MAY 1 8 2001 

Honorable Gerald V. Chingwa 

Tribal Chairman, Little Traverse Bay Bands 

of Odawa Indians 

P.O. Box 246 

Petoskey, Michigan 49770 

RE: Tribal Gaming Ordinance Approval of the Little Traverse Bay Bands of Odawa Indians 

Dear Chairman Chingwa: 

This letter responds to your request to the National Indian Gaming Commission (NIGC) for the review 

and approval of the amendment to the Little Traverse Bay Bands of Odawa Indians (Band) tribal 

gaming ordinance and received in our office on February 22, 200 1. The Band on February 18, 200 1, 

adopted the amendments to the ordinance. The Chairman of the NIGC approved the original 

Ordinance on April 30, 1996. 

This letter constitutes approval of your submission under the Indian Gaming Regulatory Act (IGRA). 

Such approval does not constitute approval of specific games. It is important to hote that the gaming 

ordinance is approved for gaming -only on Indian lands, as defined in the IGRA, over which the Band 

exercises jurisdiction. 

We note that the definitions of "Indian lands" and "net revenues" are not included in the ordinance. 

We understand that the Band would rely on the IGRA's definitions of "Indian lands" and 

"net revenues" found in 25 C.F.R. 5 502 when conducting the affairs of this ordinance. 

We also note that the ordinance potentially modifies the function of the tribal gaming commission. 

In implementing this ordinance we would encourage the Band to be faithful to the principle that 

the tribal gaming commission is an independent body, separated completely from the tribe's role as 

owner and operator of the tribe's gaming activities. 

Thank you for submitting the amendment to the tribal gaming ordinance of the Little Traverse 

Bay Bands of Odawa Indians for review and approval. The NIGC staff and I look forward to working 

with you and the Band in implementing the IGRA. If you have questions or require further assistance, 

please contact Staff Attorney Danna Jackson at 2021632-7003. 

Sincerely yours, 

Montie R. Deer 

Chairman 

NATIONAL HEADQUARTERS 1441 L St. NW, Suite 9100. Washington. DC 20005 Tel: 202.632.7003 Fax: 202.632.7066 WWW.NlGC.GOV 

REGIONAL OFFICES Portland. OR: Sacramento. CA: Phoenix, AZ: St. Paul. MN: Tulsa. OK 
WAGANAKISING ODAWAK STATUTE 2001-02 

GAMING REGULATORY ORDINANCE 

;q 92 ye-,. 

' .:. . 

SECTION I: PURPOSE 

The Tribal Council of the Little Traverse Bay Bands of Odawa Indians, enacts this Statute 

pursuant to the Tribal Constitution, Article VII sections m and n which authorizes and directs the 

Tribal Council "To manage any and all economic affairs and enterprises of the Bands and to engage 

in any business not contrary to federal law. . ."and "To establish and delegate to subordinate boards, 

organizations, cooperative associations, Bands officers, committees, delegates, or other Bands 

groups, any of the foregoing powers, reserving the right to review any action taken by virtue of such 

delegated power or to cancel any delegation."The Tribal Council hereby ordains and establishes this 

Ordinance for the purpose of authorizing and comprehensively and preemptively regulating the terms 

and conditions under which Class I1 and Class I11 gaming may be conducted on the lands of the 

Tribe. This Ordinance rescinds and replaces the Gaming Regulatory Ordinance enacted on March 

3, 1996, as amended, being Waganakising Odawak Statute 1996003. 

SECTION 11: DEFINITIONS 

A. "Gaming Regulatory Commission" or "Commission" means the entity created under Section 

X of this Statute. 

C. "Key employee" means 

(a) A person who performs one or more of the following functions: 

(1) Bingo Caller; 

(2) Counting Room Supervisor 

(3) Chief of Security 

(4) Custodian of gaming supplies or cash; 

(5) Floor Manager 

(6) Pit Boss 

(7) Dealer 

(8) Croupier 

(9) Approver of Credit; or 

(1 0) Custodian of gambling devices including persons with access 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 1 
to cash and accounting records within such devices; 

(b) If not otherwise included, any other person whose total cash 

compensation is in excess of $50,000 per year; or 

(c) If not otherwise included, the four most highly compensated persons 

in the gaming operation. 

C. "Primary management official" means 

(a) The person having management responsibility for a management contract; 

(b) Any person who has authority: 

(1) To hire and fire employees; or 

(2) To set up working policy for the gaming operation; or 

(c) The chief financial officer or other person who has financial management 

responsibility. 

D. The terms "Statute" and "Ordinance" are synonymous when used herein. 

E. "Tribal Council" means the elected governing body of the Little Traverse Bay Bands of 

Odawa Indians called the Board of Directors in the Tribe's Constitution and Bylaws. 

G. "Tribe" means the Little Traverse Bay Bands of Odawa Indians membership and collective 

federally recognized tribal entity. 

SECTION 111: GAMING AUTHORIZED 

A. Class I1 gaming as defined in the Indian Gaming Regulatory Act, P.L. 100-447,25 U.S.C. 

Section 2703(7)(A) ("IGRA") and by regulations lafilly promulgated by the National Indian 

Gaming Commission ("NIGC") that now or hereafter may be in effect is hereby authorized. 

B. Class I11 gaming as defined in IGRA, 25 U.S.C. Section 2703(8) and by regulations 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 2 
promulgated by the NIGC that now or hereafter may be in effect is hereby authorized, provided such 

gaming is also authorized by and consistent with a Tribal-State Compact that has been approved by 

the Secretary of the Interior and is in effect, or otherwise has been authorized by the Secretary of the 

Interior or federal law. 

SECTION IV. OWNERSHIP OF GAMING FACILITIES AND/OR ENTERPRISES 

The Tribe shall have the sole proprietary interest in and responsibility for the conduct of any 

gaming facilities andor enterprise(s) authorized by this ordinance. 

SECTION V. USE OF GAMING REVENUE 

A. Except as specifically authorized pursuant to Subsection B of this Section, net revenues from 

Class I1 and Class I11 gaming shall be used only for the following purposes: 

1) to fund Tribal government operations and programs; 

2) provide for the general welfare of the Tribe and its members; 

3) promote Tribal economic development; 

4) donate to charitable organizations; or 

5) help hnd operations of local government agencies. 

B. If the Tribe elects to make per capita payments to Tribal members, it shall authorize such 

payments only in conformity with a plan submitted to and approved by the Secretary of the lnterior 

pursuant to applicable law. 

SECTION VI. AUDIT 

A. The Tribal Council, through official action or appropriate delegation, shall cause to be 

conducted at least annually an independent audit of all gaming operations and shall submit the 

resulting audit reports to the National Indian Gaming Commission, and to such other agencies as 

may be required by the terms and conditions of any Class I11 compact or other document authorizing 

Class I11 gaming. 

B. All gaming-related contracts that result in the purchase of supplies, services, or concessions 

in excess of $25,000.00 annually, except contracts for professional legal and accounting services, 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 3 
shall be specifically included within the scope of the audit that is described in Subsection A above. 

SECTION VII: PROTECTION OF THE ENVIRONMENT AND PUBLIC HEALTH AND 

SAFETY 

Class I1 and Class I11 gaming facilities shall be constructed, maintained and operated in a 

manner that adequately protects the environment and the public health and safety. 

SECTION VIII: LICENSES FOR KEY EMPLOYEES AND PRIMARY MANAGEMENT 

OFFICIALS 

The Gaming Regulatory Commission shall ensure that the policies and procedures set out in 

this section are implemented with respect to key employees and primary management officials 

employed at any class I1 andlor Class I11 gaming enterprise. The Gaming Regulatory Commission 

has the authority to determine additional job classifications and/or positions as ones which will 

require licensure. The Gaming Regulatory Commission has to demonstrate, subject to the review 

and approval of the Tribal Council, that such additional determination is reasonable and prudent and 

in the best interest of the Tribal membership. 

A. Application Forms 

1. The following notice shall be placed on the application form of a key employee or 

a primary management official before that form is filled out by an applicant: 

In compliance with the Privacy Act of 1974, the following information is provided: 

Solicitation of the information on this form is authorized by 25 U.S.C. $2701 et sea. 

The purpose of the requested information is to determine the eligibility of individuals 

to be employed in a gaming operation. The information will be used by National 

Indian Gaming Commission members and staff who have need for the information 

in the performance of their official duties. The information may be disclosed to 

appropriate Federal, Tribal, State, local, or foreign law enforcement and regulatory 

agencies when relevant to civil, criminal or regulatory investigations or prosecutions, 

or when pursuant to a requirement by a tribe or the National Indian Gaming 

Commission in connection with the hiring or firing of an employee, the issuance or 

revocation of a gaming license, or investigations of activities while associated with 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 4 
a tribe or a gaming operation. Failure to consent to the disclosures indicated in this 

notice will result in a tribe's being unable to hire you in a primary management 

official or key employee position. 

The disclosure of your Social Security Number (SSN) is voluntary. However, failure 

to supply a SSN may result in errors in processing your application. 

2. Existing key employees and primary management officials shall be notified in writing 

that they shall either: 

a. Complete a new application form that contains a Privacy Act notice; or 

b. Sign a statement that contains the Privacy Act notice and consent to the 

routine uses described in that notice. 

3. The following notice shall be placed on the application form for a key employee or 

a primary official before that form is filled out by an applicant: 

A false statement on any part of your application may be grounds for not hiring you, 

or for firing you after you begin work. Also, you may be punished by fine or 

imprisonment. (1 8 U.S.C. $1001). 

4. Existing key employees and primary management officials shall be notified that they 

shall either: 

a. Complete a new application form that contains a notice regarding false 

statements; or 

b. Sign a statement that contains the notice regarding false statements. 

B. Background Investigations 

1. The Gaming Regulatory Commission shall perform background investigations and 

issue licenses for key employees and primary management officials according to requirements that 

are at least as stringent as those in 25 C.F.R. parts 556 and 558. 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 5 
2. The Gaming Regulatory Commission shall conduct an investigation sufficient to 

make a determination under Subsection C. below. In conducting a background investigation, the 

Gaming Regulatory Commission or its agent(s) shall promise to keep confidential the identity of 

each person interviewed in the course of the investigation. The Commission shall utilize the Tribe's 

Law Enforcement Department to take fingerprints and conduct criminal history checks utilizing the 

Law Enforcement Information Network. Such a criminal history check shall include a check of 

criminal history records information maintained by the Federal Bureau of Investigation. 

C. Eligibility Determination 

The Gaming Regulatory Commission shall review an applicant's prior activities, criminal 

record, if any, and reputation, habits and associations to make a finding concerning the eligibility of 

a key employee or primary management official for employment in a gaming operation. If the 

Gaming Regulatory Commission determines that employment of the person poses a threat to the 

public interest or to the effective regulation of gaming, or creates or enhances dangers of unsuitable, 

unfair, or illegal practices and methods and activities in the conduct of gaming, the gaming operation 

shall not employ that person in a key employee or primary management official position. 

D. Procedures for Forwarding Applications and Reports for Key Employees and Primary 

Management Officials to the National Indian Gaming Commission 

1. When a key employee or primary management official begins work at a gaming 

operation authorized by this Ordinance, the Gaming Regulatory Commission shall forward to the 

National Indian Gaming Commission a completed application for employment and conduct the 

background investigation and make the determination referred to in Subsection C of this Section. 

2. The Gaming Regulatory Commission shall forward the report referred to in 

Subsection E of this Section to the National Indian Gaming Commission within 60 days after an 

employee begins work or within 60 days of the approval of this Ordinance by the Chairman of the 

National Indian Gaming Commission. 

3. The gaming operation shall not employ as a key employee or primary management 

official a person who after 90 days does not have a license pursuant to section VIII F. of this 

Ordinance. 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 6 
E. Report to the National Indian Gaming Commission 

1. Pursuant to the procedures set out in Subsection D of this Section, the Gaming 

Regulatory Commission shall prepare and forward to the National Indian Gaming Commission an 

investigative report on each background investigation. An investigative report shall include all of 

the following: 

a. Steps taken in conducting the background investigation; 

b. Results obtained; 

c. Conclusions reached; and 

d. The bases for those conclusions. 

2. The Gaming Regulatory Commission shall submit, with the report, a copy of the 

eligibility determination made under Subsection C of this Section. 

3. If a license is not issued to an applicant, the Gaming Regulatory Commission: 

a. Shall notifjl the National Indian Gaming Commission; and 

b. May forward copies of its eligibility determination and investigative report 

(if any) to the National Indian Gaming Commission for inclusion in the 

Indian Gaming Individuals Records System. 

4. With respect to key employees and primary management officials, the Gaming 

Regulatory Commission shall retain applications for employment and reports (if any) of background 

investigations for inspection by the Chairman of the National Indian Gaming Commission or his or 

her designee for no less than three (3) years from the date of termination or denial of employment. 

F. Granting a Gaming License 

1. If, within a thirty (30) day period after the National Indian Gaming Commission 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 7 
receives a report, the National Indian Gaming Commission notifies the Gaming Regulatory 

Commission that it has no objection to the issuance of a license pursuant to a license application 

filed by a key employee or a primary management official for whom the Gaming Regulatory 

Commission has provided an application and investigative report to the National Indian Gaming 

Commission, the Gaming Regulatory Commission may issue a license to such applicant. 

2. The Gaming Regulatory Commission shall respond to a request for additional 

information from the Chairman of the National Indian Gaming Commission concerning a key 

employee or a primary management official who is the subject of a report. Such a request shall 

suspend the 30-day period under Subsection G. 1. of this Section until the Chairman of the National 

Indian Gaming Commission receives the additional information. 

3. If, within the thirty (30) day period described above, the National Indian Gaming 

Commission provides the Gaming Regulatory Commission with a statement itemizing its 

objection(s) to the issuance of a license to a key employee or to a primary management official for 

whom the Gaming Regulatory Commission has provided an application and investigative report to 

the National Indian Gaming Commission, the Gaming Regulatory Commission shall reconsider the 

application, taking into account the objection(s) itemized by the National Indian Gaming 

Commission. The Gaming Regulatory Commission shall make the final decision whether to issue 

a license to such applicant. 

4. If the NIGC provides no response within the thirty (30) day period described above, 

the Gaming Regulatory Commission may issue a license based on its own findings on a temporary 

basis contingent on the contents of a final report from the NIGC. 

G. License Suspension 

1. If, after the issuance of a gaming license, the Gaming Regulatory Commission 

receives from the National Indian Gaming Commission, or from its own sources, reliable 

information indicating that a key employee or a primary management official is not eligible for 

employment under Subsection C above, the Gaming Regulatory Commission shall suspend such 

license and shall notify in writing the licensee of the suspension and the proposed revocation. 

2. The Gaming Regulatory Commission shall noti@ the licensee of a time and a place 

for a hearing on the proposed revocation of a license. 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 8 
3. After a revocation hearing, the Gaming Regulatory Commission shall decide whether 

to revoke or to reinstate a gaming license. The Gaming Regulatory Commission shall notifL the 

National Indian Gaming Commission of its decision. 

SECTION IX: LICENSING OF GAMING PLACES, FACILITIES AND LOCATIONS 

A separate license shall be required for each place, facility, or location on Indian lands where 

Class I1 andlor Class I11 gaming is to be conducted. 

SECTION X. CREATION OF GAMING REGULATORY COMMISSION 

A. There is hereby created the Gaming Regulatory Commission, which shall consist of three 

Tribal members who would themselves qualify for licensing under this Ordinance. 

B. The members of the Gaming Regulatory Commission shall be appointed by the Tribal 

Council as follows: 

1. Initial appointment. Immediately upon passage of this ordinance, the Tribal Council may 

publicize, to the extent reasonable and practical, that it will be appointing a three (3) member 

Gaming Regulatory Commission seeking both applicants for appointment and nominations of 

individuals to be appointed. At the next regularly scheduled meeting, or as soon thereafter as the 

Tribal Council identifies qualified Tribal members willing to serve on the Gaming Regulatory 

Commission, the Tribal Council shall appoint three (3) members to the Gaming Regulatory 

Commission. 

2. Term and compensation. Members of the Gaming Regulatory Commission shall be 

appointed to serve for three (3) year terms. Members may be reappointed for additional terms 

without limitation. Provided, to stagger terms, when the Tribal Council makes initial appointments, 

one person shall be appointed to a one (I) year term, one person shall be appointed to a two (2) year 

term, and one person shall be appointed to a three (3) year term. All appointments thereafter shall 

be for three (3) year terms. There shall be a Chairperson of the Gaming Regulatory Commission, 

who shall be selected by the members of the Commission from the Commission members for a one 

year term. 

3. Subject to the availability of funding and a budget approved by the Tribal Council, 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 9 
members of the Gaming Regulatory Commission may receive a stipend, mileage and expense 

reimbursement for attendance at properly called meetings at which a quorum is present. 

4. Future Appointments. At least two (2) weeks prior to any meeting during which 

appointments to the Gaming Regulatory Commission will be made, the Tribal Council shall 

publicize that it will be making such appointments and shall seek applicants for appointment and 

nominations of individuals to be appointed. 

5. Oath of Office. As soon as possible after appointment, the Tribal Court, by any member 

of the Judiciary or the Court Administrator, shall administer the oath of office to the members of the 

Gaming Regulatory Commission which oath of office shall include a commitment to uphold the 

Constitution and laws of the Little Traverse Bay Bands of Odawa Indians and to perform faithfully 

and diligently the duties and responsibilities set forth in this ordinance. 

6. In the event a vacancy occurs in the Gaming Regulatory Commission, by virtue of 

death, resignation or removal, the vacancy shall be filled in the following manner: 

a. If one year or less remains of the term of office which has become vacant, the 

Tribal Council shall appoint a qualified member of the Little Traverse Bay Bands of 

Odawa Indians to fill the remaining term of office without seeking applications or 

nominations therefor. 

b. If more than one year remains of the term of office which has become vacant, the 

Tribal Council shall comply with the requirements of Section X(B)(3) prior to 

appointing a qualified member of the Little Traverse Bay Bands of Odawa Indians 

to fill the remaining term of office. 

c. To ensure that the Commission remains functional, the Tribal Council may make 

emergency temporary appointments for 60 day increments. Council members who 

would themselves qualify for licensing under this Ordinance may be appointed to 

such emergency interim positions. 

7. Removal or Discipline. Members of the Gaming Regulatory Commission shall not be 

removed during their terms of office except for misconduct, neglect of duties or other acts that would 

render such persons unqualified for licensure hereunder. The procedure for removal shall be as 

follows: 

a. The Chairman of the Little Traverse Bay Bands of Odawa Indians shall call a 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 10 
special meeting of the Tribal Council to deal with a request to remove the member 

or place the item on the agenda of the next regularly scheduled Council meeting in 

response to any one of the following: 

1. The Tribal Council by majority vote determines that there is cause to 

suspect that a member may be subject to removal for one or more of the 

reasons specified in this section; 

2. The Tribal Council receives a petition signed by at least fifty (50) 

members of the Little Traverse Bay Bands of Odawa Indians alleging cause 

to suspect that a member may be subject to removal for one or more of the 

reasons specified in this section; 

3. The Tribal Council receives a petition signed by two members of the 

Gaming Regulatory Commission alleging cause to suspect that a member 

may be subject to removal for one or more of the reasons specified in this 

section. 

b. In the event that the Tribal Council receives a petition under this section, or 

determines itself that there may be grounds for removal the Council shall: 

1. Submit the petition to the Election Board for verification that the 

petition contains a sufficient number of valid signatures; 

2. If the Election Board finds the petition to contain a sufficient number 

of valid signatures, the Tribal Council shall submit the petition to the Tribal 

Court to determine if the charges, if proven true, would constitute grounds for 

removal; 

3. In the event that Council itself has determined that there is cause to 

suspect that a member may be subject to removal, Council shall submit its 

reasons in writing to the Tribal Court to determine if the charges, if proven 

true, would constitute grounds for removal. 

4. If the Tribal Court determines that the charges, if proven true, would 

constitute grounds for removal of a Commissioner from his or her appointed 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 11 
position, the Tribal Council shall set a date for hearing the charges on the 

petition and shall provide notice to the member of the Gaming Regulatory 

Commission whose removal is being sought. 

c. Notice to the member whose removal is being sought shall be served no later than 

two (2) weeks prior to the date set for the hearing, shall include the date, time and 

location of the hearing, shall attach a full and complete copy of a statement of the 

Tribal Council or the petition seeking removal, and shall attach a copy of the rules 

to be followed during the hearing. Upon good cause shown, the Tribal Council may 

postpone the hearing to a later date. Notice shall also advise the recipient of the 

availability of Tribal Council power to require the presence of any witness or the 

production of any document which the recipient deems necessary in order to attempt 

to defend against the charges contained in the petition, and the right of the 

commissioner to have one attorney or Tribal member advocate present to represent 

and assist the commissioner at the hearing. 

d. The Tribal Council shall also provide copies of the notice to the other members of 

the Gaming Regulatory Commission, and to the member of the Little Traverse Bay 

Bands of Odawa Indians who presented the petition, advising each of them of the 

opportunity to appear and to present evidence, either in support of the charges against 

the member of the Gaming Regulatory Commission whose removal is sought or in 

support ofthe defense of such member. The presenter of the petition or a person who 

signed the petition designated by the presenter shall have the ability to request the 

Tribal Council to require the presence of witnesses or production of documents 

deemed necessary to support the charges contained in the petition. 

e. The Tribal Council shall preside at the hearing of the charges contained in any such 

petition and shall allow as much time as necessary for the testimony of witnesses and 

presentation of evidence in support of the charges, as much time as necessary for the 

testimony of witnesses and presentation of evidence to refute the charges, and such 

time as the Tribal Council deems appropriate for summary statements and arguments. 

At any time, the Tribal Council may recess the hearing until a later time certain. At 

the request of the member whose removal is at issue, the hearing may be held in 

executive session. The Tribal Council also may elect to receive in executive session 

any evidence public disclosure of which might compromise the proprietary interests 

of the Tribe or any on-going law-enforcement investigation. 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 12 
f. Upon the conclusion of the presentation of evidence and of summary statements 

and arguments, the Tribal Council shall deliberate in executive session and shall 

either dismiss the petition, remove the member charged in the petition from the 

Gaming Regulatory Commission, or take such other disciplinary action as it deems 

appropriate short of removal, upon such findings of fact as may be appropriate. The 

decision of the Tribal Council shall be final, and no appeal to any other tribunal shall 

be available. 

g. Upon conclusion of the hearing, any information disclosing possible criminal 

activity shall be promptly reported to Tribal Law Enforcement. 

C. The Gaming Regulatory Commission shall be authorized and hereby is directed to 

promulgate detailed and comprehensive regulations for the implementation and enforcement of this 

Ordinance. Provided, the Tribal Council retains the right to approve andlor modify such regulations. 

Said regulations shall describe and establish the rules for each specific Class I1 and Class 111 gaming 

activity to be authorized to be conducted, and no form of such gaming may be conducted without 

prior approval by the Gaming Regulatory Commission. The regulations may contain an appellate 

procedure whereby appeals of licensing decisions are taken to the Tribal Court or such other 

appellate body as established therein. 

D. Subject to the ultimate authority of the Tribal Council under Article VII, sections (m) and (n) 

of the Constitution, the Tribal Council delegates to the Gaming Regulatory Commission authority 

to monitor compliance with this Ordinance and its Regulations, and to investigate and act to prevent 

any violation(s) thereof. Any investigation disclosing criminal violations shall be promptly reported 

to Tribal Law Enforcement. 

E. Subject to the approval by Tribal Council action and the appropriation of funds therefor, the 

Gaming Regulatory Commission shall be authorized to employ such staff andlor consultants as 

reasonably may be required to fulfill its responsibilities under this Ordinance. Compensation of 

Commission employees shall be limited to that which is comparable to compensation paid to persons 

performing similar duties in other Tribal governmental departments. Such employees are not 

employees of the Enterprise, but of the Tribal Government. 

F. Subject to the approval by Tribal Council action, the Gaming Regulatory Commission hereby 

is authorized to establish and impose upon gaming facilities, permittees, applicants and licensees 

such application, permit and license fees as may be necessary to fully reimburse the Tribe for its 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 13 
actual costs of operating the Gaming Regulatory Commission, enforcing this Ordinance and Gaming 

Regulatory Commission regulations, processing of licensing and permit applications, and otherwise 

hlfilling its regulatory responsibilities under IGRA. All such fees shall be collected by the Gaming 

Regulatory Commission and hereby are continuously appropriated solely for the purposes 

enumerated in this Subsection. 

G. Failure to timely pay any gaming-related fee imposed by the Tribal Council or the Gaming 

Regulatory Commission, or failure to comply with any Commission regulation or order, or any other 

violation of this Ordinance or the terms of any Class 111 gaming compact to which the Tribe is a party 

authorizing and regulating gaming, shall be grounds for suspension or revocation of any license or 

permit issued pursuant to this Ordinance, exclusion of any non-member of the Tribe from the Tribe's 

Gaming Enterprise, and imposition of such other sanctions as the Gaming Regulatory Commission 

may deem appropriate. 

SECTION XI: RESOLUTION OF DISPUTES BETWEEN THE GAMING PUBLIC AND 

TRIBE OR MANAGEMENT OFFICIAL 

Disputes between the gaming public and Tribe or management official shall be resolved in 

accordance with procedures adopted by the Gaming Regulatory Commission. Such procedures shall 

at a minimum include: 1. The aggrieved member of the gaming public shall first bring hisher 

complaint either verbally or in writing to staff of the gaming facility. 2. If not satisfied with staff 

response, the complaining party may file a written complaint with the Gaming Regulatory 

Commission which shall take appropriate action on the complaint within thirty (30) days of 

submission. 

SECTION XII: SAVINGS CLAUSE 

In the event that any phrase, provision, part, paragraph, subsection or section of this ordinance 

is found by a court of competent jurisdiction to violate the Constitution, laws or ordinances of the 

Little Traverse Bay Bands of Odawa Indians, such phrase, provision, part, paragraph, subsection or 

section shall be considered to stand alone and to be deleted from this ordinance, the entirety of the 

balance of the ordinance to remain in full and binding force and effect. 

SECTION XIII. EFFECTIVE DATE 

This Statute takes effect upon approval of the Chairman of the National Indian Gaming 

Commission, or when considered approved by operation of applicable Federal law and/or regulation. 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 14 
. Certification 

As Tribal Chairman and Tribal Secretary, the undersigned certify that this Statute was duly enacted 

by the Tribal Council of the Little Traverse Bay Bands of Odawa Indians at a regular meeting of the Tribal 

Council held on February 18,2001 at which a quorum was present, by a vote of three (3) in favor, two (2) 

opposed, and zero (0) abstentions as recorded by this roll call. 

In Favor Opposed Abstained Absent 

George Anthony -XGerald Chingwa -XDorothy Gasco -XJanet Sliomin -XSusan Wysocki -XAlice Yellowbank -XDate: 71glo I 

Gerald Chingwa, Tribal Chairman u 

Dorothy Gasc Tribal Secretary d 

LTBB Revised Gaming Regulatory Ordinance, Enacted February 18,2001, pg 15