La. Admin. Code tit. 42 § III-2717

Current through Register Vol. 50, No. 6, June 20, 2024

Section III-2717 - Internal Controls; Table Games

A. Table Games Fill and Credit Slip Requirements (computerized and manual)

1. Each licensee and casino operator shall utilize fill and credit slips to document the transfer of chips and tokens to and from table games. Fill and credit slips shall, at a minimum, be in triplicate form, in a continuous numerical series, pre-numbered or numbered by the computer in a form utilizing the alphabet and only in one series at a time. The alphabet need not be used if the numerical series is not repeated during the business year. All table game fill and credit slips shall be safeguarded in their distribution, use, and control as follows.

a. Each slip shall be clearly and correctly marked "Fill" or "Credit," whichever applies, and shall contain the following:

i. date and time of transaction;

ii. shift;

iii. table number;

iv. game type;

v. amount of fill or credit by denomination and in total;

vi. sequential slip number (manual slips may be issued in sequential order by location); and

vii. identification code of the requestor, in stored data.

b. All fill slips shall be distributed as follows.

i. One part shall be deposited in the table drop box by the dealer/boxperson. The part that is placed in the drop box shall be of a different color for fills than that used for credits or other manner approved by the division.

ii. One part shall be retained in the cage for reconciliation of the cashier bank.

iii. One part shall be forwarded to accounting or retained internally within the computer. This copy shall be known as the "restricted copy" and shall not be accessible to cage or pit employees. The stored data shall not be susceptible to change or removal by cage or pit personnel after preparation of a fill, with the exception of voids. Only accounting shall have access to the restricted copies of the fill slips.

c. All credit slips shall be distributed as follows.

i. One part shall be retained in the cage for reconciliation of the cashier bank.

ii. One part shall be deposited in the table drop box by the dealer/boxperson. The part that is placed in the drop box shall be a different color for credits than that used for fills or other manner approved by the division.

iii. One part shall be forwarded to accounting or retained internally within the computer. This copy shall be known as the "restricted copy" and shall not be accessible to cage or pit employees. The stored data shall not be susceptible to change or removal by cage or pit personnel after preparation of a credit, with the exception of voids. Only accounting shall have access to the restricted copies of the credit slips.

2. Processed slips shall be signed by the following individuals to indicate that each has counted the amount of the fill or credit and the amount agrees with the slip:

a. cashier who prepared the slip and issued the fill or received the credit transferred from the pit;

b. runner, who shall be a gaming employee independent of the transaction, who carried the chips, tokens, or monetary equivalents to or from the table. This count shall be performed prior to transferring chips, tokens, or equivalents;

c. dealer/boxperson who received the fill or had custody of the credit prior to the transfer; and

d. pit supervisor who supervised the fill or credit.

3. Fill and credit slips that are voided shall be clearly marked "Void" across the face of all non-restricted copies. The cashier shall print his employee number and sign his name on the voided slip. A brief statement of why the void was necessary shall be written on the face of the copies. The pit or cage supervisor who approves the void shall print his employee number and sign his name and shall print or stamp the date and time the void is approved. All copies shall be forwarded to accounting on a daily basis.

4. Access to slips and slip processing areas shall be restricted to authorized personnel.

a. All unissued, pre-numbered fill and credit slips shall be securely stored under the control of the accounting or security department.

b. All unissued pre-numbered fill and credit slips shall be controlled by a log. Monthly, the accounting department shall reconcile the log to purchase invoices for these slips.

5. The accounting department shall account for all slips daily and investigate all missing slips within 10 days. The investigation shall be documented and the documentation retained for a minimum of five years.

B. Computerized Table Fill Transactions

1. Computerized table fill transactions shall be:

a. initiated by a pit supervisor and the order acknowledged by a cage cashier prior to the issuance of a fill slip and transportation of the chips, tokens, and monetary equivalents. The pit supervisor or pit clerk shall process the order for fill by entering the following information into the computer:

i. date and time of transaction;

ii. shift;

iii. table number;

iv. game type;

v. amount of fill by denomination and in total; and

vi. identification code of preparer;

b. transported and deposited on the table only when accompanied by a completed fill slip;

c. transported from the cage by a gaming employee independent of the transaction. This must be the employee who signs as the runner;

d. broken down or verified by the dealer/boxperson in public view before the dealer/boxperson places the fill in the tray;

e. acknowledged by the pit clerk or cage personnel by computer upon completion of the fill; and

f. finalized by the cage cashier who shall complete the transaction by computer entry.

C. Cross-fills

1. Cross-fills between tables are prohibited.

D. Computerized Table Credit Transactions

1. Computerized table credit transactions shall be:

a. initiated by a pit supervisor and the order acknowledged by a cage cashier prior to the issuance of a credit slip and transportation of the chips, tokens, and monetary equivalents. The pit supervisor or pit clerk shall process the order for credit by entering the following information into the computer:

i. date and time of transaction;

ii. shift;

iii. table number;

iv. game type;

v. amount of credit by denomination and in total; and

vi. identification code of preparer;

b. broken down or verified by the dealer/boxperson in public view before the dealer/boxperson places the credit in racks for transfer to the cage;

c. transacted and transferred from the table to the cage only when accompanied by a completed credit slip;

d. transported from the table by a gaming employee independent of the transaction. This must be the employee who signs as the runner;

e. acknowledged by the pit clerk or cage personnel by computer upon completion of the credit; and

f. finalized by the pit clerk or cage cashier who shall complete the transaction by computer entry.

E. Alternate Internal Controls for Non-Computerized Table Games Transactions

1. For any non-computerized table games systems, alternate documentation and procedures which provide at least the level of control required by the standards in this Section for fills and credits will be acceptable. Such procedures must be enumerated in the internal controls.

F. Table Games Inventory Procedures

1. All table game inventories shall be counted each gaming day simultaneously by a dealer/boxperson and a pit supervisor, or two pit supervisors. The count shall be conducted at the end of the gaming day, except for tables which are counted and closed before the end of the gaming day. These tables do not have to be recounted at the end of the gaming day if they remained closed. At the beginning and end of each gaming day, each table's chip, token, and coin inventory shall be counted and recorded on a table inventory form. Tables which have remained closed after crediting the entire inventory back to the cage will be exempt from conducting a daily count; however, the zero balance shall be documented in the table games paperwork for each day that they maintain a zero balance.

2. Table inventory forms shall be prepared, verified and signed by the individuals conducting the count.

3. If the table banks are maintained on an imprest basis, a final fill or credit shall be made to bring the bank back to the imprest amount.

4. If final fills are not made, beginning and ending inventories shall be recorded on the master game sheet for win calculation purposes.

5. Table inventory forms shall be placed in the drop box by someone other than a pit supervisor.

G. Credit Procedures in the Pit

1. Prior to the issuance of gaming credit to a player, the employee extending the credit shall determine if credit is available.

2. Proper authorization to extend credit in excess of the previously established limit shall be documented.

3. Issuance of credit shall be documented by the creation of a marker slip, which is a formal record of the credit transaction.

4. Marker preparation shall be initiated and other records updated within two hands of play following the initial issuance of credit to the player.

5. All credit extensions shall be initially evidenced by marker buttons representing the amount of credit extended, which shall be placed by pit supervisory personnel on the table in public view.

6. Marker buttons shall be removed only by the dealer or boxperson employed at the table upon completion of a marker transaction.

7. The marker slip shall, at a minimum, be in triplicate form, pre-numbered or numbered by the printer, and utilized in numerical sequence. Manual markers may be issued in numerical sequence by location. The three parts shall be utilized as follows:

a. the original slip shall be maintained in the pit until paid or transferred to the cage;

b. the payment slip shall be sent to the cage accompanied by the original and a transfer slip, or maintained in the pit until:

i. the marker is paid, including partial payments, at which time it shall be placed in the drop box;

ii. the end of the gaming day, at which time it shall be sent to the cage accompanied by the original and a transfer slip;

c. the issue slip shall be inserted into the appropriate table drop box when credit is extended or when the player has signed the original.

8. The original slip shall include the following information:

a. marker number;

b. player's name and signature;

c. date; and

d. amount of credit issued.

9. The issue slip shall include the same marker number as the original slip, the table number, date and time of issuance, and amount of credit issued. The issue slip also shall include the signature of the individual extending the credit and the signature or initials of the dealer at the applicable table, unless this information is included on another document verifying the issued marker.

10. The payment slip shall include the same marker number as the original. When the marker is paid in full in the pit, it shall also include the table number where paid, date and time of payment, manner of payment such as cash or chips and amount of payment. The payment slip shall also include the signature of a pit supervisor acknowledging payment and the signature or initials of the dealer/boxperson receiving payment, unless this information is included on another document verifying the payment of the marker.

11. The pit shall notify the cage by computer when the transaction is completed. The cage or another independent source shall update the patron's credit record within a reasonable time, in accordance with the internal controls, subsequent to each issuance.

12. Voided markers (computer-generated and manual) shall be clearly marked "Void" across the face of all copies. The supervisor who approves the void shall print their employee number and sign their name, print or stamp the date and time the void is approved, and print the reason for the void. All copies of the voided marker shall then be forwarded to accounting and retained for a minimum of five years.

13. Marker documentation shall be inserted in the drop box by the dealer/boxperson at the table.

14. When partial payments are made in the pit, a new marker shall be completed which shall note the remaining balance and the number of the original marker.

15. When partial payments are made in the pit, the payment slip of the original marker shall be properly cross-referenced to the new marker number and inserted into the drop box.

16. The cashier's cage or another independent source shall be notified when payments, full or partial, are made in the pit so credit records can be updated for such transactions. Notification shall be before the patron's play is completed or at shift end, whichever is earlier.

17. All portions of markers, both issued and unissued, shall be safeguarded and procedures shall be employed to control the distribution, use and access to the forms.

18. The accounting department shall investigate the loss of any part of a numbered marker form immediately upon discovery of the missing part. Accounting shall be notified immediately when another department discovers part of a numbered marker form is missing. The investigation is to determine the cause and responsibility for the lost form. The results of the investigation shall be documented and maintained for five years. The licensee or casino operator shall notify the division in writing of the loss, disappearance or failure to account for marker forms within 10 days of such occurrence.

19. When markers are transferred to the cage, marker transfer slips shall be utilized and such documents shall include, at a minimum, the date, time, shift, marker number(s), table number(s), amount of each marker, the total amount transferred, and the signature of pit supervisor releasing instruments from the pit.

20. Markers shall be transported to the cashier's cage by an individual who is independent of the marker issuance and payment functions. Pit clerks may perform this function.

21. Marker log documentation shall be maintained by numerical sequence, indicating marker number, name of patron, date marker issued, date paid, manner of payment, if a combination of payment methods, the amount paid by each method, and amount of credit remaining.

H. Non-marker Credit Play

1. Non-marker credit play shall be prohibited except as provided in this Section.

2. Prior to accepting credit instruments, except traveler's checks, from a player, the employee extending the credit shall contact the cashier or another independent source to determine if the player's credit limit has been properly established and the remaining credit available is sufficient for the advance.

3. All credit instruments shall be transferred to the cashier's cage immediately following the acceptance of the instrument and issuance of chips.

4. An order for credit shall be completed and include the patron's name and amount of the credit instrument in addition to the information required for a standard table credit.

5. The acceptance of payments in the pit for non-marker credit instruments is strictly prohibited.

6. All non-marker credit play shall be evidenced by the placement of a lammer, a button with numbers representing the total amount of credit provided, or other item in the amount equal to the wager.

7. The pit supervisor shall place the lammer in the wagering area of the table only after the supervisor's specific authorization.

8. Non-marker credit extensions shall be settled at the end of each hand of play by the preparation of a marker or payoff of the wager.

9. There shall be no other extension of credit without a marker.

I. Call Bets

1. Call bets shall be prohibited. A call bet is a wager made without chips, tokens, or cash.

J. Table Games Drop Procedures

1. The drop process shall be conducted at least once each gaming day according to a schedule submitted to the division setting forth the specific times for such drops. Each licensee and casino operator shall notify the division of any changes to such schedules at least five days prior to implementing a change to this schedule, except in emergency situations. Emergency drops, which require removal of the table drop box, require written notification to the division within 24 hours following the emergency drop. The drop process shall be conducted as follows:

a. All locked drop boxes shall be removed from the tables by an individual independent of the pit. Surveillance shall be notified when the drop process begins. The entire drop process shall be recorded by surveillance. At least one surveillance employee shall monitor the drop process at all times. This employee shall record on the surveillance log the times that the drop process begins and ends, and any exceptions or variations to established procedures observed during the drop including each time the count room door is opened.

b. Upon removal from the tables, the drop boxes are to be placed in a drop box storage rack and locked therein for transportation directly to the count area or other secure place approved by the division and locked in a secure manner until the count takes place.

c. The transporting of drop boxes shall be performed by a minimum of two individuals, at least one of whom is a security officer.

d. Access to all drop boxes regardless of type, full or empty, shall be restricted to authorized members of the drop and count teams.

K. Table Games Count Procedures. The counting of table game drop boxes shall be performed by a soft count team with a minimum of three persons. Count tables shall be transparent to enhance monitoring. Surveillance shall be notified when the count process begins and the count process shall be monitored in its entirety and recorded by surveillance. At least one surveillance or internal audit employee shall watch the entire count process on at least two days per month that shall be randomly selected. Surveillance shall record on the surveillance log any exceptions or variations to established procedures observed during the count. Surveillance shall notify count team members immediately if surveillance observes the visibility of hands or other activity is consistently obstructed in any manner. Testing and verification of the accuracy of the currency counter shall be conducted and documented quarterly. This test shall be witnessed by someone independent of the count team members.

1. Count team members shall be:

a. rotated on a routine basis. Rotation is such that the count team does not consist of only the same three individuals more than four days per week; and

b. independent of transactions being reviewed and counted and the subsequent accountability of soft drop proceeds.

2. Soft count shall be performed daily and include:

a. a test count of the currency counter prior to the start of each count;

b. the emptying and counting of each drop box individually;

c. the recordation of the contents of each drop box on the count sheet in ink or other permanent form prior to commingling the funds with funds from other boxes;

d. the display of empty drop boxes to another member of the count team or to surveillance;

e. the comparison of table numbers scheduled to be dropped to a listing of table numbers actually counted to ensure that all table game drop boxes are accounted for during each drop period;

f. the correction of information originally recorded by the count team on soft count documentation by crossing out the error, entering the correct figure, and then obtaining the initials of at least two count team members who verified the change;

g. the signatures of all members of the soft count team on the count sheet attesting to the accuracy of table games drop after the count sheet has been reconciled to the currency;

h. the transfer of all monies and monetary equivalents that were counted to the cage cashier who is independent of the count team or to an individual independent of the revenue generation and the count process for verification. This individual certifies by his signature the accuracy of the monies delivered and received from the soft count team. If a pass-through window between the count room and the vault is not utilized, monies shall be transferred in a locked transport cart; and

i. the delivery of the count sheet, with all supporting documents, promptly to the accounting department by a count team member. Alternatively, it may be adequately secured (e.g., locked in a container to which only accounting personnel can gain access) until retrieved by the accounting department.

3. Access to the count room during the count shall be restricted to members of the drop and count teams, division agents, authorized observers as approved by the division and supervisors for resolution of problems. Access shall be further restricted unless three count team members are present. Authorized maintenance personnel shall enter only when accompanied by security.

4. Accounting shall perform the following functions:

a. match the original and first copy of the fill and credit slips;

b. match orders for fills and credits to the fill and credit slips;

c. examine fill and credit slips for inclusion of required information and recordation on the master gaming report;

d. trace or record pit marker issue and payment slips to the master gaming report by the count team, unless other procedures are in effect which assure that issue and payment slips were placed into the drop box in the pit;

e. examine and trace or record the opening and closing table and marker inventory forms to the master gaming report; and

f. review accounting exception reports for the computerized table games on a daily basis for propriety of transactions and unusual occurrences. Documentation of the review and its results shall be retained for five years.

L. Table Games Key Control Procedures

1. The keys used for table game drop boxes and soft count keys shall be controlled as follows.

a. Drop box release keys shall be maintained by a department independent of the pit department. Only the person authorized to remove drop boxes from the tables shall be allowed access to the release keys. Count team members may have access to the release keys during the soft count in order to reset the drop boxes. Persons authorized to remove the table game drop boxes are precluded from having access to drop box contents keys. The physical custody of the keys needed for accessing full drop box contents requires involvement of persons from three separate departments. The involvement of at least two individuals independent of the cage department is required to access empty drop boxes.

b. Drop box storage rack keys shall be maintained by a department independent of the pit department. Someone independent of the pit department shall be required to accompany such keys and observe each time drop boxes are removed from or placed in storage racks. Persons authorized to obtain drop box storage rack keys shall be precluded from having access to drop box contents keys with the exception of the count team.

c. Drop box contents keys shall be maintained by a department independent of the pit department. Only count team members are allowed access to the drop box contents keys. This control is not applicable to emergency situations which require drop box access at other than scheduled count times. At least three persons from separate departments, one of which shall be management, must participate in these situations. The reason for access must be documented with the signatures of all participants and observers.

d. The issuance of soft count room keys and other count keys shall be witnessed by two gaming employees who shall be from different departments. Neither of these two employees shall be members of the soft count team.

e. All duplicate keys shall be maintained and issued in a manner which provides the same degree of control over drop boxes as is required for the original keys.

M. Supervisory Controls

1. Pit supervisory personnel with authority equal to or greater than those being supervised shall provide supervision of all table games.

N. Table Games Records

1. Each licensee and casino operator shall maintain records and reports reflecting drop, win and drop hold percentage by table and type of game by day, cumulative month-to-date, and cumulative year-to-date. The reports shall be presented to and reviewed by management independent of the pit department on at least a monthly basis. The independent management shall investigate any unusual statistical fluctuations with pit supervisory personnel. At a minimum, investigations are performed for all statistical percentage fluctuations from the base level for a month in excess of plus or minus three percentage points. The base level is defined as the licensee's or casino operators statistical win to statistical drop percentage for the previous business year. The results of such investigations shall be documented in writing and maintained for at least five years by the licensee.

2. The division shall have access to all information pertaining to table games.

La. Admin. Code tit. 42, § III-2717

Promulgated by the Department of Public Safety and Corrections, Gaming Control Board, LR 38:1635 (July 2012), Amended LR 442014 (11/1/2018).

AUTHORITY NOTE: Promulgated in accordance with R.S. 27:15 and 24.