205 CMR 138.48
Procedure for Opening, Counting and Recording Contents of Table Drop Boxes and Slot Cash
Storage Boxes
A system of internal controls submitted by a gaming licensee in accordance with 205 CMR
138.02 shall include procedures relative to opening, counting, and recording contents of table
drop boxes and slot cash storage boxes that include, at a minimum, the following provisions:
(1) Immediately prior to the commencement of the count process, a count room supervisor
shall:
(a) Obtain a preliminary master game report which shall list forms and documents related
to the table drop box count that were entered into the computer system at the time of
preparation;
(b)
Reconcile the number of boxes recorded on the drop box verification form to the
number of boxes secured in the trolley;
(c) Remove the emergency drop box log and reconcile the log to the boxes removed from
the emergency drop box cabinet or trolley; and
(d)
Document any unresolved discrepancies on a two-part Drop Variance Report, the
original of which shall be delivered to the IEB and the duplicate placed in the locked
accounting box.
(2) A gaming licensee shall open, count and record the contents of each drop box in the soft
count room except that an emergency slot cash storage box may be held and counted on the
regularly scheduled count for the slot machine from which it originated. For currency, gaming
vouchers, and coupons, a gaming licensee shall perform a second count to obtain the aggregate
total of each denomination of currency and coupon, and the total number of gaming vouchers
counted. The counts shall be independent of each other and access to the result of the first count
shall not be available to the employee performing the second count until completion of the
second count. At the completion of the second count, a comparison of the two counts shall be
made and any discrepancies resolved by the count team supervisor.
(3) A gaming licensee shall use a counting machine, to be identified in the internal controls, to
count currency, gaming vouchers, and coupons. An alternative procedure shall be provided in
the event that a counting machine cannot be used due to mechanical failure or other emergent
situation.
(a) A gaming licensee mayuse one countingmachine that automaticallyprovides the counts
required in 205 CMR 138.48(2) of the items at different stages of the counting process. If
the counts are not in agreement, the machine shall document the discrepancy and cease
operation until the discrepancy is resolved by a count team member.
(b)
If a gaming licensee does not use a counting machine described in 205 CMR
138.48(3)(a), two different counting machines shall be used. Upon completion of the count
using the first machine, the cash storage bins or cassettes shall be emptied and displayed to
the full view of a closed circuit television camera to assure that the contents have been
emptied. The second machine count shall be performed to verify the totals of the first
machine. If the counts are not in agreement, the count team shall resolve the discrepancy
before continuing the second count.
(c) Each machine shall generate a report at the completion of its count documenting the
following:
1. The total of each denomination of currency;
2. The total of all currency;
3. The total number of gaming vouchers;
4. The total number and amount of coupons for which the count machine can determine
the value of the coupon (machine count coupons); and
5. The total number of coupons for which the count machine cannot determine the value
of the coupon (manual count coupons).
(4) A test count shall be conducted prior to the start of the first use of each counting machine,
each gaming day, and prior to each count. The count room supervisor shall:
(a) Verify that the counting machine has a zero balance on its display and cause a receipt
to be printed which denotes 0 cash, gaming vouchers or coupons on hand, and 0 notes,
gaming vouchers or coupons in the machine, or other approved means to indicate that the
machine has been cleared of all currency, gaming vouchers and coupons;
(b) Visually check the counting machine to be sure there are no bills, gaming vouchers or
coupons remaining in the various compartments of the machine;
(c) Supervise a count team member who shall select a drop box or slot cash storage box.
If slot storage boxes are being counted that day, a slot cash storage box must be selected and
it must contain currency, and if issued by the gaming licensee, gaming vouchers and
coupons. The count team member shall place the entire contents of the table drop box or slot
cash storage box into the first counting machine, which shall count the currency by
denomination as well as any gaming vouchers and coupons. Any soiled or off-sorted bills,
gaming vouchers or coupons shall be re-fed into the machine. Any items which the counting
machine is not able to count automatically, such as coins, tokens, gaming chips or mutilated
or torn currency, gaming vouchers, and coupons shall be manually counted, recorded either
manually or entered into the counting machine, and segregated from items which the
counting machine was able to count automatically. The count team member shall cause the
counting machine, in conjunction with the gaming voucher system, to produce one or more
test receipts of the count, and the count shall not be shown to anyone until completion of the
final verification process;
(d) Supervise a second count team member, independent of the team member performing
the initial count, who shall manually count or use a second counting machine to count and
summarize the items on test receipts;
(e) Compare the totals on the test receipts for agreement. If the totals are in agreement, the
count room supervisor shall sign and date the test receipts and place them in the locked
accounting box to be forwarded to the gaming accounting department at the end of the count
process. If the totals do not agree, the test count procedures shall be repeated. The test count
procedures shall be repeated until the totals are in agreement or a determination is made that
the count machine cannot be used. The count room supervisor shall not permit a counting
machine to be used until these totals are in agreement;
(f)
Supervise a count team member who, at the conclusion of the test procedure shall
display the cash bin or storage cassettes to the full view of a closed circuit television camera
to assure that the contents have been emptied prior to replacing cassettes into the counting
machine; and
(g) Verify that the counting machine has a zero balance in accordance with 205 CMR
138.48(4)(a).
(5) Procedures for the count of boxes shall be as follows:
(a) The contents shall be segregated and counted so as to permit the contents to be recorded
for the box from which it was removed. Each box shall be individually:
1. placed on the count table at which time one count team member shall verbalize, in
a tone of voice to be heard by all persons present and to be recorded by the surveillance
audio recording device, the game and table number marked thereon for table drop boxes,
or the asset or unique identification number marked thereon for slot cash storage boxes;
and
2. unlocked and the contents emptied on the count table. The inside of the box shall be
held up to the full view of a closed circuit television camera to assure all contents of the
drop box or slot cash storage box have been removed, after which the drop box or slot
cash storage box shall be locked and placed in the storage area for drop boxes and slot
cash storage boxes;
(b) A count team member shall segregate:
1. Currency, machine count coupons, and gaming vouchers;
2. Coin, tokens, gaming chips, manual count coupons and any mutilated or torn items;
and
3. Forms and documents;
(c) A count team member shall attempt to match pieces of mutilated or torn items which
shall be processed as follows:
1. Mutilated or torn currency shall be recorded as revenue if the bill includes one entire
serial number and one letter and number of the serial number from the other half of the
bill;
2. Mutilated or torn currency that is not recorded as revenue shall be placed in a sealed
transparent envelope or container and transferred to the main bank by the main bank
cashier or cage supervisor at the end of the count; and
3. All mutilated or torn coupons and gaming vouchers shall be recorded as revenue
regardless of condition;
(d)
The value and number of coin, tokens, gaming chips, manual count coupons (by
denomination) and any mutilated or torn items shall be manually entered into the counting
machine for each drop box or slot cash storage box;
(e) Currency, machine count coupons and gaming vouchers shall be placed in a counting
machine. The counting machine shall count and calculate the value of the currency. The
value of each gaming voucher or coupon shall be obtained from the counting machine or an
approved gaming voucher system, as applicable;
(f) Upon completion of the machine count:
1.
For each drop box, the counting machine shall generate the report required by
205 CMR138.48(3)(c);
2. The currency, table game coupons, coin, tokens, and gaming chips counted shall be
placed on the banking table; and
3. Any drop box coupon which has not already been cancelled upon acceptance or
during the count shall be cancelled prior to the conclusion of the count;
(g) The forms and documents shall be compared to the preliminary master game report for
accuracy by a count team member who shall not simultaneously have access to currency.
Any discrepancies shall be recorded on the preliminary master game report to be resolved by
the gaming accounting department. The forms and documents and preliminary master game
report shall be placed in the locked accounting box to be forwarded to the accounting
department at the end of the count process; and
(h) The count team supervisor shall prepare a detailed written report describing all count
room incidents that may have negatively impacted the opening, counting and recording of
the drop boxes (for example, a computer interface problem, dropped basket). The report
shall include a description of any corrective action taken and shall be electronicallyfiled with
the IEB at the conclusion of the count.
(6) As the contents of each table drop box are counted, if not already recorded in the computer
system used to create the Master Game Report and supporting documentation, a count team
member shall manually record or cause a computer system to record, the following information
by game and table number:
(a) The value of each denomination of currency counted;
(b) The value of coin, tokens and/or gaming chips counted;
(c) The total value of currency, coin, tokens and gaming chips counted;
(d) The value of each denomination and total value of coupons other than match play
coupons;
(e) The value of each denomination and total value of match play coupons and table game
wager coupons;
(f) 50% of the total value of match play coupons and table game wager coupons;
(g) The amount recorded on each document and the total of all documents evidencing a
debit card chip transaction;
(h) The amount of the Opener;
(i) The amount of the Closer;
(j)
The serial number and amount of each Counter Check and the total amount of all
Counter Checks;
(k) The serial number and amount of each Pit Redemption Form and the total of all Pit
Redemption Forms;
(l) The serial number and amount of each Fill and the total amount of all Fills;
(m) The serial number and amount of each Credit and the total amount of all Credits;
(n) The amount recorded on each Complimentary Vigorish Form and the total amount of
all Complimentary Vigorish Forms;
(o) The table game win or loss or, for poker, the poker revenue; and
(p) The table game win or loss percentage.
(7) In addition to the requirements of 205 CMR 138.48(6), the Master Game Report shall
include:
(a) The gaming date of the items recorded;
(b) The grand total for items in 205 CMR 138.48(6)(c) through (p);
(c) The total number of drop boxes opened and counted; and
(d) The date and time prepared.
(8) If the gaming licensee offers the game of poker, the count room supervisor shall review the
Master Game Report to ensure that negative poker revenue has not been reported for any poker
table. If negative poker revenue has been reported for a poker table, the count room supervisor
shall initial the Master Game Report for each such poker table and immediately notify the
surveillance department of the poker table(s) and correspondingnegative poker revenue reported
thereon.
(9) As the contents of each slot cash storage box are counted, if not already recorded in the
computer system used to create the Slot Cash Storage Box Report and supporting documentation,
a count team member shall manually record or cause a computer system to record, the following
information by asset number:
(a)
The asset number of the bill changer to which the slot cash storage box contents
correspond;
(b) The value of each denomination and total value of currency counted;
(c) The number and value of each cashable coupon counted, and if a gaming voucher system
is used to redeem coupons, the validation number and value of each coupon counted, and
total number and value of all cashable coupons;
(d) The number and value of each non-cashable coupon counted, and if a gaming voucher
system is used to redeem such coupons, the validation number and value of each coupon
counted, and total number and value of all non-cashable coupons;
(e) A listing of the validation number and value of each gaming voucher counted, and total
number and value of all gaming vouchers; and
(f) Any additional information on the Slot Cash Storage Box Report as may be required by
the IEB.
(10) In addition to the requirements of 205 CMR 138.48(9), the Slot Cash Storage Box Report
shall include:
(a) The gaming date of the items recorded;
(b) The grand total for items in 205 CMR 138.48(9)(b) through (e);
(c) The total number of drop boxes opened and counted;
(d) The date and time prepared.
(11) After preparation of the Master Game Report or the Slot Cash Storage Box Report, the
count room supervisor shall compare the total number of boxes counted to the number of boxes,
including any emergency boxes, collected and recorded on the box reconciliation form. Any
unresolved discrepancy shall be documented on the Drop Variance Report which shall be filed
with the IEB.
(12) All suspected counterfeit currency shall be counted and recorded as drop on the Master
Game Report or Slot Cash Storage Box Report. The counterfeit currency shall be segregated
from all other currency and placed in a transparent container. A count room supervisor shall
complete a Department of Treasury Counterfeit Note Report and place the container and report
on the banking table.
(13) A count team member designated as the banker shall count each denomination of currency,
table game coupons, tokens, and gaming chips, and verbalize the amounts. The count room
supervisor shall verifythe amount verbalized to the amount recorded on the Master Game Report
or Slot Cash Storage Box Report. The banker and count team supervisor shall sign the report(s)
attesting to the accuracy of the information recorded thereon. The information recorded thereon
shall not be accessible to any person outside the count room until after the main bank cashier or
cage supervisor (cashier) has verified and accepted the drop unless otherwise authorized by the
IEB.
(14) All other count team members shall sign the Master Game Report and/or the Slot Cash
Storage Box Report as evidence of their participation in the counting of the drop boxes and/or
slot cash storage boxes.
(15) After the contents of the boxes have been counted and recorded on the Master Game
Report and/or Slot Cash Storage Box Report, the count room supervisor shall notify the main
cage. A cashier shall enter the count room and not have any access to the information recorded
on the Master Game Report or the Slot Cash Storage Box Report. The cashier, in the presence
of the banker, shall count the currency, table game coupons, coins, tokens, gaming chips, and
mutilated or torn items.
(a) Currency, table game coupons, coin, tokens, and gaming chips shall be presented in the
count room by the banker to a main bank cashier or cage supervisor (cashier). Prior to
having access to the information recorded on the Master Game Report or the Slot Cash
Storage Box Report, the cashier, in the presence of the banker, shall count the items in
accordance with the following requirements:
1. The cashier shall have physical access to all items presented for counting and no
currency or table game coupons presented for counting shall be wrapped or placed in any
sealed bag or container until the entire count has been completed and the Master Game
Report or the Slot Cash Storage Box Report has been signed by the cashier;
2. The cashier shall bulk count all strapped currency and table game coupons. The
cashier shall count all partial straps, loose currency and table game coupons, mutilated
or torn currency and coupons, coin, tokens, and gaming chips either by hand or with an
approved counting machine.
If a discrepancy in an individual denomination is
discovered during the initial count, the cashier shall recount the currency of that
denomination either by hand or with an approved counting machine;
3. The cashier shall randomly count the currency within at least 10% of the total number
of straps. The count shall be by hand or with an approved counting device; and
4.
The cashier shall randomly sample the table game coupons for intermixed
denominations and proper cancellation.
(b) If the total currency or total coupons counted by the cashier do not agree with a total on
the Master Game Report or Slot Cash Storage Box Report and the discrepancy cannot be
resolved, a Drop Variance Report shall be completed by the count room supervisor. The
original shall be delivered to the IEB and the duplicate placed in the locked accounting box
in the count room. The report shall include, at a minimum, the following:
1. The date of preparation;
2. The source of the variance (currency and/or coupon);
3. The denomination(s) of the source of the variance;
4. The amount of the variance;
5. The measures taken to detect the source of the variance;
6. The name and signature of the count room supervisor; and
7. The name and signature of the cashier.
(c) Upon completion of the cashier's count, the cashier shall attest by signature on the
Master Game Report and/or Slot Cash Storage Box Report, that the amount of cash from
drop boxes counted, and the amount of coupons from table drop boxes counted as recorded
on these documents, and if applicable, the Drop Variance Report, agree with the total
amounts of cash and coupons counted by the count team. Upon attestation, all items other
than coupons and vouchers shall be under the exclusive control of the cashier and shall not
be handled by a count team member.
(16) Once all required signatures have been obtained, a copy of the totals page of the original
Master Game Report, Slot Cash Storage Box Report and disc(s) detailing all gaming vouchers
and coupons counted, shall be delivered to the IEB. In addition, an electronic copy of the Master
Game Report and/or Slot Cash Storage Box Report shall be filed with the IEB within 48 hours
of the completion of the drop.
(17) Each copy of an original Master Game Report or Slot Cash Storage Box Report which is
not part of a multi-part form shall be stamped with the word "copy" by the count room supervisor
prior to its distribution.
(18) Any coupons and gaming vouchers for which the value could not be determined by the
count machine or the gaming voucher system shall be segregated and placed in the locked
accounting box for review.
(19) The original Master Game Report and Slot Cash Storage Box Report, after signing, and
any other supporting documentation shall be placed in the locked accounting box located in the
count room. A member of the gaming accounting department with no incompatible functions
shall retrieve the contents of the locked accounting box and the gaming vouchers and coupons
which were processed during the count immediately after the cashier verifies, accepts, and
removes the drop from the count room.
(20) For each trolley scheduled for the next drop, the count team supervisor shall determine that
the number of empty boxes on the trolley is correct. The count team supervisor shall prepare and
sign a drop box verification form as required by 205 CMR 138.00, with the following:
(a) The trolley number;
(b) The pit number and number of empty boxes by pit, if applicable;
(c) The slot zone and number of empty boxes by zone, if applicable; and
(d) The total boxes in the trolley.
(21) A count room employee shall conduct a thorough inspection of the entire count room and
all counting equipment located therein to verify that no cash, tokens, gaming chips, gaming
vouchers, or coupons remain in the room and shall certify the foregoing in a writing which shall
be filed with the IEB.