§543.41 What are the minimum internal control standards for drop and count for Tier 

C gaming operations? 

(a) Computer applications. For any computer applications utilized, alternate 

documentation and/or procedures that provide at least the level of control described by 

the standards in this section, as approved by the Tribal gaming regulatory authority in 

writing, will be acceptable. 

(b) Card game drop standards. (1) The setting out of empty card game drop boxes and 

the drop shall be a continuous process. The drop begins with the removal of the first card 

game drop box; however, empty drop boxes are not required to be placed on tables that 

are inactive at the time of the drop. 

(2) At the end of each shift: 

(i) All locked card game drop boxes shall be removed from the tables by a person 

independent of the card game shift being dropped; 

(ii) A separate drop box shall be placed on each table opened at any time during each 

shift or a gaming operation may utilize a single drop box with separate openings and 

compartments for each shift; and 

(iii) Upon removal from the tables, card game drop boxes shall be transported directly to 

the count room or other equivalently secure area with comparable controls and locked in 

a secure manner until the count takes place. 

(3) If drop boxes are not placed on all tables, then the card game department shall 

document which tables were open during the shift. 

(4) The transporting of card game drop boxes shall be performed by a minimum of two 

persons, at least one of whom is independent of the card game shift being dropped. 

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(5) All card game drop boxes shall be posted with a number corresponding to a 

permanent number on the gaming table and marked to indicate game, table number, and 

shift. 

Written Comment (March): As a result of the section (b) (1) being revised, we 

recommend removing the requirement of the drop boxes being marked according 

to shift. If not please provide clarification on this section 

If this requirement is deleted from this section, there may still be 2 sets of boxes 

that will be used during the course of any given game day; one set of boxes will 

be counted at the end of a shift and the second set of boxes will be on the open 

tables. 

Response: The Committee reviewed (b) and did not have any comments 

pertaining to subsection (b)(5). The comment has no bearing on the transition 

from 542 to 543.

Note (May): Following discussion during the conference call, the decision was 

made to add “if applicable” following “shift” due to the fact that an increasing 

number of gaming operations are using a single box for a twenty-four shift. 

Proposed revision incorporating May note: 

(5) All card game drop boxes shall be posted with a number corresponding to a 

permanent number on the gaming table and marked to indicate game, table number, and 

shift, if applicable. 

(6) Surveillance shall be notified when the drop is to begin so that surveillance may 

monitor the activities. 

(c) Soft count room personnel. (1) The card game soft count and the player interface 

financial instrument storage component count shall be performed by a minimum of three 

individuals. 

Written Comment (March): What is the rationale for using the term “employee” 

in 542 and “individual” in 543? 

Response: We will revise for consistency. 

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Proposed revision as a result of March written comment: 

(1) The card game soft count and the player interface financial instrument storage 

component count shall be performed by a minimum of three individuals employees. 

(2) Count room personnel shall not be allowed to exit or enter the count room during the 

count except for emergencies or scheduled breaks. At no time during the count, shall 

there be fewer than three individuals in the count room until the drop proceeds have been 

accepted into cage/vault accountability. Surveillance shall be notified whenever count 

room personnel exit or enter the count room during the count. 

(3) Count team members shall be rotated on a routine basis such that the count team is 

not consistently the same three persons more than four (4) days per week. This standard 

shall not apply to gaming operations that utilize a count team of more than three persons. 

(4) The count team shall be independent of transactions being reviewed and counted. 

The count team shall be independent of the cage/vault departments; however, an 

accounting representative may be used if there is an independent audit of all soft count 

documentation. 

(5) All coin, tokens, chips and/or cash inventory stored in the count room shall be secured 

from unauthorized access at all times. 

(d) Card game soft count standards. (1) The card game soft count shall be performed in a 

soft count room or other equivalently secure area with comparable controls. 

(2) Access to the count room during the count shall be restricted to members of the drop 

and count teams, with the exception of authorized observers, supervisors for resolution of 

problems, and authorized maintenance personnel. 

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(3) If counts from various revenue centers occur simultaneously in the count room, 

procedures shall be in effect that prevent the commingling of funds from different 

revenue centers. 

(4) Immediately prior to the count at least two count team members shall verify the 

accuracy of the currency counter with previously counted currency for each 

denomination (i.e., test currency). The test currency shall be counted by the currency 

counter to ensure that the counter is functioning properly. The test results shall be 

documented and maintained. 

(i) The currency counter test shall be performed with test currency rather than with 

currency from a drop box. 

(ii) If the same currency counter is used for one revenue center (e.g., gaming or 

nongaming revenue center) and then immediately used for a second revenue center, 

performing the currency counter test once will satisfy the standard provided the same 

count team members complete one count and then proceed to the other revenue center 

count. 

(5) The card game drop boxes shall be individually emptied and counted in such a 

manner to prevent the commingling of funds between boxes until the count of the box has 

been recorded. 

(i) The count of each box shall be recorded in ink or other permanent form of recordation. 

(ii) For counts that do not utilize a currency counter, a second count shall be performed 

by a member of the count team who did not perform the initial count. Separate counts of 

chips and tokens must always be performed by members of the count team. 

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(iii) Coupons or other promotional items not included in gross revenue may be recorded 

on a supplemental document by either the count team members or accounting personnel. 

All single-use coupons shall be cancelled daily by either the count team members or 

accounting personnel to prevent improper recirculation. 

(iv) If a currency counter interface is used: 

(A) It shall be adequately restricted (e.g., password, keys, etc.) so as to prevent 

unauthorized access. 

(B) The currency drop figures shall be transferred via direct communications line or 

computer storage media to the accounting department. 

543.41 (d) (6) has been moved to proposed 543.50 Revenue Audit. 

(6) Unannounced currency counter and currency counter interface (if applicable) 

tests shall be performed by personnel independent of the cage, vault, count team, 

and card games departments on at least a quarterly basis with the test results 

documented and maintained. All denominations of currency and vouchers counted 

by the currency counter must be tested. This test may be performed by internal 

audit or the Tribal gaming regulatory authority. The result of these tests shall be 

documented and signed by the person or persons performing the test.

(6) If currency counters are utilized and the count room table is used only to empty boxes 

and sort/stack contents, a count team member shall be able to observe the loading and 

unloading of all currency at the currency counter, including rejected currency. The count 

team member operating the currency counter does not need to be monitored by another 

count team member if an individual independent of the count process monitors the 

operator of the currency counter on an unannounced basis for a minimum of one hour 

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during the count process from recorded or live surveillance at least monthly. The date, 

time, and results of the independent observation shall be documented. 

(7) When the currency counter rejects currency (re-run of rejected currency is 

permissible) but does not record the amount of rejected currency, procedures shall be 

developed and implemented to record the rejected currency amount by table and to 

ensure that two counts of the rejected currency (by table and in total) are performed to 

ensure the correct amount of the drop is recorded on the count sheet. Posting rejected 

currency to a nonexistent “dummy” table is prohibited. 

(8) Card game drop boxes, when empty, shall be shown to another member of the count 

team, or to another person who is observing the count, or to surveillance, provided the 

count is monitored in its entirety by a person independent of the count. 

(9) Pit marker issue and payment slips (if applicable) removed from the card game drop 

boxes shall either be: 

(i) Traced to or recorded on the count sheet by the count team; or 

(ii) Totaled by shift and traced to the totals documented by the computerized system. 

Accounting personnel shall verify the issue/payment slip for each table is accurate. 

Written Comment (March): The use of the term “pit marker” in 543 is a Class 

III term; we recommend using the term “marker”. 

Response: The reference will be stricken. This represents an error in transition 

from 542 to 543. 

Corrected proposal as a result of March written comment: 

(9) Pit marker issue and payment slips (if applicable) removed from the card game 

drop boxes shall either be:

(i) Traced to or recorded on the count sheet by the count team; or

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(ii) Totaled by shift and traced to the totals documented by the computerized 

system. Accounting personnel shall verify the issue/payment slip for each table is 

accurate.

(9) To correct errors in soft count documentation, a single line shall be drawn through the 

error, and the correct figure entered above the original figure. The correction shall be 

initialed by at least two count team members verifying the change. If a currency interface 

is used, corrections to card games count data shall be made using one of the following: 

(i) Draw a single line through the error on the card games document, and write the correct 

figure above the original figure. The correction must then be initialed by the two count 

team members verifying the change. If this procedure is used, an individual independent 

of the card games department and count team shall enter the correct figure into the 

computer system prior to the generation of related card games reports; or 

(ii) During the count process, correct the error in the computer system and enter the 

passwords of at least two count team members. If this procedure is used, an exception 

report shall be generated by the computer system identifying the table number, the error, 

the correction, and the count team members attesting to the correction. 

(iii) If the computer system does not allow corrections as specified in (ii), management 

shall develop and implement alternative procedures for documenting corrections to the 

soft count records and communicating the information to the accounting department. 

(10) The count sheet shall be reconciled to the total drop by a count team member who 

shall not function as the sole recorder, and variances shall be reconciled and documented. 

(11) All members of the count team shall sign the count document or a summary report to 

attest to their participation in the count. 

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(12) All drop proceeds and cash equivalents that were counted shall be turned over to the 

cage or vault cashier (who shall be independent of the count team) or to an authorized 

person/individual independent of the revenue generation and the count process for 

verification. Such person shall certify by signature as to the amount of the drop proceeds 

delivered and received. It is recommended that the individual performing the verification 

count be precluded from having prior knowledge of the results of previous count 

performed by count team personnel. Any unresolved variances shall be reconciled, 

documented, and/or investigated by accounting/revenue audit. 

(13) The count sheet, with all supporting documents, shall be delivered to the accounting 

department by a count team member or a person independent of the cashiers department. 

Alternatively, it may be adequately secured (e.g., locked container to which only 

accounting personnel can gain access) until retrieved by the accounting department. 

(14) The cage/vault person shall sign the count sheet, or other reconciling document, and 

thereby assume accountability of the currency drop proceeds, ending the count. 

(15) Access to stored, full card game drop boxes shall be restricted to authorized 

members of the drop and count teams. 

(e) Player interface financial instrument storage component drop standards. (1) A 

minimum of three individuals shall be involved in the removal of the player interface 

storage component drop, at least one of whom is independent of the player interface 

department. 

(2) All financial instrument storage components shall be removed only at the time 

previously designated by the gaming operation and reported to the Tribal gaming 

regulatory authority, except for emergency drops. 

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(3) Surveillance shall be notified when the drop is to begin so that surveillance may 

monitor the activities. The player interface financial instrument storage component drop 

begins when the first financial instrument storage component is removed. 

(4) The financial instrument storage components shall be removed by a person 

independent of the player interface department then transported directly to the count 

room or other equivalently secure area with comparable controls and locked in a secure 

manner until the count takes place. 

(i) Security shall be provided over the financial instrument storage components removed 

from the player interfaces and awaiting transport to the count room. 

(ii) The transporting of financial instrument storage components shall be performed by a 

minimum of two persons, at least one of whom is independent of the player interface 

department. 

(5) All financial instrument storage components shall be posted with a number 

corresponding to a permanent number on the player interface. 

(f) Player interface financial instrument storage component count standards. (1) The 

player interface financial instrument storage component count shall be performed in a 

soft count room or other equivalently secure area with comparable controls. 

(2) Access to the count room during the count shall be restricted to members of the drop 

and count teams, with the exception of authorized observers, supervisors for resolution of 

problems, and authorized maintenance personnel. 

(3) If counts from various revenue centers occur simultaneously in the count room, 

procedures shall be in effect that prevent the commingling of funds from different 

revenue centers. 

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(4) The count team shall not have access to bill-in meter amounts until after the count is 

completed and the drop proceeds are accepted into the cage/vault accountability. A count 

team member is allowed to read/record the amount from the bill-in meters provided the 

count team members do not have knowledge of the dollar amount of currency contained 

in the currency acceptor drop boxes pursuant to the bill-in meters during the count 

process.

Written Comment (March): Need to use “financial instrument storage 

component” rather than “currency acceptor drop box”. 

Response: Agree. Scrivener error. Will be corrected. 

Corrected proposal as a result of March written comment: 

(4) The count team shall not have access to bill-in meter amounts until after the count is 

completed and the drop proceeds are accepted into the cage/vault accountability. A count 

team member is allowed to read/record the amount from the bill-in meters provided the 

count team members do not have knowledge of the dollar amount of currency contained 

in the currency acceptor drop boxes financial instrument storage components 

pursuant to the bill-in meters during the count process. 

(5) Immediately prior to the count at least two count team members shall verify the 

accuracy of the currency counter with previously counted currency for each 

denomination (i.e., test currency). The test currency shall be counted by the currency 

counter to ensure the counter is functioning properly. The test results shall be 

documented and maintained. 

(i) The currency counter test shall be performed with test currency rather than with 

currency from a financial instrument storage component. 

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(ii) If the same currency counter is used for one revenue center (e.g., gaming or 

nongaming revenue center) and then immediately used for a second revenue center, 

performing the currency counter test once will satisfy the standard provided the same 

count team members complete one count and then proceed to the other revenue center 

count. 

(6) If a currency counter interface is used: 

(i) It shall be adequately restricted (e.g., password, keys, etc.) so as to prevent 

unauthorized access). 

(ii) The currency drop figures shall be transferred via direct communications line or 

computer storage media to the accounting department. 

543.41 (f) (7) has been moved to proposed 543.50 Revenue Audit. 

(7) Unannounced currency counter and currency counter interface (if applicable) 

tests shall be performed by personnel independent of the cage, vault, count team, 

and player interface departments on at least a quarterly basis with the test results 

documented and maintained. All denominations of currency and vouchers counted 

by the currency counter must be tested. This test may be performed by internal 

audit or the Tribal gaming regulatory authority. The result of these tests shall be 

documented and signed by the person or persons performing the test.

(7) The financial instrument storage components shall be individually emptied and 

counted in such a manner to prevent the commingling of funds between storage 

components until the count of the storage component has been recorded. 

(i) The count of each storage component shall be recorded in ink or other permanent form 

of recordation. 

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(ii) [Reserved] 

(8) If currency counters are utilized and the count room table is used only to empty 

financial instrument storage components and sort/stack contents, a count team member 

shall be able to observe the loading and unloading of all currency at the currency counter, 

including rejected currency. The count team member operating the currency counter does 

not need to be monitored by another count team member if an individual independent of 

the count process monitors the operator of the currency counter on an unannounced basis 

for a minimum of one hour during the count process from recorded or live surveillance at 

least monthly. The date, time, and results of the independent observation shall be 

documented. 

(9) When the currency counter rejects currency (re-run of rejected currency is 

permissible) but does not record the amount of rejected currency, procedures shall be 

developed and implemented to record the rejected currency amount, by player interface, 

and to ensure that two counts of the rejected currency (by player interface and in total) 

are performed to ensure the correct amount of the drop is recorded on the count sheet. 

Posting rejected currency to a nonexistent “dummy” player interface is prohibited. 

(10) Storage components, when empty, shall be shown to another member of the count 

team, to another person who is observing the count, or to surveillance, provided that the 

count is monitored in its entirety by a person independent of the count. 

(11) To correct errors in soft count documentation, a single line shall be drawn through 

the error, and the correct figure entered above the original figure. The correction shall be 

initialed by at least two count team members verifying the change. If a currency interface 

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is used, corrections to player interface count data shall be made using one of the 

following: 

(i) Draw a single line through the error on the player interface document, and write the 

correct figure above the original figure. The correction shall then be initialed by two 

count team members verifying the change. If this procedure is used, an individual 

independent of the player interface department and count team shall enter the correct 

figure into the computer system prior to the generation of related player interface reports; 

or 

(ii) During the count process, correct the error in the computer system and enter the 

passwords of at least two count team members. If this procedure is used, an exception 

report shall be generated by the computer system identifying the player interface number, 

the error, the correction, and the count team members attesting to the correction. 

(iii) If the computer system does not allow corrections as specified in (ii), management 

shall develop and implement alternative procedures for documenting corrections to the 

soft count records and communicating the information to the accounting department. 

(12) The count sheet shall be reconciled to the total drop by a count team member who 

shall not function as the sole recorder, and variances shall be reconciled and documented. 

This standard does not apply to vouchers removed from the financial instrument storage 

components. 

(13) All members of the count team shall sign the count document or a summary report to 

attest to their participation in the count. 

(14) All drop proceeds and cash equivalents that were counted shall be turned over to the 

cage or vault cashier (who shall be independent of the count team) or to an authorized 

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person independent of the revenue generation and the count process for verification. 

Such person shall certify by signature as to the amount of the drop proceeds delivered 

and received. It is recommended that the individual performing the verification count be 

precluded from having prior knowledge of the results of previous count performed by 

count team personnel. Any unresolved variances shall be reconciled, documented, and/or 

investigated by accounting/revenue audit. 

(15) The cage/vault person shall sign the count sheet, or other reconciling document, and 

thereby assume accountability of the currency drop proceeds, ending the count. 

(16) The count sheet, with all supporting documents, shall be delivered to the accounting 

department by a count team member or a person independent of the cashiers department. 

Alternatively, it may be adequately secured (e.g., locked container to which only 

accounting personnel can gain access) until retrieved by the accounting department. 

(17) Access to stored full financial instrument storage components shall be restricted to: 

(i) Authorized members of the drop and count teams; and 

(ii) Authorized personnel in an emergency for the resolution of a problem. 

(g) Player interface coin drop standards. (1) A minimum of three individuals shall be 

involved in the removal of the player interface drop, at least one of whom is independent 

of the player interface department. 

(2) All drop buckets shall be removed only at the time previously designated by the 

gaming operation and reported to the Tribal gaming regulatory authority, except for 

emergency drops. 

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(3) Surveillance shall be notified when the drop is to begin in order that surveillance may 

monitor the activities. The player interface coin drop begins when the first drop bucket is 

removed. 

(4) Security shall be provided over the buckets removed from the player interface drop 

cabinets and awaiting transport to the count room. 

(5) As each player interface is opened, the contents shall be tagged with its respective 

player interface number if the bucket is not permanently marked with the player interface 

number. The contents shall be transported directly to the area designated for the counting 

of such drop proceeds. If more than one trip is required to remove the contents of the 

player interfaces, the filled carts of coins shall be securely locked in the room designed 

for counting or in another equivalently secure area with comparable controls. There shall 

be a locked covering on any carts in which the drop route includes passage out of doors. 

(i) Alternatively, a smart bucket system that electronically identifies and tracks the player 

interface number, and facilitates the proper recognition of gaming revenue, shall satisfy 

the requirements of this paragraph. 

(ii) [Reserved] 

(6) Each drop bucket in use shall be: 

(i) Housed in a locked compartment separate from any other compartment of the player 

interface and keyed differently than other player interface compartments; and 

(ii) Identifiable to the player interface from which it is removed. If the player interface is 

identified with a removable tag that is placed in the bucket, the tag shall be placed on top 

of the bucket when it is collected. 

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(7) Each player interface shall have drop buckets into which coins or tokens that are 

retained by the player interface are collected. Drop bucket contents shall not be used to 

make change or pay hand-paid payouts. 

(8) The collection procedures may include procedures for dropping player interfaces that 

have trays instead of drop buckets. 

(h) Hard count room personnel. (1) The weigh/count shall be performed by a minimum 

of three individuals. 

(2) At no time during the weigh/count shall there be fewer than three individuals in the 

count room until the drop proceeds have been accepted into cage/vault accountability. 

Surveillance shall be notified whenever count room personnel exit or enter the count 

room during the count. 

(i) If the player interface count is conducted with a continuous mechanical count meter 

that is not reset during the count and is verified in writing by at least three individuals at 

the start and end of each denomination count, then one person may perform the wrap. 

(ii) [Reserved] 

(3) Count team members shall be rotated on a routine basis such that the count team is 

not consistently the same three persons more than four (4) days per week. This standard 

shall not apply to gaming operations that utilize a count team of more than three persons. 

(4) The count team shall be independent of transactions being reviewed and counted. The 

count team shall be independent of the cage/vault departments, unless they are nonsupervisory player interface personnel and perform the laborer function only (Nonsupervisory player interface personnel are defined as persons below the level of player 

interface shift supervisor). A cage cashier may be used if this person is not allowed to 

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perform the recording function. An accounting representative may be used if there is an 

independent audit of all count documentation. 

(i) Player interface coin count and wrap standards. (1) Coins shall include tokens. 

(2) The player interface coin count and wrap shall be performed in a count room or other 

equivalently secure area with comparable controls. 

(i) Alternatively, an on-the-floor drop system utilizing a mobile scale shall satisfy the 

requirements of this paragraph, subject to the following conditions: 

(A) The gaming operation shall utilize and maintain an effective on-line player interface 

monitoring system, as described in §542.13(m) (3); 

(B) Components of the on-the-floor drop system shall include, but not be limited to, a 

weigh scale, a laptop computer through which weigh/count applications are operated, a 

security camera available for the mobile scale system, and a VCR to be housed within the 

video compartment of the mobile scale. The system may include a mule cart used for 

mobile weigh scale system locomotion. 

(C) The gaming operation must obtain the security camera available with the system, and 

this camera must be added in such a way as to eliminate tampering. 

(D) Prior to the drop, the drop/count team shall ensure the scale batteries are charged; 

(E) Prior to the drop, a videotape shall be inserted into the VCR used to record the drop 

in conjunction with the security camera system and the VCR shall be activated; 

(F) The weigh scale test shall be performed prior to removing the unit from the hard 

count room for the start of the weigh/drop/count; 

(G) Surveillance shall be notified when the weigh/drop/count begins and shall be capable 

of monitoring the entire process; 

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(H) An observer independent of the weigh/drop/count teams (independent observer) shall 

remain by the weigh scale at all times and shall observe the entire weigh/drop/count 

process; 

(I) Physical custody of the key(s) needed to access the laptop and video compartment 

shall require the involvement of two persons, one of whom is independent of the drop and 

count team; 

(J) The mule key (if applicable), the laptop and video compartment keys, and the remote 

control for the VCR shall be maintained by a department independent of the player 

interface department. The appropriate personnel shall sign out these keys; 

(K) A person independent of the weigh/drop/count teams shall be required to accompany 

these keys while they are checked out, and observe each time the laptop compartment is 

opened; 

(L) The laptop access panel shall not be opened outside the hard count room, except in 

instances when the laptop must be rebooted as a result of a crash, lock up, or other 

situation requiring immediate corrective action; 

(M) User access to the system shall be limited to those persons required to have full or 

limited access to complete the weigh/drop/count; and 

(N) When the weigh/drop/count is completed, the independent observer shall access the 

laptop compartment, end the recording session, eject the videotape, and deliver the 

videotape to surveillance. 

(ii) [Reserved] 

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(3) Access to the count room during the count shall be restricted to members of the drop 

and count teams, with the exception of authorized observers, supervisors for resolution of 

problems, and authorized maintenance personnel. 

(4) If counts from various revenue centers occur simultaneously in the count room, 

procedures shall be in effect that prevent the commingling of funds from different 

revenue centers. 

(5) The following functions shall be performed in the counting of the player interface 

drop: 

(i) Recorder function, which involves the recording of the player interface count; and 

(ii) Count team supervisor function, which involves the control of the player interface 

weigh and wrap process. The supervisor shall not perform the initial recording of the 

weigh/count unless a weigh scale with a printer is used. 

(6) The player interface drop shall be counted, wrapped, and reconciled in such a manner 

to prevent the commingling of player interface drop coin with coin (for each 

denomination) from the next player interface drop until the count of the player interface 

drop has been recorded. If the coins are not wrapped immediately after being weighed or 

counted, they shall be secured and not commingled with other coins. 

(i) The amount of the drop from each player interface shall be recorded in ink or other 

permanent form of recordation on a player interface count document by the recorder or 

mechanically printed by the weigh scale. Additionally, if a weigh scale interface is used, 

the count figures shall be transferred via direct communications line or computer storage 

media to the accounting department. 

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(ii) Corrections to information originally recorded by the count team on player interface 

count documentation shall be made by drawing a single line through the error, writing the 

correct figure above the original figure, and then obtaining the initials of at least two 

count team members who verified the change. 

(A) If a weigh scale interface is used, corrections to player interface count data shall be 

made using one of the following: 

(1) Drawing a single line through the error on the player interface document, writing the 

correct figure above the original figure, and then obtaining the initials of at least two 

count team members. If this procedure is used, an individual independent of the player 

interface department and count team shall enter the correct figure into the computer 

system prior to the generation of related player interface reports; or 

(2) During the count process, correct the error in the computer system and enter the 

passwords of at least two count team members. If this procedure is used, an exception 

report shall be generated by the computer system identifying the player interface number, 

the error, the correction, and the count team members attesting to the correction. 

(B) [Reserved] 

(7) If applicable, the weight shall be converted to dollar amounts before the reconciliation 

of the weigh to the wrap. 

(8) If a coin meter is used, a count team member shall convert the coin count for each 

denomination into dollars and shall enter the results on a summary sheet. 

(9) The recorder and at least one other count team member shall sign the weigh tape and 

the player interface count document attesting to the accuracy of the weigh/count. 

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(10) All members of the count team shall sign the count document or a summary report to 

attest to their participation in the count. 

(11) All drop proceeds and cash equivalents that were counted shall be turned over to the 

cage or vault cashier (who shall be independent of the count team) or to an authorized 

person independent of the revenue generation and the count process for verification. 

Such person shall certify by signature as to the amount of the drop proceeds delivered 

and received. 

(12) All player interface count and wrap documentation, including any applicable 

computer storage media, shall be delivered to the accounting department by a count team 

member or a person independent of the cashier's department. Alternatively, it may be 

adequately secured (e.g., locked container to which only accounting personnel can gain 

access) until retrieved by the accounting department. 

(13) If the coins are transported off the property, a second (alternative) count procedure 

shall be performed before the coins leave the property. Any variances shall be 

documented. 

(14) Variances. Large (by denomination, either $1,000 or 2% of the drop, whichever is 

less) or unusual (e.g., zero for weigh/count or patterned for all counts) variances between 

the weigh/count and wrap shall be investigated by management personnel independent of 

the player interface department, count team, and the cage/vault functions on a timely 

basis. The results of such investigation shall be documented, maintained for inspection, 

and provided to the Tribal gaming regulatory authority upon request. 

(j) Security of the count room inventory during the player interface coin count and wrap. 

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(1) If the count room serves as a coin room and coin inventory is not secured so as to 

preclude access by the count team, then the following standards shall apply: 

(i) At the commencement of the player interface count the following requirements shall 

be met: 

(A) The coin inventory shall be counted by at least two individuals, one of whom is a 

member of the count team and the other is independent of the weigh/count and wrap 

procedures; 

(B) The count in paragraph (j) (1) (i) (A) of this section shall be recorded on an 

appropriate inventory form; 

(ii) Upon completion of the wrap of the player interface drop: 

(A) At least two members of the count team (wrap team), independently from each other, 

shall count the ending coin inventory; 

(B) The counts in paragraph (j)(1)(ii)(A) of this section shall be recorded on a summary 

report(s) that evidences the calculation of the final wrap by subtracting the beginning 

inventory from the sum of the ending inventory and transfers in and out of the count 

room; 

(C) Prior to verification of the count by cage/vault personnel, the same count team 

members shall compare the calculated wrap to the weigh/count, recording the comparison 

and noting any variances on the summary report; 

(D) A member of the cage/vault department shall count the ending count room inventory 

by denomination and shall reconcile it to the beginning inventory, wrap, transfers, and 

weigh/count. Any reconciliation variance shall be documented; and 

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(E) At the conclusion of the reconciliation, at least two count/wrap team members and the 

verifying cage/vault person shall sign the summary report(s) attesting to its accuracy. 

(2) If the count room is segregated from the coin room, or if the coin room is used as a 

count room and the coin room inventory is secured to preclude access by the count team, 

all of the following requirements shall be completed, at the conclusion of the count: 

(i) At least two members of the count/wrap team shall count the final wrapped player 

interface drop independently from each other; 

(ii) The final counts, in total and by denomination, shall be recorded on a summary 

report; 

(iii) The same count team members (or the accounting department) shall compare the 

final wrap to the weigh/count, recording the comparison and noting any variances on the 

summary report; 

(iv) A member of the cage/vault department shall count the wrapped player interface drop 

by denomination and reconcile it to the weigh/count summary report. Any variance shall 

be reconciled and documented; 

(v) At the conclusion of the reconciliation, at least two count team members and the 

cage/vault person shall sign the summary report attesting to its accuracy; and 

(vi) The wrapped coins (exclusive of proper transfers) shall be transported to the cage, 

vault or coin vault after the reconciliation of the weigh/count to the wrap. 

(vii) The count team shall not have access to coin drop meter amounts until after the 

count is completed and the drop proceeds have been accepted into the cage/vault 

accountability. A count team member is allowed to read/record the amount from the coinin meters provided the count team members do not have knowledge of the dollar amount 

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of coin contained in the drop buckets pursuant to the coin-in meters during the count 

process. 

(k) Transfers of currency and coin during the count. (1) Transfers may be permitted 

during the count only if permitted under the internal control standards approved by the 

Tribal gaming regulatory authority. 

(2) Each transfer shall be recorded on a separate multi-part form with a preprinted or 

concurrently-printed form number that shall be subsequently reconciled by the 

accounting department. 

Written Comment (March): Add language that would allow for a paperless 

system. In the vault section a similar method of recording. 

Response: The Committee reviewed the proposed standard and had no 

comments. This comment has no bearing on the transition from 542 to 543. 

(3) Each transfer must be counted and signed for by at least two members of the count 

team and by a person independent of the count team who is responsible for authorizing 

the transfer. 

(4) At least one part of the transfer form shall remain in the count room until the drop has 

been accepted into cage/vault accountability. The other part of the transfer form shall 

accompany the funds transferred from the count room during the count. 

(l) Key controls-general (1) The player interface coin drop cabinet keys, card games drop 

box release keys, financial instrument storage component release keys, card games drop 

box contents keys, financial instrument storage component contents keys, and kiosk keys 

shall all be separately keyed from each other. 

Written Comment (March): No Comment so long as the NIGC strikes this 

provision as agreed. 

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Response: The Committee reviewed the proposed standard and had no 

comment. Scrivener’s notes contain no reference to agreeing to strike this 

provision. Believe that the commenter has confused agreement to strike similar 

provisions located in later subsections of 543.15 due to redundancy with (l) (1). 

The comment has no bearing on the transition from 542 to 543. 

(2) Surveillance monitoring key access does not satisfy the requirements in this part for 

physical involvement. 

(3) All duplicate keys shall be maintained in a manner that provides the same degree of 

control as is required for the original keys. Records shall be maintained for each key 

duplicated that indicate the number of keys made and destroyed. 

(4) Records shall be maintained by the custodian of sensitive keys to document 

authorization of personnel accessing keys. 

(m) Player interface drop key control standards. (1) Player interface coin drop cabinet 

keys, including duplicates, shall be maintained by a department independent of the player 

interface department. 

(2) Accessing the keys needed to open player interface coin drop cabinets, including 

duplicates, shall require the involvement of two persons, one of whom is independent of 

the player interface department. 

(3) Two individuals (separate from key custodian) shall be required to accompany such 

keys while checked out and observe each time player interface drop cabinets are 

accessed, unless surveillance is notified each time keys are checked out and surveillance 

observes the person throughout the period the keys are checked out. 

Written Comment (March): If two people are required to accompany the keys 

while they are checked out, then what is the need for surveillance to monitor this 

activity? 

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

Commenter has misinterpreted the standard. Surveillance is not required to 

monitor this activity unless there are less than two people (i.e. only one person) 

accompanying the key. This comment has no bearing on the transition from 542 

to 543. 

(n) Card game drop box key control standards. (1) Procedures shall be developed and 

implemented to insure that unauthorized access to empty card game drop boxes shall not 

occur from the time the boxes leave the storage racks until they are placed on the tables. 

(2) The involvement of at least two persons independent of the cage department shall be 

required to access stored empty card game drop boxes. 

(3) At least three (two for card game drop box keys in operations with three tables or 

fewer) count team members are required to be present at the time count room and other 

count keys are issued for the count. 

(o) Card game drop box release keys. (1) The card game drop box release keys shall be 

maintained by a department independent of the card game department. 

(2) Only the person(s) authorized to remove card game drop boxes from the tables shall 

be allowed access to the card game drop box release keys; however, the count team 

members may have access to the release keys during the soft count in order to reset the 

card game drop boxes. 

(3) Persons authorized to remove the card game drop boxes shall be precluded from 

having simultaneous access to the card game drop box contents keys and release keys. 

(4) For situations requiring access to a card game drop box at a time other than the 

scheduled drop, the date, time, and signature of the individual signing out/in the release 

key must be documented. 

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Written Comment (March): What about electronic key control systems? This 

would appear to require a manual process; we feel that a username and password 

should satisfy the signature requirement. 

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

543.41 (a) permits the use of a computerized application so long as it provides the 

at least the level of control described by the standards in this section and has been 

approved by the TGRA. This comment has no bearing on the transition from 542 

to 543. 

(p) Financial instrument storage component release keys. (1) The financial instrument 

storage component release keys shall be maintained by a department independent of the 

player interface department. 

(2) Only the person(s) authorized to remove financial instrument storage components 

from the player interfaces shall be allowed access to the release keys. 

(3) Persons authorized to remove the financial instrument storage components shall be 

precluded from having simultaneous access to the financial instrument storage 

component contents keys and release keys. 

(4) For situations requiring access to a financial instrument storage component at a time 

other than the scheduled drop, the date, time, and signature of the individual signing 

out/in the release key must be documented. 

(q) Card game drop box storage rack keys. (1) A person independent of the card games 

department shall be required to accompany the card game drop box storage rack keys and 

observe each time card game drop boxes are removed from or placed in storage racks. 

(2) Persons authorized to obtain card game drop box storage rack keys shall be precluded 

from having simultaneous access to card game drop box contents keys with the exception 

of the count team. 

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(r) Financial instrument storage component storage rack keys. (1) A person independent 

of the player interface department shall be required to accompany the financial 

instrument storage component storage rack keys and observe each time storage 

components are removed from or placed in storage racks. 

(2) Persons authorized to obtain financial instrument storage component storage rack 

keys shall be precluded from having simultaneous access to financial instrument storage 

component contents keys with the exception of the count team. 

(s) Card game drop box contents keys. (1) Issuance of the card game drop box contents 

keys at other than scheduled count times shall require the involvement of at least three 

persons from separate departments, including management. The reason for issuance shall 

be documented with the signatures of all participants and observers. Two individuals 

from separate departments are required to accompany the card game drop box contents 

key from the time the keys are issued until the time the keys are returned. The key 

custodian issuing keys constitutes physical involvement. A computerized key security 

system functions as the key custodian. 

Written Comment (March): It is our position that a usernames and passwords or 

biometric signatures would satisfy the signature requirements. 

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

543.41 (a) permits the use of a computerized application so long as it provides the 

at least the level of control described by the standards in this section and has been 

approved by the TGRA. This comment has no bearing on the transition from 542 

to 543. 

(2) Only count team members shall be allowed access to card game drop box contents 

keys during the count process. 

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(t) Financial instrument storage component contents keys. (1) Issuance of the financial 

instrument storage component contents key at other than scheduled count times shall 

require the involvement of at least three persons from separate departments, one of whom 

must be a supervisor. The reason for issuance shall be documented with the signatures of 

all participants and observers. Two individuals from separate departments are required to 

accompany the financial instrument storage component contents key from the time the 

keys are issued until the time the keys are returned. The key custodian issuing keys 

constitutes physical involvement. A computerized key security system functions as the 

key custodian. 

Written Comment (March): It is our position that a usernames and passwords or 

biometric signatures would satisfy the signature requirements. 

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

543.41 (a) permits the use of a computerized application so long as it provides the 

at least the level of control described by the standards in this section and has been 

approved by the TGRA. This comment has no bearing on the transition from 542 

to 543. 

(2) Only the count team members shall be allowed access to financial instrument storage 

component contents keys during the count process. 

(u) Player interface computerized key security systems. (Adopted May 4, 2005) 

 

Written Comment (March): What is the significance of the use of the May 4, 

2005 sign post? 

Response: Scrivener error. Will be deleted. 

Corrected proposal as a result of March written comment: 

(u) Player interface computerized key security systems. (Adopted May 4, 2005)

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(1) Computerized key security systems which restrict access to the player interface drop 

and count keys through the use of passwords, keys or other means, other than a key 

custodian, must provide the same degree of control as indicated in the aforementioned 

key control standards; refer to paragraphs (m), (p), (r) and (t) of this section. This 

standard does not apply to the system administrator. The system administrator is defined 

in paragraph (u) (2) (i) of this section. 

Written Comment (March): If the technology can provide access to the box with 

the keys then it should provide access without the keys. We recommend the 

following language be added to this item (u) as noted above in item (a): 

“Nothing herein shall prohibit the account access component, financial instrument 

acceptor, and financial instrument dispenser from being included within the same 

component, or separated into individual components.” This statement was taken 

from the technical standards part 547.7(l). 

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

Disagree that this language should be incorporated in 543.41 since, as noted by 

the commenter, it is a technical standard and not a control standard. This 

comment has no bearing on the transition from 542 to 543. 

(2) For computerized key security systems, the following additional player interface key 

control procedures apply: 

(i) Management personnel independent of the player interface department assign and 

control user access to keys in the computerized key security system (i.e., system 

administrator) to ensure that player interface drop and count keys are restricted to 

authorized individuals. 

(ii) In the event of an emergency or the key box is inoperable, access to the emergency 

manual key(s) (a.k.a. override key), used to access the box containing the player interface 

drop and count keys, requires the physical involvement of at least three persons from 

separate departments, including management. The date, time, and reason for access, must 

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be documented with the signatures of all participating persons signing out/in the 

emergency manual key(s). 

(iii) The custody of the keys issued pursuant to paragraph (u) (2) (ii) of this section 

requires the presence of two persons from separate departments from the time of their 

issuance until the time of their return. 

(iv) Routine physical maintenance that requires accessing the emergency manual key(s) 

(override key) and does not involve the accessing of the player interface drop and count 

keys only requires the presence of two persons from separate departments. The date, time 

and reason for access must be documented with the signatures of all participating 

individuals signing out/in the emergency manual key(s). 

543.41 (u) (3) and (4) have been moved to proposed 543.50 Revenue Audit 

(3) For computerized key security systems controlling access to card games drop 

and count keys, accounting/audit personnel, independent of the system 

administrator, shall perform the following procedures:

(i) Daily, review the report generated by the computerized key security system 

indicating the transactions performed by the individual(s) that adds, deletes, and 

changes user's access within the system (i.e., system administrator). Determine 

whether the transactions completed by the system administrator provide an 

adequate control over the access to the card games drop and count keys. Also, 

determine whether any card games drop and count key(s) removed or returned to 

the key cabinet by the system administrator was properly authorized.

(ii) For at least one day each month, review the report generated by the 

computerized key security system indicating all transactions performed to 

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determine whether any unusual card games drop and count key removals or key 

returns occurred.

(iii) At least quarterly, review a sample of users that are assigned access to the card 

games drop and count keys to determine that their access to the assigned keys is 

adequate relative to their job position.

(iv) All noted improper transactions or unusual occurrences are investigated with 

the results documented.

(4) At least quarterly, an inventory of all count room, card game drop box release, 

storage rack, contents, override and panel keys shall be performed, and reconciled 

to records of keys made, issued, and destroyed. Investigations shall be performed 

for all keys unaccounted for, with the investigations being documented. 

(v) Card games computerized key security systems. (1) Computerized key security 

systems which restrict access to the card game drop and count keys through the use of 

passwords, keys or other means, other than a key custodian, must provide the same 

degree of control as indicated in the aforementioned key control standards; refer to 

paragraphs (n), (o), (q), and (s), of this section. This standard does not apply to the 

system administrator. The system administrator is defined in paragraph (v) (2) (i) of this 

section. 

(2) For computerized key security systems, the following additional card game key 

control procedures apply: 

(i) Management personnel independent of the card game department assign and control 

user access to keys in the computerized key security system (i.e., system administrator) to 

ensure that card game drop and count keys are restricted to authorized individuals. 

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(ii) In the event of an emergency or the key box is inoperable, access to the emergency 

manual key(s) (a.k.a. override key), used to access the box containing the card game drop 

and count keys, requires the physical involvement of at least three persons from separate 

departments, including management. The date, time, and reason for access, must be 

documented with the signatures of all participating individuals signing out/in the 

emergency manual key(s). 

(iii) The custody of the keys issued pursuant to paragraph (v) (2) (ii) of this section 

requires the presence of two persons from separate departments from the time of their 

issuance until the time of their return. 

(iv) Routine physical maintenance that requires accessing the emergency manual key(s) 

override key) and does not involve the accessing of the card games drop and count keys, 

only requires the presence of two persons from separate departments. The date, time and 

reason for access must be documented with the signatures of all participating individual 

signing out/in the emergency manual key(s). 

543.41 (v) (3) and (4) have been moved to proposed 543.50 Revenue Audit. 

(3) For computerized key security systems controlling access to player interface 

drop and count keys, accounting/audit personnel, independent of the system 

administrator, shall perform the following procedures:

(i) Daily, review the report generated by the computerized key security system 

indicating the transactions performed by the individual(s) that adds, deletes, and 

changes user's access within the system (i.e., system administrator). Determine 

whether the transactions completed by the system administrator provide an 

adequate control over the access to the player interface drop and count keys. Also, 

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determine whether any player interface drop and count key(s) removed or returned 

to the key cabinet by the system administrator was properly authorized.

Written Comment (March): Where did the concept of a daily review come 

from? Not even in a manual system is there a requirement for the daily sign 

out log be reviewed each day. It would appear that having a daily review of 

the administrator’s activity would defeat the purpose of having a 

computerized key security system. Therefore, we recommend removing 

“daily” and replacing it with the following: “For at least one day each 

month”

Response: The Committee reviewed the proposed standard and had no 

comment. Disagree that daily review of the reporting containing the 

transactions performed by the system administrator defeats the purpose of 

having a computerized key security system as vigilance over the system 

administrator’s activities is an essential control, particularly as it relates to 

drop and count keys. This comment has no bearing on the transition from 

542 to 543.

Note (May): Following discussion during the conference call it was concluded 

that the importance of oversight of the system administrator’s transactions 

outweighed the small amount of time that daily review of the report would 

require.

(ii) For at least one day each month, review the report generated by the 

computerized key security system indicating all transactions performed to 

determine whether any unusual player interface drop and count key removals or 

key returns occurred.

(iii) At least quarterly, review a sample of users that are assigned access to the 

player interface drop and count keys to determine that their access to the assigned 

keys is adequate relative to their job position.

(iv) All noted improper transactions or unusual occurrences are investigated with 

the results documented.

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(4) At least quarterly, an inventory of all count room, player interface door, player 

interface fill cabinet, storage rack, contents, override and panel keys shall be 

performed, and reconciled to records of keys made, issued, and destroyed.

Investigations shall be performed for all keys unaccounted for, with the 

investigation being documented. 

(w) Emergency drop procedures. Emergency drop procedures shall be developed by 

the Tribal gaming regulatory authority, or the gaming operation as approved by the 

Tribal gaming regulatory authority. 

(x) Equipment standards for player interface count. (1) A weigh scale calibration 

module shall be secured so as to prevent unauthorized access (e.g., prenumbered 

seal, lock and key, etc.).

(2) A person independent of the cage, vault, player interface, and count team 

functions shall be required to be present whenever the calibration module is 

accessed. Such access shall be documented and maintained.

(3) If a weigh scale interface is used, it shall be adequately restricted so as to prevent 

unauthorized access (passwords, keys, etc.).

(4) If the weigh scale has a zero adjustment mechanism, it shall be physically limited 

to minor adjustments (e.g., weight of a bucket) or physically situated such that any 

unnecessary adjustments to it during the weigh process would be observed by other 

count team members.

543.41 (x) (5) has been moved to proposed 543.50 Revenue Audit. 

(5) Unannounced weigh scale and weigh scale interface (if applicable) tests shall be 

performed by a person or persons independent of the cage, vault, and player 

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interface departments and count team at least quarterly with the test results being 

documented and maintained. This test may be performed by internal audit or the 

Tribal gaming regulatory authority. The result of these tests shall be documented 

and signed by the person or persons performing the test.

(5) Immediately prior to the player interface count, at least two individuals shall 

verify the accuracy of the weigh scale with varying weights or with varying amounts 

of previously counted coin for each denomination to ensure the scale is properly 

calibrated (varying weights/coin from drop to drop is acceptable).

(6) If a mechanical coin counter is used (instead of a weigh scale), the Tribal gaming 

regulatory authority, or the gaming operation as approved by the Tribal gaming 

regulatory authority, shall establish and the gaming operation shall comply with 

procedures that are equivalent to those described in paragraphs 543.43 (x) (4), 

543.43 (x) (5), and 543.50 (g) (2). 

(7) If a coin meter count machine is used, the count team member shall record the 

machine number, denomination and number of coins in ink on a source document, 

unless the meter machine automatically records such information.

(i) A count team member shall test the coin meter count machine before the actual 

count to ascertain if the metering device is functioning properly with a 

predetermined number of coins for each denomination.

(ii) [Reserved]

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