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    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist CAGE AND CREDIT

Licensee Review Period

    NGC Regulation 6.090(9) requires the CPA to use “criteria established by the chairman” in determining whether a Group I licensee is in compliance with the Minimum Internal Control Standards (MICS). This checklist is to be used by the CPA in determining whether the licensee’s cage and credit operations are in compliance with the Cage and Credit MICS.

    Date of Inquiry Person Interviewed Position

Checklist Completion Notes:

    1) Unless otherwise instructed, examine a completed document for compliance for those questions referring to

    records/documentation as indicated and recalculate where appropriate. Indicate (by tickmark) whether the procedures were

    confirmed via examination/review of documentation, through inquiry of licensee personnel or via observation of procedures.

    Tickmarks used are to be defined at the bottom of each page.

2) All "no" answers require referencing and/or comment, and should be cited as regulation violations, unless the Board Chairman

    has granted a MICS variation or the question requires a "no" answer for acceptability.

3) "(#)" refers to the Minimum Internal Control Standards for Cage and Credit, Version 5.

Minimum Internal Control Standard Notes (paraphrased from the standards)

    Note 1: For the purpose of completing this checklist, classify the licensee into one of two categories. A “Category A” licensee is a

    licensee whose “Collections in Areas Other than the Pit” on the NGC-1’s for the 12 months ended June 30 exceeds $10 million. A

    “Category B” licensee is a licensee whose “Collections in Areas Other than the Pit” on the NGC-1’s are less than or equal to $10 million. All questions must be completed for “Category A” licensees including, if applicable, procedures for branch offices. Questions 12, 25, 31-33 and 62 (MICS #’s 5, 18, 24-26 and 54) do not apply to “Category B” licensees and should be marked as

    “N/A.” The term licensee includes race and sports books who cash checks for patrons.

State Licensee’s Category: _____________________

    Note 2: The definition of categories A and B above are intended to apply only to those licensees who have pit credit and/or list credit adjustments on their NGC-1’s. If a licensee has no pit credit and makes no adjustments for returned checks or cage credit on their NGC-1’s, only questions 1, 2-7, 23-24, 42-49, 55, 66-69 and 74-80 (MICS #’s 16-17, 35-48, 58-61 and 66-70) apply.

    Note 3: These standards represent the minimum acceptable credit procedures applicable to race and sports, slots, keno, bingo and the cage departments. The requirements of Regulation 6.120 must also be met if credit issuances are to be excluded from gross gaming revenue.

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 1 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

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

    of control described by these standards will be acceptable. Such alternate documentation and/or procedures must be described in

    detail as to their acceptability.

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

    money wagering transactions and cash deposit/withdrawal (CDW) transactions.

    Questions Yes No N/A Comments, W/P Reference

    1. Has the licensee’s written system of internal control for cage and

    credit been read prior to the completion of this checklist to obtain

    an understanding of the licensee’s cage and credit operation?

     Cage/Vault Accountability

    2. Are all transactions that flow through the casino cage

    summarized on a cage accountability form on a per shift basis?

    (40) Verify by examination.

    3. Are increases and decreases to the cage inventory supported by

    documentation? (41) Verify by examination.

    4. For any individual increase/decrease which exceeds $100, does

    the documentation indicate the date and shift, the purpose of the

    increase/decrease, the person(s) completing the transaction, and

    for decreases an indication of the person or department receiving

    the cage funds? (41) Verify by examination.

    5. Are the cage and vault inventories (including coin rooms/vaults)

    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 and does such documentation

    include the date and shift for which the count was performed?

    (42)

    Note: The above procedure must be performed at least once

    daily even if no activity took place in a specific area of

    accountability. (42)

    6. Are all net changes in outstanding casino accounts receivables,

    including all returned checks, summarized on a cage

    accountability form or similar document on a per shift basis?

    (43) Verify by examination.

    7. Is the information mentioned in the preceding question

    summarized and posted to the accounting records on at least a

    monthly basis? (44) Verify by examination.

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 2 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

    Questions Yes No N/A Comments, W/P Reference

     Approval and Issuance of Credit

Note: A counter check is a form provided by the licensee that is

    completed as is necessary for the instrument to be presented to the

    patron’s bank for payment. (1, Note 2)

Testing of patron credit accounts is required. Select 10 patron

    credit accounts and examine the documentation evidencing the

    authorization to establish a credit limit or to issue credit.

    8. Is at least the following information 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 exclude personal checks, payroll

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

Note: The information required by “a” through “e” below is

    documented prior to the issuance of credit in any amount. (1,

    Note 1)

    a) The patron’s name, current address, and signature? (1a) b) The type of identification credential, credential number,

    expiration date of credential, and date credential was

    examined? (1b)

    Note: A driver’s license is the preferred method for

    verifying the patron’s identity. A passport, non-resident

    alien identification card, or other government issued

    identification credential or another picture identification

    credential normally acceptable as a means of identification

    when cashing checks, may also be used. (1b)

    c) Documentation of credit worthiness using a method

    permissible under Regulation 6.120(2)(a)? (1c)

    d) Authorized credit limit? (1d) e) Signature/initials of the individual(s) designated by

    management to approve credit limits? (1e)

    Note: For computerized systems, a credit limit approval

    controlled through system passwords is acceptable. (1e)

    f) Date, time and amount of credit issuances and payments?

    (1f)

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 3 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

    Questions Yes No N/A Comments, W/P Reference

    g) Amount of available credit? (1g) 9. Prior to the issuance of gaming credit to a patron, does the employee issuing the credit perform the following:

    a) Determine whether the credit limit is properly authorized?

    (2a)

    b) Determine whether the available credit is sufficient to cover

    the issuance? (2b)

    c) Verify the patron’s identity by examining the patron’s

    identification credential (except for patrons that are known)?

    (1c)

    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 other picture identification

    credential normally acceptable as a means of identification,

    may also be used. (2c)

    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 be

    compared to the copy of the patron’s picture identification (if

    applicable) and signature that were obtained when the

    patron’s credit account was established. (2c)

    10. Are credit limits over a specified dollar amount approved by personnel designated by management? (3) State the amount(s)

    and designated personnel.

    11. Is proper approval for the increase of credit limits of over 10 percent of the previously established credit limit or $1,000,

    whichever is greater, documented? (4) State who may

    authorize these limits.

    12. Are the job functions of credit approval (i.e., establishing the patron’s credit worthiness) and credit issuance segregated if pit or

    cage credit issuances to a single patron of $10,000 or more per

    day are transacted? (5)

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 4 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

    Questions Yes No N/A Comments, W/P Reference

    13. If cage markers and/or counter checks are issued to a single

    patron in an amount exceeding $3,000, are applicable gaming

    personnel notified on a timely basis of the patron’s playing on

    cage credit, the applicable amount of credit issued, and the

    available balance? (6)

    Note: This can be accomplished through the use of a

    computerized credit system that automatically updates a patron’s

    account after every issuance.

    14. Are cage marker forms 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? (7) Verify by examination.

    15. Does the original cage marker contain the marker number, the

    patron’s name and signature, the amount of credit issued (both

    alpha and numeric), and the signature or initials of the cashier,

    unless this cashier information is included on another document?

    (8) Verify by examination.

    16. Does the payment slip include the same marker number as the

    original, the date and time of payment, the amount of payment,

    the nature of settlement (cash, chips, etc.), and the signature or

    initials of the cashier receiving the payment, unless this cashier

    information is included on another document? (9) Verify by

    examination.

    17. When counter checks are issued, does the check include the

    patron’s name and signature, the dollar amount of credit issued

    (both alpha and numeric), and the signature or initials of the

    cashier, unless this cashier information is included on another

    document? (10a-c) Verify by examination.

    18. Do voided marker contain the word “void” written across all

    parts of the marker along with the reason for the void, the date

    and time of void, and the signature or initials of the cashier and a

    cage department supervisor? (11a-c) Verify by examination.

    19. Is the marker voiding process completed no later than thirty

    minutes after the issuance of the marker unless the reason for

    exceeding this time period is documented? (12)

    20. For computer-generated markers, is the patron’s computer

    account updated to reflect the voided marker transaction? (13)

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 5 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

    Questions Yes No N/A Comments, W/P Reference

    21. Are all parts of the voided marker submitted to the accounting

    department for retention and accountability? (14) Verify by

    examination.

    22. Are pit markers prohibited from being voided by cage personnel?

    (15)

    23. If personal checks, cashier’s checks, or payroll checks are cashed,

    does the cage cashier:

    a) Examine and record at least one item of patron identification

    (e.g., driver’s license)? (16a)

    b) For personal checks, verify the patron’s credit worthiness

    pursuant to Regulation 6.120(2)(a) and record the

    verification source and results on the check? (16b) Verify

    by examination of one check the recording of the

    verification source and results.

    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” is recorded as

    the verification source and results. (16b)

    c) For payroll checks, make a reasonable effort to verify

    business authenticity? (16c)

    d) Make a reasonable effort to verify the authenticity of

    cashier’s checks for amounts over $1,000? (16d)

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, then “a” through “d” above do not apply. (16d)

    24. When traveler’s checks/guaranteed drafts are presented, are all

    required issuance and acceptance procedures adhered to by the

    drawee and cage personnel? (17)

     Testing of documentation for outstanding credit instruments is

    required. Select two outstanding credit instruments transferred

    to branch offices per day for 2 days. Test days must be in non-

    consecutive months. Indicate test dates selected and results of

    testing.

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 6 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

    Questions Yes No N/A Comments, W/P Reference

    25. If outstanding credit instruments are transferred to branch offices,

    collection agencies, or other collection representatives, is a copy

    of the credit instrument and a receipt from the collection

    representative obtained and maintained until such time as the

    credit instrument is returned or payment is received? (18)

    26. If outstanding credit instruments are transferred to a law

    enforcement agency (e.g., district attorney’s office), is a copy of

    the credit instrument and documentation from the law

    enforcement agency maintained stating that the original credit

    instrument is in their possession? (19)

    27. Is a detailed listing maintained to document all outstanding credit

    instruments that have been transferred to other offices? (20)

    28. Is the listing mentioned in the previous question prepared or

    reviewed and signed by an individual independent of credit

    transactions and collections thereon? (21)

     Payment Standards

    29. Are all payments received on outstanding credit instruments

    permanently recorded in the licensee’s records and at the branch

    office, if applicable? (22) Verify by examination.

     Testing of partial payment receipts is required. Select 3 multi-

    part partial payment receipts per day for 2 days. Test days must

    be in non-consecutive months. Indicate test dates selected and

    results of testing.

30. When partial payments are made on credit instruments, including

    personal checks, payroll checks and cashier’s checks, and the

    original instruments are not replaced with a marker for the

    remaining balance, are they evidenced by a multi-part receipt (or

    another equivalent document) which contains the following:

    a) The same receipt number on all copies? (23a)

    b) Patron’s name? (23b)

    c) Date of payment? (23c)

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

    chips, etc.)? (23d)

    e) Signature or initials of individual receiving payment? (23e)

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 7 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

    Questions Yes No N/A Comments, W/P Reference

    f) Number of credit instrument on which payment is being

    made? (23f)

    Note: The following three questions do not apply if account balances are routinely 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. (Note after

    MICS #23f)

    31. Are mail payments received by a department independent of the

    credit instrument custody and collection functions? (24) State

    the department.

     Testing of mail payment listings re is required. Select one mail

    payment listing per day for 2 days. Test days must be in non-

    consecutive months. Indicate test dates selected and results of

    testing.

32. Are mail payments documented on a listing that contains the

    name of patron’s account that the payment is being applied to, the

    name of the individual making the payment, if different than the

    patron, the amount of the payment, the nature of payment (if

    other than a check), and the date the payment was received?

    (25a-d)

    33. Is the total amount of the listing of mail receipts required per the

    standard mentioned in the previous question reconciled with the

    total mail receipts recorded on the appropriate accountability by

    the accounting department on a random basis for at least 3 days

    per month? (26)

     Access to Credit Documentation

    34. Is access to credit information restricted to those positions which

    require access and are so authorized by management? (27) State

    the positions.

    35. Is access to outstanding credit instruments restricted to persons

    authorized by management? (28) State the positions.

    36. Is access to written-off credit instruments further restricted to

    individuals specified by management? (29) State the

    individuals/positions.

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 8 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

    Questions Yes No N/A Comments, W/P Reference

     Documentation

    37. Are all issuances of cage credit, pit credit transferred to the cage

    and subsequent payments documented on a credit instrument

    control document by cage personnel? (30) Verify by

    examination.

    38. Are records of all correspondence, transfers to and from outside

    agencies, and other documents related to issued credit

    instruments maintained? (31) Verify by examination.

     Write-off and Settlement Standards

     Testing of write-off and settlement documents is required. Select

    2 write-off and 2 settlement documents. Include a copy of the

    documents in the workpapers along with the results of testing.

    39. Are written-off or settled credit instruments authorized in

    writing? (32)

    40. Are written-off or settled credit instrument approvals made by at

    least two management officials, other than branch office

    personnel, and do the individuals approving the write-off or

    settlement sign a document indicating their authorization? (33)

    Note 1: At least one of the management individuals must be

    independent of the initial credit limit approval process, and the

    issuance and collection of credit relative to the patron’s account.

    (33)

    Note 2: The job titles of management personnel designated to

    review and grant such approvals are included in the cage and

    credit section of the written system of internal control pursuant to

    Regulation 6.120(6)(b). (33)

    41. Is the completed written-off and settled credit instrument

    documentation submitted to the accounting department within 72

    hours of completion? (34)

     Customer Deposits

     Testing of customer deposits is required. Select 2 documents

    evidencing the receipt or disbursement of customer deposits per

    day for 2 days. Test days must be in non-consecutive months.

    Indicate test dates selected and results of testing.

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 9 of 21

    State of Nevada

    Gaming Control Board Auditor’s Name and Date

    CPA MICS Compliance Checklist

     CAGE AND CREDIT

    Licensee Review Period

    Questions Yes No N/A Comments, W/P Reference

    42. Are receipts or withdrawals of customer deposits evidenced by at

    least a two-part document with one copy going to the customer

    and one copy remaining in the cage file? (35)

    43. Does the multi-receipt mentioned in the previous question

    contain the following:

    Note: Provided all of the information in “a” through “e” below is

    available, the only required information for all copies of the

    receipt is the receipt number. (36)

    a) The same receipt number on all copies? (36a)

    b) The customer’s name and signature? (36b)

    c) The date of deposit/withdrawal? (36c)

    d) The dollar amount of deposit/withdrawal? (36d)

    e) The nature of the deposit/withdrawal (e.g., cash, check,

    chips)? (36e)

    44. Are procedures established to:

    a) Maintain a detailed record by patron name and date of all

    funds on deposit? (37a)

    b) Maintain a current balance of all customer deposits which

    are in the cage/vault inventory or accountability? (37b)

    c) Reconcile this current balance with the deposits and

    withdrawals at least daily? (37c)

     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).

     Testing of safe deposit box documentation is required. Select 2

    documents evidencing the issuance and closure of safe deposit

    boxes per day for 2 days. Test days must be in non-consecutive

    months. Indicate test dates selected and results of testing.

     Verified per representation

     Verified per observation/examination

     VERSION 4

     EFFECTIVE: January 21, 2004 Page 10 of 21

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