compamy non-key NOTE 1: For testing of Restricted Access to applications, and SAS 70 status, see IT

testwork.
NOTE 2: For segregation of duties review, see flowcharts.
SOX to ER Audits Mapping/Test Plan

Control Business Process Sub-Process Risk Description Control Control Activity Control Risk Control Testing Step Performed

Preventive (P)
or Detective (D)
Number Objective Activity (H, M, Owner (Who
Frequency L) or Title)
(D, W, BW,
M, Q, A)

1.1 Payroll (PR) Data Entry Payroll changes are Payroll HR department head or manager approves all P BW M HR Director See Payroll Audit - For 10 pay periods (from 1/07-9/07 ), reviewed
valid, properly changes are changes (except changes to employee Personnel/Payroll Transmittal for evidence of HR department head or
prepared and approved by exemptions). All payroll changes are manager approval, noting no exceptions.
authorized HR authorized.

1.2 Payroll (PR) Data Entry Payroll data are Data entry is Verification by Payroll that all approved wage P BW M Jamie Price, See Payroll Audit - For 10 pay periods (from 1/07-10/07), reviewed
properly recorded accurate adjustments and payroll changes have been Supr. Personnel/Payroll Transmittal for evidence of cross-check by someone
accurately entered in the Paychex system. independent of the data entry, noting no exception.

1.3 Payroll (PR) Processing Timesheets are not Data entry is Verification by Payroll (by cross-check and P BW H Jamie Price, See Payroll Audit - For 5 pay periods (from 1/07-5/07), reviewed Time Edit
correctly entered in accurate initials) that approved manual changes for non- Supr. Report and Salaried Time Sheets for evidence of cross-check by someone
the PR system exempt hours and salary time sheets are properly independent of the data entry noting no exceptions.
entered into Paychex.

Reviewed 5 pay periods' Time Edit Report summaries (6/18-7/1, 7/2-7/15,

7/30-8/12, 8/13-8/26, 9/10-9/23) and Salary time sheets for 5 employees for
evidence of review noting manual changes on Time Edit Report summaries
for non-exempt employees and salary timesheets were approved by
department heads and cross-checked by someone independent of the data
entry in payroll noting no exception.

1.4 Payroll (PR) Reporting Payroll is not Payroll is Payroll department summaries are reviewed for D BW H Jamie Price, See Payroll Audit - For 10 pay periods (from 1/07-9/07), reviewed Payroll
accurate, valid, or accurate, valid, accuracy, validity, completeness and Supr. Journals for evidence of review by department head noting no exceptions.
complete and complete. reasonableness by department heads (or
designee) subsequent to processing.

1.5 Payroll (PR) Reporting Payroll is not Payroll is Racetrack Controller prepares the payroll journal P/D M H Racetrack See Payroll Audit - Reviewed 4 payroll journal entries (March-June) for
reasonable and reasonable. entry. Accountant reviews and approves. Controller propriety (by agreeing to supporting documentation) and evidence of review
properly recorded & approval by someone independent of the preparation, noting no
exceptions.
1.55 Payroll (PR) Reporting Payroll is not Payroll is Mktg. Fin. Mgr. prepares the gross payroll P/D M H Racetrack Reviewed 4 Payroll Journal Entries for June-September for evidence of
reasonable and reasonable. allocation journal entries, which are reviewed Controller review and approval by the Racing Controller noting no exception.
properly recorded and approved by the Racing Controller.
1.6 Payroll (PR) Reporting Payroll is not Payroll-related Payroll-related accounts (reviewed monthly by D Q H Racing See Payroll Audit - Reviewed 1 payroll reconciliation (1st Qtr) for
properly recorded. accounts and the Accountant (as part of the month-end Controller propriety (by agreeing to supporting documentation & GL), noting review
vacation checklist), with quarterly reconciliations & approval by someone independent of the preparation, noting no
accrual (performed by the Accountant) reviewed for exception.
properly reasonableness and propriety and approved by
recorded. Racing Controller. (Vacation accrual
compamy non-key NOTE 1: For testing of Restricted Access to applications, and SAS 70 status, see IT
testwork.
NOTE 2: For segregation of duties review, see flowcharts.
SOX to ER Audits Mapping/Test Plan

Control Business Process Sub-Process Risk Description Control Control Activity Control Risk Control Testing Step Performed

Preventive (P)
or Detective (D)
Number Objective Activity (H, M, Owner (Who
Frequency L) or Title)
(D, W, BW,
M, Q, A)

1.7 Payroll (PR) Rec Payroll payments are Payroll Bank reconciliations are reviewed and approved D M H Accountant (See Cage testwork- 3.33) - Reviewed 4 months' bank reconciliations for
not accurate. payments are by someone independent of the preparation. propriety (agreement to adequate supporting documentation) and proper
accurate. approval, noting no exception. (February, March, June, July)

1.75 Payroll (PR) Rec Payroll payments are Payroll Each employee (or departmental designee) must P/D BW L Jamie Price, See Payroll Audit - Reviewed 10 pay periods (1/07 - 9/07) noting receipt of
distributed to existing payments are initial a form evidencing receipt of their check. Supr. departmental payroll checks were properly evidenced by applicable
employees. not distributed employees, noting no exception.
to existing
1.8 Payroll (PR) 401K 401K information is 401K VP-Finance reviews and approves 401K P BW H VP-Finance See Payroll Audit - Reviewed 8 pay periods' (1/17, 2/14, 3/28, 4/11, 5/23,
employees.
not accurate, valid, or information is worksheet from Payrolland compares to Paychex 6/20,7/18, 8/15) 401K worksheets for accuracy, noting evidence of review by
complete accurate, valid, 401K report for accuracy VP-Finance, noting no exception.
1.9 Payroll (PR) 401K 401K information is or complete
401K Payroll Clerk enters amounts from spreadsheet P BW H Jamie Price, See Payroll Audit - Agreed spreadsheets (see 1.8) to Paychex, noting
not accurate, valid, or information is into Paychex, and agrees back to spreadsheet. Supr. evidence of Payroll review & approval; no exceptions
complete accurate, valid, Payroll Supv. reviews and approves.
or complete
1.10 Payroll (PR) 401K 401K information is 401K 401K Report from Paychex is agreed to D BW M Jamie Price, See Payroll Audit - Reviewed the same pay periods as above (1.8) for
not accurate, valid, or information is spreadsheet, and entered into WYSTAR’s Track Supr. evidence of WYSTAR confirmation noting no exception.
complete accurate, valid, Now spreadsheet; they confirm batch totals &
or complete post balances to the website.
1.12 Payroll (PR) Corporate Payroll is Payroll is CFO reviews and approves the payroll analysis D M H CFO Reviewed Feb.-May 2007 payroll analysis for reasonableness and evidence
unreasonable reasonable prepared by the Corp. Controller of CFO review & approval, noting no exception.
compamy

SOX to ER Audits Mapping/Test Plan

Control Sample Size Exception?

Number

1.1 5 no

1.2 5 no

1.3 5 no

5 salary time sheets no

5 Time Edit Report

1.4 5 no

1.5 2 no

1.55 4 no

1.6 1 no
compamy

SOX to ER Audits Mapping/Test Plan

Control Sample Size Exception?

Number

1.7 4 no

1.75 5 no

1.8 4 no

1.9 4 no

1.10 4 no

1.12 2 no
Monticello Gaming & Raceway
SOX Test Plan - 2008
Control Business Sub-Process Control Activity Control Control Testing Step Performed Sample Size Exception?
Number Process Activity Owner (Who
Frequency or Title)
(D, W, BW,
M, Q, A)
Initials Date
2.1 Purch/AP MRMI & The A/P Dept. reviews the purchase D A/P Supr Review payments for MRMI & Racing for proper AP approval. 5 each (MRMI
Racing documentation, noting proper required & Racing) per
signatures prior to data entry. month
2.5 Purch/AP MRMI & The accounting staff and VP of Finance both D VP-Fin Reviewed MRMI & Racing checks for evidence of review (initials on check 5 each (MRMI
Racing review all MRMI expenditures for propriety. stub). & Racing) per
VP-Finance initials his review. In the absence month
of VP-Finance, the Racing Controller, Sr
Accountant, or Mktg./Fin. Mgr may initial the
final review.

2.15 Purch/AP MRDC VP-Finance (or Mktg/Fin Mgr.) reviews & M VP-Fin Reviewed MRDC checks for evidence of review (initials on check stub). 5/month
approves checks prior to mailing.

1.7, 2.18, Payroll Rec Bank reconciliations are reviewed and approved M Accountant Review bank reconciliations for proper approval (initials). each month
3.33, by someone independent of the preparation.
4.48,
4.91,
2.17 Purch/AP MRDC Journal entries are independently reviewed and M Accountant Review MRDC journal entries for evidence of review and approval by each month
approved by someone independent of the someone independent of the preparation (initials).
preparation.

3.27 Revenue POS/Non- VGM Accountant reviews & approves the D Accountant Reviewe POS journal entries for evidence of VGM Accountant review & 5/month
Gaming journal entry after posting to the GL. approval.

3.31 Revenue RV A 2nd VGM Accountant evidences an M Accountant Review VGM journal entries, noting all contain evidence of VGM 5/month
independent check by reviewing for propriety Accountant's proper review and approval (initals).
and initialing the Main Bank Rec journal entry
and the VGM journal entry.
3.32 Revenue RV VGM Accountant reconciles the Main Bank M Accountant Review reconciliations of the Main Bank Reconciliation to the GL for each month
Reconciliation to the GL. evidence of Accountant's initials.
4.46 Mktg Marketing Sr. VGM Accountant (or someone independent D Accountant Review journal entries for proper approval (initials) by someone 5/month
Reimbursem of the posting) reviews and approves journal independent of the posting.
ent entries for restricted cash receipts and accrual of
8% of marketing allowance.

4.8 AP / Horsemen's Journal entries for purses and interbank transfers M Accountant Review journal entries for evidence of proper review and approval (initials) each month
Expense- Purses are prepared by the Racing Controller and by someone independent of the preparation.
Racing reviewed and approved by someone independent
of the preparation
Monticello Gaming & Raceway
SOX Test Plan - 2008
Control Business Sub-Process Control Activity Control Control Testing Step Performed Sample Size Exception?
Number Process Activity Owner (Who
Frequency or Title)
(D, W, BW,
M, Q, A)
Initials Date
5.9 F/S Close Depr The VGM Senior Accountant. reviews and M Accountant Review journal entries for evidence of review and approval by VGM each month
approves the depreciation journal entries Accountant.
prior to posting.

4.2 AP / Players Club Marketing Dept. reviews and approves any large W Dir - Mktg Review manual point adjustments for proper approval (initials) by someone 1 / month
Expense manual point adjustments on a monthly basis. who does not perform Players Club transactions (Director, etc.)

1.3 Payroll Processing Verification by Payroll (by cross-check and BW Jamie Price, Review Time Edit Report and Salaried Time Sheets for evidence of cross- 1 dept. / month
(PR) initials) that approved manual changes for non- Supr. check by someone independent of the data entry (2 initials).
exempt hours and salary time sheets are properly
entered into Paychex.

1.75 Payroll Rec Each employee (or departmental designee) must BW Jamie Price, Review that receipt of departmental payroll checks were properly 1 / month
(PR) initial a form evidencing receipt of their check. Supr. evidenced by applicable employees (signatures)

1.5 Payroll Reporting Racing Controller prepares the payroll journal M Racing Review payroll journal entries for evidence (initials) of review & approval 1 / month
(PR) entry. Accountant reviews and approves. Controller by someone independent of the preparation.
1.55 Payroll Reporting Mktg. Fin. Mgr. prepares the gross payroll M Racing Review payroll journal entries for evidence of review and approval (initials) 1 / month
(PR) allocation journal entries, which are reviewed Controller by the Racing Controller.
and approved by the Racing Controller.
4.1 AP / Players Club The Racing Controller reviews, approves, and M Racing Review outstanding redeemable points expense journal entries for evidence 1 / month
Expense initials the VGM Accountant’s month-end Controller of properly review and approval (initials) by the Racing Controller.
journal entry recording the expense and liability
for outstanding redeemable cash points.

4.5 AP / Horsemen's Either the second Assistant to the Racing D/W Racing Review Overnight Sheet for evidence of review (initials). 5/month
Expense- Purses Controller or the Racing Controller compares the Controller
Racing purse totals on the Overnight Sheet to the Purse
Summary. After confirming the totals, the
Overnight Sheet is initialed.
Monticello Gaming & Raceway
SOX Test Plan - 2008
Control Business Sub-Process Control Activity Control Control Testing Step Performed Sample Size Exception?
Number Process Activity Owner (Who
Frequency or Title)
(D, W, BW,
M, Q, A)
Initials Date
4.7 AP / Horsemen's The Racing Controller or designee agrees the W Racing Review weekly purse transfer for evidence of Racing Controller's review of 1 / month
Expense- Purses weekly purse transfer to the supporting Controller purse amounts (initials).
Racing Overnight Sheets and compares the weekly total
to the (upper limit) range established by the
Exec. VP & GM, then signs off on the purse
transfer (and then prepares an inter-bank transfer
of funds from the Purses Escrow account to the
Horsemen's purses acccount.)

5.41 F/S Close F/S Close - MRMI reconciliations, account analyses and M Racing Review checklists for evidence of review & approval (initials) by someone 1 / month
MRMI revenue entries are completed in accordance Controller; independent of the preparation.
with a checklist, reviewed for propriety, and Accountant
approved by the Accountant and Racing
Controller.

5.40 F/S Close F/S Close - VP-Finance reconciles the intra-company M VP-Fin Review financial statements for both MRMI and MRDC for evidence of
5.43 MRMI & balances (Racing & VGM) and signs off on draft review and approval by VP of Finance and CFO (initials).
MRDC financials before submission to Corp. Controller.
CFO also reviews & signs off.
Monticello Gaming & Raceway
SOX Test Plan - 2008
Control Business Sub-Process Control Activity Control Control Testing Step Performed Sample Size Exception?
Number Process Activity Owner (Who
Frequency or Title)
(D, W, BW,
M, Q, A)
Initials Date

Quarterly Controls

1.6 Payroll Reporting Payroll-related accounts (reviewed monthly by Q Racing Review payroll reconciliation for evidence of review & approval (initials) by
(PR) the Accountant (as part of the month-end Controller someone independent of the preparation.
checklist), with quarterly reconciliations
(performed by the Accountant) reviewed for
reasonableness and propriety and approved by
Racing Controller. (Vacation accrual is
annual)

5.21 F/S Close Asset MRMI periodically reviews long-lived assets to Q VP Fin, CFO Review evidence of the review by Management (initials) of MRMI's long-
Impairmt/All determine if carrying values are recoverable or lived assets for impairment.
ow for should be reduced to fair value. Journal entries
Doubtful for any necessary adjustments are made and
Accts approved by a person independent to the J/E
process.