11-VAC-5-90-150 Slots

DD. 4. A facility operator may not authorize a manufacturer to remotely access a slot machine management system until its system access protocols are approved in writing by the department.

We are asking that once remote access is approved by the Department for a specific manufacturer that subsequent approvals are not necessary.

DD. 4. A facility operator may not authorize a manufacturer to remotely access a slot machine management system until its system access protocols are approved in writing by the department.  Such written approval by the Department shall be deemed to satisfy the requirement in subsection EE and subsequent approvals are not warranted.

11 VAC 5-90-170

O. Cards (entire subsection)

We contend generally that including too much detail in the regulation regarding cards would require significant staffing to ensure compliance and potentially restrict development of new game variations and adjustment to future market demands. Decks of cards have evolved to support the use of no-peek devices and the composition of decks of cards are constantly changing to suit new games or rules variations.  For example, Spanish 21 uses a 48 card deck of cards whereas Pai Gow Poker uses a 53 card deck of cards and there are games that use multiple decks of cards.  As cheating methods are discovered, card backs required immediate change as is seen with edge tracking.  In short, over-regulation now could prevent industry from progressing or developing future technologies as they would be banned by current regulation.

Accordingly, we would respectfully request a re-write of the section to include less specificity and allow for more flexibility to evolve.  Below is an example of how it could be drafted.

O. Cards

1. Approved cards and decks of cards;

A. Cards used in the casino for table game play must be submitted to the Department for approval based on;

• The proposed use of the cards
• The suitable design of the cards based on applicability for use on a designated game.
• The size
• The deck composition
• Any coloring specifications required for applicable game use
• Identification of origin

B. Cards and decks of cards may not be altered in any way from their approved form.

2. Cards must be received from the manufacturer in sealed containers or boxes.

3. The operator must submit a set of internal controls and procedures to the Department for approval regarding the receipt of card shipments.

4. The operator must submit a set of internal controls and procedures to the Department for approval regarding the secure storage of cards.

5. The operator must submit a set of internal controls and procedures to the Department for approval regarding the management of cards while on premises.  The controls should assure an auditable method of;

• Receipt
• Secure handling of cards
• Real time inventory
• Authorized access to cards for inventory or distribution
• Distribution process

6. The operator must submit a set of internal controls and procedures to the Department for approval regarding the process of opening a new game.  This should include;

• Delivery of the cards to the game
• Designated staff with authority levels
• Inspection of cards prior to play
• Hand and machine shuffled card games
• Pre-shuffled card games

7. The operator must submit a set of internal controls and procedures to the Department for approval regarding the process of closing a game.  This should include;

• Removal of the cards from play
• Transportation of card to used card storage.

8.  The operator must submit a set of internal controls and procedures to the Department for approval regarding the cancellation and destruction of cards.

9. The operator shall have procedures in place for dealing with damaged or missing cards.  Discrepancies should be noted in the shift log.

10. In the instance of a card or deck of cards not complying with approved standards, the instance should be brought to the attention of the Department.

11.  The operator must submit a set of internal controls and procedures to the Department for approval regarding the maximum duration of card usage or service life.  Specific areas that shall be addressed are;

• Hand shuffled games
• Machine shuffled games
• Pre-shuffled games
• Multi-deck games
• Plastic Cards

11 VAC 5-90-170
W. Roulette- Ball, Table, and Wheel Inspection; Security Procedures

W. 7. When a Roulette table is not open for play, the Roulette wheel shall be secured by a cover that is placed over the entire wheel and securely locked.

Operators are tasked with inspecting and balancing the wheel each time the game is opened and required to complete monthly maintenance logs.  Furthermore, the tables have dedicated surveillance coverage to aid in addressing tampering concerns.  The opening inspection, surveillance, and property personnel are all reinforcements to mitigate the risk of not having an additional lock placed on the wheel.

When a Roulette table is not open for play, the Roulette wheel shall be secured by a cover that is placed over the entire wheel and securely locked.

11 VAC 5-90-180 Inspecting Cards

Y. 2. After receiving one or more decks of cards at the table, the dealer shall inspect the cards for any defects and a floorperson assigned to the table shall verify the inspection.

3. After the cards are inspected, the dealer shall spread the cards out face up on the table, in horizontal fan shaped columns by deck according to suit and in sequence, for visual inspection by the first player to arrive at the table.

4. After the first player arriving at the table has been afforded an opportunity to visually inspect the cards, the dealer shall:

    (a) Turn the cards face down on the table;

    (b) Mix the cards thoroughly by washing them; and

    (c) Stack the cards.

5. After the cards have been stacked, the dealer shall shuffle them in accordance with subsection Z.

6. If an automated card shuffling device is utilized and two decks of cards are received at the table, each deck of cards shall be spread for inspection, mixed, stacked, and shuffled in accordance with subdivisions Y2-5.

Eliminating the need for the first patron to inspect fanned cards would allow the patron quicker play time instead of waiting 5-6 minutes for the shuffler.  The shuffler verifies with the camera.

Y.2. If the decks of cards received at the table are preinspected and preshuffled, the provisions of this subsection shall not apply After receiving one or more decks of cards at the table, the dealer shall inspect the cards for any defects and a floorperson assigned to the table shall verify the inspection.

 After the cards are inspected, the dealer shall spread the cards out face up on the table, in horizontal fan shaped columns by deck according to suit and in sequence, for visual inspection by the first player to arrive at the table.

After the first player arriving at the table has been afforded an opportunity to visually inspect the cards, the dealer shall:

    Turn the cards face down on the table;

     Mix the cards thoroughly by washing them; and

     Stack the cards.

3. After the cards have been stacked, the dealer shall shuffle them in accordance with subsection Z.

4. If an automated card shuffling device is utilized and two decks of cards are received at the table, each deck of cards shall be spread for inspection, mixed, stacked, and shuffled in accordance with subdivisions Y 2-35.

11 VAC 5-90-180 Table Game Procedures

T. Game rules; notice; wagers

5. A facility operator may not accept a bet at a table game in an amount less than $5 or more than $50,000.

Operators should be permitted to yield manage their table game offerings and accept bets in whatever dominations it determines, consistent with its internal controls and other requirements of the Act and its implementing regulations.

The $5 bet minimum bet is especially problematic on games where it is common practice to make multiple bets. For example, it would prevent a player from making a $5 bet on red/black in roulette as well as a separate $1 bet on a particular number.

5. A facility operator may not accept a bet at a table game in an amount less than $5 or more than $50,000.