205 CMR 138.33
Removal of Slot Drop Containers; Unsecured Funds; Recording of Meter Readings for Slot
Machine Drop
A system of internal controls submitted by a gaming licensee in accordance with 205 CMR
138.02 shall include procedures and protocols relative to the removal of slot drop containers,
unsecured currency, and the recording of meter readings for slot machine drop that, at a
minimum, incorporates the following requirements:
(1) A gaming licensee shall file with the IEB a drop schedule setting forth the specific times at
which the slot drop containers will be brought to or removed from the slot machines and the
routes to be utilized. The schedule shall include the number of slot drop containers to be
removed each day by zone or other designation. At a minimum, the schedule shall provide for
removal at least once per week.
(2) All slot drop containers which are not actively in use shall be stored in the count room or
other secure area outside the count room as approved by the IEB to prevent unauthorized access.
In addition, slot drop containers in use shall be stored in an enclosed storage cabinet or trolley,
secured by a key. The key must have restricted access and may be maintained and controlled by
either the security department or by means of an electronic key control system which documents
the date, time, and electronic signature of any person signing out/in the aforementioned keys.
Such electronic key control system also must have the ability to restrict access and ensure keys
are released onlywhen the properlyauthorized individual(s) are present. An electronic signature
shall include a unique employee PIN and key card swipe, or PIN and employee biometric
identification.
(3) Slot drop containers shall be removed from a slot machine by at least three employees, two
of whom shall be members of the security department and one of whom shall be a member of
the accounting department (the drop team). At least one member of the drop team shall be
licensed as a key gaming employee in accordance with 205 CMR 134.00: Licensing and
Registration of Employees, Vendors, Junket Enterprises and Representatives, and Labor
Organizations. Other than the security department members, all employees participating in the
removal of slot drop containers shall wear as outer garments only a full-length, one-piece
pocketless garment with openings only for the hands, feet and neck.
(4) A drop team member shall notify the surveillance department at the commencement of the
slot drop process. Surveillance shall make a continuous video recording, with the time and date
inserted thereon, of the entire slot drop process.
(5) All slot drop containers removed from the slot machines shall be transported directly to, and
secured in, the count room by a security department member and a member of the accounting
department. The process shall be documented in writing ensuring that the number of slot drop
containers brought into the gaming area and the number of slot drop containers removed from
the gaming area are reconciled with a drop box verification form.
(6)
Emergency drop procedures to remove a full or inoperable slot drop container or for
removal for other legitimate reasons, as approved by the IEB, outside of the slot drop schedule
shall require at least three employees (two of whom shall have no incompatible functions, and
one of whom shall be licensed as a key gaming employee in accordance with 205 CMR
134.00:
Licensing and Registration of Employees, Vendors, Junket Enterprises and
Representatives, and Labor Organizations), be replaced with an empty emergency slot drop
container of the same type if the slot machine is to remain available for play by patrons, and
include at a minimum established procedures as follows:
(a) A security department member shall notify the surveillance department which shall
monitor and record the transaction. If more than one slot drop container is being removed,
such notification shall include the sequence in which the containers will be removed and
replaced;
(b) The security department member shall complete an emergency box form documenting
the replacement of the slot drop container. The form shall include at a minimum:
1. The date and time;
2. The asset and location number;
3. The reason for the removal; and
4. The signatures of all employees participating in the process.
(c) The emergency box form shall be distributed by a member of the emergency drop team
as follows:
1. The original affixed to the emergency slot drop container;
2. The duplicate placed in a locked accounting box; and
3. The triplicate delivered to the cage to be routed within 24 hours of preparation to the
IEB’s on-site office.
(d) A slot department member, in the presence of the other members of the emergency drop
team, shall remove the slot drop container from the slot machine and replace it with the
empty emergency slot drop container if the slot machine is to remain available for play by
patrons;
(e)
The slot drop container removed from the slot machine shall be transported by a
minimum of two members of the emergency drop team to the count room where it must be
secured in an emergency drop box cabinet or trolley; and
(f) For each slot drop container removed, an emergency drop team participant shall record
on an emergency box log, to be maintained with the emergency drop box cabinet or trolley,
the following:
1. The date and time the slot drop container was secured in the cabinet or trolley;
2. The slot drop container location and asset number; and
3. The signatures of at least two members of the emergency drop team participating in
the emergency slot drop container process.
(7) Whenever currency, a gaming voucher, or a coupon is found inside a slot machine but
outside of the slot drop box during the collection of slot drop boxes, it shall be deemed
“unsecured funds.” When unsecured funds are located, a count team member and a member of
the security department shall complete and sign an unsecured funds form which includes the
asset number in which the unsecured funds were found, the date the unsecured funds were found,
and the total value of the unsecured funds. The unsecured funds and the original unsecured funds
form shall be transported to the cashier’s cage. A determination shall be made as to whether the
unsecured funds registered on the coin-in meter of the slot machine from which they were
retrieved. If the unsecured funds registered on the coin-in meter of the slot machine, the funds
shall be recorded as part of the gross gaming revenue for the slot machine and recorded with the
contents removed from the corresponding slot drop box. If it is determined that the unsecured
funds did not register on the coin-in meter of the slot machine, the funds shall be processed as
unclaimed cash in accordance with 205 CMR 138.68(1)(b).
The duplicate of the unsecured funds form shall be placed in a locked accounting box. Upon
completion of the count, the original unsecured funds form, relative to funds that registered on
the coin-in meter, shall be placed in a locked accounting box located in the count room. The
accounting department shall retrieve the original form and reconcile it to the duplicate. A copy
of the form shall be provided to the IEB.
(8) Whenever unsecured funds are found inside a slot machine but outside of the slot drop box
at times other than the collection of slot drop boxes, a slot department member shall notify the
surveillance department and complete and sign the unsecured funds form referenced in 205 CMR
138.33(7). The unsecured funds and the original form shall be transported by the slot department
member, escorted by a security department member, to the cashiers’ cage where a cashier shall
sign the form acknowledging receipt. The unsecured funds and original form shall be handled
in accordance with the process described in 205 CMR 138.33(7).
(9) Upon receipt of an unsecured gaming voucher or coupon, the cage cashier in the presence
of the slot department member shall deface or otherwise deactivate the gaming voucher or
coupon, to the extent necessary, so as to prevent subsequent redemption.
(10) At the end of the gaming day, at a minimum, the original unsecured funds forms and as
applicable, gaming vouchers and coupons, shall be forwarded to the accounting department. The
accounting department shall reconcile the original and duplicate forms and record the appropriate
amount on the Slot Win Report or unclaimed cash report, as applicable. Reconciliation of
unsecured funds shall be completed by the end of the gaming day on which the count of the slot
machine drop for the machine in which the unsecured funds were located is performed.
(11) In conjunction with the removal of any slot drop box, a gaming licensee shall manually
read, or cause an approved slot monitoring system to record, the slot machine’s accounting
meters that are used to calculate gross gaming revenue, as described by GLI-11, 5.4.1 Electronic
Accounting and Occurrence Meters, including the in-meter, drop meter, out-meter, attendant
paid jackpots meter, attendant paid cancelled credits meter, bill meters and handle pull meter.
In addition, the following meters shall be read and recorded:
(a) If the slot machine accepts gaming vouchers, the numerical and value cashable gaming
voucher meters, and the numerical and value non-cashable gaming voucher meters;
(b)
If the slot machine accepts coupons enrolled in the gaming voucher system, the
numerical and value cashable coupon meters and numerical and value non-cashable coupon
meters;
(c) If the slot machine accepts promotional credits, the electronic cashable credit meter and
the electronic non-cashable credit meter; and
(d) If the slot machine accepts funds from an account based wagering system, the wagering
account transfer-in meter and the wagering account transfer-out meter.
(12) The slot monitoring system shall provide a report to the accounting department for a
comparison of the meter readings to the count room reports and the calculation of each slot
machine’s payout percentage. In the event it is determined after a count that a shortage or
overage exists between the total registered on a slot machine’s accounting meters that are used
to calculate gross gaming revenue, as described by GLI-11, 5.4.1 Electronic Accounting and
Occurrence Meters, and the total value of the contents of the drop box, the licensee shall
investigate to determine the cause and record the findings. Only members of the accounting
department shall have the authority to adjust meter readings subsequent to the count, provided
that notification is provided to the IEB and the commission’s finance office if the shortage or
overage was caused by a technical malfunction. The IEB and/or finance office may take any
action necessary to ensure the integrity of the adjustment prior to the month end reconciliation
and public reporting of gross gaming revenue.
(13) Nothing in 205 CMR 138.00 or a gaming licensee’s internal controls shall preclude the
IEB from requiring a gaming licensee to read a slot machine meter manually as a remedial
measure in the event of a malfunction or as it may otherwise deem necessary to ensure the
integrity of gaming and the accurate reporting of gross revenue.