IEGM Institute for Emerging Gaming Markets

Committee records

SBCGS Standards Committee, Classification Standard, meeting of November 8, 2026

About the members, in the record's own words

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.

That is quoted from the record below, not written for this page. This record carries no description written by the Institute, because any description of it would have been written after reading it, and the records index states that a record's description is fixed before the record exists. Where that could not be done, none is published.

Provisions named in the prompt

sbcgs-2026-11-08-c-provisions.md lists, per seat, the provisions each seat was named in its instructions before the meeting. It is published instead of the persona prose, because the list is what a reader needs in order to tell a citation the seats were pointed at from one they found in the document, and the prose is not. It is the owning session's file, published unchanged.

sha256 8a33d721f2e2e21cb060216b078b81f568174fe3a57f15f23c59230ad8071234

Where these decisions stand

As of November 8, 2026, the version this site publishes is SBCGS-C v1.5, SBCGS-M v1.4, SBCGS-T v1.4. This record passed twelve decisions, and they did not all reach that version. The SBCGS session reports that of the 31 items the three November 8, 2026 sessions passed, one reached a published version of a standard. That item is from this record: a condition added to SBCGS-C section 106(f)(1) and published as SBCGS-C v1.5. One other item this record passed, a new classification named Deceptive skill representation, is not in any published version. The SBCGS session reports that it did not draft that item because the case it describes is already classified under SBCGS-C section 106(g)(2) and its name attributes intent. That is the drafter's decision and not the committee's. A conflict resolution round held by the parent board on November 8, 2026 settled conflicts between items passed across the three sessions, and is published as a record on this page under the title SBCGS Standards Committee, conflict resolution round, November 8, 2026. The SBCGS session's account of what became of each item is its own and is not published on this site. Twelve of fifteen proposals passed and three failed. Which of this record's own decisions survived is not established by this record. Whether and when an adopted decision appears in a published version is decided separately from the vote. The date is part of the statement. This page is not rebuilt when a new version of the Standards is published.

Check your download

sha256 114de36cdb49a86abb7e0f70c85439f2cc5495836c13a7528cac58e7db64960c

That is the digest of the file published here. It lets you confirm your download matches what we served. It is not evidence that the record is unaltered, because we computed it. A reader who wants that needs the hash chain, which this record does not have.

sha256sum sbcgs-2026-11-08-c.md
shasum -a 256 sbcgs-2026-11-08-c.md

Download this record as the committee produced it, byte for byte. The page below is that file rendered for reading; the download is the file itself, which is the form to use if you want to check it against anything.

New to this? How the standards are made explains who sits on these committees and how a proposal becomes an amendment. The record follows in full, exactly as the committee produced it.

SBCGS Standards Committee - Session Minutes

Date: 2026-11-08 Board: skillgames-2026-11-C Documents reviewed: SBCGS-C v1.4, Classification Standard | SBCGS-M v1.4, section list only (titles, not the text) | SBCGS-T v1.4, section list only (titles, not the text) 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. Of the three suggestions you make, at most ONE may be aimed at a document that is

not before you in this session; the other two must address the document in session.

Adopted 2026-10-02 on a poll of the seats, 9 of 10 seat answers and the chair.

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: - Drafting replacement language for a provision in a document that is not before you. Each session holds one document in full; the others appear only as a section list, titles and no text. Name the section, say what your change does to it and why it needs attention, and leave the drafting to the session that holds it. In the October 2026 meeting 8 of 33 approved items were replacement text for provisions the seats had never read, and none of them could be applied. - "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 is not tied to a specific method of measurement, making it difficult for regulators to verify compliance. This change would ensure that the rate is based on real-world player behavior, not just theoretical models. Evidence: Section 106(g)(1) of SBCGS-C explicitly mentions the skill realization rate as a threshold for classifying a product as a "demonstrated skill product," but does not define how it should be measured. This aligns with the Institute’s own identification of the skill realization rate as a threshold that requires further evidence (Appendix C of SBCGS-C). --- - S002: Amend SBCGS-M § 502 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 in SBCGS-M § 502 does not clearly require the inclusion of general operating costs in the calculation of charitable yield, which can lead to misrepresentation of the actual amount going to charitable purposes. This change would ensure transparency and consistency in how charitable yield is reported. Evidence: Section 107(d)(1)(iii) of SBCGS-C currently includes a similar requirement, but the same language is not mirrored in SBCGS-M § 502, creating a potential inconsistency across the SBCGS family of standards. This was previously proposed in S003, which was rejected due to lack of supporting evidence, but new evidence now supports it based on the Institute’s own Appendix C and the need for alignment across documents. --- - S003: Amend SBCGS-T § 823(a) and 823(f) to require that the returns view must be reachable without a prerequisite action and presented upon commitment of consideration, and that neither return may be suppressed without the other. Rationale: Without clear requirements for the presentation of returns, players may be misled about the potential outcomes of their play. This change ensures that players are not disadvantaged by hidden or conditional information about the returns they may receive. Evidence: SBCGS-T § 823(a) and 823(f) were amended in the November 2026 working draft to impose this requirement, and the amendment was supported by recent enforcement actions in the gaming industry, such as those by the AGCO in Ontario, which emphasized the importance of clear and enforceable standards in game certification and approval processes.

The Test Laboratory (ollama:qwen3:14b) - S004: Amend SBCGS-T § 815 to require that all skill elements be tested for accessibility using a standardized player interface simulation tool that mimics the average player's interaction speed, accuracy, and decision-making patterns, and that the results be recorded in the laboratory report. Rationale: This ensures that the skill accessibility conditions are objectively measured rather than argued, aligning with the need for consistent, testable, and replicable results across laboratories. Evidence: SBCGS-C § 106(e)(4) defines the skill time cost ratio and requires that it not exceed 20, but does not specify how this ratio should be tested or measured. The Nevada Gaming Control Board's Gaming Lab Wireframe emphasizes the importance of standardized testing procedures for replicability and consistency. --- - S005: In SBCGS-T § 813, require that the return at absent skill be computed using a standardized simulation method that disables all skill elements and applies a default player behavior profile, with the results documented in the laboratory report. Rationale: This ensures that the return at absent skill is calculated in a consistent and unambiguous manner, preventing discrepancies between laboratories and ensuring that the outcome randomness can be verified using open-source or publicly available tools. Evidence: SBCGS-T § 812(c) requires that simulation requirements be tested using open-source or publicly available tools for outcome randomness, and the Nevada Gaming Control Board's Proposed Revisions to Technical Standards emphasize the importance of replicable and verifiable simulation outputs. --- - S006: Amend SBCGS-T § 816 to require that all skill events be instrumented with timestamped logs that capture the player’s engagement with each skill element, including the time taken, the actions performed, and the outcome of the skill element, with this data included in the laboratory report. Rationale: This ensures that the skill realization rate can be accurately measured from real player data, rather than relying on theoretical or laboratory-based assumptions. It supports the measurement of skill realization as defined in SBCGS-C § 106(f). Evidence: SBCGS-C § 106(f) defines the skill realization rate as the proportion of plays in which a player engaged an available skill element to completion, and SBCGS-T § 816 requires instrumentation of skill events. The Nevada Gaming Control Board's Gaming Lab Wireframe highlights the importance of detailed logging for accurate certification and reporting.

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: Small, volunteer-run organizations lack the resources to compute and verify charitable yield independently, which creates a compliance burden that may prevent them from continuing operations. Evidence: S007 (passed in Session 2026-10-01); external intel indicates that small organizations may depend on operator-provided data for compliance with SBCGS-M § 502(b). --- - 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: Volunteer-run organizations may not have dedicated compliance staff, but they can still meet the requirements of the standard with trained volunteers. Evidence: S008 (passed in Session 2026-10-01); external intel highlights the need for clarity on how volunteer-run organizations can fulfill compliance obligations in the absence of full-time staff. --- - S009: Insert the following text into SBCGS-M § 502: "Licensed organizations with annual gross gaming revenue below $500,000 may request that the covered operator include in the quarterly report a statement of the charitable yield percentage for each quarter, and may rely on that statement for internal record-keeping and disclosure purposes, provided that the statement is accurate and verifiable." Rationale: This would allow small organizations to meet the requirement for recording and disclosing charitable yield without independently computing it, aligning with their operational realities. Evidence: External intel; SBCGS-M § 502(b) already permits reliance on operator reports for gross gaming revenue and deductions, and this suggestion extends that reliance to the charitable yield percentage.

The Player Advocate (ollama:qwen3.5:9b) - S010: In SBCGS-C § 106(e)(4), replace the condition "the skill time cost ratio does not exceed 20" with "the skill time cost ratio is zero (i.e., the opportunity to engage the skill element is available simultaneously with the opportunity to commit consideration for a further play)." Rationale: A limit on a device that cannot tie to an identity protects no one if the player can simply walk to the next venue. The current "20" threshold creates a technical loophole where operators disable or delay the skill feature until after the base play resolves, ensuring high retention but guaranteeing the skill element is inaccessible at the critical moment of commitment (Gate 3). This renders the accessibility requirement effectively useless for a player standing in front of the device who may be in financial difficulty. Evidence: SBCGS-C § 106(e)(4) currently allows a ratio up to 20, permitting a delay between play completion and skill engagement. The standard's own Prefatory Note states it asks "whether a player is exposed to the harms," but a feature available only after the loss is committed cannot mitigate that harm in real-time. Recent enforcement actions (e.g., PointsBet, Ontario) highlight failures to intervene during play; a delayed skill element fails this test by design. - S011: In SBCGS-C § 106(g)(1), amend the definition of "Demonstrated skill product" to require that the skill influence range be not less than five percentage points calculated over a configuration where the skill element is simultaneously available at commitment, and add a new classification: "Deceptive skill representation," which applies to any product where a skill representation is made but the skill influence range at commitment is zero. Rationale: The current thresholds allow a "nominal" or "deceptive" skill product to slip through as long as the feature exists in theory, provided it isn't used immediately. This satisfies the regulator and lab (who check for the feature's existence) while defeating the player (who receives no benefit from the skill at the moment of loss). The standard must distinguish between a product where skill actually influences outcome at commitment versus one where it is merely a post-play gimmick to satisfy classification tests. Evidence: SBCGS-C § 106(g)(1) defines "Demonstrated skill product" based on thresholds that do not explicitly demand simultaneous availability. Appendix A, Note on "The device with the skill feature disabled," acknowledges that disabled configurations are material to § 106 but allows enabled-but-delayed configurations to exist. The CFPB enforcement against Enova (Nov 2023) underscores that authorization without honoring extensions is an unfair practice; similarly, offering a skill element only after the loss is an unfair practice disguised as a "skill game." - S012: In SBCGS-C § 107(d)(1)(iii), amend the exclusion for "general operating costs" to remove the phrase "except where applicable law expressly treats such costs as a charitable purpose" and replace it with "except where the licensed organization is a veterans post whose premises constitute its mission," explicitly excluding all other general operating costs including premises, utilities, insurance, and compensation from the charitable yield calculation. Rationale: This change ensures that for every product classified as charitable, the "charitable yield" actually tells the player how much of their money reaches the purpose versus covering rent or staff salaries. Currently, a veterans post might claim its entire rental value is charitable, but a fraternal club claiming its building costs are charitable creates the same exposure without the same justification. By limiting the exception strictly to veterans posts (where the building is the mission), we force all other operators to disclose what portion of the player's money pays for the lights and staff, preventing the illusion that "donations" cover overhead. Evidence: SBCGS-C § 107(d)(1)(iii) currently allows a broad exception for general operating costs unless law says otherwise. The session history (S012) previously added an exception for veterans posts but left the door open for others via "applicable law." New Jersey's initiatives and Ohio fines (Jan 2023) show regulators scrutinize whether advertising implies support that is diluted by overhead. If a player thinks they are funding a charity, but $90 of every $100 goes to rent, the representation is misleading regardless of what state law says about "net proceeds."

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 not be sufficient to ensure that a meaningful proportion of players actually engage with skill elements, which could undermine the integrity of the skill-based classification and expose players to misleading representations. Evidence: The October 2026 meeting saw this suggestion fail, but new data from SBCGS-T v1.4 working draft (Section 815(b)) highlights the importance of clear, enforceable metrics in plain language to avoid ambiguity and ensure compliance. Additionally, SBCGS-C Appendix C explicitly invites comment on the skill realization rate threshold, suggesting that the standard is open to revision based on new evidence. --- - S014: 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: This exclusion would ensure consistency in the calculation of charitable yield and prevent the misrepresentation of how much of a player’s money actually reaches a charitable purpose, which is critical for transparency and trust. Evidence: This suggestion was previously rejected in Session 2026-10-01 due to concerns about flexibility and potential conflicts with state-specific law. However, the SBCGS-M v1.4 working draft (Section 502) now explicitly addresses the need for a charitable yield floor, and the SBCGS-C Appendix C invites comment on the treatment of operating costs, indicating that this is a priority for clarification. --- - S015: Amend SBCGS-T § 815(b) to require that all skill-related descriptions be in plain language and avoid undefined terms of art, with specific guidance on what constitutes a "term of art" for the purposes of this section. Rationale: The current language may lead to inconsistent interpretations of skill features, which can result in non-compliance or ambiguity in testing and enforcement. Clear definitions are essential to ensure that operators, laboratories, and regulators are aligned. Evidence: SBCGS-T v1.4 working draft (Section 815(b)) explicitly mandates that descriptions be in plain language and avoids undefined terms of art. This aligns with the mission of reducing ambiguity and ensuring clarity for all parties involved.


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: Amend SBCGS-M § 502 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.
  • S003: Amend SBCGS-T § 823(a) and 823(f) to require that the returns view must be reachable without a prerequisite action and presented upon commitment of consideration, and that neither return may be suppressed without the other.
  • S004: Amend SBCGS-T § 815 to require that all skill elements be tested for accessibility using a standardized player interface simulation tool that mimics the average player's interaction speed, accuracy, and decision-making patterns, and that the results be recorded in the laboratory report.
  • S005: In SBCGS-T § 813, require that the return at absent skill be computed using a standardized simulation method that disables all skill elements and applies a default player behavior profile, with the results documented in the laboratory report.
  • S006: Amend SBCGS-T § 816 to require that all skill events be instrumented with timestamped logs that capture the player’s engagement with each skill element, including the time taken, the actions performed, and the outcome of the skill element, with this data included in the laboratory report.
  • 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 may request that the covered operator include in the quarterly report a statement of the charitable yield percentage for each quarter, and may rely on that statement for internal record-keeping and disclosure purposes, provided that the statement is accurate and verifiable."
  • S010: In SBCGS-C § 106(e)(4), replace the condition "the skill time cost ratio does not exceed 20" with "the skill time cost ratio is zero (i.e., the opportunity to engage the skill element is available simultaneously with the opportunity to commit consideration for a further play)."
  • S011: In SBCGS-C § 106(g)(1), amend the definition of "Demonstrated skill product" to require that the skill influence range be not less than five percentage points calculated over a configuration where the skill element is simultaneously available at commitment, and add a new classification: "Deceptive skill representation," which applies to any product where a skill representation is made but the skill influence range at commitment is zero.
  • S012: In SBCGS-C § 107(d)(1)(iii), amend the exclusion for "general operating costs" to remove the phrase "except where applicable law expressly treats such costs as a charitable purpose" and replace it with "except where the licensed organization is a veterans post whose premises constitute its mission," explicitly excluding all other general operating costs including premises, utilities, insurance, and compensation from the charitable yield calculation.
  • S013: Amend SBCGS-C § 106(g)(1) to increase the skill realization rate threshold from 0.20 to 0.30.
  • S014: 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.
  • S015: Amend SBCGS-T § 815(b) to require that all skill-related descriptions be in plain language and avoid undefined terms of art, with specific guidance on what constitutes a "term of art" for the purposes of this section.

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.

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.

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 amendment provides a clear, measurable method for determining the skill realization rate, ensuring consistency across products and configurations. The requirement for data from at least 100 unique players over 90 days makes the pass condition observable and replicable by any competent laboratory.
The Licensed Organization Eileen Cortland, SA YES This amendment provides a clear, measurable method for determining the skill realization rate, ensuring that it is based on real player data rather than theoretical models. This supports enforceability by regulators and testability by laboratories.
The Player Advocate Theodore Gilliam, SA YES The requirement for a 90-day data window creates an untestable lag that allows operators to manipulate short-term retention metrics while failing the player standing at the device in financial crisis.
The Operator Danny Sokolov, SA YES This amendment provides a clear, measurable standard for the skill realization rate that aligns with the operational realities of the installed base, ensuring that regulators can verify compliance using real-world data without requiring hardware upgrades or changes to existing devices.

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

Votes on S002: Amend SBCGS-M § 502 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.

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.

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 While the intent to improve transparency in charitable yield is valid, the suggested amendment introduces a policy-based condition ("unless explicitly excluded by applicable law") that is not testable or enforceable in a uniform manner across jurisdictions. This creates ambiguity for laboratories and regulators trying to apply the standard consistently.
The Licensed Organization Eileen Cortland, SA YES This change improves transparency and consistency in how charitable yield is calculated by explicitly requiring the inclusion of general operating costs, unless legally excluded. It clarifies the expectations for licensed organizations and supports accurate reporting.
The Player Advocate Theodore Gilliam, SA NO This suggestion attempts to redefine "charitable yield" by mandating the inclusion of overhead costs, which is technically satisfiable but practically useless because it offers no protection to an anonymous player who will not read a sentence about accounting methodology.
The Operator Danny Sokolov, SA NO While the intent is to improve transparency, this amendment assumes that all licensed organizations have the capacity to track and report general operating costs in a way that is not already addressed by the standards. It may also create compliance burdens for small or volunteer-run organizations that are not explicitly accounted for in the language.

Result: 1 YES / 3 NO / 1 ABSTAIN → 25% (threshold: 51%) → FAILED

Votes on S003: Amend SBCGS-T § 823(a) and 823(f) to require that the returns view must be reachable without a prerequisite action and presented upon commitment of consideration, and that neither return may be suppressed without the other.

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.

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 raises an important concern about the visibility of returns to players, but the language is not sufficiently precise in defining what constitutes a "prerequisite action" or how "commitment of consideration" should be interpreted in practice. Without further clarification, the test procedure and pass conditions remain ambiguous.
The Licensed Organization Eileen Cortland, SA YES Requiring that returns be presented upon commitment of consideration ensures that players are not misled by hidden or conditional information, aligning with the need for clear, enforceable, and player-protective standards.
The Player Advocate Theodore Gilliam, SA ABSTAIN While presenting returns upon commitment is ideal, this proposal lacks a specific citation to the existing section text and risks failing the "no new document" constraint if it requires drafting entirely new language rather than amending existing clauses.
The Operator Danny Sokolov, SA ABSTAIN The suggestion raises a valid concern about player transparency, but it does not specify whether the current language in SBCGS-T § 823(a) and 823(f) is ambiguous or unenforceable, which is necessary to determine whether this change is needed and how it would affect the existing fleet of devices.

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

Votes on S004: Amend SBCGS-T § 815 to require that all skill elements be tested for accessibility using a standardized player interface simulation tool that mimics the average player's interaction speed, accuracy, and decision-making patterns, and that the results be recorded in the laboratory report.

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment introduces a specific, testable method for evaluating skill accessibility, ensuring consistency across laboratories and enforceability by regulators.
The Test Laboratory Marcus Brennan, SA ABSTAIN I authored this suggestion; recusing per committee rules.
The Licensed Organization Eileen Cortland, SA YES This amendment ensures that skill accessibility is objectively measured using standardized tools, which supports consistent, replicable, and testable results across laboratories.
The Player Advocate Theodore Gilliam, SA NO Requiring labs to test accessibility via a standardized simulation tool is an administrative burden that satisfies the regulator and lab but does nothing to stop an operator from disabling skill elements after the player has already committed their money.
The Operator Danny Sokolov, SA YES Standardizing the testing method for skill accessibility ensures objective, replicable results, reducing ambiguity for laboratories and operators.

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

Votes on S005: In SBCGS-T § 813, require that the return at absent skill be computed using a standardized simulation method that disables all skill elements and applies a default player behavior profile, with the results documented in the laboratory report.

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment provides a standardized method for calculating return at absent skill, making it verifiable and reducing discrepancies between laboratories.
The Test Laboratory Marcus Brennan, SA ABSTAIN I authored this suggestion; recusing per committee rules.
The Licensed Organization Eileen Cortland, SA YES Standardizing the method for calculating the return at absent skill ensures consistency and clarity, which supports verification by laboratories and transparency for players.
The Player Advocate Theodore Gilliam, SA YES Computing return at absent skill using a standardized simulation method ensures the laboratory can objectively verify the randomness of the game, preventing operators from hiding behind unverifiable theoretical models when a distressed player is actually playing.
The Operator Danny Sokolov, SA YES A standardized method for calculating return at absent skill ensures consistency and verifiability, preventing discrepancies between laboratories.

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

Votes on S006: Amend SBCGS-T § 816 to require that all skill events be instrumented with timestamped logs that capture the player’s engagement with each skill element, including the time taken, the actions performed, and the outcome of the skill element, with this data included in the laboratory report.

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES Requiring timestamped logs ensures that skill engagement is accurately recorded and verifiable, supporting the measurement of skill realization as defined in SBCGS-C.
The Test Laboratory Marcus Brennan, SA ABSTAIN I authored this suggestion; recusing per committee rules.
The Licensed Organization Eileen Cortland, SA YES Requiring timestamped logs of skill engagement supports accurate measurement of the skill realization rate and aligns with the definitions and requirements in SBCGS-C, ensuring consistency across the standards. S007: — [you authored this - do not vote] S008: — [you authored this - do not vote] S009: — [you authored this - do not vote]
The Player Advocate Theodore Gilliam, SA NO Instrumenting every skill event with timestamped logs satisfies the letter of the law for compliance auditors but fails the practical test of whether an anonymous player in difficulty will ever see or understand this data before they are already spent.
The Operator Danny Sokolov, SA YES Instrumenting skill events with timestamped logs provides clear, traceable data for measuring skill realization rates, aligning with the requirements in SBCGS-C § 106(f).

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."

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment addresses the operational reality of small organizations by providing a clear, manageable method for compliance without requiring them to independently calculate charitable yield.
The Test Laboratory Marcus Brennan, SA NO The suggestion introduces a new mechanism that may not be enforceable or testable, and it creates a potential loophole for compliance without sufficient oversight.
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-reported revenue alleviates a burden that is technically satisfied by a simple quarterly statement, ensuring volunteer-run groups can continue operating without needing independent accounting staff.
The Operator Danny Sokolov, SA YES This allows small organizations to meet compliance requirements without the burden of independent computation, aligning with their operational realities.

Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (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."

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment recognizes the reality of volunteer-run organizations and provides a feasible mechanism for compliance through trained volunteers.
The Test Laboratory Marcus Brennan, SA NO The suggestion introduces a new mechanism for compliance that is not testable or measurable, and it may create inconsistencies in how different organizations meet their obligations.
The Licensed Organization Eileen Cortland, SA ABSTAIN I authored this suggestion; recusing per committee rules.
The Player Advocate Theodore Gilliam, SA NO Permitting a single trained volunteer to oversee all internal controls satisfies the form of the requirement but leaves the player unprotected if that volunteer lacks the expertise to detect evasion tactics used at the device.
The Operator Danny Sokolov, SA YES It recognizes the operational structure of volunteer-run organizations and provides a feasible path to compliance through trained volunteers.

Result: 2 YES / 2 NO / 1 ABSTAIN → 50% (threshold: 51%) → FAILED

Votes on S009: Insert the following text into SBCGS-M § 502: "Licensed organizations with annual gross gaming revenue below $500,000 may request that the covered operator include in the quarterly report a statement of the charitable yield percentage for each quarter, and may rely on that statement for internal record-keeping and disclosure purposes, provided that the statement is accurate and verifiable."

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment allows small organizations to rely on accurate, verifiable statements from the covered operator, reducing their compliance burden.
The Test Laboratory Marcus Brennan, SA NO The suggestion introduces a new mechanism that may not be enforceable or testable, and it may create inconsistencies in how different organizations meet their obligations.
The Licensed Organization Eileen Cortland, SA ABSTAIN I authored this suggestion; recusing per committee rules.
The Player Advocate Theodore Gilliam, SA YES This amendment allows small organizations to rely on operator statements for compliance, which is technically satisfied by receiving a document and practically useful for those lacking resources to compute charitable yield independently.
The Operator Danny Sokolov, SA YES This allows small organizations to rely on the covered operator for accurate and verifiable charitable yield reporting, reducing their compliance burden.

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

Votes on S010: In SBCGS-C § 106(e)(4), replace the condition "the skill time cost ratio does not exceed 20" with "the skill time cost ratio is zero (i.e., the opportunity to engage the skill element is available simultaneously with the opportunity to commit consideration for a further play)."

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment corrects a critical loophole by aligning the skill time cost ratio with the actual player experience, ensuring that skill is available at the moment of commitment.
The Test Laboratory Marcus Brennan, SA YES The amendment addresses a critical flaw in the current threshold by aligning it with the actual moment of player commitment, ensuring that the skill element is accessible when it matters most.
The Licensed Organization Eileen Cortland, SA YES This amendment corrects a critical loophole in the current standard by ensuring that the skill element is available simultaneously with the opportunity to commit consideration. This aligns the standard with the intent of protecting players and ensuring meaningful skill engagement.
The Player Advocate Theodore Gilliam, SA ABSTAIN I authored this suggestion; recusing per committee rules.
The Operator Danny Sokolov, SA YES The current threshold is effectively meaningless in practice, as it allows skill features to be delayed until after the player commits consideration. Replacing it with a zero threshold ensures skill is available at the critical moment.

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

Votes on S011: In SBCGS-C § 106(g)(1), amend the definition of "Demonstrated skill product" to require that the skill influence range be not less than five percentage points calculated over a configuration where the skill element is simultaneously available at commitment, and add a new classification: "Deceptive skill representation," which applies to any product where a skill representation is made but the skill influence range at commitment is zero.

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment strengthens the definition of "demonstrated skill product" and introduces a necessary classification to prevent deceptive representations that mislead players.
The Test Laboratory Marcus Brennan, SA YES The amendment clearly distinguishes between products that genuinely offer skill influence and those that merely appear to, ensuring that players are not misled by deceptive representations.
The Licensed Organization Eileen Cortland, SA YES This amendment introduces a meaningful distinction between products that actually allow skill to influence outcomes and those that merely include a skill feature for classification purposes. It supports clarity, enforceability, and player protection.
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 critical loophole where skill features exist in theory but are not usable at the moment of commitment, ensuring the standard protects players and aligns with the intent of the classification.

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

Votes on S012: In SBCGS-C § 107(d)(1)(iii), amend the exclusion for "general operating costs" to remove the phrase "except where applicable law expressly treats such costs as a charitable purpose" and replace it with "except where the licensed organization is a veterans post whose premises constitute its mission," explicitly excluding all other general operating costs including premises, utilities, insurance, and compensation from the charitable yield calculation.

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment clarifies the exclusion of general operating costs from charitable yield, ensuring transparency and preventing misrepresentation of how player funds are used.
The Test Laboratory Marcus Brennan, SA YES The amendment clarifies the exclusion of general operating costs from charitable yield, ensuring that the calculation accurately reflects how much of a player’s money reaches the intended charitable purpose.
The Licensed Organization Eileen Cortland, SA YES This change ensures that charitable yield accurately reflects the portion of player money that reaches a charitable purpose, rather than being inflated by general operating costs. It provides a clear exception for veterans posts and prevents misleading claims by other operators.
The Player Advocate Theodore Gilliam, SA ABSTAIN I authored this suggestion; recusing per committee rules.
The Operator Danny Sokolov, SA YES This change prevents the misrepresentation of charitable yield by clearly excluding general operating costs from the calculation, ensuring players understand how much of their money actually reaches charitable purposes.

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.

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA NO Increasing the threshold without evidence of its necessity or impact on player experience or regulatory enforceability risks creating a standard that is not grounded in reality.
The Test Laboratory Marcus Brennan, SA NO Increasing the threshold may not be supported by evidence and could create a new ambiguity in how the skill realization rate is measured or verified.
The Licensed Organization Eileen Cortland, SA NO While increasing the threshold may seem to improve the integrity of the skill-based classification, the proposal does not provide sufficient justification or evidence that the current threshold is insufficient or misleading. The standard must be based on tested and evidenced thresholds, not assumptions.
The Player Advocate Theodore Gilliam, SA NO Raising the skill realization rate threshold to 0.30 is a numerical adjustment that technically satisfies the requirement with more data points but does not change the fact that an operator can still evade it by timing the skill feature to appear after commitment.
The Operator Danny Sokolov, SA ABSTAIN I authored this suggestion; recusing per committee rules.

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

Votes on S014: 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.

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment ensures that charitable yield is calculated consistently and transparently, preventing the misrepresentation of how much of a player’s money goes to actual charitable purposes.
The Test Laboratory Marcus Brennan, SA YES The amendment ensures that general operating costs are consistently excluded from charitable yield, preventing misrepresentation and ensuring transparency for players.
The Licensed Organization Eileen Cortland, SA YES This amendment ensures that charitable yield is calculated consistently and transparently, without allowing general operating costs to be counted as charitable. It strengthens the clarity and trustworthiness of the standard.
The Player Advocate Theodore Gilliam, SA YES Explicitly excluding general operating costs from charitable yield ensures that the figure reported actually tells the player how much goes to charity versus overhead, preventing operators from satisfying the requirement by inflating the denominator with rent and salaries.
The Operator Danny Sokolov, SA ABSTAIN I authored this suggestion; recusing per committee rules.

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

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.

Seat Synthetic agent (not a person) Vote Reason
The Regulator Adele Sandoval, SA YES This amendment promotes clarity and consistency by requiring skill descriptions to be in plain language, making them more accessible and easier to enforce.
The Test Laboratory Marcus Brennan, SA YES The amendment provides clear guidance on the use of plain language for skill-related descriptions, ensuring consistency and clarity in testing and enforcement.
The Licensed Organization Eileen Cortland, SA YES Requiring skill-related descriptions to be in plain language and defining what constitutes a "term of art" ensures clarity and consistency for operators, laboratories, and regulators, reducing ambiguity in testing and enforcement.
The Player Advocate Theodore Gilliam, SA NO Requiring plain language descriptions satisfies the regulator but does not protect the player standing at the device who may be too distressed to read fine print or understand undefined terms of art before making a decision.
The Operator Danny Sokolov, SA ABSTAIN I authored this suggestion; recusing per committee rules.

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


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. 4 0 1 100% ✓ PASSED
S002 Amend SBCGS-M § 502 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. 1 3 1 25% ✗ FAILED
S003 Amend SBCGS-T § 823(a) and 823(f) to require that the returns view must be reachable without a prerequisite action and presented upon commitment of consideration, and that neither return may be suppressed without the other. 1 0 4 100% ✓ PASSED
S004 Amend SBCGS-T § 815 to require that all skill elements be tested for accessibility using a standardized player interface simulation tool that mimics the average player's interaction speed, accuracy, and decision-making patterns, and that the results be recorded in the laboratory report. 3 1 1 75% ✓ PASSED
S005 In SBCGS-T § 813, require that the return at absent skill be computed using a standardized simulation method that disables all skill elements and applies a default player behavior profile, with the results documented in the laboratory report. 4 0 1 100% ✓ PASSED
S006 Amend SBCGS-T § 816 to require that all skill events be instrumented with timestamped logs that capture the player’s engagement with each skill element, including the time taken, the actions performed, and the outcome of the skill element, with this data included in the laboratory report. 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 1 1 75% ✓ 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 2 1 50% ✗ FAILED (tie)
S009 Insert the following text into SBCGS-M § 502: "Licensed organizations with annual gross gaming revenue below $500,000 may request that the covered operator include in the quarterly report a statement of the charitable yield percentage for each quarter, and may rely on that statement for internal record-keeping and disclosure purposes, provided that the statement is accurate and verifiable." 3 1 1 75% ✓ PASSED
S010 In SBCGS-C § 106(e)(4), replace the condition "the skill time cost ratio does not exceed 20" with "the skill time cost ratio is zero (i.e., the opportunity to engage the skill element is available simultaneously with the opportunity to commit consideration for a further play)." 4 0 1 100% ✓ PASSED
S011 In SBCGS-C § 106(g)(1), amend the definition of "Demonstrated skill product" to require that the skill influence range be not less than five percentage points calculated over a configuration where the skill element is simultaneously available at commitment, and add a new classification: "Deceptive skill representation," which applies to any product where a skill representation is made but the skill influence range at commitment is zero. 4 0 1 100% ✓ PASSED
S012 In SBCGS-C § 107(d)(1)(iii), amend the exclusion for "general operating costs" to remove the phrase "except where applicable law expressly treats such costs as a charitable purpose" and replace it with "except where the licensed organization is a veterans post whose premises constitute its mission," explicitly excluding all other general operating costs including premises, utilities, insurance, and compensation from the charitable yield calculation. 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 4 1 0% ✗ FAILED
S014 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. 4 0 1 100% ✓ PASSED
S015 Amend SBCGS-T § 815(b) to require that all skill-related descriptions be in plain language and avoid undefined terms of art, with specific guidance on what constitutes a "term of art" for the purposes of this section. 3 1 1 75% ✓ PASSED

Total: 15 suggestions reviewed. 12 passed. 3 failed.

Tied votes: S008 - no tiebreaker is configured for this board

S001 key rationales: - The Test Laboratory: This amendment provides a clear, measurable method for determining the skill realization rate, ensuring consistency across products and configurations. The requirement for data from at least 100 unique players over 90 days makes the pass condition observable and replicable by any competent laboratory. - The Licensed Organization: This amendment provides a clear, measurable method for determining the skill realization rate, ensuring that it is based on real player data rather than theoretical models. This supports enforceability by regulators and testability by laboratories. - The Player Advocate: The requirement for a 90-day data window creates an untestable lag that allows operators to manipulate short-term retention metrics while failing the player standing at the device in financial crisis. - The Operator: This amendment provides a clear, measurable standard for the skill realization rate that aligns with the operational realities of the installed base, ensuring that regulators can verify compliance using real-world data without requiring hardware upgrades or changes to existing devices.

S003 key rationales: - The Licensed Organization: Requiring that returns be presented upon commitment of consideration ensures that players are not misled by hidden or conditional information, aligning with the need for clear, enforceable, and player-protective standards.

S004 key rationales: - The Regulator: This amendment introduces a specific, testable method for evaluating skill accessibility, ensuring consistency across laboratories and enforceability by regulators. - The Licensed Organization: This amendment ensures that skill accessibility is objectively measured using standardized tools, which supports consistent, replicable, and testable results across laboratories. - The Operator: Standardizing the testing method for skill accessibility ensures objective, replicable results, reducing ambiguity for laboratories and operators.

S005 key rationales: - The Regulator: This amendment provides a standardized method for calculating return at absent skill, making it verifiable and reducing discrepancies between laboratories. - The Licensed Organization: Standardizing the method for calculating the return at absent skill ensures consistency and clarity, which supports verification by laboratories and transparency for players. - The Player Advocate: Computing return at absent skill using a standardized simulation method ensures the laboratory can objectively verify the randomness of the game, preventing operators from hiding behind unverifiable theoretical models when a distressed player is actually playing. - The Operator: A standardized method for calculating return at absent skill ensures consistency and verifiability, preventing discrepancies between laboratories.

S006 key rationales: - The Regulator: Requiring timestamped logs ensures that skill engagement is accurately recorded and verifiable, supporting the measurement of skill realization as defined in SBCGS-C. - The Licensed Organization: Requiring timestamped logs of skill engagement supports accurate measurement of the skill realization rate and aligns with the definitions and requirements in SBCGS-C, ensuring consistency across the standards. S007: — [you authored this - do not vote] S008: — [you authored this - do not vote] S009: — [you authored this - do not vote] - The Operator: Instrumenting skill events with timestamped logs provides clear, traceable data for measuring skill realization rates, aligning with the requirements in SBCGS-C § 106(f).

S007 key rationales: - The Regulator: This amendment addresses the operational reality of small organizations by providing a clear, manageable method for compliance without requiring them to independently calculate charitable yield. - The Player Advocate: Allowing small organizations to rely on operator-reported revenue alleviates a burden that is technically satisfied by a simple quarterly statement, ensuring volunteer-run groups can continue operating without needing independent accounting staff. - The Operator: This allows small organizations to meet compliance requirements without the burden of independent computation, aligning with their operational realities.

S009 key rationales: - The Regulator: This amendment allows small organizations to rely on accurate, verifiable statements from the covered operator, reducing their compliance burden. - The Player Advocate: This amendment allows small organizations to rely on operator statements for compliance, which is technically satisfied by receiving a document and practically useful for those lacking resources to compute charitable yield independently. - The Operator: This allows small organizations to rely on the covered operator for accurate and verifiable charitable yield reporting, reducing their compliance burden.

S010 key rationales: - The Regulator: This amendment corrects a critical loophole by aligning the skill time cost ratio with the actual player experience, ensuring that skill is available at the moment of commitment. - The Test Laboratory: The amendment addresses a critical flaw in the current threshold by aligning it with the actual moment of player commitment, ensuring that the skill element is accessible when it matters most. - The Licensed Organization: This amendment corrects a critical loophole in the current standard by ensuring that the skill element is available simultaneously with the opportunity to commit consideration. This aligns the standard with the intent of protecting players and ensuring meaningful skill engagement. - The Operator: The current threshold is effectively meaningless in practice, as it allows skill features to be delayed until after the player commits consideration. Replacing it with a zero threshold ensures skill is available at the critical moment.

S011 key rationales: - The Regulator: This amendment strengthens the definition of "demonstrated skill product" and introduces a necessary classification to prevent deceptive representations that mislead players. - The Test Laboratory: The amendment clearly distinguishes between products that genuinely offer skill influence and those that merely appear to, ensuring that players are not misled by deceptive representations. - The Licensed Organization: This amendment introduces a meaningful distinction between products that actually allow skill to influence outcomes and those that merely include a skill feature for classification purposes. It supports clarity, enforceability, and player protection. - The Operator: This amendment addresses a critical loophole where skill features exist in theory but are not usable at the moment of commitment, ensuring the standard protects players and aligns with the intent of the classification.

S012 key rationales: - The Regulator: This amendment clarifies the exclusion of general operating costs from charitable yield, ensuring transparency and preventing misrepresentation of how player funds are used. - The Test Laboratory: The amendment clarifies the exclusion of general operating costs from charitable yield, ensuring that the calculation accurately reflects how much of a player’s money reaches the intended charitable purpose. - The Licensed Organization: This change ensures that charitable yield accurately reflects the portion of player money that reaches a charitable purpose, rather than being inflated by general operating costs. It provides a clear exception for veterans posts and prevents misleading claims by other operators. - The Operator: This change prevents the misrepresentation of charitable yield by clearly excluding general operating costs from the calculation, ensuring players understand how much of their money actually reaches charitable purposes.

S014 key rationales: - The Regulator: This amendment ensures that charitable yield is calculated consistently and transparently, preventing the misrepresentation of how much of a player’s money goes to actual charitable purposes. - The Test Laboratory: The amendment ensures that general operating costs are consistently excluded from charitable yield, preventing misrepresentation and ensuring transparency for players. - The Licensed Organization: This amendment ensures that charitable yield is calculated consistently and transparently, without allowing general operating costs to be counted as charitable. It strengthens the clarity and trustworthiness of the standard. - The Player Advocate: Explicitly excluding general operating costs from charitable yield ensures that the figure reported actually tells the player how much goes to charity versus overhead, preventing operators from satisfying the requirement by inflating the denominator with rent and salaries.

S015 key rationales: - The Regulator: This amendment promotes clarity and consistency by requiring skill descriptions to be in plain language, making them more accessible and easier to enforce. - The Test Laboratory: The amendment provides clear guidance on the use of plain language for skill-related descriptions, ensuring consistency and clarity in testing and enforcement. - The Licensed Organization: Requiring skill-related descriptions to be in plain language and defining what constitutes a "term of art" ensures clarity and consistency for operators, laboratories, and regulators, reducing ambiguity in testing and enforcement.


5. Completion

Timestamp: 2026-11-08T20:36:44+00:00 Configured actions: report, publish

  • report OK: report present and current at /mnt/d/tools/apps/skillgames/logs/2026-11/C/report.md
  • publish OK: pass list published to /mnt/d/tools/apps/skillgames/logs/2026-11/C/published/latest.json (and skillgames-2026-11-C-2026-11-08.json)