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    AGA Calls for Streamlined Shipping Rules

    Press Release
    August 21, 2013

    WASHINGTON – The American Gaming Association (AGA) is leading an effort to streamline the overly costly and complex regulatory requirements related to gaming machine shipping practices. In research released today, titled “Streamlining Shipping: Recommendations for Regulatory Reform,” an AGA task force of compliance experts and former regulators offers solutions to the current regulatory system, which creates daunting complexities for both gaming businesses and industry regulators. The research is being distributed to industry regulators throughout the country and around the world.

    “These modest but significant reforms to shipping rules achieve the balance of making it more efficient for our companies to do business while maintaining the integrity of the industry,” said Geoff Freeman, president and CEO of the AGA. “Meeting the concerns of regulators and adding efficiency to business operations will make our already good system even better; it propels our industry forward by alleviating unnecessary burdens on manufacturers, operators and regulators.”

    Currently in North America, 365 individual jurisdictions apply different sets of regulations, which fill more than 1,000 pages and create a scenario in which 1.5 million different combinations of regulatory requirements can apply to the shipment of a single gaming machine today. For five of the larger manufacturers of gaming machines, these regulations generated nearly 61,000 separate filings over a recent 12-month period, requiring the dedication of 29 full-time and 20 part-time workers.

    The white paper suggests seven specific recommendations for standardizing and streamlining shipping rules to “simplify the burden of compliance while providing the same or even enhanced regulatory control.” The following changes would create “substantial efficiencies, smoothing the flow of new products to consumers,” without reducing regulatory effectiveness:

    • Allow Shipment of Complete Machines
    • Establish a Uniform Advance Notice Period for Shipments
    • Allow Shipment Without Express Prior Authorization
    • Allow Shipments Directly to Customers and Multiple Customers
    • Exempt Non-Gaming Components from Prior Notice Requirements
    • Remove the Requirement of Prior Notice Before Removing Slot Machines
    • Allow Shipment Notices to be Delivered Either Electronically or Via E-mail to a Single Regulatory Official

    “Streamlining Shipping: Recommendations for Regulatory Reform” also contains a detailed, six-part appendix that includes charts illustrating how commercial and tribal jurisdictions currently handle the processes suggested for reform in the paper. The charts cover slot machines and other electronic gaming machines.

    “Streamlining Shipping: Recommendations for Regulatory Reform” is the result of an aggressive regulatory reform initiative launched in 2011 by the AGA. A taskforce of former regulators, compliance officers, lawyers and other industry professionals from the AGA membership collaborated to develop key regulatory reform recommendations. The resulting white paper, titled “Improving Gaming Regulation: 10 Recommendations for Streamlining Processes While Maintaining Integrity” was distributed to legislators and regulators nationwide. Since its release, the paper has been cited extensively in several conference sessions across the country, increased dialogue about regulation reform in the industry and helped facilitate reform in various jurisdictions.

    Simplifying shipping rules was a top priority among the original 10 recommendations, which also included focusing on improving the licensing processes, simplifying gaming licensees’ ability to gain access to financing, reforming regulation of gaming machines, and modifying or eliminating unnecessary red tape and reporting requirements.

    During the past several months, the AGA brought together a group of experts from the tribal and commercial sectors to convene on shipping regulations. The group collected industrywide statistics related to the filing of shipping notices as well as other data and best practices compiled in this white paper. The paper was authored by gaming attorney David O. Stewart of Ropes & Gray, LLP.

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    The AGA represents the commercial casino-entertainment industry by addressing federal legislative and regulatory issues. The association also serves as a clearinghouse for information, develops educational and advocacy programs, and provides leadership on industry-related issues of public concern.

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