“Testing Times”
1. Please give specific information on what services your company provides to the gaming industry?
Since opening its doors in 1981, BMM has been helping regulators ensure the integrity of gaming operations. BMM also ensures manufacturers provide gaming equipment compliant with established rules and that operators configure and manage their equipment as required. These services for the technical sector of the gaming market have evolved with the advancement of innovative and technological developments. Conducting tests to confirm that a gaming device is compliant with rules is not sufficient to ensure that it will remain compliant with the rules once placed in operation. To assist in providing confidence of compliance and integrity for operational equipment, BMM assists in writing technical standards and internal controls in order to establish transparency in the regulatory process. Upon request, BMM also provides its own experts to conduct operational audits to verify that equipment is installed and operating as required and desired.
2. Which countries do you primarily deal with and do you have any plans to move into other countries?
BMM is licensed or recognized in over 400 jurisdictions to provide its services as required. Generally these licenses and recognitions authorize manufacturers to engage BMM to provide testing services but these licenses and recognitions also place BMM as an available service provider to the governments in a consultation or advisory role. Since its inception BMM has expanded to meet the needs of its global clients and, as a result, BMM has become a local or regional service provider for many smaller companies. Currently, BMM has a global presence operating in ten countries with ten test labs. (map) BMM will continue to expand as required to meet the needs of its clients and the markets. As recently as 2010, BMM expanded its global footprint into Korea and Mexico.
3. As technology advances – meaning machines become more advanced – does this make your job harder or easier? Please explain your answer.
The short answer is, not necessarily. Advances in technology do not always translate into being better for the gaming industry. Concerns with security and integrity have always been the challenge for regulators who author the rules that permit technological innovations. The testing lab works closely with the regulator to assist in analyzing new products or changes to existing products to see whether the changes fit within the framework of existing rules. The manufacturer looks to the testing lab to analyze the equipment and verify for the regulator that the new product or innovation is reliable, auditable and operates with integrity. Should use of a new product require a modification to existing rules, BMM also provides that service.
4. What new ‘issues’ do advances in machines bring with them with regard to testing processes?
The newest issue, for bricks and mortar operations, will be the reliability on server based gaming where the servers are no longer in the same facility or perhaps in the same jurisdiction. While this concept is already successfully used for wide area progressives, a server based game using cloud computing will be the next hurdle for regulators. Typically, the non-gaming commercial world will continue to innovate with this new technology and that development and exposure helps pave the path for providing the necessary assurances that regulators will need for adapting and approving. Similarly and particularly in the USA, land based regulators are anticipating legal changes and are already looking to the testing labs to provide guidance for regulating internet gaming.
5. Which countries demand the most/are the strictest when it comes to machines?
Jurisdictions that take an active part in the creation of and modification to their technical standards seem to take the most interest in learning about the technological challenges to their rules and insuring that all products approved for use meet their standards. While some industry observers may say that this active participation in the review and approval process is being strict, the active role of a regulator should be seen as being an advocate for the gaming operators in their jurisdiction. If the regulator does not pose the hard questions to the testing lab and manufacturer, there may be products that operate with unanticipated results because the rules are not providing the necessary guidance for both the manufacturer and the testing lab. Specificity in the rules makes clearer the expected operation of the product.
6. Which have the most drawn out processes/the most complex legislation?
A jurisdiction that regularly meets with both testing labs and the manufacturers and engages them when attempting to understand new products or adapt rules for new technology will usually create the most complex legislation. Often there are bureaucratic/legal restrictions in the jurisdiction that cause delays to the rule making process as well. There are some jurisdictions that have comprehensive rules but expedited rule making processes. What may be perceived as complex legislation generally results in a well-defined process for establishing clear rules, the end result of which is that the manufacturer knows what to build and the testing lab knows how to conduct its tests for the desired result. A strong engagement process, while tedious due to learning curves and details, provides the regulator and operator with a greater chance of consistency in their gaming operations.
7. Which countries have the fairest and worst legislation in your opinion and why?
Whether legislation is ‘fair’ or ‘worst’ is in the eye of the beholder. The definition of fair for a manufacturer may be obtaining an approval for a non-compliant product in the interest of commercial enterprise. However, is that leniency fair to the operators or players? The objectiveness of the regulator to see through the issues and address each situation in a balanced manner is key to what will be deemed fair by all concerned parties. The jurisdiction’s philosophical approach to the application of regulations will be the measure for fairness. In the ‘worst legislation’ category would be rules with no guidance but it is the application of rules that all stakeholders evaluate. A jurisdiction with ‘bad’ or difficult rules that are applied consistently helps all parties to know what to expect when seeking approvals.
8. Which type of machine is most strictly regulated and why do you think this is?
A review of the regulations for land-based Class III operations will reveal the strictest gaming regulations. Rules for electronic Class II products have been developing as well and probably are a close second. The Class III rules have evolved with technologic industry advancements. Rules and accompanying operational internal controls for traditional slot machines were created to compensate for the inability to monitor all the individual transactions that made up the payout percentage or hold and to insure a certain level of payout. The early rules from the seventies and eighties never anticipated the many gaming innovations and, as a result, as new products emerged with the dawn of personal computers there also emerged many rules to permit yet control the revolution of Charles Fey’s invention. Many significant changes occurred including the randomness of the games which required changes to the rule and testing methodologies.
9. How would you like to see the international gaming industry regulated moving forward – which areas could be improved on in your opinion?
Although gaming in its many applications may be a global enterprise for many manufacturers and operators, it remains local for the regulatory environment. Regardless of whether the gaming is Class III, Class II, AWP, mobile, horse racing, lottery, internet or any other iteration, there will be some regulatory oversight which may or may not play an active role. The services of a testing lab are needed when a regulator requires or a manufacturer seeks independent analysis of a gaming product. The best of all options is when jurisdictions create clear rules, apply them consistently, and provides a mechanism for meaningful discussion of clarifications.
