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Regulatory Reform David O. Stewart Ropes & Gray, LLP

Regulatory Reform David O. Stewart Ropes & Gray, LLP. Global Gaming Expo October 4, 2011. Current Climate Favors Regulatory Reform. Overhaul of New Jersey’s casino regulations (S.12) Nevada reform legislation (closing state testing lab, etc.)

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Regulatory Reform David O. Stewart Ropes & Gray, LLP

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  1. Regulatory ReformDavid O. StewartRopes & Gray, LLP Global Gaming Expo October 4, 2011

  2. Current Climate Favors Regulatory Reform • Overhaul of New Jersey’s casino regulations (S.12) • Nevada reform legislation (closing state testing lab, etc.) • Governor and NGCB both pressing for further reforms • Even the federal government is touting regulatory reform

  3. Our Process • AGA Regulatory Reform Working Group was established in spring 2011 • Target Audience:  State policymakers • Regulators, legislative leaders, governors, and senior executive staff • Strategy:  Generate a range of reform proposals • Some are relatively simple and less controversial  • Some seek more fundamental changes, as in New Jersey

  4. Process • Stage One:  Develop proposals through of the working group • Stage Two:  Prepare white paper, secure Board of Directors’ adoption, and disseminate it •  “IMPROVING GAMING REGULATION:  10 Recommendations for Streamlining Processes While Maintaining Integrity” • Stage Three:  Public education, lobbying and direct advocacy at the state level to seek adoption of reforms

  5. Licensing-related Recommendations • Move to gaming licenses without fixed terms, as in N.J. and Nev., or at least five-year terms • Secure wider adoption of standardized IAGR form for “personal history” for licensing of key employees • Also, develop standardized application form for licensing of business entities and reciprocity between jurisdictions • Allow for the waiver of licensing for institutional investors holding up to a 25 percent stake in a licensee, and automatic waiver up to 15 percent. • Require no more than registration of outside directors.

  6. Operations-related Recommendations • Authorize five-year shelf approvals of debt and equity offerings • Eliminate unnecessary reports to regulators • Foreign Gaming Reports (Nev.) • Loan Reports (Nev., Miss.) • Ownership reports (Ill., Ind., La.) • Quarterly Contract Reports (Ill., Ind., Mich.)

  7. Operations-related Recommendations • Update licensing practices • Request “employment-related” credit checks, not “credit-related” • Accept electronic fingerprint records from any law enforcement agency • Use video-conferencing for most licensing interviews of distant applicants • Eliminate licensing of non-gaming-related employees (hotel, food & beverage) • License applications should be presumed confidential. • Allow secure electronic filing of all regulatory submissions • Eliminate Prescribed Minimum Internal Control Standards (MICS) (Ill., Mo.)

  8. Electronic Gaming Machines • Eliminate prior approval or pre-notification of electronic gaming machine shipments • Eliminate pre-approval of machine modifications relating solely to the esthetic features of games • Artwork • Sounds

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