Chairwoman LaRue Parker 

Caddo Nation of Oklahoma 

P.O. Box 487 

Binger, OK 73009 

RE: Amendments to the Caddo Nation Gaming Ordinance 

Dear Chairwoman Parker: 

This letter is in response to your request for the National Indian Gaming 

Commission (NIGC) to review and approve amendments to the Caddo Nation of 

Oklahoma's revised Gaming Ordinance, submitted on May 16,2006. The Caddo 

Nation Council approved the Ordinance by Resolution # 05-2006-03 on May 16, 

2006. This letter constitutes approval of your submission under the Indian 

Gaming Regulatory Act (IGRA). It is important to note that the Gaming 

Ordinance is approved for gaming only on Indian lands, as defined in the IGRA, 

over which the Tribe has jurisdiction. 

/---I 

the ordinance for review and approval. The NIGC staff 

with you and the Nation on future gaming issues. 

Chairman 

NATIONAL HEADQUARTERS 1441 L St. NW, Suite 9100. Washington. DC 20005 Tel: 202.632.7003 Fax: 202.632.7066 WVVW.NIGC.GOV 

REGIONAL OFFICES Portland, OR. %cramento. CA; Phoenix. AZ; St Paul. MN; Tulsa. OK 
$a ffon 

0 

Post Office Box 487 6' Binaer. Oklahoma 73009 

(405) 656-2344 405-656-2345 

FAX # 4051656-2892 

Resolution #p 5 . 2606 -0 3 

Resolution of the Caddo Nation of Oklahoma to 

adopt a new Caddo Nation Gaming Ordinance 

Whereas: the Caddo Nation of Oklahoma is a federally recognized tribe, governed 

by a Constitution pursuant to the Oklahoma Indian Welfare Act of 1936, 

(49 Stat. 1967); and 

Whereas: under the revised Caddo Nation Constitution and Bylaws adopted by the 

Caddo Nation of Oklahoma on June 26, 1976, and recognized by the 

Secretary of the Interior, the Tribal Council of the Caddo Nation has 

certain powers; and 

Whereas: under Article V, Section 2 part "F of the Caddo Nation Constitution, the 

Tribal Council is empowered to establish procedures for the conduct of all 

tribal government and business operation; and 

Whereas: under Article V, Section 2, part "M?' of the Caddo Nation Constitution the 

Tribal Council is empowered to pass such ordinances and resolutions 

necessary or incidental to the exercise of any of the foregoing powers and 

duties; arld 

Whereas: the Caddo Tribal Council finds the new Gaming Ordinance is up to date 

and in line with the current National Indian Gaming Commission (NIGC) 

model gaming ordinance. 

Whereas: the Caddo Tribal Council hereby revokes all prior gaming ordinances and 

hereby approves and submits the attached ordinance for expedited review 

and approval under NIGC rules and regulations. 

Therefore be it resolved: the Caddo Nation Tribal Council hereby passes a new Gaming 

Ordinance to be forwarded to the NIGC for Approval on this 16~ day of 

May 2006, and hereby revokes all previous ordinances and submits the 

attached Caddo Nation Gaming Ordinance for expedited review and 

approval. 
Resolution # 0 5 - 3 0 C1 d C1 3 

CERTIFICATION 

We certitjl that the Caddo Nation Council with a quorum being present at a meeting duly 

called and convened on the 16~ dayof May 2006 at the Caddo Nation Tribal Office, 

Binger, Oklahoma has duly adopted this resolution by vote of 5 FOR, 

() OPPOSING and i) ABSTAINTNG. 

~if&e aft in' Parker, Chairman Date 

J./6 6 

Date 

Caddo Nation of Okluho~na Gm~llg Ordinance 

Purpose 

Dellnitions 

Ganling Authotlzed 

Ownership of Gaming 

Use of Gaming Revenue 

Per Capita Payments 

Gartling Commission 

Ethics 

Complimentary Items 

Audit 

Environment and Public IIenlth and Safety 

Dispute Resolution 

Tribal Internal Control Standards 

Facility Licenses 

Agent for Service of Process 

Compliance with Federal Law 

Repeal 

Ttlbal Access to Futancial Information 

License for Key E~nployees and I'rimary 

Management O~cials 

License Application Forms 

License Fees 

Fingerprints 

Background Investigations 

Procedures for Conducting a Background Check on 

AppUcmts 

Eligibility Detennhmtioa 

Procedures for Forwarding Applications and Reports 

For Key Employees and Primary Management OIBcials 

Repol* to the NIGC 

Granting a Gaming License 

License Suspension 

Board of Review for Disputes 

Licenses for Vendors 

Subnlission of a Vendor License Application 

Contents of the Vendor License Application 

Vendor Background Investigations 
305. Vendor License Fee 

306. Vendor Backgrour~d h~vestig rtiun R.e lport 

307. Ememption for Vendor Licelnse by 111 I ogt&~:d 

Regulatory Autl~orities 

308. License for Non-Ganllng Ver~dors 
Section 101. Purpose 

The Caddo Nation of Oklahoma (Tribe), empowered by the Wto enact ordinances, hereby enacts this ordinance in order to govern Class II gaming 

operations on the Tribe's Indian lands. 

Section 102. Definitions 

Unless a different meaning is clearly indicated in this Ordinance, the terms used herein shall have the same meaning as defined in the lndian Gaming Regulatory Act (IGRA), 25 

U.S.C. § 2701 et seq., and its regulations, 25 C.F.R. § 500 et seq. Specifically: 

(a) Class I gaming means social games solely for prizes of minimal value or traditional forms of Indian gaming engaged in by individuals as a part of, or in connection with, 

tribal ceremonies or celebrations. 

p6 U.S.C. f 2703p); 26 C.F.R. f 602.21 

(b) Class II gaming means: 

(1) the game of chance commonly known as bingo (whether or not electronic, 

computer, or other technologic aids are used in connection therewith): 

(A) which is played for prizes, including monetary prizes, with cards 

bearing numbers or other designations, 

('3) in which the holder of the card covers such numbers or designations 

when objects, similarly numbered or designated, are drawn or electronically determined, and 

(c) in which the game is won by the fht person covering a previously 

designated arrangement of numbers or designations on such cards, including (if played in the same location) pulltabs, lotto, punch boards, tip jars, instant bingo, and other games similar to 

bingo, and 

(2) card games that: 

(A) are explicitly authorized by tile laws of the State, or 

(B) are not explicitly prohibited by the laws ofthe State and are played 

at any location in the State, but only is such card games are played in conformity with those laws and regulations (if any) of the State regarding hours or periods of operation of such card 

games or limitations on wagers or pot sizes in such card games. 

(3) The term "class I1 gaming" does not include: 

(A) any banking card games. including baccarat, chemin de fa, or 

Blackjack (2 1 ), or 

(B) electronic or electromechanical facsimiles of any game of chance or 

slot n~achines of any kind. 

[25 U.S.C. 5 2703U); 26 C.F.R. f 602.31 

(c) Class Ill gaming means all forms of gaming that are not class I gaming or class II gaming. 
I26 U.S.C. § 2703(8); 26 C.F.R. 5 602.41 

(d) Commission means the Tribal Gaming Commission established to perform regulatory oversight and to monitor compliance with Tribal, Federal, and applicable State 

regulations. 

(e) Commissioner means a Tribal Gaming Commissioner. 

(f) Compact means a Tribal-State Compact concerning class Ill gaming approved by the Secretary of the Interior and published in the Federal Register pursuant to 25 U.S.C. § 

271 O(d). 

(g) Complimentary shall have the meaning as set forth in 25 C.F.R. §542.2(a). 

(h Directly related to means a spouse, child, parent, grandparent, grandchild, aunt, uncle, or first cousin. 

(k) Indian lands means: 

(1) all lands within the limits of the Tribe's reservation; 

(2) any lands title to which is either held in trust by the United States for the 

benefit of the Tribe or individual or held by the Tribe or individual subject to restriction by the United States against alienation and over which the Indian Tribe 

exercises governmental power; and 

(3) for all lands acquired into hst for the benefit of an Indian tribe aAer October 

17, 1988, the lands meet the requirements set forth in 25 U.S.C. 5 2719. 

126 U.S.C. 5 2703(4);26 U.S.C. 5 2719; 26 C.F.R. § 602.121 

(I) Tribe means the Caddo Nation of Oklahoma. Tribe is consistent with Caddo Nation Tribal Council unless otherwise directed in the Caddo Nation Constitution. 

(rn) Key ~rnployee~ means: 

(I) A person who performs one or more of the following functions: 

(A) Bingo caller; 

(B) Counting room supervisor 

(c) Chief of security; 

(Dl Custodian of gaming supplies or cash; 

(E) Floor manager; 

(F) Pit boss; 

(G) Dealer; 

(H) Croupier; 

(1) Approver of credit, or 
(0 Custodian of gambling devices including persons with access to 

cash and accounting records within such devices; 

(2) If not otherwise included, any other person whose total cash compensation 

is in excess of $50,000 per year, or 

(3) If not otherwise included, the four most highly compensated persons in the 

gaming operation. 

[26 C.F.R. 0 602.14)] 

(n) Net Revenues means gross gaming revenues of an Indian gaming operation less 

(1) Anlounts paid out as, or paid for, prizes; and 

(2) Total gaming-related operating expenses, excluding management fees. 

[26 U.S.C. g 2703(9); 26 C.F.R. g 60216] 

(0) Prlmary Management omcialU means 

(1) The person (s) having management responsibility for a management contract; 

(2) Any person who has authority: 

(A) To hire and fire employees, or 

(B) To set up working policy for the gaming operation; or 

(C) The chief fmancial officer or other person who has fmancial 

management responsibility. 

Section 103. Gaming Authorized 

(a) Class II and Class Ill gaming are hereby authorized. 

[26 C.F.R. 5 622.6@)-(c)] 

Section 104. Ownership of Gaming 

nle Tribe shall have the sole proprietary interest in and responsibility for the conduct of any 

gaming operation authorized by this ordinance. 

[26 U.S.C. 2710(b)(2)(A); 26 C.F.R. 5 6224(b)(l)] 
Section 105. Use of Gaming ~evenue' 

(a) Net revenues 6om tribal gaming shall be used only for the following purposes: 

(1) to hnd tribal government operations and programs; 

(2) to provide for the general welfare of the Tribe and its members, 

(3) to promote tribal economic development; 

(4) to donate to charitable organizations; or 

(5) to help fund operations of local government agencies. 

126 U.S.C. g 2710(b)(2)(8); 26 C.F.R. 5 6224(b)(2)] 

Section 106. Per Capita Payments 

(a) "Per Capita Payment" means the distribution of money or other thing of value to all 

Members of the Tribe, or to identified groups of members, which is paid directly fhm the net revenues of any tribal gaming activity. 

@) If the Tribe elects to make per capita payments to tribal members from revenues 

derived 6om its gaming operations, it shall ensure that the following requirements of 25 C.F.R. Part 290 are met: 

(1) The Tribe shall authorize and issue such payments only in accordance with a 

Revenue allocation plan submitted to and approved by the Secretary of the Interior under 25 U.S.C. 5 2710@)(3). 

[26 U.S.C. 5 2710@)(3); 26 C.F.R. 5 622.4(b)(2)(11)] 

(2) The Tribe shall ensure that the interests of minors and other legally incompetent 

persons who are entitled to receive any per capita payments under a Tribal per capita payment plan are protected and preserved, and that the per capita payments 

are disbursed to the parents or legal guardian of such minors or legal incompetents in such amounts as may be necessary for the health, education, or welfare or 

the minor or other legally incompetent person, under a plan approved by the Caddo Nation Tribal Council and the Secretary of the Interior. The Tribe must also 

establish criteria and a process for witl~drawal of funds by the parent or legal guardian. 

[26 C.F.R. Q 290.12(b)(3)] 
(3) The Caddo Nation Tribal Cou~rcil shall designate or create a Tribal couri system, 

forum, or administrative process for resolution of disputes concerning the allocation of net gaming revenues and the distribution of per capita payments and will explain 

how it will correct deficiencies. 

(4) The Caddo Nation Tribal Council shall ensure that the Tribal revenue allocation plan 

reserves an adequate portion of net gaming revenues from the tribal gaming activity to do one or more of the following purposes: fund Tribal government operations or 

programs to provide for the general welfare of the Tribe or its members, promote tribal economic development; donate to charitable organizations; or to help fhd 

operations of local government. 

(5) The Caddo Nation Tribal Council shall ensure that distributions of per capita 

Payments are made according to specific eligibility requirements. 

[26 C.F.R. 290.12(3)(iIi), (b)(b)] 

(6) The Caddo Nation Tribal Council shall ensure that Tribal members are notified of the 

tax liability for per capita payments and how taxes with be withheld 

[26 C.F. R. 5 290.12@)(4); 26 C.F. R. Part 3 11 

Section 107. Gaming omm mission^ 

(a) The Tribe hereby establishes a Tribal Gaming Commission whose duty it is to regulate tribal gaming operations. The Tribal Gaming Commission shall consist of three 

members. There shall be among them a Chairperson, Vice-Chairperson, and one additional Commissioner. 

(b) The purpose of the Tribal Gaming Commission is regulatory, not managerial. The Commission will conduct oversight to ensure compliance with Tribal, Federal, and, if 

applicable, State laws and regulations. The Commission will serve as the licensing authority for individuals employed in the gaming operation and will administer background 

investigations as part of the licensing process. The Commission will also have a role in monitoring compliance with the internal controls for the gaming operation and in tracking 

revenues. In order to carry out its regulatory duties, the Commission shall have unrestricted access to all areas of the gaming operation and to all records. The Commission shall 

have authority to take enforcement actions, including suspension or revocation of an individual gaming license when appropriate. 

(c) The Tribe recognizes the importance of an independent Tribal Gaming Commission in maintaining a well-regulated gaming operation. The Commission shall be and act 

independently and autonomously from the Tribal Council in all matters within its purview. No prior or subsequent review by the Tribal Council of any actions of the Commission shall 

be required or permitted except as otherwise explicitly provided in this Ordinance. To avoid potential conflicts of interest between the operation and regulation of the gaming facility, 

the Tribe hereby finds that, at a minimum: 

(1) No member of the Tribal Council may serve on the Gaming Commission 

(2) No member directly related to or living with any Tribal Council member 
may serve 011 the Gmnit~g Cotmnission. 

(3) Me~nbers of the Gaming Cot~unissiot~ are prohibited from gan~blir~g in the 

facility; and 

(4) Metnbers of the Gan~itlg Comn~ission are prohibited from acceptit~g 

cotnplinlentary items fron~ the gaming operation, excepting food and beverages 

valued at under five dollars. 

(d) Tribal Gaming Commissioner positions shall be filled in the following manner: 

Through appointment by the Caddo Nation Tribal Council. 

(e) Nominees for positions of Tribal Gaming Commissioner must satisfy the suitability standards set forth for key employees and primary management offi~:ials, found in 

Section 207 of this Ordinance. Such background investigations shall be performed under the direction of the Gaming Commission by either a designated employee of the gaming 

commission or an outside independent investigative firm. 

(f) The Tribal Gaming Commission shall: 

(1) Cot~duct or cause background i~~vestigations to be cot~ducted on, at a 

minin~un~, primary n~anagemei~t officials and key employees; 

(2) Review and approve all investigative work conducted; 

(3) Report results of background investigations to the NIGC; 

(4) Obtain and process fingerprints; 

(5) Make licetlsit~g suitability detenninatio~ls, wluch shall be signed by 

The Chainnat~ of the Giuning Cotnmission, 

(6) Issue gami~g licenses to managenlent officials and en~ployees of the 

opera ti or^ cotlsistent with the suitability detenninatiot~; 

(7) Establish standards for licensing Tribal gaming operations; 

(8) Issue facility gaming licenses to Tribal gaming operatio~ls; 

(9) Inspect, examine and tnonitor all gaming activities. and have itiunediate 

access to review, inspect. exaniie, photocopy and audit all records of tl~e gaming 
(10) Ensure compliance with all Tribal, State, and Federal laws, rules, and 

regulations regarding Indian gaming; 

(1 1) Investigate any suspicion of wrongdoing associated with any gaming 

activities; 

(12) Hold hearings on patron complaints, in compliance with procedures 

established in the ganling ordinance and other Tribal gaming regulations; 

(13) Comply with any and all reporting requirements under the IGRA, TribalState compact to which the Tribe is a party, and any other applicable law; 

(14) Promulgate and issue regulations necessary to comply with applicable 

internal control standards; 

(15) Promulgate and issue regulations on the levying of fees and/or taxes 

associated with gaming license applications; 

(16) Promulgate and issue regulation. on the levying of fines andlor suspension or 

revocation of gaming licenses for violations of the gaming ordinance, or any other Tribal, Federal, or State, ifapplicable, gaming regulations; and 

(17) Establish a list of persons not allowed to game in Tribal gaming facilities in 

order to maintain the integrity of the gaming; 

(18) Establish a list of persons who have voluntarily asked to be excluded fiom 

Tribal gaming facility and create regulations for enforcing this exc~usion;~ 

(19) Provide referrals and information to the appropriate law enforcement officials 

when such information indicates a violation of Tribal, Federal, or State statutes, ordinances, or resolutions; 

(20) Create a list of regulatory authorities that conduct vendor background 

investigations and licensing which the Commission recognizes as trustworthy, 

(2 1) DraR regulations exempting vendors hm the licensing andlor background 

investigation requirements ifthey have received a license kom a recognized regulatory authority; 

(22) Perform such other duties the Commission deenls appropriate for the proper 
regulation of the Tribal gaming operation. 

(23) Promulgate sucl~ regulations and guidelines as it deems appropriate to 

implement the provisions of this Ordinance. 

(g) The Gaming Commission shail ensure that all records and information obtained as a result of an employee background investigation shall remain confidential and shall 

not be disclosed to persons who are not directly involved in the licensing and employment processes. Information obtained during the course of an employee background investigation 

shall be disclosed to members of management, human resource personnel or others employed by the tribal gaming operation on a need-to-know basis for actions taken in their official 

capacities. 

This Section does not apply to requests for such information or records from any Tribal, Federal or State law enforcement or regulatory agency, or for the use of such information 

or records by the Commission and staff in the performance of their officiai duties. 

(h) Terms of Office for Tribal Gaming Commissioners shall be as follows: the Chair shall serve an initial term of one year, with subsequent Chairs serving three-year terms. 

The Vice-Chair and Commissioner(s) shall serve an initial term of hvo years, with subsequent Vice-Chairs and Commissioners serving three-year terms. 

(i) The following persons are not eligible to serve as Tribal Gaming Commissioners: Tribal Council members, while serving as such; employees of the gaming operation, 

while serving as such; gaming contractors (including any principal of a management or other contracting company); persons directly related to or sharing a residence with any of the 

above; persons ineligible to be key employees or primary management officials. Non-tribal members previously convicted of a felony, of embezzlement, of theft, or of any other moneyrelated crime or honesty-related crime (such as fraud) cannot serve as Tribal Gaming Commissioners. Tribal members previously mnvicted of a felony, of embezzlement, of theft, or of 

any other money-related crime or honesty-related crime (such as fraud) will only be allowed to serve as Tribal Gaming Commissioners if the Caddo Nation Tribal Council specifically 

finds a significant amount of time has passed and that the person Is now of trustworthy character. The Tribal Council shall require a criminal history check with appropriate law 

enforcement agencies and shail review this criminal history report and make an appropriate suitability determination before appointing an individual to a position as a Tribal 

Gaming Commissioner. 

(j) The independence of the Tribal Gaming Commission is essential to a well-regulated gaming operation. For that reason, Commissioners may only be removed from office 

by the Caddo Nation Tribal Council prior to the expiration of their respective terms for neglect of duty, misconduct, malfeasance, or other acts that would render a commissioner 

unqualified for hislher position. Any allegations of neglect of duty, misconduct, malfeasance, or other acts that would render him or her unqualified for hisher position must be 

substantiated by a preponderance of the evidence. Commissioners will be given an opportunity to provide evidence rebutting the grounds for their proposed removal before the 

removal is considered. A vote of the Caddo Nation Tribal Council on the validity of the removal shall be final and not subject to further appeal. A wrongful removal shall entitle the 

affected Commissioner to compensation for expenses incurred in an appeal and any pay withheld. 

(k) A majonty of the Commission shall constitute a quorum. The concurrence of a majority of the members appointed to the Commission shali be required for any final 

determination by the Commission. The Commission may act in its officiai capacity even if there are vacancies on the Commission. 

(I) Tribal Gaming Commissioners shall be compensated at a level determined by the Tribal Council. Commissioner compensation shall not be based on a percentage of 

gaming revenue to ensure the Commission is not improperly influenced. 

(m) The Commission shail keep a written record of all its meetings 

Section 108. Ethicsw 

(a) The Tribe recognizes that the duties of the Tribal Gaming Commission include making important decisions on highly sensitive issues. As such, the Tribe has determined 

that the Gaming Commission shall be held to extremely high ethical standards. Prior to taking their positions on the Commission (Members), the Members shall agree to be bound by 

the following principles: 

(1) Members shall not hold fmancial interests that conflict with the conscientious 

performance of their duties as managers and regulators.u 

Section 109. Complimentary lternsUU 

(a) The use of complimentary items shall be governed by regulations established by the Tribal Gaming Commission 

(b) No Key Employee, Primary Management Official, Tribal Council member, member of the Tribal Gaming Commission, or any person directly related to or sharing a 

residence with the persons, shall be authorized to receive complimentary items other than food and beverages valued at under five dollars, or, if at a public event held at the gaming 

facility, the free food and beverages offered to the general public. 

(c) Complimentary Items shall be included in the annual budget for the gaming operation, with maximum limits specified, and shall be subject to approval by the Tribal 

Council. 

Section 110. Audit 

(a) The Tribe shall cause an annual outside independent audit of gaming operations to be conducted, and shall submit the resulting audit reports to the National Indian 

Gaming Commission. 

126 U.S.C. f 2710(b)p)(C); 26 C.F.R. $6224(b)IJ)] 

(b) All gaming related contracts that result in the purchase of supplies, services, or concessions in excess of $25,000.00 annually, except contracts for professional legal 

and accounting services, shall be specifically included within the scope of the audit that is described in subsection (a) above. 

[26 U.S.C. f 2710(b)p)gJ); 26 C.F.R. f 622.4(b)(4)] 

Section 111. Environment and Public Health and Safety 

(a) Gaming facilities shall be constructed, maintained and operated in a manner that adequately protects the environment and the public health and safety. 

[26 U.S.C. f 2710(b)12)(E); 25 C.F.R. f 522.4@)(7)] 

(b) The Caddo Nation Tribal Council shall adopt standards that assure adequate protection of the environment and the public health and ~afety.~ 

Section 112. Patron Dispute ~esolution~ 

Patrons who have complaints against the gaming establishment shall have as their sole remedy the right to file a petition for relief with the Tribal Gaming Commission. 

Complaints shall be submitted in writing, and at the discretion of the Commission, the petitioner may be allowed to present evidence. The Gaming Commission shall hold a hearing 

within 30 days of receipt of petitioner's complaint. Petitioner may have counsel present at such hearing. The Commission shall render a decision in a timely fashion and all such 

decisions will be final when issued. Any patron complaint must be submitted to the Commission within thirty (30) days of the incident giving rise to the complaint. All claims by patrons 

shall be limited to a maximum recovery of $10,000.00 per occurrence, and a cumulative limit of $50.000.00 per patron in any twelve (12) month period, except disputes relating to a 

patron's entitlement to a game prize, which shall be limited to the amount of such prize. The Commission's decision shall constitute the complainant's final remedy. 

Section 113. Tribal Internal Control Standards 

The Tribe shall adopt and implement Internal Control Standards (ICS) for the operation of its Tribal gaming operation in accordance with applicable law. The Tribe's ICS shall 

be set out in separate regulations to be reviewed and approved by the Tribal Council. 
Section 114. Facility ~lcenses~ 

(a) The Tribal Gaming Commission shall issue a separate license to each place, facildy, or location on Indian lands where class II gaming is conducted under 

this ordinance. 

126 U.S.C. 5 2710(b)(I)(B); 26 C.F.R. 5 622yb)(6)] 

(b) The Tribal Gaming Commission shall issue a separate license to each place, facility, or location on lndian lands where Class I1 and Class Ill gaming is conducted under 

this ordinance once every three years." The Tribal Gaming Commission shall specify the form, conditions and content for the application for such licenses, which shall be submitted 

by the chief management official of the facility, and the initial application shall include a legal description of the lands whereon the facility is located, and a certifcation that said 

premises constitute "lndian lands" as specified in the lndian Gaming Regulatory Act, and shall identify the environmental, health, and public safety standards with which the facility 

must comply, and a certification that the facility is in compliance therewith. Each subsequent application for the renewal of such facility license shall identify any changes or additions to 

said legal description and applicable environmental, health and safety standards, and include current certifications of compliance therewith. The Tribal Gaming Commission shall only 

issue such licenses if the applications therefore Include the required information and certifications and such further conditions as the Tribal Gaming Commission shall have specified. 

Section 115. Agent for Service of Process 

The Tribe hereby designates the Chairman of the Tribal Council as agent for service of process, who may be contacted at: 

Hwy 281 and 152, P.O. Box 487 Binger, Oklahoma 73009 

[26 C.F. R. 5 61@.1] 

Section 116. Compliance with Federal ~a* 

The Tribe will comply with all applicable federal law, including the Bank Secrecy Act, 31 U.S.C. § 531 1 et seq. 

Section 117. ~epeal~ 

To the extent that they are inconsistent with this ordinance, all prior gaming ordinances are hereby repealed. 

Section 118. Tribal Access to Financial lnfotmationw 

A copy of the Tribal gaming operation annual audit will be made available for review, upon request, to: 

Caddo Nation Council of Oklahoma 

Section 201. Licenses for Key Employees and Primary Management Officials 

The Tribe shall ensure that the policies and procedures set out in this section are implemented with respect to kev emplovees and primaw manaaement officials em~loved at 

any gaming enterprise operated on lndian lands. The ~ribe will issue licenses and perform background investigations according to requiremenis at least asstringent as 25 c.F.R:P~~~s 

556 and 558. 

126 U.S.C. 5 2710(b)@"(F); 26 C.F.R. 5 658.3; 26 U.S.C. 5 6224(b)(6)] 

Section 202. License Application Forms 

(a) The following notice shall be placed on the application form for a key employee or a primary management official: 

(1) Full name, other names used (oral or written), social securlty number(s), birth date, place of birth, citienship, gender, all languages 

(spoken or written); 

(2) 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; 

(3) 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 (b)(2) of this section; 

(4) Current business and residence telephone numbers; 

(5) A description of any existing and previous business relationships with Indian Tribes, including ownership interests in those businesses; 

(6) A description of any existing and previous business relationships with the gaming industry generally, including ownership interests in those 

businesses; 

(7) The name and address of any licensing or 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; 

(8) For each felony for which there was an ongoing prosecution or a conviction, the charge, the name and address of the court involved, and the date and 

disposition if any; 

(9) 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; 

(10) 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 paragraph (b)(8) or (b)(9) of this section, the criminal charge, the name and address of the court involved and the date 

and disposition; 

(1 1) 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; 

(1 2) A photograph taken within the last year; and 

(1 3) Any other information the Tribe deems relevant. 

[26 C.F.R. 5 556.41 

Section 206. Procedures for Conducting a Background Check on ApplicantsUu 

(a) As part of it's review procedure, the Commission or its agent shall employ or engage a private investigator to conduct a background investigation on each applicant 

sufficient to allow the Gaming Commission to make an eligibility determination under section 207 below. The investigator shall: 

(1) Verify the applicant's identity through items such as a social securlty card, drivers license, birth certificate, or passport; 

(2) Contact each personal and business reference provided in the License Application, when possible; 

(3) Obtain a personal credit check; 
(4) Conduct a civil history check; 

(5) Conduct a criminal history check via the submission of the applicant's fingerprints to the NIGC, and further obtain information from the 

appropriate court regarding past felony andlor misdemeanor convictions and criminal charges within the last ten years; 

(6) Inquire into any previous or existing business relationships with the gaming industry and lndian tribes by contacting the entities or tribes; 

(7) Verify the applicant's history and status with any licensing agency by contacting the agency; and 

(8) Take other appropriate steps to verify the accuracy of the information, focusing on problem areas noted 

(b) The investigator shall create an investigative report noting the steps taken, information gained, potential problem areas, and disqualifying information. 

(c) The Gaming Commission and its investigator shall promise to keep confidential the identity of each person interviewed in the course of the investigation, other than 

disclosure as required under Federal, Tribal, or State law. 

Section 207. Eligibility Determination 

The Tribal Ga~ning Cotiunission shall review a person's prior activities, criminal record. if my, and reputation, habits and associations to niake a finding 

concerning the eligibility of a key ernployee or prinlary n~anagen~ent official for enlployment in a gmling operation. If the Tribal Gaming Commission 

detemunes Uvat enlployu~ent of the person poses a heat to the public interest or to tile effective regulation of gaming. or creates or enhances dangers of 

unsuitable, unfair, or illegal practices and niethods ald activities in the conduct of gaming, a tribal gaming operatioil shall not employ that person in a key 

enlployee or prinlary managernerit official position. 

[25 C.F.R. 5 568.21 

Section 208. Procedures for Forwarding Applications and Reports for Key Employees and Primary Management Officials to the National lndian Gaming Commission 

(a) When a key employee or primary management official is employed to work at a gaming operation authorized by this ordinance, the Commission shall forward to the 

National lndian Gaming Commission a completed application for employment and conduct the background investigation and make the determination referred to in subsection 207 of 

this section. 

125 C.F. R. 5 558.3(a)] 

(b) The gaming operation shall not employ as a key employee or primary management official a person who does not have a license after 90 days. 

[25 C.F.R. 5 558.3(b)] 

Section 209. Report to the National lndian Gaming Commission 

(a) The Tribal Gaming Commission shall prepare and forward a report on each background investigation to the National lndian Gaming Commission. An investigative 

report shall include all of the following: 

(1) Steps taken in cot~ducth~g a background investigation; 

(2) Results obtained; 
(3) Cot~clusio~~s reached; and 

(4) The bases for those conclusions 

125 C.F.R. $ 6M1.6(a), @)j 

(b) The Commission shall forward the completed investigative report to the National lndian Gaming Commission within 60 days after an employee begins work or within 60 

days of the approval of this ordinance by the Chairman of the National lndian Gaming Commission. 

(c) The Commission shall submit, with the investigative report, a copy of the eligibility determination, unless the NlGC shall have advised the Tribe that the submission of 

the eligibilii determination is not necessary. This determination shall include a Statement describing how the information submitted by the applicant was verified; a Statement of 

results following an inquiry into the applicant's prior activities, criminal record, if any, and reputation, habits and associations; a Statement showing the resuls of interviews of a 

sufficient number of knowledgeable people (such as former employers, personal references, and others referred to by the applicant) in order to provide a basis for the Tribal Gaming 

Commission to make a finding concerning the eligibilii for licensing required for employment in a gaming operation; and a Statement documenting the disposition of all potential 

problem areas noted and disqualifying information obtained." 

[25 C.F.R. 5 6MI.S(c)j 

(d) If a license is not issued to an applicant, the Tribal Gaming Commission: 

(1) Shall notify the NIGC, and 

(2) Shall forward copies of its eligibility determination and investigative report 

(if any) to the NIGC for inclusion in the Indian Gaming Individuals Records System. 

126 C.F.R. 8 W6.6(cr)] 

(e) With respect to all emp~oyees,~ and in particular key employees and primary management officials, the Tribal Gaming Commission shall retain applications for 

employment and reports (if any) of background investigations for inspection by the Chairman of the NlGC or his or her designee for no less than three (3) years from the date of 

termination of employment. 

126 C.F.R. § SMl.l(c)] 

Section 210. Granting a Gaming License 

(a) If, within a thirty (30) day period after the National lndian Gaming Commission receives a report, the National lndian Gaming Commission notifies the Tribe that it has 

no objection to the issuance of a license pursuant to a 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 National lndian Gaming Commission, the Tribal Gaming Commission, acting for the Tribe, may issue a license to such applicant. 

(b) The Tribal Gaming Commission shall respond to a request for additional information from the Chairman of the National lndian Gaming Commission concerning a 

key employee or a primary management official who is the subject of a report. Such a request shall suspend the 30day period under paragraph (a) of this section until the Chairman 

of the National lndian Gaming Commission receives the additional information. 
(c) if, within the thirty (30) day period described above, the National lndian Gaming 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 Tribal Gaming Commission has provided an application and investigative report to the National lndian 

Gaming Commission, the Tribe shall reconsider the application, taking into account the objections itemized by the National lndian Gaming Commission. The Tribe shall make the nnal 

decision whether to issue a license to such applicant. 

126 C.F. R 5 658.4@)] 

Section 211. License Suspension 

(a) If, after the issuance of a gaming license, the Tribal Gaming Commission receives from the National lndian Gaming Commission reliable information indicating that a key 

employee or a primary management official is not eligible for employment, the Tribal Gaming Commission shall suspend such license and shall notify in writing the licensee of the 

suspension and the proposed revocation. 

[26 C.F.R. 5 S68.6(b)] 

(b) The Tribal Gaming Commission shall notify the licensee of a time and a place for a hearing on the proposed revocation of a license. 

126 C.F.R 5 658.6(c)] 

(c) After a revocation hearing, the Tribal Gaming Commission shall decide to revoke or to reinstate a gaming license. The Commission shall notify the NlGC of its decision. 

126 C, F.R. 5 568.6(d)] 

Section 212. Board of Review for ~isputes~ 

The Tribe has determined that, in order to adhere to this Ordiice and all gaming regulations, there shall be established a Tribal Gaming Board of Review (Board of Review). The Board of Review shall 

serve as the fmal review body for employee disputes. Employee disputes shall include disputes with management, terminations, fines or other internal employee disputes, not to include actions taken by the 

Commission. 

The Board of Review shall consist of five members. The membership shall be comprised of one member of the Tribal Gaming Commission, one member from the Tribal Council, one primary management 

official or key employee, one enrolled Tribal member not employed by the gaming operation, and one employee of the gaming operation.lul The members 6om the Tribal Gaming Commission, Tribal 

Council, and gaming operation primary management official or employees shall be elected from their representative groups and the enrolled Tribal member shall be appointed by the Tribal Council. Board of 

Review members shall serve staggered terms. The two Tribal members shall serve three-year terms. The primary management official or key employee shall serve a two-year term. The members fiom the 

Tribal Gaming Commission and the Tribal Council shall serve one-year terms. The Board of Review members who are not employed by the Tribe in some other capacity shall be compensated at a rate of 

$75.00 per meeting or hearing, and shall be reimbursed for actual costs incurred during the scope of hisher duties as a member of the Board of Review. Compensation shall never be tied to tribal gaming 

revenues. 

The Board of Review members shall elect a Chairperson fiom among them, whose duty it shall be to preside over all meetings and hearings. In addition, the members shall elect a Viachair who shall be 

the custodian of any evidence submitted, and who shall preside in the Chairperson's absence. The Board of Review shall meet as needed but no later than ten days of a dispute being received, shall keep 

official records of the meetings. No later than three working days following a hearing on employee disputes, the Board of Review shall issue its fmdings. Findings of the Board shall be final when issued. 

No Board of Review member shall be removed prior to the end of hisher term without cause. Removal shall be effectuated by a majority vote of the entire Board of Review, and shall be a fmal decision. A 

Board of Review member shall not review any decisions atfeding himseElherself, or any person directly related to him or her. 

Section 301. Licenses for vendor* 

(a) Vendors of gaming services or supplies with a value of $25,- or more annually must have a vendor license from the Tribal Gaming Commission in order to transact 

business with the Tribal gaming operation. Contracts for professional legal and accounting services are excluded from this section. 
(b) Gaming vendors are vendors who provide gaming supplies and services, including cash-related services. 

(c) Non-gaming vendors provide services that do not have the ability to impact the integrity of the Tribal gaming operations, such as media advertising, facility maintenance 

workers, linen and laundry services, and food and beverage suppliers. The Tribal Gaming Commission shall create a regulation detailing which vendors fall into this category and shall 

maintain a register of the non-gaming vendors that it licenses. The regulation may exempt from licensing requirements non-gaming vendors who: 1) are a Tribal, Local, State, or 

Federal government agencies; 2) are regulated by the State of Oklahoma or the Tribe; or 3) will provide goods of insubstantial or insignifmnt amounts or quantities if the Tribal 

Gaming Commission determines that licensing of the vendor is not necessary to protect the public interest. 

Section 302. Submission of a Vendor License Applicationm 

In order to obtain a gaming vendor license, the business must complete a vendor application and submit to background checks of itself and its principals. Principals of a business include its officers, 

directors, management, owners, partners, non-institutional stockholders that either own 10% or more of the stock or are the 10 largest stockholders, and the on-site supervisor or manager under the 

agreement with the Tribe, if applicable. 

Section 303. Contents of the Vendor License ~pplication~ 

(a) Applications for gaming vendor licenses must include the following: 

(1) Name of business, business address, business phone, federal tax ID number (or SSN if a sole proprietorship), main office address if different from business 

address, any other names the applicant has done business under, type of service applicant will provide; 

(2) Whether the applicant is a partnership, corporation, limited liability company, sole proprietorship, or other entity; 

(3) If the applicant is a corporation, the state of incorporation, and the qualification to do business in the State of Oklahoma if the gaming operation is in a different 

State than the State of incorporation. 

(4) Trade name, other names ever used, names of any wholly owned subsidiaries or other businesses owned by the vendor or its principals; 

(5) General description of the business and its activities; 

(6) Whether the applicant will be investing in or loaning money to the gaming operation and, if so, how much; 

(7) A description of any existing and previous business relationships with the gaming industry generally, including ownership interests in those businesses; 

(8) A list of Indian tribes with which the vendor has an existing or previous business relationship, including ownership, financial, or management interests in nongaming activitie~;~ 

(9) Names, addresses, and phone numbers of three business references with whom the company had regularly done business for the last five years; 

(10) The name and address of any licensing or regulatory agency with which the business has filed an application for a license or permit related to gaming, whether 

or not such license or permit was granted; 

(1 1) If the business has ever had a license revoked for any reason, the circumstances involved; 

(12) A list of lawsuits to which the business has been a defendant, including the name and address of the court involved, and the date and disposition if any; 

(1 3) List the business' funding sources and any liabilities of $50,000 or more.u 
(1 4) A list of the principals of the business, their social security numbers, addresses and telephone numbers, title, and percentage of ownership in the company; and 

(15) Any further information the Tribe deems relevant. 

(b) The following notice shall be placed on the application form for a vendor and its principals: 

Inclusion of false or misleading information in the vendor application may be grounds for denial or revocation of the Tribe's vendor license. 

(c) A vendor may submit a copy of a recent license application to another jurisdiction if it contains the information listed above. The vendor will be required to submit in 

writing any changes in the information since the other license application was filed and any information requested by the Tribe not contained in the other application. 

Section 304. Vendor Background lnvestigationW 

The Tribal Gaming Commission shall employ or otherwise engage a private investigator to complete an investigation of the gaming vendor. This 

investigation shall contain, at a minimum, the following steps: 

(a) Verify of the business' incorporation status and qualification to do business in the State where the gaming operation is located; 

(b) Obtain a business credit report, if available, and conduct a Better Business Bureau check on the vendor; 

(c) Conduct a check of the business' credit history; 

(d) Call each of the references listed in the vendor application; and 

(e) Conduct an investigation of the principals of the business, including a criminal history check, a credit report, and inte~iews with the personal references listed. 

Section 305. Vendor License ~ee~ 

The Tribe may charge a license fee, to be set by the Tribal Gaming Commission, to cover its expenses in investigating and licensing vendors of the gaming operation. 

Section 306. Vendor Background Investigation Reportw1 

The private investigator shall complete an investigative report covering each of the steps taken in the background investigation of the gaming vendor and its principals and 

present it to the Tribal Gaming Commission. 

Section 307. Exemption for Vendors Licensed by Recognized Regulatory AuthoritiesLm 

The Tribal Gaming Commission may adopt regulations naming specific licensing authorities that it recognizes and may authorize exemptions to the vendor licensing process for 

vendors which have received a license from one of the named regulatory authorities. 

Section 308. Licenses for NonGaming vendorsm 

For non-gaming vendors, the Tribal Gaming Commission is authorized to create a less stringent vendor licensing process, including a due diligence check rather than a full 

background investigation as laid out in Section 304. The Gaming Commission may investigate such vendors when appropriate and may conduct audits in addition to monitoring Tribal 

purchases.