 All right, good morning, everyone. This is a convening of the Massachusetts Gaming Commission. And because we are using a virtual platform, I'll take a roll call of my fellow commissioners. Good morning, Commissioner O'Brien. Good morning, I'm here. Good morning. Good morning, Commissioner Hill. Good morning, I am here. Thank you. Good morning, Commissioner Skinner. Good morning, I'm here. And good morning, Commissioner Maynard. Good morning, Madam Chair. I'm here. All right, we're all set to begin. Today is August 18th, my anniversary. So yesterday I stumbled upon the fact that it was the 17th. So here we are. August 18th already 2020 to public meeting number 389. We'll get started first before we turn to our roundtable discussion within a brief update from Executive Director Wells. Thank you. Good morning, Madam Chair, members of the commission. I just have two items I'd like to address this morning. One, I want to reiterate the importance of the notice and intent that commission approved. That is going to be critically important for our planning purposes. So my request is that any party that is seeking any kind of license for sports wagering go to our website. And I can even share my screen so folks, I can walk folks through where that is. Just give me a minute. Thanks, good. Someone could also help you, yeah. Yeah, so hold on, share. Can everyone see the website right now? Let's see our notice of our meeting and agenda. That's what I'm seeing. I'll show in the wrong thing. Hold on. Stop sharing. Give me one second. All right, can you see the website right now? We do. OK, so this is the homepage for the website. If you just scroll down, notice of intent, right on the homepage, click on that. It gives you the blog information with a notice of intent and then just click on the link. And there's the form right here. So if folks could fill that out, anyone that's interested, it is going to help us tremendously. It'll also give us a list of interested parties. So those interested parties that are intending to file for a license will be able to be in communication with the commission much more easily. So that is critically important. The due date on that is the 31st of August. So the request is that the companies that are looking to get a license fill out that form and give it to us, and then we'll be in touch from there. The second update I just want to give to the public is that we have also posted for our chief of our sports wagering division, so that job posting is on Tuleo and mass careers, as well as the MGC website. We are hoping for a robust response to that position. It's going to be critically important as we go forward with implementing sports wagering. So any interested parties should look at that on our website or on Tuleo. And we expect to be also pushing that out through other venues in the coming days. So just wanted to give that update, and I will turn it back over to Kathy. Thanks. Great, thank you. Before we start our discussion with our guests today, I just want to start by thanking everyone for being here. Thank you to the representatives of our current licensees, the MGC staff, and to the media and the public watching this spring. The legislature passed a sports wagering bill early on the morning of August 1st, just 18 days ago. And Governor Baker then signed the bill into law just this past week on August 10th. Before this official action, the MGC has been keenly aware of this issue and has been doing our due diligence to understand what our responsibilities are as a potential regulator. Again, want to thank Executive Director Wells and the entire MGC staff for their hard work and their efforts in anticipation of a bill being signed into laws while we've already held a number of public meetings on this issue and why these stakeholder roundtables are able to happen so quickly. One is just that this roundtable is just the first of many such meetings that we plan to have. Today we're going to hear from our current licensees on Corboson Harbor, MGM, Springfield, Plain Ridge Park, Casino, Suffolk, Downs and Rain Park. The new law that designates the MGC as regulator also references these entities. In the law, a Category 1 sports wagering license is envisioned for gaming establishments currently licensed and defined by Section 2 of Chapter 23K. That's Encore, MGM Springfield, and Plain Ridge Park, Casino. The law also envisions a horse track where live racing is conducted or an entity authorized to conduct simulcast wagering to be eligible for a Category 2 sports wagering license. That would be Suffolk and Rainham. That's why we've invited these representatives here today to begin the discussion with those with whom we already have a regulatory relationship who will have the opportunity to operate sports wagering should they apply and meet certain requirements set by law in our regulations. In the weeks ahead, we'll be conducting further roundtables with companies interested in applying for a Category 3 wagering license. An operated awarded Category 3 license will be eligible to offer sports wagering through a mobile app or other digital platforms such as a website, but without a working-moderate retail location. The MGC has issues, as you just heard from Executive Director Wells, a notice of intent to learn without commitment the landscape of interest. That notice, as she explained, can be accessed on the Massachusetts Gaming Commission website. We ask any company intending to apply for a Category 3 license to build out this form so we may again understand the level of interest and work to adequately develop our next roundtable. During these roundtables, we will ask representatives about their plans surrounding responsible gaming and advertising. But, and this is an important distinction, we will also hold at least one standalone roundtable on the issue of responsible gaming and advertising, ensuring that those who choose to gamble in the commonwealth have the supports they may need is essential. And MGC put the premium on these efforts and expect our license to be done so as well. And then just in terms of logistics for today, I want to set the stage. We hope that this discussion is conversational in nature. It's intended to inform us all, the public, our licensees and perspectives for its wagering operators and me and my fellow commissioners and the entire team at the MGC. These roundtables should give us all an idea of the work that is currently underway, the work that needs to be done, and through that assessment, begin to understand the milestones that will inform the timeline licenses and the licensees in the MGC will need to get sports wagering underway, including the prioritization of regulation accommodation. I will work to ensure that each licensee today has an opportunity to address the many categories and subcategories set forth in our agenda. And I ask and encourage my fellow commissioners to follow up with any questions, observations, or comments as we proceed. We have joining us two several staff members from the MGC who are available to assist us and the licensees with questions. I ask you commissioners to help me ensure that this is an inclusive process. If I miss anyone trying to weigh in, including yourself, please interject at any time. I need extra eyes because the virtual format can be challenging with as many participants. We understand that there may be a point where a licensee may be hesitant to give a complete answer, perhaps because it might result in a disclosure of sensitive information or perhaps information that could be considered a competitive disadvantage. We will respect those boundaries and thank all five representatives today for the cooperation and collaboration in this public forum. My fellow commissioners, and I want to emphasize as we have already in earlier public meetings that we want to introduce sports wagering in the Commonwealth as the law intends swiftly, but certainly without sacrificing the high level of integrity we expect from gaming operators in Massachusetts. Before I turn to our participants commissioners, but do you have anything that you'd like to add with respect to setting the stage and what we can expect for today? I'll start with Commissioner O'Brien. Thank you, Madam Chair. I think you laid it out pretty well. Everyone who's participating in the agenda today in terms of the licensees, we did this during COVID. It was incredibly helpful, I think, for everyone. In addition to us learning from you, some of the questions might help you going forward, too, as we work through this process. As the Chair said, we're going to do it in a way that is deliberate and protects the interests of the Commonwealth as we move forward as well. So I look forward to hearing what everybody has to say. Thank you. Commissioner Hill. I have nothing to add. I'm Madam Commissioner. I'm looking forward to a very robust conversation today. Thank you. Commissioner Skinner. Thank you, Madam Chair. Nothing else to add? I think you covered everything in your introductory remarks. Just want to say hello to everybody and welcome to this platform. And I look forward to hearing a very robust discussion. Thank you. Commissioner Maynard. Thank you, Madam Chair. Nothing to add, but I do appreciate the time of everyone on here and look forward to the conversation. Excellent. Thank you. So, given that Plain Ridge Park was the first facility that opened back in 2015, we're going to turn first to General Manager North Groundsall. And thank you for being here. Norak, I'm interested in hearing your initial thoughts. Thank you. Great. Good morning, commissioners. Good morning, Madam Chair. If you'll give me just a moment, I'm going to make sure that I have myself all set. I hope that you were able to see my screen. It looks like there's a portion of it that may be overlapping. No, I think we're good. We're good? Okay. Yes, Mr. Norak. Thank you. Okay, fantastic. So, again, thank you so much for taking the time to hear from us today. Plain Ridge Park is pleased to present our initial thoughts with regards to sports wagering and our initial preparations in the Commonwealth. Before I begin the formal presentation, though, I wanted to take a moment to thank the commission's staff, led by Executive Director Wells for their collaborative spirit, professionalism and diligence leading up to today. While there are still many questions left to answer before sports wagering begins, I am confident that, working together, we will achieve an outcome that is in the best interest of the citizens of the Commonwealth. With that, I'll go right into our presentation. And I wanted to start our presentation by providing a bit of background on Penn Entertainment's experience as it relates to sports wagering. Penn Entertainment currently operates 24 retail or in-person sports books across 13 different U.S. states. Our executive team at Plain Ridge Park includes experienced operators and between members of the executive team. We've opened four different sports books in multiple jurisdictions. And finally, we have great support from our parent company, Penn Entertainment. Our experience launching other sports books has allowed us to develop detailed project timelines, job descriptions, and standard operating procedures, which integrate best practices. We have a team on standby, ready to assist us with troubleshooting and any unforeseen scenarios. And our attention to regulatory compliance, both at the property and the corporate level, is strong. So with that firm foundation in place, PPC has undertaken several actions to prepare our operation for this exciting new form of wagering in the Commonwealth. On the compliance side, we've provided commission staff with our retail vendor list, which covers certain areas, such as hardware, software, data feeds, and integrity monitoring. And we've conducted an initial review of the legislation to make sure that we understand what is required from us as licensees. On the human resources side, we have defined our organizational structures, prepared job descriptions, began making updates to our compendium so that we could ready those for submission, looking at our hours of operation, and assessing our staffing needs. On the design and construction side, we have identified potential temporary locations for a sports wagering facility and permanent locations on the casino floor. Our layouts for those are complete and we will be ready to submit those when the commission is ready. On the operations side, we have a project timeline for retail operations launch. Which includes a hiring timeline, training guides, and standard operating procedures. We've confirmed the availability of our hardware and our house rules are ready for submission to the commission. And then I think kind of that leads us into what's next. One of the things that we as an operator look for as we begin our preparation is an official launch date. And that date's important because it feeds a lot of other decisions operationally that need to be made in terms of when we will start construction, whether or not we will need a temporary location, the initiation of our recruiting efforts, a goal date for equipment delivery, and a multitude of other operational decisions. As we've looked at the rollout of sports wagering and other jurisdictions, there are two main things that have stood out as things that can potentially slow down the process. And I just wanted to talk about those briefly today. One is just the licensing piece. We understand that occupational licensing for the people involved in this activity will begin as we begin the hiring and recruiting process. The vendor and operator licensing, PPC is ready to begin when the license type and submission requirements are determined. And we are beginning, we are gathering the expected information that we anticipate the commission will be asking for now. On the hardware and software side, some of the things that are helpful to us are understanding what the certification requirements may need to be in terms of whether or not there are specific GLI letters or other certifications that are required, whether or not the commission will accept temporary reciprocity agreements while those final GLI letters are obtained and whether or not we have the approval to receive or stage equipment prior to installing and turning them on live. All of those things are things that are helpful to us as we prepare to be able to offer this activity within the Commonwealth. And so that is the wrap up of what it is that we have to present to the commission today. We appreciate the opportunity to share this information with you and for the rest of the session today. Thank you, Northam. We'll hold on questions and just go through the five presentations and then follow up with the questions as we move into our roundtable discussion. So I'm going to turn now to President and C.L.O. Chris Kelly of MGM Springfield and I'm just looking to see. Oh, it's, Goss, are you standing in for Chris? Good morning, Chair. Yes, I am. Chris is actually under the weather and he apologizes that he's unable to participate. I will try to make a reasonable facsimile of Chris on this presentation. Thank you very much. Good morning, Chair. Good morning, commissioners. Good morning, Goss. Just for the record, if you could just give your full name and your exact title because I want to get ahead. Yes, yes, Chair. Good morning. My name is full name Augustine Kim, Vice President and Legal Counsel, MGM Springfield. Great. Thank you, Goss. Okay. Good morning, Chair. Good morning, commissioners and good morning Executive Director Wells and the members of the MGM staff. Thank you very much for this opportunity to speak to you this morning at this roundtable. Before I go into my presentation, though, I feel that I must make a special announcement. My friend and colleague Daniel Miller last week gave up British citizenship to become an American citizen. So we are all very happy with that event. And I thought that when Dan gave up his citizenship, he would also give up the British accent, but he did not do that. So we still hear him. We still appreciate his hearing him speak, but we are excited and thrilled to call Dan our fellow countryman now. So thank you very much for everybody, for the indulgence in making that announcement. With respect to the sports betting issue, Chair, commissioners, you are probably already aware that MGM Springfield had already expended considerable funds, millions of dollars to construct a sports betting lounge. If you're on property, you've seen it. It's a great facility with stadium captain-like chairs with a wall full of TVs. We've got a cage built out, and we're all set to go, frankly speaking. In addition to actually creating that sports book lounge, we also, to enhance the experience for other casino patrons, we also extended and built a very nice sitting area for viewing in our tap bar between the restaurant area and the bowling alley. And if you haven't seen that area, that's worth while seeing as well. So in terms of actual infrastructure, physically speaking, MGM Springfield is ready and set to move as soon as we know what the regulatory framework is. We've already submitted to the commissioner, to the commission to MGC list of vendors that we will need to operate a sports betting book. We've already provided to the staff copies of national harbors, internal controls, standing operating procedures, and the like. We expect that we can use national harbor as a template and modified according to MGC's final regulations. But we are also really in a good position with respect to that as well. We operate, as you know, in various jurisdictions. We already have sports folks operating in Nevada, Mississippi, Michigan, New Jersey, and Maryland. And FedMGM, our partner in sports betting, is well positioned to assist in helping to make sure that we are set up accordingly in Massachusetts as well. So overall, I am very pleased with where we are in terms of preparation. We are ready to go as soon as probably within 90 days of when the regulations become final, we can probably go live, hopefully within about a 90-day window. And so we are excited about this opportunity and we look forward to participating in these roundtables. This one and the one's going forward. So thank you, Madam Chair. Thanks, Scott. Thank you very much. And again, we'll hold questions and augment them as we move forward in our roundtable discussion. We're going to move now to Encore Boston Harbor. Good morning, Jackie. Senior Vice President and General Counsel. Good morning, Madam Chair and Commissioners. We appreciate the opportunity to present you today. We know we did this during COVID as well and it was very helpful from our perspective to get some feedback directly from the Commission. Once again, the legislature has passed a legislation that is both thoughtful and robust. And we look forward to providing sports wagering in a responsible manner, commensurate with the quality that our guests have come to expect from us. As you know, we've already completed the construction and are currently operating the Win Bet Sports Bar, which is already a popular place for viewing purposes. And we are very excited to take this to the next step and open up the wickets for wagers. We know that this is going to attract new customers and we're looking at every location within our facility to best serve our guests. Some of our guests will want to come, sit and view a game while they're wagering and others will want to stop by quickly just to place a wager. So we're looking at locations throughout our building for bedding kiosks so that we can meet all these different needs. To that end, we would appreciate the opportunity to discuss floor plans and gaming areas to better understand where we might be able to place these kiosks. Much like Penn and MGM, timing is critical to us. Once we understand launch dates and how the launch will work, whether it is one at a time or altogether, we can immediately proceed with hiring and licensing. One of the specific topics that we're very interested in is whether our employees from affiliated companies will be able to come here for training purposes. As you know, we operate a retail facility at our location in Las Vegas and those trainings will be very valuable to us when under 23, well I shouldn't say under 23k, under the current gaming act, there was a provision that did allow the employees of our affiliates to come here for training purposes. We're also working with our vendors to ensure that they are licensed in accordance with the requirements established and our IT team is working diligently to understand the requirements and obtain the necessary certifications. Reciprocity in this particular area would be critical to enabling a timely launch. In terms of training, we have identified particular training modules and as soon as we understand the regulations, particularly as they apply to marketing and responsible gaming, we will further develop those. So lastly, I'll just end with, marketing is obviously a big part of sports wagering and we understand the concerns that have been raised both by the legislature, the governor, other states. So we're very eager to see what regulations the commission might develop with respect to that so that we can create a campaign and launch effectively to educate our guests. So thank you for the opportunity. Thank you, Jacqueline. And again, we'll move on to the next speaker. Thank you for highlighting some of your questions in these introductory remarks. I'm going to turn now to Suffolk Downs. Good morning, Mr. Cuddle. I see that you're here. Chip Cuddle, Chief Operating Officer Downsimal Casting Center. Thanks. Yeah, good morning, Madam Chair and commissioners and staff. We're obviously very excited about the final form of the legislation and that the legislature and the governor saw fit to include the simulcast licensees as part of this process. We appreciate your time and consideration today. As other speakers have said, these round tables were very helpful during COVID and we look forward to participating in a very fulsome manner as you continue this process. I will try to synopsize or summarize the letter that I sent to the commission and I guess I was mistaken thinking that when August 1st came around I would have less work to do and probably several of the commission staff feel the same way. But we do appreciate all the work that you've done already to get ready for this eventuality. We do plan to move ahead. The legislation grants us both retail and mobile rights. We plan to move ahead with those. And right now we are working on parallel paths. One is to select the best in class sports book partner. We've had considerable interest in that regard. Have heard from virtually all of the major operators in the U.S., all of whom seem very keen on potentially partnering with us. So we don't have a firm decision on that yet. But we will obviously keep the commission abreast of our conversations and we expect we are well underway in that process and expect that we will conclude the process of selecting a partner or partners in coming weeks. Similarly we are working on a parallel path on real estate options. As the commission is aware we've been operating in our current location as a tenant since 2017. The Suffolk Downs property where we operate is owned by HYM Development. And we do have a lease agreement with HYM that extends through the end of 2023. We are in conversations with HYM about how we potentially move forward with them beyond that. But we also have several other real estate options in Suffolk County as well. This is another area where I am hopeful that I will be able to give the commission a more concrete plan and definitive details in the coming weeks. But for now we are in business discussions on the real estate side as well as the potential partnership side. And looking at today's agenda and some of the areas you're going to cover I will likely have to defer until we have identified a partner that is suitable to the commission because we assume that a best in class sportsbook partner is going to have all of the protocols and information that the commission is going to need to make a decision. That's a snapshot of our update. And we'll look forward to any questions that you or any of the commissioners have as this meeting progresses and we'll do my best to answer those. Thank you. Thank you Chip. Appreciate your comments and again digest them as we go forward in today's discussion. So our final presentation is from Rainham Park. Good morning, Attorney Eichel. Am I saying that correctly? Sorry about that. It's Eichel, Steve Eichel. Steve Eichel, and I should know that. My apologies. No problem at all. We actually pronounce it wrong. It's just the way we pronounce it right. So good morning. And so Attorney Eichel is representing Rainham Park this morning for us. Thank you. Yes, thank you very much. Morning, Madam Chair, morning commissioners and Executive Director Wells. So I am actually a partner at the law firm of Ramon PC and an outside counsel for the Carney family and its affiliated entities. I've been working with the Carney family I guess at this point for about a decade. And so know them very well as well as their various operations and endeavors. That said, I will readily admit that I am a business and tax attorney. I'm not a gaming expert. So I am here humbly to learn from you as much as to provide whatever information that I can and insights kind of with, I guess, a fresh view of things. In terms of where the Carney family stands, we're a little bit of a different position, I think, from, you know, certainly the casino facilities. You know, we are essentially a family family on business that has a long history of working in the community in real estate development as well as in the Greyhound racing originally and ultimately simulcasting business. So in terms of a brief history, the family started with the Greyhound racing facility at Rainham Park in way back in 1940. And that progressed rapidly with quite an upswing in the business all the way through 1989 when the track set the world record for the largest handle at the time about 240 million dollars was a very successful business. Obviously in 2000, when the animal rights concerns became acute and legislation was ultimately passed out on Greyhound racing in the Commonwealth in terms of live Greyhound races. The family pivoted to simulcast wagering and continued to run the facility. So, you know, they have stayed with the business through thick and through thin and, you know, a lot of folks at the time lost employment but kept as many employees on board as possible and have continued to operate the simulcast facility through the present time. The family is extremely excited about the sports wagering opportunity and have been anticipating this for a couple of years now and we're thrilled when August 1st came along and we have already similarly to Suffolk towns so we have quite a few similarities I think with Suffolk towns and a few differences in situation in the sense that again while we have experienced for many, many years running a limited gaming facility of a type we would look primarily to an experienced operating partner in the specific sports wagering industry both on the retail license side as well as the mobile license side and we have been I'm sure as Suffolk towns deluged by the same usual suspects looking to partner with us and so we have been having a number of calls with those players discussing on obviously a very preliminary basis which one would be the ideal partner I think in terms of questions we have been getting a lot of questions from those potential partners where they have questions about certain ambiguities in the legislation that we would love to pose as questions on their behalf and on our behalf that will be very helpful in their making certain go-no-go decisions or figuring out their business models and plans and projections number of them have to do with how the fee structures work how the licensing process will work in particular I'll just front that one of our questions important questions for you will be whether or not it's permitted and even if permitted the commissions whether or not the commission has a preference one way or the other if we have a different operator for the retail license operating partner for I should say for the retail license and the mobile license or if there is any kind of strong preference or requirement that it be the same operator for both our retail and mobile license because that will obviously have a significant impact on which partner we go with because various partners have expressed preferences to us as to whether they go with some of them want to do mobile only some of them want to do retail only and some of them would do both so I think where we're in a little bit of a different position here is that in terms of real estate which is what the Kearney family brings to the table and you know was going to bring to the table for example when using their Brockton fairgrounds property we applied in a joint venture for the Regency category one casino license bringing the real estate the relationships very good relationships with the local community and experience and dealing with the local community we have the same with Rainham Park we have an excellent piece of real estate that is extremely well located in terms of access to the public and transportation there is the existing Greyhound simulcast facility that is still up and running but eventually you know that will be demolished and replaced with the new facility which we're very excited about is already under construction I think you saw some artist renderings of that and a floor plan which looked very cool to me and the steel at the steel structure is already up obviously this indicates you know a commitment that has already been heavily made by the Carney family even well before the the legislation actually was passed the just in general terms the total facility will have about 50 I think 58,300 total square feet of space 30,000 square feet of which will be devoted to the gaming area it will be contemplated to have totally state of the art facilities and equipment again very large viewing area with all of the TV screens automated kiosks theater seating as well as live teller windows again we do anticipate retaining all of the employees that we have as well as hiring additional employees as necessary and in combination with whoever our selected partner is who will be helping us with the with the training etc and so with that I think that's you know good general summary of where we are we again we have a number of specific questions that will we will pose at the time that they come up in the course of your very thoughtful agenda that we see will go through today thank you thank you see so we'll get started with the agenda then and it's going to be fluid it may not always align exactly with the bullets in the order that they are put on the agenda because as I said said initially we want it to be conversational but we'll keep track of those topics and commissioners if there's any questions that you have or our guests if you have on the particular topics just circle back and to the members of our team this is an opportunity too for you to get clarification and just let me know if you need to interject we welcome everybody's participation commissioners am I correct I'm seeing nodding heads we will keep track of time if for any reason we really need more time we will make that in a future date but let's get started and our initial bullet has come up already in today's initial comments about questions around placement and floor plans Karen if you want to just elaborate a bit you've met with the licensees some of the concerns that are coming up with respect to why we have the floor plan some at the top of the list here yeah I think yes I think that the sort of the the key question here is where can we place kiosk so where can we have this what is considered the gaming space and I think that from our prior conversations it certainly will be helpful for the licensees to know what the parameters are from the commission if the commission has any constraints on where they want these items to be located or where they can conduct sports wagering on the premises it's better to know now so they can plan accordingly I think for example Jackie from I think we'll start with Jackie yeah yeah I just took notes they're looking at potentially putting kiosk in different locations on the property so if there are any concerns this is the time for the commissioners to potentially express those or if they want more information they can get more information from the licensees yeah so Jackie you were you did raise the issue precisely so I think Karen thank you we'll get started with Jackie and I know this is with respect to floor plans kiosk and technology will address the all right so for example one of the things that we would be interested in understanding from the commission is whether let's say if we turn to ballroom even on a temporary basis into a viewing party would we be able to put kiosks in there providing provided of course that we have the appropriate surveillance and security that is applicable to gaming areas generally you know we've also frankly been looking at locations within our garage that might potentially be converted I know we as you know we've been complaining about real estate for a while so one of the one of the thoughts is potentially creating a location within the garage which would obviously be cordoned off with security appropriate security and surveillance where we might it might be helpful for guests who want to just pull up have short-term parking come in place a wager and depart the premises so those are all the different iterations that we're thinking about and just would appreciate any feedback in terms of whether that is something that would be entertained commissioners you want to address jack before we move on to other representatives questions I actually have a question but I think I mean I think I mean be you to it go all right she did I raised my eyebrows before Brad had a chance to unmute himself so I guess my question in terms of I have a number of questions about sort of the the idea of taking it off the gaming floor but the the idea of like the garage in particular is that something that you are asking short-term in the potential that this is rolled out where you have on-premises and then that becomes less of a need when mobile becomes active or is this something that you are potentially envisioning as a change in the structure in terms of how you'd offer sports wagering certainly in the short term we're concerned about the volume and making sure that we have enough space and enough locations for everybody you know but potentially once online comes we think that that demand will change a little bit but potentially even long-term and as you know we've come before you before asking for changes to the gaming area to expand certain things and so we'd envision it envision it sort of in a similar manner and then in terms of the ballroom in particular is this contemplating taking a particular ballroom space and making a permanent conversion or is this more like you know Super Bowl comes and you've got things like that and you're gonna you want to do this on a temporary basis so for the ballroom it would be a temporary use that we'd be looking for never all right I'll let Brad queue up this question oh yeah all right so this being so conversational I'm hoping that all of the licenses can share with us some of their experiences and other jurisdictions that are owned by your you know the your company so Jackie can you give me your experience of what floor plans are like and other jurisdictions and what other commissions have done to be either helpful or hurtful I might I might push this over to Penn to answer because we only have one other location where we have a retail sports book and that's in Las Vegas which is obviously very different you know again we think under the current construct it would need to be designated as a gaming area so that we would all those provisions that go into gaming areas would apply but north do you want to can you add to this potentially so I think what we end up finding out in other jurisdictions is that the patrons who are sports wagers or sports betters also enjoy other forms of gaming whether that's poker or horse racing or you know they're just hanging out watching a game in a restaurant and so having the ability to have a kiosk in those locations is helpful to those people specifically if they're looking to make an endgame wager which is where we find these types of kiosks to be particularly helpful so an endgame wager would be somebody is placing a wager on an outcome of an event after the game has already started and so speed is of the essence in those instances you know the other thing I would say is that we certainly as it relates to the horse racing side Penn would have an interest in being able to have some kiosks in that location we know there are a segment of our guests within the racing operation that have become very accustomed to self-service and use our facilities there our kiosks are there to place wagers and you know I think that it's reasonable to anticipate those folks who are hanging out down there watching races betting on those may also be interested in placing a wager on a game that's active at the moment anybody else want to add to that from any of the other companies licensees MGM guest do you have anything to add does any other facility use the garage it would be a it would be a lovely area within the garage no doubt no doubt Jackie I just I'm wondering and North is quite familiar with our questions about drive and drive up betting because of Derby Day activities at PPC so he's very familiar with the kinds of questions that the commission has presented in the past you're imagining that they would park and then walk through the kiosks and not drive up that's correct so it would be an enclosed space again with a security just like entering any other portion of the the gaming area I get I understand okay commissioner Maynard commissioner Skinner do we have questions on this topic um kiosks in terms of the exact placement MGM Gus I think you might have some thoughts on where you'd like to see those kiosks I want to make sure Commissioner Maynard did turn off his volume Commissioner Maynard Hi Jackie is the idea that these garage kiosks that a patron would go to them and really that would be their only experience on the property right they're going to go to the kiosk and then go back to their car correct that's correct for some of the patrons or it could be they walking towards the elevator banks they enter into this secure area they place their wager and then they continue into the casino so a combination of both but we would provide short term parking for those patrons who don't want to necessarily stay does your Vegas property have something similar I've not been we do not in Las Vegas thank you so much I appreciate it yes thank you thank you sorry commissioner's gonna you're all set for a moment yes I'm all set thank you sorry Gus thank you oh no thank you chair at this time MGM Springfield does not intend to place any kiosks in spaces that are not already designated as a casino floor so but we are very interested in about the concept of temporary spacing for example watch parties at the Jack had brought up that is something that we are very keenly aware and mindful of and would like some answers and clarity on that but we at this point in time any kiosks that we place would be on the casino floor itself so you know in terms of the overall long-term expansion of casino floors that is not of an immediate concern to MGM Springfield right now thank you questions anyone else on the kiosk plate splint anyone from the staff want to ask a follow-up question okay let's keep on moving on and the issue of hiring and staffing is still pertinent right now and of course this commission is always interested in how gaming is truly an economic driver for jobs and revenue so if I can I'll start with you north in terms of hiring we also get those quarterly updates from you as to casino operations and we know there are some challenges right yeah so as I said in our comments we've we've prepared an initial assessment of what we believe our staffing needs will be some of that you know is more starting with the organizational structure of you know what does it look like like who's supervising the people what are the positions where does it report up through the organization those types of things so we've made those determinations I think with regards to the hiring some of this will depend on the way the commission proceeds with regards to activities that may be prioritized first so if retail operations were to go first we would anticipate that it would be a greater need for staffing as we begin and that over time that we would proud more of the wagers would probably go to the online piece so there will always be a retail component we see that from our other experiences but the actual number of people that required have have many things to do with in terms of the season in which you know wagering would begin and what that looks like so we'll remain flexible to to whatever the needs are but we believe that we'll be able to adequately staff Commissioner Hill I thank you North for those comments and I'm concerned about this initially because what we've been hearing from all our licensees is the hiring issues that they have been having over the last few months in regards to the food and beverage industry I think I remember hearing that some licensees are having issues having getting dealers to become workers in their establishment so I'm trying to I'm trying to grapple or juggle with what I heard but now what I'm hearing now that we should be able to be able to get the employees we need now let's be honest if you're a retail operation you're going to need some some employees not a lot but if it goes to the mobile you're not going to really need a lot of employees coming forward is that an accurate statement so I would say a couple things with regards to the the hiring softness that we've seen I think it's been pretty concentrated within the culinary realm for for many of us and that that is typical of what's happening in the culinary industry in general so we've we've seen some some softness in that area although it has been gradually returning with regards to the retail operations the needs for staffing within the retail operations are going to fluctuate up and down or what we tend to find when sports wagering operates you know when it begins operating in a jurisdiction is that it's a new thing people are interested in getting in on the ground floor of that they want to learn more about it they want to be involved in it and you know our our needs depending on how things roll out you know may differ from the long term but the retail need will always be there and so sometimes some of those people come in into entry level positions are able to make a way for themselves and stand out and be impressive and then as other jurisdictions open up we have other jurisdictions that are in the process of launching right now and many times there's opportunities for those folks if we perhaps you know have a lesser need here there's sometimes an opportunity for people to grow in their career and move to a different jurisdiction and become a supervisor or a manager in another capacity in another jurisdiction so I would say that you know and that's true as we look across our organization sometimes our managers come from other properties they started as team members on the hourly level and have built a reputation for themselves and found a way forward so I think that ultimately as it comes to the way that we would fill those jobs I feel comfortable that we'll be able to meet the demand that that's there and that there will be folks who find interest in the positions we have and I think that it is different from what we're seeing on the retail side similar to what Jackie and I think some of the other licensees had shared in terms of the types of people who normally come into these positions we find that we have a mix of people we either have cash handling experience and or a passion for sports and between those two that that is a pretty a broad swath of people to be able to pull from and so again I've learned over the past two years never to say never or to say that we know exactly what's going to happen but I feel I think that this is a slightly different scenario than what we've seen in other parts of the business over the past two years thank you thank you thank you now cushion Hill cushioners on on jobs questions observations cushion winner they have a comment and that is north you presented to us fantastic diversity members last week and just really want to say that this is another great opportunity I think to diversify the staff and I'm looking forward to see if that comes to fruition thank you I guess I'm also interested in from all well five licensees and I know that this is new territory for both Mr. Todd on and in this direction is that how many of the operational jobs are really taking place from behind the scenes outside of Massachusetts and outside even maybe the country versus how many will actually be available in terms of percentage perhaps rather than exact number will will be operationally involved in Massachusetts if you have a sense of that given your experience in other jurisdictions and I guess that does speak a little bit to Commissioner Hill's point it might be different for the multiple versus the retail I mean go ahead yeah I mean I'll just say from my perspective and we we don't have experience operating and other jurisdictions and as a result of that I would just say from our perspective I think we view this certainly and we don't have experience on the mobile side of it so we can't really speak to that that will be something that will be within the domain of our operating partner that said I think our our full expectation is that with respect to the retail side of the business we expect it to operate as it has since the 1940s with the Carney family which is that this is going to be a great thing for the local community we expect to hire I think pretty much entirely from the local community and that's what's so exciting about the opportunity you know what I know from about the Carney family from working with them for the last decade is that they care a great deal about the local community they are very happy that they'll be able to offer additional employment it's one of the things that excites them the most about this many of their employees have been with them for literally 30 plus years and you know so they have very little turnover generally speaking in their businesses they treat their employees well and I think you know the the economic reality is with the you know the pandemic and people reevaluating their views on work and there's a little bit of I think a a paradigm shift in you know economic distribution and you know people will have to be paid enough to get them to enough to get them to do the jobs that that some people are choosing you know not not to do and I think they understand that reality and and plan to do what's necessary to hire a sufficient staff to to have a very successful operation I would I would echo on behalf of SSR commissioners I would echo what Steve said you know while we we certainly are not a mobile operator and can't speak to you know how many jobs on the mobile side would be here in Massachusetts and at the facility we one of the things that's most gratifying for us about this is you know the ability to to expand our workforce we're currently open five days a week for simulcasting somewhat limited hours whereas a combined simulcast sportsbook operation will be open seven days a week or perhaps more than twice you know double the hours or at least double what we are hoping not now so we have an agreement with IBW local 103 that's the primary union for the Suffolk Downs employees that all the new jobs that we're able to offer in a in a combined simulcast sportsbook operation will be with 103 and you know there are a lot of our current employees have not necessarily been able to get as many shifts as they would like so we're really looking forward to enabling current employees to expand their hours and bringing on new people with new job opportunities in an expanded facility thank you Jackie in response to your question about what percentage would be located within the Commonwealth and as opposed to outside I think with respect to retail you're going to see that as a very very high percentage located within Massachusetts so I'd say over 95 percent of the people who support the retail operation would be located in Massachusetts we're looking at hiring primarily in the food and beverage cash shares security and surveillance and tech those would be the main areas that we'd supplement our current staff we don't anticipate that need going away when online comes we think retail is going to continue to be a robust portion of the business and then in terms of online you'll see the majority of that is ready from the current infrastructure that that we have in place would not be as heavily based in Massachusetts thank you questions so far with respect to the comments we've received commissioners on jobs it's been very informative thank you Madam Chair thank you and and our team any questions all right then we'll move on we're now looking at house rules and internal control submissions I think that the commissioners could all stand a a bit of an education on exactly what we would anticipate for house rules that you must present to us I believe but for approval before you can operate if you just want somebody wants to give us a quick education on what what those look like that would be really helpful I'm sure for my fellow commissioners and perhaps for the public if some would like to take a stab at that Jackie thank you house rules are going to look very similar to the rules that we have for instance for the games that we offer the table games so we have those ready to go whenever the commission is ready to receive them based on our other operations internal controls is obviously dependent will be largely dependent on the regulatory process and the regulations that are promulgated so as soon as we have a sense of the regulations we'll be able to develop the internal controls any any other licensee you want to comment on those rules development and commissioners this is a chance to ask those fundamental questions you may have and team you may have questions exactly what the house rules may look like a few of us had the benefit of going to a sports book recently and I think director wells took a v-line to getting a copy of the house rules so okay in the terms of the process Loretta director Lilios any questions you might have with respect to or that you'd like to drill down on in terms of internal controls what ranks might be particularly helpful in the development of those from the perspective of a licensee anything you have on your mind director Lilios on this time for this category chair okay and I want to turn to Burke our specialists on this so are there any questions that you have on this matter like good morning everybody I think we're like Jackie said waiting for the regs to come out we're prepared from our side for the physical inspections I've been working and talking with the three properties about that aspect so we're trying to get in front of that so as it's all being laid out we'll be ready to go to do the inspections great thank you all right and I'm sure if I could just interject for any of our licensees that have the house rules please send them over to director Lilios as soon as you have them so we can get going on with those no reason to delay thank you okay then in terms of I think we should go to the security issues this a lot of us are familiar with but these matters we're not necessarily familiar with how they're put into operation so it would be really helpful to go over what do you contract with how do you contract and what exactly do they accomplish and Karen I don't know if there's something else that you want to keep sort of set the stage for this important discussion all right I think that it just may be helpful as you had said on the prior uh bullet point to sort of educate the commissioners on generally what is the approach from the licensees to ensure the physical pardon me the physical security the cyber security the know your customer all all these things that are part of ensuring the integrity of your operations just if you could give a general approach to how the licensee deals with those issues so they can understand for when they implement the regulatory framework can I turn to Gasa you comfortable moving on I don't want to put anyone in the spot no no no madam chair I'm fine so as I said earlier at least with respect to MGM Springfield our intent is to keep sports betting on the existing casino floor so we will have the same surveillance same security operations the same SOPs on all of those of those you know matters that exists now what on the on the gaming side that'll exist on the on the sports betting side and so we see we see that there will be no interruption in in coverage of sports betting we don't we don't foresee there'll be anything you know additional that we have to do obviously we want to make sure there are cameras cover camera coverage adequately captures the kiosks and the light but in terms of making some minor tweaks and adjustments at least for MGM Springfield we don't foresee any major changes to the way we operate currently as a result of adding sports book to our to our amenities that we offer to our customers and with respect to cybersecurity again same thing the same levels of cyber security that we maintain for our current operations we will have that and you know once once you know bet MGM is is duly licensed or in the process we'll certainly you know coordinate and work with bet MGM in making sure that whatever protocols that they have in place are also you know put into place at at at MGM Springfield as well North you have your thank you guys North you have your audio available yeah I would just say you know similar to MGM we'll use many of the same systems that we use currently and then we'll add on additional systems which help us identifying unusual betting patterns things like that which could represent opportunities for for arbitrage or fraud so we we will use those existing systems and then supplement with other things that are specific to sports waitering North I have a quick follow-up question for you and correct me if I'm wrong I haven't looked at this for a bit and I think I may have raised this to you but you did mention that the possibility of accommodating the horse racing patrons by placing kiosks for sports waitering in that space that's so nicely situated along the the track horse racing age for betting is 18 is that correct and of course for sports waitering it's 21 I know you have an answer for this so I thought we might offer a how you'll manage that so I mean I think that you know we we similarly need to monitor that in the in the current scenario and we have adequate staffing including you know detail from from Plainville occasionally and and other security or teller positions who are down there who are able to monitor that we could certainly place those kiosks in a location that's a little bit easier for us to have visibility to but you know and and then of course surveillance coverage of those types of areas remain strong but you would have 18 year olds accessing horse racing in the same place as accessing perhaps a sports waitering kiosk and and correct me the kiosk don't they're like placing in person so they don't have any of the the tools on knowing your customer age etc that you will get with the mobile at top one or do they so kiosk have the ability to register player account information and and to be able to use that as a as a form of verification otherwise we are depending on someone to to look to make sure that the person accessing that is of age and you know that we we tend not to operate at least at Plain Ridge with a single point of failure mentality meaning that as long as someone gets in through the door that that means they can stay there forever we make sure that team members understand that occasionally an officer can make a mistake they can be distracted something can happen that's allows an underage page from the floor so it remains part of all of our responsibilities to make sure that the people who are there and wavering are of legal age to do so and if they have reason to believe that they're not to request an ID and act appropriately thank you Commissioner O'Brien I see your meaning in I did so North is there another jurisdiction that you function in you as a corporate company have functioned in that has this dichotomy one age for say horse racing and the other for those for the sports Madam Madam Commissioner I believe that West Virginia does and I know that Pennsylvania does and then do you know whether or not you have any other protocols security protocols in place or placement restrictions and those jurisdictions and you probably don't know off the top of your head but just in terms of furthering the discussion with us if that's something that's something I'm interested in knowing I believe it's going to again depend on the human element of someone there to be able to make sure they're monitoring those transactions yeah that I'll be perfectly blunt that makes me uncomfortable that's the end of my comments on that topic for now I like the the absolute nature of it Commissioner O'Brien so appreciate that in terms of just a little bit more education on the security issues that might arise around in-person vetting Jackie do you have any further helpful information for us? so well we're operating under the assumption that the commission will require the same level of surveillance and security with respect to respect to sport spending that it does for any other kind of gaming so we would propose to have that level of security and surveillance throughout any areas that are authorized for sport spending okay then commissioners are there any further questions on this topic I think they might become more complex as we move into mobile for our future roundtables I just want to acknowledge Daniel Miller while he has his video on congratulations again I was lucky to see you the day after your ceremony and we congratulate you so in terms of the next topic equipment and technology I think this is an important area that I think a few of you touched on in terms of what will be expected that might actually affect timelines am I correct in that framing that Karen if you want to help me out or Loretta yes I can help out there because I think one of the asked and I took notes when North was talking one of the some of the policy questions that'll come before the commission on this would include the ability to bring in the equipment potentially before it's licensed or approved so they can set the stage and then there's also the you know we'll get into the licensing later but also licensing offenders and then there's also the certification procedures the expectation I think that the staff has is that there will be some kind of requirement by the commission for the what we call the GLI certification so there's an independent test lab that certifies that the information that the any kind of equipment is functioning according to Massachusetts rules and regulations so I think that's the kind of ask from the licensee side and I'll defer to them on on the details is what are some things that can be done to expedite the launch process for the equipment that they're going to need does some representative want to take the first staff at this issue just to make sure we understand precisely and then we may need to turn to you director Lillios for any insights as to how you're imagining with your team to facilitate these the testing of the equipment nor do you want to elaborate so I believe that some of it will come down to the determination of what gaming equipment is and what gaming what is not gaming equipment so one of the examples would be you know it would to like a kiosk is that considered gaming equipment the teller workstation that they use in order to process tickets is that gaming equipment so those are the types of determinations where we sometimes get stuck and then the question is you know is there a state specific GLI letter that's required or is it just something that says that this equipment and or the heart or the software complies with certain sections of GLI those are usually the areas where we we tend to get stuck and take some time to to work out so Karen on the latter point and then commissioners I'll turn to you that sounds like Katrina question I'm not sure if Katrina is able to be here today but is that something that we couldn't be moving head on to on these certifications state specific needs well so the commission prior to this already indicated that they were looking as a general framework that the staff should be looking at the GLI standards so from that perspective the commission is already moving forward on that so then the next step is and we're meeting internally tomorrow the question of is it through regulation that they have the GLI standards and then are there any additional requirements that the commission wants above and beyond that North mentioned the reciprocity on the sort of GLI letter normally my understanding what happens is that the independent test lab would test to the particular state standard so if there's you've got the GLI standards and you require three other things they'll test that the GLI standards and those three other things I think the ask is if there either are no additional Massachusetts requirements or the commission is comfortable going forward without the certification of the additional Massachusetts requirements could they get up and running with that ahead of time so those are kind of the kind of questions so I think that the commission moving forward either through a regulatory or whatever process the commission deems appropriate for establishing what those standards are will help move forward the certification process precious I'm going to just continue with my question and they'll turn to you seems to me that it would be really helpful for our experts internal experts to come to us with recommendations and perhaps options as to those additional requirements and if so that we could move on it in terms of the process I understand that that's a question too and there's all kinds of factors that come into that evaluation but maybe next step will be to hear for as you did with the GLI and it would come to us and say we've identified these additional needs commissioners I turn to you now what do you have on this is an important piece of work for all of the licensees and random and Suffolk in terms of being able to move forward on on equipment and and technology and I assume purchasing any questions or questions for our team Commissioner O'Brien So North I hate to do this to you again but do you know in your jurisdictions how many have state specific GLI standards on top of sort of the base GLI standards? I do not but many other states have allowed us to launch based on GLI certifications from other jurisdictions on a temporary basis while the state specific letter is gathered we do have a corporate compliance team which is really well versed in all of these matters and without getting into a lot of the specifics in which I would probably be very greatly out of my depth I think I will defer to them for more complete answers if you have questions Okay that would be great thanks I think I may use that line North that was very very well placed line I appreciate that commissioners other other questions on this topic so it sounds like this this area is really on us to be thoughtful and it sounds like we have some policy questions to decide commissioner Maynard commissioner Skinner anything you have to ask commissioner Skinner I know you're interested in the technology side of things anything at this particular point in time? No not at this time madam chair thank you Okay thank you Commissioner Hill on set all right and we'll move on to really it's my favorite bullet maybe that's why it made the agenda frequently how can we help you where in your experience can regulators present challenges you know we like to be cooperative and collaborative with our licensees but you also know we're rigorous regulators and all of my fellow commissioners as I stated at the beginning made it clear that you know integrity the experience the safe experience of the patrons is going to be paramount so at this point under operations is there's something that you'd like to give us a heads up on and and we even if we don't agree with you it'll be okay I shouldn't have prefaced it as being my favorite bullet Jackie any thoughts on this in terms of your experience that you could predict where there just might be not only timetable issues but operational implementation issues if we went in a particular direction they don't mean to put them in the spot well the GLI is probably the the biggest one from a time perspective if there is reciprocity with other states and what we've seen as as North said in other jurisdictions where they rolled us out they have accepted there's been reciprocity and then with a set time frame say 90 days or whatever to get state specific certification on top of that obviously one of the operational issues is our ability to contract with the various vendors and go through the licensing process I know that your staff has been working diligently to to address that and there's already a framework for that so if we could get a greater understanding on that in terms of what employees and vendors would need to do to get going very helpful right Karen Karen you have your your audio off do you have some thoughts no I yeah so I think that is why you know internally we identified some of the priorities for determinations of what needs to be in regs and what could be in some kind of other rulemaking it's the initial license application it's the vendor licensing and then the employee licensing because operationally if we can do that on the front end we prioritize those and move those forward that's going to help the timeline down the road so there's lots of things obviously that we need to get done but we're looking at what's going to be the backup not just now but down the road and given that they have the licensees have to basically have a timeline they need to know when to hire they have to identify how long it's going to take to do licensing and then their start date so they've got to back it all out and then with the vendors presumably my recommendation is going to be there be some kind of similar licensing process for vendors that we have for our operations on the gaming side so to do that we have the infrastructure in place so to get that going and at least have the application forms ready to go and have a process for temporary licensure for those vendors is going to impact the timeline very helpful commissioners anything on this commissioner Skinner Adam Chi I just have a practical question in terms of the technical standards how does reciprocity work I can address that so I think you know for instance if the commission would consider accepting a GLI certification that was prepared for Mississippi for instance so that would be the initial thing that we submit is that certification letter and then if there are additional standards perhaps you say to us will accept Mississippi and then within 90 days you've got to get a certification letter that addresses all of any additional standards that messages may have so sorry right ahead commissioner Skinner and then so just in terms of the Mississippi equipment and technology how does that tie into Massachusetts so it would be essentially the same equipment that we would use it would be identical the equipment that we use in Mississippi for instance as in Massachusetts so you would have presumably a level of comfort that if GLI was able to certify that equipment that it would at least from a baseline be acceptable here okay thank you I didn't want to make any assumptions so appreciate that very very helpful question thank you commissioner Maynard commissioner Hill commissioner Bryan I'll set right now and if I could if I could jump in Parley-Elford what Jackie was saying and that's where we would out in the field even at the racing facilities be able to check that GLI standard with the approved version that's replicated on that kiosk so the physical inspections just because there's a GLI cert we would have to verify that that is what's in that kiosk for example so all in lines that's correct thank you very helpful Karen are you leaning in no no I'm also thank you okay thank you all right really really helpful discussion so now another big topic is is our licensing procedures Karen this is an area that you and Loretta really have the full experience on and I know you've had conversations with the licensees on this right now I think by statute there's an express language relating to the operating license and the occupational license but that there is room for other licensing and I think your conversations revealed everybody was interested in the vendor licensing so in terms of going forward do we speak about all three at once or should we distinguish from Karen I think distinguishing I mean it's interesting because we're just talking about today our current license so that would be category one and category two and I think we were just talking about retail right now so yeah for the operator license I think one thing that's important to note is these are not entities that we are completely unfamiliar with and don't have the history but the casino licensees they went through the rigorous background check for the for their licenses through the Gaming Act and then the to a lesser extent that we have some knowledge of the the simulcast licensees because we deal with them on a regular basis plus folks connected with those entities have also had also either applied or been connected with an application for the casino licensees so they've done background checks so then the what the commission may want to consider is what do you what do you want for information for that operator license and if the the licensees have any feedback on that operator license this might be a time they could present that but the I think the process and the criteria for the final license you know the staff will put together some recommendations that the commission can consider but given the structure of the legislation it is relatively straightforward so let's go right to vendor licensing for right now then does that make sense Karen yeah the only thing I'd say because occupational licensing is the next one yeah one thing that can be helpful is the jobs compendium so we have the license management system so I'm trying to think what what can we do to speed things up because we remember from licensing the employees for the casinos that the speed in which we do that greatly helps their ability to open so one of the if you look at the legislation there are some determination about who needs to be licensed based on supervision so if we can get the jobs compendium so we get what the casinos are expecting and the and the femal casinos are expecting for retail hiring and the job descriptions we can then present to the commission what the recommendation is for what levels of license what level would require a licensure and then we can add that those jobs into the LMS system and then we'll be ready to go we already have a structure for licensing temporary licensing licensing employees so we can just fold that into our existing structure my expectation is we would use the same format for the levels and we just put the levels into our GEL and key standard and the executive license applications and and Karen you've noted that it's at the supervisory level and about right Loretta do you want to add in before we start to ask our questions just that our licensing division has a communication to each of the potential retail operators here that we can send today delineating exactly what we're looking for with the job descriptions for the compendium so we can send that today and we've already had and we already have gained an understanding of the you know potential volume and scope in discussions but we can get this more formal process rolling today to to get the documentation from from each of them so what I'm hearing is that this particular process doesn't necessarily have to be stood up by regulations in place perhaps we memorialize regulations down the road in some way or guidance I think before we identify the applications for the different positions we will need to hear from the commission but right now we can start with receiving the job descriptions thinking about identifying job codes and finalizing a compendium and then come back to us commissioners questions for licensees or Karen and Lorena on on the occupational thing I do want to hear from our our licensees up there we go Commissioner Hill thank you for the hand yeah just a very quick question what is the volume of employees that we're actually talking about because I don't think it's gonna I thought at the beginning it might be an extreme amount but now that I've I'm learning a little more about what employees would be doing what and management and things like that I'm not sure as as many as I thought so do we have a so before we asked yeah before we'd ask like a percentage of local now we're asking for real numbers is there are you able to project that Jackie sure so we're initially we're looking at an additional 75 employees more or less I think the good news is from a licensing perspective a lot of the jobs that we'll be hiring for are already like food and beverage we already know what level of licensing that requires or cashiers we know what level of licensing that requires so we already have a current job available for that and I think you're gonna see Lorena I hope this is helpful but relatively few new job descriptions for betting can you give me an example Jackie of what a new one would be sure so we would we would need the biggest one would be like the director of our sports betting operations but most of them I'm just going through you know cashiers we're gonna use cashiers at both cages so we're not going to create a new job position for that food and beverage employees same thing surveillance security win rewards we're gonna hire some old people and we might change that definition change that job description just a little to include some new responsibilities for sports betting but that's really it can I hear from the other licensees what you may envision for additional positions we'll go to north thanks so similar to Jackie would have somebody who would lead that department reporting up through one of the members of the executive team we would have supervisory team members and then we would have tellers or ticket writers so those would be kind of the positions that we're looking at obviously we would expect they'll probably be additional people that get hired that are not directly involved in sports wagering but are supporting the activities that surround it do you know how many that might be I think all in all we're probably looking at a low double digit number precisely yeah is low 10 or is low 20 I think it's probably in the neighborhood of you know probably all in all everything together 20 to 50 thank you and Gus thank you chair until the regulations become final and we kind of understand you know what roles various team members may have to play I think it'd be really tough for us to hazard a guess as north and Jack have said you know in addition to the direct employees there will be operation operating the sports book we suspect that we'd likely will it need to hire additional staff for surveillance security and the like so I would I would hazard not want to throw a number out there and then you know it would be an uninformed number so I would rather not do that right now chair thank you how about you Steve I know we you talked about the commitment of the Kearney family and we we acknowledge the those comments do you have a I guess I try to remember the number that you have currently you did reference your current base yeah I think currently you didn't say that you know I hadn't before I think currently there are about 75 employees that are based in the existing simulcast facility obviously that would be you know certainly a floor and and considerably increased I think you know there there are a certain number of simulcast betting window tellers that would still be you know brought over to the new facility as well as adding additional teller windows that I think would be dedicated to the sports wagering operations um so you know I'm again very very you know vague you know in terms of in terms of commitment but I think that guessing probably given also that there would probably an additional shift depending on again what what we what kind of agreement we come to with our operating partner and what what you know what they tell us make sense in terms of operations we were probably approximately double the existing staff I would think at least at least double it you know with with primarily similar positions to what we have in terms of job descriptions together with the added jobs that you know I would say again we're going to learn what they are from our operating partners because you know those would be the ones that would be specific to the sports wagering operation that you know again we're not well versed in at this point in time thank you and Mr. Teller you're off on video I'm not sure if you're there but all right there he is if you could just I was multitasking here so if you could repeat the question that would be great that's okay I didn't mean to put you on the spot we were just talking there was a question from Commissioner Hill about the the actual number of employees that will come with in-person betting and and I don't know your exact number I think Mr. I shall be the important point from their perspective that there'll be additional shifts in the expansion of hours not sure if you want to comment on your current employee base and then what might be added given this opportunity yeah we between our own you know full-time employees staffers you know and the the union members who work directly for Suffolk Downs and all of our on-site vendors as well you know we still generate nearly a hundred jobs annually in the simulcast facility we've provided that breakdown to the Commission in the past as part of annual reporting we're we're hopeful that we'll be able to almost double that in a in a a new state of the art retail sports betting and simulcast location that would be you know anywhere from 20 to 30,000 square feet so that's that's our tentative plan and given given the current job numbers you know if if if we're able to you know I can't guarantee obviously that we'll be able to get double that but you know if we're able to increase our employment rule from anywhere or from 50 to 100 percent we'd be very excited about that so just to follow up so Loretta if I'm hearing this correctly this this won't be as hard I don't want to say hard I I thought at the beginning of this process that this would be very well hard for the staff to be able to get it all up and running and get them all licensed in a timely fashion but I'm feeling more comfortable that that is not the case that we are going to be able to do this pretty easily and quickly is that an accurate statement we certainly have a plan for that these numbers have been shared with us so these numbers are not a surprise to me we have a plan for that includes a hiring plan I do want to point out though that those are not insignificant numbers for us and our you know we have renewals for two of the locations that are in the foreseeable future for us but our plan accounts for the ongoing renewals for the two locations as well as this number that we're talking about now thank you commissioners any questions on this topic occupational licenses all right then we'll move on to the bend the licensee how can we help build down on this topic Jackie any any way that you can no you know thank you to all the staff we've I believe we've turned in our list I think we have of all of our proposed vendors at least on the retail side and I know that you know as soon as it's ready we'll make sure they get their application submitted in a timely manner the big the big ones obviously are the vendors who have the gaming aspect because I understand that those obviously require a more thorough review so those are the ones we're really focused on Karen I think that you know we are our threshold question is commission you know what is the commission want to do with respect to vendors since that's not in the legislation so we certainly have a recommendation for the commission which I've already indicated and I think that the utilization of temporary licensure is going to be very important so that my recommendations commission adopt that we do have a whole process for gaming vendors on the casino side so for gaming vendors on the sports wagering side if we match that that's going to make it easier for us because we already have that infrastructure in place and staff is already familiar with how to do the background check you know complete evaluate the application for completeness etc so we have a system that we use we'd be recommending that we fold it into the system but we need confirmation of that from the commission so that's why that's one of the first things we'd like to address with the commission is how the commission wants to address vendor licensing so I'm available for any questions on that right now since we're in an open public meeting but we can certainly put that on in the next item yeah this is this is very helpful to do it openly Labrata you've got your audio off before I turn to my fellow commissioners because I know that scoping is an important piece of this work I do share in you scoping and organizational complexity made it on to the agenda I'm really not sure that I have questions for this group of potential operators now we are working with the vendor lists that they have provided and starting to gain an understanding of some of the scoping implications but I am interested in hearing from from this group on the potential exemption list our existing regulations on the gaming side does look based on a risk analysis and does provide a list of potential exemptions and I'm interested in hearing whether these folks have thought about that have seen that in other jurisdictions and would be prepared to comment on exemptions in the promulgation process on the sports betting side anyone want to address that Jackie or North or Gus there you go Jackie it's okay did I hit it first so I feel like I'm on jeopardy well we put Henry in a room right it's it's hard but we really appreciate everyone soon just jumping in thank you sure you know on the exemptions if the same level of exemptions applied that would be great if that list could be expanded that would be even better but you know that that's how we've been at least addressing this while operating internally are there any exemptions in particular that you're thinking of that would be on the expansion list you know the only things that we could think of all panned and it's really it's a lot of it what we're dealing with now is there's certain retail products and stuff like that which don't pose a huge threat like so for instance and I'm going to use a commissioner skinner is very aware of this but you know if we buy shoes from Louboutin we would apply for an exemption on those things so if it could be expanded to cover vendors that pose very very little risk that would be something and we can certainly give that more thought Madam Chair the other thing that the commission we want to consider is does the commission itself want to grant the exemptions or does the commission want to allow the IEB to grant the exemptions for specific requests that's up to the commission one area historically that's used for exemptions if it's under a certain monetary threshold and I'm talking about what we use now is non-gaming vendors and I think the recommendation for staff that gaming vendors would require some kind of licensure but for non-gaming vendors so not if gaming equipment any anything else a common exemption is to have a monetary threshold so if the operator spends less than 10,000 those vendors do not need to be licensed you could up that amount and do a risk analysis at what point would the commission want some kind of licensure or registration requirement for a vendor if there was a certain amount and then what kind of discretion do you want either the direct the IEB to have or do you want those coming before the commission similar to what we do with employee exemptions where every one of those comes before the commission they allow it and then that category is is set so that would be your call and how you'd like to handle those yeah this is in this we can circle back to this too after the lunch break we have marketing guidelines and guidelines and advertising is one of the items but one of the last online trainings that I went to they were talking about the use of third-party marketing to get people in particularly in the online setting I knew were primarily focusing on the brick and mortar in the kiosks today but something that I was interested in is the payment setups for some of those vendors in terms of some of them may potentially get percentage of profits maybe flat fee based on client who signs up and is retained for a certain period of time on the apps so I'd be curious to know what the licensees here use what they may anticipate those remuneration agreements to be because to me that goes into sort of the non-gaming vendor you're talking about dispensations and you're talking about exemptions and to me it rolls into the marketing guidelines so we can talk about it there as well but in terms of licensing and non-gaming vendors that's an area I'm concerned about I think that's a really important point commissioner what you're saying is that while it's in the responsible games space we've learned that these are vendors and how are we going to regulate those vendors and what would be a good expect because it's a different category than Louis Vuitton marketing advertising and also just deployment of responsible gaming features okay excellent excellent point can be re-interpreting in the next discussion too missionaries any thoughts on on the vendor licensing you know we are pretty familiar with the licensing process it's just that I'll just just take a right head to just get the expertise I'll just offer comments relative to exempting non-gaming vendors at least in the gaming world aside from sports wagering that is a responsibility that was has been delegated historically to the director of licensing in other words it has not come before those those those issues and requests for exemption have not come before the commission for determination that's not to say that we can't change that at this point but just making a note so for instance the example that Jackie used relative to shoes or or you know watches those exemptions were granted by the by the chief of the licensing division so just offering that little bit of insight from internal operations yeah I can I can I ask a follow-up on that Nikisha in terms of were there internal policy guidelines that drove that decision-making process or was that entirely vested within the authority of the chief the licensing division and let me make a correction it was not entirely vested in in the with the chief of the licensing division there was collaboration and discussion with IEB and so there was there was a policy determination that needed to be made in order to grant such exemption but generally the the process very much lied within IEB and so I guess my question is we have that that you know so the statutory exemptions were we as a commission vote on in terms of you know the service employee exemptions and then we have a a list of criteria and you know are they on the gaming floor are they on access do they you know was there anything similar to that internally in terms of vendors or if I can jump in because we do deal with this it's not routine we don't have a lot of exemptions but there is a regulatory provision with the list of potential exempted categories often it's a straightforward analysis like there is the threshold dollar amount that Karen mentioned so you know that's a calculation and if it meets it it meets it a number of the other categories are things like if the vendor is regulated by another area so for instance attorneys utilities things like that I think there's an exemption for professional entertainers like they would have bring in a entertainment group in that whole group doesn't go have to go through licensing and the one area that gets some analysis is it would not further the public interest it's a public interest exemption and we've utilized that for certain things like you know in the back of the house or you know Microsoft photocopying you know that that sort of thing so can I ask a legal a legal question here I understand the point generally Todd does a section of 23k imagine a delegation that authority that I don't think we see that it's 23 and that doesn't mean that there aren't ways that we can have work accomplished but out of delegation authority I'm just wondering if there is something different in the statute that we don't happen to have to go I'm asking Todd general counsel but you've got your Karen sorry Todd Todd looks he looks frozen to me actually but oh no it's not he's moving he's moving he's in the office too around the corner I can shout maybe he's not hearing that's Karen I'm not sure I can I can maybe I'm about to get I think we're I can repeat that I'm sorry were you looking for me maybe Loretta can answer it share it's yes I know the term delegation has been used this is not an authority that was vested in the by the statute in the commission that the commission then delegated I think the statute may have authorized exemptions but the the authority is originally given to my recollection but we will check in the regulation I think you're right and I did not mean to confuse things by using that terminology I apologize I was making the point really to Commissioner O'Brien's reference to advertising companies and the like I think marketing and advertising Loretta correct me if I'm wrong is a specific category of exemption under the regulations that's important in light of Commissioner O'Brien's question that's really where why I just decided to ask that because that's a really important question I see North raising his hand I was just going to say we're comfortable with the exemptions that are listed in 205 CMR 134.04.6 so we would assume that those same exemptions apply within this area as well and that and so I think just as if I'm hearing Commissioner Skinner correctly and hearing Commissioner O'Brien correctly at least with respect to marketing where right now that's a topic of you know critical sort of discourse across the country that might be an area where we would think there might be further guidance on vendor exemptions but I'm just hearing Commissioner O'Brien I mean because we don't have we have not had online gaming in the Commonwealth and so to me marketing going into that space is a new conversation but I hear North's comment too that he likes the list as as is okay thank you Commissioner Maynard anything you want to add no not at this time okay anything else on this this um this is a good uh Commissioner Skinner we appreciate your having the expertise on on on that topic and and and it'll help us going forward we don't want to create stickiness unnecessarily so if I if I can add chair I'm not suggesting at all that we should not take a look at you know the the environment for sports wagering as it relates to our marketing exemptions or or you know an exemption for marketing and advertising services I think given sort of the landscape of what we've seen in the past relative to advertising for sports wagering it is very much worth taking a taking a look at and thank you and Commissioner Skinner you might even want to look at the entire list and see if there's anything else given your experience that you know in the new landscape also might be of interest really helpful and of course Jackie did raise often this is a topic that's a of great concern for the licensees because they want to get going with their marketing plans so Karen again that's an area of regulation where we might want to try to work on prioritizing as well Commissioner Hill Commissioner Maynard any thoughts on that well you know this is something that I've been concerned about for many many months even before the legislation was passed and I think it's going to be an ongoing conversation from this point on so I'll look forward to those conversations in greater detail right yeah Madam Chair I'm going to hold my comments on that till we get to section four yeah and I was going to say we are complaining a little bit because this is an interesting Commissioner Bryan picked up that the vendor could include these third party markers so I appreciate that Commissioner Bryan no I think when I first brought this up to I don't know if it was Karen or the chair but the only thing I can sort of conceptually liken it to was sort of the the junket conversations that you know we had the junket regs that we had that's what it reminded me of is that kind of relationship which is above and beyond a typical vendor relationship but I will stop now so we can move on to the very last and the rest of the agenda yeah in fact we're doing just fine on time so we don't want to short change anyone including you and Commissioner Bryan but the point was very good point bring up the context of vendors again the fourth the last bullet yes it is the fourth in terms of licensing procedures if you haven't already stated where you could see a regulator like us having you know I guess it would be challenges that you've seen where maybe a regulator didn't address something and then there was a problem that arose in this area or where we could be creating unnecessary friction you know stickiness again always be serving our right to discreet any thoughts on that or anything where you saw jurisdictions backing up on something on in this particular area well okay all right before we break for lunch I guess that I would just ask my fellow commissioners we've heard from presentations from each you may have made some notes that you want to now follow up on that that hasn't that we haven't addressed so far and or anything else that you'd like to address given our earlier conversations now that we've heard more and Karen I have I have nothing further I think we're I think we're good okay now ready you have your audio off anything you wish to add thank you okay commissioners health oh this has been great information madam chair and through you to the licensees great information I hope it's been helpful for you as much as it has been for us so far and I'm looking forward to the next couple of subjects after lunch okay thank you for that seeing no one else oh I see there thank you so much never an enviable position to be standing between dozen people on lunch but my one question is we did have a number of questions about the interpretation of the statute with respect to the various licensing fees and I don't know what is the appropriate point in the agenda to address those whether it was this licensing procedures or perhaps at the end when we talk about licensee milestones but I just wanted to ask kind of when when if at all it's appropriate to discuss those at this meeting it is and my apologies I know we haven't taken a break and so it may be hard for everybody to digest I'm happy to do it after the break maybe if you have your questions kind of in front of you is that more or because something for us to reflect on during lunch maybe that's helpful yeah I'm happy to quickly you know quickly list them and then that would be good if you want to think about them while you're enjoying your lunch what just so very quickly one one question is I think I know the answer to it but just just to confirm because it was a little unclear at one point the notice of intent is only to be filed by pure category three licensee applicants correct not by the category one or two we have also included the category one and category two just for clarification it also gives up conflict and contact information a little bit more information so we'd appreciate that as well okay so you do want us to complete yes please okay okay great thank you that's that that's helpful with respect to the the five million dollar license fee that's payable upon granting of a license we've had several operators talking with us question whether they think that for a category two licensee I suppose for category one licensee would be the same question whether or not there is a single five million dollar license for both the retail and the mobile let's just say in the category two context or whether it is a separate five million dollar fee for each of the retail and the mobile so just curious as to the commissioners views as to how the statute is to is to be read on that um third question there also is a is a fee that I see of one million dollars that goes to the I think the public trust health fund that appears to only apply to Suffolk Downs and Rainham I believe and the category three pure category three licensees that is supposed to be allocated somehow by the commission and just curious as to the commission's thoughts as to how they contemplate that that fee would be allocated and I think it's a single one million dollar fee that's allocated among the licensees as opposed to one million dollars each but that's that's another question we did have the question that I previously posed about whether or not there is an issue with having a separate outside operator third party operator that we would partner with for each of retail and mobile or if there's any kind of either requirement or preference for it to be the same operator for both and then last but not least with respect to the requirement of a seven point five million dollar investment to be made by the category two licensees we just wanted to confirm what your views are as to when the if you will the clock starts running with respect to what counts as an investment because you know we've already been as I believe some others well I guess it doesn't apply to the category one licensees but you know we've already made a significant investment toward the 24 million dollars in the new facility and our view was you know well we can easily surpass the seven point five million if there were a rule for example that said well you don't start counting the investment until the license is granted you know we tell everybody to stop you know take the shovels out of the ground right now and wait you know so I that's obviously very important so that's that's it so these are really helpful for us to have over the next half hour lunch break Karen I think that there may be some that we can get back directly or give some direction on and then there may be a couple that our team will have to chew on them a little bit more care good questions correct Karen is there any follow-up that you want from the stretch I think that with any kind of question we want to be careful before giving a public answer or a pining so some of these we may just circle back and I completely understand and I just wanted to sort of get them on the table because I will say that they to some extent these are gating issues with some of our operators that they're kind of waiting to find out the answer is before they decide whether or not they're interested in a particular approach or not okay all right sounds good thank you so much ultimately they will be become public I think but Karen saying we wouldn't want to say anything that's not complete but we may be able to give some direction on some of these so thank you for listing them and I and I had noted the other question but we just hadn't gotten to it the one that you framed at the beginning anything else before we break the lunch nothing other than Bon Appetit I appreciate that all right then if it works for everyone it's 12 o'clock it's now so is a half an hour good or do we need a little bit more time absolutely our time Commissioner Ryan you get to name the time how much so we're almost 12 10 so do 12 40 yeah so I'll have enough yeah okay you're good for that because I know we're yeah and this okay now I planned accordingly today I was able to yeah excellent thank you all right then we'll convene at 12 40 and there'll be just a notice right now that we'll put up as a conforming the public that we're just on on a break thank you so much everyone's very very helpful appreciate it Lisa I see you sitting there and we didn't get to say hello to you this morning so hello hello how are you good I'm just getting back from our property in Colorado oh very nice yes it which was very nice handsome kind of congested my my bucket list those on the commission and my staff know that I love rock and roll and one of my bucket lists is to get out to red rocks to see a show all right so I totally did that I'm jealous unbelievably awesome and I will definitely go back and do that again I went there happened to be they're doing their summer concert series so they had reggae concert Saturday and yeah it was blast I totally recommend it and where I was sitting was 6440 feet that's where I sat for the concert I was just like oh my god I'm afraid of heights too so it was and I made it up there and I was fine so that's the good thing about it pack a lunch when you go because it is a hike to get in and out of there and then once you get to the theater you got to hike up to your seat well as you as you know I'm grossly overweight so maybe that will give me a good workout I don't know that they're a landing area though they're a break area as you can hold on and take a breath so I was told that in the daytime in that area it's quite hot but as soon as the sun goes down it gets quite cold out there at the red rocks we had major wind come in during the comm reggae concert and I literally thought I was gonna get blown off the top oh no yeah it was pretty I figured oh well they're allowing us to stay it must be safe well I my claim to fame is I've been hanging off the hanging off the red rocks themselves I did an all-day three-day climbing workshop on red rocks so a few years ago it was a lot of fun it was beautiful climbing there they tell me it's just magnificent to go see a concert and all that stuff oh it's beautiful the sound is just amazing so next time I actually and I shouldn't say this we're not public yet or are we we're kind of that way my daughter is in a relationship with a Colorado and is that what you say and so I'm sure at some point I'm going to be going out to Colorado and that will be one of my my stops absolutely so Dave I think that we can take down the screen but I echo it's a beautiful spot that's a beautiful beautiful spot all right all set thanks Dave Jordan it always comes back to rock and roll just so you know a part of rock and roll is Brad is that hand in front of you on purpose I don't see a hand up oh I think it's a it moved on to your face I got it thank you most people try and cover my face whenever possible I understand I wasn't comfortable with that all right so we're getting closer to everybody being here we got there now I don't really need and Gus is it's not quite back but I see Daniel is there so there's Gus now I'm your chair thank you so much thank you and we have the Mr. Eiffel and then Mr. Tuddle I don't see him right now think we'll let me just see if he's on them there he is hi Chip there we go excellent thank you so much we'll get started again this is a reconvening of a meeting public meeting number 389 of the messages this gaming commission we're joining a round table discussion but we are doing so from a virtual platform so I'll do a roll call with my fellow commissioners Commissioner O'Brien I am here thank you Commissioner Hill President thank you Commissioner Skinner I'm here thank you and Commissioner Maynard I'm here Madam Chair thank you we're all set then to proceed again we thank everybody for your cooperation and your your frankness and hope that we'll have a similar conversation going forward now that we've had a little bit of lunch in terms of the questions that were presented Karen I think maybe we can hold for section five to the extent that there's any guidance will be given or direction we can be given on as you pointed out and start showing in terms of licensing milestones I think right now if we could turn to item four for responsible gaming and advertising we shifted a little bit in that direction we've been thinking a lot about this issue well before sports wagering really came to us in any kind of a build form Commissioner Hill as he alluded to earlier it's been a priority for him early on really we were experiencing it during the NFL season so I think through Karen's conversations with you folks you identified a few particular areas in the response working from your perspective again we'll have the experts and the stakeholders in this area convene in a different round table so we set out three areas voluntary self exclusion promo play and the advertising marketing guidelines so perhaps we should and just to know our colleague Mark Vandalin is on vacation this week so if we have any particulars we'll be able to swing back he is our director of research in responsible gaming so we'll swing back to him as needed so in terms of about voluntary self exclusion there's some guidance on the statute are there specific questions or the guidance you're looking to for from us Jackie I see your range I think the only thing we were wondering about is whether that would be a combined list or whether it would be separate lists obviously just explain what you mean by that I think I know but I want to make sure Vandalin sure so obviously there are people who have who are on the voluntary self exclusion list right now and have signed forms asking to be excluded from the gaming the gaming facilities and whether that would apply whether that exclusion list would automatically apply to sportsway during as well and whether that's something that they've elected to exclude from as well and from our perspective doesn't matter we just like to understand it procedurally right and that's important for this category because there are restrictions on ensuring that you don't in any way market to those who are included on whatever we decide is that list so Karen I think there is probably some ambiguity as to whether that list is a combination do we have any thoughts on that from our end I mean I think that could probably do it either way and it's probably more of a policy decision that's where I've had discussions with Director Vandalin so I think this is something we should probably put an agenda for a commission meeting for a discussion and when Mark is available he can run through and there are pluses and minuses to each side from the problem gambler perspective and protecting that problem gambler so he can outline those for you and in further detail commissioners questions for Karen no questions for for Karen but I would like to hear from the other licensees if they have a opinion on it yeah again I also would I know that there is a national conversation going on on this exact issue but I wonder what your experience is with other jurisdictions that would be really helpful North it looks like you're meeting in yeah so our policy at Penn National is exclude one exclude all so patrons who exclude from one of our properties are excluded at all properties and patrons who exclude from any form of gaming are excluded from all forms of gaming okay and that's across all your properties the exclude one exclude all yes and then I believe for the all forms of gaming as well North can I do a follow-up is that sometimes more restrictive than even what the jurisdiction requires yes it is there there are instances in which a jurisdiction may only require a self-exclusion list to apply to that individual jurisdiction however we honor it across jurisdictions can I ask a quick question North yeah have you seen in your experience that once it's a once excluded all excluded that they try and get off the list because they may want to be able to do one form of gaming and not another so asking so I think when we get into the exclusions piece the the one thing to there are there are many different forms of exclusion that exist within each multiple jurisdictions the ones that we're primarily concerned with and talking about here are responsible gaming exclusions so a person who's either registered with a state sponsored program or told us that they are you know do want to be excluded so in those instances in those instances we honor that exclusion across all of our properties just do you want to add in on this than the vsc in your experience across the mgm properties yes I'm sorry I was going to say thank you chair specifically with what mgm the enterprise does I will I would defer to to my colleague Dan to answer that question more directly but coincidentally Mark Vandal in the was on property last week and and then I did speak with him a little bit about the voluntary or the exclusion list and we did voice to Mark that that it would be mgm spring fields I I don't know whether a preference I guess it would be the better word preference that we have one list I think two lists would be a cumbersome to to to maintain operationally and also you know our thought was that if you have a problem gambling in one medium why should you then be allowed to gamble in another so from a policy perspective it makes us it makes sense for us to have just one list but obviously we defer to you the commissioners and chair you on that specific issue but I'll defer to Dan to speak to about mgm spring mgm the enterprise is exclusion policy thank you guys and and yes we apply a similar program that north was talking about it's not as stringent by sounds of things as pens we we have an internal program called a self limit program in our other jurisdictions which can either be because someone has entered on to the voluntary self exclusion list in Massachusetts they are therefore self limited at our other facilities they could still come and visit our non-gaming amenities at other facilities but generally speaking that that's where we restrict them throughout questions for our licensees on this topic commissioners and can I just ask a clarifying question I want to make sure I heard correctly if there's a somebody who is self excluded let's say for one year here in Massachusetts if they go to the Las Vegas from the mgm property they cannot gamble they can visit and without I'm sorry I'm sorry carry on I didn't mean to cut you off there this one does not extend to all forms of gaming so they could game as a cash playing member only but we don't allow them to use their points use any of their rewards we don't incentivize them you know we try to take away the idea of incentivizing the gaming okay I was like I wasn't sure I'm sorry it was a little bit hard to hear okay sorry yes does everybody did everybody get that clearly the policy all right but Karen and do you have any further questions for on the BSE this is our public system with what we've been hearing right yes yes I'm all set thank you okay more complicated issue promo play and oh I should turn to the Mr. Tone and Mr. I shall you know forgive me but I I don't know the answer to this question if there's any and Dr. Lightbound I think may be out commissioners Karen we don't have voluntary self-exclusion for simulcast or first we maintain we maintain a voluntary self-exclusion list and have for for several years yes so you do that through on on your on your own correct yeah okay and is it for a particular time frame or do you have the same options that are exercised for the casinos um for a particular time frame I mean is once you're on it you're on it and you know we have security checks you know we have it posted and and have security checks and and yeah you know I would have to get back to you on the process for getting off it I think in our history once you've voluntarily self-excluded that's it you're you're self-excluded yeah okay that's very helpful and Mr. do you have anything similar at your that Mr. Carney's yeah um there there to my knowledge here is no formal program thus far although the simulcast center is in the process actually of having initial meetings with game sense and we're I believe starting to put up the you know signage and and begin the program but literally we're just in the initial stages of this I think even before not even in the context of the upcoming sports wagering if I'm correct about that and that would include game sense and then the issue around voluntary self-exclusion yeah okay exactly yes so we're we're fully I guess the answer of you we're fully prepared to you know and enter that program in full force going forward with respect to the sports wagering as well as the simulcasting thank you questions then I want to make sure that we had our simulcasts and representatives speak on this okay then we'll go to promo play who wants to give all of us there is a definition in this in the statute for the act who wants to just explain to all of us in the public what promo play is to a licensee don't quickly raise your hands but you're all sitting at the front seat so I get to choose I'll go with Jackie from because she has Elvis behind her so promotional play I think this has been it is a topic that's been very widely debated and and frankly every jurisdiction has treated it slightly differently you know we're we think we look forward to seeing what the regulations are obviously about it and participating in that in that in that discussion that it is something what it means for as a casino what promo play actually is practically just so we all know that we're speaking about the same thing an exam I'm going to defer to someone else one of the other operators to if I may north just turned off he's okay so the what the the reg or I'm sorry what the the final bill defines it as is a sports wager and credit or other item issued by an operator to a patron to enable the placement of a sports wager so you know practically speaking this is similar to what we offer to slot players or what some of the other licensees may offer to table games players it is essentially a coupon they can use to assist them in placing a wager and the issue that we hear about is the taxation and things of that sort so can we a little elaborate a little there we're all kind of new to this at least three of us for sure in regards to this so I think a further explanation would be helpful for all of us but you know I we I think we all know what a promo play is but what the ramifications of that is either with taxation things of that sort I would love to hear more about if possible could we just pause and just say Karen can you um I don't know yeah I think available but the current state or right now casinos how is promo play treated for taxation purposes I don't I don't know if I actually know the answer to that I think I don't know Burke you know the answer to that and I don't think Derek is on right now to ask that question I think generally though the question with related to sports betting is is promo play counted for tax purposes right and I just wondered about the current is you know I think it's I'm not I don't want to wager a guess but I think it's not apparently it's not it is not I just wanted to use the gaming word major in my sentence structure but yeah so I think so currently it is not and I think the statute is silent on it for taxation purposes now am I right Todd yeah that's right the definition north just read is not made use of anywhere else in the law that we could see the term is defined but that's it right and if you look at how GDR is is assessed for purposes of taxation they address the federal tax they address the the state tax but they don't address they address prizes right that might be given out like let's say Elkhorn Boston Harbor has a prize of a car that isn't treated as a winning for the the winnings are taken out of the overall GDR so for the taxation purpose so they don't include that but they did not address promo play and Todd you don't think that that's the same I think I asked that question it's not the same thing right I don't think no I think it's a separate issue I think you know ultimately it'll I believe come down to a matter of policy and how the commission wants to handle promotional play whether it's considered part of the revenues or not part or there are caps put in place or things along those lines there are as I understand it a variety of approaches that have been taken in different jurisdictions and with different results so it's an issue that will certainly have to take a close look at and ultimately the commission I think will have to decide most likely by way of regulation how the I don't have the term right in front of me but the essentially the the sports wager and revenue is calculated we have done that on the casino side there's an actual formula that's used and I would anticipate that a similar regulation would be adopted on the sports wagering side that would address the specific you people got no clue what's going on I can I can I just I think as the friendly neighborhood tax layer on the call I think also that maybe there's we're conflating two different issues here one of which is is the granting of a promotional credit taxable to the individual gamer or wagerer in terms of did I have to include it in their income for federal and state income tax purposes versus what I also at first thought we were talking about which was whether or not it is the amount of it is included for purposes of calculating the state taxation on the net net gaming revenue right which to me that would almost seem to be irrelevant because it would be part of the handle but it doesn't it's kind of meaningless unless they're winnings right or is that not but it includes the issue around winnings I don't know how other jurisdictions for sports betting include promo although I guess you know I guess if it's part of the gross handle then it would go into the theoretically into there so you have to come up with a rule as to whether you consider that part of the gross handle I would I guess for what it's worth as a policy matter and a tax lawyer I would view it as being really kind of a discount as opposed to you know an actual I'm going to have a public share so this is the first time that we've had somebody from the public decide to chime in and you should know we can hear you you're not able to be identified in a public meeting members who are not invited could be invited with the chair's permission if you would like to identify yourself and you'd like to make a statement I could consider whether you could become a participant for the discussion in a productive fashion and we're having if you're the way you can mute your background Kevin I couldn't get your last name I want to be really respectful to you and then in turn I hope that you'll be respectful to us if you could um thank you just having a little trouble hearing you yeah don't you know you're a little clearer there and I appreciate it we do want to hear from you and I think we'll definitely have public hearings where there'll be an opportunity for the public to weigh in in a really constructive fashion we don't want to dismiss your concerns and we want to we want to also acknowledge that we're working hard here to do our best all right I'll send you an email today thank you very much sorry for bothering you no no it wasn't a bother thank you Kevin okay so let's get back to promo play Madam Chair it might be helpful my understanding and please licensees chime in my understanding is that with it with the emergence of of a new offering so sports wagering there may be and this may apply more to the mobile than the retail but there is definitely a competition for customers because the the long-term benefit of having a customer may outweigh the short-term pain of offering a lot of promo play so what we have heard is that there's this this balancing that the licensees may be interested in offering a lot of promo play at the get go so that they can attract more long-term customers to their company and the downside to that we've heard from other states is that then the tax revenue can be remarkably decreased and that may have an impact on the benefit to the state so the benefit to the Commonwealth of Massachusetts so I think that's my understanding a very basic understanding I think we need to have a little more internal discussion on promo play and come up with some training materials and education materials for the commissioners before making a decision but it would be helpful I think to sort of get the perspective of the licensees on the importance of promo play and the importance of to them of not taxing it versus taxing it I think and I think there's two issues for promo play at least two and that's taxation then there's also the marketing correct correct so this I'm talking about the taxation but the tax responsible gaming and marketing and advertising that's a whole other other avenue as well that's correct and and just to clarify Todd I don't know I have my copy of the the statue I don't know if you have it there but if you could go through what the the definition is for Mr. Eichman those purposes how the taxes is calculated I think it's on line 57 line 57 okay and yeah just to clarify Mr. Eichel one of your comments we are talking specifically just about the calculation of the tax payment by the licensee not the tax treatment for the individual that's a separate issue it's typically just handled under the code the tax important line thank you so I'm sorry North I missed the line you just cited there but five seven five seven definition of adjusted cross sports majoring receipts the definition of all right let's pull that oh sorry I was looking at the wrong one I'm sorry I don't it looks like I don't have it open it's the definition of adjusted gross sports wagering receipts found it's just early on in the definition yeah I gotta just pull up the whole bill north in the interest of time if you have the definition of adjusted yeah if so if so don't count I can I can I'll pull up it's it's defined as the total gross receipts from sports wagering less the sum of one the total of all winnings paid to participants and two all excise taxes paid pursuant to federal law provided however that the total of all winnings paid to participants shall not include the cash equivalent of any merchandise or thing of value that is awarded as a prize so it does not mention promo play yeah and I would think that what needs to be clarified is whether or not and I don't see a definition that relates to it is whether or not total gross receipts from sports wagering would include promo credits well that's the we as a commission have to decide and I'll be honest I'm a little surprised at the reticence of the licensees because what I've gathered so far is this is you know they're pretty strong feelings usually on whether or not they want this we've had several jurisdictions in the in the country that have actually changed their position on this because they felt they maybe didn't do the best interest for their states so I'm actually a little taken aback by the reticence on this to be honest it is absolutely something we as a commission have to dive into in greater detail and I was hoping to get some preliminary views from the licensees so I'm somewhat taken aback by the silence but we can move forward in terms of looking at what other jurisdictions have done in terms of no credit whatsoever to us you know phasing it in versus capping it in any given year there's a lot of options that we have in front of us or whether we read the statute to mean there's absolutely no place for an offset for gross gaming in the revenue for promo play Goss Yes, Chair Thank you very much With all the respect to our commissioner Brian I was actually waiting for a chance to to speak I didn't want to interrupt anybody so if you if you can thank you that's why I do apologize for that that's for no that's right the chair asked for licensees to chime in so I'm I may not have been clear on what I was asking you really helped frame it I'm finding thank you but Goss I don't think there's any surprise to you chair or to any any commissioner anybody else on this call if I tell you that MGM Spring Field is all for accepting promo play from calculating in the in the GGR promo plays is crucial to to to driving customers to the market promo plays crucial to awarding customers for loyalty promo plays is crucial to making sure that this new new venue that we're interest interest to the public is is a successful venture not only for the for the you know the casinos and the other sports betting agents agents for for the city the state everybody else which may be involved so we are 100% behind giving as much credit to promo play as possible so if there was any reticence there is no we we hardly 100% indoors making sure that that promo plays is excluded from the calculation of course in revenues and you take a position on whether that's more critical early on I mean I get there's the idea of wanting it all the time obviously and to to minimize the tax impact but then there's also the question of is it more critical early on in launching yourself into a new jurisdiction I think it's very I'm sorry I'm sorry go ahead check out for two we'll go with Gus first and then Jackie thanks yes the preference would be for the promo play to be permanent but if if that is not possible or improbable that of course promo play earlier on in the process it's going to be much more critical to our success than then down the line so yes to answer Commissioner O'Brien's question yes earlier on it's it's more critical okay now Jackie you wanted to elaborate on both the first question in the section sure so on promotional play we'd obviously like like for it to be deducted as you know most states have made changes in that the the issue like Colorado is an exception Michigan allows for a small percentage of deduction Virginia used to but they changed it definitely for retail that makes a big difference for us obviously as we launch that's a that's an incentive to get customers we balance this all the time we balance it on the casino side and we balance it on the sports betting side if we give away too much that's a problem for us too so certainly it's something we feel strongly about it we're also very cognizant that the the regulatory environment has viewed that differently from an an operated perspective other comments north I I guess I would just say you know if you ask if I want to be able to deduct promo play I would say yes it's a it's a helpful marketing tool to us but I am I'm not an attorney and I'm not good at being able to decipher what the legislation says or doesn't say around promo play I can just read what the Senate says so I you know certainly we would be in favor of being able to deduct it and you know we're relying on the legislation and the commission's interpretation of that legislation to give us guidance I appreciate that north it's it's I don't even think it's necessarily really helpful to have a law degree right now with respect to deciphering that but it is a really a critical issue I mean did you want to follow up no so what I'm other than to say I'm curious to to know what impact if any the and this obviously is not going to apply to Encore given the jurisdictions that you're in but maybe Penn and MGM if there's anything you can talk about pre and post in terms of impact when the jurisdictions that you're functioning in have changed how they treat promo play good question have you experienced some do you do you have facilities in those states that have shifted and the impact so I'm not as close to those states that have shifted their impact I would say that Penn's position with regards promotional play within this environment has been relatively stable since the beginning we have not been irrational investors in this area so I think that our position is has remained relatively fixed throughout I think that you know the natural consequence sometimes of the increased promotional play is is an increase in total wagers or total handle but may at least at the outset decrease the net gaming revenue I think now one of that what that translates to in the long term I think is yet to be seen and I think from a launch perspective at the outset it helps us frankly offset some of the offering cash that we have to pay out to get customers and it also gets the players comfortable with playing so that's a reason why we would appreciate it at least at the at the beginning for retail commissioners I think that the issue has been maybe clarified what questions do you have and also I need to go to our I don't mean to in any way skip over Mr. Eichel and Mr. Tuttle I don't know if right now you have thoughts on promo play for the purposes of standing up your retail sports rager interested in the discussion but nothing more to offer right now Madam Chair thank you thank you Steve yeah I would just say that we have heard from our potential partners that promo play is an important element of their business strategy but we have no personal historic experience with it in our business okay commissioners follow-up questions no you're all set commissioner Hill commissioner Skinner any follow-up questions commissioner Maynard what are you thinking no commissioner Brian perfectly captured any questions that I had to okay excellent so so moving on to the the other side of promo play because I'm hearing and I'm hearing our licensee say how critical it is to attract customers and I think I know I publicly said it and I certainly have heard director Banderlin and say it we respect that need but it can't come at any cost right so how do you balance the marketing and the promotional play your approach to customers around promo play without it going into a predatory in a predatory approach commissioners if you want to elaborate on that that's kind of the framework for the the discussion on the other side and I know that Jackie started with we need we need guidance on this and for tax rate but it's also to respond to the statutory provision around advertising the parking commissioner Brian are you leaning in no I'm curious to know what their comments are I'm sure it's a balance you exercise Jackie absolutely I mean look we think about that all the time it's not sports betting isn't the only time when we have to make those decisions I we as part of the launch of gaming we spent a lot of time working with Mark Vandal and the team the and developing not obviously it was the commission who developed the responsible gaming framework but we provided a lot of feedback in that process and we would welcome the opportunity to sit down with that team perhaps in a smaller group and give it some thoughts to that and develop our responsible gaming plans once that's advanced excuse me Das do you want to chime in thank you chair I think that when you came out here last week with commission and maynard you saw the new game sense space that we had created you know that we and Jim Springfield rolled out play my way we take responsible gaming exceedingly serious and not only at the property but enterprise-wide at MGM and so we would certainly defer to mark and his experts on the best way to to market and to control sports betting but we are fully on board with whatever mark in his team want to do I think we have shown our commitment to responsible gaming and we continue to use that as a touchstone as a cornerstone for everything we do here at MGM Springfield thank you Christian Maynard do you want to respond to that you were part of that generous tours and GM party I did appreciate the tour that MGM and and and on court of the Friday I do think you asked a question chair around framing this this issue and I think that you know this has to be done thoughtfully it has to be done correctly because you know when you turn a cell phone into part of the experience it's um you totally change the way this is it's done I can't put you know poker table in my pocket I can't put you know a slot machine in my pocket and we have a duty to the patrons to get this right and so it's it's very important that we do that but I'm hearing that the licensees are agreeing that they think it's important to to engage with us on that process and so I'm really interested I have a question at the end of this statement and seeing what's going on in other jurisdictions what we can do to to help mitigate problem gambling when you know this becomes part of the equation okay now we're going to see oh sorry I just just was going to say one of the other things we've seen is that there's talk of also the amount of advertising that just seems like it's everywhere and there's some talk about whether regulators could potentially across the board limit the amount of advertising various mechanisms yeah that's our bullet I just would like to just stick with promo marketing yeah thanks yeah just because of the promo it's a little bit different then I think you're just about to frame the next bullet so hold that thought I'd always put down my apologies yeah you're just getting ready for the next the last issue yeah okay North you are going to maybe respond to the the promo and how we balance it now being predatory and I think you've heard Dustin Jackie reference their work with Mark right so I think as we we think through this issue and look at it especially as it relates to retail the you know which I believe was the focus of today's conversation a lot of the same behaviors that we see from patrons who would have a responsible gaming issue in our who play slots with us or electronic table games that that those customers would probably present some of the same behaviors and we would use the same resources that we have right now in terms of relying on our team members who are all we're all the time and interact with patrons and on our game sense advisors to help us find those folks who are in need of assistance and get them the help that they need and the tools and resources to be able to deal with any responsible gaming concerns that they might have can I go ahead Commissioner Maynard yes okay though I want to I want to be clear that every tour that I did and saw the spaces this was brought up as a part of the cell phone for those on the phone was brought up as a part of the experience right that you know here's here's where you can go and and make your wager here here's how the kiosk works and you can serve this chair and use your cell phone so I do think it's a very game question even for this forum and I appreciate that so maybe the way to think about it north is retail alone is promo play the approach going to be different for retail of sports wagering versus casino promo play which is something maybe Brad we should be thinking about you know right and then to Jordan's point to commissioner's point what well today the focus is on the standing up of retail how will the promo play question collide because what I think Karen started with was in order to attract it's it's just more it's going to be more competitive so promo play might even be more of an issue as you as the two intersect the retail in lower I agree that that it probably will be more important when the two do collide and you know one of the things that we've seen that that has worked well for us in other states is they have a sunset provision so they allow it up to a certain limit for let's say 12 or 24 months whatever the time period is and then it tapers off from there that would enable us to be competitive also with the with surrounding states who already have an established customer base so that's helpful so the timing that's that early on and and so north do you want to add in no I'm I'm all set thank you okay Mr. Todd on the star I shall do you want to add in this is probably a good a good conversation for you to be hearing these are challenges yeah this is this whole forum is very helpful madam chair and again we appreciate the commission doing it I but I don't have anything to add on the top Mr. I shall no no this is educational for me as well I mean again just as a common sense matter I would think that it would be somewhat self-regulating in the sense that you know you're going to go bankrupt if you give away too much promotional credit and I've heard that there are instances of companies that have gotten into trouble by doing it excessively in terms of their own financial well-being but I realize that that alone might not be sufficient and that you know there would just logically be considerations about you know using it to get people hooked on you know gambling unnecessarily or you know or predatory competition so all ideas well understood thank you that I think we'll move on Karen you were just framing it out the the frequency the intensity of advertising you want to finish your thought and I know Commissioner Hill I'll let you I'll let you because I know it's so important to you to add on Karen's framing yeah I think that I'm just think it would be helpful for the commissioners to hear if restrictions potential restrictions in whatever format were applied across the board it would there would there not be an objection by the licensees it's that you know rising tide lifts all boats so if you're at the same level as all your competitors it's actually is it actually a sort of a neutral thing for you and everybody is limited in the amount of advertising and then you're not spending all that money on advertising and then the public's not subject to a constant barrage of gambling advertising so I think just curious what the what the licensees think about any limitations on advertising that would be across the board I'm just gonna let commissioner how did you want to add in this is something that are you good right now no I think Karen framed it very well actually great thank you and Karen do you think it's necessary it may not be to have Todd read in what what is in the statute now is it is everybody is everybody comfortable in terms of familiar with what the act provides Todd do you have that handy I do have the act handy I'm sorry can you just repeat what you or you'd like me to go through just the language referring to the advertising restrictions so and I think this is a helpful exercise to remind us and then also the public Jackie and then I'll turn to you next okay the looks like I think the bulk of the advertising language is contained in the section that talks about the regulations that the commission shall promulgate and it goes through a series of principles that need to be included in these regulations and it's it's a whole paragraph I'll try to go through I can read the whole thing of course I think it's just to go through what the restrictions are on advertising so it starts about applying 185 yeah so it says that the commission shall promulgate regulations that prohibit and then it goes through a list of things that shall be prohibited it includes the purchase or other use of any personal biometric data of an athlete so and then it gets into a little more detail on that and the following advertising marketing and branding activities and then there's there's a list of so these are all on the list of things that are to be prohibited advertisements marketing and branding in such a manner that is deceptive, false, misleading or untrue or tends to deceive or create a misleading impression whether directly or by ambiguity or omission it also includes use of unsolicited pop-up advertisements on the internet or by text message directed to an individual on the list of self-excluded persons established pursuant to the law it includes any form of advertising marketing or branding that the commission deems unacceptable or disruptive to the viewer experience at a sporting event a sports event it includes advertising marketing and branding deemed to appeal directly to a person younger than 21 years old and it applies to advertising on any billboards or any other public signage which fails to comply with federal state or local law I think that's the crux of it that's what we needed I think just a it's a good reminder that the legislature did think about advertising restrictions marketing restrictions I think a couple of proposals were more global there was I imagine quite a bit discussion around this so I want to turn now to Jackie who started to provide her thoughts and I just did some additional framework thank you Jackie thank you I think we've all seen in different states where advertising it's gone awry driving through New Jersey I think every other billboard is for sports betting but and we clearly don't want to participate in a race to the bottom the only thing that I want to raise is that our competitors from other states are already advertising in Massachusetts and we need to try to be on a level playing field with respect to that I raised that issue the other day Jackie and I know Karen I don't know if you picked up on I don't know if we call the Department of Transportation but I noticed as I was leaving Massachusetts well no we were staying in Massachusetts we were going south that two competitors were advertising and they have no responsible gaming language on their billboards where on core I I happen to live north on 93 and I go by those billboards and I I do see the the language is there so that's something we should be approaching maybe DOT is in charge of billboards I don't know Commissioner that Hill do you know there's an outdoor advertising in MassDOT that controls the billboard MassDOT yeah MassDOT it's a section of MassDOT yeah Commissioner Hill yeah so you know maybe we reach out to Secretary Tessler and now they've got a few things on their minds right now but that point is one that's important so thanks for bringing it up it happened two separate trips and I have to confess it was my husband who noted it and how come they don't have to have responsible gaming language so we're educating an expanded public so thank you Jackie in terms of the overall question and and the need to be on level playing deal with competitors when you saw this language what did you see that might be helpful for us to understand from a regulatory point of view and Commissioner Skinner don't know if you have any thoughts to add in anybody jump in from my fellow commissioners Jack Jackie I don't think there's anything problematic for us at all with respect to the language that's in the act obviously we we would never engage in deceptive marketing practices or advertising to people who are under 21 directed advertising to people under 21 or self excluded persons so we didn't see any issues with this language at all good thank you I think Plain Ridge Park sees the same thing with regards to what Jackie does I mean we would obviously continue to include our responsible gaming messages and our advertisements and as Jackie said we would never engage in practices that we thought were any way false misleading or deceptive Commissioner Hill can I you I I can't remember if it was bam bam bam but the disruptive nature of of at least television advertising that caught your attention back last fall so the concern I had and I've heard it from different people but I'm not the more I dig into this I'm not sure there's a there's something we can do about it but the barrage of advertising that that we were seeing like during the playoffs of the NFL during the baseball back in the fall was just like they were popping up in game they were before games they were after games I mean every time I put on my TV um one of the companies just kept popping up popping up and popping up and people were like holy Toledo enough is enough already but I'm not so sure under the Constitution that we can do anything about it but I'm still you know I'm looking for feedback on how or if this is something we can address I want to address and I and I think the section the third section C where it says any form of advertising mark and bring with the commission deems and I said we're disruptive to the viewer experience at a sports event yeah does that mean it doesn't include TV viewing Michelle Bryan and you have you already noted that I did and one of the other I I harken back again to the last online training that I did and the gentleman from Michigan talking about their experience and he picked some of the topics that were the most troublesome advertising was one of them in terms of inundating and not just at sports events it was general you know residents of the state calling up and complaining and saying enough I am just getting a barrage be it online or TV and why why can't this be you know dialed back but when you look at the wording in the statute there are narrow limitations put on specifically there now whether there are other vehicles and are responsible gaming and things like that you know the advertising marketing branding deemed to appeal directly to a person under the age of 21 seems to be the broadest category because it's not confined to someone in attendance at a sporting event and so that to me is an area I'm curious to dive into more to say well what exactly does that mean and what do we have the authority to do in terms of making sure this is not getting marketed to anyone under 21 I'm not sure North that sort of jacket if you can address that but the the issue that Commissioner Hill noted very publicly and really start our conversation on on gaming advertising I don't see how we get that except to again if it's so at you doesn't start to get into the minor into and of course there's other language but is that part of your do you do you provide us some of the help or are you thinking about it with respect to your marketing advertising sensibilities that it's a non-issue and of course I'm thinking two of the two simulcast centers thank you Madam Chair so just to complete the trip trifecta before I answer your immediate question is that I completely agree with both North and Jackie that MGM Springfield does not say anything problematic in the in the statute regarding you know marketing and advertising just like you know those entities you know MGM you know takes pride in having the highest ethical standards and we would never never ever you know even in the absence of the statute purport to you know misrepresent ourselves or do anything to undermine the public trust in us so so again I completely agree with Jackie and North on their point with respect to advertising you know not being not being a constitutional lawyer I would presume to say that federal laws the federal trade commission federal communication commission probably has more control over advertising than than you know state might so I think that would probably be problematic to try to govern that on a state basis but again not being a constitutional lawyer that's just my opinion on that point really helpful insight though I think Mr. Hill that's kind of to your point right yeah and I'm also you know I'm also cognitive of the fact and I think Jackie brought it up and I'm only going to speak for and I do this a lot so bear with me because I know I do this a lot I can only speak to the North shore area of advertising I don't live near Rhode Island but I do live near New Hampshire and we get advertising on our TVs from all the New Hampshire betting facilities as well as being able to go on your phone and do your betting so we're going to now be having New Hampshire competing with Massachusetts Connecticut Rhode Island there's going to be a lot of advertising going on around Massachusetts and it's not just Massachusetts that we're going to be seeing so it's going to be quite a barrage at some point but I'm not exactly sure there's anything we can really do about it but we're going to dig into it a little further and see for sure because I think there are some concerns with the constitutionality of trying to tell people what they can and can't do in terms of advertising but just wanted to share that with you Madam Chair that's really helpful and part of a continuing conversation that really got started last fall Patricia Skinner haven't heard from you what are you thinking I am thinking that you know it really will be worthwhile to continue the discussion more indefinitely our licensees have demonstrated that they are conscientious about responsible gaming that they support it and the commission's initiatives and I don't see a reason to believe that they won't continue on in that vein especially given their direct statements that they're just fine with the language in the statute thank you Commissioner Maynard Commissioner O'Brien is a dog visiting you right now Commissioner Hill it was a comfort lock I love that Commissioner O'Brien no this is an area I was curious about before the statute came out again after the discussion with a gentleman from Michigan it's another area that's concerning to me particularly the 21 and under and so I understand that you know there are limitations to what we're going to be able to do but I do think that the population under the age of 21 is an area for us to really look at and again I agree with Nikki just not that I'm saying that any of the licensees who are in attendance today have done anything that would lead us to believe they're going to run afoul of the statute I'm just talking about our ability as the commission to further protect the interests of the citizens of the Commonwealth particularly those that cannot gamble that's where I'm looking at with this statute to see what is what are the boundaries of what we can lawfully do to protect that constituency I would just volunteer on the subject that I think it's not a unique problem and that you've got some analogies I would suggest that you could look to I think the ability that there is to regulate advertising I would think even on the state level is probably I'm not an expert on it either but I think it's probably broader than you're assuming you know I mean there's limits on advertising for smoking and vaping there's I assume this was a big issue when cannabis you know became you know more you know legal and is advertised there's certainly talk about billboards all over the place I mean it's like cannabis is you know every place you look so I would think that there you know you might look to some of those analogous areas where it's an activity prohibited to those legally to those under 21 and what the advertising restrictions in terms of billboards and media ads etc have been in those areas that you know might provide some guidance really helpful really helpful ship yeah you know we certainly don't have any issue with the statute obviously the commission is wrestling with the practicality of national advertising and you know I mean if if a major sports book operator has ads running in you know college football and NFL games on Saturdays and Sundays there's obviously no way to prohibit citizens of Massachusetts from seeing those ad advertisements and things like that but to Steve's example again you know the cannabis control commission has set out pretty stringent regulations about marketing to people under the age of 21 you know I am a partner in an advertising agency in Boston and we're aware of some of the restrictions on billboards you know and in the locations the billboard companies have to attest to the fact that the audience for billboards is you know less than less than 85% right things like that so there are some examples I'm sure that the commission can draw from elsewhere in the Commonwealth that may be helpful to you yeah one further point by the way is that there may be some distinctions here in terms of state versus federal regulation as Chris just a chip I'm sorry just mentioned because you know those those national advertisers you know are working in interstate commerce and that is you know sort of federally regulated and cannot be regulated by the states whereas here you know at least to some degree you are talking about regulation that is by definition within the Commonwealth so you may actually have more power to do that within the Commonwealth subject to less restrictions in terms of violating the commerce clause for what it's worth as a constitutional matter that's really helpful and encouraging sorry if I could just add one more thing sorry sorry who was speaking Jackie sorry thanks sorry I also just I wanted to point out that the ADA has adopted a responsible marketing code for sports wagering which goes into some of these topics in more depth so that might be a place a source as well and I know we look closely at that with Mark so thank you been helpful for for all present today they've done an excellent job all right I want to make sure we give adequate time to the next million important topic we put it at the end so much strategically the first bullet is the licensee for standing at retail operations and I want to turn to Mr. Aysel first he asked those questions Karen I know you had a very brief time to think about it and I don't know as any of them could be given any kind of partial or full answer or some general guidance with of course some permission to correct down the road if it's general how do you feel about that Karen so I did get email from Joe Delaney so thank you Joe in response to the question that came up from Rainam on the capital expenditure requirement and when it kicks in he did send me the text from the law which says provided further a category two licensee shall make a capital investment of not less than 7.5 million within three years after receiving a sports wage during license so there there is that there you know I'm just highlight that for the commission so of course thank you that's yeah Mr. Eichel pointing that out Mr. Eichel raised the right question though yes stop the process yeah stop the clock would you write it right it's a little irony send all those construction workers home a little irony here I think they were fearful that folks might linger about putting those that investment in so they said a three year but to your point you've been investing interesting I mean we were going to be done by February and obviously this is an issue well could you read the language again just said it says provided further a category two licensee shall make a capital investment of not less than 7.5 million within three years after receiving a sports wage during license receiving the license yeah well if that's interpreted to mean beginning with the time that the license is issued and can't count if you've done it before but within three years after the license is issued I mean there's there are two ways you can interpret that but I I don't think we want to take our chances on that one let's see yeah if that's an interesting an interesting challenge because probably unintended consequences I would have the opposite effect of probably what it was intended to do exactly exactly so so that's really helpful Joe thank you thank you and Steve that's just a preliminary observation right you're stood okay in terms of other the other questions Karen so the third party operator question I mean I'll I'll defer to the commission obviously I think you know from my perspective as executive director at I don't think it matters if you have one or two operators I think that probably is your discretion what will have to be decided by the commission is any kind of licensing requirements for those operators you know we talk about scope of licensing background checks all of that so where a simulcast facility you know they're saying they're going to bring in an operator we'll have to figure out the proper construct for vetting of the operator and how the commission wants to approach that so it may be or only to do one than two so resource-wise we understand that right but not in two it's easier obviously if it's a single one right right thank you and then the other two the other two questions Kathy the license fee and the public health trust fund amount I I did not have an opportunity to speak to anyone on the staff about that so I'd ask them we just hold on those for now so if I'm just to make sure I heard the public health trust it's right now if I could call correctly maybe it was clear on category three have to share that but the simulcast centers have to participate so as a question is it a five if it's let's say it's seven mobile would it be a nine-way division of a million dollars is that your question Steve yes yes and of course I mean that's that's the way I think that's the way it reads I don't think it's a million each but I just want to cut that okay I want to make sure you know what might be helpful Steve if you could email me the two questions in writing so that I can make sure properly answering the question so on the license fee and the public health trust one if you email me those questions happy to do so staff take a look at that sure thank you so much sure and and just to clarify the the three casino licensees make a contribution to that fund already so I think sharing them from this one yeah yeah so just creating an equal somewhat of an equal playing field there okay so do you mind if we then go on to test everybody's interested in timelines and so we would ask if you could help us understand what your timeline might be so that we can be helpful and it will also inform our timeline who would like to go first on this one nor did you go sure right okay so with regards to timelines I'd say really the only determination we will be making is whether or not we need to construct a temporary facility before a more permanent one could be opened I think under either scenario we would be be able to to launch wagering at a time that is fits in with the regulatory framework that the commission has follow-up questions to got to north's answer did I lose I don't know Christian Hill do you have any any follow-up questions right now okay Karen do you have a follow-up question put on that yeah I mean I think well and we we've discussed this along the along the way I think sort of understanding what these milestones are like what needs to happen in order for you to stand up the retail operations my understanding is for example you need a space you need regulatory approval of the space you need to order equipment you need to have that equipment you know the like vendor license you need approval to get that equipment in and you need the equipment tested things like that so are there I guess the question is what are what do you identify as the biggest milestones or potentially the regulatory needs that you would have in order to progress and then what is the order of those so we can match up timelines so three things launch date the firm launch date is helpful second thing would be prioritizing the promulgation of rules or regulations around licensing and then the promulgation of rules and regulations around technical standards those three things or or technology you know hardware software those types of things so those things are the things that that would help us move the quickest and that's kind of the priority order in which we would see it that's helpful thank you very very helpful Gus thank you chair as I said earlier MGM Springfield has the prop that you know the space set ready to go all of our FF&E that's all installed our cabling and wiring is done it is a matter of just getting the kiosks and getting them tested getting them approved and getting them hooked up so really we don't have any milestones that we necessarily need to hit in order to start soon as we have the approval I think we can as I said earlier I think we can probably be ready to go within a matter of 90 days within 90 days so if you're asking for key milestones it really would be better guidance from from MGM on the licensing process and the approval of the equipment thank you okay and chat G I agree with both North and Gus I think what what's really important to reiterate what North said is to have a set launch date and then we can work backwards and provide you provide you with how long things will take us from that point you know from a hiring perspective and getting people on boarded and you know we've got to identify them license them and then get them on boarded and train them that's probably a six-week process if we're if we push the button today and then the equipment you know we're we're ready to go on that as soon as we as soon as we get the go ahead and as soon as we see the regulations all right I'm going to Mr. Eichel and then Mr. Tuttle and then we'll get questions on the timeline and we might as well just also wrap into this discussion the third point which is a staggered versus simultaneous in person sports majoring in law okay so Mr. Eichel so I mean I would just I would just echo the comments of those more experienced with the process who have spoken before me I would say you know they're just again in speaking with the operators that we've been talking with you know there's there seems to be you know a lot of sort of chicken or the egg you know issues in coming up with timelines because they are dependent upon kind of seeing what the rules are before you know they know how to you know how to come up with their models and procedures so you know obviously waiting for you know regulations and and you know application you know applications and finalization of of those procedures will be will be critical you know I think there's an expectation out there that this was going to you know be possible to get up and running a lot faster than than I think is really possible and so you know and but I I understand and agree with you know the the commission's diligence and thoughtfulness with which you know the the process is being handled there's a lot of you know issues of first impression and and complicated issues to to be dealt with everyone's anxious to get up and running and you know I think the good news is that I think the ability of folks to get up and running in terms of the physical facility and you know their financing and willingness to do it probably is actually ahead of you know kind of the the legal infrastructure to just sort of know that we can go ahead and proceed in the way that you know we would plan to because everybody's in a little bit of a a holding pattern you know knowing that there's a lot of legal rules that need to sort of come out before we paint ourselves into a corner by doing something that might not be the right thing to do like continue constructing exactly like exactly like that right all right very helpful chef yeah well it appears the spending of the 7.5 million may be one area where we actually have an advantage over other licensees since ours is is going to be on a moving forward basis the the only thing in terms of timeline madam chair and commissioners that I would add to what's already been said is that we are endeavoring to catch up very quickly and again as I said at the outset you know expect that we will have news in the near future on both sports book partner and short-term and long-term certainty on the location to come back to you with mm-hmm before I turn it over to my fellow commissioners and just maybe to close the loop on an earlier discussion we spoke quite a bit about the challenge of staff and you had all excellent responses you see supply issues for the equipment that you'll be needing that might impact your accelerated timelines Madam chair Penn does not we're good to go we got a big warehouse right north somewhere we have equipment we can we can get here when we need it got it okay Jackie at on court feeling the same where are these coming against some supply issues not yet so we're not done yet yes okay and Gus we have inventory I mean obviously to tap into that inventory we'll need a little bit of a lead time but we don't force you that that being a problem Madam chair that's good news okay and Chip and Steve I don't know if you're right now at that point in time but I had thought that might and I think Karen thought maybe that might be an issue but it sounds like not so much Steve yeah I think we're not not close enough along you know far enough along in the process to really be able to say anything intelligent on that one okay great and Chip yeah I you know I think there's a level of confidence that we'd we'd be able to get up and running pretty quickly but in terms of specific equipment and things like that I can't offer much more okay questioners timeline questions we heard some good feedback on prioritization of regulatory obligation questions Eileen Commissioner Bryan yep on the launch date suggestion obviously we have sort of two different paths I mean they're on a path you guys have to get yourself up and running we have to make sure we've done everything we need to do to not only do that but make sure our compliance role is up and running as well so my question on the launch date is more once we what is the critical juncture at which point you would be able to anticipate going out in terms of what is it that you would need because I'm not anticipating we're going to say to you on date X we anticipate you'll be ready to go I don't anticipate that that's realistic so I'm trying to figure out when you say launch date what exactly do you mean by that so I think that would be the point at which we know that the regulations are set and that we are we are free to begin accepting wagers so if we have a heads up on when we think that's going to be then we kind of we back into it that way so the way we've kind of developed since you know passport was first repealed as we began developing a timeline or you know imagine a Gantt chart that has X number of weeks from the date that we think that we're going to be able to begin accepting wagers and we just work backwards from there you know it has a certain amount of time in there there is a little bit of of wiggle of gosh if this goes wrong not everything is sequential some things are on parallel paths but those really I think when we're talking about launch date it's like hey when when do we anticipate that all the rules will be set and then you would be okay with us beginning to accept wagers at the facility with regards to the timing of of the staggered versus simultaneous I I think Madam Chair probably is planning to I assume address that next but I will have a couple of comments on that okay so I guess I'm I'm still and and you know we're pretty early in this process but I am not envisioning that we're going to be able to give you right now or even in the next couple of weeks a date in the near future that says we anticipate there and you can start working your way back from there until we get to sort of the critical juncture of most of the regs being in a position to go application ready that sort of thing so I like the discussion and I appreciate how you from a business perspective work back from a launch date but I think that's a great internal discussion for us to have as a commission in terms of prioritizing everything in a way that makes sense for not only the launch date but also for us as a commission to kept everything in place that we need and I think what's a little what was a little concerning for us and what we're trying to work into is if for instance the commission decides okay we're going to get all of our regulations done or I'll make up that I'll make up a date in 30 days we want to be prepared we want to be ready to go if that's going to be a longer process we understand that but you know we'll calibrate accordingly right so I think obviously we have you know great communication with everybody who's on this call now and so I think what's going to be critical is just continuing to communicate in terms of progress some of it you'll see obviously when it goes into the central register in terms of where we are but obviously communication will be a big part of planning I think that we've just to put it out there Karen correct me I don't want to create expectation unfairly but September 8th you're planning on um perhaps presenting to us some kind of a timeline that explains where regulatory action whether it's emergency or otherwise could start where maybe some there might be some steps we can take outside of a regulatory mode that might be further you know could be done always by policy and procedure or else adopted later down the road by regulation but some kind of a framework where we can start to give our licensees a little bit more of a timeframe for our work in light of today's discussion am I wrong is that how you said no you're correct I think the critical decision making which will help that put together any perspective timeline is is it's the regulation process because the regulation process has some built in waiting periods for comment etc so having some kind of definitive structure as to what actually a has to be done by regulation or the commission wants to be done by regulation is a critical question and then the question is what regulations need to be in place before the licensee can operate there may be some regulations because I'm looking through the statute right now there's some requirements by statute for regulations and then the question is what is the commission's position on what has to be done before they can operate and what things can potentially come later so those two threshold decisions on what has to be in regulation and when the do these things have to be in regulation that will direct the timeline so we are trying to put together that structure so we can identify for the commission if you if you want X so hypothetically you want everything done by regulation we would then have to draft all the regulations put it then that that extends the timeline but if you want to make some decisions on certain things you want to do by rules instead of regulation that can impact the timeline and potentially shrink the timeline so I can't and that's our our specifics to that so for the eighth what we're expecting is recommendations from the staff as to options around these because time there's a time implication for each decision we make so that's where I say a timeline to come in and what are our choices what are our options why would it be recommended to do a reg versus something else is it required that we do a reg versus something else but always with the understanding if we do it by reg I know this having got a lawyer unless it's an emergency bag you know if we started today the process will be no shorter than nine days and that puts us into November so there's there's a timeline that we're looking for in September 8th we'll start and I hope really produce something that will be helpful to I know for myself if I need I need it commissioners we talked about it yesterday gender setting and now we're hearing it from the licensees that our timeline absolutely informs theirs commissioners it's a chance to just think about what we want from our team and then a hustle I'll turn back to our licensees is there anything else that will help us as commissioners get you know any any anything you've seen in your experience pitfalls and we welcome it Commissioner Skinner do you have any thoughts on this just one this conversation this particular conversation feels a bit premature to me around the timelines given that we haven't heard from the category three potential category three applicants I worry about moving forward with the licensees participating in this call at the very least with respect to mobile wagering when we haven't we haven't heard from from other potential licensees I know we have the roundtable that's that's in the process of being scheduled but I worry about things like you know giving the licensees participating in this call more of a competitive advantage when you know to sort of focus on their launch of the mobile piece without having the opportunity to have the other mobile operators potential mobile operators being put at a level playing field so I can I just think for our blind I thought that we were I today focusing on their standing the timeline for standing up retail okay so if that's okay that's good otherwise I think you're absolutely right now that does of course raise an important policy question that we've touched on in our public meetings but haven't voted on and that would be if we approach parallel tracks retail going up in advance of mobile operations going out or it must there be a simultaneous launch I don't think that's for today's discussion if you feel all indulge me I think that's really at the different conversation commissioners not being disagree and this is important weighing you know weighing in but I think otherwise commissioners can have an absolutely agree with you I think my licensees we're all talking about right now simply standing up retail okay so to the couple of points at north I know we're going over so I want to be careful here the discussion of staggered and this is an important follow-up commissioner because it raises a different issue staggered versus simultaneous in person what if one licensee is able to stand up retail in advance of another and this is assuming just for today's this immediate discussion that stand-up could go on its own you know office the retail in person I'm sorry not stand-up getting a little tired in person could go in advance of mobile just for today's discussion would the three licensees have concerns or actually I shouldn't say three five be concerned if one one location was standing up its retail in advance of the other or should it be a simultaneous launch date which maybe north that's what you're commenting on so I turn to you you said you had a couple of thoughts right so this is one where obviously the commission has got a lot to consider here the thing that I I guess I get a little concerned about from an operator perspective is just the you know how the commission would make decisions on which operator to go to first so for example if they said if the commission were to say hey we believe that the regular regulations will be set as of date x and there are you know three licensees that are ready to go on date x you know how if there's a staggered launch how does the commission make the decision around which one to go to first I think that that's a you know if you ask kind of our preference we would think that there's something along the lines of you know if you have a if we have a date at some point once we can you know reliably say we think that all the regulatory milestones can be met and the operator milestones can be met within that time a simultaneous launch probably makes sense from the commission resource perspective in terms of being able to get everybody all set and then you know know that we're we're able to launch that way I think that realistically there may end up being an initial wave I would assume of people who may be ready and then licensees who may not be ready until a much later date and I think there's obviously the the need at that point to kind of balance out you know is it is it then reasonable to hold up you know if you've got three or four people who are ready to go is it reasonable to hold everyone up because one person is not yet ready and and those are those are obviously the decisions that the commission needs to make but you know I I think as I listen at least to the existing casino licensees that there's an ability to be ready reasonably quickly and and from a pen entertainment perspective I have no issue of saying that we would be ready to go at the same time that Encore and MGM would be ready ready to go that's just kind of where we stand today Michelle Bryan you have your audio up do you have a question I just forgot to turn it off so I don't know what you all said is surprising to me other than you know I just they all launched the brick and mortar obviously staggered and I I take north point too in terms of you've got sort of even within this grouping there's sort of two postures of readiness so that you know to hold up one group that may be ready to go because of just the nature of readiness to me would seem not particularly equitable but yeah and commissioners you know we certainly would not suggest that you know if if licensees are ready to proceed at a time that you're ready to proceed that that anyone would hold it up for any other licensee that may be behind by the same token given the provisions in the law for a temporary location you know we we certainly would look to work with you to make sure that we were ready at whatever date you decide you're going to launch or as close to that as possible so you'd be advocating for one launch date you know whether people could make it or not kind of even if you had five different postures still picking one launch date well I think I think that's what you're hearing from some of the other licensees about when you're ready and you feel comfortable with the regulations in the process you know saying a targeting a launch date for the commission will certainly help all of the licensees kind of back into that launch date and what we need to do to be ready even if that were in a short-term location in our case well we we continue to work on the longer term so I guess Chair I have a question more on the agenda are you talking about launch dates I mean there's launch date in terms of we think everything could be ready by now and then there's you're going to do the ribbon cutting and open the door so are we talking about a simultaneous you know no one's going to go until a date x regardless of ready state that's really important distinction so I think what I'm hearing and everybody can correctly if I'm hearing incorrectly that they're looking to us as a commission to give a date of readiness that we're all set so that we can actually issue their license right and that when we put this in of the agenda we were thinking they're cutting of the ribbon in other words does it have to all be this exact same date I think today the guidance from my perspective is that they are looking for a single launch date from us and then they would act based on that launch date is that fair licensees and might getting it kind of right absolutely if we and obviously we understand that that date can't be established until you further along in the process but if a date was picked and we all knew that that was the date that potentially we could launch whether we meet that because we've filled all the steps or not at least we'd have a level playing field that's fair really helpful and I would just say that I you know I agree with that we you know understand that we're all in a different you know perhaps other than the three casinos who obviously are much closer to being ready to go when this you know when the green light comes on we're all in slightly different positions and you know I don't think anyone expected that anyone was going to have to wait until you know anyone else was was ready once the the commission is ready you know you know from a regulatory perspective to grant the licenses and and give the go ahead to actually start operating commissioners questions we're about at 221 by the month a short change system but this was a very helpful way to close out Karen I feel on that final bullet point Commissioner Skinner how would you like to close out today no I'm good I think this was very informative I enjoyed the participation by our licensees you know I'm I'm pleased to hear that there's consensus among them that one launch date makes sense and given that they're all at different levels of preparedness you know that's that's exactly where I think we need to move as a commission hopefully we'll get there but I do note that it will take us some time and hopefully the licensees respect that and give us you know patience as we move through this process thank you commissioner Maynard I appreciate the licensees coming in today to discuss this very important and difficult topic it's been very informative and I look forward to thinking about and making tough decisions along the front row commissioner thank you commissioner O'Brien mixing up I'm mixing it up there you go now I I didn't think this could be more painful than the COVID roundtables that we had but somehow this feels even harder than those conversations are um but again you know just like the last set around tables very very helpful in terms of us you know getting a getting a framework for how we need to move forward so I appreciate everybody's time and candor thank you and commissioner Hill the great thing about going last is there's nothing else to say except thank you for everybody for everybody coming today and it was very informative but thanks to everybody and we look forward to a continued dialogue thank you everyone I appreciate collaboration the cooperation and other and the insights that you've provided you have a lot to a lot of work ahead of us me understand you probably feel in many ways you've got a lot to do too we'll continue to be the rigorous regulators that we need to be but also good partners to you in the Commonwealth in this effort so thank you so much appreciate the time nice to see so many faces thank you thank you everyone thank you chair thank you commissioners thank you so much have a good day good weekend too bye