§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 1 of 25

NIGC General Comment Applicable to Entire Document:

In 2010, the NIGC posted on its web-site draft Class II minimum internal control standards. The 

This document will compare the 2010 draft MICS to the TGWG MICS proposal. 

Editing convention

 The words in blue (underlined) and red (struck-through) are the additions and deletions made by the 

TGWG. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 2 of 25

 2010 Draft Proposed TGWG Change 

NO COMPARABLE SECTION § 543.7 (a) Internal Control Procedures. 

Subject to the approval and oversight of the TGRA, 

each gaming operation shall establish, implement and 

adhere to internal control policies and procedures that 

provide at least the level of control established by the 

standards of this section. 

TGWG Guidance

(a) Internal Control Procedures. The TGRA should ensure that the gaming operation establishes a system 

of internal control standards (SICS) that are applicable to Bingo operations. Such SICS should address, at a 

minimum, how the department operates, agents’ responsibilities, and controls to protect assets. The TGRA 

should review and approve the SICS prior to implementation. 

NIGC Comments

The use of “should” rather than “shall” or “must” in the guidance could lead the reader to believe that 543.19 

(a) does not require the establishment, implementation and adherence to SICS but that it is recommended. 

EFFECT OF 2010 PROVISIONS: No current provision. 

EFFECT OF TGWG PROPOSED AMENDMENT: Standard appears to restate provision in § 543.3(c), (TGWG 

version 543.3(b)) which states the tribal system of internal controls must equal or exceed the federal rule. 

TGWG version states that gaming operation policies and procedures approved by the TGRA must provide 

a level of control established by the standards in the TGWG text. As the TGRA will likely approve only 

those policies and procedures that equal or exceed the federal rule, the standard is somewhat self-evident. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 3 of 25

 2010 Draft Proposed TGWG Change 

NO COMPARABLE SECTION § 543.7(b) Computerized applications. 

 For any computer applications utilized, alternate 

documentation and/or procedures that provide at least 

the level of control established by the standards of this 

section, as approved in writing by the TGRA, will be 

acceptable. 

TGWG Guidance

1. (b) Computer Applications. A gaming operation may use computer applications, whether developed inhouse or acquired externally, provided that controls are established in accordance with MICS and approved 

in writing by the TGRA. For any computer applications utilized, alternate documentation and/or 

procedures that provide at least the level of control established by the internal control standards shall be 

implemented. For example, where an agent or multiple agents are required in the control, a computer 

application could substitute for one or all of the agents. Another example would be where a log is required 

a computer application report could substitute for the log. If computer systems are used, procedures must 

be designed to account for computer system failure without compromising the effectiveness of the internal 

control standards. 

NIGC Comments

Agree with first two sentences of (b). Third sentence (first example) should be clarified as it is 

unlikely that a computer application could substitute for a person or persons in all situations. The second 

example (substitution of a computer report for (presumably a manual) log should clarify that a computergenerated report would have to contain the same information/characteristics to substitute for a manually 

prepared log. The last sentence should clarify the meaning of “account for computer system failure without 

compromising the effectiveness of the internal control standards.”

EFFECT OF 2010 PROVISIONS: The current regulation is included in part 542 and no corresponding 

regulation is listed in part 543. 

EFFECT OF TGWG PROPOSED AMENDMENT: The proposed standard appears to be consistent with proposed 

542.7(a). 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 4 of 25

 2010 Draft Proposed TGWG Change 

NO COMPARABLE SECTION § 543.7 (c) Variances. 

The TGRA shall establish the threshold level at which 

a variance shall be reviewed. Any such review shall 

be documented. 

TGWG Guidance

(c) Variances. 

(1) The TGRA or the gaming operation as authorized by the TGRA should establish a threshold at which 

variances (i.e., exceptions against controls, inconsistencies with established policies and procedures or 

deviations from expected outcomes) must be investigated. 

(2) Best practice suggests that when the relevant predetermined threshold is achieved, the controls should 

require agents – preferably supervisory agents – to conduct a variance investigation. Variance investigation 

controls/procedures should include, but are not be limited to: 

(i) Transaction(s) document(s) review, including all department(s) records relating to the variance 

investigation; 

(ii) Recalculating inventory, cash and cash equivalents, sales and payout amounts; 

(iii) Re-verifying the winning event and prize payouts; 

(iv) Recount of assets/inventory; 

(v) Surveillance reviews; 

(vi) Physical inspections; and 

(vii) Agent interviews. 

(3) The investigation results must be supported by documentation and forwarded to the accounting 

department for review and retention. Best practice suggests that documentation should include copies of 

transaction forms, logs, and a description of the variance. 

NIGC Comments

It is not clear why the guidance on variances is located in this section as none of the standards in 543.7 

address or refer to variances. The examples given (i.e., exceptions against controls, inconsistencies with 

established policies and procedures or deviations from expected outcomes) should be elaborated upon. For 

example, what is an “exception against controls” or “deviations from expected outcomes?” The guidance 

fails to specify who should be performing the investigation and does not require that the “agents”

conducting the investigation must be independent of the department in which the “variance” occurred. 

EFFECT OF 2010 PROVISIONS: No comparable standard. 

EFFECT OF TGWG PROPOSED AMENDMENT: The control does not explain the type of variance to which it 

pertains. A standard within the MICS referring to an analysis of a variance will, by necessity, also identify 

the processes being compared. A variance results from at least two sets of records originating from 

different sources which produce results that are inconsistent. The above standard does not identify the data 

to be compared, does not identify the procedures for evaluating the inconsistency, and does not identify the 

employee or department responsible for performing the review. Allowing variance thresholds to be 

determined by the TGRAs without minimum guidance may lead to thresholds so high as to effectively 

circumvent the standard. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 5 of 25

 2010 Draft Proposed TGWG Change 

NO COMPARABLE SECTION § 543.7 (d) Supervision. 

Supervision shall be provided for bingo operations as 

needed by an agent(s) with authority equal to or 

greater than those being supervised. 

TGWG Guidance

 (d) Supervision. 

(1) Controls should identify the supervisory agent in the department or area ultimately responsible for 

ensuring that the department or area is operating in accordance with established policies and procedures. 

(2) The reporting structure may permit a supervisory agent to function as a bingo agent without any other 

supervision. In such instances, however, a supervisory agent either independent of the transaction or 

independent of the relevant department or area must resolve disputes. 

(3) Best practice suggests that the written system of internal controls should include: 

(i) An organizational chart of the department or area; 

(ii) Job descriptions; and 

(iii) A narrative description of the reporting structure, which is designed to ensure adequate supervision and 

segregation of function. 

NIGC Comments

Guidance appears relevant. 

EFFECT OF 2010 PROVISIONS: No comparable standard. 

EFFECT OF TGWG PROPOSED AMENDMENT: The control requires supervision over the bingo operations. 

There is no comparable standard within the current 543.7 and it was not considered during the MICS 

advisory committee meetings. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 6 of 25

 2010 Draft Proposed TGWG Change 

§ 543.7(a) Bingo Cards 

(1) Inventory of bingo paper. (i) The bingo paper 

inventory must be controlled so as to assure the 

integrity of the bingo paper being used as follows: 

(A) When received, bingo paper must be inventoried 

and secured by an authorized agent(s) independent of 

bingo sales; 

(B) The issue of bingo paper to the cashiers must be 

documented and signed for by the authorized agent(s) 

responsible for inventory control and a cashier. The 

bingo control log must include the series number of 

the bingo paper; 

(C) The bingo control log must be utilized by the 

gaming operation to verify the integrity of the bingo 

paper being used; and 

(D) Once each month, an authorized agent(s) 

independent of both bingo paper sales and bingo paper 

inventory control must verify the accuracy of the 

ending balance in the bingo control log by reconciling 

it with the bingo paper inventory. 

(ii) Paragraph (a)(1) of this section does not apply 

where no physical inventory is applicable. 

§ 543.7(e) Bingo Cards 

a) Bingo Cards—(1) Inventory of bingo paper. (i) The 

bingo paper inventory must be controlled so as to 

assure the integrity of the bingo paper being used as 

follows: 

(A) When received, bingo paper must be inventoried 

and secured by an authorized agent(s) independent of 

bingo sales;

(B) The issue of bingo paper to the cashiers must be 

documented and signed for by the authorized agent(s) 

responsible for inventory control and a cashier. The 

bingo control log must include the series number of 

the bingo paper;

(C) The bingo control log must be utilized by the 

gaming operation to verify the integrity of the bingo 

paper being used; and

(D) Once each month, an authorized agent(s) 

independent of both bingo paper sales and bingo paper 

inventory control must verify the accuracy of the 

ending balance in the bingo control log by reconciling 

it with the bingo paper inventory.

(ii) Paragraph (a)(1) of this section does not apply 

where no physical inventory is applicable. 

(e) Bingo Cards

(1) Physical inventory. 

(i) The bingo paper card inventory must be controlled 

in a manner designed to prevent unauthorized access, 

misappropriation, forgery, theft or fraud. Such controls 

shall address bingo cards exchanged between agents, 

increases and decreases to inventory, and inventory 

reconciliation. 

TGWG Guidance

(e) Bingo Cards – Physical Inventory. To safeguard the integrity of the bingo card inventory, procedures 

must be established to control the physical inventory of bingo cards. Best practice suggests that physical 

inventory controls should address the placement of orders, receipt, storage, issuance, removal, and 

cancellation of bingo card inventory to ensure that: (i) the inventory can be accounted for at all times; (ii) 

an inventory of bingo cards is maintained sufficient to operate the games; and (iii) bingo cards have not 

been marked, altered, or otherwise manipulated. 

(1) Receipt from supplier. 

(i) When bingo card inventory is initially received from the supplier, it should be inspected (without 

breaking the factory seals, if any), counted, inventoried, and secured by an authorized agent. Best practice 

suggests this agent should be independent of bingo card sales. 

(ii) Inventory records should include the following information: date received, quantities received, and the 

name of the individual conducting the inspection. 

(2) Storage. 

(i) Bingo cards should be maintained in a secure location (i.e., controlled access, under lock and key), with 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 7 of 25

appropriate surveillance coverage, which is accessible only to authorized agents to prevent unauthorized 

access and reduce the possibility of tampering. 

(ii) For smaller operations, inventory can be stored in a cabinet, closet, or other similar area; however, such 

area should be a secured area separate from the working inventory. 

(3) Issuance and Returns of Inventory. 

(i) Controls must be established for the issuance and return of inventory. Such controls must provide for 

proper recordation on appropriate control logs signed by the issuer and receiver, at a minimum covering the 

following circumstances: 

(A) Issuance of inventory from storage to a staging area; 

(B) Issuance of inventory from a staging area to the cage or sellers; 

(C) Return of inventory from a staging area to storage; and 

(D) Return of inventory from cage or seller to staging area or storage. 

(ii) Inventory must be secured at all times with adequate controls for accountability and in a manner 

designed to prevent unauthorized access, tampering, and theft. 

(4) Cancellation and removal. 

(i) Bingo cards removed from inventory that are deemed out of sequence, flawed, or misprinted and not 

returned to the supplier, shall be properly cancelled to ensure that they are not utilized in the play of a bingo 

game. Bingo cards that are removed from inventory and returned to the supplier or cancelled must be 

properly logged as removed from inventory. 

(ii) Cancellation methods may include, but are not limited to: shredding, drilling, and permanent ink 

marking. Cancelled cards may then be removed from inventory and recorded on the appropriate log. Best 

practice suggests that the cancellation process be under surveillance to ensure established controls have 

been followed. 

(iii) In the event of an investigation, the bingo cards associated with the investigation must be retained 

intact outside of the established removal and cancellation policy. These bingo cards should be sealed and 

forwarded to an independent department responsible for investigations, such as a security or a surveillance 

supervisory agent. 

(5) Logs. 

(i) The inventory of bingo cards should be tracked on a log(s) from original receipt from supplier into 

inventory, through use or permanent removal from inventory. 

(ii) Management should determine, based on the size of the operation and inventory needs, where bingo 

card inventory logs are required to ensure the integrity of bingo cards offered for play. 

(iii) The bingo card inventory log(s) should include: 

(A) Date; 

(B) Shift; 

(C) Time; 

(D) Location; 

(E) Inventory received, issued, removed, and returned; 

(F) Signature of agent performing transaction; 

(G) Signature of agent performing the reconciliation; 

(H) Any variance; 

(I) Beginning and ending inventory; and 

(J) Description of inventory transaction being performed. 

 

Examples of logs: Log maintained in the bingo card storage room that shows inventory of all cards: 

Inventory Log: 

 

Bingo Card Record: Best practice suggests that a log is maintained at each location (e.g., bank, booth, 

window, etc.) to record bingo card inventory received or returned. 

NIGC Comments

The use of “should” rather than “shall” or “must” in the guidance could lead the reader to believe that the 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 8 of 25

standard is not required by the MICS but that it is recommended. Otherwise guidance appears relevant. 

EFFECT OF 2010 PROVISIONS: The current regulations are intended to provide control procedures for bingo 

paper, which is typically considered a secured item within tribal gaming operations. The sales of bingo 

paper are the basis of the gaming activities and produce revenues and therefore warrant exacting controls. 

Segregation of duties between the accountability of bingo paper from the function of bingo sales has been a 

long-established standard and protects the integrity of the bingo paper. Without such basic accountability 

and segregation of duties, gaming operations could be subject to a high risk of compromise. 

EFFECT OF TGWG PROPOSED AMENDMENT: The proposed modification appears to be consistent with the 

intent of 543.7(a) but should provide specific control functions for the control of bingo paper. Also the 

proposed standard does not specify how to control bingo paper to prevent unauthorized access, 

misappropriation or fraud. Also, the inclusion of “Agent” should be clarified to provide guidance on 

whether the agent is a Class II vendor representative or an employee of the gaming operation. The 

definition of “Agent” should also be consistent with NIGC regulation 25 CFR part 556, Background 

Investigations for Primary Management Officials and Key Employees. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 9 of 25

 2010 Draft Proposed TGWG Change 

543.7(a) Bingo Cards 

(2) Bingo sales. 

(i) There must be an accurate accounting of all 

bingo sales. 

(ii) All bingo sales records must include the 

following information: 

(A) Date; 

(B) Time; 

(C) Shift or session; 

(D) Sales transaction identifiers, which may be the 

unique card identifier(s) sold or when electronic 

bingo card faces are sold, the unique identifiers of 

the card faces sold; 

(E) Quantity of bingo cards sold; 

(F) Dollar amount of bingo sales; 

(G) Signature, initials, or identification of the agent 

or device who conducted the bingo sales; and 

(H) When bingo sales are recorded manually, total 

sales are verified by an authorized agent 

independent of the bingo sales being verified and 

the signature, initials, or identification of the 

authorized agent who verified the bingo sales is 

recorded. 

(iii) No person shall have unrestricted access to 

modify bingo sales records. 

(iv) An authorized agent independent of the seller 

must perform the following standards for each seller 

at the end of each session: 

(A) Reconcile the documented total dollar amount 

of cards sold to the documented quantity of cards 

sold; 

(B) Note any variances; and 

(C) Appropriately investigate any noted variances 

with the results of the follow-up documented. 

(3) Voiding bingo cards. 

(i) Procedures must be established and implemented 

to prevent the voiding of card sales after the start of 

the calling of the game for which the bingo card 

was sold. Cards may not be voided after the start of 

a game for which the card was sold. 

(ii) When a bingo card must be voided the 

following controls must apply as relevant: 

(A) A non-electronic bingo card must be marked 

void; and 

(B) The authorization of the void, by an authorized 

agent independent of the original sale transaction 

(supervisor recommended), must be recorded either 

by signature on the bingo card or by electronically 

associating the void authorization to the sale 

transaction of the voided bingo card. 

(4) Reissue of previously sold bingo cards. When 

one or more previously sold bingo cards need to be 

§ 543.7 (e) Bingo Cards 

(2) Bingo sales. Sales.

(i) There must be an accurate accounting of The sale 

of bingo cards must be controlled in a manner to 

adequately record, track, and reconcile such all bingo 

sales., including voids. 

(ii) All bingo sales records must include the 

following information:

(A) Date;

(B) Time;

(C) Shift or session;

(D) Sales transaction identifiers, which may be the 

unique card identifier(s) sold or when electronic 

bingo card faces are sold, the unique identifiers of the 

card faces sold;

(E) Quantity of bingo cards sold;

(F) Dollar amount of bingo sales;

(G) Signature, initials, or identification of the agent 

or device who conducted the bingo sales; and

(Hii) When the sale of bingo cards is recorded 

manually, such sales must be verified by an 

authorized independent agent. of the bingo sales 

being verified and the signature, initials, or 

identification of the authorized agent who verified the 

bingo sales is recorded. 

(iii) No unauthorized person shall have unrestricted

access to modify bingo card sales records. 

(iv) An authorized agent independent of the seller 

must perform the following standards for each seller 

at the end of each session:

(A) Reconcile the documented total dollar amount of 

cards sold to the documented quantity of cards sold;

(B) Note any variances; and

(C) Appropriately investigate any noted variances 

with the results of the follow-up documented.

(3) Voiding bingo cards.

(i) Procedures must be established and implemented 

to prevent the voiding of card sales after the start of 

the calling of the game for which the bingo card was 

sold. Cards may not be voided after the start of a 

game for which the card was sold.

(ii) When a bingo card must be voided the following 

controls must apply as relevant:

(A) A non-electronic bingo card must be marked 

void; and

(B) The authorization of the void, by an authorized 

agent independent of the original sale transaction 

(supervisor recommended), must be recorded either 

by signature on the bingo card or by electronically 

associating the void authorization to the sale 

transaction of the voided bingo card.
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 10 of 25

reissued, the following controls must apply: the 

original sale of the bingo cards must be verified; 

and the reissue of the bingo cards must be 

documented, including the identity of the agent 

authorizing reissuance. 

(4) Reissue of previously sold bingo cards. When one 

or more previously sold bingo cards need to be 

reissued, the following controls must apply: the 

original sale of the bingo cards must be verified; and 

the reissue of the bingo cards must be documented, 

including the identity of the agent authorizing 

reissuance.

 

TGWG Guidance

(e) Bingo Cards – Sales. 

(1) Controls should be established to segregate the functions of seller and payout verifier. Agents who sell 

bingo cards should not be the sole verifier of bingo cards for prize payouts. However, such agents may be 

permitted to announce the identifiers of the winning bingo cards to the verifier. 

(2) In order to adequately record, track and reconcile sales of bingo cards, the following information should 

be documented: 

(i) Date; 

(ii) Shift or session; 

(iii) Number of bingo cards issued, sold, and returned; 

(iv) Dollar amount of bingo card sales; 

(v) Signature, initials, or identification number of the agent preparing the record; 

(vi) Signature, initials, or identification number of an independent agent who verified the bingo cards 

returned to inventory and dollar amount of bingo card sales. 

(3) Bingo card sale voids. Controls must be established for the voiding of bingo card sales. Bingo card 

voids must be processed in accordance with the rules of the game and established controls should include, 

but not be limited to, the following: 

(i) Patron refunds; 

(ii) Adjustments to bingo card sales to reflect voids; 

(iii) Adjustments to bingo card inventory, which may include but be not limited to: 

(A) Cancelling voided bingo cards and removing the returned bingo cards from inventory; or 

(B) Returning the returned bingo cards to inventory, making such cards available for future games. 

(iv) Document the reason for the void; and 

(v) Authorization for all voids. 

NIGC Comments

The use of “should” rather than “shall” or “must” in the guidance could lead the reader to believe that the 

standard is not required by the MICS but that it is recommended. Otherwise guidance appears relevant. 

EFFECT OF 2010 PROVISIONS: Bingo sales, which include voided bingo card sales, are the basis of the 

gaming activities that result in the revenues for the gaming operations and tribes. Exacting controls are 

therefore warranted to protect the assets and the revenue streams. The bingo sales and voids must be 

accurately tracked and verified to ensure the gaming operation records and accounts for its bingo revenues 

accurately. Basic revenue recognition requirements help reduce the risk of compromise to a gaming 

operation’s and tribe’s bingo sales.. 

EFFECT OF TGWG PROPOSED AMENDMENT: The proposed addition, modification and deletions are not 

consistent with 543.7(a)(2) as there is a lack of basic revenue control procedures. For example, bingo sales 

and voids are not required to be recorded, accurately tracked or reconciled. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 11 of 25

 2010 Draft Proposed TGWG Change 

§ 543.7(b) Draw 

(1) Verification and display. 

(i) Procedures must be established and implemented to 

ensure the identity of each object drawn is accurately 

recorded and transmitted to the participants. The 

procedures must identify the method used to ensure 

the identity of each object drawn. 

(ii) For all games offering a prize payout of $1,200 or 

more, as the objects are drawn, the identity of the 

objects must be immediately recorded and maintained 

for a minimum of 24 hours. 

(iii) Controls must be present to assure that all objects 

eligible for the draw are available to be drawn prior to 

the next draw. 

§ 543.7 (f) Draw 

(1) Verification and display. 

(i) Procedures must be established and implemented to 

ensure the identity of each object drawn is accurately 

recorded and transmitted to the participants. The 

procedures must identify the method used to ensure 

the identity of each object drawn.

(iii) (1) Controls must be established requiring present 

to assure that all objects eligible for the draw are 

available to be drawn prior to the next draw. 

(2) The draw must be controlled in a manner that 

ensures random selection of the objects drawn.

(3) The draw must be controlled in a manner that 

ensures the identity of each object drawn is accurately 

recorded and transmitted to the participants. The 

procedures must identify the method used to ensure 

the identity of each object drawn.

(ii) For all games offering a prize payout of $1,200 or 

more, as the objects are drawn, the identity of the 

objects must be immediately recorded and maintained 

for a minimum of 24 hours.

(iii) Controls must be established requiring present to

assure that all objects eligible for the draw are 

available to be drawn prior to the next draw. 

TGWG Guidance

(f) Bingo Cards – Draw. 

(1) Controls must be established to ensure that all eligible objects used in the conduct of the bingo game are 

available to be drawn and that the physical integrity of the objects has been verified. Verification of 

physical objects must be performed before the start of the first bingo game/session and be verified by two 

agents. Best practice suggests that one of the agents be either a supervisory agent or independent of the 

bingo games department. Where the objects are electronic, certification in accordance with 25 CFR Part 

547 is acceptable for verifying the integrity of the objects. 

(2) The draw must be controlled in a manner that ensures random selection of the objects drawn. Where 

the selection is electronic, certification in accordance with 25 CFR Part 547 is acceptable for verifying the 

randomness of the draw. 

(3) Controls should be established over the draw to: 

(i) Verify the identity of the objects as they are drawn; 

(ii) Accurately record the drawn objects; and 

(iii) Transmit the identity of the drawn objects to the participants. For example, each bingo blower/console 

should have a dedicated camera monitoring, and displaying to the participants, the balls as they are drawn. 

(4) Controls should be established to provide a method of recall of the draw, which includes the order and 

identity of the objects drawn, for dispute resolution purposes. 

NIGC Comments
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 12 of 25

The use of “should” rather than “shall” or “must” in the guidance could lead the reader to believe that the 

standard is not required by the MICS but that it is recommended. Otherwise guidance appears relevant. 

EFFECT OF 2010 PROVISIONS: The current regulations are intended to protect the integrity of the bingo draw 

process. The regulation requires gaming operations to establish and implement procedures that ensure each 

object drawn is properly identified, transmitted to the patrons, recorded, and then placed back into the game 

for the next draw. The regulations also require the results of bingo games offering large payouts that are 

reportable to the Internal Revenue Service (IRS) be recorded and maintained for 24 hours to allow for 

independent verification by gaming operation management personnel. 

EFFECT OF TGWG PROPOSED AMENDMENT: The proposed addition, modification and deletions are not 

consistent with 543.7(b) as the standards do not require written procedures to protect the integrity of the 

bingo game draw process nor are large bingo payouts adequately protected or available for verification. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 13 of 25

 2010 Draft Proposed TGWG Change 

§ 543.7 (c) Manual Payouts and Short Pays. 

(1) Procedures must be established and 

implemented to prevent unauthorized access 

or fraudulent transactions using manual 

payout documents, including: 

(i) Payout documents must be controlled and 

completed in a manner that is intended to prevent a 

custodian of funds from altering the dollar amount 

on all parts of the payout document subsequent to 

the manual payout and misappropriating the funds. 

(ii) Payout documents must be controlled and 

completed in a manner that deters any one 

individual from initiating and producing a 

fraudulent payout document, obtaining the funds, 

forging signatures on the payout document, routing 

all parts of the document, and misappropriating the 

funds. Recommended procedures of this standard 

include but are not limited to the following: 

(A) Funds are issued either to a second verifier of 

the manual payout ( i.e. , someone other than the 

agents who generated/requested the payout) or to 

two agents concurrently ( i.e. , the 

generator/requestor of the document and the verifier 

of the manual payout). Both witness the manual 

payout; or 

(B) The routing of one part of the completed 

document is under the physical control ( e.g. , 

dropped in a locked box) of an agent other than the 

agent that obtained/issued the funds and the agent 

that obtained/issued the funds must not be able to 

place the document in the locked box. 

(iii) Segregation of responsibilities. The functions of 

sales and prize payout verification must be 

segregated, if performed manually. Agents who sell 

bingo cards on the floor must not verify bingo cards 

for prize payouts with bingo cards in their 

possession of the same type as the bingo card being 

verified for the game. Floor clerks who sell bingo 

cards on the floor are permitted to announce the 

identifiers of winning bingo cards. 

(iv) Validation. Procedures must be established and 

implemented to determine the validity of the claim 

prior to the payment of a prize ( i.e. , bingo card was 

sold for the game played, not voided, etc.) by at 

least two persons. 

(v) Verification. Procedures must be established and 

implemented to ensure that at least two persons 

verify the winning pattern has been achieved on the 

winning card prior to the payment of a prize. 

(vi) Authorization and signatures. (A) A Class II 

§ 543.7(g) Manual Payouts and Short Pays. 

(1) Procedures must be established and implemented 

to prevent unauthorized access or fraudulent 

transactions using manual payout documents, 

including:.

(i) Payout documents (1) Payouts must be controlled 

and completed in a manner that is intended to prevent 

a custodian of funds from altering the dollar amount 

on all parts of the payout document subsequent to the 

manual payout and misappropriating the funds.

(ii) Payout documents must be controlled and 

completed in a manner that deters any one individual 

from initiating and producing a fraudulent payout 

document, obtaining the funds, forging signatures on 

the payout document, routing all parts of the 

document, and misappropriating the funds. 

Recommended procedures of this standard include 

but are in a manner designed to verify winning events 

and prevent unauthorized access to, or 

misappropriation of, cash or cash equivalents. Such 

controls shall include, but not be limited to, the 

following: 

(A) Funds are issued either to a second verifier of the 

manual payout (i.e., someone other than the agents 

who generated/requested the payout) or to two agents 

concurrently (i.e., the generator/requestor of the 

document and the verifier of the manual payout). 

Both witness the manual payout; or (i) Payout 

records;

(B) The routing of one part of the completed 

document is under the physical control ( e.g., dropped 

in a locked box) of an agent other than the agent that 

obtained/issued the funds and the agent that 

obtained/issued the funds must not be able to place 

the document in the locked box.

(iii) Segregation of responsibilities. The functions of 

sales and prize payout verification must be 

segregated, if performed manually. Agents who sell 

bingo cards on the floor must not verify bingo cards 

for prize payouts with bingo cards in their possession 

of the same type as the bingo card being verified for 

the game. Floor clerks who sell bingo cards on the 

floor are permitted to announce the identifiers of 

winning bingo cards.

(iv

(ii) Validation. Procedures must be established and 

implemented to determine the validity of the claim 

prior to the payment of a prize (i.e., bingo card was 

sold for the game played, not voided, etc.) by at least 

two persons.
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 14 of 25

gaming system may substitute as one 

authorization/signature verifying, validating or 

authorizing a winning card of less than $1,200 or 

other manual payout. Where a Class II gaming 

system substitutes as an authorization/signature, the 

manual payout is subject to the limitations provided 

in this section. 

(B) For manual prize payouts of $1,200 or more and 

less than a predetermined amount not to exceed 

$50,000, at least two agents must authorize, sign 

and witness the manual prize payout. 

( 1 ) Manual prize payouts over a predetermined 

amount not to exceed $50,000 must require one of 

the two signatures and verifications to be a 

supervisory or management employee independent 

of the operation of bingo. 

( 2 ) This predetermined amount, not to exceed 

$50,000, must be authorized by management, 

approved by the tribal gaming regulatory authority, 

documented, and maintained. 

(2) Documentation, including: 

(i) Manual payouts and short-pays exceeding $10 

must be documented on a two-part form, of which a 

restricted system record can be considered one part 

of the form, and documentation must include the 

following information: 

(A) Date and time; 

(B) Player interface identifier or game identifier; 

(C) Dollar amount paid (both alpha and numeric) or 

description of personal property awarded, including 

fair market value. Alpha is optional if another 

unalterable method is used for evidencing the 

amount paid; 

(D) Type of manual payout ( e.g. , prize payout, 

external bonus payout, short pay, etc.); 

(E) Game outcome ( e.g. , patterns, symbols, bingo 

card identifier/description, etc.) for manual prize 

payouts, external bonus description, reason for short 

pay, etc.; 

(F) Preprinted or concurrently printed sequential 

manual payout identifier; and 

(G) Signatures or other authorizations, as required 

by this part. 

(ii) For short-pays of $10 or less, the documentation 

(single-part form or log is acceptable) must include 

the following information: 

(A) Date and time; 

(B) Player interface number; 

(C) Dollar amount paid (both alpha and numeric). 

Alpha is optional if another unalterable method is 

used for evidencing the amount paid; 

(D) The signature of at least one agent verifying and 

witnessing the short pay; and 

(E) Reason for short pay. 

(iii) In other situations that allow an agent to input a 

(v) Verification. Procedures must be established and 

implemented to ensure that at least two persons 

verify the winning pattern has been achieved on the 

winning card prior to the payment of a prize.and 

verification;

(vi) Authorization and signatures. (A) A Class II 

gaming system may substitute as one 

authorization/signature verifying, validating or 

authorizing a winning card of less than $1,200 or 

other manual payout. Where a Class II gaming 

system substitutes as an authorization/signature, the 

manual payout is subject to the limitations provided 

in this section.(iii) Authorization or signatures; and

(B) For manual prize payouts of $1,200 or more and 

less than a predetermined amount not to exceed 

$50,000, at least two agents must authorize, sign and 

witness the manual prize payout.

(1) Manual prize payouts over a predetermined 

amount not to exceed $50,000 must require one of 

the two signatures and verifications to be a 

supervisory or management employee independent of 

the operation of bingo.

(2) This predetermined amount, not to exceed 

$50,000, must be authorized by management, 

approved by the tribal gaming regulatory authority, 

documented, and maintained.

(2) Documentation, including:

(i) Manual payouts and short-pays exceeding $10 

must be documented on a two-part form, of which a 

restricted system record can be considered one part of 

the form, and documentation, must include the 

following information:

(A) Date and time;

(B) Player interface identifier or game identifier;

(C) Dollar amount paid (both alpha and numeric) or 

description of personal property awarded, including 

fair market value. Alpha is optional if another 

unalterable method is used for evidencing the amount 

paid;

(D) Type of manual payout (e.g., prize payout, 

external bonus payout, short pay, etc.);

(E) Game outcome (e.g., patterns, symbols, bingo 

card identifier/description, etc.) for manual prize 

payouts, external bonus description, reason for short 

pay, etc.;

(F) Preprinted or concurrently printed sequential 

manual payout identifier; and

(G) Signatures or other authorizations, as required by 

this part.

(ii) For short-pays of $10 or less, the documentation 

(single-part form or log is acceptable) must include 

the following information:

(A) Date and time;

(B) Player interface number;

(C) Dollar amount paid (both alpha and numeric). 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 15 of 25

prize payout or change the dollar amount of the 

prize payout by more than $1 in a Class II gaming 

system that has an automated prize payout 

component, two agents, one of which is a 

supervisory employee, must be physically involved 

in verifying and witnessing the prize payout. 

(iv) For manually paid promotional prize payouts, 

as a result of the play of a game and where the 

amount paid is not included in the prize schedule, 

the documentation (single-part form or log is 

acceptable) must include the following information: 

(A) Date and time; 

(B) Player interface number; 

(C) Dollar amount paid (both alpha and numeric). 

Alpha is optional if another unalterable method is 

used for evidencing the amount paid; 

(D) The signature of at least one agent verifying and 

witnessing the manual promotional prize payout of 

$599 or less and two agents verifying and 

witnessing the manual promotional prize payout 

exceeding $599; 

(E) Description or name of the promotion; and 

(F) Total amount of manual promotional prize 

payouts must be recorded by shift, session or other 

relevant time period. 

(v) When a controlled manual payout document is 

voided, the agent completing the void must clearly 

mark “void” across the face of the document, sign 

across the face of the document and all parts of the 

document must be retained for accountability. 

Alpha is optional if another unalterable method is 

used for evidencing the amount paid;

(D) The signature of at least one agent verifying and 

witnessing the short pay; and

(E) Reason for short pay.

(iii) In other situations that allow an agent to input a 

prize payout or change the dollar amount of the prize 

payout by more than $1 in a Class II gaming system 

that has an automated prize payout component, two 

agents, one of which is a supervisory employee, must 

be physically involved in verifying and witnessing 

the prize payout.

(iv) For manually paid promotional prize payouts, as 

a result of the play of a game and where the amount 

paid is not included in the prize schedule, the 

documentation (single-part form or log is acceptable) 

must include the following information:

(A) Date and time;

(B) Player interface number;

(C) Dollar amount paid (both alpha and numeric). 

Alpha is optional if another unalterable method is 

used for evidencing the amount paid;

(D) The signature of at least one agent verifying and 

witnessing the manual promotional prize payout of 

$599 or less and two agents verifying and witnessing 

the manual promotional prize payout exceeding 

$599;

(E) Description or name of the promotion; and

(F) Total amount of manual promotional prize 

payouts must be recorded by shift, session or other 

relevant time period.

(v) When a controlled manual payout document is 

voided, the agent completing the void must clearly 

mark “void” across the face of the document, sign 

across the face of the document and all parts of the 

document must be retained for accountability. 

(iv) Voids.

 

TGWG Guidance

(i) Verification and Prize Payout Records. 

(1) Payout records, including manual payouts records. Payout records and forms must be controlled in a 

manner designed to prevent unauthorized access, misappropriation, fraud or forgery. 

(i) Best practice suggests that payout forms be multi-part (an electronic record may constitute one part) to 

ensure separate control of the cash accountability functions; and 

(ii) Procedures should require funds issued for payouts to be witnessed and verified against the payout 

record or form by an agent other than the agent issuing the payout. 

(2) Payout forms should include the following: 

(i) Date and time; 

(ii) Amount of the payout (alpha and numeric); 

(iii) Player interface identifier or bingo card identifier; and 

(iv) Manual payouts should also include the following: 

(A) Game name or number; 

(B) Description of event (i.e., pattern covered, player interface malfunction, etc.) as applicable; 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 16 of 25

(C) Signature of all agents involved in the transaction; 

(1) Best practice suggests that at least two agents perform the manual payout and sign the manual payout 

document. 

(D) Override reason(s); and 

(1) Best practice suggests the agent verifies the amount of the prize at the player interface to the accounting 

system amount. If the player interface amount is different than the accounting system amount an override 

may be necessary and, if so, should be properly documented. For example, if the player interface indicates 

a verified prize of $1,250.00 but the accounting system reflects $1,249.00, then the accounting system may 

require an override to process the manual payout. 

(E) Any other information necessary to substantiate the payout. 

(3) Controls should be established to segregate the functions of seller and payout verifier. Agents who sell 

bingo cards should not be the sole verifier of bingo cards for prize payouts. However, such agents may be 

permitted to announce the numbers or designations on the winning bingo cards to the verifier. 

(4) Validation and Verification. Controls must include steps to verify the following is valid for the game in 

play prior to payment of a winning prize: 

(i) Winning card(s); 

(ii) Objects drawn; and 

(iii) The previously designated arrangement of numbers or designations on such cards, as described in 25 

USC 2703(7)(A) (i.e., winning pattern). 

(iv) Best practice suggests at least two agents perform the validation and verification. Where an automated 

verification method (e.g., electronic verifier, software program, among others) is available, validation and 

verification by such method is acceptable. 

(5) Authorization or Signatures. 

(i) Controls should be established in a manner designed to prevent unauthorized access or misappropriation 

of cash or cash equivalents by identifying the agent authorized (by position) to make a payout and at what 

levels. 

(ii) In addition, controls should include how many agents are required for authorization or signature for 

each predetermined level of payout. This could be accomplished through the use of a matrix, an example 

of which is provided below. 

Example of Authorization or Signature Matrix (The dollar amounts noted in this matrix are examples only. 

Each operation should perform a risk assessment to determine appropriate payout levels and 

authorizations.): 

Payouts up to $1,199.99 

 

Originator of Payout Funds: Cage Cashier, Paymaster, Kiosk, or automated funds dispenser 

Originator of Payout Document: Automated payout method 

Verifier of bingo card, pattern, & amount: Automated verification method 

Verifier of payment: Automated payout method 

 

Payouts equal to or greater than to $1,200.00 

 

Originator of Payout Funds: Cage Cashier or Paymaster 

Originator of Payout Document: Automated payout method 

Verifier of bingo card, pattern, & amount: Floor Person, Caller and/or automated verification method 

Verifier of payment: Floor Person and Floor Supervisor 

 

Per current IRS regulations, a W-2G or 1042-S form is required to be completed for payouts $1,200.00 and 

above. Such regulations are subject to change and controls should be updated accordingly. 

Manual Payouts up to $4,999.99 

 

Originator of Payout Funds: Cage Cashier or Paymaster 

Originator of Payout Document: Paymaster 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 17 of 25

Verifier of bingo card, pattern, & amount: Floor Supervisor, Floor Person, Security, or Technician 

Verifier of payment: Floor Supervisor and Security 

 

Per current IRS regulations, a W-2G or 1042-S form is required to be completed for payouts $1,200.00 and 

above. Such regulations are subject to change and controls should be updated accordingly. 

 

Manual Payouts $5,000.00 to $19,999.99 

 

Originator of Payout Funds: Cage Cashier or Paymaster 

Originator of Payout Document: Floor Supervisor or Floor Person 

Verifier of bingo card, pattern, & amount: Floor Supervisor (other than originator) or Floor Person (other 

than originator) or Security or Technician; and 

Verifier of Payment: Shift Manager 

 

Per current IRS regulations, a W-2G or 1042-S form is required. Such regulations are subject to change 

 

Manual Payouts $20,000.00 and over 

 

Originator of Payout Funds: Cage Cashier 

Originator of Payout Document: Floor Supervisor or Floor Person 

Verifier of bingo card, pattern, & amount: Shift Manager and Floor Supervisor (other than 

originator) or Technician; and 

Verifier of Payment: Security Manager or Security Supervisor 

 

Per current IRS regulations, a W-2G or 1042-S form is required to be completed. Such 

regulations are subject to change. 

 

1.(6) Voids. Documentation must include the reason for voids and signatures of both the originating agent 

and a supervisory agent. Best practice suggests that a supervisory agent process the voiding of manual 

payout forms. 

NIGC Comments

The use of “should” rather than “shall” or “must” in the guidance could lead the reader to believe that the 

standard is not required by the MICS but that it is recommended. Guidance for “Manual Payouts $5,000.00 

to $19,999.99 and Manual Payouts $20,000.00 and over” appear burdensome and detailed, but otherwise 

the guidance appears relevant. 

EFFECT OF 2010 PROVISIONS: The current regulations are intended to protect the assets of the gaming 

operation and tribe by requiring exacting controls over the bingo prize payout process. The payment of 

bingo prizes poses the highest risk of compromise to a gaming operation and numerous tribal casinos have 

suffered significant losses from thefts and embezzlements in the past. 

EFFECT OF TGWG PROPOSED AMENDMENT: The proposed additions, modifications and deletions are not 

consistent with 543.7(c) and do not appear to provide the controls required for the high risk transactions of 

bingo prize payouts. It has been a long established procedure that when large gaming prize payouts occur, 

two employees are present to verify and witness the transaction. The majority of the proposed standard 

removes the two employee requirement altogether as well as the records required to document the payout 

transaction. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 18 of 25

 2010 Draft Proposed TGWG Change 

§ 543.7 (d) Operational controls. 

(1) Procedures must be established and implemented 

with the intent to prevent unauthorized access to or 

fraudulent transactions involving cash or cash 

equivalents. 

(2) Cash or cash equivalents exchanged between two 

persons must be counted independently by at least two 

persons and reconciled to the recorded amounts at the 

end of each shift or if applicable each session. 

Unexplained variances must be documented and 

maintained. Unverified transfers of cash or cash 

equivalents are prohibited. 

(3) Procedures must be established and implemented 

to control cash or cash equivalents in accordance with 

this section and based on the amount of the 

transaction. These procedures include, but are not 

limited to, counting and recording on an accountability 

form by shift, session or relevant time period the 

following: 

(i) Inventory, including any increases or decreases; 

(ii) Transfers; 

(iii) Exchanges, including acknowledging signatures 

or initials; and 

(iv) Resulting variances. 

(4) Any change of control of accountability, exchange 

or transfer must require the cash or cash equivalents be 

counted and recorded independently by at least two 

persons and reconciled to the recorded amount. 

§ 543.7 (d) Operational controls. 

(1) Procedures must be established and implemented 

with the intent to prevent unauthorized access to or 

fraudulent transactions involving cash or cash 

equivalents.

(2) Cash or cash equivalents exchanged between two 

persons must be counted independently by at least two 

persons and reconciled to the recorded amounts at the 

end of each shift or if applicable each session. 

Unexplained variances must be documented and 

maintained. Unverified transfers of cash or cash 

equivalents are prohibited.

(3) Procedures must be established and implemented 

to control cash or cash equivalents in accordance with 

this section and based on the amount of the 

transaction. These procedures include, but are not 

limited to, counting and recording on an accountability 

form by shift, session or relevant time period the 

following:

(i) Inventory, including any increases or decreases;

(ii) Transfers;

(iii) Exchanges, including acknowledging signatures 

or initials; and

(iv) Resulting variances.

(4) Any change of control of accountability, exchange 

or transfer must require the cash or cash equivalents be 

counted and recorded independently by at least two 

persons and reconciled to the recorded amount. 

(h) Cash and cash equivalent controls. Cash and cash 

equivalents must be controlled in a manner designed to 

prevent unauthorized access, misappropriation, 

forgery, theft or fraud. Such controls shall be in 

accordance with cash and cash equivalent controls 

established in sub part 543.14.

TGWG Guidance

(i) Cash and Cash Equivalents. Controls should be established for cash and cash equivalents in accordance 

with MICS 543.14 (What are the minimum internal control standards for cage, vault, cash, and cash 

equivalents?) and the guidance provided in the associated document. Procedures should also comply with 

all applicable federal regulations (e.g., IRS code, Title 31, among others). 

NIGC Comments

EFFECT OF 2010 PROVISIONS: The current regulations are intended to protect the assets of the gaming 

operation and tribe by requiring exacting controls over the cash and cash equivalents including: dual counts 

of the cash and cash equivalents, inventory and storage of currency, exchanges between employees, and 

variance investigations when cash and cash equivalents are missing. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 19 of 25

EFFECT OF TGWG PROPOSED AMENDMENT: The proposed deletions and additions are not consistent with 

543.7(d) and remove all standards governing cash and accountability of the funds used in gaming 

transactions. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 20 of 25

 2010 Draft Proposed TGWG Change 

§ 543.7 (e) Gaming equipment. 

(1) Procedures must be established and implemented 

with the intention to restrict access to agents for the 

following: 

(i) Controlled gaming equipment/components ( e.g. , 

draw objects and back-up draw objects); and 

(ii) Random number generator software. (Additional 

information technology security standards can be 

found in §543.16 of this part.) 

(2) The game software components of a Class II 

gaming system will be identified in the test laboratory 

report. When initially received, the software must be 

verified to be authentic copies, as certified by the 

independent testing laboratory. 

(3) Procedures must be established relating to the 

periodic inspection, maintenance, testing, and 

documentation of a random sampling of gaming 

equipment/components, including but not limited to: 

(i) Software related to game outcome must be 

authenticated semi-annually by an agent independent 

of bingo operations by comparing signatures against 

the test laboratory letter on file with the tribal gaming 

regulatory authority for that version. 

(ii) Class II gaming system interfaces to external 

systems must be tested annually for accurate 

communications and appropriate logging of events. 

(4) Records must be maintained for each player 

interface that indicate the date the player interface was 

placed into service or made available for play, the date 

the player interface was removed from service and not 

available for play, and any changes in player interface 

identifiers. 

 

§ 543.7 (e) Gaming equipment.

(1) Procedures must be established and implemented 

with the intention to restrict access to agents for the 

following:

(i) Controlled gaming equipment/components ( e.g. , 

draw objects and back-up draw objects); and

(ii) Random number generator software. (Additional 

information technology security standards can be 

found in §543.16 of this part.)

(2) The game software components of a Class II 

gaming system will be identified in the test laboratory 

report. When initially received, the software must be 

verified to be authentic copies, as certified by the 

independent testing laboratory.

(3) Procedures must be established relating to the 

periodic inspection, maintenance, testing, and 

documentation of a random sampling of gaming 

equipment/components, including but not limited to:

(i) Software related to game outcome must be 

authenticated semi-annually by an agent independent 

of bingo operations by comparing signatures against 

the test laboratory letter on file with the tribal gaming 

regulatory authority for that version.

(ii) Class II gaming system interfaces to external 

systems must be tested annually for accurate 

communications and appropriate logging of events.

(4) Records must be maintained for each player 

interface that indicate the date the player interface was 

placed into service or made available for play, the date 

the player interface was removed from service and not 

available for play, and any changes in player interface 

identifiers. 

(i) Technologic aids to the play of bingo. Internal 

control procedures must be established to safeguard 

the integrity of technologic aids to the play of bingo 

during installations, operations, modifications, and 

retirements. Such procedures must include, but not be 

limited to, the following:

(1) Shipping and receiving;

(2) Access credential control methods; 

(3) Record keeping and audit processes; 

(4) System software signature verification; 

(5) Testing;

(6) Display of rules and necessary disclaimers such as 

“Malfunctions void all prizes and pays", etc.

(7) Dispute resolution; 

(8) Malfunctions; and

(9) Removal, retirement, and/or destruction.
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 21 of 25

TGWG Guidance

(j) Technologic Aids to the Play of Bingo. Internal control procedures must be established to safeguard the 

integrity of technologic aids to the play of bingo during installations, operations, modifications, and 

retirements. Such procedures must include, but not be limited to, the following: 

(1) Shipping and receiving. 

(i) A communication process must be established between the supplier, the gaming operation and the 

TGRA to properly control the shipping and receiving process. Such process should include: 

(A) Establishing a notification procedure covering shipping dates and other TGRA requirements (e.g., 5-10 

business days shipping notification for Class II Gaming System new installation, or 3-5 business days 

shipping notification for Class II game play software, same or next day delivery for repair and replacement 

parts). Such notification procedure is communicated to the gaming operation and suppliers. 

(1) Best practice suggests that notification of pending shipments should be provided to the TGRA by the 

gaming operation. 

(2) Certification in accordance with 25 CFR §547 and approval by TGRA prior to shipment. 

(3) Supplier should provide notification to the TGRA, or the gaming operation as approved by the TGRA, 

of the shipping date and expected date of delivery. The shipping notification includes, but is not limited to: 

(i) Name and address of the supplier; 

(ii) Description of shipment; 

(iii) For player interfaces: an identifier; 

(iv) For software: program number and description of software; 

(v) Method of shipment; and 

(vi) Expected date of delivery. 

(4) Procedures should be established for the exchange of Class II gaming system components for 

maintenance and replacement (e.g., bingo card minders, screens, printers, bill acceptors, etc.). 

(ii) Class II gaming system components must be shipped in a secure manner to deter unauthorized access. 

(iii) Best practice suggests the TGRA, or its designee, receives all Class II gaming system components and 

game play software, and verifies against the shipping notification. 

(2) Access Credential Control Methods. 

(i) Controls should be established to restrict access to the Class II gaming system components. Such 

controls should ensure access is controlled through passwords, PINs, cards, or other credential controls. 

Refer to standards established under 543.16 Security and Management of Server, Server Software and Data 

Associated with Class II Gaming Systems. 

(3) Recordkeeping and Audit Processes. 

(i) Best practice suggests that the gaming operation, subject to TGRA requirements, should maintain the 

following records, as applicable, related to installed game servers and player interfaces: 

(A) Date placed into service; 

(B) Date made available for play; 

(C) Supplier; 

(D) Game software version number; 

(E) Unique identifier (i.e., serial number); 

(F) Game title; 

(G) Asset and/or location number; 

(H) Seal number; and 

(I) Initial meter reading. 

(ii) Controls should establish procedures for auditing such records in accordance with MICS 543.19 (What 

are the minimum internal control standards for audit and accounting?) and associated guidance documents. 

(4) System Software Signature Verification. 

(i) Procedures should be established relating to system software verifications. These procedures should 

include comparing signatures generated by the verification programs to the signatures provided in the 

independent test laboratory letter for that software version. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 22 of 25

(ii) Agents, independent of the bingo operation, should perform system software signature verification(s) to 

verify that only approved software is installed. 

(iii) Procedures should be established relating to the investigation and resolution of any software 

verification variances encountered. 

(iv) Best practice suggests internal audits be conducted at intervals established by the TGRA. Such audits 

should be documented. 

(5) Testing 

(i) Testing should be completed during the installation process to verify the player interface has been 

properly installed. This should include testing of the following as applicable: 

(A) Communication to the Class II Gaming System; 

(B) Communication to the accounting system; 

(C) Communication to the player tracking system; 

(D) Currency and vouchers to bill acceptor; 

(E) Voucher printing; 

(F) Meter incrementation; 

(G) Verification of paytable; 

(H) Verification of player interface denomination; 

(I) Verification that all buttons are operational and programmed appropriately; 

(J) System components are safely installed at location; and 

(K) Ensuring that locks are secure and functioning. 

(6) Display of Rules and Necessary Disclaimers 

(i) The TGRA, or the operation should verify that all game rules and disclaimers (i.e., “Malfunctions void 

all pays and plays.”) shall at all times be displayed or made readily available to the player upon request as 

required by 25 CFR Part 547. 

(k) Operations. 

(1) Dispute Resolution. 

(i) Controls and procedures must be established and approved by the TGRA, to investigate, document, and 

resolve patron disputes. Such procedures should include but not be limited to:

(A) Notifying upper management and/or the TGRA of the outstanding nature of the dispute; 

(B) Collecting and securing all records of the dispute; and 

(C) Providing patron(s) with instructions for available dispute resolution mechanisms.

(2) Malfunctions. 

(i) Procedures should be established to investigate, document and resolve malfunctions. Such procedures 

may address, but not be limited to, the following:

(A) Determination of the event causing the malfunction; 

(B) Review of relevant records, game recall, reports, logs, surveillance records; 

(C) Repair or replacement of the Class II gaming component; 

(D) Verification of the integrity of the Class II gaming component before restoring it to operation; and 

(E) Completion of requisite documentation. 

(3) Removal, Retirement and/or Destruction. 

(i) Procedures should be established to properly retire or remove any or all associated components of a 

Class II Gaming System from operation. Procedures may include, but are not limited to, the following:

(A) For player interfaces and components that accept cash or cash equivalents: 

(1) Coordinate with the drop team to perform a final drop; 

(2) Collect final accounting information (e.g., meter readings, drop, payouts, etc.); 

(3) Remove and/or secure any or all associated equipment from the retired or removed component (e.g., 

locks, card reader, ticket printer); and 

(4) Complete requisite documentation. 

(B) For removal of software components: 

(1) Purge and/or return the software to the license holder; and 

(2) Complete requisite documentation. 

(C) For other related equipment (e.g., blowers, cards, interface cards, etc.): 

(1) Remove and/or secure equipment; and 

(2) Complete requisite documentation. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 23 of 25

(D) For all components: 

(1) Verify that unique identifiers (i.e., serial numbers) and descriptions of removed/retired components are 

recorded on the retirement documentation; and 

(2) Coordinate with the accounting department to properly retire the component in the system records. 

(ii) Where the TGRA authorizes destruction of any Class II Gaming System components, procedures 

should be developed to properly destroy such components. Such procedures should include but not be 

limited to the following: 

(A) Methods of destruction; 

(B) Witness or surveillance of destruction; 

(C) Document all components destroyed; and 

(D) Signatures of agents destroying components attesting to destruction. 

(d) Audit and Accounting. 

(1) Controls must be established for audit and accounting in accordance with MICS 543.19 (What are the 

minimum internal control standards for audit and accounting?) and the guidance provided in the associated 

document. 

1. 

(2) Best practice suggests that each operational area secure daily audit and accounting records, forms, and 

documents prior to audit. For example, a cashier may place records in a locked box for next-day delivery 

to accounting for audit. 

NIGC Comments

The information in the above guidance appears to pertain to the technical standards. 

EFFECT OF 2010 PROVISIONS: The current regulations are intended to protect the integrity of the Class II 

gaming equipment. 

EFFECT OF TGWG PROPOSED AMENDMENT: The proposed deletions and additions appear consistent with 

543.7(e) and provide controls over the Class II gaming equipment. 
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 24 of 25

 2010 Draft Proposed TGWG Change 

§ 543.7 (f) Voucher systems. 

(1) The voucher system must be utilized to verify the 

authenticity of each voucher or coupon redeemed. 

(2) If the voucher is valid, the patron is paid the 

appropriate amount. 

(3) Procedures must be established and implemented 

to document the payment of a claim on a voucher that 

is not physically available or a voucher that cannot be 

validated ( e.g. , mutilated, expired, lost, stolen, etc.). 

(i) If paid, appropriate documentation is retained for 

reconciliation purposes. 

(ii) Payment of a voucher for $50 or more, a 

supervisory employee must review the applicable 

voucher system, player interface or other transaction 

history records to verify the validity of the voucher 

and initial the voucher or documentation prior to 

payment. 

(4) Vouchers redeemed must remain in the cashier's 

accountability for reconciliation purposes. The 

voucher redemption system reports must be used to 

ensure all paid vouchers have been validated. 

(5) Vouchers paid during a period while the voucher 

system is temporarily out of operation must be marked 

“paid”, initialed and dated by the cashier. If the 

voucher is greater than a predetermined amount 

approved (not to exceed $500), a supervisory 

employee must approve the payment and evidence that 

approval by initialing the voucher prior to payment. 

(6) Paid vouchers are maintained in the cashier's 

accountability for reconciliation purposes. 

(7) Upon restored operation of the voucher system, 

vouchers redeemed while the voucher system was 

temporarily out of operation must be validated as 

expeditiously as possible. 

(8) Unredeemed vouchers can only be voided in the 

voucher system by supervisory employees. The 

supervisory employee completing the void must 

clearly mark “void” across the face of the voucher and 

sign across the face of the voucher, if available. The 

accounting department will maintain the voided 

voucher, if available. 

§ 543.7 (f) Voucher systems.

(1) The voucher system must be utilized to verify the 

authenticity of each voucher or coupon redeemed.

(2) If the voucher is valid, the patron is paid the 

appropriate amount.

(3) Procedures must be established and implemented 

to document the payment of a claim on a voucher that 

is not physically available or a voucher that cannot be 

validated ( e.g. , mutilated, expired, lost, stolen, etc.).

(i) If paid, appropriate documentation is retained for 

reconciliation purposes.

(ii) Payment of a voucher for $50 or more, a 

supervisory employee must review the applicable 

voucher system, player interface or other transaction 

history records to verify the validity of the voucher 

and initial the voucher or documentation prior to 

payment.

(4) Vouchers redeemed must remain in the cashier's 

accountability for reconciliation purposes. The 

voucher redemption system reports must be used to 

ensure all paid vouchers have been validated.

(5) Vouchers paid during a period while the voucher 

system is temporarily out of operation must be marked 

“paid”, initialed and dated by the cashier. If the 

voucher is greater than a predetermined amount 

approved (not to exceed $500), a supervisory 

employee must approve the payment and evidence that 

approval by initialing the voucher prior to payment.

(6) Paid vouchers are maintained in the cashier's 

accountability for reconciliation purposes.

(7) Upon restored operation of the voucher system, 

vouchers redeemed while the voucher system was 

temporarily out of operation must be validated as 

expeditiously as possible.

(8) Unredeemed vouchers can only be voided in the 

voucher system by supervisory employees. The 

supervisory employee completing the void must 

clearly mark “void” across the face of the voucher and 

sign across the face of the voucher, if available. The 

accounting department will maintain the voided 

voucher, if available. 

TGWG Guidance 

None 

NIGC Comments
§ 543.7 What are the minimum internal control standards for bingo? 

Comparison of TGWG to 2010 Draft Regulation 

Page 25 of 25

EFFECT OF 2010 PROVISIONS: The current regulations are intended to protect the assets of the gaming 

operations and tribes by requiring controls over vouchers issued by Class II bingo systems and the 

subsequent payout process. The vouchers and payouts pose the highest risk to a gaming operation of being 

compromised and numerous tribal casinos have suffered significant losses from thefts and embezzlements 

in the past. 

EFFECT OF TGWG PROPOSED AMENDMENT: The proposed deletions are not consistent with 543.7(f) as they 

remove all standards governing vouchers and the subsequent payout process.