1 IN THE UNITED STATES OF AMERICA

2 * * * * * * * * * * * * * * * * * * * * * * * * * *

3 In Re:

4

5 NATIONAL INDIAN GAMING COMMISSION

6

7 REGULATORY REVIEW

8

9 * * * * * * * * * * * * * * * * * * * * * * * * * *

10

11 June 13th, 2011

12

13 9:16 a.m. to 11:26 a.m.

14

15 at

16

17 HYATT REGENCY HOTEL

18 LAKESHORE BOARDROOM

19 333 WEST KILBOURN AVENUE

20 MILWAUKEE, WISCONSIN 53203

21

22

23 Job No. NJ331341

24 Reported by David W. Wahlberg

25 * * * * * * * * * * * * * * * * * * * * * * * * * *

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1 A P P E A R A N C E S

2 CHAIRMAN DAN LITTLE, Associate Commissioner

3 MIKE HONECK, Assistant General Counsel

4 DAWN HOULE, Deputy Chief of Staff

5 JOHN GERBER, Regional Director

6 LINDA DURBIN, Field Investigator

7 JIM BENSON, Field Auditor

8 * * *

9 I N D E X

10 Statements By:

11 Chairman Little..................................003

12 Mr. Tippeconnie..................................004

13 Chairman Little..................................008

14 Ms. Houle........................................011

15 Chairman Little..................................022

16 Ms. Lash.........................................025

17 Chairman Little..................................026

18 Mr. Heffelfinger.................................027

19 Mr. Honeck.......................................027

20 Ms. Lash.....(Reading Chief Gamble's Letter).....040

21 Mr. Danforth.....................................045

22 Mr. Harris.......................................061

23 Mr. Valandra.....................................079

24 Mr. Lombardo.....................................097

25 Ms. House........................................101

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1 TRANSCRIPT OF PROCEEDINGS

2 CHAIRMAN LITTLE: Good morning. Wow,

3 that's loud. All right. We have a small crowd

4 today, but we're going to get started anyways.

5 I'd like to welcome all tribal leaders and

6 elders and tribal representatives that are

7 present to the NIGC Conference Session on

8 Groups 3 and 4 of our Regulatory Review

9 Schedule. On behalf of the entire Commission

10 we are very grateful and honored to be here and

11 I mean to address everyone this morning to

12 discuss these very important issues contained

13 in our Notice of Regulatory Review. My name is

14 Dan Little. I am the Associate Commissioner

15 with the NIGC, and today I'm here on behalf of

16 Chairwoman Tracie Stevens and Vice-Chairwoman

17 Steffani Cochran, who send their regards and

18 look forward to reviewing the transcript and

19 the comments that are submitted.

20 Before we get started, I would like to

21 turn the session over to Mr. Robert

22 Tippeconnie. I hope I said that correctly,

23 sir. He's with the Comanche Nation, and he's

24 going to start us off properly.

25 MR. TIPPECONNIE: That sounds tremendous.

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1 (General laughter.)

2 MR. TIPPECONNIE: You know, most of you

3 know, concurrent with this is the National

4 Congress of American Indians, and there are

5 many sessions ongoing, starting here at 9:00

6 o'clock as well, so we were here at 7:30.

7 Well, it's always smart to start quickly, and

8 I'd like to say I like what you said, because I

9 would like to say we're done with this. I have

10 a whole kind of outline of what we can do.

11 Well, anyway, the National Congress appreciates

12 that you're here. There's often conflict with

13 what we're doing, and you know that, and it's

14 always smart to be in consultation with each

15 other as you're consulting, but we welcome you

16 to be here and I know we just -- that's the

17 point we wanted to make, the National Congress.

18 And I know a lot of our tribal leaders are here

19 and active and some of our tribal leaders are

20 here today, and they may be members of National

21 Congress, may not, but I know all those gaming

22 tribes are very interested in this, like our

23 Comanche nation is, and so I just want to say

24 welcome and glad you're here, along with that.

25 Okay.

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1 CHAIRMAN LITTLE: Okay. Thank you. Prior

2 to coming to the Commission, I worked with

3 Mashantucket for 12 years and was a very active

4 participant in the National Consternate and can

5 appreciate all the great work that everyone

6 does, so very good point.

7 I also want to recognize the NIGC staff

8 that is here with me today. To my left is

9 Deputy Chief of Staff Dawn Houle. To my right

10 is, from our Office of General Counsel,

11 Attorney Mike Honeck. Then in our region

12 office from the St. Paul area, we have John

13 Gerber, who's a regional director, Linda

14 Durbin, she might be outside, she's a field

15 investigator, and one of our field auditors,

16 Jim Benson.

17 I think it would also be nice if we could

18 go around the room, maybe we could start on the

19 left here, and maybe folks might want to

20 introduce themselves and what tribe they're

21 representing or they're on behalf.

22 MR. DANFORTH: Good morning. Thank you,

23 Mr. Little. My name is Gerry Danforth, and I'm

24 here as a member of the Miami Tribes, of their

25 Development Authority. I'm a member of their

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1 Board of Directors.

2 SERGEANT AT ARMS: Mr. Commissioner,

3 Ladies and Gentlemen, if you push the button on

4 the left of your mike when you go to speak,

5 that'll activate it.

6 MR. DANFORTH: Do we need to say it again?

7 CHAIRMAN LITTLE: Naw.

8 (General laughter.)

9 MS. LASH: Good morning. My name is Robin

10 Lash. I'm an attorney and Gaming Commissioner

11 with the Miami Tribe.

12 MS. WILLIAMS: Hi ya and good morning.

13 I'm Donya Williams, councilperson and tribal

14 member of Miami Tribe of Oklahoma.

15 MR. LANKFORD: Good morning. I'm Second

16 Chief Lankford, Miami Tribe of Oklahoma.

17 MR. PITCHER: I'm Gregory Pitcher,

18 Government Relations with the Shawnee Tribe in

19 Miami, Oklahoma.

20 MR. TIPPECONNIE: I've already introduced

21 myself. Bob Tippeconnie, Comanche Nation.

22 MR. ROWE-KURAK: Janice Rowe-Kurak, I'm

23 Chairwoman, Iowa Tribe of Oklahoma.

24 MR. SNYDER: Good morning. My name is

25 Darwin Snyder and I represent the Winnebago

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1 Tribe of Nebraska. I'm a tribal council

2 member.

3 MR. MANN: My name is Lawrence Mann,

4 Forest County Potawatomi.

5 MR. HEFFELFINGER: I'm Tom Heffelfinger,

6 attorney for the Forest County Potawatomi

7 Gaming Commission.

8 MR. STOUSER: James Stouser, Stosselman

9 Kiowa League of Nation. (Phonetically spelled.)

10 MS. VANSCHYNDEL: Tamara VanSchyndel,

11 member of the Oneida Tribe of Wisconsin.

12 MR. SCHUYLER: Oscar Schuyler, OCGES.

13 MR. ERMATINGER: Kenneth Ermatinger, I'm

14 Executive Director of the Sault St. Marie Tribe

15 of Chippewa Indians Gaming Commission.

16 MR. MURPHY: Mike Murphy, Ho-Chunk Nation

17 Counsel.

18 MR. HARRIS: Ron Harris, Chief Executive

19 Officer, Miami Tribe of Oklahoma, and board

20 member.

21 MR. WEBSTER: Joe Webster, attorney with

22 Hobbs, Straus, Dean and Walker, on behalf of

23 the Seminole Tribe of Florida.

24 MR. LOMBARDO: Charlie Lombardo,

25 international party.

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1 (General laughter.)

2 CHAIRMAN LITTLE: I would like to invite

3 everybody to come sit at the table. We

4 obviously have plenty of room, so don't be

5 bashful. Okay. As many of you know, I came on

6 board with the Commission about a little bit

7 over a year ago. I'm originally from

8 Connecticut and prior to joining the Commission

9 I served with the Mashantucket Pequot for about

10 11 years, and then prior to that I worked with

11 the Connecticut State Assembly, and spent over

12 14 years in the Army, in the Army Reserve.

13 When the new Commission organized last

14 summer we developed a vision for this agency

15 that includes a commitment to building a

16 meaningful government to government working

17 relationship with tribes. In parliamentary

18 terms we are committed to respecting tribes as

19 the primary regulators, and we understand that

20 tribes and their regulators are most familiar

21 with their own operations. We know that tribes

22 differ from region to region and state to state

23 and so do the gaming operations. In order to

24 fully support tribal regulations we must work

25 with tribes to ensure the entire industry is

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1 maintained. Tribes, states and the NIGC each

2 have an important function in the regulatory

3 structure created by IGRA. The industry is

4 best protected when we can all perform our

5 goals effectively. We have heard from tribes

6 that the process of consultation is just as

7 important as the substance of the consultation.

8 Through government to government consultation

9 we can be cooperative, collaborative,

10 meaningful and must be an ongoing dialogue of

11 exchanging ideas. It is not merely a box to

12 check off when developing policy. You know, we

13 kind of sit here at this meeting and folks, you

14 know, probably would enjoy more participation.

15 However, any participation is good, and I think

16 that the NIGC is trying to really show our

17 willingness and desire to come out here and

18 meet with tribes and then provide every

19 opportunity available to hear your concerns as

20 we do move forward with these important

21 regulatory endeavors.

22 In January and February the NIGC held a

23 series of eight consultations through the

24 country enlisting tribal leaders and invited

25 their written comments to be submitted by

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1 February 12, 2011. After reviewing all the

2 consultations and transcripts submitted, on

3 April 1st of this year, the Commission

4 published a notice of regulatory review

5 schedule. The review schedule provides a

6 comprehensive agenda for addressing regulations

7 that were raised during that notice of inquiry

8 last fall. Based upon the tribal consultations

9 and comments the Commission decided to

10 organized their regulatory review into five

11 groups. They originally were groups three and

12 four. We've been doing this since, I think,

13 late April, and we started I and II and we will

14 end early next year. The regulations in each

15 group were reviewed separately from the

16 regulations in other groups, and specific

17 regulations in each group may proceed to the

18 regulatory review process independent from the

19 other regulations in a particular group. And

20 this was done because you've got some

21 regulations that are contentious and will

22 involve a lot of discussion and a lot of

23 consultation. We don't want others that I

24 think, you know, are in need of improvement or

25 change, that everybody can agree upon. That is

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1 why we're trying to do these independently. So

2 I guess that today we're going to talk about

3 the regulations included in groups three and

4 four of the Regulatory Review Schedule. I'm

5 going to turn the program over to Dawn Houle,

6 our Deputy Chief of Staff, and she's going to

7 go through kind of a more detailed explanation

8 of those specific items in groups three and

9 four. So a couple things. I know Dawn's going

10 to repeat, repeat some of these, but when you

11 speak, this is being transcribed, it'll be up

12 on our website, if you could just state your

13 name and your organization. So I will turn it

14 over to Dawn.

15 MS. HOULE: Good morning everybody. I

16 know time is of the essence and, as you all

17 know, there's lots of sessions going on and

18 everybody wants to get to them, so if I talk

19 too fast just let me know. I've been with the

20 NIGC since October of last year. I'm Chippewa

21 Cree from Noxon, Montana and this is my first

22 time being a fed, so I come from a

23 self-governance background, and I used to work

24 for the Quinault Indian Nation, as well as many

25 others. But I am excited to be here to learn

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1 about the issues affecting tribes and so with

2 that I will kick it off.

3 So as we all know there's an Executive

4 Order 13,175 Consultation and Coordination with

5 Indian Tribal Governments that was issued by

6 the president of the United States and as a

7 federal agency we definitely have to comply but

8 also find it very refreshing that we have

9 somebody that, a president that honors that and

10 respects that and has laid out some pretty

11 clear criteria for us. So with that, the

12 criteria set out in that policy is to formulate

13 and implement policies that have tribal

14 implications and it encourages tribes to

15 develop their own policies, to achieve program

16 objectives, as well as to defer to you to

17 establish standards, thankfully, and also in

18 determining whether to establish federal

19 standards, consult tribal officials as to the

20 need for federal standards and any alternatives

21 that would limit the scope of federal standards

22 or otherwise preserve the prerogatives and

23 authority of Indian tribes. Again, the power

24 is yours and I think it's, again, it's

25 refreshing to see that we're here listening to

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1 you instead of telling you what the policy's

2 going to be. So tribal consultation between

3 tribal governments and us, and only tribes and

4 their designees can attend and participate in

5 these meetings. So we've had media ask if they

6 could attend, we've had state legislators,

7 state representatives. This is your meeting

8 and we want to make sure that we don't want to

9 embarrass anybody, but if there's anybody

10 that's not a tribal representative, please

11 excuse yourself. This is tribal consultation.

12 The regulatory review process is a

13 three-phase approach. There's a preliminary

14 drafting phase, which we're currently in now,

15 and there's a proposed rule, which is

16 consultations and approximately 60-day comment

17 period and if the Commission decides to issue a

18 Notice of Proposal Rule-making, that would

19 accompany that, and then the third is the Final

20 Rule, which is approximately a 40-day written

21 comment period. And on our website we

22 reinforce all of those deadlines, so a lot of

23 these are going to be overlapping and Group 1

24 might be in the second phrase, Group 3 might be

25 in another phase, so definitely we encourage

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1 you to look at our website to keep track of

2 when those comment periods are going to end.

3 There's five groups of regulation, as Dan

4 outlined. Not any one of those groups

5 indicates a priority. We try to group like

6 subjects and factors and some of those, what

7 are the similar subject matter, what were some

8 of the priorities that the comments that were

9 received on the Notice of Inquiry and what kind

10 of estimated time would it take us to get

11 through some of those regulations and,

12 obviously, the resources to complete the

13 review. Some, like Dan said, are going to be a

14 little more straightforward and we can get

15 through them faster, and others take a little

16 bit more time. So those were the criteria of

17 how we grouped them, and that's that.

18 So the Regulatory Review consultation

19 process, as Dan was indicating, these are

20 preliminary discussion drafts for consultation

21 and everything is an initial working draft.

22 All of the meetings are transcribed and, again,

23 if you refer to our website you can review

24 those. From my former experience with the

25 Assistant Secretary of Meeting Affairs, the

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1 other tribal members or tribal counsel or

2 tribal leaders appreciated going and reading

3 what other tribes are saying to gain kind of an

4 insight or impact across the nation, and so

5 those are there and if you are not able to

6 attend any of the other groups, we encourage

7 you to submit something in writing, but keep in

8 mind those will be posted on the website. So

9 we definitely take what you're telling us for

10 the face value that it is and everything will

11 be reviewed and is reviewed and is considered.

12 Any proposed or final rule will include a

13 summary of comments received, and I believe the

14 approach is going to be, this is what we

15 received and this is the action that was taken.

16 Sometimes some of the comments are not

17 reflective of what the subject matter is.

18 Obviously, those are not considered, but at

19 least you'll know kind of a matrix of how these

20 responses will be used, I mean how your

21 comments will be used. The Commission is

22 committed to a clear and transparent process

23 and that's kind of that. So if you tell us

24 something, this is what we're going to do with

25 it, that's that matrix, or follow the matrix,

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1 hopefully, as I said, will be developed.

2 So the agenda today is Group 3, which is

3 Class II MICS and Class II Technical Standards,

4 as well as Group 4, Pilot Gram, Background and

5 Licensing and Management Contracts.

6 So quickly an overview for Group 4, we

7 have a current pilot program that's been in

8 existence since a long, long time. I think we

9 have 98 percent of all tribes participating in

10 it, so it doesn't really qualify as a pilot

11 project any more or pilot program. We'll talk

12 about access to fingerprint card processing for

13 non-PMOs and/or key employees, as well as

14 background requirements for management

15 contractors, access to off-site records held by

16 Third-party, and a review of collateral

17 agreements and discuss the definition of net

18 revenues and management fees.

19 So the Pilot Program, the Notice of

20 Inquiry requested comment on whether or not

21 this should be a formalized organization.

22 Right now the Pilot Program allows tribes to

23 submit notice of results to the NIGC and to

24 maintain completed applications and

25 investigative reports.

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1 Does anybody else need to turn their cell

2 phone off?

3 MR. HONECK: That was me.

4 CHAIRMAN LITTLE: I got lucky. Mine went

5 off when at the airport.

6 (General laughter.)

7 MS. HOULE: What would we do without that

8 noise? All of the commenters, we've received

9 support formalizing this program, as we have

10 either a regulation or policies.

11 So what are the issues affecting the

12 policy program? We kind of outlined them in

13 questions to spark dialogue and get some

14 feedback from you all. How will this

15 regulation change impact current ordinances?

16 Currently, IGRA provides for two types of

17 notifications: One, tribe to notify the NIGC of

18 the background results; and, tribe is to notify

19 the NIGC of issuance of a license. And then

20 the other question is, is how should this

21 notice be sent to NIGC?

22 Fingerprint Processing. And the NOI asked

23 if NIGC should allow access to fingerprint

24 processing for any employee designated by the

25 tribes. The majority of the comments received

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1 support this action.

2 Am I going too fast, too slow? I know I'm

3 reading to you and I apologize to those that

4 are not familiar with the two groups. We're

5 hoping to be comprehensive, and you're seeing

6 this all at once. So the NOI asks if

7 regulations should be revised, clarify that

8 management contractors of Class II and Class

9 III facilities must have a complete background

10 investigation, and again, the comments received

11 on this was that they support the

12 clarification, and then the other side is we

13 have no authority, NIGC has no authority to

14 approve Class III management contracts or to

15 require background investigations. Some

16 commenters also stated that most of these

17 issues are covered by the current compact.

18 So Management Contracts. Additional

19 comments received is how could the process be

20 streamlined while maintaining integrity of the

21 current process and who should qualify for the

22 streamlined process. And this is all related

23 to the approval of the Management Contract.

24 The NOI asked whether or not Part 531

25 should be revised to require the submission and

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1 approval of collateral agreements. The

2 majority of the comments support the

3 requirements of these submissions, and there

4 was some disagreement regarding whether or not

5 the Collateral Agreement should be approved by

6 the Chair. Additional comments received on

7 this was that NIGC didn't have the authority to

8 approve these collateral agreements. We

9 shouldn't second guess a tribal decision,

10 requiring approval of collateral agreements

11 would discourage private investments.

12 Agreements other than a management agreement

13 should be left to the discretion of the tribe.

14 Additionally, more comments were received about

15 NIGC has a trust responsibility to review and

16 approve the collateral agreements. Approval of

17 these agreements protects tribes from sole

18 proprietary interest violations and it could

19 discourage a business from attempting to take

20 advantage of a tribe and approval of collateral

21 agreements reduces the risks to both parties.

22 Access to off-site records held by a

23 third-party. NOI asked whether or not Part 571

24 should be revised to clarify NIGC access to

25 papers, books and records including at sites

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1 maintained by third parties. Some of the

2 comments received, a revision is unnecessary

3 because the NIGC already has access to all the

4 records, or some of the comments also suggested

5 that only clarification or suggested that only

6 clarifying that NIGC can access off-site

7 locations maintained by third parties.

8 Additional comments suggested requiring tribes

9 to maintain all their records on-site and

10 commenters also stated that NIGC should only

11 request records within their statutory

12 authority. Regulations should be revised to

13 deny NIGC access to Class III records.

14 Net Revenues and Management Fee. The NOI

15 asked whether or not the definition of net

16 revenues, management fees be defined to be

17 consistent with the general accepted accounting

18 principles. The majority of comments received

19 support this type of revision. Comments also

20 said we need to maintain compliance with IGRA.

21 If the intent is to change the calculation of

22 management fees, then different terminology

23 should be used and a repeal of the most recent

24 change to the definition is required to

25 maintain compliance with IGRA definitions. The

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1 definition needs clarification. These are some

2 of the questions being posed regarding

3 management fees. Would GIPRA provide

4 clarification? Not GIPRA. Would GAAP provide

5 clarification? How can the definition be

6 clarified while maintaining compliance with

7 IGRA definition of net revenue? So currently,

8 net revenue means gross gaming revenues of an

9 Indian gaming activity less amounts paid out

10 as, or paid for, prizes and total operating

11 expenses excluding management fees. 25 USC

12 Section 2703(9). So again, real quickly for

13 Group 3, Part 543 is Class II minimum internal

14 standards and Part 547 talks to technical

15 standards.

16 And the NOI asked how to proceed with the

17 revisions to these parts. Currently, 2008 MICS

18 implementation date is October 13th, 2011 and

19 additionally, until July of 2010, NIGC was

20 drafting changes to the Class II MICS, and

21 alternative draft rules submitted to the NIGC

22 by the Tribal Gaming Work Group are under

23 review.

24 So what are some of the issues affecting

25 Class II MICS and Class II Technical Standards?

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1 What are the key issues that need to be

2 addressed in the MICS? What are the key issues

3 that need to be addressed in the technical

4 standards? How have the Technical Standards

5 worked in the industry? And how should the

6 NIGC make revisions in the future to address

7 new and advanced technology? Like I said the

8 website will have a lot of these deadlines but

9 just as a reminder, Part 559, Facility License,

10 the deadline for written comments is June 17th,

11 so this Friday.

12 So if there's any questions now or in the

13 next eight months, when we get done with all

14 the reg reviews, please feel free to use our

15 website at reg.review@nigc.gov, or give us a

16 call at 202-632-7009. Thank you.

17 CHAIRMAN LITTLE: All right. Thank you,

18 Dawn. A couple, just a quick thing. We're

19 scheduled to go to 5:00 o'clock. We won't make

20 it to 5:00 o'clock, so we're going to progress

21 through the agenda. We're going to flip it. I

22 see Ron Harris is here, and he can talk a long

23 time about Group II, I mean Class II games. So

24 we're going to do Group 4 first and then we'll

25 get to the Group 3 one. Once again, when you

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1 speak, please state your name and your

2 organization for the transcriptionist. And I

3 think that was it. So we're going to just jump

4 right into Part 556 and 558 in Group 4, and as

5 you probably know, these are to help shield

6 Indian gaming from organized crime and other

7 corrupting influences by requiring background

8 investigations and reporting the results to the

9 NIGC for key employees and primary management

10 officials. Like Dawn had said, the Commission

11 has, or right, there was a pilot program that's

12 been in place for a long time. I'm sure that

13 some folks, Mike might know, probably ten

14 years.

15 MR. HONECK: Yes, at least.

16 CHAIRMAN LITTLE: At least ten years. And

17 from my understanding it's working pretty

18 effectively. And we would like to hear if

19 folks have some comments on that, should this

20 been promulgated into a regulation, don't broke

21 it if it's not fixed, I mean don't fix it if

22 it's not broken, something like that. Oh, one

23 other housekeepings. Some of you may have come

24 with prepared statements on a number of

25 different statements. If you'd like, you can

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1 do that now, you can make your complete

2 statement, you can summarize, you can submit

3 the entire copy into the transcript if you'd

4 like. It's up to you. So as we progress

5 through the meeting, if you would like to read

6 a statement on behalf of your organization,

7 please go right ahead. Let me correct that.

8 On behalf of your tribe or the tribe that you

9 represent, you can go right ahead, even though

10 it might not be on the topic that we're

11 discussing at that particular time. So I'll

12 leave that up to you. So going back to Parts

13 556 and 558, does anybody have any comments

14 about the pilot program? Yes, you can go back

15 to that screen if you'd like. I think some of

16 the questions in the Power Point that we had

17 kind of thrown out there was is there a need

18 to, you know, background check management

19 officials and contractors, I guess that's it,

20 but any anything, comments on the pilot

21 program? Yes, ma'am.

22 MS. LASH: Robin Lash with the Miami Tribe

23 of Oklahoma.

24 CHAIRMAN LITTLE: These are very

25 expensive.

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1 MS. LASH: They are.

2 CHAIRMAN LITTLE: They're nice.

3 MS. LASH: The Miami Tribe participates in

4 the pilot program and we support it. I don't

5 know that it would necessarily need to be a

6 regulation. I think as you say, it's not

7 broken, so why fix it. I think it works very

8 well. It saves a lot of time and accumulation

9 of paperwork. We do have the licensing

10 information in our office for inspection at any

11 time. I think that there was some concern

12 logistically at the presentation last week

13 about the fact that IGRA requires two

14 notifications, one where we send in the two

15 bills of determination and then normally we'd

16 try to just license it, and there was a request

17 that perhaps a form could be created for the

18 part two, that once you send back your notice

19 saying we concur, then you could send an

20 official notice that this person has in fact

21 been licensed, and that would address the issue

22 of two notifications. Thank you.

23 CHAIRMAN LITTLE: Great. Thank you very

24 much. That's helpful. Does anyone else have

25 anything further to add about the Pilot Program

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1 or anything else in Part 556 and 558,

2 Background and Licensing?

3 (No response.)

4 CHAIRMAN LITTLE: Well, moving right

5 along, then. Part 571, this details the

6 procedures the agency represents the users to

7 modern gaming and conduct investigations, and I

8 think that one of the topics that has come up

9 in some of the other consultations was about

10 the NIGC conducts investigations periodically

11 and I think tribes or facilities would like to

12 be notified or have some kind of a notice when

13 the NIGC has concluded with our investigation.

14 Does anybody have any comments or past

15 experiences they would like to share, you know,

16 what criteria should the NIGC use, should they

17 issue letters that our investigations have

18 concluded? Now this is with or without any

19 kind of an action taken. Does anybody have any

20 experience they would like to share?

21 (No response.)

22 CHAIRMAN LITTLE: Okay. Also included in

23 this part, we've heard comment about should the

24 NIGC create a different procedure for

25 requesting the records held by third parties

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1 other than tribes? I think that's where their

2 records are located off property.

3 (No response.)

4 CHAIRMAN LITTLE: This is a tough crowd

5 here. Okay. Should the NIGC notify tribes

6 that records held by third parties or held at

7 third-party locations --

8 MR. HEFFELFINGER: Could I ask a question

9 that actually goes back to the Power point?

10 CHAIRMAN LITTLE: Sure.

11 MR. HEFFELFINGER: My name is Tom

12 Heffelfinger with Potawatomi. We may have

13 moved so quickly we missed fingerprint

14 processing, but as part of this process has the

15 NIGC reached out to the FBI to obtain the FBI's

16 response or attitude towards providing tribes

17 more direct access or, I should say, direct

18 access to FBI fingerprint records?

19 CHAIRMAN LITTLE: Yes. I do understand we

20 have an end review. Mike might be able to talk

21 about this a little bit further.

22 MR. HONECK: We do have an MOU and we also

23 have been talking with FBI with their office in

24 I think West Virginia that does all the

25 fingerprinting processing. I'm not sure at

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1 what stage those talks are. The talks have

2 been going on for a while and I think we're

3 both trying to shape what the limits are and

4 what we can ask for and what direct access the

5 FBI can give, but I know that, yes, we are

6 talking with them about it. Not only access

7 directly to tribes but also whether FBI could,

8 if tribes elected to send in contractors or

9 people that they're doing business with for

10 background investigations, if FBI could even

11 look at those fingerprints and issues like

12 that.

13 MR. HEFFELFINGER: Again, Tom

14 Heffelfinger, Potawatomi. Is this the same MOU

15 that was in place five, six years ago, which

16 goes back to the 1990's or is there a new one?

17 MR. HONECK: I think it's the same MOU. I

18 don't know if it ever had an expiration date,

19 but I don't think anything new has been

20 developed, no, but I would have to double check

21 that before I could say 100 percent.

22 MR. HEFFELFINGER: Again, Tom Heffelfinger

23 Potawatomi. There it goes. We addressed this

24 issue with the prior commission about five

25 years ago, four years ago, and directly with

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1 the FBI and DOJ and we're quite frustrated by

2 the process, and Potawatomi processes a lot of

3 background investigations, and we're quite

4 frustrated to find that our options were very

5 limited because the FBI basically said that for

6 nonmanagement level employees and for vendors,

7 for example, getting access to fingerprints was

8 extraordinarily limited without either federal

9 legislation, state legislation or our hiring

10 somebody who the FBI, in other words, you had

11 to spend money or you go and lobby the heck out

12 of the issue. It seems to me that affording

13 tribes access to fingerprint data is in the

14 best interests of tribes as well as NIGC, but

15 that the tribes ought not be put in a position

16 where they either have to fork over a lot of

17 money for a commercial processing operation or

18 engage in a federal or state lobbying effort in

19 order to get that access, and it's the FBI that

20 is the hurdle, and so I guess my request would

21 be, or suggestion would be, based on Potawatomi

22 experience, is that the NIGC needs to take a

23 lead role in getting the FBI on board on this,

24 and that's going to require updating that MOU.

25 CHAIRMAN LITTLE: Yes, we've heard that

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1 before, you know, that tribes like us to be, or

2 try to expand their ability to access that

3 information for some employees. I appreciate

4 that comment. Does anyone have any other

5 comments about the fingerprinting process?

6 (No response.)

7 CHAIRMAN LITTLE: Okay. Go back to 571, I

8 guess. We talked about off-site records,

9 investigative closure letters. Mentioned that.

10 Does anybody have any comments about NIGC's

11 authority to access records that are held

12 off-site? Some have commented that we do have

13 that authority, some have commented that we

14 don't have that authority. I'd be interested

15 in hearing what anyone might have to say

16 regarding that. We've heard requests that how

17 would the NIGC keep information obtained from a

18 third-party confidential? Mr. Heffelfinger, do

19 you have anything you want to add?

20 MR. HEFFELFINGER: Well, actually, I was

21 seeking a clarification. When I read your

22 original proposal, it wasn't as clear to me.

23 Are we talking about, let's say we've got 150

24 bankers' boxes in a remote storage facility, or

25 are we talking about your accessing our bank

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1 records at Wells Fargo?

2 CHAIRMAN LITTLE: Hmm.

3 MR. HONECK: Well, I think, you know, I

4 would be interested to hear about both. I mean

5 I think definitely the first example, you know,

6 those would be anything in storage, if it's

7 pursuant to an investigation that the NIGC is

8 conducting then we would be interested to know

9 if you think that's something you think that we

10 should be able to have access to or be able to

11 demand access to, and definitely tribal records

12 that may be at a bank or at a financial company

13 that a tribe is working with.

14 MR. HEFFELFINGER: Again, Tom

15 Heffelfinger, Potawatomi. It seems to me

16 there's a significant difference, that if you

17 are talking about access to records that are

18 tribal records that are being stored in an

19 off-site location, that's a good business perk

20 that you don't want to tie up precious gaming

21 space to store old records and tribal records,

22 no matter where those tribal records are kept,

23 it seems to me you have the right to access

24 them, if the regs and IGRA authorize. However,

25 data that is confidential for other reasons,

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1 such as confidential financial data, you ought

2 not have access to, absent some level of

3 subpoena authority, and I will throw into that

4 category financial records like bank account

5 records which, as a sovereign nation, just like

6 any individual with other individual financial

7 rights, that those rights ought not be trumped.

8 So I think there's a significant difference,

9 depending upon whether there is an independent

10 level of confidentiality, such as financial.

11 CHAIRMAN LITTLE: Okay. Thank you.

12 MR. HONECK: Can I just ask him, do you

13 think that the Commission's current subpoena

14 power would cover that, or do you think it

15 would have to be narrowed or better defined?

16 MR. HEFFELFINGER: Never having had to

17 respond to one of your subpoenas because we

18 usually cooperate, it seems to me that the NIGC

19 subpoena authority has not reached the level of

20 giving NIGC access to confidential financial

21 data, which generally arrive at data under

22 federal law, will only be accessible either

23 through a court order, like a search warrant,

24 or some other kind of order, like a grand jury

25 subpoena, and the administrative record, that I

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1 do not believe would fall, rise to that level,

2 even within the Department of Justice, although

3 there is administrative subpoena authority

4 that's based on, I believe it's Congressional

5 action, that it gives DOJ a right to get

6 financial records through that. So it seems to

7 me that the current subpoena authority of the

8 NIGC does not reach to that level.

9 CHAIRMAN LITTLE: Anything else on that

10 one?

11 MR. HONECK: Thank you.

12 CHAIRMAN LITTLE: Here's another question.

13 Does anybody have any comments regarding how

14 the CRIT decision restricts the NIGC from

15 accessing Class III records?

16 (No response.)

17 CHAIRMAN LITTLE: Okay. We're making some

18 quick time here. I don't have any other

19 questions here. Any other questions you have,

20 Mike?

21 MR. HONECK: No, no questions.

22 CHAIRMAN LITTLE: Okay. Then I think

23 we're going to move on to Part 531, Collateral

24 Agreements, and that's a contentious topic for

25 some. I think the purpose of this regulation

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1 is to specify what must be included in a

2 management contract for it to be approved. In

3 the NOI we got some comments. The majority of

4 the comments support requiring the submission

5 of collateral agreements relating to management

6 contracts. There was some disagreement among

7 commenters regarding whether collateral

8 agreements should be approved by the chair.

9 Should the Commission consider whether it has

10 the authority to approve collateral agreements

11 for the management contracts? Anybody have any

12 comment on that?

13 (No response.)

14 CHAIRMAN LITTLE: Don't everybody speak up

15 at once. Should the Commission revise Part 531

16 to require permission to approve collateral

17 agreements?

18 MS. LASH: Robin Lash with the Miami

19 Tribe. It's our position, I don't believe that

20 the NIGC should approve the collateral

21 agreements. I think that that's kind of a

22 paternalistic role on behalf of the NIGC.

23 Tribes are advanced, have legal counsel and are

24 doing business in ways outside of gaming and I

25 think that tribes are well able to take care of

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1 themselves without needing oversight with

2 collateral agreements.

3 CHAIRMAN LITTLE: I'd be lying if I didn't

4 say that I didn't hear something similar from

5 other stuff. Appreciate your comment. Thank

6 you. At the NOI folks said that you should not

7 be second guessing tribal business decisions

8 without the authority. Requiring these

9 agreements could discourage private investment.

10 MR. HEFFELFINGER: Again, Tom

11 Heffelfinger, Potawatomi. I won't repeat the

12 comments we've made in writing to you earlier

13 after prior consultation, but as I read the

14 issue as it's been formulated, it seems to me

15 that the issue is really an attempt to respond

16 to the fact that the industry has moved beyond

17 management contracts and that the NIGC is

18 attempting through this proposed regulation to

19 identify other agreements and then add their

20 jurisdiction to it. It seems to me it's an

21 attempt to catch up to 20 years of practice,

22 and that it doesn't recognize the fact that the

23 industry has grown and that the operators of

24 those, of these operations are incredibly

25 sophisticated now and, therefore, it's a

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1 solution seeking out a problem, and it ought

2 not be applied to all tribes. If there are one

3 or two issues out there, seek to solve the

4 problem with those one or two operations rather

5 than dragging all operators in under a solution

6 that's looking for a problem.

7 CHAIRMAN LITTLE: Does anyone else have

8 any further comments on collateral agreements?

9 (No response.)

10 CHAIRMAN LITTLE: We are making some good

11 time here. Part 537, Background Investigations

12 for persons at NIGC with a financial interest

13 in or having a management responsibility for a

14 management contract. We talked about this a

15 little bit already. Should the Commission

16 require -- this should stimulate some

17 conversation -- should the Commission require

18 consummation for the contractor to give

19 background information where the contractor is

20 used for Class III gaming only?

21 (No response.)

22 CHAIRMAN LITTLE: I thought that would get

23 someone's comments.

24 (General laughter.)

25 CHAIRMAN LITTLE: You're all in agreement

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1 with what we've said? In jest I say that.

2 Should the Commission revise Part 537 to

3 specifically require consummation of contracts

4 submitted for background information? Do you

5 guys have any comments?

6 (No response.)

7 MS. HOULE: If you don't say something

8 after six seconds, it's a no.

9 (General laughter.)

10 CHAIRMAN LITTLE: All right. Well, I'm

11 not going to force anybody to say anything, so

12 the last section in our Part 4 is on the

13 definition of Net Revenue. Is there any part

14 in the definition -- this was the only

15 particular section that we did get comments on,

16 the term net revenue is currently defined in

17 NIGC regulations as, quote, gaming revenue from

18 any gaming operations less amounts paid out of

19 prizes for, prizes, and total gaming-related

20 operating expenses. Now, the Commission has

21 requested comment on whether the change to the

22 definition of net revenue, and should it more

23 closely match terminology used in GAAP,

24 generally accepted accounting principles,

25 instead of matching terminology used in IGRA?

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1 Does anybody have any comments on that?

2 (No response.)

3 CHAIRMAN LITTLE: Is it break time yet?

4 MR. HEFFELFINGER: Tom Heffelfinger,

5 Potawatomi. I feel like I'm the only one who

6 has anything to say. I'm sorry about that. We

7 had an experience at Potawatomi with net

8 revenue in a dispute with the state over the

9 definition of net revenue within our compact,

10 and part of the resolution of that involved our

11 attempting to look at GAAP for assistance in

12 solving the matter, looking at the NIGC

13 definition, and then ultimately negotiating a

14 resolution. I guess the problem we had is that

15 the NIGC definition didn't really help a lot.

16 What does total operating expenses include, for

17 example? That was a major factor for us. One

18 of the things we did conclude is that had the

19 NIGC definition been closer to the GAAP

20 definition, it might have been more helpful to

21 us. So I think this is a -- I support the

22 effort because of the experience we had, but it

23 needs a lot more work.

24 CHAIRMAN LITTLE: Okay. Thank you.

25 Anybody have any comments regarding Group 4,

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1 any of the other parts?

2 (No response.)

3 CHAIRMAN LITTLE: Okay. I guess we'll

4 move on to Group 3, and the first one in Group

5 3 is Part 543 and that's the Class II Minimum

6 Internal Control Standards. As you know, MICS

7 has three purposes: To protect tribal assets,

8 to ensure operational integrity of the gain,

9 and to ensure the reliability of financial

10 statements of gaming operations, and so to

11 accomplish this purpose, the MICS were created

12 and they make it more difficult to steal from a

13 gaming operation and it establishes

14 recordkeeping and accountability procedures to

15 increase the likelihood that those who steal

16 would get caught. Does anybody want to start

17 off with any questions or any comments

18 regarding Class II MICS?

19 MR. LANKFORD: Doug Lankford, Miami Tribe.

20 Chief Gamble was unable to attend today, and he

21 had prepared a statement that I would like for

22 our attorney, Robin Lash, to read that

23 statement to you.

24 CHAIRMAN LITTLE: I'm sorry. And please

25 give my regards to the Chief.

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1 MS. LASH: Thank you, Assistant Chief

2 Lankford. As Second Chief said, Chief Gamble

3 was not able to attend today. I think he

4 anticipated that perhaps the three

5 commissioners would be here, so the letter, the

6 statement is addressed to all three

7 commissioners, and I'll just read it as

8 written. Comments by Thomas E. Gamble, Chief,

9 Miami Tribe of Oklahoma.

10 Good morning Commissioner Stevens,

11 Commissioners and staff. Thank you again for

12 the opportunity to comment this morning

13 concerning the NIGC consultation topics. My

14 name is Tom Gamble and I serve as chief of the

15 Miami Tribe of Oklahoma. My comments are

16 respectfully submitted today on behalf of the

17 Business Committee and our forefathers and

18 tribal members, and shall be read into the

19 record in my absence by Robin Lash, our

20 attorney and gaming commissioner. While this

21 consultation today involves a myriad of topics,

22 my comments today will concern primarily Class

23 II Minimum Internal Control Standards. As I

24 expressed last week during MICS consultation,

25 the Class II regulation topics are very

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1 important to the Miami Tribe. The Miami Tribe

2 was the third tribe in Oklahoma to compact with

3 the state in 2005. We choose to operate only

4 Class II gaming at our casino. Class II gaming

5 has made a huge difference for the Tribe since

6 we started gaming in the mid 1990s. As a

7 result of Class II revenues, the Tribe has

8 experienced impressive growth in our tribal

9 infrastructure, businesses and essential

10 governmental services. In addition to offering

11 Class II gaming, in 1999 the Tribe made a

12 unique decision to enter into Class II gaming

13 as a business as well. The Tribe created the

14 Miami Business Development Authority, a

15 subordinate governmental entity, and purchased

16 World Link Gaming Corporation, also known as

17 Rocket Gaming Systems. Over the past 12 years

18 our business relationship with Rocket Gaming

19 Systems has flourished and Rocket continues to

20 grow with cutting edge state-of-the-art Class

21 II gaming systems. As a tribe with a Class II

22 casino and as a manufacturer of Class II gaming

23 systems, we feel it is very important for the

24 Tribe to comment today concerning the MICS

25 regulations topic. As I stated last week, the

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1 Tribe and our Miami Business Development

2 Authority have been very involved with the

3 Tribal Gaming Work Group meetings which has

4 taken place since last November. This Tribal

5 Gaming Working Group has completed an in-depth

6 review of Part 543 and 547 and the proposed

7 revised regulation submitted to you by the

8 group on May 15th are well-organized, concise

9 regulations that more clearly establish the

10 minimum requirements for Class II internal

11 control and technical standards. I understand

12 from last week's consultation there was some

13 concern because a proposed 543 document looks

14 so different. As explanation, in the proposed

15 revised document the Tribal Gaming Working

16 Group reorganized 543, added more definitions

17 and created new subparts for clearer

18 regulation. For instance, in the current

19 regulations the subpart Bingo contains all

20 kinds of topics, some that are suited as

21 separate subparts. For example, accounting

22 language was taken out of Bingo and included

23 with audit to create new subparts for MICS,

24 audit and accounting. Promotions was taken out

25 of Bingo and made into its own subpart. In the

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1 current MICS repetitive regulations for

2 surveillance are contained in three separate

3 tier-related subparts. In the proposed

4 document, surveillance is one subpart which

5 includes the tier-related requirements. The

6 proposed 543 document is smaller in size than

7 the current 543 which contained huge sections

8 of procedure-related language. Instead of just

9 required standards of regulations, the Tribal

10 Gaming Working Group removed all of the

11 procedure-related language, leaving only the

12 regulation itself. This allows us, the Tribe,

13 as the primary regulator for Class II gaming to

14 implement procedures to comply with the

15 regulations. Additionally, the Tribal Gaming

16 Working Group is preparing guidance documents

17 and checklists to correspond with each subpart

18 of 543 to assist tribes in drafting and

19 implementing procedures to comply. As a tribal

20 leader it is my job to ensure that the

21 integrity of our tribal gaming is protected and

22 that revenues sent in from private gaming are

23 secure. This is accomplished with clear,

24 concise regulations. I am confident that

25 adoption of the proposed regulations will allow

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1 for lawful, well-regulated Class II gaming that

2 will serve the interests of the tribe as

3 primary regulator of Class II gaming, as well

4 as the NIGC in its oversight role. I would

5 like to express to your Commission the sincere

6 gratitude of the Miami Tribe for allowing the

7 tribe to submit proposed regulations we feel

8 are more clearly written to allow for better

9 regulation of our facilities. With your

10 Commission I note that interest in a close,

11 cooperative relationship between the NIGC and

12 the tribe is possible. I look forward to a

13 continued positive working relationship for the

14 benefit of the tribe and Indian gaming.

15 Respectfully, Thomas E. Gamble, Chief, Miami

16 Tribe of Oklahoma.

17 CHAIRMAN LITTLE: Well, thank you. Could

18 we get a copy of that? Would that be possible?

19 MS. LASH: Yes.

20 CHAIRMAN LITTLE: Okay. I'd appreciate

21 that. I know, and the Commission does know

22 that we've -- is it proper nomenclature now,

23 TGWG, of the Tribal Gaming Working Group?

24 That's what we've adopted. So -- sorry.

25 Sorry. But appreciate the comments submitted

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1 by the chief and we'll make sure that gets into

2 the transcript. So does anyone else have

3 written statement or comments they want to make

4 about the Class II?

5 MR. DANFORTH: Well, good morning. My

6 name is Jerry Danforth. I'm here again as a

7 member of the board of directors from the Miami

8 Tribe Development Authority, and I don't have

9 comments specific to this particular group that

10 is before us right now, but I sat through the

11 consultation this past week. There was good

12 dialogue and there were a lot of good comments

13 came forward, but I noted at the same time

14 there was a lot of apprehension of submitting

15 comments verbally over, in this kind of a

16 forum, for varieties of reasons. What I'd like

17 to propose to the group this morning, because

18 there's been a ton of work, about seven or

19 eight months worth of work by a multitude of

20 people, regulators, accounting people, vendors,

21 legal counsel, et cetera, reviewing and

22 revising these regulations. And I'd note

23 during the course of that, those months,

24 tremendous debate over the content took place.

25 And I know that if the group assembled here

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1 today, we're understanding of some of that

2 debate, of some of that process, I believe that

3 it's going to generate questions and generate

4 comments. So I would like to suggest, and

5 there are at least a couple, Ron Harris was a

6 part of that group, as was Robin, and maybe

7 others present for part of that group as well,

8 but I would like to ask some of those to

9 comment on that process of what went through on

10 this regulation and I think from there, going

11 into the content, if you understand the process

12 better of what occurred, I think you're going

13 to have more questions about the content. So

14 if the group would indulge that recommendation,

15 then I would like to see that occur at this

16 point.

17 CHAIRMAN LITTLE: Yes, I agree, that would

18 be wonderful. I mean because as a commission,

19 or as a commissioner, I actually would like to

20 know what went into the drafting process and

21 what were some of the logic behind that, so

22 please.

23 MS. LASH: Robin Lash with the Miami

24 Tribe. I was part of the and am part of the

25 Tribal Gaming Working Group. We started back

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1 in November, we started with technical

2 standards and we went through that entire

3 document line by line. The changes that we

4 came up with primarily were technical

5 standards. I mean that was a good document in

6 itself, but we just felt like there were a few

7 changes that needed to be made. We did some

8 clarification in terminology. And with regard

9 to grandfather provision, I think we removed

10 the sunset clause with the grandfather

11 provision. We feel like the games are already

12 well-regulated, they're already submitted to

13 labs and we feel like there's not an issue with

14 the games remaining on the floor. I think we

15 removed the Underwriter Lab testing

16 requirement. Tribal Gaming is the only gaming

17 that requires that, and we didn't feel that

18 that was needed.

19 I think there were issues with

20 entertaining display. The outcome of the game

21 is, the entertaining display has nothing to do

22 with the outcome of the game and that doesn't

23 need to be regulated, and so that was changed

24 as well. And I think the mathematical

25 probability standards, or odds, that's an

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1 arbitrary number that the NIGC has in the

2 regulations and we didn't agree to that as

3 well. So I think Ron can probably actually

4 speak to the technical standards better than I

5 can, but those were some changes that we made

6 in that document.

7 Now in regard to 543, we started with a

8 document that was 556 pages long. At our

9 meeting we have two screens in the room and we

10 had a legal-sized horizontal document with

11 columns. The first column was with 543, the

12 regs as written now, the second column was work

13 on the 2010 regs, the changes in the 2010 regs,

14 and then we had some comments from parties

15 during the past working group. So we basically

16 started with 543 and just went line by line by

17 line, and any time we made a change we noted

18 that change with a comment. So at the working

19 group, at the consultation last week at Mystic

20 Lake, Chairwoman Cochran said well, let's start

21 at 30,000 feet and look down because this

22 document does look so different to us and we're

23 not quite sure how to go about addressing the

24 proposed document. So we suggested that you

25 look at it in parts first, just look at it in

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1 parts and it does look different but, like I

2 said, we've restructured, or like Chief Gamble

3 had said in his letter, we reorganized the

4 document. There were so many different areas

5 in the subparts that referenced other subparts,

6 and I think we cleaned that up, reorganized, we

7 have new subparts, we created some new subparts

8 and just made it a clear document to

9 understand. But we did go line by line through

10 the entire thing. If you have any questions

11 about why a change was made, we have comments

12 that we inserted to remind ourselves of what we

13 discussed and why a change was made, and we

14 feel like all the procedure-related language

15 was removed from the document, leaving just the

16 standards, just the regulations, and then the

17 tribes and the primary regulators can come up

18 with the procedures to implement the

19 regulations. And we are preparing a guidance

20 document that the tribes can use, they can

21 adopt in whole or in part, and that will assist

22 them to implement the regulations. And we have

23 checklists as well. We have a face-to-face

24 meeting in Las Vegas the week of the 27th and

25 from there our stylistic group, which is me and

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1 a set number and Terry Popp, are going to go

2 through all the entire, all the documents to

3 make sure that they read well together, but we

4 sincerely appreciate the opportunity to submit

5 to you our document that we feel works best for

6 gaming. I think that we're very confident that

7 when you have a chance to review it and go over

8 it that you'll find it a clear, cleaner

9 document and I think it will work very well for

10 Class II gaming and tribes.

11 MR. HARRIS: I think that works. Does

12 that work? (Referring to the microphone.)

13 CHAIRMAN LITTLE: Okay. Thank you.

14 MR. HARRIS: This is Ron Harris with the

15 Miami Tribe of Oklahoma, Business Development

16 Authority. We did spend seven months working

17 on the product that we've submitted to the NIGC

18 so far. We had face-to-face meetings, we had

19 seven face-to-face meetings around the country.

20 We started off in October in Oklahoma at the

21 Windstar Casino. We worked through the

22 holidays with a number of telephone

23 conferences, and Commissioner Little, you've

24 been through a few of those back in the day

25 when we did those in 2006 and seven, and you

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1 know what those teleconferences are like and

2 the face-to-faces. In the Windstar meeting in

3 October we then began a pretty good pace of

4 meetings, and we met in the US Grant, San

5 Diego, in February we went to Hollywood,

6 Florida, and again in February, late in

7 February we want to the Cherokee Hardrock in

8 Tulsa. We, first part of March, went to Wind

9 Creek, Alabama. At the end of March we went to

10 the Toledo Resort. In Washington, in early

11 May, we went to New Orleans in Louisiana, and

12 we have our final meeting, we believe,

13 scheduled the 27th through the 29th in Las

14 Vegas.

15 This schedule, the face-to-face, it

16 didn't, you know, it was normally pretty brutal

17 meetings of two or three or four days at a time

18 of just locking up in a room like this. Every

19 sentence was reviewed about the MICS. We

20 started with our first meeting at Windstar

21 looking at both the MICS as published on the

22 NIGC website and the technical standards that

23 have already been published and in practice now

24 for a couple years and, as group, we had

25 approximately 50 people I believe in that

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1 initial meeting, primarily gaming commissioners

2 from around Oklahoma. And we had on our wish

3 list to clean up the technical standards and

4 certainly it was the MICS as published, and no

5 one, no one in the group liked the MICS the way

6 it was written. We decided that what needed

7 action were the technical standards and the

8 technical standards, I think, at that

9 conference in November, was written by the

10 industry at the cost, you know, as reported, of

11 more than $20 million of what it cost the

12 industry to write them. But most of it was

13 adopted. There were some policy issues that

14 were not adopted. Our review of the technical

15 standards almost parrot what we did in 2007

16 when the NIGC published them for comment. Our

17 positions have never changed.

18 There were things -- the grandfather. I

19 know one manufacturer in the industry alone,

20 that's a $30 million hit on the grandfather,

21 and to say magically there's some date out

22 there that this equipment that tribes have had

23 on their floor for ten plus years is magically

24 no longer able to be played on the floor, we

25 felt that was arbitrary and capricious then, we

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1 feel the same it is today. The greatest impact

2 is going to be on the small manufacturers, such

3 as the Miami. The impact will also be on the

4 smallest tribes -- and I say small meaning

5 revenue-wise -- in the country, because most

6 equipment like this certainly starts off in the

7 highest revenue earning venues and then finds

8 its way, as you know, functional obsolescence

9 or what-not finds its way into lesser

10 profitable venues. So the grandfathering is

11 the key, key place for you to focus on. Our

12 comments, as I said, haven't changed in four

13 years and that is, it should not be there.

14 That equipment should be left up to the Tribal

15 Gaming Regulatory Authorities of each tribe to

16 decide if they want it on their floor, not to

17 have a regulation to come in and wipe it out

18 arbitrarily.

19 There was a piece in there about testing

20 labs. Our opinion did not change about it

21 either. In September of 2007 we submitted a

22 number of comments. And we call ourselves the

23 GDWG, you know, so yeah, you can call us what

24 you want. We've been called a lot of things.

25 (General laughter.)

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1 CHAIRMAN LITTLE: But we'll call you Ron.

2 MR. HARRIS: Okay. But our position

3 hasn't changed on the testing labs either.

4 There was a phrase in there that basically said

5 that if you're a tribal testing lab, you can't

6 test your own equipment. And I think that we

7 felt that was distasteful then, and we feel it

8 is distasteful today. You have states that

9 have testing labs and they also test equipment

10 in state-owned facilities. So to take the

11 position again of an Indian tribe, and yet we

12 see it in practice in non-tribal individuals, I

13 think that it's distasteful by most tribes in

14 the country.

15 There was also another issue with fairness

16 documents here that's, again, and we sat in the

17 room with the NIGC and we asked one of the

18 commissioners, where did you come up with these

19 odds of one in a hundred million? And that's

20 what we were shown. Just out of thin air. And

21 said, because I think that's fair. Well, while

22 that might be true, and in that commissioner's

23 view of what fair is. I think our position is

24 equitable standards. We've been working on the

25 limitation of the odds. It's less than what

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1 states have for their lotteries. Again, tribes

2 are put at a disadvantage.

3 CHAIRMAN LITTLE: Well, what are the

4 benefits of increasing or changing the odds?

5 MR. HARRIS: Well, I think one is the

6 theoretical position. It shouldn't --

7 CHAIRMAN LITTLE: Well, I mean by the --

8 or to the operative. Not necessarily

9 the cards.

10 MR. HARRIS: Well, for the tribes to be

11 able to offer the same odds of a game would

12 allow you to build large jackpots and then be

13 able to offer that kind of marketing tool to

14 bring players out to some have remote

15 reservations for tribal gaming is a huge plus.

16 Our little group, we have a large jackpot

17 of a million dollars on a game, we have over

18 130 casinos on that network now, which is

19 growing are rapidly. For you to be able to

20 take a million dollar game that is hitting

21 about every 40 days now, to take that out and

22 offer that in a small venue in South Dakota,

23 North Dakota, Montana, it's a big draw. Again,

24 you can then chase after the type of player

25 that typically is a lottery player. They want

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1 a life-changing event. You know, who wants to

2 hit a machine and, you know, blunk, blunk along

3 playing pennies. If they're going to play,

4 they want a decent sized jackpot.

5 CHAIRMAN LITTLE: Thank you.

6 MR. HARRIS: Okay. The odds we put on

7 there, we've got some of the best math minds in

8 the country. I don't know if the guy is here

9 now -- but Charlie Lombardo is in here. We did

10 our best with Power Points and everything to

11 educate the Commission as to why these odds,

12 you cannot -- odds don't apply to Bingo. So

13 you know, what is the odds of a coverall?

14 Well, it all depends upon how many balls have

15 been drawn and it depends upon how many cards

16 have been sold. And so again, what's the odds

17 of a coverall on one ball? You can't win. So

18 that odds setting to begin with was a red

19 herring. It should never have been put in

20 here. So it's mathematically inappropriate on

21 top of the other theoretical issue.

22 What we did, though, we did address, as we

23 did in most of these meetings, if we sat in a

24 meeting and we did during the -- and I call

25 them the old days, even though it was only five

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1 years ago -- with the NIGC at that time, and we

2 sat with them, with their technical folks, we

3 sat with some of their auditors and stuff, and

4 just worked with them basically, if we

5 understood what the NIGC wanted, we got it

6 there for them, but in a way that maintained

7 maximum flexibility for technology in the

8 technical standards, or in the MICS, and if you

9 remember it, that day or at that time when we

10 wrote the technical standards, the NIGC didn't

11 know it needed MICS. We wrote the technical

12 standards. Many of the things they wanted in

13 the technical standards were not appropriate

14 for technical standards, they were appropriate

15 for Minimum Internal Control Standards.

16 Technical standards is how you build it. MICS

17 is how you use it. So we drafted the MICS as

18 best we could, but if we understood what the

19 government wanted and an Indian country agreed

20 that that was a worthy goal, we got to there in

21 a way that didn't trample on technology and

22 didn't trample on the federal laws.

23 Fairness was a big issue. Again, our

24 opinions have never changed. And I can

25 literally -- and I may do this in our next

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1 meeting, we have a meeting every Wednesday,

2 TTWG reviewing the MICS -- we may break this

3 down into here's issues that we've been

4 dissatisfied with since they were promulgated.

5 We did some things in there, too, that we would

6 argue the point, but sometimes it didn't work,

7 so you'll see the markup of the technical

8 standards that say some things we added, simple

9 words like under financial instrument storage

10 components. I think the way it reads right now

11 is, any class remaining ... to store financial

12 instruments that are not operated under the

13 direct control of the gaming operation employee

14 or agent should be located within a secure

15 locked area or locked in a cabinet in the

16 housing. And we put in the word designed to be

17 operated, or designed to be tamperproof. You

18 can't put into federal law that I'm going to

19 make something that's tamperproof. We try to

20 design it that way, but if you show up with a

21 crowbar and a stick of dynamite, you're gettin'

22 in. All right?

23 (General laughter.)

24 MR. HARRIS: So we put in some words like

25 that. Those didn't make it. For whatever

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1 reason, they were crossed out. So you'll see

2 that refined again and put 'em back in there,

3 to make sure that the law it as accurate as it

4 can be.

5 There are a number of -- entertaining

6 display. Again, that's a huge policy issue.

7 We argued and argued and argued. Member

8 position papers were written on entertaining

9 displays. One of the commissioners, a former

10 gaming commissioner found that book. I want

11 all the facts that the players said they saw.

12 I want them all. That includes this

13 entertaining display. None of that matters,

14 though. The law is the Bingo club, the balls.

15 If you give legal precedence to entertaining

16 display, many -- there were several position

17 papers written on the dangers that that

18 presents to Indian country. And unfortunately

19 it was published with having to record the

20 entertaining displays. The difficult part is,

21 many tribal gaming regulatory authorities see

22 this as an ignorance of their tribal gaming

23 regulatory authorities, most of which don't

24 give any credence to the entertaining display.

25 Some of them do and that causes a problem. So

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1 again we've advanced, but you have to take this

2 out.

3 And particularly, we were at least

4 successful when we argued that you can't

5 replicate what the player saw if you have

6 mechanical reels. You can't drop a -- all you

7 can do is try to replicate it. Right? You

8 can't take a picture of what the mechanical

9 reels did, so the reels can roll back, but you

10 have no assurances that the tape didn't slip or

11 something along those lines. That was

12 understood. But now we have a law that

13 basically is that we have to display the

14 results that recall the game as originally

15 displayed, or intent to representation,

16 including entertaining displays. Results in

17 video, comma, rather than electromechanical.

18 So what we've done is, we're saying we're going

19 to be more stringent on video and we'll let

20 that gamble stuff off the hook because we don't

21 know how to deal with it.

22 CHAIRMAN LITTLE: What are the disclosure

23 requirements on the machines? I know there's

24 some there that says what, malfunctions, void,

25 foul play? What else? Is there any other

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1 disclosures there on the constitution?

2 MR. HARRIS: I think the attorneys know

3 off the top of their head a little better than

4 me. I believe we've got that disclosures on

5 there, a bunch of void things and -- and I

6 think we've got some requirements --

7 CHAIRMAN LITTLE: I think your mike is

8 off.

9 MR. HARRIS: Do you have a problem hearing

10 me?

11 (General laughter.)

12 MR. HARRIS: And I think that we have some

13 of this in the rule screens. We've had some

14 requirements that this is the game of Bingo.

15 CHAIRMAN LITTLE: Okay. Do you think that

16 the general patrons understand that it's a

17 Bingo game and not a --

18 MR. HARRIS: Some do. Some don't.

19 CHAIRMAN LITTLE: Is there a better way to

20 make that clearer to the patrons?

21 MR. HARRIS: I think that the other huge

22 thing that always has to be remembered, these

23 regulations are written -- did it go off again?

24 -- these regulations are written in a way you

25 can't differentiate electronic Bingo, partial

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1 electronic Bingo, or paper. Bingo's Bingo.

2 The three statutes. That's it. So to get in

3 and to try and shave this thing and to say

4 well, but if you have an all one product board

5 up, just like rocket streaming, I mean we can

6 play it with paper, too, so you can't

7 differentiate, you know. When you walk into a

8 Bingo hall, they don't say, this is the game of

9 Bingo. It's a Bingo hall, and you have some

10 posted rules that say how things work in Bingo

11 format. All the electronic manufacturers that

12 I know do that, as well as in the game rules.

13 So I think the inquisitive player, or the aware

14 player, when they walk up, there's some

15 distinct differences between this and a

16 proverbial lottery game or a wheel game or a

17 slot game or anything else, but guess what,

18 there's a Bingo card on the screen somewhere

19 and there's some Bingo balls on the screen

20 somewhere, so they know if they're looking at

21 the screen. So these are things that we have

22 proposed in the markup of the technical

23 standards, things that we knew about that we've

24 argued now for four and five years about, that

25 are policy issues that are going to be right

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1 back on your desk.

2 The entertaining issues, the fairness

3 issues, the tribe and the lab issues, these are

4 things that are going to end right back up on

5 your desk. Things such as verifying downloads.

6 You know, there's some things in there that

7 cause responsibilities to the Tribal Gaming

8 authorities, they shouldn't have to do it, it's

9 already being done or has been done and signed

10 off on by a lab.

11 Now you'll also see, though, that there

12 are some things that we didn't know, that now

13 that we've had them in practice, now it's time

14 that we're suggesting we fix. These are things

15 that we just missed, for instance, the word

16 agent. There was a lot of discussion and

17 debate with the previous commission on what the

18 word agent was. They didn't want the word

19 agent. And we were successful in our argument

20 of what an agent was, but where we missed it is

21 we didn't put into the definition that this

22 definition permits the use of a computer

23 application to perform the functions of an

24 agent. We hit a number of rocks in that way,

25 both on the MICS and on the technical standards

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1 side.

2 CHAIRMAN LITTLE: And I know we're jumping

3 back and forth from the MICS to the technical

4 standards, but I was going to mention or I have

5 more a comment on the effort or some of the

6 background logic or reasoning behind the

7 changes to reflect the software and what was

8 the purpose of that, or of your opinion?

9 MR. HARRIS: As you know, our work group

10 puts pride in the tribal leadership,

11 manufacturers, Tribal Gaming regulatory folks,

12 attorneys for tribes, for manufacturers, for a

13 number of people, but we had a lot of attorneys

14 participating here, we also had the gaming

15 labs. This actually was a GLI catch and GLI

16 said well, we understand what you tried to

17 capture, but you didn't capture it just right.

18 We made the change to reflect the software

19 really at GLI's comment that our definition, we

20 were trying to capture something that then

21 Chairman Hogen's pet peeve was software that

22 was reacting to the player versus just a purely

23 random event. And so the language we changed

24 here is more reflective of reflective software

25 as understood internationally, and so there

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1 was, I don't know, a several-hour debate on it.

2 That's where that came from.

3 CHAIRMAN LITTLE: Is there a problem with

4 manufacturers using that?

5 MR. HARRIS: I think it was thought at

6 that time that there were some, and I think

7 they thought -- I think at that time there was

8 some speculation there was, to my knowledge, no

9 one has been charged with any type of

10 improprieties like that.

11 CHAIRMAN LITTLE: But regardless, we've

12 addressed it here?

13 MR. HARRIS: It should be.

14 CHAIRMAN LITTLE: I think we're up on a

15 break. I'm not sure if anyone wants to take a

16 break. Do we want to -- are we at 10:30 or

17 10:45? We're supposed to take a break at

18 10:30. Do we want to push on, or do folks feel

19 like we need to --

20 MR. HARRIS: Does that mean we get an

21 earlier lunch?

22 (General laughter.)

23 MR. HARRIS: If we were at a TGWG meeting,

24 we would press on, by God.

25 CHAIRMAN LITTLE: All right. I don't

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1 know. How do you guys feel about going on?

2 MR. HONECK: I'm fine. Whatever.

3 CHAIRMAN LITTLE: Okay. Let's just

4 continue on here. I think we've got a pretty

5 good discussion going.

6 MR. HARRIS: I was talking about the

7 things that we argued before, so you'll see

8 that in the technical standards markup. Then

9 there are things that we messed up on that we

10 missed as a group and, if you remember, we

11 wrote those technical standards in 50 days, so

12 we knew they weren't perfect, but we thought we

13 had caught. So regarding software action,

14 thank you, Commissioner, for bringing that up.

15 That was one of the things we caught. The

16 agent issue was one of the things that was

17 caught. There was also a thing in here, the

18 grandfather limited media compliance issues.

19 Again, our position on that was -- oh, that was

20 that -- I'm still stepping around. And

21 actually regarding UL, Underwriters

22 Laboratories certifying the gaming equipment,

23 that was our idea and we put those in the regs

24 and we realized the whole industry did, all the

25 manufacturers did it, it just kind of sailed

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1 through. Well, you know, we in one, UL or its

2 equivalent, there are -- it's not really, and

3 it's interesting to see how it evolved, because

4 some folks have horses in the race, some don't.

5 The Miami, our manufacturing facility is

6 well-certified. We put our own little sticker

7 on our boxes, so it's not really an issue for

8 us, but there are some very old equipment, that

9 helps those in the industry that don't have the

10 UL stickers on it. But yet, they've been

11 apart, somebody may have tested it, they've

12 done different things to it to where we feel

13 like that should be modified and we suggested

14 language for it that requires that the TGA to

15 be comfortable with that equipment on the

16 floor. If it's already been on the floor for

17 eight years and hasn't electrocuted anybody, it

18 might in some severe, dramatic setting. But

19 yet, there are some tests you can do on it by

20 moving it off the floor, or some tests you can

21 do with it on the floor that would give comfort

22 to the TGA this is a safe piece of equipment.

23 If the board were to require that kind of a

24 standard, that every single piece of equipment

25 has to be brought out of the casino, put

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1 somewhere at a great cost. I know one of the

2 manufacturers told me that if that is in there,

3 it will cost them alone $30 million, is their

4 internal estimate. They have to pull somewhere

5 close to 16,000 machines out of tribal casinos,

6 bring them back, certify them and send them

7 back out. That's just one manufacturer. So

8 there is language in here that, basically,

9 again, we tried to parrot. Nevada doesn't

10 require you to have certification. It just

11 says the lab has to note what kind of

12 certifications, what certifications exist. If

13 it's UL, it'll say UL. If it says spilt test,

14 along with electrostatic discharges, all these

15 things, it'll say that. But it doesn't require

16 that an actual lab be doing that. So we felt

17 that was a good change. We're the ones who put

18 it in, we're the ones who are going to have to

19 live with it. If the grandfathering happens,

20 that becomes a massive, massive expense to

21 Indian country and then you know, the

22 manufacturer gets hit with the costs, yes, but

23 guess who ultimately pays for it. We pass it

24 down through, yup.

25 CHAIRMAN LITTLE: You talked about

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1 variances and I think for me, I'm kind of

2 interested, you know, is this a big issue, and

3 maybe our staff would know, do a lot of our

4 tribal clients allow the manufacturers to

5 prepare the technical standards and how do

6 those work? I know you, I think, submitted

7 some suggested amendment to the variance

8 procedures. Do you want to talk about that at

9 all?

10 MR. HARRIS: I know that Rocket, yes, I

11 know at Rocket, we end up with a number of

12 variances, most of the statistics are much more

13 stringent than the existing MICS.

14 CHAIRMAN LITTLE: So the variance is the

15 process of the TGRA, not the NIGC?

16 MR. HARRIS: That's correct. Other than

17 what the TGRA does, is typically -- so I can't

18 speak for what they're doing -- if some of the

19 tics requirements they have are because of

20 inadequate, you know, not meeting federal

21 standards, which I don't think so, or every

22 tribe would be asking this of us, and that's

23 not the case.

24 CHAIRMAN LITTLE: Do you have any

25 questions?

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1 (No response.)

2 CHAIRMAN LITTLE: Do you have any

3 questions?

4 MR. HONECK: No.

5 CHAIRMAN LITTLE: No.

6 MR. HARRIS: Before we move to my comment

7 about the MICS, that was what we considered to

8 be low hanging fruit.

9 CHAIRMAN LITTLE: One more question on the

10 grandfather.

11 MR. HARRIS: Sure.

12 CHAIRMAN LITTLE: Are machines that are

13 grandfathered, can they become compliant? I'm

14 mean sorry, I should say the system, because

15 they're basically just use-interfaced devices,

16 but can the systems become complaint and do

17 they ever become compliant?

18 MR. HARRIS: I think that the answer to

19 that would probably be no in some of the

20 equipment, that there are -- there are some

21 games that have been built, in essence, out of

22 very sturdy wood cabinets that have, you know,

23 double locks in some areas that probably

24 wouldn't meet, they they'd get -- those would

25 be Megalomania boxes, for instance, that helped

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1 build this. I've also noticed in the Tapped

2 Force and the Lucky Tattoo boxes, that I know

3 that those manufacturers felt definitely that

4 they would not be able to meet these more

5 stringent MICS and the technical standards.

6 The systems themselves, I think we still get

7 back into a dollars and cents issue. We can

8 press our own issue that I think we've also

9 made some suggestions in the MICS to address,

10 but we had -- the only thing that the

11 Department of Justice ever certified as a Class

12 II game was a rocket game, and this was our

13 rocket classics game. Literally Bingo balls

14 with balls dropping one at a time, we'd have 12

15 cards on the screen and when these were

16 written, most of those, they were all -- we had

17 turned that software off. Well, it was

18 operating Windows 97 and it was old, old

19 software that still works perfectly fine, but

20 when these MICS or the technical standards were

21 promulgated, we didn't take that piece of

22 software and rush to the gaming lab and give it

23 to them. So although we've had a gaming

24 software that was certified by the DOJ, we also

25 received letters from the NIGC because we

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1 didn't take it, we didn't think there were any

2 more commercial applications for it, we didn't

3 take it to a gaming lab. Now all of a sudden

4 we found commercial applications for it, there

5 are some people that want that game back. We

6 went and turned it back on, and boom, we hit

7 this grandfather machine. It's commercially

8 unreasonable to rebuild that software by

9 today's standards. So there are other systems

10 just like that out there, but it just isn't

11 worth the money to bring them up to that

12 specification.

13 CHAIRMAN LITTLE: Okay. Thank you. Did

14 you want to talk about the -- go back to 543?

15 MR. HARRIS: Yeah. Again, you know, I

16 think Terry Danforth wanted to be able to talk

17 about profits and the process was, this whole

18 work group got together at any time period,

19 about 50 people typically, a lot of open

20 conference bridges. What we did was a little

21 different. Ours wasn't conference bridges. A

22 few states have dropped in and listened and a

23 few other people, probably so, and if you stay

24 on the phone long enough and heard all the

25 beeps afterwards, you might have 30 to 50

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1 people acknowledge they're there, but then

2 you'd hear 125 beeps when people hang up. A

3 very well attended meeting. A lot of interest,

4 very transparent. You know, if anybody had a

5 hidden agenda, it got called out pretty quick.

6 And you remember having some sat in of those.

7 We decided to go ahead and go through technical

8 standards. Then we tore into the MICS and we

9 felt like we had to deal with what we called

10 the Joe Smith document, the document that was

11 out on the NIGC website. We felt we had to

12 start with that and it was so cumbersome and

13 unworkable. We tried to get into the position

14 of saying what did the government want by this

15 and then focus on federal regulation that would

16 give not just the government but tribal

17 interests that, which secured the cash. But

18 the existing MICS went so far as almost to tell

19 you how many sets of keys you had to have, what

20 color jump suit somebody had to wear, almost to

21 that level, which are fine, but they should be

22 in a tic. The tribe should decide all those,

23 not a federal statute. So we got the MICS, we

24 said okay in the perfect world, how should you

25 do this? How should you do this? How we did

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1 this was minimal means minimal, this is what

2 the MICS should do and then once you get these

3 things promulgated and they're law, when you

4 find something wrong like we've done, even in

5 the technical standard we wrote, we've made

6 some error, to change that, it's a whole

7 another thing. We felt that the operational

8 issues and stuff, that the NIGC's job should be

9 as backup to the primary regulator, which is

10 the Indian Gaming Regulatory Authority. They

11 are the primary regulators. The MICS should be

12 written saying, we think at a federal level

13 these things should be met. How you get there

14 is your business but, as an agency, the NIGC

15 should be giving guidance and counseling to all

16 Indian country, particularly those tribes that

17 can't afford to send people to these type of

18 meetings. That's where we came with, minimum

19 means minimum. Here are guidance documents,

20 what we in turn were calling best practices.

21 Here's how you should count your cash, this is

22 how many times you should count your cash, and

23 separation of duties. Most of those things are

24 in these guidance documents. We tried to do

25 the check sheets when we did the technical

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1 standard before. A lot of problems exist right

2 now in Indian country because the same authors

3 that wrote the MICS and the technical standards

4 didn't do the check sheets. And the check

5 sheets are a bit confusing because we think

6 that the people who wrote the check sheets were

7 confused. So we also have come up, and our

8 groups also do the check sheets that match the

9 technical standards, the MICS, the same way,

10 guidance documents, and the check sheets roll

11 up. We very much think that for this process

12 to really work and everybody to understand it,

13 this last meeting in June, those three days in

14 June literally it is to check for substance.

15 That means we're taking the MICS from start to

16 finish, going through every section. We would

17 love to invite, you know, a few of the NIGC

18 substance matter experts to get them there, so

19 they can hear firsthand the debates, see what

20 it is, and then ask what would you think works

21 for you. It's a very helpful process when that

22 happens. In the interim, if that can't happen

23 what does need to happen I think, as Ms. Lash

24 pointed out, is that there should be

25 collaborative interaction between Indian

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1 country certainly and the NIGC's subject matter

2 experts to sit down when -- and I don't know

3 how many people may or may not know that -- but

4 the technical standards, when we submitted

5 those after 50 days, where there was a meeting

6 where the NIGC brought in industry experts. I

7 sat through the meeting and asked a number of

8 questions and it became a vigorous debate

9 between the Commission, their experts, and the

10 industry and their experts, tribal and their

11 experts, and a vigorous debate on issues. It

12 was very helpful. When we took on the MICS

13 project, they asked us to write the MICS. We

14 said okay. The same band of people began

15 working on the MICS. They did send in subject

16 matter experts to say look, Joe Smith was in

17 many of the meetings. This is what we're

18 trying to get to and help us get there. And

19 how's how -- you can't replace that kind of

20 interaction to build appropriate regulations

21 and so somehow or another I know that Miss

22 Echo-Hawk suggested that in these classroom

23 forums when we go into meetings like this, that

24 the NIGC bring their subject matter experts.

25 You all provide an agenda to where we can reach

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1 out to them, all of Indian country, bring in

2 the appropriate attorneys, bring in the

3 appropriate gaming labs, bring in the

4 appropriate manufacturers, bring in the

5 appropriate tribal leaders to watch and listen,

6 get in the tribal regulatory folks, the gaming

7 commissioners, and then we'll all sit at the

8 table and say here's where we think we should

9 be. Do we all agree on it? And start doing

10 that as a part of these type of meetings, I

11 think it would be the best way to do that and

12 would certainly expedite the process.

13 CHAIRMAN LITTLE: I know I've let Ron

14 dominate the conversation here for a few

15 minutes, but does anybody have any comments

16 they want to add on or insert or?

17 (No response.)

18 CHAIRMAN LITTLE: On the technical

19 features, I think we've got some questions that

20 we'd like to throw out there and I know

21 probably in the working group you've addressed

22 this, but is there any areas that the MICS does

23 not address that they should, more regulations?

24 (No response.)

25 CHAIRMAN LITTLE: Anyone?

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1 (No response.)

2 CHAIRMAN LITTLE: Anyone?

3 (General laughter.)

4 MR. HARRIS: Commissioner, when you say

5 the MICS, are you talking about the ones that

6 are out on the NIGC website?

7 CHAIRMAN LITTLE: Yes.

8 MR. HARRIS: Yeah. I think that you would

9 probably find that there are some areas that

10 were missed and I think, though, that the main

11 issue is that they go into far too great a

12 detail, that they overstep your bounds, yes.

13 CHAIRMAN LITTLE: Does anyone have any

14 comment on, you know, I think that Class II and

15 Class III, we created these separation of MICS

16 depending upon game type after the CRIT

17 decision, is there any benefit to going back to

18 one MICS? Does anybody have any comment on

19 that?

20 (No response.)

21 CHAIRMAN LITTLE: I mean sometimes I get

22 to forget to ask, but I mean the MICS was the

23 MICS, it wasn't separated by game.

24 (No response.)

25 CHAIRMAN LITTLE: Does anybody have any

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1 comment about what the NIGC should do regarding

2 the MICS that is scheduled to go into effect in

3 October?

4 MR. VALANDRA: Good morning. My name is

5 Joe Valandra. I'm a member of the Rosebud

6 Sioux Tribe and I'm here speaking on my own

7 behalf today. On that specific question,

8 Commissioner, I think that is a good

9 negotiating point, if that's what it comes to,

10 certainly a good policy point is to withdraw

11 that. Take the Damocles sword off the table or

12 off the ceiling so that it doesn't fall this

13 fall, so that when the dialogue does begin in

14 earnest about the regulations and how they're

15 proposed, assuming that they are proposed

16 again, using bits and pieces that you're

17 gathered from other places, that draft that has

18 been very clearly shown to be terrible for the

19 industry and a bad starting point isn't where

20 we have to start from. We start from a

21 different place. That would be my

22 recommendation to the Commission. And if you'd

23 indulge me, I wrote down some of your questions

24 and I have a couple of other --

25 CHAIRMAN LITTLE: Okay.

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1 MR. VALANDRA: -- I can add to what Ron

2 said, actually. But one thing I want to, I

3 wanted to share I was an active member in the

4 TGWA the last seven months. It seems longer

5 actually. It seems a lot longer.

6 (General laughter.)

7 MR. VALANDRA: But it wasn't all one happy

8 family. We didn't always agree. We didn't

9 always come at this from the same point of

10 view, but after talking about it and debating

11 and fighting about it at times, we came to the

12 conclusion that the best thing obviously was

13 for us to cooperate and have a package to

14 present to the NIGC that represented the best

15 views, and the best view Ron said at last, is

16 that we don't want to get into what color shoes

17 the regulators should wear when they're

18 counting coins. It's more of a here's how you

19 have to count the coins, the NIGC says that you

20 have to count the coins. We're not going to

21 tell you exactly how to count them, as long as

22 you count them and when we come look to see

23 your process for counting them that it's

24 secure, acceptable and doesn't allow for any

25 security breaches and it's fine. So you know,

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1 the Oneida might do it one way, the Potawatomi

2 might do it a different, but so long as it

3 meets the overall policy for counting coins, it

4 doesn't really matter. And I think that policy

5 scheme becomes very important for the NIGC to

6 keep in mind, that the primary regulators have

7 boots on the ground every day, our tribes, and

8 to give them as much flexibility from the very

9 small facilities in the Great Plains to the

10 very large facilities in the northeast and

11 Southern California. That has to be there.

12 And it plays into the question about whether

13 there should be one MICS or not. The answer,

14 well, for me, is no, because Class II is about

15 a system. It's about a Bingo system that

16 allows multiple players playing from a

17 consistent version, where a Class III game or a

18 compacting game generally is a slot machine.

19 You can have one slot machine in the middle of

20 that floor and you can play it. If you have

21 one, one box only in the middle of that floor,

22 no one can play it, because it takes more than

23 one player to play Bingo. So the MICS and the

24 other regulations have to respect that,

25 recognize it, otherwise, you know, they have

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1 the continuation of this perception that a box

2 on the floor is a box on the floor, and that's

3 where we started seven -- seven years ago.

4 CHAIRMAN LITTLE: But doesn't that -- a

5 dollar is a dollar going into a, whether it be

6 a Class III slot machine, whether a Class II

7 user interface device. Certain dollars are --

8 MR. VALANDRA: Certainly some of those

9 things are the same, but I think unless you

10 recognize the unique nature and continue to

11 recognize the unique nature of Class II, the

12 debate, in fact the battles between the tribes

13 and the states continues. Class II is a

14 different animal than the compacted game and is

15 regulated different than the compacted game.

16 The regulation with the compacted game is

17 between, primarily is as the CRIT decision

18 says, between the tribe and the state. And so

19 the extent the NIGC confuses that with

20 regulations, it doesn't help. So to me that's

21 the primary answer to your question, which is a

22 policy answer, not a nuts and bolts answer.

23 When you say the dollar in, that's nuts and

24 bolts. Certainly how you count that dollar is

25 very similar between Class II and Class III,

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1 but that distinction is very important to the

2 overall health of Indian gaming and the

3 relationships, the complex relationships

4 between states and tribes, states and the NIGC

5 and tribes and the NIGC. There's a difference

6 there. And if that gets blended together,

7 we'll have seven more years of confusion we've

8 had for the last 10. At least that's my view.

9 And it's important to keep in mind that the

10 policy's implemented as I said, it's the system

11 versus the box. Class III, or slot machines,

12 it's all in the box. The box can run by

13 itself. Class II needs a system. So the

14 system is what's important. And that goes to

15 one of your questions about grandfathering. If

16 the system is -- if the system is providing

17 fairness, the box itself is, whether it's made

18 out of wood or metal or whatever-wise, so long

19 as the interface between that box and the

20 system is secure, you know, the grandfather

21 issue probably becomes a little bit less

22 important. But again, that's a policy decision

23 for the NIGC to make. I think Ron did a

24 reputable job of talking about Bingo

25 management, but don't ever ask Ron about Bingo

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1 management, because he's not the right guy.

2 (General laughter.)

3 MR. VALANDRA: When it comes to odds --

4 and you can ask some of your staff because I've

5 had this conversation with them -- as Ron

6 pointed out, is it fair to calculate the odds

7 on a coverall with one ball? Of course not.

8 Because there are no odds. There's no coverall

9 with one ball. With 25 balls, a random draw,

10 then you can begin to calculate. But Bingo's a

11 game based on winning, not on losing, and so if

12 you calculate the odds win, when the win --

13 when the win is obtained, not when what loss is

14 obtained. Because every game of bingo has a

15 winner. So when it comes to odds, grabbing a

16 number out of the air, saying 100 million to

17 one or 10 to one, or whatever number, it

18 doesn't play to Bingo math, and I think that's

19 important, a very, very important distinction.

20 And if you'd like some of the tutorials that we

21 gave on table math, we would be happy to

22 provide them to you, because I think it's

23 important to understand when the odds are

24 calculated, not when just this stuff is

25 calculated when it comes to Bingo.

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1 Entertaining display. You know, we had a

2 commissioner when I was Chief of Staff, at

3 least he came from --

4 CHAIRMAN LITTLE: You were Chief of Staff?

5 MR. VALANDRA: I was at one point, yes. I

6 don't usually say that out loud because I don't

7 want this group to know that, so. That came

8 with a tribal regulatory background, and it was

9 important to note, tribal regulators went

10 around resolving disputes with patrons, and so

11 as much information as you can possibly have to

12 resolve that dispute one way or the other is

13 important. Entertaining display can play a

14 role in that, although we all recognize that

15 the Bingo card is really where it is. And on

16 most Class II machines it does say

17 malfunctions, but it also says that the Bingo

18 card determines the win, not anything else that

19 happens there, and it also says house rules

20 determine how that winner is determined,

21 because that's how Bingo is played, house

22 rules, again, whether it's played at Oneida or

23 Ho-Chunk or elsewhere, it depends a little bit

24 on how the house wants to play the game, but

25 the rules are all published and available. So

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1 I think that the concept of fairness is

2 certainly covered by Bingo, because Bingo has a

3 winner every game. Now there can be interim

4 winners, there can be other kinds of winners,

5 but there's a winner every game. It's just how

6 you measure that win. So that's another very

7 key concept as you're considering the odds and

8 the entertaining display issue. Those are both

9 very important points.

10 And you asked about the -- again, this is

11 my background, my main area, I think I can

12 explain -- how does a patron, a player know

13 that they're playing Bingo? Well, certainly it

14 says it on the machine. In some states, in

15 some compacts, in some belts and suspenders

16 tribe, the federal regulators say, you know, a

17 sign has to be put on there. That's what

18 Chairman Hogen wanted, a sign that says, this

19 is a game of Bingo. There is a Bingo card,

20 there's Bingo balls. There is, you know,

21 there's enough other things on display, and I

22 can guarantee you, although you're probably not

23 the kind of players, I'm not the kind of

24 player, but players know the game they're

25 playing. I mean real players, they're aware

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1 that they're playing a slot machine, they're

2 aware that they're playing a Bingo machine, and

3 they also know all the varieties, okay, in

4 between there, and there's thousands of

5 varieties: There's a grime (phonetically

6 spelled) game, there's a winner game, there's

7 all kinds of games and the players know that,

8 and I think that's one of the misconceptions

9 that the last Commission had is they assumed

10 that the players knew nothing. Now maybe

11 that's a good start if you really want to be

12 draconian about the rules, but I would urge you

13 not to assume that, I would urge you not to

14 assume that the players don't know that. The

15 players know often times more, a lot more, than

16 the game handlers or the game designers. We

17 learn from them, or they learn from them all

18 the time. So those are my comments to answer

19 some of the questions that you have, but in

20 terms of policy, this is all about policy. The

21 nuts and bolts will take care of itself. As

22 long as the policy is good, it takes the right

23 direction.

24 One final thing about the not-getting25 along thing.

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1 CHAIRMAN LITTLE: Who, with us?

2 MR. VALANDRA: No, within the TGWG.

3 CHAIRMAN LITTLE: Oh.

4 MR. VALANDRA: I want to say this, because

5 I think it's important, I think it's an

6 important perspective that we do get along, but

7 when it came to nuts and bolts there the issue

8 became, as I said, is how detailed should the

9 regulations get, and I think it's an important

10 point again for the Commission to carry forward

11 is how detailed do you want them to be, because

12 the more detailed they are the more

13 responsibility you have to looking out for

14 them, the larger the staff you need to have,

15 the better expertise on the staff you have to

16 have. Nothing wrong with that, but you already

17 have thousands of boots on the ground who

18 travel regularly. Use them. They'll help you

19 and they'll do a very good job. Thank you.

20 CHAIRMAN LITTLE: And I think you made a

21 good point about just the diversity of this

22 industry is immense and, you know, it's

23 something that I think helps, you know, move

24 around this industry, and that is a very good

25 point. The point on the entertainment display,

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1 and I think you all know I'm not all that

2 familiar working in a, for a facility that

3 works quite strictly in contact with the games,

4 but you know we are seeing more and more where

5 you've got these mesh floors, where you've got

6 slot machines right next to pop soda machines,

7 and I'm not sure if I totally agree with you

8 about, I mean I do think that we need to make

9 sure our regulations work for everybody, and

10 that is the experienced player and the new

11 player that may have walked in. You know, I

12 was embarrassed: I walked up to a machine in

13 Las Vegas one time and threw a hundred dollar

14 bill in and hit it twice and realized what I

15 thought was a 25 cent machine was a $25

16 machine. Not being an experienced player, you

17 know, it was my own fault, my own stupidity. A

18 penny machine right next to $25 machines. You

19 know, that's best served for the unknowing

20 player. So well, but we can continue to talk

21 about this, and these are good forums that we

22 can hear the feedback. So thank you.

23 MR. HARRIS: This is Ron Harris. I can't

24 help, but this is how we work the TCWG meeting.

25 Somebody stands up and has a position, it's

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1 almost like Rock'em Sock'em Robots. There's a

2 lot of different positions you can take. And

3 Mr. Valandra said, you know, being that it's a

4 game about winning, not losing, and then you

5 can take that and spin it all kind of ways, and

6 Bingo's, actually one of the best games we had

7 was a game called California Gold and you

8 played until you won a worst card. I mean

9 after a certain number of balls if you didn't

10 have any hits, you had the worst card, you were

11 the winner. So you won by losing.

12 (General laughter.)

13 MR. HARRIS: And then also there's good

14 neighbor prizes, right, or hot-ball prizes to

15 where you might not have discovered the pattern

16 but because it's the last ball called, I hit

17 the pattern and your next meet you also hit

18 that ball on the card. Everybody wins

19 something. So there's so many different

20 varieties to Bingo, you cannot try and put a

21 lid on it in any form or fashion or it's a

22 disaster. Bingo has to have its own MICS.

23 There are components, as you just talked, about

24 that certainly, if you were to say geez, go

25 right to Class III MICS. We can point to Class

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1 III MICS. You could point to the Class III

2 MICS and it's probably 70 percent of the weight

3 on there. Because cage is cage. Vault is

4 vault. Once that dollar passes through the

5 system now you get into things that are very

6 similar, but there are some things that aren't

7 similar, and Mr. Lambert pointed out, for

8 instance, a machine that has got a $10 million

9 jackpot on it, sits there in the middle of the

10 floor, Class III MICS requires you have a

11 camera on it. Why? Because you can tamper

12 with it. You can play with the EPROM inside of

13 that machine. You can go in and tamper with

14 it. And there's this old case, the largest

15 scam in Nevada history, that's exactly what

16 happened is, a guy that worked for the Nevada

17 Gaming Commission, he went out and he had

18 access to everybody's source code, he made

19 modifications to the source code, went in and

20 every once in a while changed EPROMs throughout

21 the casinos in Las Vegas. I don't know how

22 much he won, but he won a lot. He did five

23 years in the federal pen. And I get grief

24 because his name, too, is Ron Harris.

25 (General laughter.)

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1 CHAIRMAN LITTLE: Really?

2 MR. HARRIS: Yeah. That's exactly right.

3 My license is always slowed down with the

4 Gaming Commission. But in a Class II

5 environment, as Joe said, it's me versus you,

6 and there's a server in between us. The server

7 knows what balls you received, the certain

8 number of cards you bought, mine, it knows who

9 hit, you know, bought it and the timing

10 sequences of it, it settles it. That machine

11 in a Class II environment doesn't need a

12 camera. And unfortunately we have MICS right

13 now that, I know one tribe that just spent

14 $25,000 putting mikes and cameras over the

15 million dollar games, because the surveillance

16 portion of 543 references 542, and 542 says, if

17 you've got a million dollar game, you've got to

18 have cameras. In a Class II environment, that

19 box is nothing but a giant bobber. You can't

20 cheat a bobber. It is a machine, the server,

21 pairing people up. You can't cheat it. I say

22 that. You can always have, you know, you can

23 always have collaboration between developer and

24 players and all these things, so I don't say

25 never, but it would be very, very difficult.

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1 We verify in real time the signature of what's

2 on the box, what's on the server, did everybody

3 win. Our million dollar jackpot, we have to

4 send no one in the field. It's all real time

5 verified, electronic signatures verify the card

6 and volley ball, the signatures at the tribal

7 locations on the machine, the server, the

8 master server, everything, boom, reboot the

9 machine. There are tribes out there right now

10 that, on a Class III basis, you hit a big

11 jackpot, that machine stays locked up for two

12 days until the manufacturer gets there and

13 verifies the EPROM's offering all the things.

14 Bingo is like a dragster to the moped. It has

15 to have separate MICS. But there are some

16 things that overlap that should, that came in

17 from the 542 and I think does a better job of

18 it actually.

19 MR. VALANDRA: One of the things -- this

20 is Joe Valandra again -- I would urge you not

21 to burden Class II with CRIT controversy,

22 because 542 is all about CRIT and how the NIGC

23 deals with the ramifications of the CRIT

24 ruling. And how you do that, and there's many

25 suggestions to that, one is to promulgate good

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1 minimum internal controls, or not promulgate,

2 but actually make them guidelines, make them

3 best practices, that certainly, I'm certain

4 Class II could probably live with that, too,

5 but if your inclination is to promulgate

6 regulations, Class II is the place to

7 promulgate regulations and how you deal with

8 Class III is a question of how you follow CRIT,

9 and I would urge you not to burden Class II

10 with that.

11 CHAIRMAN LITTLE: Okay. Anybody have

12 any -- one of the questions I have is, you

13 know, when you're drafting the MICS or when

14 you're looking at these regs, excuse me,

15 through the working group, is it better to look

16 at the risks versus, you know, hit the big

17 items, the risk items first, and look at those,

18 then have a birthday kind of mix, or just a,

19 you know, I think -- I mean obviously

20 predated -- I mean when I was here I got the

21 issue when these were all created, but it seems

22 to me that it takes jurisdiction, and kind of

23 all links over Indian gaming. Does anybody

24 have any comments on should we be looking at

25 risk versus just putting something in place

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1 because it needs to be in place?

2 (No response.)

3 CHAIRMAN LITTLE: Okay.

4 MR. HARRIS: I'm not sure that I

5 understand. This is Ron Harris. I'm not sure

6 I understand your question.

7 CHAIRMAN LITTLE: When we look at the

8 MICS, should we look and see where the problems

9 arise? You know, is it a security issue, is

10 it, you know, somebody's tampering with the

11 software and that's where we should be focusing

12 on, beefing up the regulations or looking at

13 the regulations, versus just doing something

14 because it's done in other jurisdictions?

15 MR. HARRIS: This is Ron Harris again. I

16 think that it's so interwoven I don't think

17 that you can really approach it that way. You

18 know, again, the technical standards I like to

19 liken them in our explanations that it's like

20 building a gun and it's the technical standards

21 of saying how long the barrel is, the thickness

22 of the metal, how the chamber interacts, you

23 know, how the bullets go through it, very

24 technical in nature, here's this gun. The MICS

25 say how you can use the gun. Can you use it

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1 like a sniper rifle or is it going to be a

2 club? And the MICS control that you use it as

3 a gun. But the MICS are interwound with

4 looking at every element of the gun, you can't

5 separate one and say it's more important than

6 the other, I don't think. Certainly cash is

7 king and when you focus on the cash movement, I

8 think we've done an exhaustive review of that.

9 Most of that now has been dealt with now for

10 over 70 years. So there's some very bona fide

11 ways of handling this stuff in the casinos. I

12 think that portion of it is done very well.

13 CHAIRMAN LITTLE: Let's have a separate

14 line of questions. And Ron, I know you're not

15 in Las Vegas, but you guys had a visit to Las

16 Vegas. How does other state jurisdictions

17 handle regulation change? And what I mean is,

18 what is the relationship with the industry

19 versus the regulators, the state regulators,

20 the federal regulators, I guess state

21 regulators, how do they go about addressing the

22 regulations? What role does the industry play?

23 Do they have a seat at the table? You know, I

24 mean I'm very interested to see the submission

25 that the Tribal Gaming Work Group submitted,

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1 but does that happen in other jurisdictions,

2 that the manufacturers in Las Vegas send in

3 suggested regulation changes to the Nevada

4 Gaming Control Board, does that happen in

5 Mississippi or Pennsylvania or New Jersey?

6 Does anybody have any -- I'd like to hear more

7 about how other jurisdictions do this.

8 Charlie.

9 MR. LOMBARDO: Hi, this is Charlie

10 Lombardo. I will tell you from my experiences,

11 normally technology, prior cases, and I think

12 if you look at a lot of things that were done

13 out of the working group, technology also

14 qualifies, but that is usually how they come

15 about. The manufacturers or the industry

16 changes, and it's always growing and doing

17 things differently and that's usually what

18 drives them.

19 CHAIRMAN LITTLE: Because I know with all

20 the changes in New Jersey the legislature

21 passed a law where the Gaming Control Board

22 there can promulgate a regulation in seven

23 days. Anybody interested in allowing us to do

24 that?

25 (General laughter.)

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1 CHAIRMAN LITTLE: Okay. I was only

2 joking. Okay.

3 MR. VALANDRA: Commissioner Little?

4 CHAIRMAN LITTLE: Yes.

5 MR. VALANDRA: This is Joe Valandra.

6 Based on my experience with the past

7 Commission, I don't think it's great policy to

8 write a regulation on the worst case scenario,

9 or on a problem, unless it becomes a chronic

10 problem and you see it in many places, one or

11 two or even three incidents of a problem,

12 unless it looks like a path, it looks like it

13 was missed, is not a good way to write a

14 regulation, from my point of view.

15 MR. HARRIS: Commissioner Little, Ron

16 Harris. Many of the people that we have on

17 this TGWG work group, Charlie Lombardo being

18 one of them, has helped write regulations

19 around the world. A number of the heavy

20 lifters, if you will, were people who wrote

21 regulations for a lot of jurisdictions

22 including Nevada, New Jersey, some in Europe,

23 at very high level, and these are very

24 technical sound people, and I can count

25 probably at least six of them I know that have

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1 been on panels writing regulations around the

2 world. My understanding of this in different

3 conversations with Charlie on these things,

4 just like Nevada right now, our good friend,

5 Mr. Chairman, of the Gaming Control Board, they

6 reach out to the industry and say, here's what

7 we think is a problem. Sometimes the industry

8 comes forward and says, we think this is the

9 problem. They all meet, they all stare at it,

10 the industry goes away, comes back with

11 typically the solution of here's what we think.

12 Nevada right now is going through a

13 deregulatory process. They're finding out that

14 geez, we've over-regulated things and it's

15 costing the casinos, the operators, more money

16 than it's worth to protect. So they're going

17 through this process right now themselves and

18 saying, what are we trying to protect and how

19 much does that cost and have a cost benefit

20 analysis. So you're seeing even states like

21 Nevada, who have been pretty staunch in their

22 own MICS and their technical standards now are

23 reevaluating everything that they're doing,

24 very similar to what the NIGC is doing.

25 CHAIRMAN LITTLE: Thank you. I think I

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1 asked a question earlier about variance on the

2 technical standards. Does anybody have any

3 experience calling for a variance for the MICS?

4 Is the process workable?

5 MR. VALANDRA: I don't believe we've ever

6 gotten to that point.

7 CHAIRMAN LITTLE: Mike was just saying

8 that the NIGC has never has received an

9 application for a variance.

10 MR. HARRIS: Commissioner, I would say

11 that what we see in the TGWG document, that

12 that document was put together by some of the

13 best of the minds in the business, in the

14 industry. All I think, all of those attorneys

15 that really hammered that all are tribal

16 attorneys and I think that the review of that

17 was to say this is the idealistic way it should

18 work, based on the law, based on the way these

19 folks that are attorneys for gaming

20 commissions, et cetera, say that this would be,

21 stressing the point that tribes are the primary

22 regulator, and there's a lot of stuff I think

23 being done out there that they're not positive

24 of but they're doing it anyway. This would

25 clean all of that stuff up. So I think that

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1 would be one of those great vigorous things we

2 would like to have, how that would structure

3 versus what the government thinks they should

4 have.

5 CHAIRMAN LITTLE: It wouldn't be a proper

6 meeting.

7 MS. HOUSE: Okay. Good morning. My name

8 is Sharon House, and I'm an attorney for a

9 number of gaming commissions in various states,

10 and the issue with the variance, we did go

11 through that whole situation on how to deal

12 with it, because you may recall that the NIGC

13 wanted us to notify the NIGC every time they

14 wanted a variance, and what has happened up to

15 this point is that it's really caused a more

16 formal process to occur within the gaming

17 commissions themselves, where they will

18 identify, does this really meet the ultimate

19 results that are wanted by the MICS, that was

20 intended by the MICS and to protect the various

21 interests, and so what they would do is they

22 require most of them, not all of them, but many

23 of the operations have to go before the

24 commission, their own commission and identify

25 why this should take the place of what it

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1 actually says in the MICS. You still get the

2 same intent and you get it done faster because

3 it's usually a situation where there's an

4 expansion or something unusual has happened and

5 the local gaming commissions have the

6 experience now, after all these years, and they

7 probably had it before, but after all these

8 years that they are able to make an adequate

9 determination as to whether or not there should

10 be a variance and does it meet the needs of

11 following the money and dealing with the risk.

12 And I'll have to go along with what Ron says,

13 not all the time I go along with what Ron

14 says --

15 (General laughter.)

16 MS. HOUSE: -- is that when it comes to

17 the risk issue, I think that's been hammered

18 out to the point within the MICS that it really

19 doesn't have to be addressed except in those

20 areas where many of the local tribes and the

21 local gaming commissions have determined that,

22 okay, this is impacting us on a regular basis

23 because of the risks to the money or to, you

24 know, the machines and the integrity. So I

25 think when it comes to those issues, is that

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1 even if there's a concern by perhaps someone

2 else that the tribes can't do it, we still go

3 back to that, unfortunately, where they believe

4 the tribes don't have the ability, is that

5 that's where you can identify, yes, maybe some

6 bulletins that would assist in those risk areas

7 first, just to try them out. Those bulletins

8 again -- and I don't want to harp on this --

9 but I also agree with Joe Valandra, which I

10 don't do all the time either --

11 (General laughter.)

12 MS. HOUSE: -- but when it comes to the

13 Class III and the bulletins, the tribes that I

14 work for are very concerned about even dealing

15 with the CRIT issue and then move back into the

16 issue of the bulletins, the tribes, and we

17 can't reiterate this enough, but the tribes

18 comply with those bulletins almost 100 percent,

19 unless they see there's something in it that's

20 unfavorable or risky or doesn't meet the needs

21 of that particular tribe. Thank you.

22 CHAIRMAN LITTLE: Thank you, Sharon.

23 Appreciate that comment. I know we've kind of

24 meshed in the technical standards, so was there

25 any other questions on the MICS or the

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1 technical standards or comments anyone wants to

2 make?

3 MS. LASH: Robin Lash again, with the

4 Miami Tribe. I just wanted to emphasize that

5 with the MICS, we didn't delete anything. We

6 just reorganized. I know that there's a

7 concern because the document is so much smaller

8 than the last document we wrote. What we have

9 in place now is really user unfriendly.

10 There's just long paragraphs of language and

11 you read it and you think, what does it say?

12 So we've taken out a lot of the procedure,

13 we've left the regulation, we haven't changed

14 or taken out any of the regulation, it's all in

15 there. And like, for instance, I wanted to

16 just direct your attention to this one part,

17 for instance, this is control keys for

18 equipment. It says: Controls shall be

19 established and procedures implemented to

20 safeguard the use, access of security keys or

21 other access methods in accordance with the

22 following. Number one. Each of the following

23 requires a separate and unique key lock or

24 alternative secure access method. Then the

25 bullet point. You get a lot of bulletizing in

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1 this. Then we have drop cabinet, drop box

2 release, drop box contents, and storage racks

3 and carts, simplifying big paragraphs of

4 verbose language. So number two under this

5 section, access to return a key or equipment

6 shall be manually or electronically documented

7 with the date, time and signatures, or other

8 unique identifier of the agent accessing or

9 returning the keys. And then you have a little

10 Romanette. And this is a sample of how we

11 removed three sections, three separate tiering

12 languages repetitive for A, B, C, except for

13 the little regulation that kicks in there

14 somewhere. We have for Tier A, the operations,

15 at least two drop team agents are required to

16 be present to access and return keys. For Tier

17 C operations at least three drop team agents

18 are required to be present accessing a joint

19 key. So there in one paragraph we're

20 addressing three tiers, instead of three

21 separate sections that would repeat the same

22 thing except for just a few words within. So

23 really, I think that's important to keep in

24 mind. The document is smaller, it looks

25 different, but it's concise, it's reorganized

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1 and it's very easy to understand and read and

2 just contains the regulations.

3 CHAIRMAN LITTLE: Well, that answers all

4 the questions I had.

5 (General laughter.)

6 MR. HARRIS: It's Ron Harris. One other

7 thing. When we finish the work on the guidance

8 documents and the check sheets, we are going to

9 have that MICS with a footnote that says, see

10 here, go to the guidance document and how that

11 all will roll out for you. We're very close to

12 being finished, to get that done. So I know

13 it's a little more difficult to look at the

14 MICS without the guidance document, but I think

15 that will be much more thorough when we're

16 finished with all of this and everybody will

17 say, ahh, you did it, congratulations.

18 CHAIRMAN LITTLE: Well, we know

19 fortunately for me, one of the things we've

20 inherited from the last commission was familial

21 staff, so I believe you'll do a very good job

22 and it will be very helpful. So appreciate

23 seeing those when they're ready, so thank you.

24 Is there any other questions or comments or

25 that folks want to raise regarding the MICS,

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1 the Class II MICS, or the technical standards?

2 I know folks that maybe were at some other

3 meetings and might have popped in here, were

4 there any other issues you want to raise about

5 the Group 4 investigation, the backgrounding,

6 fingerprinting? Is there any questions that

7 the staff have?

8 (No response.)

9 CHAIRMAN LITTLE: If there's nothing else,

10 I would probably think it might be time to

11 conclude the meeting. But I want to give

12 everybody the opportunity to speak, and

13 especially the tribal leaders here, any

14 comments or anything from their tribes they

15 want to submit that they didn't get a chance to

16 recite, I'd be very happy to take them and have

17 them be put into the record.

18 If there's nothing else I think I'll call

19 the meeting to a close, a conclusion and say

20 thank you all for coming and wish you a great

21 week here. I know there's a great agenda and

22 wish you all safe travels.

23 The written transcript of this event will

24 be online and any comments that are submitted

25 will be also posted online. I think our

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1 deadline for the proposed discussion draft of

2 facility license is the 17th. I think it's

3 still on his desk. I think our next -- when is

4 the next consultation? Do you have that

5 offhand? It's on the website. I think it's

6 coming up here. I have it right in front of

7 me.

8 The NIGC consultation will be June 21st

9 and 22nd at the CNIGA Membership Meeting at

10 Rincon, so just for the record, if anybody

11 wants to be there. I want to thank everybody

12 for coming. Have a great day. Thank you.

13 (Proceedings were concluded at 11:26 a.m.)

14 * * *

15 (Original and One Certified Transcript and CD were

16 furnished to the U.S. Department of the Interior

17 National Indian Gaming Commission.)

18 * * *

19

20

21

22

23

24

25

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1 C E R T I F I C A T E

2 STATE OF WISCONSIN )

 ) SS

3 COUNTY OF MILWAUKEE )

4 I, David W. Wahlberg, a court reporter and

5 Notary Public in and for the State of Wisconsin, do

6 hereby certify that the preceding meeting was

7 reported by me and reduced to writing under my

8 personal direction.

9 I further certify that said meeting was

10 taken at the Hyatt Regency Hotel, Lakeshore

11 Ballroom, 333 West Kilbourn Avenue, Milwaukee,

12 Wisconsin, 53203, on the 13th day of June, 2011,

13 commencing at 9:16 a.m. and concluding at 11:26 a.m.

14 I further certify that I am not a relative

15 or employee or attorney or counsel of any of the

16 parties, or a relative or employee of such attorney

17 or counsel, or financially interested directly or

18 indirectly in this action.

19 In witness whereof, I have hereunto set my

20 hand and affixed my seal of office at Milwaukee,

21 Wisconsin, this 15th day of June, 2011.

22

23 _________________________________

 DAVID W. WAHLBERG

24 Notary Public - State of Wisconsin

 My Commission Expires November 27, 2011

25

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0

003 2:11

004 2:12

008 2:13

011 2:14

022 2:15

025 2:16

026 2:17

027 2:18,19

040 2:20

045 2:21

061 2:22

079 2:23

097 2:24

1

1 13:23

10 83:8 84:17 91:8

100 28:21 84:16

103:18

101 2:25

10:30 65:16,18

10:45 65:17

11 8:10

11:26 1:13 108:13

109:13

12 5:3 10:1 41:17

71:14

125 73:2

13,175 12:4

130 55:18

13th 1:11 21:18

109:12

14 8:12

150 30:23

15th 42:8 109:21

16,000 68:5

17th 22:10 108:2

1990's 28:16

1990s 41:6

1999 41:11

1st 10:3

2

20 35:21 52:11

2005 41:3

2006 50:25

2007 52:15 53:21

2008 21:17

2010 21:19 48:13,13

2011 1:11 10:1

21:18 109:12,21,24

202-632-7009 22:16

21st 108:8

22nd 108:9

25 21:11 84:9 89:15

89:15,18

25,000 92:14

27 109:24

2703 21:12

27th 49:24 51:13

29th 51:13

3

3 3:8 13:24 16:2

21:13 22:25 39:4,5

30 52:20 68:3 72:25

30,000 48:21

333 1:19 109:11

4

4 3:8 16:4,6 22:24

23:4 37:12 38:25

107:5

40 13:20 55:21

5

50 51:25 66:11

72:19,25 76:5

531 18:24 33:23

34:15

53203 1:20 109:12

537 36:11 37:2

542 92:16,16 93:17

93:22

543 21:13 39:5 42:6

42:13,16 43:6,7,18

48:7,11,16 72:14

92:16

547 21:14 42:6

556 23:4 24:13 26:1

48:8

558 23:4 24:13 26:1

559 22:9

571 19:23 26:5 30:7

5:00 22:19,20

6

60 13:16

7

70 91:2 96:10

7:30 4:6

9

9 21:12

97 71:18

98 16:9

9:16 1:13 109:13

a

a.m. 1:13,13 108:13

109:13,13

ability 30:2 103:4

able 15:5 27:20

31:10,10 34:25 40:3

52:24 55:11,13,19

71:4 72:16 102:8

absence 40:19

absent 32:2

acceptable 80:24

accepted 20:17

37:24

access 16:12,15

17:23 19:22,24 20:3

20:6,13 27:17,18

28:4,6 29:7,13,19

30:2,11 31:10,11,17

31:23 32:2,20 91:18

104:20,21,24 105:5

105:16

accessible 32:22

accessing 30:25

33:15 105:8,18

accompany 13:19

accomplish 39:11

accomplished 43:23

account 32:4

accountability

39:14

accounting 20:17

37:24 42:21,24

45:20

accumulation 25:8

accurate 59:3

achieve 12:15

acknowledge 73:1

action 15:15 18:1

26:19 33:5 52:7

66:13 109:18

activate 6:5

active 4:19 5:3 80:3

activity 21:9

actual 68:16

add 25:25 30:19

35:19 77:16 80:1

added 42:16 58:8

addition 41:10

additional 18:18

19:6 20:8

additionally 19:14

21:19 43:15

address 3:11 22:6

25:21 56:22 71:9

77:23

addressed 22:2,3

28:23 40:6 65:12

77:21 102:19

addressing 10:6

48:23 96:21 105:20

adequate 102:8

administrative

32:25 33:3

adopt 49:21

adopted 44:24 52:13

52:14

adoption 43:25

advanced 22:7

34:23 60:1

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advantage 19:20

affairs 14:25

affixed 109:20

afford 74:17

affording 29:12

agency 8:14 12:7

26:6 74:14

agenda 10:6 16:2

22:21 73:5 76:25

107:21

agent 58:14 63:16

63:18,19,20,24

66:16 105:8

agents 105:15,17

ago 8:7 28:15,25,25

57:1 82:3

agree 10:25 46:17

48:2 77:9 80:8 89:7

103:9

agreed 57:19

agreement 19:5,12

36:25

agreements 16:17

19:1,8,10,12,16,17

19:21 33:24 34:5,8

34:10,17,21 35:2,9

35:19 36:8

ahead 24:7,9 73:7

ahh 106:17

air 54:20 84:16

airport 17:5

alabama 51:9

allow 17:23 43:25

44:8 55:12 69:4

80:24

allowing 44:6 97:23

allows 16:22 43:12

81:16

alternative 21:21

104:24

alternatives 12:20

amendment 69:7

america 1:1

american 4:4

amounts 21:9 37:18

analysis 99:20

animal 82:14

answer 70:18 81:13

82:21,22,22 87:18

answers 106:3

anticipated 40:4

anybody 13:9,9 17:1

24:13 26:14,19

30:10 33:13 34:11

37:11 38:1,25 39:16

67:17 73:4 77:15

78:18,25 94:11,23

97:6,23 100:2

108:10

anyway 4:11 100:24

anyways 3:4

apart 67:11

apologize 18:3

application 63:23

100:9

applications 16:24

72:2,4

applied 36:2

apply 56:12

appreciate 5:5 30:3

35:5 44:20,25 50:4

103:23 106:22

appreciated 15:2

appreciates 4:11

apprehension 45:14

approach 13:13

15:14 95:17

appropriate 57:13

57:14 76:20 77:2,3

77:4,5

approval 18:23 19:1

19:10,16,20

approve 18:14 19:8

19:16 34:10,16,20

approved 19:5 34:2

34:8

approximately

13:16,20 51:25

april 10:3,13

arbitrarily 53:18

arbitrary 48:1

52:25

area 5:12 58:15

86:11

areas 49:4 70:23

77:22 78:9 102:20

103:6

argue 58:6

argued 59:7,7,7

60:4 62:24 66:7

argument 63:19

arms 6:2

army 8:12,12

arrive 32:21

art 41:20

asked 17:22 18:24

19:23 20:15 21:16

54:17 76:7,13 86:10

100:1

asking 69:22

asks 18:6

assembled 45:25

assembly 8:11

assets 39:7

assist 43:18 49:21

103:6

assistance 38:11

assistant 2:3 14:25

40:1

associate 2:2 3:14

assume 87:13,14

assumed 87:9

assuming 79:15

assurances 60:10

attempt 35:15,21

attempting 19:19

35:18 38:11

attend 13:4,6 15:6

39:20 40:3

attended 73:3

attention 104:16

attitude 27:16

attorney 5:11 6:10

7:6,21 39:22 40:20

101:8 109:15,16

attorneys 61:2

64:12,13 77:2

100:14,16,19

audit 42:23,24

auditor 2:7

auditors 5:15 57:3

authorities 53:15

59:21,23 63:8

authority 5:25

12:23 18:13,13 19:7

20:12 30:11,13,14

32:3,19 33:3,7

34:10 35:8 41:14

42:2 45:8 50:16

74:10

authorize 31:24

authors 75:2

available 9:19 85:25

avenue 1:19 109:11

aware 62:13 86:25

87:2

b

b 105:12

back 24:12,14 25:18

27:9 28:16 30:7

46:25 50:24 59:2

60:9 63:1,4 64:3

68:6,7 71:7 72:5,6

72:14 78:17 99:10

103:3,15

background 11:23

16:4,14 17:18 18:9

18:15 23:7 24:18

26:2 28:10 29:3

36:11,19 37:4 64:6

85:8 86:11

backgrounding

107:5

backup 74:9

bad 79:19

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ball 56:17 84:7,9

90:14,16,18 93:6

ballroom 109:11

balls 56:14 59:14

62:19 71:13,14 84:9

86:20 90:9 92:7

band 76:14

bank 30:25 31:12

32:4

bankers 30:24

barrel 95:21

based 10:8 29:21

33:4 84:11 98:6

100:18,18

bashful 8:5

basically 29:5 48:15

54:4 57:4 60:13

68:8 70:15

basis 93:10 102:22

battles 82:12

beefing 95:12

beeps 72:25 73:2

began 51:3 76:14

behalf 3:9,15 5:21

7:22 24:6,8 34:22

40:16 79:7

believe 15:13 33:1,4

34:19 46:2 51:12,25

61:4 100:5 103:3

106:21

belts 86:15

benefit 44:14 78:17

99:19

benefits 55:4

benson 2:7 5:16

best 9:4 29:14 50:5

56:7,10 57:18 74:20

77:11 80:12,14,15

89:19 90:6 94:3

100:13

better 32:15 44:8

46:12 48:4 61:3,19

88:15 93:17 94:15

beyond 35:16

big 55:23 57:23 69:2

93:10 94:16 105:3

bill 89:14

bills 25:15

bingo 42:19,22,25

56:12 59:14 61:14

61:17,25 62:1,1,8,9

62:9,10,18,19 71:13

81:15,23 83:24,25

84:14,18,25 85:15

85:17,21 86:2,2,13

86:19,19,20 87:2

90:20,22 93:14

bingo's 62:1 84:10

90:6

birthday 94:18

bit 8:6 14:16 27:21

36:15 75:5 83:21

85:23

bits 79:16

blended 83:6

blunk 56:2,2

board 6:1 7:19 8:6

29:23 45:7 62:4

67:23 97:4,21 99:5

boardroom 1:18

bob 6:21

bobber 92:19,20

bolts 82:22,24 87:21

88:7

bona 96:10

book 59:10

books 19:25

boom 72:6 93:8

boots 81:7 88:17

bought 92:8,9

bounds 78:12

box 9:11 81:21 82:1

82:2 83:11,12,12,17

83:19 92:19 93:2

105:1,2

boxes 30:24 67:7

70:25 71:2

breaches 80:25

break 38:3 58:2

65:15,16,17

bridges 72:20,21

bring 55:14 68:6

72:11 76:24 77:1,2

77:3,4

bringing 66:14

broke 23:20

broken 23:22 25:7

brought 67:25 76:6

brutal 51:16

build 55:12 57:16

71:1 76:20

building 8:15 95:20

built 70:21

bullet 104:25

bulletins 103:6,7,13

103:16,18

bulletizing 104:25

bullets 95:23

bunch 61:5

burden 93:21 94:9

business 19:19 28:9

31:19 34:24 35:7

40:17 41:13,14,18

42:1 50:15 74:14

100:13

businesses 41:9

button 6:3

c

c 2:1 105:12,17

109:1,1

cabinet 58:15 105:1

cabinets 70:22

cage 91:3,3

calculate 84:6,10,12

calculated 84:24,25

calculation 20:21

california 81:11

90:7

call 22:16 53:22,23

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chairman 2:2,11,13

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75:25

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e 2:1,1,9 40:8 44:15

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[dispute - expertise] Page 7

Veritext/NJ Reporting Company

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[experts - game] Page 8

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total 21:10 37:19

38:16

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track 14:1

trample 57:21,22

transcribed 11:11

14:22

transcript 3:1,18

24:3 45:2 107:23

108:15

[tamara - transcript] Page 21

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transcripts 10:2

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travel 88:18

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u.s. 108:16

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w

w 1:24 109:4,23

wahlberg 1:24

109:4,23

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walk 62:7,14

walked 89:11,12

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x

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96:10 102:6,8

yup 68:24

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