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    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

    CAGE AND CREDIT

Note 1: Category A licensee is a licensee whose “Collections in Areas Other than the Pit” on the NGC tax returns

    for the 12 months ended June 30 exceeds $10 million. All of these MICS apply to Category A licensees.

    Category B licensee is a licensee whose “Collections in Areas Other than the Pit” on the NGC tax returns for

    the 12 months ended June 30 are less than or equal to $10 million. MICS #4, #24 - #25 and #64 do not apply to

    Category B licensees.

Note 2: If a licensee has no pit credit and makes no adjustments for returned checks or cage credit on the licensee’s

    NGC tax returns, only MICS #16 - #17, #34 - #58, #68 - #72, and #77 - #82 are applicable.

Note 3: The Cage and Credit MICS represent minimum acceptable credit procedures applicable to the race and sports,

    slots, keno, bingo and the cage departments (see Table Games MICS for credit procedures applicable to the pit).

    The requirements of Regulation 6.120 must also be met if credit issuances are to be excluded from gross

    gaming revenue.

Note 4: For any Board-authorized computer applications, alternate documentation and/or procedures which provide at

    least the level of control described by these MICS as determined by the Audit Division will be acceptable, and a

    MICS variation pursuant to Regulation 6.090 will be unnecessary.

Note 5: The accounting treatment and documentation requirements applicable to marker transactions are also applicable

    to front money transactions including customer deposit withdrawal (CDW) transactions.

Note 6: Cage and Credit MICS #18 - #23, #30 - #31, #44 - #46, and #83 - #87 also apply to activity occurring in branch

    offices.

Establishing Credit Account

    1. At least the following information is recorded and maintained for patrons who have established credit limits or are issued

    credit of any amount (credit issuances include the issuance of markers and the use of counter checks, but excludes

    personal checks, payroll checks, cashier’s checks and traveler’s checks):

Note: A counter check is a form (similar to a marker form) provided by the licensee that is completed as is necessary

    for the instrument to be presented to the patron’s bank for payment.

    a. Patron’s name, current address, and signature.

b. Type of identification credential, credential number, expiration date of credential, and date credential was examined.

Note: A patron’s driver’s license is the preferred method for verifying the patron’s identity. A passport, non-resident

    alien identification card, other government issued identification credential or another picture identification

    credential normally acceptable as a means of identification when cashing checks, may also be used.

c. Documentation of credit worthiness using a method permissible under Regulation 6.120(2)(a).

d. Authorized credit limit.

e. Signature of the individual(s) designated by management to approve credit limits. For computerized systems, a

    credit limit approval controlled through system passwords is adequate.

    VERSION 6 PAGE 1 OF 16 EFFECTIVE: 9/1/2008

    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

    CAGE AND CREDIT

2. Credit limits over specified dollar amount(s) are approved by personnel designated by management. The dollar amount

    thresholds and job titles of personnel so designated are documented. Such documentation, or alternatively the job title of

    the employee responsible for the documentation (available upon request by authorized internal and external auditors and

    by Board personnel), is delineated in the cage and credit section of the written system of internal control pursuant to

    Regulation 6.090.

3. Proper approval for the increase of credit limits of over 10 percent of the previously established credit limit or $1,000,

    whichever is greater, including a temporary increase, is documented.

4. The job functions of credit approval (i.e., establishing the patron’s credit worthiness) and credit issuance are segregated

    if pit or cage credit issuances to a single patron of $10,000 or more per day are transacted.

    Credit Issuances and Voiding Markers

5. Prior to the issuance of gaming credit to a patron, the employee issuing the credit:

    a. Determines whether the credit limit has been established.

    b. Determines the amount of available credit and whether the available credit is sufficient to cover the issuance.

    c. Verifies the patron’s identity by examining the patron’s identification credential or other reasonable method to

    ensure the patron’s identity (e.g., review of scan of driver’s license on file).

    Note 1: A patron’s driver’s license is the preferred method for verifying the patron’s identity. A passport, non-resident

    alien identification card, other government issued identification credential or another picture identification

    credential normally acceptable as a means of identification when cashing checks, may also be used.

    Note 2: It is recommended, but not mandatory, that in order to mitigate identity theft the identification credential

    presented when issuing credit and the patron’s signature on the marker be compared to the copy (or computer

    scan) of the patron’s picture identification (if copy or scan was retained) and signature that were obtained when

    the patron’s credit account was established.

6. For patrons that have an established credit limit pursuant to MICS #1, a record of credit activity (i.e., patron’s credit

    account records) is created and maintained that details the following:

    a. Date, time and amount of each credit issuance.

    b. The marker number, if applicable.

    c. The name or other identifier of the individual(s) issuing the credit.

    d. The legible name of the individual receiving the credit.

    e. The current amount of available credit.

7. If cage markers and/or counter checks are issued to a single patron in an amount exceeding the amount established by

    management (the amount at which notification is required must not exceed $10,000 and is delineated within the cage and

    credit section of the written system of internal control pursuant to Regulation 6.090), applicable gaming personnel are

    notified on a timely basis (e.g., via computer and gaming department can access computer record of gaming activity) of

    the patron’s playing on cage credit, the applicable amount of credit issued, and the available balance.

VERSION 6 PAGE 2 OF 16 EFFECTIVE: 9/1/2008

    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

    CAGE AND CREDIT

8. Cage marker forms are at least two parts (the original marker and a payment slip), prenumbered by the printer or

    concurrently numbered by the computerized system, and utilized in numerical sequence.

9. The original cage marker contains at least the following information: marker number, patron’s name and signature,

    amount of credit issued (both alpha and numeric) and the signature of the cashier, unless this cashier information is

    included on another document.

10. When counter checks are issued, the following is included on the check:

    a. The patron’s name and signature.

    b. The dollar amount of credit issued (both alpha and numeric).

    c. Signature of the cashier, unless this information is included on another document.

11. Voided cage markers contain the following:

    a. “Void” written across all parts of the marker.

    b. The reason a marker is voided is documented on one part of the marker or other document (e.g., a log) sufficiently

    identifying the marker.

    c. Date and time of void on at least one part of the marker.

    d. Signatures on at least one part of the marker (adjacent to the void indication) of the cashier and cage department

    supervisor performing the void.

    Note: In the event a cage marker is voided by accounting/audit personnel, the signature of the cashier and cage

    department supervisor authorizing the void is required.

12. The voiding process for cage markers is completed no later than thirty minutes after the issuance of the marker unless the

    reason for exceeding this time period is documented on one part of the marker or other document (e.g., a log) sufficiently

    identifying the marker.

13. The patron’s credit account records are updated to reflect the voided cage marker transaction if the marker issuance was

    posted in the patron’s credit account.

14. All parts of voided cage markers are submitted to accounting for retention and accountability.

15. Pit markers cannot be voided by cage personnel.

    Cashing Checks and Guaranteed Drafts

16. If personal checks, cashier’s checks, or payroll checks are cashed, for each check cashing transaction the cage cashier:

    a. Verifies the patron’s identity by examining the patron’s identification credential (e.g., driver’s license) or other

    method to ensure the patron’s identity. The identification credential information is documented on the check unless

    the information is maintained elsewhere. In such cases, “ID on file” or the patron’s account number is recorded on

    the check as the verification source and results.

    b. Verifies the patron’s credit worthiness pursuant to Regulation 6.120(2)(a) and records the verification source and

    results on the check (for personal checks).

    VERSION 6 PAGE 3 OF 16 EFFECTIVE: 9/1/2008

    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

     CAGE AND CREDIT

    Note: For patrons that have an active established credit limit pursuant to MICS #1, verification of the patron’s credit

    worthiness is not required. “Account on file” or the patron’s account number is recorded as the verification

    source and results.

    c. Makes a reasonable effort to verify business authenticity (for payroll checks).

    d. Makes a reasonable effort to verify the authenticity of cashier’s checks for amounts over $1,000.

    Note: If a check guarantee service is used to guarantee payment of an instrument and the procedures required by the

    check guarantee service are followed, MICS #16 does not apply.

    17. When traveler’s checks/guaranteed drafts are presented, all required issuance and acceptance procedures are adhered to

    by the drawee and cage personnel.

    Transferring Credit Instruments

18. If outstanding original gaming credit instruments are transferred to branch offices, collection agencies, or other

    collection representatives, a copy of the credit instrument and a receipt from the collection representative are obtained

    and maintained until such time as the credit instrument is returned or payment is received.

19. If outstanding original gaming credit instruments are transferred to a law enforcement agency (e.g., district attorney’s

    office), a copy of the credit instrument and documentation from the law enforcement agency is maintained stating that

    the original credit instrument is in law enforcement agency’s possession.

20. A detailed listing is maintained to document all outstanding credit instruments that have been transferred to other offices

    as indicated above. Branch offices maintain a detailed listing of outstanding original credit instruments in custody of the

    branch office.

21. The above listing is prepared or reviewed and signed by an individual independent of credit transactions and collections

    thereon.

    Payment Standards

22. All payments received on outstanding credit instruments (other than payments made in the pit addressed by the Table

    Games MICS) are permanently recorded in the licensee’s records, including the patron’s credit account records, and at

    the branch office (if applicable) as follows:

    a. The date, time and amount of payment.

    b. The nature of payment (e.g., cash, chips, etc.).

    c. The name or other identifier of the individual receiving payment.

    d. The patron’s name.

    e. The marker number or other identifying characteristic of the credit instrument on which payment is being made.

    Alternatively, for branch office payments, the marker number may be recorded in the licensee’s records rather than

    at the branch office.

VERSION 6 PAGE 4 OF 16 EFFECTIVE: 9/1/2008

    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

    CAGE AND CREDIT

23. When partial payments are made on credit instruments (i.e., markers, personal checks, payroll checks, cashier’s checks,

    etc.), and the original instruments are not replaced with a marker for the remaining balance, the payments are evidenced

    by a multi-part, sequentially-numbered receipt (or another equivalent document) which contains:

    a. The same receipt number on all copies.

    b. Patron’s name.

    c. Date of payment.

    d. Dollar amount of payment and nature of settlement (cash, chips, etc.).

    e. Signature of individual receiving payment.

    f. Marker number or other identifying characteristic of the credit instrument on which payment is being made.

    Alternatively, for branch office payments, the marker number may be recorded in the licensee’s records rather than

    at the branch office.

    Note: MICS #24 and #25 do not apply if account balances are annually confirmed on a random basis by the

    accounting or internal audit departments, if statements are mailed by someone independent of the credit

    transactions and collections thereon, and the department receiving payments cannot access cash.

24. The routing procedures for payments by mail require that the mail payments are received by a department independent of

    credit instrument custody and collection.

25. Credit instrument payments received via mail are documented on a listing indicating the following:

    a. Patron’s name on account to which the payment is being applied and the name of individual making the payment, if

    different than the patron.

    b. Amount of payment.

    c. Nature of payment (if other than a check).

    d. Date payment was received.

    Access to Credit Documentation

26. Access to credit information is restricted to those positions which require access and are so authorized by management.

27. Access to outstanding credit instruments is restricted to persons authorized by management.

28. Access to written-off credit instruments is further restricted to individuals authorized by management.

    Note: For MICS #27 #28, the job titles of authorized personnel are documented. Such documentation, or

    alternatively the job title of the employee responsible for the documentation (available upon request by

    authorized internal and external auditors and by Board personnel), is delineated in the cage and credit section of

    the written system of internal control pursuant to Regulation 6.090.

VERSION 6 PAGE 5 OF 16 EFFECTIVE: 9/1/2008

    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

     CAGE AND CREDIT

    Documentation

29. All issuances of cage credit, pit credit transferred to the cage and subsequent payments are documented on a credit

    instrument control document by cage personnel.

30. Records of all correspondence, transfers to and from outside agencies, and other documents related to issued credit

    instruments are maintained.

31. Documentation is created and maintained of collection efforts for outstanding credit instruments, and patron payment

    agreements entered into pursuant to Regulation 6.120(3)(a).

    Write-Off and Settlement/Discount Standards

32. Written-off or settled/discounted credit instrument approvals are made by at least two management officials, other than

    branch office personnel, at least one of whom is independent of the initial credit limit approval process, and the issuance

    and collection of credit relative to the patron’s credit account. The individuals approving the write-off or

    settlement/discount must sign a document indicating authorization.

    Note: The job titles of management personnel required to review and grant such approvals are delineated within the

    cage and credit section of the written system of internal control pursuant to Regulations 6.090 and 6.120(6)(b).

33. Completed written-off and settled/discounted credit instrument documentation is submitted to the accounting department

    within 72 hours of when the patron’s credit account records are updated.

    Wagering Accounts

    Note 1: A wagering account is established when a patron places funds on deposit for the purpose of using the funds for

    wagering activity in a gaming area other than slots through electronic wagering account transfers initiated by a

    patron. Slot wagering accounts are addressed in the Slots MICS.

    Note 2: MICS #34 - #43 also apply when a wagering account functions as a subsidiary account (or sub-account) of a

    patron’s master account with the transfers to/from other sub-accounts and the master account of the licensee

    considered in any reconciliations and summaries.

34. In order to facilitate a reconciliation, wagering accounts must be established at one designated area of accountability

    (e.g., main casino cage). Further, all subsequent deposits/withdrawals and account adjustments must be transacted

    through the same designated area of accountability.

    Note: MICS #34 does not require all patron transactions to be performed at the designated area of accountability (e.g.,

    deposits may be accepted at auxiliary cage and accountability is at the main cage).

35. For each wagering account established, an employee shall:

    a. Require the patron to personally appear at the licensee’s premises prior to the patron completing wagering account

    transactions.

    b. Examine, in the patron’s presence, the patron’s valid identification credential.

    c. Record:

    1) The patron’s name and signature.

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    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

    CAGE AND CREDIT

    2) Type of identification credential, credential number, expiration date of credential, and date credential was

    examined.

    Note: A patron’s driver’s license is the preferred method for verifying the patron’s identity. A passport, non-resident

    alien identification card, other government issued identification credential or another picture identification

    credential normally acceptable as a means of identification when cashing checks, may also be used.

    3) The dollar amount of the patron’s initial deposit.

    4) The patron’s wagering account number.

    5) The date the patron’s account is opened.

36. Procedures are in place to provide a secure method for a patron to access funds in a wagering account.

37. Prior to the patron making a cash withdrawal from a wagering account, the cashier must verify the identity of the patron

    and availability of funds in the wagering account.

38. A deposit/withdrawal is evidenced by at least a two-part document, with one part remaining in the cashier’s area and the

    other part given to the patron when a deposit or withdrawal is made. An adjustment to a patron’s wagering account is

    also documented and maintained.

39. The deposit/withdrawal/adjustment document contains the following information:

    a. For deposits and withdrawals, same document number on all copies.

    b. Patron’s name, account number, and signature (except adjustments to the wagering account do not require the

    patron’s signature).

    c. Date of deposit/withdrawal or account adjustment.

    d. Dollar amount of deposit/withdrawal or account adjustment.

    e. Nature of deposit/withdrawal (e.g. cash, check, chips).

    f. Reason for adjustment to wagering account, if applicable.

    g. Signature of employee handling the transaction.

40. Adjustments to wagering accounts are made by personnel authorized by management with such personnel’s job titles

    delineated within the cage and credit section of the written system of internal control pursuant to Regulation 6.090.

41. Procedures are established to maintain a detailed record for each patron’s wagering account that includes the dollar

    amount of all funds deposited and withdrawn specifically to or from the wagering account, account adjustments made,

    transfers to/from a master account or sub-account and the transfers to/from a gaming area. This record is available to the

    patron upon request.

42. The total of all wagering accounts are reconciled by employees of the designated area of accountability, as follows:

    a. For each shift, generate a system report that details the beginning and ending balance of wagering accounts,

    adjustments to wagering accounts, and the wagering account transfers to and from a gaming area.

VERSION 6 PAGE 7 OF 16 EFFECTIVE: 9/1/2008

    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

    CAGE AND CREDIT

b. Reconcile the ending and beginning balances (per the computer system) to the hard copy deposit/withdrawal

    documentation, account adjustment documentation, and the wagering account transfers to gaming areas (per the

    computer system).

43. All wagering account deposits/withdrawals, account adjustments, and wagering account transfers to/from gaming areas

    are summarized in total on an accountability form on at least a per shift basis.

Customer Deposits

Note: MICS #44 - #46 regarding customer deposits apply when a patron places funds on deposit for safekeeping

    and/or front money purposes. These MICS also apply when transfers are made from such deposit account to a

    wagering account resulting in the funds being transferred to a gaming area for wagering purposes.

44. The receipt or withdrawal of a customer deposit is evidenced by at least a two-part document with one copy going to the

    customer and one copy remaining in the cage (or branch office).

45. Each of the two parts of the sequentially-numbered receipt contains the following information:

a. Same receipt number on all copies.

    b. Customer’s name and signature.

c. Date of deposit/withdrawal.

d. Dollar amount of deposit/withdrawal. For foreign currency transactions in a branch office, the name of the foreign

    country, the amount of the foreign currency by denomination and its U.S. dollar equivalent is also documented.

e. Nature of deposit/withdrawal (e.g., cash, check, chips).

f. For a branch office deposit/withdrawal, branch office location where the deposit/withdrawal was transacted.

    g. Employee’s name and signature who conducted the transaction.

46. Procedures are established to:

a. Maintain a detailed record by patron name and date of all funds on deposit.

b. Maintain a current balance of all customer deposits which are in the cage/vault (or branch office) inventory or

    accountability.

c. Reconcile this current balance with the deposits and withdrawals at least daily.

Safe Deposit Boxes

Note: It is recommended, but not mandatory, that the following procedures for maintaining accurate records on the

    issuance and closure of safe deposit boxes also be adhered to in non-gaming areas of the licensee’s

    establishment (e.g., hotel front desk).

47. The issuance and closure of a patron’s safe deposit box in the casino cage or in other gaming areas of the licensee’s

    establishment is evidenced by a document that includes the following information:

a. Safe deposit box number.

    VERSION 6 PAGE 8 OF 16 EFFECTIVE: 9/1/2008

    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

     CAGE AND CREDIT

    b. Date of issuance and closure.

    c. Patron’s name and signature.

    d. Type of identification credential, credential number, expiration date of credential, and date credential was examined.

    Note 1: A patron’s driver’s license is the preferred method for verifying the patron’s identity. A passport, non-resident

    alien identification card, other government issued identification credential or another picture identification

    credential normally acceptable as a means of identification when cashing checks, may also be used.

    Note 2: For patrons that have an active established credit limit pursuant to MICS #1, examining the patron’s

    identification credential is not required if another method is used to ensure the patron’s identity. In such a case,

    “Account on file” is recorded as the type of identification credential examined.

    e. Employee’s name and signature that issued or closed safe deposit box.

48. Procedures are established to maintain a detailed record of all casino safe deposit boxes and the current status of each

    box (e.g., issued, not issued).

    Cage/Vault Accountability

49. All transactions that flow through the casino cage are summarized on a cage accountability form for each of the cage’s

    shifts.

50. Increases and decreases to the total cage inventory are supported by documentation. For any individual

    increase/decrease which exceeds $100, the documentation indicates the date and shift, the purpose of the

    increase/decrease, the person(s) completing the transaction, and for decreases indicate the person or department receiving

    the cage funds.

51. For owner/licensed key employee personal funds stored in the cage/vault (including funds stored in a restricted manner,

    e.g., locked safe), detailed documentation is maintained accounting for such funds regardless of whether the funds are

    included in the cage’s accountability.

52. The cage and vault inventories (including coin rooms/vaults) are counted by at least two persons, attested to by signature,

    and recorded in ink or other permanent form at the end of each shift during which activity took place (at least once

    daily). Such documentation is to include the date and shift for which the count was performed.

53. All net changes in outstanding casino accounts receivables, including all returned checks, are summarized on a cage

    accountability form or similar document on a per shift basis.

54. Such information is summarized and posted to the accounting records on at least a monthly basis.

    Promotional Payouts, Drawings and Giveaway Programs

    Note: MICS #55 - #57 apply to any payout (including the disbursement of non-negotiable chips) resulting from a

    promotional payout, drawing, or giveaway program (e.g., paycheck wheels) disbursed by the cage department

    or any other department, inclusive of programs that involve more than one department but exclusive of

    programs that have been addressed in the MICS for other departments. The promotional payout, drawing or

    giveaway programs applicable to these MICS are associated with gaming activity or a promotional scheme to

    encourage the patron to participate in gaming activity.

VERSION 6 PAGE 9 OF 16 EFFECTIVE: 9/1/2008

    STATE OF NEVADA

    GAMING CONTROL BOARD

    MINIMUM INTERNAL CONTROL STANDARDS

     CAGE AND CREDIT

55. The conditions for participating in promotional payouts, including drawings and giveaway programs, are prominently

    displayed or available for patron review at the licensed location.

56. Promotional payouts, including those as a result of drawings and giveaway programs, that are either deducted from gross

    gaming revenue, or are greater than or equal to $500 and not deducted from gross gaming revenue, are documented at the

    time of the payout to include the following:

    a. Date and time.

    b. Dollar amount of payout or description of personal property (e.g., car).

    c. Reason for payout (e.g., promotion name).

    d. Signature(s) of the following number of employees verifying, authorizing, and completing the promotional payout

    with the patron:

    1) Two employee signatures for all payouts of $100 or more that are deducted from gross gaming revenue;

    Note: For approved computerized systems that validate and print the dollar amount of the payout on a computer-

    generated form, only one employee signature is required on the payout form.

    2) One employee signature for payouts of less than $100 that are deducted from gross gaming revenue; or

    3) One employee signature for payouts of $500 or more that are not deducted from gross gaming revenue.

    e. Patron’s name (for drawings only).

    Note: MICS #56 documentation may be prepared by an individual who is not a cage department employee as long as

    the required signatures are those of the employees completing the payout with the patron.

57. If the promotional cash (or cash equivalent) payout, including those as a result of drawings and giveaway programs, is

    less than $500 and is not deducted from gross gaming revenue, documentation is created to support bank accountability.

    Note: Required documentation may consist of a line item on a cage accountability document (e.g., 43 $10 cash

    giveaway coupons = $430).

    Accounting/Audit Standards

    Note: The term “casino accounts receivable”, as used in these Cage and Credit MICS, includes any item (including

    returned checks) for which an adjustment to gross gaming revenue is made on the NGC tax returns.

58. The cage accountability is reconciled to the general ledger at least monthly.

59. A listing of all casino accounts receivable, including the name of patron and current balance, is prepared at least monthly

    for active, inactive, settled/discounted or written-off accounts. (A listing of written-off items, i.e., worthless items at the

    time of write-off, and another listing of payments on items previously written-off are acceptable.)

60. Reclassification of an unpaid balance between the various casino accounts receivable listings (e.g., changing an account

    from active to write-off status) must not be reflected as a credit adjustment on the NGC tax returns.

61. The listing of all casino accounts receivable is reconciled to the general ledger each month.

VERSION 6 PAGE 10 OF 16 EFFECTIVE: 9/1/2008

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