1

2

3

4

5 NATIONAL INDIAN GAMING COMMISSION MEETING

 TAKEN ON JUNE 11, 2012

6 IN OKLAHOMA CITY, OKLAHOMA

7

8

9 APPEARANCES

10 Daniel J. Little

Commissioner

11 1441 L Street Northwest, Suite 9100

Washington, DC 20005

12 (202) 632-7003

daniel_little@nigc.gov

13

Steffani Cochran

14 Vice-Chairman

1441 L Street Northwest, Suite 9100

15 Washington, DC 20005

(202) 632-7003

16 steffani_cochran@nigc.gov

17 Sarah Murray

Counselor to the Chairwoman

18 1441 L Street Northwest, Suite 9100

Washington, DC 20005

19 (202) 632-7003

Sarah_Murray@nigc.gov

20

21

22

23

24 Job No. NJ401497

25 REPORTED BY: Jean Baysinger, CSR RPR RMR

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1 * * * * * * * *

2 MR. LITTLE: We are on the record. We

3 have a transcriptionist named Jean. As we progress

4 through the discussion for Part 547 and then later

5 on, Part 543, we're going to ask you to, if you have

6 a comment, speak into a microphone. Tom Cunningham

7 will come to you and give you the microphone. Each

8 time you speak, you're going to need to state your

9 name and your organization so we have a record of

10 it, and then you can continue with your comments.

11 We'll do our best to answer all of your -- anything

12 you ask. If not, we'll get back to you, and then

13 this transcript will be put on our website shortly.

14 So we're going to pick up with Part 547,

15 and before we broke, Michael Hoenig walked through

16 the PowerPoint presentation, and how we will

17 continue for the remainder of the meeting is we'll

18 take comments on Part 547. If there's time before

19 lunch -- we're scheduled to break in an hour for

20 lunch -- we'll move on to Part 543. If you have

21 comments, you can make them at any time.

22 I also want to take an opportunity, if

23 anyone has written comments, if they can't stay here

24 for the entire day, especially on Part 543, if we

25 don't get to that this morning, if you would like to

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1 make a statement for the record on Part 543, you can

2 do so at any time. You don't have to wait until

3 this afternoon because I know many of you have busy

4 schedules and you may need to leave, so if you would

5 like to make a comment on either one of those, you

6 can grab a mike at any time and make that statement,

7 or if you want to submit a written comment, you can

8 do so at any time.

9 So at this time, I'll open the floor to

10 any comments regarding Part 547, or if you have --

11 if you need some more clarification on the

12 presentation, now would be a good time to do so.

13 Once again, state your name and the organization and

14 speak into a microphone.

15 MS. PETERS: Good morning. I'm Jill

16 Peters with Comanche Nation Gaming Commission.

17 First of all, we would like to thank the Chickasaw

18 Nation for hosting us and having us here today.

19 Secondly, the Comanche Nation appreciates the open

20 dialogue that we have with the NIGC for this federal

21 rule making and also including us in part of the

22 TAC. We appreciate that very much.

23 We submitted written comments, and we were

24 happy to see your published draft because you

25 accepted ten out of our 16 comments. Most of the

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1 other ones were pretty livable. One of the ones we

2 are still going to respond to is the grandfather

3 clause because I think you said there are seven

4 questions that need to be answered, so our

5 commission is going to look at that and get back

6 with you on the grandfather. If you don't mind, I'm

7 going to go over the 543.

8 MR. LITTLE: Yes, that's fine. Go ahead.

9 MS. PETERS: Okay. On 543 minimum

10 internal controls, we had 36 comments. We're

11 pleased you accepted 14 of those. You did not

12 accept nine, and I think what was kind of

13 frustrating for us is you failed to acknowledge 13

14 of the comments, so we still are not clear on those.

15 We may want to have dialogue with those 13 that we

16 did not get a response to.

17 One of the things is the surveillance, the

18 definition of sufficient clarity, and limits the use

19 of future technology by defining frames per second.

20 One of the alternatives that you offered was the

21 equivalent recording speed, and I think that we

22 would be fine with that.

23 And then the last one would be the 543.17.

24 The nation expressed concern about the use of the

25 defined terms financial instrument storage component

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1 and billing meter, suggesting that these terms might

2 confuse particular technologies, and then you define

3 additional comments on how the terms might limit the

4 use of those specific technologies and invited

5 suggestions for alternative terms, so we will also

6 be getting back with you on those, so thank you very

7 much.

8 MS. MURRAY: Miss Peters, do you have a

9 list of the 13 comments that we did not respond to?

10 MS. PETERS: Yes, I do.

11 MS. MURRAY: If you would provide those to

12 us, I would be happy to convey those to the

13 commission and review them to respond.

14 MS. PETERS: Okay. Thank you.

15 MR. LITTLE: All right. Thank you very

16 much. Any other comments? Next comment on Part

17 547? Yes, sir.

18 MR. YORK: My name is Steve York, and I'm

19 the gaming commissioner for Fort Sill Apache Tribe.

20 I have some written comments that I'll submit. Last

21 year, on July the 18th of 2011, I submitted a whole

22 group of questions to Tracie Stevens, who attended a

23 consultation session, Dan Little here, and Steffani

24 Cochran concerning a wide range of subjects that

25 never has been replied to, and I'm going to resubmit

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1 those to you again, and I won't bother you about

2 what the content is. I've sent the copies to

3 Miss Stevens, and they've never been answered. That

4 spoke on open, transparent, and accountable. I

5 haven't seen that terminology from you guys in a

6 while, so that's the primary reason I submitted

7 those questions when I thought that we were

8 transparent and accountable.

9 But my total deal is, you know, and my

10 question is I go back to the alphabets of Indian

11 gaming. The alphabets of the Indian gaming are 2701

12 through 2726, the same number of letters in the

13 alphabet. Okay? And the way I read it, the NIGC,

14 one of their principal duties is to monitor, so if I

15 ask you a question how many Class II gaming

16 operations are in the United States or in Indian

17 country, can you give me an exact number of how many

18 Class II gaming operations there are?

19 MR. LITTLE: Is this a question on 547?

20 MR. YORK: Yeah. It covers 547 and 543.

21 I mean, if you look at -- if you look at 2704, when

22 it talks about the commission and some of the duties

23 and stuff that the commission has, Congress is very

24 clear about what the NIGC's roles are, and so what

25 I'm saying to you, one of the specific things in

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1 there is to monitor, so if you guys are in charge of

2 monitoring the deal, just like us in Tribal Gaming

3 Regulatory Authority, we're to monitor Class II

4 gaming operations in the state of Oklahoma, so I go

5 in every day to work or we go in to work every day,

6 we know how many Class II gaming machines we have on

7 the floor, how many Class III gaming machines we

8 have on the floor. If we're dealing cards, we know

9 how many's there, so, you know, I'm asking how many

10 Class II gaming operations are in the United States

11 in Indian country. We've got 28 states.

12 MR. LITTLE: We know how many Class II

13 systems there are. We know how many Class II gaming

14 systems or operations there are, if you want us to

15 provide that information to you.

16 MR. YORK: That's all I'm asking. Can you

17 tell me how many Class II gaming operations exist in

18 the United States in Indian country right now? I

19 mean, you can go back a year. I mean, go back to

20 your last report and stuff. How many gaming

21 operations are in the United States?

22 MR. LITTLE: We can get that question, if

23 you want to submit it in writing. Right now --

24 MR. YORK: I've got it in writing. I'll

25 give it to you.

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1 MR. LITTLE: Okay.

2 MR. YORK: And to go along with that

3 question, you know, I mean, I'm a person that

4 believes in laws and regulations, and I have total

5 respect for the National Indian Gaming Commission,

6 but like I say, if you guys read the law, and even

7 if I read this handout material you got here, it

8 talks about you guys in the consultation process

9 about going back and looking and adhering to our

10 standards, the tribe's standards, you know. That's

11 what it says, but the way I'm reading 547 and 543,

12 we're totally ignoring what that is because we're

13 allowed to correct 547 to begin with. We shouldn't

14 have allowed that to happen, but it happened. Does

15 that give you precedence over our responsibility in

16 Indian gaming?

17 The way I read Indian gaming, it

18 specifically says if the state allows Class II

19 gaming -- it doesn't say Class II gaming, but if the

20 state allows gaming, then we are the tribal

21 jurisdiction over that gaming, not the NIGC. That's

22 what the law says, so if I develop my own technical

23 standards underneath this 547, it says I've got to

24 now submit my technical standard to you or to the

25 chairperson, and she can either approve it or

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1 disapprove it, but if my technical standards meet

2 the law and she disapproves it, where do we go for a

3 remedy besides the appeal process? The only place

4 we can go is to court.

5 I mean, no different than the Colorado

6 Indian River Tribe. Colorado Indian River Tribe

7 said you don't have any jurisdiction in Class III.

8 At that time, I was working for the NIGC. I knew

9 that we never had authority in Class III because

10 that's what the law read, and I didn't disagree with

11 it at all, but the Court come out and ruled, and I

12 told Chairman Hogan at the time, "You need to appeal

13 it if you don't believe in it." He didn't appeal

14 it, so it's applicable to all tribes across the

15 nation in Indian country, so we don't have any

16 authority to Class III.

17 And then the other one is, is if your job

18 is to investigate, then you didn't tell me how many

19 Class II gaming operations there are in existence.

20 Even though your principal job is to audit, you

21 should be able to tell me how many Class II games

22 are in existence in Indian country today, or last

23 year, the exact number. Alls I'm doing is just

24 reading what the law says to me, and I'm not trying

25 to be, you know, anything about it. I'm just saying

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1 what the law says and what the job is, and if you're

2 doing investigations, how many Class II operations

3 did you audit last year, total Class II audits? I'm

4 not talking about MICS audits on Class III, but how

5 many Class II MICS audits were done, and I

6 understand you can't go down to Mississippi and do

7 them.

8 And then the other thing is, is how many

9 illegal gaming operations are there in the United

10 States, Class II gaming operations? I don't see

11 anything in the press that says that these

12 operations are illegal. Like I say, I've got all

13 this in writing, these questions, and since I

14 submitted those past deals and never received an

15 answer -- and I didn't push it because I understand

16 that, you know, limited manpower and stuff, but the

17 element that you guys got to be careful about is

18 we've got our fee schedules up to 4076, and I want

19 to point out to you is you also got another little

20 deal that you do, and you charged me for an FBI

21 fingerprint. I can guarantee you if them funds

22 exist, the 4080 that Congress gave you, what can I

23 say to you? So, you know, I'm just being

24 straightforward, and I'll be here for the rest of

25 the day, but like I say, I want you guys to think

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1 about what the law says, you know, because Congress

2 is very clear.

3 I mean, you got another partial thing that

4 I was kind of proud of that you guys went in and did

5 your electrical mechanical definition. Matter of

6 fact, you've done it three times, but still, that

7 doesn't fully clarify the difference between Class

8 II and III. Do you know what needs to be done for

9 that definition to be clarified, fully clarify the

10 difference between Class II and III? You just got

11 to add one thing. You got to add in your electrical

12 mechanical definition what constitutes a Class III

13 lottery. Once that happens, then Class II and III

14 are settled out because everybody knows what a slot

15 machine is and everybody knows what roulette is.

16 Everybody knows what dice is, but the only thing

17 missing of it, you got timely suspension taken care

18 of in your definition, but you need to fully clarify

19 it.

20 And I understand you guys say, "Well, we

21 can't do that. Congress says everything else is

22 Class III," but the way I see it, that doesn't

23 restrict me from writing a technical standard that

24 says, "This is the definition of a Class III

25 lottery," so I can tell the manufacturers out there

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1 if they submit anything that meets that definition,

2 it's not a viable Class II game, so like I say, I

3 just want to provoke a little thought for you, and I

4 will submit my questions to this committee.

5 MR. LITTLE: Thank you. Is there another

6 comment on Part 547?

7 MS. GREEN: On behalf of the Creek Nation,

8 we have a few comments. Nancy Green, Green Law

9 Firm. Just a few comments on behalf of the Muscogee

10 Creek Nation. You know, first, I think that the

11 nation would like to convey just their thanks and

12 appreciation for the consideration of everyone's

13 comments and the fact that, obviously, some of those

14 changes have been made. We appreciate the fact that

15 the regulation is going to be much better.

16 You know, the primary comments, and there

17 will be written comments later, is, of course,

18 regarding the grandfather provisions. I think, you

19 know, it has to be said that, first, we disagree

20 with the whole premise that, you know, a whole group

21 of games are just a wholesale recall of those games,

22 and we believe that maybe there's some authority,

23 and it might be under contract law. We recognize

24 that it's there, and we would like to, in our

25 written comments, submit to you some answers to the

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1 questions that you pose regarding, you know,

2 primarily lasting impact to gaming. I think it will

3 be significant.

4 At this point, we've estimated, and I

5 believe there's other groups out there working

6 together, but, you know, approximately 32 percent of

7 games that are on our floor will be impacted, and

8 again, we've not pulled together numbers, but that

9 information will be forthcoming. I think it will be

10 surprising to you, and, really, everyone else once

11 those numbers get put together how huge that's

12 really going to be.

13 You know, in regard to the question

14 about -- your question about, you know, what if we

15 modified those games as they, you know, needed work

16 or -- you know, so that at the time that they had to

17 be repaired, they would just be brought up to date

18 in sort of a process by which, you know, at some

19 point, they would all ideally, you know, meet the

20 new standards and be on the floor.

21 I really -- I mean, that sounds great in

22 theory. I think the problem with that's going to be

23 that it's not feasible to modify these games even if

24 we're doing one or two games here and there. I

25 think you're going to find that, you know, they're

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1 not going to be able to be modified in regard to

2 some. You know, we are talking about different

3 vendors and different games, but I don't think it's

4 feasible, and, you know, and I don't think in the

5 end that even some of it's even possible, really,

6 without just recreating a whole new system and a

7 whole new gaming, at which point we've sort of

8 defeated the purpose, and then, you know, further,

9 there are some other comments.

10 You know, we have an objection to the fact

11 that the regulations -- and this is to 543 in the

12 gaming promotion regulations. We feel that's

13 outside the scope of NIGC. I can see you're not

14 shocked or surprised. Maybe you've heard that.

15 Well, at any rate, so we -- we, of course, reserve

16 our opportunity and, hopefully, provide comments

17 that are responsive to the questions that you've

18 posed, and hopefully, at the end of this process,

19 we'll have a better idea of what the impact may be

20 on gaming if we keep the grandfather privilege.

21 Thank you.

22 MS. MURRAY: Thank you very much for your

23 comment, Miss Green. I wanted to address what you

24 were saying about the potential modification

25 problems, and I really appreciate that particular

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1 comment because those are the types of answers that

2 we are looking for. That's why we're posing these

3 questions, is so that if there are problems with

4 these potential modifications to the grandfather

5 clause, that we know that, so we look forward to

6 receiving Creek Nation's comments, as well as

7 everyone else's, and getting answers to those

8 questions. Thank you.

9 MS. LASH: Robin Lash, Miami Tribe. I'd

10 like to thank you also for being here and providing

11 an opportunity for the Oklahoma tribes to address

12 you on these important issues, and on behalf of the

13 Miami Tribe, the tribe is still in the strong

14 position concerning 547 that the grandfather

15 provision be extended, that the sunset clause be

16 removed.

17 The issue that we have for the tribe, we

18 have probably 90 percent of our floor are

19 grandfathered systems, and I know that you're asking

20 for specifics on cost, and we lease the equipment,

21 but when you ask for modifications and equipment

22 upgrades, those costs always get passed on to the

23 tribe. In addition, when systems are put down or

24 shut down for the changes, you know, our floors are

25 not bringing in money, either, so there is a direct

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1 impact on tribes when you're looking at

2 modification.

3 Speaking for Rocket Gaming Systems, as

4 part of the Miami Tribe, currently, Rocket has 4,000

5 grandfathered systems on the floor and 2,500 units

6 in storage, and those 2,500 were not submitted for

7 grandfather, so when you ask whether it would be

8 beneficial to have a new -- you know, another

9 provision to allow for grandfathering, specific for

10 this manufacturer, the manufacturer would consider

11 submitting the 2,500 boxes that were not submitted

12 previously. Overall with your question, can they be

13 upgraded, the opinion from our manufacturer is no.

14 These are very basic systems. The Rocket

15 classic system is an older system. It's a basic

16 system, and it is just not cost-feasible to upgrade

17 it, so that if you look at the 6,500 boxes that this

18 involves, you're looking at a 39 million dollar

19 impact to the business of the Miami Tribe if these

20 are removed from the floor and not used and

21 grandfathered, and I think it's important to

22 remember that, again, these are valid Class II

23 systems. An arbitrary date set by the NIGC to

24 remove these from the floor does not make sense.

25 I think it's a sovereign right for the

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1 tribes to have the systems that they choose on the

2 floor. The older systems do make sense for the

3 tribes that are in remote locations and maybe only

4 bring in eight dollars a day on a game. They can't

5 afford to have new $14,000 boxes in their facility.

6 They don't have backup cost. They just need a means

7 to bring in a basic amount of money to assist their

8 tribes, and these older systems provide those means

9 for these smaller tribes in these remote locations,

10 so I think it's important to keep that in mind, too.

11 Thank you.

12 MR. LITTLE: Thank you, Robin. When we

13 talk about -- and thanks for giving us your

14 specifics. When we talk about the whole idea of

15 modifications, I think the idea was that, say, for

16 instance, if the data storage hardware went bad,

17 that in lieu of replacing that data storage with a

18 older, you know, piece of hardware, that it be

19 modified to a fully compliant piece of hardware.

20 That was the thought on that. It would only -- it

21 would only take effect when something broke. It

22 wouldn't be a requirement that it had to be put in

23 there.

24 We do hear often that a lot of these

25 systems are modified and modified repeatedly, and

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1 the thought was that perhaps they could be modified

2 when there's a modification. If there's ability to,

3 you know, modify it with a fully compliant part or

4 whatever, that that take place. That was the

5 thought. I can provide you with information.

6 The other comment I want to just respond

7 to is the -- I'm not quite sure. The 120-day

8 submission for the devices or systems, is there a

9 particular -- we don't know if this is a widespread

10 problem. When you say there are 2,500, are these

11 boxes or gaming systems or --

12 MS. LASH: Boxes.

13 MR. LITTLE: Boxes. Okay. If there is a

14 particular -- I mean, if this is widespread, if it's

15 very specific, and what I think I'd be interested in

16 is should there be like a one-time get-these-all-in17 right-now and that's it, or is it just something

18 that, if we were to make any future modification to

19 be fully compliant, would it even matter with these,

20 so those are some of the things that we're trying to

21 understand and be helpful, and I'm not asking for

22 you to respond right now.

23 If anybody can, you know, provide some

24 more information, you know, why wasn't the 120-day

25 notice met, it could be that that was a short period

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1 of time. I don't know, and as we deliberated, we

2 kind of looked back in the past, you know, records

3 of the commission to try and establish how that was

4 set, the reason for that, the reasoning for the

5 five-year sunset provision, why was that set.

6 When we did have some discussions, we did

7 get a comment that I think most folks thought the

8 five-year period is what the normal market would

9 have, you know, pushed these systems through.

10 However, I'm not sure if the commission really took

11 into account the economics that we've all been

12 through in the last five years, so if anybody can

13 provide some information on what was the five-year

14 time, the logic and reasoning behind this five-year

15 provision, it would be very helpful to the

16 commission. As always, thank you for your -- oh, do

17 you have some --

18 MS. LASH: I do. One follow-up comment.

19 MR. LITTLE: Oh, hold on. He's got a mike

20 for you.

21 MS. LASH: Just one additional point about

22 the cost to the tribes. If you are upgrading, if

23 you're modifying and you have to shut your floor

24 down for that, you could have a third of your floor

25 shut down and no income coming into the tribe while

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1 it takes perhaps three days to perform an upgrade or

2 a modification, so there is going to be a financial

3 impact on the tribes.

4 MR. LITTLE: Okay. Thank you very much.

5 State your name and the organization.

6 MR. HUMMINGBIRD: Jamie Hummingbird,

7 director of gaming commission for Cherokee Nation.

8 If I might begin just by also thanking Governor

9 Anoatubby and the Chickasaw Nation for allowing us

10 into their home, and I also want to thank the NIGC

11 board for taking time to listen to the many comments

12 that hopefully will help shape the future of our

13 regulations.

14 Let me just offer a couple of statements,

15 one being that in my spare time, I also serve as the

16 chairman of the National Tribe of Gaming

17 Commissioners/Regulators Association. In our last

18 meeting that we held back in the spring, the NTGCR

19 took a resolution up and passed it by a majority of

20 the membership there in support of the work product

21 that was produced by the Tribal Gaming Working

22 Group, and when I went into my reading of both 543

23 and 547, I saw that there were some things that were

24 taken into account, but there's a number of things I

25 did not see taken into account.

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1 Most glaring and what's probably been most

2 of the subject of today's discussion is the

3 grandfather clause, and being on the committee that

4 was seated at the time that these technical

5 standards were drafted, I can say that as we were

6 going through there, and to kind of reiterate what

7 both Nancy and Robin have said, is that the advisory

8 committee that was in place at the time objected to

9 the institution of the grandfather clause as well as

10 the 120-day submission time frame simply because

11 there was no basis, no logical basis given to us at

12 the time as to why we had to have a five-year

13 moratorium, if you will, or a five-year deadline in

14 order to change out our machines or why we had to

15 submit everything that we -- all of us had

16 individually to a lab certification.

17 It was noted at the time in our objection

18 that the tribal members of the advisory committee

19 felt that the imposition of those requirements was

20 arbitrary and without any support, so hearing today,

21 however, that NIGC is still open to deciding whether

22 or not those two provisions need to remain within

23 this document gives me a little encouragement simply

24 because, as both Nancy and Robin have pointed out,

25 this is going to have a significant impact on our

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1 operations because, as a Class II operation, we're

2 talking about a Class II system. We're not talking

3 about individual games, so when you take a system

4 down, you take all games down, so it's all or none.

5 We can't say, "Yes, that's fine," and go to the next

6 and finish up however many thousands of machines

7 happen to be sitting on our floors just in Oklahoma,

8 let alone what happens nationwide.

9 And this expense is not going to be just

10 in lost revenue, but an expense that's going to be

11 incurred by the vendors to get their products up to

12 spec, and it is not going to be endured by them.

13 Our history tells us those expenses are going to be

14 passed on to the tribe in one form or another, so

15 not only will we be losing revenue, but we also will

16 be paying for upgrades to the vendors, so it is very

17 important for us, and I think you'll see those

18 numbers come out when you do get written comments

19 back, and I appreciate you outlining some of the

20 questions that you are looking to have answered

21 because I think you will get clear answers for those

22 questions, and once you see that data, I believe

23 you'll be able to come to a realistic conclusion

24 that the imposition of those two provisions needs to

25 be removed simply because of the impact, significant

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1 impact, I would say, it's going to have on our

2 tribal operations.

3 The other thing I would like to offer up

4 is one of the things that have been suggested

5 through the TDWG was -- and this comment also

6 applies to 543, so forgive me if I jump ahead, but

7 looking at the document that we had, it is more

8 procedural-driven, it seems, in parts than

9 goal-oriented. I get the same criticisms from my

10 operations, so I'm not saying anything that nobody

11 hasn't heard before, but in looking at a federal

12 mandate for a particular step to be followed from A,

13 B, C, D, E, F, and G, it becomes a little bit more

14 difficult for us to apply that one-size-fits-all

15 type approach to our operations, and if we were to

16 get to be more goal-centric and less

17 objective-centric, I think that would provide the

18 tribal gaming regulatory agencies the flexibility

19 and the structure, if you will, to design our own

20 systems coming into compliance with the overall

21 ruling, and I think that, too, is also consistent

22 with the president's executive order, that is, to

23 look to the tribes to set their own rules.

24 And what we do here in Oklahoma -- what I

25 do in the Cherokee operation is different than what

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1 Robin does, what Matt does, and everybody else in

2 the state has some unique characteristic about them.

3 The vast majority of our operations and our rules

4 and regulations will be the same, but there are some

5 differences that we have within our own tribes that

6 speak to the need for us to design something that

7 fits us rather than us trying to conform to

8 something else, whether that be the use of

9 technology, whether that be the use of alternative

10 standards, if you will.

11 It is something that we should be able to

12 design for ourselves, and we need to have the

13 flexibility to respond to changes in the gaming

14 environment, whereas if we had a federally imposed

15 regulation, we cannot change that without going

16 through a very cumbersome process, as we have gone

17 through with this product. It's been a couple of

18 years in the making. Any new changes a couple years

19 from now is still going to take a couple of years.

20 Where are we in the meantime? We are a

21 square peg fitting in a round hole, so if we had the

22 ability to go through and design our own regulatory

23 structures when we need to, I believe that would be

24 something that would be of benefit to regulators

25 across the country. Thank you.

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1 MR. LITTLE: Jamie, thank you for that

2 comment, and I really enjoy hearing your comments,

3 and I know all the work that you do with the

4 National Tribal Gaming Commissioners/Regulators, and

5 I appreciate all the work that you do. You bring up

6 a couple of points, and we have tried to identify

7 areas, and more specifically talking about the Part

8 543 where the regulations were too specific, and the

9 staff had some tough meetings where we went through

10 line by line identifying areas where they needed

11 to -- you know, it doesn't have to be written in

12 blue ink. We tried to identify those areas and then

13 provide basically the minimum standard and provide

14 the gaming operation the ability to design what

15 works for their organization.

16 You know, there's areas that we don't

17 limit the use of technology. We tried to make the

18 alternative minimum standard section appropriate,

19 and if there's areas where you think that still

20 needs to be complete, let us know, but we're not

21 limiting you if there is an easier process that you

22 can, you know, submit that doesn't make you jump

23 through a whole lot of hoops, so if there's areas

24 where we need to work on that, please let us know,

25 so -- but I do appreciate your comments and look

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1 forward to receiving your comments. Thank you.

2 Is there another comment on Part 547?

3 MS. TAYLOR: Leslie Taylor, elected

4 secretary of the Delaware Nation, also an attorney

5 with the Green Law Firm. On behalf of the Delaware

6 Nation, thank you for allowing us to come to this

7 process and have this consultation today. Thank you

8 to the Chickasaw Nation for hosting this, and I'll

9 be brief about Part 547.

10 You know, the Delaware Nation is a small

11 tribe. We have about 1,400 members. We have a

12 small casino. We're working on another casino, but

13 the truth of the matter is that, like many small

14 tribes, gaming is what funds our tribal government.

15 It provides for our schools and provides for our

16 social services programs, and if you ask us to look

17 at the financial impact, we're in the process of

18 tracking that. I think it's safe to say it's

19 significant. It's so significant that, you know,

20 we're looking at losing scholarships for kids if we

21 have to take these games out. You know, Robin Lash

22 talked about the time they're not on the floor.

23 That's significant.

24 And what I don't think anyone has said yet

25 is we have a very specific market in Oklahoma.

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1 You've got a certain number of players that are

2 going to play their certain machine, and that's it.

3 We take those machines out, we're going to lose that

4 player, and that's something that's hard to quantify

5 into a formula to show you. It is what it is. You

6 may lose those players.

7 I think that what my tribe is most

8 concerned about is, you know, the initial comments

9 from the latest draft say that the purpose of the

10 grandfather provision was to protect the security

11 and integrity of the Class II gaming systems and

12 that this grandfather clause was supposed to somehow

13 play into that. I guess the question from my tribe

14 is, do you have any evidence or any data that these

15 grandfathered games would compromise the security

16 and integrity of any of our casinos?

17 MR. LITTLE: Is that a question?

18 MS. TAYLOR: I think that would be a

19 question for more than just my tribe, so, you know,

20 if you're going to make a -- if you're going to

21 force a provision that would cut the knees off of a

22 lot of tribes, what would be the reason behind it?

23 MR. LITTLE: You know, that's a very

24 helpful question, and I thank you for that. I want

25 to thank you for, you know, while the commission

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1 fully understands, it's always good to remind us of

2 the benefits that Indian gaming has provided to the

3 community, providing, you know, healthcare and

4 senior centers and scholarships for the children and

5 all of the other plethora of, you know, opportunity

6 provided to your communities. It's always good to

7 remind us of that. I appreciate that, and I want to

8 thank you for that.

9 As far as the grandfather provision, there

10 are some areas that, you know, as far as metering

11 and, you know, security and things like that that

12 involve correction. It's what we all do as

13 regulators. We always try to mitigate risk, so

14 that's the reason. You know, like I said, we don't

15 see this huge problem, however, we need to always

16 make sure that we try to keep it to a minimum.

17 MS. TAYLOR: Now that I've approached you

18 on that, you said it wasn't a problem.

19 MR. LITTLE: Necessarily a problem, but we

20 need to always try to mitigate risk.

21 MS. TAYLOR: Thank you. I appreciate it.

22 MR. LITTLE: Thank you very much. Next

23 comment on Part 547? Mr. Morgan?

24 MR. MORGAN: Matthew Morgan, gaming

25 commissioner, Chickasaw Nation. Commissioner

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1 Little, thank you today for providing us this

2 opportunity. I have a couple of comments on behalf

3 of my office, as I've sat around and listened to

4 some of the discussion, and kind of to follow up on

5 Miss Taylor's comments, you know, any time we enact

6 a regulation at a local level, you're always looking

7 at what the rule is supposed to be in response to,

8 and it is somewhat difficult to figure out in this

9 instance what the response is for under a

10 grandfathering provision.

11 We have a significant amount of games on

12 our floor, as well, that operate under a

13 grandfathering system. Not having the data pulled

14 and fully vetted out, I would venture a guess it's

15 probably 30, 35 percent of my floor, but, you know,

16 when we get those numbers nailed down a little bit

17 more, I'll provide you with some of those numbers,

18 but it seems strange to me that we're still talking

19 about this grandfathering and the 120-day

20 submission.

21 I'm still trying to figure out why you

22 have this rule, what is it in response to, and why

23 those dates, you know. 120 days does not make it a

24 Class II game, and I know you've talked about it's

25 not a classification, but if I classify a game as a

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1 Class II game and it didn't meet the 120-day

2 submission, I still can't play it under your rules,

3 so I have a Class II game that's unplayable, so

4 you've effectively still reached the goal of the

5 game is not going to make a profit on the floor,

6 which is probably my next point.

7 Why we don't let the market dictate what

8 is on the floor? If the grandfathering games are

9 running the way they're supposed to be running and

10 there's not an issue with them, I'm not for sure

11 what the five-year date brings to us when suddenly

12 there's going to be an issue here that these games

13 need to be converted over. If they have a market

14 that's playable and your tribal gaming regulatory

15 authority is comfortable with that risk and they can

16 provide you with any type of documentation that

17 shows it's been to an independent testing lab and

18 it's met those certain criteria, I'm not for sure

19 why those games need to leave our floor. Again, as

20 other speakers have talked about today, that's going

21 to be a huge impact on tribal governments trying to

22 go through this process.

23 That is probably my question that I keep

24 trying to come back to. What is the significance of

25 those dates and what is the problem we're trying to

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1 solve? Thank you.

2 MR. LITTLE: Thanks, Matt, for your

3 question, and I think we've tried to answer this in

4 the past. You know, this commission wasn't here

5 when this regulation was created, and, you know, we

6 can't -- it wouldn't be a good idea for us to try to

7 guess on what was the logic and reasoning. What

8 we've heard from discussions or consultation and

9 discussion is that they felt -- and this came from

10 tribal leaders had made comments that -- that the

11 market would have driven these out within the five

12 years, and that was the reasoning behind that.

13 Now, it went into effect in 2008, and

14 these discussions took place in probably 2006, 2007,

15 and not a situation that folks, you know, knew of

16 the economic conditions that, you know, was coming

17 ahead, so that's only kind of guess I can make, but

18 -- so like I requested earlier is if you can provide

19 me more information on why or how that five-year

20 date was created, that would be very helpful, but

21 I'm asking the question you're asking, basically.

22 MS. LASH: Robin Lash, Miami Tribe. I

23 guess, you know, I just have a high level of

24 frustration, and you are aware of this from the

25 tribal advisory committee, with maintaining a

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1 regulation that you can't explain. You know, we've

2 asked in the past, you know, why this and why that,

3 and I know it was a different administration, but

4 this is your opportunity to change something that

5 was not right in the first place, and it isn't

6 right, and I know you're asking us for specifics,

7 and we're going to provide that, you know, but --

8 and I don't mean to let my frustration show, but

9 honestly, I mean, if you can't substantiate

10 something and there's no reason, you know, at your

11 end why it was initiated, then let's do something

12 about it.

13 MR. LITTLE: Thank you, Robin. Any other

14 question on Part 547? You don't have to be at the

15 table to make a comment if anyone in the audience

16 wants to speak.

17 Well, we could start on -- we're about ten

18 minutes from a lunch break. We could start on the

19 543 presentation, but I'm not sure if we'll get

20 through it in time. I think we'll let her make --

21 the vice-chair make some comments, and then we'll

22 break for lunch early. We'll come back at -- the

23 schedule says 1:30, and we'll pick up on Part 543.

24 MS. COCHRAN: Well, since Dan has this all

25 under control, I'm going to go home and be sick. I

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1 apologize. I wanted to let you know I wanted to

2 hear your comments, and I still want to hear your

3 comments, but I'm not doing probably anybody in the

4 room nor myself any good by sitting here, so I'm

5 going to beg your indulgence and I'm going to go

6 home and get some rest. I look forward to seeing

7 everybody at the sovereignty symposium, and I will

8 listen to the transcript, and I'll read the comments

9 that come in, and I do wish the rest of the

10 afternoon is productive, and I appreciate the

11 comments and I look forward to continuing a

12 dialogue, so I'm going to let the commissioner

13 handle it and I'm going to call it a day.

14 MR. LITTLE: Thank you, Vice-chair.

15 Okay. I think we will recess until 1:30.

16 Thank you.

17 (Recessed from 11:48 a.m. to 1:34 p.m.)

18 MR. LITTLE: Good afternoon, everyone. I

19 want to welcome you back. Let's get started here.

20 Okay. We're going to get started with the

21 afternoon portion of the agenda for the regulatory

22 review -- Part 547 and Part 543 of the regulatory

23 review agenda.

24 Before we broke, we did -- we went through

25 the 547 presentation and we took comments. A couple

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1 things as we -- before we broke we want to clarify,

2 and I think there was a comment on the need for the

3 grandfather -- or the regulation, and my comment was

4 directed towards the commission was not sure of

5 the -- why the former commission chose five years.

6 We know why there's a need for the

7 regulation. We know that there's reasoning behind

8 any regulation. There's limited information to

9 determine why they set five years, and I can only

10 allude to what we hear and what we've learned

11 through comments, but that was what my comment was

12 directed towards, and I hope it wouldn't be

13 misconstrued in any other fashion. Sarah wanted to

14 make one other comment here, so I'll turn it over to

15 Sarah.

16 MS. MURRAY: Good afternoon. I wanted to,

17 in some respect, respond to Miss Taylor's question

18 from earlier today regarding the risk of the

19 grandfathered games and whether we know -- have a

20 quantifiable risk associated with those games, and

21 the answer to that is that we don't always know what

22 the risk is because our authority is a civil

23 regulatory authority, which means that we promulgate

24 regulations, usually, to prevent breaches in

25 security and laws that protect the integrity of

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1 Indian gaming.

2 On the other side of that is a criminal

3 authority, which we do not have, to deal with actual

4 theft loss and other compromises in security in

5 Indian gaming. At that point, the NIGC would not

6 always be notified or be aware at the level that a

7 security breach has occurred at an operation or a

8 tribe. We wouldn't actually get those statistics,

9 so it would be very difficult for us to know what

10 the actual risk is unless the operations or the

11 tribes voluntarily provide us with that information.

12 I also wanted to clarify that the

13 technical standards in the grandfather clause are --

14 were created to protect the security integrity of

15 Class II systems, and the grandfather clause in

16 particular was created as a mechanism by which

17 tribes could gradually come into compliance with the

18 technical standards, and it was designed to mitigate

19 and potentially eliminate the cost to tribes

20 because, over the five-year period, it would make it

21 possible for them to not have to close down their

22 entire floor at one time to come into compliance.

23 They would have five years to do that over time.

24 At this time, we're starting to reevaluate

25 the necessity of the five-year period, the 120-day

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1 period, and evaluate what the actual risk is

2 associated with these grandfathered systems, and

3 we're very interested in hearing the responses to

4 the questions that are in our preamble as well as

5 any supplemental information that tribes or

6 organizations feel is pertinent to deciding what to

7 do about the grandfather clause and the five-year

8 period, generally, so we very much appreciate

9 everyone's comments, and we look forward to

10 receiving written comments in response to those

11 questions. Thank you.

12 MR. LITTLE: Is there any other comments

13 on 547 before we move to 543? Let's get a

14 microphone over here, if you can state your name and

15 organization for the record, please.

16 MR. GREEN: Jess Green, employee of the

17 Miami Tribe of Oklahoma, and I represent other

18 tribes, of course. In 1997, litigation started

19 against these Class II games that you're worried

20 about and are trying to grandfather -- trying to get

21 out of existence by the grandfather clause. It was

22 started by the U.S. Attorney in the Northern

23 District of Oklahoma, and shortly thereafter, it

24 started in California. It resulted, in 2000, in the

25 two Multimedia decisions which say that Class III

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1 gaming principles are not equitable to these linked

2 video games, that they are Class II games, and they

3 are lawful as Class II.

4 Now, what you're doing with the

5 grandfather clause is you're causing both of these

6 federal circuits to task. You got federal judges

7 that have ruled that these two systems are Class II,

8 and yet the regs are going to prevent them from

9 being in play. I don't think federal judges will be

10 happy with that. I also want to advise you that

11 that Multimedia system that was litigated is owned

12 by the Chickasaw Nation, who may at any time start

13 replaying it, and because the systems and the Rocket

14 systems are so near the same, they will probably use

15 those Rocket boxes that are in storage because

16 they'll be very reasonable to utilize.

17 And if you understand those games, those

18 games separate money from players at a much slower

19 rate than most of the Class II games you see today,

20 but they might be ideal if you're busing people to

21 bingo halls. I want you to understand that because

22 bussed people bring about 40 to 60 bucks with them.

23 They've got about $20 to play. They usually have

24 two to three hours from when the bingo session ends

25 before they leave. Well, they're going to lose

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1 their money real quick in a regular gaming facility.

2 They're just sitting in there taking up space. If

3 we keep them utilizing these games, they will

4 entertain them for long periods of time, as these

5 games have proven they will. These games have a

6 place as a niche game.

7 You're also, of course, protecting us from

8 a risk that has never been proven, not in ten years,

9 but in 15. We haven't had a risk in 15 years over

10 these Class II link server based games, and the

11 reason we haven't had a risk is because we pay the

12 manufacturers a percentage fee, so they watch things

13 just as close as the tribe. You already have two

14 people being watch dogs on the games. Anything goes

15 awry, both the gaming commission, management, and

16 the manufacturer want to know why the percentages

17 are off. That's why you haven't had a problem.

18 Again, they're not designed with back

19 office systems. They're not designed to look into

20 back office systems because in order to win the

21 initial litigation, the box had to be dumber than a

22 post. We had to prove that there was nothing in the

23 box that could do anything. I mean, Dan, you well

24 know the game ain't in the box. It's in the server,

25 and so those games are intentionally, by design, not

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1 very smart at the box. Your regulations require

2 games to be smarter at the box.

3 Now, you've not heard any protest over the

4 new games that are coming into effect, and again, a

5 lot of the tribes have required the games that go

6 into their bigger, more marquee facilities to have

7 intricate back office systems so they can track

8 everything, but in our smaller to medium size

9 facilities, we still use these old boxes, and we use

10 lots of them, and if you think about it, these

11 smaller to mid-size facilities are the places where

12 some of the smaller to mid-size tribes have all

13 their money.

14 If you cost them more money, if you make a

15 third of their floor be down three to four days out

16 of a month, you will destroy their profitability for

17 that month, and you need to be able to tell them

18 which government programs they're not going to fund

19 that month. Are we not going to let the seniors eat

20 that month? That's the direct impact you're going

21 to have with this grandfather clause. I appreciate

22 your listening to an old man's comments. Thank you.

23 MR. LITTLE: Thank you, Jess. I

24 appreciate your words. I know you've raised the

25 issue of the court decisions on the games in the

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1 past, and we do take those into account, and I know

2 the legal staff is aware of it, so I do appreciate

3 that and always appreciate comments that you make.

4 They're very thoughtful and very well thought out,

5 so thank you very much.

6 Is there any -- yes, ma'am.

7 MS. COODY: My name is Lottie Coody. I'm

8 with the Seminole Nation of Oklahoma. I'm the

9 gaming regulator. I'm sitting here and I'm trying

10 to play catch-up, and I've been going to these

11 meetings, and I've listened to everyone making

12 comments here. I know that it will affect our

13 casinos because they're very small, and just

14 thinking about it and talking about dollars and

15 everything, I'm thinking to myself when those Class

16 II games go down, we're losing money and we won't

17 get paid, so I know you depend on our money to pay

18 for your jobs, so I'm just thinking about that.

19 Thank you.

20 MR. LITTLE: It's always a good reminder

21 that -- and I know folks in the audience all know

22 this, but the agency is fully funded through the fee

23 assessments that you all pay, and it's a great

24 responsibility to make sure that we utilize those

25 resources wisely, so I really appreciate you

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1 reminding us of that. Thank you for your comment.

2 Is there any other comments on the Part

3 547 before we move to the 543 presentation? Okay.

4 I will turn the microphone over to Jennifer Ward.

5 She's going to continue the Part 543 presentation.

6 MS. WARD: Good afternoon. Welcome back

7 from lunch. We're going to dive right into Part 543

8 here, and unlike 547, since we have a

9 transcriptionist now, if you have any comment,

10 please feel free to interrupt me, and quite

11 literally interrupt me if you need to. I may be

12 looking down at the paper or up at the screen and

13 may not see you, so please let me know. Just make

14 sure that we get a chance to get you on microphone

15 before you get started too far into your comments.

16 All right. So Part 543. This part

17 addresses only Class II games and their associated

18 functions. The proposed rule is based on the

19 discussion draft, and that was a new document with

20 ideas and language that we drew from several

21 sources. Those included the current MICS, the TAC

22 recommendation, the Tribal Gaming Working Group

23 guidance, and the 2010 proposed MICS.

24 In this proposed rule, generally we

25 reviewed the use of "agent," "person," and

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1 "personnel" in response to comments, and we made

2 changes where we felt it was appropriate so that

3 where it says "agent," "person," or "personnel," we

4 tried to make sure that it says exactly what we mean

5 there.

6 We also inserted "as needed" language in

7 each of the supervision provisions, excepting the IT

8 section, and this is to promote consistency in the

9 proposed rule. We also added supervision provisions

10 for patron deposit accounts, lines of credit, and

11 surveillance.

12 We changed a few of the definitions in

13 response to comments. The first has to do with

14 "drop proceeds" and "drop." The "drop proceeds"

15 definition has been amended to include the financial

16 instrument storage component proceeds. Previously,

17 it only included drop box proceeds, so we included

18 both of them, and the "drop" definition has been

19 deleted as unnecessary. The process of collecting

20 boxes and components is described thoroughly within

21 that section.

22 The definition of "gaming promotion" has

23 been altered to include only those promotions that

24 require game play to participate, and this is the

25 same as it was in the discussion draft, so there

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1 were no changes from the discussion draft to this

2 one.

3 Similarly, the definition of "sufficient

4 clarity" continues at 20 frames per second minimum,

5 but adds "clearly identify" to the requirements, and

6 the commission invites comments on whether 20 frames

7 per second or the equivalent will be acceptable to

8 prevent a limitation on technology. We did receive

9 a comment today that if we limit it to 20 frames per

10 second, there may be a limitation on technology if

11 the technology doesn't use frames per second, so

12 we're inviting comment on whether the insertion of

13 "or the equivalent" is acceptable there.

14 Under 543.3, the section on how tribes

15 comply with this part, these are minimum standards,

16 and a TGRA may establish additional controls that do

17 not conflict with this part. The regulations

18 provide a framework that recognizes the significant

19 role of TGRAs in regulating gaming, and throughout

20 this document, the TGRAs establish thresholds for

21 investigating variances, and they implement

22 procedures for various standards.

23 There's also 12 months to comply by

24 establishing and implementing procedures. You have

25 12 months from the date of the final publication to

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1 establish standards, and then you have until the

2 next fiscal year begins to come into compliance with

3 those, and the new facilities must be compliant

4 immediately. Yes?

5 MR. CHRISTENSEN: Bear Christensen with

6 Cherokee Nation Entertainment. We're going through

7 the definition sections. You had mentioned agents,

8 but you didn't mention anything regarding a

9 definition for the TICS, the internal controls that

10 are written by the operation, and are -- is that

11 something that you're planning to leave in the draft

12 going forward or is that something that is still

13 open for discussion?

14 Because, you know, one of the feelings I

15 have on that is that I think that's a big

16 over-stepping of an NIGC authority to require those

17 policies and procedures for the individual

18 operations. I think that's something best left to

19 the tribal gaming authorities to determine what sort

20 of controls that they have for their properties

21 because those properties can be different from site

22 to site, as well as unique.

23 There's no language within that definition

24 that addresses what qualifies as a satisfactory TIC,

25 and what troubles me is the ability stated within

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1 the discussion draft for the NIGC to fine an

2 operation based on that definition.

3 MS. WARD: We might need a follow-up

4 comment to clarify your question, but continuing

5 about the definition of this specific internal

6 control standard is that the tribe's operation is in

7 conjunction with the security established and

8 implemented, and you're right. There is nothing

9 that says what a sufficient or acceptable TICS would

10 be, and that's by design.

11 We want the flexibility there for each

12 individual operation and each individual TGRA to be

13 able to establish their own TICS that meet their

14 operation's needs, but it is important that each

15 tribe have those TICS because throughout the MICS,

16 as you look through it, you'll see that tribes have

17 to establish thresholds to investigate variances.

18 They have to, for example, come up with a policy to

19 make sure that when a kiosk reconciles pull-tabs,

20 that those are then destroyed in accordance with the

21 policy, so things like that would be the TICS, and

22 those do need to be established and maintained.

23 MR. CHRISTENSEN: Right, but why is the

24 NIGC establishing that? Why isn't it left up to the

25 individual tribal gaming regulatory authority to do

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1 that, and why would the NIGC therefore fine those

2 operations while not letting the tribal gaming

3 regulatory do that themselves?

4 MS. WARD: I think we do leave it up to

5 the tribes unless I'm misunderstanding your comment.

6 When we require the tribes to establish thresholds,

7 it's the tribes that are coming up with those. When

8 we require procedures for security destroying

9 pull-tabs that are taken from a kiosk, the tribe

10 comes up with those procedures. We just require

11 that each individual tribe has those procedures.

12 You can then determine what that is and what suits

13 your needs, but we just require that you have them.

14 MR. WEST: I don't know if everybody has

15 looked at the federal register. That is the current

16 document that's being published by the commission

17 for both 547 and 543. I know in some of the last

18 meetings, some people are looking at the past

19 discussion drafts and other documents that have been

20 distributed around, but one of the proposed

21 standards states that each gaming operation must

22 develop something that at a minimum comply with the

23 TICS.

24 It's not the intent to take away any of

25 the power and approval from the TGRA as far as the

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1 TICS that are developed and managed by the gaming

2 operations, so there's nothing taken away from the

3 TGRA.

4 MS. WARD: Thank you, Rest. I just also

5 wanted to clarify that there was some talk of fining

6 folks about the MICS unless I misunderstood the

7 comment. We've, as far as I know, never fined

8 anyone for a MICS violation or issued a violation.

9 There's never been a notice of violation for a MICS

10 exception.

11 MR. CHRISTENSEN: For MICS or a TICS?

12 MS. WARD: Either. MICS, really. TICS

13 are new to this.

14 All right. Also, moving on to 543.4 on

15 this same slide is the small and charitable

16 exceptions, and -- oh, Jess, you have a comment.

17 MR. GREEN: I'll allow you to finish it

18 first.

19 MS. WARD: Okay. The small and charitable

20 exceptions. Now, the history on this, the

21 charitable exception came first in 2002 when the

22 MICS were written, and then later in the next

23 incarnation of the MICS, there came along the small

24 gaming operations exception, and as we look through

25 it now, we're wondering whether a charitable

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1 exception is still necessary or whether it's already

2 encompassed by the small gaming operation exception,

3 and it's fairly redundant, so we're looking for

4 comments on that.

5 MR. GREEN: Again, my comment on the

6 charitable is it is not redundant. It is very

7 important, and where it becomes important is if

8 you're actually out there doing the work. Matthew

9 Morgan regulates -- my name is Jess Green. I'm

10 employed by the Miami Tribe. I'm a member of the

11 Green Law Firm, who represents tribes throughout the

12 nation.

13 But my point is, is that in regard to

14 charities, that's where you stuff the senior side.

15 Now, I say stuff because the seniors will operate a

16 bingo game just before lunch, and if you think

17 there's any way you can control senior citizens of

18 any Indian government, you need to tell me how

19 because I haven't seen anybody be capable of it.

20 They've been running their nickel bingo or

21 ten-cent bingo game not since IGRA, not since '82,

22 but ever since they've had a senior site of any

23 kind, and they jealously guard it. They need their

24 own exception for us to squeeze them in, and they do

25 not need to be considered a small operation. They

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1 need to have their own category because they do

2 things in a real unique fashion, and they police

3 their own work.

4 MS. MURRAY: Thank you, Jess, for your

5 comment. I think the issue wasn't whether to get

6 rid of the charitable exception, meaning that you

7 wouldn't be able, as a charity, to operate under the

8 exception. It was, rather, whether a small gaming

9 exception sort of encompassed and could be merged

10 into one, and whether that was appropriate, or

11 whether there was some reason why it shouldn't be,

12 so if that's what your comment is directed toward,

13 then I appreciate that.

14 MR. GREEN: No, my comment is that we

15 still need to keep that charitable and put those

16 seniors in small. A gaming commissioner might want

17 to exercise some authority because sometimes small

18 is in the eye of the beholder, and they tend to

19 grow, and the gaming commissioner may need to have

20 some authority over them and he might need to

21 exercise it, but from a practical standpoint, you're

22 not going to do anything with the seniors. You just

23 can't.

24 MS. MURRAY: That was the answer that I

25 was looking for, and I appreciate that comment about

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1 why we need -- why we need those exceptions, so

2 thank you. I appreciate that.

3 MR. LITTLE: And this is one of the

4 questions that we did ask in the preamble, so, you

5 know, looking at ways to make -- and these are

6 minimums to make them continue to be workable. If

7 this is an area where we could streamline a little

8 bit, that was the reason behind it, but we weren't

9 sure, and that's why we asked the question, so thank

10 you.

11 MS. WARD: Okay. Moving on to 543.5, how

12 tribes apply to use an alternate standard, and this

13 is the same thing we talked about in 547, the

14 alternate standard language versus variance. I

15 think it was in the TAC when they went through and

16 there was some discussion about the word "variance"

17 and how it can be confusing, particularly in the

18 context of the MICS, where "variance" is used to

19 describe when you have a value that is different

20 than what you expected it to be, and here that's not

21 what we mean.

22 Here we mean the tribe comes up with a

23 standard that's different from the MICS, so we

24 changed the language to an "alternate minimum

25 standard" based on the public comments. There were

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1 some comments asking what exactly we meant by

2 alternate standard, and we wanted to clarify that a

3 tribe can always implement a standard that's more

4 stringent than the MICS, but if it wants to

5 implement a standard that's something different from

6 the MICS, it requires this procedure where the TGRA

7 may approve the alternate minimum standard, but they

8 still have to obtain approval from the NIGC chair.

9 The NIGC chair then reviews and comes to a decision

10 within 60 days unless she requests an additional 60

11 days. Yes, Mr. York?

12 MR. YORK: Yeah. I don't think I need a

13 microphone. My primary question is, you know, you

14 guys talk about a minimum like on this one. You

15 can't have anything less than a minimum. You have

16 something greater than a minimum. I mean, me and

17 Jethro Bodine went to the same school. We're both

18 edumicated. So how can you talk about having a

19 minimum, because you either have a standard or you

20 don't have a standard. You can't create a variance

21 that's less than a minimum, so it has to be

22 something that exceeds the minimum. That's the only

23 thing I'll point out to you. I mean, I'm just

24 talking about a common understanding of the English

25 language. You can't have anything less than a

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1 minimum.

2 MS. WARD: Thank you for your comment, and

3 in the standard itself, it explains that it can't be

4 less than the minimum. You don't -- and you're

5 correct. You don't require chair approval if it's

6 more stringent than minimum, but there is a middle

7 ground where it's different than the minimum, and

8 that's what we're trying to get to here.

9 MR. YORK: I mean, the only reason I'm

10 bringing this up is that I come from back in the old

11 days when Joe Smith was in charge of the division

12 when he first come out with the MICS in 2002, and by

13 the time it come out, he'd already changed it by the

14 time it became published in the regs. I mean, every

15 time that we see regs published, you know, in the

16 content that we're looking at, they're already

17 changed. Somebody in their thinking ability,

18 basically, will change them things and then try to

19 tell me like the Colorado Indian River Tribe case

20 would apply. It's not applicable because you wasn't

21 part of the lawsuit. Well, that's a bunch of bull,

22 too, you know.

23 I mean, I'm trying to be honest with you.

24 If we're going to have a truthful discussion, we

25 need to talk about it, and I'm going to raise the

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1 fact of the TGRA. You keep mentioning the TGRA.

2 There's nothing in the alphabet of IGRA in 2701

3 through 2726 that talks about a tribal gaming

4 regulatory authority. There's nothing in it. The

5 only thing that happened is the NIGC created this

6 myth that you need to have an independent gaming

7 commission and you developed model gaming ordinances

8 that talked about an independent gaming commission.

9 And I will say this to you, too. If my

10 tribe decides to do away with the TGRA and the

11 business committee wants to become the tribal gaming

12 regulatory authority and they submit that to you,

13 are you going to approve it? I would say, by law,

14 you have to. Isn't that correct?

15 MS. WARD: So the question --

16 MR. HOENIG: I'm sorry. I don't think I

17 understand your question.

18 MR. YORK: I'm saying that in the law, and

19 I -- it says that the tribes, in their

20 jurisdiction -- it doesn't talk about a tribal

21 gaming. It talks about you guys, the chairman of

22 the National Indian Gaming Commission, approving a

23 tribal gaming ordinance, but it doesn't say that you

24 have to have an independent gaming commission.

25 There's nothing in the law that basically says that.

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1 That was just something that was created as the

2 interpretation of IGRA.

3 One group of gaming commissioners for the

4 National Indian Gaming Commission said we had to

5 have an independent tribal gaming regulatory person,

6 agent, and since then, that myth has been carried on

7 in the entire process. Even in this process, we're

8 talking about a tribal gaming regulatory authority,

9 but underneath the law, there's nothing that

10 signifies that whatsoever.

11 MS. WARD: Okay. Thank you. In 543.8,

12 this is a MICS for bingo, and this is a big change

13 from the discussion draft. Based on many of the

14 public comments we received, everyone wanted us to

15 combine manual bingo with gaming system bingo, and

16 the commission agrees that bingo is bingo and has

17 combined it into one section. 543.7 is now

18 reserved, so bingo starts at 543.8.

19 We believe this is less procedural than

20 the existing MICS, but it requires the TGRA and/or

21 the operation to establish controls that meet the

22 detailed criteria, and for an example of some of the

23 detailed criteria, take a look at 543.8(b)(1) that

24 discusses the bingo card inventory.

25 There is also a requirement for

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1 verification of prizes over $1,200, and the player

2 interface may serve as one verifying signature for

3 manual payouts and may serve as the sole verifying

4 signature for automatic payouts, and that was

5 corrected from the discussion draft, where it

6 appears to be an oversight. We meant to include it

7 and it didn't get done, so this proposed rule

8 corrects that and allows for the system itself to be

9 a verified signature.

10 This received a lot of comments. I'm

11 going to pause here in case anyone has any comments

12 or questions on this bingo section.

13 MR. YORK: You need to change it from

14 manual bingo to paper bingo. I don't know of any

15 manual bingo games.

16 MS. WARD: Can you repeat it again in the

17 mike? I could barely hear you up here.

18 MR. YORK: I said you need to change

19 manual bingo to paper bingo. I don't know of any

20 manual bingo games.

21 MS. WARD: Okay. I'm being told, and I'm

22 looking in the regs for confirmation, but I'm being

23 told that in the regs itself, it doesn't say manual

24 bingo, so that's something that looks like in the

25 PowerPoint I need to change, but I'm told that in

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1 the regs themselves, it does not say manual anymore.

2 Okay. So thank you for pointing that out. We'll

3 change the PowerPoint.

4 In Section 543.9, MICS for pull-tabs, we

5 have a $600 or more prize verification threshold,

6 and we've added the definition of kiosk. It's been

7 amended to clarify that it may also be capable of

8 redeeming and reconciling pull-tabs. We received a

9 comment that talked about kiosks possibly not being

10 able to dissipate the pull-tabs if they're redeeming

11 and reconciling them, and we were concerned that

12 that may limit technology if operations wanted to

13 use kiosks for this function.

14 MR. YORK: It also limits the game.

15 MS. WARD: Tom, can we get a microphone,

16 please?

17 MR. YORK: This is Steve York again. A

18 pull-tab game is basically a pull-tab game. Well,

19 the funny thing about it, without human

20 intervention, in other words, you have to have a

21 bingo game and then you have to be selling pull-tabs

22 in order to run a pull-tab game, and the pull-tab

23 game itself, if you're doing it totally automatic,

24 then it becomes not a Class II game. It becomes a

25 Class III game, even though itself, it's based on

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1 the pull-tab itself, but if you go back and read

2 originally the law set up on pull-tab underneath 25

3 CFR, you'll see that you have to have a bingo game

4 in order to have pull-tab games. It goes back to

5 the Santee Sioux tribe up in Nebraska.

6 They come in and sue the National Indian

7 Gaming Commission and say, "Hey, why don't you go

8 ahead and pull up the tabs they use in there?"

9 There wasn't nothing wrong with Lucky Tab IIs, but

10 there was the fact that the Department of Justice

11 and even the NIGC missed, and that's all they had,

12 was pull-tab games, and they had to have paper bingo

13 or an electronic bingo game in order to make it not

14 a Class III game. That's all I'm saying.

15 So if you allow everybody to cash their

16 tickets through a pull-tab game through this

17 particular deal, then you take out the prominent

18 thing of Class II. You take out the human

19 intervention that's required to have a Class II

20 game.

21 MR. HOENIG: Thanks for that comment, and

22 I'd like to point out again that at the beginning of

23 the PowerPoint, you know, all these internal

24 controls are presumed to apply just to Class II

25 games. These are not classification regulations.

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1 These don't in any way try to classify the games as

2 Class II or Class III. You're right. Class II is

3 defined in the CFR. That's where the classification

4 distinctions are going to be made, so this

5 regulation 543 is presumptive that this is a Class

6 II game. It's not going to try and classify them

7 within the regulation.

8 MS. WARD: Do we have any more questions

9 on the pull-tabs? Okay. Moving on to 543.10, the

10 MICS for card games, the TGRAs review and approve

11 cancellation and removal procedures, and this

12 proposed rule continues the standard that no

13 administrative or overhead fees may be taken from

14 player pool funds, and we did receive one comment

15 that the supervision section in the card games may

16 not provide for adequate supervision of the card

17 room, and we request additional comments on whether

18 the supervision level is effective and adequate.

19 Okay. 543.12, MICS for gaming promotions

20 and player tracking. The gaming promotion standards

21 are limited to those promotions that require game

22 play to participate. So, for example, if you have a

23 tumbler in the front entryway of your gaming

24 operation and patrons can come in and drop a card

25 with their name and contact information in this

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1 tumbler for a raffle to be held later, that's not

2 covered under gaming promotions. Gaming promotions,

3 under this proposed rule definition, must require

4 actual game play to participate. They require some

5 sort of wager, and the section also covers player

6 tracking systems because player tracking, again,

7 requires game play to track it.

8 And 543.13, the MICS for complimentary

9 services and items. The TGRA/operation is to

10 establish specific controls and procedures, and the

11 TGRA establishes the threshold for recording comps.

12 I'm going to pause here because I'm sure we have

13 some comment on the gaming promotions, player

14 tracking, and complimentary service items.

15 No? Nothing? Wow. Okay.

16 Moving right on to 543.14, the MICS for

17 patron deposit accounts and cashless systems. We

18 removed the reference to unrestricted player

19 accounts because of the Bank Secrecy Act.

20 In the MICS for lines of credit, it covers

21 the establishment of lines of credit, and the

22 commission has heard that this provision may not be

23 necessary, and we invite specific comment on why

24 folks think this provision may not be necessary.

25 We've heard in consultations that there are several

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1 tribes that are considering adding lines of credit

2 to their operation, and others currently offer it,

3 so we felt it was necessary, but again, interested

4 in comments if you feel otherwise.

5 543.17, the MICS for drop and count. It's

6 been simplified as much as drop and count can be

7 simplified, and it provides for more TGRA and

8 operation discretion.

9 The MICS for cage, vault, cash, and cash

10 equivalents and kiosks in 543.18. There is a

11 provision on the kiosks there, and that was in the

12 discussion draft. Any cage increase or decrease of

13 a hundred dollars or more must be verified,

14 documented, and recorded, and promotional payments

15 of a hundred dollars or more must be documented.

16 Those are all unchanged from the discussion draft.

17 In 543.20, the MICS for information

18 technology and IT data, most of these topics were

19 adopted from the TAC for guidance, and those include

20 Class II gaming systems and physical controls. The

21 list is up there. I'll just highlight a few,

22 physical and logical security and remote access, and

23 the rest of those on the list.

24 In this section, we also added a

25 definition of "system" in the IT section to

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1 distinguish it from Class II gaming systems within

2 the IT section only, and that's based on public

3 comment where folks were a bit confused as to what

4 kind of system we were talking about, so I hope that

5 adds some clarification, but we're interested in

6 comment on that, as well.

7 543.21, MICS for surveillance. It

8 requires cameras with sufficient clarity in the

9 count room, card tables, and cage and vault, and for

10 Class II gaming systems, the surveillance must

11 include the jackpot meter. We've revised this from

12 the discussion draft to remove the requirement of

13 surveillance of the bingo server, based on public

14 comment. Physical and logical controls that are in

15 the IT section appear to be adequate.

16 The commission invites comment on whether

17 the one-year retention period for surveillance

18 footage is appropriate. We received one comment

19 that said that's just way too long, and I wanted to

20 clarify this, as well. We received a comment in

21 Green Bay saying, "Does all surveillance footage now

22 need to be retained for one year," and no.

23 In the proposed rule, if it stays one

24 year, the proposed rule says that the suspicious

25 activity, suspected crimes, and detention by

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1 security personnel, those are events that need to be

2 retained for one year, and we're interested in

3 hearing whether that one year for those events is

4 appropriate or whether it's too long and what -- if

5 it's too long, what would an adequate period be.

6 This section also requires TGRA-approved procedures

7 for reporting suspected crimes and suspicious

8 activity.

9 543.23, the MICS for audit and accounting.

10 The annual requirements here adopt the TAC

11 recommendation, and 543.24, the MICS for revenue

12 audit, it's operated from audit and accounting, and

13 it specifies the frequency of each testing

14 procedure, and the game sections, those being the

15 Class II gaming systems, bingo -- I guess it's all

16 bingo now -- pull-tabs, and card games, those adopt

17 the TGWG guidance.

18 MR. CHRISTENSEN: I'm Bear Christensen

19 from Cherokee Nation Entertainment. Would it be

20 possible to have a better or a more precise

21 definition for suspicious activity?

22 MS. WARD: That's a good comment. Thank

23 you for your comment. Do you have any ideas about

24 what that definition would look like?

25 MR. CHRISTENSEN: Well, I mean, suspicious

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1 activity is pretty vague, and I want to make sure

2 that, you know, what we're -- what you guys are

3 regulating, you know, is very specific because we do

4 have to tell our tribal regulatory agents,

5 specifically fining license, what suspicious

6 activity or suspicious activity reports are, and so

7 if we're talking about that, we need to make sure

8 that the tribal regulatory authorities understand

9 that that's what they're defining. If not, then

10 that -- then that should be said, too, to leave it

11 up for the regulatory authorities in the tribe to

12 define, as well.

13 MR. HOENIG: I'm sorry. Can you tell me

14 again what regulation you cited to for the

15 definition of suspicious activity?

16 MR. CHRISTENSEN: Oh, the Bank Secrecy

17 Act, Title 41, because there are specific things

18 that are called suspicious activities. It's a term

19 of art that we have to follow in terms of suspicious

20 activities with particular elements that are in

21 those definitions, so if it doesn't apply to that,

22 we need to make sure that there's clarity in that

23 regulation.

24 MS. WARD: Thank you for your comment.

25 That's it. I will open the floor to any

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1 questions.

2 MR. LITTLE: Okay. There's a lot of

3 information that Jen went over, and we've had some

4 good discussion so far. Is there any other topics

5 you want to raise?

6 You know, the commission fully understands

7 that these were just published on June 1st, so I

8 know many of you may not have been able to look

9 through these thoroughly. The comment period is

10 open until July 31st. You do have plenty of time to

11 gather your thoughts and put things together, and we

12 are hoping that we will get similar really good

13 comments as we did during the discussion draft,

14 so -- we've got a question over here.

15 MS. HOMER: Thank you. Elizabeth Homer,

16 and I just wanted to briefly raise a comment, going

17 back to Part 547, which is -- you know, one of the

18 things that happened when the regulations were first

19 being developed is there was a Tribal Gaming Working

20 Group, and there was a long series of meetings

21 talking about all the various types of Class II

22 gaming systems, and I'm thinking that this

23 commission did not have the benefit of participating

24 in those discussions and reviewing that kind of

25 technology, and one of the things that it strikes me

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1 might be useful before going to final with these

2 regulations is for the NIGC to sponsor a forum that

3 allows for vendor participation.

4 You know, right now, these meetings are

5 not public and there's really not an opportunity to

6 engage with the vendors other than the

7 tribally-owned vendor, Rocket Gaming, and I think

8 that that would really help your thinking on this

9 grandfather provision and that we should not lose

10 the opportunity to capture this discussion for your

11 benefit and your edification before the regulations

12 go final, and right now, there just has not been an

13 opportunity for vendors to participate because

14 there's been no public comment, so there's been no

15 opportunity for them, and I think it will be very

16 beneficial to your thinking.

17 You know, one of the things that happens,

18 and it's easy to do, is, you know, to kind of forget

19 about the distinction between the Class II gaming

20 systems and Class III gaming technology, and they

21 really are different things. You will notice, if

22 you have an opportunity to review the various gaming

23 systems, that they really are quite different.

24 You know, one of the discussions that I

25 had earlier this morning with one of the members of

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1 the commission is that -- you know, the question

2 about whether the box locks or not. In some cases,

3 there's nothing in the box. Everything is linked to

4 the server, so having this kind of standard for the

5 boxes might not make a whole lot of sense if it's

6 just a cabinet, one in which there's a video monitor

7 on top of it, so, you know, that's another reason

8 why that language about the standards that are

9 applicable shall apply because some of these boxes,

10 they don't do the same kinds of things that you

11 would have in a Class III self-contained gaming

12 device, so I just wanted to kick that back. I think

13 that that discussion is missing, and I think it's an

14 important one before you make these final decisions.

15 MR. LITTLE: You're always helpful, Liz.

16 Thank you for your thoughts. Jess?

17 MR. GREEN: Jess Green, Miami tribal

18 employee, representative of other tribal

19 governments. One of the things I think that you may

20 be missing when you're trying to evaluate is how

21 many games are we affecting, how many games or how

22 many gaming systems in all.

23 You've had several gaming commissioners

24 point out that you don't have any idea how many of

25 our games you're about to affect if you don't do

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1 this grandfathering. The previous commission had

2 invited the manufacturers, many times over my

3 objection, to the table and knew precisely how many

4 games would be affected overall. They didn't have

5 to ask each tribe to get the numbers. They had

6 overall numbers from the manufacturers of how many

7 grandfathered systems were still out in the field.

8 I think if you were to inquire of the

9 system manufacturers of Class II games, the AGSs,

10 the Multimedias, the VGTs, those three, plus the

11 Miami Tribal Development Authority -- that's four.

12 You get those big four -- if I haven't said

13 Multimedia, Liz is saying I need to say it again.

14 But you get the big four in. I believe

15 those numbers will be rather overwhelming for you

16 because the number of grandfathered systems still

17 out there is incredible, and that's all I can say to

18 you, but the manufacturers are in a position to give

19 you their total numbers, whereas if you get them

20 from tribes individually, you're going to have

21 people wondering, "Well, do I protect myself and not

22 give them anything at all, or do I stand up and say,

23 'Yeah, I've got this many boxes that are like this

24 so it comes through the next audit?'"

25 Asking the manufacturer directly, as a

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1 part of the process, I think, will get you really

2 good answers. Thank you.

3 MS. HOMER: And I think just one other

4 comment, if you'll indulge me -- I'm sorry about

5 that -- but I did want to touch on, you know, take a

6 hard look again at the language of the regulation

7 because I can't imagine that the NIGC really intends

8 that these grandfathered systems, if they otherwise

9 meet all the standards, have to be taken off the

10 gaming floor, but that appears to be the effect of

11 the way the regulation is drafted, and, to me, that

12 can't possibly be your intent. I can't imagine that

13 these gaming systems, if they otherwise meet the

14 standards, have to be removed from the gaming floor,

15 and I think that that language, at least, appears to

16 have that effect.

17 MR. LITTLE: All right. Thank you, Liz.

18 We will definitely review that.

19 Is there any other question on Part 543 or

20 Part 547? I know we're coming up on a break here,

21 but if there's no other questions, I think we can

22 probably conclude the consultation stage.

23 MR. STEVENS: Granthum Stevens, Pawnee

24 Nation gaming commission. Basically, as a smaller

25 tribe, what we are looking at is about 300 machines.

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1 I know when the NIGC first introduced this some

2 years ago, we had Class II on our floor, and what

3 operations contemplated was shutting down 20

4 machines out of 70 machines. That was almost a good

5 quarter of our floor going out the door, so what

6 operations elected to do was basically eliminate

7 Class II altogether in the facility and went all

8 Class III, and that was one of the things that the

9 tribe had to look at in their decision-making, and

10 now we come back to it again where we're back in the

11 same position of where are we at in trying to define

12 why this regulation, the intent of the regulation,

13 and where we're going to go with the regulation.

14 Grandfathering, as you see, five years,

15 we're still in the same boat. We're asking the same

16 question two years from that point to now, and I

17 don't think we're ever going to get out of it, and

18 so the requirements in 543, when we look at it, may

19 put our operation, as a smaller operation, into some

20 noncompliance issues. I think that a lot of the

21 gaming promotions as far as, you know, player

22 tracking, a lot of that's covered in the BSA, as

23 well. Title 31 requires your player rating system

24 on your player tracking.

25 I think you're sort of mimicking that with

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1 your gaming promotions in following that criteria,

2 but mainly, some of these aspects is -- no offense,

3 but is written for a bigger casino, and right now

4 with the Pawnee Nation, we had one facility that had

5 to go Tier B, barely made it into Tier B, and under

6 the new proposals, we may have to slide back down to

7 a Tier A, but we're in that limbo right now.

8 I had a question earlier about where we're

9 tackling 543, and I had raised the question before

10 it was in 543, and in the compact, it says we're

11 under 542, so I was wondering how that would come

12 into play later on in anything else, so that was

13 basically what I have at the moment, but yes, we are

14 currently reviewing and will be submitting a written

15 comment, as well. Thank you.

16 MR. HOENIG: Just to address what you were

17 saying about 542 versus 543, this 543 is just Class

18 II games, so any reference in the compact to 542,

19 those are Class III games, which currently we're not

20 enforcing or requiring because of the Colorado River

21 Indian cases.

22 MR. LITTLE: Thank you for your comment.

23 MR. HUMMINGBIRD: Jamie Hummingbird,

24 Cherokee Nation. I just wanted to dovetail about

25 something that Liz brought out about reaching out

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1 and getting data from the various vendors out there

2 for the Oklahoma tribes. There are a number of

3 jurisdictions out there across the USA that rely on

4 Class II gaming machines just as much as we do, so

5 our brothers and sisters in Alabama and California,

6 South Dakota, wherever they may be, are going to be

7 impacted by this, as well, so it would be a good

8 idea to get, I guess, a whole listing set of numbers

9 versus just what we're going to have here in

10 Oklahoma, which, while it in itself is going to be

11 significant, it's just going to be a part of the

12 picture, and I'm not sure how many consultations the

13 NIGC is going to have between now and the end of the

14 commentary, but if you're not -- if these same

15 questions are asked of all tribes, I'm not sure, but

16 they may not be able to get their data in to you,

17 whereas if we reach out to the Class II

18 manufacturers, they could probably have those

19 figures at their fingertips, so I agree with that.

20 MR. LITTLE: Thank you, Jamie. There's

21 three additional consultations scheduled, Arizona at

22 the end of the month, and then we have California

23 and Washington state in July, so that's a good

24 point. Thanks for reminding me. A lot of these

25 questions are in the preamble, so we really urge

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1 folks to read the preamble. That provides an area

2 where we ask questions and also provides some

3 information on the logic and thinking behind the

4 decisions that we made, so thanks for reminding us.

5 Are there any other comments? Last

6 chance. Well, actually, it's not your last chance

7 because you can submit written comments, so if

8 there's no other comments, then I think we're going

9 to conclude for the day.

10 I'll remind everybody once again that the

11 comment period is open until July 31st. You raise

12 the bar very high with the very thoughtful comments

13 that you've had during the discussion comment

14 period, so we'll be expecting similar good ones.

15 Unless we've answered all the questions,

16 we've taken care of all the issues raised, so I know

17 a couple of commenters did raise the issue that

18 there were some areas that we did not address.

19 We'll look into those.

20 But other than that, I just want to thank

21 everybody for coming today. I want to thank all the

22 staff here in the room and those back in Washington

23 and other regions that help us throughout this

24 entire process. Without them, we could never do our

25 job, and I always say that one of the greatest

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1 assets that this commission inherited from previous

2 commissions is a great staff. I'm very proud of

3 them and very grateful for all the hard work they

4 do.

5 I also want to thank the members of the

6 tribal advisory committee that, you know, did a lot

7 of hard work and helped us get to where we are. We

8 may not be exactly where they want to be, but we're

9 hopefully learning and moving in a positive

10 direction for this industry.

11 I know I speak on behalf of the chair and

12 vice-chair that we definitely understand the

13 importance of a strong Class II initiative. We

14 understand that compacts are coming up for renewal.

15 We understand a lot of challenges that you-all face.

16 We want to work with you. We want to make sure that

17 the things that we do, you know, help this industry

18 maintain strong regulation. We need to do that

19 together. We need to do it through good

20 consultation, so that's what these consultations

21 provide us.

22 We definitely appreciate the comments that

23 we've heard today. We've taken notes on everything

24 that you've said. I'll bring those back to the

25 chair and vice-chair, and we'll review those, just

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1 as we review every comment that is submitted to us.

2 We do review them.

3 Sometimes I don't see Jenn and Mike for

4 days, and I'm wondering where they are just because

5 they're in their office closely reviewing all the

6 comments, so I do appreciate it and thank you all

7 for the comments submitted. I want to wish you all

8 safe travels, and have a safe trip home. Thank you.

9 (Proceedings concluded at 2:38 p.m.)

10

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

2

3 I, Jean Baysinger, Certified Shorthand

4 Reporter do hereby certify that on June 11, 2012,

5 the above and foregoing proceedings were by me taken

6 in shorthand and that the foregoing pages constitute

7 a full, true, and correct transcript of the proceedings

8 held on the date as indicated; and that I am not an

9 attorney for nor relative of any of said parties or

10 otherwise interested in the event of said action.

11 IN WITNESS WHEREOF, I have hereunto set my

12 hand and official seal this 18th day of June, 2012.

13

14

15

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17

18

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20

21

22

23

24 ________________________________

25 Jean Baysinger, CSR RPR RMR

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1

1 54:23

1,200 55:1

1,400 26:11

11 1:5 75:4

11:48 33:17

12 43:23,25

120 18:7,24 21:10

29:19,23 30:1 35:25

13 4:13,15 5:9

14 4:11

14,000 17:5

1441 1:11,14,18

15 38:9,9

16 3:25

18th 5:21 75:12

1997 36:18

1:30 32:23 33:15

1:34 33:17

1st 64:7

2

2,500 16:5,6,11

18:10

20 37:23 43:4,6,9

69:3

2000 36:24

20005 1:11,15,18

2002 47:21 52:12

2006 31:14

2007 31:14

2008 31:13

2010 41:23

2011 5:21

2012 1:5 75:4,12

202 1:12,15,19

25 57:2

2701 6:11 53:2

2704 6:21

2726 6:12 53:3

28 7:11

2:38 74:9

3

30 29:15

300 68:25

31 69:23

31st 64:10 72:11

32 13:6

35 29:15

36 4:10

39 16:18

4

4,000 16:4

40 37:22

4076 10:18

4080 10:22

41 63:17

5

542 70:11,17,18

543 2:5,20,24 3:1

4:7,9 6:20 8:11

14:11 20:22 23:6

25:8 32:19,23 33:22

36:13 41:3,5,7,16

46:17 58:5 68:19

69:18 70:9,10,17,17

543.10 58:9

543.12 58:19

543.13 59:8

543.14 59:16

543.17 60:5

543.17. 4:23

543.18. 60:10

543.20 60:17

543.21 61:7

543.23 62:9

543.24 62:11

543.3 43:14

543.4 47:14

543.5 50:11

543.7 54:17

543.8 54:11,23

543.8. 54:18

543.9 56:4

547 2:4,14,18 3:10

5:17 6:19,20 8:11

8:13,23 12:6 15:14

20:23 26:2,9 28:23

32:14 33:22,25

36:13 41:3,8 46:17

50:13 64:17 68:20

6

6,500 16:17

60 37:22 51:10,10

600 56:5

632-7003 1:12,15,19

7

70 69:4

8

82 48:21

9

90 15:18

9100 1:11,14,18

a

a.m. 33:17

ability 18:2 24:22

25:14 44:25 52:17

able 9:21 14:1 22:23

24:11 39:17 45:13

49:7 56:10 64:8

71:16

accept 4:12

acceptable 43:7,13

45:9

accepted 3:25 4:11

access 60:22

account 19:11 20:24

20:25 40:1

accountable 6:4,8

accounting 62:9,12

accounts 42:10

59:17,19

acknowledge 4:13

act 59:19 63:17

action 75:10

activities 63:18,20

activity 61:25 62:8

62:21 63:1,6,6,15

actual 35:3,10 36:1

59:4

add 11:11,11

added 42:9 56:6

60:24

adding 60:1

addition 15:23

additional 5:3 19:21

43:16 51:10 58:17

71:21

address 14:23 15:11

70:16 72:18

addresses 41:17

44:24

adds 43:5 61:5

adequate 58:16,18

61:15 62:5

adhering 8:9

administration 32:3

administrative

58:13

adopt 62:10,16

adopted 60:19

advise 37:10

advisory 21:7,18

31:25 73:6

affect 40:12 66:25

afford 17:5

afternoon 3:3 33:10

33:18,21 34:16 41:6

agencies 23:18

agency 40:22

agenda 33:21,23

agent 41:25 42:3

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agree 71:19

agrees 54:16

agss 67:9

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ain't 38:24

alabama 71:5

allow 16:9 47:17

57:15

allowed 8:13,14

allowing 20:9 26:6

allows 8:18,20 55:8

65:3

alls 9:23

allude 34:10

alphabet 6:13 53:2

alphabets 6:10,11

altered 42:23

alternate 50:12,14

50:24 51:2,7

alternative 5:5 24:9

25:18

alternatives 4:20

altogether 69:7

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amount 17:7 29:11

annual 62:10

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answer 2:11 10:15

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anymore 56:1

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appearances 1:9

appears 55:6 68:10

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applies 23:6

apply 23:14 50:12

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appreciate 3:22

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25:5,25 28:7,21

33:10 36:8 39:21,24

40:2,3,25 49:13,25

50:2 73:22 74:6

appreciates 3:19

appreciation 12:12

approach 23:15

approached 28:17

appropriate 25:18

42:2 49:10 61:18

62:4

approval 46:25 51:8

52:5

approve 8:25 51:7

53:13 58:10

approved 62:6

approving 53:22

approximately 13:6

arbitrary 16:23

21:20

area 50:7 72:1

areas 25:7,10,12,16

25:19,23 28:10

72:18

arizona 71:21

art 63:19

asked 32:2 50:9

71:15

asking 7:9,16 15:19

18:21 31:21,21 32:6

51:1 67:25 69:15

aspects 70:2

assessments 40:23

assets 73:1

assist 17:7

associated 34:20

36:2 41:17

association 20:17

attended 5:22

attorney 26:4 36:22

75:9

audience 32:15

40:21

audit 9:20 10:3 62:9

62:12,12 67:24

audits 10:3,4,5

authorities 44:19

63:8,11

authority 7:3 9:9,16

12:22 30:15 34:22

34:23 35:3 44:16

45:25 49:17,20 53:4

53:12 54:8 67:11

automatic 55:4

56:23

aware 31:24 35:6

40:2

awry 38:15

b

b 23:13 54:23 70:5,5

back 2:12 4:5 5:6

6:10 7:19,19 8:9

19:2 20:18 22:19

30:24 32:22 33:19

38:18,20 39:7 41:6

52:10 57:1,4 64:17

66:12 69:10,10 70:6

72:22 73:24

backup 17:6

bad 17:16

bank 59:19 63:16

bar 72:12

barely 55:17 70:5

based 38:10 41:18

45:2 50:25 54:13

56:25 61:2,13

basic 16:14,15 17:7

basically 25:13

31:21 52:18 53:25

56:18 68:24 69:6

70:13

basis 21:11,11

bay 61:21

baysinger 1:25 75:3

75:25

bear 44:5 62:18

beg 33:5

beginning 57:22

begins 44:2

behalf 12:7,9 15:12

26:5 29:2 73:11

beholder 49:18

believe 9:13 12:22

13:5 22:22 24:23

54:19 67:14

believes 8:4

beneficial 16:8

65:16

benefit 24:24 64:23

65:11

benefits 28:2

best 2:11 44:18

better 12:15 14:19

62:20

big 44:15 54:12

67:12,14

bigger 39:6 70:3

billing 5:1

bingo 37:21,24

48:16,20,21 54:12

54:15,15,16,16,18

54:24 55:12,14,14

55:15,19,19,20,24

56:21 57:3,12,13

61:13 62:15,16

bit 23:13 29:16 50:8

61:3

blue 25:12

board 20:11

boat 69:15

bodine 51:17

bother 6:1

box 38:21,23,24

39:1,2 42:17 66:2,3

boxes 16:11,17 17:5

18:11,12,13 37:15

39:9 42:20 66:5,9

67:23

breach 35:7

breaches 34:24

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68:20

brief 26:9

briefly 64:16

bring 17:4,7 25:5

37:22 73:24

bringing 15:25

52:10

brings 30:11

broke 2:15 17:21

33:24 34:1

brothers 71:5

brought 13:17 70:25

bsa 69:22

bucks 37:22

bull 52:21

bunch 52:21

business 16:19

53:11

busing 37:20

bussed 37:22

busy 3:3

c

c 23:13 75:1,1

cabinet 66:6

cage 60:9,12 61:9

california 36:24

71:5,22

call 33:13

called 63:18

cameras 61:8

cancellation 58:11

capable 48:19 56:7

capture 65:10

card 54:24 58:10,15

58:16,24 61:9 62:16

cards 7:8

care 11:17 72:16

careful 10:17

carried 54:6

case 52:19 55:11

cases 66:2 70:21

cash 57:15 60:9,9

cashless 59:17

casino 26:12,12 70:3

casinos 27:16 40:13

catch 40:10

category 49:1

causing 37:5

cent 48:21

centers 28:4

centric 23:16,17

certain 27:1,2 30:18

certification 21:16

certified 75:3

certify 75:4

cfr 57:3 58:3

chair 32:21 33:14

51:8,9 52:5 73:11

73:12,25,25

chairman 1:14 9:12

20:16 53:21

chairperson 8:25

chairwoman 1:17

challenges 73:15

chance 41:14 72:6,6

change 21:14 24:15

32:4 52:18 54:12

55:13,18,25 56:3

changed 42:12

50:24 52:13,17

changes 12:14 15:24

24:13,18 42:2 43:1

characteristic 24:2

charge 7:1 52:11

charged 10:20

charitable 47:15,19

47:21,25 48:6 49:6

49:15

charities 48:14

charity 49:7

cherokee 20:7 23:25

44:6 62:19 70:24

chickasaw 3:17 20:9

26:8 28:25 37:12

children 28:4

choose 17:1

chose 34:5

christensen 44:5,5

45:23 47:11 62:18

62:18,25 63:16

circuits 37:6

cited 63:14

citizens 48:17

city 1:6

civil 34:22

clarification 3:11

61:5

clarified 11:9

clarify 11:7,9,18

34:1 35:12 45:4

47:5 51:2 56:7

61:20

clarity 4:18 43:4

61:8 63:22

class 6:15,18 7:3,6,7

7:10,12,13,17 8:18

8:19 9:7,9,16,19,21

10:2,3,4,5,10 11:7

11:10,12,13,22,24

12:2 16:22 22:1,2

27:11 29:24 30:1,3

35:15 36:19,25 37:2

37:3,7,19 38:10

40:15 41:17 56:24

56:25 57:14,18,19

57:24 58:2,2,2,5

60:20 61:1,10 62:15

64:21 65:19,20

66:11 67:9 69:2,7,8

70:17,19 71:4,17

73:13

classic 16:15

classification 29:25

57:25 58:3

classify 29:25 58:1,6

clause 4:3 15:5,15

21:3,9 27:12 35:13

35:15 36:7,21 37:5

39:21

clear 4:14 6:24 11:2

22:21

clearly 43:5

close 35:21 38:13

closely 74:5

cochran 1:13,16

5:24 32:24

collecting 42:19

colorado 9:5,6 52:19

70:20

comanche 3:16,19

combine 54:15

combined 54:17

come 2:7 9:11 22:18

22:23 26:6 30:24

32:22 33:9 35:17,22

44:2 45:18 52:10,12

52:13 57:6 58:24

69:10 70:11

comes 46:10 50:22

51:9 67:24

comfortable 30:15

coming 19:25 23:20

31:16 39:4 46:7

68:20 72:21 73:14

comment 2:6 3:5,7

5:16 12:6 14:23

15:1 18:6 19:7,18

23:5 25:2 26:2

28:23 32:15 34:2,3

34:11,14 41:1,9

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65:14 68:4 70:15,22

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commentary 71:14

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commission 1:5

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6:23 8:5 19:3,10,16

20:7 27:25 31:4

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commissioners

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commissions 73:2

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73:6

common 51:24

communities 28:6

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compliant 17:19

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complimentary 59:8

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contemplated 69:3

content 6:2 52:16

context 50:18

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continues 43:4

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control 32:25 45:6

48:17

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converted 30:13

convey 5:12 12:11

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copies 6:2

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53:14 75:7

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cost 15:20 16:16

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costs 15:22

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count 60:5,6 61:9

country 6:17 7:11

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couple 20:14 24:17

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33:25 72:17

course 12:17 14:15

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court 9:4,11 39:25

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create 51:20

created 31:5,20

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credit 42:10 59:20

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creek 12:7,10 15:6

crimes 61:25 62:7

criminal 35:2

criteria 30:18 54:22

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criticisms 23:9

csr 1:25 75:25

cumbersome 24:16

cunningham 2:6

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dan 5:23 32:24

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800-227-8440 973-410-4040
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[defined - events] Page 5

Veritext/NJ Reporting Company

800-227-8440 973-410-4040
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[everybody - gaming] Page 6

Veritext/NJ Reporting Company

800-227-8440 973-410-4040
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[gaming - ii] Page 7

Veritext/NJ Reporting Company

800-227-8440 973-410-4040
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[ii - know] Page 8

Veritext/NJ Reporting Company

800-227-8440 973-410-4040
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[know - meets] Page 9

Veritext/NJ Reporting Company

800-227-8440 973-410-4040
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