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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations
  • James Maida, President
  • Paul Hogan, Manager of Regulatory Compliance


  • Gaming Laboratories International, Inc. (GLI)


  • www.gaminglabs.com
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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations
  • The term “Cashless”


    • A misnomer


    • Should be called “Cashful”


    • Any system that allows for or provides wagering with other than chips, tokens, or legal currency

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations
  • Cashless


    • Different systems
      • Automated Teller Machine (ATM) Transactions
      • Ticket-In/Ticket-Out (TITO)
      • Cashless
      • Bonus
      • Promotions

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - ATMs
  • The ATM system – One of the most controversial issues in United States gaming – Access bank account on gaming floor


  • Could be equally as problematic in  Europe – Limited vs. Unlimited gambling


  • Public policy issue – patrons gambling away life savings


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - ATMs
  • Nevada has establish technical standards – no regulations over ATM transactions at slots


  • Gambler Anonymous groups concerned about effect on addicted gamblers


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - ATMs
  • GLI certified a manufacturer to utilize an ATM interfaced to ticketing system – approved ATM transactions cause ticket to be generated
  • GLI worked with tribe to develop technical regulations based on Nevada’s new technical regulations and GLI 16
  • GLI worked with tribe’s Gaming Commission – the public policy concern


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - ATMs
  • ATM – Debits – Credit - Point of Sale Interface
  • Cashless Protocols (Communication  Languages)
    • The move away from “first generation” protocols to “second generation” protocols to track cashless transactions are very important.  ATM  transactions must be as bullet proof as a banking system
    • When banking system fails, transaction tracking is used.  Casino is no exception
    • The ability to lock out a game and wait until transaction is completed is as fundamental to cashless transaction processing as record locking is to database record processing

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - ATMs
  • ATM Standards
    • Ensure that gaming device will properly“process” an ATM transaction.
    • Ensure audit trails exist at each gaming device.
    • The patron must feel comfortable that an ATM transaction occurred.
    • The ATM system must be able to generate reports.
    • Patrons requesting funds must feel comfortable that no other person(s) will be capable of determining their account number and PIN?

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - ATMs
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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - TITO
  • Two types of ticketing Systems
    • Ticket Out
    • Bi-Directional


  • TicketIn/TicketOut (TITO)
    • TITO systems -  refer to slot machines with ticket printers that are interfaced to a validation system

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - TITO
  • Ticket Issuance


    • Tickets are issued when the patron requests the funds
    • A printer found inside the slot machine is used to generate ticket
    • Partial credit tickets may be automatically issued, if configured
    • Cashier booth used to pay off, if supported by validation system

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - TITO
    • Ticket Redemption


      • In all cases, redemption does not occur until validated by system
      • On-line - Tickets inserted in any slot machine interfaced with validation system
      • Cashier - Ticket information - validation number is entered by cashier and system validates


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - TITO

      • Tickets can be redeemed at “Redemption Kiosks” - devices that look like ATMs


      • Interfaced to validation system


      • Tickets presented must first be validated before cash dispensed


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - TITO
  • If validation system temporarily goes down and validation information cannot be provided
    • Must use system unique feature, or
    • alternate method of payment approved by regulators must be used


  • Trying to prevent fraud or accidental duplicate payments


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Cashless
  • Cashless System


    • Characterized as a host system where a player maintains an electronic account on the Casino’s cashless or host system
    • Allows patrons to pay for game play through the use of magnetic strip cards and player tracking units
    • Access to account via Personal Identification Number (PIN)

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Cashless

  • Patron places funds on deposit with casino cashier


  • Casino issues a magnetic strip card to the patron


  • Patron “withdraws” funds from the cashless system by placing card into player tracking unit, entering PIN, and requesting funds


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Cashless

  • Once patron completes play, funds are transferred back to account by
    • Patron placing card into player tracking unit
    • Requesting up-load of funds
    • System requires patron to input PIN
    • Funds are transferred to electronic account


  • Transactions are called “Electronic Funds Transfer” (EFT) - not credit card based


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Cashless
  • Cashless Standards


    • Configuring Cashless Transactions on a Gaming Device
    • Audit Trails for Cashless Transactions
    • Meter Requirements for Cashless Gaming Devices
    • Transaction Confirmation
    •  Error Conditions


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Cashless
  • Cashless Standards


    • Full Transfer of all Transactions
    • Modification of  Patron Information
    • Balance Adjustments
    • Security Levels
    • Prevention of Unauthorized Transactions
    • Diagnostic Tests on a Cashless Gaming Device
    • Financial and Player Reports
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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Bonuses

  • Bonus Award Systems


    • Bonus awards are additional pays to those described on the paytable (artwork or help screens)
    • Facilities now exist to support these awards at a gaming machine utilizing communications for direct credit transfers to the gaming machine as the patron is playing the device

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations -Bonuses
  • A bonus award is won based on:
    • A variable amount of play occurring on a group of participating gaming machines
      • multiplied jackpots - the host system instructs the gaming machine to multiply all wins within a specified range by a specified value
    • Achieving a winning combination during a specific time frame
      • an award is won when a percentage of play on participating gaming machines reaches a randomly selected value

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations -Bonuses
  • Bonus Standards


    • Configuring Bonus Transactions on a Gaming Device
    • Audit Trails for Bonusing Transactions
    • Meter Requirements for Bonusing Gaming Devices
    • Identifying a Bonusing Device



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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations -Bonuses
  • Bonus Standards


    • Notification of a Bonus Award
    • Communication Failures
    • Modification of Critical Parameters
    • Prevention of Unauthorized Transactions
    • Diagnostic Tests on a Bonusing Gaming Device




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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations -Bonuses
  • Bonus Standards


    • Financial Reports


    • Central System Random Number Generator


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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Promotions
  • Promotional Systems


    • Promotional awards - features that entitle players to special promotions based on patron’s play activities
    • Gaming devices that are configured to participate in electronically communicated promotional award payments from a host system, and the host system that controls the promotional award issuance parameters

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Promotions
  • Promotional Systems


    • Like bonus awards, facilities exist to support direct credit transfers from the marketing department or slot club department directly to the players’ cashless account as the patron is playing the device
    • Assumption is that the promotional credits will have no direct impact on the theoretical payback percentage

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Promotions
  • Awarded promotional credits need be metered uniquely to so that they will not affect the payback percentage


  • Different types of promotional awards exist -
    • Static awards - based on predefined criteria where patron play is not required for promotion
    • Non-static - based on predefined patron activity

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Promotions
  • Non- Static Promotions may include:


    • A patron is awarded 100 points for every $20 played in a slot machine - Points may be converted to credits that can be wagered
    • A patron who plays a predefined threshold ($200) during a predefined period (one day), receives an award ($10) for returning the next day

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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Promotions
  • Promotions Standards


    • Configuring Promotion Transactions on a Gaming Device
    • Audit Trails for Promotional Transactions
    • Meter Requirements for Promotional Gaming Devices
    • Error Conditions
    • Full Transfer of all Transactions
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International Association of Gaming Regulators – Cashless Wagering

Effects on Regulations - Promotions
  • Promotions Standards


    • Notification of a Promotional Award
    • Modification of Critical Parameters
    • Diagnostic Tests on a Promotional Gaming Device
    • Transaction Report
    • Removing Promotional Credits from a Players Account
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