 Okay. Okay. Thank you. Good morning, everyone. This is a meeting of the Massachusetts Gaming Commission. And because we are holding this on a virtual platform, we will do a roll call please. Good morning, Commissioner Brian. Good morning. I am here. Good morning, Commissioner Hill. Good morning. I'm here. Good morning, Commissioner Skinner. Good morning. I'm here. And good morning, Commissioner Maynard. Good morning, Madam Chair. I am here. Excellent. We'll get started with the call. Today is December 7, 2022. It is public meeting number 407. And before I turn to our general counsel, I would like to make a few introductory remarks. For those of you who attended yesterday's public meeting, much of what I will say will sound familiar. I'm going to reiterate my remarks as I assume Councilor Grossman will because today is a different applicant with different stakeholders and interested parties. So bear with me, commissioners. But today, as we begin our evaluation of these applications, we as commissioners are reminded of our principal responsibility to ensure the public confidence in the integrity of the gaming industry here in Massachusetts and the strict oversight of the gaming establishments and regulations for sports wagering operators through rigorous regulation. We are reminded that the MGC's licensees will be held to the highest standards of compliance, including an obligation to maintain their integrity. As we have said in the past, the award of a gaming license in the Commonwealth is a peerless privilege. The laws require gaming licensees to be held to those highest standards on a continuing basis. The MGC mission commits us to creating a fair, transparent and participatory process that engenders the competence of the public and its participants. By law, that process is to maximize the benefit to the Commonwealth. Critically, it must minimize potential or realize negative or unintended consequences. Again, as I mentioned yesterday, I do want to thank you, my fellow commissioners, for your continued commitment to that mission and for your thoughtfulness and diligence today and over the next several weeks as we evaluate these applications. As I said, I feel very fortunate to serve with you, particularly as we work tirelessly to implement this new law with the public's interest in the forefront. Our last several months and the months ahead have been demanding and will continue to be demanding on our MGC team. Many of who are here today and available to us. It is a team of excellence. We are grateful for the contribution each of you are making individually, making personal sacrifices, but always collaborating as colleagues. We thank you for your dedication as public servants and commitment to the MGC mission. With that, let me give a brief overview of today's agenda. First, you will hear from our general counsel Todd Grossman, who will review the statutory and regulatory framework that will guide us as we evaluate the applications. Then, Blue Tarp Ray Development LLC doing business as MGM Springfield will present its application for a category one license using 205 CMR 2018.063 as guidance. After that presentation, we will likely take a short break. Then we'll hear from GLI, IEB and RSM relative to the technology suitability and finance components of the application. That will lead us to a section by section analysis of the application during which the applicant will answer your questions and staff members as yesterday and our legal team, of course, in addition to GLI, IEB and RSM will also be available to answer questions. And to ensure that we have ample time to reflect, finalize any personal notes, memorializing our impressions and following up with an unanswered question, I will take the liberty of calling for a break or pausing the section. We'll just call it right here. Then after any further questions for purposes of review of the category one applications, I'll see from the group comments in a sense as to whether we have a consensus regarding the quality of the applicant's response to that section. Did the applicant not meet expectations relative to the standard of review as employed by General Counselor Grossman, or did the applicant meet expectations, or did the applicant exceed expectations? At any time during this public meeting, permission may determine that an executive session is required for us to fully review and evaluate certain information in the application as to the forth in the agenda. Should we vote to go into executive session? At this time it is anticipated that the public session of this commission meeting will be convened today, and we will rely on the guidance of Counselor Grossman should we consider going into executive session. After our review of the application today, we will consider whether we wish to proceed with our determination process fully or in part, or defer that decision entirely to another day. And with that, let's turn to item number two on the agenda. Good morning, Todd. Good morning, General Counsel Grossman. Thank you. Good morning, Madam Chair, commissioners and all who are joining us here today. Of course, we're here so that the commission may evaluate the application received for a Category 1 sports wagering operator license submitted by Blue Tar Breed Development LLC, which is the licensee that operates MGM Springfield. Prior to commencing the review, however, it may be useful to set the stage by walking through the legal provisions and principles that will inform the commission's decision making. And with that I'll highlight a few provisions of the Massachusetts Sports Waging Act, which has of course been enacted as chapter 23N of the general laws, and then a number of sections of the commission's recently adopted regulations. Of course, as always, questions and comments are invited along the way. But with that, allow me to begin with chapter 23N. And the first place to look is at section 6B1, which says, quote, the commission shall issue a Category 1 license to any holder of a gaming license, as defined in section 2 of chapter 23K, that meets the requirements of this chapter and the rules and regulations of the commission. Provided, however, that any holder of a Category 1 license shall not be issued a Category 2 license. So in the present matter, Blue Tar Breed Development is a holder of a gaming license under chapter 23K. Accordingly, if it meets the requirements of chapter 23N and 205CMR that I'll discuss momentarily, then it shall be issued a Category 1 sports wagering operator license. Before we look at the commission's regulations that govern the licensing process for Category 1 applicant though, we should discuss what a Category 1 sports wagering operator license is. And that term is defined in chapter 23N, section 3, to mean a license issued by the commission that permits the operation of sports wagering in person at a gaming establishment, as defined in section 2 of chapter 23K, and through not more than two individually branded mobile applications or other digital platforms approved by the commission. So this application, if it were to be awarded in a Category 1 license granted, they would be authorized to operate an in-person retail sports wagering operation at MGM Springfield, and have two mobile operations as well. And this Category 1 license is the tool that enables the licensee to operate through those two mobile platforms. But remember that the entities that will actually run the mobile or digital platforms would first have to obtain a Category 3 license themselves. Let's have a look now at the commission's rules and regulations that have to be met by an applicant in order to be issued a license. And I think the best place to begin there is with 205CMR 218, which as you know is the section that sets out the application requirements, standards, and procedures. The process itself has of course already begun, and administrative efficiency review is performed upon the submission of the suitability portions of the application. And then the commission convened a public meeting two days ago in order to receive public feedback on the Category 1 applications, and momentarily will walk through the factors and standards that the commission has set up for the award of a license. But prior to doing so, there are a few other provisions and principles that are important to keep in mind. First, the regulations provide that the commission shall analyze the factors and considerations set out in the regs, but need not do so in any particular order, or give any individual factor any particular way, and in fact can assign a factor no weight at all, if deemed appropriate. Next, you'll recall that the regulations provide that the commission may require or permit the applicant to provide additional information or documents as the commission deems appropriate in its review of the application. So if you're evaluating the information provided in the application relative to a particular factor, and you determine that further information is required, you may direct the applicant to provide it. Similarly, if during the course of the commission's evaluation of the applicant, the applicant itself observes that there is additional information that was not provided that may be of use, it may request an opportunity to provide it. Further, it's noteworthy that the present review today is being conducted as part of a regular public meeting under the open meeting law and not as an adjudicatory proceeding. That means a number of things, including that all deliberations must take place in public, and that if necessary the executive session provision of chapter 38 may be utilized. As it pertains to the instant matter section 21 a seven of chapter 30 a allows the commission to move into executive session quote to comply with or act under the authority of any general law and quote. In the present situation there is a general law that gives the commission authority to move into executive session. Specifically section six I of chapter 23 n says that applications for an operator license that shall be public records under section 10 of chapter 66 provided however that trade secrets competitively sensitive or other proprietary information, provided in the course of an application for an operator license under this chapter, the disclosure of which would place the applicant at a competitive disadvantage, maybe withheld from disclosure under the public records law. In some if there is any specific information that the commission would like to discuss, but that the applicant identifies as falling within that provision, and the commission agrees, it may move into executive session to discuss that specific information. The statutory provision in chapter 23 and relates to the public records law, and not the open meeting law to require that the subject information be discussed publicly with nullify the whole purpose of the provision which is designed to protect such information. Accordingly, application of the executive session provision I referenced before is appropriate in this instance. And finally, before moving into the factors themselves. It's also important to recall that any finding the commission makes today, or during the course of this application review must be supported by substantial evidence. This term is defined as such evidence as a reasonable mind might accept as adequate to support a conclusion. So, when making a determination as to whether there is support in the application to find that a specific factor has been satisfied, or has not been satisfied. The commission will have to ensure that there is substantial evidence in the record to support that conclusion. And there is one exception to this rule. And it's an area in which a heightened standards applied, and that is, as it relates to the review of an applicant suitability. In section 215 of the regulations, any durable finding of suitability must be supported by clear and convincing evidence, not just substantial evidence which is a lower standard. The jurisprudence tells us that clear and convincing proof exists when the evidence induces in the mind of the fact finder here the commission. There is no belief that the facts asserted are highly probably true that the probability that they are true or exist is substantially greater than the probability that they're false or do not exist. And for evidence to be clear and convincing it must be sufficient to convey a high degree of probability that the proposition to be proved is true, and it must be strong and positive and full clear and decisive. So those are the two standards of review that we'll experience here during these proceedings, and we will work through those lenses. So now let me lay out the factors included in section 218. The factors are included specifically in 218.06 subsection five. Each factor falls under the umbrella standard that the commission included in the regulation which directs that in determining whether to award a sports catering operator license. The commission will evaluate the application to determine whether the license award would benefit the commonwealth. So that's the main standard that will have to be met in order to award a license. In conclusion, though, the commission provided that it will consider the following factors and recall that the application itself was designed so as to elicit information in these specific categories. First, the applicants experience and expertise related to sports major. Second, the economic impact and other benefits to the commonwealth if the applicant has awarded a license. Number three, the applicants proposed measures related to responsible gaming. The description of the applicant's willingness to foster racial, ethnic and gender diversity, equity and inclusion. Number five, the technology that the applicant intends to use in its operation. Number six, the suitability of the applicant and its qualifiers, and we'll come back to that one momentarily. And number seven, any other appropriate factor in the commission's discretion. Those are the factors that will be reviewed as we go through the application, but I would like to circle back to that suitability factor for a moment. You'll recall that the commission adopted section to 15 of the regulations that govern suitability determinations, and it included provisions allowing for a durable finding of suitability, meaning the so called final determination. It included a provision related to a preliminary findings. So those are the two different types of findings that are addressed in the regulations. In the matter before you, you may choose to award a durable finding, ie a final finding, if you conclude that the applicant and each of its qualifiers has already demonstrated their suitability by clear and convincing proof. It means of the review conducted under chapter 23 K, and that such was maintained on an ongoing basis up to the present time. In that event, no preliminary finding need to be entered, and the this applicant could move right into durable finding territory. In principle, I direct you to section 60 of chapter 23 and which says that in investigating the suitability of an applicant, the commission may use information obtained from the applicant pursuant to chapter 23 K, chapter 128 a chapter 128 C, or information from other jurisdictions where the applicant is authorized to support. So those are the factors that the commission must consider in order to make a licensing decision. If you work through the evaluation, though, it may become clear that a condition of licensure will be appropriate in a particular area. For example, you may find that information relative to a particular factor is lacking. In that event, it does not mean that the applicant cannot be awarded a license. It may simply mean that the area may require it to be supplemented with an appropriate condition. So those are described in section 220 of the regulations, and you'll recall there are a number of automatic conditions like an obligation to obtain an operation certificate prior to commencing operations, and that the operator comply with chapter 23 and and all commission regulations. Also a provision that allows the commission to impose any other conditions that it determines are appropriate to secure the objectives of chapter 23 and and 205 CMR. As a practical matter, I might suggest that the commission begins discussing any additional conditions as part of the review of each individual factor. The commission has made its way through all of the enumerated factors, but before any final decision is made as to whether to award a license, the commission can shore up with those final conditions are in the event it is inclined to award the license. Once that's done, the commission may decide whether it will award the category one license, determine that the applicant is eligible to request the temporary license, while a complete suitability assessment is performed, or it may deny the application for failure to meet a requirement of the regulations, or for having violated section 60 or section nine of chapter 23 and once that decision is made a written decision will be prepared and issued commemorating the commission's decision and keep in mind of course that the award of a license does not mean that the licensee has the green light to commence operations. This simply means that they are eligible to work towards the award of an operation certificate, which is a prerequisite to conducting sportsway during operations. That process is described in section 251 of the regulations and requires submission and approval of such things as internal controls, including the house rules and compliance with any conditions that may be imposed as we just discussed. I'll pause, open the floor to any questions and turn things back to you, Madam Chair. Thank you. Can I just see if you have any questions for General Counsel Gross? Okay. Thank you very much. So, now they're going to turn to Luther Development LLC, Ray Development LLC, but we know them as MGM Springfield, a good morning. And I see Chris Kelly there quite clearly. I would, before you get started in your, in your review or your presentation, Chris, if you could introduce the members of your team that are here today. I'm hoping that right now I can't see everybody in your room that I don't know if you if others are experiencing that too. Good morning, Chair. It's Jed Nozzle service outside. Good to see a chair. Absolutely. I serve as outside licensing regulatory council for MGM resorts and put our development, also MGM, obviously doing business as MGM Springfield. So I'm going to introduce the team to the commission. I'll start with who's in the room here. And we have of course Chris Kelly, president and COO of MGM Springfield. We have Arlene Carballo, executive director of finance. Jeff Ward, director of community affairs. Dan Miller, director of compliance, as well as Gus Kim vice president and legal counsel. Also presenting today, but not in the room with us will be Garrett Farms, director of responsible gaming for MGM resorts international. Daniel White, vice president, community engagement for MGM Springfield, and Jay Rim, director of financial investigations for MGM resorts. Chair, do you want to know we have other members of the team on the phone today are on the call today to be available to the extent that we get questions that the commission may have regarding the application and to the extent that we pull in that expertise will identify those love ask those folks to identify themselves as we go. But that's the team that we expect will be presenting today. So just, yeah, just a couple of just opening remarks. So obviously, as the commission has laid out, the company is here today in application of a category one sportsway during license application is filed by MGM Springfield. And as attorney Grossman indicated in his opening remarks, this is for a sports book facility at the gaming establishment in Springfield. The application again as attorney Grossman and indicated is filed under section six be six be one of chapter 23 and as well as the regulations governing today's proceeding, including 205 CMR 218. So that's an application that applications and through the initial review process is presented to the Commission today you noted the public comment period. That is, I believe, continuing. And we're certainly happy to respond to anything that comes up during that particular aspect of the Commission's review. We're really in connection with this hearing, and of course subject to the Commission's deliberative process we're asking the Commission to make a durable finding of suitability and grant MGM Springfield the category one sports way during license for And just before I turn it over to Chris to start our presentation. I just had one housekeeping matter that I know the Commission is sensitive to our affirmative presentation to you today does not involve any confidential information. We do certainly understand if a question comes up that that may elicit discussion around that we'll try to identify that for you and and counselor Grossman's consideration and how we best address that type of question in order to ensure the integrity that information as as commissioner as a counselor Grouse been also outlined just give a quick overview of today's agenda, which really we're going to follow the evaluation criteria as set out by the Commission in our presentation, and that's going to be going through the keys of the company to run a retail sports book, the economic impact and other benefits of that sports book. We're going to touch on very important subject responsible gaming, as well as diversity equity inclusion technology, and then we'll also discuss the company's suitability. So with that, I'm going to turn it over to Chris Kelly to begin our presentation. Well, thank you, Jed. And good morning, everyone a very happy belated Thanksgiving to each of you as well. I'll make a quick comment just on the camera that we're using. Since it came up a little bit earlier so we just installed this, how it works exactly I couldn't tell you but what should happen as different folks in the room speak. We're going to engage that person's image on the screen and so hopefully that's the way it works otherwise you're going to be staring at at a picture of me for a prolonged period of time which of course no one, no one would want. I'll also mention that Jed this morning is wearing a bow tie, which is hopefully something you captured in the earlier shot several degrees cooler than the ties that Gus and I are wearing, but nonetheless worthy of mention. Chris is without a doubt a milestone moment among many recently, but it's worthy to point out that this has been a journey, and would like to thank the entire Commission for your partnership, and for your leadership along the way for your effort, and for your diligence we are extremely appreciative. And with that, we'll get started. Before we talk about the brand and GM resorts. We have been an operator of sports books for literally decades, going back to the first wager ever taken an engine brand back in 1979, an extraordinary amount of successful history there. Changing the Supreme Court ruling in 2018 bet MGM was formed we are a 50% owner in a joint venture bet MGM was the result of that, and it is a service provider for all of our retail operations in both Las Vegas and regionally. It's also worth mentioning that we have demonstrated a track record of success as operators and with our service provider in market leading ways in each of the jurisdictions in which we operate today. But if we take a step back from that conversation and move to the next slide and look at the scope and the scale of bet MGM operations today. As you can see to this slide the number of states in which bet MGM is currently live. We can see those states that are in progress are anticipated, and the level of growth that we have seen over a relatively short period of time. Again, through the market leading platform that bet MGM provides, and of course, as operators within the retail markets that MGM resorts brick and mortar exists as well. Let's do a visual look at those. This is something that's pretty extraordinary to see, and I'll use the word experience. You're going to hear that theme echoed through many of the speakers today. MGM is an amenity, but how you weave that amenity into the larger integrated resort experience is something that is very unique to every market in which we operate. What you see here is the interpretation of that in several of the businesses that we have and properties across the country. What I think is so noteworthy about this is the extraordinary level of detail, the differences that exist within them, the way that they integrate seamlessly into those resorts. And ultimately, the way they create very positive levels of engagement and experience for our guests. But of course the big question is, how would we interpret something like this at MGM Springfield. And if we take a look at our property today, we made a decision at risk about a year and a half ago, hoping and believing that we would see legislation come through allowing for sports betting in the Commonwealth. At risk, we spend several million dollars that aligned with our third anniversary in August of 2021 to create one of the most compelling sports viewing experiences in the fleet, and something that we believe creates an unparalleled experience for our guests in this region. This is one view of one of my favorite parts of the of the property, which is a 45 foot wide if you can believe it, viewing wall at viewing wall is immersive when you are standing in front of it, but it is also configurable, literally thousands of ways. I was down there the other night watching Tom Brady and yet another last minute comeback, wishing he was wearing a Patriots jersey as he was doing it. But the experience that you can have in this lounge is truly extraordinary. I would mention as well you have sight lines as you look to the back of the room, and what would ultimately become the betting windows for this retail establishment. If you go to the right and perhaps we can move one slide ahead, you'll see a little bit of that experiential element that I am speaking to. Ultimately, sports betting is a people attractant, and when we have guests engaged with this amenity, they often engage with other elements of the resort at the same time. And so we want to make sure we facilitate that in a positive way. You can see that we have a bar built into the sports lounge experience. I can tell you right off of this viewing point. We have an Italian restaurant that is just across the corridor from this bar. We are immediately adjacent to our cage cashiers. We also have table games immediately alongside this portion of the property and slots as well. It's also, as you can see looking straight ahead, easily accessible from one of our many entrances to the property directly off of Main Street. We take one more look ahead. There's another element of this that I am and the team is particularly excited about what kind of diversity of experiences can we create with our guests through this amenity. What we've done in the back of our tap sports bar, which is already a wonderful place to come and watch and view the game from every angle, what we've done is create a VIP viewing experience. Now this is not an area of the property in which betting would be taken. This is an area of the property for viewing the game with a smaller crowd. Perhaps it's a small party. Perhaps it's a VIP viewing experience. Perhaps it's the induction weekend at our basketball hall of fame. This is an opportunity to bring small groups of people together and create a heightened viewing experience for them in this space. I can tell you this is one our guests have already engaged with. We completed both of these rooms in August of 2021 and so we've received nothing but positive feedback regarding the experience that our guests have experienced in these areas. And this is another view. You can see how it is adjacent to the bowling center in the back of tap. I have been working on my bowling game since I joined the property. I can tell you, I still have not broken triple digits, but I'm committed. And this is one more way in which we can weave multiple experiences into a guest visit to the property. Alright, let's talk about impacts for a moment. Employment is extremely important for a couple of different reasons and I'll raise them both. First, we are one of the largest employers in the city of Springfield, we are one of the largest taxpayers in the city of Springfield. And if we look back in the not too distant past, it was just a few years ago that this property was closed for a period of four months. This experience since then is often referenced at the property as a comeback story, thinking again about how this amenity interacts with the property. Ultimately, we have direct employment attached to sports betting. But what we should see is an accretive improvement to the experience across the property. We've been able to grow our employment numbers quarter over quarter since reopening that continues. As we look at the sports book specifically, that has approximately 15 jobs attached to it. But keep in mind again, as guests visit the property, they have the option of making choices to engage with other elements of the integrated resort, whether that's hotel, whether that's entertainment, whether that's our movie theaters, whether that's our restaurants, etc. And so ultimately, this is a macro story that will play out with the introduction of betting at the property. Thinking about the challenging aspects of operating the property in today's environment, the biggest operational challenge we have is hiring. And that has been a story that has played out nationally that has impacted our entire industry, among many others, we have taken steps as an operator to enhance our position as an employer of choice. These are some of the ways in which we have demonstrated that. I would mention we still have close to 300 open recs on the books today. So we are actively filling open positions. We have done a few things that I think are noteworthy to improve the team member experience when they join our property in the last year, we created three meals for our employees that come to the property every day we have a three team member dining room. We have an extraordinarily competitive health and benefits package. Our compensation is extremely competitive within markets and to call out dealers specifically, but we could apply this to several positions around the property. We will actually pay team members to learn this skill set and build a career in ways that can be life changing. We have been running back to back classes for over a year now. And we have brought a great number of graduates onto the floor and into this industry that otherwise had no experience in this particular line of business. Again, sports betting creates another opportunity to do that. So we provided in our application revenue and tax projections specific to NGM Springfield. Those data points are confidential, but for conversational purposes only, we did include a snapshot of one of the markets in which we operate. And so this is a look at the Mississippi State Market. We operate the Gold Strike Facility in Tunica, Mississippi. And we've provided a look at both the 2021 results for aggregate revenue, as well as the year to date through 2022 results as well. So capital. I mentioned a little bit earlier that we moved at risk as a property to invest significantly in this facility, even in the absence of past legislation and having the ability to work through this process now. We spent about $4 million in total in capital on both our sports lounge and our VIP viewing experience in the back of tap. And fortunately, we are in a position now to be able to move very quickly in the event that sports betting is ultimately green lighted. And with that, I would like to hand it over to one of the most popular members of our leadership team. I always like walking next to her because it makes me feel better about myself. Our Director of Community Affairs, Beth Ward. Wow. Thank you, Chris. Hello, everyone. Good morning, Madam Chair. Good morning, commissioners. So great to see everyone this morning. My eyesight isn't as good as those in the room. So I'm going to rely as we go through my slides. A look on my computer, just want to say thank you for this opportunity so proud to be able to share with you some of the events and volunteerism that we are excited about particularly over the last year. And engaging our MGM team members. It's part of a program called Focus What Matters here at MGM Springfield and corporate wide focusing on food insecurity education workforce development and sustainability. So what does that mean that means giving back to the community. Again, I'm using the word proud you're going to hear that a lot because that is what we are here at MGM Springfield as we look at this first slide. Community engagement. These are some snapshots of just some of the events MGM Springfield employees are taking part in throughout our community, not only on property but really within our nonprofits throughout Springfield and Western Mass. In the upper left hand corner of your screen Puerto Rican Day Parade we have dozens of team members who were excited to take part in that Springfield's first pride parade again dozens of team members. We're excited to march alongside members of the community in this first ever event in the city of Springfield. Also want to point out that MGM Springfield is proud to be the presenting sponsor of the spirit of Springfield you may have heard of this organization called the SOS. It is a nonprofit in Springfield about 25 years ago it got its start they put on about seven major events in the community that draw people from all over New England we are again proud to be there presenting sponsor you see there in the middle. The fireworks display. They also have the country's largest holiday light display. One of were very proud of in the park located just down the street here from MGM Springfield. They also put on the world's largest pancake breakfast, want to give kudos to Chris Kelly who was named the honorary chair of that I know that's a distinction that you were very proud of you for that as well bottom right you see something that we do every year and we have since prior to opening, cleaning up the Connecticut River is part of a group called source to see all about giving back to our environment Connecticut River I can see it out the window here so we're very proud to be part of that bottom left you can see two of our team members volunteering at a local soup kitchen that's a community partner we've had again since prior to opening. We open pantry emergency food services. We regularly volunteer at their lows and fishes soup kitchen. And we are, we're excited to continue that looking a lot of events coming up in 2023 in the top middle at MGM Springfield fourth anniversary, we had an all employee party took the opportunity also to distribute thousands of dollars to support several local profit organizations and community partners through our property and corporate grant foundation so it was just a great opportunity for our team members to be able to see you know what what our dollars go towards and just being part of the community in which we live and work. If we want to go to the second slide. Let's take a look in the middle right our employees have continued a long standing partnership with habitat for humanity. And in blue there surrounded by a lot of different pictures we love helping out recently we have to build a home for a springfield mother and her two sons we got to know them very well. And we're happy that they are all moved in we have some plans to continue that in 2023 in the center we had dozens of team members take part in. And we have to raise a hope walk toward the cure of breast cancer this is something that's been going on for nearly 30 years it is one of the largest fundraisers for breast cancer awareness, and support in every dollar goes to western mass, much of it staying right here in springfield dozens of team members participating that I also want to note, we're also a sponsor for that as well. Right, we initiated something new this year, you see a group of chefs are top chefs up there on the top middle we adopted a school here in the city of springfield part of a new initiative, we call the adoptive school program. This school that we adopted we're working with the city of springfield to identify the schools moving forward we're going to do this every year identifying together a school that could use some support. This is a south and middle school, literally a block or two, just down the street on Main Street, we started off this relationship by having a top chef sort of event, which was very well received by the students there are executive chef and team, and joined in and including our CSR Council to help make a really great experience about learning to cook healthy meals for the kids there it was just so much fun and a wonderful way to start off that relationship, which is also going to include volunteering a co drive is in the mix and also looking at refreshing their teachers found the school is over 100 years old so they sure could use some help we're very excited to move forward with that. On the top left you'll see had a veterans day working with the city of springfield veteran services department does is have employees took part in a flagging event we made sure that the springfield cemetery every single veteran in that cemetery. Deserved to have their flag atop their grade we made sure that that happened again working with the city of springfield. And GM springfield enter into a new partnership with Rachel's table that's a nonprofit finding food and security, a group that has been around has a lot of notoriety they've been working hard for 30 years to fight food and security in western mass. We are now moving forward by donating our unused food with our food and beverage department that started a few weeks ago, and will continue weekly again as we move forward through 2023 as well. Our marathon, want to make sure to point that out this is something it's not a foot race, but it is a three day event 24 seven a local radio station to DJs within that radio station. They started this event almost 30 years ago, it is iconic in this area they've always had it at the basketball Hall of Fame, which is right across the street from property here at MGM springfield for 30 years. This past summer, they, the Hall of Fame said that they could no longer hold that Mayflower marathon three day collection event for non perishables to go to the open pantry. That is again one of our community partners that I mentioned earlier, thousands of pounds of food are donated each year thousands and thousands of people come by to take part in this. We jumped in I can't tell you how many team members, when this news broke that they no longer had a phone home jumped in and said, Hey, how can we help so we made it happen we got together with the open pantry and the folks from the radio station and for three days. I tell you, it was just heartwarming to see our team members out there at 435 o'clock in the morning helping to receive donations again a three day event that went very well. I have to say that it smashed all records in the 30 year history of the event so we look forward to continuing that I'm going to wrap up something with some are my time here with some fun from the holiday season on black Friday. I think probably to the biggest crowd we've ever had we opened our ice skating rink or outdoor ice skating rink and we had an official lighting of our tree out on Armory Square part of the Plaza here at MGM springfield. The families here team members. It was such a wonderful experience a true winter wonderland that we are able to create each and every year for the community and it is one of the things that we look forward to most on property to have families come down in the evening you walk by and they're skating. It really is kind of a hallmark moment if I can say that but we're so excited to be able to provide that once again for the community Santa was also there so it was a lot of fun for all of us. So I want to thank you for your time as I kind of went through all of those pictures and trying to describe what it's been like and what we're engaged with in the community here at MGM springfield. I thank you for that and I would like to turn it out over now to Garrett farms director of responsible gaming at MGM resorts international. Thank you so much. I'd like to begin also with the thank you to the Massachusetts Gaming Commission colleagues at MGM resorts and bet MGM for allowing me to provide an overview of our responsible gaming efforts and how we will further our commitment with legalization of sports wagering in Massachusetts. So MGM resorts and bet MGM have a long and proud history of demonstrating our dedication to responsible gaming. In large part due to the Massachusetts Gaming Commission's adoption of game sense MGM resorts and later bet MGM decided to license the platform and integrate it into our guest service model enterprise wide with continued expansion and growth into new markets comes in need to ensure our guests continue to have a safe and fun gambling experience no matter the form of entertainment they choose at our properties or online. We plan to do this through MGM resorts and bet MGM holistic and comprehensive approach to responsible gaming. This really starts with an emphasis on consumer education, a focus on sustainability and player health, as well as doing all we can to mitigate gambling related harm. We've utilized research as an ally to enhance the ways we engage with our guests to reinforce positive play and address problematic behaviors. This research also helps guide our employee training programs internal controls and responsible gaming best practices. As we know, we can't do this alone. The collaboration and partnerships with regulators, external organizations, advocacy groups and researchers were able to keep the responsible gaming needle moving forward. We believe the MGM resorts and bet MGM unified approach to responsible gaming puts the best interest of our guests, customers, their families and the communities where we operate at the forefront. The heart of our responsible gaming efforts is our employees. We invest a significant amount of time, energy and resources to ensure our team members have the most advanced and effective RG training available. Using game sense all employees company wide regardless of level or title, receive a solid foundation and understanding responsible gaming, problem gambling, and most critically, how to identify and address concerning communication and behaviors. Customer facing employees and department leaders receive extended responsible gaming trainings aimed at empowering our employees and building their confidence with interactions. Over the past 12 months MGM resorts has completed over 55,000 responsible gaming trainings. We facilitated nearly 50 game sense advanced and advisor level trainings, which does not include specialized trainings for internal departments such as marketing and casino hosts. This year we have certified over 200 game sense advisors company wide, including 11 team leaders from MGM Springfield to provide supplemental support to our guests. While virtual platforms have been a great ally and training efforts during pandemic restrictions, we truly value the face to face engagement we can have with our employees within trainings. As such with the expansion of sports way during the Massachusetts, I will be flying out to MGM Springfield to conduct responsible gaming trainings with our new sportsbook employees. These trainings will also include participation and insight from my good friend Rich Taylor at bad MGM. As a two of us were collaboratively to build employee awareness confidence within their interactions and reinforce our two organizations unified commitment to responsible gaming through training. Now important part of responsible gaming training is to ensure that our team members are informed and confident within the interactions with guests. While MGM Springfield works closely with the Mass Council and game sense advisors on site, we all want our team members to be aware of opportunities they too can engage with our guests on responsible gaming and be cognizant of instances when they can call in a GSA to provide further support. These include when observing red flag behaviors such as a guest making frequent trips back and forth to the ATM. Naturally when we hear any gambling myths or misconceptions we know to be inaccurate. Any occurrence when a guest that voices concern about their play. We also train our team members to look for proactive opportunities, such as when guests enroll in MGM rewards or engaging with new or curious guests who may be unsure how the rules of games or how sports way during works. An important part and valuable part of responsible gaming is awareness. As such, we want to increase the visibility of messaging and resources available at our properties in order to have guests ask that question. What is game sense. These images illustrate our roll out of game sense from a corporate level. We understand that not everyone accesses information the same way. So we have prioritized adding multiple game sense touch points throughout our properties. These include property marquees, low rise screens throughout properties, 35,000 screens within our hotel rooms, digital ads and you are messages that display on over 22,000 slot machines, 7,000 of which contain QR codes to the MGM resorts game sense web page. Ticket redemption booths which contain game sense and problem gambling messages and collateral pieces of which are also accessible and on display throughout gaming establishments, as well as our game sense touchscreen and advisors at that are available at our game sense info centers. It's the goal that these touch points will spark interest and questions regarding responsible gaming and help promote informed decision making. With the addition of sports wagering, we will be adding sports centric RG messaging and information through multiple platforms accessible to guests and customers in Massachusetts. This information is intended to be easily consumed and designed to empower customers to make the right choices regarding their gambling. These include online resources such as our game sense websites of which MGM saw over 100,000 visits in less than 12 months. Our QR codes available on slot ads help drive an uptick in visits during key marketing campaigns. Game sense welcome messages to new bet MGM customers and most recently our game sense specific emails that were sent to over 2 million MGM rewards members reminding them to use their game sense whether they are at our properties or on the bet MGM app. Also, we utilize social media platforms for responsible wagering messages through campaigns that occur around key sporting events, such as the onset of the NFL season Super Bowl and men's NCAA basketball tournament to increase awareness. Visitors to MGM Springfield will be greeted with sports themed responsible gaming messages on low right screens. And we are also proud to partner with the American Gaming Association and their effort to promote responsible sports wagering. To have a game plan that responsibly campaign presses the importance to wager responsibly and for operators and stakeholders alike to educate consumers on illegal and unregulated markets that seemingly rob state governments and legal operators of billions of dollars annually. At our sports book with other game sense collateral, we will also have our sports betting 101 brochure with insight on how sports wagering works and providing responsible gaming tips to our guests and customers. Our sports and bet MGM abide by the American Gaming Association's code of sports wagering marketing and regulatory requirements to ensure marketing is tasteful. It doesn't appeal to underage or vulnerable populations and supports responsible gaming messaging and problem and handling health line information. All employees are trained to understand and promote both the state self exclusion and company self limit programs to customers. All employees are also trained to identify and request proof of identification from customers who appear to be under the age of 30. This pertains to tools to mitigate harm MGM resorts and bet MGM take a unified approach to addressing voluntary self exclusion programs. Daily reporting between our two systems help ensure that appropriate restrictions are placed onto accounts. We have also added safeguards in the way of daily automated reports that scrub all newly created MGM rewards accounts against those of self excluded individuals. We believe that this collaboration stays true to the spirit of self exclusion and help support those who willfully enroll in these programs. MGM resorts and bet MGM believe in working with stakeholders and experts to both improve its operations and contribute to the field of responsible gaming and problem gambling at large. This is done through collaboration with game sense licensees including the Massachusetts Gaming Commission with the game sense community of practice. Our two companies provide support to the NCPG and are active with state councils on problem gambling. This year we contributed nearly half a million dollars to the ICIG ICRG to support responsible gaming research with that MGM's recent contribution help and support a study focusing on the impact of advertising on problem gambling. MGM resorts has a long standing issue of supporting the ICRG as we've contributed approximately 5.5 million to this organization since 1997. Additionally, bet MGM agreed to work with epic risk management to develop training modules for customer facing employees with an emphasis on sensitive conversations. We also collaborate with providers such as the Dr. Robert Hunter International Problem Gambling Center to obtain data on problem gambling rates, comorbidity, and third party harm and share this information within our trains. As previously mentioned, we partner with the AGA have a game plan campaign and also sit on the AGA's responsibility committee which unites operators on responsibility efforts, research and modernization. Lastly, both our organizations recently joined in the first industry led responsible gaming standards. This 12 point pledge serves as a commitment to ensure safeguards education and consistent standards for online wagering. We truly believe that we are better together and through ongoing collaboration between our two organizations, our peers, advocates, and the Massachusetts Gaming Commission, we will be able to offer our guests and customers a safe informed and responsible sports wagering experience. Thank you for your time and the priority we all share in responsible gaming. I would now like to introduce Danielle White, Vice President of Regional Community Engagement to speak on diversity, equity, and inclusion. Thank you, Garrett. Thank you all for having us in the morning. Our team inclusion commitments are really embedded in our strategic goals. First, we invest in people, our culture suppliers and customers really focus on human capital to create an inclusive culture through talent management reducing inequities, which are critical to attracting developing and retaining talent. Our goals to create a workplace and a consumer experience that promotes tolerance mutual respect, equity and belonging. DE&I extends to our consumer engagement and the market leadership we have. We value our responsibility to create decent work ethic and economic growth in the communities where we operate. DE&I is implanted in our business strategy by growing our supplier diversity program and cultivating key relationships with diversity centers of excellence to enhance our brand reputation as well as keep us best in class in the communities. That's right. We really believe this starts at the top with the leadership of our board of directors and with Rose McKinney James who serves as our chair of corporate responsibility and sustainability committee. The trickles to our CEO and president Bill Hornbuckle, followed by our chief people, inclusion and sustainability officer Jati Chopra, who has six direct reports who are specifically dedicated to the DE&I team and responsible for our goal implementation. A critical piece in our success is our external partnerships with both local and national organizations. Locally, we're partnered with Job Corps, Putnam Vocational High School, Dress for Success, Veterans Inc, just to name a few. Nationally, we really rely on leveraging our relationships that we've had for a very long time to include and highlight NAACP, Hispanic Association of Corporate Social Responsibility, National Association of Women Business Owners, Human Rights Campaign, and many more. In our business strategy, we understand the necessity of setting goals. As a category one licensee, MGM Springfield will report retail sports operational spend, including diversity spend as part of our operation. For procurement, we're dedicated to identifying and building ongoing relationships with diverse suppliers through previously mentioned organizations. Attending and sponsoring events designated to attract diverse suppliers, hosting town halls and having meetings to meet suppliers, as well as creating a competitive bidding process for requisitions exceeding $100,000, requiring at least three quotes from different suppliers. All of this is really driven by accountability and best efforts. We have regular workforce reporting, formally set annual company-wide goals for both our employees and leadership, required DE&I training, and a diverse talent and recruitment strategy. Next slide. Cultivating our workforce is incredibly important to us. Our strategy is designed to embed diversity in the framework of our overarching recruiting strategy programmatically through processes and how we source and recruit talent. By intentionally including diversity in the design of these components of our strategy, it ensures that we are attracting the best, selecting and retaining top talent through the processes that are inclusionary and equitable for all of our candidates. We understand the importance of having a diverse workforce, especially when it comes to underrepresented groups. Therefore, diversity is something we like to take into account when we are looking at our entire recruiting process. Next slide. As a few examples of this, we work to create real programmatic solutions to help us achieve our diversity talent recruitment and retention goals. Some of those solutions in the area of disability are investing in neurodiversity hiring programs to increase our disability hires. We create accommodations and focus internship programs. We also focus on retention by creating a path for internal mobility for our workforce. We have a formal mentorship program, an accelerated leadership program to formally train directors for future promotional opportunities within the organization, a formal recognition process, a referral program, and partners with our employee network groups as well. Veteran hiring is also a critical piece of our business. We have a programmatic process that has role identification and alignment programs focused on military spouses and partnerships with the National Guard outreach through military specific career fairs connecting us directly with future candidates. Our programmatic hiring strategy is built on transparent disclosure, our vast array of community partnerships, and continuous review of retention data. And closing diversity and inclusion really is one of the strategies that's critical to highlight who we are, shapes our culture, and the experience we're able to provide for our customers as part of our strategic business goals. I will go ahead and turn it over to Dan Miller, our director of compliance. Thank you, Danielle. Lady, Lady chair commissioners always a pleasure to speak with you. I'll take the first slide on specifically technology and then I'll be handing over for more procedural KYC. MGM Springfield will use the bed MGM police system as a primary retail system for all our sports events and wages. The sports wagering counter will contain tills that permit the cashier to issue redeem and the week tickets with proper authorization. All sports wagering employees will go through a sports wagering one on one type training, as well as job specific training provided by our colleagues at bed MGM. They will also go through the typical types of related AMO procedures, cash handling, alcohol awareness, and of course responsible gaming. We will also use bedding kiosks similarly provided through bed MGM. From a consumer integrity perspective, they can feel comfortable that making a sports major at the counter or the kiosk will yield the same results in a safe, legal and entertaining environment. Lastly, with the beds replaced points of sale kiosks, these pieces of technology come in numbers of integrated ID verification suspicious or forging activity monitoring and other KYC pieces. Jane, I'd like to turn it over to you for the next slide. Thank you then. Good morning everyone morning modern commissioner. Good morning, my name is Jim. I'm the chair and the commissioner. So the, your customer program, your academic most KYC is an integral part of the company's AML and time on a laundering bank secrecy at program. Since 2012 corporate compliance of engine resource international has implemented and continuously improve KYC program for our ongoing effort to comply with bank secrecy act. We are now laundering our regular requirement and make customers known to the company based on their level of established play. And these are the program that we run on a daily basis to run our KYC program. The first one is a know your customer know your customer process includes collection and validation of relevant information from customers, which includes legitimate and issued identification physical residential address and US social security number if applicable. The distinction between source of wealth and source of funds source of wealth describes how a customer or their family members has a pain their network, whereas social funds refers to an origin and means of particular customers funds that are used at a specific transaction. We use this is these distinctions when we evaluate customers financial financial transactions at the company and the property to determine the know your customer program. Next media, our office subscribe to various news portal with key AML words or phrases to identify names of persons involved in alleged financial crimes or illicit financial activities. Then we use those information to scrub against our engine resource customer database to locate the person review the transaction and report if necessary. Our office also subscribe to various law enforcement agencies, regulatory agencies and specific AML and I'm wondering data provider services for negative news detailing the alleged financial crimes. For transaction review, a data set is generated from monthly aggregation of race and sport and currency transaction that meet a minimum threshold based on the tier of the casino and aforementioned programs are applied to do KYC review. Once down to screening engine resource currently utilizes ID identification screening and ongoing monitoring screening for identification screening we utilize as a third party service provider to authenticate customers identification and screen against us all back SDN list and casino regulators excluded for ongoing monitoring engine resource subscribe to a different third party data provider to identify investigate potential matches to the US old back SDN list and other countries sanction list, adverse media and politically exposed person. These are highlights of our KYC program that corporate compliance employees to address AML challenges and risk. Our programs are continuously evolving and adapting based on the changes of the risk and regulators focus. With that, I will conclude my presentation to KYC. I'll hand it over to Jed for suitability. Thank you. Thanks Jim. Good morning again, chair members of the commission. I'm going to touch on the suitability prong here in consideration as part of your evaluation. I do note that director hall will be providing some additional information on this in connection with her report and review of blue tarps application for category one license. As attorney Grossman had indicated earlier, you know, the, this gaming, excuse me, the sports wagering act section six B provides for a license to be issued as a matter of right, however, we recognize that that is subject to the company meeting the gaming commissions rules and regulations. The top of that those requirements certainly is the commission suitability standards. The legislature and its wisdom did provide and recognize that category one applicants are in a unique position. It allows you to draw from the company's records and information submitted and maintained as part of its category one chapter 23 K gaming license. And as certainly as attorney Grossman explained in his opening remarks, the company has both met those requirements and continues to maintain it. And as you're aware, all of the initial qualifiers including MGM resorts international were found suitable by the commission back in December of 2013. And the additional qualifiers that have been added since also have been found suitable. And this is all summarized in the report that Heather has provided excuse me director hall has provided to the commission. Importantly, blue tarp and all its qualifiers continue to demonstrate by clear and convincing evidence that they have the requisite integrity honesty good character and reputation pursuant to the standards that are applicable to this application as well as under 23 K section 12. Let me turn to the history of compliance. This is not something that's, you know, certainly distant from the commission blue tarp has almost a decade record of compliance, getting back to its initial application through pre opening, opening and certainly over the last four years during operations. But in connection with this history, we certainly recognize in a regulated industry. It's not uncommon to have investigations occasional enforcement actions or violations and certainly blue tarp and MGM is no different than other regulated enemies when it comes to those particular matters. Importantly, however, the company has a policy of transparency and cooperation with regulators has a record of self reporting, as well as voluntary and proactive, corrective actions that have been taken across all of its jurisdictions. The IED and the commission is familiar with the company's track record in this regard. Turning to the prong regarding business related litigation, a lot, certainly, similarly to history of compliance, there are going to be instances of litigation, it's likely unavoidable in this industry. The MGM and blue tarp however have been entirely transparent regarding any litigation they've self reported as required under the continuing duty regulations, and they've kept the commission apprised as it's moved through those particular, those particular matters. Quickly to financial suitability, we understand that the commission's consultants will also opine on this particular topic. We certainly benefit here from MGM resorts being a publicly traded company and certainly all their financial information is readily available through its SEC filings. This is aware MGM resorts reports its financials on a consolidated basis. And I'm going to highlight just quickly what those numbers look like for the third quarter of 2022. It's recently reported. The company had consolidated net revenues of $3.4 billion. And this is comprised primarily of three areas of income, the Las Vegas properties, where there were net revenues of $2.3 billion, the regional properties of which MGM Springfield is part of, with net revenues of $974 million. And then also the revenues from Macau SAR China made up the balance of that. These revenues are have been lower due to ongoing COVID-19 and other travel restrictions that have been well documented and reported certainly within SEC filings but also in connection with general media. Importantly, and the company has cash and cash equivalents as of September 30th, 2022 of $5.29 billion. Based on the information, the company's track record, I think certainly they meet and continue to meet the commission standards for suitability in the Commonwealth. And with that, I'm going to turn it back to Chris for some closing remarks. Thank you. Well, thank you again to the commission. Thank you so much to all of our MGM resorts leaders that presented us presented today and helped us with this presentation. Not an easy thing to do, but very much appreciated for each of you. You know, these discussions I think are aptly timed around the holidays. There is a certain sense of community and family that I think is intrinsic within the season and within this specific effort. When we think about the history going back to grassroots efforts within our team member community, city officials, our local elected delegation, those we worked with at the state level, certainly the executive branch. When we think about the community that had to come together to bring us to this point, it's inspiring. And when we think about the present tense, the extraordinary work of the Massachusetts Gaming Commission and the commissioners that join us now a very heartfelt thank you from our entire team at MGM Springfield, and we look forward to opening it up to questions. Thank you. Thank you for presentation. Thank you for all the voices that were shared commissioners yesterday we decided to hold our questions pending the presentations that will follow from RSM, IEB and GLI. Do we agree that that was a good path. Okay, so Attorney Nozzle and President Kelly, are you comfortable being with us for a good portion of the day. We look forward to absolutely. Okay, then, as I indicated, I think we should take a break digest this presentation, which I know that we were all appreciating. It's 1120 15 minutes. Does that make sense or okay. So 1135 will return, and then we'll turn to those individual presentations that I just mentioned. Thank you everyone. Thanks, Dave. Also, okay, I feel as though we're all back. Just a reminder we are reconvening after short break Massachusetts Gaming Commission public meeting number 407 and because we're holding this virtually, I will do a roll call. Good morning again Commissioner Brown. Good morning. Good morning, Commissioner Hill here. Good morning, Commissioner Skinner. Good morning again. I'm here. And good morning, Christian Maynard. Good morning. I'm here. Okay, we're all set to continue then and again, thank you for the presentation to all President Kelly. And we are now moving to the next item on our agenda, which they're labeled as if there's a continuation because we are doing category ones together so then they are numbered as 12 people are wondering about that. So we're turning to item number 12 on the agenda presentations and analysis relevant to review and evaluation of the application for category one, and we'll first turn to the technical components. And that will be presented by gaming laboratories international. I'm going to do an introduction that was offered yesterday. Gli was the first to write and set gaming technical standards which are now considered to be the industry benchmark worldwide. Gli has continuously responded to the industry by innovating new standards and testing allowing regulators to build confidence that they are providing a safe responsible method of revenue generation, whether stakeholders and preservation of integrity. I believe I want to make sure it's Kevin here today, Joe. Kevin's actually traveling today. That's what I thought. Okay, so we will turn to Joe benefit, who is the director of client solutions at Gli. And Joe has over 16 years of experience in the gaming industry but extensive experience in developing fantasy sports online gaming platforms. Also has over 16 years of product management and operations management experience recognized Joe has been recognized for demonstrating a natural attitude for overseeing all stages of the product development lifecycle. And I think Joe mentioned some Massachusetts ties. That's correct actually attended UMass just north of MGM Springfield sometime ago at one point as an engineering student. So thanks for having Madam chair and members of commission is Joseph on a talk to clients decisions to Gli. I'll give an overview of the submittal certification and field verification process regarding the implementation of retail or referred to as over the counter and kiosk for sports wagering. This lab can take submittals and mass gaming commission will have to approve 205 CMR 138 238 247 and 248 which are on the schedule for next week. After approval the operators will premiere prepared to submit the code basis for the entire sports wagering system. They end the hardware that they intend to deploy submittal preparation includes an architect. This is a technical review which is complete comprehensive and technically accurate description and explanation of all the sports wagering systems. This includes the description of all hardware devices in virtual servers. Description of all server and client modules including the software versions. The layout of all network communications between various software and hardware modules and expert in an explanation of all third party integrated systems. This is the technical documentation review critical files regarding compliance will be identified and documented. The lab will run supervised complete compilation of those source files the signature of those files and compilation steps and the signatures of the compiled code. Once complete the source code will be submitted for testing in a locked down testing environment. The lab will verify events markets point spreads bet acceptance and car corresponding time stamps and logging of those issues verification of the and enforcement of betting in all education will be tested at this time. Continuing to verify pre event in live data feeds post event bet settling and the corresponding time stamps and all logging and reporting of those time stamps and and attributes. The lab will also review change management process and procedures. The certification product process. The lab will verify the changes made for Massachusetts specific deployments. This will include source code differential and change testing for the last reviewed version lab will evaluate all the product details to the Massachusetts specific requirements and then transfer in kiosk machine hardware devices in firmware. At that point they will issue a certification to which the mz mgc commission will accept or reject. Post issue of certification a field verification will be conducted in conjunction with mgc that procedure will be finalized in the upcoming weeks. During that time the following should commence verify that the machines on the floor match the certification report by model number. They will be trained for devices bill validators and printers verify the signatures of installed firmware on the kiosk and bill validators. And this is done at the production server. And also to verify the critical file signatures. We will also verify a run of test data through a sampling of kiosk and retail point of sale, likely a two to three day process in place to place wagers, let them result settle overnight and reconcile all the data and reports. Lastly, review the internal controls and procedures to operate the sportsbook, check the technology for configurations such as proper setup of roles in user rights assignment, and potentially interview key personnel to ensure they know and will fall procedures from the internal controls approved by the mgc. That's, that's the technical submittal process and certification and field verification by the end of the test lab. Thank you Joe. I think that again, commissioners shall we hold questions and continue on. Okay. And then we're going to now turn to Heather Hall, who is Chief Enforcement Council of our IEB, the Investigations and Enforcement Bureau. Good morning, Councilor Hall, and you will be helping us on the suitability of the applicant. Good morning chair. Thank you and good morning commissioners. So I will be brief, as I know you have a lot to cover today. And as you've heard, in evaluating MGM Springfield suitability for a category one sports wagering license under chapter 23 yet, the commission may leverage the information obtained in the suitability investigations performed pursuant to the casino gaming law under chapter 23 K. The criteria for suitability in the gaming law substantially aligns with the criteria for suitability in the sports wagering law. And as stated in the IEB's executive summary in 2013, the commission found MGM Springfield and each of its then qualifiers both individual and entity suitable in connection with its initial application for a casino gaming license. And those suitability findings were conducted or found after full investigations by the IEB. And as the commission knows, as new qualifiers joined the company, they were also required to submit to the full background process as well. And the commission ultimately issued positive determinations of suitability for each of those qualifiers referenced in the executive summary who joined the company subsequent to the issuance of the initial license. And as stated in the IEB's executive summary, MGM Springfield's license to operate a category one gaming license under chapter 23 K remains active and in good standing. And as we also noted, the applicant has a continuing duty to maintain suitability, as well as a continuing duty to update the commission in the event of various occurrences set forth in the regulations and that's required by the commission. And like I said, this applicant MGM Springfield remains in good standing. And I think that's all I have in the way of prepared remarks, but as I have said before, I'm happy to answer any questions. And Heather, will you be available today for us if we have any questions? Yes, Chair, absolutely. And I also just want to thank Jed for the promotion. It looks like both Todd and I are receiving promotions over the course of the last day when he referred to me as Director Hall just for the record, I am not. Those would be incredibly difficult shoes to fill. So thank you for my title. And thank you, Jed for that. But I just wanted to note that. I think Todd got that promotion twice in two days. So he did. Yes, he is also promoted recently. So thank you. And Heather, I like that you noted that. Okay, that's, then move now to the next item on the agenda. I'm consulting RSM and who is available today. There we have it. Let me introduce you properly. Sure. They are with me. I can't I can, I can see now members of your team coming on. So RSM is RSM US LP is one of the leading providers of audit tax and consulting services in the United States. RSM has been working with the Massachusetts Gaming Commission to provide insights and analyses to help the commission. I'd like to introduce the individuals who'll be here with us today and I think I see them coming on. We've got a partner of RSM Greg Navalov. Good morning. He leads New England financial investigation and dispute services practice. I'm not sure if I see Teresa here tonight. Teresa is going to join if she can. But we've got Chuck Teresa here in her stead. Teresa may be able to join. Okay, excellent. So, and Chuck, I will have you introduce yourself and, but if Teresa comes on Teresa Merlino leads RSM national gaming and hospitality practice. Then we have Jeff Katz who leads our SM strategic financial practice. Director and RSM strategic finance practice. And then we have Chuck Teresa who we have certainly met you before, but I'd love for you to give to introduce yourself. Thank you. Thank you, Madam Chair. I'm Chuck Teresa. I'm a director in our financial investigations and dispute services practice in Boston. Thank you. We'll have a quick roundtable discussion or further introduction of the team here but first one that started out by saying RSM appreciates the opportunity to present to the commission. We understand that the importance of the licensing process and the importance of these meetings. As you've laid out the team here we've got a diverse team of professionals to present on the topics requested by the commission. The team here has been asked to join this meeting to make the presentations related to certain aspects of the application so we'll give a little quick highlight of those. It should be noted that RSM is not presenting on all the aspects of the application. Specifically RSM has been asked to provide insights based on our experience and research in some of the following sections. First of which is section B2, section D, which is specific to the sports wagering experience. Second of which is the version of the sports wagering operations that we've found in the application. We've been asked to focus on the estimated market share within each jurisdiction. Other areas that we're focused on C2 projected revenue that's going to tie into P2D as well. But we've been asked to provide some insights into the aspects of the applicants projected revenue. The next item would be section C3 where we're asked to cover sections A through C, specific to the construction of gaming space by MGC Springsfield. RSM has been asked to focus on the construction timeline here that's going to be an easy one, relatively easy one, and the proposed gaming area. Next item would be the financial stability and integrity, which is section G3 of the application. And for that RSM is being asked to find some of our insights into all aspects of the applicant's financial stability and integrity. And we'll add other insights as applicable to these sections where appropriate as our experts comb through the information that they found in the presentation. Just a quick, I guess, roll call here. I lead our practice in out of Boston for providing financial consulting services in and around providing mentorship services and also providing forensic related integrity due diligence support to clients. I'm going to hand it over to Jeff, Jeff Katz to introduce himself further. Thanks Greg. Good morning Madam Chair and the Commission. Jeff Katz here. I lead our strategic finance practice at RSM based in Boston, focus primarily on forecasting business modeling and FB and a transaction modeling evaluation and obviously helping companies look at, you know, their financial plans, you know, into the future. I'll hand it over to Greg. Yeah, the next person on working closely with Jeff Katz is Connor Laughlin. Connor, you want to introduce yourself. Hi, good morning everyone. Hi, I'm Connor, director and underneath Jeff and the strategic finance and FPNA group. Prior to RSM I spent about 12 years with BDO in their business restructuring services and in term financial management group. And pleasure to be here today. And Chuck had previously introduced himself. So we work closely with our gaming practice leadership and team professionals to come up with insights with respected application. This presentation that we're about to provide is based on documents received as of December 2. The discussion prepared by the team is based on our preliminary research to date and is subject to change if new information becomes available. Any questions opposed to our team may require further research. If we aren't able to respond to those questions during this meeting will circulate a response as soon as practical afterwards. Chuck, do you want to start off and kick us off with the B2 and market share retail and provide some opening remarks there? Yeah, absolutely. So the market share analysis as noted in B2 section D is closely linked to C2 projected revenue analysis as requested by the commission. Sportsbook revenue is the handle or amount wagered multiplied by the hold percentage, which is the wind rate. The hold percentage can vary significantly from period to period based upon the player wagering activity, the betting mix and the results of the games played. The estimated market share is relevant to the revenue calculations as the market share influences the handle. MGM included their estimated market share within the application. In our analysis, we used external research to understand the likely Massachusetts sportsbook market size and use this external research to understand and compare to MGM's market share assumptions, which will further describe now. Jeff O'Connor. Thanks Chuck. Yep. So what we did is we compared the estimated market shares expressed in gross gaming revenue for MGC Springfield to third party data sources that express their TAM for the state of Massachusetts overall, which includes both retail and online sports better. And then from there we looked at the contribution mix historically for between retail and online sports betting of states that already have legalized sports betting. And we basically came up with the percentage contribution historically for those states a range in which retail sports betting would be applicable. And then from there we basically also looked at the state of Massachusetts current casino operations landscape and what the mix in terms of market share was for each casino. And then we also basically on their based on their projections we also added them to their total casino operations to basically calculate a percentage of total for retail versus tables and slots. Based on the information provided and the third party research that we prepared and analyzed. It appears that they are in line in terms of market share within the range. And I'll pass that back to Chuck but for the revenue it also based on gross gaming revenue. It also is within the range. Thanks Jeff. So as part of the application, we are not provided projected non gaming revenue associated with the implementation of the sports book. So here's that there's an active bar that will remain as part of the sports book lounge, and in its presentation MGM indicated that there may be an opportunity for VIP events in the back of the current tab sports bar lounge, which may provide incremental revenue attributable to opening the sports book. While we don't have a specific recommendation or thought, the Commission may find it helpful to understand how the non gaming revenue projections, compared to the current non gaming revenue projections, and the impact that the sports book will have on these projections. Continuing within C to subsection G. MGM provided a summary of the mass advertising strategy to create awareness and encourage the public of Massachusetts to play within the state noted in C to F of the application. MGM referenced a seamless experience between the retail sports waging operation and the partnership with the mobile platform bet MGM. We also called these for other systems and jurisdictions with the combination of loyalty programs between the traditional gaming floor loyalty program and the sports book loyalty program. The Commission may seek to understand the approach and the timing of linking the current MGM Springfield loyalty program with the bet MGM loyalty program, or if these two programs will remain entirely separate. Follow along with the construction theory. As observed in the application and as shared in the MGM presentation, the retail sports book location has already been built close to the main entrance and adjacent to the gaming floor. The sports lounge is referenced in section B to a, and which states that there is space for sports sports betting kiosks. Finally, application section C 3b reference that the sports wagering area is located within the predetermined gaming area, which appears to be close to the current tap sports bar and on the gaming floor. Finally, we compared the proposed square footage to other sports book markets, including New Jersey, Pennsylvania, and Michigan. The book square footage may differ between properties. The proposed square footage by MGM is somewhat similar to a somewhat smaller excuse me than a representative sample that we analyzed. However, this book square footage appears to be in alignment with the proposed revenue estimates. And with that I'm going to send it over to Connor to discuss some of the financial stability and integrity. Before we jump into that one of the observations thus far from in our seminar research that the square footage associated with retail gaming, at least from a handful of revenue reports that have been produced for different casinos around the country, does not seem to be strongly correlated with revenue generated from from from those those spaces, meaning that large areas don't necessarily create larger total revenues compared to smaller gaming spaces that have been built out thus far, according to our research. Yes, thanks Greg. So I'm going to touch on section g3 the financial suitability of MGM Springfield. And as a part of RSM's engagement and assisting the MGC in its financial suitability review, RSM analyze the current capital structure of MGM Springfield's parent company MGM Resorts International. According to publicly available information, as of September 30 this year MGM resorts has approximately 33.9 billion in total debt and commitments, comprised primarily of 25.4 billion in total lease commitments. The balance of the parent company's total debt includes 7.3 billion of senior and senior bonds notes and 1.3 billion outstanding on the company's revolving credit facilities. During the nine month period ended September 30 MGM resorts has reduced its senior bonds and notes exposure by approximately approximately 5 billion. This is primarily driven by the recognition of debt totaling 4 billion associated with MGM resorts sale of MGM growth properties to BC properties in April of this year. The balance of the identified production and senior bonds and notes stems from MGM resorts pay down of their 7.75% notes at maturity totaling approximately 1 billion. During the same timeframe MGM has increased its total long term lease commitments from 12 billion to 25.4 billion. The total average annual maturities for MGM is these lease liabilities approximately 1.8 billion annually from 2023 to 2026. The weighted average rating lease term is approximately 27 years. This increase is primarily driven by the new lease agreements with the BC properties through the April 2022 BC properties transaction where they acquire MGM growth properties. In conclusion, it is apparent that MGM resorts historically and currently maintains suitable free cash flow capital and liquidity to support its sportsbook operations. At the MGM Springfield Pistino as well as its other operations. MGM has maintained an average total available liquidity position of approximately 5.2 billion for the period 2018 through September 2022. As of September 30, 2022, MGM has approximately 7.3 billion in total available liquidity comprised of 5.3 billion cash on end and 2 billion in availability under its current revolving credit facilities. And with that I'll pass it back to Greg and Chuck for a closer look. Yeah, just to summarize a little bit there on the financial side, cash flow positive for parent company MGM, they've been cash flow positive. They want negative during the COVID pandemic, which I think we've seen that that's consistent with other businesses. And they, as Connor mentioned, there's significant cash and liquid assets in terms of being able to withstand any future business cycles. So, as far as sports betting as a whole, and may or may not have been shared previously. The sports betting has not been a hugely profitable industry for those entities that are public and sharing that that information so that the sports betting app business and profitability and that is still an emerging market. Aside from that I don't know if there's any other notes or information that that the team has gathered or plans to share here. Certainly open up to any questions that the commission may have. To your team. Do you have anything else. Commissioners, do you wish to hold your questions as long as some of the RSM folks are available there's Teresa joining. Nice to see you. Mr. Shall we wait. I think it would be helpful if you're available. I think that would be great commissioners do you wish to have a short break before we start with the evaluation of the application or should we go right in. We comfortable. Okay. Well, thank you to RSM to GLI and to counselor hall for providing your expertise on these subject matters. Now turn to item number 13 on the application on the agenda. I'm sorry, review and evaluation of the application. You'll note that there are factors listed for criteria listed. Those are the factors that counselor Grossman went over that will ultimately guide us in our determination and our decision making with respect to the license. Right now we'll go through each section as we did yesterday. We'll go through these sections. And it's a reminder that at the conclusion of each. I'll ask for your comments. If you have any additional questions that need to return to, but then I'll check in to see if we have a general consensus around the quality of the particular section. Do we need the expectations relevant to our standard review earlier outlined by general counsel Grossman. Did it not meet those expectations or did the applicant exceed expectations. So we will start with the application section be everyone has access to that. I will take questions. Are you leaning in. No, Adam chair, I'm leaning in. Thank you commissioner help. Thank you. Good afternoon. Just a very quick question. And since I think we have three newer commissioners. This might be appropriate for us three newbies. The area in which you're going to that you're proposing to put the sports betting. Was that a gaming area and I just heard I believe Chuck tell us that it was but has that always been an area where gaming has been allowed. And if not, will you be coming before us, asking that this be allowed for gaming. I just need a clarification about that area in terms of present gaming or future gaming. This is an area of property that had existing gaming within it previously, it was a predominantly occupied by slot product and would be a continuation of that use now for purposes of sport thing. Okay. Thank you. Thank you madam chair. Thank you. Questions commissioners. Richard Skinner chair. Good morning again or good afternoon now. MGM team. Your application states that you will be relying very heavily on that MGM to conduct your sports book operations, but it doesn't. Your application doesn't explicitly detail the relationship between MGM resorts international and that MGM and on team that's referenced and I apologize if I missed it but could you just describe what that relationship will be. Okay, a summary stab on that and then we've got our team here to help us fill in any of the blanks on it. The MGM is a joint venture 50% owned by MGM resorts and then the company that you mentioned previously, and tain. It is a service and platform provider for our retail operations in Las Vegas and regionally. The key distinction is in the operations of the venue and the use of that platform and system. Those operations are exclusive to MGM Springfield operators team members and will not be bed MGM employees. So other than the platform what other services do you expect that MGM to provide. Bed MGM provides advisory and consulting services regarding best practices, etc. We also have a linked reward system bed MGM and MGM rewards. We occupy separate databases, but players within bed MGM and MGM rewards are able to accrue points and benefits to your credits collectively. So we occupy a companion space from a marketing standpoint. Thank you also for speaking on the rewards program systems. One of the questions that I was going to ask when we got to that point was whether they're integrated so appreciate you speaking to that. So I'll say what I said yesterday in terms of my concern. My review of the MGM category one application and you know I'm not terribly pleased with the fact that much of the application references the bed MGM application so a lot of the detail that would be necessary in order to completely and comprehensively consider the category one application is essentially missing from from this application again understanding that there are significant references to the bed MGM application and it will be a few more days until we get to that particular application so I just want to note for the record. That I have the same concerns as I raised yesterday when we reviewed the category one application for PPC that I, you know, happy to continue on with the discussion I think it's necessary. In terms of a full evaluation and deliberation on the application I'm just not prepared to do that today without having the benefit of the review of the bed MGM application. Commissioner Skinner if I can just react to that, I completely understand those particular concerns as well. I think what you have in front of you is an application for category one applicant that does certainly rely on what I'm going to describe as essentially a vendor to provide several of the services, just like you would have with a category one establishment as well. I think the category one sportsway during application does stand on its own. We are certainly happy to answer any questions that you have over what services will be provided by by that MGM throughout this process. And certainly, you know, going through this for the first time and looking at sort of the relationship between the category one applicant and a scenario that you have in I think all of these situations where the service provider is also separately a category three applicant. So what we, you know, what we certainly propose here and what we think we've provided to the commissioning connection with the category one applicant that does satisfy the rules and regulations but we are happy to answer any specific questions about the services that will be provided as one of essentially the vendors to the category one sportsway during applicant here and those services. If there are any particular concerns around them, we do want to fill in that piece for you as you evaluate this application as well. I do actually have a follow up question about the services that you expect that MGM to provide to trading services is that one of the items that you will be seeking from that MGM. I learned about trading services are I think I first heard about trading services yesterday in connection with our discussion with PPC. Essentially, it's the math model behind the game. That's something that you're familiar with that you could speak to us about and that MGM's role. I'm asking because my point is that that appears to me to be a significant point of control and integrity. And, you know, that this is, this is, you know, one of the reasons why I say I don't have enough information to fully evaluate the MGM application because I would, I would think and it sounds like the trading services is a very significant piece of sportsway during operations, obviously both retail and online. So anything you could tell us about, you know, really in detail beyond what you've already shared. What collaboration with that MGM will entail that would be good. Commissioner, I will say this, let us attempt to make just a preliminary answer there. And also, if we can take the opportunity, maybe during one of the breaks to see to the extent that we haven't satisfied you with our sort of preliminary answer to see if we can get some additional information for you as this process proceeds this afternoon. So it may be that we can just give you a sort of a brief answer now but something maybe more detailed even today on that particular question. And that works, but I, you know, understanding that we will get to bet MGM's application next week and so, you know, if they're, if you run into any roadblocks in obtaining that information, then I understand that. But I will say that should MGM Springfield be issued the category one license. My expectation is that the licensee is aware of the operations that it will be providing. So, because you will hold the category one, if issued license and so, you know, really to say, we don't know yet, we'll find out and get back to you is somewhat concerning and I know those aren't your words. You know, what we want to do is be responsive to your question today and I'm saying we have a lot of resources in order to do that. You know, honestly, we don't know what questions you're going to ask today. Certainly, and I think I just asked for a little bit of forbearance maybe to provide you with a full sum answer but we're happy to provide you again with a preliminary, preliminary answer. So that's that today and, you know, absolutely those were not my words that I used in connection with sort of our presentation, certainly in our answer that question our job here today is to be responsive for you to evaluate everything you need for purposes of a category one retail application and with that Chris do you want to just maybe provide a quick answer here and then again if we need to provide additional detail, we will absolutely do that. I appreciate that Jed and Commissioner scanner I'll try to hit the two points that I think you were asking one, you know, first on the train front. When we think about training for this, the engine spring field facility, we would be bringing in really two components, we would be bringing in resources from bed and GM, absolutely. We would be bringing in resources from and GM resorts that are operating our facilities in Las Vegas and regionally. And so through both contexts would be applying training to our team members here. You know, relative to what I think you were asking which is, you know, how do you know how are that set and you know what are the odds pertaining to those and how do you, you know, incentivize play around making etc. Absolutely those are parts of the bed and GM platform and system, and that is the, you know, the foundation of the service that is being provided. And so that is an element of what bed and GM will also be training us on, as well as ultimately how guests will interact with that system, as they do in other markets around the country. And Commissioner I'll just sort of close out this question and again, if we have additional information we can provide here we will. It's not a question of, you know, necessarily, you know, it's much more than being aware, it's actually being responsible at the end of the day as the operator as President Kelly indicated in his opening remarks, this at the end of the day is operated by MGM Springfield, they are responsible for all of that, including any services that are provided, whether it be through how the odds are going to be said through to FNB if the buck stops with them. Thank you. Other questions or follow ups. I have a question. Thank you, Commissioner Maynard. Just to just to point out clarification for you chair. We are going over the entire section the right just one subsection. Commissioner Maynard, I had a little trouble hearing you just now. Could you repeat it please. Are we going over the entire section be or just a particular subsection. I think we should give ourselves a little bit of leniency and skip around within the section so if you if you find that you want to go, you know, to B or B2D that's fine. Thank you. Is able to navigate that okay. So, speaking of some of the offerings. I was really interested in finding out more about edit my bed and share my bed. And thank you for being here first of all, today we appreciate it. I think that's how the those two functions work. And if that's in any way, an issue for confidentiality. We rely on you folks to flag that. Yeah. I've memorized the reactions, of course. That is a question. I think we're going to have to identify a team member to provide a response to you. Commissioner Maynard, and again, we're happy to do that today. You can just give us some time maybe during the break to do that. Oh, so it's not a matter of confidentiality. Mr. No, so it's just a matter of you'll make sure you get an accurate answer. That's fine. I'm not our intent. You know, I'll have to reserve chair on that, but I don't anticipate for finding a description of those, those, those options will necessarily be something that's confidential. Madam chair, I do think they're in use some of the joysticks. Yeah, I assumed I just was wondering if they were going to provide some information that they were uncomfortable that I just saw the hesitancy but I understand they want to be accurate now. Okay. Do you have another question, Commissioner Maynard? Not on section B. Or no, any, no, any section of anything within the subsection. Okay. So, again, just staying within the section B. This is a very straightforward question. President Kelly, can you remind us of the number of kiosks that you're intending to have at the property overall and also on placement. And to the extent you can share some strategy comfortably on that, that would be helpful. Sure. So we have, we have ordered and received a nine chaos to see that referenced in the application, but we're actually aiming for a final count of 18 kiosks that we would like to bring to bear for purposes of the introduction. Okay, so that I did say nine later, but I wanted to check in. So right now total of 18, will they all be, if I recall correctly, maybe one was going to be in the high limits area, but otherwise they're on the gaming floor. Is that correct? Since they'll be on areas designated as gaming, but we do have a space allocated in our high limit room, we have an area on the gaming floor, not too distance from the primary entrance, where our elevator banks, and in most frequently used kiosks exist, and then we'll have kiosks also located around the sports lounge itself. Not of course in the tap sports viewing area that is a non gaming space. And then we have one allocated for our poker room, which again is a gaming area on the floor. Right. And because of the nature of which, of course, I fully appreciate. You know, it's forest nature. It's, it makes a very special property, but sometimes a challenge with respect to enforcement of keeping younger people off the gaming floor. Are you comfortable with the spacing between the edge of the gaming floor and the access of very younger people might be traveling so that we can make sure they don't have access somehow. That's a great question. And it's very top of mind for us here at the property. And so a couple of things that we have done recently, but I'll also speak to some of the efforts, you know, longitudinally since opening. We had the opportunity to present our Q3 results to the MVC team, and we're proud to be able to say that in September, for example, relative to the same period in 2019, our instances of miners on the floor actually dropped by 90%. So the efforts in collaboration with, with the MVC I think have been moving us in a positive direction. In addition to those things, we are in the process of looking at some specific barrier locations that will be deploying on the floor. That's something we've done historically and has been effective. We also recently added a director of security position so we have added to our senior leadership at the property that is in support of our security chief. And among many in the building that are leading in this, I have two in the room in Dan Miller and Gus Kim, which are providing additional point of contact training in pre shifts with our operational and back of house departments across the property. So those three initiatives are ongoing. In addition to the steps we've taken over time that we think will put us in a, in a good place relative to this ongoing challenge. Thank you. Okay, and like you chair, in actual fact, in answer to Commissioner Maynard's question, the two options that he mentioned are strictly a mobile option. That's not something that will be available through a retail program. Thank you. I appreciate that. I like Commissioner Skinner I was doing a lot of cross referencing to both to both applications. So I think that's in section B, Commissioner O'Brien. Nothing new just reiterating that, like Commissioner Skinner and Maynard I, it was a little frustrating to see a reference to go see this application that wasn't actually part of this application so I know that as a creature of how we've had to structure it, but I just echo some of the questions that I have really aren't going to be before us until next week so. Just if I can follow quickly quickly with Commissioner Maynard, because your question pertains specifically to something that deals with the category three application, I would suggest that that piece you do we reserve and have those questions answered during that application. Certainly today's a great heads up for that. But because it doesn't impact retail, we're happy to try to provide the additional information but it may be more appropriate for the next year. Absolutely understand. Okay commissioners with respect to this section. Do we feel that the applicant has the expectations exceeded or does it meet do we need additional information. How we feeling. I believe they have met the expectations. Agreed met expectations. Commissioner Skinner section. Yes, they have met expectations. I agree. Okay, so we're all set we'll move on to section. And again, thank you. Great commissioners you have questions. Well, I'll lead and then people can catch up with their notes. I can leave because it's a little bit connected to an earlier response. I think it's C1D where you include. I made it be wrong. You include the criteria of the job descriptions. The positions that will be hired. I understood. The MGM in terms of the trading services that commissioner scanner raised and the idea that they'll be responsible for this. As I understood the setting of the facts and it will be all universal for both the retail and online. But I saw in the supervisor position. That they also can, you know, set the line and monitor the lines. And I wondered if you could explain how the, the, the larger role that commissioners can and quite, you know, properly raised. We understand learn more than in the next. The category three although we're delighted to learn as much as we can today to understand how that source is going to affect retail and then how this, this position of supervisor will be integrated into that. That's the question for Johnny. Do we have Johnny on? Yeah. Yeah. So we are going to introduce a new member to try to work through that answer for you, chair. And I believe that's going to be Mr. Gomes, Gomes, Susie. Thank you. Good afternoon everyone. I'm Johnny Grooms. I'm the director of retail sports for bed MGM and would be happy to answer that question. I would tell you that looking at the, the job description. It says that supervisors at the books set lines that with the job description said I have to. Yeah, I, let me see if I can pull it out. I think it says move and monitor. Move down the line. Move and monitor. Okay, so, so typically in our existing operations on MGM properties, the supervisors actually consult with the trading teams on the movement and monitoring of lines. They don't have the specific ability there at the property to move lines. They monitor them and then can actually consult with the trading team, which this will be based in Atlantic City or I'm sorry in Jersey City in our corporate office, but they'll consult with the trading team and then that's how the lines will be moved. So there will be sort of live communication eyes, basically eyes on the floor right that can be communicating with those folks who are the trading services team to bed MGM. And now we know they're in Jersey City. So that's good. Very helpful. They don't have independent control over that. That's correct. Thank you very helpful. Any other questions. I'll ask the next and see it. I have to ask the question that RSM did raise in its report. I think it's in C to be again for giving him looking cross referencing and hoping that I got it right. But you report that you don't expect any non gaining monitoring revenue. I did note that you don't have within the sports betting. The retail space itself. A restaurant, but it's certainly a bar next to it. I think that that was noted by RSM is nearby a space and I just wondered about that response because it kind of surprised me that it would be just we don't expect it at all or should you be perhaps seeing that there's an MGM Springfield here to maybe a leverage the retail site for expanded non gaining revenue, which would of course help the bottom line for not only the Commonwealth crisis spring field city spring field. Anything to add or is that something you're still thinking about. President Kelly, I just noted that RSM also noted that there was simply a note that they wouldn't be at it. Chris, just before you. Chair, I think sometimes these answers are done, especially when they're being relied on for purposes of projections in a very conservative way. So I think that's partly what's reflected in this answer but I think your president Kelly can probably touch on, you know, certainly what our aspirations are, but it's that may be different from what we can bake into some of these numbers. And to pause with that's important as for public company purposes. That's something that's not proper publicly. I know we have other avenues to discuss it but I did note that that was your public answer so I just And I think, you know, speaking in speaking directionally, you know, nice choice of words I think expectation versus aspiration. And there are a couple of qualifiers all throughout their first I think you know this is extraordinarily impactful as a mechanism for creating competitive parody for us as you know we compete directly against the operators in the state of Connecticut so in terms of being able to provide you know what should be viewed as a like service. This would certainly allow for that and that directionally as a positive. One of the headwinds we're facing and you heard referenced in the presentation is our hiring efforts and certainly our ability to leverage that fully will require you know the ability to access the labor market in a more fulsome way. A reference to steps that we've taken the challenges in the industry as a as a whole nationally, but we've not been into that, certainly in Western Massachusetts and so that could impact that aspiration, but to answer more directly. You know, we've seen across the country, you know, opportunity here, and we certainly look to leverage that opportunity I think the advantage of the design of a bar that is essentially you know contiguous with and within the sports betting lounge gives us a leg up there. The fact that we are, you know, diagonally across from our Costa restaurant and pizza kitchen, I think gives us another opportunity and of course, we're just a short walk away from our from our food court. So we do, we do agree that there's opportunity there, the degree to which we'll be able to leverage that I think that's what drove the answer and again judge response earlier. Thank you very help. Richard. Richard Brian. Yep. First just to say, thank you to the chair for asking a question about access to under 21 to the kiosks. It's been an ongoing challenge I know the layout of MGM Springfield and so I am looking forward to seeing exactly what Barry are going to be able to put up to help in that area. So as a workforce labor development, I think back to some of the prior quarterlies and annuals that we've gotten from you guys in terms of how you go out to job fairs and working and I think one of the things I remember in the past is, as you put in this application I think it was a tendency and rightly so focus on Springfield and the immediate surrounding areas and communities, but then there was sometimes a tendency to drift down into Connecticut for other workforce as opposed to say heading towards a Worcester County in Massachusetts. So I don't see any reference to Connecticut in this application but I just would, you know, put a plug in that as you go through this and as you're feeling that the number of empty jobs that you're still trying to fill even before sports and I would hope for a push into central mass before a reach into Connecticut. Other questions on section of me. Let's see, I'm sorry. About chair. Thank you commissioner. I also agree with Commissioner O'Brien on that point. I just want to ask for the record, the seven new full time six new part time, essentially 13 new positions, those be net positions, or would those also be. They're incremental new. So to answer your question, are they, you know, did they exist on the property now in any way, or would they be new ads to the current number. They would be the latter new ads net new. And I'll mention just as a just as a data point, you know, over 75% of our residents are team members now are from Western Massachusetts nearly 80% are from the state of Massachusetts and of course, the largest percentage of the city of Springfield itself and so we, we recognize the, the, the asked there and appreciate that as well. Another question under community engagement thank you. So he has a lottery answer, and the commission has expressed. Wish that any potential license he does work with the lottery. The response was essentially if we can keep more people on property, we can have people have availability to the lottery. And that was kind of the answer. I wanted to give you the opportunity to talk about maybe any current agreements that you have with the lottery or how you're working with the lottery. I just want to make sure that it's what I think it is, because I think it's more robust than in this paragraph in this application. What we do and have had an ongoing partnership with the lottery and it's been a very positive one I think for both parties certainly from our perspective and when you when you enter the facility. We actually see agreed upon locations for lottery units on the floor, and we have worked together, you know, from prior to and even through Kobe to make sure that they are in portions of the business that have high visibility, have a comfort level on the part of the lottery and have visibility of course to the guests that visit MGM Springfield every day. We also are able to report out on on lottery sales on a consistent basis through our quarterly reporting and have been able to see I think robust numbers with respect to that line of business. And so in that sense, the communication and the presence in the partnership direction has been moving in a positive way from from opening through now. Commissioner the only additional thing I'll add to that is that is actually governed by a formal agreement between MGM Springfield and the lottery. I think you guys have a copy of which, you know, certainly I think that what we're saying here is we're able to sort of, you know, build on that that was obviously a requirement on 23 K, and now looking to continue to leverage that agreement going forward. Thank you. I appreciate it. I appreciate the question except I was expecting it to come from the chair, which is why I held out. But I also appreciate MGM team your further elaboration on that question. I have seen thought as commissioner Maynard. We don't have to wait for any question commissioner Skinner, but I do have a follow up and it's really going to just a tip for next week's presentation. I think it's next week. We're working on our schedule. The at the end of the application in today's application. The language is at this time that MGM does not have a commercial relationship with the mass state lottery that would produce significant partnership and collaboration. I understand that perhaps that MGM won't be the signature to the, the license, the agency license that was executed as part of the 23 K licensing process. But I am hoping that maybe that relationship could be reimagined somehow. MGM will probably be advertising everywhere. And there might be some cross marketing opportunities to help the lottery stay unaffected by this expansion of gaming and to support Charger Goldberg's request. She did come to us and we included, this is part of the application and it's also part of the applications for our three candidates. So just, we would, I think commissioners, we would allow them to reimagine that perhaps that they wanted to give some thought for that answer for next week. I have a real softball here, President Kelly. And, and Commissioner Hill you may have some follow up on community engagement, they did a terrific job in the presentation right, but I am in looking at the answer about and I think I understood it. How, when you're working perhaps with local vendors you use a standard purchasing program does that. Does it help as an economic driver or does it celebrate their payment that got mentioned in your response and I just thought I'd like to learn a little bit about it. If you know, otherwise we have we have an answer ready for you. Nice to see you. I wasn't sure if you went right there. Thank you. Good morning. So when we talk about our vendor spend as we report quarterly we have our very robust program becomes to our vendors that we identify them how we work with them. We continue to strive to meet our diversity goals. And it's just part of our DNA every time we enter into any agreements so that's where we're referencing in the, in the application. Okay, thank you. Thank you very much. Okay, anything else. I'll set. I think we have time to move to section be then and then take a break at probably after that one does that make sense commissioners. Except to say that see met expectations, at least in the view, the view of this commissioner. And that's the net and thank you so much for helping me. I appreciate that. And do we have a consensus on, on sec to see in terms of meeting your expectations. Yeah, I would agree. Okay. Okay, thank you. Julie noted. Okay, I'm going to move right to be. Thank you, Commissioner Hill. Okay. Do we have questions for section D. I'll know. Go ahead. Thank you, Madam chair. And so this question kind of relates to my earlier question around, you know, what exactly better GM is going to be doing for MGM Springfield. You know, to the retail sports book. There seems to be, you know, a deferring to that MGM in a, in a lot of areas throughout the application as I indicated, but at the same time. Also, you indicated that I agreed, I should say that MGM Springfield is ultimately responsible for a category one license. So that being said, is the relationship between the two entities will that be governed by a legal agreement of any kind I mean you like in that MGM to a vendor. I assume that there is a contract that would govern that relationship I asked that in connection with the section D, because the MGM application states that when it comes to diversity goals. MGM is working to solidify its goals by quarter one 2023. And you refer to that MGM diversity policy. So, I guess, just getting to the question, you know how much how much, you know, do you expect MGM Springfield to influence these kinds of issues, particularly around diversity spend, let's say. What do you envision MGM Springfield's influence to be. So I'm going to start with the answer commissioner scanner to your first question about agreements. There are agreements between ultimately blue tarp through a and that MGM those the commission has those agreements, I believe they're both submitted not they we didn't submit them twice but they were submitted as part of that MGM's application so you have those materials there's essentially a JV and then another agreement regarding the sports book. So those are documents that you have access to mark both of those as confidential. But certainly you have access to them to take a look at in connection with your consideration to understand the the what I will say sort of the legal arrangement between the parties here. And I guess I'll defer further on the on the rest of that question to the rest of the team. So speaking to the, you know, hiring, for example, you know the diversity goals that MGM Springfield has in our approach to diversity and inclusion, ultimately drives these positions equally to any other position on the property and so those decisions are made by MGM Springfield. And when we talk about things like operational expenses that will be forthcoming as a result of operating a sports book and opportunities relative to suppliers and some of what Arlen was referencing. So the decisions that will be driven by the property as well. The only exclusion to that would be if there are certain items that you know have to be, you know, soul source vendor provided as is not uncommon. In the case of gaming, but exclusive of that and consistent with the way we approach these things now, those will be driven by MGM Springfield and not by MGM. Good to know that those agreement that agreement is available. I think I indicated earlier I had not gotten to the category three tethered applications just yet but I look forward to doing so. Sure, I'll have more questions as we move forward with that application review. Anything further. Right now. First, I want to thank you for the diversity section. I mentioned yesterday I'm drawing some inspiration maybe it's the holiday. I'm not really telling, but I like that you have made the statement, and I believe that the entity lives by this is that you're committed to taking strong and principle stands on issues of equality and aim to better unify our world. And so we, we appreciate that. Thank you for that support that. I know that we focus a lot on the fact that you have not met your workforce goal with respect to women. I think it's a 50% goal and then maybe it's 40% and that can be corrected. I want to applaud you, because I think that you have been consistently above your goal with respect to bets. And I know that statewide that is sometimes a struggle. And Commissioner Hill, you may want to lean in on this. I know it's an important issue for you. But, you know, we applaud that I think that your goal is 3% and you've been hovering at 5%, I think, pretty consistently. The other thing you alluded to, Commissioner, President Kelly is that, you know, much of your workforce is right from the city of Springfield. I can imagine when lawmakers governor signed this 23 k into law, that was exactly what they hope for in my, my number suggests it's 39%. I don't know if you had that up to your tongue. But again, I applaud that with respect to your workforce. And with respect to the issue around women. I think that would be working on it and I think that ties into the issue that you raised as to why there's a challenge with non gaining revenue. We also appreciate any steps that you can take to recruit women, I believe the daycare centers and are away but I wonder if that's also a challenge for. I don't know if finding challenges with respect to educators at the childcare centers. But again, for whatever reason, COVID has impacted the all caretakers but I think that's probably harder on women so we'll just look for that growth but thank you. I think that's a good point to have on the bets and if you have any comments on that present Kelly. Well, first, thank you. This is something that the team takes a tremendous amount of pride in certainly for those goals that we have been able to meet but also for those goals that we recognize we have yet to meet but that are pursuing. We have a tremendous amount of time, attention and effort around it. You know, speaking to the springfield resident piece. I had the privilege of going to every new hire orientation at the property we have them on Mondays at 930, and there's never a time in which we don't ask you know how many folks are from the springfield area, and just remind them that you know this 14 years that we sit on was destroyed 10 years ago was as you know very well chair and the other commissioners on with us. And was a very uncertain future. And so from that, you know, destroyed 14 acres that these city residents know very well to now one of the largest private investments in the history of the city. And now or you know come back as it was characterized earlier from Kobe, you know this this is part and parcel of that story. They are very proud of it as well. And we very much appreciate your comments. Thank you. Follow up on this section B. I do. Madam chair and I agree with the sentiments that you've expressed but I playing the bad cop a little bit I am going to ask for some more detail on particularly the demographics in D one C and drilling down a little bit more if you could talk about what are the areas that you're making to try to get your women's percentage up and also can you speak to percentages in terms of these areas and particularly women in management and what those stats are. So speaking to the to the first half of the question, you know, again and again recognizing to the chairs earlier comments, we as an industry certainly within the state and certainly within the market in which we operate have not seen a return of women to the workforce in the same space as we have seen men returning. We also have you know the larger challenge which is a few hundred plus approaching 300 open positions, most of which are in our food and beverage space as the singular largest gap that we have now. As we look at things that we can adjust and change within the world of variables that we cannot. We have been adjusting the way we threw a weekly hiring fair, we hold them every Tuesday, the way that we push candidates forward within our queue. We try to identify women candidates to push through our queue to our leaders. First and foremost, we have increased our outreach to many organizations that during code with shut down, but to re engage our efforts together with them as well as we have the benefit of a large network of diversity and school systems around us. So opportunities to partner with Bay Path or, you know, our community college network, those have all been engaged with and we are actively looking to leverage as a means of filling the opportunities that we have. We are launching dynamic from a scheduling standpoint of course, but we do think that you know we can be flexible and are looking for opportunities to do so. And is anyone prepared to speak about the supervisory management numbers. I have those in front of me. I'm just looking at our last queue through reporting to the MGC so I do have kind of percentages of manager and above etc but not broken out demographically beyond a looks like and check me if this is off it looks like about 36%. Supervisor and above and I wouldn't know it. Well, presently, this could be if you need to do a little bit of research, we could break and we turn to that if you'd like to get those a little bit of a final point on those numbers for Commissioner Brian for sure Brian would you be okay with that. Yeah, that's fine. I do I do have them. Manager and above through our most recent reporting it is 36% women. Supervisor and above, as of our most recent reporting it is 44%. And in both instances, those are increases quarter over quarter. So q2 to q3 management went from 34 to 36 q2 to q3 supervisor and above went from 36 to 44%. That's a significant jump there. And not my last question and I'm not asking anyone to comment on going litigation but representations or allegations that maybe some of the numbers early on were puffed up a little bit that were submitted to the MGC. Does anybody want to address that. Commissioner Brian that's pretty difficult for us to talk about in this setting. Yep. Absolutely. Okay. That's fair. Yes, Commissioner Hill. So just as a follow up and I think you touched upon it in your presentation to us earlier this morning, you talked about programs for diversity, equity and inclusion to move people into managerial positions. So as we're talking about this, could you elaborate a little bit about what programs that you have moving forward to assist our DEI folks into managerial positions. Yeah, I think I would, I would first ask Danielle if you're on with us still, I think you could provide us with some great context for that and then I can jump into follow you. We have to our mentorship program which was recent recently launched at the beginning of this year, which Paris leaders, obviously with aspiring leaders, and then launched in 2020 are accelerated leadership program takes usually on average between 50 and 60 across the country taking into consideration, really developing the bench strength of our diverse leaders to provide them a path of upward mobility, which was launched. Actually Arlen's in our ALP program right now. And I'll conclude at the end of the year as an immersive long training program that takes about a year to go through. Thank you Danielle I was just going to share you took the wind out of my sales with that Arlen acts in a couple of different capacities and this exists obviously outside of this room but just given her interaction with many on the call. Arlen is not just a member of the ALP program. She also acts as a mentor program, working with local suppliers of a diverse background, giving them an opportunity tools and assistance in becoming vendors to the property and so it's an external program but it's an internal program as well as Danielle mentioned, we look for these opportunities in all aspects of what we do. Thank you. Thank you madam chair. Thank you. Excellent questions. Anything further on diversity equity and inclusion. Section D. How do we feel do we have a consensus that the applicant has met our expectations with respect to this. Madam chair I believe they have met expectations. Okay. Great. Mr. Maynard are you all set or can we just go Brian. Michelle Brian. I'm good. And so we will move on to section E after we take a break. It's about one should we return just around 130. That sound good. Yes. And mgm springfield is that work for your schedule okay. Thank you. Excellent. Thank you very much. One, one third. Thank you so much. All set. Thank you. Thank you everyone. So we are reconvening master's game commission public meeting number 407 because we're holding this virtually. Good afternoon. Again, commissioner Brian. Good afternoon. I'm here. Thank you. Commissioner Hill. Good afternoon. Hello, and I am here. Excellent. Thank you commissioners. Good afternoon. That's me and I'm here. And commissioner Maynard. Good afternoon, madam chair. I am here. Okay, so we left off. Thank you. Thank you. Thank you for having gotten through. Section D of the application. And we're moving into. Responsible gaming. Section E questions for. Our applicant and I see that Mr. Farms has joined us. Thank you again for your presentation earlier today. Very comprehensive. Thank you. And I do. If you have any questions that you'd like to ask at him. I have some questions. If I may. Yes. And if you did cover it and I missed it, I. I apologize. But. There's a lot of conversation about sort of what's done on the floor at MGM in terms of responsible gaming and all of that. And so if someone could speak a little more in depth to the guardrails that Bet MGM and or MGM put up in that regard, and then specifically if someone can address the Bet MGM fine that was given up in Canada back in April, I would appreciate it. I could take the first part of that, Commissioner O'Brien, if that's okay. And deferred to the Bet MGM piece. And so really what it starts with is our training process. So prior to COVID closures, we were tracking, similar to what the Massachusetts Gaming Commission does, is our conversation with guests. Now, a lot of these were limited to short interactions. And again, these did stop once COVID had hit. Now, what we're trying to do based off of our research with UNLV and Cambridge Health Alliance is try to increase the visibility. Number one, so we increase that awareness of responsible gaming so that we can start the conversation with our guests, strike that interest. We also have to offer them those tools to mitigate gambling related harm, whether that's self-exclusion through the MGC or through our self-limit program as well. But making sure that our team members are trained on all of these facets and comfortable engaging with our guests on conversations regarding responsible gaming and making sure they know where the resources are available on site as well. Does that give you a good response to your first part of that question? Is there anything relative to, and maybe someone else is more in a better position to answer, but in terms of marketing and advertising, sort of what MGM does and or vet MGM does in that regard? I can take a stab to it at that first part. In terms of marketing, our company's responsible gaming best practices really serve as a framework when we create marketing pieces. Now, these overlap with the AGA's code of conduct, our responsible gaming sports wagering marketing conduct as well through the AGA. An essential piece of this, though, and I'm always going to go back to it, is training. It's developing relationships with our team members. And I'm proud to say, as I can change, develop my relationship with properties as well as conduct trainings as well, we open up that interaction with one another. So if there are questions about, does this sound right? Is this reinforcing any problematic conceptions on gaming? We review that on top of having the disclaimers and the helpline information there as well. We really want to reemphasize our focus on player health and creating a cultural responsibility that really ensures all of our departments put the guests at the best interest of our efforts. And so if that means that our marketing teams going over what the new campaign is going to be, we'll do that. So that's kind of from a high level how we address marketing. And does MGM or vet MGM have any policies about whether or not they create relationships with colleges and universities for marketing and advertising purposes? So that is part of, and I'm only going to speak on behalf of the marketing that's done there, is that we're going to avoid having partnerships where it's solely collegiate, that we're going to put MGM resorts or that MGM marketing out there. So in terms of larger partnerships, I can't speak on behalf of that. But in terms of exposure to potentially vulnerable populations, such as those of college age, and those who are underage who may be attending those, that's something that we're very cognizant of. Hi, Sarah Brennan, Senior Director of Compliance for Vet MGM, just to answer on a couple of the questions that directly touch our business. For your edification, responsible gaming and marketing compliance, both reported to me at Vet MGM. Richard Taylor, he's our senior manager of responsible gaming, is unable to join us today, but works in direct parallel with Garrett on marketing and advertising initiatives that run in parallel between MGM and Vet MGM. And so specifically for an MGM retail book, where MGM is responsible, but the branding is Vet MGM, we are obviously very involved, both from the basics, so ensuring that the correct responsible gaming helpline is available to patrons, jurisdictionally specific language and helpline information. But then to Garrett's point, taking the AGA's best practice guidance, as well as just good business ethics, and always paramount to us is responsible marketing, not engaging in anything that would be considered to be predatory or directed at an underage population. We have not conducted any advertising on college campuses conscious of the underage factor there, as well as we don't intend to in the future, but we have not to this date either. We scrub our marketing lists to ensure both the age of patrons and receipt of marketing materials, but also to ensure that they're not on any excluded persons list in any of our jurisdictions. And so they do not receive marketing materials if they're in a responsible gaming. It's called an RG closed status or a cool off status on the account side. Several, you know, bed MGM, and again, we'll get into this in much further depth next week during our own session with you. But we are operational in 27 jurisdictions. We look at the regulations across the board, both from a marketing compliance and RG perspective and say, you know, we don't advertise drinking and gambling. We don't advertise, again, on college campuses. We don't, in the proximity of those campuses or, you know, schools, there are several states who have, the reason I mentioned the 27 jurisdictions is several states explicitly say that in their regulations, but out of abundance of caution, we don't do it in any jurisdiction, whether or not it's specifically outlined in the regulations or not. Did I satisfy that part of your question? Yeah. OK. I was directly involved in the fine that occurred in Ontario from AGCO in May. Unfortunately, that was a human error. We put together comprehensive training materials for our marketing teams. And we, I say, my marketing compliance team and RG teams work together to put together comprehensive back sheets and data, training materials ahead of every jurisdiction's launch, informing the teams of what's appropriate and what's not. So, you know, we're getting ready to launch in Ohio, so you can't have risk-free in Maryland, et cetera. Ontario, we did the same. Unfortunately, there was an individual who wasn't fully trained on the do's and don'ts and inadvertently published advertisements, which would have been permissible in another jurisdiction on our Twitter feed in Ontario. It was an honest mistake and earnest mistake this individual recognized immediately that what they had done was counter to the standards in the market. Unfortunately, we had just launched. You know, we launched April 4th. And so Ontario takes its player protection measures and responsible gaming measures very seriously. And we worked together to investigate the issue. We identified the offending materials immediately, withdrew them from the market. We re-trained our entire staff on what's appropriate and what's not for marketing in the Ontario market and worked really closely with AGCO on remediation measures. We were able to, you know, because we, of course, didn't deny that it happened. I mean, one of the things that's paramount to BenMGM and MGM is to self-report any instances of non-compliance. We're not ever, you know, if we know we've made a mistake, we fully accept it. We investigate how it happened and then the appropriate mitigation measures. So we did so in this case, worked with AGCO and the fine was actually lessened because we were able to, you know, one of the provisions of the monetary penalty was, you know, if we're in agreement that this occurred and you immediately correct, then the fine will be lessened. And I think the original fine amount was $48,000 Canadian so we ultimately paid $32,000 Canadian. So since then, we have worked really closely with AGCO and have not had any further instances of non-compliance in this specific way. And any jurisdiction? In marketing compliance, I believe no. Obviously, trading compliance is different. You are always gonna have trading errors, unfortunately. There's millions of markets offered every day, literally, lines, odds. You will learn that there will always be trading errors, unfortunately. But for marketing compliance, now we take a lot of pride in having very few issues across all 27 jurisdictions in the three years that I've been with the company. Okay, great. Thank you. Sure. Did you have a follow-up, Mr. Farns? Were you leading it? No, thank you though. And Sarah's explanation was great. Yeah, thank you, Sarah. When we have Director Vandal and what was very noteworthy during your presentation, Jared, of course, you spoke about the adoption of Game Sense across the MG entity. And Mark, I don't know if you wanna just comment on that. I don't know if, did you see the earlier presentation? Yes, I did see that better in your presentation. And MGM is the leader of across different gaming companies in terms of responsible gaming. And I think their leadership shows through the corporate-wide adoption of Game Sense. And then, obviously the Game Sense program in Massachusetts at MGM Springfield looks different than the Game Sense program that you will see at MGM Grand or in any other property, quite honestly. And so I think there is a clear distinction between the two models of how Game Sense is rolled out. That said, they are quite good partners in the message, what we call the Massachusetts model of Game Sense. Thank you. I guess I wanted to make sure that that history was clear to everyone. I'm trying to remember what year that MGM made that decision to adopt Game Sense. 2017, Madam Chair. Was it pleasant? Okay, thank you. Thank you very much. Okay, thank you, Mark. And any other questions on responsible gaming? Just going to note my own. Just one minute, please. Madam Chair, I can go if... Thank you. Yes, I'm sorry. I wonder if Sarah could talk to us about a couple of examples of advertising and marketing campaigns that MGM has launched since we have the benefit of your presence today. Sure. I mean, with respect to national advertising, we have brand ambassadors, you know, Jamie Foxx, I'm sure you have seen him in front of the fountain. You know, and we ensure in close coordination with the marketing teams who sends me storyboards, my marketing compliance team storyboards and myself to review to ensure that none of the language runs afoul of anything that would even come close to towing the line. You know, our approach pretty much is to stay a mile away from anything that would be offending to the regulatory parameters in all our jurisdictions. We review script language for radio advertisements. We review all of the fact sheets for promotions that will be run in our jurisdictions. We review television commercials, billboards, not only again for content, but also for the appropriate disclaimers, both jurisdictionally specific, but then also for national ads. We have team-specific advertisements. So where we have partnerships, you know, with the Steelers or with the... Now I'm gonna embarrass myself by not being able to think of team partnerships we have, but with the Denver Broncos, we review those types of affiliate partnerships. We provide information on dos and don'ts to our affiliates as well. So anybody, you know, action network, things of partnerships of that nature that have on kind of like the back. And we provide them guidance Yahoo, for example, we provide them guidance as well to ensure their compliance. Now, with the understanding that Ben MGM isn't necessarily responsible for third-party affiliates compliance, but in best practice, we would like to see them using the appropriate responsible gaming disclaimers and that their advertising is also of good responsible gaming and ethical standards. So we provide them guidance and materials on appropriate marketing as well. Did I answer? Yeah, yeah. That answers the question. But who are you referring to when you talk about the third-party affiliates? We have, I mean, we all... Well, there's a variety of different partners that we have. We have sports partnerships. So with like the 76ers, Denver Broncos, Pittsburgh Steelers, but then we also have, you'll see there's like affiliates that kind of operate behind the scenes. So there's like Buffalo Wild Wings, for example, might be an affiliate partner of ours or Action Network or other sort of like Yahoo, those are big ones and they advertise, they may advertise like a Ben MGM offer on their landing page. And so we would ensure that they have the correct disclaimers. Obviously, if we have a partner who needs to be licensed, that's addressed by our licensing team, Josh Wiseman distributes the licensing materials and scoping parameters to any affiliate partners we may have. So they go through the appropriate process with you all independently to become licensed and then follows the appropriate channels in that regard. And does Ben MGM adhere to the AGA's advertising guidelines? We do. Thank you. It was actually one of the first things I did at my time with Ben MGM because I came from working for the New Jersey Lottery and we worked closely with AGA and I came in and said, you know that they have marketing standards, right? So as a startup company, that was one of the things that we embraced right from the onset was AGA's best practice and responsible marketing. Not to pat myself on the back, of course, but I'm proud of that and that we've maintained the standard of ethical marketing. Commissioner Skinner and then lady chair, so if I might bring this back more to the category one in the brick and mortar nature, some of the oversight and review type procedures that Sarah was alluding to from a Ben MGM perspective also already occur here through myself without marketing on-site at MGM Springfield, which of course will continue and then expanding the sports wagering area as well. So it's making sure that we compare it against our existing internal control, the responsible gaming plan that we have and that the types of marketing that we put out is in trying to attract anybody that should be excluded from that kind of marketing. Thank you, Danielle. The question that I started with for Sarah wasn't answered by MGM in the application. It's E2H, it actually refers us to MGM, so I thought I would take the opportunity to ask Sarah while she was here. I understand, I just thought I would give some brick and mortar color to it too for you. Are there other questions on responsible gaming? I'm gonna do a follow-up. I think I heard it straight and I think I read it straight, but following up with the RSM, I think, who brought up the idea that sometimes the systems of MGM rewards might not align with your online partners. I heard today that the two are fully integrated in my right, but do you anticipate any concerns that were, I don't know if RSM is there. I think it was Teresa who said that sometimes they just aren't aligned, but I assume, given the number of properties you have right now, you're not seeing any disconnects there. And then I'll go right ahead, Sarah, if you're leaning in. I guess I would just ask for a little bit of clarification because when you say not aligned, do you mean from like a technical integration perspective or do you mean from like a philosophy perspective? No, a technical concern that got raised yesterday that sometimes with the rewards when you start integrating it into the online program, an existing rewards program with the casino might not be integrated. But it sounds like, it sounds as though you're integrating two rewards programs in each way. There are two, right? MGM rewards and then that MGM rewards. There's rewards points earned for your online gaming play which is separate from any type of reward that you would earn, like say sitting at a table on an MGM property. There's parallel in program but I don't wanna speak to something that I'm not the subject matter expert on specifically but we recently about a year ago went through a complete overhaul to our rewards programs and so any sort of interruption that there previously was in the way that the programs intersected and one of the paramount concerns of ours from day one has been, okay, if we have a patron who we think is displaying problematic behavior has an issue with their gameplay has expressed to someone on the floor that they are wagering too much then we wanna be able to know that on the online platform as well and also communicate that information if it's happening within someone's online gameplay to the property. And so we can make a decision one way or another and so we actually have a list based upon rewards numbers that shared overnight every night to ensure that the global ban list is universally reviewed for the online operations and the retail to ensure player protection. And then as far as loyalty points are concerned we have materials that we can provide you as to how exactly the loyalty programs work for both retail and online and I would be happy to get those together for you. They're also very clearly outlined in our online operations terms of service which will be part of that MGM submission to you with our internal control documentation and then also explain to patrons when they engage and play at the retail book. That was really helpful, Sarah. I didn't articulate it well but you guessed what I was thinking. So thank you very, very much. It's the policy was clear in my mind but I wasn't sure about the technology piece. Okay, I got it. Okay, very helpful. Any other questions? Okay, consensus on E, did they meet expectations? I believe they met expectations, Madam Chair. Michelle Bryan. Same. Mr. Skinner. Yes. I think I know that there were cross-references and I think that that's probably on people's minds. The cross-references, I must say that today's presentation, being so close to them on this was very, very helpful. And then, Mr. Maynard, how are you feeling? Yes. All right, then we'll move on to F, would like to start. I don't know if our, Joe is available. Joe, this, I believe if my memory serves correct that probably Joe, when you had through your exercise you went over to the other application or did you not have access to the other application on F3? Maybe you didn't end up looking at it. I don't want to put you on the spot either. I was in preparation of MGM's, Frankfield, today. Right. And so I think almost all their answers, if not all of them did reference that MGM separate application. So I wondered if you had had access to the other application. Probably not, correct? That MGM. But there's probably any type of question I could answer on a technical end for sure. So, I guess one of the things I noted, maybe I noted it incorrectly, but you are independent test lab with really quite command of the market, but I don't believe that you have tested the retail platform here after I think another independent test lab did. That is correct. Okay. With that said, are you comfortable that you would be able to say you have no concerns about the platform that's planned for with respect to the launching of retail by MGM? I actually would like to consult Kevin with that answer. Yeah. I actually don't think we can answer that question. Are you generally familiar with that platform or is it because you haven't had that testing? We are not familiar with that platform because. Oh, okay. I have not tested them. Okay. I wondered if you had been, that maybe you might have had just experienced in generally with them, but you don't have that. Okay, that's helpful to know. So, this is in the platform, President Kelly is, if you could describe that the kiosk and the, but I guess it's both the hardware and the software and I don't know if you are able to address that, but the retail, because I was worried when I saw that, GLI wasn't the tester that maybe we couldn't ask, we wouldn't be able to get information about the platform itself and the software that's being used. Can you help us on that? I did look, I did go to the IBM's application, but it's part of the technology. So thank you. Lady chair. So from a software perspective and even a hardware perspective, this is where it comes into our earlier comments about that MGM being our service provider. So the product comes from them, both in the style of the point of sale systems that our writers will write bets with, which at least from a guest facing perspective gives them the ability to confirm that the bet that they placed is correct before a slip is provided. And then similarly at a kiosk, clearly that's more automated, the actual better themselves is choosing the type of bet, the amount of bet, et cetera. And so from a software perspective, it has our, or I guess better MGM's test lab is PMN, which you're correct does differ from GLI, but in all other jurisdictions that we have gone live, it has met the requirements and certifications of those individual jurisdictions through that lab and then their requirements. So this software and hardware has met all requirements everywhere else as this has gone live. Thank you. Questions on technology? Commissioner Skinner? Sure, Brian. No question? Commissioner? The only question I have, and again, I apologize if this was said earlier in the presentation, but Entain, how does Entain, does it have anything to do with the technology that we're talking about an app? I guess. Anybody can answer that for me. Entain is the platform provider for our mobile operations. Okay. So in applicable to the retail point of sale? Right, because this is the PLE platform, which they're separate platforms and they're not integrated or they will not be for this specific project. So the PLE platform will be certified by the BMM test lab. It's the same structure we use that our other retail sports books that MGM has in Detroit, Maryland, et cetera. And then the Entain platform is what you will be getting a full dissection on next week by Madam GM. Madam Chair, I had checked with GLI with that and they said as long as they had gotten the BMM test reports, they will be able to do certification on their equipment. Thank you. Thank you, Assistant Director Bann, that's helpful. And have they gotten them yet or are they still waiting? That MGM is gathering the reports for them for we can go up proceed and get the test done. Okay. I checked on that yesterday. Yeah, so I don't know. From my perspective, I think this needs to hold until that box is checked, yeah. No, I don't think we'll have any trouble getting the reports. I don't expect to be what either, but in terms of have they met right now in this moment for me, it's not full information to be able to say that. BMM is one of our certified independent test labs for this regulation. And as long as they're meeting GLI's 33 standards and in one of those other jurisdictions, that would meet our regulation. So whether it was, and so GLI is just saying they can't attest that they've tested the software, but BMM is testing to GLI standards. And we have- I think we're just waiting for the paperwork that confirms that, Derek. I think there is a firm statement in the application that it does meet the GLI standard. Is that helpful or did I, first off, did I read it accurately? Daniel, that's in the application. I'm not sure that we asserted that it met the GLI certification from the perspective of the way you're using GLI to certify in this jurisdiction. Obviously, I don't have the wording in front of me, but the point you were trying to make across was the fact that this is a technology that has been approved in all other jurisdictions to whatever level that they have tested it and then certified it through the Rome Independent Lab. If I was saying, I meant to say standard with the GLI standard that we had approved. I think there's an affirmative statement on that. And then the independent tester is BMM. I'm not seeing that. You're not. In my- And Madam Chair, we're having Katrina jump on. She's working today. She's gonna jump on it. And if we could just summarize the question for her, I think she's been involved in this. Absolutely. MGM's equipment was tested by BMM and GLI says that if they get the test paperwork, they can certify that it passes the inspection using their paperwork. I mean, they- So BMM is a certified independent test log. So they do a GLI 33 standards because it's a requirement of the jurisdiction. So all GLI, in my understanding, if anyone from GLI is on the call at this moment, feel free to chime in. But all GLI would be able to do at that point is to verify that the certification for that particular piece of equipment hardware for a more software was tested according to the standards, but not truly a test that it was done because it's not being done by GLI. That is correct. But can anyone from MGM verify that there's not an affirmative statement that did meet in the other jurisdictions, the GLI standard? What is it, 33 Katrina? I think I thought I read a affirmative statement, but it might have been in the MGM's house. Definitely. And that's the conundrum I'm having. Yeah, it's a lot of this is a cross-reference, so. So my understanding is that BMM does test to the GLI standards because BMM does not create their own. They adhere to the GLI standard since that's been accepted industry-wide. However, what we could do, and again, Sarah, I didn't mean to cut you off, so feel free to add any other detail you think is applicable. I think it would be beneficial to maybe have BMM if they're submitting paperwork to state something to that effect. So we have that assurance for our commissioners. So we're missing the actual box checks, really is what this is, it seems. Commissioner O'Brien, if I could just comment just briefly on that too, I don't think this question is requiring the certification for operations. And I'm just, again, we're going through this for the first time, obviously, is this an operations piece? And certainly I would imagine that the A condition of licensure is that you obtain an operation certificate, which to me has to be based partly on our system being certified as meeting the gaming commission standards. So I just, I only point that out as to sort of what this question, I think it was attempting to elicit versus are we, do we have a system that's going to meet the Massachusetts standards for operations purposes, which we have confidence that it will, but I don't think that was prevented or to be quite frank, asked as part of this question. Yeah, it's not going to shock you, Jed, when I say confidence and corroboration for me just is a little bit different, you know? I know, but I think you'd also have a process for that to happen through the operations and conditions for the licensure. I do agree with that. Council knows, I guess, having a little bit of trouble because generally I'd like to be able to turn to our GLI consultant on a high level in career that I know I'm able to make because I don't think he had access to the application. He really couldn't review that. And again, Joe, maybe you wouldn't be able to. Well, I mean, then again, if since the products in question aren't test by our laboratory, we wouldn't attest to it. Anyway, anyway, and exactly what Katrina said is exactly the process. I mean, independent test labs test against our standards all the time. No. And that's just how it goes. You know, we put them out there to kind of set a baseline for the industry to make the industry more streamlined and more efficient. And yeah, that's, I mean, we do actually have a, we do test bed MGM mobile, but that's a different category here. So, yep. And I just provide a statement that I think may help the group understand the process a little bit. The kiosks in software will be certified by BMM, the Certified Independent Test Lab, that is verifying the compliance to the GLI-33 standards. And so you'll receive a certification letter from BMM attesting to the suitability of the product. And we have parallel certifications from BMM from other jurisdictions verifying that the same product, I would say product in reference to the kiosks in software that'll be used at the sportsbook and MGM has already been found in compliance with the GLI-33 standards in another jurisdiction. They will obviously independently test them for compliance in Massachusetts. So if that letter, and again, I'm just providing clarification, but not detail because MGM has to verify this, but when they receive that certification letter from BMM, that is then what will be shared with you all and GLI if that's the process. I believe they'll be providing the BMM certification letter to GLI, but it'll verify that the kiosks comply with the GLI-33 standards. That is standard for the industry. That is what we do at all of our other retail books. Hopefully that provides a little bit of clarity, but just so you all are of the understanding, the basis for compliance is GLI-33. So there will not be another standard that the kiosks are held to. Yes, I don't think this should be deemed a big negative here. I think what I'm hearing is that we just need, we're gonna get some more information. Director Vand is that correct? Those letters. And our regulation allows us to have you provide additional information. And there's going to be, as Attorney Nosell points out, the final testing in the operational certificate. So, and also, I think we've made clear today, through a few of my fellow commissioners that they are going to be looking for a little bit more information down the road through our review of the MGM. So is it fair, Commissioner O'Brien, that we say, well, this doesn't meet maybe our very, yeah, sort of, it's a relaxed standard that we, that perhaps it can be addressed through some additional information. Is that in that slide? Yeah, so for me, it's, I don't doubt the representations that are being made that this will be satisfied. But what I'm looking at is sort of these repetitive references to different applications, materials and answers that were not really incorporated. And so I do think this needs to be supplemented with a little more specificity to meet the standard. Commissioner O'Brien, I don't know if it helps. And I hope I'm right about this, but I don't think that we have the certification from GLI for PSI, Penn Sports Interactive, in connection with PPC's category one application. It's more the description. It's sort of like, please go see about MGM. It wasn't attached. And so this is like another example for me of that not being touched. So I'm looking for that to be in this act. We can either defer these until we get to the MGM and wrap it all up. So we have that in front of us or if they could supplement that answer. That's just what I'm looking for. I don't think it's not going to satisfy it ultimately. I had asked, I think at the beginning of the discussion that we not give a final evaluation on the application or at least deliberate at all or take a vote today until we get through that MGM's presentation next week. So is that helpful? Councilor Nozl, I think. I'm gonna have to speak so I can speak a lot and speaker. Yeah, so a few things. Of course we are willing and certainly able to supplement with any information that we can provide and we'll go back and certainly provide additional information and connection with this question that we can and go forward with that. And again, it's difficult for me to comment on your deliberative process. I certainly don't wanna overstep as well and we certainly will respect what the commission decides in order to get these approved and to ensure that we can generally stick to the timeline that we have been discussing and that's been discussed by the commission publicly. Certainly our wishes to get the category one application approved certainly as soon as we can and we're happy to again supplement this answer certainly to try to facilitate that. Well, I think that we are comfortable deferring our decision today to get some more information. We have, commissioner Skinner has pointed out from the start that she needs some more information and I wanna make sure she's all set. And in terms of our deliberative process, it's going to work out just fine, right? Okay, so we'll now go to, we'll go commissioner Maynard and commissioner Kil, I don't wanna neglect you. I changed my view here. Are you all set? I'm all set to move forward. Okay, then we'll go commissioner Maynard, are you all set to move to section G? I guess there's one question that I have on the KYC and I asked this yesterday too and I expect I ask it of almost everyone. Can you just explain the relationship to me between what happens at the window, what happens at the kiosk, what happens on the mobile app and how the relationship is with the data that is shared between these different entities. And again, it also referred to the category three application which I've pulled up and was trying to just figure out what data do you get from one and how does it flow? What I learned yesterday is some of the data flows app to kiosk to window but not all of the data flows the other way. So can you talk a little bit about that one information you get and how you get it? Yes, so Dan, if I'm missing something, please chime in, this is my understanding is that the data is all there in the main database. It's just that our office have an individual who can run the script to pull the information out for the kiosk information, how the patrons are wagering at the windows, whether they redeem their tickets at the cage cashiers, all those data, currency transaction, actual racing sports transaction, online transaction, those will be all gathered into the repository system and then our office have access to run the script to pull the information out. As I mentioned during the KYC presentation, the data aggregation part is happening on a monthly basis and then we apply the threshold per the tier of the Xeno. Actually, I have a meeting with the other my management team to set a preliminary threshold to see how the transaction in the following will that be? But at the same time from there that we do our KYC review. Also, our compliance team has another separate team called suspicious activity reporting team. They are the ones that actually runs multitude of different script to investigate different categories of the transactions to see whether those information need to be reported to the regulators according to the minimum standard or the US Treasury's Title 31 PSA Regulatory Requirement. Thank you. I'm all set, Chair. Okay. Do you need any further direction from us on what we are looking for with destructive technology? President Kelly, because I wanna make sure Katrina's available. I don't know if Katrina's still there, but to make sure that, because we're struggling here a little bit, I wanna make sure that we're asking, or we've been clear as to what will help us understand that the standard has been met. And maybe Commissioner Skinner, I don't know if you're asking that, and I shouldn't just say Commissioner Skinner, Commissioner O'Brien as well, do we want them to fill out the application itself in section half? More specific to MGM Springfield. Yeah, I think part of the conundrum though, yeah, that F3 doesn't appear to be accurate in connection with the CAT-1 necessarily. And so I think that answer needs to be more specific to the CAT-1 retail point of sale kiosk situation. Right, I think that to the extent that, because we all went to the application for the CAT-3, but we're struggling to bring it back to retail. Commissioner, at this point, I think it makes the most sense for us to supplement that. Okay, yeah, yeah, there's no, I didn't want to do the certification letters, I think we have to actually get a response. I know, okay, excellent. Okay, then if everyone's started to move on to the question, this is of course on the final section. I have a couple, I don't know if Heather Hall is on still. So this deals with suitability. I'm here. For the end of the qualifying integrity and also it goes into the financial stability. I don't know if our SM is still available. I see them there and then, so that's Commissioner O'Brien. So Heather, I just wanted to follow up and if you can't answer this in this setting, just let me know, but whether there's any change in Mr. Diller's status in terms of the suitability that we did in May, because there was another proceeding that we were also mindful of. Certainly, there has not been a change that we have been informed about. We have been in communication with the contact person who is handling those disclosures to us. And unfortunately, the person that we were working with unexpectedly passed away. Yes, and but we have made contact with that new person from the law firm that represents MGM on this particular matter. And they are aware of the need to provide ongoing disclosures. We have not had any specific updates to that, to the best of my knowledge at this point. Okay. And then the only other question is a more a broader comment of the entities that are listed as qualifiers in connection with the CAT-1. And it, I'm sort of on the fence about it because it seemed to me looking at the application. I didn't understand why I bet MGM wasn't also necessary as a qualifier, as an entity qualifier here. To some extent, what we were just talking about seems to clarify why they wouldn't be in terms of the technology. But the answer to the chair's question about the interaction on moving the lines and setting the lines and that someone from that MGM might be somehow subject to the way involved and how that's going to happen on the floor in Springfield is making me, if someone can answer the question for me, why they're not, that's not in front of us today as part of this suitability as opposed to discreetly being put in front of the CAT-3 next week for two weeks from now. Certainly. And I hope I can provide a helpful answer in this regard. With respect to the entity qualifiers for the executive summary that the IED provided with respect to the CAT-1s, we simply went with the existing, fully suitable entity and individual qualifiers in summarizing that for you. It is an interesting dynamic and I think we talked about this a bit yesterday in the sense that you have, and of course, if I'm misspeaking in terms of this flow then certainly somebody can correct me, but you have the, in a sense, that MGM as a vendor providing services to the retail and then you have the CAT-1, the CAT-1, excuse me, CAT-3 role as the mobile app. My recollection of the way we approached this was we were going to focus on suitability of the CAT-1 entities that the current suitability and not go focusing so much on vendors at this point because we didn't want to delay things. And we knew that particularly with respect to entities like that MGM and others that are coming before the commission, they would be addressed their preliminary suitability would be addressed in the CAT-3 context if that makes sense. And I think I have that right and I'm certainly open to input and thoughts on that. But I hope that we approach the IEB token and I believe the direction that we were given as well. Can I ask if I could clarify? Is it, was that a decision because you didn't want to delay or was that a reflection of the law? Because of the fact that they were treating current fall under 23 and differently. Well, I think that's a great question. And I think there was part of it in terms of the delay, but that you're absolutely right. I mean, the law does say the commission shall issue the CAT-1 license. And I want to reframe that council home because I'm anticipating all commissioners would be on and executive director Wells has heard me say it over and over. Are we compromising anything, right? So are we compromising anything because of our timeline? And it was never an intent to not defer all because we didn't want to create a delay. It was because of the understanding of the law. So I need to be, I need to have clarification on this. So, Michelle, Brian, you're asking about why isn't that MGM a qualifier to, you know, given for the CAT-1 for CAT-1. And I said that because they were referenced constantly through the app. The idea that they were not going to be in here was confusing to me. Now, the conversation we just had about certification and the point of sale he asks versus mobile clarifies that a little bit for me. But again, your question, when you asked about what it meant to be able to move to that somebody called to it, now I'm like, well, should they be there? Are they really involved in making decisions now on what's going to happen on the floor on this such that they should be in there, even if they're more of a vendor and more of a CAT-3 entity? Can I share those exact concerns? I think this is where I started yesterday. You know, why aren't these retail partners qualifiers? And I had, interestingly enough, I had a conversation this morning with Heather around that very thing. And I posed to her the question, let's say that the statute didn't contemplate category 3 licenses at all. And we just dealt with category 1. Or even better, let's say we have the scenario where the category 1 MGM was not seeking a category 3 partner. But yet, in their retail operation, they are referencing betting MGM. In that scenario, I believe that we would have to look at them as a qualifier. I don't have the answer, but this is exactly what I'm struggling with. This is exactly why I'm confused about what has been put before us in the application. Is it that MGM? Is it MGM, Springfield, that we should be relying on in terms of suitability? I will say about the particular questions in Section MGM around has the license been denied, revoked, or suspended in any other jurisdictions. That question wasn't answered with respect to bet MGM. So if MGM is so significantly intertwined with MGM in the delivery of its sportsbook, I think we need to have some more information. I guess just to speak to and follow up on what I was saying earlier, the way we approached it, in terms of the CAT 1 executive summaries, we did the ownership chain, qualifiers in the ownership chain that the commission has previously found suitable. That is what we did for those CAT 1 reports based on the time frame that we have. We are also doing the preliminary review for preliminary suitability with respect to the CAT 3s. And I guess in essence, we do have the CAT 3s and we are doing that preliminary review, which will be provided to the commission. So I understand your example, Commissioner, but I think in this context, we are in the situation where we are going to be providing information. And from my vantage point, that MGM isn't in the ownership chain of MGM Springfield, but I completely understand your question. Second, Director Wells, thank you, Councillor Hall. Can you shed any light on this when you think about the combined roles that you've been in, this role and my EV director? Yeah, I mean, I think we've had this conversation internally, and I know I've talked to Loretta about this. And Loretta will be back next week if you have further conversation on that with her. But my understanding is that MGM is being basically, in the sportsbook context, is being treated as a vendor. But in the tethered operator, it's being treated as its own entity requiring a licensure. So for suitability, because they're being determined as a licensee, they would go through that further background check. But I understand what the comment is. So for this, I understand what the other commissioners are saying. With the context of this application, what I hear you saying is that there's not a lot of information about that sportsbook operator role as opposed to the mobile operator role. Am I understanding that correctly? That's fair. Yeah. But I think also you're adding light, because I'm no, I am not a step. I am not going to second guess the follow-up process. But from my perspective, I wanted to ask Councillor Hall, I would want it to be about time. I'd want it to be about judgment. And what I'm hearing is that the judgment of IEB is that this relationship is a vendor relationship rather than a qualifier. And if something that was revealed in the application review process triggered a different, or triggered a different inquiry, we would, we always have the flexibility of ongoing suitability to treat an entity as a qualifier. But for right now, Karen, you've said that MGM was deemed to be in a vendor relationship. And that's why we're not seeing it today. Those were my conversations with Loretta, that work. That's my understanding as well. And that's, I think, what I didn't relate earlier. That is my understanding. You did start with that. Absolutely, you absolutely did, Councillor Hall. So, you know, Commissioners O'Brien and Commissioners Kevvie, you may feel more comfortable with that analysis amount of the application. But I'm deferring to IEB. I don't know if I would still have permission. Yeah, what I'm struggling with is almost every answer refers us over to that MGM, even parts of G, saying go ahead and please look at that other application. And so conceptually, while I understand that, if you took that MGM model of this application is a lot shorter. So I'm having trouble with that vendor being that prominent in this and not rising to the level of entity qualifier in this application. And again, I'm not having any doubt that when we get to bed MGM, and that material is in fact in front of us that we're not going to be moving forward. But I think on the four corners of this, I'm struggling with how someone, this prominent in application, critical to the information before us is somehow not a qualifying entity. So I think it's this, again, commissioners, that it's not necessarily so much substantively, although Commissioner Skinner, I agree with you. I'm struggling with that too. If we ask for more information on G to be supplied, that'd be helpful. And then I'm going to turn, of course, to the applicant for the clarifiers here. But would we at least want that, Commissioner Skinner and Commissioner Browning? Yeah, I think that would help. But at the end of the day, I mean, the entire application refers to bed MGM. And so I don't think we're going to avoid ultimately waiting until that MGM's presentation next week before we deliberate on this application. I think that, can we all agree that we know that we can't make a decision until after bed? And I think we all are struggling with that. I'm saying nodding head. Commissioner Maynard, are you in agreement with that? Yeah, Madam Chair, I think I agree. No, I don't think it, I know it. I agree with Commissioner O'Brien on the fact that the four corners is lacking. And I think had we had a little more information, even about what bed MGM was doing, we could at least understand a little more about it. And it's important to understand more about it. But I'm also hearing Heather say that we are going to get this information, at least in some way, shape, or format. So that makes me very comfortable with knowing that we're going to eventually get the information that we need to get make this decision. To be complete, probably you should probably go back through the application where there's reference to the other application. It'd probably be helpful to supply substance. And then also, we will learn, let me sit down with that MGM next week. And then we turn to our CAT-1 deliberations and dispositions. Does that all make sense? We probably should get the submission as well as here from the CAT-3. That's additional work, but work that probably, for whatever reason, just may not have happened. Cher, I just want to kind of make sure we're on the same page in the sense of what information is coming with respect to the CAT-3s. It is the IUB's preliminary review for suitability, which is based on the applicant's submissions and an open source check of the applicant and the individual qualifiers. Just so we're all on the same page about what is coming, it's certainly not a full investigation. But I think everybody understands that. Thank you. Madam Chair, I also want to highlight, I agree with Commissioner Skinner, that we have to get more information on these revocations, denials, anything that's come through. There's no information there. Commissioner Maynard, can I ask for clarification on that? Denials for whom, MGM, or are you talking about the category one applicant that's in front of you today? The question was not limited to MGM Springfield, though it was answered as if it was limited to MGM Springfield. I agree with that. I would like to see it as broadly as possible. And maybe it's that we're spoiled from having seen some other applications where they've went company-wide on this and given us this information, I want the same information here, too. And I think that's a valid point, Commissioner Skinner raised. And for purposes of the applicant, the category one applicant, we did treat this question as applied to the qualifiers, the licensees that you have in front of you. But it sounds to me that you're also interested in understanding that in connection with that MGM. Yes, if that MGM is providing the service for MGM, I am interested in knowing the information. It's also the wording of the answer to be free. Each doesn't incorporate everything in the answer. We asked for this, and the answer was MGM over here. And then please go see the next application for that MGM. So I think it's a question. Again, I don't have any doubt what the answer is going to be, but the answer is not in the answer on the app. Yeah, it's like on one hand. It's MGM's application. And Attorney Nozl, you've repeatedly said that. But throughout, MGM isn't providing any answers to the questions they're referring us to that MGM. Yeah, but we are going to accommodate the commission's need for additional information. As I said before, and if I could just comment quickly on the approach to the qualifier piece and how I think this was scoped, it was really around ownership and control, right? And those are the qualifiers for purposes of suitability. And I don't think that there's really a question as to the suitability of any of them, obviously, because they're ongoing obligations to meet the commission's regulations, and they're currently all in good standing. And the other piece, again, I think the approach and we want to make sure that the commission ends up in a comfortable place. And from a practical perspective, you may get there, obviously, because you've got a parallel process happening. But really this application and its focus on the qualifiers and its plans, of course, relying on a service provider or vendor to do some of that work was the way that we had approached completing the application. We want to definitely supplement that to where we need to and we're happy to. And just so we understand at the end of the day as well what you need for additional information. Right now, I have that in connection with Section F for purposes of the technology piece, which we're prepared to provide that information for, as well as I believe I just need additional clarification on Section G to the extent that there's any information needed from a suitability perspective for MGM, Blue Tarpa, any of its qualifiers. I'm going to go a little bit further, Councilor Nozl. And this is maybe the school doorling me, school arm. If you were in our shoes and you read the application, every time it says go to that MGM, you might want to take your answer that is in that MGM and copy it and put it into the application. I am getting complete literal so that we have an application that when you read it, from page to page, we don't have to go to another application for a different category. And when I read both, I saw there really is the same answer. And many, many times there is the same answer. And I don't know why at one point they just decided I'm not even going to copy and paste it anymore. I'm just going to say just go to the other application. I think when I say copy and paste, that is not to be disparaging. I think it was a complete answer. There are times where I think you're hearing from the commissioners now, it's not going to be the exact same answer. And that's probably where you're going to see F and G and perhaps in some of the others, but I can't guess. But your team knows what we're talking about. It was submitted and in many ways, that makes great efficiencies from your group. It just made it hard for us as we review an application that is before us. And as Commissioner O'Brien pointed out before pages, on floor corners, I mean. So that's pretty black and white. And if I were you to avoid any confusion or just do that. Am I wrong, commissioners? Would you like to see that? Yeah, because I think some of the answers may not actually be. I mean, now that I got the tech part of it to me is a little bit like it's not necessarily referral over to them on the cat one. So yeah. Yeah, I am going through that process, I think to clarify everything. I'm not saying copy and paste of wrong answer. I'm just saying. Right, right. Yeah, yeah. I agree. And it caused problems like for me when I asked my edit my bed and share my bed question. You know, I'm having to divide by four and carry the three. And you know, I'd rather just have it there in front of me. But can I also, Madam Chair, have the floor attorney nozzle each call the question under G for the compliance section says in any jurisdiction. So every call the question says, you know, the questions asked. And then it says in any jurisdiction. And so that's that's as wide as I think we want. This is in any jurisdiction. So I wouldn't limit it to any particular individuals or a particular location. I would do any jurisdiction. Yes, of course, Commissioner Mayden. And again, I think we we did approach that question again, going back to the whether the applicant or its key persons. And I think what we're hearing today is that that is a bit more expansive than maybe we had interpreted. Yeah, especially when it references another application, I would go I would go that broad with it. With all that said, there are many parts of this application that I found to be extremely helpful in today's presentation. To be extremely comprehensive. And for that, I just wanted to express my thanks for any attention you've given to us today, including bringing in Sarah at the last minute to have to to address tough questions without expectation of being here. We're grateful. But that said, commissioners, do we have any other questions or comments on on Section G? And what I'm hearing is that we haven't quite reached a consensus on this one. So that completes the application. Do we have any need to go into an executive session? I haven't heard that raised today. The only question I had is the question I asked right before the break, whether they're in a position to do that in an executive session or simply on in the position to answer the question about the numbers that have been provided to the M.G.C. on diversity over the years. I. I didn't know whether to take the responses. They're they're not prepared to do that today or whether it was the forum. I want to be clear that the company has been transparency transparent regarding that. It's just not appropriate for us to discuss this in public care. So General Counsel Grossman, I don't see a conduit for an executive session in any case that topic. Yeah, I'm not sure that meets the parameters of the chapter twenty three and statutory exemption. And I I don't believe that the litigation exemption under the executive session provisions would apply here because it's not our litigation. Let's if we can think about that since we're coming back to this application anyway and see if there is a viable way to talk about that. But I don't see it on its face right here. I also do recognize that it is there is ongoing litigation. Some respect for that issue. And I know you are too commissioner right. Anything else? Heather, anything else? As your any second thoughts are I think we're good, right? I don't think so. Thank you. OK, all right then. I'm going to put somebody has to speak in in Springfield for me to get you to get your whole group. President Kelly, I'd be happy to happy to do that. Can you can you see us again? I can. Thank you so much. Thank you. I just wanted to make sure that you had a chance to to close, you know, I think what we're seeing is is many of us will ultimately conclude it's more formalistic than substantive. But that form piece is also part of our process. So, you know, thank you for for following up on the information. This is why we have that regulation. Quite frankly, we anticipated that there would probably be needs for some clarifications like this. I mean, is that if they're summary commissioners? Yeah, so I just wanted to thank you and your entire team. So thorough and responsive today. I don't know if you wanted to make any closing remarks. Oh, just thank you again, Madam Chair. Thank you to the commissioners. I thought this was a great dialogue today. I also want to thank again our team that helped with this together. Sarah has been on to this the whole time. Thank you for playing an all-star role here in the closing meetings, but also for the dialogue around additional follow up items. We understand and appreciate the ask and think that this is part of what the process has been from the beginning, which is a you know, a fulsome and appropriately so attended process. So we appreciate the opportunity to participate. We'll follow up appropriately and and look forward to continuing the conversation. Great. Thank you, commissioners. Any any final questions or comments? Now, just to thank you to everybody, Sarah and everybody over in Springfield. Been very helpful. I'll set commissioners. OK, then this is a public meeting and to adjourn properly. I will meet a motion to adjourn from like all commissioners. Move to adjourn. Second. Any further discussion? OK, thank you, everyone. Once again, Commissioner O'Brien. Hi, Commissioner Hill. Hi, Mr. Skinner. Hi, Mr. Maynard. I vote yes. Thank you, everyone. Have a good rest of the day. Five zero. Thank you.