Count Rooms; Physical Characteristics; Count Protocols

(1) A gaming licensee shall have one or more rooms to be known as a "count room" specifically designated, designed, and used for counting the contents of table drop boxes, and slot drop boxes containers. If a gaming licensee's system of internal controls provides for counts of the contents of slot drop buckets and slot drop boxes in a different room from the room where the table drop boxes and slot cash storage boxes are counted, that latter shall be known as the "soft count room", and the former shall be known as the "hard count room". (2) A system of internal controls submitted by a gaming licensee in accordance with 205 CMR 138.02 shall include a description of all equipment used in the counting and recording process and all other systems used for purposes related to the counting of gross revenue and shall otherwise comport with the requirements of 205 CMR 138.19. (3) A gaming licensee shall design and construct each count room to provide maximum security with, at a minimum, the following security measures: (a) A metal door installed on each entrance and exit equipped with a lock which shall be maintained and controlled by the security department; (b) An alarm device, which audibly signals the surveillance, security departments, and the on-site IEB office whenever a count room door is opened; (c) A light system, which illuminates one or more lights in the surveillance department and at each count room door, for purposes of maintaining constant surveillance on the entrance and exits to the count room; (d) Closed circuit television cameras wired to the surveillance department capable of, but not limited to, the following: 1. Video monitoring of the entire count process; and 2. Continuous video-monitoring of the interior of the count room, including storage cabinets or trolleys used to store drop boxes, slot drop containers, and emergency drop boxes. (e) For the soft count room only, microphones wired to the surveillance department for audio monitoring of the entire count process. Any room that is wired for audio monitoring shall have, conspicuously posted on the entrance and the walls within, a notice indicating that the room is subject to such monitoring. (4) In addition to the requirements of 205 CMR 138.19(3), a count room used to count coin slot drop boxes and buckets shall have: (a) A fixed-door type or a hand-held metal detector used by a security department member to inspect all persons exiting the hard count room; and (b) A separate light system or other device approved by the IEB which shall provide a continuous visual signal at the count room door, whenever any access door to the count room is opened while the system is activated. The light system or device shall: 1. Maintain the visual signal until the system is reset or deactivated; and 2. Be designed so as to permit its activation, deactivation or resetting only by a member of the security department. (5) In addition to 205 CMR 138.19(3), the soft count room shall have: (a) A table constructed of clear glass or similar material for the emptying, counting, and recording of the contents of drop boxes and slot cash storage boxes which shall be known as the "count table"; (b) A table constructed of clear glass or similar material for the stacking of the contents of table drop boxes and slot cash storage boxes which have been counted, prior to the recount and acceptance by the cage cashier or cashier supervisor. The table shall be known as the "banking table"; and (c) A locked accounting box, the key to which shall be maintained and controlled by a supervisor in the gaming accounting department with no incompatible functions. (6) The count room doors shall be secured at all times except when opened for the following authorized purposes: (a) To allow one or more members of the count team to change shifts or take a work break; (b) To permit access to equipment by authorized IT department employees; (c) To permit table drop boxes or slot cash storage boxes to be secured in the count room; (d) To permit empty table drop boxes, slot cash storage boxes, emergency table game drop boxes or emergency slot cash storage boxes that were not part of the current count to be removed from the count room; (e) To allow a main bank cashier or cage supervisor to enter the count room to recount and accept the drop; (f) To allow the count team to exit the room at the conclusion of the count; or (g) In the event of an emergency. (7) A system of internal controls submitted by a gaming licensee in accordance with 205 CMR 138.02 shall include a workflow diagram that shall indicate, at a minimum, the location of all equipment in a count room, all equipment used in the counting process and the flow of all currency, coupons, gaming vouchers and paperwork from the start of the count to the conclusion of the count. (8) The count team may simultaneously count the contents of the table drop boxes and the slot cash storage boxes provided that the contents of the table drop boxes remain segregated from the contents of the slot cash storage boxes throughout the count and acceptance by the main bank cashier or cage supervisor. (9) Except during an emergency, with the exception of the count team and agents of the IEB, prior to anyone entering or leaving a count room during the soft count process, all contents that have been removed from either a drop bucket, drop box or slot cash storage box shall be counted at least once and secured. Any trolleys that contain uncounted drop boxes or slot cash storage boxes shall be secured. (10) The opening, counting, and recording of the contents of table drop boxes, and slot drop containers shall be performed in the presence of a count room supervisor. The count shall be performed by at least three employees (count team), which shall include the count room supervisor. The counting and recording process shall be discontinued where the minimum number of count room personnel is not present or are not capable of performing their responsibilities. (11) All persons present in the count room during the counting process, except agents of the IEB, shall: (a) Wear as outer garments, only a full-length, one-piece, pocketless garment with openings only for the arms, feet, and neck; (b) Not be permitted to wear a long sleeve garment under the outer garment; and (c) Not be permitted to carry a bag, pocketbook or other container unless it is transparent. (12) Access to the count room during the counting process shall be limited to the count team, internal audit personnel, other persons authorized by the IEB, or agents of the IEB. No count room employee shall, during the soft count process, enter a storage area for table drop boxes or slot cash storage boxes adjacent to the count room to perform any function not directly related to the counting process. (13) No person shall remove his or her hands from or return them to a position on or above the count table, banking table or counting equipment unless the backs and palms of his or her hands are first held straight out and displayed to other members of the count team and surveillance cameras. In addition, whenever any person enters or leaves the count room during the counting process, any employee remaining in the count room shall be required to step awayfrom the count table, banking table and counting equipment until the person has entered or left the count room. (14) Immediately prior to the commencement of the count, doors to the count room shall be securely locked and remain locked at all times, except when opened for an authorized purpose in 205 CMR 138.19(6). A count team member shall notify surveillance that the count is about to begin, after which surveillance shall make a continuous video and, if applicable, audio recording, with the time and date inserted thereon, of the entire counting process. A count room member shall also notify surveillance whenever a count room door will be opened during the count. (15) Once all currency, gaming vouchers, coupons, coin and/or slot tokens have been counted and the final count totals have been obtained, no employee shall be permitted to leave the count room, except in an emergency, until the recount and acceptance of the drop is completed by a cage cashier or cashier supervisor. (16) The count room supervisor shall prepare a record of the names and credential or license numbers of each employee who was present in the count room during any part of the count process. Such record shall be forwarded to the accounting department at the conclusion of the count.