brief summary of the changes that the retail operators made to their house rules in response to the commission's request from prior meeting? We didn't do that yesterday. We didn't, I don't know if that was intended, but, and I don't know if this further complicates the issue of the agenda. But could I ask one favor, Commissioner Skinner? You know, this is a little bit out of, out of, but we have to take a break anyway, I think for E. Could we all take a look at what's in our email boxes and then have him do that summary so we could get, I'd like to take a look at the submissions of the three because he just said that they're just sent them to us. So I wanted during our lunch break if we could look at it and then have him do what you just asked. Yeah, so right. So just to be clear, I understand that all three of the category one operators made the change in response to yesterday's discussion on obvious errors. But in addition to that, I understand that there were other amendments made in response to the last meeting on house rules where category one, category one house rules was discussed. So I wasn't present for that meeting and because we didn't address those specific changes in yesterday's meeting, I was hoping to get it clear for the record exactly what it is we're going to be voting on today relative to the category one house rules. All the changes, all the changes from what we adopted when you were here. Yes, all the changes. Does that work for you, Sterl? If we take a look, we're going to see the red line from before and yesterday's, correct? So in yesterday's packet, the red lines are in all of the details from the changes. If I'm hearing Commissioner Skinner correctly, it's just the changes that were from the approved ones that are online to here currently, correct? Yeah, that was the document yesterday at the very end of the meeting, right? Okay. Those were all the changes that were made by the licensees. Each one had a little bit different things to do. Okay, so if we look at yesterday's packet for the earlier changes, we're not going to see those reflected in what you just sent out. What you're going to see is just the obvious errors. Though the one I just sent out will be just the obvious errors. So we've got to look at two sets of documents at the site. I can send both of them if it will be easy for everyone in one email to everyone if you would like. I understand where to look for the documents. I'm just asking that there be a public statement or summary of the amendments that were made just because they're amendments. I think we're going to do that. If you don't mind if we could just put it in our heads and review them and then he'll come and summarize right at the top of our meeting after lunch. I hope it's okay for you. If you're not prepared to do that, that's fine. But I'm hoping you are. No, I am. I can do it an hour after lunch. I think lunch will help us if you don't mind. Half an hour and then will that help you, Karen, if we just use this time to take a look at that? How are we doing on item D? You're on mute, Karen. I'm sorry. I was just speaking with Director Vand doing a final review. The document is ready to go. So we'll add that to the packet, send the final version to the commissioners and we'll be ready to go when you are. So for the category three house rules, we're dealing with that after lunch, right? We're voting on them after lunch as well as the operations certificate. Oh, I'm sorry. Category three. Okay. I made this understood. The memo is ready to go with the assumption that the commissioners approved the house. Okay. That's where we are. Yes. So that's right. So my mistake, Karen, and you need that for just the online. Just the online. Exactly. So we can come back and do the retail after lunch, but we do need to move on the online now. Correct. That was my understanding of the plan. Okay. And it's best if we take them one house rules at a time, correct? Let's do it. Do I have any emotions with respect to, emotions with respect to the health rules for the online sports wager? Category three. Okay. Madam Chair, I move that the commission approved the house rules submitted by the category three sports lead during operator Penn Sports Interactive has included in the commissioners packet and discussed here today. Second. Any discussion? Commissioner Bye? Aye. Mr. Hill? Aye. Mr. Skinner? Aye. Mr. Maynard? Aye. And I vote yes. Five, zero. Another commissioner or commissioner Skinner? Either one. I'd be more than happy to move that the commission approved the house rules submitted by the category three sports way during operator bet MGM as included in the commissioners packet and discussed here today. Excellent. Second. Thank you so much. Mr. O'Brien? Aye. Mr. Hill? Aye. Mr. Skinner? Aye. And I vote, oh, sorry, commissioner Maynard. Aye. I need lunch apparently. And I vote yes. Five, zero. Thank you for bet MGM. Moving on to Caesars. I have a motion. Mr. Skinner? I move that the commission approved the house rules submitted by the category three sports majoring operator, American majoring Inc. DBA Caesars sports book as included in the commissioners packet and discussed here today. Second. Second. Okay. Commissioner O'Brien? Aye. Thank you. And she had the second as well. Commissioner Hill? Aye. Mr. Skinner? Aye. Commissioner Maynard? Aye. And I vote yes. How about for Draft King? Madam Chair, I move that the commission approved the house rules submitted by the category three sports majoring operator Crown in May gaming LLC doing business as Draft King as included in the commissioners packet and discussed here today. Second. Any discussion? Commissioner O'Brien? Aye. Commissioner Hill? Aye. Commissioner Skinner? Aye. Commissioner Maynard? Aye. And I vote yes. Five, zero. All right. Now bet there. I move that the commission approved the house rules submitted by the category three sports majoring operator bet fair interactive DBA fan dual sports book as included in the commissioners packet and discussed here today. Second. Mr. O'Brien? Aye. Mr. Hill? Aye. Mr. Skinner? Aye. Mr. Maynard? You say aye. Aye. Thank you. And I vote yes. Five, zero. Madam Chair, I moved that the commission approved the house rules submitted by the category three sports majoring operator wind bet as included in the commissioners packet and discussed here today. Second. Thank you. Commissioner O'Brien? Aye. Mr. Hill? Aye. Commissioner Skinner? Aye. Commissioner Maynard? Aye. And I vote yes. Five, zero. I want to make sure I did vote affirmatively on Vandal, correct? Yes. Thank you so much, everyone. I'm making check marks and I'll make sure I recorded my own vote. All right. We've dealt with the waiver, the operation certificate will deal with after lunch, the first before we turn to operation certificates after lunch we will turn to the retail house rules that have been amended and we'll just ask Gerald to walk us through those amendments. Those that were prior to yesterday and the ones that we dealt with today. Okay. And thank you to Uncle Bosch's Margaret for getting that done. One 16. We'll return a quarter of two, one 45. All right. Thank you so everyone else after that. Thank you so much. All good to go. Thank you. Okay. We're reconvening the meeting of master's gaming commission holding this meeting virtually. So we'll do a roll call. Good afternoon, Commissioner Ryan. Good afternoon. I'm here. Good afternoon, Commissioner Hill. Hello. I'm here. Good afternoon, Commissioner Skinner. Good afternoon. And good afternoon, Commissioner Maynard. Good afternoon. So we're going to get started again. We're reconvening public meeting number 442 and we left off having just approved the house rules for the category three operators. There are six of them at this time. We have one that will be returning for their house rule approval at a future date as they look to launch in the near future. But we did need to return before we go to item 14 on the agenda. We want to turn to the category one house rules and their request for amendments as well as their response to our decision yesterday with respect to obvious, but we decided they're not necessarily so obvious errors. So I think we're going to have Sturrell go through and Sturrell, if you want to remind us of the fact, I think they're alphabetical order, am I wrong? But there's so many pages. If people want to turn to it, you could start with the number page. I don't know if you have that. It's a 1089 page document from yesterday. Small document, yes. It's a small document, but I love saying that we have a 1089 page document in front of us. Sturrell, we'll turn to you for the three retails. And today, we appreciate the fact that Armour Corp Boston Harbor got back to us on yesterday's issue. So we should be all set now. Correct. So I have two options for the commission. I can either go through my document that just lists out all of the changes from them, or I can go and direct you to each page in each of the operators house rules in the packet. Which would you prefer? Madam Chair, so I asked for the summary. I don't need you to go through each of the pages. I'm just really looking for kind of quick and dirty summary. It's just helpful for me to have you confirm my understanding of what the changes are, because again, I would be present for that meeting. So this doesn't have to be in depth. So the answer to the question about going line by line, page by page, I don't need that. But I defer to my fellow commissioners. Yes. Thank you, Commissioner. Commissioner, are you all set with respect to this? Just an overview is all we need, Madam Chair. Okay. Thank you very much. Okay. Then in that case, I will share my screen and I will increase the font size when I get it to it. Is that a good size for everyone? Okay. Yes. So Encore Boston Harbor updated how they contact the commissioner for unresolved patron complaints. And we provided all of our licensees with this language. And Encore has updated it to state exactly what we wanted to. As you can see the change we were being contacted directly by the division. There's the exact email, mail, and phone number options are now straightforward to the consumer. They cleaned all their grammatical errors. They're very like commerce. It's very minor on there. And then of course, from today's or from yesterday's meeting, they have addressed their obvious errors section. MGMS, MGM Springfield, they added specific maximum and minimum wagers that are to be accepted. They now list that it was from 50 cents to $10 million. They deleted a line about payout ratio limits and they deleted any reference towards penalties. So listed here they had one in their football section and then they had yellow cards in their soccer. PPC, they added specific minimum and maximum wagers that were to be accepted. They list out that it is $10 million as well and $5 as a minimum. They cleaned their grammatical errors. There were small references in their prohibited players from inserting it from the pen interactive. They changed Parley language in section five just to be a little clear. The bet is made as part of a Parley. Shall we remain valid notwithstanding a matron event which is part of the Parley bet being made void. Of course, again, we have specific voids but we also have voids in which are by regulation that would fall under the Parley. And then they removed penalty language in event areas. So there was one here in their bet types referring to it with the first card. They had one referring to it. It's just in head to head as team will receive a yellow card and then settlement of penalty offers will be based on the penalties being accepted. They removed that section in port two. And those were just the changes that they had to their regulations from the one that was on our website. Of course, they all have now addressed the obvious errors in the document sent today. Is there any other further questions? Questions commissioners? All set. So we are looking to approve those amendments today as well. I have a motion. I'd be more than happy to make the first motion, Madam Chair. Thank you. I move that the commission approve the amended House rule submitted by the category one sports wagering operator, Penn National doing business as Plain Ridge Park Casino as included in the commissioners packet and discussed here today. Any other questions? Mr. O'Brien? Hi. Mr. Hill? Hi. Mr. Skinner? Hi. Mr. Maynard? Hi. I vote yes. Five zero. Thank you. Madam Chair, I move that the commission approve the amended House rule submitted by the category one sports wagering operator on for Boston Harbor as included in the commissioners packet and discussed here today. Second. Thank you. Any questions or edits? Mr. O'Brien? Hi. Mr. Hill? Hi. Mr. Skinner? Hi. Mr. Maynard? Hi. And I vote yes. Five zero. All right. Next. Mr. Hill? Madam Chair, I move that the commission approve the amended House rule submitted by the category one sports wagering operator, MGM Springfield as included in the commissioners packet and discussed here today. Second. Thank you. Any questions or edits? Okay. Mr. O'Brien? Hi. Mr. Hill? Hi. Mr. Skinner? Hi. Mr. Maynard? Hi. And I vote yes. Five zero. All right. Well done, Starle. Thank you so much. Thank you all. That was a very big, big project and an important piece of work as we move on to 4D. So thank you. I'm going to turn to Karen and Bruce. Thank you. Morning, Madam Chair and commissioners. We're moving on to the sports wagering operations certificate for the mobile operators. The sports wagering operations certificate falls under 205-251. And today, before you, we have a request from American Wagering, which is also known as Caesar Sportsbook, Bet MGM, Crown MA Gaming, also known as DraftKings, Betfair Interactive, that are known as FanDuel, Penn Sports Interactive, and WinBet. In accordance with 251, Class Category 3 operator certificate shall not issue unless sports wagering operator is demonstrated to the commission that is complied with all the requirements of 23N205-CMR and the applicable laws. Such compliance includes but is not limited to approval of the system of internal controls, including implementation of approved policies and procedures required. Provision of the current list of sports wagering employees, sports wagering vendors, and non-sports wagering vendors. Compliance with any other conditions imposed by the commission to secure objectives of 23N and 205. There are a number of other requirements in this section that only apply to Category 1 and 2 operators. A note of internal control process includes approval of the house rules and responsible gaming plan, including voluntary self-exclusion protocols in 205-233.066. Prior to the issuance of the operations certificates, sports wagering operators shall successfully complete an evaluation of the test period in accordance with such terms and conditions as reasonably calculated by the commission to allow the commission to assess whether the licensee is in compliance with 23N205-CMR-251-205-CMR-2502. This process will be conducted by GLI and include a review of the geofencing capabilities upon successful completion of the test period in accordance with 205-2502. The commission shall establish the effective date of operations certificate and the scope of the sports wagering operators authority to conduct sports wagering. 205-CMR-2501-031, each certificate once issued shall remain in effect throughout the term of the sports wagering operators license under such terms and conditions as the commission may impose, but may be revoked, suspended, limited, or otherwise altered by the commission. 205-CMR-251-32, each sports wagering license to which the operations certificate is issued shall conduct sports wagering strictly in accordance with the terms of the original operations certificate and shall not change any of the items to which the operations certificate applies except as otherwise approved by the commission 205-CMR-2501-033. Listed below are the results of each applicant. American Wagering Caesar Sports Book. I might add this is the only one that is requesting a waiver in their application. The wager was attached in it. As far as the internal controls go, that passed through JLI with no major findings in their submission. Staffing and vendors and non-sports wagering vendors, there's no issues to report. Compliance with any other conditions imposed by the commission to secure their conditional upon Caesar Sports Book completing operational audits of the wagering procedures and practices and technical security controls as required by the commission, the standards gathering, sports wagering, within 90 days of commencement as a sports wagering. Geofencing capabilities passed. Player management. This is where the requested wager comes up. They did not pass when it came to the requirement of 205-248-16 when you put a limit on and they could change the requested limit, but they couldn't change it again in a second dairy thing. They have this change request in with JLI right now. JLI had asked that there is another change to it and they're hoping by the end of the day, I believe tomorrow or today that they will have this debt out of the lab again. So this would be the waiver that they're requesting right now that they be allowed to proceed with this in effect. Is that that they've done the fix, but they're waiting for JLI to confirm? They're waiting for the approval on the fix through JLI, yes. Good afternoon, Joe. Thank you. I'll let Floyd introduce himself and speak to the commission here. That's okay. Fair. Go ahead, Floyd. You might want to introduce yourself. Thank you, Joe. This is Floyd Baroga, Vice President and Product Compliance for Caesars. So to add up, as far as what Director Ban mentioned, Caesars has finalized the update for JLI and this morning they've confirmed the closure of that issue and we do meet Caesars Sports Waging Platform does meet the 205-CMR-248-16 section 2. So that would close off all of the items that JLI flagged in their evaluation and I believe that report will be issued later today. So depending on the recommendation of the commission, our platform is compliant with all of the current adopted regulations associated with the product. So depending on, you know, there's the administrative process of JLI providing that report and then the MGC approving. So we can see this can either rescind that conditional approval request or, you know, maybe suggest a conditional approval for a week. We will go live with the update but if there's any administrative process needed, then that would give us time to give the commission time to approve that and and do with the due diligence. So to clarify, have we heard that there is now compliance that JLI is signing off on verbally right now? Good afternoon, Commissioner. I just kind of want to jump in just to reiterate and just verify what Floyd had mentioned. It was submitted, it was fixed, the system is verified, the letter will be issued by end of day today. That sounds good. So it doesn't sound like provisional is even necessary, right? It sounds like they're good to go according to JLI, right? Well the official letter, I mean this just came out of the lab, I just got this over the wire like honestly minutes ago. So the actual official letter has yet to be issued. So the current letter they have has the stipulation which would require a waiver. But that's the actual status right now. So here we are. But it's a ministerial execution in terms of updating your letter, right? That is correct. Correct. Let's just slow it down for a second. We've got, Kristen has joined us. Joe, I just want to make sure that the letter that is issued, that has the mentions the a need for a waiver or a condition was issued by JLI. Correct. And the letter that Gabe says it's going to be ready by the end of today will be issued by JLI. Correct. And you are saying that you know you can tell us that what will be content of tonight's letter? Is there any comment? It will be the exact same letter that was currently issued except the exception will be removed. That one stipulation has now been qualified by Floyd's group and verified by JLI. Okay. And I'm just going to ask one more question. I'll turn Kristen, my fellow commissioners. I know that there's a little bit of time between now and whatever time you're going. Is there any chance that there'll be a different decision by JLI? No. Thank you. Kristen? Yes. Once we receive the letter today, I'll review it and I'll also verify against the hash signatures that exist now on Cesar's platform. So I'll do one more check. So there is an additional check by us. There's the process commissioners. Excellent work, everyone. Ruth's really nice. Nicely done. All right. I'm trying to think if we can, you're going to continue, right, Ruth? Just one clarification for Christian. The signatures as far as what JLI will be issuing will be the same. So that validation that the lab has conducted will still be valid. It's, we configured the environment so that JLI can verify that we're compliant with the regulation that was requested. Kristen? I understand. I agree. Great. Ruth? Yeah, I kind of agree with what they're saying with this. I don't see why this should hold it up that they're going to get the approval. I hope you have a follow-up for Christian. Yes. Thank you. I'm just looking to see what's in our packet. And we have Cesar's, DraftKings, Vandal, and Barstool. Yes. Thank you.  Christian, I don't mean to put you on the spot, but do you have any reason to believe that your check, your internal check of the letter issued by JLI will not meet the requirements? No. Okay. Thank you. Thank you. I'm just processing, guys. I feel like I'm short on JLI documents. I've got Cesar's, DraftKings, Vandal, Barstool. You have in that they're the internal controlled documents, not the geofencing documents? No, no, no. But in terms of, this is for the certificate of operation, draft 4 out of the 6 with pending items. Am I looking at the wrong document? The other thing you have in there is the waiver request from Cesar's. Yeah, I have that. What about BetMGM? BetMGM should be in there. Pack it or the email? This is the timing I have is... There's an email from 126 this afternoon. Yeah, that's what I need. Let me just see.  Yeah, thank you. I'm working hard on documentation, guys. So thank you. And it came from whom, Patricia Skinner? It came from Bruce. I just sent it to the... That was Karen. I'm sorry. I just sent it so you should get any seconds. And there are all six PDFs for each of the... Yeah, thank you. And the conditional request and the memo? Yeah, I read the memo and I only had four and it didn't make sense for the memo. So thank you very much. Okay, that's going to be much more helpful to me. This is just because I was scrolling for the wrong names during my lunch breaks. Thank you. So questions for Bruce on the process of just determining that the certificates can issue. And Director Wells, please chime in. And whoever else should be chiming in. Anything that you want to add? Karen? No. Actually, we'd like to, you know, Gabe and Joe have been tremendous. They've been with us every step of the way on this process. They've put in a tremendous amount of work along with their team. They've got all these done by this date is incredible. So thank you to them on the testing process and all that. Very grateful. Yeah. So in terms of walking through any desire commissioners in terms of needing to go through one of these just to kind of point it with a certificate? Are you comfortable having gone through? It was all real time today. I know we're pressed for time, but is there a way to just go through really quickly? High view for the record? One of them? I feel like we should probably do that because we did just get them and we're painting ourselves. Yeah. I had the others. I don't know. In terms of being pressed for time, do we have a hard stop today? I know that we have excused Mark from the item. So I think this is our key decision today. So I want to make sure everybody, this will allow online sports wagering to occur tomorrow. So I do want everyone to be very comfortable. This is the process that had to occur kind of with this kind of timing. So Bruce, does that make sense? And with Joe's help and Gabe's help to just go through this process a little bit more? Yes. Thank you. I appreciate it. Which one do you want to go through? Just use one and then who are you pulling up? So where do you want to go to next? Which one do you want to start with Barstool? Just use that one as the first alphabetical order. Sure. With Barstool, you mean as far as looking at their attachment? Yeah, looking at the certificate, the GLI. I could just walk through that. Maybe it's with Joe and Gabe, but it's the report on the assessment. You want me to share my screen? I see Commissioner Hill saying yes. Okay. See, and I will make it bigger. Everybody see that? Looks good. Everybody see that okay? You want bigger? A little bigger? Yeah, Commissioner Skinner, I can see her leaving in. Yeah. For the future, anytime you want to put a font of 150, feel free. I know. But my computer is kind of acting on its own. That's okay. Looks like he froze. Bruce is frozen on my screen. I don't know if... Yeah, he looks it on mine too. I may stop sharing his screen and it may jolt him back real quick. I'll see if that helps. It looks good. There you it. It has any questions? Bruce, you did freeze. You looked really nice when you froze, but you did freeze for a bit. So we'll have to start at the beginning again. I don't know if there's any way to just have the document, but we do see a little bit of the... That's fine. Okay. Can you see the executive summary? The rest is really who did the evaluation. Basically says that, you know, sports waging is approved in Massachusetts. This is the scope of their evaluation, how they approach this. I have to scroll down. Yeah. My scrolling thing isn't working the best on this, but... Sorry. The conclusion is the most important thing. So they identified none all together, even the most. Okay. And I asked the question, and Commissioner is chiming too. If we were to look at all six, that's the conclusion the same. Yeah. Oh, no, no, no. Pretty much so, yes. I say this is, I think, out of the report, the most important thing that you guys would be interested in. Okay, everybody. Commissioner, is there any questions on those? Bruce, when you said pretty much, can I just ask Gabe and Joe, were there any of the other that had different findings, or were they all the same with the no, no, no? All risks, categories. I'm entirely sure of the question. I mean, it's a... I could say this. It's a pretty massive audit that we went through and process here. I believe there's almost 1200 line items on the template. And there was multiple teams assigned to the different operators. So that, to answer that question with full confidence would be, take me some time. Yeah, I was going to say, if you want to go on the document page to 124. There we go. There is a summary, I think. Yeah, go Gabe. I was going to say, if you go to 124, that's another, I know you wanted other examples from the other licensees. If you go to 124 in your document page, it's going to be Caesar's. Of Caesar's? Yeah, it's 124 on that document. And then if you go into the findings, you'll see, right, none of them are going to have any major non-conformities. And anything that was brought up during the audit would have been addressed with the licensee at that point before anything would move forward. And we, if you keep scrolling, it should be page 124 on the revised packet. Okay, this only goes up page 16. Yeah, it's a commission packet, Bruce. So if you look at page 124, if you pull that down, Bruce, I can bring it up. Okay. Or I could share it. And I didn't mean to disrupt, but I think probably, as you knew where it was going, I just, we saw that finding, and I just wanted it to cross the board. It was similar, but I. No, again, adoring it, if there was any kind of issue, there would have been addressed with the licensee. But okay, for example, if you see down here, there's some points of emphasis and observation would have been made, which are considered low risk. And if you look at a standard audit, you would have actual non-compliance, non-conformance. And then you would have these observations as something that would go in a management letter, which is basically saying you're compliant, but we think you can do better. And this is what these areas of observations would be that GLI has worked with the, with the licensee zone. So these two areas, the major non-conformities and minor non-conformities would be places that you're not compliant with the internal controls and the regulations that we've put forward. And these observations are things that you would say, hey, you're there, but we think you can get better based on, based on your peers in the industry. And if you scroll down just a little more, you can actually see the, okay, yeah, stop right there. You can actually, you can see it in the actual environment itself. And then it's easy. Yeah, so you're finding right there. So that's really helpful. I would refrain from using finding, I would say observation. Observation. Yeah, in all of the world, it's two different things. Yeah, I don't want them to. So if you could just go back up to the summary, because I think that's for us the highest level we saw for, who was our first? It was a bar stool, right? There were no observations, no. They were just in no major and no minor non-conformities. So you come to Caesars, commissioners, I'm curious to know if there's any other of the six today for observations. And then I'm also curious to know about these observations, but I, this is just me. If we want to go through without disruption, I apologize, because I know I said, let's go through the document and now I'm disrupting it. Do you want to do a comparison across the board on the subsection four? Do you want me to go back up to bar stool so you can see, then go to bed MGM and then go? That's what I'm wondering. I don't want to disrupt completely, but it does show, I see now the comparison. So maybe we should go back up to bar stools and commissioners. So we were at section four. Whoever's sharing, if you could just call up the page numbers as we go through, that would be helpful. I will. Got the very, very top there, little and tiny, tiny. So I think this is our first one for bar stool, and we are at page 92. And there were some observations. There were. Thank you. Oh yeah, temporary proposition. So commissioners, do you want to go through this, these summary of findings with more carefully with Bruce and Gabe and Joe? I need a little bit of input from you, I guess. I think it makes sense if that's, if that's what you need to feel comfortable, Madam Chair. At least there's two of us. Thank you so much. So Chair Judd Stein, I would recommend that these two areas, major nonconformities and minor nonconformities, you see nothing there. And then under the observations, I don't think that should hold up opening or discussion. But I think you, if you take a look at these areas here and see these first two areas, nothing, no major or minor nonconformities move on to the next one. And then if you have an issue with an observation, you could follow up with the staff after the fact. Otherwise, you're going to get into management level discussions that do not impact compliance with our internal controls or our regulations as written. And just to add what Derek was saying, you know, an observation is really to ensure good practice that gets, that's kind of below the internal control procedures that gets into what Derek alluded to, your operating procedures and management decisions. So this is Commissioner O'Brien though, on that particular reg reference for that observation, because of what it is, I'm just looking for a little more clarity. I'm assuming that because the specific 72, 1 week, 2 week, 3 week was removed. That's why they're nonconforming with that at this point. Because that's the section that we initially had prescribed set time periods and we realized it was better to not do that. So if that's the only reason that that observation is in there, I'm comfortable. If it's something beyond that, that's different. In other words, I do think we might want you to give a little higher level of the observations. Yeah, just I mean that particular one because of what it is. Yeah, just if you can confirm for me what I'm thinking it is, that would be great. Or if it's something different, obviously tell me it's different, but I can speak on behalf of the audit group that did this. I'd have to dive into their notes, their work papers to see. I wouldn't feel comfortable answering on their behalf. And that's going to be true as we go through this, all of these documents. Yeah, again, I mean, it's okay that there are findings and I will note that every single regulation you see here has a subset of lists and every single one was checked to which the report shows there's findings. I mean, we're going to be here a week if we drill into every one. Yeah, I don't want to do that, but I also don't want to gloss over something that for all of the commission was deemed pretty important. So I'm not asking for that, but if there's, you know. And again, Commissioner O'Brien, these are observations. They're not major or minor. I know.  Right. Although that observation says that they're not consistent with our updated requirement. Right. I'm going to ask for a five minute break, please, if you don't mind and regroup, because I think Commissioner O'Brien is asking fair questions. Thanks so much. Someone is unmuted. Okay, Dave. Sorry, a little bit longer than five minutes, but some good assessment and planning. Remember, you have to reconvene, so we're holding this virtually. I'll do a real call. Commissioner O'Brien. I am here. Commissioner Hill. I'm here. Commissioner Skinner. I'm here. Commissioner Maynard. I'm here. Right. And I thank everyone for being patient. Remember, these documents did have to come to us kind of at the last minute when we were really issuing, issued pursuant to our last vote. So we knew that there would be a little bit of a collision. So we just talked a little bit about process. And I think Karen will be coming on. I do believe that perhaps it was a little bit of a miscommunication. And I want to clarify that. I want to thank Gabe and Joe from GLI for being on board. We've got Bruce back. And then Derek also weighed in. I'm going to turn to Karen where we left it. Karen, if you could, I see Joe's got his hand up. But I'm going to start with the executive director. If you want my job. Thank you. Yes. Thank you, Madam Chair. Yes. Just to clarify, I think we just need to get all on the same page here is that my understanding that commission is not looking to go through every single thing that the GLI team tested. They're just looking for some high level. And I spoke again with GLI regarding what is a major nonconformity, what is a minor nonconformity and what is an observation. And that the major and minor nonconformities were things there may be a violation in the reg. However, the observations are more at that high level. Look that there didn't seem to be any kind of violation or no reason to not launch the operators going forward. But as we go forward in the process, there may be something we want to look at going forward and work with them. They're not the way that the GLI team went through all these. You know, they'd have to pull work papers and on the observations, they did look up the answer to the question that Commissioner O'Brien asked. So they may not be able to do that for all of these. We could certainly come back for another commission meeting to go through observations if we've wanted anything, any specific question answered, but we may not be able to answer the observations today. But what from what they're indicating to me that should not impact the launch, but they would do their best to get the information to the commission because they're entitled to any information that they want. It just may take a little bit of time. Does that make sense? So my recommendation again would be this and thank you, Karen. That does make sense. There is in each GLI report a section for with the findings. And there's a notation about major nonconformities and minor nonconformities. Commissioners, we have our decision making is this. We have to decide whether or not we can authorize the issuance of the certificate of operations. Those findings are going to be telling for us. We are going to rely on the expertise of GLI and the testing in the S. Ports-Wadring Division in IEP. The observations are noted. The GLI won't have necessarily answers for all of them. But what I think we could ask of GLI, any observation, something that we have to consider as risk high enough to consider for operations? My thinking, Karen, given your assessment is that both the observations, if they were impactful, they would have moved up on a noncompliant. That is 100% correct. Okay. So what I think when we're looking at the observations, what you're saying is if it's something of note, we could take it up later or GLI and Bruce's team will be taking up later. Correct. So I had, when we first got to that thought, it might be helpful to look at section four across the board because for all six of them, because it would indicate to us, do we have any concerns? I do think there's also the exercise of going through the document, just what the document is on a high level, not going through each element at all, but just going through the high level of what the document is, and then maybe returning to section four, do we have any issues? Now, Turner-Jo, do you have another recommendation or am I clear? I do. I just wanted to note that I have brought on Torsten Toms, who works directly at GLI, who you have met on previous calls and maybe at GLI university events. He has extensive experience as a regulator and he was part of the audit team. Again, like I said, there was close to 17, we'll call it 20, 20 individual people who worked as teams to get these audit reports completed. So it was a monstrous task and Torsten was part of one of those teams and worked on one of these reports. So if there's very specific questions to the process or the verbiage on the report, Torsten is I brought them on so you can answer those questions. Thank you so much and thank you, Torsten. And good to see you again. So commissioners, do we want to go through one of the documents for format, high level to understand the process, and then how do we feel about just going across the board with section four, I started to look at them, but I didn't know if everybody else had the chance to do that exercise. Commissioners, I'm all ears if you have ideas for process. That makes sense to me, Madam Chair, to do the walkthrough on one and then across the board on four. And we'll turn to your specific question in a second when we get to that one. Okay. And other input, Commissioner Hill, how are you feeling about that approach? This is what the majority of the board would like to do, then I will move forward with it. I was able to go through during the break and look at section four in all the applications and I'm fine with moving forward after looking at that and from hearing from GLI that there doesn't seem to be any major issues that we should be concerned of. However, if there are other members of the commission who want to go through the exercise that you have outlined, I'm okay with that. Commissioner Scanniel? So I have an understanding of the differences between a finding and an observation and I absolutely agree that there are items that are more urgent for the commission's attention and it's my understanding that we don't have any of those urgent items today. There's no reason to call into question GLI's judgment there. I was comfortable moving forward with that representation and going through the votes for the operations certificates but I do understand that there are questions remaining of my fellow, among my fellow commissioners so I'm happy to just to walk through the process because I want us all to be comfortable. I do think that the point of reviewing the observations at a later date makes total sense because while the observations don't suggest that any of the operators are out of compliance with our regulations, we can always take a recommendation to improve the process, our regulations and perhaps amend them at a later time. So it's good to know what those observations entail but again, I'm comfortable moving forward as is with the representations made by GLI. Okay, I don't know if we've had full representations yet from GLI but we can get those certificate. I don't think anybody was calling into question GLI's judgment. Certainly I'm going to speak for me, Commissioner O'Brien. I think I want to make sure that because that's not we would just think understanding process in terms of has everybody had the chance then to go through the document because there's no need to if we, Commissioner O'Brien, are you comfortable? Would you like to walk through? Hi, for transparency to be blunt in the open meeting, I think it wouldn't be a bad idea to just walk through on a high level what this is on one of them. I really don't. I agree entirely. This is a very significant decision. He's just came to us. We've got Bruce Banner expert. That's only two of us. Commissioner Maynard, how do you feel? I will never stop any commissioner from wanting a more detailed review than what I'm satisfied with. And so that's where I'll leave this. Okay, I'm sure let's go through the document. Jared, can I just clarify? I'm in support of walking through the document and I think I made that clear. So that's now four of us. I think five actually because Commissioner Hill is also on the same page. I wasn't sure if you were or not. Okay, thank you. My apologies. All right. I just want to confirm with GLI these documents. There's no issue because there is a red confidential on there. But my understanding is all this is available to be shared publicly. It would just be more but more detail about some of the information may trigger some confidential information. I just want to be sure because. If it's marked confidential, it shouldn't be shared. I can speak strongly at that. I mean, again, this is a pretty massive undertaking. So there's a lot of line items and what was marked confidential will be clear on the letter. It should be. I mean, just so you fully understand a little bit of the process and also the internal controls themselves. Some of these control controls aren't actually active because the sportsbooks aren't active. So that's also needs to be considered going over this review. While they do have policies that should fit those things, there is more process to be taken place in the audit to make sure that while they're actually live, things can be verified. But I will make one more note that some of the things that got checked off actually happened over share, like screen share because of confidentiality. So it's just how the audit process works. Derek, did you have a thought on that? Yeah, so I have a question for you, Joe, on that matter. So these are the summary reports. We don't have the work papers behind it. Are the summary reports public documents or are they because every page is marked confidential in your summary report? I'm not a lawyer and really can't speak. That's not a question. I think a Todd way in case. Thank you. We have these have already been put in the public domain. I mean, the real question is whether there's any sensitive information in there. There's been no request. So we don't have to share this information publicly at this point. And so that is really the question. And I mean, a quick look, I didn't see anything myself, but there are certainly things in there that I might not have detected. So General Counsel Grossman, I believe that Karen explained that these documents would go into the public sphere earlier, and I believe they were posted. We need to take those down, Todd. Well, again, it depends whether there's sensitive information in there. Well, why don't I do this? Why don't we take a five minute break? Let me talk to them and be good. Thank you. Thank you very much for your patience. Thank you. I'll start again, Dave. Yeah, great. Thanks, Dave. All right, missionaries, Michelle, Brian, is there a problem right now? Can you hear me? Yes. But I can't hear you guys. You can unmute yourselves now. Somebody must have been shoddy at the break because we were all forced to do this. I am here. Okay. So are we doing a roll call? Oh, right. That was funny. Yes, Commissioner Brian. I'm here. Good. That was really good communication, Commissioner Brian. I just want you to know I was... I do it across the room with my children all the time. Like, you need to stop. Sometimes we see that look. We know that look. Okay, Commissioner Hill. I'm here and I was not the one that was shoddy. Yeah. Was I shoddy? No.  Got it. Commissioner Skinner? I'm here. Commissioner Meanard. I'm here. And I'm still here. Okay, let's get going. So again, patience for the public. This is real-time work at hand. We do have to work in the public sphere and we just want to get this right. And so, Karen, you were right to pause. Let's get a little update. Yes. So many thanks for the pause. Just wanted to confirm that we were doing everything appropriately. We are. So both through legal and we've checked with GLI that that document was designed for the public purpose. So as far as running through the process, the GLI suggested that Thorsten go through what one of the documents that he was involved in. And we recognize the Commission just wants a really high level. This is what we're doing. Not no need to go too far into detail, but just so they have a sense of what the process is. And then, Madam Chair, my understanding is we can look at section four if there's any, you know, my understanding is all of them in the major and minor are all set. So those should be consistent across the board. But, Gors, if you just want to start reviewing the document you had worked on, that would be helpful for the Commission. Thank you, Thorsten. Oh, he's trying to get unmuted. Let's see. Okay, star six. That's all I know. Oh, there you are. I'm here now. I kept hitting unmute and it kept saying the host is not allowing you to unmute. I must have been the chatty one.  Would you like me to share the document or do you have the document there to share? If you have it available to share, that's probably easier. All right, let me give it a try here. Thank you. The next step will be to have them, we're just going to fly through each section four and then have the Commission move if they are satisfied to move per section four. Okay. Are you seeing the document and it is that if it's sufficient size for people to understand it? Yes. And yes. Okay. So this is actually 148 of the packet, page 148, which is the beginning of the FanDuel section. And I'm the primary auditor for FanDuel. So I thought I'd walk you through this one as an example of how it's done. Just as a general overview for the way that I've done audits, and typically they're done, as has already been said, if there's a major nonconformity, to me that means a regulation has been violated and it's a serious violation, a minor nonconformity, a regulation has been violated, but it's not that significant. The risk is low. And an observation is just something where the auditor has seen something that does not quite seem right, but it's not a regulation violation. So with that in mind, let me just scroll through here. This first part, as you can see, is for FanDuel, for mobile. We have some reference information and they're all going to be the same. So the beginning of all these reports is going to have this information. As you can see, I am the report author of this. The quality was assured by another person on our team. And the confidential classification is, it's confidential for us at GLI. And if we send it to you and you decided to make it confidential, then you could, of course, keep it confidential. We're not going to share it with anybody, but you are a customer. And then we have the table of contents. Again, the table of contents is going to be identical for all of these. So this is kind of boilerplate. You'll see that for all of them. Of course, you are our customer. And the purpose of this is to go through and look at the internal controls and make sure that as far as we can tell before go live, because remember, we're doing all this before bed has been placed, are these internal controls provided to you and then on to GLI sufficient to meet the regulations? And that's, you know, there's a lot of words here, but that's what they say. That's what we're going to go through and make sure of. So what mechanism did we use to do that? The operators, and here we have more scope and methodology and things like that. But what the operators did is they submitted a set of policies and then kernel controls and other documents. We internally have a spreadsheet that has about a thousand checks, thousand steps to check. And here's the summary of findings. So for FanDuel, I found no major nonconformities were identified during my review. No minor nonconformities were identified during my review. At the end of the process, when I first went through them, I did find things and I reached out to FanDuel and they addressed those and sent updated internal controls, updated policies, updated terms and conditions, until in my opinion, they met the requirements of the regulations pre-launch. So it's not like we had a perfect set of internal controls, policies and documentation up front. It took a couple of back and forths to get that to the point where I was willing to sign off on it, to allow I was willing to put my name on this and say that they were good. Now let's get to the observation. In their documents submitted for review, they said that they were not a class one or class two licensee. Therefore, some of the things on the checklist did not apply. I took them at their word. So if they, you know, they said that that did not apply, I would look at that. No, yep, this is definitely class one specific. This is definitely class two specific. They're not doing that. So I'm not even going to check it. And in my document review, that would be, it does not apply. DNA I would put on that one. As we mentioned in the conclusion section above, this is all being done before anyone goes live. There are certain things we can't check yet, right? I mean, there's requirements in the regulations that you're going to be doing this thing. And I don't know that they're going to be doing this thing until they're up and running and live. So baked into this process is the requirement that within, I believe it's 90 days of go live, there's going to be a verification process to make sure all the things that they said they're going to do are being done, especially when it comes to the technical standards. So remember that before any of this has happened, the hardware and software identified as gaming has already been certified by the test lab has been verified by the test lab. So we've said, yep, this piece of software that they're using is capable of doing this thing. So for example, in Massachusetts, there's a requirement that you cannot place a bet on collegiate sports for teams in the state unless they're as part of a tournament. So the test lab verifies that the functionality to do that exists. In the document review, we verify that they say the right words, that they are going to stop those things that aren't allowed in Massachusetts. But we can't test that they actually are stopping those things until they're actually up and running live. So that would be an example of some things here in this number two, with the inclusion sections above, that we're not going to be able to verify that until we can go in and check after they've gone live. The last observation I made is some of the items I can't test now because they don't have a history of doing this. So if the requirement is something along the lines that a patron who wants to rescind a bet or something like that has a method for redress if they want to do that, I really can't check that now. Sure, they can have something that says they're going to do it, but until we have a history of these things happening, it can't be done. And those are things that I marked as auditable. In other words, this is something that should be checked at an annual or audit by someone, whether that's your investigative department, your audit department, but someone in the future should look at these specific regulations as part of a regular audit, which I'm guessing you're doing annually and doing a follow-up. That's where you would check those things. Are there any questions about this? And then I'll get into the details of what I found. Okay, so then this next section is really, really boring because what I did is here is the regulation and one of three things happened. They either passed, did not apply, or it's something that needs to be checked in a follow-up audit. These codes here, remember I mentioned a spreadsheet that had 1,100 rows in it? So in that spreadsheet, 205CMR243, questions in rows five and six referred to that regulation. And I found that they were in compliance. In other words, they passed. Those rows 7, 14, 17, and 531, they don't apply right now. They didn't apply. Could be header, could be something like that. And rows 544 through 552 need to be checked in an audit. And this document here, I just go through everything that was checked. And as you can see, there's no failures. Everything either passed, does not apply, requires verification. So here's one that needs to be verified within 90 days or should be checked at an audit in the future. And I'm sorry, Mr. Thorpe, this is Commissioner Bryant. Yes. How do we know the difference between what needs to be verified in 90 days and what it can be audited over the course of a recurring audit cycle? So within this document, the difference is the word verify and the word audit. Okay, because you said either needs just now when you did verify, you said either verified or audited. Sorry. I was unclear in my language, but I am clear in this document that audit means at some point in the future and verify within 90 days. Yeah, perfect. Thank you. And so as you can see, we went through, I went through all of these things and did that. Now, you'll notice that a lot of these things are verified. Well, remember, this is GLI-33 appendices. We knew all along that those appendices were going to have to be checked post launch, which is what this says. And then I went into great detail and all those things. And then if you look here, these are all the documents. So this is what FanDuel submitted and what I used to check their internal controls.  You'll notice there's some repeats in here. That's because they would submit something, we would have communications, they'd submit something updated that addressed any issues. So that's why you might see the same, for example, I think they have two job compendiums. So I found that they did not properly meet some of the regulation requirements talking about who is responsible for things. A good example is these, there's a requirement, the chief financial officer certified that the internal controls meet the requirements. They didn't have that. I requested it, they provided it. So this is a list of everything that they sent that I used to make this determination. And then this is more boilerplate just talks about all the rules and regulations that are there. Thank you, Thurston. Thank you, Thurston. Thurston, can I ask you one general question? Absolutely. You've been a regulator. And so we have to make a decision as to the certification process. We've now been walked through just to understand the process and appreciate that. The concept was to now go to the section four. That seems to be a reasonable reliance. Is that correct for us to be able to confirm no major, no minor issues on compliance? And then the observations we can turn to down the road, should we so choose? Is that reasonable? I think that is an accurate reflection of a reasonable way to go about this. If there were non-conformities, it certainly would be something that you as the commissioners would be most interested in. And then I would say a lot of these other things can be pushed to staff for future investigation. And if there is a problem, then they bring it to your attention. Excellent. That's really good marching orders for the future too. Okay. So can we scroll up to, this is Vanduul. We'll start with Vanduul. Commissions, let me pause. Are there questions for Dorsen? That's a good sign. All right. I'm going to suggest here that Dorsen not be the one driving. If you're going to do this process, maybe one of you should drive. We're going to drive it now, but we're turning to this process now, but I just wanted to ask that high level question, make sure we are taking a reasonable approach as we move forward. Very, very helpful. Thank you to GLI. So now, Karen, we'll just start with Vanduul because we happen to be in this document. Okay. But commissioners, looking at Section 4-1, Karen, do you want to, or DeBruce, do you want to walk us through it? Or Derek, I don't care, but we have no major non-conformities, no minor non-conformities. Who wants to help me, Karen? Sure. I'll go through that with you. So I think it's helpful if you just know that, so for Vanduul, the critical components are no major or no minor non-conformities. Dorsen already sort of highlighted a few of what the observation was. Observations weren't part of me, but they indicated that none of those would be rise to the level of not issuing the operation certificate. Commissioners, questions for Karen or GLI generally? Do I have a motion? Madam Chair, I move that the commission find that the requirements outlined in 205CMR 251 have been satisfied and that an operation certificate be awarded to Betfair Interactive DBA Fanduul Sportsbook for the purposes of operating a category 3 sports wagering operation, commencing March 10th, 2023 conditional upon Betfair Interactive DBA Fanduul Sportsbook completing operational audits of wagering procedures and practices and technical security controls as required by the commission's technical standards, governing sports wagering 205CMR 243.011S 205CMR 243.011X within 90 days of the commencement of sports wagering operations. Second. I got it. No, go ahead. Okay. I got it. Okay. Thank you, commissioners. Commissioner Bryan. Hi. Commissioner Hill. Hi. Commissioner Skinner. Hi. Commissioner Maynard. Hi. And I vote yes. Congratulations to Fanduul. All right. Now let's go back. If we can scroll somehow. I don't know who's got the document. Of course, if you want to take that down, I can share my screen. And we just go through them individually. Okay, let me just make sure. Right. So, we'd be starting with... Let's start Bar Stools. Bar Stools, yep. Bar Stools Sports. I keep saying Bar Stools in the floor. That's incorrect, but... All right. Can you see my screen here? Let me make it bigger. So, again... Okay. There we are. Yep, section. Got it. So, again, for Bar Stools Sports, no non-conformities were identified during the review, no major non-conformities, no minor non-conformities, and that they had some low-risk observations, some references to notes on the... We've made it... We're found in documentation other than the references indicated by Bar Stools and then for requirement 205-CMR-254-2031, although control activities referenced meet requirements as stated in the current review matrix, their recommending Bar Stools should update its documentation as per the updated requirement on the MGC website. So, that's something that Bruce and his team can follow up with the operator and make sure that happens. So, this was the one that I had the question on. Just to determine that this was in fact in reference to... We changed this not too long ago so that there's more discretion in terms of the time periods that are available. So, if someone can circle back to me in the very distant future, confirming that I'm correct on that, because if it's something else, I'd want to get a more specific follow-up on that observation. I'll just speak. I'll reach out to the other team that was on this and get that to you. Thank you. Any questions on these findings? Do I have a motion? I think we're going to have to... Maybe... Can we just... Can we just clarify the official name of Bar Stools because we don't... Actually, I don't think we have a draft. Sports Interactive, right? Yeah. Yeah. Transports Interactive. It actually might be at the top of this report. But it's different. I said, might. If you're waiting for a motion, Madam Chair, I'm more than happy to do that. Okay. I move that the Commission find that the requirements outlined in 205 CMR 251 have been satisfied and that an operation certificate be awarded to Penn Sports Interactive for the purpose of operating a Category 3 sports wagering operation, commencing March 10, 2023, conditional upon Penn Sports Interactive. Completing operational audits of wagering procedures and practices and technical security controls as required by the Commission's technical standards governing sports wagering at 205 CMR 243.01, 1S, and 205 CMR 243.01, 1X, within 90 days of the Commencement of Sports Wagering operation. Second from Commissioner Skinner. Any questions? Thank you, Commissioner Hill. I have a friendly amendment, which is to follow up on Madam Chair's point, that following Penn Sports Interactive that we insert doing business as bar stool sports. I would accept that as a friendly amendment. All the others are listed with DBAs, so. Right. And the GMI refers to bar stools. Have a correlation. Thank you. Friendly amendment accepted. The second was made. Commissioner Skinner. Yes. Thank you. We got a friendly amendment. Thank you. Commissioner Bryan. Hi. Commissioner Hill. Hi. Commissioner Skinner. Hi. Commissioner Maynard. Hi. I vote yes. For 5-0, congratulations to PSI Bar Stool. All right. Next up is DraftKings. What happened to BetMGM? Oh, I just pulled it off of my, I mean, I'm just doing it okay. I just wondered. Okay. Don't worry. Again, summary of findings, no non-conformities identified during the review, no major non-conformities, no minor non-conformities. They did make some observations with respect to 205CMR-254 and 205CMR-138. DraftKings indicated that MGC had waived the relevant two requirements until March 17th. And then on that 138, which is the internal controls, it just had a comment that they hadn't spoken to us. How will it be discussed prior to launch, but notably through the major non-conformities and the minor non-conformities analysis, they are in compliance with all the regulations under 138. Any questions on this? For GLI, Karen or Bruce? Okay. Do I have a motion? Madam Chair, I move that the commission find that the requirements outlined in 205CMR-251 have been satisfied and that an operation certificate be awarded to Crown MA Gaming LLC doing business as draft Kings for the purposes of operating a category three sports wagering operation, convincing March 10th, 2023 conditional upon Crown MA Gaming LLC DBA draft Kings, completing operational audits of wagering procedures and practices and technological security controls as required by the commission's technical standards, governing sports wagering at 205CMR-0101S and 205CMR-243.011X within 90 days of the commencement of sports wagering operations. Second. I have a friend of amendment. I think one of the reference to 205CMR-243.011S was not clear. I do speak with an accent, Commissioner Skinner. I did say yes. No, that's fine. I heard 205CMR-0101S. So I just wanted to make that clarification. Accepted. Thank you. It's a friendliest kind of amendment when it's just about numbers. So there we go. Okay. We have a second then. Second. Thank you so much. All right. Commissioner Ryan. Hi. Commissioner Hill. Hi. Commissioner Skinner. Hi. Commissioner Maynard. And I vote yes. Five-zero. Congratulations to draft Kings. All right. Who do you have up next, Karen? Next we have Winn Bet. So we'll just share my screen here. This one's pretty straightforward in that there were no non-conformities, no major, no minor, and there were no observations indicated in the report. Pretty clean. Let's just say clean report. That phrase can be used once again. Where's Gail? Exactly. Okay. Any questions for GLI on that? You're wondering how good of a job they did. It was so clean. All right. Perfect. Section 4. No questions. Do I have a motion? Madam Chair, I move that the Commission find the requirements outlined in 205-CMR 251 have been satisfied and that an operation certificate be awarded to Winn Bet for the purposes of operating category 3 sports wagering operation commencing March 10, 2023, conditional upon Winn Bet completing operational audits of wagering procedures and practices, and technical security controls as required by the Commission's technical standards governing sports wagering at 205-CMR 243.01 1S and 205-CMR 243.01 1X within 90 days of the commencement of sports wagering operations. Second. Thank you. Any questions on that? Okay. Commission Varian? Aye. Commissioner Hill? Aye. Commissioner Skinner? Aye. Commissioner Maynard? Aye. And I vote yes. 5-0. Congratulations to Caesars. All right. All right. Madam Chair, next up is that MGM. There's summary of findings. No non-conformities were found, no major non-conformities, no minor non-conformities, and they had no observations to report. Well, similar. Yes. Any questions for Karen or Geo and this one? Do I have a motion? Madam Chair, I move that the Commission find the requirements outlined in 205-CMR 251 have been satisfied and that an operation certificate be awarded to Bet MGM for the purposes of operating a category 3 sports wagering operation. Commencing March 10th, 2023 conditional upon Bet MGM completing operational audits of wagering procedures and practices. Security controls as required by the Commission's technical standards governing sports wagering at 205-CMR 243.01 1S and 205-CMR 243.01 1X within 90 days of the commencement of sports wagering operations. Thank you. I couldn't tell who second I may do is Commissioner Hill. Second. Okay. Thank you. Any questions on that? All right. Commissioner O'Brien. Hi. Commissioner Hill. Hi. Commissioner Skinner. Hi. Commissioner Maynard. Hi. My vote yes. Congratulations to Bet MGM. The last one we have here is Caesars Entertainment. Any good Caesars? No. No, I let that one to last. That was a win bet. I congratulate Caesars. I did not want to interrupt you Madam Chair, but you said Caesars when we had done win bet, but we were moving. I gave Caesars that A plus that was win bet that had the A class. Okay. My apologies. Caesars, you are holding for the very, very best for the lot. Thank you. I got my check marks off. Congratulations to Win Bet. That's good Caesars. Okay. So with respect to the GLI letter, some are finding no non-conformities identified during the review, no major, no minor non-conformities. They did have two observations. One, some to security data, security plan documentation will need to be provided to the NGC. The IT team and Bruce can follow up on that. And then they had a note that for one of the regulations, the reference evidence is in section 238.49, not 48 as indicated in the spreadsheet. So there was just a notation there. So I do want to flag that this, Caesars was the one that the issue with the pop-up of ensuring that. So we'll make sure that General Counsel Grossman is in the mix of how to word the motion to incorporate the commission's desires on that point as well. Thank you for the reminder. So Caesars, if you recall earlier, at the very beginning of this conversation, we learned that they are going to be in compliance with the limit setting. It's just that the GLI letter won't quite issue, but we have, and then also I guess Kristen has to do a final verification or final check off. I can quickly say that I checked during a break in the letter should be done by end of day today. Okay, end of day commissioners. Let's just chat about how we want to approach that. Commissioner O'Brien. I actually, before we get to that, just if I could put a follow-up request in terms of the data security detail plan, I'd like that followed up and a briefing back to us ASAP. That makes good sense, Commissioner. I'll go back to that section four because we haven't voted on it, but that would be. That would be my request on that. Thank you. And commissioners, I imagine you all think that that's something we should get. Okay. I do note that it says detailed, so I'm assuming there was some kind of a plan, but let's get that addressed. Okay, good. Thumbs up. Thanks, Commissioner Hill. Alrighty. So how are we feeling about this other issue? Should we, I should, in legal, you can chime in, but Commissioner O'Brien will turn to you if you have some thoughts. I just have an administrative issue that I think we should address is, I know Mr. Baroga indicated that seizures would withdraw their request for waiver. And I just think that that should be formally done in this meeting so that we can get to the matter at hand, namely Commissioner O'Brien's request for language in the motion. I have a live update. The letter is actually posted to GLI access, which Christian can actually log in and probably get it right now. And the report has been provided to the lab as well. So that the report is in the hands, and I believe just so you know, we can hear you speaking whoever's talking. Debbie Floyd, I think. Yeah, he's, I think he's attending. I'm waiting for the, it's a Floyd second time.  My apologies. Madam Chair, just to confirm, GLI has issued the report and that's also been provided to the lab and Christian has verified the signatures. We can rescind the conditional approval request and Caesars will implement that fix tomorrow if the commission proves. Well, before you rescind that, let's just make sure everything's in order, right? So we've got the letter posted and now Kristen is going to do his check on the. Has Christian completed that or? I don't see his name. Considering I got the update exactly one minute ago and he might be actually doing that right now. Great. Thank you. That's what I was looking for when I missed your comment. So I understand that you would withdraw it, but I don't want you to withdraw it until we know you're offset. And that's where the assistance from legal comes in with the language. Is that the idea? I mean, hopefully we can just be done. Yeah, we can just deal with it on this before we leave. I don't know if we have a sense of how long it's going to take to we move on to another item to give them time to do it and circle back on this vote. Jen did confirm the signatures, but I'll let him speak. Maybe if you can hop on the meeting and just confirm that for us on the record. Karen, I'll give down. Yeah, if you want to let's just see if you have a sense. Yeah, I want to write why don't you move on to another item? I'll go downstairs and check with Christian and then we'll come back to this if you'll excuse me to go see him. You want to do that? Oh, it's calling him. Thank you. I think Bruce might be calling him. Right. And we are just so that IEB is ready, we would be turning to a new item. So this is all happening in real time, which is fantastic. Hi, Sterl. Hi, I just talked to Christian. He says he's joining now. Oh, there he is. There he is. Thank you. Christian, this is all in real time. Are you comfortable with this? Welcome to Mobile Internet Quadring. Yes, I'm comfortable now. Okay, so what's happened? Do we have all the documents signed and posted? Yes, I can confirm that GLI has certified Caesar's platform and I also verify the signature is on Caesar's platform via screen share. Excellent. So now General Counsel Grossman, am I right that Mr. Borova can withdraw his request for a waiver? Yes, it sounds like they're in conformance, so they don't need a waiver. Does that work for you, Lloyd? If you want to withdraw that request now, it sounds like Caesar's is all set. For the record, we will withdraw the conditional preload request. Thank you. Excellent there. We're taking care of that. So now we go back to, and actually everybody congratulates Caesar some step ahead. If we can go back to section four as a reminder, because of course Commissioner Bryan has noted that observation around the detail plan, but I think with this matter, thank you so much, GLI. Thank you for the efforts, Kristen. Really nice to get that all wrapped up neatly. And to Karen, thank you. I know that kind of pressed a little bit for this, so thank you very, very much. Turning back to section four, I don't know, Karen, if you can pull that up, or is that everybody has it in their memory bank?  Sorry, Karen. Is that what you were looking for, the summary of findings for? Yeah, that same. You've already brought it up and it had the observation around the detail plan, but if we put it up, everybody can have that in front of them. Are you seeing this now? See, Lisa, Rain, can you have your hand up? How can I help you? Good afternoon, Madam Chair and commissioners. I did want to mention on one of the breaks. We too went back to see what the status was of that data security plan. And it looks like the actual plan in our 131 submission was missing. So we do have that and can easily provide today to Bruce and his team. Excellent. Thank you. And so then we can just get an update in the future meeting. Commissioner Bryan on that, is that right? Yeah, if there's a way for you to shoot that off to Bruce and his team right now, that would be great before closing business. Excellent. Little Duke, Commissioner Bryan. Thank you. Thank you, Ms. Rain Kim. Okay, so here we have the findings in front of us again. I think the second observation is pretty straightforward. Commissioners, do you have any questions for Karen or for um, Caesars who are well represented right now or um, GLI? If not, I'll take a motion. Madam Chair, I move the commission find that the requirements outlined in 205 CMR 251 have been satisfied and then operation certificate be awarded to American Wagering Inc. doing business as Caesar Sportsbook for the purpose of purposes of operating a category three sports wagering operation convincing March 10 2023 conditional upon American Wagering Inc. doing business as Caesar Sportsbook completing operational audits of wagering procedures and practices and technical security controls as required by the commission's technical standards governing sports wagering at 205 CMR 243.01 subsection one subsection S and 205 CMR 243.01 subsection one subsection X within 90 days of the commencement of sports wagering operations. Second. Second from Commissioner Hill. Any questions or any? Okay, Commissioner Hill. Hi. Commissioner Hill. Hi. Commissioner Skinner. Hi. Commissioner Maynard. Hi. And I vote yes. Congratulations to Caesars. Okay. Thank you and thank you for the for you being here today, Mr. Moraga and Ms. Rankin. Thank you very much. All right, commissioners. Launch time tomorrow 10 a.m. I think that each of the folks who are operating best of luck and again we reiterate our commitment to the safety and consumer protections and health and the integrity of the gaming tomorrow. We know that we have confidence in each operator putting all of those concerns so good luck. Let's move on then to IEB's report where we turn to an issue of non-compliance. Hi, Chair. Hi, commissioners. Again, I guess the IEB has its summary report on this non-compliance subsequent matter at Encore. I'm going to turn it right over to Chief Enforcement Council Hall and then you're going to get to hear from a new face and a new voice before you, Attorney Zach Mercer. So I'm going to just turn it right over to Heather. Thank you, Loretta. And for those of you who haven't met him yet, I would like to introduce IEB Enforcement Council, Zachary Mercer. Zach's been with us for about two months now and I think all of us who have worked with him would agree he hit the ground running from the start and we are really happy to have him on board. So with that, I will turn it over to Zach. Thank you, Heather, for that introduction. Good afternoon, Madam Chair and commissioners. This is a summary of a review conducted by the IEB regarding two incidents of non-compliance that occurred at Encore Boston Harbor, EVH, the Category 1 sports wagering operator in February 2023. It's worth noting that this is the second incident instance of non-compliance involving similar facts with EVH, the first occurring on February 2nd, 2023. For that incident, the IEB presented its summary review of the matter to the commission on February 14th. That matter is currently scheduled for the Judicatory hearing before the commission on March 14th, 2023. Turning to the new matters, on February 21st, 2023, EVH Senior Vice President General Counsel Jackie Crum notified sports wagering director Bruce Band that EVH had inadvertently offered wagering on two unauthorized events through their sports wagering vendor WinBet. EVH reported to the IEB that on February 15th, 2023, they became aware that unauthorized events had been added to their offerings but had not yet been activated for wagering. WinBet disabled these events and contacted its vendor, Gann Nevada. Gann is a technology platform that provides event management and other services to EVH and WinBet. Despite the actions taken to disable these events, they did not in fact remain disabled and wagers were placed on an NCAA event featuring a team from the Commonwealth. The unauthorized wagers were initially identified by a WinBet trader on February 19th, a trader being an individual responsible for setting odds on an event. That trader discovered that four wagers totaling $50 were placed on the February 19th Boston College Women's Basketball versus University of Louisville game. Following the discovery of those unauthorized offerings, WinBet discovered an earlier unauthorized event that had been offered for wagering, specifically another Boston College Women's Basketball game. This one being the February 12th game versus the University of North Carolina. For that event, there were three wagers placed totaling $163. In the course of this investigation so far, the IED has learned the following key facts. As to the time frame, the wagering was allowed for each of these events. Boston College versus University of North Carolina was available for approximately four hours on February 12th. Boston College versus University of Louisville was available on February 19th for two hours and 13 minutes. As stated before, there were three wagers for $163 on BC versus UNC on the 12th and four wagers for BC versus University Louisville totaling $50 on the 19th. As far as the winning wagers, there was one for each event, one partial winning wager on the Boston College versus University of North Carolina game as part of a parlay. That ticket paid $53 in total winnings. $12.37 of that were specific to that game. That ticket was redeemed on February 13th at 6.48 p.m. There was one winning wager on Boston College versus Louisville totaling $9.09 in winnings. That ticket was redeemed on February 19th at 1.59 p.m. All in all, there were seven total bets placed, all seven of which were placed at kiosks. The IEV was able to review reports from both EVH and GAN in generating this presentation. From the GAN report, GAN explained that the issue at hand was due to the submitted titles for events that had been provided from feed providers and how they were processed against their exclusion list. Essentially, GAN maintains a list of excluded teams or events. The feed provider, in this case, Genius Sports Media, uploads all markets and wager types. Those are then filtered by GAN to comply with the regulations that we have in place. GAN reported that, quote, unquote, Boston College as a term was on their exclusion list. However, Boston College Eagles Women was not. Genius uploaded the events in question under the title Boston College Eagles Women and the lack of a match to the specific exclusion list title name allowed the erroneous availability for wagering. This issue was further complicated by an upload of those games uncharacteristically close to the start time, whereas they're generally updated, uploaded two days prior to the event. These incidents were, this incident, they were uploaded roughly 30 minutes prior. As to the delay and discovery of those February 12 wagers, EVH explained that due to the initial deactivation of games for wagering, it did not appear on their first daily audit of offerings. Likewise, the second daily audit was then conducted under the auspices that that BC versus North Carolina game had been disabled or had remained disabled and was thus not discovered to have been activated. There has been information provided in regard to remedial measures or mitigation from EVH and GAN. GAN has placed Boston College Eagles Women, BC and BC Eagles on their excluded team list. EVH has also reported that GAN is in the process of implementing additional access for WinBet traders to have additional control over the posted offerings within the WinBet database. My understanding is that upon WinBet's mobile launch, this access will allow for added ability to suspend markets or wagers earlier on in the process. GAN reported that the measures and audits that have been placed since the February second incident have successfully identified and excluded two Boston College women's basketball games on February 5th and February 9th. EVH has also indicated that twice daily audits conducted by its trading team are still in place following this incident and noted that these audits are overseen by Max Berlin, the manager of sportsbook operations of WinBet. Finally, EVH has disabled all wagering on NCAA women's basketball until this issue has been remedied. Those events remain disabled at this time. Questions and welcome again. Thank you Madam Chair. Good evening Mr. Nice to see you. Commissioner's questions. You also have the chance to read the report. I did welcome Zachary I guess and you probably can't answer this question and I don't know if anybody can but it would seem to me they could code the various teams. I'm a little confused as to why GAN has done this several times and how do we know this isn't going to keep happening? I can't specifically answer. I'm sorry Zach. If I can jump in and excuse me for jumping in but I want to caution everybody that I think this matter is scheduled today for this. Yeah so you know the party is not here. Thank you so much. I invited questions but the cautionary tale is that we are about to make a decision as to what we want to do with this this this matter. We had very similar matters of non-compliance and we have decided to opt into the option of hearing this on our own in an adjudicatory hearing. And I don't have that reg at my fingertips. I hope maybe legal does but you are familiar with it commissioners. We have some options. Do you all wish to take the same approach with this one? We've taken with the other three. I've seen nodding of heads. Absolutely madam chair. Commissioner Skinner. Yes I don't see how I don't see how there's another option. Okay excellent so um so we will uh we'll show him Brian I think it's best um to take the best advice. So uh we turn to legal and IEB to work to have this probably addressed uh in the adjudicatory hearing. I know we have at least one date set up for maybe it's two dates now and perhaps we'll be able to merge them together um director Lillio's you know we talked about scheduling a little bit the other day. I do and just really quickly we do have um March 14th for the first EVH matter that is scheduled currently. Yeah I think do we and do we have one in the morning one in the afternoon? Yes that's correct there's the EVH in the morning and TPC. So um we would need to have the third one marked up uh uh council Grossman and then um excuse me and then not today's. Zach Zachary you did an excellent job. Thank you very much. Thank you. Thank you commissioners. Any other questions about process? Chair may I just say just to be clear the first on core potential non-compliant issue is the 14th the second non-compliant issue will be another date. I just want I don't want anyone to think they're both coming next Tuesday. They're both on the 14th there's on core in the morning and PPC in the afternoon. Right and then we're looking for another date for yep this one and then we have one from the other licensing as well. Okay I think we can move on do we even have thank you everyone on that thank you excellent preparation thank you so much Director Lillio's uh Councilor Hall and Councilor Mercer. Nice to see you. Now patiently waiting Chief Delaney thank you so much we are really covering a large um um segment of showing that highlights the diversity of our work. I'm happy to hear from you I'm sorry it's so late Joe. No worries thank you Madam Chair and commissioners um so today we have before you a request from the City of Medford to transfer some monies between a couple of different grants that they have and I thought I would just quickly share my screen with you just with a map of the area to put this all in a little bit of context of what we're talking about. So on core Boston Harbor is down here in the lower right hand corner of the screen the uh one of the projects is this route is everybody seeing this okay? Yes we can yes okay so one project is this route 28 Wellington underpass what's actually going to happen here is you can see these green paths here this is going to bring a essentially a boardwalk out over the river and underneath this route 28 bridge which will connect up all of these paths so that you can get across 28 without having to cross through a bunch of traffic and then the other project that we're talking about is a little bit further down which is known as the South Medford connector so that would this connector path again another bike path multi-use trail would run from where you see route 16 right here along the Mystic River and then terminating right here at Main Street in Medford so just as a quick history on this South Medford connector this project started in 2017 where we gave the community a grant to to study the feasibility of this path to connect up all this whole other path network and it the results of that were promising so we uh they applied for a second grant to try to get this project up to the 25 design level now one of the things that's interesting about this this whole mystic valley parkway route 16 i 93 all this land was taken by the state as part of the i 93 project back in the 60s I guess initially and so mastod actually owns all this property along the river one of the things that the the feasibility study did demonstrate that there were some pretty good constraints in here some steep slope to other things utilities that they would have had to get around so the suggestion came up saying hey why don't we see if we can't put this path right up along the mystic valley parkway itself because that road's pretty wide right now and maybe we could even just use that narrow that roadway down and if you've ever driven on it it is quite a wide segment of road now of course getting mastod to agree to give up a piece of their highway as you imagine might imagine takes a bit of doing so essentially only a small amount of the money out of that second grant was used to do this evaluation of whether or not they could move this piece roads only 20 a little over $20,000 was spent off of that grant so through that mastod finally ended up saying hey you know what we'll build this thing and we'll do this we're doing a project down here on this the interchange with main street and all of these ramps and so on we'll just add this onto our project and do it as part of our project so essentially we don't have to pay for that anymore so now that left a surplus of about $174,000 in that application now going back over to our other project the route 28 underpass project we gave them a grant to get this project up to about 25 design which they have done now in order to get this project built they have to get it to 100 design what they'd like to do is take the surplus funds from the other project that mastod is taking on and put it towards this project to advance the design of this towards the 100 design now with this mastod this is on the state's transportation improvement program so this is going to be built by the state but the city has the responsibility of getting the design plans up to a level where this can be taken over by the state so what is being proposed here is that transfer of funds will get this project the route 28 project to the 75 design level at which point mastod will take it over so we're recommending making that transfer of $175,604 from the south medford connector grant and moving it over to the route 28 grant we just think it's you know we're going to get both projects built both of them are going to be done by mastod so this is just a great way to leverage our money into this much larger expenditure that the state is going to do to get these paths together which will help improve you know access to encore for patrons and for um for employees and you know it seems like a win win all the way around questions for job I have one clarifying and I think in your memo it says this the amount will bring them up to 75 percent and no balance right they'll use the total amount yep it's we're not capping it at 75 percent it just no we're just we're just saying that the the dollar they can expend the dollar the full dollar value of 175,604 that's left and you know they're saying that should get them to 75 percent design if for some reason they got to 75 and there was a surplus there they would presumably turn that back or they could uh you know it still has to get to 100 design but mastod has said they would take it over at 75 so okay so they would presumably turn it back or whatever would need to happen so we don't have to worry about that delta no okay good any other questions mr hill you making a motion I read your mind yes I am um madam chair I move that the commission authorize a transfer of 175,604 dollars from the city of medford's 2018 transportation planning grant to the city of medford's 2019 wellington route 28 underpass project transportation planning grant for further design of the route 28 wellington underpass second any comments questions I think it's great that's my only comment I think it's great yeah I agree I love the bike rail development in this area I know commissioner ryan and if I'll see them it's excellent and I just want to thank Joe and his team for excellent work very clear memorandum any other comments okay commissioner brian hi mr hill hi uh commissioner skinner hi mr maynard hi i vote yes five zero Mary thank you very much very nice to see you thank you so much okay um mark vandalin has helped us by agreeing to roll his mat thank you again to the community affairs division excellent work moving on to item number seven mark vandalin has a generously said that he would move his um item to a future public meeting we want to make sure to give the research agenda is due so given the late hour that made sense but that said we still have another matter that anticipate voting on but before I turn to that precious do you have any updates that you want to share and teams is there any matter that you we need to get an update on director wells you're on me and jaren general grossman and I had been discussing me notify the commission about a disclosure time is the appropriate time to mention that yes this is perfect this is under kind of other business or matters not okay so it would be under number nine so i'll defer if there are any commissioner updates but it would be under um so if I could just the only commissioner updated have it it's more a request of the sports wagering team there was another um promo online promo that was brought to my attention which I forwarded over to the sports wagering team but to make sure that the other commissioners are you know aware of it um while they're looking at it if maybe they could just forward that link so that people um have the same access to what was sort of brought to my attention it's the one where I feel like we may want to talk about it sooner rather than later so um I would just ask if you guys could forward that to the other commissioners for a review so that you know we can speed that along that would be great that's excellent thank you that was it for me anything else before we move on to the other matter okay Karen counseling yes so this is just notification I'm waiting for a licensed number but uh upon advice of counsel I'm going to be filing a disclosure uh under 268a section 23b3 uh disclosure of appearance of a conflict appearance of a conflict of interest in that geo comply uh which is a vendor uh is is providing us with video and tech equipment so that we can have uh one of those screens and maps which will show where all the uh live and in real time bets are being placed on mobiles sports wagering uh phones and other devices so that would be something we're planning on putting it in the main area downstairs near where the entrance is so that staff commissioners and the public who will be coming into public meetings so at some point in the near future can see the operation so there's a public value to that you know in this instance the decision to accept that will not have any effect on our dealings with geo comply whatsoever or have an impact on any decision making related to them so I indicated in the uh disclosure form that I feel I can perform my official duties objectively and fairly despite receiving that from geo comply I don't know if there's anything else I need to mention Todd but that's the general overview and we have confirmed with the legal department that we have the illegal authority to accept this appropriately I make this also mention Karen I'm sorry I don't have a great friend I mean what the exact equipment is and what the value of it yeah so it is um uh television uh at value of $596.99 a wall mount at $99 $1.99 and an Apple Mac mini two base model at $599 total value of the equipment is $1,295.98 it's for office use though yes for everyone it's not the office for commissioners and and if we put it out in the main area of public if they're coming in as well they can use it or see it and and we always understood that the way that geo comply works is that they do work closely with the regulator as well yeah the information yeah thank you any questions on that okay all right so moving on uh commission commission I know it's 422 but we'll see how you vote right now the commission anticipates that I'll meet in executive session in accordance with GL chapter 30a section 21a3 to discuss strategy relative to potential litigation related to the employment status and associated circumstances pertaining to a former racing official um in the event that we do choose to go into executive session we will not convene in back in the public session so I would um want to note that commissioners do I have a motion Madam Chair I'm hoping we can entertain a postponement of the discussion set for executive session just at this late hour and and you know full disclosure I lost track of council Grossman's email and I have not had a chance to catch up and so have not read the material that being said if there's a quorum to move into executive session um that that that's quite all right do we have an outside council that will that's joining us yeah they're both here it's Andrea and Mario I don't know if you can see them on the screen yeah um I wonder if it's helpful just to get procedural posture if nothing else um and even if we have to do substantive later on um to follow up probably probably worth it just since outside council's here but we can probably do it fast you know I think we're all ready to wrap it up I agree with that that proposal I certainly want to be respectful of our outside council's time thank you commissioner okay so if um if someone does wish to move I will accept a motion uh madam chair I move that the commission go into executive session in accordance with general law chapter 30a section 21a3 to discuss strategy relative to potential litigation relating to the employment status associated circumstances pertaining to a former racing official second thank you commissioner scanner all right any questions um we're not coming back here after right right so we'll take the vote and then I'll then I'll um say say goodbye and thank you commissioner bryan hi mr hill hi mr speaker hi mr maynard all right and I vote yes now to the so we'll go into executive session we you know I'm not sure who is managing uh moving into the virtual session um dave susan looks like he might be on board but before we go anywhere to the next um chamber uh I just want to thank everybody the team for today um it's an extraordinarily long meeting but also an extraordinarily important meeting and um no one ever surprises me you are prepared your nimble you're able to adjust matters it's to move things forward but always with the right amount of diligence and excellence and for that I am grateful so thank you I'm so proud of of um what has been accomplished today goosepan you should be very proud of the good work of your team uh Karen you should be very very proud of the entire team and thank you to the public we thank everyone for their patience as we had to navigate a few new matters this afternoon and uh now we'll move into our executive session with again our best wishes for our new operators measures do you wish to say anything before me we all sat just to thank you to everybody um end of legal team probably got more than their fair share of me so special shout out to the legal team uh everybody did a great job GLI's assistance was uh immeasurable so thank you to everybody thank you okay all right we're getting moved thank you