§ 543.21 What are the minimum internal control standards for drop 

and count? 

 Comparison of July TGWG Submission to July 2010 Draft MICS 

Page 1 of 14 12/29/2011 

 NIGC VERSION  

In 2010, the NIGC posted on its web-site draft Class II MICS. This document will compare the 2010 draft 

MICS to the TGWG MICS proposal. 

This document does not include discussion of sections 543.21(a) – (d) (Internal Control Procedures, 

Computerized applications, Variances, and Supervision) of the TGWG Version. The provision is identical 

to others discussed in earlier comparison documents. 

2010 Draft Version TGWG Version 

§543.21 What are the minimum internal control 

standards for drop and count for Tier A gaming 

operations?  

Due to the length of the 2010 Draft Regulation (32 

pages), it is attached to this comparison document.  

§ 543.21 What are the minimum internal control 

standards for drop and count?  

Due to the length of the TGWG edits, please consult 

the TGWG working document, Appendix 1. 

(e) Count Room Access. Controls must be 

established to limit physical access to the count 

room to count team agents, designated staff, and 

other authorized persons. Such controls must 

include, but not be limited to, the following:  

(1) Count team agents shall not be allowed to exit or 

enter the count room during the count except for 

emergencies or scheduled breaks.  

(2) Surveillance shall be notified whenever count 

room agents exit or enter the count room during the 

count.  

(3) The count team policy, at a minimum, shall 

address the transportation of extraneous items (e.g., 

personal belongings, tool boxes, beverage 

containers, etc.) into or out of the count room.  

(f) Count team. Controls must be established in a 

manner designed to ensure security of the count and 

the count room to prevent unauthorized access, 

misappropriation of funds, forgery, theft, or fraud. 

Such controls must include, but not be limited to, 

the following:  

(1) For Tier A and B operations, all counts shall be 

performed by a minimum of two (2) agents. For 

Tier C operations, all counts shall be performed by a 

minimum of three (3) agents.  

(2) For Tier A and B operations, at no time during 

the count shall there be fewer than two (2) count 

team agents in the count room until the drop 

proceeds have been accepted into cage/vault 

accountability. For Tier C operations, at no time 

during the count shall there be fewer than three (3) 

count team agents in the count room until the drop 

proceeds have been accepted into cage/vault 

accountability.  

(3) For Tier A and B operations, count team agents 

shall be rotated on a routine basis such that the 

count team is not consistently the same two (2) 

agents more than four (4) days per week. This 

§ 543.21 What are the minimum internal control standards for drop 

and count? 

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standard shall not apply to gaming operations that 

utilize a count team of more than two (2) agents. 

For Tier C operations, count team agents shall be 

rotated on a routine basis such that the count team is 

not consistently the same three (3) agents more than 

four (4) days per week. This standard shall not 

apply to gaming operations that utilize a count team 

of more than three (3) agents.  

(4) Functions performed by count team agents shall 

be rotated on a routine basis.  

(5) Count team agents shall be independent of the 

department being counted and the cage/vault 

departments. An accounting agent may be used if 

there is an independent audit of all count 

documentation.  

(g) Drop. Controls must be established in a manner 

designed to ensure security of the drop process to 

prevent unauthorized access to gaming equipment 

and the drop, misappropriation of funds, forgery, 

theft, or fraud. Such controls must include, but not 

be limited to, the following:  

(1) Drop schedules and periods, including procedure 

to continue drop once started through completion.  

(2) Security during transport of drop boxes, 

including escort by a minimum of two (2) agents, at 

least one of whom is independent of the revenue 

being dropped.  

(3) All drop boxes shall be uniquely identified to 

correspond with the card table, player interface, 

and/or other location from which the drop box was 

removed.  

(4) Security over drop boxes removed and awaiting 

transport to the count room.  

(5) Security of drop boxes until the count takes 

place.  

(6) Notification to surveillance when a drop is to 

begin.  

(7) Provisions for emergency drop.  

(h) Count. Controls must be established in a manner 

designed to ensure security of the count process to 

prevent unauthorized access to count equipment and 

the drop, misappropriation of funds, improper 

manipulation of financial records, forgery, theft, or 

fraud. Such controls must include, but not be limited 

to, the following:  

(1) Establishment of a dedicated count room;  

(2) Manual count process;  

(3) Utilization, testing, and calibration of counters 

and/or validation systems;  

(4) Verification of count;  

(5) Prevention of the comingling of funds until 

recorded per drop box;  

§ 543.21 What are the minimum internal control standards for drop 

and count? 

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(6) Accurate and permanent forms of recordation 

for all cash and cash equivalents and rejected cash 

or cash equivalents;  

(7) For card game counts, additional controls, as 

applicable, shall be established and procedures 

implemented to ensure:  

(i) Fills/credits, marker issue / payment slips are 

recorded and forwarded to the appropriate 

department for verification and reconciliation.  

(ii) Opening/closing card table inventory forms are 

examined and traced to or recorded on the 

appropriate documentation with discrepancies 

investigated and results documented.  

(8) The reconciliation of count records to the total 

drop, which shall address, but not be limited to:  

(i) Signature of each agent of the count team 

attesting to their participation in the count;  

(ii) Reconciliation of the total drop by a count team 

agent who shall not function as the sole recorder; 

and  

(iii) Documentation of all unresolved variances.  

(9) Transfer of the drop following the count.  

(10) All cash and cash equivalent inventory stored 

in the count room shall be secured from 

unauthorized access at all times.  

(11) Access to stored drop boxes, full or empty.  

(i) Controlled keys or equivalents. Controls shall be 

established and procedures implemented to 

safeguard the use, access, and security of keys or 

other access methods in accordance with the 

following:  

(1) Each of the following requires a separate and 

unique key lock or alternative secure access 

method:  

(i) Drop cabinet;  

(ii) Drop box release;  

(iii) Drop box content; and  

(iv) Storage racks and carts.  

(2) Access to and return of keys or equivalents shall 

be documented with the date, time, and signature or 

other unique identifier of the agent accessing or 

returning the key(s).  

(i) For Tier A and B operations, at least two (2) drop 

team agents are required to be present to access and 

return keys. For Tier C operations, at least three (3) 

drop team agents are required to be present to 

access and return keys.  

(ii) For Tier A and B operations, at least two (2) 

count team agents are required to be present at the 

time count room and other count keys are issued for 

the count. For Tier C operations, at least three (two 

for card game drop box keys in operations with 

§ 543.21 What are the minimum internal control standards for drop 

and count? 

 Comparison of July TGWG Submission to July 2010 Draft MICS 

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three tables or fewer) count team agents are required 

to be present at the time count room and other count 

keys are issued for the count.  

(3) Where an alternative access method is utilized, 

the use of such method shall be controlled in a 

manner consistent with the objectives of this 

standard.  

(4) Documentation of all keys, including duplicates, 

shall be maintained including:  

(i) Unique identifier for each individual key: (ii) 

Key storage location;  

(iii) Number of keys made, duplicated, and 

destroyed; and  

(iv) Authorization and access.  

(5) Custody of all keys involved in the drop and 

count shall be maintained by a department 

independent of the count and drop agents and those 

departments being dropped and counted.  

(6) Other than the count team, no agent shall have 

access to the drop box content keys while in 

possession of storage rack keys and/or release keys.  

(7) Other than the count team, only agents 

authorized to remove drop boxes are allowed access 

to drop box release keys.  

(8) Utilization of keys at times other than the 

scheduled drop and count must be properly 

authorized and documented.  

(9) Emergency manual keys (i.e., override key) for 

computerized, electronic, and alternative key 

systems. 

NIGC Comments and Questions Regarding the TGWG Proposed Regulation (questions in blue) 

Supervision 

Effect of 2010 Draft Regulation: No provision in proposed MICS for supervision standards 

Effect of TGWG Proposal: TGWG amendment adds a general supervision statement. Other TGWG 

proposed standards include the term “agent”, which appears can be a non-employee of the gaming 

operation. As such licensing and back grounding requirements have not been specified which could result 

in gaming machine vendor or other personnel with supervisory authority over Tribal assets. Should this be 

clarified to limit the ability of non-employees to have any supervisory authority over Tribal assets? 

Card Game Drop Standards 

Effect of 2010 Draft Regulation: The draft regulation is intended to provide control procedures over the 

performance of the card game drop. The controls are intended to uphold the integrity of the drop process, as 

well as ensure that gaming revenue is attributed to the appropriate game/table/shift, thereby ensuring the 

accuracy of statistical reports that are utilized by management. Also, the draft regulation requires the 

creation of a record of which tables were open or closed during a particular shift. Without this record, it 

§ 543.21 What are the minimum internal control standards for drop 

and count? 

 Comparison of July TGWG Submission to July 2010 Draft MICS 

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would not be possible to confirm that all gaming tables with activity were dropped and the revenue 

accurately recognized for the appropriate shift/day.  

Effect of TGWG Proposal: The proposed modification is not consistent with the draft 543.21 standards. The 

proposed addition of 543.21 (g) (Drop) is overly broad and does not contain details specific to the Card 

Game Drop standards in the draft 543.21 (b), such as the restriction on who is permitted to remove drop 

boxes from tables; the requirement of a separate drop box on each table opened during each shift or a single 

drop box with separate openings/compartments for each shift; the requirement that the card game 

department shall document which tables were open during the shift if drop boxes are not placed on all 

tables; and all drop boxes being posted with a number corresponding to a permanent number on the gaming 

table and marked to indicate game, table number, and shift.  

Soft Count Room and Count Team 

Effect of 2010 Draft Regulation: The draft provision is intended to provide controls for the staffing of the 

soft count team and authorized entries to the soft count room.  

Effect of TGWG Proposal: The proposed deletion of 543.21 (c) (1)-(4) is replaced by the addition of the 

proposed 543.21(e)(1)-(3) and is mostly consistent with the draft  543.21(c)(1)-(4). However, this proposed 

addition does not contain the allowance of a dealer or cage cashier to participate on the count team if this 

person is not allowed to perform the recording function. Also, the TGWG proposal does not contain an 

equivalent standard to 543.21(c)(5), which it proposes for deletion. The draft standard 543.21(c)(5) 

recognizes that a gaming operation may store coin, tokens, chips and cash in the count room; however, if 

such inventories are located in the count room, the rule stipulates that they must be secured from 

unauthorized access, thereby protecting tribal assets from misappropriation.  

Card Game Soft Count 

Effect of 2010 Draft Regulation: The draft regulation is intended to protect the accuracy, integrity and 

accountability of the card game soft count process. The draft is intended to ensure the security of gaming 

operation funds by reducing the opportunities for the misappropriation of casino funds. The security of 

funds is also enhanced by verifying the amount of funds turned over to the cage or vault cashier for transfer 

to the vault.  

Effect of TGWG Proposal: The proposed deletions are not consistent with 543.21(d), as the TGWG 

proposed standards do not include equivalent standards to 543.21(d)(3), (4)(ii)-(iv), (5)-(8), (11)-(13). 

Financial Instrument Storage 

Effect of 2010 Draft Regulation: The draft regulation is intended to ensure the integrity of the drop process, 

and ensure the security of gaming operation funds. 

Effect of TGWG Proposal: The proposed deletion of 543.21(e)(1)-(3) is not consistent with 543.21. The 

proposed additions of 543.21(g) (Drop) are overly broad and do not contain details specific to the player 

interface financial instrument storage component drop standards in 543.21(e) such as the minimum number 

of individuals required to be involved in the drop, and the restriction on who is permitted to remove storage 

components.  

Accuracy, integrity and accountability of the count process 

Effect of 2010 Draft Regulation:  The draft regulation is intended to ensure the accuracy, integrity and 

accountability of the count process, specifically for the player interface financial storage components.  

§ 543.21 What are the minimum internal control standards for drop 

and count? 

 Comparison of July TGWG Submission to July 2010 Draft MICS 

Page 6 of 14 12/29/2011 

 NIGC VERSION  

Effect of TGWG Proposal: There are a number of proposed deletions in this subsection which are not 

consistent with 543.21(f). The TGWG proposal does not contain equivalent standards to 543.21(f)(4), (5) 

(i)-(ii), (7)-(10), (13)-(16).  

• 543.21(f)(4) – The prohibition on count team members having access to gaming machine meter 

data prior to completion of the count is intended to prevent the use of incorrect meter data that 

results from overages, leading to possible misappropriation of gaming operation funds without an 

audit trail.  

• 543.21(f)(5) – This standard is intended to ensure the accuracy of currency drop figures by 

reducing the possibility of human error or the unauthorized access to the currency counter 

interface.  

• 543.21(f)(7)-(10) – These standards are in place to ensure the accuracy, integrity and 

accountability of the count process. In doing so, the security of gaming operation funds is 

enhanced.  

• 543.21(f)(13)-(15) – These standards are intended to ensure the integrity and accuracy of the count 

process and, especially, the transfer of accountability of casino funds.  

• 543.21(f)(16) – This standard is intended to mitigate the opportunities for tampering with financial 

instrument storage components, leading to the compromise of gaming machines and the 

misappropriation of casino funds.  

• In addition, 543.21(f)(11), proposed for deletion, is partially replaced by the proposed addition of 

543.21 (g)(8)(ii), (iii). However, this proposed addition does not include a statement that the 

standard does not apply to vouchers removed from the financial instrument storage components.  

Transfers of Currency and Coin During the Count 

Effect of 2010 Draft Regulation: The draft provision is intended to mitigate the added risk involved with 

transferring currency out of the count room prior to completion of the count and the verification by the 

cage/vault.  

Effect of TGWG Proposal: The TGWG 543.21 proposal does not contain standards equivalent to 543.21 

(k). With no standards to regulate this potential event, a gaming operation may be vulnerable to the 

misappropriation of count proceeds without an audit trail.  

Key Controls 

Effect of 2010 Draft Regulation: The draft provision is intended to provide general controls over the 

sensitive keys involved in the drop and count processes.  

Effect of TGWG Proposal: The proposed 543.21 does not contain equivalent standards to 543.21(i)(1)-(3). 

Specifically, the proposed 543.21 does not include a requirement that kiosk keys be separately keyed or 

that all duplicate keys be maintained in a manner that provides the same degree of control as is required for 

the original keys.  

Card game drop box key control standards 

Effect of 2010 Draft Regulation: The draft provision is intended to provide controls over the access to the 

sensitive keys involved in the drop and count processes, specifically the card game drop box keys.  

Effect of TGWG Proposal: The proposed deletion of 543.21(n)(2), (3) is inconsistent with 543.21. The 

TGWG proposal contains the addition of 543.21(h)(11) which calls for the establishment of controls for the 

access to stored drop boxes, full or empty, but provides no specific guidance for gaming operations 

regarding these controls, as included in the standards proposed for deletion. In addition, the TGWG 

§ 543.21 What are the minimum internal control standards for drop 

and count? 

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proposal does not include an equivalent standard to 543.21(n)(1), which allows for the possible exemption 

of Tier A gaming operations from compliance with the standard.    

Card game drop box release keys 

Effect of 2010 Draft Regulation: The draft provision is intended to provide controls over the maintenance 

of and access to the sensitive keys involved in the drop and count processes, specifically the card game 

drop box release keys.  

Effect of TGWG Proposal: The proposed deletion of 543.21(o)(1), (3), (5) is inconsistent with 543.21. The 

TGWG proposal contains the addition of 543.21(i)(6), which allows for the count team to have access to 

drop box release keys but does not include the restriction of that access to during the soft count, as stated in 

543.21(o)(3). Also, the proposed addition of 543.21(h)(7) requires the documentation of key access at times 

other than the scheduled drop and count but does not detail the required information to be documented 

(date, time and signature of the individual signing out/in the key) as noted in 543.21(o)(5). In addition, the 

TGWG proposal does not include an equivalent standard to 543.21(o)(1), which allows for the possible 

exemption of Tier A gaming operations from compliance with the standard.     

Financial instrument storage component release keys 

Effect of 2010 Draft Regulation: The draft provision is intended to provide controls over the maintenance 

of and access to the sensitive keys involved in the drop and count processes, specifically the financial 

instrument storage component release keys.  

Effect of TGWG Proposal: The proposed deletion of 543.21(p)(1), (3), (5) is inconsistent with 543.21. The 

TGWG proposal contains the addition of 543.21(i)(6), which allows for the count team to have access to 

drop box release keys but the proposed 543.21 (p)(3) does not contain any such permission. Also, the 

proposed addition of 543.21 (i)(8) requires the documentation of key access at times other than the 

scheduled drop and count but does not detail the required information to be documented (date, time and 

signature of the individual signing out/in the key) as noted in 543.21 (p)(5). In addition, the TGWG 

proposal does not include an equivalent standard to 543.21(p)(1), which allows for the possible exemption 

of Tier A gaming operations from compliance with the standard.     

Card game drop box contents keys 

Effect of 2010 Draft Regulation: The draft provision is intended to provide controls over the issuance of 

and access to the sensitive keys involved in the drop and count processes, specifically the card game drop 

box contents keys.  

Effect of TGWG Proposal: The TGWG proposal contains no equivalent standards to the above standards 

proposed for deletion. Unauthorized access to the contents key could facilitate the theft of casino funds. 

What was the rational for not including this provision in TGWG proposal? 

Financial instrument storage component contents keys 

Effect of 2010 Draft Regulation: The draft provision is intended to provide controls over the issuance of 

and access to the sensitive keys involved in the drop and count processes, specifically the card game drop 

box contents keys.  

Effect of TGWG Proposal: The TGWG proposal contains no equivalent standards to the above standards 

proposed for deletion. As the unauthorized access to the contents key could facilitate the theft of casino 

funds, the inclusion of equivalent standards is warranted and recommended.  

§ 543.21 What are the minimum internal control standards for drop 

and count? 

 Comparison of July TGWG Submission to July 2010 Draft MICS 

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Player interface computerized key security systems 

Effect of 2010 Draft Regulation: The draft provision is intended to provide controls over the maintenance, 

access, and security of the player interface drop and count keys maintained within a computerized key 

security system.  

Effect of TGWG Proposal: The TGWG proposal contains no specific procedures or controls for the 

utilization of a computerized key security system. Considering the widespread use of computerized key 

systems in the gaming industry, the inclusion of equivalent standards should be considered an absolute 

necessity. With no established standards in place, employees are enabled to misuse sensitive keys, leading 

to the compromise of the drop and count process. What was the rational for not including this provision in 

TGWG proposal? 

Card games computerized key security systems 

Effect of 2010 Draft Regulation: The draft provision is intended to provide controls over the maintenance, 

access, and security of the card game drop and count keys maintained within a computerized key security 

system.  

Effect of TGWG Proposal: The TGWG proposal contains no specific procedures or controls for the 

utilization of a computerized key security system. Considering the widespread use of computerized key 

systems in the gaming industry, the inclusion of equivalent standards should be considered an absolute 

necessity and is recommended. With no established standards in place, employees are enabled to misuse 

sensitive keys, leading to the compromise of the drop and count process. What was the rational for not 

including this provision in TGWG proposal?       

Emergency drop procedures 

Effect of 2010 Draft Regulation: The draft provision is intended to require the establishment of emergency 

drop procedures.  

Effect of TGWG Proposal: The proposed addition of 543.21 (g) (7) is consistent with the intent of the draft  

543.21(w), although it does not contain the option for the emergency drop procedures to be developed by 

either the Tribal gaming regulatory authority (TGRA) or the gaming operation, as approved by the TGRA.  

TGWG Guidance 

(e) Risk Assessments. Risk assessments and periodic program reviews may be used to determine how often 

drop and count functions should be audited. When an assessment and review is necessary, an agent 

independent of the organizational component responsible for conducting drop and count functions should 

perform it.  

NIGC Comment to TGWG Guidance 

Guidance is unnecessarily vague. It does not suggest or recommend that the risk assessments be performed 

by the internal auditors who are generally in the position to perform such assessments/reviews and who 

would generally be the individuals performing the audits. The language “independent of the organizational 

component responsible for conducting the audited operations should perform it” is complex and 

ambiguous. 

TGWG Guidance 

§ 543.21 What are the minimum internal control standards for drop 

and count? 

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(g) Count Team. Controls should be established in a manner designed to ensure security of the count and 

the count room to prevent unauthorized access, misappropriation of funds, forgery, theft, or fraud. Such 

controls must include, but not be limited to, the following:  

(1) Based on the gaming operation’s Tier, counts must be performed by a count team that consists of at 

least the minimum number of agents required by the MICS.  

(2) The minimum number of count team agents must be present at all times during the count until all drop 

proceeds are transferred to the cage/vault accountability.  

(3) Controls must include procedures to ensure that if the count team consists of the minimum number of 

agents required by the MICS, that the agents are sufficiently rotated to prevent the same count team from 

working together more than four (4) days a week to mitigate against the potential for collusive fraud or 

theft.  

(4) Controls must require that count team agents rotate functions performed during the count on a routine 

basis. An example is the count agent who removed drop box content yesterday will be counting today and 

another count agent will conduct the removal.  

(5) The count team must be independent of transactions being counted as well as independent of the 

cage/vault departments. An accounting representative may be used if there is an independent audit of all 

count documentation.  

NIGC Comment to TGWG Guidance 

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

543.21(g) does not require the establishment controls for count team. Section (g)(1) states that the count 

team must consist of the minimum number of agents required by the MICS but fails to state where this 

information is located. Sections (g)(2) and (g)(3) mention the “minimum number of agents” with no further 

information. 

TGWG Guidance 

(h) Drop. Controls must be established for the drop process and be designed in a manner to identify and 

prevent misappropriation of funds, forgery, theft, and/or fraud during the drop. Such controls should 

include, but not be limited to:  

(1) Procedures to ensure that the drop process continues through completion once started.  

(2) Notification to surveillance when a drop process is to begin, including emergency drops. Best practice 

suggests that surveillance is notified no later than when the first drop box is dropped.  

NIGC Comment to TGWG Guidance 

Best practice is that surveillance should be notified when the drop keys are being checked out of the cage or 

other secure location where they are kept. 

TGWG Guidance 

(3) Best practice suggests that the TGRA should be notified of established and any changes to the drop 

schedule.  

(4) Security of empty drop boxes transported to the floor, drop boxes dropped and drop boxes awaiting 

transport to the count room, including escorts as required by the MICS. Best practice suggests that at least 

one (1) escort is a Security agent and that these controls also cover emergency drops. The presence of an 

independent agent helps prevent possible collusion.  

(5) Security of drop boxes awaiting count and emergency drop boxes.  

§ 543.21 What are the minimum internal control standards for drop 

and count? 

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NIGC Comment/Question to TGWG Guidance 

The term “drop box” is generally applicable to table games or card games but not gaming devices. Could 

this be clarified in through guidance documents? 

TGWG Guidance 

(6) Controls must ensure that drop agent(s) are independent of the department being dropped.  

NIGC Comment to TGWG Guidance 

The use of the phrase “drop agent(s)” suggest that is permissible to use only one drop agent as long as the 

agent is independent of the department being dropped. Would the guidance would be clearer if stated, 

“Controls must ensure that at least one of the drop agents is independent of the department being dropped?” 

TGWG Guidance 

(i) A system in which all drop boxes are uniquely identified to correspond with the card table, player 

interface, and/or other location from which the drop box was removed. This will prevent possible 

commingling of funds and ensure proper recording of the drop. An example is labeling each drop box with 

a number corresponding to a permanent number on the player interface or card game table. Generally, card 

game drop boxes are also labeled to indicate game, table number, and shift.  

NIGC Comment to TGWG Guidance 

“Generally, card game drop boxes are also labeled to indicate game, table number, and shift” appears to be 

an observation rather than a recommendation.  

TGWG Guidance 

(i) Count. Controls must be established for the Count process including, but not limited to:  

(1) Designation of a count room or other secure area with identical controls.  

(2) Controls to cover all aspects of count and equipment used, including manual counts.  

(3) Procedures to prevent the commingling of funds from different revenue centers during the emptying and 

counting of drop box until the content of each drop box is recorded.  

(4) Count equipment and systems should be tested, with the results documented, at minimum before the 

first count begins to ensure the accuracy of the equipment. Such procedures may include but not be limited 

to:  

(i) At least two (2) count agents should verify the test results.   

(ii) The test should be performed with test currency and coin (in all denominations), vouchers, and other 

financial instruments to verify that the equipment is functioning properly.  

(iii) If currency counters are utilized, at least one count agent who is not loading or unloading the currency 

counter should observe the loading and unloading of all currency at the currency counter, including rejected 

currency.  

(iv) If currency counters are utilized, controls should be established to ensure all rejected cash or cash 

equivalents are counted and recorded to the drop box for which it was being counted.  

(v) If the currency counter does not automatically count the currency twice, then it should be run through 

the counter a second time.  

NIGC Question 

How could the guidance documents be clarified to make sure the reader understands that the currency 

§ 543.21 What are the minimum internal control standards for drop 

and count? 

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counter should make two independent/separate counts? 

TGWG Guidance 

(vi) For counts that do not utilize a currency counter, a count agent who did not perform the initial count 

should perform a second count.  

(vii) If a currency counter interface is used, it should be adequately restricted (e.g., password, keys, etc.) to 

prevent unauthorized access.  

(5) The test results must be delivered to the accounting department.  

(6) The count team must not have access to bill-in meter amounts for the count being performed. This does 

not prohibit count team members from performing tasks that involve access to bill-in meter amounts when 

such members are not performing a count for those metered values.  

NIGC Question 

Why would the count team have need of the bill-in meter amounts? Would it be clearer if the second 

sentence of (i)(6) was struck? 

TGWG Guidance 

(7) Access to stored drop boxes, full or empty, is restricted to authorized agents.  

(8) Coin, cash, and cash equivalents must be controlled in a manner that precludes the commingling with 

the count from another revenue area. Best practice suggests that when the count for a revenue area is 

complete it is transferred to the cage/vault prior to another count being started.   

(9) The minimum number of count agents, per Tier as defined in the MICS, shall be present throughout the 

bundling, strapping, or sacking of the drop proceeds. Tiers A and B require a minimum of two (2) count 

agents at all times. Tier C requires a minimum of three (3) count agents at all times.  

(10) Requirements for permanent forms of recordation.  

(i) Procedures to correct information originally recorded by count team agents on count documentation 

should be established, including but not be limited to, the following.  

(A) All corrections should be made with a permanent ink pen;  

(B) A single line should be drawn through the error;  

(C) The correct figure should be entered above the original figure;   

(D) The correction should be initialed by at least two (2) count team agents verifying the change;  

(E) If a currency interface is used, corrections to count data may be made using one of the following:  

(1) During the count process, correct the error in the currency interface and enter the authorization (e.g., 

passwords, key, etc.) of at least two (2) count team agents.   

(2) An exception report should be generated identifying the drop box identifier, the incorrect value, the 

correct value, and the identity of count team agents attesting to the correction.  

(F) All documentation and records for corrections must be forwarded to the accounting department.  

NIGC Question 

Would it be clearer if the guidance included who must forward information, and how, to accounting, or 

“best practice?”  

TGWG Guidance 

(11) Verification that each drop box is emptied during the count. Two (2) agents must participate in the 

verification process. A surveillance agent may serve as one of these two (2) agents if verification is 

monitored in its entirety with good clarity by surveillance cameras. A person independent of the agent who 

removed the contents from the drop box may also serve as one of the two (2) required agents to verify the 

§ 543.21 What are the minimum internal control standards for drop 

and count? 

 Comparison of July TGWG Submission to July 2010 Draft MICS 

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drop box is empty.  

(12) Count results must be recorded for each drop box.  

(13) For card game counts, additional controls, as applicable, shall be established and  

procedures implemented to ensure the security and delivery of any card table fills/credits, marker 

issues/payments, opening/closing inventory forms to accounting. Some gaming operations record these 

forms in the count room and then forward to accounting while others may only forward these forms to 

accounting for recording. In either situation the forms must be controlled, secured and forwarded to 

accounting.  

NIGC Comment to TGWG Guidance 

Would it be clearer if the guidance included who must forward information, and how, to accounting, or 

“best practice?”  

TGWG Guidance 

(i) The count documentation and records must not be transferred to the cage/vault with the drop proceeds.  

(ii) The cage/vault agent should have no knowledge or record of the drop proceeds total before it is 

verified. Best practice suggests that the agent  

should perform what is known as a “blind count.”   

(iii) All count records should be forwarded to accounting. Alternatively, it may be adequately secured (e.g., 

locked container to which only accounting agents can gain access).  

NIGC Comment to TGWG Guidance 

Would it be clearer if the cage/vault retained one copy of the count record showing the amount verified? 

TGWG Guidance 

(19) The cage/vault agent receiving the transferred drop proceeds must sign the report attesting to the 

verification of the total received.  

(20) Controls should be established to require all verification, recount, and signatory requirements for 

partial transfers in accordance with the same controls that are applicable to the transfer of the total drop 

proceeds. To prevent commingling of funds, best practice suggests that partial transfers should be properly 

segregated from any funds still being counted.  

(21) Any unresolved variances between total drop proceeds recorded on the count room report and the 

cage/vault final verification during transfer must be documented and investigated.  

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

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

accounting for audit.  

NIGC Comment/Questions to TGWG Guidance 

Best practice is for documents to be delivered immediately upon completion of the count and verification 

of drop, to accounting by the count team or for the “count team” to secure in a locked box to which only 

accounting has the key. Should this be included in the guidance? 

TGWG Guidance 

(i)(j) Controlled Keys or Equivalent.  

(1) All drop and count keys must be secured and controlled by agents independent of the operational areas 

or departments for which the keys provide access, including the following:  

§ 543.21 What are the minimum internal control standards for drop 

and count? 

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(i) Player interfaces for any Class II game;  

(ii) Card games;  

(iii) Kiosks;  

(iv) Drop;  

(v) Count; and  

(vi) Cage/vault.  

(2) Each of the following requires a separate and unique key lock or alternative secure access method:  

(i) Drop cabinet;   

(ii) Drop box release;    

(iii) Drop box content; and    

(iv) Storage racks and carts.  

(3) All controlled drop and count keys or equivalents must be secured in a manner designed to prevent 

unauthorized access.  

(i) Controls must prohibit any one agent from having simultaneous access to the cabinet, release, content, 

and storage racks keys. The count team agents may have access to release, content, and storage racks keys 

only during a count.  

(4) All key or equivalent issuances and returns, including emergency manual/override keys, must be 

performed by the minimum number of agents in accordance with the MICS, be documented and maintained 

by a key control agent including, but not be limited to:  

(i) Date issued/returned;  

(ii) Time issued/returned;  

(iii) Unique identifier for the key issued/returned;  

(iv) Name of the agent the key was issued to/returned by; and  

(v) Reason for access to the key (if a key watch system is not in use and/or emergency key access is made 

the reason should be recorded).  

(5) Emergency manual keys (a.k.a. override keys) for computerized, electronic, and/or alternative key 

systems must be secured and controlled. Best practice suggests that at least three (3) agents, two (2) from 

independent departments, be involved in the issuance and return of the emergency manual/override keys.  

(6) When controls require physical involvement of more than one agent in the key control process, 

including for the entire duration of drop and count, surveillance may not act as one of those agents. If 

physically present, security agents may act as part of the minimum number of agents required by the MICS.  

(7) All duplicate keys should be maintained in a manner that provides the same degree of control as is 

required for the original keys.  

(8) Documentation of all keys, including duplicates and emergency manual/override keys, shall be 

maintained by a key control agent including, but not be limited to:  

(i) Unique identifier for each individual key;  

(ii) Key storage location;  

(iii) Number of keys made, duplicated, and destroyed;   

(iv) Issuance and return; and  

(v) Authorization and access.  

(9) An agent independent of the drop, count, cage/vault, and key control must audit key access records 

periodically, in accordance with Part 543.19, and for propriety.  

NIGC Comment to TGWG Guidance 

An unannounced inventory of all keys, including duplicates, should be performed periodically; at least 

twice per year. Should this be included in the guidance? 

TGWG Guidance 

 (i) Audit and Accounting.  

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

§ 543.21 What are the minimum internal control standards for drop 

and count? 

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

document.  

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

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

accounting for audit.  

NIGC Comment to TGWG Guidance 

Best practice is for documents to be delivered immediately to accounting by the count team upon 

completion of the count and verification of drop. Or, alternatively, for the “count team” to secure in a 

locked box to which only accounting has the key. Should this be included in the guidance?