# SBCGS Standards Committee - Session Minutes
Date: 2026-10-01
Board: skillgames-2026-10-M
Documents reviewed: SBCGS-M v1.3, Minimum Internal Control Standards
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-M § 502(d) to require that the charitable yield floor be computed on a basis that deducts only the cost of acquiring, leasing, servicing, monitoring, and financing covered devices, and not on gross gaming revenue.
  *Rationale: The current floor of 25% of gross gaming revenue is unworkable for many operators, particularly small ones, and may not reflect the true charitable contribution when operational costs are considered. This change aligns the standard with existing state practices that compute charitable yield on a post-expense basis, ensuring that the floor is meaningful and achievable.*
  *Evidence: Appendix A of SBCGS-M invites comment on the 25% floor, noting that no existing measure is computed on the same basis. Additionally, several states compute charitable yield after expenses, as noted in the Appendix B gap analysis. ---*
- S002: In SBCGS-M § 401(d), remove the cap on the aggregate of sessions conducted under limited anonymous play and replace it with a requirement that all anonymous play must be limited to sessions where the player is not identified and the device is not connected to a monitoring system.
  *Rationale: The current cap on anonymous play may be insufficient to prevent problematic behavior, and the requirement to connect anonymous sessions to a monitoring system ensures that enforcement of exclusion and limit programs can still occur even when identity is not known.*
  *Evidence: Appendix B of SBCGS-M notes that no existing regulation requires the disclosure of the return at absent skill, suggesting a gap in enforcement. This change would ensure that even with anonymous play, the operator can still enforce exclusion and limit policies as required under § 301 and § 302. ---*
- S003: In SBCGS-M § 202(d), remove the allocation of enforcement duties to host locations and instead require that all enforcement duties related to exclusion and limit programs be discharged by the covered operator or the licensed organization, with host locations only required to hold and enforce exclusion lists provided by the operator.
  *Rationale: Host locations, especially those that are volunteer-staffed or small organizations, may lack the capacity to enforce exclusion and limit programs effectively. This change ensures that enforcement is centralized and carried out by entities with the necessary resources and training.*
  *Evidence: Appendix B of SBCGS-M identifies a gap in the enforcement of exclusion programs at the device level, noting that no existing regulation requires enforcement to be carried out by the operator or licensed organization. The note in § 205(c) also highlights the difficulty small volunteer organizations face in identifying and auditing the beneficial interests of operators.*

**The Test Laboratory** (ollama:qwen3:14b)
- S004: Amend SBCGS-M § 502(d) to require that the charitable yield floor be computed on a basis that deducts only the direct costs of operation (e.g., device lease, service, monitoring) before calculating the floor, rather than on gross gaming revenue.
  *Rationale: The current floor of 25% of gross gaming revenue is unattainable for many small operators and may incentivize misrepresentation of charitable yield. Adjusting the floor to a more realistic and transparent basis ensures the standard is both enforceable and meaningful.*
  *Evidence: Appendix A of SBCGS-M notes that publicly reported splits in this category, under which the host and the route operator each take about forty percent of profit, would not meet the current 25% floor on gross gaming revenue. ---*
- S005: Amend SBCGS-M § 401(d) to replace the 20% session limit with a fixed maximum of 5 sessions per device per quarter, regardless of the jurisdiction’s allowance for anonymous play.
  *Rationale: The current 20% session limit is ambiguous and may vary in interpretation, leading to inconsistent enforcement. A fixed numerical limit ensures clarity and uniformity across jurisdictions.*
  *Evidence: Appendix A of SBCGS-M invites comment on whether the 20% test is administrable, indicating that the current approach may not be effectively measurable or consistently applied. ---*
- S006: Amend SBCGS-M § 304(c)(1) to require that the return at absent skill be disclosed as a fixed percentage (e.g., 30%) rather than as a computed value, if the skill influence range is less than 50%.
  *Rationale: The current requirement to disclose both the return at optimal skill and the return at absent skill may be impractical or misleading for products with minimal skill influence. A fixed disclosure threshold simplifies compliance and improves clarity for players.*
  *Evidence: Appendix B of SBCGS-M identifies a complete gap in existing regulation for the disclosure of the return at absent skill, indicating that no source currently requires either end of the range to be computed or shown.*

**The Licensed Organization** (ollama:qwen3:14b)
- S007: Amend SBCGS-M § 502(d) to state that the twenty-five percent charitable yield floor applies to the average of the four most recent completed quarters, rather than the aggregate of those quarters.
  *Rationale: This change would make the requirement more achievable for small organizations with fluctuating revenue, while still ensuring that the charitable yield remains above a meaningful threshold over time.*
  *Evidence: Appendix A, Matter 1: The Institute selected the figure by reference to the fraction of the player's money that a reasonable player would understand a charitable representation to describe, not by reference to any existing measure. This suggests that the current aggregate approach may be overly burdensome for small operations. ---*
- S008: Add a new subsection to SBCGS-M § 202(d) that allows a host location, such as a volunteer-run veterans post, to rely on the covered operator to perform certain duties related to the enforcement of limits, exclusion programs, and charitable yield reporting, provided that the operator has documented procedures and provides the host location with relevant records.
  *Rationale: This would reduce the operational burden on volunteer-run organizations that lack dedicated compliance staff, while still ensuring that necessary requirements are met through the operator’s oversight.*
  *Evidence: Appendix B, Documented Gap 7: The allocation of duties in § 202(d) is noted as a gap, particularly for host locations that are volunteer-staffed clubs. This suggests that the current allocation may be impossible to discharge as stated for such organizations. ---*
- S009: Amend SBCGS-M § 502(f) to require that the covered operator provide the licensed organization with the necessary data to compute charitable yield in a format that is user-friendly and compatible with common accounting software, rather than requiring manual input or complex reconciliation.
  *Rationale: This would reduce the administrative burden on the licensed organization and improve the accuracy of the charitable yield computation, especially for small organizations with limited resources.*
  *Evidence: Appendix A, Matter 1: Comment is invited from licensed organizations on what the figure means for a small operation, and from route operators on the cost structure that determines what is attainable. This implies that the current requirement may be difficult for small organizations to meet without additional support.*

**The Player Advocate** (ollama:qwen3.5:9b)
- S010: Replace the floor in SBCGS-M § 502(d) with a requirement that computes charitable yield as the percentage of *net* proceeds (gross gaming revenue less all operating costs and prizes) applied to charity, rather than 25% of gross gaming revenue.
  *Rationale: The current floor is technically satisfied but practically useless for an anonymous player holding cash; it allows operators and distributors to pocket the vast majority of player funds while claiming a charitable representation, making the "charitable" label a marketing fiction that reaches no one but the regulator's spreadsheet. A share of *net* proceeds ensures the charity actually receives what the player intuitively believes they are supporting, closing the gap where the organization named on the device is often the party with the least control over the obligation.*
  *Evidence: SBCGS-M Appendix B explicitly notes that "State charitable gaming statutes compute a share after prizes and expenses" and that no source computes the fraction of the player's money that reaches the purpose. The NCPG report (Jan 30, 2023) found that regulations in major jurisdictions do not mandate sufficient protections, often allowing entities to deduct operating costs before calculating charitable contribution, leaving players uninformed about where their money actually goes.*
- S011: In SBCGS-M § 304(a), amend the "Manner" requirement to mandate that disclosures be presented in a single sentence or less on the primary display, utilizing high-contrast text (e.g., white on black) and positioned at eye level without requiring interaction to view.
  *Rationale: The current standard requires disclosures to be "available... before the player commits consideration," but assumes the player will read them; an anonymous player in difficulty with cash in hand has a cognitive load already high and will not read anything longer than a sentence. A requirement for multi-line disclosures or interactive menus is practically defeated by the moment of impulse play, failing the test of whether protection reaches someone at the moment it matters.*
  *Evidence: The prompt instructions state: "assume that person... will not read anything longer than a sentence." SBCGS-C § 106(g) defines skill products where the player stands at a device; if they cannot read the disclosure in under a second, the protection is illusory. The Ohio Administrative Code Rule 3772-13-02 emphasizes clear messages designed to prevent problem gambling, implying brevity and clarity are essential for effectiveness, not just presence.*
- S012: Add a new subsection to SBCGS-M § 506(c)(3) prohibiting the application of charitable proceeds to lobbying or advocacy related to covered products, and require the licensed organization to disclose annually the total amount spent on such activities if any remain in the general fund.
  *Rationale: A player told that play supports a veterans post has not been told that a share of it supports a lobbying campaign; current standards fail to reach this exposure because organizations often fund advocacy through the very entities hosting devices, creating a conflict where the "charitable" purpose is diluted by political spending. This requirement ensures the representation made to the anonymous player is accurate and that the charitable yield floor truly represents funds for public good rather than industry protectionism.*
  *Evidence: The prompt instructions note: "a player told that play supports a veterans post has not been told that a share of it supports a lobbying campaign." SBCGS-M § 506(c)(3) currently prohibits political contributions, but the Note indicates this prohibition only reaches amounts counted as applied to a charitable purpose; it does not reach what the organization does with money *not* so counted. The NCPG report (Jan 30, 2023) highlights that existing regulations do not mandate sufficient responsible gambling protections, and allowing funds to be siphoned off for lobbying exacerbates this lack of protection by prioritizing industry interests over player safety.*

**The Operator** (ollama:qwen3:14b)
- S013: Amend SBCGS-M § 502(d) to require that the charitable yield floor be computed on a basis that deducts only the direct costs of the operation (e.g., device lease, service, communications, monitoring, and financing) before calculating the floor, rather than on gross gaming revenue.
  *Rationale: The current floor is based on gross gaming revenue, which includes profits for multiple parties and does not reflect the actual fraction of player money reaching the charitable purpose. This creates a risk that the floor cannot be met in practice, especially in models where host and route operators take a large share of profits.*
  *Evidence: SBCGS-M § 502(d) currently states the floor as 25% of gross gaming revenue, but the Institute has found no jurisdiction that states a floor on this basis, and several that state one on a basis that has already deducted expense. Publicly reported splits in this category, under which the host and the route operator each take about 40% of profit, would not meet the current floor. ---*
- S014: In SBCGS-M § 401(d), remove the 20% cap on sessions conducted under limited anonymous play and replace it with a requirement that all anonymous play sessions be limited to $50 committed and that the host location must verify identity to the extent possible.
  *Rationale: The 20% cap creates ambiguity around enforcement and may lead to inconsistent application across jurisdictions. Removing the cap and focusing on the $50 limit and identity verification ensures clarity and reduces the risk of misuse or unenforceable exclusion enforcement.*
  *Evidence: SBCGS-M § 401(d) currently permits limited anonymous play only if the aggregate of such sessions does not exceed 20% of sessions at a device in a calendar quarter. However, the note in the section acknowledges that the cap is an accommodation that may not be administrable, and the alternative of requiring identity in every case is defensible. ---*
- S015: In SBCGS-M § 506(c)(3), expand the prohibition on applying charitable proceeds to lobbying to include any use of charitable proceeds for political contributions or advocacy related to covered products, even if not explicitly labeled as such.
  *Rationale: Current language prohibits only explicit payments for lobbying or influencing legislation, but does not address indirect or disguised uses of charitable funds. This creates a risk that funds may be diverted to advocacy efforts without the player being aware.*
  *Evidence: SBCGS-M § 506(c)(3) currently prohibits the use of charitable proceeds for political contributions or payments to influence legislation, but the note clarifies that the prohibition applies only to amounts the organization has counted as applied to a charitable purpose. This leaves a gap in cases where funds are used for advocacy efforts without being explicitly labeled as such.*

---

## 2. Pool Phase

**Leader actions:**
- S004 and S013 and S001 merged → S001 (authors credited: The Regulator, The Test Laboratory, The Operator)
  *Merge note: S001 (The Regulator), S004 (The Test Laboratory), and S013 (The Operator) all amend SBCGS-M § 502(d) to compute the charitable yield floor by deducting direct operational costs (device acquisition/lease, servicing, monitoring, financing, and in S013's case communications) rather than basing the floor on gross gaming revenue. Acting on any one would satisfy the others. S001's wording is kept as the clearest and most complete enumeration of deductible cost categories.*
- 12 suggestion(s) retained as submitted

**Final pool: 13 suggestions (from 15 submitted; 1 merged)**

- S001: Amend SBCGS-M § 502(d) to require that the charitable yield floor be computed on a basis that deducts only the cost of acquiring, leasing, servicing, monitoring, and financing covered devices, and not on gross gaming revenue. *(merged from S001, S004, S013; credited: The Regulator, The Test Laboratory, The Operator)*
- S002: In SBCGS-M § 401(d), remove the cap on the aggregate of sessions conducted under limited anonymous play and replace it with a requirement that all anonymous play must be limited to sessions where the player is not identified and the device is not connected to a monitoring system.
- S003: In SBCGS-M § 202(d), remove the allocation of enforcement duties to host locations and instead require that all enforcement duties related to exclusion and limit programs be discharged by the covered operator or the licensed organization, with host locations only required to hold and enforce exclusion lists provided by the operator.
- S005: Amend SBCGS-M § 401(d) to replace the 20% session limit with a fixed maximum of 5 sessions per device per quarter, regardless of the jurisdiction’s allowance for anonymous play.
- S006: Amend SBCGS-M § 304(c)(1) to require that the return at absent skill be disclosed as a fixed percentage (e.g., 30%) rather than as a computed value, if the skill influence range is less than 50%.
- S007: Amend SBCGS-M § 502(d) to state that the twenty-five percent charitable yield floor applies to the average of the four most recent completed quarters, rather than the aggregate of those quarters.
- S008: Add a new subsection to SBCGS-M § 202(d) that allows a host location, such as a volunteer-run veterans post, to rely on the covered operator to perform certain duties related to the enforcement of limits, exclusion programs, and charitable yield reporting, provided that the operator has documented procedures and provides the host location with relevant records.
- S009: Amend SBCGS-M § 502(f) to require that the covered operator provide the licensed organization with the necessary data to compute charitable yield in a format that is user-friendly and compatible with common accounting software, rather than requiring manual input or complex reconciliation.
- S010: Replace the floor in SBCGS-M § 502(d) with a requirement that computes charitable yield as the percentage of *net* proceeds (gross gaming revenue less all operating costs and prizes) applied to charity, rather than 25% of gross gaming revenue.
- S011: In SBCGS-M § 304(a), amend the "Manner" requirement to mandate that disclosures be presented in a single sentence or less on the primary display, utilizing high-contrast text (e.g., white on black) and positioned at eye level without requiring interaction to view.
- S012: Add a new subsection to SBCGS-M § 506(c)(3) prohibiting the application of charitable proceeds to lobbying or advocacy related to covered products, and require the licensed organization to disclose annually the total amount spent on such activities if any remain in the general fund.
- S014: In SBCGS-M § 401(d), remove the 20% cap on sessions conducted under limited anonymous play and replace it with a requirement that all anonymous play sessions be limited to $50 committed and that the host location must verify identity to the extent possible.
- S015: In SBCGS-M § 506(c)(3), expand the prohibition on applying charitable proceeds to lobbying to include any use of charitable proceeds for political contributions or advocacy related to covered products, even if not explicitly labeled as such.

---

## 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-M § 502(d) to require that the charitable yield floor be computed on a basis that deducts only the cost of acquiring, leasing, servicing, monitoring, and financing covered devices, and not on gross gaming revenue.

| 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 | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | This amendment aligns the standard with practical realities faced by small operators and ensures the charitable yield floor is meaningful and achievable, rather than a technicality that fails to reflect actual contributions. |
| The Player Advocate | Theodore Gilliam, SA | NO | Deducting only device costs while leaving the vast majority of operating expenses out of the calculation allows operators to claim a "charitable" floor that is mathematically satisfied but functionally meaningless to an anonymous player who has no idea how much was actually spent running the venue. |
| 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: 1 YES / 1 NO / 3 ABSTAIN → 50% (threshold: 51%) → FAILED**

### Votes on S002: In SBCGS-M § 401(d), remove the cap on the aggregate of sessions conducted under limited anonymous play and replace it with a requirement that all anonymous play must be limited to sessions where the player is not identified and the device is not connected to a monitoring system.

| 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 | NO | Replacing the cap with a requirement that anonymous sessions be limited to unconnected devices is not testable or enforceable, as it does not provide a clear, quantifiable threshold for regulators or laboratories to verify compliance. |
| The Licensed Organization | Eileen Cortland, SA | NO | While the intent to improve enforcement is valid, replacing the cap with a requirement that all anonymous play must be disconnected from monitoring systems may undermine the ability to enforce exclusion and limit programs effectively, particularly for regulators and host locations. |
| The Player Advocate | Theodore Gilliam, SA | NO | Requiring a monitoring system for anonymous sessions creates a technical impossibility that can be evaded simply by walking to a different device or venue, thereby failing the test of whether protection reaches someone at the moment it matters. |
| The Operator | Danny Sokolov, SA | NO | Requiring all anonymous sessions to be connected to a monitoring system introduces new hardware and enforcement requirements that many host locations, especially small or volunteer-run ones, may not have the capacity to support, effectively making the requirement unworkable without significant upgrades. |

*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 S003: In SBCGS-M § 202(d), remove the allocation of enforcement duties to host locations and instead require that all enforcement duties related to exclusion and limit programs be discharged by the covered operator or the licensed organization, with host locations only required to hold and enforce exclusion lists provided by the operator.

| 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 | The suggestion involves a shift in enforcement responsibilities that affects the operational structure of host locations and licensed organizations, which is outside the scope of the Test Laboratory's role in defining test procedures and pass conditions. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | The suggestion raises a valid concern about the capacity of small or volunteer-run host locations to fulfill enforcement duties, but the proposal to centralize enforcement responsibilities with the operator or licensed organization may not fully address the complexities of shared responsibility and could create gaps in oversight. Further clarity on how enforcement would be coordinated between parties is needed. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | Centralizing enforcement on operators ignores the reality that host locations are often volunteer-run and lack capacity, which means this requirement is practically defeated rather than strengthened for the player in difficulty. |
| The Operator | Danny Sokolov, SA | ABSTAIN | While the intent to centralize enforcement duties is clear, the suggestion does not explicitly address how this change affects the consistency of skill measures or charitable yield computations across the three documents, which is required for a full evaluation of its impact on the standards family. |

*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 S005: Amend SBCGS-M § 401(d) to replace the 20% session limit with a fixed maximum of 5 sessions per device per quarter, regardless of the jurisdiction’s allowance for anonymous play.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | A fixed numerical limit provides clarity and uniformity, enabling regulators to enforce the requirement consistently across jurisdictions without ambiguity in interpretation. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | A fixed numerical limit provides clarity and consistency, reducing ambiguity and ensuring uniform enforcement across jurisdictions. |
| The Player Advocate | Theodore Gilliam, SA | NO | A fixed session count does not address the core issue of financial harm to an anonymous player holding cash, as a single high-limit session can still cause severe distress regardless of how many times they play in that quarter. |
| The Operator | Danny Sokolov, SA | YES | A fixed numerical limit removes ambiguity and ensures consistent enforcement across jurisdictions, which is critical for operators managing a fleet of devices. |

*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 S006: Amend SBCGS-M § 304(c)(1) to require that the return at absent skill be disclosed as a fixed percentage (e.g., 30%) rather than as a computed value, if the skill influence range is less than 50%.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Requiring a fixed percentage simplifies compliance and ensures players receive clear, unambiguous information about the return at absent skill, improving transparency and enforceability. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | This change simplifies compliance for products with minimal skill influence, ensuring that disclosures are clear and meaningful for players without overcomplicating the standard. |
| The Player Advocate | Theodore Gilliam, SA | NO | Mandating a fixed percentage for disclosure fails the test of reaching the player because it allows operators to present a misleadingly low return at absent skill that does not reflect the actual mathematical disadvantage, deceiving the anonymous user before they commit. |
| The Operator | Danny Sokolov, SA | YES | Requiring a fixed percentage disclosure simplifies compliance for operators and ensures clarity for players, particularly on devices with minimal skill influence. |

*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: Amend SBCGS-M § 502(d) to state that the twenty-five percent charitable yield floor applies to the average of the four most recent completed quarters, rather than the aggregate of those quarters.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Applying the charitable yield floor to an average of the most recent quarters ensures a more stable and achievable standard for small operators, while still maintaining a meaningful charitable obligation over time. |
| The Test Laboratory | Marcus Brennan, SA | YES | Changing the charitable yield floor to an average over four quarters provides a more stable and achievable metric for small organizations with fluctuating revenue. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | NO | Averaging over four quarters smooths out the reality of immediate financial harm and allows an operator to claim compliance during good quarters while knowingly enabling ruinous spending in a bad quarter right now. |
| The Operator | Danny Sokolov, SA | YES | Averaging over the most recent four quarters makes the requirement more achievable for small organizations with fluctuating revenue, while still maintaining a meaningful charitable yield 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.*


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

### Votes on S008: Add a new subsection to SBCGS-M § 202(d) that allows a host location, such as a volunteer-run veterans post, to rely on the covered operator to perform certain duties related to the enforcement of limits, exclusion programs, and charitable yield reporting, provided that the operator has documented procedures and provides the host location with relevant records.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | This amendment allows volunteer-run host locations to rely on the operator’s documented procedures, ensuring compliance without placing undue burdens on understaffed or volunteer-run organizations. |
| The Test Laboratory | Marcus Brennan, SA | YES | This amendment allows host locations to rely on the operator for certain duties, which is testable and ensures compliance through documented procedures. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | YES | Allowing volunteer-run hosts to rely on the operator for complex enforcement duties prevents the standard from becoming a barrier that forces small organizations to fail simply because they lack dedicated compliance staff, ensuring the player gets protection regardless of who runs the booth. |
| The Operator | Danny Sokolov, SA | YES | This change reduces the operational burden on volunteer-run host locations without compromising compliance, which is beneficial for both operators and the installed base. |

*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 S009: Amend SBCGS-M § 502(f) to require that the covered operator provide the licensed organization with the necessary data to compute charitable yield in a format that is user-friendly and compatible with common accounting software, rather than requiring manual input or complex reconciliation.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Requiring data in a user-friendly format compatible with common accounting software reduces administrative burdens and improves accuracy, ensuring the licensed organization can effectively compute charitable yield. |
| The Test Laboratory | Marcus Brennan, SA | YES | Requiring user-friendly data formats improves the accuracy and feasibility of charitable yield computation, making it easier for licensed organizations to comply. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | YES | Requiring data in a user-friendly format ensures the licensed organization can actually verify the charitable yield without manual reconciliation errors, making the requirement enforceable by a regulator and meaningful for the player rather than just a checkbox exercise. |
| The Operator | Danny Sokolov, SA | YES | Requiring data in a user-friendly format reduces administrative burden and improves accuracy, which is essential for small organizations with limited resources. |

*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 S010: Replace the floor in SBCGS-M § 502(d) with a requirement that computes charitable yield as the percentage of *net* proceeds (gross gaming revenue less all operating costs and prizes) applied to charity, rather than 25% of gross gaming revenue.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Computing charitable yield as a percentage of net proceeds ensures that the charitable contribution is meaningful and reflects the actual amount of player funds that reach charity, rather than merely a percentage of gross revenue. |
| The Test Laboratory | Marcus Brennan, SA | YES | Computing charitable yield as a percentage of net proceeds rather than gross revenue ensures that the charitable contribution is meaningful and reflects actual funds directed to charity. |
| The Licensed Organization | Eileen Cortland, SA | YES | Requiring a share of *net* proceeds ensures that the charitable yield is meaningful and reflects actual contributions to charity, rather than a superficial percentage of gross revenue. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | Computing charitable yield based on net proceeds ensures that the actual share reaching charity is meaningful and transparent, aligning with the player’s intuitive understanding of support. |

*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 SBCGS-M § 304(a), amend the "Manner" requirement to mandate that disclosures be presented in a single sentence or less on the primary display, utilizing high-contrast text (e.g., white on black) and positioned at eye level without requiring interaction to view.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Requiring concise, high-contrast, and easily accessible disclosures ensures that players—especially those in moments of impulse—can quickly understand critical information without interacting with the device. |
| The Test Laboratory | Marcus Brennan, SA | YES | Requiring concise, high-contrast disclosures on the primary display ensures that players, especially those in impulse situations, can easily access critical information. |
| The Licensed Organization | Eileen Cortland, SA | YES | This requirement ensures that disclosures are immediately visible and comprehensible to players in the moment of play, improving protection for anonymous players with limited cognitive capacity. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | Requiring disclosures to be presented in a single sentence with high-contrast text ensures they are actually seen and understood by players at the moment of decision, fulfilling the intent of the 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.*


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

### Votes on S012: Add a new subsection to SBCGS-M § 506(c)(3) prohibiting the application of charitable proceeds to lobbying or advocacy related to covered products, and require the licensed organization to disclose annually the total amount spent on such activities if any remain in the general fund.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Prohibiting the use of charitable proceeds for lobbying or advocacy and requiring annual disclosure ensures that players are accurately informed about how their contributions are used, aligning the standards with the intent of charitable support. |
| The Test Laboratory | Marcus Brennan, SA | YES | Prohibiting the use of charitable proceeds for lobbying and requiring annual disclosure ensures transparency and aligns the charitable purpose with player expectations. |
| The Licensed Organization | Eileen Cortland, SA | YES | This addition ensures transparency and accuracy in the use of charitable proceeds, preventing the dilution of the "charitable" label through political spending and aligning the standard with player expectations. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | Prohibiting the use of charitable proceeds for political contributions or advocacy ensures the representation made to players is accurate and aligns with the public good, avoiding dilution of the charitable purpose. |

*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 S014: In SBCGS-M § 401(d), remove the 20% cap on sessions conducted under limited anonymous play and replace it with a requirement that all anonymous play sessions be limited to $50 committed and that the host location must verify identity to the extent possible.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Replacing the cap with a $50 limit and requiring identity verification provides a clear, enforceable standard that reduces the risk of misuse while maintaining compliance with exclusion and limit programs. |
| The Test Laboratory | Marcus Brennan, SA | YES | Replacing the 20% cap with a $50 limit and identity verification provides a clearer, more enforceable standard for anonymous play sessions. |
| The Licensed Organization | Eileen Cortland, SA | NO | The suggestion introduces a new limit and verification requirement that may not be feasible for small or volunteer-run organizations, potentially creating new administrative burdens. |
| The Player Advocate | Theodore Gilliam, SA | NO | Verifying identity for anonymous play defeats the fundamental purpose of the category; if a host must verify identity to limit sessions, they are no longer providing "anonymous" play, and this requirement can be evaded by players simply refusing to have their identity checked. |
| 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: 2 YES / 2 NO / 1 ABSTAIN → 50% (threshold: 51%) → FAILED**

### Votes on S015: In SBCGS-M § 506(c)(3), expand the prohibition on applying charitable proceeds to lobbying to include any use of charitable proceeds for political contributions or advocacy related to covered products, even if not explicitly labeled as such.

| Seat | Synthetic agent (not a person) | Vote | Reason |
|---|---|---|---|
| The Regulator | Adele Sandoval, SA | YES | Expanding the prohibition to include indirect or disguised uses of charitable funds for political contributions or advocacy ensures that players are not misled about how their contributions are used, closing a critical gap in the current standards. |
| The Test Laboratory | Marcus Brennan, SA | YES | Expanding the prohibition to include indirect or disguised political contributions ensures that charitable proceeds are used for genuine public good rather than industry-related advocacy. |
| The Licensed Organization | Eileen Cortland, SA | YES | Expanding the prohibition to include indirect or disguised uses of charitable proceeds for political contributions strengthens the standard by preventing the misallocation of funds and ensuring that charitable yield is genuinely applied to public good. |
| The Player Advocate | Theodore Gilliam, SA | NO | Expanding the prohibition on lobbying uses is good in theory, but without a clear definition of what constitutes "advocacy related to covered products," operators can easily satisfy this by burying such expenditures in general fund categories, making the requirement technically met while allowing the player's money to support political causes they did not intend. |
| 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**

## 4. Pass List

| ID | Suggestion | Yes | No | Abstain | % | Result |
|----|-----------|-----|----|---------|---|--------|
| S001 | Amend SBCGS-M § 502(d) to require that the charitable yield floor be computed on a basis that deducts only the cost of acquiring, leasing, servicing, monitoring, and financing covered devices, and not on gross gaming revenue. | 1 | 1 | 3 | 50% | ✗ FAILED (tie) |
| S002 | In SBCGS-M § 401(d), remove the cap on the aggregate of sessions conducted under limited anonymous play and replace it with a requirement that all anonymous play must be limited to sessions where the player is not identified and the device is not connected to a monitoring system. | 0 | 4 | 1 | 0% | ✗ FAILED |
| S003 | In SBCGS-M § 202(d), remove the allocation of enforcement duties to host locations and instead require that all enforcement duties related to exclusion and limit programs be discharged by the covered operator or the licensed organization, with host locations only required to hold and enforce exclusion lists provided by the operator. | 0 | 0 | 5 | 0% | ✗ FAILED |
| S005 | Amend SBCGS-M § 401(d) to replace the 20% session limit with a fixed maximum of 5 sessions per device per quarter, regardless of the jurisdiction’s allowance for anonymous play. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S006 | Amend SBCGS-M § 304(c)(1) to require that the return at absent skill be disclosed as a fixed percentage (e.g., 30%) rather than as a computed value, if the skill influence range is less than 50%. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S007 | Amend SBCGS-M § 502(d) to state that the twenty-five percent charitable yield floor applies to the average of the four most recent completed quarters, rather than the aggregate of those quarters. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S008 | Add a new subsection to SBCGS-M § 202(d) that allows a host location, such as a volunteer-run veterans post, to rely on the covered operator to perform certain duties related to the enforcement of limits, exclusion programs, and charitable yield reporting, provided that the operator has documented procedures and provides the host location with relevant records. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S009 | Amend SBCGS-M § 502(f) to require that the covered operator provide the licensed organization with the necessary data to compute charitable yield in a format that is user-friendly and compatible with common accounting software, rather than requiring manual input or complex reconciliation. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S010 | Replace the floor in SBCGS-M § 502(d) with a requirement that computes charitable yield as the percentage of *net* proceeds (gross gaming revenue less all operating costs and prizes) applied to charity, rather than 25% of gross gaming revenue. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S011 | In SBCGS-M § 304(a), amend the "Manner" requirement to mandate that disclosures be presented in a single sentence or less on the primary display, utilizing high-contrast text (e.g., white on black) and positioned at eye level without requiring interaction to view. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S012 | Add a new subsection to SBCGS-M § 506(c)(3) prohibiting the application of charitable proceeds to lobbying or advocacy related to covered products, and require the licensed organization to disclose annually the total amount spent on such activities if any remain in the general fund. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S014 | In SBCGS-M § 401(d), remove the 20% cap on sessions conducted under limited anonymous play and replace it with a requirement that all anonymous play sessions be limited to $50 committed and that the host location must verify identity to the extent possible. | 2 | 2 | 1 | 50% | ✗ FAILED (tie) |
| S015 | In SBCGS-M § 506(c)(3), expand the prohibition on applying charitable proceeds to lobbying to include any use of charitable proceeds for political contributions or advocacy related to covered products, even if not explicitly labeled as such. | 3 | 1 | 1 | 75% | ✓ PASSED |

**Total: 13 suggestions reviewed. 9 passed. 4 failed.**

**Tied votes:** S001, S014 - no tiebreaker is configured for this board

**S005** key rationales:
- The Regulator: A fixed numerical limit provides clarity and uniformity, enabling regulators to enforce the requirement consistently across jurisdictions without ambiguity in interpretation.
- The Licensed Organization: A fixed numerical limit provides clarity and consistency, reducing ambiguity and ensuring uniform enforcement across jurisdictions.
- The Operator: A fixed numerical limit removes ambiguity and ensures consistent enforcement across jurisdictions, which is critical for operators managing a fleet of devices.

**S006** key rationales:
- The Regulator: Requiring a fixed percentage simplifies compliance and ensures players receive clear, unambiguous information about the return at absent skill, improving transparency and enforceability.
- The Licensed Organization: This change simplifies compliance for products with minimal skill influence, ensuring that disclosures are clear and meaningful for players without overcomplicating the standard.
- The Operator: Requiring a fixed percentage disclosure simplifies compliance for operators and ensures clarity for players, particularly on devices with minimal skill influence.

**S007** key rationales:
- The Regulator: Applying the charitable yield floor to an average of the most recent quarters ensures a more stable and achievable standard for small operators, while still maintaining a meaningful charitable obligation over time.
- The Test Laboratory: Changing the charitable yield floor to an average over four quarters provides a more stable and achievable metric for small organizations with fluctuating revenue.
- The Operator: Averaging over the most recent four quarters makes the requirement more achievable for small organizations with fluctuating revenue, while still maintaining a meaningful charitable yield standard.

**S008** key rationales:
- The Regulator: This amendment allows volunteer-run host locations to rely on the operator’s documented procedures, ensuring compliance without placing undue burdens on understaffed or volunteer-run organizations.
- The Test Laboratory: This amendment allows host locations to rely on the operator for certain duties, which is testable and ensures compliance through documented procedures.
- The Player Advocate: Allowing volunteer-run hosts to rely on the operator for complex enforcement duties prevents the standard from becoming a barrier that forces small organizations to fail simply because they lack dedicated compliance staff, ensuring the player gets protection regardless of who runs the booth.
- The Operator: This change reduces the operational burden on volunteer-run host locations without compromising compliance, which is beneficial for both operators and the installed base.

**S009** key rationales:
- The Regulator: Requiring data in a user-friendly format compatible with common accounting software reduces administrative burdens and improves accuracy, ensuring the licensed organization can effectively compute charitable yield.
- The Test Laboratory: Requiring user-friendly data formats improves the accuracy and feasibility of charitable yield computation, making it easier for licensed organizations to comply.
- The Player Advocate: Requiring data in a user-friendly format ensures the licensed organization can actually verify the charitable yield without manual reconciliation errors, making the requirement enforceable by a regulator and meaningful for the player rather than just a checkbox exercise.
- The Operator: Requiring data in a user-friendly format reduces administrative burden and improves accuracy, which is essential for small organizations with limited resources.

**S010** key rationales:
- The Regulator: Computing charitable yield as a percentage of net proceeds ensures that the charitable contribution is meaningful and reflects the actual amount of player funds that reach charity, rather than merely a percentage of gross revenue.
- The Test Laboratory: Computing charitable yield as a percentage of net proceeds rather than gross revenue ensures that the charitable contribution is meaningful and reflects actual funds directed to charity.
- The Licensed Organization: Requiring a share of *net* proceeds ensures that the charitable yield is meaningful and reflects actual contributions to charity, rather than a superficial percentage of gross revenue.
- The Operator: Computing charitable yield based on net proceeds ensures that the actual share reaching charity is meaningful and transparent, aligning with the player’s intuitive understanding of support.

**S011** key rationales:
- The Regulator: Requiring concise, high-contrast, and easily accessible disclosures ensures that players—especially those in moments of impulse—can quickly understand critical information without interacting with the device.
- The Test Laboratory: Requiring concise, high-contrast disclosures on the primary display ensures that players, especially those in impulse situations, can easily access critical information.
- The Licensed Organization: This requirement ensures that disclosures are immediately visible and comprehensible to players in the moment of play, improving protection for anonymous players with limited cognitive capacity.
- The Operator: Requiring disclosures to be presented in a single sentence with high-contrast text ensures they are actually seen and understood by players at the moment of decision, fulfilling the intent of the standard.

**S012** key rationales:
- The Regulator: Prohibiting the use of charitable proceeds for lobbying or advocacy and requiring annual disclosure ensures that players are accurately informed about how their contributions are used, aligning the standards with the intent of charitable support.
- The Test Laboratory: Prohibiting the use of charitable proceeds for lobbying and requiring annual disclosure ensures transparency and aligns the charitable purpose with player expectations.
- The Licensed Organization: This addition ensures transparency and accuracy in the use of charitable proceeds, preventing the dilution of the "charitable" label through political spending and aligning the standard with player expectations.
- The Operator: Prohibiting the use of charitable proceeds for political contributions or advocacy ensures the representation made to players is accurate and aligns with the public good, avoiding dilution of the charitable purpose.

**S015** key rationales:
- The Regulator: Expanding the prohibition to include indirect or disguised uses of charitable funds for political contributions or advocacy ensures that players are not misled about how their contributions are used, closing a critical gap in the current standards.
- The Test Laboratory: Expanding the prohibition to include indirect or disguised political contributions ensures that charitable proceeds are used for genuine public good rather than industry-related advocacy.
- The Licensed Organization: Expanding the prohibition to include indirect or disguised uses of charitable proceeds for political contributions strengthens the standard by preventing the misallocation of funds and ensuring that charitable yield is genuinely applied to public good.

---

## 5. Completion

Timestamp: 2026-10-02T03:56:39+00:00
Configured actions: report, publish

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