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Training Material Level II- NYNY Las Vegas Dec 2019

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Training Material Level II- NYNY Las Vegas Dec 2019

Dec 11 - 13 , 201 9 NY/NY Hotel & Casino

Las Vegas , N evada

NIGA Seminar Institute Commissioner Certification Training

NATIONAL INDIAN GAMING ASSOCIATION

LEVEL II AGENDA December 11-13, 2019 NYNY, Las Vegas, Nevada

Wednesday, December 11

8:00 AM 9:00 AM

Breakfast to be provided

Journey of Submission Peter Nikiper, Director of Technical Compliance, BMM Test Labs

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

Employment Issues for Regulators Charlene Jackson, Jackson Law

10:45 AM 12:15 PM

12:15 PM 1:15 PM

Lunch Break

Licensing: Vendors & Facilities Billy David, Bo-Co-Pa & Associates

1:15 PM 2:45 PM

2:45 PM 3:00 PM

Break

Licensing: Key Employees & Primary Officials Billy David, Bo-Co-Pa & Associates Thursday, December 12

3:00 PM 4:30 PM

8:00 AM 9:00 AM

Breakfast to be provided Effective Regulatory Writing Liz Homer, Homer Law

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

Tribal Sovereign Immunity and The Gaming Regulator Liz Homer, Homer Law

10:45 AM 12:15 PM

12:15 PM 1:15 PM

Lunch Break

Internal Auditing-What's Required & How it Should Be Approached Sheryl Ashley, Director of Risk Consulting, Blue Bird CPA's

1:15 PM 2:45 PM

2:45 PM 3:00 PM

Break

Financial Controls & Accounting Standards Sheryl Ashley, Director of Risk Consulting, Blue Bird CPA's Friday, December 13

3:00 PM 4:30 PM

8:00 AM 9:00 AM

Breakfast to be provided

Roles of Surveillance Cheats & Scams George Joseph, Worldwide Casino Consulting, Inc.

9:00 AM 10:30 AM

10:30 AM 10:45 AM

Break

Roles of Surveillance Cheats & Scams George Joseph, Worldwide Casino Consulting, Inc .

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

Journey of Submission What happens when a gaming machine is sent to a gaming test lab? February 15, 2017

company confidential

Different laboratories… Do different testing.

Electrical

Safety

Gaming

And many more…

company confidential

General Process

Manufacturersubmits to a lab

The lab tests according to requested standards

The lab issues a report

The TGRA makesa finding basedon the report

company confidential

Submission to the lab 25 CFR 547.5 (c) Submission, testing, and approval – generally. Except as provided in paragraph (b) and (d) of this section, a TGRA may not permit the use of any Class II gaming system, or any associated cashless system or voucher system or any modification thereto, in a tribal gaming operation unless: …

company confidential

Submission to the lab (1) The Class II gaming system, cashless system, voucher system, or modification thereto has been submitted to a testing laboratory;

company confidential

Submission to the lab What does the lab need?

Hardware including peripherals, i.e. BV, printers

Submission letter

Math

Software

Servers

company confidential

Testing (2) The testing laboratory tests the submission to the standards established by: (i) This part; (ii) Any applicable provisions of part 543 of this chapter that are testable by the testing laboratory; and (iii) The TGRA ;

company confidential

Testing Scope of work / Submission management • Each submission is entered into a project tracking system • Kick off meeting – Engineersare assigned to the project

– Resources assigned – Timelineestablished – Any foreseen compliance issues

company confidential

Testing Random Number Generators (RNGs) • Source code review • Algorithm implementation • Samples • Analysis against Die-Hard battery

company confidential

Testing

company confidential

Testing Math Analysis • Review all combinations / patterns (wins & losses) • Calculate the game cycle • Calculate the game volatility • Calculate the RTP / hold or edge • Calculate the top award odds • Compare with manufacturers math • Emulate combinations on device and verify payouts

company confidential

Testing Functional testing

• Generate list of test scripts to be used • Based on Part 547 & 543 for Class II • Based on GLI-11/NV for Class III • Additional tests based on location or tribe the device will go to.

company confidential

Results of Testing (3) The testing laboratory provides a formal written report to the party making the submission, setting forth and certifying its findings and conclusions, and noting compliance with any standard established by the TGRA pursuant to paragraph (c)(2)(iii) of this section;

company confidential

Results of Testing (4) The testing laboratory’s written report confirms that the operation of a player interface prototype has been certified that it will not be compromised or affected by electrostatic discharge, liquid spills, electromagnetic interference, radio frequency interference, or any other tests required by the TGRA;

company confidential

Results If everything works • Technical reviews of the testing • A draft report is generated

• A regulator and/or client review of the report • Final report issued to both regulator and client

company confidential

Results What happens if issues were found during testing? • Document the problem(s) • Steps to reproduce and/or show frequency • Assign a severity (Low to High) • Resubmission or withdrawal of the submission

company confidential

Final part of a submission (5) Following receipt of the testing laboratory’s report, the TGRA makes a finding that the Class II gaming system, cashless system, or voucher system conforms to the standards established by: (i) This part; (ii) Any applicable provisions of part 543; and (iii) The TGRA.

company confidential

Key Items for Class II • Bingo Patterns • Ball Draw Process • Bingo card distribution / generation • Minimum number of players • Game Ending Pattern • Bingo game type • Disclaimers

company confidential

Key Items for Class III • RNG Review & Analysis • Game Determination

• Game Play • Accounting • Game Recall • Emulation • Security

company confidential

12/3/19

Employment Issues and Gaming Regulators

NIGA Level II Commissioner Training

Charlene D. Jackson

Objective Generalized overview of employment law Things to consider ◦Jurisdiction ◦Applicability of law ◦Interpretation ◦Regulatory authority Law cannot be read in a vacuum

12/3/19

Scenario: Edward Employee Edward Employee – resign or be terminated Card dealer, required to stand for long periods of time

Reasonable accommodation requested and granted on paper but not implemented; required to resume normal duties, HR complaint Routine drug test - failed Reinjured back at work; ambulance transported, hospitalized and missed work Resign or be terminated – NC/NS; failed drug test – impact gaming license He says terminated because of union activity

Long term employee and union rep; currently working on increasing wages Hurt on the job when he picked up something heavy Medical care; off work; return to work with limitations and on pain medication Workmen’s compensation paperwork not submitted

Reading the Law – Important Considerations Mandatory versus Discretionary Terms ◦ Must and shall ◦ May and can Qualifiers ◦ Notwithstanding ◦ Except ◦ Provided, however ◦ Commas ◦ And/or Legislative Intent Definitions

12/3/19

Some Examples Fry Bread: Combine flour, salt and baking powder Combine flour, salt or baking powder The power of the comma:

Qualifying language: “That’s not something I’m expecting.” “That’s not something I’m expecting right now.”

Let’s eat Grandma! Let’s eat, Grandma!

Companion Reading Constitution ◦ Bill of Rights, Civil Rights, Indian Civil Rights, Tribal Constitutions Treaties Law ◦ Applicable federal law: IGRA and employment laws ◦ Applicable state law ◦ Tribal Codes and Ordinances, including the Gaming Ordinance Case Law Regulatory Agencies and Decisions Administrative and Human Resource Policies Gaming Compacts including Appendices

12/3/19

Relevant Question: Jurisdiction? Tribal? State? Federal? Regulatory Agency? Concurrent? *Do not assume tribal only jurisdiction Specific applicability

Applicability by terms of a different law, agreement, regulation or policy Interpreted applicability by case law and/or action or facts *Do not assume only tribal law applies *Do not assume state law doesn’t apply

But I’m a Regulator – I Don’t Need to Know this “HR Stuff” Overlap between HR Issues and Regulatory Issues

1 2 3 4 5 6 7 8 9

◦ HR – Suitability for employment and job performance within policy (operational) ◦ Commission – Threat to public interest; regulation of gaming; creation of unfair or illegal practices in conduct of gaming (Regulatory) Stay in your lane – but understand your lanes will overlap or cross Awareness is critical

TRIBAL COURT INDIAN COUNTRY, USA

EDWARD EMPLOYEE, Plaintiff, vs.

Case No.: TC-CV-2017-876

COMPLAINT

TRIBAL CASINO, TRIBAL CASINO CEO, in his individual and as CEO, TRIBAL GAMING BOARD MEMBERS and DEFENDANTS 1-6, unnamed spouses in their professional and individual capacities, TRIBAL GAMING COMMISSIONER and DEFEDANTS 7-14, unnamed spouses, in their professional and individual capacities. Defendant

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

COMPLAINT - 1

12/3/19

Federal Employment Laws

Applicability to Tribes – The General Rule General statutes by their own terms “applying to all persons” includes Tribes and their “property interests.” ◦ Federal Power Commission v. Tuscarora Indian Nation, 362 U.S. 99 (1960) Exceptions: ◦ Exclusive rights of self governance - intramural matters ◦ Application of the law abrogates treaty rights ◦ Proof that Congress intended the law not to apply ◦ Donovan v. Coeur d’ Alene Tribal Farms , 751 F.2d 1113, 1116 (9 th Cir. 1985)

12/3/19

Title VII of the Civil Rights Act of 1964 42 U.S.C. §§ 2000e – 2000e-17 (2000); Executive Order 11246 Prohibits discrimination due to race, color, religion, gender or national origin Applies to employers with 15+ employees for each working day in 20+ calendar weeks Excludes US, corporations owned by US or Indian Tribes . However, exemption does not extend to enterprises with mixed ownership (Tribe and non-Indian owner) ◦ Myrick v. Devils Lake Sioux Manufacturing Corp ., 718 F. Supp. 753 (D.N.D. 1989)

Indian Preference Under Title VII Indian preference in hiring is expressly permitted for employers on or near reservations Exceptions: ◦ No preference for members of a particular tribe over other tribes ◦ Dawavendewa v. Salt River Project Agricultural Improvement Power Dist ., 154 Fed.3d 117 (9 th Cir. 1998), See also Dawavendewa v. Salt River Project , 276 F.3d 1150 (9 th Cir 2001) ◦ Note: SRP is not a tribally owned corporation

12/3/19

Age Discrimination in Employment Act 29 U.S.C. §§ 621-634 (2000) Prohibits discrimination on basis of age Employees/applicants protected if over 40 Liability may be avoided if employer can show bona fide occupational qualification requiring an employee to be younger Silent on applicability to tribes

Case Law ADEA applies to the tribe “in its capacity as proprietor” of bingo facility, at least when claimant is not a tribal member. ◦ EEOC v. Forest County Potawatomi Community , No. 2:2013mc00061 (E.D. Wis. 2014) ADEA does not apply when dispute ◦ Involves treaty rights ◦ EEOC v. Cherokee Nation , 971 F.2d 937 (10 th Cir. 1989) ◦ Intramural affairs ◦ EEOC v. Fond du Lac Heavy Equipment and Construction Co. , 986 F.2d 246 (8 th Cir. 1993) ◦ EEOC v. Karuk Tribe Housing Authority , 260 F.3d 1071 (9 th Cir. 2001)

12/3/19

Americans with Disabilities Act of 1990 42 U.S.C. § 12101 et. seq. National mandate with enforceable standards for elimination of discrimination against individuals with disabilities Federal enforcement Invoke congressional authority, including the power of the 14 th Amendment and to regulate commerce to address discrimination Disability specifically defined term

Nondiscrimination Title I : Employment opportunities and requires reasonable accommodations for employers with 15+ employees ◦ Excludes: US, corporations owned by US or Indian tribes Title II: State and local government - equal opportunity to benefit from programs, services and activities ◦ No mention of tribes but tribal sovereignty may exempt tribes Title III: Public accommodations and commercial facilities that prohibit exclusion, segregation or unequal treatment ◦ Can apply to public accommodations run by a tribe, but cannot be enforced by private person against tribe in non-Indian forum due to sovereign immunity. However compliance can be compelled by US Attorney General. Florida Paraplegic Assoc. v. Miccosukee Tribe of Indians of Florida, 166 F.3d 1126 (11 th Cir. 1999)

12/3/19

Fair Labor Standards Act 29 U.S.C. §§ 201-219 (2000 and 2016) Standards for minimum wages and terms of payment for overtime No specific mention of tribes 2016 Amendments ◦ Increases minimum salary levels necessary for an employee to be classified as exempt ◦ Rises the highly compensated employee threshold ◦ Automatic updates every 3 years ◦ Effective December 1, 2016

FLSA Case Law LEO not entitled to protections because tribal law enforcement is traditional governmental function. ◦ Snyder v. Navajo Nation , 371 F.3d 658 (9 th Cir. 2004)

In a case involving tribal consortium to protect native game and fishing rights, the court opted not to apply FLSA as a matter of comity and sovereignty because FLSA would not apply to state or local governments. However, government employees exercising powers of tribal government are exempt from FLSA. ◦ Reich v. Great Lakes Indian Fish and Wildlife Commission, 4 F3d 490 (7 th Cir. 1993)

12/3/19

More FLSA Case Law FLSA applies to business operated on tribal land and owned by tribal member. ◦ Chao v. Matheson , 2007-WL-1830738, No. C-06-5361 (W.D. Wash., June 25, 2007)

National Labor Relations Act 29 U.S.C. §§ 141-187 (2000) Authorizes employees to form unions for collective bargaining and engaging in “protected concerted activity” Prohibits employers from prohibiting exercise of rights or engaging in conduct that may have a “chilling effect” Applies to employers with $50,000 in annual business Applies to private employers operating on or near reservations No express applicability or exemption for tribal governments but does exempt the US

12/3/19

Protected Concerted Activity 2+ people acting together to improve working conditions or wages; also 1 person if

Excludes reckless or malicious behavior – sabotaging equipment, lies about a product, revealing trade secrets may cause action to lose protection May also exclude “hate speech”

he/she involves others before acting or acts on behalf of others Does not require union membership

Some Examples Social media comments Sharing own confidential information, including wages, corrective actions, etc. Rules restricting criticism of management Rules requiring employees to be respectful or that prohibit an employee from poking fun, denigrate or defame co-works and others Rules prohibiting resistance to proper work related orders or discipline, even though not overt insubordination

12/3/19

Tribal Challenges Tribal law prohibiting union membership as a condition of employment did not violate NLRA. It is an exercise of sovereign authority of tribe to govern its own territory. ◦ National Labor Relations Board v. Pueblo of San Juan , 276 F.3d 1187 (10 th Cir. 2002) NLRA applies to casino wholly owned and operated by tribe on tribal reservation because the operation of a casino is not an exercise of self-governance or a governmental function. ◦ San Manuel Indian Bingo and Casino v. NL RB, 475 F.3d 1306 (D.C.Cir. Feb. 2007), reh’g en banc denied (D.C. Cir. June 8, 2007)

NLRA v. Little River Band of Ottawa Indians, No. 14-2239, (6 th Cir. June 9, 2015) Facts: Tribe operates casino under IGRA. Tribe enacted tribal law giving the tribe authority over collective bargaining, including prohibition over certain topics and banned strike activity. NLRB found the tribal law violated the NLRA and issued a cease and desist order. The tribe challenged jurisdiction on basis of sovereignty. 6 th Circuit affirmed the NLRB jurisdiction.

12/3/19

Reasoning and Current Status Court found the the NLRA is a law of general applicability, that no treaty rights were involved, the issue was not one of internal self governance and affirmed NLRB jurisdiction. Petition for Writ of Certiorari denied without reasoning at same time a similar petition involving Saginaw Chippewa was denied

Far Reaching Effects Year end bonuses for labor members reduced without notice violated NLRA. ◦ Viejas Band of Kumeyaay and United Food and Commercial Workers International , 21-CA-166290, NLRB, October 11, 2016.

12/3/19

Casino Pauma (9 th Circuit – 2018) NLRA applies to tribal gaming establishment owned and managed by the tribe and operated on tribal land. Violation of NLRA to try to stop distribution of union literature

Tribal Labor Sovereignty Act Legislation to exclude Indian Tribes from the definition of employer under NLRA

Introduced but no traction

12/3/19

Family Medical Leave Act 29 U.S.C. §§ 2601-2654 (2000) Employers with 50+ must provide 12 weeks of unpaid leave in a year for family and medical reasons ◦ Birth, adoption, placement of child in foster care ◦ Care of seriously ill child, spouse or parent; or ◦Own serious illness ◦ Return to same or equivalent position upon return Law does not specifically mention tribes – DOL position that the law applies to tribes ◦ Eligible employee requirements ◦ employed for 12 months and 1,250 hours

FMLA Case Law Exhaustion of tribal court remedies required ◦ Sharber v. Spirit Mountain Gaming, Inc ., 343 F.2d, 724 (9 th Cir. 2003) Tribe has sovereign immunity from suit that is not abrogated by FMLA. Likewise, gaming compacts and tribes policies did not waive immunity, so none would be inferred. ◦ Muller v. Morongo Casino Resort & Spa, ED-CV-14-02308-VAP (KK)(C.D. Cal., July 17, 2015)

12/3/19

Employee Retirement Income Security Act 29 U.S.C. §§1001 et. seq. Standards for voluntarily established pension or welfare-benefit plans Not applicable to tribal employer benefit plans if the plan covers only tribal employees employed in traditional governmental roles but applicable to tribes engaged in commercial activities (2006 amendment)

Consolidated Omnibus Budget Reconciliation Act 29 U.S.C. §§ 1161 et seq . (2000) Requires continuation of health insurance coverage for up to 18 months after an employee leaves Not applicable to insurance plans maintained by tribes if ◦Tribal employees employed in traditional governmental roles Insurance plans for commercial tribal enterprises are subject to COBRA

12/3/19

Workers’ Compensation General Rule: State labor and employment laws do not apply to employers operating solely on Indian reservation ◦ California v. Cabazon Band of Mission Indians, 480 U.S. 202, 208 (1987) Except : 40 U.S.C. § 290 provides state authority to apply workers’ compensation laws to all lands owned or held by the US within the state. Interpretation – state workers’ compensation laws may apply

The Take Away – When law is silent TRIBAL GOVERNMENT Tribal internal issue Tribal treaty Tribal members with no applicability to non- members Law generally not applicable

COMMERCIAL INTERESTS Effect on non-tribal members Not a governmental function - even though profits will be used to fund government Law probably applicable

12/3/19

Scenario: Edward Employee Edward Employee – resign or be terminated Card dealer, required to stand for long periods of time

Charlene Jackson [email protected] (480) 785-6196

12/3/19

DOES YOUR TRIBE REQUIRE YOU BACKGROUND/LICENSE VENDORS? 1. Indian Gaming Regulatory Act 2. Tribal Gaming Ordinance 3. Compact Licensing Requirements 4. Tribal Gaming Authority Gaming Requirements 5. Tribal Council or Other Tribal Ordiances

12/3/19

LICENSEES

Non-gaming Vendor

Gaming vendor

Specialty Vendors

Who are these guys!

Attorneys

Onetime/Emergency vendor

CPA Firm

GOVERNING DOCUMENTS: IGRA

Really only referring to Class II management contracts and those individuals and/or companies who are engaging the Tribe in business.

12/3/19

VENDOR LICENSING: GAMING

Who are your gaming vendors?

VENDORS: GAMING

• GAMING MACHINE COMPANIES, • BINGO SUPPLIER COMPANIES, • SLOT PAPER COMPANIES, • CAN YOU NAME OTHERS??

12/3/19

NON-GAMING VENDORS Not all Tribes license/background Non-gaming vendors, make sure you know and understand the Tribes non- gaming vendor regulations/policies

NON-GAMING VENDORS

Who are your non-gaming vendors? Ø Food vendors, Ø Merchandise vendors, Ø Copier vendor, Ø Electricians, plumbers, carpenters and other construction professionals, Ø Others???

12/3/19

WHY PERFORM INVESTIGATIONS OR LICENSEE VENDORS?

• WHY BACKGROUND OR LICENSING VENDORS? LICENSING VENDORS IN MANY CASES IS A REQUIREMENT PER TRIBAL-STATE COMPACTS OR TRIBAL GAMING ORDINANCES. BUT THIS USUALLY PERTAINS TO THE GAMING VENDORS.

LICENSING GAMING VENDORS If you are currently licensing gaming vendors what processes do you use? What are tools that can make you efficient at this licensing process? Are you just “shuffling” paperwork? Do you completely understand the application forms and what you are asking from the gaming vendor?

12/3/19

LICENSING PROCESSES FOR GAMING VENDORS • MANY TIME THE PROCESSES ARE SIMILAR FROM TRIBE TO TRIBE, EACH TRIBE RESERVES THE RIGHT TO REQUEST ANY INFORMATION THEY FEEL NECESSARY. • NORMALLY WE ARE REQUESTING EACH PRINCIPLE OWNER OR KEY EMPLOYEE OF THE COMPANY TO FILL OUT A LENGTHYAND IN-DEPTHAPPLICATION. • WE ASK THAT EACH GAMING COMPANY TO SUBMIT TO THE TRIBE FINANCIAL STATEMENTS, IRS SUBMISSION PROOF, ORGANIZATION CHARTS, OTHER COMPANIES OWNED BY THE VENDOR, SECURITIES HOLDING, BANK ACCOUNT BALANCES….ECT. (EXAMPLE AVAILABLE)

GAMING VENDOR PROCESSES

• WHEN ALL DOCUMENTS ARE SUBMITTED TO YOUR TRIBE WHAT ARE YOUR PROCESSES? • WHO PERFORMS THE BACKGROUND ON BEHALF OF THE TRIBE? • WHAT DOES THE COMMISSION EXPECT FROM THE BACKGROUND? • DO YOU HAVE DIFFERENT LEVELS OF GAMING LICENSES? EXAMPLES, • HIGH SECURITY, MAJOR PROCUREMENT, MINOR PROCUREMENT, CLASS II, CLASS III AND OTHERS DEPENDING ON THE TRIBES LICENSING REGULATIONS

12/3/19

GAMING VENDOR INVESTIGATION

• WHEN REVIEWING THE BACKGROUND RESULTS ARE YOU IN COMPLETE UNDERSTANDING OF WHAT THOSE RESULTS TRULY MEAN? (SELF REFLECTION) • ARE YOU PARTICULARLY INTERESTED IN THE CRIMINAL ACTIVITY OF THE APPLICANT? • ARE YOU INTERESTED IN THE BUSINESS ETHICS OF THE APPLICANT? • ARE YOU INTERESTED IN THE FINANCIAL STATUS OF THE APPLICANT? • ARE YOU INTERESTED IN THE OTHER JURISDICTIONS THAT THE APPLICANT IS LICENSED IN AND IF THERE ARE ANY REGULATORY INFRACTIONS TO THE LICENSE?

WHAT SHOULDWE KNOWABOUT GAMING VENDORS: • EVERYTHING! IT IS YOUR RESPONSIBILITY, • UNDERSTAND WHAT A PUBLICALLY TRADED COMPANY COMPARED TO A NON-PUBLIC COMPANY, • UNDERSTAND WHAT THE FINANCIAL RECORDS ARE AND WHAT TO LOOK FOR WHEN REVIEWING THEM. WE REALLY WANT TO MAKE SURE THAT THE COMPANY IS FINANCIALLY STRONG, ESPECIALLY IF THEY ARE FINANCING THE CASINO PROJECTS OR ARE COMMITTING TO SELLING THE CASINO A LOT OF PRODUCT. • TO STAY IN COMPLIANCE WITH IGRA/NIGC YOU WANT TO MAKE SURE THAT THE COMPANY IS NOT “IN BUSINESS” WITH ANY ORGANIZED CRIME, THIS WILL NORMALLY COME UP IF AN INDIVIDUAL WHO YOU HAVE BACK GROUNDED HAS A CRIMINAL RECORD.

12/3/19

GAMING VENDORS

• CONSIDER: • IF YOU DON’T BACKGROUND THE ACTUAL INDIVIDUALS THAT COME ON THE PROPERTY THEN YOU MIGHT WANT TO, (DISCUSSION) • MAKE SURE THAT THEY DISCLOSE ANY OTHER JURISDICTIONS THAT THEY ARE CURRENTLY LICENSED IN (ESPECIALLY IN TRIBAL JURISDICTIONS), • IF YOU DO NOT UNDERSTAND A FINANCIAL STATEMENT THEN CONSIDER GETTING TRAINED ON UNDERSTANDING FINANCIAL STATEMENTS,

FINANCIAL STATEMENTS: 101

• FINANCIAL STATEMENTS REPRESENT A FORMAL RECORD OF THE FINANCIAL ACTIVITIES OF AN ENTITY. THESE ARE WRITTEN REPORTS THAT QUANTIFY THE FINANCIAL STRENGTH, PERFORMANCE AND LIQUIDITY OF A COMPANY. FINANCIAL STATEMENTS REFLECT THE FINANCIAL EFFECTS OF BUSINESS TRANSACTIONS AND EVENTS ON THE ENTITY

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STATEMENT OF FINANCIAL POSITION

STATEMENT OF FINANCIAL POSITION, ALSO KNOWN AS THE BALANCE SHEET, PRESENTS THE FINANCIAL POSITION OF AN ENTITY AT A GIVEN DATE. IT IS COMPRISED OF THE FOLLOWING THREE ELEMENTS: • ASSETS : SOMETHING A BUSINESS OWNS OR CONTROLS (E.G. CASH, INVENTORY, PLANT AND MACHINERY, ETC) • LIABILITIES : SOMETHING A BUSINESS OWES TO SOMEONE (E.G. CREDITORS, BANK LOANS, ETC) • EQUITY : WHAT THE BUSINESS OWES TO ITS OWNERS. THIS REPRESENTS THE AMOUNT OF CAPITAL THAT REMAINS IN THE BUSINESS AFTER ITS ASSETS ARE USED TO PAY OFF ITS OUTSTANDING LIABILITIES. EQUITY THEREFORE REPRESENTS THE DIFFERENCE BETWEEN THE ASSETS AND LIABILITIES .

12/3/19

INCOME STATEMENT INCOME STATEMENT, ALSO KNOWN AS THE PROFIT AND LOSS STATEMENT, REPORTS THE COMPANY'S FINANCIAL PERFORMANCE IN TERMS OF NET PROFIT OR LOSS OVER A SPECIFIED PERIOD. INCOME STATEMENT IS COMPOSED OF THE FOLLOWING TWO ELEMENTS: • INCOME : WHAT THE BUSINESS HAS EARNED OVER A PERIOD (E.G. SALES REVENUE, DIVIDEND INCOME, ETC) • EXPENSE : THE COST INCURRED BY THE BUSINESS OVER A PERIOD (E.G. SALARIES AND WAGES, DEPRECIATION, RENTAL CHARGES, ETC) • NET PROFIT OR LOSS IS ARRIVED BY DEDUCTING EXPENSES FROM INCOME.

CASH FLOW STATEMENT

CASH FLOW STATEMENT , PRESENTS THE MOVEMENT IN CASH AND BANK BALANCES OVER A PERIOD. THE MOVEMENT IN CASH FLOWS IS CLASSIFIED INTO THE FOLLOWING SEGMENTS: • OPERATING ACTIVITIES : REPRESENTS THE CASH FLOW FROM PRIMARY ACTIVITIES OF A BUSINESS. • INVESTING ACTIVITIES : REPRESENTS CASH FLOW FROM THE PURCHASE AND SALE OF ASSETS OTHER THAN INVENTORIES (E.G. PURCHASE OF A FACTORY PLANT) • FINANCING ACTIVITIES : REPRESENTS CASH FLOW GENERATED OR SPENT ON RAISING AND REPAYING SHARE CAPITAL AND DEBT TOGETHER WITH THE PAYMENTS OF INTEREST AND DIVIDENDS.

12/3/19

STATEMENT OF CHANGES IN EQUITY STATEMENT OF CHANGES IN EQUITY , ALSO KNOWN AS THE STATEMENT OF RETAINED EARNINGS, DETAILS THE MOVEMENT IN OWNERS' EQUITY OVER A PERIOD. THE MOVEMENT IN OWNERS' EQUITY IS DERIVED FROM THE FOLLOWING COMPONENTS: • NET PROFIT OR LOSS DURING THE PERIOD AS REPORTED IN THE INCOME STATEMENT • SHARE CAPITAL ISSUED OR REPAID DURING THE PERIOD • DIVIDEND PAYMENTS

• GAINS OR LOSSES RECOGNIZED DIRECTLY IN EQUITY (E.G. REVALUATION SURPLUSES) • EFFECTS OF A CHANGE IN ACCOUNTING POLICY OR CORRECTION OF ACCOUNTING ERROR

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WHY IS ALL THAT IMPORTANT TO ME • LETS DISCUSS

NON-GAMING VENDORS

• DO YOU LICENSE NON-GAMING VENDORS?

DISCUSSION

12/3/19

NON-GAMING VENDORS

• DO YOU TREAT NON-GAMING VENDORS THE SAME AS THE GAMING VENDORS WHEN PERFORMING LICENSING PROTOCOLS?

NON-GAMING VENDORS

Ø Depending on the jurisdiction non-gaming vendors are sometimes required to fill out the same application as gaming vendors. Ø In some cases we only require non-gaming vendors to apply for an application only if they surpass a certain dollar amount of business with the Casino.

12/3/19

NON-GAMING VENDOR

What is a non-gaming vendor?

NON-GAMING VENDORS: WHO ARE THEY?

In most cases a “non-gaming vendor” is usually determined by some type of Gaming Commission regulation. Normally a non-gaming vendor is a vendor who does not qualify for a gaming license per the governing documents licensing regulations. They don’t usually have any benefit to the gaming activities of the gaming operation

12/3/19

NON-GAMING VENDORS

Ø What are the benefits of licensing non-gaming vendors?

NON-GAMING VENDORS 1. Gets the non-gaming vendor under the authority of the regulatory commission, 2. Protects the Tribes interest in the gaming operation, 3. What are others benefits?

12/3/19

WHAT ARE LICENSING OBSTACLES?

What are some of the issues that we face when we are licensing our vendors? Discussion

• NON-COMPLIANCE ISSUES, USUALLY COMES FROM NON-GAMING VENDORS, • PRESSURE FROMMANAGEMENT TO GET THE VENDOR LICENSED ASAP, • FAILURE TO COMPLY WITH DEADLINES, • FAILURE TO COMPLETE THE DOCUMENTS AS REQUESTED, OBSTACLESWHEN LICENSING VENDORS: GAMING AND NON-GAMING

• FAILURE TO PAY ANY ASSOCIATED FEES, • STORING ALL SUBMITTED PAPERWORK? • OTHERS?

12/3/19

FACILITIES LICENSE

• DO YOU LICENSE THE FACILITY?

• THIS SOMETIMES IS A TOUGH ONE…….WHO DOES LICENSE THE FACILITY?

AUTHORITY

12/3/19

GOVERNING DOCS

• WHERE IS IT AT IN YOUR GOVERNING DOCS…..

FACILITIES LICENSE • WHAT SHOULD THE APPLICATION LOOK LIKE? • WHAT PURPOSE DOES A FACILITY LICENSE HAVE? • WHO IS RESPONSIBLE FOR FILLING OUT THE APPLICATION?

12/3/19

FACILITIES LICENSE HOW DO YOU GET THE AUTHORITY TO ENFORCE A FACILITY LICENSE?

FACILITIES LICENSE

• ENVIRONMENTAL PUBLIC HEALTH AND SAFETY (EPHS) DISCUSSION AND REVIEW CHECKLIST

• DISCLAIMER: MAKE SURE YOU FOLLOW YOUR APPROVED TRIBAL GUIDELINES AS WELL AS MAKE SURE EVERYTHING IS UP TO DATE AND IN ACCORDANCE WITH TRIBAL, FEDERAL AND WHERE APPLICABLE STATE LAW.

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ELEMENTS THAT SHOULD BE FOUND IN A INDEPTH FACILITY LICENSE APPLICATION/PROCESS

SAFETY PROCESSES OF THE OPERATION • ENVIRONMENTAL HEALTH, • BUILDING CODES, • FIRE PROTECTION (STRUCTURAL/WILDFIRE) • WATER, • SEWAGE, • FOOD SAFETY, • MAINTENANCE (PREVENTATIVE)

12/3/19

SAFETY PROCESSES OF THE OPERATION • ACTIVE SHOOTER, • HUMAN TRAFFICKING, • POLICING AGREEMENT (IF NEEDED) • CYBER SECURITY, • UPDATED MANUALS, • ETC…

FACILITY LICENSE

• MANY TIMES OPERATIONS AND SOMETIMES LEADERSHIP DOES NOT SEE THIS AS A VALUE ADD, MAKE SURE YOU CAN JUSTIFY THIS PROCESS. • BE PROACTIVE, WORK WITH ALL ENTITIES. • THIS IS ABOUT PROTECTING THE TRIBES MILLION-DOLLAR INVESTMENT.

12/3/19

SENARIOS

• GAMING VENDOR • GAMING CONSULTANT • NON-GAMING VENDOR • FACILITY LICENSE DISAGREEMENT

QUESTIONS????

12/3/19

THANK YOU!

Billy David, Owner Bo-Co-Pa & Associates Phone: 541-810-0700 Email: [email protected] www.bo-co-pa.com

12/3/19

YOUR SPEAKER

• BILLY DAVID, OWNER

BO-CO-PA & ASSOCIATES, LLC

BILLY.DAVID90@GMAIL,.COM 541-810-0700

12/3/19

LICENSING AUTHORITY: • WHERE DOES IT COME FROM?

YOUR DOCUMENTS The governing documents of licensing regulations: 1. Indian Gaming Regulatory Act 2. Tribal Gaming Ordinance 3. Compact Licensing Requirements (if applicable) 4. Tribal Gaming Authority Gaming Requirements

12/3/19

WHAT YOU SHOULD REALLY KNOWREGARDING THE LICENSING PROCESS?

1. UNDERSTAND EVERYONE'S ROLES AND RESPONSIBILITIES: I. GAMING COMMISSION/ERS II. TRIBAL COUNCIL/GOVERNMENTS

III. GAMING MANAGEMENT/DEPARTMENTS IV. CASINO/BUSINESS BOARD OF DIRECTORS V. OTHER GOVERNMENTAL AGENCIES

UNDERSTANDING EVERYONE'S ROLE • GAMING COMMISSIONS/ERS Ø LICENSING AUTHORITY Ø ENFORCEMENT Ø PROMULGATE RULES AND REGULATIONS

Ø APPROVE AND DEVELOP INTERNAL CONTROLS Ø HIGHER APPROPRIATE COMMISSION STAFF

Ø CONDUCT HEARING (SOME TRIBAL PROPERTIES HAVE ANOTHER ENTITY CONDUCT HEARINGS) Ø ACT AS THE OFFICIAL TRIBAL AUTHORITY AS PRESCRIBED IN THE TRIBAL GAMING ORDINANCE Ø PROTECT THE FAIRNESS, INTEGRITY, SECURITY, AND HONESTY OF THE TRIBAL GAMING OPERATION (F.I.S.H) Ø CONDUCT OR OVER SEE INTERNAL INVESTIGATIONS

Ø ENSURE COMPLIANCE WITH ALL REQUIRED REGULATING DOCUMENTS Ø AMONGST OTHER REQUIRED DUTIES, BUDGETS, FINANCIAL TRACKING ETC.

12/3/19

UNDERSTANDING EVERYONE’S ROLE • TRIBAL COUNCILS: Ø ULTIMATELY RESPONSIBLE FOR THE WHOLE CASINO OPERATIONS. Ø APPROVE TRIBAL GOVERNING DOCUMENTS Ø MEET WITH STATE AND FEDERAL AGENCIES REGARDING GAMING COMPACTS, ORDINANCES AS WELL AS OTHER APPLICABLE LAWS Ø APPOINTING OR HIRING COMMISSIONERS Ø ANY OTHER REQUIREMENTS AS DICTATED BY TRIBAL LAW(S)

UNDERSTANDING EVERYONE’S ROLE • GAMINGMANAGEMENT/DEPARTMENTS Ø HIRE ALL QUALIFIEDCASINO STAFF Ø FOLLOWTHE CASINOBUSINESS PLAN Ø WRITE AND IMPLEMENT DEPARTMENT POLICY Ø WRITE AND IMPLEMENT DEPARTMENT PROCEDURES Ø ENSURE THAT COMPLIANCE IS ACHIEVEDBY ALL REQUIREDDEPARTMENTS Ø GENERATE REVENUE TOBE DISTRIBUTED TO THE TRIBE PER THE GAMINGORDINANCE, REVENUE ALLOCATION PLAN OR

OTHER TRIBAL LAWDICTATINGHOWGAMING REVENUE IS TOBE HANDLED. Ø ANY OTHER REQUIREMENTS PER THE GAMINGBOARDOF DIRECTORS

12/3/19

UNDERSTANDING EVERYONE’S ROLE

• CASINO/BUSINESS BOARD OF DIRECTORS

Ø DEVELOP AND IMPLEMENT THE BUSINESS PLAN Ø HIGHER APPROPRIATE CASINOS CEO, GM. CFO ETC Ø APPROVE CERTAIN POLICY AND PROCEDURES

Ø HOLD UPPER MANAGEMENT ACCOUNTABLE FOR DAILY, QUARTERLY AND ANNUAL FINANCIAL STATEMENTS Ø ASSURE THE TRIBE THAT THE BUSINESS IS BEING OPERATED IN A MANNER THAT GENERATES REVENUE FOR THE TRIBE.

OTHER GOVERNMENTAL AGENCIES

• NATIONAL INDIAN GAMING COMMISSION • STATE DEPARTMENT OF GAMING

12/3/19

WHEN SHOULD I EXERCISE MY AUTHORITY

WITH GREAT POWER COMES GREAT RESPONSIBILITY

12/3/19

ENFORCEMENT LICENSING:

• YOU ARE NOT LAW ENFORCEMENT (UNLESS TRIBAL ORDINANCE GIVES YOU THAT AUTHORITY) • YOU ARE AN ADMINISTRATIVE ENFORCEMENT OFFICER. • WORK WITHIN YOUR SCOPE OF AUTHORITY: DISCUSSION

LICENSING: SCOPE OF AUTHORITY

• WHAT IS YOUR RESPONSIBILITY WITH LICENSING? • GAMING COMMISSION, • GAMING COMMISSION STAFF, • MANAGEMENT, • POTENTIAL LICENSEE

12/3/19

GOVERNING DOCUMENTS: IGRA

Most licensing regulations must comply with the Federal licensing standards.

Those standards are found in the Indian Gaming Regulatory Act 1988

LICENSING: IGRA

Important items to know about IGRA

Not all licensing regulations need to comply with IRGA

National Indian Gaming Commission can only enforce their own standards

The Tribal licensing authority is responsible to ensure that the Tribe is in compliance with all licensing documents

12/3/19

IGRA REQUIREMENTS 25 CFR Part 556 – Addresses Background Investigations – Addresses Licensing for Key and PMO. • Changes were published in the CFR January 25, 2013 with a compliance date of February 25, 2013. for Key and PMO. • 25 CFR Part 558.

IGRA REQUIREMENTS

556.8 and 558.6 “Compliance with this part” both state: – All tribal gaming ordinances and ordinance amendments approved by the Chair prior to the February 25, 2013 and that reference this part, do not need to be amended to comply with this part. All future ordinance submissions, however, must comply.

12/3/19

IGRA REQUIREMENTS

• 25 CFR 502.14 AND 502.19 DEFINES KEY EMPLOYEE AND PMOMINIMUMS • • TRIBES ABLE TO EXPAND KEY AND PMO DEFINITIONS THROUGH ORDINANCE • – “ANY OTHER PERSON DESIGNATED BY THE TRIBE AS A PMO” • • ENSURE 556 AND 558 REGULATIONS APPLY TO KEY AND PMO EMPLOYEES

IGRA REQUIREMENTS: APPLICATION PROCESS 556.4 (1 – 14) Sets forth what the application must contain: Privacy Notice, False Statement Notice, name, social security number, address, employers, business relationships, previous gaming licenses, references, criminal history photograph and fingerprints (results).

12/3/19

IGRA LICENSING REQUIREMENTS

• 556.2 PRIVACY NOTICE. • • 556.3 NOTICE REGARDING FALSE STATEMENTS. • – CHANGES INCLUDED REPLACE ALL LANGUAGE REFERRING TO HIRINGAND FIRINGAND REPLACING IT WITH LICENSING LANGUAGE. • – EXACT LANGUAGE CAN BE FOUND IN CFR 556 AT NIGC.GOV • – ALL FORMS MUST BE UPDATE BYAUGUST 2013.

IGRA LICENSING REQUIREMENTS

• FOR EVERY PRIMARY MANAGEMENT OFFICIAL OR A KEY EMPLOYEE, A TRIBE SHALL: • • CREATE AND MAINTAIN AN INVESTIGATIVE REPORT ON EACH BACKGROUND INVESTIGATION. AN

INVESTIGATIVE REPORT SHALL INCLUDE ALL OF THE FOLLOWING: • – STEPS TAKEN IN CONDUCTING A BACKGROUND INVESTIGATION; • – RESULTS OBTAINED; • – CONCLUSIONS REACHED; AND • – THE BASIS FOR THOSE CONCLUSIONS .

12/3/19

IGRA LICENSING REQUIREMENTS • REGULATION’S REQUIRE A TWO-PART SUBMISSION • – A NOTICE OF RESULTS (NOR) OF BACKGROUND INVESTIGATIONS, 25 CFR 556 • – A NOTICE OF LICENSING DETERMINATION, 25 CFR 558 • • NOTIFICATIONS SUBMISSION METHODS. • – ENCRYPTED EMAIL TO THE REGIONAL OFFICE. • – FAX. • – MAIL. • • THE TWO PART SUBMISSIONS MUST NOT BE MADE AT THE SAME TIME

IGRA LICENSING REQUIREMENTS • A TRIBE MUST NOTIFY NIGC OF THE RESULTS OF THE BACKGROUND INVESTIGATION WITHIN 60 DAYS OF AN INDIVIDUAL BEGINNING WORK. • – A TRIBE SHALL CONDUCT AN INVESTIGATION SUFFICIENT TO MAKE AN ELIGIBILITY DETERMINATION

• • NOR MUST INCLUDE: • – APPLICANTS NAME • – DOB • – SOCIAL SECURITY NUMBER

• – DATE ON WHICH THEY WILL BEGIN WORK • – COPY OF THE ELIGIBILITY DETERMINATION

• • AN ELIGIBILITY DETERMINATION IS TO MAKE A FINDING CONCERNING THE ELIGIBILITY OF A KEY EMPLOYEE OR PRIMARY MANAGEMENT OFFICIAL FOR GRANTING OF A GAMING LICENSE, AN AUTHORIZED TRIBAL OFFICIAL SHALL REVIEW THE RESULTS OF A PERSON'S INVESTIGATION TAKING INTO CONSIDERATION A PERSON CRIMINAL HISTORY, REPUTATION, HABITS, AND ASSOCIATIONS.

12/3/19

IGRA LICENSING REQUIREMENTS

• A SUMMARY AND LISTING OF THE INFORMATION PRESENTED IN THE INVESTIGATIVE REPORT MUST BE INCLUDED IN THE NOR: • – PREVIOUSLY DENIED LICENSES • – REVOKED LICENSES • – CRIMINAL CHARGES BROUGHT WITHIN 10 YEARS OF THE APPLICATION • – EVERY FELONY CONVICTION OR ON-GOING PROSECUTION • • A DEFERRED SENTENCE IS CONSIDERED AN ONGOING PROSECUTION.

IGRA LICENSING REQUIREMENTS

• A TRIBE SHALL RETAIN THE FOLLOWING FOR INSPECTION BY THE CHAIR OR HIS OR HER DESIGNEE FOR NO LESS THAN THREE YEARS FROM THE DATE OF

TERMINATION OF EMPLOYMENT: • – APPLICATIONS FOR LICENSING; • – INVESTIGATIVE REPORTS; AND • – ELIGIBILITY DETERMINATIONS

12/3/19

TRIBAL-STATE PROTOCOLS FOR LICENSING PMO AND KEYS

This will differ and is subject to each individual State and Tribal negotiations. There are similar differences that can be found in many Tribal-State Compacts.

COMPACT LICENSING SIMILARITIES

Many similarities would include: • Definition of how Class III licenses will be handled in the State • Who will the Tribe have to submit information to within the State • Who from the State will have availability to Tribal licensing records

12/3/19

TRIBAL ORDINANCE: LICENSING REQUIREMENTS

In many Tribal Gaming Ordinances there are criteria that the Tribe has lined out for the regulatory authority has outlined.

Do you know what your Tribal licensing standards are??? Discussion

TOOLS AND TIPS TO HELP UNDERSTANDING LICENSING STANDARDS

To be an effective and productive licensing authority you need to understand not only the licensing regulations used by the Tribe, NIGC and your State but you need to know the internal details used by your licensing/background department.

12/3/19

TIPS AND TOOLS: 1. Learn your internal processes I.

The different regulatory/law enforcement agencies you will have to work with II. Timelines for submission to all regulatory agencies involved with the licensing processes III. What your Tribal standards are for denials and revocations 2. Understand the vocabulary of the industry: Fingerprint results, law enforcement reports for the different jurisdictions, 3. Don’t be ashamed to ask questions 4. Network with your fellow Commissioners 5. Be knowledgeable of what technology your background/licensing department utilizes 6. Be respectful, confidential and ethical

LICENSING AND BACKGROUNDING

Licensing and back grounding potential PMOs and/or Key casino employees could be one of the most single important directives of a regulatory authority. Be diligent and through DISCUSSION

12/3/19

LICENSEES

Primary Management Official

Key Employee

High Security

Help!!

Dual License

Low Security

Class III

DEVELOP TRACKING PROCESSES:EXAMPLE

Name

Position

Id Number/Classification Application Date Received

Date Submitted for Approval

Date submitted to NIGC/State

Joe schmoo Blackjack dealer 13-012/Key

10/2/13 04/2/12

Judy schmoo T.G. Director

12-001

6/5/12

6/10/12

12/3/19

SCENARIOS

• DISCUSSION

#1 • PMO HAD A SPOUSE PASS AWAY FROM CANCER. SHE BATTLED IT FOR YEARS AND IT COSTED THEM DEARLY. MEDICAL COSTS FOR FIVE YEARS EXHAUSTED THEIR SAVINGS, EXHAUSTED KIDS COLLEGE SAVINGS, MAXED OUT THEIR CREDIT, AND THEY LOST THEIR HOME. • IN THE END HIS SPOUSE PASSED AWAY AND HE LITERALLY LOST EVERYTHING HE HELD DEAR. THE ONLY THING HE HAD WAS HIS OWN HEALTH, COLLEGE DEGREE AND HIS GAMING EXPERIENCE. • WHAT ARE THE ISSUES AS YOU SEE IT?

12/3/19

#2 • A POTENTIAL PMOWAS AFFECTEDBY THE RECESSION IN 2008; • JOBS CLOSED AND SHE LOST HER JOB AFTER 20 YEARS. SHE HAD A DIFFICULT TIME GETTINGBACK INTO THE JOBMARKET WITH LIMITED JOBS AVAILABLE. HERHUSBAND LOST HIS JOB ASWELL, THEY LOST THEIRHOME AND SAVINGS. • THEY ACCEPTED JOBS AT A LOWER PAY RATE AND LIVEDOFF OF THEIRCREDIT FOR SEVERAL YEARS UNTIL THEIRCREDIT DRIEDUP. • THEY ARE APPLYING FOR A DIRECTOR POSITION, ONE OF THE JOBDUTIES IS APPROVING PURCHASES ANDDEVELOPING BUDGETS, • THIS POTENTIAL LICENSEE IS A TRIBAL MEMBER, • WHAT CONCERNSWOULD YOU SEEWITH LICENSING THIS PMO?

#3 • KEY EMPLOY APPLIED FOR TABLES DEALER POSITION. • SHE FILLED OUT HER APPLICATION IN THE OFFICE AND SHE LOOKED STRESSED OUT, SHAKING, CRYING, ETC. SHE LEFT OUT PORTIONS OF HER RESIDENCY IN THE UNITED STATES AND VIETNAM. • THIS PROMPTED YOUR BACKGROUND PERSON TO SIT DOWN AND ASK ME TO VISIT WITH HER TO SEE WHAT WAS GOING ON WITH HER. SHE HAD A FEELING THAT SHE WAS HOLDING BACK BUT DID NOT KNOW HOW TO APPROACH HER. SO YOU SET THERE WITH HER IN SILENCE FOR 5 MINUTES AND ALLOWED HER EMOTIONS TO POUR THROUGH HER. YOU HAND HER TISSUES AND WATER AND SAY SOFTLY, IT’S OK TO SPEAK OPENLY ABOUT YOUR PAST. YOU ASK IF THERE WAS SOMETHING IN HER PAST THAT GAVE THE IMPRESSION THAT SHE WAS TIED TO ORGANIZED CRIME, • ASSOCIATED WITH BY DEFAULT, MARRIAGE OR RELATIONSHIP IN ANY SHAPE OR FORM. SHE WAS CRYING REALLY HARD AND TALKED ABOUT HER RELATIONSHIP WITH ONE OF THE LEADERS FROM THE TRAN ORGANIZATION. HER LAST NAME WAS TRAN, VENTED ABOUT HER EXPERIENCE AND HOW SHE GOT CAUGHT IN THE MIDDLE OF SOMETHING THAT SHE DID NOT WANT TO GET CAUGHT UP IN. • CONCERNS???

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• KEY EMPLOYEE APPLIED FOR A GAMING LICENSE. WHEN THE FBI RESULTS CAME BACK, SHE CAME UP AS DECEASED. • SHE WAS A FALSE POSITIVE AND THERE WAS AN ERROR ON THE FBI >Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32 Page 33 Page 34 Page 35 Page 36 Page 37 Page 38 Page 39 Page 40 Page 41 Page 42 Page 43 Page 44 Page 45 Page 46 Page 47 Page 48 Page 49 Page 50 Page 51 Page 52 Page 53 Page 54 Page 55 Page 56 Page 57 Page 58 Page 59 Page 60 Page 61 Page 62 Page 63 Page 64 Page 65 Page 66 Page 67 Page 68 Page 69 Page 70 Page 71 Page 72 Page 73 Page 74 Page 75 Page 76 Page 77 Page 78 Page 79 Page 80 Page 81 Page 82 Page 83 Page 84 Page 85 Page 86 Page 87 Page 88 Page 89 Page 90 Page 91 Page 92 Page 93 Page 94 Page 95 Page 96 Page 97 Page 98 Page 99 Page 100 Page 101 Page 102 Page 103 Page 104 Page 105 Page 106 Page 107 Page 108 Page 109 Page 110 Page 111 Page 112 Page 113 Page 114 Page 115 Page 116 Page 117 Page 118 Page 119 Page 120 Page 121 Page 122 Page 123 Page 124 Page 125 Page 126 Page 127 Page 128 Page 129 Page 130 Page 131 Page 132 Page 133 Page 134 Page 135 Page 136 Page 137 Page 138 Page 139 Page 140 Page 141 Page 142 Page 143 Page 144 Page 145 Page 146 Page 147 Page 148 Page 149 Page 150 Page 151 Page 152 Page 153 Page 154 Page 155 Page 156 Page 157 Page 158 Page 159 Page 160 Page 161 Page 162 Page 163 Page 164 Page 165 Page 166 Page 167

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