Stakeholder/Public Comment for JCAR Agency Report: Internet Gaming  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Comments  
Public  
Hearing/  
Written  
Written  
LSBA  
LIGA  
Change/no  
change  
Name/Org  
Rule  
432.611(c)  
Comment  
Agency rationale  
Andrea Hansen on  
behalf of FanDuel  
LIGA  
Definition of “Affiliate marketer”: Change  
Definition modified  
resulting in change to  
rule 432.622(3)(e) and  
432.629(1)(a)(i)  
Add to end of subrule: who have  
an agreement with an internet  
gaming operator to be  
compensated based on the  
number of registrations, the  
number of depositing  
registrations, or a percentage of  
adjusted gross receipts.  
Andrea Hansen,  
Written  
LIGA  
432.611(c)  
The current definition of  
“affiliate marketer” is very broad.  
Change to:  
Change  
Definition modified  
resulting in change to  
rule 432.622(3)(e) and  
432.629(1)(a)(i)  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
“Affiliate marketer” means  
entities and individuals involved  
in promoting, marketing, and  
directing business to online  
gaming sites, on their own  
behalf, and who have an  
agreement to be compensated  
by a sports betting or internet  
gaming operator licensee based  
on the number of registrations,  
the number of depositing  
registrations, or a percentage of  
adjusted gross revenue.”  
Add bingo and keno to  
Robert Russel, RNC, on  
behalf of DraftKings  
Written  
Written  
LIGA  
LIGA  
432.611(e)  
432.611(l)  
No change  
Change  
Board retains authority  
to authorize bingo and  
keno.  
Board changed to  
address authorized  
multijurisdictional  
internet gaming  
authorized games  
Lloyd D. Levenson  
(Cooper Levenson)  
Definition of “Internet gaming  
network”: We are in favor of  
Rules being put in place that will  
allow multi-state poker  
agreements should the  
legislature pass such a bill  
authorizing same.  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
432.611(p) – (q)  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
As a result of the  
change from version 2  
to version 3 (R  
432.633(2), the  
definitions of “live  
game” and “live game  
environment” were  
added  
MGCB  
Written  
Written  
LIGA  
LIGA  
432.611(r)  
432.611(r)  
Definition of “Peer-to-peer”  
gaming is not in alphabetical  
order  
Definition of “Peer-to-peer  
gaming”: Should clarify that the  
intention of this does not include  
exchange wagering (sports) as  
peer to peer gaming.  
Change  
Moved to alphabetical  
order  
Seth Young, PointsBet  
No change  
No need to clarify, as  
exchange wagering is  
conducted under LSBA,  
not LIGA  
Mike Phelan, Pokagon  
Gaming Authority  
Written  
LIGA  
432.611(s)  
Definition of “Prohibited  
person”: Employee  
participation/risk  
Change  
Removed (iv) and (vi);  
Definition changed to  
no longer prohibit  
person licensed under  
Gaming Control and  
Revenue Act or the  
Indian Gaming  
Regulatory Act from  
creating accounts or  
placing wagers.  
Mike Phelan, Pokagon  
Gaming Authority  
Written  
LIGA  
432.611(s)(vi)  
Def. of “prohibited persons”:  
The Pokagon Band has concerns  
about the addition of the term  
“appointees” to the definition of  
“Prohibited person”. (1) What is  
an “appointee” of a tribal casino?  
(like most other commercial  
entities, tribal gaming enterprises  
don’t “appoint” people to  
Change  
Moved “appointees” to  
a new paragraph:  
432.611(s)(v). Including  
appointees with tribal  
gaming commission is  
consistent.  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 2  
positions, they hire them as  
employees); (2) what regulatory  
purpose is intended to be served  
by extending the prohibition to  
“appointees”?; (3) why shouldn’t  
the prohibition be applied also to  
state-licensed casinos?  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.611(u)  
432.611(w)  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
Change  
As a result of the  
change from version 2  
to version 3 (R  
432.633(2), the  
definition of “random  
number generator” was  
updated  
As a result of the  
change from version 2  
to version 3 (R  
Andrea Hansen on  
behalf of FanDuel  
Version 2 of Standard GLI-19  
should be “version 3”  
432.633(2), the  
definition of “remote  
player device” was  
added and  
“remote/proxy player  
games deleted  
Seth Young, PointsBet  
Written  
LIGA  
432.611(cc)  
Definition of “Targeted mailing”:  
Would this prohibit cross-selling  
customers from a sports betting  
platform to a casino?  
No change  
R 432.674 prohibits  
targeted mailing to  
persons on the self-  
exclusion list  
Andrea Hansen on  
behalf of FanDuel  
Andrea Hansen on  
behalf of FanDuel  
Seth Young, PointsBet  
Written  
Written  
Written  
LSBA  
LIGA  
LIGA  
432.611  
432.621a  
432.621a  
Add definition of ex parte  
communication  
No change  
No change  
No change  
Limits Board discretion  
Proposed adding “operator”  
along with “platform provider”  
Requesting the Board rely on  
reporting requirements outside  
of those reported by the US  
Securities and Exchange  
Commission  
Covered in R 432.721  
The Board relies on  
reporting to the US  
Securities and Exchange  
Commission  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
432.621f(2) - (3)  
Suggests language is duplicative  
of other subrules  
No change  
Unnecessary  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 3  
Bill Brooks on behalf of  
Quinto Singleton on  
behalf of Nottawaseppi  
(NHBP)  
Written  
LIGA  
432.621k(2)  
Not all vendors will have an  
actual representative in Michigan  
to receive services and other  
persons required to be licensed  
likely will have no presence in the  
state  
Change  
Removed “within  
Michigan.”  
Robert Russel, RNC, on  
behalf of DraftKings  
Written  
Written  
LIGA  
LIGA  
432.622(2)  
Requesting clarification  
No change  
Contrary to the  
definition of supplier  
MCL 432.403(ee)  
Definition modified  
resulting in change to  
rule 432.622(3)(e) and  
432.629(1)(a)(i)  
Andrea Hansen on  
behalf of FanDuel  
432.622(3)(e)  
Definition of “Affiliate marketer”: Change  
Add to end of subrule: who have  
an agreement with an internet  
gaming operator to be  
compensated based on the  
number of registrations, the  
number of depositing  
registrations, or a percentage of  
adjusted gross receipts.  
Robert Russel, RNC, on  
behalf of DraftKings  
Written  
LIGA  
432.623(1)  
Subpart (1) could be overly  
burdensome  
No change  
There is a mechanism in  
place for a sports  
betting operator or  
sports betting supplier  
to provide an  
explanation, such as a  
job description, to  
support an allegation  
that a position should  
not require an  
occupational license.  
Board identified  
persons having direct  
impact on integrity of  
gaming.  
Robert Russel, RNC, on  
behalf of DraftKings  
Written  
LIGA  
432.623(2)  
Encompassing too large group of Change  
employees; add “deployment of  
code to production of”  
Board identified  
persons having direct  
impact on integrity of  
gaming  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 4  
Robert Russel, RMC, on Written  
behalf of DraftKings  
LIGA  
432.623(2)  
Suggest including "deployment of Change  
code" language to limit who is  
included in occupational  
Board identified  
persons having direct  
impact on integrity of  
gaming  
licensing.  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.623(2)  
Limit the scope of who is  
required to be licensed  
Change  
Change  
Board identified  
persons having direct  
impact on integrity of  
gaming  
Board identified  
persons having direct  
impact on integrity of  
gaming  
Andrea Hansen on  
behalf of FanDuel  
432.623(2)(a) and (b)  
Limit scope of occupation  
licensing only to individuals that  
make changes to hardware or  
software having ability to affect  
the outcome of a game  
Robert Russel, RNC, on  
behalf of DraftKings  
Written  
LIGA  
432.623(2)(a) and (b)  
Encompassing too large group of Change  
employees; add “deployment of  
code to production of”  
Board identified  
persons having direct  
impact on integrity of  
gaming  
Robert Russel, RNC, on  
behalf of DraftKings  
Mike Phelan, Pokagon  
Gaming Authority  
Written  
Written  
LIGA  
LIGA  
432.623(2)(c)  
432.623(11)(c)  
Vague and unclear  
Change  
Change  
Removed 623(2)(c) and  
(d)  
Occ. Licensing:  
Board added language  
allowing exemption  
from occupational  
licensing if licensed by  
governmental entity.  
Can still require  
Reciprocity provision was  
removed, request it be added  
back in  
registration  
Mike Phelan, Pokagon  
Gaming Authority  
Written  
Written  
LIGA  
LIGA  
432.623(12)  
432.624  
Occ. Licensing:  
Change  
Board added language  
allowing exemption  
from occupational  
licensing if licensed by  
governmental entity.  
Can still require  
Reciprocity provision was  
removed, request it be added  
back in  
registration  
Robert Russel, RNC, on  
behalf of DraftKings  
Asking for clarification that  
employers are permitted to pay  
occupational licensing fees on  
behalf of their employees  
No change  
Operators or platform  
providers can pay  
occupational license  
fees  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 5  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
Written  
LIGA  
LIGA  
LIGA  
432.624(3)(c)  
432.624(8)  
Proposed occupational license  
fees are higher than other  
jurisdictions  
Occupational license should be  
payable every two years  
concurrent with the renewal  
Supplier licensing:  
The contingent rule regarding  
whether a supplier qualifies as  
“an arm of the tribe” should only  
apply if the tribe who is in a  
relationship with the supplier  
claims that the supplier is an arm  
of the tribe. The determination  
of whether the supplier qualifies  
as an “arm of the tribe” should  
be based on objective criteria  
informed by proper analysis of  
federal Indian law. See, e.g.,  
People v. Miami Nation  
Change  
Change  
Change  
Board lowered fee from  
$500 to $250  
Andrea Hansen on  
behalf of FanDuel  
Changed to reflect  
payment biennially  
Mike Phelan, Pokagon  
Gaming Authority  
432.625b(3)  
Language was added to  
clarify that relevant  
legal criteria under  
federal Indian law will  
be used to establish  
arm of tribe status.  
Enterprises, 386 P.3d 357 (2016)  
confidentiality of commercial  
contracts  
Seth Young, PointsBet  
Written  
Written  
LIGA  
LIGA  
R 432.628c  
No change  
Confidentiality will be  
dictated by LIGA and  
FOIA  
Definition modified  
resulting in change to  
rule 432.622(3)(e) and  
432.629(1)(a)(i)  
Andrea Hansen on  
behalf of FanDuel  
432.629(1)(a)(i)  
Definition of “Affiliate marketer”: Change  
Add to end of subrule: who have  
an agreement with an internet  
gaming operator to be  
compensated based on the  
number of registrations, the  
number of depositing  
registrations, or a percentage of  
adjusted gross receipts.  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.629(1)(a)(iii)  
432.629(1)(a)(iii)  
Should “supplier” be changed to  
“platform provider”  
Change  
Platform provider is  
the correct term  
Robert Russel, RNC, on  
behalf of DraftKings  
Add “that directly affects  
internet sports betting”  
No change  
If the business “directly  
affects internet sports  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 6  
betting,” it is likely a  
supplier, not a vendor  
The registration should  
be obtained when the  
vendor crosses the  
$100,000 threshold.  
If the goods and/or  
services are specifically  
related to sports  
betting, the person is  
likely to be a supplier  
not a vendor. Board  
needs authority to  
determine other  
Robert Russel, RNC, on  
behalf of DraftKings  
Written  
Written  
LIGA  
LIGA  
432.629(1)(a)(iii)  
432.629(1)(a)(iii)  
Change “in a” to “during the  
prior” calendar year  
No change  
No Change  
Andrea Hansen on  
behalf of FanDuel  
Suggest deleting (1)(a)(iii) and  
limiting (1)(a)(v) to other persons  
who provide more than $100,000  
worth of goods and/or services in  
a calendar year that are  
specifically related to the  
operation of internet gaming as  
deemed necessary by the board.  
persons that require  
vendor registration.  
“Data Center” is a more  
appropriate term  
Mike Phelan, Pokagon  
Gaming Authority  
Written  
Written  
LIGA  
LIGA  
432.629(1)(a)(iv)  
432.631(1)  
“Data Warehouses” may not be  
the best term -- “Data Centers”  
seems more accurate.  
Insert language allowing for  
multi-jurisdictional internet  
gaming  
Change  
Change  
Andrea Hansen on  
behalf of FanDuel  
Board changed to  
address authorized  
multijurisdictional  
internet gaming  
Lloyd D. Levenson  
(Cooper Levenson)  
Written  
Written  
LIGA  
LIGA  
432.631(1)  
We are in favor of Rules being  
put in place that will allow multi-  
state poker agreements should  
the legislature pass such a bill  
authorizing same.  
For clarity purposes, what about  
non-wagering activities such as  
login, withdrawals and deposits?  
Can these permissibly occur from  
outside of the state?  
Limit source code to those  
deemed to be a critical  
component  
Change “sports betting” to  
“gaming”  
Change  
Change  
Board changed to  
address authorized  
multijurisdictional  
internet gaming  
Robert Russel,  
Regulatory  
Management  
Counselors, (RMC) on  
behalf of Playtech  
Robert Russel, RNC, on  
behalf of DraftKings  
R 432.631(1)  
Board changed to  
address authorized  
multijurisdictional  
internet gaming  
Written  
Written  
LIGA  
LIGA  
432.632a  
No change  
Change  
Lab needs source code  
for any component, not  
just critical components  
Error correction  
MGCB  
432.632a(1)(j)(i)  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 7  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.632a(2)  
432.632a(6)  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
GLI standard changed.  
As a result, all rules  
relying on prior version  
were changed to align  
with version 3  
Board needs source  
code to evaluate the  
submission and ensure  
the submitted software  
is what was approved  
Andrea Hansen,  
Submitting source code to any  
entity, even a third-party testing  
laboratory, could become a  
security breach to any operator  
or supplier’s platform and open  
up the platform to unnecessary  
risk. We respectfully suggest the  
following substitute language,  
“The internet gaming platform  
provider or internet gaming  
supplier shall verify the hashes of  
critical components.”  
No change  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
Mike Phelan, Pokagon  
Gaming Authority  
Written  
LIGA  
432.632a(7)  
Provide automatic approval for  
software updates to reduce  
unnecessary delays and  
No change  
Handling of software  
updates is sufficiently  
addressed under the  
self-monitoring of  
increased regulatory costs.  
gaming platform critical  
components and  
change approval  
requirements of the  
administrative rules.  
GLI standard changed.  
As a result, all rules  
relying on prior version  
were changed to align  
with version 3. Rules  
affected: 432.611,  
432.632a, 432.633(2),  
432.633a, 432.633b,  
432.639(2)(c)(vi), R  
432.639b, R 432.649  
GLI standard changed.  
As a result, all rules  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
432.633(2)  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
432.633a(1)(b)  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 8  
relying on prior version  
were changed to align  
with version 3  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
432.633a(3)  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
GLI standard changed.  
As a result, all rules  
relying on prior version  
were changed to align  
with version 3  
Board has authority to  
approve auto-spin  
feature  
Andrea Hansen on  
behalf of FanDuel  
LIGA  
LIGA  
432.633a  
432.633a  
Propose adding: “This Rule is not No change  
intended to prohibit an auto-spin  
feature on a slot game.”  
Request clarity on the term  
“induce”  
Robert Russel, RMC, on Written  
behalf of Playtech  
No change  
This will be assessed as  
part of platform  
submission assessed on  
a case-by-case basis  
The Board has authority  
to approve auto play  
features  
Andrea Hansen,  
Written  
LIGA  
432.633a(3)  
We respectfully request that the  
inclusion of “no auto play” being  
allowed without Board approval  
is targeted towards disallowing  
“bots” and is not meant to  
No change  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
disallow the auto-spin feature  
seen on slot games. Every slot  
machine game developed for  
iGaming has auto-spins built in as  
a core feature.  
Seth Young, PointsBet  
Written  
Written  
LIGA  
LIGA  
432.633b  
432.633b  
What happens if the RTP (return  
to player) goes over 100%?  
No change  
Change  
RTP requirement  
applies to theoretical  
RTP, not actual RTP  
GLI standard changed.  
As a result, all rules  
relying on prior version  
were changed to align  
with version 3.  
Andrea Hansen on  
behalf of FanDuel  
Version 2 of Standard GLI-19  
should be “version 3”  
Reduced from subrules  
(1)-(14) to subrules (1)-  
(4)  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 9  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.633c  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
432.633c was removed  
as a result of changes to  
GLI-19 version  
Branded games are  
allowed  
This rule was deleted  
when GLI version was  
updated.  
Andrea Hansen,  
432.633c(1)(a)  
Seeking clarification that branded No change  
games are not disallowed  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
Lloyd D. Levenson,  
Cooper Levenson  
Written  
LIGA  
LIGA  
LIGA  
432.634(1)  
432.634(1)  
432.634(1)  
We are in favor of Rules being  
put in place that will allow multi-  
state poker agreements should  
the legislature pass such a bill  
authorizing same.  
Can progressive product servers  
and other network product  
servers that are not receiving  
wagers be located in other  
states?  
Eliminate the requirement that  
servers be located in Michigan  
and can be located in other  
jurisdictions where the operator  
or platform provider operates  
internet gaming  
Change  
Board changed to  
address authorized  
multijurisdictional  
internet gaming  
Robert Russel, RMC, on Written  
behalf of Playtech  
No change  
Change  
See Board’s technical  
bulletins  
Andrea Hansen on  
behalf of FanDuel  
Written  
Added language to  
allow Board to approve  
location of servers out  
of state.  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.634(1)  
432.635(4)  
Change “and” to “and/or”  
No change  
Change  
Board needs  
information on the  
location of all servers  
Change “and” to “or, or  
both”  
Andrea Hansen on  
behalf of FanDuel  
Change “and” to “or”  
More appropriate term  
See Board’s technical  
bulletins  
Change “and” to “or, or  
both”  
Robert Russel, RMC, on Written  
behalf of Playtech  
LIGA  
LIGA  
432.636  
Questions on report formats and No change  
types of data to be recorded  
Andrea Hansen on  
behalf of FanDuel  
Written  
432.636(3)  
Change “and” to “or”  
Change  
More appropriate term  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
432.637a  
Change “and” to “or”  
No change  
Must be done jointly  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 10  
Mike Phelan, Pokagon  
Gaming Authority  
Written  
LIGA  
432.639  
In order to avoid confusion and  
possible conflict, this provision  
should be coordinated with (or,  
possibly, combined with)  
432.634(1), which addresses  
substantially the same subject  
matter.  
No change  
432.634(1) addresses  
wagering components  
only (which must be  
located in Michigan),  
while this provision  
addresses all critical  
components. Some  
components will be  
subject to both  
requirements, while  
certain non-wagering  
components will only  
be subject to this  
provision.  
Andrea Hansen on  
behalf of FanDuel  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.639(1)  
Change “and” to “or”  
change  
Change  
Change to “or both”  
More appropriate term  
GLI standard changed.  
As a result, all rules  
relying on prior version  
were changed to align  
with version 3  
432.639(2)(c)(vi)  
Version 2 of Standard GLI-19  
should be “version 3”  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.639(3)  
Change “and” to “or”  
Change  
Change  
Change “and” to “or or  
both”  
More appropriate term  
Added language to  
allow Board to approve  
locating the gaming  
environment out of  
state  
Robert Russel, RNC, on  
behalf of DraftKings  
432.639b(1)  
Remove that gaming  
environment used to conduct  
remote/proxy player or similar  
games must be located “in the  
state of Michigan”  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.639b(2)  
432.639c(5)  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
Change  
GLI standard changed.  
As a result, all rules  
relying on prior version  
were changed to align  
with version 3  
Andrea Hansen on  
behalf of FanDuel  
Change “and” to “or”  
Change “and” to “o,r or  
both”  
More appropriate term  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 11  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
Written  
Written  
Written  
LIGA  
LIGA  
LIGA  
LIGA  
LIGA  
432.639c(6)  
432.639c(7)  
432.639c(8)  
432.639c(9)  
432.639c  
Change “and” to “or”  
Change “and” to “or”  
change  
change  
change  
change  
No change  
In both places, change  
“and” to “or, or both”  
More appropriate term  
change “and” to “or, or  
both”  
More appropriate term  
change “and” to “o,r or  
both”  
More appropriate term  
change “and” to “o,r or  
both”  
add “provider”  
it allows for progressive  
jackpots in general  
Andrea Hansen on  
behalf of FanDuel  
Change “and” to “or”  
Change “and” to “or”  
Change “and” to “or”  
Andrea Hansen on  
behalf of FanDuel  
Andrea Hansen on  
behalf of FanDuel  
Andrea Hansen,  
Seeking confirmation that Rule  
432.639 allows for progressive  
jackpots to be shared between  
two internet gaming operators  
within the State of Michigan.  
Seeking confirmation that Rule  
432.639 allows for progressive  
jackpots to be shared between  
two internet gaming operators  
within the State of Michigan.  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
Andrea Hansen,  
Written  
LIGA  
432.639d  
No change  
it allows for progressive  
jackpots in general  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
Seth Young, PointsBet  
Seth Young, PointsBet  
Written  
Written  
LIGA  
LIGA  
432.639d(1)  
432.641(6)  
Can an internet gaming operator No change  
link to a third-party poker room?  
An operator can pool  
with another operator  
in Michigan  
Operator or platform  
provider is only  
required to notify the  
Board of an unresolved  
complaint; it is the  
participant’s  
Request shift burden of  
complaint resolution from the  
operator to the patron  
No change  
responsibility to file an  
unresolved complaint  
with the Board  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
432.641(7)  
Add “Any such decision by the  
Board may be appealed under  
the Administrative Procedures  
No change  
Not provided for in the  
APA  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 12  
Act, 1969 PA 306, MCL 24.201 to  
24.328.”  
Seth Young, PointsBet  
Written  
LIGA  
432.643(2)  
As a result of changes made due  
to PointsBet comment on LSBA R  
432.743(12) the change was also  
made in LIGA for consistency  
Change  
Clarified to now  
provide: “An internet  
gaming platform  
provider must promptly  
notify any affected  
internet gaming  
operators on behalf of  
which it accepts  
internet wagers of any  
issues impacting the  
integrity of internet  
gaming.”  
Robert Russel, RMC, on Written  
behalf of Playtech  
LIGA  
LIGA  
LIGA  
432.647  
Question on resettlement of  
accounts resulting in a negative  
balance  
No change  
Change  
Board’s explanation of  
the rule relates to  
authorized participant  
initiation resulting in  
negative account  
balance  
GLI standard changed.  
As a result, all rules  
relying on prior version  
were changed to align  
with version 3. Title  
changed.  
GLI standard changed.  
As a result, all rules  
relying on prior version  
were changed to align  
with version 3. Subpart  
(7) removed.  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
432.649  
Version 2 of Standard GLI-19  
should be “version 3”  
Andrea Hansen on  
behalf of FanDuel  
432.649(7)  
Version 2 of Standard GLI-19  
should be “version 3”  
Change  
Robert Russel, RMC, on Written  
behalf of Playtech  
LIGA  
LIGA  
432.649  
432.651  
Question on how winnings of  
celebrity authorized participant is  
reported or counted  
No change  
To be addressed in  
operator and platform  
provider’s internal  
controls  
Board inserted  
language allowing  
Robert Russel,  
Regulatory  
Written  
Authorize participants to be able Change  
to use same account for internet  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 13  
Management  
Counselors, PC  
gaming and internet sports  
betting  
integrated accounts  
with conditions  
Robert Russel, RMC, on Written  
behalf of GAN and  
DraftKings  
LIGA  
432.651(1)(c)  
Propose adding:  
Change  
Board inserted  
language addressing  
integration of accounts  
“Notwithstanding the foregoing,  
the internet sports betting  
account may be integrated with  
an internet wagering account  
from the authorized participant’s  
perspective allowing participants  
to have one account/sign-in that  
will provide access to both sports  
betting and (if applicable)  
internet gaming while still  
providing the accounting  
capability of separating sports  
betting and internet wagering  
upon request.”  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
LIGA  
432.651(1)(c)  
432.651(2)  
432.651a  
Authorize participants to be able Change  
to use same account for internet  
gaming and internet sports  
betting  
Board inserted  
language allowing  
integrated accounts  
with conditions.  
Robert Russel, RMC, on Written  
behalf of DraftKings  
Would like internet sports  
betting accounts and internet  
wagering accounts to interface  
from the participants perspective  
Provided recommendations for  
accuracy of data in identity  
authentication  
Change  
Board inserted  
language allowing  
integrated accounts  
with conditions  
Identity verification  
addressed in the rules;  
specific procedures to  
be addressed in internal  
controls  
List of prohibited  
persons doesn’t include  
anyone who would be  
prohibited from placing  
certain wagers  
Kimberly Sutherland,  
LexisNexis Risk  
Solutions  
Written  
Written  
No change  
Andrea Hansen on  
behalf of FanDuel  
LIGA  
432.651a(2)  
Insert “This subsection shall not  
be construed to prevent an  
individual from creating an  
internet gaming account and  
depositing funds to such an  
account even if they are  
prohibited from placing certain  
wagers.”  
Change  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 14  
Andrea Hansen on  
behalf of FanDuel  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
LIGA  
432.651a(3)  
432.651a(3)  
Change “demonstratable” to  
“demonstrable”  
Add “Such standards shall be  
satisfied by the use of a customer  
attestation that they are not a  
prohibited person at the time of  
account creation.”  
Change  
Grammatical  
No change  
Customer attestation  
may work in some cases  
but not others. Board  
retains discretion to  
determine if licensee  
has met this obligation  
Board changed to  
address authorized  
multijurisdictional  
internet gaming  
Lloyd D. Levenson  
(Cooper Levenson)  
Written  
Written  
LIGA  
LIGA  
432.652(1)(c)(ii)-(iii)  
432.653(1)(c)  
We are in favor of Rules being  
put in place that will allow multi-  
state poker agreements should  
the legislature pass such a bill  
authorizing same.  
Change  
Seth Young, PointsBet  
Responsibility for filing an  
No change  
The rule only requires  
that the authorized  
participant protection  
page notify authorized  
participants on how  
they may file  
unresolved complaint with the  
Board to be on the authorize  
participant, not the operator  
unresolved complaints  
with the Board.  
Andrea Hansen,  
Written  
Written  
LIGA  
LIGA  
432.653(3)  
432.654  
The registration and cashier  
functionality are separate from  
the responsible gaming limit  
functionality.  
Request to approve a shorted  
responsible gaming message to  
be included on areas of the  
platform outside of the  
No change  
No change  
Authorized participant  
should have access to  
setting responsible  
gaming limit  
Rule doesn’t require the  
message be displayed  
outside the responsible  
gaming page  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
Andrea Hansen,  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
responsible gaming page  
Can authorized participant’s  
certifications and  
acknowledgments be handled by  
spelling them out as part of the  
Terms & Conditions and  
recording acceptance by each  
participant?  
Robert Russel, RMC, on Written  
behalf of Playtech  
LIGA  
432.655  
No change  
Certifications and  
acknowledgments must  
be separate from the  
terms and conditions  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 15  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
Written  
LIGA  
LIGA  
432.655c  
Propose inserting “belonging to  
another authorized participant”  
Change  
Change  
Clarifies it is intended to  
prevent one authorized  
participant from  
transferring funds to  
another authorized  
participant  
Added at end: “or any  
other applicable state  
or federal law”  
Bill Brooks on behalf of  
Quinto Singleton on  
behalf of Nottawaseppi  
(NHBP)  
432.655d(1)  
Consider including concept that  
withdrawal may be delayed due  
to state/tribal/federal  
requirement and withdrawal is  
subject to player’s compliance  
with the same.  
Suggests adding language to  
allow an operator to close an  
account at any time  
This draft rule contemplates the  
possibility of a negative balance.  
Are there other circumstances  
where a negative balance would  
be permissible?  
Lachlan Hood,  
PointsBet  
LIGA  
LIGA  
432.657  
432.659  
No change  
No change  
This rule only addresses  
authorized participant  
account closure  
Robert Russel, RMC, on Written  
behalf of Playtech  
Although not  
permissible, a negative  
balance could occur due  
to an error or  
malfunction  
Andrea Hansen,  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
Lachlan Hood,  
Written  
LIGA  
432.663(2)(a)  
Request definition of “significant No change  
platform failure”  
Operator or platform  
provider can define this  
in their internal controls  
Written  
Written  
432.672 and  
432.674  
Asked whether self-exclusion can Change  
be applied across jurisdictions  
and channels  
Propose striking this rule because Change  
it adds complexity and creates an  
unnecessary potential for  
confusion, and it is not “best  
practice” from a responsible  
gaming standpoint  
Board struck language  
limiting use of  
information  
Board struck language  
limiting use of  
information  
PointsBet  
Andrea Hansen on  
behalf of FanDuel  
LIGA  
LIGA  
432.672(4)  
Andrea Hansen,  
Written  
432.672(4)  
Would like to exclude an  
excluded individual across all  
properties and platforms  
Change  
Board struck language  
limiting use of  
information  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 16  
Andrea Hansen on  
behalf of FanDuel  
Robert Russel, RMC, on Written  
behalf of GAN  
LIGA  
LIGA  
432.674(1)  
Change “and” to “or its”  
No change  
Change  
They only need one  
exclusion list  
Board to leave as  
business decision  
432.674(3)-(7)  
Question about state-wide  
exclusion versus casino-specific  
exclusion. If an individual self  
excludes for casino X, can’t also  
exclude them for sports,  
right? What about if a person  
excludes for casino X, can  
we/should we exclude them  
from the casino Y site as  
well? (Same platform, but  
different operator)  
Tammi Barlow, William  
Hill  
Written  
LIGA  
432.674(4)  
Can someone self-exclude  
without first establishing an  
account?  
Change  
Any individual  
requesting placement in  
the self-exclusion list  
must submit through  
his or her internet  
wagering account or by  
another means  
authorized by the  
Board a completed  
request for self-  
exclusion.  
Andrea Hansen on  
behalf of FanDuel  
Written  
LIGA  
432.674(7)  
Propose striking this rule because Change  
it adds complexity and creates an  
unnecessary potential for  
Board struck language  
limiting use of  
information  
confusion, and it is not “best  
practice” from a responsible  
gaming standpoint  
Andrea Hansen,  
Written  
Written  
LIGA  
LIGA  
432.674 (7)  
432.675(1)  
“exclude one, exclude all”  
Insert “must knowingly”  
Change  
Board struck language  
limiting use of  
information  
(Honigman LL) on  
behalf of Rhea Loney,  
Penn Interactive  
Andrea Hansen on  
behalf of FanDuel  
No change  
board retains discretion  
on enforcement  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 17  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.675(1)  
432.675(1)  
Add language referencing R  
432.651a re: age and identity  
requirements  
Add “This subsection shall not be Change  
construed to prevent an  
individual from creating an  
internet gaming account and  
depositing funds to such an  
account even if they are  
No change  
Not necessary  
Andrea Hansen on  
behalf of FanDuel  
A prohibited person  
may be able to create  
an account  
prohibited from placing certain  
wagers.”  
Andrea Hansen on  
behalf of FanDuel  
Written  
Written  
LIGA  
LIGA  
432.676(1)  
432.676(1)  
Add language referencing R  
432.651a re: age and identity  
requirements  
No change  
Not necessary  
Andrea Hansen on  
behalf of FanDuel  
Add “This subsection shall not be Change  
construed to prevent an  
individual from creating an  
internet gaming account and  
depositing funds to such an  
account even if they are  
prohibited from placing certain  
wagers.”  
A prohibited person  
may be able to make  
certain wagers  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Gaming Public Comment – page 18  
;