For most of us in this industry, technical and communication standards are not the easiest subjects to discuss. Standards are varied, complex, mind-boggling, evolving, and even more so for i-gaming. But not to worry, CEM is here. We talked to those who do understand standards, and who work with them every day, to offer the rest of you some clarity on this murky topic. Trust me, it won’t hurt.
There are really two types of standards in gaming: technical standards and communication standards. The trouble is that sometimes they are incorrectly fused to create one confusing mess. So let’s sort them out first.
A technical standard is a regulatory standard, a requirement the machines, equipment and software must meet to be acceptable for a given jurisdiction. Technical standards vary from jurisdiction to jurisdiction and can take on many forms. In general, technical standards let manufacturers know what they have to do to their equipment and let laboratories know what to test to make sure that equipment is working as designed. As Drew Pawlak, vice president of business development for BMM Compliance, puts it, technical standards should be clear, just like building standards. Technical standards relate to components like math, art, functionality, security and the random number generator, as their primary job is to ensure the integrity of the game. Most technical standards do not cover things like player tracking or a player-user interface, for example, unless they affect the game outcome.
That’s where communication standards come in. Communication standards use input from technical standards, among other things, to create a protocol for the way pieces of equipment talk to each other. The two types of standards are related, but they are not one in the same. The Gaming Standards Association’s (GSA) Technical Director Marc McDermott explains, “We have the messaging structure to allow someone to comply with technical standards, because we’re able to move the information that’s required.”
When followed, communication standards allow computers to speak the same dialect of the same language, which can make amazing things happen for the operator and player.
Although GSA’s standards are not typically called for by law, that may soon be changing. Illinois recently put it onto law that the state will require GSA standards to be followed for its gaming equipment, which McDermott says is “a pretty powerful statement to make.” GSA standards are currently recommended by state regulatory agencies in Oregon, Alberta and Maryland.
Technical Standards
Technical standards are enacted after lawmakers meet and approve gaming statutes. Regulators, or agencies hired by them, take the laws and create a set of regulations, or administrative rules, that reflect the intent of the government and effectively implement the statutes in a more concise manner. Technical standards, in turn, are generally a category of the administrative rules and contain the technical aspects and attributes of gaming devices and systems. Technology is a major driver for statutes and standards.
People who write standards include employees of BMM Compliance, Eclipse Compliance Testing, Gaming Laboratories International, operators, manufacturers, gaming associations and governments. Chairman, President and CEO of BMM International Martin Storm says: “One of the myths to debunk here somehow is that there are only four people in the world who can do this. The truth is there are probably many, many people in the world who can write standards competently on the behalf of jurisdictions.”
Storm explains the process: “You’ve got to actually sit down and try to understand what their objectives are, what they’re trying to achieve … because there’s a lot of issues involved.”
Those issues could include cultural differences. Standard writers will talk with regulators about their objectives, issues, needs and goals. Because, as Storm says, “What one person thinks of as gambling and what another person thinks of as gambling are two completely different things.”
Richard Williamson, senior vice president of regulatory services at BMM Compliance, says once standards are written, there should be a formal adoption process to allow for comment. Williamson directed the New Jersey Division of Gaming Enforcement’s testing laboratory for more than 22 years and then went on to establish Pennsylvania’s test lab. He adds, “You never want to create rules in a vacuum, because you’re not ever going to anticipate everybody’s approach or everybody’s product.”
Williamson reminds us that even when you set standards and test for all of the critical items in a game, there is no guarantee that the game is going to be great. “You can’t really evaluate a game so thoroughly that to be 100 percent sure it’s going to be the perfect game when it hits the floor,” he notes. “Because by the time you finish, the next iteration of technology is coming out. So you have to take the best, educated approach to evaluate all the critical items.”
Storm believes one key to writing standards is that they need to be descriptive, as opposed to prescriptive: “Standards need to provide the right kind of environment for technology to deliver an engaging experience, and we shouldn’t be too prescriptive around how that should be done.” Storm sees standards developing more and more in this direction.
Once a standard is chosen, who owns it? Twenty three-year industry veteran Nick Farley, president of Eclipse Compliance Testing, advises regulators to make sure they put their name on their standard. Eclipse Compliance Testing is authorized in more than 200 jurisdictions and works with state and tribal governments.
Some regulatory agencies will adopt other jurisdictions’ standards in part or in whole. Farley says, “That’s fine for that day, but it’s always been our position that if a regulatory agency likes somebody else’s standard, then just use it as a model, borrow it and put your name on it. If changes down the road are made, regulators can accept them or not, depending on how they want to regulate their own jurisdiction.”
Jeff Jalovec, compliance manager at Eclipse Compliance Testing, adds, “This is one way to ensure that outside forces will not change a standard, leading to possible inadvertent consequences that could impact operators in a particular jurisdiction in a way not originally intended and that they’re not ready for.”
Williamson agrees, though he says claiming a standard as your own does not always happen. In some cases, small jurisdictions don’t have ongoing control over their standards. Williamson says, “If there is any change made to a rule, then the commission should be responsible for reviewing that and taking some formal action to accept any change that occurs therein.”
He says he understands that small operations just don’t have the exposure to technology to understand what some rules really mean. At that point, he wants people to start asking questions. It comes down to this, Pawlak says: “There’s lots of ways to approach standards, and each jurisdiction and each regulator needs to fundamentally approach them and say, ‘What do we want to do? How do we want to control this?’”
A Message to Regulators
Regulators have a daunting job, tasked with understanding the evolving world of standards. Some, Storm says, don’t realize just how vital their role is. “How they manage their technical standards, their internal controls, their statutes, how they handle reports, how they play their role is really critical,” he notes. “In the end, it’s better for the manufacturers if they do; it’s better for the operators if they do that. Because then the industry is professional, it’s clean. The players are protected, they come back to play more—and that’s in everybody’s best interest.”
Farley says most regulators understand their role and the purpose of regulating gaming, as well as their jurisdiction’s standards, but he has experienced working with some regulators and operators who rely too heavily on others, simply believing what they are told about standards. “It’s imperative that regulators and operators read their jurisdiction’s rules and standards, ask questions and seek clarification when necessary,” he notes.
Eclipse Business Manager Ron Rollins includes manufacturers in this responsibility, saying, “Manufacturers should also be keenly familiar with jurisdictional standards of target markets. Ultimately, these standards will need to be understood as they will have an effect somewhere, somehow on the conduct of gaming.”
New technology in gaming is just one reason regulators need to understand what they are working with. Current standards do not always support evolving technology. Farley explains: “We find that there are a lot of standards that were written many years ago, to the technology that was in place at that time. We find that most regulators want to work with the industry to try to advance those standards to keep up with the technology as it’s coming into the industry.”
Farley says he also believes many regulators do not fully understand jurisdictional transfers for compliance testing. The transfer of approvals is a matter of taking products that have already been approved in other markets with similar standards and then issuing approval letters for the same product in other jurisdictions. A jurisdictional transfer is a benefit to the manufacturer because it allows products to be approved faster, particularly in multiple jurisdictions. It’s also seen as a benefit to smaller regulatory agencies. Farley, however, says that its benefit to regulatory agencies is limited. Problems could arise if regulators do not realize they’re on the end of a transfer. Storm says many tribes understand this concept, but a lot of major regulators don’t. “It’s bad for the regulator because it tells you the regulators don’t realize how the industry works,” he explains. “It’s bad for the regulators in the sense that they wanted someone who could run 30 yards and they got someone who can run 50 yards. But clearly 30 is less than 50, so it must be OK, but is it really if they don’t even realize that nothing’s been tested to 30, but it’s been tested to something else? It’s shocking to realize that they don’t know what’s going on in their environment.”
Janice Farley, vice president of Eclipse Compliance Testing, believes the onus is on the lab to actually test to each jurisdiction. “To test to one jurisdiction’s requirements and say that that’s all encompassing, we think, could lead to unforeseen circumstances that no one may want to deal with,” he says. “A transfer may not have any problems ever.”
Williamson says if a transfer is in play, the lab should make sure it gives that information to regulators. The problem is, with pages and pages of documentation, that information might not be absorbed. “Getting regulators to turn past that third page is the difficult part,” he explains. “If they’re not going to do it, they’re not going to do it. You can give them all the information that you think they need, but are they going to read it, are they going to understand it? It’s a challenge.”
Looking to the future of land-based gaming technical standards, Nick Farley says there are many new concepts being introduced that regulators should watch for. One such concept that he sees becoming popular is slot machines that are coupled with skill-based bonus games, and he believes regulators should be proactive and learn about these types of games now. “I think it would be good to address such a matter, so that each player is assured an equal opportunity to win,” he says. “The game software in these games that include skill-based bonuses cannot prevent the player from obtaining any win once they get into the skill and dexterity-type rounds or games.”
A Message to Operators
The relationship between regulators and operators requires a delicate balance—one that operators do not want to throw off. Williamson says operators would approach him one-on-one to get their point across about a proposed standard they did not like. However, those who only approached him during public comment periods were careful and considerate. He appreciated this, no doubt, but he and Pawlak wonder if more could be accomplished if more honestly was allowed at the table. Pawlak explains: “Regulators need to check their authority at the door; technology needs to check their power at the door. Almost like the way GSA works, everybody needs to check their stuff and say, ‘This doesn’t make any sense, guys.’”
Communication Standards
Each time GSA President Peter DeRaedt and GSA Technical Director Marc McDermott travel to visit regulators and operators, they have to explain the difference between what they do, and communication standards and technical standards. Although DeRaedt finds this frustrating, he says operators, quite frankly, should not know the details of what GSA is all about. Seems like an odd statement from the man whose career is based on communication protocols or standards. He explains: “The word protocol should be eliminated from our dictionary. Frankly, nobody is going to be talking about a protocol five years from now. Who cares? They’re going to talk about, ‘Wow, look at this! I can do social gaming on a gaming machine.’ Who cares how you do it, as long as it gets done consistently across the industry by every single vendor so an operator can chose its products wisely?”
This lack of in-depth understanding on the operator’s side does put DeRaedt’s team of technical geniuses in an awkward position to communicate how the standards will drive innovation and generate revenue on a level that is non-technical. DeRaedt says: “We know the power of these technologies; we know what it can do. We simply look at the Internet and there it is. Yet we seem to be struggling in communicating this to operators, especially an operator that has to start making an investment of $20,000 per machine and a couple million bucks for a system.”
Technology and operators are crucial to communication standards. They are, in fact, what drives the standards forward. When GSA creates communication standards, it starts with the minimum required by technical standards. Next, GSA looks to the operators to see what they want. One way GSA does this is by working with the Operator Advisory Committee (OAC). The OAC facilitates collaboration between operators, manufacturers and system providers to ensure that GSA standards are meeting market demands. DeRaedt says there is a shift by large operators that really want to be able to be on the cutting edge, since they need the technology to drive their business. Through GSA, operators are now leveraging their positions and ensuring that manufacturers listen to what they need.
Manufacturers are able to come to a consensus through GSA. DeRaedt adds: “If the industry works together in the same sandbox, then we can offer what the operator requests. Then that’s all a wonderful world. And if they’re not, well, operators have the power to put their foot down and say, ‘Guys, this is what I want. Make it happen.’”
So far, DeRaedt says the industry is working together and GSA members are cooperating very nicely to come up with new technology.
Goodbye SAS, Hello G2S
Let’s take a look at the move from Slot Accounting System (SAS) to Game to System (G2S) as an example of the industry wanting more. SAS is still doing the majority of communication in North America at this point, but it is outdated. DeRaedt says, “To move on to do the new things, the new technology, to actually bring the gaming industry into the 21st century, we need a different way to communicate.”
SAS handles basic communication but is missing new and exciting innovations like software download and player-user interface. It uses technology from the 1980s, when modems were just introduced into the market and people, if they were lucky, were dialing up to get online. “The market globally is very limited about what it can do, and it’s limited because the fundamental way to exchange information is restricted through a very, very narrow 30-year old pipe called SAS,” DeRaedt elaborates. “So that is what’s holding back the industry.”
With the promise of new technology and innovation, the industry began to get on board with GSA, and now G2S is here. We saw the first major implementation of G2S this year at MGM Resorts International’s ARIA casino at CityCenter, and DeRaedt is glad MGM understands the benefits of what his team has developed. Storm, meanwhile, considers G2S as in its early adoption phase, with the innovators ironing out the wrinkles. There were some problems with communication between machines at ARIA. On this, Storm notes, “It’s not GSA’s fault by any means. GSA is an idea and a standard that is a tremendous contribution to the industry.”
The trouble stems from the fact that people can write to the same set of rules and end up with something different. As an example, Storm says, “It’s like saying to people, we want you all to speak Japanese, and then you get 11 different dialects and they can’t speak to each other, even though they’re all speaking Japanese.”
GSA did benefit from ARIA’s server-based gaming installation. McDermott explains: “The standard has matured. We tried to make things painfully clear in the document, but when you put two engineers together and they look at stuff, in many cases they’ll look at the same text and come up with two different interpretations.”
GSA has since clarified information in the G2S protocol document in a way that has never been done before. The document is now more than 2,000 pages long. But DeRaedt says you shouldn’t let that scare you, because the document describes in detail, in plain English, the capability of each feature enabled by the standard. The only way to really find out what G2S is capable of is reading through it. “What we enable is just simply mind-boggling,” he says. “Providing everyone with the opportunity to implement the standard in the same way, down to the little details, will directly benefit the operators through significantly improved interoperability.”
DeRaedt says the technology of G2S enables much more than what is currently visible on ARIA’s floor. “These guys, I’m sure, have a plan in place that will enable certain features at specific times depending on testing,” he notes. “They have not yet had the opportunity to utilize G2S to its full potential, because as a large corporation, managing multiple properties, they have to be careful what they do.”
GSA says the industry should watch for more innovation to come from the smaller, more aggressive, second-level operators. “Probably the Native American ones, because they really want to innovate,” DeRaedt says. “They can innovate, they want to do it, and they have less at risk or at stake than these large corporations.”
A Message to Operators
For those of you wanting to take it to the next level, McDermott says you need to ask questions: “Sometimes they don’t know what to ask, or they’re afraid to ask. Or sometimes it takes us a little while to get to where they are comfortable enough to say, ‘We think this is good, but this is bad and we need this fixed.’ But once we get to that level, we can start to move forward. Asking questions is a cool thing.”
Because communication standards are hard to understand, McDermott also suggests telling GSA what you want to happen on your floor and ask how you can get there. “That helps us explain, ‘this is how you do that’ through the protocols, or we can take notes and bring interesting information back to our committees and have them put in,” he says.
As more manufacturers start to participate in GSA’s certification registry, it will be another place operators can go to join the conversation. Scientific Games was the first, and at the time of this writing, the only company on the registry. It correctly implemented GSA technology and is now certified. The registry is searchable and tells viewers what the product or program is certified for. For example, Scientific Games is a voucher system and is certified for handling vouchers. It is not certified for player tracking.
DeRaedt says there are, of course, ways in which standards are beneficial, but there are also ways standards in which are not necessarily beneficial. “At the end of the day, it’s about speed to market, and standards tend to take a bit longer to build consensus,” he explains. “An operator is not going to wait to put online gaming in place because GSA needs to finish the standard. So there’s an interesting challenge there as to how fast the industry is able to move.”
Online Standards
At this point, the experts don’t see much in the form of i-gaming standards. There are some regulations and technical standards, but they don’t appear to be as clear as what land-based operators are used to. Several operators already implement self-imposed. McDermott says, “Everybody is still developing their own stuff and communicating in their own way, so that when they hook up together, they have to develop a custom interface or they can’t move information back and forth.”
Williamson said: “Ultimately governments will not ignore the revenue from this industry and, to accompany the taxation, will establish the ground rules by which Internet gaming will operate.” He believes standards will not be difficult to create. “In practice, they should reflect a combination of game review methodologies currently practiced by independent and state test labs with best practices for software development and implementation.”
Nick Farley believes technical standards for i-gaming would be important to players. “I think that the public being aware that there is a regulatory scheme behind i-gaming will raise the comfort level,” he explains.
He says there should be requirements, standards, a means to monitor the programs running on the sites, verification of age and location, and a way to ensure players are getting the prizes they’re entitled to.
It is however, tricky for a company like Eclipse Compliance Testing to get involved with i-gaming standards at this point. Janice Farley explains: “When you look at licensing in some of the regulated jurisdictions where we currently are approved, they don’t allow the lab to support or engage in illegal gambling—as i-gaming is currently considered in the United States. So it makes it a little difficult to get involved at that level unless there’s some sort of regulatory agency in place.”
If there would be a regulatory agency exploring i-gaming in expectation of legislation coming about, Farley says Eclipse Compliance Testing would welcome the opportunity to get involved with pro-actively putting a scheme together. It is not, however, doing so at that point at this time.
GSA, meanwhile, is looking at getting involved in communication standards for the back-end accounting side of i-gaming. McDermott says, “That’s where we think at this point that GSA may be able to provide some serious value.”
Whether or not GSA moves forward with this depends on feedback from the i-gaming industry. DeRaedt explains, “It’s hard to get a hold of the people, but it’s a matter of weeks, months, before we know, yes we have support, before we can provide the industry with a definite response as to whether or not we’re going to get involved with it.”
GSA’s board will not spend resources on something if the i-gaming industry does not want to get involved. As DeRaedt says, “That doesn’t make sense.”
Final Thoughts
As DeRaedt put it, “At the end of the day, GSA and standards are here to stay. I don’t think they’re going away.”
So if you haven’t already, take time to learn more about G2S and your jurisdiction’s technical standards. Technology is cruising along and regulators are trying to keep up. That means standards will continue to evolve to meet the demands of players, operators, regulators and manufacturers. If you have questions, ask. If you have knowledge, share. And continue or try to play nicely in the sandbox that is the competitive gaming industry.