§ 543.9 What are the minimum internal control standards for pull tabs?

(a) Supervision. Supervision must be provided as needed for pull tab operations and over pull tab storage areas by an agent(s) with authority equal to or greater than those being supervised. (b) Pull tab inventory. Controls must be established and procedures implemented to ensure that: (1) Access to pull tabs is restricted to authorized agents; (2) The pull tab inventory is controlled by agents independent of pull tab sales; (3) Pull tabs exchanged between agents are secured and independently controlled; (4) Increases or decreases to pull tab inventory are recorded, tracked, and reconciled; and (5) Pull tabs are maintained in a secure location, accessible only to authorized agents, and with surveillance coverage adequate to identify persons accessing the area. (c) Pull tab sales. (1) Controls must be established and procedures implemented to record, track, and reconcile all pull tab sales and voids. (2) When pull tab sales are recorded manually, total sales must be verified by an agent independent of the pull tab sales being verified. (3) No person may have unrestricted access to pull tab sales records. (d) Winning pull tabs. (1) Controls must be established and procedures implemented to record, track, and reconcile all redeemed pull tabs and pull tab payouts. (2) The redeemed pull tabs must be defaced so that they cannot be redeemed for payment again. (3) Pull tabs that are uniquely identifiable with a machine readable code (including, but not limited to a barcode) may be redeemed, reconciled, and stored by kiosks without the need for defacing, so long as the redeemed pull tabs are secured and destroyed after removal from the kiosk in accordance with the procedures approved by the TGRA. (4) At least two agents must document and verify all prize payouts above $600, or lower threshold as authorized by management and approved by the TGRA. (i) An automated method may substitute for one verification. (ii) The predetermined threshold must be authorized by management, approved by the TGRA, documented, and maintained. (5) Total payout must be calculated and recorded by shift. (e) Pull tab operating funds. (1) All funds used to operate the pull tab game must be accounted for and recorded and all transfers of cash and/or cash equivalents must be verified. (2) All funds used to operate the pull tab game must be independently counted and verified by at least two agents and reconciled to the recorded amounts at the end of each shift or session. (f) Statistical records. (1) Statistical records must be maintained, including (for games sold in their entirety or removed from play) a win-to-write hold percentage as compared to the expected hold percentage derived from the flare. (2) A manager independent of the pull tab operations must review statistical information when the pull tab deal has ended or has been removed from the floor and must investigate any unusual statistical fluctuations. These investigations must be documented, maintained for inspection, and provided to the TGRA upon request. (g) Revenue audit. Standards for revenue audit of pull tabs are contained in § 543.24, Revenue Audit. (h) Variances. The operation must establish, as approved by the TGRA, the threshold level at which a variance must be reviewed to determine the cause. Any such review must be documented.