, . NATIONAL . , INDIAN 

4 i GAMING COMMISSION 

Herb Glazier 

Chairman 

Bridgeport Indian Colony 

P.O. Box 37 

Bridgeport, CA 93517 

Dear Chairman Glazier: 

This letter responds to your request to review and approve 

the tribal gaming ordinance, Ordinance No. 95-02, adopted on 

August 8, 1995, by the Bridgeport Indian Colony (Tribe). This 

letter constitutes such approval under the Indian ~aming 

Regulatory Act (IGRA). 

Under the IGRA and the regulations of the National Indian 

Gaming Commission (NIGC), the Chairman is directed to review 

ordinances with respect to the requirements of the IGRA and the 

implementing regulations. Thus, the scope of the chairman's 

review and approval is limited to the requirements of the IGRA 

and the NIGC regulations. Provisions other than those required 

under the IGRA or the NIGC regulations that may be included in a 

tribal ordinance are not subject to review and approval. Also, 

such approval does not constitute approval of specific games. It 

is important to note that the gaming ordinance is approved for 

gaming only on Indian lands as defined in the IGRA. 

With the Chairman's approval of the Tribe's gaming 

ordinance, the Tribe is now required to conduct background 

investigations on its key employees and primary management 

officials. The NIGC expects to receive a completed application 

for each key employee and primary management official pursuant to 

25 C.F.R. § 556.5(a) and an investigative report on each 

background investigation before issuing a license to a key 

employeeNor primary management official pursuant to 25 C.F.R. 

§ 556.5(b). 

,Thank you for submitting the ordinance of the Bridgeport 

India? Colony for review and approval. The NIGC staff and I look 

forward to working with you and the Tribe in implementing the 

IGRA. 

Sincerely yours, 

chairman 

-. -- -~ ..-- . _ -- _ - _ _--- 1441 L STREET, N.W. .~ 9TH . .-. FLOOR ..- ~.. WASHINGTPN. DzC. 20005 7EL: ~. 202-632-7003 . - -.- -~ FAX: 202-632-7066 ~ . 
I P.O.BOX 37 

BRIDGEPORT. CALFORNl4 63517 

RESOLUTION 95-15 

SUBJECT: RESOLUTION APPROVJNG TRIBAL CLASS I1 GAMLNG 

ORDINANCE 

WHEREAS: the Bridgeport Indian Colony is a federally recognized Indian Tribe 

(hereinafter) "the tribe"); and 

WREREAS: the General Council is the Tribe's governing body; and 

WHEREAS: the Tribe is engaged in various forms of Class I1 gaming on the 

~eservation and is presently negotiating a Class III tribal-state compact 

dth the State of Califomia; and 

WHEREAS: the National Indian Gaming Commission has now promulgated 

regulations, which contain explicit requirements concerning gaming 

employees licensing, background checks, and related matters; and 

WHEREAS: the Tribe wishes to ensure that its Class II gaming operations comply 

wjth these new regulations; and 

WHEREAS: the Tribe believes that the new regulations will hrther enhance the 

Tribe's capability to ensure that its Class I1 gaming operations are 

managed honestly and efficiently; and 

WBEREAS: the Tribe wishes to designate the State of California to carry out 

criminal history checks on key employees and primary management 

officials; and 

WHEREAS: the Tribe wishes to designate its counsel, Howard Dickstein, as its agent 

for service of process for official communications fiom the National 

Indian Gaming Commission; 

NOW THEREFORE BE IT RESOLVED that the General council hereby enacts the 

Tribal Class I1 Gaming ordinance attached hereto, and authorizes its Chairman, Herb 

Glazier, to execute the ordinance and submit said ordinance with all accompanying 

documents required to the National Indian Gaming Commission for review and approval. 
CERTIFICATION 

The foregoing resolution was adopted by a vote of JUor, and Qagabst and 4 

abstentions, at a duly called meeting of the General Council, at which a quorum was 

present, on this &$,- day of August , 1995, 

.\A 

Herb Glazier, ~ha"mn 
ORDINANCE NO. 95-02 

TRIBAL CLASS I1 GAMING ORDINANCE 

The General Council of the Bridgeport Indian Colony 

(hereinafter "TribeM) , empowered by the Tribe's Constitution to 

enact ordinances, hereby enacts this ordinance in order to set the 

terms for Class I1 gaming activities on tribal lands. 

11. Gaminu Authorized 

All forms of Class I1 gaming as defined in the Indian Gaming 

Regulatory Act, P.L. 100-447, 25 U.S.C. Section 2703 (7) (A) ("IGRAI1) 

are hereby authorized, including but not limited to bingo, 

pulltabs, and non-banking card games. 

111. Ownership of Gaminq 

The Tribe shall maintain the sole propriety interest in and 

responsibility for the conduct of all Class I1 gaming activities 

authorized by this ordinance. 

IV. Use of Gamins Revenue 

A. Net revenues from the Tribe's share of Class I1 gaming 

activities authorized herein shall be used only for the following 

purposes: to fund tribal government operations and programs; 

provide for general welfare of the Tribe and its members; promote 

tribal economic development; donate to charitable organizations; or 

help fund operations of local government agencies. 

B. If the Tribe elects to make per capita payments, it shall 

authorize such payments only upon approval of a plan submitted to 

the Secretary of Interior under § 2710(b) (3) of IGRA. 

V. Audit 

An annual independent audit of all gaming activities, 

including all contracts for supplies, services or concessions in 

excess of $25,000.00 annually, except contracts for professional 

legal and accounting services, shall be conducted and provided to 

the National Indian Gaming Commission (hereinafter "Commission") 

annually. 
VI. Environmental Protection 

The construction, maintenance and operation of Class I1 gaming 

facilities and Class I1 games shall be conducted in a manner which 

adequately protects the environment and the public health and 

safety. 

VII. Licenses for Key Em~loyees and Primary Manauement Officials 

The Tribe shall ensure that the policies and procedures set 

out in this section are implemented with respect to key employees 

and primary management officials employed at any Class I1 gaming 

enterprise operated on tribal lands: 

Definitions 

For the purposes of this section, the following 

definitions apply: 

1. Key employee. 

(a) A person who performs one or more of the 

following functions: 

(1) Bingo caller; 

(2) Counting room supervisor; 

(3) Chief of security; 

(4) Custodian of gaming supplies or cash; 

(5) Floor manager; 

(6) Pitboss; 

(7) Dealer; 

(8) Croupier; 

Approver credit; or 

(10 ) Custodian of gambling devices including 

persons with access to cash and accounting records 

within such devices; 

(b) If not otherwise included, any other person 

whose total cash compensation is in excess of $50,000 per 

year; or 

(c) If not otherwise included, the four most highly 

compensated persons in the gaming operation. 
Primary Manasement Official. 

(a) The person having management responsibility for 

a management contract; 

(b) Any person who has authority: 

(1) To hire and fire employees; or 

(2) To set up working policy for the gaming 

operation; or 

(c) The chief financial officer or other person who 

has financial management responsibility. 

B. Amlication Forms 

1. he following notice shall be placed on the 

applicationform for a key employee or a primary management 

official before that form is filled out by an applicant: 

In compliance with the Privacy Act of 1974, the 

following information is provided: Solicitation of 

the information on this form is authorized by 25 

U.S.C. 2701 et seq. The purpose of the requested 

information is to determine the eligibility of 

individuals to be employed in a gaming operation. 

The information will be used by National Indian 

Gaming Commission members and staff who have need 

for the information in the performance of their 

official duties. The information may be disclosed 

to appropriate Federal, Tribal, State, local, or 

foreign law enforcement and regulatory agencies 

when relevant to civil, criminal or regulatory 

investigations or prosecutions or when pursuant to 

a requirement by a tribe or the National Indian 

Gaming Commission in connection with the hiring or 

firing of an employee, the issuance or revocation 

of a gaming license, or investigations of 

activities while associated with a tribe or a 

gaming operation. Failure to consent to the 

disclosures indicated in this notice will result in 

a tribe's being unable to hire you in a primary 

management official or key employee position. 

The disclosure of your Social Security Number (SSN) 

is voluntary. However, failure to supply a SSN may 

result in errors in processing your application. 

2. Existing key employees and primary management 

officials shall be notified in writing that they shall either: 
a. Complete a new application form that contains a 

Privacy Act notice; or 

b. SPgn a statement that contains the Privacy Act 

notice and consent to the routine uses described in 

that notice. 

3. The following notice shall be placed on the 

application form for a key employee or a primary management 

official before that form is filled out by an applicant: 

A false statement on any part of your application 

may be grounds for not hiring you, or for firing 

you after you begin work. Also, you may be 

punished by fine or imprisonment. (U.S. Code, 

title 18, section 1001.) 

4. The Tribe shall notify in writing existing key 

employees and primary management officials that they shall 

either: 

a. Complete a new application form that contains a 

notice regarding false statements; or 

b. Sign a statement that contains the notice regarding 

false statements. 

C. Backaround Investisations 

1. The Tribe shall request from each primary management 

official and from each key employee all of the following 

information: 

a. ~u11 name, other names used (oral or written), 

social security number (s) , birth date, place of 

birth, citizenship, gender, all languages (spoken 

or written) ; 

b. Currently and for the previous 5 years: business 

and employment positions held, ownership interests 

in those businesses, business and residence 

addresses, and drivers license numbers; 

c. The names and current addresses of at least three 

personal references, including one personal 

reference who was acquainted with the applicant 

during each period of residence listed under 

paragraph (i) (b) of this section; 

d. Current business and residence telephone numbers; 

e. A description of any existing and previous business 

relationships with Indian tribes, including 

ownership interests in those businesses; 
f. A description of any existing and previous business 

relationships with the gaming industry generally, 

including ownership interests in those businesses; 

g. The name andaddress of anylicensingor regulatory 

agency with which the person has filed an 

application for a license or permit related to 

gaming, whether or not such license or permit was 

granted; 

h. For each felony for which there is an ongoing 

prosecution or a conviction, the charge, the name 

and address of the court involved, and the date and 

disposition if any; 

i. For each misdemeanor conviction or ongoing 

misdemeanor prosecution (excluding minor traffic 

violations) within 10 years of the date of the 

application, the name and address of the court 

involved and the date and disposition; 

j . For each criminal charge (excluding minor traffic 

charges), whether or not there is a conviction, if 

such criminal charge is within 10 years of the date 

of the application and is not otherwise listed 

pursuant to paragraphs (i) (h) and (i) (i) of this 

section, the criminal charge, the name and address 

of the court involved and the date and disposition; 

k. The name and address of any licensing or regulatory 

agency with which the person has filed an 

application for an occupational license or permit, 

whether or not such license or permit was granted; 

A photograph; 

m. Any other information a tribe deems relevant; and 

n. Fingerprints consistent with procedures adopted by 

a tribe according to 25 C.F.R. § 522.2(h). 

2. The Tribe shall conduct an investigation sufficient 

to make a determination under subsection (c) below. In 

conducting a background investigation, the Tribe shall promise 

to keep confidential the identity of each person interviewed 

in the course of the investigation. 

D. Elisibilitv Determination 

1. The Tribal Council review a person's prior 

activities, criminal record, if any, and reputation, habits 

and associations to make a finding concerning the eligibility 

of a key employee or a primary management official for 
employment in a gaming operation. If the Tribal Council 

determines that employment of the person poses a threat to the 

public interest or to the effective regulation of gaming, or 

creates or enhances dangers of unsuitable, unfair, or illegal 

practices and methods and activities in the conduct of gaming, 

a tribal gaming operation shall not employ that person in a 

key employee or primary management official position. 

2. The Tribe's gaming operation shall not employ in a 

key employee or primary management official position a person 

who has supplied materially false or misleading information 

with respect to the required information for that person's 

background investigation under subsection B above. 

E. Procedures for Forwardins Awwlications and Reworts for 

Key Emwlovees and Primary Manasement Officials to the Commission 

1. When a key employee or primary management official 

begins work, the Tribe shall forward to the Commission a 

completed application for employment and conduct the 

background investigation and determination referred to in 

subsections A, B, C and D of this section. 

2. Upon completion, the Tribe shall forward the report 

referred to in subsection F of this section to the Commission 

within 60 days after an employee begins work or within 60 days 

of the Chairman's approval of this ordinance. 

3. The gaming operation shall not employ a key employee 

or primary management official who does not have a license 

after 90 days. 

F. Rewortto Commission 

1. pursuant to the procedures set out in subsection E 

of this section, the Tribe shall prepare and forward to the 

Commission an investigative report on each background 

investigation. An investigative report shall include all of 

the following: 

a. Steps taken in conducting a background 

investigation; 

b. Results obtained; 

c. Conclusions reached; and 

d. The bases for those conclusions. 

e. The Tribe shall include in its report a copy of the 

eligibility determination made under section D of this 

section. 
2. I£ a license is not issued to an applicant: 

a. p he Tribe shall notify the Commission; and 

b. Forward copies of its eligibility determination and 

investigative report (if any) to the Commission for 

inclusion in the Indian Gaming Individuals Records 

System. 

3. The Tribe shall retain applications for employment 

and reports (if any) of background investigations for 

inspection by the Chairman of the Commission or his or her 

designee for no less than three (3) years from the date of 

termination of employment. 

G. Grantins a Gamins License 

1. If, within a thirty (30) day period after the 

Commission receives a report, the Commission notifies the 

Tribe that it has no objection to the issuance of a license 

pursuant toa license application filed by a key employee or 

a primary management official for whom the tribe has provided 

an application and investigative report to the Commission, the 

Tribe may go forward and issue a license to such applicant. 

2. If, within the thirty (30) day period described 

above, the Commission provides the Tribe with a statement 

itemizing objections to the issuance of a license to a key 

employee or to a primary management official for whom the 

Tribe has provided an application and investigative report to 

the Commission, the Tribe shall reconsider the application, 

taking into account the objections itemized by the Commission. 

The Tribe shall make the final decision whether to issue a 

license to such applicant. 

3. The thirty (30) day period described in this section 

may be suspended by the Commission after the Commission makes 

an investigative report if the Chairman requests additional 

information from the Tribe, until the Chairman receives the 

information. The Tribe shall respond to any request from the 

Chairman of the Commission for such additional information. 

H. License Suswension 

1. If, after the issuance of a gaming license, the 

Commission receives reliable information indicating that a key 

employee or a primary management official is not eligible for 

employment under subsection C above, the Commission shall 

notify the Tribe that issued a gaming license. 

2. Upon receipt of such notification under paragraph 

(1) above, the Tribe shall suspend such license and shall 
notify in writing the licensee of the suspension and the 

proposed revocation. 

3. The Tribe shall notify the licensee of a time and a 

place for ahearing on the proposed revocation of a license. 

4. After a revocation hearing, the Tribe shall decide 

to revoke or to reinstate a gaming license. The Tribe shall 

notify the Commission of its decision. 

VIII.Customer Dispute Resolution Procedure 

The general manager of the tribal gaming operation shall 

attempt to resolve on an informal basis any customer complaints 

relating to payment of prizes or services and report any such 

resolution to the governing body of the enterprise. If the 

complaint cannot be resolved at the general manager level, the 

customer shall be informed that he/she has the right to present his 

or her complaint to the governing body of the gaming enterprise, 

whose decision shall be final. 

IX. IGRA Comwliance 

The Tribe shall ensure enforcement of rules and regulations 

for all games played to ensure that they conform to the Indian 

Gaming Regulatory Act and that the games are honest and fair. 

X. License Locations 

The Tribe shall issue a separate license to each place, 

facility or location on tribal lands where Class I1 gaming is 

conducted under this ordinance. 

XI. Repeal 

All prior gaming ordinances are hereby repealed. 

CERTIFICATION 

The foregoing resolution was adopted by a vote of 12 for, and 

o against and o abstentions, at a duly called meeting of the 

General Council, at which a quorum was present, on this 8th day of 

Auaust , 1995. 

en 

Herb Glazier, a~hairman 
1 BRIDGEPORT INDIAN COLONY 

PROCEDURES FOR BACKGROUND INVESTIGATIONS 

OF KEY EMPLOYEES AND PRIMARY MANAGEMENT OFFICIALS 

OF TRIBAL GAMING FACILITY 

1. Res~onsibilitv for the Investisations. The Bridgeport 

Indian Colony (hereinafter "the Tribe") , through the Tribe's 

governing body, the Tribal Council, shall be responsible for 

ensuring that background investigations and suitability 

determinations are conducted concerning all key employees and 

primary management officials, as defined in section 7 (a) of the 

Tribe's Class I1 Gaming Ordinance, of its tribal gaming facility, 

as required by 25 C.F.R. section 522.2(b). 

2. Conduct of the Backqround Investisations. The Tribal 

Council shall retain responsibility for conducting background 

investigations. 

3. Procedures for the Backqround Investiqations. In order 

to provide a basis for the Tribe to make a finding concerning the 

eligibility for employment in a gaming operation, said background 

investigations shall include: 

a. Verification by written or oral communication of the 

information submitted by the applicant; 

b. An inquiry into the applicant's prior activities, 

criminal record, if any, and reputation, habits and associations; 

c. Interviews with a sufficient number of people such 

as former employers, personal references, and others with 

sufficient knowledge of said applicant; 
d. Documentation setting forth the disposition of all 

potential problem areas and disqualifying information which is 

obtained; 

e. The obtaining and processing of fingerprints from 

each applicant. The Tribe designates the State of California 

Department of Justice to obtain said fingerprinting and the 

National Indian Gaming Commission to process said fingerprint cards 

through the Federal Bureau of Investigation. 

4. Reworts Resardins the Backsround Investisations. Reports 

regarding all background investigations shall be reviewed and 

approved by the Tribal Council, selected by the Tribe's General 

Council. Said reports shall set forth the following: 

a. The steps taken in conducting the background 

investigations; 

b. The results obtained; 

c. The conclusions reached; and 

d. The bases for those conclusions. 

5. Submission of Reports to Commission. The Tribe's 

governing body, the Tribal Council, shall be responsible for 

submitting the reports referred to above to the National Indian 

Gaming Commission.