§ 542.23 What are the minimum internal control standards for surveillance for Tier A 

gaming operations? 

(a) Tier A gaming operations must, at a minimum, maintain and operate an unstaffed 

surveillance system in a secured location whereby the areas under surveillance are 

continually recorded. 

Comment (January): Require staffing of the secured location. 

Response: Disagree. Requiring surveillance staffing could be financially 

burdensome for many Tier A operations. 

(b) The entrance to the secured location shall be located so that it is not readily accessible 

by either gaming operation employees who work primarily on the casino floor, or the 

general public. 

Note (January): Consider removing remainder of the paragraph after accessible. 

Comment (January): Location is irrelevant to accessibility, provided the 

entrance is properly secured against unauthorized entry. 

Response: Agree. See below revision. 

Revised proposal based on January comments: 

(b) The entrance to the secured location shall be appropriately secured to prevent 

unauthorized access. located so that it is not readily accessible by either gaming 

operation employees who work primarily on the casino floor, or the general public.

(c) Access to the secured location shall be limited to surveillance personnel, designated 

employees, and other persons authorized in accordance with the surveillance department 

policy. Such policy shall be approved by the Tribal gaming regulatory authority.

Justification: See 542.3 Compliance Section for general standard. 

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Comment (January): Remove (c), redundant to (b). 

Response: Disagree. Paragraph (b) pertains to physical access; whereas, 

paragraph (c) pertains to the policy of determining who has the authority to 

access the room and certain documentation requirements. 

(d) The surveillance system shall include date and time generators that possess the 

capability to display the date and time of recorded events on video and/or digital 

recordings. The displayed date and time shall not significantly obstruct the recorded 

view. 

(e) The surveillance department shall strive to ensure staff is trained in the use of 

the equipment, knowledge of the games, and house rules. Surveillance department 

personnel shall be trained in the use of the equipment, knowledge of the games, and 

house rules. There must be at least one person on the property at all times with a 

working knowledge of and the ability to operate the surveillance equipment.

Justification: The revision is intended to add clarity and to ensure that knowledgeable 

staff are available at all times.

Comment (January): Remove or revise the first sentence. Operations with an 

unstaffed surveillance system allowed by paragraph (a) may not have 

designated surveillance department personnel. 

Response: Disagree. The standard does not require that an operation have a 

surveillance department, only that department personnel must be sufficiently 

trained if the operation does have a surveillance department. 

Comment (January): Second sentence requirement that a person must be on the 

property is unreasonable. Tribes with multiple facilities might have a person 

available that would not necessarily be on property. 

Response: Agree. See below revision to the proposed regulation. 

Comment (January): Replace “on the property” with “available”. 

Response: Disagree in favor of the following alternative comment. 

Comment (January): Replace “on the property” with “readily available”.

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Response: Agree. See below revision to the proposed regulation. 

Revised proposal based on January comments: 

(e) The Surveillance department personnel shall strive to ensure staff is be trained in 

the use of the equipment, knowledge of the games, and house rules. There must be at 

least one person readily available at all times with a working knowledge of and the

ability to operate the surveillance equipment. 

(f) Each camera required by the standards in this section shall be installed in a manner 

that will prevent it from being readily obstructed, tampered with, or disabled by 

customers or employees. 

(g) Where a PTZ camera is used to observe gaming and gaming-related activities, 

the camera must be placed behind a smoked dome, one-way mirror, or similar 

materials that conceal the camera from view.

Justification: The revision is intended to establish the standard requiring PTZ cameras to 

be concealed, thereby precluding employees and customers from being able to detect the 

area being observed/recorded. 

Comment (December): Could be interpreted as a PTZ camera requirement. 

Replace “observe gaming and gaming-related activities” with “satisfy 

requirements of this part”. 

Response: Disagree with regard to interpretation. The standard is sufficiently 

clear that it does not require PTZ cameras to be used. Agree with regard to 

suggested replacement language, as modified. 

Revised proposal: 

(g) Where a PTZ camera is used to satisfy coverage requirements of this part, the 

camera must be placed behind a smoked dome, one-way mirror, or similar 

materials that conceal the camera from view.

Comment (December): A smoked dome can reduce clarity in low-light areas. 

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Response: Disagree. The objective of the control is to prevent patrons and 

employees from being able to determine the direction of the camera. A smoked 

dome was only one of the suggested means to satisfy the regulation. 

Comment (January): Any concealing material will reduce clarity. 

Comment (January): Concealing the direction of the camera plays a minimal 

role in reducing risk.

Comment (January): Coverage and clarity concerns greatly supersede any 

benefit of concealing direction. 

Response: On reconsideration, agree. Proposed standard will be struck. Note: 

subsections (h) – (v) then become (g) – (u), corrected to (g) – (t). 

Revised proposal based on December and January comments: 

(g) Where a PTZ camera is used to satisfy coverage requirements of this part, the 

camera must be placed behind a smoked dome, one-way mirror, or similar 

materials that conceal the camera from view.

(g) Each camera required by the standards in this section shall possess the capability of 

having its picture recorded. The surveillance system shall include sufficient numbers of 

recorders to simultaneously record multiple gaming and count room activities, and shall 

record the views of all dedicated cameras and motion activated dedicated cameras. 

(h) Reasonable effort shall be made to repair each malfunction of surveillance system 

equipment required by the standards in this section within seventy-two (72) hours after 

the malfunction is discovered. The Tribal gaming regulatory authority shall be 

notified of any camera(s) that has malfunctioned for more than twenty-four (24) 

hours.

Justification: The standard was moved to (h) (2). 

(1) In the event of a dedicated camera malfunction, the gaming operation and/or the 

surveillance department shall, upon identification of the malfunction, provide alternative 

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camera coverage or other security measures, such as additional supervisory or security 

personnel, to protect the subject activity. 

(2) The Tribal gaming regulatory authority shall be notified of any camera(s) that 

has malfunctioned for more than twenty-four (24) hours.

Comment (December): The notification threshold should be determined by the 

TGRA. Replace “for more than twenty-four (24) hours” with “in accordance 

with a time schedule established by the TGRA”. 

Response: Disagree. The MICS should be specific and, to the extent possible, 

incorporate objective criteria for determining compliance. To ensure that 

notification is made to the TGRA in a timely manner when a camera cannot be 

repaired, the regulation needs to specify a time period. 

Comment (December): Insert “required” to clarify that the standard applies 

only to cameras required by the standards in this section. 

Response: Agree. Proposed revision is as follows: 

Revised proposal based on December comment: 

(2) The Tribal gaming regulatory authority shall be notified of any required 

camera(s) that has malfunctioned for more than twenty-four (24) hours.

Comment (January): Include alternative shorter period as determined by the 

TGRA. 

Response: Agree. See below revision to the proposed regulation. 

Comment (January): Standard does not specify when notification is to occur. 

Response: Agree. See below revision to the proposed regulation. 

Comment (January): Insert “within twenty-four (24) hours” after notified. 

Response: Disagree. See below revision that is intended to add clarity. 

Comment (January): Limit notification requirement to malfunctions resulting 

in inadequate coverage and clarity. 

Response: Agree. See below revision to the proposed regulation. 

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Comment (January): Insert “immediately” after notified. 

Response: Agree. See below revision to the proposed regulation. 

Revised proposal based on January comments: 

(2) The Tribal gaming regulatory authority shall be notified immediately of any 

required camera(s) that has malfunctioned for more than twenty-four (24) hours (or 

a shorter period as determined by the Tribal gaming regulatory authority), 

resulting in coverage or clarity that does not meet the requirements of this part.

(i) Bingo. The surveillance system shall record the bingo ball drawing device, the 

game board, and the activities of the employees responsible for drawing, calling, and 

entering the balls drawn or numbers selected.

Justification: Surveillance standards for Bingo will be addressed in 543. 

(i) (j) Card games. The surveillance system shall record the general activities in each 

card room with sufficient clarity to view customers, dealers and activities on the card 

table surfaces. and be capable of identifying the employees performing the different 

functions.

Justification: The revisions are intended to clarify that the requirement extends to 

customers and the table surfaces. 

(j) (k) Keno. (1) A dedicated or motion-activated dedicated camera shall be utilized 

to monitor and record the following both prior to and subsequent to the calling of a 

game: 

(A) Empty rabbit ears or wheel; 

(B) Date and time; 

(C) Game number; and 

(D) Full rabbit ears or wheel; 

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(2) The recording of the rabbit ears or wheel during the course of the draw shall 

provide a legible identification of the numbers on the balls drawn. 

(3) The surveillance system shall record the keno ball-drawing device, the general 

activities in each keno game area and be capable of identifying with sufficient clarity 

to identify the employees performing the different functions. .

(k) (l) Pari-mutuel. The surveillance system shall monitor and record general 

activities in the pari-mutuel area, to include the ticket writer and cashier areas, with 

sufficient clarity to identify the employees performing the different functions.

Comment (January): Replace “with sufficient clarity to identify” with “and be 

capable of identifying”, to reflect paragraph (j). 

Response: Agree. See below revision to the proposed regulation. 

Revised proposal based on January comment: 

(k) (l) Pari-mutuel. The surveillance system shall monitor and record general 

activities in the pari-mutuel area, to include the ticket writer and cashier areas and 

be capable of identifying the employees performing the different functions.

Justification: The MICS is currently silent regarding surveillance of pari-mutuel in a 

Tier A gaming operation. The proposed revision adds a needed control.

(l) (m) Table games (1) Operations with four (4) three (3) or more table games shall 

monitor and record the following: Except as otherwise provided in paragraphs 

(l)(3), (l)(4), and (l)(5) of this section, the surveillance system of gaming operations 

operating four (4) or more table games shall provide at a minimum one (1) pan-tiltzoom camera per two (2) tables and surveillance must be capable of taping:

(i) Each table game area Wwith sufficient clarity to identify customers and dealers; and 

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(ii) Each table game surface, with sufficient coverage and clarity to simultaneously 

view the table bank and determine the configuration of wagers, card values, and game 

outcome. 

Comment (December): Strike “simultaneously”. As written the standard could 

be interpreted to require a single high performance camera. 

Response: Disagree. Although the coverage requirement is typically satisfied 

with one overhead camera, the following is an amended proposed revision 

intended to add clarity: 

Revised proposal: 

(ii) Each table game surface with sufficient coverage and clarity to simultaneously view 

the table bank and determine the configuration of wagers, card values, and game 

outcome. Satisfaction of the coverage requirement may require multiple cameras of 

different types.

(iii) One (1) dedicated camera per table and one (1) pan-tilt-zoom camera per four 

(4) tables may be an acceptable alternative procedure to satisfy the requirements of 

this paragraph.

(2) Operations with three (3) or fewer table games. The surveillance system of gaming 

operations operating three (3) or fewer table games shall:

(i) Comply with the requirements of paragraph (l) (1) of this section; or

(ii) Have one (1) overhead camera at each table.

(3) Craps. All craps tables shall have two (2) dedicated cross view cameras covering 

both ends of the table.

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(4) Roulette. All roulette areas shall have one (1) overhead dedicated camera 

covering the roulette wheel and shall also have one (1) dedicated camera covering 

the play of the table.

(5) Big wheel. All big wheel games shall have one (1) dedicated camera viewing the 

wheel.

Justification: The proposed standards are intended to provide greater latitude to gaming 

operations regarding the number, type and placement of surveillance cameras needed to 

provide sufficient coverage and clarity over the bank and table wagering activity. 

(m) Progressive table games. (1) Each Pprogressive table games with a progressive 

jackpot of $25,000 or more shall be recorded by dedicated cameras that provide coverage 

of: 

Comment (December): Reconsider the reasonability of the $25,000 threshold. 

 

Response: Disagree. The threshold is derived from a similar standard in the 

Nevada MICS. 

(i) The table surface, sufficient that the card values and card suits can be clearly 

identified; 

(ii) An overall view of the entire table with sufficient clarity to identify customers and 

dealer; and 

(iii) A view of the progressive meter jackpot amount. If several tables are linked to the 

same progressive jackpot meter, only one meter need be recorded. 

(2) [Reserved] 

(n) Gaming machines. (1) Except as otherwise provided in paragraphs (n)(2) and 

(n)(3) of this section, Each gaming machine offering a payout of more than $250,000 

shall be monitored and recorded by a dedicated camera(s) to provide coverage of: 

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Comment (December): Strike “Each”, make “Gaming machine” plural. 

Response: Agree. Proposed revision amended as follows. 

Revised proposal based on December comment: 

(1) Except as otherwise provided in paragraphs (n)(2) and (n)(3) of this section,

gaming machine Gaming machines offering a payout of more than $250,000 shall be 

monitored and recorded by a dedicated camera(s) to provide coverage of:

(i) All customers and employees at the gaming machine, and 

(ii) The face of the gaming machine, with sufficient clarity to identify the payout line(s) 

of the gaming machine. 

(iii) The above requirements do not apply to wide area progressive gaming machines 

offering a payout of less than $3,000,000 and monitored by an independent vendor 

utilizing a linked, on-line progressive computer system.

Comment (December): By this language every machine that pays above $3 million 

requires the dedicated cameras. The problem is that most machines with low base payouts 

of say $50k can still progress to well over $3 million. This exception would only apply to 

machines that ONLY pay up to and not beyond $2,999,999. All the machines that 

progress higher than that would require the additional coverage and that is a whole lot of 

machines!! See the next comment below for more clarity. Does the NIGC mean a BASE 

payout of $3 million? If so, that will work still because most machines’ base amount is 

less than $3 million. 

In our opinion this says is that if a machine pays less than $3 million the enhancements 

are not required but if the machine pays $3 million or more they are required. Well, this 

does not suit the industry at all. The machines start at a number much lower than $3 

million and are able to progress to much more than $3 million. Thus, the Surveillance 

departments are not going to watch the progressive meters and install cameras when they 

reach $3 million, they must install cameras on ALL machines that can possibly progress 

to $3 million or more. That means two cameras for virtually every progressive machine 

in the every casino. It does not seem probable that a facility would install a camera when 

the threshold is met or only begin recording when it reaches the threshold. Either it is 

hung and recording or it is not. 

Response: Agree. The following amended revision is intended more clearly define when 

the enhanced coverage would be applicable to a wide area progressive machine. 

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Whenever the probability of the payout exceeding the threshold is 25% or greater, the 

surveillance coverage will apply. Utilizing the formula that the Agency will provide, 

management will be able to determine at the time the device is put into service. 

Revised proposal based on December comments: 

(n) Gaming machines. (1) Except as provided in paragraphs (n)(2) and (n)(3) of this 

section, g Gaming machines offering a payout of $250,000 or more shall be monitored 

and recorded by a dedicated camera(s) to provide coverage of: 

(i) All customers and employees at the gaming machine, and 

(ii) The face of the gaming machine, with sufficient clarity to identify the payout line(s) 

of the gaming machine. 

Justification: The revision is to reduce the surveillance requirements specific to in-house 

gaming machines without regard to whether the devices are linked to a wide area 

network. Specifically, the required dedicated camera coverage for large gaming machine 

payouts is being increased from $100,000 to $250,000, which is more consistent with 

other jurisdictions. 

Additionally, to clarify the exemption relevant to wide area progressive systems, the 

enhanced surveillance requirements are not applicable to actual payouts of less than 

$3,000,000 if the device is monitored by an independent vendor utilizing a linked, on-line 

progressive computer system. 

It is noteworthy that under the proposed standards for progressives, no enhanced 

monitoring or recording is required until such time as the progressive payout amount 

reaches the specified threshold. 

Comment (January): Clarify that the standard is not necessarily a one 

camera/one machine requirement. 

Response: Agree. See below additional standard. 

Comment (January): Remove “by a dedicated camera(s)”. The coverage and 

clarity standards in the subsequent paragraphs are sufficient. 

Response: Disagree. Dedicated cameras ensure that a video record of the 

activity being observed will always be created. 

Comment (January): Machine electronic records and verification procedures 

greatly reduce the relevance of large payout surveillance controls. 

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Response: Disagree. The control is common to the established gaming 

jurisdictions and recognizes that a corresponding relationship exist between the 

risk of compromise and the potential reward. Because of the size of the payouts 

in question, additional controls are warranted. 

Comment (January): Add paragraph (n)(1)(iii): “The coverage required in 

paragraphs (n)(1)(i) and (n)(1)(ii) does not require one dedicated camera per 

gaming machine if one dedicated camera is able to provide the required coverage 

for more than one gaming machine”. 

Response: Agree. The following standard is proposed to be added to the 

proposed revisions to section (n) (1): 

(iii) The above requirements do not apply to wide area progressive gaming machines 

offering a payout of less than $3,000,000 and monitored by an independent vendor 

utilizing a linked, on-line progressive computer system.

(iii) The coverage required in paragraphs (n)(1)(i) and (n)(1)(ii) does not require one 

dedicated camera per gaming machine if one dedicated camera is able to provide 

the required coverage for more than one gaming machine.

(2) The requirements in paragraph (n)(1) do not apply to wide area progressive 

gaming machines that are monitored by an independent vendor utilizing a linked 

on-line progressive computer system that have less than a 25% probability for a 

payout of $3,000,000 or more. 

Comment (January): Standard appears to reduce risk for the vendor rather than the 

gaming operation. 

Response: Disagree. The controls are relevant to the gaming operation, which, 

notwithstanding any agreements that may exist between the gaming operation and a 

vendor, is ultimately responsible for making all wagering payouts to patrons. 

 

(3) The requirements in paragraph (n)(1) do not apply to in-house progressive 

gaming machines that have less than a 25% probability for a payout of $250,000 or 

more.

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(4) Probability calculations for paragraphs (n) (2) and (n) (3) shall be performed 

using a formula provided by the Commission. 

Comment (December): The risk associated wide area progressive machines belongs to 

the vendor, but compliance responsibility and costs are the responsibility of the gaming 

operation.

Response: Disagree. The vendor has a contractual relationship with the gaming 

operation. Likewise, the patron enters into a wager with the gaming operation. Should 

be vendor fail to honor its commitment to the casino to pay a progressive jackpot, the 

casino is still obligate to make good the payout to the patron. 

Except for tribal gaming, the state gaming regulatory authorities typically require strict 

conditions are satisfied by the wide area progressive vendors, such a minimum liquidity 

standard. 

(2) In-house progressive machine. In-house progressive gaming machines offering a 

base payout amount (jackpot reset amount) of more than $100,000 shall be 

monitored and recorded by a dedicated camera(s) to provide coverage of:

(i) All customers and employees at the gaming machine; and

(ii) The face of the gaming machine, with sufficient clarity to identify the payout 

line(s) of the gaming machine.

(3) Wide-area progressive machine. Wide-area progressive gaming machines 

offering a base payout amount of $1 million or more and monitored by an 

independent vendor utilizing an on-line progressive computer system shall be 

recorded by a dedicated camera(s) to provide coverage of: (Revised August 12, 

2005)

(i) All customers and employees at the gaming machine; and

(ii) The face of the gaming machine, with sufficient clarity to identify the payout 

line(s) of the gaming machine.

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(4) Notwithstanding paragraph (n)(1) of this section, if the gaming machine is a 

multi-game machine, the Tribal gaming regulatory authority, or the gaming 

operation subject to the approval of the Tribal gaming regulatory authority, may 

develop and implement alternative procedures to verify payouts.

Justification: It is proposed that the standard be struck due to its ambiguity. 

(o) (p) Cage and vault. (1) The surveillance system shall monitor and record a general 

overview of activities occurring in each cage and vault area with sufficient clarity to 

identify employees within the cage and customers and employees at the counter areas. 

Justification: The MICS is currently silent regarding surveillance of the cage and vault 

in a Tier A gaming operation. The proposed revision adds a needed control.

Comment (December): Add identification of currency denominations to the 

sufficient clarity requirement. 

Comment (December): Add verification of transactions to the sufficient clarity 

requirement. 

Response: Agree 

Revised proposal based on December comments: 

(o) (p) Cage and vault. (1) The surveillance system shall monitor and record a general 

overview of activities occurring in each cage and vault area with sufficient clarity to 

identify employees within the cage and customers and employees at the counter areas 

and to confirm cash transactions occurring between employees and between 

employees and customers.

Note (May): In the course of a discussion of another section, it became apparent 

that there was some confusion as to the meaning of the proposed addition to (o) 

(1). The standard has been revised to improve clarity. 

Revision based on May note: 

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(1) The surveillance system shall monitor and record a general overview of activities 

occurring in each cage and vault area with sufficient clarity to identify employees within 

the cage and customers and employees at the counter areas and to confirm the amount 

of each cash transactions occurring between employees and between employees and 

customers.

(2) Each cashier station shall be equipped with one (1) dedicated overhead camera 

covering the transaction area. 

(3) The cage or vault area in which fills and credits are transacted shall be monitored and 

recorded by a dedicated camera or motion activated dedicated camera that provides 

coverage with sufficient clarity to identify the chip values and the amounts on the fill and 

credit slips. Controls provided by a computerized fill and credit system may constitute an 

adequate alternative to viewing the amounts on the fill and credit slips.

(p) (o) Currency and coin. Count rooms. The surveillance system shall record a general 

overview of all areas where currency or coin may be stored or counted. 

Justification: The title has been changed to provide clarity. 

(q) (p) Video recording and/or digital record retention. (1) All video recordings and/or 

digital records of coverage provided by the dedicated cameras or motion-activated 

dedicated cameras required by the standards in this section shall be retained for a 

minimum of seven (7) days. 

Comment (December): Add “or such longer period as required by the TGRA”. 

Response: Agree. 

Revised proposal based on December comment: 

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(q) (p) Video recording and/or digital record retention. (1) All video recordings and/or 

digital records of coverage provided by the dedicated cameras or motion-activated 

dedicated cameras required by the standards in this section shall be retained for a 

minimum of seven (7) days, or such longer period that may be required by the Tribal 

gaming regulatory authority.

(2) Recordings involving suspected or confirmed gaming crimes, unlawful activity, or 

detentions by security personnel, must be retained for a minimum of thirty (30) days. 

Comment (December): Add “or such longer period as required by the TGRA”. 

 Response: Agree. 

Revised proposal based on December comment: 

(2) Recordings involving suspected or confirmed gaming crimes, unlawful activity, or 

detentions by security personnel must be retained for a minimum of thirty (30) days, or 

such longer period that may be required by the Tribal gaming regulatory authority.

(3) Duly authenticated copies of video recordings and/or digital records shall be provided 

to the Commission upon request. 

(r) (q) Video library log. A video library log, or comparable alternative procedure 

approved by the Tribal gaming regulatory authority, shall be maintained to demonstrate 

compliance with the storage, identification, and retention standards required in this 

section. 

Note (January): Remove TGRA approval requirement for consistency with Tier 

B and Tier C. 

Revised proposal incorporating note: 

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(r) (q) Video library log. A video library log or comparable alternative procedure 

approved by the Tribal gaming regulatory authority shall be maintained to 

demonstrate compliance with the storage, identification, and retention standards required 

in this section. 

(s) (r) Malfunction and repair log. (1) Surveillance personnel shall maintain a log or 

alternative procedure approved by the Tribal gaming regulatory authority that 

documents each malfunction and repair of the surveillance system as defined in this 

section. 

Justification: Above revision is relevant to the general recommendation proposed for 

542.3. 

(2) The log shall state the time, date, and nature of each malfunction, the efforts expended 

to repair the malfunction, and the date of each effort, the reasons for any delays in 

repairing the malfunction, the date the malfunction is repaired, and where applicable, any 

alternative security measures that were taken. 

(3) The log must be retained for a minimum of 1 year after the date of the last entry 

in it.

Justification: The MICS is currently silent regarding the retention period for surveillance 

equipment malfunction logs. The above standard is intended to establish a one year 

retention period. 

(t) (u) Digital Surveillance System Standards (1) The digital surveillance equipment 

used to satisfy the surveillance standards in this Section must:

 Comment (December): Replace “must” with “shall”. 

 Response: Agree. 

Revised proposal based on December comment: 

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(t) (u) Digital Surveillance System Standards (1) The digital surveillance equipment 

used to satisfy the surveillance standards in this section shall:

(i) Record and play back video at a minimum of 30 frames per second (FPS), full 

screen (4 common intermediate format CIF), in real time.

(ii) Produce visual resolution that is adequate to satisfy the sufficient clarity 

standards in this section.

(iii) Have adequate storage capacity to maintain for a period of not less then seven 

(7) days, all images obtained from the video cameras.

(iv) Have a failure notification system that provides audible and visual notification 

of any failure in the surveillance system or the Digital Video Recording (DVR) 

media storage system.

Comment (December): Camera failures are not always tied to alarms and this 

requirement might require major system installations. Provide an alternative 

such as daily verification of camera and DVR operation. 

Response: Disagree. The requirement is not inconsistent with gaming 

regulatory standards and the capability is common to most digital surveillance 

systems. Essentially involves the activation or deactivation of a parameter 

option. The standard should not impose an undue hardship on tribes with digital 

surveillance systems. 

Comment (January): The response does not adequately address the concerns 

expressed in the comment from the December meeting. Camera failures are not 

always tied to alarms and this requirement might require major system 

installations. Provide an alternative such as daily verification of camera and 

DVR operation. 

Response: Agree. Proposed regulation has been amended as follows: 

Revised proposal based on January comment: 

(iv) Have a failure notification system that provides audible and visual notification 

of any failure in the surveillance system or the Digital Video Recording (DVR) 

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media storage system. Alternatively, daily verification of the effective operation of 

surveillance system and the DVR media storage system components is acceptable.

(v) Have a media storage system that is configured so that a failure of any single 

component will result in no loss of data from the media storage system.

(2) Access, or the ability to access, a digital surveillance system from any location 

outside of the surveillance operation room, must be approved by the Tribal gaming 

regulatory authority. Such transmissions must be effectively encrypted, firewalled 

on both ends, and password protected. 

Note (January): Replace “surveillance operation room” with “secure 

surveillance location” for Tier A only. 

Comment (January): Replace “must” with “shall”. 

Response: Agree. Proposed regulation is amended as follows: 

Revised proposal based on January comments: 

(2) Access, or the ability to access, a digital surveillance system from any location 

outside of the secure surveillance location, shall be approved by the Tribal gaming 

regulatory authority. Such transmissions shall be effectively encrypted, firewalled 

on both ends, and password protected. 

(3) All digital video disks or other storage media produced from the DVR system 

must contain the data with the time and date it was recorded superimposed, the 

media player and the software necessary to view the DVR images, as well as a video 

verification encryption code (also known as a watermark).

Comment (January): Replace “must” with “shall”. 

Response: Agree. Proposed regulation is amended as follows: 

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Revised proposal based on January comment: 

(3) All digital video disks or other storage media produced from the DVR system 

shall contain the data with the time and date it was recorded superimposed, the 

media player and the software necessary to view the DVR images, as well as a video 

verification encryption code (also known as a watermark).

(4) In the event of a failure of a DVR storage media system (total system failure), 

the gaming operation should strive to repair or replace the equipment within 8 

hours of the failure. 

(5) All DVR equipment must be located in a secure surveillance location(s).

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