 No, we're all set. We are all set now. Excellent. Okay. Good morning, everyone. This is a convening of the Massachusetts Gaming Commission. And because we're employing a virtual platform, I'll take a roll call. I note that Commissioner O'Brien will be joining us probably just around 1030 or so. So good morning, Commissioner Hill. Good morning. Good morning. Good morning. I'm here. Thank you. Yes. Good morning, Commissioner Skinner. Good morning. I'm here. Right. Thank you. And good morning, Commissioner Maynard. Good morning, Madam Chair. I am here. Excellent. So we'll get started. I think we had meetings every single moment of every single day this week. And so for that, I want to express my gratitude to my fellow commissioners and to the entire team. I know that you're working beyond our public meetings. And I thank you for all of the efforts that are going into not only the work that we're going to be discussing today, but the varied work that we accomplished over the course of this past week. We are not bored, certainly. So we're going to get started today is November 17, public meeting number 403. We do have, I'm calling the meeting to order and we do have some minutes, Commissioner Hill. Madam Chair, I would respectfully request that we do these at the end of the meeting. And I will remind you, I always want to make sure the other commissioners don't have any issues with what we have put forward. And knowing that Commissioner O'Brien will be joining us a little later, I thought maybe we could wait in case she has an issue. And I think that's right, because I believe they these these minutes do were which was going to you were here for those minutes. So great. OK, good. Fine. But do remind me. I will. And thank you for that request. Thank you. Thank the legal team for getting them ready. Excellent job. OK. So we have a good number of regulations to turn to. Todd, I think we can go right ahead with the the racing. Commissioner O'Brien was particularly concerned about for B that we address, perhaps the issues around minors when she is here. Let's see how we how we proceed. And then we'll talk about reordering if necessary. OK. OK, good morning, Madam Chair, commissioners and all. And we're going to jump right in and associate general council, Judy Young will take the first one. This is for a on the agenda. Good morning, Madam Chair. Good morning, commissioners. Good morning, Judy. All right. So coming before you today, we have excuse me. We have 205 CMR 2.01 that is the application for a license to conduct a racing meeting by a new operator. This is coming to you for a vote of finalization. The first time it came before the commission was on September 15, 2022. As previously stated, this is an entirely new regulation aimed at codifying various points of 128A that pertain to what an applicant who is seeking a racing license must submit to the commission. So essentially, this regulation is intended to call together that information and provide a little bit more clarity for future advocates. I'm happy to walk through the regulation with you or screen share at your preference, commissioners. I just think we should mention that we received a public comment from this. Yes. This has assisted in her comments in the past. Did everybody have a chance to see that comment? It is in the packet. Yeah. And I love screen share in Judy. So share would allow that to happen. I would be grateful. That would be great. Very good as we walk through. All right, certainly give me just one second. All right, let me know if the size is all right. I can make it bigger or smaller at your preference. Good. OK, I see a thumbs up from Conditioner Maynard. OK, so here we have the entire regulation. I do want to point out just a few things that are helpful as we before we kind of get into the comment that we received. Section one states the requirements or enumerates them in the letters, but beneath and below. And it also allows the commission to require specific information from the applicant, but specifically states that this is not all that we can require from an applicant and allow them to submit. So it's kind of the floor and not the ceiling. So to speak, commissioners. So starting first with the name of the applicant, a three a three hundred dollar licensing fee. One thing to note is that within MGL 128 a section four, there is another calculation for licensing fees, but it's not listed here as the other licensing fee is for applicants who are seeking renewal and it uses a very handy calculation of of the previous year's racing handle. So that's why it's not listed here, but applicants seeking a new license simply pay three hundred dollars is a flat fee. Moving on, we ask for the location of the race track calendar year and days in which an applicant wishes to race the hours of the day. All of this is pulled from specific places within 128 a feasibility study. And notably as the comment that we received, the approval and information of local support here in 128 a section 13. Moving on to section J. We ask the applicant to discuss and share the evaluation of suitability and qualifiers similar to what we do for gaming and soon to be sports wagering licensees down in section K. We ask for information relative to the public interest and benefits association with a racing meeting, including first represent purse agreements, agreements with horsemen's associations, local support and any sort of intention that they have of working with. MBEs, VBEs and WBEs. Next, we go on to request information relative to paramutual wagering and simulcasting. And then lastly, an attestation asking the applicant to comply with any licensing requirements that the commission bestows upon them. An affirmation that what they're saying is true and that they intend to abide by every statement and promise that they have made in the application. And lastly, in section N, similar to section one above any other additional information that the commission can prescribe. So this is within the statute as well. But we did want to include it in the application here. Notably, just if there was any other information that the commission wished to receive from an applicant, an applicant is aware and not kind of caught flat floated or surprised that the commission asks for more information. So with these two statements or with these two areas here, both in one and N, we do feel that this regulation is is ready to go forward. We appreciate the significant public comment that we received from Mrs. Kellogg, however, we are confident that we don't need to necessarily propose changes to the regulation as it as it lies, as the commission can ask for more information many times throughout this process. Questions, questions for Judy. All set. All set, Maddox. Thank you. So my what stood out to me in the public comment was the reference to the October 1st deadline and the suggestion that the commission require the applicant to have satisfied all of the legal conditions precedent prior to that deadline. And so that may require further discussion among commissioners and further analysis among the team. But I think that that is something that we should be paying particular attention to going into this next application season. I think Commissioner O'Brien also suggested that we take a look at that. So I just want to make sure that we don't lose that in this in this regulatory promulgation process. Certainly. And I think that that is that is definitely a fair consideration. And I would be willing to table vote on this if we did want to wait for Commissioner O'Brien to kind of rejoin the meeting and we can discuss that portion, Commissioner Skinner, or bring it back at a later meeting. It's ultimately, you know, you're just your decision, Judy. Did is, you know, is including that requirement? Is this the set of regulations where it would go? Or is there another regulation that it might fit neatly within? Well, completeness is mentioned within the statute, within this regulation, within the first couple of lines, as well as 205 CMR, 14.02. Give me just one second to double check that reference. 14.01 that pertains to supplemental procedures for licensure for horse racing applicants. And so within those three areas of law, the commission specifically has the discretion to deem an application complete based on what an applicant submits. However, within 14.01, I'm happy to pull up that site for you so you can have a look at the language commissioners. The commission does have sorry, I'm getting a cat on my lap. The commission has the ability to deem an application for a license complete as of the first date it's filed, but also has that that ability and authority and discretion to require applicants to continually submit more information before deeming an application fully complete and ultimately awarding a license. So this is kind of the power to just request more and more information. But ultimately, I do feel that there is probably some discussion that the commissioners would like to have regarding local approvals and 13A in regards to the licensing process. So I'm definitely willing to wait for Commissioner O'Brien if you would like to have a deeper discussion. Commissioner Skinner. Well, I defer to the chair and my fellow commissioners. I am just one of four right now, but I would suggest we do wait and hold off because, you know, we have had some unusual events over this the course of the past couple of weeks as we reviewed the new application that that was submitted. So I would suggest we hold off, but I, you know, would like to hear from my fellow commissioners. I think that the regulation and the regulations that we've been working under have covered us in terms of how we have managed the matters before us now and would give us the flexibility to address the applications that could come to us in the future. And as I understand it, do we reflect the statutory mandate? I I'm happy to wait for Commissioner O'Brien. I'm just also very cognizant of the fact that I want to keep things moving. I don't know, Commissioner Maynard, Commissioner Hill, do you want to weigh in? I think I saw Commissioner Maynard raise his hand first, so I would defer him at this point. I do think that. Thank you, Commissioner Hill. I do think that it's a significant issue that the commissioner just raised about the fact that we will want to do something going forward with the deadlines. I do think that this regulation captures that. And I was also under the understanding yesterday in scheduling when Commissioner O'Brien was discussing her availability today that that this particular regulation probably could move forward. But maybe I misheard her when she said that. But I do I do share Commissioner Skinner's concern about next season, but we do have the current season in front of us. And and I think there's enough there's enough flexibility in this regulation to do what we're trying to do and do what Commissioner Skinner wants to do, too. For clarification purposes, my request isn't to necessarily wait for Commissioner O'Brien. I just am more looking for a substantive discussion as to whether or not we should include language as we're reviewing this regulation today that speaks to the October 1st deadline and whether the legal condition precedent that local approval be obtained should be included as an amendment to this regulation. And if not, and if not, if we're not prepared to to discuss that in depth lead today, what would be the process whereby we are communicating with the public that there's been a change to prior process? How how would we communicate that if we rely, Judy, on the language that you referenced earlier, that gives us the authority to set parameters for application submission? So I think that the Commission, I feel I definitely don't want to feel like I'm beating a dead horse, but the Commission does have a large amount of discretion and authority here as we prepare for an upcoming racing seasons, we will go through the exact same process that we did in previous years. So we will bring forth a racing application for a new applicant again. And within that racing application, we can we can add additional language or questions for applicants to answer, hopefully a little bit earlier and providing them a bit more time. But also we can ask and I'm trying to find the exact section within our racing application now while I speak, but we can ask them if they have certain levels of approval and we can go beyond a yes or a no, but also require more information from them if where they are in the process. If they aim to have local approval, what what sort of a thing what sort of things that they've already achieved. And I think within that application and utilizing these regulations, again, the floor and not the ceiling, I do think that the Commission will be able to receive enough information prior to submission from applicants, but again, requiring more before that final deadline of making a decision. You may, may I? Thanks, Judy. May I just add something? Absolutely. So I think procedurally where we are on this reg Commissioner Skinner is that the vote today is a vote to finalize it. So if you vote on it today as is, it will be finalized in this form. It will take a little bit of time for it to get through the process because racing regs go to the legislature before they become final. So to the extent any revisions, the Commission wanted to make any revisions to this reg in the future, it might be best to wait until this version is finalized and then sort of bring it back for revisions. And we can kind of go through it again at that point. That's one way to do it. Another way to sort of codify the thoughts that you're talking about of deadlines for a specific, statutorily required elements would be to do it in a revised application. So we could either bring this reg back in the future and revise it or amend the application. Those would be my two suggestions. Does anybody have a memory of Commissioner Bryant asking on a public record that this be tabled? This reg be tabled all together? Yeah. Madam chair. Yes. I think I was thinking the same way Caitlin was thinking, to be honest with you, I think there's plenty of opportunity for us to make revisions with the process moving forward if we were to be able to vote on this today. So I am of the feeling that we have discussed this regulation quite a bit over the last few months. The legal team has heard what we've had to say and they've made the changes, I think, in a very good way for us to be able to move forward today. But Commissioner Skinner, there will be opportunities for us to be able to make revisions, should there still be concerns moving forward? And I think it's one, two, or maybe even three different steps throughout the process that will make that happen or could make that happen if we need it to. I think there's plenty of opportunity to bring this issue back up again in the future and to make changes. I'm ready to move forward with this one. Mr. Stader, I wanted to make sure that I had missed anything that Commissioner Bryant had raised. I would would follow the recommendation of of Councilor Monaghan and and take the advice of Councilor Young that we have that discretion under the statute and that if need be, maybe does it, if that will work for you. It does work for me, given, again, as you noted, the advice of Council, I am satisfied that we will have another opportunity to address this issue. Thank you. Madam Chair, if anything, I've learned through this regulation process over the last six weeks is that we can always bring back any regulation should we see that there should be an issue that we could change. And I believe we did one within a week, a few weeks back. So I'm comfortable with moving forward. I think it's fully promulgated. We always have the right to amend and that means more work, I suppose. But, you know, that's Rag Review and Rag Review can start the day we finalize. You know, it's because we get smarter every day. So I appreciate that, Commissioner Hill, and I appreciate the legal team chiming in on this matter. With that said, do I have a motion on this particular you want a motion? Correct, Judy, are you at? Yes, Madam Chair, we are seeking a motion today of finalization and approval. However, I just did want to clarify, as Caitlin mentioned previously, because this is a racing wreck, it will go and be filed with the clerk of the Senate for approximately 60 days before becoming finalized and filed with the Secretary of State. So we estimate that this regulation will become final sometime in mid January or early February 2023. I'm ready to make a motion, Madam Chair. Thank you very much. I move that the Commission approve the amended small business impact statement and the draft of 205 CMR 2.01 as included in the commissioner's packet and discussed here today and further that the staff be authorized to take the steps necessary to file the required documentation with the Secretary of the Commonwealth to finalize the regulation promulgation process. Second. Commissioner Maynard and then we'll other any questions or edits on that. OK, Commissioner Hill. Hi. Mr. Skinner. Hi. Mr. Maynard. Hi. So for zero, I'll. Thank you. We're all set on that one. And then you'll just keep us surprised on the legislative review. Again, until we have Commissioner O'Brien here, we will skip over the minors. Legal team and and I guess attorney Karius has turned off his video, but does it make sense? I'm trying to imagine what Commissioner O'Brien would be most comfortable with us addressing as a team of four rather than a team of five. Um, I don't want to put you out of order in terms of of, you know, the the order that is set forth in the agenda, because I know that it was intentional. Is there one? I had wondered if the operation certificate was one to go for. Madam chair, I was here and listen and listening. I'll defer to Todd and Katelyn, but I do know it's 1026. So if if you want us, we could start talking through any of them. And I believe Commissioner O'Brien will join shortly. But my operations make sense to go first. Todd Katelyn, do you disagree? I think that works. Yeah, there I don't that's as good a one as any, I suppose, I guess would be. I also believe we're not asking for a vote today. Katelyn, correct me if I'm wrong on definitions so we could talk about the overall approach to definitions, perhaps as a starting point. Yeah, let's go with definitions. Thanks. Great. And then let's go back up to occupational licenses. I think that she should be part of the discussion. Chris, are you agree with that? OK, thank you. All right. So I'll give a quick introduction about the definitions before I turn this back over to Mina. So as you may remember, the commission voted to promulgate a definition section by emergency a while ago now. And so it's been moving through the emergency promulgation process and there will be a final vote on that regulation on December 1st. In advance of that final vote and with when there is still time for some public comment, we wanted to make a few tweaks to some of the definitions and add a few definitions now that we've promulgated additional regulations. There are additional definitions that we'd like. So that's what we're bringing forward for you today is some additional definitions, some tweaks to the definitions. And what we're asking for is not actually a vote on the reg itself, but a vote for your approval to post this revised version of the regulation on the website for comment before we bring it back to you for final vote on December 1st. That's a little complicated, so if there's any questions on that, please let me know. But otherwise, I'll turn it over to Mina to walk through the changes. I think, Mr. Keras, we're starting on we did the red line. Is it packet page 160? Right now, the red line is at 160. Yes. OK, so if there's no questions on the process, let me just briefly explain what we did here. This is probably not one that lends itself to telling you about every single red line. But what, as Katelyn mentioned, we had done the emergency regulation initially to capture definitions that were needed for some of the first batches of regs that went through vendor regs, in particular, and then some of the licensing ones. As we've drafted a few, you've probably gotten sick of us saying that's a defined term that you'll see in 202 when we revise it. So here we are. These are some of the defined terms in 202 are added here. We also took the opportunity to add in the remaining definitions in the statute that are going to be defined with references statute in working with with GLI. In the background, we'll continue to work with GLI and the Legal Department and NK to make sure other definitions in additional regs come up. But these were the ones that are sort of ready to go at this point for public comment. Key ones that I will just quickly cover that are not purely just defined as in the statute. I'm sorry for the interruption. I'm going to ask that you share your screen, I'm only working with one monitor today. It's OK, let me do that. And let me try to do that without messing everything up. So give me a second. Thank you. Otherwise, somebody else can share the screen. Legal, perhaps to help out Mr. Macarius, page one, one sixty one. Yeah, I mean, I'd be happy to do that if that would be helpful to say the word. One sixty two. We got it. OK. Yeah, I got it. That should be good. Just making sure you weren't getting anything else. That's that's just need to increase the font if you don't mind. Let's see. That better. Thank you. OK. All right. So some of the key ones that are added here and sort of where they come from annual assessment, this has to do with the licensing and and upper and fees for investigations. This is the the way that the sports wagering portion of the budget gets covered. It tracks the annual assessment process under gaming. Most of the other ones on this first page, you'll see are defined with reference to the with the statutory definition. House rules is not defined in the statute, but is described in twenty three and section ten. And that's where that tracks the language and how it's described there. The we get some of the more interesting ones, perhaps on this next page, where we define throughout we've had issues, as you know, trying to make sure we define the different ways in which sports wagering can be accessed. One is a mobile application. This is a definition developed in part with the experience from Gli and a little bit of wordsmithing, but the idea is to keep it broad for us. A mobile device, that's a mobile application division, excuse me, definition. The operation certificate, this definition is almost identical to the one in in the one one hundred series. It's a certificate of compliance issued by the Commission to an operator. We have a generally speaking, we have not, you know, cited back to other regs in the definition, unless absolutely necessary. So that's why you don't see a reference to the two fifty one here. But that is that operations are difficult. The going down the list, again, a bunch of these are just coming from the statute. Qualifier is a term that now appears several times in the suitability process. And the the the the sports wagering vendor and occupational licensing process. So that is where that is where that's the case. We've wanted to capture it here as well. And the two that I would call or a couple that will call your attention to sports wagering area. And then I'm going to just scroll down a little bit to sports wagering facility. You may be wondering or we have seen some questions internally as we talked about that do we really need both and what's a distinction. And the distinction is a sports wagering area is intended to be the area of a gaming establishment or ready licensed under twenty three K that is used for sports wagering. A sports wagering facility is a is a sort of standalone sportsbook. So they're both in person wagering. The reason for the distinction has to do with language that was changed and is proposed to be changed in some of the one hundred series regs to clarify the bureau or the commission's authority for enforcement over certain aspects of the facility or recall that we of excuse me of gaming establishments and in areas where for instance when we get to a surveillance rank, we are saying we were likely to suggest that gaming establishment has to be able to capture not just the gaming area but areas where sports wagering is happening. That's where this definition sports wagering area might come in handy, even though it might be within the gaming establishments, physical parameters. So that's the reason for the distinction between the two. It also is attempting to address in part the conversation we had last week or the week before about access to sports wagering equipment within an area, for instance, at Plain Ridge, if it were set up that way. Madam Chair, may I interrupt for a moment? Yes, thank you. Meena, I think you minimized your screen and I'm only getting half of what you were showing. I apologize. You know what it is? Yeah, you would just have the yeah. And now if you could just expand a little bit, you know. A better thing. Yeah, much better. Thank you. Sorry about that. I can't see what you're seeing. I'm on your end, unfortunately. If you increase the font a bit, I think it says two hundred. I think it's because there's something on this. It's because it's a red line or something. That's why it's still small, but it's good. Yeah, it's good. Thank you, Madam Chair. And Meena, you're welcome. So did you get a chance to see, Brad, if you scroll down, Meena, he'll see the sports wagering area in sports wagering. Yeah, but here's sports wagering. Facility, though. That's facility. Sports wagering areas up here, unfortunately, it's just on different pages just because of the order. Yep, I got it. Thank you. I see area. I just don't see facility. Right. They're on different pages, so I have to show them separately. That's all. So why don't I just read these two out loud? A sports wagering area means a part of a gaming establishment operated by a Category 1 sports wagering licensee for in-person sports wagering. That's a and then on page 162 of your packet at the. Is sports wagering facility, a facility operated by a Category 1 sports wagering licensee category? Sorry, Meena. That's all right. I forgot the F follows A. Thank you. Well, I'm just glad it did. That's that that's actually a copy now. Thank you so much. That's OK. There's also in here a definition of sports wagering kiosk, which is a fairly straightforward definition, but again, necessary to explain what these things are because they pop up in the ranks quite a few times. And and it's it's it's a self service facility. The last key definition here is sports wagering platform, which is a broader definition than a mobile sports wagering. Obviously, that would include a desktop platform or website, etc. I'm not sure if this will be the only place in the entire CMR where the word widget is used. But if so, we'll be proud to have it started into the lexicon. So. Meena, I might flag sports wagering vendor the slight change to that. Yes, I'm sorry. Thank you, Kailin. Yes, slight change to sports wagering vendor, helpful comment from folks at GLI and also in the process of amending the two forty four. Right. That the testing or certification labs are not exactly sports wagering vendors are certified separately as testing facilities. So it didn't make sense to include them here. Of course, if you recall, within the sports wagering vendor regulations, there is a catch also for if for whatever reason, there is a vendor who's doing a peer review or something else and isn't going to be licensed under two forty four, which I think we're going to come back to in a little bit, too. If they would get captured that way, if necessary, but it didn't make sense to have them as a presumptive category here. Thank you, Kailin. Tell me less the question about that and it's very spontaneous. So forgive me if it's not well thought out. But, Commissioner Maynard, you raised the issue during our round table or or or. What's wagering vendor? A vendor under our statute as an office, it's always under the control of the operator, correct? As an agent, regardless of how we whether it however we. Seem it for purposes of suitability. A vendor would be under the control of the operator. And the reason why I'm asking this, you also have down some of the types of services, one of the concerns we have with respect to advertising and marketing. And I know that we did address that third party marketing piece that Commissioner Bryan has raised in the past. We want to make sure that vendors have to comply with our expectations around advertising and in marketing, particularly around social media. And. I know this is just definitions, but I'm marking this as an issue that's come up. I feel like we covered. We have, Madam Chair, we talked about this a little bit. And I believe this when we talked about two thirty four, I know we talked about it as a drafting team quite a bit. It is a third party marketing entities are listed here because we do imagine that there may be what we don't want to have happen is for an operator to say, well, we're not the ones putting the ads out there. We give our, you know, our content to a third party entity and they buy ads and do whatever else for us. And so, yes, the vendor would, if they're in, if they meet the other criteria for regulation in two thirty four may need to be licensed or registered as a vendor as well. And in addition, because as you pointed out, all of this assumes at least contractual control, if not more so from the operator, if they are not controlling their vendor in the sense of having them comply with whatever marketing requirements you end up having, that would be, you know, that would ripple back onto the operator and the vendor as a violation. That's really tough when we have questions from you on that point. I know it's a little bit outside of definitions, but so it would be, I know, get the third party marketing and it would include any vendor that has any control over any lists. They are, the operator must make sure their vendors comply. It falls back to the operator. Correct. Yeah. And this, I don't want to go too far down this because I think one of the next steps from the roundtable is going to be what the commission's desire is on sort of how to guide the, what to do on marketing controls. And one of the questions will be how to make sure it actually happens. And what's an adequate level of operator control over advertising. So the definition, back to definitions, a vendor is broad enough to capture those concerns, correct? Correct. Thank you. Thank you. Are you all set on that? Thank you. Thank you for raising that. You all set commission. Stay here. Madam chair. Is there any language that you're thinking that we could add to that definition to. Ensure. I mean, I know it's brought up in other regs, but here we have a nice list. Can we add anything else to it? Yeah. I think with the discussions that we've been having, I'd like it to be a little more clear, but I'm also not a, I'm also not illegal legal. And maybe this language does that. I don't think it hurts to spell it out. Right. I mean, this is not, yeah, it's not limited to, I see that in the language. So obviously it's not an exhaustive list, but it does make a statement that we are. It does make a statement that we are concerned about it. Because I think all of us has. Have raised that concern. Commissioners Maynard and Hill, I, I think I just want to be clear on what we'd be adding. Because I think the third party marketing entities is, is very broad. We could certainly add third party advertising and marketing entities to make it, you know, in case there's any distinction between the two words. I don't know if that would catch for somebody, but I think when you're talking about how, how those entities start operating, I would be hesitant to put it in the definitions here. For instance, just to use one of the examples, I think the chair brought up is a social media marketing. And I imagine when we get to thinking directly about how that's regulated, we'll have to address the issue that my colleague Christina brought up about the communication decency act of how far we can go to regulate third party content on social media. There may be some things where we can, we can say the operator shouldn't be pushing out stuff. But if, if, how much a third party that they contract with promotes, you know, social discussion of it, we'll have to just think about more. So that's, so I guess I would rather keep this category broad to not accidentally make it seem like we're only focused on one piece, if that makes sense. And then address it when we're going to get a body around advertising and marketing. Yeah, although the word advertising, if that, if that feels like it's a big problem. Yeah. If you would be okay. I would love the word advertising as part of that. I mean, or if you think it would be okay to do. I don't have a problem with that. And Todd, I assume not either. We could just add that in. So, I mean, this is commissioner, Brian. My only thought on that is to do an and or. So it doesn't look like the entity has to be providing both to fall within the list. Can I just make it an or out of. Or yeah. Yeah. Well, it's not so much a word count. It's not a word count. It's not a word count. It's not a weird allergy to and or that we can talk about at some point from, from my own legal mentor. Yeah. So no, I, but we can certainly do that. We're sure. Brian. Welcome. We, we have had a bit of a discussion around the force racing and it did pass with the idea that. Should we desire and then was down the road. We'd be able to make that. So we're, that will now go to the legislature for their review. As you know, with respect to force racing was very saying we have that additional process. So. And, and. Judy and Caitlyn can bring them to date on that. So. Welcome. Good morning. May the record reflect that she is here. If there's nothing else on the vendor definition. Can I move on to some of the remainder of this one? Thank you for that. That's really helpful though. No, thank you. Thank you for the helpful discussion. As always, it's good to have it and understand what the thought processes on it. Last. New definition that is not a 23 N. Repetition here. This was suggested. By GLI as, and again, this one is not one that you'll see used just yet, but it will come up as we start thinking about house rules and some internal controls. Different categories of wager may come up and they. They're this definition just is intended to capture that also includes an example, which is done sometimes as a way of clarifying in the CMR. I think it makes sense here. So. So that's it for the definitions. As Caitlyn said, the outset, I don't believe we're asking for a vote today other than a vote to publish this with the one edit that we discussed. For public comment as, as, and we'll obviously also be keeping an eye on this list as we go forward with other wrecks. Any questions. Madam chair, I have a process question. I thought we needed to take a vote to move these forward to the public. Am I wrong about that? I think it would be helpful to have a vote. I think it would be helpful to have a vote on the final reg or anything like that, but it would just be a vote to allow us to publish it in this form for comment. And then we will bring it back to you on the 12th on December 1st. So this mean accommodates our desire to just have the public way in if we vote. And then. We could react on December 1st. Does that work for you? And then. Absolutely. Yes. Yeah. Great. Great. I would give you the definitions of you have any questions for me and seeing that you came in. I don't know at what point you. Join the conversation. I came out at 10 30 pretty much on the dot. No, I might understand meaning correct me if I'm wrong, but these will probably be revised necessarily as other regs are rolled out. Right. The definitions. Not necessarily striking what's in there now, but potentially have an ad. Right. But they aren't there are terms right now that are haven't been used so they're anticipating as well, which is great. Right. Okay, excellent. So commissioners that you have no further questions on this. Do we have a motion. And I'm chair. I just have a process question please. Or more of a statement. I think the practice of voting. To allow these regulations to move forward. By posting on the website is a new process. I understood, correct me if I'm wrong, Caitlin and Todd, I understood that the regulations were being posted on the website as they were drafted to allow public comment so I'm a little confused as to why for this set. You're seeking a vote to post on the website. Sure. So these have been posted. So when these, these were passed originally in a sort of shorter format. They were posted when they, when they passed initially they've been up for public comment, and they're moving through the promulgation process to a final vote on December 1. Because of the emergency process because of what we're doing right now we wanted to make some changes to them before the final vote on the first so this is almost like an interim change. That doesn't require a final vote or an initial vote, but we're just seeking your approval before we change it and put a revised version on the website for further comment. Thank you. That that's helpful. Thank you. Next clarification. Do we have a motion. Adam chair, I would move that the commission approved to post for public comment, the draft 205 CMR 202 as included in the commissioner's packet and discussed here today. Second. Thank you. Any further questions or edits. Right. I'm sorry, I didn't hear you. I was okay. I was sure if all of a sudden you were on mute. Yes. We recorded your eye and then commissioner Maynard. Hi. That's five zero. Thank you. Your microphone, madam chair, your microphone may be coming in and out a little like Karen's does. Thank you. When you move back ever so slightly, I think it drops. I think I can change it. Let's see. And Mills, you can let me know if I'm doing this right. Got the ego cancelling speaker session on both. Let me know. Thank you because it can be, it can be a little bit of a challenge. All right. So then I guess then we could go back. Does it make sense to go back to or be, now legal Todd. Yes, that sounds good. One moment here. So we're on to. Two or five CMR 250. This is the protection of minors and underage youth. At the top of our packet. I'm using that. Page 28. After the memo. I think that's, that's correct. Thank you very much. So the, just by way of a refresher, I'm going to go back to the slide. I just didn't come before you once before November 10th. It's back. For further discussion. Without further ado, I think I can turn this one over to Dave and Annie lead from and K to discuss these particulars. Thank you, Todd. And so just to recap this for everyone, these were the regulations that we previously presented last week on page 28 and 29 and 30. The content of the regulations is largely unchanged, except for sort of two major edits. Or not major, but just two edits that should be apparent to you on pages 28. And 29 and 30. And so the first one that you'll see on your screen is that to address concerns about kiosks getting placed in sort of bars, specifically the example that we were looking at. So we have a wonderful horse racing facility wants to put kiosks at the bar. How do we prevent minors and underage youth from engaging in sports wagering in those scenarios. And so we've expanded 250 111 to include the prohibition of placing a bet at a sports wagering kiosk. And then with to, to sort of conform the rest of the section, we also included in 250 one subsection two, a provision that the written policy that sports wagering operators will submit to the commission for approval will include specifically a policy practice or procedures that are designed to keep minors and underage youth from engaging in sports wagering at these kiosks. So that was the first substantial change. The second one is if you move to the packet pages 29 to 30, we removed 250 five, which we had previously added to mirror the sanctions provided in 133 and 233 regarding sanctions against a sports wagering operator for violations of the voluntary self exclusion regulations. After some discussion with the IEB, we came to the conclusion that this section is better left out to afford the IEB the same discretion to enforce underage minor and youth prohibitions in the same way that they're enforced in the gaming context. So we understand that in the gaming context, the IEB has a discretion to evaluate sort of the severity of sort of the offense and the corresponding sanction based on a totality of the circumstances. And in order to allow the IEB to enforce these regulations in the sports wagering context in the same way that they enforce them in the gaming context, we thought it was best to conform these sections and just remove 250 five since that had never appeared in 150 five. Annie, I had wondered about that. I, I feel as though there is a conflict between the two statutes that the sanctions can be imposed by IEB. And there's a whole process on a 23 K where that process is for sports wagering is actually addressed to be by statute of the commission to do the sanctions. And that's actually a somewhat significant because the current process, if the party that's having a sanction imposed on them agrees with the sanction with IEB, they can no longer appeal to the in commission or and then ultimately accord. And so the fact that the sanctions are to be imposed by the mission for sports wagering means that we would, I would assume we would use IEB for investigatory purposes and analysis, but that the first stop for the sanction would begin with the commission. But I might, I haven't looked at those provisions for a bit in the statute. I might be wrong. Dave, do you, do you mind addressing this? I wonder, it may make sense to have director Lilius weigh in here because what we've tried to do is make the IEB's authority with respect to underage sports wagering mirror its authority with respect to underage gaming and a gaming establishment, which based based on feedback from the director, you know, she was content with the mechanism they had in place there. I always welcome director Lilius is, I think that makes sense, but I think that the sanction that we could rely on them in the investigatory process, but the sanction itself would be imposed under 23 N regardless of whether it's a minor issue or otherwise. Let's start with the commission. Chair, if I may, I think the edits that were done in this version of the reg primarily meant to establish the standard for infractions for underage. The prior version said that in order to amount to a violation, there had to be a knowing and reckless standard. The standard that the IEB has used under 23 K has not required that high standard of proof for the high standard of proof. It's more like any explained, a totality of the circumstances standard requiring substantial evidence in the end of the of the infraction. The question you're getting to chair of whether the enforcement mechanism under 23 N can be delegated to the IEB or must rest with the commission. There's a lot to unpack there. And we have already, we have on our agenda setting as under review that question with respect to vendors. And it's my suggestion that this be visited. You know, that authority, the enforcement authority, which implicates also for the licensee, what type of review the licensee would be entitled to, you know, if the commission is the primary enforcement mechanism, the next layer of review then would be the superior court as opposed to if there were internal agency review with a hearing officer, you know, then review by the commission. So that is a larger question. I don't think that is addressed in this draft. I think what this draft is intended to do is to address that standard, the knowing and reckless standard. But this question of the enforcement mechanism and whether, you know, what use the commission will utilize the IEB for is a matter that's under review with respect to vendors and is a, you know, I think the same issue with respect to the operators. Can I ask in the statute with respect to the standard is where did, where was the language knowing and practicing? It's on the gaming side with respect to violations of voluntarily and involuntarily excluded persons. So that was lifted. So if the, if the operator lets a VSE in a knowing and reckless standard has been applied, same with an involuntarily excluded person, minors were treated differently. So a minor is a higher standard or a lower standard? The standard of proof for the IEB is lower. We do not have to prove for minors that the operator knowingly or recklessly allowed a minor front of the premises. Okay. And just to add there, we, oh, excuse me. I guess my only question would be, sanctions have been taken out of this particular bag. Things just need to eliminate that at the top, but that we're going to be addressing sanctions. I didn't know it was tied into the vendor issue. But I do think that the commission needs to have, you know, be really well informed as to the 20, the difference between 23 men and 23 K. And I think commissioners, you should be aware of the fact that it is treated differently. This is certainly an issue that has come up in the course of my three years as to the process. So, you know, then I guess we stay tuned to the different red altogether. Yes, that's the plan. Thank you. All right. The only other thing I wanted to point out there is the very first paragraph. And I wanted that inserted when I was reading it because there's the possibility you might get someone over the age of 21 who's allowed to go in and sort of test software and that sort of thing in any of these apps or kiosks and looking at the language in 150 trying to make sure nothing was going to get left out, wanted to make sure that there was no backdoor for anyone under the age of 21 to have a claim of being in there appropriately and then betting. So while the chance might have been miniscule, I think that word was put in there to make sure you could have somebody under 21 who's actually on the tech side working and testing these things, but it was going to protect a backdoor avenue to argue they had the right to be there. All of the other things I think now sufficiently address the concerns that I raised last week on this and particularly the striking of five and putting in a different section because I think trying to merge the BSE standard into this was not going to give us the result that really was going to be warranted and to protect the minors that we're looking for. So I thank the team for the work they did on this in the week in between. I think it was necessary because I think it's in a much better spot today. Excellent. So are there any other questions then for Annie or the legal team or Mr. Mackey? I guess I have a question, Chair. How did when 250.05 when it was drafted, what was the, I want to understand why it was drafted and why it was taken out because I wasn't subject or privy to the conversations on how it was drafted or how it was taken out. So I'm interested why it was drafted the way it was when it was put in and why it was taken out. I just heard Commissioner O'Brien explain a little bit of why it was taken out, but I don't want to abrogate any authority the legislature gave to the commission and there's obvious differences in the statutes. If the legislature would have wanted to control C, control V, they would have done that. They didn't. So I want to make sure that our regulations do match the new statute. And Commissioner Mater, I'm happy to provide a little bit more context on why we initially drafted this. So we initially drafted 250.05 because as you'll recall, we were drafting 233 on voluntary self-exclusion and the protection of underage minors and youth from sports wagering at the same time. And so looking at both of these regulations is sort of the responsible sports wagering regulations. When we were drafting 233, we sort of thought about what would be appropriate and what would make sense to also include in 250 because 233 includes a lot more provisions than 250 or I should say 133 includes a lot more than 150 since those were the initial inspiration for this. And so when it came time for 250.05, we noticed that there was a lack of sanctions in 250 and in 150. And so looking at sort of the counterpart in 133 and 233, it sort of made kind of good sense to us at the time that to the extent that there are sanctions for failing to abide by VSE obligations, there should also be parallel sanctions for failing to abide by any regulations regarding the protection of underage youth from sports wagering. And so that was the intent was really to sort of conform 233 and 250 as much as possible in the recognition that these two regulations are designed to promote responsible sports wagering. Do you have more to add to that? The only thing I'd add to that, that's exactly right. And then the feedback we got both at the meeting last week and then from Director Lilios is related to that knowing and reckless standard, which I think folks felt was appropriate in the context of BS, voluntary self exclusion, but maybe not appropriate in the context of underage gaming. And so that's why we removed it here so that the ability the IEB had with respect to finding violations of the underage sports wagering regulations would mirror the powers that it had under 150 for regulating underage gambling and a gaming establishment. And Mr. Mackey, I do think we probably need to have regulations that say that the commission wants to have the bureau do the investigatory work because, you know, we're jumping to that conclusion. Again, 23 and the silent. And I don't think any of us are going to question that. But what I am cautioning is that I want to make sure that the full commission as a body of five gets a chance to really discuss the difference between how the administrative penalties are assigned and, you know, how the bureau is involved and the administrative process. I am acutely aware of the administrative process that's used now with a hearing officer, IEB. We have a policy that's going to be adopted by the commission. 3N is different. And that's all my point is, is that we want to understand I hear, you know, Director Lillio say there's a lot to unpack that needs to be unpacked with all five of us, you know, and not just ahead of us, because I want to make sure that the commissioners have, you know, full awareness of the process and the implications. I don't have a position formulated in my mind just to be clear. I just know there's a difference. Yeah, I really need the benefit of a full sum discussion. Fully understood in this version of 250 in front of you now, it doesn't address that issue, it simply addresses the standard that would be applied for determining a violation of the, you know, underage sports wagering regulations. So strictly, and so it assumes it does assume what I said. I'm assuming that IEB is the does preliminary work on these matters. The statute doesn't necessarily assume that. So I'm assuming that the brand that's going to come to us, will somehow address that, that silence that we use that resource. Is that right, Dave? Understood. Okay, great. Thanks. Okay. Any other questions on this? I think I'm hearing Commissioner O'Brien had raised some questions. I think we had a full sum discussion on the issues. I think that they were addressed just as I imagine that they might be with the additional issue around the sanctions. Anything further? All right. Can we take down the screen, please? Thank you, Annie Ms. Lee. Excellent job. Thank you to Dave and team for its work on this. Thank you, Director Lillios, for your explanation. And now I assume we want to vote. Do I have a motion? I move that the commission approve the small business impact statement and the draft 205, CMR 250 as included in the commissioners packet and discussed here today. Second. Okay. Any questions or edits? Okay. Commissioner O'Brien? Aye. Commissioner Hill? Aye. Commissioner Maynard? Aye. Oh, gosh. Thank you. You took Skinner out of order. Well, you know what? Honestly, you guys changed places on me. Commissioner Skinner. This is where our virtual gets me. It's a little bit of a creature habit. Commissioner Skinner? Aye. Commissioner Maynard? Aye. Yes. Excellent work. Thank you for taking good care of that. Alrighty. And I further move it. I further move that I have to do a second part. I further move that the staff be authorized to take the steps necessary to file the required documentation with the Secretary of the Commonwealth by emergency and thereafter to begin the regulation promulgation process. And I further move staff be authorized to modify chapter or section numbers or titles to file additional regulation sections as reserved or make any other administrative changes as necessary to execute the regulation promulgation process. Second. Any questions or edits on those? Okay. Great. Commissioner O'Brien? Aye. Commissioner Hill? Aye. Commissioner Skinner? Aye. Commissioner Maynard? Aye. And I vote yes. 5-0. Excellent. Thank you. Okay. Then moving ahead, we've done the definitions. So we would go to, if everyone's comfortable without a break, move on to, am I right, Todd, for? Before. My occupational license. Oh, B2. Sports weight, I guess it's two, B2. Sports weight during occupational licenses. Yeah, we can, we can move right into B2, the occupational license one. So that's a 235. Caitlin? Hello, everyone again. So this is the second time you'll be seeing 205-CMR-235, the sports weight during occupational licenses reg. Last week, there was discussion about the majority of the reg and we took it back to review the section of the reg dealing with specific job titles, which is in section 235.01 with GLI. We've received some input from them and we may in the future receive some more input. But at this point, we're comfortable moving forward with it for a final vote, not a final vote for an initial vote to start the promulgation process. Meena or Laura, I'm not sure if there's anything else we wanted to say at this point. Caitlin, I'll just quickly go through some other small edits in 235.01 B. This was just a small, the insertion of the word qualified. You heard me earlier talk about the definition of qualifier. That's to make sure that we're capturing folks who might be qualified as part of a vendor or as part of a licensee, not simply licensed or registered. That's nomenclature of just what category of vetting somebody might have, which would exempt them from the need to go get a separate occupational license. That's a change to 235.01. The note in two Caitlin just addressed the feedback was generally these categories are right and we can go through that. If in the future, we need to make any other edits, we will, but that these are acceptable categories. We did take out to pit boss and cage manager. We had included these waiting for GLI input with the idea that we weren't sure if a pit boss, if there is a person at a sports wagering facility, an in-person facility that functions as a pit boss or cage managers explain to us that those were terms of art, not typically used with just a standard sports book and instead were, but to the extent and that in a gaming establishment, to the extent there is a cage manager for the gaming establishment who's also cashing out winnings for a sports book, they would be the same person and so be licensed anyway through the gaming licenses. There's no separate sports book cage managers as a point. I have some question about that because I understood the pit boss. So cage manager, what about what about for like category two? So that what that person would end up being as we understood from GLI is something closer to a general manager or a sports book manager as opposed to they wouldn't be called a cage manager. The terms cage manager and pit boss came apparently from sort of colloquialisms within the gaming industry, sports wagering industry, legitimate sports wagering industry is younger and has not adopted some of the same ones as the gaming industry. So it's just a matter of nomenclature again. And keep in mind, just sorry, I don't mean to, Madam Chair, you want to weigh it, I can just want to add one quick thing. There's still right here, if I can highlight it, there is again a sort of catch all. None of this is by title, it's all by function. And so if there is somebody at a category two facility handling money and supervising the handling of money the way a cage manager would, that person would need an occupational license as well. So there, there is some of that left in there. Thank you. I believe Caitlin and Todd correct me if I'm wrong, but every other edit was either this one just the word was a repetition that was unneeded. There is no other change to this reg. And again, this reg when as I mentioned last time we came before you with it is almost verbatim what was passed with respect to 234 but adjusted for some of the tweaks obviously for occupational licensing. That's all I have. Questions for Caitlin and Mina? Are you sure you're all set? I guess we can take down the screen, Mina, just so I can see faces. Of course, yep. Thank you. Okay, I'll set the bet is I know that Bruce Van and Burke have been looking closely at these matters to what they all set terms of terminology and all being brought up to date on that. Yes, we've been working together. The most recent version reflects all of our all of our comments and we've, you know, as explained by Caitlin, we've you're still developing a further list, but we're comfortable with the version now for current purposes. And getting the nomenclature up to date, apparently. So good. All right. So we need a motion on this. Caitlin, correct? Yes. Thank you. Madam Chair, I would be more than willing to make that motion. I move that the commission approved the small business impact statement and the draft 205 CMR 235 as included in the commissioner's packet and discussed here today. Second. Thank you. Any questions or edits on that? Okay. Commissioner O'Brien? Hi. Commissioner Hill? Hi. Commissioner Skinner? Hi. Commissioner Hill? Hi. And I vote yes. Excellent. And then I would further move, Madam Chair, that the staff be authorized to take the steps necessary to file the required documentation with the secretary of the commonwealth by emergency and thereafter to begin the regulation promulgation process. I further move that the staff shall be authorized to modify chapter or section numbers or titles to file additional regulation sections as reserved or to make any other administrative changes as necessary to execute the regulation promulgation process. Second. Thank you. Any questions, edits? Commissioner O'Brien? Hi. Commissioner Hill? Hi. Commissioner Skinner? Hi. Commissioner Maynard? Hi. I vote yes. Five-zero. I have to say my virtual platform is very busy today. Things are shifting. Madam Chair Maynard may ask for one more vote actually. So there are forms referenced in this regulation and those are the standard forms that we use for gaming right now and they're attached in the packet Loretta if you want to explain which or which that would be helpful. But we would like a vote on those so that those can go into effect once the reg is in effect. Thank you so much for remembering the forms. The forms where once again drawing on the forms that we use on the gaming side this regulation contemplates two classifications of occupational licensure and the key executive level would rely on the multi-jurisdictional and the Massachusetts supplement form and the key standard would rely we have a special form of the key standard application form. So those are the forms that are in your packet and we'd be asking to adopt those forms for these purposes for the occupational purposes. So they weren't incorporated into the regulation is that my understanding Caitlyn I guess when I reviewed it last night. The regulation references forms to be approved by the commission and so these are the forms that IEB would propose be approved by the commission for this purpose. Yeah I guess my question I guess my question is that I thought that by approving the regulation we approve the forms but you want a separate motion. I think it would be helpful just to be clear. Okay excellent commissioners so you're comfortable with that. Do I have a motion? Caitlyn what's the actual part of the reg that references the forms? Yeah that's what I'm struggling with. Well let me find that and if someone else finds it first shout out. Get bragging right? Yeah. 3502. Yes. But where within is the form? That's what I'm looking at the language about that. It says said every person applying shall be obligated to complete and submit an occupational license application form. Said form shall be created by the bureau subject to the approval of the commission. The bureau may create different occupational license applications forms for different categories. Yeah so it's on page 43 44 right? I believe that's right someone correct me if I'm wrong but that was my understanding of the reference. That's right. It's correct that's the bottom of 43 top of 44. The form shall be created by the bureau subject to our approval but I'm hearing that needs a separate approval. That makes sense. And then what are the pages in the packet the forms are actually attached in today just for clarity. And do you want separate for each or do we do both in one motion? So the form start at page 51 of the packet. I think it would be sufficient to say the you know the forms referenced in the packet starting at page 51 are the forms approved by the commission. Again anyone jump in if they don't think that's so it's the key gaining employee standard application form right? And then the next one is identifiable by the title. I'm trying to find the page number for you. So the next one I believe starts on 82 the Massachusetts supplemental form and then the multi-jurisdictional form starts on 90. So easy to scroll over I'm just trying to get the exact title. Yeah so the Massachusetts supplemental form page 82 and then the multi-jurisdictional personal history disclosure form. Does that help with Commissioner O'Brien? Yeah I think as long as we've referenced the where the page starts in the packet and discussed here today that that should cover it but yeah so it's the key gaining employee form messed up and then the multi-jurisdictional personal history disclosure form. The acronym okay. What's the last page? The 91 is the last page all together and the last page all together ends as long just as we've heard. Let's see. I believe it's page 155 Madam Chair. Thank you. I'm still in 120s. Is anybody comfortable making the motion? I'm just saying so mine ends on 153 do I have a different packet maybe? You might there was an update this morning to include that's fine. I have it on 153 as well. It's 155 on the new one. Yeah it was an update because there were a couple of documents that were entered last night so Crystal did update this is I believe I was in front of the public right now so. All right so maybe not the page I'm considering. So page yeah I would say maybe yeah so I move that the commission approve the forms referenced in 205 CMR 235.02 that are included in today's packet commencing at page 51 specifically the key gaming employee the mass up and the multi-jurisdictional forms that were discussed here today and included in the packet. Very helpful. Thank you. Do I have a second? Second. Thank you. Any questions on that? All right. Commissioner O'Brien. Hi. Commissioner Hill. Hi. Commissioner Skinner. Hi. Commissioner Maynard. Hi. And I vote yes. Five zero so that taking care of Caitlyn thank you. Thank you. All right. So now Todd and team we look at the definitions but we didn't vote on them. No we did do an initial vote. Commissioner Skinner helped on that. And then we now have the operation certificate. Yes I think we're on to B4 now so this is 205 CMR 251. This is a regulation that is before you for the first time. You'll recall we've talked about the significance of the operation certificate vis-à-vis the award of the sportsway during licenses and that the when the license is awarded it doesn't necessarily mean that an operator can commence operations immediately. They would also need to secure this operation certificate and this regulation you're about to look at is the process and standard by which the what will then be licensees will be able to get their operation certificate to get the green light to begin sportsway during operations. Mina and Paul are standing by here to walk through this particular draft and I will turn it over to them. Thank you. Thank you Todd. I'm sorry I'm having a little bit of a lag I think a connectivity issue on my end but I will try to share screen again here we are. This is at page 165 of today's packet. The 251 there's not a whole lot more to say than what Todd has already said that the way this proceeds is similar to 151. It makes abundantly clear that before any sportsway during can start other than for testing purposes which will be covered in the second section of 251 subsection of 251 you must have an operation certificate and it identifies the sort of prerequisites in a broad sense that need to be met before operation certificate can issue. Keeping in mind the reason it's in a broad sense is because you want to make sure that any more specific rank that comes forward on operations is also covered in any other condition that's on a particular license is also covered. 251.01 lays out the certificate will be in a form prescribed by the commission that's not yet before you but that's when you are done that will happen. For category one or category two facilities those will need to be prominently displayed just as they are currently for casinos. For category three it'll have to be prominently displayed on a website or mobile application. 251.03 identifies those sort of prerequisites before certificate will issue. They're identified here approval of internal controls just a small tweak that will make before this gets approved is that internal controls will be capitalized. That was one of the new definitions you saw today. There's a listing of all employees vendors and and non sportsway during vendors. Note that this is this is consistent with 151. It doesn't say licensing of all of those. The reason for that is licensing happens separately under the other provisions. They still need to provide a list to make sure it matches up with who is and isn't licensed and of course if there's not an adequate number of there may be folks who are still going through the licensing process that can't participate in the operation but they may be able to open with the folks who are licensed or registered. So that's that's why it's a list and that's why I think that was done in 151. C I won't go through every one of these but highlighting a few of these. C, D and E really all have to do with updates to physical improvements or security etc that an emergency response that had that a category one existing gaming establishment or a category two sports wagering licensee would have to do. So those are particular to the in-person sports wagering and then F is the catch-all for conditions imposed by the commission. In the gaming side one of the key differences between this and 151 is that there were a lot of sort of other host communities around the community impacted live entertainment venues. There's a lot of references to things that's just simply aren't in 23N so this is a bit more streamlined than 151 for that reason but still captures the key things before any go live period. I could take questions on this now but yeah. So and you got did you want to add more because I don't want to. No I was just going to move on to test period so we can talk about this part of the first. You can go through the whole thing because I just wanted to clarify my understanding of the process because I have some experience with it as does Commissioner Brian but I would like to. Sure yeah so before a go live and it's open to the public there is a test period that's identified in 2502 and this process essentially explains that there'll be an evaluation and test period of the sports wagering operation to make sure everything is running as it should and secure as it should. This again mirrors 151 in the way it's set up. Once the test period is done a certificate is when when the certificate of operation would issue and that's described in 03 and the term of it is is coterminous with the license so that if it's a temporary license as we've talked about before it follows that process if it's a full license it follows that I should say excuse me follows that timeline and otherwise it follows the full period timeline. Caitlin, Todd or Paul anything to add that I missed? No I think that that covers sorry I was looking for the mute button. Go ahead Todd. No I'll say thank you sorry. So could we just take down the screen because I just wanted to have a pretty open conversation with the newer commissioners and I want the legal team to correct me but as you can see there's a test period where the commission is given the opportunity to designate someone to do in the physical space a testing. This was done with the opening of the casinos and the way it was done in the past was that one commissioner was designated by the commission. I can tell you that the commission can't make a decision to designate more than one because I understand often meaning law could say that that's some kind of public body. My problem with the designation is that I have the privilege of of chairing four of you and I would love for everybody to be able to participate in the testing and under the statute I understand that I have the ability to make assignments and my preference would be able to assign if this was compliant with the opening of the meaning law to go to each site to test for the in-person sports books and make sure that they fully comply because I feel then they can talk to each other and it's a better process and then everybody gets some chance to participate. I also need clarity about what testing of the online. Is that going to be coming in front of us as a commission one sweep and that will be testing something how do we test that? So that's a big question on the online. This follows what was the test period for the casinos and like Commissioner Bryan was the tester for Encore two others were testers for the other two but it means that an individual commissioner went out and I remember thinking that was and you know it was interesting but that might be the only paradigm so I wanted to put out there because of my instinct to allow for maximum participation if we are in fact going to designate a commissioner or more if we want to have to. So I throw that out to the legal team. Commissioner Bryan you know I don't know what happened. Well no what I was thinking in terms of sheer numbers I'm you know more than happy to pull myself out of the mix I mean I've had the opportunity to be the tester out of facility I know that the three newest commissioners none of them have you might have three physical locations obviously if you were to go to to any of them that wouldn't be violation to have them too but I'm happy that makes the math easier also to simply you know step back however that turns out to be that might make the math a little easier. If we did the assignment would that be permissible so that you could talk to each other I just am wondering if that's an attractive option. Yeah I think the concern is not necessarily that there would be a quorum of the commission but that more than one could be considered a subcommittee that is established and that it would still be subject to the meeting law even if the chair just designates the people. A sign assign them to do tasks. A sign designate whatever but yeah so anyway that's the the concern you could just mark it up as a public meeting and allow people to follow you around I suppose that's one way to do it. Yeah just just to add to that I you know I have the same you know I think we're all on the same page in terms of what the concern would be it's if you weren't deeming it a a subcommittee and you were having it as a public meeting you would effectively be doing a site visit under the open meeting law which is also permitted however what you have to be careful about there is deliberation during it so it would be appropriate for commissioners to take in information but but when you say you know talk to each other issues that are raised from the from that test period should come back to a duly notice meeting so there may be some logistical things to work out as an open meeting law but I think you know we have the same reaction Todd had. So the assignment is off the table. Oh I mean if that's really something that you want to do we can try to think about ways to to do it but that's the reason it was done the way it was done before. Commissioners I'm fine with it if we want to do a single and then we'll pull it out of the hat as to who goes where that's okay so that we'll just make that decision a public meeting as to the the assignment as to place so that unless you unless you choose it I just want to make sure everybody recognizes that it could be a January a day in January or February so Commissioner Hill are you okay I see you nodding we'll just do something fun like that right Commissioner Skinner are you okay with that and Commissioner Maynard are you okay with that okay yes and then in terms of the testing for the for us you know we are not going to be going to have this complaint so will that come before us as the online how are we envisioning that process I can't yeah I don't that would be something we might have to get back to you to discuss a little further I mean I know we we kind of have thought it through to the point that there has to be a testing process how it will actually work I can't really speak to right now okay so let's look to see how the brackets because we're going to have a bunch of online's we've got ultimately five perhaps five retails it works well to translate 23k to 23 n for the retail but it's a little bit more of a challenge for the armor did we speak with um sterile I see that you're on has have you thoughts um so um my understanding in what was done in other jurisdictions is what it could be done is the testing could actually take place at in Boston um we are going to have our it team um overseeing all of these platforms um and I'm sure Katrina could probably speak to this more but that the testing in the um processes of all these different licensees will have to then be tested in an environment in the it world right so through the web browser or mobile application I see Katrina's here so she might be able to thank you and I think Kevin has joined us so Kevin and Katrina sterile thank you and and chime in um as as we grow this might be a really helpful discussion just as we think about this is a significant piece of our business so Kevin and Katrina with bodies like ours how does this testing happen usually yeah so um and I'll ask Joe Carlin to join if he can uh to add he he runs our digital and sports betting testing group globally so probably best you get it from the engineer not the lawyer um but the because it's an adoption of GLI 33 and I see Joe Bonovit has also joined us who has a technical background and might add to anything that I would say but because you've adopted GLI 33 and um because I well we don't know who all your operators are yet um but the vast majority of them um are operating somewhere in the United States and already subject to GLI 33 and the platform's already been tested to GLI 33 so what really needs to be done is the local deployment so it's it's the the geolocation the network security on the local server it's the integration of the local server um but the the system the fundamental system that they'll be using has been tested repeatedly and and ongoing according to the change management program so Joe Bonovit do you have anything to add to that the operators are quite used to obviously this process in all the other jurisdictions that are live they will submit their final software headed towards the mass market Massachusetts market once the technical regulations have been approved and we will test that in lab verifying that that software is the piece of software that ends up heading toward the market and we will issue certificates upon approval which includes all those parameters that Kevin just mentioned the geolocation the critical file checks that you know we can get real technical here and then post the mass MGC's approval of those certifications for those individual operators and suppliers they'll be as long as you guys say so they'll be good to go live but I can't say that there hasn't been a single market where we have not been able to meet the deadline from a testing perspective and that includes some very very aggressive launch dates in fact includes some jurisdictions that launched before their rules were even finally approved so as far as areas of concern this it's not priced towards the top of my list no chair yeah as I was trying to train and now if you could translate what you're hearing from our gli colleagues how do you imagine unfolding in front of the gaming commission for our final approval um so very much in line thank you madam chair very much in line with what they're saying so there's a lot of prep work that we're going to do once the tech regs have already been approved like you know Kevin Malali stated a lot of these software firmware etc has already been approved in other jurisdictions so the core coding the core firmware the code the software all of those things that we can test in advance we will do and we will have all of those certificates and signatures and everything else so when we're ready to go to launch there will be that pre-launch phase prior to that we will validate with the operators and the licensees that these are the signatures and the softwares that have been utilized and launched in the jurisdiction so it's almost like a two-step phase so there is a lot that we will be doing once the tech regs have been pushed through in anticipation of that pre-launch phase and again a lot of this is so digital it's pretty you know this isn't their first rodeo so we get the benefit of that and the the operators and the licensees will work very quickly and agilely to get us the information that we need to ensure that we're able to launch on time so that's really helpful because I think it's it's informing this regulation that's in front of us now which is you know the switch way during operation certificate and I'm just trying to imagine I think we've got the retail in our minds it's familiar at least to two of us and in the other three we'll catch up very very quickly on it but now I'm just trying to imagine Mina and team with the input that you just got how do we address the online with more specificity or is it not necessary I certainly you know welcome others thoughts on this my thinking on it this is this is sort of what I was getting at with the keep it broad but not you know identify the the things you have to do at a broad level but not get into the weeds so that you don't tie whether it's GLI or or Sturler Katrina's hands as they go do the testing process especially when we see what the license who the licensees are and what what kinds of platforms they have what what issues might be coming up in the industry at that particular moment etc. Chris you have thoughts on this at all I guess I'm I'm I'm pressing a little bit Mina because I don't even see category three mentioned it but this does encompass it right my wrong yes sorry I was having trouble finding so I see above or probably I see the the issue around this displaying form but in terms of our testing in the test operating operator but you have a lot about category one of category two and it's correct the sports waging operator captures all of them the reason that oh one has a little bit more about one or two is it it carries over the 151 issues related to actual physical facility but that may or may not actually be the bulk of the work it's just a it's just a matter of repeating some of the ones in 151 to make make clear that those may need to be updated you know if you had a chance to review this and Kevin was regulation well sorry was that directed to me Madam Chair? No Kevin and Katrina I have not seen this particular rig if we're referring to 235 the occupational my understanding and I could be completely incorrect in this is this was specifically geared towards the category one category two that the category threes since they really don't need an occupational license in its definition would be handled differently but am I looking at the wrong thing this is 251 this is 251 Katrina oh I'm sorry I apologize I was looking at the wrong thing and no I have not seen this as of yet and neither is Kevin yeah I know well I we actually did see it and I'm I'm fine with it it's not something that's used in every jurisdiction but I think it's a healthy tool a lot of times it's rolled into the licensing resolution the things that you're talking about here and if there are any specific concerns and most of the time there are not but there are occasions where there are you can put it in if you use a licensing resolution you can use conditions of licensure and I think that same concept could apply to a certificate of operation and it's alluded to in the regulation that you can apply specific conditions if there are specific operational concerns for a particular deployment or a particular piece of technology so it gives you gives you a lot of flexibility let's hope we don't need to use any of those tools but I think it's pretty straightforward from from our perspective and Madam Chair just one clarification when you said Kevin I meant Kevin Gavril not Kevin Malawi so I apologize for that oh that's okay I we um I appreciate everybody being so available uh in this way I really appreciate it um you know you are you satisfied yeah we're certainly satisfied that captures category threes and that it leaves that flexibility but um yeah sorry but I'll obviously others have comments and then this is strictly this is strictly procedure guys because I understand Kevin it was really helpful to understand what other jurisdictions do but are we envisioning at some point you know let's just say we have 15 category three online sports waiters that they will come and they'll be all the evidence of their compliance that with all the testing requirements and they'll come in front of us and they'll be in a public meeting and we will do a check off and an approval is that really what we're envisioning for testing for the the gaming commission because this I'm just trying to understand the process that would work Todd are you are you imagining that too yeah essentially I think that's exactly right though we'll come before you say here's so here's everything they've submitted this we've done a test period we'll go through the whole list and then you'll say hope you know hopefully okay we vote to award the operation certificate now you can start operating so absolutely that is that is kind of how I would see it yeah I agree Madam Chair very similarly with what we did with the land-based side of things I mean we had technological components that needed to be approved as well for that and so we came with a checklist of things there were our certification letters that were attached and that was part of the approval process to move forward with um being able to open to launch so we would treat it very similarly except in the retail there's an individual commissioner that kind of is associated with that in-person check okay I'm happy this is sorry to spend a little bit of time but I am actually thinking not only of the process I'm thinking of our calendar so thank you thank you very much Madam Chair if you if I may Joe Carlin has joined us and he's very good at providing a a brief high-level overview of what goes on in the testing process if you if you if you're of the of a mind to listen to that I think Joe's available I saw him on screen yeah he was on hi Joe yes hello uh the question is just a high level of the testing and certification process yeah I level what needs to happen before launch and what our timeline is and some of the aggressive timelines that we've worked under to in other jurisdictions okay yeah absolutely first I'll talk about a complete high level but know that a lot of this work has already been done with clients that we're handling in other jurisdictions but first and foremost we start with a complete architecture review of the system to identify the areas that have critical regulatory relevance isolate those first step in any submission is a witness build process where we're checking it watching the checkout with the source code for the product all steps of the compilation and creating the files and having a chain of trust over that entire process and then ensuring that those are the files that are deployed to the test environment ultimately those files and the shall one hash as a digital fingerprint to match those in production are listed on our certification report from then from there we're going to break down all of the elements of the player account management platform so everything to do with the registration process age verification everything to do with responsible gaming all of the account controls for a user to manage their account like they would a bank account so to speak there there's some equivalency you can draw from there to close that account what happens to the account goes dormant in activity timers for protection against again underage gaming geolocation data logging reporting all of those aspects that that are sort of front end player facing items and then we're we're going to fully evaluate the sportsbook product so looking at all of the events and markets markets being like point spread money line different types of wagers that are offered those combinations all the exotic wagers were teasers parlays and other things can be wagered on retail and mobile if those are together we're doing cross-validations within accounts where that exists we are looking at cross-validations between kiosks and point of sale making sure that best place at one can be redeemed at the other within within various limits ensuring limits are enforced we're creating a whole number of events on our own to hit edge cases we're also through the testing process having live feeds integrated and fully testing with real games that are actually occurring in events you know NFL NBA NHL MLB depending on what time of year it is so that's the end of what we're testing and certifying in the areas with significant regulatory relevance having to do with player protection state protection accurate accounting and and fairness and in all aspects with with our clients most of which we're very familiar with the process we've done a lot of those steps we're looking at taking the latest version of their platform in understanding all of the changes applying the new set of requirements for in this case the state of Massachusetts and ensuring that the product complies and signing off on each one of those points point one point because of our familiarity because of the base work you know the the timelines can be accelerated for end-to-end testing you know within you know potentially as small as a week depending on ongoing work that we're doing with a client to you know anywhere in the two to three week range max for a brand new client that we've never seen before would be somewhere around six weeks all very dependent on number of issues responsiveness availability of environments and and other factors that you know we work day in and day out with with suppliers on to to address so i know joke joke so the timing to me uh i'm so sorry process that's why karen would do some work with gli and that's how we got i'm sorry was the only one that had trouble hearing kathy yeah madam chair your that thing is happening again with your microphone oh sorry thank you for your dinner so you might have repeat what you just said sorry wasn't that interesting um let's see um let's try this guys and then otherwise just to let you know sometimes that breakup happens if the audio is picking up background noise from someone else's audio and i think it was i heard a little humming from somebody's connection so that could have been why you cut out patrina should i keep off for both speaker and microphone the echo cancelling is that are those that is the echo cancelling is your speaker and microphone that's the docking station um i'll check for the best audio i would use that yes that's what i have so maybe there was some disruption i'll try to stay close to the microphone um joe um i don't know i know that joe carlin has a hard stop like right now so he's gonna jump off i will note that every single element that joe c just mentioned is documented in the tech regulations that comes from gi 33 which is the accepted standard across the industry i frankly across the world when it comes to event wagering systems um and we go straight from uh all the front facing elements the geo location age verification all that account verification deposit withdrawal all the logging and all the timestamps data marks every single thing is checked on that end as well as on the sports wagering platform which is where the bets were accepted all those the prices the teams the event times the timestamps every single thing is uh logged and cable to be uh recalled and audited we check all of that and that is contained within the tech standard as well as gi 33 and madam chair it's for that reason that joe just mentioned that i didn't look at this set of regulations with the technology lens and maybe i took the wrong approach but i read these regulations as more requiring an i e b presence in with respect to the testing so it maybe director lilios could speak to that a little bit if i'm just way off base um it's good to know that too but i didn't because the technology piece is covered under a different set of regulations i i just assumed this was this was all from a compliance perspective and can i just interrupt briefly i um understand that maybe i e b is involved i'm looking at the strictly as to what the commissioner had the commission has to do um to issue that certificate and it was just i very clearly could understand the process from the retail um side i understood that the technology piece would come to gli i just wondered what our process was going to be because we are um going to be signing off on these operations because i understand it in some form or fashion under this under this drag and so it just wasn't as clear to me as with respect to the online uh what our process was that's all but director lilios if you want to weigh in on that thank you chair so i i think the process for the retail is largely going to mirror the process for the category threes there are as mena pointed out in the reg i think there are three or four subsections that specifically address an in-person environment uh but the testing the certifications and the review of the internal controls they are going to mirror one another in both the retail and the digital environment so it's the picture i have is that for each of the up to seven uh the i e b with the assistance of gli and our tech team will be coming to you for approval of the operation certificate you know with your designated uh commissioner having been there for the conditional so you're saying that it doesn't apply to the category three broadly just the um tether the untethered rata uh no i think it applies to all yeah so it's like maybe up to 15 that'll be yes yes come on good all right no i think i'm good on this um i understand it now um and i and i i understand the process in the regulation and i imagine it in terms of the timing working out just fine commissioners do you have any questions thank you for your patience as i work my way through this strike okay do i have a motion i guess uh me know you do want to vote it on today um uh chairs uh dudstein i don't believe me know it was done he didn't get the section three which i want to make sure that the correction is made in that section on the duration and the duration yes sure uh let me try to address both and taun and katelyn tell me from ron i think this is the first time the commission has seen this one so i wasn't sure if it was up for a vote today it is it is the first one okay first so i'll defer to katelyn and taun on on whether it's ready it was expected to be voted on today or not um with the second actually stirall i was done we had it i i think this is where i was saying the we went back to testing but on three the upshot is that the certificate would last would be coterminous with the license of our temporary license it would expire with the temporary license otherwise it would expire but if there's a an issue to talk about sorry yeah just uh if if you were sharing it i just wanted to make sure section one had the proper reference of point zero two rather than point zero three oh i'm sorry thank you thank you you're right i i had i had forgotten that um that's right kary kary caught that um this morning and had asked us to pass along and stirall i appreciate the correction so it's just a across thank you yep so that'll be fixed so do we hold on this for um have a comment katelyn or no i see katelyn the commission can vote on this to promulgate by emergency which would then start the comment period and the promulgation process okay any further questions and thanks again for your help as i navigated that that emotion with the um one edit don't forget that was just me thank you stirall mr hella you're leaning in yes for some reason i was having an issue with my mute button i apologize um so 205 cmr 251 um i move that the commission approved the small business impact statement and the draft 205 cmr 251 as included in the commissioner's packet and discussed here today second any edits or questions okay commissioner brian hi mr hill hi mr skinner hi mr maynard hi i felt yes five zero thank you madam chair i move that the staff be authorized to take the steps necessary to file the required documentation with the secretary of the commonwealth by emergency and thereafter to begin the regulation promulgation process i further move that the staff shall be authorized to modify chapter or section numbers or titles to file additional regulation sections as reserved or to make any other administrative changes as necessary to execute the regulation promulgation process second thank you okay any questions all right mr brian hi mr hill hi mr skinner hi mr maynard hi and i vote yes five zero okay it is uh 12 o'clock now does anybody need a quick break before we go on we have um the um equipment chaos and then of course gli's what would you like to proceed commissioners i want to check in with you on on your i need a break you need a quick break good um madam chair we didn't get the timed agenda um just wondering if there is a lunch break contemplated in the day just didn't do it time because we were only doing regulations and it was hard to predict so yes it's no problem i'm just wondering because if we're taking a longer lunch break then i i would i would opt to forego the break right now well unless somebody really needs a break right now then i'm i'm right and i'm just giving my my my preference is all you're calling for preferences right right now so i'm just sharing that i'm calling um does anybody just first off i should ask do we want a lunch break now or do we need a quick break now commissioner maynard either way i need a break i understand um commissioner um what why don't we take 20 or 30 minutes now and then we can power through without having you know it seems reasonable to me um we'll do that as long as everybody's all right but that we will have a lunch break now it's 12 11 we'll um we'll uh reaching being at 12 40 okay thanks everyone and thank you uh mills thanks mills we can probably turn down the screen now there you are i think we've got everyone now okay so this is uh me convening after a short break of master's game commission's public meeting we're holding this virtually so i'll do the roll call commissioner opriate i am back thank you commissioner hill i'm here great thank you commissioner skinner i'm here thank commissioner maynard i'm here madam chair okay excellent and this is the reconvening of public meeting number 403 and we are looking at a whole bunch of bags today and we've just completed the operation certificate moving on now to sports wagering equipment in the salt business impact statement so Todd thank you madam chair commissioners so now we're at uh four b five six um and seven on the agenda these three items are all related we'll present for your review drafts of the regulations governing the technology standards that sports wagering equipment will be required to meet as well as the process under which such equipment will become certified and approve for use as well as the process under which modifications may be made um let me just introduce everyone who is joining us first you can see uh mike robbins who is the technical compliance specialist from gli has joined us and he will uh present a bulk of the drafts and walk us through the materials you can see also of course that kevin malaly is alongside as well as joe bunaveth who are here as well and i'm not sure whether there are other members of gli joining us but that is a significant portion of the brain trust there we're also of course joined by our very own Katrina jagroup gohme so we will all endeavor to walk through the drafts before you i'd like to just offer a brief preview of coming attractions if i may as the drafts you're about to look at contain a great deal of substantive material we'll begin with 205 cm r 243.01 in this draft the proposed language would adopt gli 33 and that standard which has been referenced earlier which is the standard that applies to event wagering systems and the proposal is to adopt that by reference i thought i would just mention by way of brief background that the format in which this draft regulation appears is consistent with the manner in which the commission has adopted a series of other gli standards on the gaming side of the ledger and that is to say that the gli standard is adopted by reference as the baseline and then the regulator meaning us of course amends the standards in certain areas to ensure that the state's legal requirements are satisfied that chapter 23 and is captured appropriately and that we answer other certain questions that are left open in this standard itself or the regulator to answer and michael will walk through all of those areas well then pivot into a 243.02 and 143.07 and that can certainly refresh everyone's memory when we get to those but just by way of background those are the regulations that will govern the standards that kiosks will have to meet the commission has already adopted gli 20 which applies to kiosks generally this standard has been in place for all the kiosks used in the gaming operations already the proposal before you is that the version of that standard that is employed be updated from the 2011 version to the 2019 version and michael explained the differences between the two a little bit but it's important to note that the amendments being proposed would make this section applicable to sportsway during operations as well and then we'll take a look at the 243.02 which is the companion to that and you'll see there that there's no substantive language in this draft but instead it's simply cross references and directs the reader to 143.07 which is where gli 20 is adopted by reference the purpose of this 243.02 is just to ensure that a sportsway during reader of the regulation knows that they have to look into the gaming regulations to find the standards that apply to kiosks and hopefully we can explain this a little more clearly as we walk through that draft and then finally we'll look at a draft of 205 CMR 244 which in a nutshell governs how sportsway during equipment will be actually tested the process for approval for use and importantly how the change management program will work so those are the series of draft regulations that we are going to walk through and if there are no questions i'll turn the program here over to mike robbins who can walk us through the drafts and help to address any questions mike welcome thanks um basically i just to kind of speak about gli 33 from a high level gli 33 was a standard that was developed to handle all forms of event wagering so we use the term event wagering because we view sports wagering as a type of event but it could be extrapolated to different types of wagering should a gaming commission or adopt their wish to stretch it to that um that being said gli 33 has been adopted in um about 33 jurisdictions around the world and that includes the majority of sportsway during markets heavily rely on gli 33 as a technical basis of standards for this type of equipment um and system and and the like uh when it comes to the brick and mortar retail type of sports wagering such as the cat one cat two there's also the addition of gli 20 which is the kiosk standard we'll be talking about shortly um but i'm going to basically step through i'm going to and if i can be given the ability let's see if i could share my screen um yeah just great what i did here was i uh just to make sure everyone can see my screen correct yes all right what i did here is i basically uh took the the the proposed regulations on on the right and a copy of gli 33 on the left and kind of illustrated how these edits are reflected in gli 33 when it's made uh when it's viewed with the lens for massachusetts purpose now a lot of like these first couple sections are typical boilerplate that has been utilized in the 143 uh regulation updates to other gli standards so i'm just going to scroll right through this this is this chapter is just basically an introduction with the purpose of the regulations are and just talking about like okay this is going to be used as a part of the framework um and then we get to chapter two which is more or less that you're you're where a lot of the system platform uh elements happen so this is your wagering engine this is your sports sports book where um this is all and this is also where your player account management exists or sports wagering account management would exist hey mike i'm going to interrupt you just real fast for just for the record and so the commissioners can note that if you do need a copy of gli 33 we can send one to you and it's also available on gaming labs dot com download it without any friction you can download it straight from the website so uh this is how we we we publish these for public record all the standards including gli 20 gli 33 you can find right underneath the standards tab on gaming labs dot com on website so if you do need to actually take a look at the part of our standard gl i got it yeah thanks charo um so yeah so all the gli standards gli 33 gli 20 and when we get to with the gli cmp are available on our website um but anyway um mike just sorry sorry to keep it right just one further contextual note that i think is important is that these are developed and uh using a process that very much mirrors a state rulemaking process and gli makes no money from them anybody can test to the standard um it's actually a fairly significant expense that mike robbins and others administer um but when we when we come up with a new standard or come up with a new version it's circulated to regulators globally for comments it it's our intent to to publish the standard as a global consensus on how regulators feel about technical issues whoever comments forms a working group the standard is then put out to the industry for comment that working groups goes through the industry's comments and eventually we arrive at a final version so very much uh it's like your your state rulemaking process yep thank you so anyway just to scroll through here what i'm what i basically did just to illustrate how this affects us so you have this section here says uh add the following as 2.1 and it's reflected in this document right here um so your first section you talk about your your system clock your control program this is the the verification that we were discussing earlier um you know making sure your your control files are your control files are correct uh your wagering management to enable and disable different wagering types mark different betting markets uh or wager categories um and of course uh your wagering devices and we use that term to within gli 33 to cover uh both sports wager sports wagering kiosks as well as mobile devices uh and as well as uh ticket rider stations which would be your over-the-counter points of sale and moving along we have your player count management there's a reference made to the 205 cmr um those regulations uh draft regs have been submitted uh for review um so just scrolling down uh here it's just basically it's it it's talking about your player registration piece but a lot of this stuff is going to be elaborated within the sports wagering account uh cmr section but here's some more technical requirements related to this um one of the things to to point out here is to meet the to serve the purposes of uh the uh massachusetts statutes we updated to 52.5.6 um basically to to alter the wording because we want because um you know 23 23n has restricted the use of credit card transactions so the the verbiage here has been updated to reflect this um just to give an example um we have a the section regarding what needs to be in your player account statements you talk about player loyalty um and here's the section I kind of wanted to point to here um is location requirements so one of the things uh that we've seen in all uh sports wagering markets in in north america is in the u.s particularly is a requirement for some sort of geolocation location detection service and that's basically to ensure that wagers are being placed within the the the states um so you see here removal we're required by the regulatory body this is this is this is this verbiage is in the standard because not every jurisdiction you know who's adopted 33 is from the u.s so some of them don't have this don't have this level of location verification requirements so that's why it says we're required by the regulatory body um but you know moving along to 2.7.4 which is really where we talk about um the category three type of um online sports wagering uh we added in the the specification from the from uh 23 and that all wagers need to be taking place within the commonwealth we also updated updated a to kind of talk a little bit more about uh increasing periods of location check when the players located within one mile of the the state border you know for for this purpose um and we also added a requirement at the end and this ties back into our testing requirements that we'll be discussing when we talk about 244 is that this location detection service needs to be tested by an independent test lab and this includes applicable field testing and what that really entails is that entails um either either um well the most common experience is independent test labs will send people out to the border and drive across the border and do a series of tests where they either set up the bet on one side of the border then jump to the border and see if it goes through or other such activities we're trying to basically make sure that you can only place wagers within the the the state um that being said also that we've heard of regulators um and you know internal organizations also do similar testing this kind of goes back to that operations uh testing period that you were mentioning earlier this would be a part of that where you know the the site is live for the purposes of testing but it's not live for the purposes of fully operational um so so one thing I wanted to bring up here too is we talk about wager record information which it aligns a lot with uh what is required by um um but by the by the by the 23N and one thing we added here was the was I we updated item O to kind of reflect um this this use of this um collection of additional player data when a player is placing a wager which exceeds and we use the the ten thousand ten thousand ten thousand dollars or wins a wager exceeding um 600 and is 300 times the amount wagered and uh basically we we we put that in there to kind of um these are these are like your your values that you'll see for uh to meeting the bank the the bsa the anti-money laundering and as well as the irs uh w2g lock up uh or w2g requirements so then uh moving along we actually parrot similar information again later on when you're talking about uh large large wins um large wagers uh large financial transactions most of these are to assess to to apply to the federal regulations already in place for this purpose when we add this section in to tie back to the to the statute talking about timely filing the reports and here's some additional reports now 2.3.1 this is where we're talking about your wagering device and as I mentioned earlier this covers both your cat one cat two and then for cat three the remote wagering device uh this is the software requirements related to it uh this is a section where we're talking about self-service wagering devices or we call you know sports wagering kiosks for the purposes of uh these regulations and we added in a reference to 205 cmr 14307 which we'll be updating um to reflect the latest version of gli-20 and just a real quick talk about that update um the main purpose of that update to gli-20 was to kind of build support for kiosks to be used for sports wagering and also extend any sort of kiosk that could be used in other forms of of gambling um as it was originally written it was heavily focused on just ticket redemption and while the new version the 2.0 version does still retain that functionality and support we wanted to expand that support such that it could be utilized for sports wagering or player account management or you know anything else uh related to gambling that isn't necessarily done on a gaming device or a mobile device like can I ask that question so the technology right now the kiosk will they will be used for those multiple purposes that we'll see put into so so for the most part the kiosk we've been seeing are a little more focused um that being said we've definitely seen concepts that are multiple that are multi-purpose so we wrote the standard in such a way we didn't want to be a hindrance to new innovations in technology so you wrote it in a way that should it be able to support this functionality we didn't want to ice it out through the standard um so we have encountered kiosks that might have the functionality to handle acceptance of player account transactions and to either deposit or withdraw funds as well as handle sports wagering ticket issuance and redemption but we've also seen separation where you might have a kiosk that it's only going to accept accept money and spit out a sports wagering ticket or it'll cash out that sports wagering ticket and give you a voucher you got to take that sports wagering voucher to the cage to be cashed we've seen you know we wrote the standards in a way to accommodate all scenarios or at least as many scenarios we could think of at the time thank you um so chapter four this is this is where it actually talks about the the action related to sports wagering where the functionality of the placement of wagers the display of information related to odds um and also talks about functionalities where it's it's we've seen systems that might support it but that hasn't necessarily been um too popular yet but once again we wanted to write a standard in such a way to be open to new newer technology so like you might have a player resource feature that that offers you some sort of tip and we haven't seen this implemented but we have heard about it through various channels um another thing too that we wanted to account for is uh an acceptance of changes in wagers and this is because um when you're when you're at these odds are are updated continuously so they're not it's not like it's updated once every 10 minutes or whatnot like it'll be updated it can be updated in seconds so there might be a chance where you're placing a wager and you have really good odds but something happened and the odds changed and if the odds are worse then you'll you'll be you'll you'll be like if the odds are worse and you'll end up with like a less of a payout if if if your wager wins the the the site or the kiosk will be like hey this these odds have changed do you still want to proceed you if you win you're going to get less than what you were originally interested in um and this is this is let me let me reiterate this is before you commit this wager so once you place the wager it's fixed uh you know it's going to be fixed and whatever your odds are at the time of that commitment is it for the purposes of fixed odds wagering um would now this auto automatic acceptance of changes would be if the odds got better so say my payout on a wager when i clicked hey i want to place this wager was a thousand dollars but the odds changed within those few seconds and i actually if i won i'd get ten thousand dollars well it's going to let you it's it's going to place the wager and be like hey guess what these odds changed in the past two seconds and if you win you're going to get more um and then there's a wager record and the wager record is synonymous with a sports wagering ticket or a bet slip or just basically what what what is the wager that the player sees so we use the term wager record to cover both the physical sports wagering ticket which will come out which could come out of a kiosk as well as a virtual sports wagering ticket or bet slip or whatever you want to call it that will appear if you place a wager using a mobile device or or a computer um so yeah the next sections we talk about the the wagering period which is time you can place wagers free play mode um your payment and redemption of winning sports wagers and then you got section four point five now four point five talks about a concept called virtual event wagering this is not to be confused with esports where in esports you're wagering on an event played by um athletes athletes who are playing video games against one another this is more uh a simulation of a sporting event as as you would see it and you know as so for instance take the nfl like instead of wagering on a live football game you're wagering on a simulation of a football game um so uh fun of it can you yeah so i i'll take a half a step back first virtual event wagering will have to be an event approved for the catalog first uh it is a simulated event um typically a lot of the uh it hasn't really gained much traction in the united states frankly but it's actually quite bet on worldwide especially in virtual soccer and horse racing um and it's an actual uh r and g that delivers a an experience and the content looks like an actual horse race or soccer event um it's frankly the technology is kind of amazing now and you almost cannot tell that is an actual computer simulated event um but uh if the commission were to go forward and approve such a uh offering for the catalog uh this part of the standard uh would would be applicable uh to uh make sure that virtual event is uh tested according um you know to to be compliant how's that mic yep that's good and the other thing too um just to bring up and when we do get to the i think it's 245 or 246 which does talk about the rules related to sports wagering those rules that have been drafted and submitted uh for commission review um does go into uh the approval the methodology of approval of events and it does mention virtual event wagering specific virtual sports wagering specifically just for the just to tie back to this so this would have to be an approved event and it actually did catch on in a couple places during the pandemic and not them saying we're going to end up back there but it you know there are we've also seen a lot of interesting implementations so say for instance you take the stats of a team from you know say you take the stats of the patriots from two years ago and you're like okay well how would they fare in a in a in a game against the stats of the patriots of one year ago and you kind of set up this um this this virtual event using those statistics and there's going to there's going to be some weights uh of and some rng calls to you know handle the randomness aspects this would uh this would basically you know this this would quality this would fall under the whole virtual event section so moving on here um we also have the external wagering systems section now this isn't as widely used however with things like esports and you know basically niche um game the weight like game type wagering operators this this might be a situation where you're going to have this this kind of talks about the interoperability between that guest system that that host system and the guest system so say for instance there was an esports wagering provider and they handle they have their own wagering engine and they tie into um you know your your operators platform this discusses like how those wagers are handled the communications between the two system components and this wraps up that chapter now appendix a this is this is when we start talking about internal controls and um this is the intention of this chapter really is to provide a framework of internal controls that are common throughout the industry and that um basically any sort of additional internal controls would be up to the regulatory agency to adopt alongside of or in lieu of this section and for for the purposes of massachusetts we've started you know we've we've submitted one third um our recommendations to 138 and potentially 238 to kind of tie into this chapter as well as establish controls that are going to be specific for the needs of massachusetts but what i am going to talk about here is this independent audit section so basically this talks about the ability that each operator is going to have to have their procedures and practices their internal controls uh audited at least once every two years and submitted to the commission um the thing to bring up here is that these internal audits can be conducted directly by the commission or it could be a third party auditor um including you know independent test labs or any sort of other auditor however it does give the commission the ability to allow for a independent department within that organization to handle the internal audits um so what you'll see in a lot of a lot of these uh companies is you'll have an internal audit department and they're completely independent of any sort of other operations of the sports wagering environment and they'll do uh they'll perform these audits and provide feedback to the regulatory body that being said it is up for commission approval uh you know full discretion of the commission um and basically i pointed out g here because what we've in this more this mostly this more applies to category three than anyone but you might have an because you have an operator who's running in many many states they might have recently done this audit so they might leverage those results previously or say if like GLI performed uh an audit previously for a jurisdiction will will you and the controls are the same we will leverage those previous results and but of course this doesn't include any sort of you know results unique to massachusetts so you know auditing procedures for say a sports wagering facility probably you're not you're not going to be able to audit much in in in lines of what's happening in the actual facility but you might be able to audit things that are happening more at the back end level um and so what we added at uh a two one is a reference saying that you know the internal controls need to meet this appendix appendix a as well as uh 205 cm are 38 which again we've we've provided drafts and i know it's on schedule to be reviewed in the in the near future um so this section kind of talks about just like the internal controls um it establishes some baseline of restricted or prohibited players some more player count controls including uh examples of what you'd see in your terms and conditions and privacy policy which will be uh once again addressed more when we get to the sports wagering accounts chapter same as the financial attraction uh transactions um limits exclusions and active accounts um talk about operator reserves protection and player funds taxation um player dispute player protection and wagering rules um so wagering rules we um the they're also known as house rules um usually within regulation i would recommend calling them house wagering rules when interfacing with gli 33 just to alleviate confusion also someone might not understand what house rules mean means per se um what is the house but they might say some see wagering rules like oh okay that's wagering rules um you know that's rules related to wagering so here's a lot of rules explaining what's going on section on promotions and bonus and and bonuses uh bonuses um as well as rules related to contests and tournaments we have sections for talking about the procedures for setting the odds and and and the the suspending uh wagering on on markets or events and that's going to be tied heavily to the regulations went for for when these might occur be it uh you know it's discovered like an event is you know something's going wrong either the event you know it was requested uh that like to spend all wagering on the event because there's investigation or it could be even related to oh it's a rain delay and we don't know what's happening next so these are these are basically things that are going to be outlined by your your operators and a seven talks about your wagering venue your sports wagering facility your sports wagering area um and this talks about any sort of verification audit so this this would be your your on on premises audit that um you know the commission or the IEB would perform or whoever would perform and just sections on wagering procedures and one of the things one of the updates here for surveillance and recording uh it got changed from 90 days to one year and that's because of the uh statute um because the statute basically said that surveillance needs to be maintained for period of one year so once again talking about what we were talking about earlier about geolocation we remove that uh we're required by the regulatory body because that it's going to be something necessary for Massachusetts to make sure that the requirements to ensure that wages are being taken place in state occur um and now we get to our independent audit or operational audit our appendix B which is our system security uh technical security controls and we added here requirements talking about the independent audit and we mentioned the the 90 days this is a common industry usage it's usually within 90 days of commencing operations and then annual audit um and this consists of vulnerability testing penetration testing firewall review assessment of information security your cloud services and any sort of additional um service providers utilized by the operator and we also talk about what what it takes who performs these types of uh these audits so we give a little background explaining like you know the qualifications as well as what needs to be included in the report as well as mentioning both the leveraging of previous results once again you're going to see a lot of these systems are in many many many many states so a lot of these audits have already done been done very uh you know very recently so this would include uh leveraging such results if I can chime in a little bit here Mike this is this aligns closely with the work that that the regulators network security task force is doing um the Dan Hartman the director in Colorado is leading and the Katrina and her staff have been involved in along with regulators from almost every other US jurisdiction and I know they're opening it up to uh in the process of opening that up to international jurisdictions and it goes to the concept that these systems are deployed globally but regulated locally and you'll notice throughout Mike's presentation he pays he's very good at paying meticulous attention to language and what things mean and one of the I think the values we brought to this process is to try to bring some consistency so that regulators and various jurisdictions are at least at very minimum calling things by the same names and using the same terminology and network security is something that unlike you know regulation of land-based casino in the past that really didn't require terribly high levels of collaboration between regulators except possibly in the area of investigations this is going to require a lot more of that because regulators at least at the current time have limited resources in this area the resources that are necessary to do it properly are highly specialized very expensive and need a lot of training to maintain and and so more collaboration is going to be needed to make it efficient while still maintaining a high level of effectiveness and so that's what a lot of this goes to yep so um just kind of move along move on here we talk about system operations and security and we update the section on physical locations of servers and this is basically to specify that it's up to the the operator to provide the commission with information on the locations of all servers and equipment used for sports wagering as well as mentioning that in particular the primary server utilize for the acceptance of sports wagers need to be within secure locations in the common within the common wealth and this requirement is basically written to cover to cover the wire act because the wire act is in the interpretation the various interpretations of the wire act I've all had in common the the the fact that the the the server used to accept the the sports wagers need to be in that state as well as a player so for the purposes of a sports wagering system we've seen what is commonly referred to as a hub and spoke model where you'll have a central server somewhere um you know within the us for instance and it will have your player account management it will have your odds feeds it will have a lot of this information stored however when you're making that wager your point of sale that server that accepts your wager needs to be within the individual jurisdiction now at least add in the unless otherwise approved by the commission because the wire act is a is a tricky thing and there might come another interpretation down the line or even a complete removal of that interpretation of the wire act completely stating that oh yeah the wager server could be in other states and that might be a situation where you know leave it to the commission to make that discretion of okay we're willing to go with this new opinion or maybe maybe it's up to the commission go well let's let's stay on the safe side we still require the that that server to be located within within massachusetts so moving on there's a lot more security requirements here and i wish i knew more about cyber security but i only know what's what's written um we definitely have uh our team our bulletproof branch go into in-depth conversations on cyber security if the commission wishes to hear that um but we'll talk about the system security and a lot of these requirements and communications but i do want to bring up a important requirement here and we are talking about communications within wagering venues and i bring this up because there might be a case where within a within a casino or or uh within a gaming establishment or a other other facility sports wagering facility there might be a wi-fi network and the requirement here is basically say okay this this network needs to be segregated from the network that's being utilized for the sports wagering system so your not your wi-fi is not going to be on the same network as the kiosks basically so another minor change the jump through here is we're talking about just one second madam chair does she have a question i kind of lost up a little bit katrina i'm sorry um no that's okay the one about the wi-fi but the guest network yeah so it's a normal industry practice to segregate your guest access so if you remember when we had guest wi-fi at the gaming commission on our floor that was um supported by eots it said guest and you didn't have access to any of the domains or any of the servers or the applications or anything else like that and that's because it was segregated away from all of the core systems so just you know simply explained it's to ensure that the guest network doesn't traverse traffic that has their core systems sitting on it so there's there's no sort of implication or risk it's to completely keep it separated from the organizational systems and that was a change that was added to um that was language mike can you go back to that section right there i wanted to well yeah i wondered why is that massachusetts there's that would be no the gli standards they modified the language in gli 33 to reflect that oh yeah so that was updated that w lan was a little bit more towards like mike was saying hub and spoke methods this really um really updates it for technological standards today yeah the the whole wireless uh the whole purposes of this particular section is more focused on cases where you had where a jurisdiction might only allow for wagering within a particular gaming facility um we've seen this on tribal lands and in other states such as uh south dakota and mississippi uh so we just modified that section to include the additional provisions for any sort of uh wi-fi network not enter interacting with the private network utilized for um communication between kiosks or or um points of sale thank you and then just one last section here one last modification we made to gli 33 for purposes we'll get to change management when we get to the next section or the next 244 is um talking about cloud services so basically and we've seen this in the majority of existing sports wagering jurisdictions that the commission can approve the the use of the the cloud for hosting backup data or data that that's you know unrelated to the the initial placement of wagers um once again you know the whole wire act thing that that was discussing about the the wagering server needing to be located within the state um this talks about the backups the the systems that are used to maintain cop backup copies or or unrelated data um once again this is this ties into the operators submitting a request for this to to the gaming commission and the gaming commission approving it and then finally there's a whole section full of full of uh there's a glossary here and yeah that is gli 33 in a nutshell um i guess i had one question we have gli 33 in our packet but it doesn't reflect these guidelines so have the the guidelines been fully adopted by gli that's but i mean outside of the mass chooses the ones the ones that are not mass chooses really died and i wondered if that's you finished your process so this document that i was showing on the left is just illustrating how 243 is applied into gli 33 so all the modifications that were made in the document on the left are based on the document on the rights modifications so it's really just an illustrative mechanism for the purposes of this conversation so the document that i have in front of me in our packet that's gli 33 it doesn't reflect the red line that is the version that is posted on our website that's right so and okay right so the document on the right which is our actual proposed technical regs and standards that's where all of the modifications from the left is being reflected for us Mike was just trying to show you generally how the mass specific edits were illustrated in the gli 33 standards houses yeah that's why i paused on that one because it seemed more universal but it's still really coming through mass through us right Gina okay yes that's that's helpful this might be a good point to address any additional questions i have a question and if we're getting to this some other time just tell me and i can table it um but while you guys are on here the idea of the one step away credit card use you know putting a credit card charge and a ban mo or a paypal how does that play into some of the standards we've talked about making sure credit cards are being used is Joe carlin on this call or no he is not okay no Joe had to leave okay um so do we table it i would table i would table it yes um i'm guessing uh and number one i'm not a lawyer number two i'm not a test engineer um just preferences this that there is responsibility on the payment service provider to flag certain types of transactions because this isn't you're not the first state to prohibit credit card transactions um Iowa is another state who prohibits transactions for funding player accounts as well as uh South Dakota um probably others but those those two immediately come to mind that uh but yeah we could definitely table this conversation uh to explain a bit further great thank you so this is right now you've walked us through this um mic and very very helpful and it actually really forced us to become you know even better acquainted with gli 33 uh in terms of our process today Todd and and i know there may be some further discussion but i just wanted to see Todd but there yeah hey mic if you wouldn't mind can you just take this document down for a moment so we can see each other thank you um so um this uh draft regulation obviously works in conjunction with uh the the two that will follow um this is the first time you have seen this draft it is um heady stuff uh for sure if if you feel like you're prepared to move it ahead that would certainly be appropriate if there are parts of it that be helpful to digest a little bit further um we can uh of course do that as well but you know this is is the just kind of the draft uh proposal is the only question outstanding how we validate that the system blocks credit card transactions yeah so well correct me if i'm wrong i haven't i haven't seen the language that unless i'm missing something the language that mic went through you know the red line uh i was reading language i hadn't today in real time that i hadn't seen oh well let me try to explain that if it wasn't clear because i did get this question once before the language you looked at that mic overlaid into gli 33 is the exact same language that's in the draft regulation that you have seen it just says as you'll you'll see hey you know delete this section and replace it with this and he's just showing you what it would look like if you read the whole thing together the other way to do it would be to have the gli standard on one side and the reg on the other and as you're going through it whether you're a gaming operator a sports wagering operator should say vendor or commission staff is just to look at the two documents uh together side by side um and check to see whether there have been any massachusetts amendments uh to the gli standard but yeah that so the the version that mic went through with the edits in the document will not be in the regulations and that's why it's important to look at the actual regulation itself does that mean i think the exercise he did it was very helpful for me to see i don't know if anybody else struggled with it the language is you know familiar for instance you know there are a few i just oh yeah i saw that as a leak but i it was really helpful so if we're looking at the the right that you want us to turn to is 243 on one right Todd well that's what we just looked at right and so all the delete sections are all all in the right side i think the challenge was when mic was going through the gli 33 document that he marked up unfortunately he didn't scroll at the same time on the right side to show you where the respective tech rag really addressed that and i think that what that's what might have been and i was trying to do that in real time and right so i think he expected the dual scrolling and i think that's mic where they might have gotten a little bit lost so everything on the left is reflected on the right but with either a delete with a new um with new language or an edit with new language yeah but and i i i feel like i kept up with it missioners are you all comfortable with it and the only outstanding question would be out the credit card what do you want to spend more time with christian huh christian skinner so madam jam comfortable with it as presented but but i've had the benefit as as the commissioner assigned to technology to review these previously i i would say that that was before we had the benefit of the gli training and by the way kevin gaban matt is it they did a fantastic job but um you know one of the things i'm wondering is whether the piece on virtual event wagering should be included in the regulation as a deletion so when i read these standards i didn't have the benefit of again understanding what a virtual event was so i just have a better context of the standards and again i mean i don't know what other um aspects of event wagering are included here that should be taking out because it's not uh relevant to massachusetts again like the virtual event wagering piece so i was reserving that for us all right it wasn't so a commissioner skinner and all the reason i i didn't propose that it be removed altogether and as mike certainly mentioned and alluded to is the definition of sports event or sporting event in chapter 23 and does afford the commission some discretion to decide what types of events will be allowed and not allowed and as described that is something that certainly the commission may elect to allow at some juncture maybe not right from the outset um so i think and correct me if i'm wrong mike and all by virtue of its inclusion in gli 33 it doesn't authorize the activity it just means that if the activity is authorized these are the standards that will apply correct that's why i thought it made sense to keep it in but um i i take your point commissioner skinner yeah and i understand i understand i understand that i just wonder if we should be a bit more intentional in what we choose to include um you know then then we are right now with you know the reserved sections as i mentioned earlier the um you know the purposes of these standards are to open up for any or all possibility but in the end of the day it is completely under the discretion of the gaming commission of whatever jurisdiction who's utilizing gli 33 or um or approving any sort of standards so you know there's there's there's some section here talking about you know virtual event virtual events the reason why we kind of separate it out and create a section for it is there's a lot of requirements involved in it if you are now having a virtual event there's software involved with generating and controlling this event and that's the only reason why we separate it out as uh you guys will see in the coming weeks and this is this is already in the document that we have submitted for review um you know we talk about the approval different types of events e-sports events uh like uh collegiate events things that aren't um basically any events that aren't um prohibited per statute and we do provide full discretion to the gaming commission to approve set events yeah so first and foremost like i spoke that's why i included in the virtual part earlier first and foremost the commission has the approval process of what types of events and types of wagers that can be offered uh by the operators that's first and foremost um say there was a global event that shut down all sports imagine that could possibly happen i can't know um uh uh and the operators were like hey you know all sports are shut down we have no content but we have this engine that runs off a regulated compliant r and g of virtual events we would like to offer that so if if an mgc says okay we'd like to approve it but wait a minute now there's no text standard for it because it got removed the other thing the other benefit i think uh commissioner skinner is that as you consider whether to allow this at least you have defined parameters about how it's going to be regulated if you should approve it yeah so the first and foremost process is the submittal and approval by the commission of what events are offered that is the outstanding um and if i may add commissioner skinner commissioners and madam chair you know drafting these tech regs were a little bit challenging technology changes on a dime and and there's always new things there's always new this new thing that's coming out so one of the things in our conversations with gli was to try to keep the language not as open as possible but to be reflective should any technological or any needs change in the example of covet when covet happened everything got shut down on the land-based side because of the physical contact there may be an opportunity for a virtual event to substitute for a physical event and so this lends that language to be able to be utilized but again entirely up to the commission entirely up to one minute i just want to pause because this is on our agenda i think um and it reflects i think as mike just printed out everything that is prohibited by statute it it allows us to consider down the road and i would argue that probably we would mark up that would be a discussion for um under an agenda item because i think we'd want to learn more about why we might want to prohibit something and into your point perhaps virtual um commissioner skinner but i don't know if we would be in a position to make that kind of a determination today anyway under the agenda um without knowing more you know for for instance you know um we don't know what we're going to get for applications right and the products that might be conferred that's just my inclination commissioner skinner to keep it wide open now and then we're going to have on our agenda those the items that we are going to determine that folks can get on and it's my understanding that we might go wide but that but we might start narrowing on it and so we might not be prepared for virtual then but today might not be the right time to to eliminate any option but i'm i'm deferring to my fellow commissioners on that um correct one thing the idea that it's that we're made in this document we're not meant to to close doors except where the statute already closed that door so for instance there was that section i mentioned where we're talking about credit card transactions we made the modifications to that because 23 and explicitly says no credit card transactions that statute and that's going to require a whole law to change um so that the other section that talks about personal personally identifiable information also a statutory requirement um but you know once again something like virtual offense for you know prohibition of any sort of prohibition kind of you know that's kind of where we leave it on a regulatory decision on a case-by-case and not so much trying to close the door shut right away commissioners do you have comments mr skinner you raised a very very fair point um how are you feeling about it now yeah no all the responses make perfect sense i was drawn to the virtual event wagering because of the statement that it's not offered anywhere else in the united states and that's not that's not entirely true actually um so new jersey and i'm not mistaken pennsylvania also offer it i know for a fact new jersey does and other states including nevada allow it okay you know and my concern was just you know more along the lines of you know massachusetts being the first jurisdiction so i got a little you know anxiety around that well and i think it's fair i think i think i don't want you to be anxious because you're going to have an opportunity to talk talk about it down the road when we have to um make our determination so just put it in the parking lot maybe your anxiety will go away more as you learn more but you know bring it back for that discussion i think we're going to have that's going to be a very critical discussion um with respect to our offerings it'll probably involve another long meeting yeah and down the road as they say like even even if no one requests virtual sports for like five years you know if they're five years down the line some operators like you know what i'm gonna offer virtual sports right i want to offer virtual sports and they make that request you guys have questions you know feel free to reach out we'll we'll definitely uh do our thing well i like chain is um uh observation that perhaps during the pandemic and let's not hope for one of those again that that could have been something that was a an offering that people would have enjoyed uh in in its and it's a computer generated imagery so i will add um the heavy regulated market out of the uk which is considered the gold standard for eye gaming uh has had the allowance of virtual events for i almost say i'm almost a decade uh it they've um they've been taking they're taking those bets right now as we talk um in a heavy regulated market there so well anyway i think we we put in the parking lot or pin it um whatever phrase you like best but Fisher Skinner and you know we'll revisit that and the the other the other categories that be an exciting uh discussion okay other i i have the chance to kind of go back where i was able to say oh yes i see the language now and it's you know familiar to me i don't know if everybody else has been able to navigate the discussion would you be willing to to move on this today commissioners in light of i think we've got one question outstanding about the credit card but i think yeah it's sure right now that it meets meet some it meets everything we need right yeah madame chair if i may i think i can address that i'm not an engineer but i do review test scripts on occasion and so what practically and and and functionally what happens after these standards are adopted is they'll take the standard and all the other requirements you for massachusetts and they'll determine it has this product been submitted before um and have we conducted a test against that version of the product that is being submitted for massachusetts or is the code identical that we can use those prior test results to to certify that particular requirement for massachusetts very very similar to the way we do it on the land base side and so because there is a prohibition against credit cards each platform will be analyzed to verify that it has the capability to do that that it is turned on and that the the implementation that is deployed for massachusetts um has that functionality enabled and then periodically your team or our team depending on how you decide to set it up during your periodic audits of the systems will will again validate that that functionality is continuing to work properly is that helpful commissioners richel regarding just to follow up i know i asked you this you know kevley when i met you um the episodes and other jurisdictions recently where the vendors were a rony c alumni credit card charges through were those the one step away or were those actual credit card charges can you see how i was able to find anything about the checks and balances in there so how did that happen yeah i wasn't able to find anything in tennessee other than there was one operator that i believe was running some transactions through their payday loan company there were two jurisdictions i believe that had it and it was uh and i think two different operators yeah i looked to the news articles and i asked our team and no one had heard that so if you could forward those articles to me i can chase down the answer and so how did the how did the going to the loan get by tally it was outside the system i think it was in the retail locations anybody know the details about that i do not yeah i can't say i do yeah somebody can just circle back to me on that one i'd appreciate it um and then my question really from here is is to our itp people and uh commissioner schenner who've been involved in this really is relying heavily on their comfort level with the the status of these today in terms of whether i'm willing to vote so katrina had to jump off because she's conducting interviews uh this afternoon but i will say that i am comfortable with the um attention to detail that has been given to these regulations um the attention to detail that has been given to the gli standards and conforming them to the massachusetts uh statute um i am more than comfortable moving forward um i appreciate uh the assistance of gli certainly katrina who has given this her full attention in you know not so ideal circumstances um you know she's relative to you know her unavailability over the past several weeks so um i think we are in good shape on these to move forward and and i know commissioner brian you asked to hear from me and katrina but i would ask uh todd to to jump in and share his um sense of whether we are ready to move forward whether he's comfortable with as they are drafted well i was going to ask my fellow commissioners um if they were comfortable commissioner hill well can i just see i'm not my comfort level depends on those answers madam chair so if we could just if i could hear from legal that they're comfortable then i'm i'm good to go so just to bring something up real quick and i know this isn't on the agenda for today but in the sports weighting account regulations we um that we that we drafted and submitted that includes the uh uh it approved types or or you know allowable types of uh funding your player account so that aspect of the credit card account or the the prohibition and the credit card and extensions of credit is reiterated in that chapter and uh we can we can always elaborate further on it if there does need to be a regulation put in within the confines of of that particular chapter as opposed to um appending the the modified gli 33 it might make more sense to to make those modifications in that area okay and then just so i just saw the article it was iowa it was cesar sportsbook iowa find them 60 000 they allowed credit cards to be used on their site that's that's what caught my eye there was another one um i lean to in iowa and to answer your question what i found was is people were purchasing debit cards with credit cards right so it's another one step away right yeah it was the one step situation it's like a different scenario for one step away so i guess the the question too and and you know definitely that is a question you're gonna have to get resolved is how far is that step for that you know credit card purchase because i mean what's to stop me from going to a bank and getting a payday loan and taking that money going to a casino or sportsbook and placing a wager i'm not using a credit card to place a wager but i use some sort of credit extension somewhere down the line and the prohibition if my memory is correct and then i hate to quote law from memory is that the casinos are prohibited from except that the operators i'm sorry are prohibited from accepting credit cards it doesn't mean that a consumer can't use a credit card in one of the many ways you can get cash uh to then use on a sports wagering transaction right and that's a that's a question i'm sure the five of us will have in terms of if the purpose is responsible gaming at what point do we draw the line to say you know getting getting the gift card the prepaid gift card or getting the Venmo pass through is too close no and one thing too to talk about your your available funding methods is those methods could be you know there's always a provision where when the operator presents it they're they're presenting the to the commission their internal controls of available funding methods and any controls used to mitigate uh or to ensure that they're only offering the approved methods um so so say for instance you might have someone who operates in multiple states who who allows credit card acceptance in so like Connecticut for instance they allow a credit card to be tied to your account but once the player crosses you know if the player is using funding their math Massachusetts account they're not going to be using a credit card so can i turn back to your skin are you um suggested that we turn to attorney Grossman i guess um i assume that given that this was your agenda item that you're comfortable with the the recommendation you put forward today on this i am and i stated that matter i actually i wanted to hear from i wanted to hear from legal and so that's why i think she had turned i'm turning out to attorney grossman thank you but i didn't want you to think i was bypassing you i made the assumption that you're all set go right ahead yes thank you no i appreciate that yeah i am comfortable with with the draft i think it was well done certainly mic and team have an expertise in this particular area these are their recommendations we have looked through them there were a couple of tweaks that were proposed along the way it is interesting just to note and this doesn't answer your question directly but if if you picked up on this that there are references to internal controls and a few other things in there that we will have to ensure are reconciled with the coming drafts that are going to appear before you shortly so there is certainly some buttoning up and reconciliation but as far as the actual content of the draft that you have before you i am comfortable moving ahead with this there there will be some trial and error perhaps with this and a lot of the regs that will have coming before us and we will have to be comfortable making certain adjustments as we go but there were certainly no glaring issues that jumped out at me that would have me recommend that you pause on this one at the moment thank you commissioner bryan and madame chair i did it but i we're talking over each other and i need i need to make sure we don't talk over each other please um it's just a matter of coordination and i and the reason why it stopped is because i can see other people wanting to speak commissioner skater do you um you want to go ahead or i was going to actually i thought commissioner bryan wanted to go ahead so no okay commissioner skater commissioner bryan asked about katrina's comfort level and moving these forward and because i don't want to speak for her i have a text message directly from her saying that she is okay moving these forward yeah and i i felt like she made that representation to us so she's been along all the way with you okay is there somebody okay attorney madam chair if i may i just add one more thing that i think everyone already knows of course but it's helpful in in this context here uh this is of course uh the first uh foray here uh into these regs if you adopt them by emergency they'll go through the formal promulgation process we will certainly have another opportunity to look at them we'll put them out for public comment so if there are any issues that anyone else spots and they want to bring to our attention there's an opportunity to do that um and so i think this is this is a good time to if everyone is comfortable to just get the process of moving ahead in this way and we can always come back in the coming weeks and months and make any adjustments we need to missional brian no that's good you're good yep okay so um again if we've answered all of our questions the gli excellent presentation today for me it was my first time to really review it with you very very helpful commissioner maynor do you have any questions for gli no just to thank them um and to thank commissioner skinner for her insights also very helpful making a decision of course we have two more sections to go before we uh congratulate everyone too much at this stage i guess i'm wondering we haven't broken around well that gives me time to thank katrina too even though she's not on so um oh i thought that we let's go through to the conclusion of that one so we don't vote on this one now you can um i think it would be okay to wait um until we get through everything um and then take a kind of uh collective vote um so just let me let me go sorry manager no i just want to so everybody's all set and what are we moving on and next yeah so i was just kind of kind of calibrate everyone here so we got through item number um it's four uh b five well we're gonna move on to b six now and so b six is the kiosk uh part of the proposal and it comes in two parts one of them is the real substantive piece the other is more of a kind of administrative part so you'll see you have before you it's uh 243.0 excuse me i'm sorry have a tail oh two um which is the the the area where we will reference over to 143.07 and that is the section of the regulations where the kiosk standard gli 20 is adopted by reference with amendments and it's made applicable to sports wagering so this is obviously a critical piece of it too i think we actually got through a really huge piece of it already with the gli 33 piece but the next two parts that are coming up are equally as important so um there are these two more parts um that we would like to try to get through today um and i'll turn things back over to mike to talk about gli 20 um its adoption the you know the distinctions between the 2011 and 2019 versions um and what it all means so um madam chair and commissioners if i may turn it back over to mike thank you um commissioners again i i am apologize for not thanking you because we we've worked on the assignment and and i know how much you are in technology so i'm thrilled for you if there's anything you want to promise here then go right ahead before we start with gli thank you madam chair no i'm good we can move right into gli's presentation okay thank you and turning to mike thanks so much okay so basically this doesn't have a large um like breakdown where you've got i need it you need a markup document um fortunately the adoption of gli 20 is fairly simple fairly light touch and basically mimics what was already previously adopted for gli 20 in in uh section 143.07 what i do want to bring up what i what i kind of mentioned was that gli 20's modification in um two two version 2.0 did expand the functionality of the kiosk to handle uh account management and uh sports wagering or event wagering and what we did too is we streamlined the the layout in the format of the standard to focus more on the aspects that are going to be at the kiosk level and kind of defining our software requirements for the kiosk to say that for many kiosks especially in sports wagering there is two aspects really there's the front end aspect your physical kiosk terminal the thing that the player interacts with and then there is what we refer to as a back end platform a back office platform and that might be a server that is either built in directly into a system like a sports wagering system or it might be a built into some sort of other monitoring system or server based system and that is basic and the other thing that we want to do too is we want to streamline our references to gli 11 for handling things that the common technologies that were utilized between both gli 11 and gli 20 in particular um your your bill valid validators and your printers and your coin acceptors and hoppers and the like and we want to kind of draw that parallel directly to the between the two standards such that you know for for the purposes of testing your your you have a consistent set of standards between both gli 11 and gli 20 because we did update gli 11 uh after gli uh 21.5 came out and we wanted to ensure that there was consistency between the two the last thing I want to bring up is we included a statement in here uh in gli 20 that that specifies that this only applies to uh this only applies to proprietary developed hardware and software it doesn't apply to any sort of off the shelf components it does apply to the modifications made to off the shelf we refer to as modified off the shelf but we didn't want to apply it to components that were literally off the shelf and this is critical for something like uh like kiosks used for sports wagering because kiosk kiosk used for sports wagering might use a commercial printer as opposed to the type of printer that you'll see in a in a casino a ticket redemption terminal a your tito voucher for lack of a better for lack of a better phrase so this is basically the the high level summary of changes that were was made to gli 20 to modernize it and open it up for usage for sports wagering and other other regulated activities okay so that's um and again so just to come back to the drafts momentarily so there's two drafts before you for consideration here the first is the draft edits to 205 cmr 143.07 that's the red line version where the standard is updated as mike just described from 11 to 19 and then a few uh edits are made and then there is the draft to uh 243.02 where you'll see it merely just says that the sports wagering operator and sports wagering vendor making use of a kiosk for sports wagering shall comply with 143.07 so those are the two drafts before you that cover the kiosk situation okay if uh if we're good with that we can move on to 244 so 244 just by way of refresher uh covers a lot of the administrative aspects if you will of the technology and the use of the equipment it talks about the certification process change management um and all of those things the only note i'll make before uh turning back to mike to talk about this a little bit is that you'll see at the end is 244.06 where we note that that will be reviewed separately so that language you'll recall the commission has already adopted that is the the part that talks about essentially allowing independent test labs that are certified under the gaming uh rules to become certified under the sports wagering rules as well and we did that in the early days uh you may recall in order to be able to contract with gli to do what they're doing right now um so that that's part six and that's why it's not included in this draft but when you see the final version it will be in any questions about that or are we okay to jump right into the draft okay okay so mike if you will um we can kind of pick it up at 244.01 and maybe just take a quick walk through our draft language sure um i want to share this can you see my screen now mike if you're able to make it a little bit bigger that would be great for commissioners you don't have to i am working on it i know there we go that's good that's excellent okay so basically 244 is heavily based on 144 so we parroted a lot of the the layout and requirements from 244 within uh from 144 within 244 uh the first one section we talk about is sports wagering or wagering equipment um basically we're defining sports wagering equipment to to cover any sort of equipment that is used for sports wagering specifically for the operator um that includes your sports wagering platform your kiosks um any sort of equipment um and we've used we've seen this definition from from other jurisdictions such as Ohio and Wyoming and Colorado and the like the other thing too we wanted to define that you know sports wagering equipment doesn't necessarily cover things like the internet um or any sort of intermediary software that connects to uh you know the the bank so we're not going to consider apple ipay to be sports wagering equipment if they're using apple ipay to fund a sports wager for instance um and any order device so for instance your mobile phone is not considered sports wagering equipment um now 242 we talk about testing and initial approval or testing approval for initial and for critical updates for sports wagering needing to be tested by an independent test lab and we talk about the operator or vendor providing the lab with any sort of documentation or materials necessary and as joe carlin discussed earlier this would include a witness bill for source code verification and and like um so and the reason why why I say sports wagering operator or sports wagering vendor is because what we've seen in sports wagering is sometimes we'll have an operator develop their own platform or or software equipment and everything is submitted under them so you know you'll have someone like caesars who is an operator and they have their own kiosks they have their own server and everything like that and then you'll have another opera another operator out there um who will out so will be an operator name so an example would be maxim bet um they utilize they have a partnership with a vendor who you know they're just a name that they slap on to vendors platform and you know just for just for vocabulary real quick you'll hear you might hear the term b2b and a b2b would be a sports wagering vendor so that's why we meant we say sports wagering operator sports wagering vendor here but so I don't get too lost in the weeds the next section we talk about if it's if it meets the expectations set by the technical standards which would be you know from 243 as well as like any other requirements set by the commission the lab will certify the equipment um and certification can't you know the the operator can't launch without any sort of certification or modified equipment critical modifications to equipment without certification um number four talks about the the commission side of things or the you know the once um a sports wagering system is approved by an independent test lab it's still up to the commission to approve that certification to take that certification and improve the sports wagering equipment and copy it a lot of the wording that was from 144 into here for that purposes now number five ties in the gaming technology lab which might require any sort of additional testing if it deems necessary and that might be some that could be something like onsite testing of the kiosks before you know clearing them for going for for launch or it might even involve Katrina and her her team hopping in a car and drive you know doing their own spot checks of geolocation on top of what you know the lab is already done or what what the itl is already done and then number six was copied straight up from 144 where it talks about you know the operator vendor notifying the commission if it's aware of any sort of negative action in other jurisdiction now 244.03 this section talks about integration and change management and integration is going to be you know something that's critical for your third party service provider so this would be your payment provider this would be your geolocation provider this would be your identity verification provider and what this is essentially saying that you know the the operator at the end of the day is responsible for everything and that integration testing for any sort of new components would need to be done by an independent test lab so say for instance um you know you you have a a sports betting provider a sports betting operator and they're using um identity verification company one and they go ah i'm not friends with these guys anymore i want to use identity verification company two now well that integration testing would need to be done by an independent test lab and you know that's outside of all sorts the the the whole license vendor thing that's unrelated to this so this is what this part this section is talking about and number two here is where things get a little get get uh interesting where we're basically talking about change management now change the the thing with sports wagering is it's not a slot machine it's not a machine that you seal up on the floor and nothing is going to change in its environment and it's just sealed uh sports wagering system uses components all across you know all across the realm it's it's not a air gap system it is it's on the internet um it uses the internet to communicate feeds even for you know your cat ones and cat twos there's the aspect of the internet and with that in mind there's constant updates to these systems and constant improvements to these systems and as opposed of you know locking down everything and requiring everything going to a lab and being certified for every little change in that environment what this process focuses on is identifying critical components and a procedural process to identify updates that need to be evaluated by an independent test lab components that don't need to be updated by components by an independent test lab for instance um changing the colors because Thanksgiving's coming up say you have your you know you've got bar stool and they're like I want to change background to Christmas colors because you know it's the season they don't need to resubmit to an independent test lab and have that value and go yeah that's good um they can make such changes and I know it's very superficial but it's something you know they they they enjoy the other thing too is there might be some critical updates and basically the whole point of the critical updates is there might be a breach in the internet you know a data breach or something and they need to update their servers right away like oh my god I can't discover this we need to patch this right away well we can't just run this through through wait until the lab says it's good to go and wait for the you know wait for the commission we need some sort of emergency process emergency patch process and so this is all covered within our GLI uh GLI CMP which is our change management program guide and it's posted on our website and it it it identifies the various levels of it identifies various things first off it this is something that is tied back into GLI 33 when it talks about server security and technical security controls and requiring your annual like security audits and it also ties into identifying you know maintaining a critical asset registry of all the critical sports wagering equipment or system components and goes through a process of level one level two and level three changes now level one changes will be completely cosmetic or something that doesn't really affect anything we we term that as no effect level two would be something as low effect and level two would be something minor which you know it does affect a regular process but it's more of a regulatory enhancement and then you have level three which is a critical process which is like changing your your changing changing out your geolocation provider or you know fixing a critical error in your reporting or adding a new feature adding virtual events um when once approved once the concept's approved by the commission you know and and based on those levels would determine whether or not those changes go to an independent test lab prior to need to go to an independent test lab so general consensus is level one doesn't need to go to a lab but as far as level two and three is concerned those get reported to the the the commission and it's up to the commission to make the call to basically say yeah this is this this change is minor and can go and can be launched or hold on you need to get this tested by independent test lab first and that that is going to be on a case by case basis for level two and level three and the other aspect there is even if you review a change for level three and are like you know what this doesn't need to be tested prior to launch there is built in within the the the GLICMP a requirement that the changes do need to be tested at just they don't need to be tested prior to deployment in the live production environment basically the system that the the users are interacting with and with regards to all these changes all these changes are recorded in a log and section b here it basically says that all these quarterly change reports need to be evaluated by an independent lab and they're ensuring that these changes are properly classified as level one level two level three and you know the higher focus is on is making sure that things that weren't incorrectly reported as a level one and therefore slip through the cracks of whether or not they need to be evaluated by an independent test lab and item c here basically reiterates an annual recertification of the entire system and the reason we do this here is because you might see a system and you'll have a mod of a mod of a mod of a mod etc but the annual recertification reestablishes a baseline saying okay there you know these are mods to the 2022 version of this platform and now this recertification is the 2023 version of the platform and then from there mods are going to be made from that so and the other thing too to bring up here is the reason why we have this annual recertification is to reestablish your independent verification of signatures for the entire system so you know when you look at a letter you're going to see version one of a system and when these change logs are submitted there are going to be these logs and they'll say if there's any signatures that change in those critical components and if there is a letter from a lab for a level two level three change that will also have the signatures of the critical components that are changed but this annual recertification establishes a full fresh baseline of the system it's like if you got it straight off the line so it'll have fresh signatures the fresh letter it's just new so 204 244 it just talks about the requirements for testing regards to the type of report we issue this is copied from 144.04 this is all the information copied from 144.04 same thing with 244.05 a copy is from 144.05 and that that's it for 244 as Todd mentioned 244.06 it's been previously discussed and what not thank you my commissioners questions for Mike is anyone leaning in Commissioner Brown are you leaning in no I have a question if there's no other question right now is there any reason other starting reason not to adopt the annual review recertification process is there been any push guy I mean multiple jurisdictions have adopted the annual recertification it's it's become standard I mean Indiana Illinois requires it twice a year but it's more common to be once a year so you know Indiana Wyoming leave Michigan not 100% but a number of jurisdictions do require annual recertification for the purposes I've mentioned you know they're establishing the baseline and also to clean out the records it's analogous to closing out your rear year end books because this is dynamic with a slot machine we test all the software on the machine all the games that are on that machine and you get a signature and that machine might sit there for 15 years and never change right these is much it's much more dynamic and if you can imagine trying to trace your way through three years of change management patches it could become a mess in a hurry so it's kind of like closing your books at the end of the year and starting a new fiscal year just a follow-up and so Illinois was that by statute that they had to do it twice so that's just their I think it's by regulation okay commissioners I think the recommendation today is for angle right and Arizona requires it once every 15 months but Arkansas requires it annually um Connecticut um DC Indiana Iowa and etc thank you other questions for for Mike okay Richard Skinner you were involved with this spot following on this as well with Katrina do you want to add it you're all set okay I got a thumbs up for the record um um now Todd do you want to add in and then we have really the whole GLI groupings today for consideration yes so that that's right no I think that I guess I would just add that I am comfortable with these drafts I think they were certainly prepared by the best people equipped to to do this we have looked at them there are parts that I've looked at with outside counsel directly and we're comfortable with certainly what they say I think they're really well done actually of course like before they'll be put out for public comment and if if there are particular areas of concern I'm sure they will be flagged and we will of course have an opportunity to go through them in a little more detail or I shouldn't say more detail but we go through them again just to confirm that but otherwise I'm comfortable if you were to move forward with these today to move the process ahead and and we can kind of take it from there so there are four drafts before you there's a 243.01 243.02 143.07 and then 244.01 through 05 there is a small business impact statement that is in your packet at age 173 I believe which covers all of them together there aren't separate statements for each of them so if you are prepared to do so that would be the request Mr. are you prepared to move today if so I'll take a motion Mr. Skinner are you prepared to move today or no I am prepared to move except I am not prepared to move on the second component of the motion that speaks to emergency promulgation so I'm happy to move on the you know moving these forward for public comment but all right so I'm hearing that we don't why don't we just go over the impact of not using the emergency regulation Todd yeah so if we don't do it by emergency that would mean that they will not be in effect for 60 to 90 days and I have to pull up my calendar here but kind of map out what the product out there sorry just because I ran this just so we would have a sense of the date these would go into effect on February 17th if we were to file the stand in the ordinary course tomorrow okay do I have a motion madam chair just for discussion purposes first if we could do these individually which I like to do I would make a motion for the first one if that would be all right with the rest of the commissioners I'll take a motion okay madam madam chair I move that the commission approved the small business impact statement in the draft 205 CMR 243 as included in the commissioners packet and discussed here today second madam chair and commissioners if I may I just want to clarify that includes 243.01 and 243.02 have it yes so your motion is amended to reflect Councilor Grossman's inclusion correct correct thank you try the second second could you restate the motion please commission yeah I move that the that the commission approved the small business impact statement and the draft 205 CMR 243.01 and draft 205 CMR 243.02 as included in the commissioners packet and discussed here today second okay all right thank you for the read read um okay any further questions on that motion okay I'll go ahead Commissioner Brian hi Commissioner Hill hi Commissioner Maynard hi Commissioner Skinner hi and I vote yes five zero okay madam chair I move that the staff be authorized to take the steps necessary to file the required documentation with the secretary of the Commonwealth by emergency and thereafter to begin the regulation promulgation process I further move that staff shall be authorized to modify chapter or section numbers or titles to file additional regulation sections as reserved or to make any other administrative changes as necessary to execute the regulation promulgation process second is there any questions or edits on that motion okay Commissioner Brian hi Commissioner Hill hi Commissioner Maynard uh Commissioner Skinner hi Commissioner Maynard hi and I vote yes five zero thank you all right we'll do it in the next the next round Commissioner Hill you're on a roll um I just want to be clear that I'm making this motion this is for 205 CMR 143 um Todd is that accurate yes 143.07 specifically thank you madam chair I move that the commission approved the small business impact statement and the draft 205 CMR 143.07 as included in the commissioner's packet and discussed here today second thank you any questions okay Commissioner Brian hi Commissioner Hill hi Commissioner Maynard no Skinner I'm so sorry you've I'm going around the counter conquest yeah we seem to have a new order today but I there is a though really might be a little fatigue Commissioner Skinner that's about it Commissioner Maynard hi and I vote yes five zero madam chair I would move that the staff be authorized to take the steps necessary to file the required documentation with the secretary of the Commonwealth by emergency and thereafter to begin the regulation promulgation process I further move that staff shall be authorized to modify chapter or section numbers with titles to file additional regulation sections as reserved or to make any other administrative changes as necessary to execute the regulation promulgation process second any questions or edits on that Commissioner Brian hi Commissioner Hill hi Commissioner Skinner hi Commissioner Maynard hi I vote yes five zero then Commissioner Hill um Todd just just being clear uh we will be doing 205 CMR 244 yes it's 0.01 through 0.05 specifically thank you madam chair I moved that the commission approved the small business impact statement and the draft 205 CMR 244 0.01 through 0.05 as included in the commissioner's packet and discussed here today second thank you commissioner okay any edits or questions on that one Commissioner Brian hi Commissioner Hill hi Commissioner Skinner hi Commissioner Maynard hi and I vote yes five zero madam chair I move that the staff be authorized to take the steps necessary to file the required documentation with the secretary of the Commonwealth by emergency and thereafter to begin the regulation promulgation process I further move that the staff shall be authorized to modify chapter or section numbers or titles to file additional regulation sections as reserved or to make any other administrative changes as necessary to execute the regulation promulgation process second thank you commissioners any questions or edits on that one commissioners okay Commissioner Brian hi Commissioner Hill hi Commissioner Skinner hi Commissioner Maynard hi I vote yes five zero how do we do Todd now Madam Chair and commissioners I'll join you in thanking Mike Kevin and Joe and the whole team for their great work on these uh drafts and helping us reach this day where our work is certainly not done uh this was a huge step forward though uh for us all and and so I think there's a lot of great work for this so thank you all thank you Todd and commissioners and special thanks to Mike Robbins he's he's always a joy to work with he has meticulous attention to detail he catches things that three uh three others of us sometimes miss and and uh so it's always he's the he's the captain of this particular uh aspect of the team and uh but it was it was a as always a team effort and uh along with with your staff Madam Chair and commissioners they are wonderful to work with and we're really enjoying the engagement so we appreciate it Kevin does that get us through our third part of uh GLLI high school or do we still have to go through yeah I think I think Matt and Gabe are working on diplomas of some kind and maybe we'll have uh special robes made up for February 1st or whatever date the target is yeah Mike you did a great job could be a professor thank you Mike I think Kevin we're all fearing the test that they're threatening us with that's we want the virtual but we just don't want the test that's all um and we need to thank your colleague who left earlier he too was very very helpful on the testing process Joe um so thank you to all of you I know that we are benefiting tremendously from GLI's work here um we really appreciate it the training and um look forward to the continued engagement precious do we have anything else for the GLI before we turn to Director Lillio's legal team are we all set we are set thank you very much okay great work commissioners okay so now we have one more item on the agenda Director Lillio's you got an update for us hi good afternoon the update is brief but very important and that is that all eyes are on Monday Monday is the application deadline for the operators so this is an important time for the operators we have been meeting with them in groups by their category we have been answering their questions and I know that they are working hard on their applications now and as for our team we are working hard to make sure that Monday goes smoothly with that initial processing so really the big the big process update is all eyes are on Monday and we continue to plug away at regulations and other preparations but everyone's focused on Monday any questions for Director Lillio's okay any commissioners updates all right but I need a motion to yes Commissioner Hill um I don't have a commissioners update but as you are very kind to allow me to put off the minutes until the end of the meeting thank you see I need the I needed the reminder thank you so much uh so so madam chair I would move at this time that the commission approved the minutes from the May 12 2022 public meeting that are included in the commissioners packet subject tending necessary corrections for typographical eras or other non material matters second everybody's got a chance to review them commissioner brian we waited for you we had a chance I'm assuming yeah I had seen them before excellent okay um no edits the motion all right Michelle brian hi mr hill hi mr skinner hi mr maynard upstairs thank you and I go yes thank you so much before we get the motion for to adjourn I I don't want to just pause and and take time to thank um and I know she's not even listening uh but crystal Bushman uh this has been an extraordinary effort um on her part to keep us organized with the materials she's been working and and is so appreciative of all of the work that she does with each division to keep us organized I know she's off at a meeting right now um Todd and I know the legal team has been working so closely with her we um are on of course of you know multiple multiple meetings um we knew that coming in and she um she hasn't blinked and so for that I just want to be on the record of thanking her in her role um and the support she provides us each and every day and I'm terribly grateful for that so there's I could thank each and every member of our team I just today wanted to highlight crystal as she continues a lot ahead okay so thank you um anything else commissioners all right um then now I do need a motion I move to adjourn second okay discussion commissioner bryne hi commissioner Hill hi commissioner Skinner hi commissioner Maynard hi I vote yes thanks everyone thank you to GLI wonderful meeting very very very helpful excellent work guys