§542.19 What are the minimum internal control standards for accounting? 

Note: It is proposed that “customer” be substituted for “patron” throughout the section 

for consistency. 

(a) Each gaming operation shall prepare accurate, complete, legible, and permanent 

records of all transactions pertaining to revenue and gaming activities. 

(b) Each gaming operation shall prepare general accounting records according to 

Generally Accepted Accounting Principles on using a double-entry system of 

accounting, and shall maintaining detailed, supporting, subsidiary records, including, but 

not limited to: 

(1) Detailed records identifying revenues, expenses, assets, liabilities, and equity for each 

gaming operation; 

(2) Detailed records of all markers, IOU's, returned checks, hold held checks, or other 

similar credit instruments; 

(3) Individual and statistical game records to reflect statistical drop, statistical win, and 

the percentage of statistical win to statistical drop by each table game, and to reflect 

statistical drop, statistical win, and the percentage of statistical win to statistical 

drop for each type of table game, by shift, by day, cumulative month-to-date, and yearto-date, and individual and statistical game records reflecting similar information for all 

other games; 

(4) Gaming machine analysis reports which, by each machine, compare actual hold 

percentages to theoretical hold percentages; 

Comment (July): Strike (5). Accounting record requirements are clearly 

specified in this section, the standard is redundant. 

Response: Disagree. The term “part” refers to accounting record requirements 

contained throughout Part 542, not just in this section. 

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Comment (July): Replace “The” with “Other” to indicate that the standard 

refers to accounting record requirements in other sections of Part 542. 

Response: Agree. Revised accordingly. 

Revised proposal as a result of July comments: 

(5) The Other records required by this part and by the Tribal internal control standards; 

(6) Journal entries prepared by the gaming operation and by its independent accountants; 

and 

(7) Any other records specifically required to be maintained. 

Justification: Revisions proposed to improve language and eliminate repetition. 

Written Comment (March): (b) (5) and (b) (7) appear to be redundant. Please 

clarify the need for having both standards. 

Response: The Committee reviewed the existing regulation and made no 

comment. (b)(5) refers only to records required by 542 and by the TICS. Other 

records could be required to be maintained by any external entity. 

(c) Each gaming operation shall establish administrative and accounting procedures for 

the purpose of determining effective control over a gaming operation's fiscal affairs. The 

procedures shall be designed to reasonably ensure that: 

Comment: (October): Standard is too general, making it difficult to interpret 

and to design compliant policies and procedures. 

Response: Disagree. Subsequent paragraphs (1) – (6) define the standard. 

(1) Assets are safeguarded; 

(2) Financial records are accurate and reliable; 

(3) Transactions are performed only in accordance with management's general and 

specific authorization; 

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(4) Transactions are recorded adequately to permit proper reporting of gaming revenue 

and of fees and taxes, and to maintain accountability of assets; 

Comment (March): Replace “taxes” with “assessments”. 

Response: The Committee reviewed the existing regulation and made no 

comment. In this context the standard is referring to excise taxes on certain types 

of gaming revenue. 

Note (May): Although the word “taxes” is limited to taxes on specific types of 

gaming revenue, the word could cause confusion and therefore it is recommended 

to be struck. 

Proposed revision incorporating May note: 

(4) Transactions are recorded adequately to permit proper reporting of gaming revenue 

and of fees and taxes, and to maintain accountability of assets; 

(5) Recorded accountability for assets is compared with actual assets at reasonable 

intervals, and appropriate action is taken with respect to any discrepancies; and 

(6) Functions, duties, and responsibilities are appropriately segregated in accordance with 

sound business practices. 

(d) Gross gaming revenue computations. (1) For table games, gross revenue equals the 

closing table bankroll, plus credit slips for cash, chips, tokens or personal/payroll checks 

returned to the cage, plus drop, less opening table bankroll and fills to the table, and 

money transfers issued from the game through the use of a cashless wagering system. 

(2) For gaming machines, gross revenue equals drop, less fills, jackpot payouts and 

personal property awarded to patrons as gambling winnings. Additionally, the initial 

hopper load is not a fill and does not affect gross revenue. The difference between the 

initial hopper load and the total amount that is in the hopper at the end of the gaming

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operation's fiscal year should be adjusted accordingly as an addition to or subtraction 

from the drop for the year. 

(3) For each counter game, gross revenue equals: 

(i) The money accepted by the gaming operation on events or games that occur during the 

month or will occur in subsequent months, less money paid out during the month to 

patrons customers on winning wagers (“cash basis”); or 

(ii) The money accepted by the gaming operation on events or games that occur during 

the month, plus money, not previously included in gross revenue, that was accepted by 

the gaming operation in previous months on events or games occurring in the month, less 

money paid out during the month to patrons customers as winning wagers (“modified 

accrual basis”). 

(4) For each card game and any other game in which the gaming operation is not a party 

to a wager, gross revenue equals all money received by the operation as compensation for 

conducting the game. 

(i) A gaming operation shall not include either shill win or loss in gross revenue 

computations. 

(ii) [Reserved].

(5) (ii) In computing gross revenue for gaming machines, keno and bingo, the actual cost 

to the gaming operation of any personal property distributed as losses to patrons may be 

deducted from winnings (other than costs of travel, lodging, services, food, and 

beverages), if the gaming operation maintains detailed documents supporting the 

deduction. 

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Justification: This is considered a formatting correction as the standard in question does 

not belong under (4) but is a standalone requirement under (f). 

 Note: On review, strike portions of paragraph not applicable to class III games. 

Revised proposal incorporating note: 

(5) In computing gross revenue for gaming machines, keno and bingo, the actual cost to 

the gaming operation of any personal property (other than costs of travel, lodging, 

services, food, and beverages) awarded as a payout to customers may be deducted if the 

gaming operation maintains detailed documents supporting the deduction. 

(e) Each gaming operation shall establish internal control systems sufficient to ensure that 

currency (other than tips or gratuities) received from a patron customer in the gaming

area is promptly placed in a locked box in the table, or, in the case of a cashier, in the 

appropriate place in the cashier's cage, or on those games which do not have a locked 

drop box, or on card game tables, in an appropriate place on the table, in the cash register 

or in another approved repository. 

(f) If the gaming operation provides periodic payments to satisfy a payout resulting from 

a wager, the initial installment payment, when paid, and the actual cost of a payment 

plan, which is funded by the gaming operation, may be deducted from winnings. The 

gaming operation is required to obtain the approval of all payment plans from the TGRA

Tribal gaming regulatory authority. For any funding method which merely guarantees 

the gaming operation's performance, and under which the gaming operation makes 

payments out of cash flow (e.g. irrevocable letters of credits, surety bonds, or other 

similar methods), the gaming operation may only deduct such payments when paid to the 

patron. 

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(g) For payouts by wide-area progressive gaming machine systems, a gaming 

operation may deduct from winnings only its pro rata share of a wide-area gaming 

machine system payout. 

Justification: This subsection is proposed for removal because it is being replaced by 

item (j) (5) in this section which provides clarification of the deduction allowed. 

(g)(h) Cash-out tickets issued at a gaming machine or gaming device shall be deducted 

from gross revenue as jackpot payouts in the month the tickets are issued by the gaming

machine or gaming device. Tickets deducted from gross revenue that are not redeemed 

within a period, not to exceed 180 days of issuance, shall be included in gross revenue. 

An unredeemed ticket previously included in gross revenue may be deducted from gross 

revenue in the month redeemed. 

(h)(i) A gaming operation may not deduct from gross revenues the unpaid balance of a 

credit instrument extended for purposes other than gaming. 

(i)(j) A gaming operation may deduct from gross revenue the unpaid balance of a credit 

instrument if the gaming operation documents, or otherwise keeps detailed records of, 

compliance with the following requirements. Such records confirming compliance shall 

be made available to the TGRA Tribal gaming regulatory authority or the 

Commission upon request: 

(1) The gaming operation can document that the credit extended was for gaming

purposes; 

(2) The gaming operation has established procedures and relevant criteria to evaluate a 

patron’s customer’s credit reputation or financial resources and to then determine that 

there is a reasonable basis for extending credit in the amount or sum placed at the 

patron’s customer’s disposal; 

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(3) In the case of personal checks, the gaming operation has established procedures to 

examine documentation, which would normally be acceptable as a type of identification 

when cashing checks, and has recorded the patron’s customer’s bank check guarantee 

card number or credit card number, or has satisfied paragraph (j) (i) (2) of this section, as 

management may deem appropriate for the check-cashing authorization granted; 

(4) In the case of third-party checks for which cash, chips, or tokens have been issued to 

the patron customer, or which were accepted in payment of another credit instrument, 

the gaming operation has established procedures to examine documentation, normally 

accepted as a means of identification when cashing checks, and has, for the check's maker 

or drawer, satisfied paragraph (j) (i) (2) of this section, as management may deem 

appropriate for the check-cashing authorization granted; 

(5) In the case of guaranteed drafts, procedures should be established to ensure 

compliance with the issuance and acceptance procedures prescribed by the issuer; 

(6) The gaming operation has established procedures to ensure that the credit extended is 

appropriately documented, not least of which would be the patron’s customer’s

identification and signature attesting to the authenticity of the individual credit 

transactions. The authorizing signature shall be obtained at the time credit is extended. 

(7) The gaming operation has established procedures to effectively document its attempt 

to collect the full amount of the debt. Such documentation would includes, but is not be

limited to, letters sent to the patron customer, logs of personal or telephone 

conversations, proof of presentation of the credit instrument to the patron’s customer’s

bank for collection, settlement agreements, or other documents which demonstrate that 

the gaming operation has made a good faith attempt to collect the full amount of the debt. 

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Such records documenting collection efforts shall be made available to the TGRA Tribal 

gaming regulatory authority or the Commission upon request. 

(j) Deductions from gross revenue. 

Comment: (July): The subsection is entitled deductions, but the first standard 

names non-deductible items. 

Response: Agree and will re-title the subsection. 

Revised proposal as a result of July comment: 

(j) Allowable and non-allowable deductions from gross revenue.(1) Any prizes, 

premiums, drawings, benefits or tickets that are redeemable for money or 

merchandise or other promotional allowance, except money or tokens paid at face 

value or the cost of personal property awarded directly to a customer as the result 

of a specific wager, must not be deducted. 

(2) Cash paid to fund periodic payments may be deducted.

(3) For gaming machines, keno, and bingo, the actual cost of any personal property 

distributed to a customer as the result of a specific legitimate wager may be 

deducted, but not travel expenses, food, refreshments, lodging, or services.

Note: On review, strike portions of paragraph not applicable to class III games. 

Revised proposal incorporating note: 

(3) For gaming machines and keno, the actual cost of any personal property 

distributed to a customer as the result of a specific legitimate wager may be 

deducted, but not travel expenses, food, refreshments, lodging, or services.

(4) A gaming operation that provides a customer with additional play at bingo as 

the result of an initial wager may deduct all money or tokens paid directly to that 

customer as a result of such additional play.

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Note: On review, strike paragraph - not applicable to class III games.

Revised proposal incorporating note: 

(4) A gaming operation that provides a customer with additional play at bingo as 

the result of an initial wager may deduct all money or tokens paid directly to that 

customer as a result of such additional play.

(4) A gaming operation may deduct its pro-rata share of a payout from a game 

played in a wide area linked system except for a payout made in conjunction with a 

card game. The amount of the deduction must be determined based upon the 

written agreement among the gaming establishments participating in the wide area 

linked system and the operator of the system. All cash prizes and the value of 

noncash prizes awarded during a contest or tournament conducted in conjunction 

with a wide area linked system are also deductible on a pro-rata basis to the extent 

of the compensation received for the right to participate in that contest or 

tournament. 

Comment (July): The reason for exclusion of payouts made in conjunction with 

a card game is not evident. Recommend striking this exclusion. 

Response: Disagree. The payouts arising from card games are not deductible 

from revenue because revenue from card games consists of compensation for the 

conduct of the game (rake) only.

 Comment (March): Please clarify why there is a “card game” reference in this

 proposed standard? Is there a linked system or WAP for card games? 

Response: The Committee reviewed the proposed revision and made no 

comment. The possibility exists for wide area linked poker games and for that 

reason the standard recognizes that the house has no interest in the payout that 

might arise from that operation and therefore, it would not be deductible. 

(5) Deductibility of free play and promotional items: 

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Justification: The NIGC has received frequent questions regarding the deductibility of 

certain items from gross revenue. The proposed additions address this issue in detail, 

consistent with Generally Accepted Accounting Principles (GAAP) and regulations of 

established gaming jurisdictions. 

Comment (July): Recommend formatting (j) (5) as a matrix or chart. 

Response: Agree and will re-format for Committee review. 

Note: This subsection was originally written in a narrative format. However, based on 

the Committee’s suggestion, it was reformatted as a matrix to facilitate readability. 

Comment (July): Recommend structuring (j) (5) as separate deductible and nondeductible segments for easier reference. 

Response: Disagree. The revised format will address this concern. 

(5) Deductibility of free play and promotional items:

(i) Gaming machines 

(A) Free pulls on a promotional gaming 

machine or other gaming device

No effect on drop and no deduction of 

payouts 

(B) Free pulls on a gaming machine No effect on drop and all payouts 

deductible 

(C) Free play wagering (negotiable, including 

free coin/tokens) if distinguishable and 

accounted for separately in the drop 

No effect on drop and all payouts 

deductible 

(D) Free play wagering (non-negotiable) No effect on drop for free play and all 

payouts deductible 

(E) Gaming machine negotiable wagering 

credits (If tracked electronically when wagered) 

No effect on drop and all payouts 

deductible 

(F) Gaming machine negotiable wagering 

credits (If not tracked electronically when 

wagered) 

Add cash value to drop and all payouts 

deductible 

(G) Non-cash prizes awarded for winning 

wagers 

Cost to gaming operation deductible 

Written comment: We recommend 

changing “cost” to “fair market value” 

in order to be consistent with IRS 

reporting requirements. 

Response: The Committee reviewed 

the proposed revision and made no 

comment. The MICS are not intended 

to address IRS income-reporting 

requirements. If the fair market value 

is greater than the cost, that issue falls 

outside the scope of the MICS. The 

standard is Intended to address the cost 

of the transaction to the casino.

(H) Premium points awarded in accordance Cash or cost of prizes for redeemed 

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with a payout schedule as the result of a 

winning wager 

points deductible (Appropriate tracking 

and documentation required) 

(I) Premium points not awarded in accordance 

with a payout schedule or as the result of a 

winning wager 

Cash or cost of prizes for redeemed 

points not deductible 

(J) Promotional activity reimbursed by an 

external party 

Written comment: Propose the following 

wording “Promotional activity in connection 

with a wager that is reimbursed by an external 

party.” 

Response: The Committee reviewed the 

proposed revision and made no comment.

Based on the context of the standard, it is selfevident that pertains it pertains to a wager.

Total amount wagered included in drop 

and all payouts deductible 

(K) Gold or silver coins paid out (legal tender) Purchase cost to gaming operation 

deductible 

(L) Gold or silver tokens paid out (not legal 

tender) 

Face value deductible 

(M) Tournaments/contests/drawings Include total amount received in drop 

and payouts deductible (limited to 

amount received) 

(N) Bonus payouts Bonus payouts resulting from a 

winning wager deductible 

(O) Mystery jackpots (Only if selected by 

random number generator) 

Written Comment: Please explain the purpose 

and intent of this statement. 

Response: The Committee reviewed the 

proposed revision and made no comment. 

The parenthetical is intended to preclude the 

applicability to mystery jackpots that are paid 

out as a result of a predetermined sequence or 

routine such as promotional payouts unrelated 

to the specific machine.

All mystery jackpot payouts reflected 

on the payout schedule deductible 

(P) Appeasement payouts (payments made on 

non-winning wagers in response to customer 

complaints) 

Not deductible 

(ii) Table Games 

(A) Match play (e.g., wager five dollars and 

receive a ten dollar bet) 

Include cash received in drop and all 

payouts deductible 

(B) Discount wagering (negotiable) Discounted dollar amount (if 

distinguishable) included in drop and 

all payouts deductible 

(C) Discount wagering (non-negotiable) Discounted dollar amount included in 

drop and all payouts deductible 

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(D) Free play wagering (negotiable) If distinguishable, no effect on drop, 

all payouts deductible 

(E) Free play wagering (non-negotiable) No effect on drop and all payouts 

deductible 

(F) Promotional activity reimbursed by an 

external party 

Total amount wagered included in drop 

and all payouts deductible 

(G) Tournaments/contests/drawings Include total amount received in drop 

and payouts deductible (limited to 

amount received) 

(H) Tournaments which include purchase and 

redemption of negotiable chips. 

Written Comment: Please explain this 

statement. This may conflict with the definition 

of net revenue in IGRA; what is the effect of 

this statement on a player’s pool?

Written Comment: An example would be 

Blackjack played in tournament format. The 

game is played against the house Whichever 

player has the most chips at a predetermined 

time, wins the prize. No conflict with the 

definition of net revenue. There would be no 

effect on player’s pools as they have the same 

treatment as any other table game. 

Include total amount wagered in drop, 

payouts deductible, tournament prizes 

not deductible

(iii) Card Games 

(A) Buy-in coupons (e.g., $25 in chips for $20 

buy-in) 

No effect on revenue

Written Comment: Does “no effect 

on revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(B) Tournaments played with negotiable chips 

and rake is taken 

Rake is included in revenue 

(C) Tournaments played with non-negotiable 

chips, contests and drawings 

No effect on revenue

Written Comment: Does “no effect 

on revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(D) Prizes (e.g., $100 prize for high hand of the 

week) 

No effect on revenue

Written Comment: Does “no effect 

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on revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(E) Promotional progressive pot and/or pool 

payouts 

No effect on revenue

Written Comment: Does “no effect 

on revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(F) Shill wins and losses No effect on revenue

Written Comment: Does “no effect 

on revenue” mean deductible or nondeductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. Card game revenue is 

derived from the rake. Therefore it is 

neither deductible nor non-deductible. 

(iv) Keno 

(A) Match play/discount wagering only Include cash received in write, all 

payouts deductible 

(B) Free play wagering (negotiable and nonnegotiable) No effect on write, all payouts 

deductible 

Written Comment: Does “no effect 

on revenue” (sic) mean deductible or 

non-deductible? 

Response: The Committee reviewed 

the proposed revision and made no 

comment. The comment has no 

relevance to the standard. 

(C) Non-cash prizes awarded for winning 

wagers 

Cost to gaming operation deductible 

Written comment: We recommend 

changing “cost” to “fair market value” 

in order to be consistent with IRS 

reporting requirements. 

Response: The Committee reviewed 

the proposed revision and made no 

comment. The MICS are not intended 

to address IRS income-reporting 

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requirements. If the fair market value 

is greater than the cost, that issue falls 

outside the scope of the MICS. The 

standard is Intended to address the cost 

of the transaction to the casino. 

(D) Promotional activity reimbursed by 

external party 

Include total amount in write, all 

payouts deductible 

(E) Tournaments/contests/drawings No effect on write unless part of wide 

area linked system 

(F) Tournaments which include elements of a 

normal wager 

Include total amount wagered in write, 

all payouts deductible, tournament 

prizes not deductible 

(G) Appeasement payouts (payments made on 

non-winning tickets in response to customer 

complaints) 

Not deductible 

(v) Pull Tabs 

(A) Match play/discount wagering Include cash received in sales and all 

payouts deductible 

(B) Free play wagering (negotiable and nonnegotiable) No effect on sales and all payouts 

deductible 

(C) Non-cash prizes Include cash received in sales and 

purchase cost of prizes deductible 

(D) Promotional activity reimbursement by 

external party 

Include cash received in sales and all 

payouts deductible 

(E) Appeasement payouts (payments made on 

non-winning pull tabs in response to customer 

complaints) 

Not deductible 

(vi) Baccarat 

Uncollected baccarat commission No effect on drop 

Written Comment: Deductible or Not 

Deductible? Response: The Committee 

reviewed the proposed revision and 

made no comment. Because there is no 

effect on the drop, the comment is 

erroneous.

(i) Gaming machines:

(A) Free pulls on a promotional gaming machine or other gaming device - No effect 

on drop and no deduction of payouts.

Comment (July): Strike the phrase “or other gaming device” as overly broad and 

unclear. 

Response: Agree. 

Revised proposal (j) (5) (i) (A) as a result of July comment: Change incorporated in 

matrix (above). 

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(H) Premium points awarded in accordance with a payout schedule as the result of a 

winning wager – Cash or cost of prizes for redeemed points deductible. Appropriate 

tracking and documentation required.

Comment (July): Deductibility could provide incentive for a gaming operation to 

award only premium points for winning wagers in place of points for all wagers. 

Response: Disagree. The desirability of deductible premium points is 

outweighed by the benefits associated with a player club point system based on 

amount wagered. 

Comment (July): Deductibility of gaming machine appeasement payouts should 

also be addressed in matrix. 

Response: Agree. 

Revised proposal (j) (5) (i) (P) as a result of July comments: Change incorporated in 

matrix (above). 

(ii) (H) Tournaments which include elements of a normal wager – Include total 

amount wagered in drop, payouts deductible, tournament prizes not deductible.

Comment (July): “Elements of a normal wager” is not clearly defined or 

understood. 

Response: Agree. 

Revised proposal (j) (5) (ii) (H) as a result of July comments: Change incorporated in 

matrix (above). 

(iii) Card Games:

(A) Buy-in coupons ($22 in chips for $20 buy-in) – No effect on revenue.

Comment (July): Identify contents within parentheses as an example by 

preceding with “e.g.” 

Response: Agree. 

Revised proposal (j) (5) (iii) (A) as a result of July comments: Change incorporated in 

matrix (above). 

Comment (July): $25 for $20 is a more realistic example. 

Response: Agree. 

Revised proposal (j) (5) (iii) (A) as a result of July comments: Change incorporated in 

matrix (above). 

(7) Credit instruments written off as uncollectible are deductible unless any of the 

following applies:

Comment (July): The standards for deductibility of credit instruments represent 

an intrusion on tribal authority. 

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Response: Disagree. The standards are currently silent on the subject. These 

new standards clarify that uncollectible gaming credit instruments, with few 

exceptions, are deductible, allowing the gaming operation to avoid paying NIGC 

fees on such amounts. 

Written Comment (March): Why is there no counterpart in 542 to 543.19 (j) 

(7)? 

Response: Scrivener error. Corrected below. 

Correction as a result of March comment: 

(6) Credit instruments written off as uncollectible are deductible unless any of the 

following applies: 

(i) The instrument was not signed by the patron; 

(ii) The gaming operation did not have an address for the patron at the time of accepting 

the instrument; 

(iii) The gaming operation does not maintain evidence that it has made a reasonable effort 

to collect the debt; 

(iv) The gaming operation does not maintain evidence that it checked the credit history of 

the patron before extending the credit; 

(v) The signature of the patron on the instrument was forged and the gaming operation 

has not made a written report of the forgery to the appropriate law enforcement agency; 

or 

(vi) The gaming operation is unable to produce the credit instrument within a reasonable 

time after a request by the Commission. (Note: However, this shall not pertain to 

circumstances beyond the control of the gaming operation e.g., custody of court, stolen, 

etc.) 

(k) Maintenance and preservation of books, records, and documents. (1) All original 

books, records, and documents pertaining to the conduct of wagering activities shall be 

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retained by a gaming operation in accordance with the following schedule. A record that 

summarizes gaming transactions is sufficient, provided that all documents containing an 

original signature(s) attesting to the accuracy of a gaming related transaction are 

independently preserved. Original books, records, or documents shall not include copies 

of originals, except for copies that contain original comments or notations on parts of 

multi-part forms. The following original books, records, and documents shall be retained 

by a gaming operation for a minimum of five (5) years: 

(i) Casino cage documents; 

(ii) Documentation supporting the calculation of table game win; 

(iii) Documentation supporting the calculation of gaming machine win; 

(iv) Documentation supporting the calculation of revenue received from the games of 

keno, pari-mutuel, bingo, pull-tabs, card games, and all other gaming activities offered by 

the gaming operation; 

 Note: On review, strike portions of paragraph not applicable to class III games. 

Revised proposal incorporating note: 

(iv) Documentation supporting the calculation of revenue received from the games of 

keno, pari-mutuel, bingo, pull-tabs (if applicable), card games, and all other gaming

activities offered by the gaming operation; 

(v) Table games statistical analysis reports; 

(vi) Gaming machine statistical analysis reports; 

(vii) Bingo, pull-tab, keno, and pari-mutuel wagering statistical reports; 

 Note: On review, strike portions of paragraph not applicable to class III games. 

Revised proposal incorporating note: 

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(vii) Bingo, Ppull-tab (if applicable), keno and pari-mutuel wagering statistical reports; 

(viii) Internal audit documentation and reports; 

Written Comment (March): Recommend deleting “documentation” from 

this standard as the entity that conducts the internal audit will have to 

comply with the internal audit portion of the MICS. This will vary from 

one jurisdiction to another. 

Response: The Committee reviewed the standard and had no comment. 

Disagree. Removing the reference to documentation would imply that only 

the report needs to be retained for five years.

(ix) Documentation supporting the write-off of gaming credit instruments and named 

credit instruments; 

(x) All other books, records, and documents pertaining to the conduct of wagering 

activities that contain original signature(s) attesting to the accuracy of the gaming related 

transaction. 

(2) Unless otherwise specified in this part, all other books, records, and documents shall 

be retained until such time as the accounting records have been audited by the gaming

operation's independent certified public accountants. 

(3) The above definition shall apply without regards to the medium by which the book, 

record or document is generated or maintained (paper, computer-generated, magnetic 

media, etc.). 

Comment (March): Replace “definition” with “standard”. 

Response: The Committee reviewed the existing language and made no 

comment. Disagree. “Definition” refers to (k) (1) “original books, records and 

documents” not to the standards for retention. 

Written Comment (March): Replace “definition” with “standard”. 

Response: The Committee reviewed the proposed revision and had no comment. 

Disagree with comment. “Definition” refers to original books, records and 

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documents” not to the standards for retention. This comment has no bearing on 

the transition from 542 to 543. 

Note (May): As a result of the discussion during the conference call, it was 

decided to substitute “standards” for “definition” to improve clarity. 

(3) The above definition standards shall apply without regard to the medium by which 

the book, record or document is generated or maintained (paper, computer-generated, 

magnetic media, etc.). 

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