FMD 2018 Level I Training Book

FMD 2018 Level I Training Book

March 21 - 23, 2017 WeKoPa Resort & Conference Center Ft. McDowell, AZ

NIGA Seminar Institute Commissioner Certification Training LEVEL I AGENDA March 21 - 23, 2018 WeKoPa, Fort McDowell, Az

NATIONAL INDIAN GAMING ASSOCIATION

Wednesday, March 21

8:00 AM 9:00 AM

Breakfast to be provided

Managing a Tribal Gaming Regulatory Authority Richard Chissoe, Wacontse Consulting

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

Basic Principles of Casino Accounting Ryan Burns, CPA, Partner Blue Bird CPA's

10:45 AM 12:15 PM

12:15 PM 1:15 PM

Lunch Break

Anatomy of a Gaming Machine Brandon Griffith, SIQ

1:15 PM 2:45 PM

2:45 PM 3:00 PM

Break

Auditing: Financial Audits Ryan Burns, CPA, Partner Blue Bird CPA's Thursday, March 22

3:00 PM 4:30 PM

8:00 AM 9:00 AM

Breakfast to be provide d

Indian Gaming Regulatory Act: An Introduction Liz Homer, Homer Law

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

Tribal Gaming Regulatory Agency: Purpose, Functions & Structure Liz Homer, Homer Law

10:45 AM 12:15 PM

12:15 PM 1:15 PM

Lunch Break

What's the Big Deal - MICs Liz Homer, Homer Law

1:15 PM 2:45 PM

2:45 PM 3:00 PM

Break

Gaming Compacts & Compact Compliance Liz Homer, Homer Law Friday, March 23

3:00 PM 4:30 PM

8:00 AM 9:00 AM

Breakfast to be provided

Introduction to Enforcement Actions Liz Homer, Homer Law

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

Rules of the Games – Classification of Games Liz Homer, Homer Law

10:45 AM 12:15 PM

Please plan to stay for the entire class on each day to get your certificate of completion. Please be on time for sessions

3/21/18

National Indian Gaming Association: Gaming Commissioners Certification Level I

Richard Chissoe Wacontse Consulting

Why Do Tribal Gaming Agencies Exist? In order to conduct gaming on Indian Lands, the Indian Gaming Regulatory Act (IGRA) requires a Tribe to enact a Gaming Ordinance that ensures: • That the Tribe will have the sole proprietary interest and responsibility for the conduct of any gaming activity ; • That gaming revenues will not be used for any impermissible purpose; • That outside independent audits of the gaming operation will be conducted annually ; • That gaming facilities are constructed and maintained in a manner that protects the environment, public health, and safety ; • That background investigations are conducted on key employees and primary management officials, and that oversight of management is conducted on an ongoing basis – this includes the issuance of licenses, as well as suitability standards designed to exclude unsuitable persons fromworking in the operation .

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Additionally…

IGRA affirms that: “ Indian tribes have the exclusive right to regulate gaming activity on Indian lands if the gaming activity is not specifically prohibited by Federal law and is conducted within a State which does not, as a matter of criminal law and public policy, prohibit such gaming activity.

How Does a Tribe Satisfy IGRA’s Mandates? By the creation of a Tribal Government Agency – a Tribal Gaming Regulatory Authority (TGRA) - that is authorized through the Tribal Gaming Ordinance to regulate gaming activity on behalf of the Tribe; to implement the provisions of IGRA by enacting and enforcing regulations that govern the conduct of gaming by tribal operators; and to ensure that gaming is conducted fairly and that the assets of the Tribe are protected. In most instances, the persons delegated by the Tribe to oversee and manage the TGRA are Appointed Officials and may, in turn, appoint an Executive to manage the agency on a day-to-day basis (i.e., an Executive Director).

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Tribal Gaming Commissioners: Common TGRA structures found in Tribal Gaming Ordinances:

• One Commissioner : A single appointed or elected person who serves as both the Regulatory Official and the full-time Manager of the TGRA. Efficient, but no distribution of authority. • Three Commissioners : Appointed or elected. Often with one serving as “Lead/Chair Person” (who may or may not be full-time) and two “lower” Commissioners. More distribution and division of authority, but may be less efficient than a single Commissioner. • Five Commissioners : Similar to three Commissioners, one may serve as the official “Head” of the TGRA. More division of authority and duties, with some Commissioners having specialized duties (i.e. one presides over all hearings). • Executive Director : Manages the TGRA on behalf of the Commissioners. Responsible for day- to-day regulatory and administrative functions of the TGRA. Acts on the directives of the Commissioners.

What Does Managing a TGRA Include? • Organizing functional divisions within the TGRA that enable the Agency to meet its statutory mandates adequately and efficiently; • Staff selection, training, and management; • Strategic planning and self-evaluation; • Budgetary projection and management; • Developing communication protocols and policies, both internal and external; • Developing document retention policies; • Understanding the larger Tribal Government infrastructure; • Being politically competent…

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That’s Right…Politics With most TGRA leaders serving as either appointed or elected officials, it is virtually impossible to avoid the political dynamics of Tribal Government. • Conflict between governmental branches regarding persons appointed/not appointed, or confirmed/not confirmed to serve as Commissioners; • The TGRA’s as an “independent” agency; • Taking regulatory actions that may be politically unpopular; • The political strain associated with appropriating an expensive agency budget; • Village/Clan/Family affiliations – or Member/Nonmember status; • Political loyalties – real or perceived; • What else??

Politics…still With the inescapable political implications inherent to managing TGRAs, Regulatory Officials must be “politically competent” in that: • They are aware of the politics of the Tribe, can anticipate the likely political reactions to specific Agency actions/activity, and when possible, can craft ways to mitigate political blowback while still meeting the Agency’s objectives; • They are aware of the political authorities that impact the TGRA and, to the extent possible, they are aware of the personalities, motivations and priorities of those authorities. They consider these factors in Agency decision-making; • They understand and consider not only the politics of the Tribal Government, but also the politics of the Tribal Community. • They are able to realistically “weigh” regulatory benefit against political cost.

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War Stories??

Can you give an example of when/how tribal politics affected your TGRA in a significant way?

Were you aware of the relevant political dynamics beforehand?

What did you do?

Can you give an example of when/how your TGRA was able to successfully navigate the politics surrounding an issue while still achieving the Agency’s objective.

Q: What Helps Insulate a TGRA from Politics? A: The Agency’s Lawful Regulatory Authority

— Where does the TGRA’s authority come from? — Where does it not come from? — What is the scope of that authority? — Who decides the scope?

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Statutory/Regulatory Resources…How They Help: • Tribal Gaming Ordinance: Mandates express and implied duties of the TGRA. • IGRA: Establishes non-negotiable federal requirements for the TGRA. • Tribal SOP’s: Sets forth administrative requirements for the TGRA. • NIGC Regulations: Implements broader federal statutory requirements. • Tribal State Compact: Sets forth requirements to which the Tribe agreed through formal government-to-government contract. • Tribal Internal Control Standards: Promulgated pursuant to the federal MICS. Largely restate the federal regulatory standards. • TGRA’s Internal Policies and Procedures: Shows that the Agency doesn’t just make it up as it goes along.

Balance As a Regulatory Official, you must always remember that you hold a vital position of authority. The Tribe’s system of regulation presumes that the Regulatory Official will exercise appropriate authority to achieve the mandates of the Ordinance. But authority must be executed with the balance of prudence and proportionality.

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Team Part of managing a TGRA successfully is understanding that you can’t do it all by yourself. You have a team of regulators around you; persons of various expertise and talents. You hire them. You train them. You motivate them. Manage and value your TGRA as your team.

The Hit List…

Top 10 Hits for Managing a TGRA Successfully…

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Top 10… 1. Understand Where the TGRA’s Authority Comes From, and Where it Doesn’t : Know the applicable Statutory/Regulatory basis for how your TGRA functions, as well as the Agency’s mandates under those Statutes/Regulations. 2. Understand Tribal Budgeting : Know the specifics of how your TGRA is funded. From fees? From the Tribe’s general fund? From both? What restrictions does your budget operate under? 3. Understand the Tribe’s Policies and Procedures : HR, Accounting, Payroll, Purchasing and Procurement, Facilities, I.T., Travel/Training, GSA, Contracting, Legal, Communications. Know if, and under what circumstances, the TGRA may follow its own policy. 4. Be Politically Competent : This is does not mean allow politics to govern the Agency’s decisions, but be aware of the political dynamics of the Tribe, possible political reactions, and be able to realistically “weigh” regulatory benefits against political costs. 5. Hire, Train, and Cultivate a Team : You can’t do it all by yourself. Build up and motivate capable people to form a reliable team. 6. Develop and Standardize Internal Agency Protocols : You will always be prepared to show that your Team doesn’t just make it up as they go along.

Top 10… 7. Balance : Have the courage to make the tough calls, while at the same time having the discipline and patience to act shrewdly, proportionately and always in the Tribe’s best interest. 8. Accountability of Funds : Document and justify expenditures. Always remember that the TGRA operates from the People’s money. Be fiscally responsible. 9. Handle Personnel Issues : Whether it’s helping a staff member resolve a benefits problem, or addressing a difficult employee who is poisoning the working environment, don’t let Agency morale suffer because you avoid handling personnel matters. 10. Know your administrative resources : Know the duties and responsibilities of the Tribe’s Administrative Staff. Know who to go to for help/guidance on different issues. Submit required documents, reports, and information to the Admin Staff in a timely manner. Try to make their life a little easier. It does not go unnoticed. Earn a reputation for being diligent, reasonable, and forthcoming when it comes to addressing administrative issues with the Tribe’s Admin Staff. They will almost always do that little bit extra to help you when the time comes.

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Questions? Comments? More War Stories?

Thank You!

Richard C. Chissoe Wacontse Consulting [email protected] (505) 659-6235

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10/30/17

Basic Principles of Casino Accounting

Ryan Burns, CPA Partner BlueBird, CPAs

Accounting Functions – What do they do? • Revenue Audit? • Other Accounting/Finance personnel? • Note: This differs from the tasks that Internal Auditor performs • Internal Auditor must have basic working knowledge of Accounting to review certain items

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Revenue Audit & The Casino

Revenue Audit • Responsible for reconciling daily casino paperwork throughout the casino

• First defense in review for compliance and internal control issues

• Summarize daily paperwork

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Various Financial Statements • External Financial Statements – Lenders, Regulatory Agencies (NIGC, Compacts), Tribal Council & Tribal Gaming Commissions – to be discussed in the next session • Internal Financial Statements - Property Management for Analysis (Flash Reports, P/L Summaries, Condensed Financial Information)

What is unique about Tribal Casino Accounting? • GAAP Issues (Net Win, State Fees, GASB, etc.) • Layers of Regulations (TRGC, State, NIGC) • Cage/Vault Accountability • 24-Hour Operations / Staggered Drop • Volume of Cash Transactions • No source revenue documentation (invoice, shipping document, etc.)

• Reliance on Computer Systems • Tribal Government Transactions

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Flow of Financial Information in a Casino

CAGE PAPERWORK

BANK STATEMENT

GENERAL JOURNAL

PAYROLL REGISTER

CHECK REGISTER

THE GENERAL LEDGER

COMPUTER SLOT SYSTEM

THE TRIAL BALANCE

ADJUSTMENTS

FINANCIAL STATEMENTS

AICPA Gaming Audit & Accounting Guide • AICPA Casino Audit Guide o The AICPA Audit and Accounting Guide Audits of Casinos (the Guide) was originally issued in 1984. The Guide was not revised or amended, other than for conforming changes, since its issuance until 2011 (updated 2012) • Why the need for change? o Shift from primarily table games when original casino guide established to slot play. o Impact of technology. o Impact of multiple jurisdictions and the introduction of Native American gaming. o Diversity in practice. o Accounting and auditing issues not contemplated in the existing Guide.

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AICPA Gaming Audit & Accounting Guide

What Makes Casino Accounting So Different?

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Casino Cage Accountability

Casino Cage Accountability - Continued

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Gaming Revenues Gross vs. Net (Chapter 3) • Gross Gaming Revenue = The difference between gaming wins and losses from banked games before deducting incentives or adjusting for changes in progressive jackpot liability accruals. • Net Gaming Revenue = Gross Gaming Revenue – incentives +/- change in progressive jackpots + revenue from related gaming activities.

Accounting for Incentive Programs (Slot Clubs, Promos, etc.) • Incentives to play should be characterized as either: (1) marketing incentives to induce potential customers to enter into transactions (Discretionary); or

(2) loyalty programs for customers based on activities or transactions undertaken (Non- discretionary).

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Incentive Programs

• Free play: o Discretionary – should be revenue neutral, no accrual (watch out for statistical reports!!) o Non-discretionary – accrue estimated cost and treat as a contra revenue • Cash or cash equivalent incentives: o Discretionary – net against revenue o Non-discretionary – accrue estimated cost and treat as a contra revenue • Complimentaries: o Discretionary – report as expense rather than reduction of revenue o Non-discretionary – accrue estimated cost of providing comps to expense

Governmental Gaming Entities (Chapter 12) • Financial Statements & Disclosures • Allocation of Assets & Liabilities (Tribal Government vs. Casino) • Reporting of Transactions Between the Tribal Government & Casino • Cost Allocations • Asset Impairments

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Interfund Transactions

• Transfers / Distributions • Quasi-External Transactions • Fees / Taxes • Reimbursements • Interfund loans and advances

Reconciliation and IGRA Compliance

Guide Changes Proposed 1. Income Statement Presentation - including complimentary sales with a reduction for promotional allowances will no longer be an option. The complimentary revenue must be excluded all together from the revenue line items. 2. Clarification that cash sales incentives/change in progressive jackpot liabilities should be accounted for as a contra revenue. 3. Tier Status, this is an interesting addition. A determination of tier level benefits will need to be performed to determine whether the customer has: (a) received a material right relating to future goods or services or (b) is receiving a marketing or promotional offer as an incentive to obtain future revenue. Accordingly a material right would represent an obligation that would need to be valued and recorded with other liabilities. 4. Jackpot insurance premiums and proceeds received will now be recorded as expense and other income, respectably, rather than as a component of net gaming revenues. 5. Clarification is provided that adjustments to chip/token floats due to breakage estimates or chip line discontinuation are to be recorded as a component of net gaming revenues.

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Basic Casino Accounting – Month End Items • Reconciling all bank accounts? • Reconciling cage accountability? • Recording asset purchases? • Accounts payable (subsidiary)? • Other liabilities? • Amounts due to/from other Tribal entities? • Transfers to/from other Tribal entities?

Basic Casino Accounting – Month End Items, Cont’d. • In-house progressive jackpot liabilities? • Wide area progressives?

• Participation fees? • Non-cash prizes? • Unredeemed ticket liabilities? • Hopper adjustments?

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Basic Casino Accounting – Month End Items, Cont’d. • Players’ club points & incentives? • Tournament entry fees and payouts? • Bonus and double jackpots?

• Comps and promotional allowances? • Cash giveaways and other incentives?

• Unclaimed jackpots? • Jackpot insurance? • Chip/token liability? • And more…

Reconciliation between Net Win in the Financial Statements and Net Win for Fee Computations (NIGC & State) • Reconciliation between the on-line system report, sharable revenues, and monthly financial statements

• Communications with the NIGC • Communication with the State

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Common Red Flag Indicators – Financial Controls • Unstable management team / council • Number, $ value, and nature of adjusting journal entries posted during the year-end audit • Management is not receptive to explaining the monthly financial statement variances • Management does not issue financial statements in a timely manner; or issues financial statements very quickly • Variances between actual and budgeted amounts are not reviewed departmental managers

Red Flag Indicators – Financial Audits • Deficiencies / delinquencies in Accounting / Finance Management • Significant and periodic changes in monthly financial statements previously issued • Regulators (State, IRS, TGRA, etc.) have difficulty in performing or resolving audit issues • Re-occurring audit issues / findings

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Cooking the Books – Why Do It? • Conceal Asset Theft (Cash, Inventory, Equipment, Etc.) • Management Company or Investor Fee Calculations • Obtain Financing, Attract Buyers / Investors, Etc. • Structure of Executive Bonuses and/or Evaluation? • Compliance with Loan Covenants • Compliance with Regulatory Requirements (RAP, Etc.) • Increase Per Capita Allowances • Conceal Budget Variances

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Cooking the Books – How Do They Do It? • Timing Differences (Accrual Basis) • Improper Asset Valuation (Cash, Inventory, Capital Assets) • Concealed Liabilities and Expenses • Classification and Allocation of Expenses

• Change in Accounting Estimates • Inadequate Controls or Collusion

Recommended Areas of Review (Based on Your Risk Assessment!) • Adherence to Procurement Polices (Capital Projects & Significant Vendors) • Compact Fees & Underlying Computations • Management Company Fees; Underlying Computations; and Significant Related Estimates. • Compliance with Loan Covenants (Financial and Non-Financial) • Transactions with the Tribal Government (Transfers, Loans, Reimbursements)

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Recommended Areas – Contd. • Review of Compliance With Gaming Revenue Distribution Plan and Tax Reporting Compliance (Per-Capita) • Payroll & Bonus Computations • Cash / Investment Risk (Custodial Risk, Interest Rate Risk, Market Risk, etc.) • Non-Gaming Revenue Centers (Hotel, F&B, etc.)

BlueBird Certified Public Accountants Scholarship for Native American Accounting Students Profession Highlights: • Significant Demand for Accounting Graduates; $50K+ Starting Salaries • Public, Private, Corporate, Tribal, Governmental • Accounting, Tax, Audit, Consulting Tracks • General Business Leadership and Entrepreneurship • Accounting is the Language of Business • Based in Principles of Ethics, Confidentiality, and Independence

• Significant Current Shortage of Natives in the Profession • Certification Tracks (CPA, CIA, FCPA, CGMA, CFE, Etc.)

www.bluebirdcpas.com/scholarship

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California Indian Culture and Sovereignty Center The CICSC fosters collaborative research and community service relationships between the students of CSU San Marcos and members of Tribal communities, for the purpose of developing and conducting research projects that support the maintenance of sovereignty and culture within those communities.

Cecilia Bowsley Cecilia Bowsley is a member of the Navajo Nation. She is a college Junior at Northern Arizona University and will graduate next year with her Bachelor of Science in Accountancy and will continue on to pursue her Master’s in Accounting.

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Shelby Enloe Shelby Enloe is a member of the Choctaw Nation of Oklahoma and Cherokee Nation. She is attending Northeastern Oklahoma State University and majoring in accounting.

Caytlin Nenema Caytlin Nenema is a member of the Kalispel Tribe of Indians in Washington. Caytlin is attending the University of Montana earning her degree in Accounting.

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Ida Williams Ida Williams is a graduate student at Gonzaga University majoring in American Indian Entrepreneurship. Williams is a member of the Flandreau Santee Sioux Tribe but also identifies herself as Oglala Lakota, Cheyenne, and Lac du Flambeau Ojibwe.

Thank You!

Ryan Burns [email protected]

5585 Kietzke Lane | Reno, NV 89511 Phone: 775.827.5999 | Fax: 775.827.2104 [email protected] | www.bluebirdcpas.com

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Anatomy of a Slot Machine March 2017

companyconfidential

Anatomy • Discuss the following parts, and why they are important – Hardware • Cabinets • Logic Boxes

• Machine peripherals • External peripherals • Operating System • Main Programs • Game Programs • Other software

– Software

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Cabinet

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Cabinets • Why are cabinets important?

– Regulations govern the materials used – Provide security for the device – Provide shielding from electromagnetic interference, static, etc. – Should prevent player injuries

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Logic Boxes / Areas

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Processors

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Logic Areas • Why is the logic area so important?

– Contains the Central Processing Unit (CPU) – Contains the Program Storage Media – Communications – Random Number Generator – Responsible for Game Determination – Responsible for Self Authentication – Responsible for Accounting – Responsible for Event tracking and logging – Responsible for Game History – … – Basically, the brain and heart of a machine

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Peripherals • Bill Validators

– Reads tickets & Bills – Checks for counterfeits – Checks for cheating techniques – Places redeemed notes in stacker – Securely stores tickets & bill until drop – Sensors detect placement & movement – Made of high strength plastic or metal – Keyed separately of other components

• Stackers

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Peripherals • Printers

– Tickets / Vouchers – Coupons – Jackpot Receipts

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Peripherals

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Peripherals • Progressive Controllers & Meters/Displays • Bonus equipment • Slot System Player Interfaces • Slot System Interfaces • Secondary System Interfaces

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Operating Systems

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Operating Systems • Can be part of the Main Program or separate • Usually an embedded version of Microsoft Windows or Linux (BusyBox) • Allows for the manufacturers Main Program and Game Software to interact with the hardware of the gaming device • Can be controlled if it contains manufacturer code

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Main Software • The Main Software provides a framework for the Game Software to use. • Responsible for accounting / metering • Responsible for event tracking and reporting • Responsible for Random Number Generator • Responsible for Communication to Systems • Responsible for accepting money and printing tickets • Contains authentication code

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Game Software • Game Software controls the theme and play of the game. • May contain the sounds and graphics or could be separate • Responsible for use of the RNG output • Responsible for the Math and payouts • Responsible for bonuses

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Other Software • Progressive Controllers • Player Interface or Service Windows

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10/30/17

Auditing: Financial Audits & Agreed-Upon Procedures

Ryan Burns, CPA Partner, BlueBird, CPAs

Introduction What do you want to learn in this class?

__________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________

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Session Agenda

• Financial Statement Audits • Agreed-Upon Procedures

What is an Audit? • An examination and verification of a

company’s financial and accounting records and supporting documents by a professional such as a Certified Public Accountant.

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What is an Audit?

CPA Work Scope & Standards: • Financial Statement Audit (GAAP & GAAS) • Financial Statement Review (GAAP & SSARS) • Operational Agreed Upon Procedures (Efficiency & Effectiveness) • Compliance AUP (Laws & Regulations) • Consulting Engagement • CPA Licensing

Why Financial Audit? • Accountability to Tribal Council and Tribal Membership • Accountability to External Financial Statement Users • IGRA, NIGC, Tribal Gaming Ordinance, State Compact

• Filing Deadlines:

o 120 Days – NIGC o Penalties up to $25,000/Day o State Compact (Depends) o NIGC TB 2009-1

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Scope of Financial Audit Work? • Financial Statement Audit (IGRA) – Gaming Activities • Gaming Vendor Testing (>$25,000) • Communication Letters (NIGC TB 2009-1)

Various Financial Statements • External Financial Statements – Lenders, Regulatory Agencies (NIGC, Compacts), Tribal Council & Tribal Gaming Commissions • Internal Financial Statements - Property Management for Analysis (Flash Reports, P/L Summaries, Condensed Financial Information)

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Exercise What do you want to know from your auditor? __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________ __________________________________________

The Financial Audit Report Contents

• Auditor’s Opinion • MD&A (if included) • Financial Statements • Notes to the Financial Statements • Supplementary Schedules (if included)

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Types of Audit Opinions

• Unmodified (a clean bill) • Qualified (with some reservation) • Adverse (financials are not presented in accordance with GAAP) • Disclaimer (unable to form an opinion)

• Going Concern or Other Significant Emphasis Notations

Example of An Opinion

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Tribal Casino Financial Statements • Balance Sheet / Statement of Net Position • Statement of Revenues, Expenses, and Changes in Net Position • Cash Flow Statement

Gaming Audit Accounting Guide

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Gaming Audit Accounting Guide

Statements of Net Position

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Statements of Net Position Continued

Statements of Revenues, Expenses, and Changes in Net Position

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Statements of Revenues, Expenses, and Changes in Net Position - Continued

Cash Flows Statements

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Cash Flows Statements - Continued

Financial Statement Notes

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Financial Statement Notes

Financial Statement Notes

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Financial Statement Audit Considerations • Consolidation for Multiple Tribal Gaming Entities • Financial Statement Reviews for Those Entities