§ 465a.25. Counting and recording of slot cash storage boxes and table game drop boxes.
(a) Prior to commencing gaming operations, a slot machine licensee shall establish a comprehensive system of internal controls addressing the opening, counting and recording of the contents of slot cash storage boxes and table game drop boxes. The internal controls shall be submitted to and approved by the Board under § 465a.2 (relating to internal control systems and audit protocols) and must include:
(1) A workflow diagram which indicates the location of all equipment used in the count, including tables, baskets and bins, and the flow of all currency and paperwork from the start of the count to the conclusion of the count. The approved workflow diagram shall also be filed with the surveillance department.
(2) A description of all computer equipment, software, files or reports used in the counting and recording process and all other systems, if any, that communicate with that computer equipment. The submission must include:
(i) The names of all revenue files, the names of the employees who have access and what type of access they have to those files.
(ii) Controls to prevent access to any count room information by anyone outside of the count room until the entire count process is concluded.
(3) The procedures for conducting each required count, which must include, at a minimum, the following:
(i) In full view of the surveillance cameras, the contents of each slot cash storage box or table game drop box shall be emptied on the count table and either manually counted separately on the count table or counted in a currency counting machine located in a conspicuous location on, near or adjacent to the count table.
(ii) After the contents of each slot cash storage box or table game drop box have been emptied on the count table, the inside of the slot cash storage box or table game drop box shall be held up to the full view of the surveillance cameras to assure that all contents of the slot cash storage box or table game drop box have been removed, after which the slot cash storage box or table game drop box shall be locked and placed in the storage area.
(iii) The contents of each slot cash storage box or table game drop box shall be segregated by a count team member into separate stacks on the count table by each denomination of currency and by the type of required forms or documents. A slot machine licensee may utilize a machine to automatically sort currency by denomination.
(iv) Mutilated or torn currency shall be separated by denomination and 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.
(v) 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.
(vi) Except as provided in subparagraph (vii), each denomination of currency shall be counted separately by one count team member who shall place individual bills of the same denomination on the count table in full view of the surveillance cameras. The 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, either verbally or in writing, with that reached by the first count team member.
(vii) A slot machine licensee may aggregate counts by denomination of all currency collected in substitution of the second count required under subparagraph (vi), if the original counts are being performed automatically by a machine that counts and automatically records the value of currency, and the accuracy of the machine has been suitably tested and proven in accordance with subparagraph (viii).
(viii) Currency counting machines utilized to count and strap currency, gaming vouchers and coupons may be used if:
(A) Prior to the start of each slot or table game count, the counting machine is tested in accordance with the procedures contained in the slot machine licensee’s internal controls to verify the accuracy of the counting machine.
(B) The counting machine automatically provides two separate counts of the funds at different stages of the count process and, if the separate counts are not in agreement, document the discrepancy.
(C) The counting machine is capable of determining the value of a gaming voucher or coupon by independently examining information printed on the gaming voucher or coupon. The information is used by the counting equipment to either calculate the value internally or obtain the value directly from the gaming voucher system or coupon system in a secure manner. When the gaming voucher system is utilized to obtain the value of a gaming voucher or coupon, the gaming voucher system must perform a calculation or integrity check to ensure that the value has not been altered in the system in any manner since the time of issuance.
(ix) A gaming voucher or coupon deposited in a slot cash storage box or table game drop box from a fully automated electronic gaming table or an electronic wagering terminal shall be counted and included in the calculation of revenue without regard to the validity of the gaming voucher or coupon.
(4) Procedures for scheduled breaks to be taken by the count team members during the count. This submission must also address the use of restroom facilities that are located in the count room.
(5) Procedures governing the proper wearing and immediate inspection of jumpsuits worn by the count team members to ensure that items are not taken from the count room without proper authority and that the jumpsuits have not been altered in any way. The count team is prohibited from removing the jumpsuits from the licensed facility.
(b) A slot machine licensee shall file with the Bureau of Casino Compliance, in accordance with § 601a.10(g) (relating to approval of table game layouts, signage and equipment), a schedule setting forth the times during which the contents of slot cash storage boxes, table game drop boxes from table games that are not fully automated electronic gaming tables or electronic wagering terminals and table game drop boxes from table games that are fully automated electronic gaming tables or electronic wagering terminals are to be counted and recorded. The slot machine licensee shall file notice with the Bureau of Casino Compliance and obtain verbal approval from the casino compliance supervisor at the licensed facility prior to deviating from the count schedule.
(c) Immediately prior to the commencement of the count, a count room employee shall notify the surveillance department that the count is about to begin so that surveillance can record the entire count process as required under § 465a.9(e)(8) (relating to surveillance system; surveillance department control; surveillance department restrictions).
(d) Except as otherwise provided in this section, access to the count room during the counting process shall be limited to the count team and those individuals whose presence is necessary to complete the count. The count team shall consist of at least three employees. Employees in the count room who are conducting the count may not, during the counting process, enter a storage area for slot cash storage boxes, table game drop boxes or other items that are part of the count room to perform any function that is not directly related to the counting process.
(e) The opening, counting and recording of the contents of table game drop boxes from table games that are not fully automated electronic gaming tables or electronic wagering terminals may not commence until a casino compliance representative is present in the count room. If the casino compliance representative has to leave the count room during the table game count, the count shall be suspended and all personnel in the count room shall vacate the count room until a casino compliance representative is available to observe the resumption of the count.
(f) All count team members and the casino compliance representative observing a count shall sign a Count Room Attendance Sheet. Any individual who enters or leaves the count room due to an emergency shall sign and record the time of entry or exit on the Count Room Attendance Sheet. When the individual exiting the count room is unable to sign the document due to the emergency, the count room supervisor shall record the individual’s name and time of exit and a notation describing the emergency on the Count Room Attendance Sheet. At the conclusion of the count, a copy of the Count Room Attendance Sheet shall be given to the casino compliance representative.
(g) Individuals who are in or who enter the count room when uncounted funds are present shall wear a full-length, one-piece, pocketless jumpsuit with the exception of representatives of the Board, the Department, the Pennsylvania State Police, the security department and the internal audit department.
(h) Individuals present in the count room when uncounted funds are present may not:
(1) Carry a handbag or other container unless it is transparent.
(2) Remove their hands from or return them to a position on or above the count table or counting equipment unless the backs and palms of the hands are first held straight out and exposed to the view of other members of the count team and a surveillance camera.
(i) Once the counting process has started, the doors to the count room shall only be opened for one of the following purposes:
(1) To allow the entire count team to take a scheduled work break.
(2) To allow for a change of casino compliance representatives.
(3) To allow a main bank cashier or cage supervisor to enter the count room to perform the responsibilities in subsection (n) or (o)(6).
(4) To allow the placement of a slot cash storage box or table game drop box or to remove a trolley, empty slot cash storage boxes or table game drop boxes from the count room.
(5) To allow the count team and the casino compliance representative to exit the room at the conclusion of the count.
(6) In the event of an emergency.
(j) If any individual enters or leaves the count room during the counting process, employees remaining in the count room shall display their hands and step away from the count table, banking table and counting equipment until the individual has entered or left the count room.
(k) The counting and recording process shall be discontinued when less than three count team members are present in the count room. When the entire count team takes a scheduled break, all cash that has been removed from the slot cash storage boxes or table game drop boxes shall be counted at least once and secured in a manner approved by the Bureau of Casino Compliance before any member of the count team may leave the count room.
(l) Once the counting process has been started, a member of the count team shall notify surveillance when the count room door will be opened.
(m) All table game drop boxes from table games that are not fully automated electronic gaming tables or electronic wagering terminals shall be counted and recorded at least once each gaming day. The slot machine licensee shall designate which slot cash storage boxes and table game drop boxes from fully automated electronic gaming tables and electronic wagering terminals will be counted and recorded each gaming day. The following shall be counted and recorded separately:
(1) Slot cash storage boxes and table game drop boxes from fully automated electronic gaming tables and electronic wagering terminals.
(2) Table game drop boxes from banking games that are not fully automated electronic gaming tables or electronic wagering terminals.
(3) Table game drop boxes from nonbanking games.
(n) After the contents of slot cash storage boxes and table game drop boxes from fully automated electronic gaming tables and electronic wagering terminals have been removed and counted, a count team member shall present the currency to a main bank cashier or cage supervisor in the count room who shall recount, either manually or mechanically, the currency prior to having access to the information recorded by the count team.
(o) Table game drop boxes from table games that are not fully automated electronic gaming tables or electronic wagering terminals shall be counted and recorded as follows:
(1) As the contents of each table game drop box are counted, a count team member shall manually record the results of the count on the Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report or a computer system. The Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report must be a three-part form consisting of an original and two duplicates. The distribution of the Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report shall be as follows:
(i) The original shall be delivered to revenue audit by the count room supervisor immediately after leaving the count room at the conclusion of the count.
(ii) The second copy shall be retained by the casino compliance representative observing the count.
(iii) The third copy shall be retained by the cage supervisor or main bank cashier.
(2) After the contents of each table game drop box from a banking table game are counted, a member of the count team shall record, manually on the Daily Banking Table Game Count Report or electronically on a computer system, the following information for each banking table game drop box:
(i) The value of each denomination of currency counted.
(ii) The total value of all denominations of currency counted.
(iii) The gaming date of the items being recorded, the total number of banking table game drop boxes opened and counted and the date that the Daily Banking Table Game Count Report is being prepared or generated.
(3) After the contents of each table game drop box from a nonbanking table game are counted, a member of the count team shall record, manually on the Daily Nonbanking Table Game Count Report or electronically on a computer system, the following information for each nonbanking table game drop box:
(i) The value of Poker rake chips counted.
(ii) The value of value chips counted.
(iii) The total value of Poker rake chips and value chips counted.
(iv) The gaming date of the items being recorded, the total number of nonbanking table game drop boxes opened and counted and the date that the Daily Nonbanking Table Game Count Report is being prepared or generated.
(4) After preparation of the Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report or the electronic equivalents prepared on a computer system, the count team members and the count room supervisor shall sign the reports attesting to the accuracy of information recorded thereon. The count room supervisor shall verify that all of the table game drop boxes from table games that are not fully automated electronic gaming tables or electronic wagering terminals that were collected and opened by count team members have been recorded on the reports.
(5) Once all currency has been counted and the final count totals have been obtained, employees may not be permitted to leave the count room, except in an emergency, until the recount and presentation procedures in paragraph (6) have been completed.
(6) After the contents of all table game drop boxes from table games that are not fully automated electronic gaming tables or electronic wagering terminals have been removed and counted, all cash, value chips and Poker rake chips shall be presented in the count room by a count team member to a main bank cashier or cage supervisor who, prior to having access to the information recorded on the Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report or electronic equivalents and in the presence of the count team members and the casino compliance representative, shall recount, either manually or mechanically, the currency, value chips and Poker rake chips presented in accordance with the following requirements:
(i) The main bank cashier or cage supervisor shall have physical access to all currency, value chips and Poker rake chips presented for recounting. Currency, value chips or Poker rake chips for recounting may not be wrapped or placed in a sealed bag or container until the entire recount has been completed and the Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report or electronic equivalents have been signed by the entire count team, the count room supervisor, the main bank cashier or cage supervisor and the casino compliance representative.
(ii) The main bank cashier or cage supervisor may bulk count all strapped currency.
(iii) All partial straps, loose currency, mutilated or torn currency, value chips and Poker rake chips shall be recounted by the main bank cashier or cage supervisor either by hand or with an approved counting device.
(iv) The casino compliance representative may direct that currency straps of any denomination be recounted by the main bank cashier or cage supervisor, either by hand or by counting equipment, if a discrepancy either in denomination total or grand total is discovered during the initial bulk recount.
(v) Upon completion of the recount, the main bank cashier or cage supervisor shall attest by signature on the Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report or electronic equivalents the amounts of currency, value chips and Poker rake chips counted, after which the casino compliance representative shall sign the report evidencing his presence during the count and the fact that both the main bank cashier or cage supervisor and count team have agreed on the total amounts of currency, value chips and Poker rake chips counted.
(vi) When all required signatures have been obtained, the second copy of the Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report or electronic equivalents shall be given to the casino compliance representative and the third copy shall be retained by the cage supervisor or main bank cashier.
(vii) The original Daily Banking Table Game Count Report and the Daily Nonbanking Table Game Count Report or electronic equivalents, the Requests for Fills, the Fill Slips, the Requests for Credits, the Credit Slips, the issuance copy of the Counter Checks, the Table Inventory Slips and any other supporting documentation shall be transported directly to the accounting department and may not be available to cage personnel.
(7) A count room employee, in the presence of the casino compliance representative who observed the count, shall conduct a thorough inspection of the entire count room and all counting equipment located therein to verify that no currency, value chips, Poker rake chips, Counter Checks, gaming vouchers, coupons or supporting documentation remains in the room.
(p) If any problems occur with the slot or table count procedures or machines (for example, computer interface malfunctions or strap overages or shortages), the problems shall be brought to the immediate attention of a casino compliance representative and a detailed written report explaining the problem, the reason for the problem and the corrective action taken shall be filed by the count room supervisor or above with the casino compliance representatives within 24 hours of the conclusion of the count.
(q) Notwithstanding the requirements of this section and § 465a.18 (relating to transportation of slot cash storage boxes and table game drop boxes to and from the gaming floor; storage), a slot machine licensee may submit, as part of its internal controls, alternate procedures for the separate collection, distribution, opening and counting of nonbanking table game drop boxes in a room, other than the count room, provided that:
(1) The room for the counting of nonbanking table game drop boxes shall be dual access controlled by the finance department and the security or surveillance department and covered by the slot machine licensee’s surveillance system.
(2) Immediately prior to the commencement of the nonbanking table game count, an employee of the finance department who is participating in the count shall notify the surveillance department that the count is about to begin so that surveillance can record the entire count process as required under § 465a.9(e)(8).
(3) The count shall be conducted by at least two employees of the finance department who are not assigned as Poker room cage employees on that gaming day and who have no incompatible duties.
(4) The opening, counting and recording of the contents of nonbanking table game drop boxes may not commence until a casino compliance representative is present. If the casino compliance representative has to leave or if less than two finance department employees are present, the count will be suspended until at least two finance department employees and a casino compliance representative are present.
(5) Individuals who participate in the nonbanking table game count may not remove their hands from or return them to a position on or above the count table unless the backs and palms of the hands are first held straight out and exposed to the view of other finance department employees involved in the count and a surveillance camera.
(6) The contents of each nonbanking table game drop box shall be counted and recorded in accordance with subsection (o)(1) and (3). After preparation of the daily nonbanking table game count report or the electronic equivalents prepared on a computer system, the finance department employees who participated in the count shall sign the report attesting to the accuracy of the information recorded thereon. Once the contents of the nonbanking table game drop boxes has been counted and the final count totals have been obtained, employees may not leave the room, except in an emergency, until the recount and presentation procedures in paragraph (7) have been completed.
(7) The cash, value chips and Poker rake chips removed from the nonbanking table game drop boxes shall then be presented to a cage supervisor who did not participate in the count and shall be recounted and recorded in accordance with subsection (o)(6).
(8) The slot machine licensee shall submit procedures governing how scheduled work breaks will be conducted, if any, during the nonbanking table game count.
Authority The provisions of this § 465a.25 amended under 4 Pa.C.S. § § 1202(b)(30), 1207, 13A02(1)—(6), 13A25, 13A62(a) and 1322.
Source The provisions of this § 465a.25 amended October 10, 2008, effective October 11, 2008, 38 Pa.B. 5652; amended September 25, 2009, effective September 26, 2009, 39 Pa.B. 5562; amended May 11, 2012, effective May 12, 2012, 42 Pa.B. 2585; amended December 15, 2017, effective December 16, 2017, 47 Pa.B. 7563. Immediately preceding text appears at serial pages (375111) to (375118) and (377549).
Cross References This section cited in 58 Pa. Code § 465a.36 (relating to table inventories); 58 Pa. Code § 465b.2 (relating to prepaid access instrument transactions—technical standard); 58 Pa. Code § 601a.9 (relating to table game taxes and gross table game revenue); 58 Pa. Code § 601a.10 (relating to approval of table game layouts, signage and equipment); 58 Pa. Code § 603a.20 (relating to Match Play Coupons; physical characteristics and issuance); and 58 Pa. Code § 609a.19 (relating to use of an electronic credit system for the processing of Counter Checks and customer deposits).
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