Michigan Office of Administrative Hearings and Rules  
MOAHR-Rules@michigan.gov  
AGENCY REPORT TO THE  
JOINT COMMITEE ON ADMNINISTRATIVE RULES (JCAR)  
1. Agency Information  
Agency name:  
Treasury  
Division/Bureau/Office:  
Michigan Gaming Control Board  
Name of person completing this form:  
Wendy Harns  
Phone number of person completing this form:  
517-335-2163  
E-mail of person completing this form:  
harnsw@michigan.gov  
Name of Department Regulatory Affairs Officer reviewing this form:  
Sarah Rowley  
2. Rule Set Information  
MOAHR assigned rule set number:  
2020-11 TY  
Title of proposed rule set:  
Fantasy Contests  
3. Purpose for the proposed rules and background:  
These rules will provide the regulatory framework for the licensing and operation of fantasy sports  
contests in the state of Michigan pursuant to the Fantasy Contests Consumer Protection Act, MCL  
432.501 to 432.516.  
4. Summary of proposed rules:  
The rules establish a framework for a secure, responsible, fair, and legal system of fantasy contests in  
Michigan.  
The Fantasy Contests Consumer Protection Act, MCL 432.501 to 432.516, was enacted on December  
20, 2019, and authorized the operation, conduct, and offering of fantasy contests which were already  
occurring in this state.  
By its own terms, the act was created to regulate the conduct of fantasy contests; to protect Michigan  
participants in fantasy contests; to require licensing of the operators of fantasy contests; to impose  
fees on the operators; to provide for the powers and duties of the Board in overseeing fantasy contests  
in Michigan; to prohibit violations of the Fantasy Contests Consumer Protection Act; and to prescribe  
civil sanctions and penalties.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 2  
5. List names of newspapers in which the notice of public hearing was published and  
publication dates:  
The Lansing State Journal – December 6, 2021  
The Detroit Free Press – December 6, 2021  
The Daily Press (Escanaba) – December 6, 2021  
6. Date of publication of rules and notice of public hearing in Michigan Register:  
12/15/2021  
7. Date, time, and location of public hearing:  
1/6/2022 10:00 AM at Michigan Gaming Control Board, Hearing Room , 3062 W. Grand Blvd., Suite  
L-700, Detroit, Michigan  
8. Provide the link the agency used to post the regulatory impact statement and cost-benefit  
analysis on its website:  
https://ARS.apps.lara.state.mi.us/Transaction/RFRTransaction?TransactionID=139  
9. List of the name and title of agency representative(s) who attended the public hearing:  
Dave Murley, Charles Negin, Wendy Harns of MGCB; Bethany McCune of the Department of  
Attorney General  
10. Persons submitting comments of support:  
No comments of support were submitted for the general rule set.  
11. Persons submitting comments of opposition:  
No comments of opposition were submitted for the general rule set. However, the following persons  
submitted comments of opposition to Rule 432.531(3)(b):  
•Elizabeth Suever, VP Government Relations, Bally’s Corporation  
•Joshua L. Kirschner, VP Legal & Government Affairs, PrizePicks  
•Andrew K Sokol, President & CEO, AKS Ventures, LLC  
•Senator Curtis Hertel, Jr.  
•120 letters were submitted by Michigan residents in opposition to this rule.  
12. Persons submitting other comments:  
The following persons submitted other comments:  
•Michael Petropoulos, FFPC Compliance Officer, Fantasy Football Players Championship  
•Cory Fox, Government Affairs and Product Counsel Vice President, FanDuel  
•Meredith C. Yu, Head of Compliance, Yahoo Fantasy Sports  
•Christopher Cipolla, Director, Legal and Government Affairs, DraftKings Inc.  
•Ryan J. Fitts, VP, Deputy General Counsel, Vivid Seats/Betcha  
•Rachel Peters, Compliance Officer, OwnersBox 3.0 Corporation  
13. Identify any changes made to the proposed rules based on comments received during the  
public comment period:  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 3  
Name &  
Organization public hearing  
Comments made at Written  
Agency Rationale Rule number  
for Rule Change & citation  
and Description changed  
of Change(s)  
Comments  
Made  
1
Michael  
Petropoulos,  
FFPC  
Clarify that a  
management  
company license reduce the  
Modified 432.522 432.522(3)-  
(3) and (4) to  
(4)  
Compliance  
Officer, Fantasy  
Football  
is only needed if regulatory burden  
a fantasy contest by clarifying that  
operator contracts an individual who  
with a third-party is an employee of  
Players  
Championship  
(FFPC)  
management  
company and is operator does not  
not required for require a  
a fantasy contest  
an employee of a management  
fantasy contest  
operator.  
company license  
to manage the day-  
to-day fantasy  
contest operations.  
2
Michael  
Provide an  
Modified 432.531 432.531(3)(a)  
Petropoulos,  
FFPC  
Compliance  
Officer, Fantasy  
Football  
exemption to the (3)(a)(i) to reduce (i)  
prohibition on  
auto draft  
the regulatory  
burden by  
functionality for allowing expanded  
season-long use of auto draft  
Players  
Championship  
(FFPC)  
fantasy contests functionality under  
in which fantasy certain conditions.  
contest players  
rank or queue  
athletes prior to  
the draft.  
3
Cory Fox,  
Government  
Affairs and  
Product  
Counsel Vice  
President,  
FanDuel  
Request  
clarification on  
Added a new  
subrule (5) to  
432.532h(5)  
the meaning of a reduce the  
“pending” fantasy regulatory burden  
contest entry as by clarifying that a  
used in 432.532h. fantasy contest  
entry is considered  
pending if the  
outcome of the  
fantasy contest in  
which the fantasy  
contest entry was  
entered has not yet  
been determined.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 4  
4
Meredith C. Yu,  
Head of  
Compliance,  
Yahoo Fantasy  
Sports  
Clarify or remove To reduce the  
the requirement regulatory burden,  
to dynamically the dynamic  
monitor a fantasy monitoring  
contest player’s requirement was  
432.539(2)  
location.  
eliminated.  
Continual  
monitoring would  
be overly  
burdensome, both  
technologically  
and financially.  
Request  
clarification on  
when age and  
identity  
5
Christopher  
Cipolla,  
Director, Legal  
and  
Government  
Affairs,  
DraftKings Inc.  
Modified  
432.541a(1) to  
reduce the  
regulatory burden  
by clarifying that a  
licensee must  
verify an  
432.541a(1)  
verification is  
required.  
individual’s age  
and identity before  
allowing the  
individual to  
create an account  
and do either of  
the following,  
whichever occurs  
first: (a) make a  
deposit; or (b)  
enter or participate  
in a fantasy  
contest.  
6
Cory Fox,  
Government  
Affairs and  
Product  
Counsel Vice  
President,  
FanDuel  
Approaches to  
Modified  
432.544b  
fraud prevention 432.544b to  
and anti-money reduce the  
laundering may regulatory burden  
change over time. and provide  
Modify  
requirements  
greater flexibility  
in investigating  
regarding failed failed ACH  
ACH deposits to deposits and  
allow more  
flexibility.  
identifying and  
resolving  
fraudulent ACH  
deposit attempts.  
MCL 24.242 and 24.245  
Agency Report to JCAR-Page 5  
14.Date report completed:  
6/27/2023  
MCL 24.242 and 24.245  
;