Responsible Gaming Presentation to the Nevada Gaming Commission

OVERVIEW

Objective: To propose minimum Responsible Gaming requirements for intranet or Internet casinos licensed and operating from the jurisdiction of Nevada that would allow such casinos to maintain market competitiveness while addressing the social concerns presented by interactive gaming.

For the purpose of this proposal the term 'Responsible Gaming' refers to an industry initiative that:

- promotes individual and community awareness of problem gambling
- encourages personal responsibility for individual gambling behavior
- provides access to problem gambling information and resources

Developed by: IGTF, Interactive Gaming Task Force, subcommittee for responsible gaming comprised of problem gambling resource and treatment professionals, casino operators, university faculty, government officials, financial services providers and interested others.

Method: The subcommittee reviewed a list of possible approaches to Responsible Gaming. Various systems in use in national and international jurisdictions both in the bricks and mortar sector and the interactive sector were considered. (Appendix I is a partial list.) The advantages and disadvantages of each were discussed and evaluated based upon the group's experience and expertise. This includes the limited scientific data that exists, as well as the lack of scientific research in most areas. Proposed and existing regulations in other jurisdictions were considered. The result is an initial set of recommendations developed in light of the information currently available. As interactive gaming develops, these recommendations should be re-evaluated considering new data on the effects of interactive gaming, new technology that would modify the operation of interactive gaming, or new law or policy that would apply to interactive gaming.

Recommendations: The Subcommittee divided their recommendations into three general sectors (which are detailed below):

I. A jurisdiction-wide database accessible to licensees for players to establish personal preferences, including self-banning or other self-limitation, to be proposed as a requirement.

II. Responsible Gaming Operations to be proposed as requirements:
a. Login procedures
b. Session requirements
c. Site requirements

III. Propose the establishment of an educational website designed to provide Responsible Gaming information and to identify resources.

DISCUSSION

I. Jurisdiction-wide database

Definition: This database, established and maintained by a trusted and impartial third party, would enable all Nevada interactive licensees to access and support certain player-elected options.

Each interactive casino would be required by regulations to interface to a database to comply with a player's self-imposed limitations on play. (This is an overall database selection, and is not associated with a 'session' as much as it is associated with the person).

Each time a person logs into a casino, this database would be checked and selected options implemented. For example, if a person elected a time limitation or an loss amount limitation on play, the player would be denied access when that limitation was reached.

Rationale: According to treatment professionals, self-chosen limitation tools may be a useful option for players attempting to cut back or control their gambling behavior. The fact that a limitation system relies on choices made by the player is preferred over limitations placed on play by the operator or other external entity. Treatment professionals have taken the position that if an individual wants to engage in gambling to his or her own personal detriment, the individual will find a way around artificial barriers placed by well-intentioned third parties. Helpful limitation tools that can be managed by the player allow the player to take personal responsibility for the limitation effort.

Procedure: During the registration process for any online casino, a menu of Responsible Gaming options would be explained and available to the player prior to the start of any actual gambling. These options include but are not limited to:

a) Self-ban for a specified period of time and a link to the jurisdiction database to enroll;
b) Self-imposed loss limits for shorter specified periods of time;
c) Self-imposed session time limits; and
d) An option to restrict marketing contact by the casino.

These options are explained and available to the customer at time of registration. Throughout play sessions, these options are available via a link on any page and may be accessed at will by the customer. In an effort to increase awareness of these options, random reminders may be given to players upon login or as periodic banners. Once established by a player, these options may be modified to be more restrictive at any time, but may only be made less restrictive once certain requirements are met; i.e., a pre-determined interval of time passes before a less restrictive change can be made.

As an alternative, a person may contact the Nevada Council on Problem Gambling, an individual casino or other approved 3rd party to self-ban for a specified period without going through the online registration process.

 

Additional Operator specified options may be included and presented in conjunction with these Responsible Gaming options, and will be addressed later in this document under 'session options'.

II. Operating Requirements

Definition: Options and requirements that are recommended to be implemented and managed by the Internet casino Operator.

Rationale: The rationale mentioned above applies. Additionally, providing direct access to a statistical display of the customer's play activity may assist the player in making informed choices regarding self-imposed limits.

Login procedures: At each login attempt, the jurisdiction-wide database must be checked by the Operator to determine if a player has self-banned using the jurisdiction database or self -imposed other limitations with the operator before play may begin. If a person has elected options, an instant message acknowledging the options will be displayed. If a player has not elected options, they will be taken directly to the casino area or other area designated by the operator. It is recommended however, that to increase awareness of these options, random reminders be given to players upon login, and (intervals/specifics to be determined).

Session Options: A session is defined to begin after a person has successfully logged in and ends when a person exits the casino. Certain options are recommended to be available to a person prior to and during play that are session specific, including, but not limited to:
· Session time limit
· Session loss limit
· Statistical display reflecting the player's activity at the casino by time period, such as session, day, week, month, year, including but not limited to: money played, net win/loss, elapsed time.

In the event that the player has elected limits in the jurisdictional database, the jurisdictional database option selections take precedence.

Site Requirements: A player preferences or options button is displayed and may be triggered at any time during play, allowing a player to elect overall jurisdictional options or session options.

III. Responsible Gaming Informational Website

It is recommended that all remote interactive casino players have access to an informational site maintained by a trusted third party. This site will include approved information on obtaining help for problem gambling or related issues. It should include appropriate 800#s for information and assistance, website locators, etc. A link to this site will be provided at sign up and login and will be accessible at all times through the options button. The Responsible Gaming informational site will open in another browser window.

SUMMARY

The Subcommittee on Responsible Gaming gave thoughtful and informed consideration to many approaches to Responsible Gaming during the development of this proposal. Approaches that have not been included in these recommendations were rejected in some cases due to insufficient research or evidence on point. Other recommendations were debated but not recommended because the Subcommittee believed them to be ill-founded, burdensome, unnecessarily intrusive, irrelevant or some combination thereof.

Approaches that were considered but not recommended include:

a) Mandatory gaming limits of any kind,
b) Play intervention automatically triggered [based on] by play patterns or losses;
c) Mandatory time outs
d) Cash out options automatically triggered [given] by [at times of] wins
e) Low maximum account funding amounts [at time of each funding of account] to slow play.

While the Subcommittee has not recommended these approaches for inclusion in this universal industry initiative, individual Operators may elect to provide these or other approaches as additional player options within their casino environment.

A further recommendation of the Subcommittee is for support of ongoing research and evaluation of approaches to Responsible Gaming.

All recommendations by the Subcommittee have been offered with the belief that they support Responsible Gaming and will benefit interactive casino players, regulators and operators alike.

APPENDIX I

February 19, 2002

Meeting Objectives

A Discussion of potential mechanisms that can and should be used in Interactive Gaming.

To work toward a consensus that can be endorsed by all interested organizations and presented to regulators.

Some potential mechanisms for discussion:
1. Self-suspension of gambling privileges/self-ban from the site
Time periods?
2. Self-limit on gambling losses/budgeting
When should this kind of "budgeting" process take place?
Budgeting both time and money?
3. Loss thresholds that trigger certain screens or wedges
4. Limits on amount of money gambler can bet per hand/game
5. "Time outs" for the gambler
Regular and periodic?
Triggered by certain gambling patterns?
6. Problem gambling web site links on gambling sites
To whom?
Single consolidated web site link required on each screen?
7. Reporting or monitoring mechanism to keep gambler informed of his/her losses
8. Win threshold that suggests the gambler cash out after a win of a certain value
9. Signing up
Should it be mandatory?
Should it be voluntary, in the context of "responsible gaming"
10. Jurisdiction or national opt-in database that must be used by all licensed operators
11. Low maximum funding of account (e.g., no more than $20 at a time), thereby making it somewhat of a nuisance to keep funding the account after losses

Are any of these applicable or transferable to the brick and mortar gaming environment?
Are any of these applicable to intranet gaming?
Are any of these applicable to intrastate internet gaming?