La. Admin. Code tit. 42, § III-2729 - Internal Controls; Cage, Vault and Credit

A. Each licensee and casino operator shall have a main bank that serves as the financial consolidation of transactions relating to all gaming activity.

B. Individuals accessing the main bank or casino cages, who are not employees assigned to those areas, shall sign a log maintained in the main bank and casino cages recording:

1. name of each person entering;

2. reason each person entered;

3. date and time each person enters and exits;

4. date, time and type of any equipment malfunction; and

5. a description of any unusual events.

C. All transactions that flow through the main bank or casino cages shall be summarized on a cage accountability form on a per shift basis and signed by the outgoing and incoming cashier after verifying the amounts. Variances of $50 or greater shall be investigated and the results of the investigation maintained for five years.

D. Increases and decreases to the cage inventory shall be supported by written documentation.

E. Open cage windows, the main bank, and the vault, including the inventory in the coin room, shall be counted by outgoing and incoming cashiers and recorded at the end of each shift during which any activity took place or once per gaming day if no activity took place. This documentation shall be signed by each person who counted the inventory. In the event there is a variance of $50 or greater, a supervisor shall verify the inventory count and sign the documentation.

F. All net changes in outstanding casino receivables shall be summarized on a cage accountability form or similar document on a daily basis. Such information shall be summarized and posted to the accounting records at least monthly.

G. All cage paperwork shall be transported to the accounting department by an employee independent of the cage.

H. All cashier tips shall be placed in a transparent locked box located inside the cage and shall not be commingled with cage inventory.

I. A licensee or casino operator may issue credit for gaming purposes.

J. Prior to the issuance of gaming credit to a player, the employee extending the credit shall determine if credit is available. If a manual system is used, prior to the issuance of gaming credit to a player, the employee extending the credit shall contact the cashier or other independent source to determine if the player's credit limit has been properly established and remaining credit available is sufficient for the advance.

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

L. Prior to extending credit, each licensee and casino operator shall obtain and copy a valid driver's license or if a valid driver's license is not available, another generally accepted means of identification, and document that it:

1. received information from a bona fide credit-reporting agency that the patron has an established credit history that meets documented company standards for issuing credit; or

2. received information from a legal business that has extended credit to the patron that the patron has an established credit history that meets documented company standards for issuing credit; or

3. received information from a financial institution at which the patron maintains an account that the patron has an established credit history that meets documented company standards for issuing credit; or

4. examined records of its previous credit transactions with the patron, showing that the patron has paid substantially all of his credit instruments and otherwise documents that it has a reasonable basis for placing the amount or sum placed at the patron's disposal; or

5. obtained information from another licensee that extended gaming credit to the patron that the patron paid substantially all of the debt to the other licensee, and the licensee extending the credit otherwise documents a reasonable basis for the amount of credit it is granting the patron; or

6. is unable to obtain information from any of the sources listed in Paragraphs 1-5 of this Subsection for a patron who is not a resident of the United States. In this case, the licensee or casino operator shall receive in writing, information from an agent or employee of the licensee or casino operator who has personal knowledge of the patron's credit reputation or financial resources that there is a reasonable basis for extending credit in the amount or sum placed at the patron's disposal.

M. Subsection L of this Section applies to personal checks and third party checks whether in exchange for cash, chips, tokens, or other cash equivalents or as payment for a previous credit instrument. If the licensee or casino operator utilizes a check guarantee company, the licensee or casino operator is only required to obtain and copy the ID as required in Subsection L of this Section, as long as it follows the requirements of the check guarantee company.

N. The following information shall be recorded for patrons who will have credit limits or are issued credit in an amount greater than $1,000 excluding cashier's checks and traveler's checks:

1. patron's name, current address, and signature;

2. identification verifications, including Social Security number or passport number if patron is a nonresident alien;

3. authorized credit limit;

4. documentation of authorization by an individual designated by management to approve credit limits; and

5. credit issuances and payments.

O. Prior to extending credit, the patron's credit application and any additional documentation shall be examined to determine the following:

1. properly authorized credit limit;

2. whether remaining credit is sufficient to cover the advance;

3. identity of the patron;

4. credit extensions over a specified dollar amount are authorized by personnel designated by management;

5. proper authorization of credit extension over 10 percent of the previously established limit or $1,000, whichever is greater, is documented; and

6. if cage credit is extended to a single patron in an amount exceeding $3,000, applicable gaming personnel are notified on a timely basis that the patron is playing on cage credit, the applicable amount of credit issued, and the available balance.

P. The following information shall be maintained either manually or in the computer system for markers:

1. the signature or initials of the individual(s) approving the extension of credit unless such information is contained elsewhere for each issuance;

2. the name of the individual receiving the credit;

3. the date and shift granting the credit;

4. the amount of credit issued;

5. the marker number;

6. the amount of credit remaining after each issuance or the total credit available for all issuances;

7. the amount of payment received and nature of settlement, for example, credit slip number, cash, and chips; and

8. the signature or initials of the individual receiving payment or settlement.

Q. 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 of the cage-issued marker shall be utilized as follows:

1. the original slip shall be maintained in the cage until settled;

2. the payment slip shall be maintained in the cage until the marker is paid; and

3. the issue slip shall be maintained in the cage until forwarded to accounting.

R. The original slip shall include the following information:

1. patron's name and signature;

2. marker number;

3. date of issuance; and

4. amount of credit issued.

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

T. The payment slip shall include the same number as the original slip. When the marker is paid in full, it shall also include, the date and time of payment, the manner of payment, such as cash, chips, or tokens, and amount of payment. The payment slip shall also include the signature of the cashier receiving the payment unless this information is included on another document verifying the payment of the marker.

U. Marker log documentation shall be maintained by numerical sequence, indicating marker number, name of patron, date marker issued, date paid, method of payment, and amount of credit remaining.

V. Voided markers, computer-generated and manual, shall be clearly marked "Void" across the face of all copies. The cashier and supervisor shall print their employee numbers and sign their names on the voided marker. The supervisor who approves the void shall print or stamp the date and time the void is approved and print the reason for the void on the slip. All copies of the voided marker shall be forwarded to accounting for accountability and retention on a daily basis.

W. 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 marker forms.

X. The accounting department shall investigate the loss of any part of a numbered marker form immediately upon discovery that the marker form or a part of the marker form is missing. The investigation shall 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.

Y. All payments received on outstanding credit instruments shall be permanently recorded in the licensee's or casino operator's records.

Z. When partial payments are made on a marker, a new marker shall be completed reflecting the original date, remaining balance, and number of the original marker.

AA. Personal checks or cashier's checks shall only be cashed at the cage and the cashier shall examine and record at least one valid form establishing the patron's identification.

BB. When travelers checks are presented, the cashier must comply with examination and documentation procedures as required by the issuer of the travelers checks.

CC. Payments by mail shall be received by a department independent of credit instrument custody and collection.

DD. Payments received by mail shall be:

1. recorded on a listing indicating the following:

a. customer's name;

b. amount of payment;

c. type of payment including check number or similar identifying number, if applicable; and

d. date payment received.

2. applied to credit balances by a different employee from the employee receiving the payments; and

3. reconciled in accordance with the internal controls to ensure all payments received are recorded and applied to the correct account.

EE. Access to credit information, including outstanding credit instruments and credit write-offs, shall be restricted to those positions which require access and are authorized by management. This access shall be noted in the appropriate job descriptions in the internal controls.

FF. All extensions of pit credit transferred to the cage and subsequent payments shall be documented on a credit instrument control form.

GG. Records of all correspondence, transfers to and from outside agencies, and other documents related to issued credit instruments shall be maintained.

HH. Written-off credit instruments shall be authorized in writing. Such authorizations shall be made by at least two management officials from departments independent of the credit transaction.

II. If outstanding credit instruments are transferred to outside offices, collection agencies or other collection representatives, a copy of the credit instrument and a receipt from the collection representative shall be obtained and maintained until such time as the credit instrument is returned or payment is received. A detailed listing shall be maintained to document all outstanding credit instruments which have been transferred to other offices. The listing shall be prepared or reviewed by an individual independent of credit transactions and collections.

JJ. The receipt or disbursement of front money or a customer cash deposit shall be evidenced by at least a two-part document with one copy going to the customer and one copy remaining in the cage file.

1. The multi-part form shall contain the following information:

a. identical number on all copies;

b. customer's name and signature;

c. date of receipt and disbursement;

d. dollar amount of deposit; and

e. type of deposit or disbursement, cash, check, or chips.

2. Procedures shall be 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 cash deposits which are in the cage or vault inventory or accountability; and

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

KK. The trial balance of casino accounts receivable shall be reconciled to the general ledger at least quarterly.

LL. An employee independent of the cage, credit, and collection departments shall perform all of the following at least three times per year:

1. ascertain compliance with credit limits and other established credit issuance procedures;

2. randomly reconcile outstanding balances of active and inactive accounts on the listing to individual credit records and physical instruments;

3. examine credit records to determine that appropriate collection efforts are being made and payments are being properly recorded; and

4. for a minimum of five days per month, reconcile partial payment receipts to the total payments recorded by the cage for the day.

Notes

La. Admin. Code tit. 42, § III-2729

Promulgated by the Department of Public Safety and Corrections, Gaming Control Board, LR 38:1650 (July 2012).

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