[Letterhead]
[Date] Hon. Sequoyah Simermyer, Chairman Hon. Katherine Ishom-Clause, Vice Chairman National Indian Gaming Commission 90 K Street, NE Suite 200 Washington, DC 20002 Re: Dear Tribal Leader Letters July 30, 2020; August 14, 2020 Dear Chairman Simermeyer and Vice-Chair Isom-Clause:
On behalf of the ________ Tribe, we write in response to your July 30, 2020 Dear Tribal Leader Letter on the NIGC 2022 Budget and the August 14, 2020 Dear Tribal Leader Letter on the Accounting Data Collection. July 30, 2020 Dear Tribal Leader Letter on the NIGC 2022 Budget: In response to the NIGC July 30, 2020 letter concerning the Budget, we note that NIGC was planning to increase FTEs from 113 to 135 in the Greenbook. In the context of the National COVID-19 Public Health Emergency and Economic Crisis, which started on March 1, 2020, our Tribe requests that NIGC freeze its hiring, cut its budget and fees by 20%. Many Tribal Governments have suffered losses in the first, second, and third quarters, as Indian gaming operations shut down and limited operations in order to slow the community spread of the COVID-19 Coronavirus. The outlook for the 4 th Quarter of 2020 and the 1 st Quarter of 2021 remains uncertain. In addition, many Tribal Governments have also had to furlough or lay- off workers. In these circumstances, NIGC should not hire new regulatory staff or raise fees. Instead, we encourage NIGC to ask Congress for an appropriation to help tide over its existing expenses until the end of the National COVID-19 Pandemic and Economic Crisis if the NIGC anticipates a drop in annual fees this year or next. See 25 U.S.C. sec. 2717—2718. August 14, 2020 Dear Tribal Leader Letter on the Accounting Data Collection: On August 14, 2020, in a Dear Tribal Leader letter the National Indian Gaming Commission (NIGC) embarked on a data collection effort seeking information about the inclusion of Gross Gaming Revenue in the audited financial statements for tribal gaming operations. This data collection has prompted considerable concern from tribal leaders as to the burden of the unfunded mandate, the security and confidentiality of the sensitive tribal government business information called for, the reason this data is needed and the purpose for which it is to be used. In the letter, the NIGC states that certain accounting standards issued by FASB for disclosing gross gaming revenues on audited financial statements have changed and this has resulted in the possible omission of GGR amounts. FASB does not apply to tribal governmental gaming operations, to which GASB standards apply. A footnote in the letter seeks to import
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