# SBCGS Standards Committee - Session Minutes
Date: 2026-10-01
Board: skillgames-2026-10-C
Documents reviewed: SBCGS-C v1.3, Classification Standard
Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.

---

## Mission

Strengthen the SBCGS family as published working drafts, by testing every
requirement against the five parties who have to live with it: the regulator
who would enforce it, the laboratory that would certify against it, the
organization whose name is on the operation, the operator who pays for it,
and the player standing at the device. The committee proposes specific,
section-level changes to the text of the standards. It does not decide
policy, and it does not take a position on whether these products should be
lawful anywhere. Before proposing that something be added, confirm the
standards do not already contain it.

In scope:
  - The text, definitions, thresholds and drafting of SBCGS-C, SBCGS-M and SBCGS-T.
  - The open questions the Institute already identified in the Appendix of each document. Treat these as the priority, because they are the provisions the Institute has itself marked as unevidenced, including the three thresholds in SBCGS-C section 106 and the charitable yield floor in SBCGS-M section 502.
  - Whether a requirement is enforceable by a regulator, testable by a laboratory, dischargeable by a licensed organization, affordable for an operator, and effective for a player.
  - Exposure the standards fail to reach, and provisions that can be satisfied in form while defeated in substance.
  - Consistency across the three documents. The skill measures are defined in SBCGS-C section 106, specified in SBCGS-T Part 810 and disclosed under SBCGS-M section 304. Charitable yield is defined in SBCGS-C section 107, floored in SBCGS-M section 502 and computed in SBCGS-T section 843. A suggestion that moves one of these must say what it does to the others.
  - Whether a suggestion that adds or changes a citation rests on a source already held in research/SOURCES.md. Where it does not, the suggestion must say so plainly rather than assert the citation. Three basis notes in version 1.0 cited the wrong provision because they were written from search results instead of source text.

Out of scope:
  - Whether skill-based products should be lawful in any jurisdiction. The Institute is jurisdiction-neutral and advocacy for or against the industry must not enter the drafting.
  - Publication, formatting, filenames, versioning and the site register. Those belong to the build and to the iegm-site session.
  - Commercial matters, including assessment pricing, certification fees, and business development for the Institute.
  - Drafting a new document or a new layer in the family. Recommending that one be considered is in scope, and SBCGS-C Appendix C already asks whether mobile delivery needs its own treatment, but writing it is a separate commission.

This board succeeds when:
  - A passed suggestion names the section it changes, correctly, and states what should change and why. A citation to a subsection that does not exist is a failed suggestion however good the idea.
  - The pass list can be applied to the markdown source by the standards session without further interpretation.
  - Suggestions differ by seat rather than converging, so that the record shows a genuine disagreement where one exists.
  - At least one passed suggestion engages a threshold the Institute flagged as unevidenced, rather than only the drafting that was easiest to improve.

---

## 1. Review Phase

### Suggestions by Member

**The Regulator** (ollama:qwen3:14b)
- S001: Amend SBCGS-C § 106(g)(1) to specify that the skill realization rate must be determined for each product and each configuration of that product, and that the rate must be calculated using data from at least 100 unique players over a period of 90 days.
  *Rationale: The current threshold for the skill realization rate (0.20) is based on data that is not publicly available, and the current wording does not ensure that the rate is measured in a way that reflects actual player behavior.*
  *Evidence: Appendix C of SBCGS-C explicitly invites comment on the skill realization rate and notes that no public data exists on this measure. ---*
- S002: Revise SBCGS-C § 104(h)(3) to clarify that a product is not excluded from coverage simply because a skill element is disabled in a particular configuration, and that the presence of a skill element in any configuration must be disclosed in the classification record.
  *Rationale: The current language may allow operators to disable skill elements to avoid compliance with skill representation requirements, which undermines the intent of the standard and creates regulatory gaps.*
  *Evidence: Appendix A of SBCGS-C includes an example where a skill feature is disabled in a deployed configuration, and the note indicates that the disabled configuration is still considered a covered product under the standard. ---*
- S003: Update SBCGS-C § 107(d)(1)(iii) to require that the general operating costs of a licensed organization be included in the calculation of charitable yield unless explicitly excluded by applicable law, and that such exclusion must be disclosed in the classification record.
  *Rationale: The current language may exclude important charitable contributions from the calculation of charitable yield, potentially misleading players about the actual impact of their play.*
  *Evidence: Appendix C of SBCGS-C invites comment on the treatment of organization operating costs, noting that for a veterans post whose building is its mission, the exclusion may be incorrect.*

**The Test Laboratory** (ollama:qwen3:14b)
- S004: Amend SBCGS-C § 106(g)(1) to require a skill realization rate of at least 0.15 instead of 0.20 for a product to be classified as a *demonstrated skill product*.
  *Rationale: A lower threshold would allow more products to demonstrate meaningful player engagement with skill elements, ensuring that the classification better reflects actual player behavior and does not exclude legitimate skill-based products due to overly stringent requirements.*
  *Evidence: Appendix C, SBCGS-C v1.3, explicitly invites comment on the skill realization rate threshold, noting that no public data exists to support the current value of 0.20. This suggests that the threshold may not be evidence-based and could be adjusted to better reflect real-world player behavior. ---*
- S005: Add a requirement in SBCGS-T Part 810 to mandate that all testing laboratories must document and report the *exact configuration* of the device under test, including firmware versions, hardware revisions, and any software patches applied, in the certification report.
  *Rationale: Without precise configuration details, laboratories may produce inconsistent or non-reproducible test results, undermining the reliability and enforceability of certification. This would ensure that any future testing against the same device can be conducted accurately and consistently.*
  *Evidence: SBCGS-T § 881 requires that the classification determination be made on the basis of a report from an independent testing laboratory. However, it does not specify the level of detail required for device configuration, which may lead to ambiguity and variability in testing procedures. ---*
- S006: In SBCGS-T Part 812(c), require that all simulation requirements be tested using open-source or publicly available tools for outcome randomness, ensuring that simulation outputs are replicable and verifiable by third parties.
  *Rationale: This would increase the transparency and auditability of simulation-based tests, reducing the risk of proprietary tools being used to obscure or manipulate test results. It would also lower the cost of compliance by allowing smaller laboratories to use standardized tools.*
  *Evidence: The Nevada Gaming Control Board's proposed revisions to technical standards (September 2026) emphasize the need for modernization and the use of standardized, open-source tools in testing procedures, which aligns with this suggestion.*

**The Licensed Organization** (ollama:qwen3:14b)
- S007: Insert the following text into SBCGS-M § 502(b): "Licensed organizations with annual gross gaming revenue below $500,000 may rely on the covered operator to provide a quarterly report that includes the gross gaming revenue, amounts deducted, and amounts applied to charitable purposes, in a format that facilitates the organization’s compliance with this section."
  *Rationale: This addresses the operational burden on small, volunteer-run organizations by allowing them to rely on the operator to provide necessary financial data, reducing the administrative and compliance workload.*
  *Evidence: [iegm.org](https://iegm.org/standards/sbcgs-m-v1.2.html?utm_source=openai) – The standard mandates that licensed organizations compute and disclose charitable yield, which can be difficult for small organizations without dedicated compliance staff.*
- S008: Insert the following text into SBCGS-M § 202(d): "Volunteer-run licensed organizations may discharge the duties under this section through a designated volunteer who has received training on the requirements of the SBCGS family and is responsible for overseeing compliance with the internal controls outlined in this standard."
  *Rationale: This acknowledges the reality of small, volunteer-run organizations and provides a mechanism for them to meet compliance requirements through trained volunteers.*
  *Evidence: The duties in section 202(d) are not currently tailored to the capabilities of small, volunteer-run organizations, as noted in the recent external intel search.*
- S009: Insert the following text into SBCGS-M § 502: "Licensed organizations with annual gross gaming revenue below $500,000 are exempt from the 25% charitable yield floor requirement, provided that the organization maintains a record of the charitable yield percentage for each quarter and demonstrates that the yield is consistent with the charitable purpose of the organization."
  *Rationale: This recognizes the practical challenges faced by small organizations and provides flexibility in meeting the charitable yield floor while maintaining transparency and accountability.*
  *Evidence: The 25% charitable yield floor is a challenge for small organizations, as noted in the recent external intel search and the proposed text for SBCGS-C v1.3.*

**The Player Advocate** (ollama:qwen3.5:9b)
- S010: In § 106(d), replace the phrase "skill influence range is the quantity a player is entitled to know" with "skill influence range is the quantity that must be disclosed on or at the covered device in the area immediately adjacent to any skill element description, in language readable by a person standing five feet from the device."
  *Rationale: A requirement that a number be "entitled to know" but not stated where the player is standing fails the test of whether protection can be evaded by walking to the next venue or failing to read. The standard must force the disclosure to reach the anonymous, distracted person with cash in hand at the moment they commit consideration. Without a mandated physical location and legibility constraint, an operator could satisfy the classification requirement by placing the data in a classified document that is never seen, rendering the player protection illusory while technically satisfying the standard.*
  *Evidence: SBCGS-C § 106(d) Note states "The skill influence range is the quantity a player is entitled to know..." but provides no enforcement mechanism for visibility; Ohio Casino Control Commission fines for advertising violations (Intel: January 6, 2023) highlight that lack of clear responsible gaming messages and helpline numbers at the point of play constitutes a failure, suggesting mere entitlement without physical disclosure is insufficient.*
- S011: In § 104(d)(3), add the condition "or where the maximum award obtainable from a single play exceeds the greater of ten dollars in wholesale value or the value of a single play" to the list of circumstances under which Gate 2 is not satisfied, explicitly ensuring that any device paying above this threshold (regardless of whether it pays cash or merchandise) is treated as covered.
  *Rationale: The current text excludes devices where the award does not exceed ten dollars or the play value. However, if a device pays $15 in merchandise but requires a skill element to reach that award, the "amusement exclusion" logic collapses. If we do not explicitly ensure that high-value awards (even non-cash) trigger coverage when paired with skill representations, operators can evade the standards by offering large prizes as merchandise while claiming they are "amusement devices" because they don't pay cash. This allows a player to be exposed to significant loss on a device that looks like an amusement machine but functions like a gambling device, defeating the practical utility of the coverage test.*
  *Evidence: SBCGS-C § 104(d)(3) currently limits the exclusion to awards not exceeding ten dollars; Intel finding on Ohio fines (January 6, 2023) shows that excluding cash products or limiting prize value is a common regulatory boundary that this standard must not allow operators to bypass by switching the form of the award if the exposure remains high.*
- S012: In § 107(d)(1)(iii), amend the exclusion for "general operating costs" to require: "except where applicable law expressly treats such costs as a charitable purpose and the treatment is disclosed under SBCGS-M § 502, or where the licensed organization is a veterans post whose premises constitute its mission and the entire rental value of the premises is applied to that mission."
  *Rationale: The current text excludes general operating costs broadly. For a veterans post (a primary host location mentioned in the Prefatory Note), the building *is* the mission; excluding the cost of maintaining that building from the "charitable yield" calculation falsely inflates the charitable share reported to the player. A player at a Veterans Hall assumes every dollar supports the veterans' cause, but if the standard allows the organization to claim the building's mortgage is an "operating cost" rather than a charitable application, the disclosure misleads the player about where their money actually goes. This creates a scenario where a requirement (disclose yield) is technically satisfied by reporting a high percentage that does not reflect reality, which is the specific failure mode of being "technically satisfied and practically useless."*
  *Evidence: SBCGS-C § 107(d)(1)(iii) excludes general operating costs including premises; Prefatory Note lists "veterans post" as among the largest hosts; Intel finding on PointsBet penalties (November 9, 2023) underscores that failing to appropriately assist or disclose the true nature of financial exposure harms vulnerable individuals.*

**The Operator** (ollama:qwen3:14b)
- S013: Amend SBCGS-C § 106(g)(1) to increase the skill realization rate threshold from 0.20 to 0.30.
  *Rationale: The current threshold of 0.20 may be too low to ensure that a meaningful proportion of players actually engage with skill elements, which could lead to misclassification of products as "demonstrated skill" when the skill element is rarely used in practice.*
  *Evidence: Appendix C of SBCGS-C explicitly invites comment on the skill realization rate threshold and notes that no public data exists on this measure, highlighting the need for a threshold that better reflects real-world player behavior. ---*
- S014: Clarify in SBCGS-C § 106(e)(4) that the "skill time cost ratio" must be measured using the median time for a proficient player, as defined by the testing laboratory in SBCGS-T § 881.
  *Rationale: The current wording is ambiguous and could be interpreted differently by inspectors or laboratories, leading to inconsistent enforcement and compliance costs. A clear definition ensures uniformity across the industry.*
  *Evidence: SBCGS-C § 106(e)(4) currently references the skill time cost ratio without defining "proficient player," creating ambiguity. SBCGS-T § 881 already includes procedures for defining player proficiency, which should be referenced for consistency. ---*
- S015: In SBCGS-C § 107(d)(1)(iii), explicitly exclude from charitable yield any amounts applied to the general operating costs of a licensed organization, regardless of whether applicable law treats them as charitable.
  *Rationale: The current wording allows for exceptions based on applicable law, which creates ambiguity and potential for misinterpretation. A clear exclusion ensures that only amounts directly applied to charitable purposes are counted in the charitable yield.*
  *Evidence: SBCGS-C § 107(d)(1)(iii) already states that general operating costs are excluded unless applicable law explicitly treats them as charitable and the treatment is disclosed. However, the wording is not unambiguous and may allow for inconsistent application.*

---

## 2. Pool Phase

**Leader actions:**
- 15 suggestion(s) retained as submitted

**Final pool: 15 suggestions (from 15 submitted; 0 merged)**

- S001: Amend SBCGS-C § 106(g)(1) to specify that the skill realization rate must be determined for each product and each configuration of that product, and that the rate must be calculated using data from at least 100 unique players over a period of 90 days.
- S002: Revise SBCGS-C § 104(h)(3) to clarify that a product is not excluded from coverage simply because a skill element is disabled in a particular configuration, and that the presence of a skill element in any configuration must be disclosed in the classification record.
- S003: Update SBCGS-C § 107(d)(1)(iii) to require that the general operating costs of a licensed organization be included in the calculation of charitable yield unless explicitly excluded by applicable law, and that such exclusion must be disclosed in the classification record.
- S004: Amend SBCGS-C § 106(g)(1) to require a skill realization rate of at least 0.15 instead of 0.20 for a product to be classified as a *demonstrated skill product*.
- S005: Add a requirement in SBCGS-T Part 810 to mandate that all testing laboratories must document and report the *exact configuration* of the device under test, including firmware versions, hardware revisions, and any software patches applied, in the certification report.
- S006: In SBCGS-T Part 812(c), require that all simulation requirements be tested using open-source or publicly available tools for outcome randomness, ensuring that simulation outputs are replicable and verifiable by third parties.
- S007: Insert the following text into SBCGS-M § 502(b): "Licensed organizations with annual gross gaming revenue below $500,000 may rely on the covered operator to provide a quarterly report that includes the gross gaming revenue, amounts deducted, and amounts applied to charitable purposes, in a format that facilitates the organization’s compliance with this section."
- S008: Insert the following text into SBCGS-M § 202(d): "Volunteer-run licensed organizations may discharge the duties under this section through a designated volunteer who has received training on the requirements of the SBCGS family and is responsible for overseeing compliance with the internal controls outlined in this standard."
- S009: Insert the following text into SBCGS-M § 502: "Licensed organizations with annual gross gaming revenue below $500,000 are exempt from the 25% charitable yield floor requirement, provided that the organization maintains a record of the charitable yield percentage for each quarter and demonstrates that the yield is consistent with the charitable purpose of the organization."
- S010: In § 106(d), replace the phrase "skill influence range is the quantity a player is entitled to know" with "skill influence range is the quantity that must be disclosed on or at the covered device in the area immediately adjacent to any skill element description, in language readable by a person standing five feet from the device."
- S011: In § 104(d)(3), add the condition "or where the maximum award obtainable from a single play exceeds the greater of ten dollars in wholesale value or the value of a single play" to the list of circumstances under which Gate 2 is not satisfied, explicitly ensuring that any device paying above this threshold (regardless of whether it pays cash or merchandise) is treated as covered.
- S012: In § 107(d)(1)(iii), amend the exclusion for "general operating costs" to require: "except where applicable law expressly treats such costs as a charitable purpose and the treatment is disclosed under SBCGS-M § 502, or where the licensed organization is a veterans post whose premises constitute its mission and the entire rental value of the premises is applied to that mission."
- S013: Amend SBCGS-C § 106(g)(1) to increase the skill realization rate threshold from 0.20 to 0.30.
- S014: Clarify in SBCGS-C § 106(e)(4) that the "skill time cost ratio" must be measured using the median time for a proficient player, as defined by the testing laboratory in SBCGS-T § 881.
- S015: In SBCGS-C § 107(d)(1)(iii), explicitly exclude from charitable yield any amounts applied to the general operating costs of a licensed organization, regardless of whether applicable law treats them as charitable.

---

## 3. Vote Phase


*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*

### Votes on S001: Amend SBCGS-C § 106(g)(1) to specify that the skill realization rate must be determined for each product and each configuration of that product, and that the rate must be calculated using data from at least 100 unique players over a period of 90 days.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Test Laboratory | Marcus Brennan, SA | YES | This suggestion provides a clear, testable method for determining the skill realization rate by specifying the number of players, the duration of data collection, and the requirement to measure it per product and configuration. This would ensure consistency across laboratories and allow for reproducible results, fulfilling the requirement for enforceability and testability. |
| The Licensed Organization | Eileen Cortland, SA | YES | This amendment enhances the enforceability and testability of the skill realization rate requirement by ensuring that it is measured across a representative sample of players and configurations, which aligns with the standard’s goal of protecting players and ensuring compliance. |
| The Player Advocate | Theodore Gilliam, SA | NO | Requiring data from 100 unique players over 90 days for a device that cannot identify the player fails to protect the anonymous individual standing at the machine right now, as the sample window allows an operator to harvest data only after a player has already lost their entire bankroll or left distressed. |
| The Operator | Danny Sokolov, SA | YES | This amendment clarifies the measurement of the skill realization rate in a way that is both enforceable and reflective of actual player behavior, reducing ambiguity that could lead to inconsistent compliance and enforcement. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED**

### Votes on S002: Revise SBCGS-C § 104(h)(3) to clarify that a product is not excluded from coverage simply because a skill element is disabled in a particular configuration, and that the presence of a skill element in any configuration must be disclosed in the classification record.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Test Laboratory | Marcus Brennan, SA | YES | This suggestion clarifies that disabling a skill element in a configuration does not remove the product from coverage and that skill elements must be disclosed in the classification record. This prevents potential regulatory gaps and ensures transparency, making the requirement enforceable and observable in practice. |
| The Licensed Organization | Eileen Cortland, SA | YES | This revision prevents operators from circumventing skill representation requirements by disabling skill elements in certain configurations, which is crucial for maintaining the integrity of the classification system and ensuring that all configurations are subject to the same standards. |
| The Player Advocate | Theodore Gilliam, SA | YES | Clarifying that disabling a skill element does not remove coverage closes the loophole where operators strip away skill features in specific configurations to evade the standards while still using the same chassis and branding to lure players in. |
| The Operator | Danny Sokolov, SA | YES | This revision prevents operators from circumventing skill representation requirements by disabling skill elements in certain configurations, aligning the standard with its intent and reducing regulatory loopholes. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S003: Update SBCGS-C § 107(d)(1)(iii) to require that the general operating costs of a licensed organization be included in the calculation of charitable yield unless explicitly excluded by applicable law, and that such exclusion must be disclosed in the classification record.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | While the suggestion aims to improve transparency in the charitable yield calculation, the wording is not sufficiently precise for a testable requirement. The phrase “general operating costs” is too broad and may not be objectively measured or verified. A more specific definition or method for inclusion/exclusion would be necessary for this to be testable. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | While the suggestion aims to improve transparency in the charitable yield calculation, it raises questions about the consistency with other sections of the standard, particularly SBCGS-M § 502, and the potential impact on the definition of charitable yield in SBCGS-C § 107. Further clarification on how this change interacts with existing provisions is needed before a definitive vote can be cast. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | While including operating costs seems fair, if applicable law treats them as charitable, forcing their inclusion creates a conflict between the standard and the jurisdiction's tax code that an anonymous player cannot navigate before handing over cash, leaving the disclosure technically true but practically misleading. |
| The Operator | Danny Sokolov, SA | ABSTAIN | While the intent to include general operating costs in charitable yield calculations is well-meaning, the current wording in SBCGS-C § 107(d)(1)(iii) already allows for exceptions based on applicable law. Without a clear and unambiguous requirement to include these costs, the suggestion may not be necessary at this time, and further clarification may be required before making a definitive recommendation. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 0 YES / 0 NO / 5 ABSTAIN → 0% (threshold: 51%) → FAILED**

### Votes on S004: Amend SBCGS-C § 106(g)(1) to require a skill realization rate of at least 0.15 instead of 0.20 for a product to be classified as a *demonstrated skill product*.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | NO | Lowering the skill realization rate threshold from 0.20 to 0.15 introduces a vague standard without defining what constitutes "meaningful player engagement." It lacks enforceability because it does not specify how engagement is measured or what constitutes a "legitimate skill-based product." The obligation is not clearly allocated to any named entity, and compliance cannot be determined from existing records. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | NO | Lowering the threshold may dilute the standard’s effectiveness in ensuring that products meaningfully engage players with skill elements, potentially leading to misclassification. |
| The Player Advocate | Theodore Gilliam, SA | NO | Lowering the skill realization rate threshold from 0.20 to 0.15 merely allows more poorly performing "skill" devices to masquerade as such, failing the test of whether a protection can be evaded by walking to a device where the player has almost no chance to demonstrate actual skill before losing everything. |
| The Operator | Danny Sokolov, SA | NO | Lowering the threshold to 0.15 may introduce ambiguity and inconsistency in how skill realization is measured. It may also lead to more products being classified as *demonstrated skill products* without sufficient evidence of meaningful player engagement, potentially increasing compliance costs and regulatory challenges. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 0 YES / 4 NO / 1 ABSTAIN → 0% (threshold: 51%) → FAILED**

### Votes on S005: Add a requirement in SBCGS-T Part 810 to mandate that all testing laboratories must document and report the *exact configuration* of the device under test, including firmware versions, hardware revisions, and any software patches applied, in the certification report.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Requiring laboratories to document the exact configuration of the device under test, including firmware, hardware, and software patches, ensures that test results are replicable and enforceable. This information can be verified from certification reports, making compliance clear and actionable for regulators. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | Requiring detailed device configuration documentation enhances the reliability and consistency of certification reports, supporting enforceability and transparency. |
| The Player Advocate | Theodore Gilliam, SA | YES | Mandating that laboratories report exact firmware and hardware versions prevents certification fraud where a lab certifies a safe configuration but the operator ships a patched, exploitable version, ensuring the protection applies to the specific metal box the anonymous player is holding. |
| The Operator | Danny Sokolov, SA | YES | Requiring precise documentation of device configuration details ensures that test results are reproducible and verifiable, improving the reliability of certification and reducing the risk of inconsistent testing outcomes. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S006: In SBCGS-T Part 812(c), require that all simulation requirements be tested using open-source or publicly available tools for outcome randomness, ensuring that simulation outputs are replicable and verifiable by third parties.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Mandating the use of open-source or publicly available tools for outcome randomness testing increases transparency and allows third-party verification. This is enforceable by requiring laboratories to document the tools used, which can be reviewed and audited by regulators. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | Mandating the use of open-source tools improves transparency, reduces compliance costs, and ensures the replicability of simulation-based test results. |
| The Player Advocate | Theodore Gilliam, SA | NO | Requiring open-source tools for randomness simulation ignores the reality that many jurisdictions mandate proprietary RNG certifications; forcing open-source tools would make compliance impossible for licensed organizations in those regions, rendering the standard unenforceable for a significant portion of the industry. |
| The Operator | Danny Sokolov, SA | YES | Requiring the use of open-source or publicly available tools for outcome randomness increases transparency and reduces the risk of proprietary tools being used to obscure test results. It also lowers compliance costs for smaller laboratories, which is a practical benefit for the industry. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED**

### Votes on S007: Insert the following text into SBCGS-M § 502(b): "Licensed organizations with annual gross gaming revenue below $500,000 may rely on the covered operator to provide a quarterly report that includes the gross gaming revenue, amounts deducted, and amounts applied to charitable purposes, in a format that facilitates the organization’s compliance with this section."

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Allowing small licensed organizations to rely on the operator to provide quarterly reports simplifies compliance and reduces administrative burdens. This is enforceable by requiring the operator to maintain and provide the necessary data, which can be verified by regulators. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | The suggestion introduces a mechanism for small organizations to rely on the operator for financial data, but it does not address whether the data can be verified or tested, which is essential for regulatory enforcement. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | YES | Allowing small organizations to rely on operator-provided revenue reports addresses the reality that a volunteer treasurer cannot possibly verify financial data without it being handed to them, ensuring the player's contribution is accounted for even in a resource-starved environment. |
| The Operator | Danny Sokolov, SA | YES | This addition provides a reasonable accommodation for small, volunteer-run organizations by allowing them to rely on the operator to provide necessary financial data, which reduces administrative burdens without compromising compliance. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 0 NO / 2 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S008: Insert the following text into SBCGS-M § 202(d): "Volunteer-run licensed organizations may discharge the duties under this section through a designated volunteer who has received training on the requirements of the SBCGS family and is responsible for overseeing compliance with the internal controls outlined in this standard."

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Allowing volunteer-run organizations to discharge compliance duties through a trained volunteer is practical and enforceable. The volunteer must be trained and accountable, and this can be verified through training records and oversight by the organization. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | While the suggestion acknowledges the reality of volunteer-run organizations, it does not specify how the training or oversight of the volunteer would be tested or verified, which could lead to inconsistent compliance. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | NO | Requiring a designated volunteer with specific training creates an administrative barrier that small, anonymous operators will bypass by simply failing to designate anyone, effectively exempting them from compliance while still offering the device to players who cannot read the fine print about who is responsible for oversight. |
| The Operator | Danny Sokolov, SA | YES | This change acknowledges the operational reality of volunteer-run organizations and provides a feasible mechanism for them to meet compliance requirements through trained volunteers, ensuring that internal controls are maintained. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 2 YES / 1 NO / 2 ABSTAIN → 67% (threshold: 51%) → PASSED**

### Votes on S009: Insert the following text into SBCGS-M § 502: "Licensed organizations with annual gross gaming revenue below $500,000 are exempt from the 25% charitable yield floor requirement, provided that the organization maintains a record of the charitable yield percentage for each quarter and demonstrates that the yield is consistent with the charitable purpose of the organization."

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | NO | Exempting small organizations from the 25% charitable yield floor creates a loophole that may undermine the standard’s consistency and transparency. The exemption is not enforceable in a way that ensures all players receive the same level of disclosure, and it introduces a disparity in compliance requirements between small and large organizations. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | The suggestion introduces an exemption for small organizations, but it does not specify how the consistency of charitable yield with the organization’s mission would be measured or verified, which is critical for regulatory compliance. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | Exempting low-revenue organizations from the 25% floor based on revenue alone ignores that a player standing at a charity event booth does not know that organization's annual revenue; without a clear disclosure of *why* they are exempt, the player assumes their money is fully supporting the cause when it may not be, defeating the purpose of the yield disclosure. |
| The Operator | Danny Sokolov, SA | YES | Exempting small organizations from the 25% charitable yield floor, while requiring them to maintain records and demonstrate consistency with their charitable purpose, provides flexibility without undermining transparency or accountability. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 1 YES / 1 NO / 3 ABSTAIN → 50% (threshold: 51%) → FAILED**

### Votes on S010: In § 106(d), replace the phrase "skill influence range is the quantity a player is entitled to know" with "skill influence range is the quantity that must be disclosed on or at the covered device in the area immediately adjacent to any skill element description, in language readable by a person standing five feet from the device."

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Requiring the skill influence range to be disclosed in a specific location on the device, readable from five feet away, ensures that players receive the information at the moment of play. This is enforceable by requiring the disclosure to be physically present on the device and verifiable through on-site inspections. |
| The Test Laboratory | Marcus Brennan, SA | YES | Requiring the skill influence range to be disclosed in a specific, readable location adjacent to the skill element ensures that the information is accessible to players in real-time, making the requirement enforceable and testable. |
| The Licensed Organization | Eileen Cortland, SA | YES | Specifying a physical location and legibility requirement ensures that players can access the skill influence range information at the moment of play, making the standard practically enforceable. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | This change ensures that the skill influence range is not only disclosed but is physically located in a place where the player can easily see it, preventing operators from hiding critical information in documents that are never seen. It aligns the standard with the practical need to protect players at the moment of decision. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S011: In § 104(d)(3), add the condition "or where the maximum award obtainable from a single play exceeds the greater of ten dollars in wholesale value or the value of a single play" to the list of circumstances under which Gate 2 is not satisfied, explicitly ensuring that any device paying above this threshold (regardless of whether it pays cash or merchandise) is treated as covered.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Adding a threshold for high-value awards, regardless of whether they are paid in cash or merchandise, ensures that all high-value skill-based devices are subject to coverage. This is enforceable by requiring laboratories and operators to document awards and their values, which can be reviewed by regulators. |
| The Test Laboratory | Marcus Brennan, SA | YES | Adding a condition that high-value awards trigger coverage regardless of whether they are cash or merchandise ensures that the standard is applied consistently and prevents operators from evading coverage through non-cash prize structures. |
| The Licensed Organization | Eileen Cortland, SA | YES | This amendment closes a regulatory gap by ensuring that high-value awards, whether cash or merchandise, are treated as covered devices when paired with skill elements, preventing misclassification. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | This amendment closes a critical loophole by ensuring that any device paying awards above the specified threshold (whether in cash or merchandise) is treated as covered. It prevents operators from misclassifying high-value devices as "amusement" when they function as gambling devices, protecting players from hidden risks. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S012: In § 107(d)(1)(iii), amend the exclusion for "general operating costs" to require: "except where applicable law expressly treats such costs as a charitable purpose and the treatment is disclosed under SBCGS-M § 502, or where the licensed organization is a veterans post whose premises constitute its mission and the entire rental value of the premises is applied to that mission."

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | The amendment ensures that veterans posts are treated consistently, with the rental value of their premises counted as a charitable application. This is enforceable by requiring disclosure under SBCGS-M § 502 and verifying that the treatment is explicitly stated. |
| The Test Laboratory | Marcus Brennan, SA | YES | The amendment ensures that general operating costs are excluded from charitable yield unless explicitly treated as charitable by law and disclosed, preventing misleading reporting and aligning the standard with the actual use of funds. |
| The Licensed Organization | Eileen Cortland, SA | YES | This clarification ensures that for veterans posts, the rental value of premises is treated as part of the charitable yield, preventing misleading disclosures to players. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | This amendment addresses a practical misalignment in how charitable yield is calculated for veterans posts, where the building itself is the mission. By explicitly treating the rental value of the premises as charitable, it ensures that the disclosure accurately reflects where player money goes, preventing misleading claims about charitable yield. S013: [Not voted on – authored by me] S014: [Not voted on – authored by me] S015: [Not voted on – authored by me] |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED**

### Votes on S013: Amend SBCGS-C § 106(g)(1) to increase the skill realization rate threshold from 0.20 to 0.30.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | NO | Raising the skill realization rate threshold to 0.30 introduces an arbitrary standard without defining what constitutes a "meaningful proportion" of players. It lacks enforceability because it does not specify how the threshold is measured or who is responsible for ensuring compliance, making it impractical for regulators to enforce consistently. |
| The Test Laboratory | Marcus Brennan, SA | NO | Increasing the skill realization rate threshold to 0.30 may be impractical to test and enforce, as it could be difficult to determine whether a product meets this threshold based on player behavior. |
| The Licensed Organization | Eileen Cortland, SA | NO | Increasing the threshold may reduce the number of products classified as "demonstrated skill," potentially limiting player engagement with skill-based elements unnecessarily. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | Increasing the skill realization rate threshold to 0.30 is a purely regulatory tightening that does not improve the moment-of-commitment protection for the anonymous player and may simply cause operators to redesign devices to artificially inflate the metric rather than genuinely enhancing skill engagement. |
| The Operator | Danny Sokolov, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 0 YES / 3 NO / 2 ABSTAIN → 0% (threshold: 51%) → FAILED**

### Votes on S014: Clarify in SBCGS-C § 106(e)(4) that the "skill time cost ratio" must be measured using the median time for a proficient player, as defined by the testing laboratory in SBCGS-T § 881.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Clarifying that the "skill time cost ratio" must be measured using the median time for a proficient player ensures consistency across laboratories. This is enforceable by requiring laboratories to define and document the proficient player standard, which can be reviewed by regulators. |
| The Test Laboratory | Marcus Brennan, SA | YES | Defining the "skill time cost ratio" using the median time for a proficient player ensures a consistent and testable metric that can be measured uniformly across laboratories. |
| The Licensed Organization | Eileen Cortland, SA | YES | Clarifying that the skill time cost ratio is measured using the median time for a proficient player ensures consistent enforcement and reduces ambiguity in compliance. |
| The Player Advocate | Theodore Gilliam, SA | NO | Defining the skill time cost ratio by a median proficient player defined by a lab introduces an unenforceable standard for an anonymous player who is likely amateur, distracted, and playing under stress, making the protection illusory if the lab's definition doesn't match the reality of the person standing at the device. |
| The Operator | Danny Sokolov, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED**

### Votes on S015: In SBCGS-C § 107(d)(1)(iii), explicitly exclude from charitable yield any amounts applied to the general operating costs of a licensed organization, regardless of whether applicable law treats them as charitable.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | NO | Explicitly excluding all general operating costs from charitable yield, regardless of applicable law, removes flexibility and may conflict with state-specific legal interpretations. It also fails to account for cases where operating costs may be considered charitable under local law. This creates a rigid standard that may not align with the actual practices of licensed organizations and could lead to regulatory conflicts. |
| The Test Laboratory | Marcus Brennan, SA | NO | Explicitly excluding general operating costs regardless of legal treatment creates ambiguity and could prevent legitimate charitable uses of funds from being counted, undermining the transparency of charitable yield. |
| The Licensed Organization | Eileen Cortland, SA | NO | This suggestion overly restricts the charitable yield calculation without considering the possibility that applicable law may legitimately treat operating costs as charitable, potentially undermining the flexibility and intent of the standard. |
| The Player Advocate | Theodore Gilliam, SA | NO | Explicitly excluding all operating costs from charitable yield regardless of law creates a rigid rule that may conflict with local tax laws, leading to situations where an operator must choose between following the standard or complying with their jurisdiction, potentially causing them to stop offering skill-based games entirely rather than protecting the player. |
| The Operator | Danny Sokolov, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |

*Note: this committee is composed of AI agents. Member names are seat names, not people. Each member's model is listed in the review section.*


**Result: 0 YES / 4 NO / 1 ABSTAIN → 0% (threshold: 51%) → FAILED**

## 4. Pass List

| ID | Suggestion | Yes | No | Abstain | % | Result |
|----|-----------|-----|----|---------|---|--------|
| S001 | Amend SBCGS-C § 106(g)(1) to specify that the skill realization rate must be determined for each product and each configuration of that product, and that the rate must be calculated using data from at least 100 unique players over a period of 90 days. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S002 | Revise SBCGS-C § 104(h)(3) to clarify that a product is not excluded from coverage simply because a skill element is disabled in a particular configuration, and that the presence of a skill element in any configuration must be disclosed in the classification record. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S003 | Update SBCGS-C § 107(d)(1)(iii) to require that the general operating costs of a licensed organization be included in the calculation of charitable yield unless explicitly excluded by applicable law, and that such exclusion must be disclosed in the classification record. | 0 | 0 | 5 | 0% | ✗ FAILED |
| S004 | Amend SBCGS-C § 106(g)(1) to require a skill realization rate of at least 0.15 instead of 0.20 for a product to be classified as a *demonstrated skill product*. | 0 | 4 | 1 | 0% | ✗ FAILED |
| S005 | Add a requirement in SBCGS-T Part 810 to mandate that all testing laboratories must document and report the *exact configuration* of the device under test, including firmware versions, hardware revisions, and any software patches applied, in the certification report. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S006 | In SBCGS-T Part 812(c), require that all simulation requirements be tested using open-source or publicly available tools for outcome randomness, ensuring that simulation outputs are replicable and verifiable by third parties. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S007 | Insert the following text into SBCGS-M § 502(b): "Licensed organizations with annual gross gaming revenue below $500,000 may rely on the covered operator to provide a quarterly report that includes the gross gaming revenue, amounts deducted, and amounts applied to charitable purposes, in a format that facilitates the organization’s compliance with this section." | 3 | 0 | 2 | 100% | ✓ PASSED |
| S008 | Insert the following text into SBCGS-M § 202(d): "Volunteer-run licensed organizations may discharge the duties under this section through a designated volunteer who has received training on the requirements of the SBCGS family and is responsible for overseeing compliance with the internal controls outlined in this standard." | 2 | 1 | 2 | 67% | ✓ PASSED |
| S009 | Insert the following text into SBCGS-M § 502: "Licensed organizations with annual gross gaming revenue below $500,000 are exempt from the 25% charitable yield floor requirement, provided that the organization maintains a record of the charitable yield percentage for each quarter and demonstrates that the yield is consistent with the charitable purpose of the organization." | 1 | 1 | 3 | 50% | ✗ FAILED (tie) |
| S010 | In § 106(d), replace the phrase "skill influence range is the quantity a player is entitled to know" with "skill influence range is the quantity that must be disclosed on or at the covered device in the area immediately adjacent to any skill element description, in language readable by a person standing five feet from the device." | 4 | 0 | 1 | 100% | ✓ PASSED |
| S011 | In § 104(d)(3), add the condition "or where the maximum award obtainable from a single play exceeds the greater of ten dollars in wholesale value or the value of a single play" to the list of circumstances under which Gate 2 is not satisfied, explicitly ensuring that any device paying above this threshold (regardless of whether it pays cash or merchandise) is treated as covered. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S012 | In § 107(d)(1)(iii), amend the exclusion for "general operating costs" to require: "except where applicable law expressly treats such costs as a charitable purpose and the treatment is disclosed under SBCGS-M § 502, or where the licensed organization is a veterans post whose premises constitute its mission and the entire rental value of the premises is applied to that mission." | 4 | 0 | 1 | 100% | ✓ PASSED |
| S013 | Amend SBCGS-C § 106(g)(1) to increase the skill realization rate threshold from 0.20 to 0.30. | 0 | 3 | 2 | 0% | ✗ FAILED |
| S014 | Clarify in SBCGS-C § 106(e)(4) that the "skill time cost ratio" must be measured using the median time for a proficient player, as defined by the testing laboratory in SBCGS-T § 881. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S015 | In SBCGS-C § 107(d)(1)(iii), explicitly exclude from charitable yield any amounts applied to the general operating costs of a licensed organization, regardless of whether applicable law treats them as charitable. | 0 | 4 | 1 | 0% | ✗ FAILED |

**Total: 15 suggestions reviewed. 10 passed. 5 failed.**

**Tied votes:** S009 - no tiebreaker is configured for this board

**S001** key rationales:
- The Test Laboratory: This suggestion provides a clear, testable method for determining the skill realization rate by specifying the number of players, the duration of data collection, and the requirement to measure it per product and configuration. This would ensure consistency across laboratories and allow for reproducible results, fulfilling the requirement for enforceability and testability.
- The Licensed Organization: This amendment enhances the enforceability and testability of the skill realization rate requirement by ensuring that it is measured across a representative sample of players and configurations, which aligns with the standard’s goal of protecting players and ensuring compliance.
- The Operator: This amendment clarifies the measurement of the skill realization rate in a way that is both enforceable and reflective of actual player behavior, reducing ambiguity that could lead to inconsistent compliance and enforcement.

**S002** key rationales:
- The Test Laboratory: This suggestion clarifies that disabling a skill element in a configuration does not remove the product from coverage and that skill elements must be disclosed in the classification record. This prevents potential regulatory gaps and ensures transparency, making the requirement enforceable and observable in practice.
- The Licensed Organization: This revision prevents operators from circumventing skill representation requirements by disabling skill elements in certain configurations, which is crucial for maintaining the integrity of the classification system and ensuring that all configurations are subject to the same standards.
- The Player Advocate: Clarifying that disabling a skill element does not remove coverage closes the loophole where operators strip away skill features in specific configurations to evade the standards while still using the same chassis and branding to lure players in.
- The Operator: This revision prevents operators from circumventing skill representation requirements by disabling skill elements in certain configurations, aligning the standard with its intent and reducing regulatory loopholes.

**S005** key rationales:
- The Regulator: Requiring laboratories to document the exact configuration of the device under test, including firmware, hardware, and software patches, ensures that test results are replicable and enforceable. This information can be verified from certification reports, making compliance clear and actionable for regulators.
- The Licensed Organization: Requiring detailed device configuration documentation enhances the reliability and consistency of certification reports, supporting enforceability and transparency.
- The Player Advocate: Mandating that laboratories report exact firmware and hardware versions prevents certification fraud where a lab certifies a safe configuration but the operator ships a patched, exploitable version, ensuring the protection applies to the specific metal box the anonymous player is holding.
- The Operator: Requiring precise documentation of device configuration details ensures that test results are reproducible and verifiable, improving the reliability of certification and reducing the risk of inconsistent testing outcomes.

**S006** key rationales:
- The Regulator: Mandating the use of open-source or publicly available tools for outcome randomness testing increases transparency and allows third-party verification. This is enforceable by requiring laboratories to document the tools used, which can be reviewed and audited by regulators.
- The Licensed Organization: Mandating the use of open-source tools improves transparency, reduces compliance costs, and ensures the replicability of simulation-based test results.
- The Operator: Requiring the use of open-source or publicly available tools for outcome randomness increases transparency and reduces the risk of proprietary tools being used to obscure test results. It also lowers compliance costs for smaller laboratories, which is a practical benefit for the industry.

**S007** key rationales:
- The Regulator: Allowing small licensed organizations to rely on the operator to provide quarterly reports simplifies compliance and reduces administrative burdens. This is enforceable by requiring the operator to maintain and provide the necessary data, which can be verified by regulators.
- The Player Advocate: Allowing small organizations to rely on operator-provided revenue reports addresses the reality that a volunteer treasurer cannot possibly verify financial data without it being handed to them, ensuring the player's contribution is accounted for even in a resource-starved environment.
- The Operator: This addition provides a reasonable accommodation for small, volunteer-run organizations by allowing them to rely on the operator to provide necessary financial data, which reduces administrative burdens without compromising compliance.

**S008** key rationales:
- The Regulator: Allowing volunteer-run organizations to discharge compliance duties through a trained volunteer is practical and enforceable. The volunteer must be trained and accountable, and this can be verified through training records and oversight by the organization.
- The Operator: This change acknowledges the operational reality of volunteer-run organizations and provides a feasible mechanism for them to meet compliance requirements through trained volunteers, ensuring that internal controls are maintained.

**S010** key rationales:
- The Regulator: Requiring the skill influence range to be disclosed in a specific location on the device, readable from five feet away, ensures that players receive the information at the moment of play. This is enforceable by requiring the disclosure to be physically present on the device and verifiable through on-site inspections.
- The Test Laboratory: Requiring the skill influence range to be disclosed in a specific, readable location adjacent to the skill element ensures that the information is accessible to players in real-time, making the requirement enforceable and testable.
- The Licensed Organization: Specifying a physical location and legibility requirement ensures that players can access the skill influence range information at the moment of play, making the standard practically enforceable.
- The Operator: This change ensures that the skill influence range is not only disclosed but is physically located in a place where the player can easily see it, preventing operators from hiding critical information in documents that are never seen. It aligns the standard with the practical need to protect players at the moment of decision.

**S011** key rationales:
- The Regulator: Adding a threshold for high-value awards, regardless of whether they are paid in cash or merchandise, ensures that all high-value skill-based devices are subject to coverage. This is enforceable by requiring laboratories and operators to document awards and their values, which can be reviewed by regulators.
- The Test Laboratory: Adding a condition that high-value awards trigger coverage regardless of whether they are cash or merchandise ensures that the standard is applied consistently and prevents operators from evading coverage through non-cash prize structures.
- The Licensed Organization: This amendment closes a regulatory gap by ensuring that high-value awards, whether cash or merchandise, are treated as covered devices when paired with skill elements, preventing misclassification.
- The Operator: This amendment closes a critical loophole by ensuring that any device paying awards above the specified threshold (whether in cash or merchandise) is treated as covered. It prevents operators from misclassifying high-value devices as "amusement" when they function as gambling devices, protecting players from hidden risks.

**S012** key rationales:
- The Regulator: The amendment ensures that veterans posts are treated consistently, with the rental value of their premises counted as a charitable application. This is enforceable by requiring disclosure under SBCGS-M § 502 and verifying that the treatment is explicitly stated.
- The Test Laboratory: The amendment ensures that general operating costs are excluded from charitable yield unless explicitly treated as charitable by law and disclosed, preventing misleading reporting and aligning the standard with the actual use of funds.
- The Licensed Organization: This clarification ensures that for veterans posts, the rental value of premises is treated as part of the charitable yield, preventing misleading disclosures to players.
- The Operator: This amendment addresses a practical misalignment in how charitable yield is calculated for veterans posts, where the building itself is the mission. By explicitly treating the rental value of the premises as charitable, it ensures that the disclosure accurately reflects where player money goes, preventing misleading claims about charitable yield. S013: [Not voted on – authored by me] S014: [Not voted on – authored by me] S015: [Not voted on – authored by me]

**S014** key rationales:
- The Regulator: Clarifying that the "skill time cost ratio" must be measured using the median time for a proficient player ensures consistency across laboratories. This is enforceable by requiring laboratories to define and document the proficient player standard, which can be reviewed by regulators.
- The Test Laboratory: Defining the "skill time cost ratio" using the median time for a proficient player ensures a consistent and testable metric that can be measured uniformly across laboratories.
- The Licensed Organization: Clarifying that the skill time cost ratio is measured using the median time for a proficient player ensures consistent enforcement and reduces ambiguity in compliance.

---

## 5. Completion

Timestamp: 2026-10-02T03:28:49+00:00
Configured actions: report, publish

- **report** OK: report present and current at /mnt/d/tools/apps/skillgames/logs/2026-10/C/report.md
- **publish** OK: pass list published to /mnt/d/tools/apps/skillgames/logs/2026-10/C/published/latest.json (and skillgames-2026-10-C-2026-10-01.json)