[Inserted] “Site Controller” means a computer system, including, but not limited to all devices and components that are utilized to support such a computer system, which is dedicated to the electronic accounting, reporting and monitoring of electronic game cards and player terminals; and to the storage and transmission of electronic game cards to the player terminals.  A site controller must meet the same requirements as a Central System.  The only difference is that Site Controllers are installed at the sites where electronic pull-tabs are sold.  Site controllers will communicate directly with a central system to download packs ("Game Subsets") of electronic game cards ("Tickets") and upload sales, inventory, and event data.  It would then distribute the game cards to the player terminals upon request.  The site controller will also change the status of all connected player terminals in response to receiving an instruction from its central system.

[Comment: Instead of specifying a monolithic central system that communicates directly to every player terminal, it would be beneficial to allow some flexibility.  For example, the functionality of the central system could be broken out.  The regulations should not preclude the use of a "site controller."  This would be a system that meets the security requirements of a central system, but would reside within the site selling electronic pull-tabs.  Such a configuration would cut communication costs, improve availability of the games to the players, and is completely compatible with GLI-14.]

[Part II, Section C, Item 1] 

[Deleted] A supplier may lease, rent or sell, distribute or otherwise provide charitable gaming supplies or equipment intended to be used in the conduct of charitable gaming to an organization that expects to generate gross receipt of $25,000 or less in any 12-month period, providing that the amount of such purchase would not be reasonably expected to generate more than $25,000 in gross receipts.  For each such organization, the supplier shall maintain the name, address and telephone number.  The supplier shall also obtain a written and signed statement from a director, officer or game manager of such organization confirming that gross receipts are expected to be $25,000 or less.  Such statement shall be dated and kept on file with the supplier for a period of three years from the end of a fiscal year.  The supplier or manufacturer shall not offer to lease, lease, offer to rent, rent, offer to sell, sell, distribute or otherwise provide electronic games of chance systems to an organization that expects to generate gross receipts of $25,000 or less in any 12-month period.

[Comment: This restriction would absolutely prohibit the electronic pull-tab program from ever getting off the ground.  Each site would be limited to just $68 in sales per day (on average).  Such a limit will prevent charitable organizations from realizing the level of benefits envisioned by the sponsors of this legislation.]

[Part II, Section K] 

[Edited] The department shall set manufacturing and testing criteria for all electronic bingo devices, electronic games of chance system, player terminals and other equipment used in the conduct of charitable gaming.  An electronic bingo device, electronic games of chance system, player terminal and other equipment used in the conduct of charitable gaming shall not be sold, leased or otherwise furnished to any person in the Commonwealth of Virginia for use in the conduct of charitable gaming until an identical sample device containing identical proprietary software has been approved by an independent testing facility, which has been formally recognized by the department as an independent testing facility that upholds the standards of integrity established by the department.  The recognized independent testing facility must certify that the device, system, terminal and equipment conforms, at a minimum, to the restrictions, standards and conditions set forth in these regulations.  Once the recognized independent testing facility submits the test results to the department, the department will either approve or disapprove the submission and inform the manufacturer of the results of its decision within thirty business days.  If any such device, system, terminal or equipment does not meet the department’s criteria, it shall not be distributed in the Commonwealth of Virginia.  The cost of testing shall be borne by the manufacturer of such device, system, terminal or equipment.  The department may require additional testing of a device, system, terminal or equipment at any time to ensure it continues to meet construction standards and to allow for fair play.  Such tests shall be borne by the manufacturer of such device, system, terminal or equipment, unless otherwise stated in these regulations.  If there is evidence that a piece of software, terminal, or other previously tested piece of equipment in use in Virginia is no longer in compliance with charitable gaming laws and regulations, the department may require additional testing of the component in question.  If the testing reveals that the characteristics or functionality of the component has changed to the point that it is no longer compatible with charitable gaming laws and regulations, the cost of the additional testing shall be born by the manufacturer of the device, system, terminal or equipment.  If the component is found to have remained consistent with charitable gaming laws and regulations, the cost of the additional testing shall be born by the department.  

[Comment: Provides some incentive for the department to be selective in requests for retesting.]

[Part III, Section E, Item 1] 

[Edited] Upon the request of the player terminal, the central system or site controller shall dispense a card from an electronic game card subset, which meets the standards set forth in 11 VAC 15-31-30 (N) of the Supplier Regulations.

[Comment: Edited to allow for the use of Site Controllers.]