Current through Register 1518, March 29, 2024
A system of internal controls submitted by a gaming licensee in
accordance with
205
CMR 138.02 shall include procedures relative
to opening, counting, and recording contents of table drop boxes and slot cash
storage boxes that include, at a minimum, the following provisions:
(1) Immediately prior to the commencement of
the count process, a count room supervisor shall:
(a) Obtain a preliminary master game report
which shall list forms and documents related to the table drop box count that
were entered into the computer system at the time of preparation;
(b) Reconcile the number of boxes recorded on
the drop box verification form to the number of boxes secured in the
trolley;
(c) Remove the emergency
drop box log and reconcile the log to the boxes removed from the emergency drop
box cabinet or trolley; and
(d)
Document any unresolved discrepancies on a two-part Drop Variance Report, the
original of which shall be delivered to the IEB and the duplicate placed in the
locked accounting box.
(2) A gaming licensee shall open, count and
record the contents of each drop box in the soft count room except that an
emergency slot cash storage box may be held and counted on the regularly
scheduled count for the slot machine from which it originated. For currency,
gaming vouchers, and coupons, a gaming licensee shall perform a second count to
obtain the aggregate total of each denomination of currency and coupon, and the
total number of gaming vouchers counted. The counts shall be independent of
each other and access to the result of the first count shall not be available
to the employee performing the second count until completion of the second
count. At the completion of the second count, a comparison of the two counts
shall be made and any discrepancies resolved by the count team
supervisor.
(3) A gaming licensee
shall use a counting machine, to be identified in the internal controls, to
count currency, gaming vouchers, and coupons. An alternative procedure shall be
provided in the event that a counting machine cannot be used due to mechanical
failure or other emergent situation.
(a) A
gaming licensee may use one counting machine that automatically provides the
counts required in
205
CMR 138.48(2) of the items
at different stages of the counting process. If the counts are not in
agreement, the machine shall document the discrepancy and cease operation until
the discrepancy is resolved by a count team member.
(b) If a gaming licensee does not use a
counting machine described in
205
CMR 138.48(3)(a), two
different counting machines shall be used. Upon completion of the count using
the first machine, the cash storage bins or cassettes shall be emptied and
displayed to the full view of a closed circuit television camera to assure that
the contents have been emptied. The second machine count shall be performed to
verify the totals of the first machine. If the counts are not in agreement, the
count team shall resolve the discrepancy before continuing the second
count.
(c) Each machine shall
generate a report at the completion of its count documenting the following:
1. The total of each denomination of
currency;
2. The total of all
currency;
3. The total number of
gaming vouchers;
4. The total
number and amount of coupons for which the count machine can determine the
value of the coupon (machine count coupons); and
5. The total number of coupons for which the
count machine cannot determine the value of the coupon (manual count
coupons).
(4)
A test count shall be conducted prior to the start of the first use of each
counting machine, each gaming day, and prior to each count. The count room
supervisor shall:
(a) Verify that the counting
machine has a zero balance on its display and cause a receipt to be printed
which denotes 0 cash, gaming vouchers or coupons on hand, and 0 notes, gaming
vouchers or coupons in the machine, or other approved means to indicate that
the machine has been cleared of all currency, gaming vouchers and
coupons;
(b) Visually check the
counting machine to be sure there are no bills, gaming vouchers or coupons
remaining in the various compartments of the machine;
(c) Supervise a count team member who shall
select a drop box or slot cash storage box. If slot storage boxes are being
counted that day, a slot cash storage box must be selected and it must contain
currency, and if issued by the gaming licensee, gaming vouchers and coupons.
The count team member shall place the entire contents of the table drop box or
slot cash storage box into the first counting machine, which shall count the
currency by denomination as well as any gaming vouchers and coupons. Any soiled
or off-sorted bills, gaming vouchers or coupons shall be re-fed into the
machine. Any items which the counting machine is not able to count
automatically, such as coins, tokens, gaming chips or mutilated or torn
currency, gaming vouchers, and coupons shall be manually counted, recorded
either manually or entered into the counting machine, and segregated from items
which the counting machine was able to count automatically. The count team
member shall cause the counting machine, in conjunction with the gaming voucher
system, to produce one or more test receipts of the count, and the count shall
not be shown to anyone until completion of the final verification
process;
(d) Supervise a second
count team member, independent of the team member performing the initial count,
who shall manually count or use a second counting machine to count and
summarize the items on test receipts;
(e) Compare the totals on the test receipts
for agreement. If the totals are in agreement, the count room supervisor shall
sign and date the test receipts and place them in the locked accounting box to
be forwarded to the gaming accounting department at the end of the count
process. If the totals do not agree, the test count procedures shall be
repeated. The test count procedures shall be repeated until the totals are in
agreement or a determination is made that the count machine cannot be used. The
count room supervisor shall not permit a counting machine to be used until
these totals are in agreement;
(f)
Supervise a count team member who, at the conclusion of the test procedure
shall display the cash bin or storage cassettes to the full view of a closed
circuit television camera to assure that the contents have been emptied prior
to replacing cassettes into the counting machine; and
(g) Verify that the counting machine has a
zero balance in accordance with
205
CMR 138.48(4)(a).
(5) Procedures for the count of
boxes shall be as follows:
(a) The contents
shall be segregated and counted so as to permit the contents to be recorded for
the box from which it was removed. Each box shall be individually:
1. placed on the count table at which time
one count team member shall verbalize, in a tone of voice to be heard by all
persons present and to be recorded by the surveillance audio recording device,
the game and table number marked thereon for table drop boxes, or the asset or
unique identification number marked thereon for slot cash storage boxes;
and
2. unlocked and the contents
emptied on the count table. The inside of the box shall be held up to the full
view of a closed circuit television camera to assure all contents of the drop
box or slot cash storage box have been removed, after which the drop box or
slot cash storage box shall be locked and placed in the storage area for drop
boxes and slot cash storage boxes;
(b) A count team member shall segregate:
1. Currency, machine count coupons, and
gaming vouchers;
2. Coin, tokens,
gaming chips, manual count coupons and any mutilated or torn items;
and
3. Forms and
documents;
(c) A count
team member shall attempt to match pieces of mutilated or torn items which
shall be processed as follows:
1. Mutilated or
torn currency shall be recorded as revenue if the bill includes one entire
serial number and one letter and number of the serial number from the other
half of the bill;
2. Mutilated or
torn currency that is not recorded as revenue shall be placed in a sealed
transparent envelope or container and transferred to the main bank by the main
bank cashier or cage supervisor at the end of the count; and
3. All mutilated or torn coupons and gaming
vouchers shall be recorded as revenue regardless of condition;
(d) The value and number of coin,
tokens, gaming chips, manual count coupons (by denomination) and any mutilated
or torn items shall be manually entered into the counting machine for each drop
box or slot cash storage box;
(e)
Currency, machine count coupons and gaming vouchers shall be placed in a
counting machine. The counting machine shall count and calculate the value of
the currency. The value of each gaming voucher or coupon shall be obtained from
the counting machine or an approved gaming voucher system, as
applicable;
(f) Upon completion of
the machine count:
1. For each drop box, the
counting machine shall generate the report required by
205
CMR 138.48(3)(c);
2. The currency, table game coupons, coin,
tokens, and gaming chips counted shall be placed on the banking table;
and
3. Any drop box coupon which
has not already been cancelled upon acceptance or during the count shall be
cancelled prior to the conclusion of the count;
(g) The forms and documents shall be compared
to the preliminary master game report for accuracy by a count team member who
shall not simultaneously have access to currency. Any discrepancies shall be
recorded on the preliminary master game report to be resolved by the gaming
accounting department. The forms and documents and preliminary master game
report shall be placed in the locked accounting box to be forwarded to the
accounting department at the end of the count process; and
(h) The count team supervisor shall prepare a
detailed written report describing all count room incidents that may have
negatively impacted the opening, counting and recording of the drop boxes (for
example, a computer interface problem, dropped basket). The report shall
include a description of any corrective action taken and shall be
electronically filed with the IEB at the conclusion of the count.
(6) As the contents of each table
drop box are counted, if not already recorded in the computer system used to
create the Master Game Report and supporting documentation, a count team member
shall manually record or cause a computer system to record, the following
information by game and table number:
(a) The
value of each denomination of currency counted;
(b) The value of coin, tokens and/or gaming
chips counted;
(c) The total value
of currency, coin, tokens and gaming chips counted;
(d) The value of each denomination and total
value of coupons other than match play coupons;
(e) The value of each denomination and total
value of match play coupons and table game wager coupons;
(f) 50% of the total value of match play
coupons and table game wager coupons;
(g) The amount recorded on each document and
the total of all documents evidencing a debit card chip transaction;
(h) The amount of the Opener;
(i) The amount of the Closer;
(j) The serial number and amount of each
Counter Check and the total amount of all Counter Checks;
(k) The serial number and amount of each Pit
Redemption Form and the total of all Pit Redemption Forms;
(l) The serial number and amount of each Fill
and the total amount of all Fills;
(m) The serial number and amount of each
Credit and the total amount of all Credits;
(n) The amount recorded on each Complimentary
Vigorish Form and the total amount of all Complimentary Vigorish
Forms;
(o) The table game win or
loss or, for poker, the poker revenue; and
(p) The table game win or loss
percentage.
(7) In
addition to the requirements of
205
CMR 138.48(6), the Master
Game Report shall include:
(a) The gaming date
of the items recorded;
(b) The
grand total for items in
205
CMR 138.46(6)(c) through
(q);
(c) The total number of drop boxes opened and
counted; and
(d) The date and time
prepared.
(8) If the
gaming licensee offers the game of poker, the count room supervisor shall
review the Master Game Report to ensure that negative poker revenue has not
been reported for any poker table. If negative poker revenue has been reported
for a poker table, the count room supervisor shall initial the Master Game
Report for each such poker table and immediately notify the surveillance
department of the poker table(s) and corresponding negative poker revenue
reported thereon.
(9) As the
contents of each slot cash storage box are counted, if not already recorded in
the computer system used to create the Slot Cash Storage Box Report and
supporting documentation, a count team member shall manually record or cause a
computer system to record, the following information by asset number:
(a) The asset number of the bill changer to
which the slot cash storage box contents correspond;
(b) The value of each denomination and total
value of currency counted;
(c) The
number and value of each cashable coupon counted, and if a gaming voucher
system is used to redeem coupons, the validation number and value of each
coupon counted, and total number and value of all cashable coupons;
(d) The number and value of each non-cashable
coupon counted, and if a gaming voucher system is used to redeem such coupons,
the validation number and value of each coupon counted, and total number and
value of all non-cashable coupons;
(e) A listing of the validation number and
value of each gaming voucher counted, and total number and value of all gaming
vouchers; and
(f) Any additional
information on the Slot Cash Storage Box Report as may be required by the
IEB.
(10) In addition to
the requirements of
205
CMR 138.48(9), the Slot Cash
Storage Box Report shall include:
(a) The
gaming date of the items recorded;
(b) The grand total for items in
205
CMR 138.48(9)(b) through
(e);
(c) The total number of drop boxes opened and
counted;
(d) The date and time
prepared.
(11) After
preparation of the Master Game Report or the Slot Cash Storage Box Report, the
count room supervisor shall compare the total number of boxes counted to the
number of boxes, including any emergency boxes, collected and recorded on the
box reconciliation form. Any unresolved discrepancy shall be documented on the
Drop Variance Report which shall be filed with the IEB.
(12) All suspected counterfeit currency shall
be counted and recorded as drop on the Master Game Report or Slot Cash Storage
Box Report. The counterfeit currency shall be segregated from all other
currency and placed in a transparent container. A count room supervisor shall
complete a Department of Treasury Counterfeit Note Report and place the
container and report on the banking table.
(13) A count team member designated as the
banker shall count each denomination of currency, table game coupons, tokens,
and gaming chips, and verbalize the amounts. The count room supervisor shall
verify the amount verbalized to the amount recorded on the Master Game Report
or Slot Cash Storage Box Report. The banker and count team supervisor shall
sign the report(s) attesting to the accuracy of the information recorded
thereon. The information recorded thereon shall not be accessible to any person
outside the count room until after the main bank cashier or cage supervisor
(cashier) has verified and accepted the drop unless otherwise authorized by the
IEB.
(14) All other count team
members shall sign the Master Game Report and/or the Slot Cash Storage Box
Report as evidence of their participation in the counting of the drop boxes
and/or slot cash storage boxes.
(15) After the contents of the boxes have
been counted and recorded on the Master Game Report and/or Slot Cash Storage
Box Report, the count room supervisor shall notify the main cage. A cashier
shall enter the count room and not have any access to the information recorded
on the Master Game Report or the Slot Cash Storage Box Report. The cashier, in
the presence of the banker, shall count the currency, table game coupons,
coins, tokens, gaming chips, and mutilated or torn items.
(a) Currency, table game coupons, coin,
tokens, and gaming chips shall be presented in the count room by the banker to
a main bank cashier or cage supervisor (cashier). Prior to having access to the
information recorded on the Master Game Report or the Slot Cash Storage Box
Report, the cashier, in the presence of the banker, shall count the items in
accordance with the following requirements:
1.
The cashier shall have physical access to all items presented for counting and
no currency or table game coupons presented for counting shall be wrapped or
placed in any sealed bag or container until the entire count has been completed
and the Master Game Report or the Slot Cash Storage Box Report has been signed
by the cashier;
2. The cashier
shall bulk count all strapped currency and table game coupons. The cashier
shall count all partial straps, loose currency and table game coupons,
mutilated or torn currency and coupons, coin, tokens, and gaming chips either
by hand or with an approved counting machine. If a discrepancy in an individual
denomination is discovered during the initial count, the cashier shall recount
the currency of that denomination either by hand or with an approved counting
machine;
3. The cashier shall
randomly count the currency within at least 10% of the total number of straps.
The count shall be by hand or with an approved counting device; and
4. The cashier shall randomly sample the
table game coupons for intermixed denominations and proper
cancellation.
(b) If the
total currency or total coupons counted by the cashier do not agree with a
total on the Master Game Report or Slot Cash Storage Box Report and the
discrepancy cannot be resolved, a Drop Variance Report shall be completed by
the count room supervisor. The original shall be delivered to the IEB and the
duplicate placed in the locked accounting box in the count room. The report
shall include, at a minimum, the following:
1.
The date of preparation;
2. The
source of the variance (currency and/or coupon);
3. The denomination(s) of the source of the
variance;
4. The amount of the
variance;
5. The measures taken to
detect the source of the variance;
6. The name and signature of the count room
supervisor; and
7. The name and
signature of the cashier.
(c) Upon completion of the cashier's count,
the cashier shall attest by signature on the Master Game Report and/or Slot
Cash Storage Box Report, that the amount of cash from drop boxes counted, and
the amount of coupons from table drop boxes counted as recorded on these
documents, and if applicable, the Drop Variance Report, agree with the total
amounts of cash and coupons counted by the count team. Upon attestation, all
items other than coupons and vouchers shall be under the exclusive control of
the cashier and shall not be handled by a count team member.
(16) Once all required signatures
have been obtained, a copy of the totals page of the original Master Game
Report, Slot Cash Storage Box Report and disc(s) detailing all gaming vouchers
and coupons counted, shall be delivered to the IEB. In addition, an electronic
copy of the Master Game Report and/or Slot Cash Storage Box Report shall be
filed with the IEB within 48 hours of the completion of the drop.
(17) Each copy of an original Master Game
Report or Slot Cash Storage Box Report which is not part of a multi-part form
shall be stamped with the word "copy" by the count room supervisor prior to its
distribution.
(18) Any coupons and
gaming vouchers for which the value could not be determined by the count
machine or the gaming voucher system shall be segregated and placed in the
locked accounting box for review.
(19) The original Master Game Report and Slot
Cash Storage Box Report, after signing, and any other supporting documentation
shall be placed in the locked accounting box located in the count room. A
member of the gaming accounting department with no incompatible functions shall
retrieve the contents of the locked accounting box and the gaming vouchers and
coupons which were processed during the count immediately after the cashier
verifies, accepts, and removes the drop from the count room.
(20) For each trolley scheduled for the next
drop, the count team supervisor shall determine that the number of empty boxes
on the trolley is correct. The count team supervisor shall prepare and sign a
drop box verification form as required by
205 CMR
138.00, with the following:
(a) The trolley number;
(b) The pit number and number of empty boxes
by pit, if applicable;
(c) The slot
zone and number of empty boxes by zone, if applicable; and
(d) The total boxes in the trolley.
(21) A count room employee shall
conduct a thorough inspection of the entire count room and all counting
equipment located therein to verify that no cash, tokens, gaming chips, gaming
vouchers, or coupons remain in the room and shall certify the foregoing in a
writing which shall be filed with the IEB.
