1 NATIONAL INDIAN GAMING COMMISSION

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4 PORTLAND REGION

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7 REGULATORY REVIEW CONSULTATION

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12 LITTLE CREEK RESORT

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14 July 19, 2012

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16 Shelton, Washington

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1 BE IT REMEMBERED that on Thursday, July 19,

2 2012, at Little Creek Resort, 91 West State Route 108,

3 Shelton, Washington, at 9:07 a.m., before BARBARA L.

4 BRACE, CCR, RPR, Certified Court Reporter, the following

5 proceedings were had, to wit:

6

7 <<<<<< >>>>>>

8

9 CHAIRWOMAN STEVENS: Good morning,

10 everyone. I'm glad to see everybody here today. We have

11 an agenda here. Everybody should have a packet. We're

12 going to follow along with the agenda today.

13 Before we get started, what I'd like to do is turn

14 this over, as is tradition out here, to the host tribe,

15 the Squaxin Island tribal community. Pete Kruger, over

16 here, is the secretary on council, and I will turn it

17 over to Pete for an opening.

18 MR. KRUGER: Thank you. My name is

19 Pete Kruger. I'm tribal council secretary here. It is

20 our honor to welcome everyone here in the NIGC. I hope

21 you have a good time, use your money in our casino, golf

22 course. We need the money.

23 It's a great pleasure to honor everybody here. I'm

24 proud and honored to be able to do this. If you haven't

25 golfed -- I'm not a golfer, but the golf course is

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1 beautiful. Go up and do your thing.

2 Thank you.

3 CHAIRWOMAN STEVENS: Thank you,

4 Mr. Kruger.

5 So with that, what we'd like to do next, following

6 along with the agenda, is to have everybody introduce

7 themselves. Also, if we have any tribal leaders here,

8 you're welcome to come sit at the table with us.

9 However, we understand if you're shy and you'd like to

10 stay there.

11 We'll start from here and we'll move the microphone

12 around. If you could please state your name, who you're

13 with, which tribe you're with.

14 MR. GIFFEN: Jack Giffen, Jr.,

15 Confederated Tribes of Grand Ronde Community of Oregon,

16 tribal council secretary.

17 MS. AUBERTIN KELLER: Deneen Aubertin

18 Keller, attorney for Grand Ronde Tribe.

19 MR. HARJU: Philip Harju. I'm the

20 vice chair of the Cowlitz Indian Tribe.

21 MR. LISTER: Nick Lister, Nisqually

22 TGA, information systems specialist.

23 MR. BOYCE: Mike Boyce, executive

24 director of Grand Ronde.

25 MR. DURHAM: David Durham, with

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1 Tulalip Tribes of Washington. I'm a tribal gaming

2 inspector.

3 MR. WOOLSEY: Tim Woolsey. I'm the

4 reservation attorney for the Colville Tribes.

5 MR. SHANNON: Lee Shannon. I'm the

6 attorney representing Metlakatla Indian Community.

7 MR. TONASKET: Mel Tonasket, gaming

8 commissioner with the Colville Confederated Tribes.

9 MS. BOX: Good morning. I'm Bertha

10 Box, from the Southern Ute Tribe, Ignacio, Colorado. I'm

11 the chairperson of the gaming commission.

12 MS. TAYLOR: Andrea Taylor, Southern

13 Ute Indian Tribe, vice chair, gaming commission.

14 MS. BRUNER: LaWana Bruner,

15 Stillaguamish Tribe, TGA director.

16 MS. CAPOENAN-BALLER: Good morning.

17 Pearl Capoenan-Baller, gaming commissioner for Quinault.

18 MR. WETZLER: Good morning. Sam

19 Wetzler, executive director for the Puyallup Tribal

20 Gaming Regulatory Offices.

21 MR. ARMSTRONG: James Armstrong,

22 Suquamish Tribe. I'm the executive director for the

23 Suquamish Tribal Gaming Commission.

24 MR. CONTRANO: Roger Contrano,

25 Suquamish Gaming Commission.

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1 MR. WHITENER: B.J. Whitener, director

2 of the Colville Tribal Gaming Commission.

3 MR. POLK: Good morning. My name is

4 Dixon Polk, Sr., from the Yakima Nation. I'm one of the

5 gaming commissioners there. My Indian name is Wup Stock

6 Tum.

7 MS. DEYETTE: Diane Deyette, with

8 Squaxin Island Gaming Commission.

9 MS. REPIN: Jennifer Repin, with the

10 Snoqualmie Gaming Commission, commissioner.

11 MR. HANKIN: Mike Hankin, compliance

12 officer of Red Wind Casino, Nisqually Tribe.

13 MR. GOFORTH: Bill Goforth, interim

14 director, Nisqually.

15 MR. McDANIEL: Jesse McDaniel,

16 Muckleshoot Indian Commission, executive director.

17 MS. ADOLPH: Good morning. I'm Patty

18 Adolph, compliance officer with the Colville Tribal

19 Gaming Commission.

20 MR. BILLINGSLEY: Ken Billingsley,

21 general manager of the Indian Head Casino for the

22 Confederated Tribes of Warm Springs.

23 MS. GOUDY SMITH: Dora Goudy Smith,

24 gaming commissioner, Yakima Nation.

25 MR. GRIFFITH: Rick Griffith, internal

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1 auditor with Squaxin Island Gaming Commission.

2 MR. STEVENSON: Craig Stevenson,

3 internal auditor, Squaxin Island Gaming Commission.

4 MR. WYNECOOP: Francis Wynecoop,

5 director of gaming for the Spokane Tribe.

6 CHAIRWOMAN STEVENS: Thank you. And I

7 appreciate again everybody being here. I'd like to have

8 our staff, starting this way, introduce themselves and

9 tell everybody who you are and what you do, and then we

10 will introduce the commissioners.

11 MR. WEST: Good morning. My name is

12 Rest West. I'm one of the senior auditors with the

13 National Indian Gaming Commission.

14 MR. PUROHIT: Good morning. I'm

15 Nimish Purohit. I'm the acting director of training and

16 technical assistance, as well as the gaming technology

17 liaison for the commission.

18 MR. HOENIG: Good morning. I'm

19 Michael Hoenig. I'm a senior attorney with the Office of

20 General Counsel.

21 MS. WARD: Good morning. I'm Jennifer

22 Ward. I'm an attorney with the Office of General

23 Counsel.

24 MS. MURRAY: Good morning. My name is

25 Sarah Murray. I'm a member of the Cheyenne River Sioux

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1 Tribe of South Dakota, and I am counselor to the

2 chairwoman.

3 MR. MYERS: Shiyo. Osda sunalei. My

4 name is Paxton Myers, member of the Eastern Band of

5 Cherokee Indians. I'm chief of staff of the National

6 Indian Gaming Commission.

7 CHAIRWOMAN STEVENS: Okay. With that,

8 I'd like to turn the mike over to our vice chairwoman,

9 Steffani Cochran, and our associate commissioner, Dan

10 Little.

11 MS. COCHRAN: Good morning. As the

12 chairwoman said, my name is Steffani Cochran. I'm the

13 vice chairwoman, and I'm a member of the Chickasaw

14 Nation.

15 I'm very pleased to be here this morning. And thank

16 you to Squaxin for such a beautiful facility and the

17 comfortable room last night. I look forward to our

18 meeting today.

19 MR. LITTLE: Good morning, everyone.

20 My name is Dan Little. I'm the associate commissioner

21 here with the NIGC. I've been on the commission since

22 April of 2010, and I've been working primarily on the

23 review of the Part 547 and Part 543 for the last year and

24 a half.

25 I'm very excited to be here this morning, and I look

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1 forward to hearing all your wonderful comments. Thank

2 you.

3 CHAIRWOMAN STEVENS: Thank you. One

4 last thing. I do want to recognize our regional

5 director, Mark Phillips, right over here. He's going to

6 be running the microphone. I'm sure you've all worked

7 with him out of the region. And also Steve Steiner,

8 who's the compliance officer who's been at the table back

9 there.

10 To my right, your left, is Barbara. She's our

11 transcriptionist. I just want to remind everybody that

12 these are transcribed, and we'll talk about that in a

13 moment.

14 My name is Tracie Stevens. I'm a member of the

15 Tulalip Tribes of Washington, and I am the chairwoman of

16 the National Indian Gaming Commission.

17 I appreciate everybody again attending today. This

18 is the fifth consultation on these particular rules that

19 are proposed in the Federal Register at this time. We'll

20 go into this a bit more as the morning progress.

21 I do want to talk about the meeting agenda. We do

22 try to break up the agenda so everyone has an

23 understanding or has -- can anticipate what we will be

24 talking about and in what order. So it's not an open

25 dialogue on any subject, but that specifically we'll be

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1 talking about certain subjects at certain times in case

2 your schedule, you know, requires that you are unable to

3 stay and you need to speak to a particular part.

4 But as it's noted on the bottom of the agenda, the

5 time frames may slow down or speed up, depending on how

6 the conversation goes this morning. So we'll be going

7 through in this order in terms of topics, although the

8 times, you know, allotted are estimates. It may go

9 slower or quicker.

10 Also, we -- just to make clear, that we're not

11 completely wedded to this. If again your schedule does

12 not permit that you're staying long enough for a

13 particular subject to come up, we do open the floor for

14 tribal comments pertaining to any of these parts that

15 we're discussing today.

16 We know that you all have a very busy schedule. If

17 you're a tribal leader, you have a number of other issues

18 besides gaming. If you're a tribal operator or

19 regulator, you actually have a full-time job somewhere

20 else that you are away from, so your schedule may not

21 permit that you stay for a particular topic.

22 We do open up the floor in every spot for comments

23 as we go. We sometimes have people read statements onto

24 the record about the whole parts that -- all the parts

25 that we're talking about, so we certainly welcome that.

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1 So with that, I do want to open it up for any

2 statements that need to be read into the record for those

3 who may have scheduling issues.

4 Okay. That will come up again, so if for any reason

5 your schedule requires that you have to depart, let us

6 know, and we'll certainly open up the floor for

7 statements.

8 We'll go ahead and get started. I should have

9 chosen my seat better so I can see where we're at. You

10 should have a packet of PowerPoint that we will go over

11 this morning. And I'll go ahead and start, and we will

12 go ahead and -- after I'm done with my parts here, we'll

13 turn it over to the staff to go into detail about the

14 proposed parts.

15 Before we begin, though, I do want to remind

16 everybody that this is -- we are in the official

17 rulemaking process for Part 543 and Part 547 with notice

18 of the proposed rules that have been published, and that

19 is the topic of today's discussion.

20 It is an official public meeting or consultation

21 specifically just for tribes. If there are

22 tribal-specific issues that do not pertain to these

23 particular proposed rules, we will be happy to talk to

24 you at the break or aside from this -- today's meeting or

25 afterwards.

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1 We know that most everybody has come here to talk

2 about these subjects, so we want to make way for the

3 consultation and the rulemaking process to continue

4 today. And if you have any particular concerns or issues

5 or requests of the agency, we can gladly talk to you

6 about that on a side discussion.

7 Okay. So consultation, it's between tribal

8 governments and the federal government. Only tribes and

9 their designees are allowed to attend and participate.

10 These particular consultations are not open to the

11 public, and they are certainly not open to the press.

12 More on consultation. In keeping with Executive

13 Order 13175, this commission is dedicated to discussing

14 policy changes before the changes are made and to talk

15 about the need for change.

16 In the past year and a half, from the time we

17 started with the Notice of Inquiry, we did just that,

18 asking tribes which regs we needed to look at, what were

19 the priority regulations that tribes wanted to review and

20 possibly change.

21 And then, as we've gone along, we were getting

22 feedback on particular regulations that informed

23 discussion drafts outside of the rulemaking process in an

24 informal process, which has now transformed into what is

25 now the proposed rule that you see in the Federal

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1 Register and the topic of today's discussion.

2 So that is all of our efforts in meeting this

3 requirement of the executive order to talk about the

4 need, if any, of policy changes before we actually start

5 making those changes.

6 And as has been our practice, the commission is

7 committed to a clear and transparent process. As I said,

8 these consultations are transcribed. They're posted on

9 the website. All comments are posted on the website so

10 that they can be read by all tribes. We have an open

11 forum here so that tribes can hear what other tribes'

12 questions are, what their issues are, and what possible

13 solutions together are.

14 We will review and consider every comment that we

15 receive, and we do in fact do that. We all three have

16 read every comment that has come in. And as one of the

17 staff said yesterday, they've sat through meetings, hours

18 and hours and hours of meetings with us, as we've talked

19 about those and drafting regulations based on input from

20 tribes. So we do consider them and do take them

21 seriously, and any proposed or final rule will include

22 the summary of those comments.

23 If there's -- you know, if there's anything,

24 Steffani or Dan, that you want to add to this, I was just

25 going to turn it over to Dan and to the staff.

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1 MR. LITTLE: Thank you, Chairwoman.

2 I'm just going to go over basically the consultation

3 agenda that we're going to talk about today. This is

4 Group 3 of the Notice of Inquiry that was published in

5 April of 2011. Basically that's Part 547, the minimum

6 technical standards for equipment used in the play of

7 Class II games, and then Part 543, the Minimum Internal

8 Control Standards for Class II gaming.

9 How we got there to -- how we got to where we are

10 today was, as I said, a long -- a long process. It

11 started with the Notice of Inquiry, and what we learned

12 from those consultations was that we needed to actually

13 reach out to the tribes and we needed to, you know,

14 develop a process for learning, you know, how the

15 regulations are affecting, you know, each and every one

16 of your facilities, so we formed a tribal advisory

17 committee.

18 And I want to make a special note to mention three

19 individuals from this part of the country that

20 participated in the Tribal Advisory Committee, or what we

21 call the TAC. That was Jeff Wheatley, from the

22 Suquamish; Michelle Stacona, from Warm Springs; and Leo

23 Culloo, from Port Gamble.

24 The TAC consisted of 15 members which of those --

25 those three were on there. When we developed the TAC, we

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1 tried to get a good cross-selection of the industry. We

2 got operators, regulators, auditors, and other industry

3 experts because we wanted to learn how each of these

4 different groups that all work together in the facilities

5 have unique responsibility and roles.

6 So we form the Tribal Advisory Committee, first met

7 in fall of 2011, and held four meetings. They were very

8 successful, although they were quite contentious at

9 times.

10 I would be lying to you if I told you it was easy.

11 It was a difficult process, but it was actually a very

12 valuable process, so much in the fact that the commission

13 and, you know, very importantly, our staff learned a lot

14 of the many challenges that you all face in dealing with

15 these regulations.

16 We understand that a lot of you are still relying on

17 the Part 542 regulation for your Class II gaming, and,

18 you know, that was created, you know, a decade ago and

19 technology has changed. There was a real need to

20 implement a new regulation and update the current

21 regulation that's on hold right now that the previous

22 commission had adopted.

23 So we established the TAC, had four very intense

24 meetings, but at the end of the four meetings, the TAC

25 provided the commission with some recommendations which

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1 we utilized to put together draft -- discussion drafts

2 for the Part 547 and 543.

3 Both of those were put out in website in the middle

4 of March, March 16, with a 30-day comment period. We

5 received over a hundred comments, and some of those

6 actually requested an extension, so we did extend it to

7 the end of May. We received over a hundred comments.

8 And many of you may know, but prior to coming on the

9 commission, I worked for the Mashantucket Pequot and

10 Foxwoods in Washington and was very involved with a lot

11 of the advocacy -- Indian gaming advocacy issues coming

12 up before the tribe and the industry. And we would

13 participate, you know, as much as you all do.

14 NIGA would send out -- the National Indian Gaming

15 Association, you know, would send out their blast faxes,

16 and we'd participate, and we'd take their form letters

17 and mail it in with our names.

18 We expected -- I expected this during this process,

19 you know, and I was actually wrong. We got -- like I

20 said, we got over a hundred of comments. But they

21 weren't form letters. These were like very unique, well

22 thought out. A lot of time, a lot of effort, and a lot

23 of good information was provided in those -- in those

24 comments.

25 And I'll tell you just, you know -- and I know I

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1 speak for the other commissioners. We really greatly

2 appreciate that. I mean, form letters are great, and

3 it's great to hear tribes are, you know, behind an issue.

4 But when we hear the specific, unique, individual

5 challenges and problems that you all are facing and how

6 we can improve the regulations, it's very, very helpful.

7 So like I said, we got a hundred comments. End of

8 May we began working on a Notice of Proposed Rule which

9 we ended up -- April. I'm sorry. End of April. Okay.

10 It was end of April.

11 So we did end up working on the Notice of Proposed

12 Rule that we did publish on June 1, and that's what we

13 have -- we're looking at right now. Now, the -- most of

14 the differences that you'll find from the discussion

15 draft to the Notice of Proposed Rule actually came from

16 the comments that you all provided to us.

17 So we -- the changes that you'll see from those two

18 documents are basically based upon what we heard from

19 you, so that's why your comments are so important and

20 they're so helpful.

21 One thing I want to say that -- and if you haven't

22 done so, I would actually urge you to do so. Read the

23 preambles to both the Notice of Proposed Rules. As you

24 go through there, you'll see the comments that we

25 received, and you'll -- it gives you an understanding of

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1 our thought process and what we're thinking. We made a

2 number of -- we put a number of questions in there and

3 some areas that we still needed a little more information

4 in.

5 So as you take the information and you go back, and

6 if you decide to put together some comments, read the

7 preamble, and that will help maybe form -- help you

8 formulate some of your responses and your comments to us.

9 We published the Notice of Proposed Rule on

10 June 1st, with a 60-day comment period that was scheduled

11 to conclude on July 31. We have received a number of

12 comments so far, and actually all of them requested some

13 additional time.

14 So without waiting until the July 31 deadline, we

15 actually extended that to August 15. So the deadline for

16 comments is August 15. We're hoping that you'll be able

17 to take that additional time, read the regulations and

18 then -- and send those in. Like the chairwoman said, we

19 will read every single one of your comments and we'll

20 read the transcripts.

21 I have attended all the consultations. The other

22 commissioners, we've kind of divided it up because of

23 other, you know, requirements around the office. But all

24 the commissioners and the staff do read all the

25 transcripts, we do hear everything that you have to say,

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1 and are really interested in getting more feedback in how

2 these regulations affect your facilities.

3 So, like I said, 543 and 547, those are the topics

4 we're going to discuss today. The comment periods, we

5 went over. I'm going to actually turn it over to Michael

6 Hoenig now, who's going to walk us through the PowerPoint

7 presentation on Part 547, actually a really good

8 discussion on the specific changes.

9 If you could follow along and then -- like we said,

10 if you have a question that you want to raise, you don't

11 have to wait until the end. You can grab a mike. Mark

12 is over here, and he'll hand the microphone to you. You

13 can make your comment at that particular time if it's

14 something you want to talk about. Or if you want to wait

15 until Mike concludes with the PowerPoint presentation,

16 and then you can, you know, make your comment.

17 Okay. So I'll turn it over to Mike. Thank you.

18 MR. HOENIG: Thank you, Commissioner.

19 So I'm going to be going over Part 547. And Nimish

20 Purohit here is going to help me out on some of the more

21 technical aspects of the explanations. So as we go

22 through, I might be handing the microphone off to him

23 from time to time.

24 But just to get started, this PowerPoint is going to

25 talk about the changes to the existing regulations, so

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1 there's going to be some sections where we just skip

2 through it because there may not be any major changes.

3 So just starting most generally, the first five

4 sections of the existing regulation were rearranged for

5 more logical flow. For example, the definitions section

6 was moved up to the front. I think, in the existing

7 regulation, it's three or four sections in. So we just

8 figured it's better to have all the terms right up front

9 so everybody knows what they mean as they go through the

10 rest of it.

11 We put the implementation section at 547.3. 547.4

12 is all the rules of general application, and we'll talk

13 about those again a little further in just a moment. And

14 kind of the meat of the regulation, with all the

15 compliance requirements, are at 547.5. That's where all

16 that begins.

17 And then within each section, some of the

18 information was reorganized, so we may have taken

19 something out of one section and put it into another one

20 if it seemed to make more sense.

21 So in the definitions section, the first definition

22 to talk about is the definition for EPROM, and I'm going

23 to let Nimish talk about this one.

24 MR. PUROHIT: Thanks, Mike.

25 Everyone that's been in gaming for a while, you've

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1 probably heard of EPROM. It's erasable programmable

2 read-only media. And the reason why it was designed --

3 and there were some more regulations that were put in

4 here, and technical standards -- is for those legacy

5 products that still do have EPROM.

6 The sections related to the EPROMs gives the Tribal

7 Gaming Regulatory Authority an option to actually have

8 the products tested. And subsequently, when it does come

9 in, any of the regulations that you have, and the

10 technical standards, are there to make sure that the

11 EPROMs are tested and subsequently approvable under the

12 tech standards.

13 MR. HOENIG: Thank you, Nimish.

14 Another definition that was added was the definition

15 of "patron," and that was added after the Tribal Advisory

16 Committee -- based on their recommendations. We also

17 added definitions for "advertised top prize," "audit

18 mode," "enroll," and "unenroll," all terms that are used

19 throughout the regulations.

20 One definition that was inadvertently, I think,

21 dropped from the discussion draft and was put back in

22 here was the definition of the "electrostatic discharge."

23 We also added a definition for "electromagnetic

24 interference."

25 Another one I'm going to let Nimish talk about a

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1 little more is, in the discussion draft, we've added a

2 definition for "proprietary Class II system." Based on

3 the comments we got, folks found that -- the comments

4 found that a little confusing and weren't sure exactly

5 what we were trying to do with that, so it's been taken

6 out in the Notice of Proposed Rulemaking.

7 I'm going to let Nimish talk a little bit about what

8 the idea was behind putting it in and again then taking

9 it back out, based on all the comments.

10 MR. PUROHIT: So initially, back when

11 the technical standards were first adopted and published

12 in the Federal Register in 2008, from then on, up until

13 recently, we get several questions for technical

14 assistance and clarification for tech standards that

15 always talk about the fact that, if you have a Class II

16 system that's connected to a common back-of-the-house

17 system, does that back-of-the-house system also need to

18 be tested to these technical standards.

19 And the answer for both back then, and even

20 currently, is that no, it doesn't have to, unless the

21 Tribal Gaming Regulatory Authority requires that.

22 But because these are minimal standards, and the

23 purpose for making sure that that's distinguished in

24 here, is, we had tried adding the word "proprietary" that

25 says, if a particular Class II system by manufacturer A

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1 has its own unique tracking system, ticketing system, et

2 cetera, that's self-contained in the Class II system,

3 only that product has to be tested to the requirements of

4 547 and none of the other interoperability with that

5 common back-of-the-house system.

6 So that's what we tried to take in the approach to

7 the discussion draft. And we got several comments and

8 feedbacks saying that, if you use the word "proprietary,"

9 it does have certain other legal connotations associated

10 with it. And that's the reason we decided to remove

11 that, and here we are with that.

12 Even going forward, and the approach that we've

13 taken with the draft right now, is that in the preamble

14 we actually added clarification on why the proprietary

15 term was removed and what is the general applicability of

16 the standards, as far as the back-of-the-house systems

17 are concerned, et cetera.

18 MR. HOENIG: Thank you, Nimish.

19 And to go with that, we had also put the word

20 "proprietary" into some of the other definitions,

21 including cashless systems and voucher systems. And so

22 since we were taking out the definition of proprietary

23 Class II system component, we took the word "proprietary"

24 out of those other definitions as well.

25 The definition for "agent" does not include computer

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1 systems. This was a comment that we had received, asking

2 us to include that. Based on the review for technical

3 standards, it was not included.

4 547.3, who is responsible for implementing these

5 standards, this was moved from 547.5. This carries over

6 a lot of the language that's still in the -- that was in

7 the existing regulation. The important thing is, these

8 are minimum standards. The Tribal Gaming Regulatory

9 Authority can enact stricter standards if they want to.

10 This is not intended to be any kind of limitation on

11 technology. Just as the other technical standards, it is

12 not intended to limit the kind of technological advances

13 that are constantly developing in Class II gaming.

14 Only the applicable standards applies. So if there

15 is a standard here, and your particular system just

16 doesn't use this kind of component and there's a standard

17 in there for that kind of component, then it's not

18 applicable, so you don't have to worry about that.

19 And finally, it does nothing to change the state

20 jurisdiction over Class II gaming. Nothing in here

21 affects the limitations or lack of state jurisdiction for

22 Class II gaming.

23 MR. HARJU: Can I ask a question?

24 MR. HOENIG: Sure.

25 MR. HARJU: Again, I'm Phil Harju,

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1 from the Cowlitz Tribe.

2 So did you receive any comments from state

3 regulators on that, your point that there will be no

4 state regulation of Class II?

5 MR. HOENIG: We got one comment from a

6 state, and it wasn't the regulator. It was -- if you go

7 on our website, you'll see it was a comment from the

8 Alabama attorney general. But it didn't go to state

9 jurisdiction directly, and we addressed the comment in

10 the preamble. It was more about how these might affect

11 classification. So we addressed his comments, thanked

12 him for his comment, but there's no change in state

13 jurisdiction.

14 MR. HARJU: I guess my follow-up

15 question is then, on behalf of the commission, it would

16 be clear that there is no intent to allow any state

17 regulation of Class II gaming?

18 MR. HOENIG: No. That's what this is

19 intended.

20 MR. HARJU: Thank you.

21 MR. HOENIG: Okay. Great.

22 Let's see. So 547.4, this is, what are the rules of

23 general application for this part. We moved this from

24 547.5, I believe.

25 The biggest change here is the removal of the

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1 minimum odds requirement. The existing regulation has

2 fairness standards which requires the odds for the top

3 prize -- winning the top prize to be less than 1 in

4 100 million. That's been removed, and we'll talk about

5 it a little bit further in this presentation.

6 Instead, there's been a new notification

7 requirement. So if the odds are greater than 1 in

8 100 million, someplace on the machine or the display of

9 the system has to notify the patron of that. We'll talk

10 about that just a little further down the presentation

11 here.

12 The test lab must calculate and/or verify the

13 mathematical expectations and report to the TGRA. This

14 is the test lab figuring out the mathematical

15 expectations and then giving a report to the TGRA.

16 In addition to this, if the TGRA wants to do their

17 own test, they can ask the manufacturer to submit the

18 mathematical expectations directly to the TGRA, so they

19 can verify, if the TGRA desires, verify what the test lab

20 is reporting.

21 As with the existing regulation, before any gaming

22 equipment or software can be used or put on the gaming

23 floor, it has to be reviewed and approved by the Tribal

24 Gaming Regulatory Authority. All the equipment must

25 perform according to the design and operating

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1 specifications.

2 Section 547.5, like I said earlier, this is kind of

3 where you get into the meat of the regulation. This is

4 all the requirements that -- the standards that are set

5 out. This is the section that we definitely got the most

6 comments on from the discussion draft because this is the

7 section that has the grandfathering provision.

8 The idea of the grandfathering provision is, when

9 the technical standards were first implemented in 2008,

10 the commission wanted to give a certain amount of time

11 for tribes to submit all their existing games for

12 testing. And if they were certified to a lower standard

13 than the new regulations, they could continue to be used

14 for five years.

15 That five years is up next year, I believe October

16 of next year, or November. And at that point, all the

17 machines that were grandfathered, all the Class II gaming

18 systems that were grandfathered, either have to be

19 brought into full compliance of the regulations, the

20 technical standards, or they have to be removed from the

21 floor.

22 The discussion draft had made some changes to that.

23 It changed it in the sense that it made everything more

24 up to date, since the initial certification period had

25 passed and the five years was about to run.

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1 Lots of comments asking that the grandfather

2 provision be just taken out, that any game that's on the

3 floor can be continued to be used until it's -- basically

4 until the market drives them out or until they're broken

5 and need to be replaced.

6 So as part of this discussion -- excuse me. As part

7 of the Notice of Proposed Rulemaking, the commission kind

8 of reset everything and put it back to where it is in the

9 existing reg and asked for a lot more information.

10 So as Commissioner Little was saying, go through and

11 look at the preamble so you can see what the questions

12 are and you can see what kind of information the

13 commission is looking to receive so they can decide how

14 they want to proceed with the grandfathering.

15 Basically, the questions are kind of broken out into

16 three categories. First is, how many Class II gaming

17 systems will be affected if the current date of

18 November 10, 2013 -- so that's the date when all the

19 grandfathered systems have to be brought into compliance

20 or removed from the gaming floor -- if that date is

21 extended, so if it's extended by, say, another three

22 years or another five years to give operations more time

23 to get the Class II gaming systems into compliance, what

24 effect will that have or how many Class II gaming systems

25 will be affected. Also, what will be the regulatory

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1 impacts for extending the period three years past

2 November 10, 2013, or just removing the time period

3 altogether.

4 In another category, for any Class II gaming system

5 to be grandfathered, it had to be submitted for testing

6 within 120 days of the regulation going into effect. So

7 if anybody, any facility or any manufacturer, had games

8 and they missed that 120 days, they can't be

9 grandfathered. The window is closed.

10 So another question is, how many Class II gaming

11 systems could be potentially submitted to the labs if

12 that 120-day period is modified. So if it's opened up or

13 it's done away with, how many noncertified games are out

14 there that could be used as a grandfathered game, and

15 what would be the regulatory -- what would be the

16 regulatory and other impacts of allowing a limited

17 submission period for those symptoms that did not meet

18 the original deadline, so if we just -- if the commission

19 just set up another 120 days, for example.

20 And then lastly, the idea of bringing games into

21 compliance without a specific deadline, but anytime a

22 game or a system was modified, that modification had to

23 bring the game into compliance or that modification had

24 to be in compliance, so it would be working towards fully

25 compliant systems over a period of time.

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1 Along the same lines, but a little different, is,

2 anytime the system or the individual game had to be

3 repaired or modified -- so if something broke and you had

4 to replace a screen or a game panel -- and that had to be

5 brought into full compliance with the technical

6 standards, what would the effect be then.

7 So that's the information that the commission is

8 looking for on the grandfathering provision, to bring --

9 so that they can make the most informed decision.

10 Also in 547.5, the proposed rule amends the test lab

11 certification requirements from the discussion draft

12 based on the public comments. So test labs must note

13 compliance with standards set forth by the TGRA. This

14 gets rid a -- of or does away with the requirement that

15 was in the discussion draft.

16 And I'm not sure about the existing regulations. I

17 kind of get them all mixed up in my head sometimes. But

18 the TGRA had to test the games to any other applicable

19 federal laws or regulations. The comments we received

20 were, that's way too much. We can't ask the test lab to

21 go out and research every single federal law or

22 regulation that may pop up.

23 So instead, the discussion draft requires the test

24 labs to test to these standards and any other

25 requirements that the TGRA may require. So, you know, we

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1 figured that the regulatory authorities and the

2 operations are going to know which laws are out there

3 that affect the play of the games, so they'll know what

4 to include for the testing labs. And it's not our job to

5 enforce every single federal law or regulation out there,

6 so that was taken out.

7 And then there's no substantive changes to 547.6, so

8 we're going to skip that and go to 547.7. And that is,

9 what are the minimum technical hardware standards to

10 Class II gaming systems.

11 So the player interface must be labeled with the

12 serial number and date of manufacture. The discussion

13 draft had the word "display," that it had to display the

14 serial number.

15 We got a lot of comments, saying that was confusing

16 because every stand-alone device or every device has its

17 own display, the screen. And people were saying, well,

18 does it have to be on the screen or can it be anywhere on

19 the box, so we changed it just to say that it has to be

20 labeled.

21 The section also removed any references to the

22 Underwriters Laboratory. Instead, now the test lab just

23 has to certify that the game has been certified to

24 withstand spills, those kind of things. But each

25 individual test lab doesn't have to do that, and there's

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1 no reference to Underwriters Laboratory now.

2 547.8 is the technical standards for software. This

3 removes any references to entertaining displays. The

4 existing regulation had language in there about the

5 last-game recall, for example, had to show the

6 entertaining display.

7 And because of -- all the comments we received

8 rightly pointed out that the entertaining display has

9 nothing to do with the game of Bingo, it's just that.

10 It's an entertaining display. The Bingo game is on the

11 card. There's nothing in here that requires any longer

12 the last-game recall show the entertaining display. In

13 fact, I think we removed all references to "entertaining

14 display" throughout the regulation.

15 This also allows for changes in the rules, just as

16 the existing regulation does, but that -- those changes

17 in the rules can't be automatic, and they can't be

18 undisclosed. So the patron has to know anytime the rules

19 change.

20 Other than that, that's it for .8. And there's no

21 substantive changes to .9, .10 or .11, so we'll move on

22 to 547.12.

23 547.12 is the technical standards for downloading on

24 a Class II gaming system. This removes the requirement

25 in the TGRA, the Tribal Gaming Regulatory Authority,

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1 authorize all the downloads.

2 It hasn't been taken out of the general NIGS

3 regulations altogether, but we put -- we got a lot of

4 comments, correctly pointing out that this is a control

5 standard. This doesn't belong in the technical

6 standards. So Jennifer, when she talks about the MICS,

7 will talk about this a little bit more, but basically

8 this requires the move over to Part 543.

9 This also requires the Class II gaming system be

10 capable of providing download information, and the

11 downloaded software must be capable of being verified by

12 the Class II gaming system. That's the changes to the

13 download requirements.

14 547.14 -- there's no substantive changes to 547.13,

15 so .14 is, what are the technical standards for

16 electronic random number generators. There's a new

17 requirement that we'll let Nimish talk about in here that

18 requires the use of an unbiased algorithm with any bias

19 reported to the TGRA. We'll let Nimish explain that.

20 MR. PUROHIT: I'll make sure I go a

21 little slower, because at the last consultation the

22 transcriber yelled at me for going too fast in this

23 section.

24 So when you look at the 547.14 for the random number

25 generator technical standards, they are quite technical.

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1 And if you look at them in their entirety, they are meant

2 for guidelines, just like with the rest of the technical

3 standards, for independent test labs to verify that all

4 of the requirements -- applicable requirements of 547 are

5 met.

6 And there's a section in here as well for random

7 number generators that deals with the bias in the actual

8 algorithm itself. And when you look at it in context,

9 it's talking about the mapping and the scaling

10 requirements and whether or not a bias exists.

11 So currently there is a technical standard

12 specifically that states that any biases of 1 in

13 100 million must be verified and then approved

14 appropriately.

15 Back in 2008, when the technical standards were

16 first introduced, there was a subsequent bulletin that

17 went out, Bulletin 2008-4, that talked about the fact

18 that one in a hundred million is not necessary applicable

19 to Bingo ball draws.

20 So the bias measurement itself was revised to

21 roughly 1 in 57 million, to make sure that it was

22 applicable to Bingo, and that's what was actually

23 presented to the Tribal Advisory Committee when they were

24 reviewing this.

25 And one of the recommendations that was made and

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1 that was subsequently adopted and passed on by the Tribal

2 Advisory Committee was that the actual bias itself,

3 instead of putting any numerical quantity in there, there

4 should just be a generic catchall that says, any bias in

5 the scaling algorithm of the random number generator must

6 be reported to the Tribal Gaming Regulatory Authority so

7 that the TGRA can make any decision on whether that bias

8 is too much or too little.

9 We got several comments in the public comment period

10 that said that, you know, that's not necessarily a

11 testable standard. It's too vague. And what we're

12 requesting in return is, please let us know why this is

13 not testable or why the particular requirement is too

14 vague, in any comment that you send in to us. That's

15 kind of the situation with this particular standard

16 itself.

17 MR. HOENIG: Thank you.

18 So in addition to the changes in the algorithm,

19 there are also now some mandatory testing requirements.

20 This was based on discussions with the Tribal Advisory

21 Committee, suggesting that these four tests -- I'm

22 sorry -- three tests be mandatory for all random number

23 generators.

24 That's the Chi-square test, the Runs test, and the

25 Serial Correlation test. There are still other tests

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1 that are named in the regulation, and those are found at

2 the discretion of the Tribal Gaming Regulatory Authority.

3 There's no changes to 547.15. So 547.16 is, what

4 are the minimum standards for game artwork, glass, and

5 rules. Earlier I talked about the fact that, in the

6 fairness standards, we removed the minimum odds

7 requirements, so there's no longer a requirement that the

8 odds be less than 1 in 100 million.

9 However, if they do exceed that -- those odds, then

10 there has to be a notification put in -- the patron

11 basically has to be notified that the game they're

12 playing has odds of winning the top prize of greater than

13 1 in 100 million. This is the language in the

14 disclaimer.

15 In the discussion draft, it had language saying that

16 this has to be continuous -- continuously displayed.

17 That language has been taken out. It doesn't have to be

18 always up there, you know, when the game is being played.

19 It can be put on the rules screen or on the odds, how the

20 game is played. There's no longer any continual display.

21 And lastly, 547.17, this is, how do -- how does the

22 TGRA apply to implement an alternate standard to those

23 required by this part. This, in the existing regs, is

24 called the "variance section." We've changed that in

25 both this section and in the Minimum Internal Control

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1 Standards because, in the Minimum Internal Control

2 Standards, the term "variance" is used to mean a couple

3 different things, or at least it was.

4 And so to make sure that it was clear what kind of

5 variance we were talking about, we just took this when

6 you're applying -- when you're trying -- when TGRA wants

7 to implement a different standard than that in these

8 regs, it's called an "alternate standard" now.

9 So the regulatory authority must submit the

10 alternate standard within 30 days of its approval. The

11 chair then has 60 days to approve or object. And based

12 on discussions with some of the field staff that go out

13 and look to see if these alternate standards are

14 reasonable, they said, sometimes 60 days is more than

15 enough time. Other times it may be a little more

16 complex, and so 60 days might not be enough. So, if

17 needed, the chair may extend the review period another 60

18 days.

19 The alternate standard can't be implemented unless

20 approved by the TGRA or the NIGC chair. Once the TGRA

21 approves the alternate standard, it can go into effect.

22 Then it gets submitted to the commission -- to the

23 chairwoman for review.

24 And then the appeal of any objections to an

25 alternate standard has been taken out of this section and

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1 put into our general appeals section. One of the

2 regulatory changes that the commission has made is to

3 take all the different appeals parts that were in various

4 parts scattered throughout the regulation and consolidate

5 them all into one, so you just have one appeals process

6 for everything. It seems much simpler than trying to

7 figure out who do you appeal to, so it's all been

8 consolidated.

9 I believe that is it for the technical standards.

10 MR. LITTLE: Okay. Thank you, Mike.

11 I'll open the floor up right now to any questions or

12 comments anybody has. Anyone?

13 There's a lot of stuff in here. I know we're sort

14 of in the middle of the comment period, so many of you

15 may have not had a chance to fully review this.

16 In the back of the room we have a taker.

17 MS. GREEN: Good morning. My question

18 actually --

19 MR. LITTLE: Can you state your name

20 and organization?

21 MS. GREEN: Thank you. Nancy Green,

22 Green Law Firm. I represent the Chickasaw Nation in

23 Oklahoma.

24 My question is, at this point have you received

25 enough information in regard to your questions? Have you

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1 received responses that give you any indication how you

2 may consider changing the grandfathering provisions?

3 Have you -- well, and I say that because I note that

4 there are changes that you've proposed in different

5 parts, and so I'm just wanting to know if you have any

6 feedback, so to speak, in regard to proposed or possible

7 changes to the grandfathered provisions?

8 MR. LITTLE: Obviously, the feedback

9 we've got -- we've done four previous consultations.

10 We've heard that there were some issues with that, that

11 we were reviewing.

12 As far as written comments, like I said earlier, the

13 only written comments that we've gotten to date are folks

14 requesting an extension of time. So, you know, just like

15 with other regulations and just like with the discussion

16 draft, we're going to wait until the comment period

17 closes and we've had a chance to fully review all the

18 comments, all the transcripts, and everything that has

19 been presented to us before we make a decision.

20 MS. GREEN: In regard to the extension

21 of time, I understand now it is --

22 MR. LITTLE: August 15.

23 MS. GREEN: August 15. And is that a

24 time period sufficient for the rules -- whatever changes

25 to be implemented during this NIGC term?

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1 MR. LITTLE: Yes, we believe so.

2 MS. GREEN: That's all I have.

3 MR. LITTLE: Thank you, Nancy.

4 Okay. Is there any other folks that want to make a

5 comment?

6 CHAIRWOMAN STEVENS: I asked this

7 during the panel yesterday, and we have a number of

8 tribes that are represented here. Could I get a show of

9 hands of the number of tribes that have Class II

10 machines?

11 Okay. I'm going to do a count for the record, more

12 hands are popping up. So it's about 16. There may be

13 duplicate tribes here that are represented.

14 I'm wondering -- my first question then is, how many

15 of these are on mixed floors, m-i-x-e-d, so your twos are

16 mixed in with your threes?

17 Okay. There's about -- it looked like about 13. I

18 also want to know which tribes have a stand-alone Bingo

19 or Class II facility? Muckleshoot -- so four. In

20 addition, you may also have stand-alone Class II

21 facilities, but also have a mixed floor, m-i-x-e-d.

22 We'll talk about the MICS in a moment.

23 I'm just trying to gauge sort of what the effect is

24 in this particular region, but I also realize there are

25 some other folks here that are from other regions besides

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1 the Northwest.

2 Now, we would certainly ask that -- I know many of

3 the people here who are attending today are regulators

4 and probably just wanting to get information from us

5 today and may not necessarily have comments to submit to

6 the record, and you all probably have to go back to your

7 tribal councils and make sure, you know, what your

8 position is after you've evaluated this regulation and

9 its potential effect on your facilities.

10 But please do provide written comment, as the

11 associate commissioner said. We've received very

12 facility- and tribal-specific comments on the discussion

13 draft, which is incredibly helpful because it did inform

14 our -- the proposed draft that is out today.

15 So please do evaluate that, given the number of

16 hands that I saw come up, and how this particular

17 regulation, Part 547 -- how it reads, how it would affect

18 you.

19 If there's good things, too, because we do like to

20 have some affirmation that we got it right, and part of

21 that is the contribution that tribes have made to the

22 proposed rules.

23 So we want to -- you know, if it does work, please

24 tell us. If there's improvements that need to be made or

25 how this might affect your tribe, please do submit that

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1 in writing.

2 MR. LITTLE: Okay. Any other

3 comments?

4 I guess we can move on to the Part 543. I would

5 say, if there's -- like the chairwoman said earlier, if

6 there are any folks that need to make a statement for the

7 record for their tribe, you can do so now.

8 We've got a scheduled break at 10:30. We're

9 thinking maybe we'll get through the PowerPoint before

10 that or -- after we finish the PowerPoint presentation,

11 we'll take the scheduled break and come back and do the

12 Q and A.

13 I'll turn it over to Jennifer Ward to go through the

14 Part 543 presentation.

15 MS. WARD: Good morning. I'm Jennifer

16 Ward.

17 We're talking today about Part 543, the Minimum

18 Internal Control Standards for Class II gaming. This

19 part addresses only Class II games and their associated

20 functions. It's not on the slide, but it's important to

21 note again that the comment period has been extended, and

22 that closes on August 15.

23 This proposed rule, it's based on the discussion

24 draft, which was a new document, and we took ideas and

25 language from many sources, and those included the

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1 current MICS, the TAC recommendation, the TGWG guidance,

2 and the 2010 proposed MICS.

3 There are a few changes from the discussion draft

4 that we made generally here throughout this proposed

5 rule. One of those is that we reviewed the use of

6 "agent," "person," and "personnel" throughout, and we

7 made changes to make sure that when we're using the term

8 "agent," we actually mean agent and not some other

9 person, like perhaps emergency personnel that needs to

10 get into the facility.

11 We also inserted "as needed" language in each of the

12 supervision provision, and this excepts the IT section.

13 We've done that to promote consistency in the proposed

14 rule. We've also added supervision provisions for the

15 patron deposit account, lines of credit, and surveillance

16 sections.

17 We've amended a few of the definitions here from the

18 discussion draft. One of those is that the drop proceeds

19 definition has been amended to include financial

20 instrument storage component proceeds.

21 We realized that the original definition in the

22 discussion draft only included drop boxes. We wanted to

23 make sure that we were including Class II games systems

24 as well.

25 The "drop" definition has been deleted as

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1 unnecessary because the process of collecting the boxes

2 and the components is described in the drop and count

3 section itself.

4 Unchanged from the discussion draft is the

5 definition of "gaming promotion." And that's altered

6 from the current MICS to include only those promotions

7 that require game play to participate.

8 So, for example -- we'll talk about this more

9 later -- but a tumbler drawing that anyone can slip a

10 card into. That would not be considered a gaming

11 promotion under this part.

12 We've also added the definition of "sufficient

13 clarity." And this is the same as in the discussion

14 draft, but it's been amended from the 2010 proposal.

15 This definition continues the 20 frames-per-second

16 minimum, but also adds, it must be a resolution

17 sufficient to clearly identify the activity being

18 recorded.

19 There was one comment that suggested the 20 frames

20 per second may limit technology. And the commission

21 requests comment on whether the 20 frames per second or

22 equivalent language, if that was added, would that

23 resolve the concern. The commission also invites

24 comments on how the 20 frames per second may limit

25 technology. We weren't clear on that in the first place.

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1 Section 543.3, how tribes comply with this part.

2 These are minimum standards, and a Tribal Gaming

3 Regulatory Authority may establish additional controls

4 that do not conflict with this part.

5 The regulations provide a framework that recognize

6 the significant role of TGRAs. Throughout this document,

7 the TGRAs are required to establish thresholds for

8 investigating variances and implement procedures for

9 various standards.

10 There are different compliance deadlines for

11 established facilities and new facilities. Existing

12 facilities have 12 months to come into compliance, and

13 the new facilities must comply upon opening.

14 Then Section 543.4, does this apply to small and

15 charitable operations. There was a question here as to

16 whether the exceptions for small and charitable gaming

17 are redundant to each other.

18 Historically the charitable gaming exception came

19 first and established a $3 million threshold and sets

20 forth additional criteria for charitable. Later, the

21 small gaming exception came in, and it also has a

22 $3 million threshold, but doesn't have the additional

23 criteria.

24 We're wondering if we can streamline the regulation

25 by deleting the charitable exception because it's already

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1 covered. Those charitable gaming operations are already

2 covered under the $3 million small gaming threshold.

3 We've received some comments that said it may

4 mislead people into thinking there's no longer a

5 charitable extension and that, if it's not broke, don't

6 fix it, but we requested additional comments on that.

7 Section 543.5, how tribes apply to use an alternate

8 standard. This is just what Michael was talking about

9 earlier. In this MICS part, we discuss variances as

10 anything that differs from the expected result. So if

11 you've got a win percentage that's coming in that's not

12 what you're expecting it to be, that's a variance that

13 may or may not need to be investigated.

14 We changed the language here. This is a new term.

15 It's an alternate standard. So if the tribe has a

16 different standard other than what the MICS require

17 that's still as stringent, they can apply to the

18 commission to have that used instead.

19 And the TGRA may approve the alternate minimum

20 standard. They submit it to the NIGC chair for approval,

21 and the NIGS chair has 60 days. And we've heard from the

22 field that sometimes 60 days is more than enough time and

23 other times it's not nearly enough, so this provision

24 also allows the chair an additional 60 days if that's

25 necessary. In the meantime, before the tribe -- before

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1 the NIGS chair approves the alternate standard, the tribe

2 can go ahead and use that standard, so long as it's been

3 approved by the TGRA.

4 Section 543.8, MICS for Bingo. This underwent

5 significant revision from the discussion draft, based on

6 public comments. We heard from many that Bingo is Bingo,

7 and you don't need to distinguish between manual Bingo

8 and gaming machines, and the commission agrees. And as a

9 result, the Class II gaming system Bingo and manual Bingo

10 have been combined into one section here, based on the

11 public comments, and that's 543.8.

12 543.7 has now been reserved. This section is less

13 procedural than the existing MICS, but it requires the

14 TGRA and/or the operation to establish controls that meet

15 detailed criteria. For an example of this, you can take

16 a look at 543.8(b)(1) that discusses Bingo card

17 inventory.

18 This also requires verification of prizes over

19 $1200. And as another result of public comment, we

20 corrected an earlier oversight that now allows gaming

21 systems to serve as the sole verifier and validator for

22 payouts less than $1200 and as one of the validators and

23 verifiers for payouts of more than $1200.

24 Section 543.9, the MICS for pull-tabs. Pull-tabs

25 continue to require a $600 or more prize verification.

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1 And we've also added the ability that the kiosks may

2 be capable of redeeming and reconciling pull-tabs. We

3 received a comment that said it may limit technology if

4 we require machines to deface the pull-tabs. Currently

5 defacing is required by anyone processing pull-tabs,

6 doing the redeeming and reconciling of them.

7 And because machines may not be able to do that,

8 this part has been amended to allow kiosks to do the

9 redeeming and reconciling of the pull-tabs, so long as

10 those pull-tabs are then secured and destroyed in

11 accordance with TGRA policy after being removed from the

12 machine.

13 We are going through this fairly quickly. I just

14 wanted to issue another reminder. If you have a comment

15 or a question as I'm going through, please feel free to

16 interrupt me. We're here for you and your comments and

17 your questions.

18 Section 543.10, the MICS for card games, this

19 section requires the TGRAs to review and approve

20 cancellation and removal procedures. And it continues

21 the standard that no administrative or overhead fees may

22 be taken from player pool funds.

23 We did receive one comment, that the supervision

24 section may not be adequate to provide supervision of the

25 card room, and we requested additional comments on that.

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1 That section, as it reads, allows a dealer to function --

2 a supervisor to function as a dealer and have disputes

3 resolved by a supervisor from another department. Those

4 comments suggested that may not be adequate supervision,

5 so we had requested additional comments there.

6 Section 543.12, the MICS for gaming promotions and

7 player tracking. The gaming promotion standards again,

8 as we discussed in the definitions section, gaming

9 promotions are limited under this part to only those

10 promotions that required game play to be eligible to win.

11 So again, a door prize, tumbler raffle, anything

12 that patrons can put a free card into to win, that's not

13 covered here. Anything that requires game play to be

14 eligible for the prize, that's covered under gaming

15 promotions. Similarly, this section covers player

16 tracking systems because it's tracking game play and

17 awarding prizes based on game play.

18 Section 543.13, the MICS for complimentary services

19 and items. The TGRA and the operation are to establish

20 specific controls and procedures for comps, and the TGRA

21 establishes the threshold for recording those comps.

22 Section 543.14, the MICS for patron deposit accounts

23 and cashless systems. We removed any reference to

24 unrestricted player accounts because it conflicts with

25 the Bank Secrecy Act which doesn't allow accounts to be

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1 accessed by anyone. It's got to have a specific person

2 associated with the account and know who's accessing

3 that.

4 543.15, the MICS for lines of credit. This covers

5 the establishment of lines of credit. And we have

6 received -- I think it was maybe one comment, there may

7 have been more -- suggesting this provision may be

8 unnecessary, and we invite comments on that.

9 We have heard at several consultations that many

10 tribes still do use lines of credit, and we have heard

11 from other tribes that they're considering beginning to

12 use lines of credit. If there is a reason this is

13 unnecessary, please submit your comments and let us know.

14 Section 543.17 is the MICS for drop and count. This

15 has been simplified and allows for more TGRA and

16 operation discretion. However, you'll note, when you go

17 through this section, that drop and count is still a very

18 procedural section, because that's what drop and count

19 is. It's the nature of the beast.

20 Section 543.18, the MICS for cage, vault, cash, cash

21 equivalents, and kiosks. Here we've added kiosks into

22 this section. It requires further that any cage increase

23 or decrease of $100 or more must be verified, documented,

24 and recorded, and that promotional payments of $100 or

25 more must be documented.

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1 Section 543.20, the MICS for information technology

2 and IT data. This is where you'll find the download

3 requirements that Michael discussed in 547.12. It also

4 covers Class II gaming systems and physical controls.

5 You see the whole list here about what's in this

6 section. I won't read through all of it, but hitting a

7 few, you have the physical security and logical security.

8 The remote access -- these are all important parts, but

9 remote access is particularly important. Data backups

10 and software downloads, you'll find all of those here in

11 this 543.20.

12 And in this section we've added a definition of

13 "system" in the IT section, based on public comments for

14 the discussion draft. There was comment that our use of

15 "system" may be confusing, and it may be confused

16 particularly with Class II gaming system.

17 And we wanted to specify that here "system" means

18 anything associated with the IT system. I can't remember

19 what those examples were.

20 Rest, what's part of the system we added in the IT

21 definition? Do you remember?

22 MR. WEST: Well, just general server

23 and --

24 MS. WARD: The server system. And

25 there were additional parts that I don't have in front of

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1 me. Anyway, the definition is there. The point is that

2 it distinguishes it, and it clarifies that we're not

3 talking about the Class II gaming systems.

4 MR. WEST: It would also be like the

5 other periphery equipment that's not in the Class II

6 gaming systems.

7 Whatever other IT systems that are not directly

8 related to the Class II gaming systems that would also be

9 covered by the IT MICS are included in the IT section.

10 This might be if you have IT data -- a computerized

11 system for your cage inventory, Bingo card inventory, any

12 other systems that the IT MICS would cover.

13 MS. WARD: Thank you, Rest.

14 Section 543.21 is the MICS for surveillance. This

15 requires that cameras with sufficient clarity monitor the

16 count room, the card tables, and the cage and vault. And

17 again, that "sufficient clarify" definition is the 20

18 frames per second and at a resolution to clearly identify

19 the activities.

20 For Class II gaming systems, the surveillance must

21 include the jackpot meter. And here we've also responded

22 to public comments, and we've removed the requirement

23 that surveillance of the Bingo server is required.

24 After reviewing it, we've determined that there is

25 no longer a need to have surveillance in the minimum

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1 standards. The TGRA is free to require it, but in the

2 minimum standards, there was no need to require

3 surveillance at the Bingo server because that's covered

4 adequately by the physical and logical controls that are

5 addressed in the IT section.

6 The commission invites comments on whether the

7 one-year retention period for surveillance footage is

8 appropriate. Generally the surveillance retention period

9 is only seven days. In cases where there is footage of

10 suspicious activity, suspected crimes, and detention by

11 security personnel, this proposed rule requires a

12 retention of one year.

13 The commission invites comments on whether that's

14 too much or not enough or just right or there's some

15 other alternative. This also requires the TGRA to

16 approve procedures for reporting suspected crimes and

17 suspicious activity.

18 Section 543.23 is the MICS for auditing and

19 accounting. The annual requirements in this sections got

20 adopted by the Tribal Advisory Committee's

21 recommendation.

22 And 543.24, the MICS for revenue audit. This has

23 been separated out from audit and accounting. It

24 specifies the frequency for each testing procedure, and

25 the game sections have been adopted from the Tribal

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1 Gaming Working Group guidance. You'll also see here that

2 the Bingo sections have been combined in the audit

3 section as well to reflect the change that was made to

4 543.7 and 543.8.

5 And we'll open up the floor to questions and

6 comments, if you have any. And while you're questioning

7 and commenting, there is the address that you can send

8 the public comments to. There's an e-mail address, a

9 U.S. mail address, hand-delivery address, and a fax

10 address.

11 MR. LITTLE: Thank you, Jen.

12 Okay. That was a lot of information there. We're

13 coming up on a break here.

14 Why don't we take a question here, and then we'll

15 move to the break. Please state your name and your

16 organization.

17 MR. WOOLSEY: Tom Woolsey, from the

18 Colville Tribes.

19 Just a small, minor thing. On this existing versus

20 new facility compliance, I'm wondering if you guys are

21 going to have some sort of definition of what constitutes

22 a new facility versus an existing one?

23 I know that a lot of tribes in the past, let's say

24 they've built a new facility, and then they've used

25 their -- the old one becomes a bingo hall or something

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1 like that and then the new one is primarily Class III, so

2 is that a new facility?

3 Or let's say they tear one down and build on the

4 exact same footprint or they add significant square

5 footage through some sort of new wing or something like

6 that. Where do you draw the line as to what's new and

7 what's existing?

8 MR. LITTLE: That's kind of a very

9 unique question and probably something we'd have to think

10 about. It might be something you might want to put into

11 a comment and send it in. That would be very helpful.

12 MS. WARD: For the time being at

13 least, it should be covered in Part 549 that covers the

14 facility licensing.

15 MR. WOOLSEY: Okay.

16 MR. LITTLE: Is there a comment that

17 anyone would like to make right now?

18 If not, we're coming up on a break. How about we

19 come back at 20 minutes until 11:00. That will give you

20 time to, you know, take a break and maybe put together

21 some thoughts. We'll come back and take some questions

22 on either this part or Part 547. We'll see you at 20 to

23 11:00.

24 (Recess from 10:24 a.m. to

25 10:46 a.m.)

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1

2 CHAIRWOMAN STEVENS: Okay. If we can

3 go ahead and get started. Hope everybody had an

4 opportunity to return those e-mails and phone calls and

5 get some coffee.

6 So I want to hand it back over to Associate

7 Commissioner Little so we can open the floor up for

8 comments on the Part 543 that we just covered, or

9 Part 547.

10 MR. LITTLE: Thank you, Chairwoman.

11 Before I call for some questions, I just want to --

12 for the record, we did receive, during the break, written

13 comments from the Spokane Tribe of Indians, and I just

14 want to say, we'll put this in the record.

15 Okay. Is there any comments? Folks want to -- had

16 a chance to think about everything that was in

17 presentation and put together some thoughts on either

18 Part 543 or Part 547? I'll open the floor.

19 MS. REPIN: Jennifer Repin, Snoqualmie

20 Gaming Commission.

21 I do have a question, since this is the largest area

22 that's been talked about, is Internet gaming. Now, I

23 know that that's the next relevant step in the

24 progression of gaming.

25 How is that going to apply to the 547, with the

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1 internal controls for the system, being that, if we want

2 to take, per se, a Bingo game online, you know, play, are

3 there thoughts of incorporating that into technical

4 standards now or is that going to be a step later, you

5 know, kind of more after the fact?

6 CHAIRWOMAN STEVENS: Well, right

7 now -- I appreciate that question. Right now there is

8 not enough information. There is certainly not any

9 federal legislation authorizing the NIGC to do anything

10 like that.

11 There are a number of bills out there right now that

12 don't name the NIGC. There are a number of other factors

13 that come into play that we just don't know. There are

14 too many unknowns and too many variables, so we wouldn't

15 be able to address that in what we're doing with these

16 parts.

17 So to answer your question, we'll probably -- if

18 anything does ever happen, it will probably have to

19 happen after the fact, because right now there's too many

20 unknown variables.

21 MR. DURHAM: David Durham, from

22 Tulalip Tribes of Washington.

23 In regards to the surveillance requirements for the

24 one-year retention period, is that going to be the

25 server-based retention, or would removable media such as

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1 DVDs or CDs be sufficient for retention?

2 MS. WARD: It doesn't matter how the

3 tribes retain that surveillance, so long as they retain

4 it. If you've got a copy that's burned onto a DVD,

5 that's fine, or any other method you may have for storing

6 it.

7 MR. LITTLE: And the other question

8 would be, it's that one-year time period. That was a --

9 that was included in the Tribal Gaming Working Group

10 guidance document. That's really where we got the one

11 year. It's substantially longer than what we were

12 looking at.

13 We're really interested in hearing, is that too much

14 time, is that not enough time, or how does that affect

15 your facility. So if you're thinking about submitting a

16 comment, maybe think about addressing that point too. I

17 appreciate that.

18 Any other comments?

19 MR. BILLINGSLEY: Ken Billingsley,

20 from the Confederated Tribes of Warm Springs.

21 For the record, since we do have a transcriptionist

22 here, the tribe that I presently work for is very

23 interested in Class II gaming to offset set some of

24 the -- for economic development purposes, and they're

25 definitely very interested in getting some knowledge

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1 about Class II gaming.

2 So we went to the extent of putting in a training

3 request well in advance, submitted it through the

4 Portland Region office, went through the channels, and

5 have not heard anything.

6 I'm in the position where I want the tribal council

7 to understand what they're getting into, just like every

8 other tribal council, I believe, wants to know what

9 they're getting into, how it's regulated, how it works,

10 so that they can make some -- put people to work and

11 generate some additional revenue for the tribal people.

12 We have not heard nothing about this training

13 request, so the chairman of the tribe wrote a letter to

14 Chairwoman Stevens. To this date, we have not heard a

15 single thing back. Tribal members aren't here today. I

16 know they have had some questions, but they felt like

17 they were shunned.

18 NIGC travels around. I'm a -- for the record, I'm a

19 former region director. I'm not a disgruntled employee.

20 This commission has gone around from the beginning.

21 Training is a priority. They've developed an ACE system,

22 assistance, compliance, and enforcement.

23 Well, we're asking for assistance so we can be in

24 compliance if the tribe chooses to go down this road, so

25 we don't have any enforcement action brought against us,

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1 but we can't get it.

2 I understand that the letter is on the chief of

3 staff's desk, who denies or approves of all training. We

4 haven't heard one thing from the initial request, whether

5 it's going to be granted, denied, nothing.

6 Transparency -- where is the transparency? And

7 oddly, a chairperson's -- the chairman of the tribe's

8 written letter -- this tribe is very interested in this

9 stuff. They took time, set aside time to attend this

10 training. We haven't heard a word.

11 I beg of this commission to take all these requests

12 seriously, to honor these requests when they are needed,

13 and first and foremost, respond to these tribal leaders.

14 My opinion of that, for what it's worth, it's

15 unprofessional when you don't even respond to tribal

16 people.

17 Being a former tribal leader, United States

18 Government has a trust responsibility. The National

19 Indian Gaming Commission is part of that federal system,

20 part of the Department of the Interior that needs to

21 respond to tribal leaders. They're there for the benefit

22 of the tribes.

23 So with that, I wanted to make this on the record.

24 And I would like those questions answered so I can take

25 the answers back to the tribal chairman on why this

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1 request, number one, wasn't even -- if it wasn't granted,

2 what was the reasons for it. Can we get it later on down

3 the road. And the chairwoman, why the tribal chairman's

4 letter was not ever answered, written, sent in.

5 Thank you very much.

6 CHAIRWOMAN STEVENS: Well, thank you

7 for your comment, Mr. Billingsley. I do want to say we

8 would be happy to talk about this as an aside.

9 I appreciate that there is some tie to 543 and 547

10 as the Confederated Tribes of Warm Springs is considering

11 whether or not to go into Class II gaming. Although not

12 specifically relevant to the proposed rules at hand, I

13 can appreciate there is somewhat of a tie here.

14 And for the record, I do want to say, I do have your

15 letter. I do have the chairman's letter. There has been

16 communications back and forth, not denying the request,

17 but actually trying to schedule it at a time that is

18 appropriate for both the tribe and the NIGC with our

19 staff's currently established calendar.

20 I believe that there is an outstanding question to

21 the tribe from the NIGC about what time would be

22 appropriate for the tribe. So just for the record, I do

23 want to say that there has been communication back and

24 forth, and I'd be happy to talk perhaps to the chairman

25 myself directly to make sure that it is clear that we are

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1 handling this, and we do not deny requests. We gladly

2 and happily schedule them as appropriate for everybody's

3 calendar involved.

4 So with that, I would like to defer this

5 conversation to after the consultation and allow for the

6 time -- the remainder of the time to go to the

7 individuals who do want to speak directly to the proposed

8 rules that are published right now.

9 If not, I would encourage everybody again to read

10 the preamble and -- you know, also it's not just for

11 comments. If you do think of something, or in your

12 discussion, as you go back to your tribal council, you

13 can also contact these numbers.

14 You can e-mail us. You can call us. You can talk

15 to Jen or Mike or any of us, if the question does come up

16 or you need some clarification as to what's published

17 right now. We would be happy to answer your questions if

18 that will help inform your comments, so that it's

19 clear -- there's a clear understanding of what's being

20 proposed. So it's not just for comments. It's open to

21 questions and clarification.

22 MR. HARJU: Again, my name is Phil

23 Harju, from the Cowlitz Tribe.

24 I want to extend my thanks to the people of Squaxin

25 Island for hosting us here in their territory.

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1 I have just one question on -- I know you have

2 published in the Federal Register. Do you have the

3 proposed rules also on your website too so that people

4 don't have to dig it out of the Federal Register? They

5 can go right to your website?

6 I also want to thank the entire commission and staff

7 for coming out and being -- making this presentation and

8 answering our questions. I want to let the chairwoman

9 know, I had a very nice conversation with Jennifer, and

10 she was very knowledgeable and helpful on my questions,

11 and I thank her personally for her work. And again,

12 thank you for coming out and being here in Indian

13 Country.

14 CHAIRWOMAN STEVENS: Thank you. We

15 all appreciate your kind comments very much and also

16 appreciate the Squaxin Island's generosity in hosting, as

17 they always do.

18 MR. HARJU: Your website is what?

19 CHAIRWOMAN STEVENS: Our website is

20 nigc.gov. And on the right side, the announcement, press

21 releases, anything that we do is -- that has quick

22 access. There's links usually right there that lead you

23 right to the electronic Federal Register. Right now it's

24 the top two on the right under Current Activities.

25 On the left is Tribal Consultation, and under 2011,

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1 2012 is everything that we've done from November 2010

2 until now: transcripts, comments, drafts, proposed

3 rules, and even final rules. So there's everything on

4 one side, and then specifically the Federal Register

5 notices on the right, so you can find them there.

6 I do also want to echo your appreciation for our

7 staff because we have really worked on staff very hard

8 over the past -- at least the two years in the time that

9 this commission has been here, because we have had such

10 an ambiguous agenda and schedule.

11 And not just, you know, our staff, but to all of you

12 for keeping up with us, all the tribes' participation and

13 contribution to this process because without that -- you

14 know, as one of the three regulators at the table,

15 without that, we don't have a -- we can't make a fully

16 considered, well-informed decision about regulations that

17 affect everybody.

18 MR. HARJU: Thank you.

19 CHAIRWOMAN STEVENS: If there are no

20 other questions or comments at this time, I want to again

21 thank everybody. I want to hand it over to the associate

22 commissioners for their last words.

23 MR. LITTLE: Thank you, Tracie.

24 Like I said, look forward to your comments. You all

25 set that bar very high during the discussion comment

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1 period time, so we'll be expecting some really good,

2 thoughtful comments.

3 I appreciate the time that you all have taken out of

4 your day to come here, and I really appreciate the -- you

5 know, your participation because this is a joint effort

6 to make sure that, you know, we can strengthen these

7 regulations and continue to provide a regulation to keep

8 this industry strong. I want to thank you all today and

9 wish you safe travels.

10 MS. COCHRAN: I, too, echo the same

11 sentiments of Commissioner Little. I appreciate your

12 time. I know that your time is valuable and we've taken

13 you away from your normal duties. We thank again the

14 Squaxin for their hospitality, and I wish you safe

15 travels and look forward to hearing your comments.

16 CHAIRWOMAN STEVENS: Okay. Well, with

17 that, on behalf of the NIGC, we want to thank you for

18 your attention and participation. And again, we look

19 forward to your contribution to this process. Again, if

20 you have any questions, feel free to contact us.

21 In wrapping it up, please have safe travels. Thank

22 you.

23 (Proceedings concluded at

24 11:02 a.m.)

25

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1 STATE OF WASHINGTON ) I, Barbara L. Brace, CCR, RPR,

 ) ss a certified court reporter

2 County of Mason ) in the State of Washington, do

 hereby certify:

3

4

 That the foregoing proceedings were taken before

5 me and completed on July 19, 2012, and thereafter was

transcribed under my direction; that the foregoing is a

6 full, true and complete transcript of the proceedings;

7 That I am not a relative, employee, attorney or

counsel of any party to this action or relative or employee

8 of any such attorney or counsel and that I am not

financially interested in the said action or the outcome

9 thereof;

10 That I am herewith securely sealing the said

transcript and promptly delivering the same to

11 Attorney Rita Homa.

12 IN WITNESS WHEREOF, I have hereunto set my hand

and affixed my official seal on the 25th day of July, 2012.

13

14

15

16

17

18 ____________________________________

 Barbara L. Brace, CCR, RPR

19 Certified Court Reporter No. 3010

20

21

22

23

24

25

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1

1 16:12 25:3,7 33:12

33:21 35:8,13 46:16

10 27:18 28:2 31:21

100 25:4,8 33:13

35:8,13 49:23,24

108 2:2

10:24 54:24

10:30 41:8

10:46 54:25

11 31:21

11:00 54:19,23

11:02 64:24

12 44:12

120 28:6,8,12,19

1200 46:19,22,23

13 39:17

13175 11:13

14 32:15

15 13:24 17:15,16

38:22,23 41:22

16 15:4 39:12

19 1:14 2:1 65:5

1st 17:10

2

20 43:15,19,21,24

51:17 54:19,22

2008 21:12 26:9

33:15

2008-4 33:17

2010 7:22 42:2

43:14 63:1

2011 13:5 14:7

62:25

2012 1:14 2:2 63:1

65:5,12

2013 27:18 28:2

25th 65:12

3

3 13:4 44:19,22 45:2

30 15:4 36:10

3010 65:19

31 17:11,14

5

542 14:17

543 7:23 10:17 13:7

15:2 18:3 32:8 41:4

41:14,17 55:8,18

60:9

543.10 47:18

543.12 48:6

543.13 48:18

543.14 48:22

543.15 49:4

543.17 49:14

543.18 49:20

543.20 50:1

543.20. 50:11

543.21 51:14

543.23 52:18

543.24 52:22

543.3 44:1

543.4 44:14

543.5 45:7

543.7 46:12 53:4

543.8 46:4,16

543.8. 46:11 53:4

543.9 46:24

547 7:23 10:17 13:5

15:2 18:3,7,19 22:4

33:4 40:17 54:22

55:9,18,25 60:9

547.12 31:23

547.12. 31:22 50:3

547.13 32:14

547.14 32:14,24

547.15. 35:3

547.16 35:3

547.17 35:21

547.3 23:4

547.3. 19:11

547.4 19:11 24:22

547.5 24:24 26:2

29:10

547.5. 19:15 23:5

547.6 30:7

547.7. 30:8

547.8 31:2

549 54:13

57 33:21

6

60 17:10 36:11,14

36:16,17 45:21,22

45:24

600 46:25

8

8 31:20

9

9 31:21

91 2:2

9:07 2:3

a

a.m. 2:3 54:24,25

64:24

ability 47:1

able 2:24 17:16 47:7

56:15

access 50:8,9 62:22

accessed 49:1

accessing 49:2

account 42:15 49:2

accounting 52:19,23

accounts 48:22,24

48:25

ace 58:21

act 48:25

acting 6:15

action 58:25 65:7,8

activities 51:19

62:24

activity 43:17 52:10

52:17

actual 33:7 34:2

add 12:24 54:4

added 20:14,15,17

20:23 21:1 22:14

42:14 43:12,22 47:1

49:21 50:12,20

adding 21:24

addition 25:16

34:18 39:20

additional 17:13,17

44:3,20,22 45:6,24

47:25 48:5 50:25

58:11

address 53:7,8,9,9

53:10 56:15

addressed 24:9,11

52:5

addresses 41:19

addressing 57:16

adds 43:16

adequate 47:24 48:4

adequately 52:4

administrative

47:21

adolph 5:17,18

adopted 14:22 21:11

34:1 52:20,25

advance 58:3

advances 23:12

advertised 20:17

advisory 13:16,20

14:6 20:15 33:23

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