The Michigan Gaming Control Board (MGCB) has published a five-page bulletin to interested online-poker operators regarding the issues at hand involving multi-state online poker that includes players to be pooled from the Wolverine State. Titled "Multistate Internet Poker: Potential Tasks and Considerations for Operators and Platform Providers," the document details the state's plans and expectations in 20 separate operational areas for when and if Michigan joins a regulated multi-state network.
Though Michigan has announced no agreement with any other U.S. states to date, last week's issuance of the guidelines markedly increases the chances that such a multi-state deal involving Michigan will be announced in the near future. By far the likeliest scenario is that Michigan would join the existing Multi-State Internet Gaming Agreement (MSIGA), which already includes Nevada, New Jersey, and Delaware as member states.
Should Michigan join MSIGA, the state would likely join the WSOP.com platform powered by 888. The platform already operates in Michigan but currently does so as a standalone, single-state entity, as it also does in Pennsylvania. Michigan joining MSIGA would also represent player-pooling opportunities for other states as well. PokerStars USA currently operates three single-state platforms, in Michigan, New Jersey, and Pennsylvania, and it would be able to merge the Michigan and New Jersey player pools. The partypokerUS network would likewise be able to pool its Michigan and New Jersey players.
Pennsylvania's online gaming authority has also been reported as being in preliminary negotiations with other states to pool its players via MSIGA. That potential partnership could bring the total number of MSIGA-linked states to five in a matter of months, and provide increased incentive for other states such as Connecticut, West Virginia and New York to become online-poker operation and further expand the opportunities for regulated U.S. play.
MGCB bulletin describes various multi-state scenarios
The impetus behind the MGCB bulletin is to make currently licensed and potential future operators aware of all the issues and areas of concern that Michigan's regulators will oversee. The bulletin declares, "This document is meant to provide guidance regarding tasks an operator or platform provider may need to complete and other items an operator
or platform provider may need to consider before the board will authorize the commencement of multistate poker."
Not all of the "tasks" that the bulletin defines will necessarily apply to every operator, though the vast majority of those tasks will be universal. The bulletin also created three potential scenarios describing how existing and new operating partnerships may come to be in Michigan's online-poker market, and each of them will be addressed in distinct ways. Those potential scenarios include the following:
- An operator that does not currently offer poker in Michigan may decide to launch multistate poker. This could be done via a partnership with a new platform provider, via a new platform provided by an operator’s existing platform provider, or as a new game or remote gaming system (RGS) added to an existing platform.
- An operator or platform provider that currently offers poker may introduce a new platform in Michigan to support multistate poker or may migrate its entire poker operation to a platform located in another state (e.g., New Jersey).
- An operator or platform provider may continue to utilize its current platform while connecting to poker platforms in other states via a remote gaming system (located in Michigan or another state).
The majority of the MSIGA bulletin details the 17 separate areas of interest where existing and potential operators are offered very brief guidelines regarding what the state will expect. Those topics, each accompanied by a very brief description of potential tasks and considerations, include:
- Multijurisdictional Agreement
- Other Jurisdictions
- Supplier Licensing
- Vendor Registration
- Occupational Licensing
- New Platform Approval
- Platform Modifications
- RGS Approval
- Data Center
- Server Location
- Game Approval
- Live (Online) Games Approval
- Geofencing
- Platform Assessment
- Tournament Notification
- Internal Controls and Security (ICS)
- Records, Adjusted Gross Receipts, and Taxes/Payments
The ICS category is a catch-all bucket under which many day-to-day operating features and aspects will be addressed. Sub-topics (with some overlap) include:
- Procedures for platform failures
- User access controls
- Segregation of duties
- Risk management procedures
- Fraud prevention and detection
- Game approval
- Acceptance of wagers
- Recording and reconciliation
- Third-party platforms
- Geolocation
- Information sharing
- Complaints
- Server location
- Technical security controls
- Calculation of adjusted gross receipts
- Hacking, cyber-attacks, and tampering
- Cheating, collusion, and bots
- Third parties involved in internal controls
- Terms and conditions
- Change control processes
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