35 Miss. Code. R. 5-07-01-101 - Drop/Count Procedures

1.

a. Each licensee shall report to the Chairman of the MSTC and maintain on file the time(s) when drop boxes will be removed and the time(s) that the contents will be counted. All drop boxes must be removed and counted only at the time(s) previously designated to the Chairman. Removal and counting of drop box contents at other than the designated time is prohibited. If the licensee determines it necessary to change the time(s) of the drop or the count, then the licensee must provide advance notice to the MSTC of a change in times before implementing such change. If there is an unscheduled drop, the taxpayer/licensee must immediately notify the Chairman by facsimile to the Jackson office of the event detailing the reason, the date, and dollar amount involved. This requirement in no way implies approval for nonscheduled drops, but instead requires the taxpayer/licensee to inform the Chairman if one should occur as result of an unforeseen emergency.

b. The drop supervisor must notify surveillance when the drop is to begin in order that surveillance may monitor the activities. Surveillance is to record in a proper log or journal in a legible manner any exceptions or variations to established procedures observed during the drop. Such log or journal shall be available for review by an agent of the Chairman upon request.

c. The Chairman may, at his discretion, have an agent present to observe the drop or count. To gain entrance to the count room or to the surveillance room(s), the State Tax Commission employee shall present an official identification card containing a photograph issued by the commission.

2. Each licensee shall submit a list to the Chairman of the MSTC of employees authorized to participate in the count including those employees, as an example, the internal audit department employees or computer technicians and equipment maintenance personnel needed for problem resolution, who are authorized to be in the count room during the count ("count personnel list"). Each licensee shall submit a revised list to the Chairman immediately upon any change to the count personnel list. The count personnel list shall indicate those persons, if any, who hold an interest in the license and shall indicate what relationship by blood or marriage, if any, exists between any person on the count personnel list and any other person on such list or any interest holder or employee of the gaming establishment.

3.

a. The count of pit revenue is to be performed by a minimum of three (3) persons, at least two (2) of whom are independent of the pit department. Immediately prior to entering the count room a member of the team shall notify surveillance that the count is about to begin. Surveillance shall make a video recording of the entire process and such tape shall be maintained for at least thirty (30) days. Surveillance is required to record in writing in a legible manner any exceptions or variations to established procedures noted in their observation of the count procedures. Said record shall be available for review by an agent of the Chairman upon request.

b. The work schedules of count team personnel must be regularly rotated and their functions regularly rotated. All personnel must wear a one piece pocketless garment with openings only for the arms, feet and neck. Such garment may include a jumpsuit or smock, as determined by the licensee. Unauthorized personnel are not allowed to exit or enter the count room unless all boxes and moneys have been secured. At no time may there be less than three (3) count team members present in the soft count room when uncounted money is present. Surveillance must monitor all entrances and exits from the count room.

4. Each casino shall have a room or room(s) specifically designated for counting the contents of drop boxes and slot machine bill/currency acceptors which shall be known as the soft count room. The soft count room shall be designed and constructed to provide maximum security for materials housed in and the activities conducted therein. All soft count room keys, drop box rack keys, drop box removal keys, drop box contents keys and any duplicate keys are to be controlled in such a way that access to the full or empty boxes or to the soft count room requires at least two (2) persons representing different departments and segregated functions. The doors to the count room will be securely locked and no count team member will be permitted to enter or leave the count room except during an emergency or scheduled breaks until the entire counting, recording and verification process is complete. There will be no transfers of chips or currency in or out of the count room until all count procedures are complete and the cage has taken possession of the drop into its accountability. Further, non-gaming revenues, such as restaurant or bar receipts, must not be counted coinciding with the count of gaming revenue.

5. Procedures and requirements for conducting the count shall be the following:

a. As each drop box is placed on the count table to be individually counted, one (1) count team member shall verbalize in a tone of voice to be heard by all persons present the game, table number and shift marked thereon for drop boxes.

b. The contents of each drop box shall be emptied on the count table and either manually counted separately on the count table or counted on a currency counting machine located in a conspicuous location on, near or adjacent to the count table. If a currency counting machine is used, it shall be tested daily prior to the actual count to ascertain if the metering device is working properly. A record shall be maintained of the daily testing containing no less than two (2) signatures attesting the daily test.

c. Immediately after the contents of a drop box are emptied onto the count table, the inside of the drop box shall be examined by at least one (1) other count team member to ascertain that all contents of the drop box have been removed. The empty box shall be positioned by a count team member in such a way that surveillance may verify that the box is empty, after which the drop box shall be locked and placed in the storage area for drop boxes.

d. The contents of each drop box shall be separated by a count team member into separate stacks on the count table by denominations of coin and currency and by type of form, record or document except that a machine may be used to automatically sort currency by denomination.

e. Each denomination of coin and currency shall be counted separately by one (1) count team member who shall place individual bills and coins of the same denomination on the count table and in writing record the results of such count. The coin and currency shall then be counted by a second count team member who is unaware of the result of the original count and who, after completing this count, shall confirm the accuracy of the total in writing with that reached by the first count team member. The MSTC may permit a licensee to perform an aggregate count by denomination of all currency collected in substitution of the second count by drop box if the MSTC is satisfied that the original count is being performed automatically by a machine that counts and automatically records the amount of currency by table and that the accuracy of the machine has been suitably tested and proven.

f. As the contents of each drop box are counted, one (1) count team member shall record in ink on a master game report by game, table and shift the following information:

i. The amount of each denomination of currency counted;

ii. The amount of all denominations of currency counted;

iii. The amount of coin counted;

iv. The total amount of currency and coin counted;

v. The amount of the opener;

vi. The amount of the closer;

vii. The serial number and amount of each fill;

viii. The amount of all fills;

ix. The serial number and amount of each credit;

x. The amount of all credits; and

xi. The win or loss;

xii. The amount of coupons authorizing chip purchases.

g. After the contents of each drop box are counted and recorded, one (1) member of the count team shall record, by game on the master game report, the total amounts of currency and coin, table inventory slips, fills and credits, and win or loss, along with such additional information as may be required.

h. Notwithstanding the requirements of 5 (f) and (g) if the licensee's system of internal accounting control provides for the recording on the master game report or supporting documents of fills, credits, and table inventory slips by cashiers prior to commencement of the count, a count team member shall compare for agreement the totals of the amounts recorded thereon to the fills, credits, table inventory slips removed from the drop boxes.

i. Notwithstanding the requirements of 5 (f) and (g) if the licensee's system of internal accounting control provides for the count team functions to be conducted only by accounting department employees with no incompatible functions they shall perform all other counting, recording and comparing duties herein.

j. After preparation of the master game report each count team member shall sign the face of the report attesting to the accuracy of the report. The count team members must record his/her work permit number with his/her signature.

k. Soft count team members must be prepared to perform a manual count of the drop in case of currency counting or sorting machine malfunctions. This manual process should be included in the written system.

6. Procedures and requirements at the conclusion of the count shall be the following:

a. All cash removed from the drop boxes or slot cash storage boxes shall be immediately presented in the soft count room by the count team to the cashier who prior to having access to the information recorded on the master game report and in the presence of the count team shall recount either manually or mechanically the cash received and attest by signature on the master game report, if applicable, the amount of cash received.

b. The master game report shall be delivered by the count team, after all signatures have been obtained and the cashier has verified the cash/chips/coins received, to the Accounting Department for audit and verification. Fills, credits, table inventory slips and all other supporting documents shall be attached or filed with the report and shall be held by the Accounting Department as a permanent record.

Notes

35 Miss. Code. R. 5-07-01-101