September 19, 2018 CSI Filing

Created by Executive Order 2011-01K, the Common Sense Initiative (CSI), and Senate Bill 2 of the 129th General Assembly, require state agencies, including the Casino Control Commission, to draft rules in collaboration with stakeholders, assess and justify any adverse impact on the business community (as defined by Senate Bill 2), and provide opportunity for the affected public to provide input on the rules. 

The Ohio Casino Control Commission submitted the following proposed rule to the CSI office for review on September 19, 2018: 

Brief Explanation of the Rule

This rule requires casino operators to engage an independent certified public accountant annually to conduct a financial audit. The rule also requires that the Commission be notified of Securities and Exchange Commission reports filed and given copies of suspicious activity reports filed. The rule also allows the Commission to require an annual compliance audit, if necessary. The amendment to the rule largely strips out unnecessary verbiage but does contain two substantive changes. First, it requires that the lead audit partner engaged by a casino operator for the annual financial audit must rotate off the assignment if that partner has served in that capacity for five years. Second, the rule eliminates the requirement that casino operators have internal controls related to certain federal regulations. Eliminating this requirement allows the casino operators to more quickly adjust to any changes required by federal government regulators without the need for Commission approval. The purpose of this rule is to ensure the integrity of casino gaming by having neutral third parties and the Commission conduct or receive audits, reports, and other important financial filings or documents.

3772-10-07 (1 Rule)

  • 3772-10-07, titled “Annual audit; other reports; currency transaction reporting; suspicious transaction reporting.”  This rule requires casino operators to engage an independent certified public accountant annually to conduct a financial audit. The rule also requires that the Commission be notified of Securities and Exchange Commission reports filed and given copies of suspicious activity reports filed. The rule also allows the Commission to require an annual compliance audit, if necessary. The amendment to the rule largely strips out unnecessary verbiage but does contain two substantive changes. First, it requires that the lead audit partner engaged by a casino operator for the annual financial audit must rotate off the assignment if that partner has served in that capacity for five years. Rotation requirements are common in the audit industry including that the requirement for public companies is also set at a five-year period. Audit partner rotation can help prevent the audit partner from becoming too comfortable with the client or from having too close of a relationship with the client. Therefore, audit partner rotation may help prevent or detect fraud and bolster the audit firm’s independence. Second, the rule eliminates the requirement that casino operators have internal controls related to certain federal regulations. Eliminating this requirement allows the casino operators to more quickly adjust to any changes required by federal government regulators without the need for Commission approval. The purpose of this rule is to ensure the integrity of casino gaming by having neutral third parties and the Commission conduct or receive audits, reports, and other important financial filings or documents.

Associated CSI Documents
Business Impact Analysis

Contact Information for Comments

The Commission welcomes comments regarding these proposed rules. To ensure your comments are considered as part of the Common Sense Initiative (“CSI”) review period, the Commission should receive them no later than October 3, 2018.

Any questions or comments with respect to these rules may be directed to William Cox via email at William.Cox@casinocontrol.ohio.gov or U.S. Mail at 100 East Broad Street, 20th Floor, Columbus, Ohio 43215. Comments may also be directed to the CSI Office at csipubliccomments@governor.ohio.gov.


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