2 specificity to that, so that's the one that

3 comes right to my mind, and then there was one

4 from the, just expanding on that, by

5 independent test labs that test these

6 manufacturers' products as well, but besides

7 those two I can't think of any other specific

8 ones for 547.

9 MR. LITTLE: While I have Nimish on

10 the mike here, I think one of the changes that

11 we did make was with requiring the hard sheets,

12 I guess. Maybe we can talk about that, and we

13 didn't really get any comments from that from

14 the manufacturer. Maybe you can talk about

15 that a little more.

16 MR. PUROHIT: Sure. So as Mike was

17 going through, Mike Hoenig was going through

18 the presentation, the one section he pointed

19 out was a requirement that has been eliminated

20 as a probability requirements to be designed

21 under, and that was morphed into a requirement

22 by manufacturers to not have any other

23 restrictions unless placed by a tribal

24 regulator of what the specific odds are going

25 to be, but it was replaced with the requirement

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1 of manufacturers not only having all the game

2 maps tested by a independent test lab, but also

3 submitting that in what would be the equivalent

4 to a par sheet on the Class II side, but it's

5 not called a par sheet, it's called a game

6 sheet, what have you, to submit it to the

7 tribal regulator and the tribal operator as is

8 industry standards, so that was kind of one of

9 the shifts in that particular approach based on

10 what the comments that we received during the

11 discussion draft and also by the Tribal

12 Advisory Committee.

13 MR. LITTLE: Right. Thanks, Nimish.

14 That was one of the areas where we thought we

15 would get a lot of comment from the

16 manufacturers, and we haven't heard anything at

17 all. The only thing I could estimate that

18 would mean is a positive thing for the TGRA, so

19 they can see how the systems are expected to

20 work.

21 Was there any other comments?

22 Well, I guess we could probably just start

23 on 543. We've got a scheduled break in a half

24 an hour. I guess we can -- we could -- does

25 anyone need a break or can we just start off

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1 and then we'll see how far we can get through

2 before the 10:30 break. Okay.

3 MS. WARD: Good morning again. My

4 name's Jennifer Ward and I am the staff

5 attorney that works with primarily this region,

6 the St. Paul region, so if you've got an

7 ordinance that you're working on it's probably

8 come across my desk, so now you can put a face

9 to the name.

10 We'll start this morning on Part 543,

11 minimum internal control standards for Class II

12 gaming. And this part addresses only Class II

13 games and their associated functions. The

14 proposed rule is based on the discussion draft,

15 which was a new document, and it took ideas

16 from several different sources, including our

17 current MICS, the TAC recommendation, the

18 Tribal Gaming Working Group guidance, and the

19 2010 proposed MICS.

20 There were a few things we did with this

21 proposed rule, generally. In response to

22 comments we reviewed the use of agent, person,

23 and personnel throughout the document and made

24 changes where it was appropriate to make sure

25 that the word there was what we meant it to

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1 say, and we also inserted as needed language in

2 each of the supervision provisions, excepting

3 the IT section, and we did that to promote

4 consistency in the proposed rule. We also

5 added supervision provisions for patron deposit

6 accounts, lines of credit, and surveillance.

7 In the definitions section we made a few

8 changes to the drop definitions. The drop

9 proceeds definition has been amended to include

10 financial instrument storage component

11 proceeds. And the drop definition has been

12 deleted because it's unnecessary. The process

13 of collecting boxes and components is described

14 in the drop account section itself.

15 The definition of gaming promotion has

16 been altered to include only those promotions

17 requiring game play to participate, and when I

18 say altered it was altered from our current

19 MICS, but that's -- this definition is the same

20 as it appeared in the discussion draft.

21 The definition of sufficient clarity

22 continues the 20 frames per second minimum, but

23 it adds clearly identify to the requirements.

24 And again, this is the same as it was in the

25 discussion draft. Now, here the commission

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1 invites comments on this. We received several

2 comments that said that it -- the 20 frames per

3 second could limit technology, and we're

4 interested in hearing why specifically and

5 we're also interested in hearing if we changed

6 the language to say 20 frames per second or

7 equivalent would that resolve any limitation on

8 technology that this could have. Those are two

9 questions we're hearing your comments and the

10 answers to.

11 While I hear some murmurings in the back

12 at this point I just want to take another

13 opportunity to remind you, if you want to

14 interrupt me at any point if you have questions

15 please feel free. We don't have to wait until

16 the end of this presentation certainly and it

17 could spur some more discussion.

18 On Section 543.3, how tribes comply with

19 this part. There are minimum standards, and

20 the TGRA may establish additional controls that

21 do not conflict with this part. The

22 regulations provide a framework that recognizes

23 the significant role of the TGRAs, and

24 throughout this document the TGRAs establish

25 thresholds for investigating variances and to

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1 implement procedures for various standards.

2 And they have 12 months to comply by

3 establishing and implementing procedures after

4 this rule goes final eventually. And there is

5 a difference between the existing and the new

6 facility compliance date. Existing facilities,

7 I believe, have 12 months to comply and new

8 facilities have until the next fiscal year. Is

9 that correct? Yes.

10 MR. WEST: Well, new facilities have

11 to be compliant.

12 MS. WARD: Okay. I'm sorry. That's

13 what I -- yes, new facilities have to be

14 compliant when they open and existing

15 facilities have up to 12 months.

16 543.4, the question here, does it apply to

17 small and charitable. Originally back in,

18 maybe it wasn't originally, 2002, there was the

19 charitable exception for MICS, so charitable

20 operations could be excepted from the MICS if

21 they met certain criteria. And then later down

22 the road during the next tradition of the MICS

23 the small gaming operations section was added,

24 and now as we're taking a look through this

25 we're wondering if the small gaming exception

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1 has swallowed up the charitable and whether

2 charitable is still necessary, so if you want

3 to take a look at it and see if it still

4 applies in your operations or if the small

5 gaming operation exception covers it, please

6 let us know.

7 543.5, and this is about how tribes apply

8 to use an alternate standard, and this is what

9 Mike alluded to earlier in Part 547 discussion.

10 As it appears in the MICS this used to be the

11 alternate standard, used to be called the

12 variance, and as you know if you're on the

13 compliance side and the audit side a variance

14 is when you get an answer or an amount that's

15 different from what the expected amount was.

16 And so when you talk about this variance all of

17 a sudden you're talking about a new standard

18 that has to be approved, and it's very

19 confusing, we thought, so we changed the term

20 to say the alternate minimum standard, and

21 that's, again, based on public comments, and we

22 added the word minimum in here from the

23 discussion draft to clarify that this is really

24 talking about putting in place a different

25 minimum standard rather than applying to any

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1 standard that exceeds what the MICS already

2 are.

3 The TGRA may approve the alternative

4 minimum standard but they still must obtain

5 approval from the NIGC chair, and the NIGC

6 chair review and decision is within 60 days,

7 and just like in 547, the chair may extend an

8 additional 60 days when necessary.

9 543.8 is the bingo section, and in

10 response to public comments we have combined

11 the gaming machine gaming systems for bingo and

12 the manual bingo sections. The commission

13 agrees that bingo is bingo and has combined it

14 into one section now.

15 543.7 was the gaming system bingo section,

16 and it's now been reserved.

17 We believe this is less procedural than

18 the existing MICS, but it requires TGRA and/or

19 the operation to establish controls that meet

20 the detailed criteria, and for an example of

21 how it's less procedural you can see 543.8B1

22 that talks about bingo card inventory. And it

23 still requires a verification of prizes over

24 $1,200, and the player interface may serve as

25 one verifying signature for a manual payout,

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1 and it may serve as the sole verifying

2 signature for an automatic payout, leaving the

3 discussion draft. It was inadvertently left

4 out and it said that the -- it required two

5 signatures and it wasn't clear that the machine

6 could be one of them, so we wanted to clarify

7 that in this case for a manual payout the

8 machines can indeed serve as a verifying and

9 validate signature.

10 Section 543.9 covers pull tabs, and here

11 the pull tabs limit for the prize verification

12 is still $600, and we've changed the definition

13 of kiosk so that it clarifies that it may also

14 be capable of redeeming and reconciling pull

15 tabs. That was in response to a comment that

16 we received saying that it limits technology if

17 the kiosks can't redeem and reconcile pull

18 tabs, then it -- it limits technology, so we

19 added a provision it would allow the kiosk to

20 do that so long as after the pull tabs are

21 pulled out from the -- are removed from the

22 machine that they are destroyed, secured and

23 destroyed in accordance with the TGRA

24 procedures, and that allows the kiosk to go

25 ahead and redeem and reconcile the pull tabs

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1 without having to deface it as required by the

2 manual redemption and reconciliation.

3 543.10 is the MICS for card games. TGRAs

4 review and approve cancellation and removal

5 procedures, and this continues the standard

6 that no administrative or overhead fees may be

7 taken from player pool funds.

8 We did receive one comment that the

9 supervision section may not provide for

10 adequate supervision of the card room, and we

11 request additional comments on that.

12 543.12 covers gaming promotions and player

13 tracking. The gaming promotion standards are

14 limited to those promotions that require game

15 play to participate. And the player tracking

16 systems are included here as well because

17 they -- they're designed to track game play and

18 give awards based on the game play.

19 543.13 is MICS for complimentary services

20 and items, requires the TGRA or the -- and the

21 operation to establish specific controls and

22 procedures, and the TGRA establishes the

23 threshold for recording comps.

24 543.14 is MICS for patron deposit accounts

25 and cashless systems. As it was in the

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1 discussion draft we've removed any reference to

2 unrestricted player accounts. It appears that

3 the Bank Secrecy Act would prohibit

4 unrestricted player funds where anyone can

5 access them, so we removed them from here.

6 543.15, the lines of credit, it covers the

7 establishment of lines of credit, and we

8 received some comments that this provision, the

9 section isn't necessary, and we invite comment

10 on why that would be the case or why not. We

11 have heard in the consultations that several

12 tribes either have lines of credit procedures

13 or are looking to add them in the future, so it

14 does not apply. If it's unnecessary we would

15 like to hear why.

16 543.17, the MICS for drop and count. This

17 has been simplified. It is still a bank

18 procedural section, just the nature of drop and

19 count, but this does provide for more TGRA and

20 operation discretion than the previous MICS.

21 543.18 covers cage, vault, cash, cash

22 equivalents, and kiosks. And again, we've

23 added kiosks to this section, and it requires

24 that any cage increase or decrease of $100 or

25 more must be verified, documented, and

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1 recorded, and promotional payments of $100 or

2 more must be documented.

3 543.20, MICS for information technology

4 and IT data. Most of these topics were adopted

5 from the TAC, and you'll see the list there, a

6 few of them are the physical security, logical

7 security, data backups, remote access, for

8 example. We also added a definition of system

9 in the IT section to distinguish it from the

10 Class II gaming systems, and that definition of

11 system applies to the IT section only and it

12 was based on public comment that said there was

13 some confusion as to what exactly we were

14 talking about in the IT section when we

15 referenced system, and a question as to whether

16 or not we may be referencing the Class II

17 gaming systems or something else, so we have

18 provided a definition there.

19 543.21 is the MICS for surveillance. It

20 requires cameras with sufficient clarity in the

21 count room, card tables, and cage and vault.

22 For Class II gaming systems, the

23 surveillance must include the jackpot meter.

24 We removed the requirement of surveillance of

25 the bingo server based on public comment, and

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1 after reviewing the IT section again we

2 determined that the physical and logical

3 controls for the bingo servers in the gaming

4 systems are adequate in those sections.

5 The commission invites comments on whether

6 the one-year retention period for surveillance

7 footage is appropriate.

8 And this section requires the TGRA

9 approved procedures for reporting suspected

10 crimes and suspicious activity.

11 543.23, MICS for audit and accounting, the

12 annual requirements in this section adopt the

13 TAC recommendation.

14 And 543.24, the MICS for revenue audit,

15 this is separated out from audit and

16 accounting. It specifies the frequency of each

17 testing procedure. And the game sections, for

18 example, the Class II gaming systems, bingo,

19 pull tabs, and card games, those all adopt the

20 TGWG guidance.

21 And these sections are largely unchanged

22 from the discussion draft. The changes that

23 you'll see relate to our combination of the

24 bingo sections because they reference back, so

25 we -- you'll see changes there. Otherwise

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1 these sections are largely the same from the

2 discussion draft. And with that I open it up

3 for comments and questions. Any --

4 MR. CHAPMAN: Good afternoon, good

5 morning again. I think I have two areas of

6 this I wanted to briefly clarification.

7 MR. LITTLE: Sir, can you please

8 state your name and organization?

9 MR. CHAPMAN: Duane Chapman from Lac

10 du Flambeau. One area, I believe this is for

11 definition clarification, you move to change

12 alternate standard variance. Is there a

13 necessity to create a definition for

14 alternative standards, or had that been

15 addressed? If I go to 543.5.

16 MS. WARD: Okay. I'm at 543.5.

17 MR. CHAPMAN: Yeah, 543.5,

18 alternative standard versus variance, I'm just

19 curious, is there a need or a necessity to

20 create a definition for alternative standard?

21 MS. WARD: I don't think that we do

22 in the definitions, do we? We don't. I

23 believe we discussed this, and at the time we

24 discussed it internally, we didn't think that

25 there was a need for it, but if you do that's

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1 something we'd like comment on. It seems to

2 spell out the procedure for it. In the NPRM we

3 attempted to explain a little further what

4 exactly an alternate system is, but again, if

5 that's something you really feel a definition

6 is necessary for it's something we'd like to

7 hear, and if you have a discussion for what

8 that definition should be we'd like to hear

9 that as well.

10 MR. CHAPMAN: Currently not at this

11 time, but to expound on it later I think that

12 there's obviously opportunity through the time

13 period to provide some feedback to you.

14 The other area was considering to

15 understand, because I'm not -- I'm just not

16 aware of it, on your 543.21 standards, you talk

17 about commission invites comments on whether

18 one-year retention period for surveillance

19 footage was appropriate. To understand that,

20 can someone please clarify that there currently

21 is a standard, that surveillance footage is to

22 be maintained for one year? Is that how I

23 understand it?

24 MS. WARD: It's not all surveillance,

25 it's only the surveillance that records

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1 suspicious activities, suspected crimes, or

2 detentions by security personnel, I believe.

3 MS. MURRAY: That is not enforced

4 right now, if that's -- if that's your

5 question. That was in the discussion draft,

6 and it was based on the Tribal Gaming Working

7 Group guidance recommendation, so that is

8 not -- that is not a standard that is currently

9 in practice. And we are interested -- we did

10 receive some comments suggesting that that was

11 not a reasonable retention period for

12 surveillance footage, but since it was Tribal

13 Gaming Working Group recommendation we are

14 interested in hearing more input and comments

15 on if that is not -- if that is not an

16 appropriate period what -- what would be a more

17 appropriate period or if that -- if the tribes

18 agree that that is an appropriate period for

19 that type of surveillance footage, so we're

20 very interested in receiving comments on that.

21 MR. CHAPMAN: Okay.

22 MS. WARD: And if it helps, the cite

23 for that is 543.21E2. It's towards the end of

24 that section.

25 MR. CHAPMAN: Please restate that,

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1 please.

2 MS. WARD: 543.21E2, and it's toward

3 the end of the section.

4 MR. CHAPMAN: Okay. I appreciate the

5 time. Thank you.

6 MS. WARD: You're welcome.

7 MR. LITTLE: Thank you, sir. Is

8 there any other -- any other comments?

9 MR. ORCUTT: I'm looking at the

10 discussion --

11 MR. LITTLE: Sir, just need you to

12 grab a mike and state your name and

13 organization for the record, please.

14 MR. ORCUTT: Rob Orcutt, attorney for

15 Oneida, the Oneida Casino. I was -- just a

16 clarification. I was looking at the discussion

17 draft and it looks like, if I'm reading it

18 right, the cite for that is D2.

19 MR. LITTLE: On the discussion draft

20 or the Notice for Proposed Rulemaking?

21 MR. ORCUTT: Preliminary draft on

22 April 27.

23 MR. LITTLE: Yeah.

24 MS. WARD: In the proposed rule

25 that's in the Federal Register.

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1 MR. ORCUTT: Oh, I'm sorry, it's

2 this --

3 MS. WARD: Yeah. It could very --

4 you're probably right and I don't know what

5 would have changed --

6 MR. ORCUTT: Okay.

7 MS. WARD: -- in the cite, but in the

8 proposed rule it is E2.

9 MR. ORCUTT: Okay. Thanks.

10 MS. WARD: You're welcome.

11 MR. LITTLE: Sir, again -- -

12 MR. CHAPMAN: It's Duane Chapman,

13 again, from Lac du Flambeau. I just want to

14 clarify my inquiry on this inquiry as to I've

15 been doing audits for casinos for the last ten

16 years, and one of the things with looking at

17 federal regulations and NIGC MICS or any other

18 MICS out there is understanding what the intent

19 of it is, and also to apply, you know,

20 reasonable -- reasonableness and understanding,

21 you know, that the language is written in such

22 a way where it reduces ambiguity, and because

23 as we can all probably attest to out there in

24 the audit world there are several ways to look

25 at things, and not only from a regulatory --

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1 there's regulators' side of it, but from a

2 operations side of it they look at it in a

3 varied way also, so my intent is just to try to

4 have some clarification to understand what

5 intents of those regulations are and, you know,

6 I know this is an ongoing process and for me

7 and I just need to do additional homework to

8 reach out and consult with you all to further

9 help me clarify what things are moving forward

10 with. Appreciate it again.

11 MS. MURRAY: I really appreciate,

12 appreciate that comment, Mr. Chapman,

13 especially because you point out that it's not

14 always the same perspective between the

15 regulatory authorities and the operations, and

16 that's kind of what we're trying to balance

17 with this, with this particular provision, is

18 that from an operational standpoint a one-year

19 retention period may not be reasonable because,

20 for instance, if you have backup tapes or

21 something like that you have a specific amount

22 of room that you -- that you -- that you can

23 have to -- for these tapes to either take up

24 space or you need to reuse your tapes, and it

25 can be a significant cost to upgrade or to do

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1 something different, so we understand that

2 perspective. Also for regulatory perspective

3 our purpose is to protect the integrity of the

4 operation, so the purpose in having a retention

5 period at all is to assist the operation in

6 protecting -- protecting itself, its integrity,

7 and also for, you know, law enforcement

8 purposes, recovery, theft, etc., in those -- in

9 those circumstances, so that's why we're

10 interested in hearing comments both from the

11 operational perspective as well as from tribal

12 regulators to see what -- what compromise we

13 can reach or what works best from everyone's

14 point of view, so I do really appreciate that,

15 that comment. Thank you.

16 MR. CHAPMAN: Thank you. Again, just

17 expressing to clarify what you're saying,

18 identify a happy medium between operations and

19 regulations.

20 MS. MURRAY: That's exactly right.

21 MR. CHAPMAN: Thank you.

22 MS. MURRAY: Thank you.

23 MR. LITTLE: That's one of the

24 reasons why we did throw out the comment for

25 that, the request for more information, because

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1 this is -- it is an area that we did discuss,

2 the commission discussed, and we just needed

3 more information, you know, is one year too

4 long, whatever, you know, the challenge is,

5 logistical challenge like Sarah had pointed

6 out, so we'd be very, very grateful if you

7 could provide us some more information on that,

8 so appreciate that.

9 Does anyone else want to make comments?

10 I'm thinking we should maybe go to a 15 or 20

11 minute break, come back, and give you a chance

12 to, you know, catch a drink or use the

13 restroom, check out of your hotel room if you

14 need to, I know I will be doing that, and then

15 see if anybody's got some thoughts they want to

16 share with us. We'll come back at 10:45, okay?

17 (Short break was taken.)

18 MR. LITTLE: I'll open the floor back

19 up to comments if anybody has had a chance to

20 consider some things and want to comment for

21 the record. Please feel free to now. You

22 know, one of the -- one of the big items in the

23 Part 543, the difference between the Notice of

24 Proposed Rulemaking and the discussion draft

25 that -- and you know, kind of the demonstration

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1 that we're -- we listen to the comments and we

2 take everything that we receive very seriously,

3 and in the discussion draft, and this was born

4 out of some discussions during the Tribal

5 Advisory Committee, we split manual bingo with

6 electronic bingo and we heard overwhelmingly

7 from the comments from the tribes that that was

8 not a good idea, so you see in the Notice of

9 Proposed Rulemaking that bingo is bingo, it's

10 in one section, and the commission, we put out

11 there in the discussion draft, and as we had

12 said during the consultation of the discussion

13 draft that there were things in there that we

14 included, that were put in there to generate

15 some -- some thinking and some comments, and

16 that was one particular area that we were, you

17 know, had to come to us in a decision and

18 that's where we're going to go, and I'm once

19 again referring to the discussion draft, so

20 when it came time to develop the Notice of

21 Proposed Rule we did decide that bingo is bingo

22 regardless of how it's played, whether it be

23 with paper or through a technical aid, it's

24 still bingo and we did consolidate that back

25 into one section, so you saw that in the Notice

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1 of Proposed Rule.

2 I'm not sure if anybody wanted to make a

3 comment on that. I know we did talk about the

4 retention period, very important, you know, we

5 did -- we did include that one year, that was

6 basically from the Tribal Advisory Committee

7 guidance document, but we definitely are very

8 open to more comment on that.

9 One of the areas that we -- we talked

10 about extensively during, you know, our

11 internal deliberations was on sufficient

12 clarity of the cameras, and that was an area

13 that was raised or in the Tribal Advisory

14 Committee, we really are interested in hearing

15 what you have to say about the types of

16 cameras, the, you know, minimum frame

17 requirements, how that can affect your

18 operation, if there are particular areas that

19 you need, you know, more sophisticated cameras,

20 you know, what are they, what are the

21 limitations that some of these, if we were to

22 create a stricter standard, what would that

23 impose for your operations, so you know, we're

24 really interested in hearing about that.

25 I'm just going through the -- the Notice

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1 of Proposed Rule in some of the areas where we

2 did ask for questions, if you want to -- if you

3 want to, you know, step up and comment please

4 feel free to. Don't -- you don't have to wait.

5 You know, we talk about, and it was an

6 area that the Tribal Advisory Committee raised,

7 we're talking about player tracking, gaming

8 promotions, comps, lines of credit where some

9 felt that it was outside of the authority of

10 the NIGC. You know, we obviously disagree, and

11 we did kind of spell out our reasoning why.

12 You know, all these, you know, issues pertain

13 to play. You have to play to participate in

14 the, you know, receiving comps or, you know,

15 gaming promotions. We tried to pull out any

16 specific instances where there could be a

17 promotion that did not specifically require

18 some type of game such as if there was a

19 drawing for a particular prize where you had to

20 put your name on a card in a tumbler, that's

21 outside the authority of this commission, so we

22 want to try to clarify that, but we do know

23 that these are potential areas for risk and

24 that's important, that you know, we do

25 establish standards, but this is what we've

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1 seen, you know, problem areas rise, and I'm

2 sure you all have seen these too, so one of the

3 reasons why we feel it's important to keep

4 these in there, you know, lines of credit is

5 another area where the Tribal Advisory

6 Committee felt we didn't have any authority.

7 We know this is an area that in the Class II

8 operations have very limited use, but we do

9 have obviously mixed floors where you have

10 Class II and Class III where it is being

11 utilized, so we do feel there's a need there.

12 Another section that Jen had pointed out

13 on the drop and count, and while it can be

14 rather cumbersome in the reg, you know, it's an

15 important -- it's such an important part of the

16 standard that it needs to be specific in some

17 areas, but if there's some things you think

18 could be, you know, better explained or

19 clarified in the standard we definitely are

20 open to your thoughts and ideas.

21 Does anybody have anything they want to

22 add?

23 MS. MURRAY: I had some actually

24 really great conversations over the break, and

25 I don't mean to put you on the spot, Eric, but

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1 he pointed out, and for those of you who don't

2 know Eric, he is in charge of slots here at

3 Oneida and he -- he mentioned that although

4 they do mostly Class III there that he was

5 pointing out some areas that in our 547 ranks

6 that could potentially limit technology, and

7 that, as explicitly stated in 547, is not the

8 goal. We do not in way want to limit

9 technology, and so while you're going through

10 547 and 543 if you do see areas that could

11 potentially limit technology please comment on

12 those and let us know how and in what ways

13 those -- those areas could limit technology and

14 ways that we could potentially remedy that

15 problem, so I really look forward to hearing

16 those comments and to reading the written

17 comments that we receive on those issues, so

18 thank you very much.

19 MR. LITTLE: Any -- any other issues

20 you think we need to talk about more? I'm

21 looking at staff here or -- and, you know, we

22 can also talk about 547, like I said, you know,

23 the grandfathering provision, there was some

24 major issues raised in the comments, and I did

25 talk about it prior to the break about, and

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1 we're very interested in hearing about the idea

2 of how modifications, if the commission was to

3 require that future modifications, you know,

4 specific, either be parts or parts of the

5 system be replaced, if they were to be -- if it

6 was to be required that they are fully

7 compliant how would that affect the operations,

8 if you're using these grandfather gaming

9 systems, so please, you know, think about that.

10 I know many of you probably don't even have any

11 grandfathered systems, so definitely understand

12 that too.

13 MR. HOENIG: Can we just say along

14 those lines I really strongly encourage

15 everybody to definitely check out the preamble

16 to the reg. I know sometimes I just jump to

17 the reg itself, but there's a lot of questions

18 that are posted in the preamble for 547 and

19 543, but there's also a lot of explanation and

20 a lot of the kind of rationale and reasoning

21 behind some of the changes that the commission

22 made, so it's a good read.

23 MR. LITTLE: Yeah, this is

24 definitely, you know, the staff spent a lot of

25 time. I know I remember having a meeting where

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1 I just basically asked Jen to put something

2 together and she did, so you know, they spend a

3 lot of time and we spend a lot of hours

4 together just going through the comments and

5 trying to make sure that we, you know, fully

6 explain our reasoning and rationale for making

7 the decisions that we made, but also

8 identifying areas where we need more input, we

9 need more information, and like we said, you

10 know, all along, we're not going to make these

11 decisions without, you know, fully providing

12 opportunity for tribes to comment and, you

13 know, thoroughly feel that, you know, your, you

14 know, input was reviewed carefully.

15 So I don't necessarily want to keep

16 everybody if -- if there really isn't any

17 comments. You know, I do understand that the

18 reg was just published on the 1st, so maybe you

19 haven't even, both regs, rather, published on

20 the 1st, had a chance to fully review them, so

21 like I said, the comment period is open until

22 July 31, so there's a lot of opportunity to

23 send in comments. There will be four

24 additional consultation sessions that are

25 posted on our website that I encourage you to

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1 attend if you can. Otherwise we're not going

2 to adjourn for the day, because I want to make

3 sure that if there was any folks that were

4 planning to be here at 1:30 after the break,

5 after the lunch break, get an opportunity to

6 speak. However, this does not mean that you

7 have to come back at 1:30. We're going to be

8 back at 1:30. If you know you've seen -- if

9 you provide all the information that, you know,

10 you came here to do then that's fine. I wish

11 you safe travels and thank you for your coming,

12 for coming today. And if you feel like you

13 might miss something, like I said, the --

14 everything will be, the transcript will be

15 posted on the website so you can review those

16 afterwards, so I think I'll, if there's no

17 other comments I'm just going to, we're going

18 to break for lunch and then we're going to come

19 back at 1:30. Thank you, everybody, for

20 coming, and if you do leave please safe travels

21 and please send those comments, so thank you

22 very much.

23 (Lunch break was taken.)

24 MR. LITTLE: We're going to continue

25 the Notice of Regulatory Review for NIGC

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1 Regulations Part 547 and 543. I'm going to

2 open the floor back up to any comments that may

3 be out there. Sir, if you want to come to the

4 microphone, state your name and the

5 organization.

6 MR. HENSLEY: Harvey Hensley, Oneida

7 tribal internal law. I was requested to come

8 back and ask a couple questions about

9 availability of analysis for decision-making.

10 MR. LITTLE: Okay.

11 MR. HENSLEY: Some jurisdictions,

12 particularly ours here, we have possibility of

13 having Class II and Class III games. Has

14 there, analysis been done as far as the

15 stringent sheet, a comparison been done between

16 the new Class II and the Class III regulations

17 as far as stringency goes, more or less,

18 particularly cage, vault, drop count, sheet

19 software, so forth, and can we obtain that

20 analysis for our decision-making?

21 MR. LITTLE: I'm not aware of an

22 analysis that I've done.

23 MR. HENSLEY: There's no stringency

24 analysis? We're required by the State of

25 Wisconsin, our Class III regulations be as

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1 stringent as the NIGC regulations, so there may

2 be a question from our standpoint when a Class

3 II regulation might be less or even more

4 stringent as to which way we go with that.

5 MR. LITTLE: All right. Well, I'm

6 assuming, I don't know the details of your

7 contract, that the contract specifically, does

8 it have a provision where you're required to

9 meet or exceed an NIGC Part 542?

10 MR. HENSLEY: No, sir. Well, as far

11 as Class III, yes.

12 MR. LITTLE: Okay.

13 MR. HENSLEY: But I'm not aware of

14 any pronouncements so far as far as these new

15 class regulations.

16 MR. LITTLE: I think just from the

17 nature that the Part 542 has not been updated

18 in a very long time. The way that technology

19 is moving so quickly, I'm sure Russ can jump in

20 and provide more information, but it would seem

21 that probably the new Part 543 would be more

22 stringent, I'm assuming. I don't know what,

23 Rest, you want to add to that, but that only,

24 you know, we work out of a, you know,

25 understanding of the Supreme Court or the, I'm

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1 sorry, the court decision in Creek (phonetic.)

2 that basically outline our, the NIGC's role

3 with Class III gaming, so you know, that is an

4 issue that the commission, you know, has been

5 reviewing and looking at that is important that

6 that regulation is becoming outdated because of

7 the, you know, the change in technology, and

8 you know, but you know, under IGRA, you know,

9 there is clearly a role for the NIGC in

10 regulating Class II gaming and, you know, we

11 feel very confident that this, you know,

12 proposed regulation in Part 543 does create

13 some, you know, good standards that does create

14 some, you know, good protections in there for

15 the integrity of the operation, so we haven't

16 done an analysis on that. I'm not sure if we

17 were ever asked to do one or --

18 MR. HENSLEY: It's a comparison.

19 MR. LITTLE: Right.

20 MR. HENSLEY: So that's not

21 available.

22 MR. LITTLE: No.

23 MR. WEST: And some of the standards

24 have been moved from different sections and

25 stuff, so I don't know if you could get a

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1 clear-cut comparison on cage to cage, because

2 some of the things might have been moved to

3 another section. I mean, you might, you know,

4 there may be some standards in the Cage 543

5 cage that are more stringent than 543, and then

6 on the other side there might be some that are

7 less, so I just don't --

8 MR. HENSLEY: And my second question

9 has to do with availability of analysis also.

10 You gave an example where surveillance over the

11 server was not deemed needed --

12 MR. LITTLE: Right.

13 MR. HENSLEY: -- per comments? Was

14 there an analysis that was done that we could

15 have as to why that would be?

16 MR. LITTLE: Well, if you look in the

17 preamble of the regulation we kind of explained

18 the reasoning, you know, it was surveillance of

19 the server because often times the server's not

20 located at the facility, it became problematic

21 and that --

22 MR. HENSLEY: I see.

23 MR. LITTLE: -- the commission felt

24 that there are, you know, there are checks and

25 balances and that does protect the integrity of

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1 the server; however, you know, we're very open

2 and would definitely like to hear a comment if

3 you think that that is an area that we do need

4 to look at further and if there is a need

5 for -- for, you know, dedicated camera,

6 surveillance on the server. We would love to

7 hear from that and we would encourage you to

8 submit those, please.

9 MR. HENSLEY: Well, this is all kind

10 of preliminary. I expect us to have some more

11 comments. We haven't had a chance yet to

12 really review the new regulations.

13 MS. MURRAY: And I would just like to

14 reiterate that if your TGRA deems that a camera

15 over the server is necessary for your operation

16 there's nothing in the regulations that would

17 preclude your TGRA from inquiring that above

18 and beyond the MICS right now, but we are

19 interested in hearing comments about generally

20 the practicability and the necessity of doing

21 that across the board, so...

22 MR. HENSLEY: Well, we appreciate any

23 analysis that you folks could do. I know

24 earlier the gentleman mentioned about

25 explanations for the reasons for regulations.

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1 That would be also -- also very helpful in a

2 casino environment to explain to the people

3 what these controls are all about, they're not

4 just regulations. There's a meaning and a

5 purpose for them. So kind of an advisory.

6 Several years ago a gentleman who was an

7 auditor in Vegas, published a book about what

8 are the reasons for these regulations, and that

9 was very, very well needed, and I still think

10 something like that, especially, I know you

11 can't audit Class III gaming, but you certainly

12 have an advisory position and you could explain

13 to folks why these regulations, why these

14 minimums are needed, and what they -- what they

15 do to serve and protect the assets of the

16 tribe. That's all.

17 MR. LITTLE: Now, you're right on,

18 and that's, you know, a very good point, you

19 know, I greatly appreciate that you stuck

20 around for a couple hours here to provide that

21 information, and Sarah, thanks for, you know,

22 raising that point, that these are minimum

23 standards and that the TGRAs can always add

24 additional requirements that, you know, they

25 feel is important to, you know, to their

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1 operations, so good point to remind and, you

2 know, these are all good points, you know, I'm

3 sure you'll provide us with some other --

4 MR. HENSLEY: That was the example I

5 was asked to come back with.

6 MR. LITTLE: Okay. Thank you very

7 much, sir. I appreciate it.

8 MS. MURRAY: I did just want to say

9 that I appreciate the position that having

10 reasons for why regulations are necessary is

11 very important and it helps the TGRAs be able

12 to better administer the regulations as well as

13 having their own regulations, so -- so for the

14 proposed rule, looking at the preambles,

15 discusses, to some degree, the reasons for the

16 regulations, but I'm certainly happy to discuss

17 some guidance documents, some potential

18 guidance documents with -- with -- when we get

19 back to the office about why we have the

20 regulations.

21 MR. HENSLEY: Do you have -- do you

22 have some advisories like that?

23 MS. MURRAY: I don't know that we

24 have any currently, but I'm -- but I'm

25 certainly happy to bring this comment back in

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1 and talk about creating something like that.

2 MR. HENSLEY: Those who work with

3 compliance have that difficulty a lot of times

4 with our audit teams. I'm an auditor.

5 MS. MURRAY: Right.

6 MR. HENSLEY: I'm not a gaming

7 regulator, and it helps to -- to get across to

8 folks why they need to do these things.

9 MS. MURRAY: No, I appreciate that.

10 Thank you.

11 MR. LITTLE: Great. Thank you. Is

12 there any other comments?

13 MS. MURRAY: Well, thank you so much

14 for coming and for sticking around for this

15 afternoon session. We appreciate it.

16 MR. LITTLE: All right. If there's

17 no other comments then I'm going to bring this

18 meeting to a close. I want to thank everybody

19 for attending. I want to especially thank our

20 staff, you do a great job. They're not

21 recognized enough. Without -- without them we

22 could never do our jobs, so on behalf of the

23 commission I just want to thank all the staff.

24 I wish you all safe travels and I want to thank

25 the United Nation again for, you know, for

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1 providing these facilities for our use and

2 we're really happy to be here. We love coming

3 here. So safe travels everyone. Thank you.

4 Have a great day.

5 (Proceedings concluded at 1:39 p.m.)

6

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1 STATE OF WISCONSIN )

 ) ss.

2 COUNTY OF MILWAUKEE )

3 I, ANNICK M. TRIMBLE, RPR, Notary Public

4 in and for the State of Wisconsin, do hereby

5 certify that the preceding deposition was

6 recorded by me and reduced to writing under my

7 personal direction.

8 I further certify that said deposition

9 was taken at ONEIDA CASINO, Green Bay,

10 Wisconsin, on the 7th day of June, 2012,

11 commencing at 9:05 a.m. and concluding at 1:39

12 p.m.

13 I further certify that I am not a

14 relative or employee or attorney or counsel of

15 any of the parties, nor a relative or employee

16 of such attorney or counsel, or financially

17 interested directly or indirectly in this

18 action.

19 In witness whereof, I have hereunto set

20 my hand at Milwaukee, Wisconsin, this

21 25th day of June, 2012.

22

 ______________________________________

23 ANNICK M. TRIMBLE, RPR - Notary Public

 in and for the State of Wisconsin

24

25 My commission expires October 6, 2013.

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20 43:22 44:2,6

60:10

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2010 4:14 42:19

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2012 1:15 17:19,23

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2013 24:23 25:3

78:25

2020 1:8

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27 56:22

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activities 55:1

activity 52:10

actual 23:11 27:5

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add 50:13 64:22

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added 19:17 20:3,6

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additional 31:10,19

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address 21:3

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adjourn 68:2

administer 75:12

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attempted 54:3

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attest 57:23

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47:17 53:10,23 55:2

ben 2:14 12:24

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utilized 64:11

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46:12,13,16 53:12

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variances 44:25

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vegas 74:7

verification 47:23

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verified 28:15 50:25

verify 23:4

verifying 47:25 48:1

48:8

versa 14:16

version 29:7

versus 53:18

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video 39:24

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wait 44:15 63:4

want 2:4 3:2 6:24,25

7:9 9:20 10:3,18

13:7 15:15,16,19,19

16:11,23 36:2 37:3

37:3,3,6,8,14,15

38:3,25 39:3 44:12

44:13 46:2 57:13

60:9,15,20 63:2,3

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63:22 64:21 65:8

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wanted 2:13 3:14,18

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wants 33:24

ward 2:21 10:15

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53:21 54:24 55:22

56:2,6,24 57:3,7,10

washington 34:13

way 6:1 36:20 57:22

58:3 65:8 70:4,18

ways 21:14 32:13

57:24 65:12,14

we've 4:9 5:5,16

7:21 8:19 9:25

13:13 15:25 24:6

28:21 32:1,19 34:18

35:14 36:10,22 37:9

41:23 48:12 50:1,22

63:25

website 9:2 17:20

67:25 68:15

week 34:11,12

welcome 2:5 3:14,14

3:18 13:8 14:24

34:8 56:6 57:10

went 5:6,7 6:19 29:7

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west 2:22 45:10

71:23

whereof 78:19

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78:10,20,23

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42:25 46:22

work 5:11,13,19 7:4

12:13 14:7 16:2

41:20 70:24 76:2

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42:5 59:13

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57:21 65:16

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yeah 53:17 56:23

57:3 66:23

year 34:25 36:17

37:20 45:8 52:6

54:18,22 58:18 60:3

62:5

years 4:4,10 15:4

25:3 36:23 57:16

74:6

yolanda 10:25

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