Indiana Administrative Code
Title 68 - INDIANA GAMING COMMISSION
Article 11 - INTERNAL CONTROL PROCEDURES
Rule 3 - Soft Count Procedure
Section 3-6 - Soft count process

(1) The soft count team shall notify surveillance prior to the initiation of the soft count. Surveillance shall visually record the entire soft count process.

(2) A security officer shall give the soft count team access to the soft count room. The soft count room door shall be locked after the soft count team has entered the soft count room.

(3) After the soft count team has entered the soft count room and the door has been locked, no one except:

(4) Prior to the initiation of the count, the currency counter shall be tested for accuracy by using a precounted amount of currency from the first live gaming device drop box or bill validator drop box that is to be counted. A discrepancy of two percent (2%) or more must be resolved to the satisfaction of the soft count supervisor, or his or her designee, prior to the use of the currency counter. The results of the test shall be documented and retained for a period of one (1) year. The currency counter test results shall be signed and dated by the individual who conducted the test.

(5) Prior to the commencement of the soft count, the recorder shall generate a drop box verification report.

(1) An individual drop box shall be selected and the identification label displayed to the surveillance camera.

(2) The drop box shall be opened by the appropriate soft count team member, and the entire contents of the drop box shall be emptied onto the soft count table.

(3) The inside of the empty drop box shall be held up for full view by the surveillance camera, and at least one (1) member of the soft count team shall verify that the drop box is empty.

(4) The slide on the drop box shall be reset, and the door to the drop box shall be relocked.

(5) If the drop box is from a live gaming device, documents shall be separated from the currency, coins, and chips.

(6) The soft count team shall separate the currency, cash, and chips into individual denominations and count the currency, cash, and chips. The soft count team may, at its discretion, separate and count manually or by the use of a currency counter. Currency counters used by the casino licensee must be capable of displaying the result of the count.

(7) Once the currency and chips have been separated and counted, one (1) member of the soft count team shall:

(8) A casino licensee shall conduct an additional, independent count of the separated currency and chips. The casino licensee shall submit internal controls in accordance with 68 IAC 11 regarding the conduct of the independent count, including how the casino licensee shall guarantee independence of the independent count.

(9) The recorder shall compare the two (2) count slips. If there is a discrepancy between the count slips, the difference shall be isolated to particular denomination of currency, coins, or chips, and that denomination shall be recounted.

(10) The recorder shall sign the count slip that is correct. If corrections need to be made to a count slip to ensure one (1) of the slips accurately reflects the count, the incorrect figures shall be struck through and initialed by the soft team count members that conducted the original count. The correct information shall then be entered on the count slip.

(11) The recorder shall compare the documents removed from each drop box to those appearing on the drop box verification report. Appropriate adjustments may be made to the drop box verification report. Discrepancies between the documents removed from the live gaming devices drop boxes and the drop box verification report shall be noted for the internal auditor or the equivalent.

(12) Once the drop boxes have been counted, the soft count team shall complete the master gaming report or the bill validator report.

(13) Upon completion of the master gaming report, the soft count team members not performing the job of recorder shall run totals of the table count slips and compare that information to the totals recorded on the master gaming report. The casino licensee shall investigate variances of two percent (2%) or more. The reason for the variance, if known, shall be entered on the master gaming report. If the reason is not known, this shall be noted. The casino licensee may require investigations for variances of less than the threshold amount.

(14) Variances of two percent (2%) or more that are not reconciled through subdivision (13) shall be investigated by the accounting director or designee. The results of the investigation shall be recorded on the master gaming report. The accounting director or designee shall sign and date the master gaming report. The casino licensee may require investigations for variances of less than the threshold amount.

(15) After the results of the count process have been reconciled, the members of the soft count team shall sign and date the appropriate section of the master gaming report or the bill validator report.

(16) After reconciliation has been completed by the soft count team, the main bank cashier shall be contacted. The main bank cashier shall complete an independent physical inventory of all of the currency, coins, and chips in the presence of at least one (1) soft count team member. The main bank cashier shall not have access to the master gaming report or the bill validator report until after the completion of the independent physical inventory.

(17) Discrepancies between the independent physical inventory and the totals entered on the master gaming report or the bill validator report shall be investigated by independent recounts conducted by the casino licensee. If the master gaming report or the bill validator report was erroneous, it shall be voided and a new master gaming report or the bill validator report generated with the appropriate signatures. A voided copy of the master gaming report or the bill validator report shall be retained and attached to the completed and signed copy of the new master gaming report or bill validator report.

(18) After reconciliation of the master gaming report, the bill validator report, and the physical inventory conducted by the main bank cashier, the main bank cashier shall verify the accuracy of and sign and date the master gaming report and the bill validator report in the appropriate section. When the main bank cashier signs the master gaming report and the bill validator report, the main bank assumes responsibility for the currency, coins, and chips.

(19) All currency and chips shall be transported to the main bank for use during the gaming day. Transportation from the soft count room to the main bank shall be:

(20) The remaining amount of currency and coin may be deposited with the casino licensee's external bank.

(21) The original table count slips, drop verification report, bill validator verification report, master gaming report, and bill validator report, with the appropriate tapes attached, shall be forwarded to the accounting department upon completion of the soft count process and after the currency, coin, and chips have been appropriately transferred or deposited.

(22) The currency counter in the soft count room shall be monitored by the central computer system for purposes of recording the amounts collected from each live gaming device and bill validator drop box. The information sent to the central computer system shall be printed out in the accounting department as a backup. The backup printouts shall be maintained by the accounting department for at least one (1) month. Electronic archival data shall be maintained for a period of one (1) year.

(23) In accordance with 68 IAC 15-7-3, the revenue auditor or the equivalent shall trace the total of the bill-in meter readings as recorded by the bill acceptor flash report to the actual count performed by the soft count team to determine variances. The casino licensee shall require the investigation of all variances. The results of the investigation shall be recorded and reported to the head of the accounting department and the commission audit staff.

(24) Every three (3) months, the internal auditor, or equivalent, shall verify the accuracy of the currency counter. The internal auditor, or equivalent, shall notify the commission immediately of a difference of plus or minus two percent (2%).

The results of the currency counter testing shall be: