APR 30 I996 

Frank Ettawageshik 

Tribal Chairman 

Little Traverse Bay Bands 

of Odawa Indians. 

Post Office Box 246 

Petoskey, MI 49770 

Dear Chairman ~ttawageshik: 

This letter responds to your request to review and approve 

the tribal gaming ordinance, ordinance No. 1996003, adopted on 

March 3, 1996, by the Little Traverse Bay Bands of Odawa- Indians 

(Tribe). This letter .constitutes such approval under the Indian 

Gaming Regulatory Act (IGRA). 

Under the IGRA and the regulations of the National Indian 

Gaming Commissio'n (NIGC), the Chairman is directed to review 

ordinances with respect to the requirements of the IGRA and the 

implementing regulations. Thus, the scope of the Chairman's 

review and approval is limited to the requirements of the IGRA 

and the NIGC regulations. Provisions other than those required 

under the IGRA or the NIGC regulations that may be included in a 

tribal ordinance are not subject to review and approval. Also, 

such approval does not constitute approval of specific games. It 

is important to note that the gaming ordinance is approved for 

gaming only on Indian lands as defined in the IGRA. 

With the Chairman's approval of the Tribe's gaming 

ordinance, the Tribe is now required to conduct background 

investigations on its key employees and primary management 

officials. The NIGC expects to receive a completed application 

for each key employee and primary management official pursuant to 

25 C.F.R. § 556.5(a) and an investigative report on each 

background investigation before issuing a license to a key 

employee or primary management official pursuant to 25 C.F.R. 

S 556.5(b). 

Thank you for submitting the 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 Tribe 

in implementing the IGRA. 

Sincerely yours, 

-- -7 

, Chairman 
WAGANAKISING ODAWAK STATUTE 1996003 

GAMING REGULATORY ORDINANCE MAR 6 1935 

SECTION I: PURPOSE 

The Little Traverse Bay Bands of Odawa Indians (hereinafter, "Tribe"), acting through its 

Tribal Council in the exercise of its inherent sovereign power to enact ordinances and otherwise 

safeguard and provide for the health, safety and welfare of the members of the Tribe, 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 September 24, 1995, being Cliaganakising Odawak Statute 19950 16. 

SECTION 11: DEFINITIONS 

A. "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 

B. "Key employee" means 

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

(1) Bingo Caller, 

(2) Counting Room Super-visor 

(3) Chief of Security 

(4) Custodian of gaming supplies or cash, 

(5) Floor hlanager 

(6) Pit Boss 

(7) Dealer 

(8) Croupier 

(9) Approver of Credit, or 

(10) Custodian of gambling devices including persons with access 

to cash and accounting records within such decices, 

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

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

LTBB Gaming Reguli~ro~?; Ordini~ncc. cn;~ctcd 3-03-1996, pz 1 
(c) If not otherwise included, the four most highly compensated persons 

in the gaming operation. 

C. "Primary management official" means 

(a) Any 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. 

SECTION 111: GAkIING 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 lawfilly 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 

promulsated by the MGC that now or hereafter may be in effect is hereby authorized, provided such 

- uaming 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 

SECTlON 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 and/or enterprise(s) authorized by this ordinance. 

SECTION V. USE OF GAMING REVENUE 

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

LTBB Girrning Regui:rto~?. Osdini~nce, en:lctetl3-03-1996, pg 2 
Class 11 and Class 111 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 conforniity with a plan submitted to and approved by the Secretary of the Interior 

pursuant to applicable law. 

SECTION VI. AUDIT 

A. The Tribe shall cause to be conducted at least annually an independent audit of all gamins 

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 111 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, shall 

be specifically included within the scope of the audit that is described in Subsection A above. 

SECTION VII: PROTECTION OF THE ENVIRONRIENT AND PUBLIC HEALTH AND 

SAFETY 

Class I1 and Class 111 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 EnilPLOYEES AND PRIMARY 3IANAGE;CIENT 

OFFICIALS 

The Tribe 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 II and/or 

Class 111 gaming enterprise. The Gaming Regularory Commission has the authority to deterniine 

LTBB Gaming Rrgulntol?. Ot.tlinanre, en;lctrtl3-03-1996, pg 3 
additional job classifications and/or positions as ones which will require licensure. The Gaming 

Regulatory Commission has to demonstrate that such additional determination is reasonable and 

prudent and in the best interest of the Tribe. 

A. Application Fornls 

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 ofthe information on this form is authorized by 25 U.S.C. $2701 et seq. 

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 

Comn~ission 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 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 processinu, 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. 

LTBB Gnrninr Regul:~tor? Or~tlicrsnce, enacted 3-03-1996. pe 4 
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. ( 18 U. S.C. 5 100 1). 

4. The Tribe shall noti@ in writing existing key employees and primary management 

officials 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 Tribe 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. 

2. The Tribe shall conduct an investigation sufficient to make a determination under 

Subsection C. below. In conducting a background investigation, the Tribe or its agent(s) shall 

promise to keep confidential the identity of each person interviewed in the course of the investigation. 

C. Eligibility Determination 

The Tribe 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 etnployment in a gaming operation. If the Tribe determines that e~tiployment 

of the person poses a threat to the public interest or to the effective regulation of gamin,, (J 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 en~ployee or primary 

management official position. 

LTBB Gilrning RceuIi~tot?. Ot.tiin;tncr, eni1ctetl3-03-1996, pe 5 
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 Tribe 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 Tribe shall forward the report referred to in Subsection E of this Section to the 

National Indian Gaming Co~nmission 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. 

E. Report to the National Indian Gaming Commission 

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

prepare and fonvard 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 Tribe 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 Tribe: 

LTBB Gaming Rcgul:~tot?. Ol.tlinance, enacted 3-03-1996, pg 6 
a. Shall notify 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 Tribe 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 Gamir~g License 

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

receives a report, the National Indian Gaming Commission notifies the Tribe 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 Tribe has provided an application and investigative report to the 

National Indian Gaming Commission, the Tribe may issue a license to such applicant. 

2. The Tribe 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 Tribe 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 Tribe has provided an 

application and investigative report to the National Indian Gaming Commission, the Tribe shall 

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

Gaming Commission. The Tribe 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 Tribe may issue a license based on its own findin2s on a temporary basis contingent on the 

LTBB Gaming Regulzitor> Ordinance, cn:~cted 3-03- 1996. pe ' 
contents of a final report from the NIGC. 

G. License Suspension 

1. If, after the issuance of a gaming license, the Tribe receives from the National Indian 

Gaming Commission, or from its own sources, reliable information indicating that a key employee 

or a prima~y management official is not eligible for employment under Subsection C above, the Tribe 

shall suspend such license and shall noti@ in writing the licensee of the suspension and the proposed 

revocation. 

2. The Gaming Regulatory Commission shall notie the licensee of a time and a place for 

a hearing on the proposed revocation of a license. 

3. After a revocation hearing, the Tribe shall decide whether to revoke or to reinstate a 

uaminy license. The Tribe shall notifji the National Indian Gaming Commission of its decision. L, 

SECTION 1X: LICENSING OF GARilING PLACES, FACILITIES AND LOCATIONS 

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

Class I1 andlor Class 111 gaming is to be conducted. 

SECTION X. CREATION OF GAMING REGULATORY CO>I>IISSION 

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

persons who would themselves qualify for licensing under this Ordinance. Pending organization of 

said Commission, the Tribal Council shall serve as the Commission, and shall promulgate and 

implement interim regulations to govern gaming until such time as the Commission adopts permanent 

regulations. 

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 

LTBB Gaming Regulato~?. Ordinance, en:ictcd 3-03-1996, pe S 
identifies qualified Tribal members willing to serve on the Gaming Regulatory Commission, the Tribal 

Council shall appoint three (3) members to the Gaming Replatory Commission. Provided that in any 

event the appointments shall be made within sixty (60) days of the date of execution of the 

Management Agreement. 

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 (1) 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. The Tribal Council shall determine and authorize the compensation to be paid to members 

of the Gaming Regulatory Commission based upon the Tribal Council's determination of the time 

required to be expended upon Commission duties and the qualifications of the appointed 

Commissioners. 

3. 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. 

4. Oath of Office. Immediately upon appointment, the Tribal Chairman shall administer the 

oath of ofice to the members of the Gaming Regulatory Commission which oath of ofice shall 

include a commitment to uphold the Constitution and laws of the Little Traverse Bay Bands of 

Odawa Indians and to perform faithfilly and diligently the duties and responsibilities set forth in this 

ordinance. 

5. 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 ofice without seeking applications or 

nominations therefor. 

LTBB Gaming Regulato~.! 0tdin;lncv. en:lctrd 3-03-1996, pg 0 
b. If more than one year remains of the term of ofice which has become vacant, the 

Tribal Council shall comply with the requirements of Section III(C)(3) prior to 

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

fill the remaining term of office. 

6. Removal. Members of the Gaming Regulatory Commission shall not be removed during 

their terms of ofice except for misconduct, neglect of duties or other acts that would render such 

persons unqualified for Iicensure hereunder. The procedure for removal shall be as follows: 

a. In the event the Tribal Council has cause to suspect that a member may be subject 

to removal for one or more ofthe reasons specified in this section, or upon receipt of 

a petition signed by at least twenty (20) members of the Little Traverse Bay Bands of 

Odawa Indians alleging the same, or receipt of a petition by two members of the 

Gaming Regulatory Commission alleging the same, the Chairman of the Little 

Traverse Bay Bands of Odawa Indians shall call a special meeting of the Tribal 

Council to deal with a request to remove the member. 

b. In the event the Tribal Council determines that a sufficient number of valid 

signatures are affixed to the petition and that the charges set forth in the petition, if 

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

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 subpoena 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. 

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

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

LTBB Gaming Regulato~? 01.clin:lncc. en:lctctl3-03-1996, prr 10 
Bands of Odawa Indians who signed 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 of the defense of such member. Any person who has properly signed such 

petition shall have the ability to request the Tribal Council to issue a subpoena 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 rehte 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 

closed session. The Tribal Council also may elect to receive in closed session any 

evidence public disclosure of which might compromise any on-going law-enforcement 

investigation. 

f Upon the conclusion of the presentation of evidence and of summary statements and 

arguments, the Tribal Council shall deliberate in closed session and shall either dismiss 

the petition or shall remove the member charged in the petition from the Gaming 

Reg~~latory Commission, upon such findings of fact as may be appropriate. The 

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

be available. 

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

promulgate, subject to review and approval by the Tribal Council, detailed and comprehensive 

regulations for the implementation and enforcer~lent of this Ordinance. Said regulations shall describe 

and establish the rules for each specific Class I1 and Class I11 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 

D. The Gaming Regulatory Commission, independent of the Tribal Council, shall have full 

authority to monitor compliance with this Ordinance and its Regulations. and tc in~restigate and act 

LTBB Gaming Regnl:~to~?. 01.clin;lnce. cn:1ctrcl3-03-1996, p,o 11 
to prevent any violation(s) thereof. The Gaming Regulatory Commission shall have the authority to 

subpoena witnesses and documents if needed to help render licensing and permitting decisions and 

rule on appeals of those decisions. 

E. Subject to the approval of the Tribal Council and the appropriation of knds therefor, the 

Gaming Regulatory Commission shall be authorized to employ such staff as reasonably may be 

required to hlfill 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 governmental gaming regulatory agencies. 

F. Subject to the approval of the Tribal Council, 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 actual 

costs of operating the Gaming Regulatory Commission, enforcing this Ordinance and Gaming 

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

fulfilling 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 to comply with any Commission regulation or order, or any other 

violation of this Ordinance or the terms of any Class 111 gaming compact 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 Reservation, and imposition 

of such other sanctions as the Gaming Regulatory Commission may deem appropriate. 

SECTION XI: RESOLUTlON OF DISPUTES BETWEEN THE GAMING PUBLIC AND 

TRIBE OR MANAGEitlENT 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 hislher 

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 

LTBB Gaming Reguli~tol-y Oldinance, enacted 3-03-1996, pg 12 
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, 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. 

Certification 

As Tribal Chairman and Tribal Secretary, the undersigned cedi@ that this Gaming Regulatory 

Ordinance 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 March 3, 1996, at which a quorum was 

present, by a vote of in favor, O opposed and 0 abstentions as recorded by this roll 

call 

In Favor Opposed Abstained Absent 

George Anthony 

Patricia Dyer-Deckrow 

S 

7 

Frank Ettawareshik / 

Barry Laughlin d 

Shirley Oldman / 

Janet Shomin 

Alice Yellowbank 7 I 

Date 3- 3-/??% b w d0~14~;& 

Frank Ettawageshik, Tribal ~hirman 

LTBB Gaming Regul:~toty Ordinance, enacted 3-03-1996, pc 13