Virginia Regulatory Town Hall
Agency
Department of Agriculture and Consumer Services
 
Board
Charitable Gaming Board
 
chapter
Supplier Regulations [11 VAC 15 ‑ 31]
Action Chapter 264 (2007 Acts of Assembly) added “electronic games of chance systems for charitable gaming in the Commonwealth”.
Stage NOIRA
Comment Period Ended on 9/30/2009
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9/29/09  12:25 pm
Commenter: Steven Fields, Oasis Gaming (a division of International Gamco, Inc.)

Suggested Changes for Proposed Electronic Pull-Tab Rules (Part 3)
 

[Part III, Section E, Item 4] 

[Edited] The central system shall not permit the alteration of any accounting or electronic log information that was properly communicated from the player terminal without supervised access control.  In the event financial data is changed, an automated electronic audit log shall record the following information: 

[Comment: In the event of a component failure, the recovery may rely on a manual process.  In such a case, there should be a standard form to be used to report the issue and the actions taken to correct.]

 

[Part III, Section E, Item 5]   

[Edited] The central system shall have a separate physical medium for securely storing deals of electronic game card on such a central system, which shall be mirrored in real time by a backup medium within the same cabinet or enclosure.  The central system shall also provide a means for storing duplicates of the deals of electronic game cards, which have already been transmitted to the player terminals, so as to reflect, on an ongoing basis, changes in the transmitted deals of electronic game cards as they occur.  In addition, duplicates of the deals of electronic game cards, as stored on the central system, shall may be stored within a secure enclosure at the gaming facility.  All storage shall be through an error checking, nonvolatile physical medium, so that if the primary storage medium should fail, then the functions of the central system and the process of auditing those functions can continue with no critical data loss.  The database shall be stored on redundant media so that no single failure of any portion of the central system would cause the loss or corruption of data.

[Comment: Where a Site Controller is used, packs or subsets of game cards are sent from a Central System to the Site Controller on-site.  The game cards are temporarily stored by the Site Controller until they are requested by the Player Terminals.]

 

[Part III, Section E, Item 12]   

[Edited] In those incidences in which the central system or components are linked with one another in a local network for the function of sharing or other purposes, communication protocols shall be used in a manner that ensures that erroneous data or signals will not adversely affect the operations of any such central system or components.  Dedicated and protected network connections, which prohibit unauthorized access, may allow multiple components of a central system to share information.  The details of electronic game cards that are prohibited from being displayed, as stated in these particular regulations, shall not be available or transmitted between the connected systems or gaming location. 

[Comment: This would seem to preclude transmitting game cards to the player terminals or sharing game data among two or more components of a central system.]

 

[Part III, Section E, Item 13]   

[Edited] One or more electronic accounting systems shall be required to perform reporting and other functions in support of the electronic game card game activities.  The electronic accounting system shall not interfere with the outcome of any gaming functions.  The electronic accounting system may communicate with the other computers utilizing the protocol standards set forth within these regulations provided the other computers have undergone initial laboratory testing and on-site certification where the communications are set-up and tested on the property prior to implementation. 

[Comment: This would seem to disallow web-based reports.  Web-based reporting would provide the DCG with secure yet flexible access to sales and system status information without the high costs of dedicated computers of systems.  Secure web-based applications are routinely deployed without needing to test every client system.]

 

[Part III, Section E, Item 14, Sub-item d] 

[Deleted] Liability report, which shall report the outstanding funds, which carry forward to following day.  At a minimum, such a report shall including the following information on a daily and monthly basis:

1)     Total amount of currency notes won by the players, but remain to be redeemed;

2)     Total amount of currency notes won by the players, but expired prior to redemption;

3)     Total amount of unused game plays and winnings that remain to be redeemed; and

4)     Total amount of unused game plays and winnings that expired prior to redemption. 

[Comment:  If validation is not required, this functionality can not be implemented.]

CommentID: 9978