News & Events
Leading Edge Software Petitions Rules Clarification
Leading Edge software is currently petitioning the Washington State Gambling Commission (WSGC) for rules clarification on the following items:

• WAC 230-40-821 General accounting records — House-banking
• WAC 230-40-865 Distributing chips and coins to tables — Requests and fills — House-banking
• WAC 230-40-875 Closing gaming tables — House-banking

Revenue and expenses.
(1) Each licensee shall maintain legible, accurate and complete records of all transactions relating to the revenues and costs of the gaming operation. These records shall be maintained in a format to ensure consistency, comparability, and effective disclosure of financial information.

General accounting records.
(2) General accounting records shall be maintained on a double entry system of accounting with transactions recorded on an accrual basis, to include detailed, supporting, subsidiary records, sufficient to meet the requirements below.

Recordkeeping.
(3) The detailed, supporting and subsidiary records shall include, but not necessarily be limited to:
(a) Records of all patrons' checks initially accepted, deposited, and returned as "uncollected," and ultimately written off as "uncollectible";
(b) Statistical game records to reflect drop and win amounts for each table, for each game, and for at least each period for which the drop boxes are removed, which shall be at the minimum, the end of each gaming day;
(c) Records of investments in property, including, but not limited to, equipment used directly in connection with the gaming operation;
(d) Records of amounts payable by the gaming operation;
(e) Records which identify the purchase, receipt, and destruction of all cards and gaming chips used in wagering; and
(f) Records of services provided for the operation of gaming activities.

Copies.
(4) Whenever duplicate or triplicate copies are required of a form, record or document:
(a) The original, duplicate, and triplicate copies shall be color-coded;
Would the WSGC consider allowing for duplicate and triplicate forms to be of white paper, but with designation on each as “original”, “duplicate” “triplicate”?
(b) If under these standards, forms, records, and documents are required to be inserted in a locked dispenser, the last copy shall remain in a continuous unbroken form in the dispenser; and
What constitutes a “locked dispenser?” A computer with secure access could be considered a “locked dispenser.”
(c) If under these standards, forms or serial numbers of forms are required to be accounted for or copies of forms are required to be compared for agreement and exceptions noted, such exceptions shall be reported immediately to the commission for investigation.

Storing documents.
(5) All forms, records, documents and stored data required to be prepared, maintained and controlled shall:
(a) Have the title of the form, record, document, or stored data (such as "fill slip," "request for fill," "credit slip," "request for credit," "reconciliation," etc.), imprinted or preprinted thereon or therein; and
(b) All records shall be maintained for a period of not less than three years. At least the past six months of records must be available for inspection on premises.

Employee records.
(6) Licensees shall maintain a records system that ensures all applicable employees have met licensing requirements. The system shall be maintained on the premises and include the following:
(a) Employee names;
(b) Gambling license numbers;
(c) Gambling license expiration dates; and
(d) Photocopies of all current employees' licenses.

Record of employees who have not yet received a license.
(7) If an employee license has not yet been issued, the licensee shall maintain a copy of the following:
(a) Temporary employment authorization;
(b) Documentation that the required payment (license or transfer fee) has been made; and
(c) Proof that the employee has adhered to the ten-day waiting period, if applicable.

Notification - new license not received.
(8) The licensed card room operator shall ensure commission staff is notified if an employee license has not been received within sixty days of employment.

230-40-865 Distributing chips and coins to tables — Requests and fills — House-banking.
Gaming chips and coins shall only be distributed to gaming tables with adequate security and in a manner that ensures proper control and accountability. The following restrictions and procedures apply:

Fill slip.
(1) Each "fill slip" shall be serially prenumbered three-part forms, which provide an original and duplicate copies as necessary: Provided, That the director may authorize use of a computer based accounting system which includes a nonrepeating sequential numbering system that is consistent with the controls and safeguards of the manual system. Requests for fills shall be a two-part form which provides an original and duplicate copy. These forms shall be controlled in the following manner:
What does the WSGC consider a three-part form? If our program prints three copies of the same sequentially numbered form, which states original and duplicate on those forms and obtains three original wet signatures, would that meet the definition of a three part form? As you can see it further states that the director may authorize use of computer based accounting system which includes nonrepeating sequential numbering system that is consistent with the controls and safeguards of the manual system. Our product does provide consistency with the current manual controls in place.
(a) Each series of fill slips received by a licensee shall be controlled and accounted for separately;
(b) Request for fills shall be secured in such a manner that only a gaming operations supervisor has access;
(c) Fill slips shall be secured by the cashier's cage;
(d) These forms shall be used in sequential order and all forms accounted for; and
(e) The preparer shall void forms that have errors by marking "VOID" on both the original and duplicate copies and sign the form.

Request for fill.
(2) A "request for fill" shall be prepared by the gaming operation supervisor to authorize the cage to prepare a "fill slip" for the distribution of chips and coins to gaming tables. The original and duplicate of the request for fill shall include the following entries:
(a) The date, time, and shift of preparation;
(b) The denomination of gaming chips or coins to be distributed to the gaming tables;
(c) The total amount of each denomination of gaming chips or coins to be distributed to the gaming tables;
(d) The game and table number to which the gaming chips or coins are to be distributed;
(e) The signature of the gaming operation supervisor; and
(f) The signature of the security department employee that distributed the chips and coins.

Transporting requests.
(3) After preparation of the request for fill, the original of such request shall be transported directly to the cashier's cage by security.

Duplicate copies of the request.
(4) The duplicate copy of the request for fill shall be placed by the dealer or floor supervisor in public view on the gaming table to which the gaming chips or coins are to be received. Such duplicate copy shall not be removed until the chips and coins are received, at which time the request for fill and fill slip are deposited in the drop box.

Fill slip procedures.
(5) A fill slip shall be prepared by a cashier whenever gaming chips or coins are distributed to the gaming tables from the cashier's cage. The following procedures and requirements shall be observed with regard to fill slips:
(a) Each series of fill slips shall be in triplicate form to be kept in a locked dispenser that will permit an individual fill slip in the series and its copies to be written upon simultaneously while still located in the dispenser, and that will discharge the original and duplicate while the triplicate remains in a continuous, unbroken form in the dispenser: Provided, That if a computer system is used, which includes a nonrepeating sequential numbering system, the controls and safeguards of the manual system must be present; and Because StraightEdge 3.0 would eliminate the Whiz Machine, there may be some concern about surveillance being able to validate the amount of the fill/credit slip when the amounts/information is entered on the computer versus the Whiz Machine, StraightEdge 3.0 adds a fourth layer of security. StraightEdge 3.0 does provide an electronic copy of the fill/credit slip to surveillance in real time so there is no question surveillance can see what was completed by the employee, as well as view the printed documents through CCTV, as what is currently being practiced with use of the Whiz Machine. This is a viable solution that would enable surveillance to validate fill/credit slips both on-screen and REAL time, but also to print out the fill/credit slip and put the sequentially numbered document under the camera for surveillance to validate before releasing the fill/credit.
(b) Access to the triplicate copy of the form shall be maintained and controlled at all times by an accounting department employee responsible for controlling and accounting for the unused supply of fill slips, placing fill slips in the dispensers, and removing from the dispensers, each day, the triplicate copies remaining therein: Provided, That access will be permitted to an employee of the security department for the sole purpose of clearing any paper jams in the dispenser.With the use of our computer based system, the triplicate copy remains in the database and is controlled by the accounting department.

Information to be recorded on fill slip.
(6) On the original, duplicate, and triplicate copies of the fill slip, the preparer shall record, at a minimum, the following information: Our computer based system captures the information required below and prints three copies. Would the WSGC consider this an original, duplicate and triplicate, if all three copies still obtain the wet signatures as required in (9) below?
(a) The denomination of the gaming chips or coins being distributed;
(b) The total amount of each denomination of gaming chips or coins being distributed;
(c) The total amount of all denominations of gaming chips or coins being distributed;
(d) The game and table number to which the gaming chips or coins are being distributed;
(e) The date and shift during which the distribution of gaming chips or coins occurs; and
(f) The signature of the preparer.
(7) Upon preparation, the time of preparation of the fill slip shall be recorded, at a minimum, on the original and the duplicate.

Employee verification.
(8) All gaming chips or coins distributed to the gaming tables from the cashier's cage shall be transported directly by a security department employee. This employee shall verify the request for fill to the amount of the fill slip and sign the original of the request for fill, which is maintained at the cashier's cage, before transporting the gaming chips or coins and the original and duplicate of the fill slip for signature.

Signatures required on fill slips.
(9) Signatures attesting to the accuracy of the information contained on the original and duplicate of the fill slips shall, at a minimum, be those of the following personnel at the following times:
(a) The cashier upon preparation;
(b) The security department employee transporting the gaming chips or coins to the gaming table upon receipt from the cashier of gaming chips or coins;
(c) The dealer assigned to the gaming table upon receipt; and
(d) The gaming operation supervisor assigned to the gaming table upon receipt of the gaming chips or coins at such table.

Transporting chips and coins.
(10) Upon meeting the signature requirements, the security department employee that transported the gaming chips or coins and the original and duplicate copies of the fill slip to the table, shall observe the following:
(a) The dealer shall immediately place the duplicate fill slip and duplicate request for fill in the drop box attached to the gaming table to which the gaming chips or coins were transported; and
(b) The security department employee shall then return the original fill slip to the cashier's cage where the original fill slip and request for fill shall be maintained together and controlled by cage employees.

VOID procedures.
(11) The original and duplicate "VOID" fill slips, the original request for fill, and the original fill slip shall be forwarded as follows:
(a) The count team, as described in WAC 230-40-885 (2), for agreement with the duplicate copy of the fill slip and duplicate copy of the request for fill removed from the drop box after which the original and duplicate copy of the request for fill and the original and duplicate copy of the fill slip shall be forwarded to the accounting department for agreement, on a daily basis, with the triplicate; or
(b) The accounting department for agreement, on a daily basis, with the duplicate fill slip and duplicate copy of the request for fill removed from the drop box and the triplicate.

230-40-875 Closing gaming tables — House-banking.
Procedures shall be followed for closing gaming tables that ensure proper accountability of gaming chips and coins. The following restrictions and procedures apply:

Counting chips and coins.
(1) Whenever the gaming activity at each gaming table is concluded for the day, the gaming chips and coins shall be counted by the dealer assigned to the gaming table and observed by a gaming operation supervisor. The entire count and closure process shall be monitored and recorded by the surveillance department.

Recording the count.
(2) The gaming chips and coins counted shall be recorded on a table inventory slip by the gaming operation supervisor assigned to the gaming table.

Table inventory slips.
(3) Table inventory slips shall be three-part serially prenumbered forms and on the original of the slip (closer), the duplicate of the slip (opener), and on the triplicate, which is maintained and controlled by security, the gaming operation supervisor shall record the following: Would the WSGC consider three copies of the same sequentially numbered table inventory slip as a three-part form? All verification signatures that are required below in (4) are obtained. Also, in (5) below, all copies of the slip are dropped and routed according to the requirements listed below. Would the WSGC consider this a three-part form is the words, “original”, “duplicate” and “triplicate” were on each copy of the same sequentially numbered form?
(a) The date and identification of the shift ended;
(b) The game and table number;
(c) The total value of each denomination of gaming chips and coins remaining at the tables; and
(d) The total value of all denominations of gaming chips and coins remaining at the gaming tables.

Verification signatures.
(4) Signatures attesting to the accuracy of the information recorded on the table inventory slips at the time of closing the gaming tables shall be of the dealer and the gaming operation supervisor assigned to the gaming table who observed the dealer count the contents of the table inventory.

Distributing table inventory slips.
(5) Upon meeting the signature requirements:
(a) The closer shall be deposited in a drop box attached to the gaming table immediately prior to the closing of the table;
(b) The opener and the gaming chips and coins remaining at the table shall be placed in a clear container provided for that purpose after which the container shall be locked; and
(c) The triplicate copy of the table inventory slip shall be forwarded to the accounting department by a security department employee.

VOID procedures.
(6) In the event the closer is voided, the preparer shall void this form by writing the word "VOID" on all copies of the form. All copies of the form shall then be forwarded to the accounting department.
(7) At the end of each gaming day, if the locked containers are transported to the cashier's cage, a cage cashier shall determine that all locked containers have been returned to the cage and adequately secured or, if the locked containers are secured to the gaming table, a gaming operation supervisor shall account for all the locked containers.

Removing drop boxes from tables.
(8) In the event drop boxes are removed from gaming tables at other than the close of the gaming day, they shall be removed at a shift change. A table inventory slip shall be prepared as required above with the incoming and outgoing supervisor verifying the inventory and signing.