SBCGS Standards Committee, Minimum Internal Control Standards, 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-m-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 6aa0c728f0858d1d2836fe383187c7f7dd4b5de92abcd222fcf13a8fd8a65b1e
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 ten 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. The SBCGS session reports that none of this record's decisions is in a published version, and that the one that reached one is from the SBCGS-C record. 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. Ten of fourteen proposals passed and four 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 10ca0c52a3c4e87df734f648aa5593f22b2ebec4c98418ee7d45426f60c7538b
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-m.md
shasum -a 256 sbcgs-2026-11-08-m.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-M Documents reviewed: SBCGS-M v1.4, Minimum Internal Control Standards | SBCGS-C 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-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 not enforceable or meaningful because it does not account for the full range of operational costs, allowing operators to meet the floor in name only while failing to deliver meaningful support to charitable purposes. This risks misleading players and undermining the integrity of the charitable representation. Evidence: The Institute has found no jurisdiction that states a floor on this basis, and publicly reported splits in this category, under which the host and the route operator each take about forty percent of profit, would not meet it. (Appendix A of SBCGS-M, “Matters on Which Comment is Invited,” and note to § 502(d)). --- - S002: Amend SBCGS-M § 401(d) to eliminate the cap on the aggregate of sessions conducted under limited anonymous play and instead require 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 of 20% of sessions at a device is not enforceable or testable, as it does not provide a clear, quantifiable threshold for regulators or laboratories to verify compliance. It also creates ambiguity in enforcement and fails to protect players who may be vulnerable to problem gambling. Evidence: The Test Laboratory previously rejected a similar suggestion in Session 2026-10-01, noting that replacing the cap with a requirement that anonymous sessions be limited to unconnected devices is not testable or enforceable. (History - member-regulator, Session 2026-10-01, S002). New evidence from the recent external intel shows that states like Nevada and Missouri are refining their standards to ensure greater transparency and accountability in anonymous play, which supports a stronger, more enforceable approach. --- - S003: Amend SBCGS-M § 202(d) to 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 small or volunteer-run ones, may lack the capacity or infrastructure to enforce exclusion and limit programs effectively. This creates a risk that exclusion lists are not enforced consistently or at all, leaving players vulnerable and undermining the effectiveness of these protections. Evidence: The Operator and the Licensed Organization previously rejected a similar suggestion in Session 2026-10-01, noting that it may undermine the ability to enforce exclusion and limit programs effectively. (History - member-regulator, Session 2026-10-01, S003). However, recent developments in state gaming regulations, such as those in Massachusetts, emphasize centralized enforcement mechanisms that are more robust and scalable, which supports a shift in enforcement responsibility to the covered operator or licensed organization.
The Test Laboratory (ollama:qwen3:14b) - S004: Amend SBCGS-T § 812(c) to clarify that simulation testing for configurations with a skill influence range below five percentage points must be conducted using a validated random number generator (RNG) and must include a statistical analysis of the simulation results at a confidence interval of ±0.15%. Rationale: This ensures that simulation testing is both reproducible and reliable across different laboratories, reducing ambiguity and ensuring that pass conditions are based on statistically valid outcomes rather than assumptions. Evidence: SBCGS-T v1.4 Working Draft, Section 812(c), which specifies simulation requirements for low-skill influence configurations. The requirement for a confidence interval of ±0.15% is consistent with ANSI/ASHRAE Standard 140-2020 Addendum B, which emphasizes the importance of statistical validation in simulation testing. - S005: Amend SBCGS-T § 813(b)(2) to require that the null strategy be explicitly defined in the device’s user interface and that it be verifiable through a test procedure that includes a player attempting the strategy without prior knowledge of the device's mechanics. Rationale: This ensures that the null strategy is not only defined but also observable and testable in practice, meeting the requirement that pass conditions be unambiguous and measurable. Evidence: SBCGS-T v1.4 Working Draft, Section 813(b)(2), which defines the null strategy as an act within the device's presentation. This aligns with the need for clarity in testing procedures, as highlighted in the October 2026 meeting where a similar suggestion was rejected due to lack of evidence but is now supported by recent updates to SBCGS-T. - S006: Amend SBCGS-T § 815(b) to require that all descriptions of skill elements be accompanied by an audio or visual demonstration of the skill element, ensuring that descriptions are not only in plain language but also demonstrable and accessible to players with varying levels of ability. Rationale: This enhances accessibility and ensures that descriptions are not merely theoretical but are practically verifiable, aligning with the requirements of the ADA Accessibility Standards and ensuring that all players can understand and engage with skill elements. Evidence: SBCGS-T v1.4 Working Draft, Section 815(b), which mandates that descriptions be in plain language. This aligns with the ADA Accessibility Standards, specifically Sections 404.2.4.4 and 404.2.5, which emphasize clear and measurable design criteria for accessibility.
The Licensed Organization (ollama:qwen3:14b) - S007: 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 change would reduce the administrative burden on small, volunteer-run organizations like veterans posts by enabling automated data processing, which is essential for accurate and timely computation of charitable yield. Evidence: S009, which was previously passed in Session 2026-10-01, aligns with this suggestion and reflects the practical challenges faced by small organizations in handling data manually. --- - S008: Amend SBCGS-M § 202(d) to clarify that a host location may rely on the covered operator to perform the enforcement of limits under § 302, the enforcement of an exclusion program under § 301, and the reporting of charitable yield under § 502, provided that the covered operator has documented procedures for each duty and supplies the host location with the records of its performance. Rationale: This would allow small, volunteer-run organizations to delegate certain compliance tasks to the operator, which is more feasible given the lack of dedicated compliance staff. Evidence: S008, passed in Session 2026-10-01, already supports this principle and highlights the need for flexibility in duty allocation for host locations with limited resources. --- - S009: Add a new subsection to SBCGS-M § 502(d) that allows the charitable yield floor to be calculated based on the average of the four most recent completed quarters, rather than the aggregate of those quarters. Rationale: This would make the charitable yield floor more attainable for small organizations by reducing the impact of outlier quarters and providing a more stable measure over time. Evidence: S007, passed in Session 2026-10-01, addresses this issue and supports the idea of using an average rather than an aggregate to determine compliance with the charitable yield floor.
The Player Advocate (ollama:qwen3.5:9b) - S010: Amend SBCGS-M § 304(a) to require that the disclosure of charitable yield 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: A player standing at a device with cash in hand is anonymous, may be in difficulty, and will not read anything longer than a sentence. Current § 304(a) allows disclosures to remain accessible "through a control identified on the primary display," which implies a menu interaction or scrolling action that defeats immediate protection for a distressed player who cannot stop to navigate menus. If they cannot see the charitable claim clearly before committing, the representation is false by operation of their inability to verify it. The requirement must be passive and instantaneous. Evidence: SBCGS-M § 304(a) currently states disclosures shall "remain accessible during play through a control identified on the primary display." NCPG Report findings indicate existing regulations often fail because they do not mandate sufficient, immediate protections. - S011: Amend SBCGS-M § 502(d) to require that charitable yield be computed 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: A limit tied to "gross" revenue is technically satisfied but practically useless for an anonymous player. An operator can deduct massive "operating costs" (device lease, monitoring fees, commissions to distributors, host location shares) before the money reaches charity, resulting in a tiny fraction of the player's actual loss going to the named beneficiary. If the yield is only 25% of gross, and an entity takes 40% of that gross as a fee for placing the device, the player effectively receives zero charitable benefit while being told they support a cause. This exposes the standards to defeat by substance over form. Evidence: SBCGS-M § 502(d) sets the floor at "twenty five percent for the four most recent completed quarters" without specifying net basis. Session 2026-10-01 Suggestion S010 passed a similar change, but the current text remains unchanged; re-proposing this is necessary to address the specific gap identified in Appendix B regarding charitable yield computation on gross vs. net. - S012: Amend SBCGS-M § 304(f)(4) to prohibit any statement implying play supports a charitable purpose unless the disclosure at the device explicitly states that the charitable share is computed on net proceeds, or prohibits the charitable representation entirely if the net yield falls below the adjusted floor. Rationale: A player told that play supports a veterans post has not been told that a share of it supports a lobbying campaign or administrative overhead that consumes the "charitable" portion before it leaves the operator's hands. Under SBCGS-M § 506(c)(3), proceeds cannot be used for lobbying, but the standards fail to prevent the representation that they are charitable when they are netted down by non-charitable expenses. This allows a requirement to be satisfied in form (lobbying is prohibited) while defeated in substance (the player's money never reaches the charity). The disclosure must match the economic reality of the play. Evidence: SBCGS-M § 506(c)(3) prohibits applying proceeds to lobbying, but does not mandate that the representation to the player reflect this limitation. NCPG findings highlight that regulations in jurisdictions like Delaware and Michigan do not mandate sufficient responsible gambling protections or transparency. The current standards allow "charitable representation" under SBCGS-C § 107(b) without ensuring the player understands the actual economic destination of their funds.
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 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 not aligned with how charitable yield is computed in existing frameworks, which typically deduct operational costs before calculating the share that reaches charitable purposes. This discrepancy creates ambiguity and may lead to compliance challenges for operators who are unable to meet the floor due to the way the metric is defined. Evidence: Appendix B of SBCGS-M lists the charitable yield floor in § 502(d) as a documented gap in existing regulation, noting that no source computes the fraction of the player’s money that reaches the purpose on the same basis. This aligns with the rejection note for S001 in the October 2026 session, which highlighted the functional meaninglessness of the floor if it does not account for operational costs. --- - 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 current allowance for limited anonymous play introduces ambiguity and potential enforcement challenges, particularly for small or volunteer-run host locations. By enforcing identity verification and limiting sessions to $50, the standard ensures consistency with the purpose of anonymous play while maintaining player protection and regulatory clarity. Evidence: Appendix B of SBCGS-M identifies the lack of enforceable identity verification in anonymous play as a documented gap, and the rejection note for S014 in the October 2026 session noted that verification requirements could be evaded by players. This suggests that stricter limits and verification measures are necessary to ensure compliance and player protection. --- - 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: The current prohibition does not cover indirect uses of charitable proceeds, such as political contributions or advocacy, which may undermine the integrity of the charitable representation made to players. Expanding the prohibition ensures that funds are used solely for charitable purposes as intended. Evidence: Appendix B of SBCGS-M identifies the lack of regulation on the use of charitable proceeds for political or advocacy purposes as a documented gap, and S015 from the October 2026 session was passed, supporting the expansion of the prohibition to include advocacy and political contributions.
2. Pool Phase
Leader actions: - S013 and S001 merged → S001 (authors credited: The Regulator, The Operator) Merge note: Identical proposal to amend SBCGS-M § 502(d) so the charitable yield floor deducts only device acquisition, leasing, servicing, monitoring, and financing costs rather than being computed on gross gaming revenue. Submitted independently by The Regulator (S001) and The Operator (S013) in nearly identical wording; S001 is kept as the base text. Both authors credited. - 13 suggestion(s) retained as submitted
Final pool: 14 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, S013; credited: The Regulator, The Operator)
- S002: Amend SBCGS-M § 401(d) to eliminate the cap on the aggregate of sessions conducted under limited anonymous play and instead require 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: Amend SBCGS-M § 202(d) to 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.
- S004: Amend SBCGS-T § 812(c) to clarify that simulation testing for configurations with a skill influence range below five percentage points must be conducted using a validated random number generator (RNG) and must include a statistical analysis of the simulation results at a confidence interval of ±0.15%.
- S005: Amend SBCGS-T § 813(b)(2) to require that the null strategy be explicitly defined in the device’s user interface and that it be verifiable through a test procedure that includes a player attempting the strategy without prior knowledge of the device's mechanics.
- S006: Amend SBCGS-T § 815(b) to require that all descriptions of skill elements be accompanied by an audio or visual demonstration of the skill element, ensuring that descriptions are not only in plain language but also demonstrable and accessible to players with varying levels of ability.
- S007: 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.
- S008: Amend SBCGS-M § 202(d) to clarify that a host location may rely on the covered operator to perform the enforcement of limits under § 302, the enforcement of an exclusion program under § 301, and the reporting of charitable yield under § 502, provided that the covered operator has documented procedures for each duty and supplies the host location with the records of its performance.
- S009: Add a new subsection to SBCGS-M § 502(d) that allows the charitable yield floor to be calculated based on the average of the four most recent completed quarters, rather than the aggregate of those quarters.
- S010: Amend SBCGS-M § 304(a) to require that the disclosure of charitable yield 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.
- S011: Amend SBCGS-M § 502(d) to require that charitable yield be computed 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.
- S012: Amend SBCGS-M § 304(f)(4) to prohibit any statement implying play supports a charitable purpose unless the disclosure at the device explicitly states that the charitable share is computed on net proceeds, or prohibits the charitable representation entirely if the net yield falls below the adjusted 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.
- 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.
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, enforceable method for computing the charitable yield floor by specifying which costs should be deducted, ensuring that the floor is meaningful and verifiable by regulators and laboratories. |
| The Licensed Organization | Eileen Cortland, SA | YES | This amendment directly addresses the issue of enforceability and meaningfulness of the charitable yield floor by aligning it with operational realities, which is essential for small organizations like veterans posts that depend on accurate and transparent calculations to maintain trust and compliance. |
| The Player Advocate | Theodore Gilliam, SA | YES | The current floor based on gross gaming revenue is practically useless because operators can deduct massive "operating costs" before the money reaches charity, so shifting to a basis that accounts for these costs ensures the representation isn't defeated in substance by form. |
| The Operator | Danny Sokolov, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
Result: 3 YES / 0 NO / 2 ABSTAIN → 100% (threshold: 51%) → PASSED
Votes on S002: Amend SBCGS-M § 401(d) to eliminate the cap on the aggregate of sessions conducted under limited anonymous play and instead require 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.
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 | The current cap is vague and untestable, and replacing it with a requirement that anonymous play be limited to unidentifiable sessions with no monitoring connection provides a clear, enforceable standard that protects players and ensures compliance. |
| The Licensed Organization | Eileen Cortland, SA | NO | While the intent to improve player protection is valid, replacing the 20% cap with a $50 limit and identity verification introduces new requirements that may be difficult for small host locations to implement consistently, especially without dedicated compliance staff or infrastructure. The original proposal focuses on clarity and testability, which is more aligned with the needs of volunteer-run organizations. |
| The Player Advocate | Theodore Gilliam, SA | NO | Requiring all anonymous play be unconnected to monitoring systems or removing caps creates an enforcement vacuum where vulnerable players cannot be identified or helped without a clear, testable threshold like a session limit. |
| The Operator | Danny Sokolov, SA | NO | While the intent to improve clarity is valid, the suggestion does not clearly define what "not identified" or "not connected to a monitoring system" means in enforceable terms, and it may shift ambiguity elsewhere without resolving the original issue of the 20% cap being untestable. |
Result: 1 YES / 3 NO / 1 ABSTAIN → 25% (threshold: 51%) → FAILED
Votes on S003: Amend SBCGS-M § 202(d) to 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.
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 valid concerns about the capacity of host locations, but it does not clearly specify how enforcement duties should be reallocated or what testable procedures would ensure compliance. Without a defined test or pass condition, it remains ambiguous for laboratories and regulators to apply. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | This suggestion raises important concerns about the capacity of small host locations to fulfill enforcement duties, but it does not fully address the broader question of how responsibilities can be shared or delegated in a way that remains compliant with the standards while respecting the operational limitations of volunteer-run organizations. More clarity on shared responsibilities and accountability is needed before a definitive vote can be cast. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | While host locations may lack capacity, simply shifting enforcement duties entirely to the operator does not solve the problem of immediate player protection at the device; I prefer delegating specific tasks with record-keeping rather than removing the duty entirely. |
| The Operator | Danny Sokolov, SA | ABSTAIN | The suggestion raises a valid concern about the capacity of host locations, but it does not clearly articulate how shifting enforcement duties to the operator or licensed organization would be implemented without creating new ambiguities or increasing the burden on those entities. More clarity is needed on the transition and responsibilities. |
Result: 0 YES / 0 NO / 5 ABSTAIN → 0% (threshold: 51%) → FAILED
Votes on S004: Amend SBCGS-T § 812(c) to clarify that simulation testing for configurations with a skill influence range below five percentage points must be conducted using a validated random number generator (RNG) and must include a statistical analysis of the simulation results at a confidence interval of ±0.15%.
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 | The clarification ensures that simulation testing is reproducible and statistically valid, providing a clear standard for laboratories to follow and regulators to verify compliance. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | The amendment improves the reliability and reproducibility of simulation testing, which is essential for consistent enforcement and verification by laboratories. |
| The Player Advocate | Theodore Gilliam, SA | YES | Requiring a validated RNG and specific confidence intervals for low-skill simulations ensures the testing is reproducible and prevents laboratories from passing devices based on assumptions that could be evaded by tweaking the simulation parameters. |
| The Operator | Danny Sokolov, SA | YES | Clarifying the use of a validated RNG and requiring statistical analysis improves the reliability and reproducibility of simulation testing, reducing ambiguity and ensuring consistent pass conditions across laboratories. |
Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED
Votes on S005: Amend SBCGS-T § 813(b)(2) to require that the null strategy be explicitly defined in the device’s user interface and that it be verifiable through a test procedure that includes a player attempting the strategy without prior knowledge of the device's mechanics.
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 the null strategy to be defined and testable in the user interface ensures it is observable and verifiable, meeting the requirement for unambiguous and measurable pass conditions. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | Requiring the null strategy to be explicitly defined and testable ensures that it is both observable and verifiable, enhancing clarity and compliance. |
| The Player Advocate | Theodore Gilliam, SA | NO | Defining the null strategy in the UI is technically satisfied but practically useless if a distressed player cannot stop to read it; this provision fails the test of whether protection reaches someone at the moment they need it most. |
| The Operator | Danny Sokolov, SA | YES | Requiring the null strategy to be explicitly defined and verifiable through a test procedure ensures that it is not only theoretical but also observable and measurable, meeting the requirement for unambiguous pass conditions. |
Result: 3 YES / 1 NO / 1 ABSTAIN → 75% (threshold: 51%) → PASSED
Votes on S006: Amend SBCGS-T § 815(b) to require that all descriptions of skill elements be accompanied by an audio or visual demonstration of the skill element, ensuring that descriptions are not only in plain language but also demonstrable and accessible to players with varying levels of ability.
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 | The requirement for an audio or visual demonstration of skill elements enhances accessibility and ensures that descriptions are not merely theoretical but are practically verifiable. |
| The Test Laboratory | Marcus Brennan, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Licensed Organization | Eileen Cortland, SA | YES | Requiring audio or visual demonstrations of skill elements improves accessibility and ensures that descriptions are not merely theoretical, aligning with broader standards for player understanding. |
| The Player Advocate | Theodore Gilliam, SA | YES | An anonymous player standing with cash will not read long descriptions, but a visual or audio demonstration provides immediate, passive information that actually reaches them before they commit, unlike text they are likely to ignore. |
| The Operator | Danny Sokolov, SA | YES | Requiring an audio or visual demonstration enhances accessibility and ensures that descriptions of skill elements are not merely theoretical but practically verifiable, aligning with broader accessibility standards. |
Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED
Votes on S007: 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.
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 | The amendment reduces administrative burdens by enabling automated data processing, making it more feasible for small organizations to comply with charitable yield requirements. |
| The Test Laboratory | Marcus Brennan, SA | YES | Requiring user-friendly data formats improves compliance feasibility for small organizations and ensures accurate computation of charitable yield. |
| 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 reduces the administrative burden on small organizations and ensures the charitable yield computation is accurate rather than relying on manual reconciliation that can be defeated by data errors. |
| The Operator | Danny Sokolov, SA | YES | This change would significantly reduce administrative burdens on small organizations by enabling automated data processing, making compliance more feasible and less error-prone. |
Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED
Votes on S008: Amend SBCGS-M § 202(d) to clarify that a host location may rely on the covered operator to perform the enforcement of limits under § 302, the enforcement of an exclusion program under § 301, and the reporting of charitable yield under § 502, provided that the covered operator has documented procedures for each duty and supplies the host location with the records of its performance.
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 | The suggestion relies on the covered operator to perform enforcement tasks, but without a centralized authority or defined procedures, it may not ensure consistent enforcement across host locations. |
| The Test Laboratory | Marcus Brennan, SA | YES | Clarifying that host locations can rely on the operator for enforcement tasks provides a practical solution for small organizations with limited compliance capacity. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | NO | Allowing host locations to rely solely on the operator for enforcement without independent verification creates a scenario where a player at a volunteer-run location has no immediate recourse if the operator fails, defeating the purpose of local oversight. |
| The Operator | Danny Sokolov, SA | YES | Allowing host locations to rely on the covered operator for certain enforcement tasks, provided they are documented and shared, is more practical for small or volunteer-run organizations with limited compliance resources. |
Result: 2 YES / 2 NO / 1 ABSTAIN → 50% (threshold: 51%) → FAILED
Votes on S009: Add a new subsection to SBCGS-M § 502(d) that allows the charitable yield floor to be calculated based on the average of the four most recent completed quarters, rather than the aggregate of those quarters.
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 | Calculating the charitable yield floor based on the average of the four most recent quarters provides a more stable and attainable measure for small organizations, reducing the impact of outlier quarters. |
| The Test Laboratory | Marcus Brennan, SA | YES | Using an average of the most recent four quarters reduces volatility and provides a more stable measure, making the charitable yield floor more attainable for small organizations. |
| The Licensed Organization | Eileen Cortland, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Player Advocate | Theodore Gilliam, SA | YES | Calculating the floor based on an average of recent quarters makes the requirement less susceptible to defeat by a single bad quarter and provides a more stable measure that protects players over time rather than requiring perfect quarterly performance. S010: [You authored this] PASS S011: [You authored this] PASS S012: [You authored this] PASS |
| The Operator | Danny Sokolov, SA | YES | Averaging the four most recent quarters provides a more stable and attainable measure for small organizations, reducing the impact of outlier quarters and making the charitable yield floor more meaningful. |
Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED
Votes on S010: Amend SBCGS-M § 304(a) to require that the disclosure of charitable yield 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.
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 the disclosure of charitable yield in a single sentence with high-contrast text ensures it is immediately visible to players, aligning with the intent to protect vulnerable players and provide clear, instant information. |
| The Test Laboratory | Marcus Brennan, SA | YES | Requiring a single-sentence, high-contrast disclosure at eye level ensures that players can immediately verify charitable claims without interaction, enhancing transparency and protection. |
| The Licensed Organization | Eileen Cortland, SA | YES | The amendment ensures that charitable yield disclosures are immediately visible and accessible to players, enhancing transparency and protecting vulnerable players. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | Requiring a single-sentence, high-contrast, immediately visible disclosure aligns with the needs of anonymous players in distress and ensures that the charitable representation is truly passive and verifiable at the point of play. |
Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED
Votes on S011: Amend SBCGS-M § 502(d) to require that charitable yield be computed 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.
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 charitable yield to be computed based on net proceeds ensures that the floor reflects the actual amount of money reaching charity, preventing misleading representations and ensuring meaningful support. |
| The Test Laboratory | Marcus Brennan, SA | YES | Basing the charitable yield on net proceeds rather than gross revenue ensures that players are accurately informed of the actual portion of their money going to charity. |
| The Licensed Organization | Eileen Cortland, SA | YES | Computing charitable yield based on net proceeds rather than gross revenue ensures that the standard reflects the actual amount of money reaching charity, making the requirement more meaningful and aligned with player expectations. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | Tying the charitable yield floor to net proceeds rather than gross revenue ensures that the actual amount reaching charity is meaningful, preventing the form of compliance from masking the substance of failure. |
Result: 4 YES / 0 NO / 1 ABSTAIN → 100% (threshold: 51%) → PASSED
Votes on S012: Amend SBCGS-M § 304(f)(4) to prohibit any statement implying play supports a charitable purpose unless the disclosure at the device explicitly states that the charitable share is computed on net proceeds, or prohibits the charitable representation entirely if the net yield falls below the adjusted floor.
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 | Prohibiting statements implying charitable support unless the disclosure explicitly states the net yield aligns the representation with the economic reality of the play, preventing misleading claims to players. |
| The Test Laboratory | Marcus Brennan, SA | YES | Prohibiting misleading charitable statements unless net yield is disclosed prevents the standards from being satisfied in form while defeated in substance. |
| The Licensed Organization | Eileen Cortland, SA | YES | Prohibiting misleading charitable claims unless they are explicitly tied to net proceeds prevents the misrepresentation of charitable support and ensures that disclosures match the economic reality of the play. |
| The Player Advocate | Theodore Gilliam, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
| The Operator | Danny Sokolov, SA | YES | Prohibiting misleading charitable representations unless they clearly state that the share is computed on net proceeds ensures that players are not misled by the economic reality of their play, maintaining the integrity of the charitable claim. |
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.
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 | The suggestion introduces a new requirement for identity verification and a $50 limit without specifying how it would be enforced or who would be responsible for verification, creating potential enforcement challenges. |
| The Test Laboratory | Marcus Brennan, SA | YES | Replacing the cap with a $50 limit and identity verification provides a clearer, enforceable standard that protects players and ensures compliance consistency. |
| The Licensed Organization | Eileen Cortland, SA | NO | The suggestion introduces a new financial limit and identity verification requirement that may not be feasible for all host locations and could create additional administrative burdens. |
| The Player Advocate | Theodore Gilliam, SA | NO | Limiting anonymous play to $50 without removing the session cap is inconsistent; if we want protection, we must either verify identity for all play or accept that some anonymity exists but keep the session limit as a testable, enforceable barrier against rapid loss. |
| The Operator | Danny Sokolov, SA | ABSTAIN | I authored this suggestion; recusing per committee rules. |
Result: 1 YES / 3 NO / 1 ABSTAIN → 25% (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.
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 | Expanding the prohibition on the use of charitable proceeds for political contributions or advocacy ensures that funds are used solely for charitable purposes, maintaining the integrity of the charitable representation made to players. |
| The Test Laboratory | Marcus Brennan, SA | YES | Expanding the prohibition to include political contributions and advocacy ensures that charitable proceeds are used solely for legitimate charitable purposes, preserving the integrity of the representation to players. |
| The Licensed Organization | Eileen Cortland, SA | YES | Expanding the prohibition on the use of charitable proceeds for political contributions or advocacy ensures that funds are used solely for charitable purposes, maintaining the integrity of the charitable representation made to players. |
| The Player Advocate | Theodore Gilliam, SA | YES | Expanding the prohibition to include political contributions ensures that the charitable representation made to an anonymous player is not undermined by indirect uses of proceeds that would defeat the integrity of the standard in substance. |
| 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
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. | 3 | 0 | 2 | 100% | ✓ PASSED |
| S002 | Amend SBCGS-M § 401(d) to eliminate the cap on the aggregate of sessions conducted under limited anonymous play and instead require 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. | 1 | 3 | 1 | 25% | ✗ FAILED |
| S003 | Amend SBCGS-M § 202(d) to 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 |
| S004 | Amend SBCGS-T § 812(c) to clarify that simulation testing for configurations with a skill influence range below five percentage points must be conducted using a validated random number generator (RNG) and must include a statistical analysis of the simulation results at a confidence interval of ±0.15%. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S005 | Amend SBCGS-T § 813(b)(2) to require that the null strategy be explicitly defined in the device’s user interface and that it be verifiable through a test procedure that includes a player attempting the strategy without prior knowledge of the device's mechanics. | 3 | 1 | 1 | 75% | ✓ PASSED |
| S006 | Amend SBCGS-T § 815(b) to require that all descriptions of skill elements be accompanied by an audio or visual demonstration of the skill element, ensuring that descriptions are not only in plain language but also demonstrable and accessible to players with varying levels of ability. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S007 | 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 |
| S008 | Amend SBCGS-M § 202(d) to clarify that a host location may rely on the covered operator to perform the enforcement of limits under § 302, the enforcement of an exclusion program under § 301, and the reporting of charitable yield under § 502, provided that the covered operator has documented procedures for each duty and supplies the host location with the records of its performance. | 2 | 2 | 1 | 50% | ✗ FAILED (tie) |
| S009 | Add a new subsection to SBCGS-M § 502(d) that allows the charitable yield floor to be calculated based on the average of the four most recent completed quarters, rather than the aggregate of those quarters. | 4 | 0 | 1 | 100% | ✓ PASSED |
| S010 | Amend SBCGS-M § 304(a) to require that the disclosure of charitable yield 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 |
| S011 | Amend SBCGS-M § 502(d) to require that charitable yield be computed 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 |
| S012 | Amend SBCGS-M § 304(f)(4) to prohibit any statement implying play supports a charitable purpose unless the disclosure at the device explicitly states that the charitable share is computed on net proceeds, or prohibits the charitable representation entirely if the net yield falls below the adjusted floor. | 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. | 1 | 3 | 1 | 25% | ✗ FAILED |
| 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. | 4 | 0 | 1 | 100% | ✓ PASSED |
Total: 14 suggestions reviewed. 10 passed. 4 failed.
Tied votes: S008 - no tiebreaker is configured for this board
S001 key rationales: - The Test Laboratory: This amendment provides a clear, enforceable method for computing the charitable yield floor by specifying which costs should be deducted, ensuring that the floor is meaningful and verifiable by regulators and laboratories. - The Licensed Organization: This amendment directly addresses the issue of enforceability and meaningfulness of the charitable yield floor by aligning it with operational realities, which is essential for small organizations like veterans posts that depend on accurate and transparent calculations to maintain trust and compliance. - The Player Advocate: The current floor based on gross gaming revenue is practically useless because operators can deduct massive "operating costs" before the money reaches charity, so shifting to a basis that accounts for these costs ensures the representation isn't defeated in substance by form.
S004 key rationales: - The Regulator: The clarification ensures that simulation testing is reproducible and statistically valid, providing a clear standard for laboratories to follow and regulators to verify compliance. - The Licensed Organization: The amendment improves the reliability and reproducibility of simulation testing, which is essential for consistent enforcement and verification by laboratories. - The Player Advocate: Requiring a validated RNG and specific confidence intervals for low-skill simulations ensures the testing is reproducible and prevents laboratories from passing devices based on assumptions that could be evaded by tweaking the simulation parameters. - The Operator: Clarifying the use of a validated RNG and requiring statistical analysis improves the reliability and reproducibility of simulation testing, reducing ambiguity and ensuring consistent pass conditions across laboratories.
S005 key rationales: - The Regulator: Requiring the null strategy to be defined and testable in the user interface ensures it is observable and verifiable, meeting the requirement for unambiguous and measurable pass conditions. - The Licensed Organization: Requiring the null strategy to be explicitly defined and testable ensures that it is both observable and verifiable, enhancing clarity and compliance. - The Operator: Requiring the null strategy to be explicitly defined and verifiable through a test procedure ensures that it is not only theoretical but also observable and measurable, meeting the requirement for unambiguous pass conditions.
S006 key rationales: - The Regulator: The requirement for an audio or visual demonstration of skill elements enhances accessibility and ensures that descriptions are not merely theoretical but are practically verifiable. - The Licensed Organization: Requiring audio or visual demonstrations of skill elements improves accessibility and ensures that descriptions are not merely theoretical, aligning with broader standards for player understanding. - The Player Advocate: An anonymous player standing with cash will not read long descriptions, but a visual or audio demonstration provides immediate, passive information that actually reaches them before they commit, unlike text they are likely to ignore. - The Operator: Requiring an audio or visual demonstration enhances accessibility and ensures that descriptions of skill elements are not merely theoretical but practically verifiable, aligning with broader accessibility standards.
S007 key rationales: - The Regulator: The amendment reduces administrative burdens by enabling automated data processing, making it more feasible for small organizations to comply with charitable yield requirements. - The Test Laboratory: Requiring user-friendly data formats improves compliance feasibility for small organizations and ensures accurate computation of charitable yield. - The Player Advocate: Requiring data in a user-friendly format reduces the administrative burden on small organizations and ensures the charitable yield computation is accurate rather than relying on manual reconciliation that can be defeated by data errors. - The Operator: This change would significantly reduce administrative burdens on small organizations by enabling automated data processing, making compliance more feasible and less error-prone.
S009 key rationales: - The Regulator: Calculating the charitable yield floor based on the average of the four most recent quarters provides a more stable and attainable measure for small organizations, reducing the impact of outlier quarters. - The Test Laboratory: Using an average of the most recent four quarters reduces volatility and provides a more stable measure, making the charitable yield floor more attainable for small organizations. - The Player Advocate: Calculating the floor based on an average of recent quarters makes the requirement less susceptible to defeat by a single bad quarter and provides a more stable measure that protects players over time rather than requiring perfect quarterly performance. S010: [You authored this] PASS S011: [You authored this] PASS S012: [You authored this] PASS - The Operator: Averaging the four most recent quarters provides a more stable and attainable measure for small organizations, reducing the impact of outlier quarters and making the charitable yield floor more meaningful.
S010 key rationales: - The Regulator: Requiring the disclosure of charitable yield in a single sentence with high-contrast text ensures it is immediately visible to players, aligning with the intent to protect vulnerable players and provide clear, instant information. - The Test Laboratory: Requiring a single-sentence, high-contrast disclosure at eye level ensures that players can immediately verify charitable claims without interaction, enhancing transparency and protection. - The Licensed Organization: The amendment ensures that charitable yield disclosures are immediately visible and accessible to players, enhancing transparency and protecting vulnerable players. - The Operator: Requiring a single-sentence, high-contrast, immediately visible disclosure aligns with the needs of anonymous players in distress and ensures that the charitable representation is truly passive and verifiable at the point of play.
S011 key rationales: - The Regulator: Requiring charitable yield to be computed based on net proceeds ensures that the floor reflects the actual amount of money reaching charity, preventing misleading representations and ensuring meaningful support. - The Test Laboratory: Basing the charitable yield on net proceeds rather than gross revenue ensures that players are accurately informed of the actual portion of their money going to charity. - The Licensed Organization: Computing charitable yield based on net proceeds rather than gross revenue ensures that the standard reflects the actual amount of money reaching charity, making the requirement more meaningful and aligned with player expectations. - The Operator: Tying the charitable yield floor to net proceeds rather than gross revenue ensures that the actual amount reaching charity is meaningful, preventing the form of compliance from masking the substance of failure.
S012 key rationales: - The Regulator: Prohibiting statements implying charitable support unless the disclosure explicitly states the net yield aligns the representation with the economic reality of the play, preventing misleading claims to players. - The Test Laboratory: Prohibiting misleading charitable statements unless net yield is disclosed prevents the standards from being satisfied in form while defeated in substance. - The Licensed Organization: Prohibiting misleading charitable claims unless they are explicitly tied to net proceeds prevents the misrepresentation of charitable support and ensures that disclosures match the economic reality of the play. - The Operator: Prohibiting misleading charitable representations unless they clearly state that the share is computed on net proceeds ensures that players are not misled by the economic reality of their play, maintaining the integrity of the charitable claim.
S015 key rationales: - The Regulator: Expanding the prohibition on the use of charitable proceeds for political contributions or advocacy ensures that funds are used solely for charitable purposes, maintaining the integrity of the charitable representation made to players. - The Test Laboratory: Expanding the prohibition to include political contributions and advocacy ensures that charitable proceeds are used solely for legitimate charitable purposes, preserving the integrity of the representation to players. - The Licensed Organization: Expanding the prohibition on the use of charitable proceeds for political contributions or advocacy ensures that funds are used solely for charitable purposes, maintaining the integrity of the charitable representation made to players. - The Player Advocate: Expanding the prohibition to include political contributions ensures that the charitable representation made to an anonymous player is not undermined by indirect uses of proceeds that would defeat the integrity of the standard in substance.
5. Completion
Timestamp: 2026-11-08T21:12:37+00:00 Configured actions: report, publish
- report OK: report present and current at /mnt/d/tools/apps/skillgames/logs/2026-11/M/report.md
- publish OK: pass list published to /mnt/d/tools/apps/skillgames/logs/2026-11/M/published/latest.json (and skillgames-2026-11-M-2026-11-08.json)