MASSACHUSETTS GAMING COMMISSION MEETING June 18, 2015 1:30 p.m. Boston Convention and Exhibition Center 415 Summer Street, Room 102B Boston, MA

Meeting Minutes

Date/Time:

June 11, 2015 – 10:30 a.m.

Place:

Boston Convention and Exhibition Center 415 Summer Street Room 102A/B Boston, Massachusetts

Present:

Chairman Stephen P. Crosby Commissioner Gayle Cameron Commissioner James F. McHugh Commissioner Bruce W. Stebbins Commissioner Enrique Zuniga

Time entries are linked to corresponding section in Commission meeting video

Call to Order See transcript Volume I page 2-5 10:31 a.m.

Chairman Crosby called to order the 154th meeting of the Massachusetts Gaming Commission.

10:32 a.m.

Commissioner McHugh stated that at no time after Chairman Crosby recused himself did Chairman Crosby offer him any suggestion or opinion about the Region A licensing decision. Commissioner McHugh also noted that the Region A work was complicated and he was proud of the process, the Commission, staff, and consultant’s efforts.

10:35 a.m.

Commissioner Zuniga noted that he felt the same way as Commissioner McHugh and that anyone who has doubts about the process should review the record.

Approval of the Minutes See transcript Volume I pages 5-6 10:36 a.m.

Commissioner McHugh moved for the approval of the May 28, 2015 minutes with reservation of power to change mechanical and typographical errors. Motion seconded by Commissioner Cameron. Motion passed unanimously.

Research and Responsible Gaming See transcript Volume I pages 6-112 10:37 a.m.

Director Mark Vander Linden provided an overview of the Social and Economic Impacts of Gambling in Massachusetts (SEIGMA) baseline study presentation. Mr. Vander Linden recognized Dr. Rachel Volberg, Martha Zorn, Amanda Houpt, the Department of Public Health, the Gaming Research Advisory Committee, Dr. Wendy Slutske, Dr. Jeff Marotta, the Public Health Trust Fund Executive Committee, and Commissioners for their role in the SEIGMA study.

10:44 a.m.

Dr. Rachel Volberg, SEIGMA Principal Investigator, shared preliminary findings on the social and economic impacts of gambling in Massachusetts. Dr. Volberg provided an overview of the SEIGMA study, which included elements of research agenda and the following topical areas: social and health impact, problem gambling and services evaluation, and economic and fiscal impacts and measures. Dr. Volberg also provided preliminary findings from the baseline population survey which included the following: survey methodology, demographics, gambling participation, gambling attitudes, problem gambling, economic and fiscal impacts analysis, lottery data analysis, next steps and access to SEIGMA report.

12:03 p.m.

Amanda Houpt, SEIGMA Project Manager, provided a demonstration on how to access SEIGMA project data online. Ms. Houpt also thanked the team of graduate students and R Studio for their work on the SEIGMA project.

12:22 p.m.

Chairman Crosby noted that funding for the SEIGMA research project was provided by the Massachusetts Gaming Commission and decisions were made in coordination with the Department of Public Health.

12:24 p.m.

The Commission recessed for lunch.

1:32 p.m.

The meeting resumed.

Investigation and Enforcement Division See transcript Volume II pages 2-12 1:32 p.m.

IEB Director Karen Wells reported that she received, by the deadline, a term sheet between KG Urban and GLPI that is currently under review.

1:34 p.m.

Ombudsman John Ziemba presented on the City of New Bedford’s citizen notification pertaining to the Commission’s suitability and application process with a recommendation that the citizens notice be accepted.

1:36 p.m.

Commissioner Stebbins moved that the Commission approve the community citizen notice as included in the packet for the New Bedford special election to be held on Tuesday, June 23, 2015. Motion seconded by Commissioner Cameron. Motion passed unanimously.

1:38 p.m.

Ombudsman Ziemba noted that the applicants for Region C will be notified that July 10th will not be the deadline for the RFA-2 application.

1:41 p.m.

Director Karen Wells presented an update on Penn National Temporary Key Gaming Employee licenses issued to: Tyler Evan Andrews, Surveillance Supervisor; Bogdan Magonski, Player Services Supervisor; and Ian Scott Thomas Burrell, Player Services Shift Manager.

Administration See transcript Volume II pages 12-77 1:43 p.m.

Chairman Crosby noted that two anti-casino representatives, Bill Walczak and Thomas Conroy, were appointed to the Gaming Policy Advisory Committee.

1:47 p.m.

Director Rick Day presented on Plainridge Park casino pre-opening assignments.

1:54 p.m.

Director of Licensing Paul Connelly presented on Plainridge Park Casino gaming beverage license application which included insurance, smoking porch, and follow-up site visit.

2:05 p.m.

Deputy General Counsel Todd Grossman presented on Plainridge Park Casino smoking porch and alcohol consumption.

2:20 p.m.

Commissioner McHugh moved that the Commission approve the gaming beverage license application for Plainville Gaming and Redevelopment, LLC as set out in the materials with the requirement and condition that if there’s any change to the insurance policy now in effect that Plainville Gaming and Redevelopment, LLC immediately notify the Commission. The second condition is that they comply with the punch list items that are included in the third bullet of the memorandum to the Commission from Paul Connelly dated June 8, 2015 which is also in the materials and, that the smoking porch and apron be included within the gaming establishment and that smoking be permitted in both areas so long as those areas are unenclosed to the satisfaction of the Plainville Board of Health. Motion seconded by Commissioner Zuniga. Motion passed unanimously.

2:24 p.m.

CFAO Derek Lennon presented on Fiscal Year 2016 preliminary budget recommendations.

2:48 p.m.

Dr. Alexandra Lightbown, Interim Director of Racing, presented on requests from the Plainridge Park Casino for the approval of Key Operating Personnel and Racing Officials: Jason Savastano, Mutuel Manager; Christine Lynch, Assistant Racing Services Manager; and AnnMarie Mancini, fill-in Judge.

2:49 p.m.

Commissioner Cameron moved that the Commission approve the request of Plainridge Park Casino to approve their June 4, 2015 update to their list of Key Operating Personnel and Racing Officials. Motion seconded by Commissioner Stebbins. Motion passed unanimously.

2:50 p.m.

Executive Director Day presented on Department of Revenue and Child Support intercept Memorandum of Understanding.

2:55 p.m.

Commissioner Zuniga moved that the Commission delegate authority to Director Day to sign off on the MOU between DOR and Plainridge Park Casino when applicable. Motion seconded by Commissioner Cameron. Motion passed unanimously.

Legal Division See transcript Volume II pages 77-91 2:55 p.m.

General Counsel Blue and Deputy General Counsel Todd Grossman presented on memorandum pertaining to Location of Gaming Establishment at Plainridge Park Casino.

3:08 p.m.

Commissioner McHugh moved that the Commission accept the boundaries of the gaming establishment as depicted on Exhibit C to the Grossman memorandum of June 11, 2015 that’s in the packet with the addition to the gaming establishment of the porte cochere area and the smoking porch and, that we substitute for Exhibit C a larger map that more clearly shows the boundaries of the structure. Motion seconded by Commissioner Zuniga. Motion passed unanimously.

Other Business Not Reasonably Anticipated See transcript Volume II pages 91-92 3:10 p.m.

Having no further business, a motion to adjourn was made by Commissioner Zuniga. Motion seconded by Commissioner Cameron. Motion passed unanimously. List of Documents and Other Items Used

1. Massachusetts Gaming Commission June 11, 2015 Notice of Meeting and Agenda 2. Massachusetts Gaming Commission May 28, 2015 Draft Meeting Minutes 3. University of Massachusetts, School of Public Health and Health Science, Results from the Baseline Phase of the SEIGMA Study 4. City of New Bedford - Citizen’s Notice 5. Massachusetts Gaming Commission Memorandum dated June 11, 2015 regarding Temporary Key Gaming Employee Licenses Issued 6. Biography of Bill Walczak 7. Biography of Thomas Conroy 8. Massachusetts Gaming Commission Memorandum dated June 5, 2015 regarding June 18th Commission Meeting with Reports/Memorandum and Supporting Documents Due for the Packet on June 15th.

9. Massachusetts Gaming Commission Memorandum dated June 8, 2015 regarding Gaming Beverage License Application: Plainville Gaming and Redevelopment, LLC, with attachments 10. Massachusetts Gaming Commission Memorandum dated June 11, 2015 regarding Fiscal Year 2016 (FY16) Initial Budget Recommendations 11. Massachusetts Gaming Commission Memorandum dated June 5, 2015 regarding Plainridge Key Operating Personnel and Racing Officials Update with attachments 12. Massachusetts Gaming Commission Memorandum dated June 11, 2015 regarding Location of Gaming Establishment at Plainridge Park Casino with attachments /s/ Catherine Blue Catherine Blue Assistant Secretary

Racing Division’s Public Meeting Minutes

Date/Time:

June 11, 2015 – 3:30 p.m.

Place:

Boston Convention and Exhibition Center 415 Summer Street Room 102A/B Boston, Massachusetts

Present:

Chairman Stephen P. Crosby Commissioner Gayle Cameron Commissioner James F. McHugh Commissioner Bruce W. Stebbins Commissioner Enrique Zuniga

Call to Order See transcript pages 2-13 3:31 p.m.

Chairman Crosby called to order the Racing Division’s Public Meeting on the Running Horse Racing License application of Suffolk Downs.

3:32 p.m.

Commissioner Cameron introduced the Commissioners, noted the purpose of the public hearing, and set the public comment guidelines.

3:34 p.m.

Chief Operating Officer Chip Tuttle, Suffolk Downs, presented on their supplemental application for three days of live racing in 2015.

Public Input See transcript pages 13-79 3:46 p.m.

The Commission took comments from the public.

5:03 p.m.

The public hearing was closed.

List of Documents and Other Items Used 1. Massachusetts Gaming Commission, Racing Division’s Public Meeting, June 11, 2015 Updated Notice of Meeting and Agenda 2. Letter from Chip Tuttle to Dr. Alexander Lightbown, dated June 8, 2015 regarding Suffolk Downs racing application. 3. The Massachusetts Gaming Commission received approximately 50 emails and 123 form letters signed by trainers, members of the NEHPBA, owners, blacksmiths, and thoroughbred owners. These emails and letters can be found on our website at: http://massgaming.com/news-events/article/mgc-open-meeting-publichearing-on-horse-racing-application-june-11-2015/ /s/ Catherine Blue Catherine Blue Assistant Secretary

301 Washington Street

Plainville, MA 02762

June 15, 2015

Mr. Rick Day, Executive Director Massachusetts Gaming Commission 101 Federal Street, 23rd Floor Boston, MA 02110

Dear Mr. Day: Pursuant to 205 CMR 151.01(1), Plainville Gaming and Redevelopment, LLC, d.b.a. Plainridge Park Casino (“PPC”), hereby requests an Operations Certificate from the Massachusetts Gaming Commission (“Commission”) to commence the gaming operations test period on June 22, 2015 and open to the public on June 24, 2015. As of this date, all of the required documentation as outlined in 205 CMR 151.03 has been provided to the Commission for review and approval. We believe that granting the Operations Certificate is in the best interest of PPC, the Commission, and the Commonwealth. If you have any questions or need additional information, please contact me by phone at (508) 576-4407. Sincerely, __Lance George Lance George Vice President/General Manager

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MEMORANDUM DATE:

June 16, 2015

TO:

Chairman Stephen Crosby Commissioner Gayle Cameron Commissioner James McHugh Commissioner Bruce Stebbins Commissioner Enrique Zuniga

FROM:

Rick Day, Executive Director

RE:

205 CMR 135 and 151: Determination That Gaming Establishment May Open for Business

___________________________________________________________________________________ Order of Presentations Dane Wigfall, Pinck and Co. Jack Rauen, Penn National • Compliance with 135 and punch list for compliance with permits and occupancy • License agreement and conditions • Related infrastructure • Host & surrounding communities • Impacted live entertainment venue agreements • Certificates of occupancy • Other essential ancillary services have been built and superior quality and comply conditions • Elevators certificate of operation • Provision of office space for MGC and MSP • Tax Intercept MOU John Glennon Jason Gittle & Mike Thoma, PPC & Ali Ghanavani, GLI • Certification and verification of the software • Permitting for platforms and ACSC test • Network Security Plan • CMS Plainridge Park Casino Floor Set-up status Mark Vander Linden Roberta Gregoire, PPC • Responsible Gaming Plan

• • •

Self-Exclusion Credit Restriction GameSense

Jill Griffin Shannon Wells, PPC • Progress in reaching diversity goals • Hiring Goals Bruce Band, Burke Cain and Monica Chang Roberta Gregoire, PPC • Floor plan and status of inspections for final approval • Hours of Operation • Internal Controls including consultant report and approval • Surveillance Plan (141.00) • Emergency Response Plan • Critical Incident Preparedness Plan (138.22) • AML\Title 31 Plan (138.14) • Slot management plan • Final inspection checklist on June 23rd based on test play and 205 CMR 151.03 & 04 if needed a Compliance Memorandum for Commission consideration on the 25th Karen Wells and Paul Connelly Shannon Wells, PPC • Licensing compliance and status • Up to date list of Gaming Establishment Employees Derek Lennon Jeremy Howland, PPC • Temporary Tax reporting process and payment • Lottery Agreement Catherine Blue • Legal Other Material as Necessary Commission Action: Consider a Determination that Plainridge Park Casino (PPC) may open for business for test play June 22, evaluation on June 23 and on June 24 conditional opening pending final on-site inspection. • •

Delegation to a Commissioner to approve a Temporary Operation Certificate following final inspection; Approval of format for Certificate of Operation.

On June 25th the Commission will consider granting Plainville Gaming and Redevelopment, LLC a Certificate of Operation.

MEMORANDUM DATE:

June 15, 2015

TO:

Stephen Crosby, Chairman Gayle Cameron, Commissioner Jim McHugh, Commissioner Bruce Stebbins, Commissioner Enrique Zuniga, Commissioner Rick Day, Executive Director

FROM:

John Glennon

SUBJECT:

Plainridge Park Casino – Gaming Technology Laboratory Pre-Opening Responsibilities

In preparation for the opening of Penn National Gaming’s Plainridge Park Casino in Plainville, Massachusetts, MGC staff and our consultants have been working to ensure compliance with our regulations in several technology related areas. This memo details that work, and contains a my recommendation to you relative to the Security Plan (Section 1) and my recommendations to the Commission relative to approval of the Electronic Gaming Devices, the Slot Floor and the Slot Management System prior to the opening the facility (Section 2).

Section 1 – Recommendations to Executive Director Day Security - Plainridge Park Casino Information Technology Policies and Procedures Manual On April 1, 2015, pursuant to the requirement in 205 CMR 138.02-4-f, Penn National Gaming submitted the Plainridge Park Casino (PPC) Information Technology Policies and Procedures Manual for review by MGC. The document was reviewed by MGC staff, as well as the Commonwealth Chief Information Security Officer’s (CISO) team. The CISO’s staff had no material comments or suggestions. The manual has the appropriate policies, procedures, and internal controls required by industry best practices. Because paper plans are only effective if they are put into practice, MGC staff Gaming Technology Laboratory staff will plan to conduct a security audit sometime during the first year of operation. It is my recommendation that you approve the manual as submitted.

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Section 2 – Recommendations to the Commission Compliance Testing of Electronic Gaming Devices, PPC Slot Management System (ACSC) and Penn National Gaming’s Player Management System (PUMA). Gaming Laboratories International, an MGC Certified Independent Testing Laboratory (CITL), was engaged by the Commission in May of 2015 to assist MGC with certain compliance testing and validation required in advance of the opening of the Plainridge Park Casino. The objective of the engagement was to confirm compliance with all pertinent sections of 205 CMR 143.00: Gaming Devices and Electronic Gaming Equipment. The results of the testing efforts over the past four weeks are included as an addendum to this memo. Below is an Executive Summary of the testing efforts: 1 – Electronic Gaming Device and Electronic Table Game (EGD) testing – the signature testing of the 1222 EGD's and 28 Table games for compliance with Massachusetts Gaming Commission technical standards. 2 - Communications testing for Electronic Gaming Positions – GLI personnel conducted operational bill and ticket testing on the 1500 Electronic Gaming Positions (EGP’s) in order to verify proper operation and communication between the Gaming Positions and the Bally ACSC CMS/SMS 11.5.1.2, by verifying that all games accurately credit and report game activity information to and from the SAS host. The data was collected from each machine and compared to the system meter test reports to ensure it was accurately reported to the system. Cashless functionality “Free Play” was also tested (205 CMR 143.04: Cashless Systems) during the communications test. Free play is Non-Cashable Electronic Promo (NCEP) which is promotional credits awarded to the player as part of a marketing promotion. These credits are restricted from being cashed out however a patron can upload any unused promo points back to their account by removing the player card from the machine. GLI personnel verified the software for Global Cash Access, Inc. kiosks. The kiosk inspection consisted of verifying that the installed files match those that have been tested and approved by Gaming Laboratories International, LLC to assure they comply with the Rules and Regulations set by the Commonwealth of Massachusetts (205 CMR 143.07: Kiosks). The signatures for each controlled file are then generated using the same tools used in the laboratory. These signatures are then compared to the signatures that are stored in our software archive and reflected on the certification report(s).

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GLI personnel verified the progressive increment rates on 546 EGD’s. This was done by documenting the start and end progressive values into the test form. The difference was verified by calculating the expected increase using the configuration supplied by the casino and the amount played on a gaming terminal during the bill and ticket testing. The progressive testing to assure the games comply with the Rules and Regulations set by the Commonwealth of Massachusetts (205 CMR 143.02: Progressive Gaming Devices). 3 - ACSC - Slot management system certification - Validation of GLI’s certification of ACSC version 11.5.1.2 previously provided by Penn National Gaming. Gaming Laboratories International, LLC personnel were on-site to inspect the Bally Technologies ACSC CMS/SMS 11.5.1.2. The system inspection process consisted of verifying that the controlled files match those that have been tested and approved by Gaming Laboratories International, LLC and to ensure they comply with the Rules and Regulations set forth by the Commonwealth of Massachusetts (205 CMR 143.03: On-Line Monitoring and Control Systems (MCS) and Validation System). The files are deemed controlled files after analyzing their functions with the participation of the system manufacturer. The signatures for each controlled file are then generated using the same tools used in the laboratory. These signatures are compared to the signatures that are stored in our system archives and reflected on the certification report(s) 4 - Penn's Player Management System (PUMA) certification - Validation of GLI’s certification of PUMA previously provided by Penn National Gaming. 5 - Mass DOR ACSC IDS Intercept Module test – Testing of the module for tax and custodial parent jackpot intercept processing that was custom developed by Bally for to meet MGC statutory requirements. According to the most recent GLI test reports, there are currently 1 issue remaining to be resolved. Based on the results of the GLI tests, PPC’s EGD’s, Slot Management and Player Management Systems are in compliance with MGC’s regulations, with the noted exceptions. Based on the test results as reported in the attached letters, along with input from MGC’s consultants, I recommend the Commission approve the ACSC Slot Management System, The PUMA Player Management System, the EGD’s and the KIOSK’s for operation.

Permitting and Asset Registration – Regulatory Compliance Permitting - 144.02: Permitting of Gaming Device Prototypes – During the testing and validation process, GLI has confirmed that each type of EGD at PPC has been tested for compliance with Massachusetts Technical Standards. It is my recommendation that the Commission issue permits for all manufacturer EGD prototype’s (Quantity). A slot operations manual will be published on the MGC website prior to PPC’s opening informing manufacturers PAGE 3

of the permitting process on a go forward basis. MGC Gaming Technology Laboratory personnel will work with the manufacturers to refine the process where necessary. Asset Registration – 144.03: Registration of Gaming Device Inventory - MGC Gaming Agents will place an MGC Asset tag on every EGD on the floor. The MGC asset tag number will be associated with EGD record in MGC’s slot master file. Permit numbers issued for EGD prototypes will be associated with each individual tagged asset. Manual processes defined the MGC Slot Operations Manual will facilitate moves, additions and changes to the configuration or location of EGD’s until the Intelligen CMS system comes on line in the fall of 2015.

MGC’s Central Management System Project Update – IGT’s Intelligen - The INTELLIGEN CMS Project delivery is tracking according to the project plan, with a scheduled implementation in the fall of 2015. Requirements documents have been reviewed and approved by the MGC project team. Because the CMS is going live on an active gaming floor, Penn National Gaming requested that as much preparation work be completed in advance of June 24th to minimize disruption to the floor or patrons. I am pleased to report that IGT has completed the necessary fiber cabling and installation in Plainridge Park Casino which should prevent any significant floor disruption during CMS implementation. With this work completed, currently the CMS project has no major risks being mitigated. Attachments in the Commissioners Packet 1 - Penn National Gaming Letter (5/28/15) to Rick Day requesting approval for ACSC 2 - GLI MGC ACSC Certification Document 3 - GLI Letter regarding Evaluation of PUMA 4 - GLI Onsite Inspection Letter – Software Audit 5 - GLI Onsite Inspection Letter – Validation and Verification of ACSC, Communication to EDG’s, Kiosks and Progressives. 6 – Penn National Gaming Letter (6/9/15) to John Glennon – ACSC IDS Subsystem for DOR 7 – Prototypes Requiring Permit

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301 Washington Street

Plainville, MA 02762

    May 28, 2015

Mr. Rick Day, Executive Director Massachusetts Gaming Commission 101 Federal Street, 23rd Floor Boston, MA 02110 Dear Mr. Day: Pursuant to 205 CMR 144.03, Plainville Gaming and Redevelopment, LLC, d.b.a. Plainridge Park Casino (“PPC”), hereby requests formal approval for the installation and use of the Bally ACSC casino management system version 11.5.1.2. PPC has been working with Bally Technologies and Commission staff to configure this system to meet all Massachusetts requirements. Attached is the GLI certification letter for the ACSC system. In addition, PPC will be installing Penn National’s proprietary Penn Universal Management Application (PUMA). PUMA, operating as “Marquee Rewards”, is already in operation at all of Penn’s U.S. casino properties except one (which will be added later this year). The Marquee Rewards System is a casino marketing system that allows Penn to build player loyalty by allowing its customers to use the same player card at all of its properties. It allows patrons to share tier points (which have no cash or redemption value, but simply allows a patron to achieve elevated tier status levels) and comp value across the linked properties. For example, a patron earning comp value at a PNG property in Bangor, Maine will be able to redeem that comp value at a dining venue in our Plainville facility, while a patron achieving “Producer” tier status at our Plainville property will be recognized in that tier level at our Pennsylvania property should they choose to go there. Cash back and/or free slot play will continue to be redeemable only at the property at which it was earned and will not be shared across properties or through the system. A white paper detailing the technical specifications of the Marquee Rewards system is attached for your review. Because this is a marketing system that will not impact the casino control or accounting elements of the ACSC system, we do not believe it is subject to Massachusetts Gaming Commission approval requirements but would like confirmation of this. Once again, PPC respectfully seeks formal approval to install and operate the ACSC casino management system. If you have any questions or concerns regarding the ACSC system or the Marquee Rewards program, please contact me at (508) 576-4407. Sincerely, __Lance George Lance George Vice President/General Manager cc:

John Glennon Page 1 of 1

THIS REPORT (denoted by " LOOK ")

CONTAINS

SPECIAL

NOTES

Date of Report:

April 10, 2015

Issued To:

WEBSITE COPY This report was sent to the Massachusetts Gaming Commission

Issued By:

Gaming Laboratories World Headquarters Christine M. Gallo Vice President of Technical Compliance and Quality Assurance 600 Airport Road, Lakewood, NJ 08701 (732) 942-3999 www.gaminglabs.com

Certification of:

One New Bally Technologies CMS/SMS Emergency Pack Version 11.5.0 E1150_12 and ACSCGUI Version 11.5.0 E1150_12

GLI File Numbers:

SY-52-ADC-11-11 (Emergency Pack Version 11.5.0 E1150_12 & ACSCGUI Version 11.5.0 E1150_12) SY-52-ADC-11-05 (Service Pack Version 11.5.0 S1150_1) SY-52-ADC-10-03 (Version 11.5.0)

Standards Tested Against and the Test Results: Standards Tested Against

Test Results

205 CMR 143.00: Gaming Devices and Electronic Gaming Equipment GLI-13 - Monitoring and Control Systems GLI-16 - Cashless Systems GLI-18 - Promotional Systems

Pass Pass Pass Pass

THE RECIPIENT, BY ITS ACCEPTANCE OF THIS REPORT OR ANALYSIS, WILL BE DEEMED TO HAVE ACKNOWLEDGED AND AGREED TO ALL OF THE “TERMS AND CONDITIONS” SET FORTH BELOW. IF THE RECIPIENT DOES NOT AGREE TO ALL OF SUCH TERMS AND CONDITIONS, GLI WITHDRAWS THE CERTIFICATION PROVIDED OR ANALYSIS ESTABLISHED BY THIS REPORT AND THE RECIPIENT MUST IMMEDIATELY RETURN TO GLI ALL COPIES OF THIS REPORT AND MAKE NO REFERENCE TO THIS REPORT FOR ANY PURPOSE AT ANY TIME.

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SY-52-ADC-11-11-497 Page 2 of 22

Evaluating Location: GLI World Headquarters 600 Airport Road Lakewood, NJ 08701 SYSTEM System Description: The Advanced Casino Systems Corporation (ACSC) on-line system has the ability to monitor slot machine activity for all machines connected to their electronic Slot Marketing System (SMS). The SMS will electronically monitor mechanisms within each machine to determine coin-in, tickets in, tickets out, drop, number of manual jackpots, the number and total value of coins or tokens paid by automatic jackpots and handle pulls. Further, the SMS will monitor currency drops associated with bill validators, and SMS has the ability to monitor certain individual patron activity and employee service activity through the use of a card reader attached to the slot machine. Finally, a two-line, fluorescent or graphic display or the iViewä display with the card reader will allow informational and diagnostic messaging to all machines connected to the SMS system. Each employee card has a magnetic stripe that is able to store 26 characters of information. This magnetic stripe will be encoded with a card number. When a card is inserted into an SMS card reader, the card number will be communicated to the host computer where the number will be matched against authorized cards in use for the shift. Each patron card also contains a magnetic stripe able to store 26 characters of information. Specifically, these cards will be encoded with the patron’s account number and name and when inserted into an SMS card reader, the account number will be communicated to the host computer and to the AS/400 in order to properly identify and rate the play for this patron.

SY-52-ADC-11-11-497 Page 3 of 22

Application Server-AS/400 Software: Licensed by the customer are the following ACSC SMS software products: 1. SMS Manager – Used to monitor and control the operation of the system. 2. SMS Slot Configuration – Used to identify all gaming devices within the system. 3. SMS Slot Accounting System – Used to audit and report revenues. 4. SMS Slot Data – Used to analyze historical performance information. 5. SMS Delphi Slot Data – Windows based analytical tool. ACSC Ticketing Features: ACSC’s Cash Ticketing System supports a full range of functionality for the creation, redemption, validation and reporting of various types of coupons/ticket. NOTE: In the ACSC lexicon coupon, voucher, and ticket are synonymous. However; ACSC uses both coupons and tickets. Coupons are always system generated and usually originate from marketing. These can be cashable or noncashable. Tickets are usually generated by a slot machine and originate from monies being cashed out from a slot machine.

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Ticket Issuance: ACSC’s Ticketing System allows for the generation of tickets at the slot machine level. Slot Ticket/Out Cashless Tickets are issued as cash valued tickets only. The validation numbers come from the NT board on System Validation, and the game on Enhanced Validation, when a cash-out is requested at a slot machine that has the cashless ticketing feature active. Each ticket is assigned a unique validation number with matching barcode. The validation number is written to a detailed Ticket Tracking File that includes game specific information for the game the ticket was generated from. The ticket may or may not be associated with a specific patron that requested the cash-out, based on existence of patrons’ card in the game. Global control parameters, set by the property, define in days and hours how long from the date/time of issuance a ticket is valid. These tickets also have the following additional control features available: 1. Ability to require a patron card at time of redemption. 2. Ability to allow redemption at a slot machine. 3. Ability to define what authority level, if any, can override what restrictions, if any.

Ticket Out Overview: Ticket Out allows slot machines to produce a ticket instead of coins. These tickets are then redeemable either at a slot machine or cashier. On a slot machine which has a ticket printer in place of, or in addition to, a coin hopper, a ticket is dispensed when a patron presses the cashout button. Each ticket will have a unique ticket number that will be added to the system once the ticket is successfully printed. The result of the ticket print will be logged both in the SMS Recall and within the system.

SY-52-ADC-11-11-497 Page 5 of 22

Ticket Redemption and Validation: Tickets can be redeemed in several ways, depending upon how they were defined at the time of issuance. For example: 1. Point-of-Sale (providing POS vendor supports ticket redemptions) 2. Slot Machine Bill Validators (providing validator accepts bar-coded tickets) 3. Cashier Cages 4. Voucher Redemption Terminals (Kiosks) Ticket In Overview: Ticket In allows marketing coupons and cashout tickets to be collected at both the slot machine and from a cashier. When a coupon/ticket is inserted into a slot machine the coupon/ticket information will be passed to the system. The system will then check the validity of the coupon/ticket and instruct the slot machine to either accept or reject the coupon/ticket. The result of the coupon/ticket in will be logged both in the SMS Recall and within the system. Cash Ticket Reporting: From the Cash Ticket Menus, several ticket related reports can be produced, which contain coupon/ticket information as follows: 1. Tickets redeemed by cashier 2. Tickets redeemed by promotion code 3. Tickets redeemed by patron 4. Trip based redemptions 5. Promotions summary 6. Tickets redeemed with no patron play 7. Tickets redeemed at slots 8. Tickets created at slots 9. Ticket Liability report 10. Slot ticket exceptions 11. Slot cash ticket reconciliation report 12. Cashier drawer slot cash ticket settlement report 13. Ticket Drop reports

SY-52-ADC-11-11-497 Page 6 of 22

Slot Machine Requirements and Operation: For support of SMS Ticket In/Ticket Out, the slot manufacturers must have SAS version 5.01 or higher ticket in and ticket out within their software. Specifically for Ticket In, the slot manufacturer must support voucher redemption. Specifically for Ticket Out, there are two settings on the slot machine. 1. The first is Enhanced set to Secure Mode; where the slot machine generates the validation number. If the communications line is broken between the slot machine and the system, then one ticket can be printed prior to the printer disabling. Once communication is restored the ticket is sent up to the system. 2. The second is System; where the System Controller Board generates the validation number. If the communications line is broken between the machine and the system, the System Print Security Setting will determine whether or not to print tickets until communications are re-established. System Print Security Setting: SMS Ticket/Coupon Printing has four levels of printing security which the system can be set to: Print Always, Print Verify, Communication Verify, and Database Verify. Print Always (01): As long as the NT Controller Board is talking with the game, tickets will be printed. However, with this level of printing, if communication is lost with the system (network) for an extended period of time, records in Recall and Memory will begin to be overwritten and lost.

SY-52-ADC-11-11-497 Page 7 of 22

Print Verify (02): When communication between the NT Controller Board and the System (network) is lost, printing will stop once the NT Controller Board Printing Buffer fills up. Games with SAS Protocol with System Validation: once the NT Controller Board Printing Buffer fills up, the NT Controller will not issue any more validation numbers. If a cashout occurs during this time, the game will either payout with a hopper pay or by a handpay lock up condition. Games with SAS Protocol with Enhanced Validation set to Secure Mode: once the NT Controller Board Printing Buffer fills up and the game’s Ticket Buffer fills up, the game will disable itself. NOTE: With this level, once communication is re-established with the system and the NT controller clears its printing buffer then the NT controller will begin to issue more ticket validation. Communication Verify (03): When communication between the NT Controller and the Gearbox is lost, printing will stop. Games with SAS Protocol with System Validation: once the NT Controller has lost communication with the Gearbox, then the NT Controller will not issue any more validation numbers. If a cashout occurs during this time, then the game will either payout with a hopper pay or by a hand pay lock up condition. Games with SAS Protocol with Enhanced Validation set to Secure Mode: once the NT Controller has lost communication with the Gearbox and the game’s Ticket Buffer fills up, then the game will disable itself. NOTE: With this level once communication is re-established with the system, the NT Controller will begin to issue more validation numbers. With this security level, the only time there would be a possibility of tickets not being in the Ticket Server would be when the system has lost its link to the Ticket Server. However, all the tickets generated while the link to the Ticket Server is down would be kept at the Gearbox and sent up for verification when the link is re-established. With the security level, if a Gearbox or line goes down, all slots connected will not print tickets.

SY-52-ADC-11-11-497 Page 8 of 22

Database Verify (04): When communication between the System (network) and the Ticket Server is lost, printing will stop. Games with SAS Protocol with System Validation: once the system notifies the NT Controller that the Ticket Server is no longer present on the network or the NT Controller has lost communication with the Gearbox, then the NT Controller will not issue any more validation numbers. If a cashout occurs during this time, then the game will either payout with a hopper pay or by a handpay lock up condition. Games with SAS Protocol with Enhanced Validation set to Secure Mode: once the system notifies the NT Controller that the Ticket Server is no longer present on the network or the NT Controller has lost communication with the Gearbox and the game’s Ticket Buffer fills up, the game will disable itself. NOTE: With this level of security, once the NT Controller is notified that the Ticket Server is again present on the network or communication is re-established with the system, the NT Controller will begin to issue more validation numbers. With this security level if the Ticket Server goes down, all the slots on the floor will not print tickets. Power Rewards Overview: The objective of promotional credits (Power Rewards) is to provide a flexible method to offer promotions to both new and existing patrons. This is accomplished by directly crediting slot machines with either cashable or noncashable credits upon play to a variable set amount in order to achieve the reward. Incorporated into the design is the ability for a patron to continue to accrue toward the reward even while playing different slot machines, which may or may not be of the same denomination. To use ACSC promotional/(Power Rewards), the player must first establish a player account and have a player card issued through the casino’s Casino Management System (CMS).

SY-52-ADC-11-11-497 Page 9 of 22

The player then goes to any Power Rewards-enabled slot machine and inserts the player card into the card reader. If a promotional session is enabled at the time, the player will be notified on the card reader display that the promotion is available. The player then will play the machine normally until the predetermined credits required to obtain the promotion are achieved. Once the player meets the predetermined amount of play, the ‘Promo’ button on the card reader will flash. This notifies the player that the promotion is available for download. Pressing this button will transfer the awarded credits to the machine. A PIN (Personal Identification Number) will be required to transfer the credits to the machine. The display will then scroll a message stating that the promotion has been awarded successfully. The CMS (Central Monitoring System) defines the conditions of Power Rewards, some of which correspond to ACSC’s settings, and keeps track of Power Rewards information. Its functions include maintaining player accounts and PINs, informing the player that the promotion is active and available once reached, setting the play (amount the player must play to reach the promotion) and get (the amount awarded) amounts, type of promotional credits to be awarded (cashable or non-cashable), establishing a start and end date and time for which the promotion is available, as well as defining zones, manufacturers, or denominations in which the promotion will be available. Power Promotions / Power Bank Overview: The objective of Power Promotions is to provide a method for a patron to directly credit their “Incentive Cash” to slot machines with either cashable or noncashable credits. To use ACSC Power Promotions the player must have a player account (which entails being issued a player card) with earned “incentive cash” (or “incentive cash”) issued through the casino’s Casino Management System (CMS) or establish a player account and earn “incentive cash” through play.

SY-52-ADC-11-11-497 Page 10 of 22

‘ A player can go to any game that has Power Promotions enabled and insert their player card into the card reader. The player will be notified on the card reader display that they have incentive cash available for downloading by the illumination of the light on the “$” key. Pressing this button will bring up a menu that will provide the patron with options relative to their incentive cash. They may either get their balance or transfer credits to the game. A PIN (Personal Identification Number) will be required to transfer the credits to the machine. If taking the option to transfer the credits, once completed, the display will then scroll a message stating that the credits were downloaded/transferred successfully. The CMS tracks the patron’s play and credits the patron’s account with the incentive cash that is earned based on a certain number of points per dollars of play. The specific criteria for earned points and incentive cash are established by the individual property. The CMS will also track the transfer of the patron points to the slot machine and generate reports regarding the same. In general it maintains the player accounts and PINs. Power Bank is an extension of the Power Promotions feature that allows for the downloading of patron deposited monies from their account to a gaming machine for play and uploading of monies from a gaming machine back to the patron’s account. The CMS tracks all of the patron’s transactions and is capable of printing out transaction reports detailing each transaction. ACSC Graphical User Interface Overview The ACSC Graphical User Interface (GUI) is a web-based interface developed to access the ACSC system. Several menu options are provided to the user which allows the user to change the GUI configurations and settings, enter patron rating, create and update promotions and view slot activity. Option availability is dependent on the user’s level of access. The GUI also allows the user to reconcile and upload currency and ticket drop data to the ACSC system accounting database.

SY-52-ADC-11-11-497 Page 11 of 22

System Software Being Certified: Emergency Pack 11.5.0 E1150_12 Architecture Software Level Group Name

Version

Libraries

SHA-1 Signature

AS/400

CMS/SMS

11.5.0 E1150_12

AS/400

CMS/SMS

11.5.0 E1150_12

CASPGMXX/ SMSPGMXX XCAPGMXX

BEE995D20D78FA7E1265D04 80199731EA52479F0 254549DB407F7E023C912EF9 2CD40E9A74F27035

ACSCGUI Version 11.5.0 E1150_12

File Name

Version

GLI Verify® CDCK Signature

GLI Verify® SHA-1 Signature

ACSCGUI_INSTALLER.exe

11.5.0 E1150_12

FD7E

ACSC.ear

11.5.0 E1150_12

BD1D

768CC4BBB0385577656749A 9BEF936F402FBBA2A 78F1F37416A1B4F9DBC04A BCFB50D9BB50CC1445

System Software Notes: Verification of the Emergency Pack version 11.5.0 E1150_12 software is to be completed after Service Packs version 11.5.0 S1150_1 and version 11.5.0 are installed. In the event that the verification process is performed prior to the installation of the service pack and emergency pack, the signature that is generated will not match the signature listed on the Gaming Laboratories International, LLC certification letter. The advanced features of Power Bank (AFT/EFT), Power Promotions, and Power Rewards are approved for use with the previously listed software or higher, unless changes are made to any one or all of the previously listed Advanced Features.

LOOK

LOOK

SY-52-ADC-11-11-497 Page 12 of 22

Please note that although the ACSC system provides a Remote Access User Activity Log which records the User, Menu Option accessed by the User, Date and Time, and duration of time each menu option was accessed, the log does not record the details of the completed transaction. Therefore, Gaming Laboratories International, LLC recommends that Internal Controls be established to manually record the details including time and date of each Remote Access User transaction. Please note, the signature verification module verifies the objects that are located in specific libraries as specified by the preconfigured manifest file. Any additional libraries and/or objects created outside of the specified libraries are not subject to the verification process. The addition or modification of custom libraries and/or objects by end users could impact the functionality of the system being approved herein and will not be detected by the verification process. GLI recommends that all Power Rewards promotions, once enabled, continue without interruption. Manual termination of a Power Rewards promotion will prevent player enrollment into a new Power Rewards promotional event(s). Alternatively, the expiration date may be modified to the current date which would limit the need to manually terminate the Power Rewards promotion. Please note this Certification Report serves as a Phase I Certification of the Bally Technologies CMS/SMS Emergency Pack Version 11.5.0 E1150_12 and ASCSGUI Version 11.5.0 E1150_12 product(s) only. Phase II testing or field inspection, is recommended. The Verification module for the ACSC system uses the SHA-1 algorithm to create two unique 40-character signatures for specific libraries. Currently, the 3 libraries controlled are the CASPGMXX, SMSPGMXX and the XCAPGMXX. The CASPGMXX and SMSPGMXX libraries are verified together to generate one 40-character signature and the XCAPGMXX is verified separately to generate the other 40-character signature The CASPGMXX library contains programs associated with cash cage, cashiers, and pit related functions. The SMSPGMXX library contains programs associated with slot system communications to slot machine events.

LOOK

SY-52-ADC-11-11-497 Page 13 of 22 The XCAPGMXX library contains programs associated with Universal Card features. The ‘XX’ in library names indicates that these could vary on any given system based on the name given to the database. A SHA -1 signature is generated after running the SHA-1 algorithm over the sum of all of date and timestamps of all of the objects in the specified libraries. If objects are modified, added or removed from the verified libraries the SHA-1 signature will change accordingly. Gaming Laboratories International, LLC recommends using the Database Verify (04) security Level. Gaming Laboratories International, LLC recommends the manufacturer’s ability to remotely access the system for any reason be closely monitored by the regulatory agency. System Verification Procedure: The ACSC Verification module consists of three separate programs that perform different tasks in the verification process. The names of the programs are Find Version Hash (CHKVNHASH), Create Exception Report Based On Manifest (CMPVNHASH), and the Create Exception Report Based On Library Objects (CHKMFST). Procedure For Verification After the installation is completed, Log on to the system with the Administrative user ID and password. Once logged in as the administrator, from the main menu select the ACSC Service Menu> Application security menu>Hash Routine option.

LOOK

SY-52-ADC-11-11-497 Page 14 of 22

Select the Submit Comparison Routine to generate the hash signature.

Press the F6 key to submit the hash jobs.

SY-52-ADC-11-11-497 Page 15 of 22

After the verification job is complete, select the Hash Log Inquiry option.

SY-52-ADC-11-11-497 Page 16 of 22

Place a 5 on the option line next to the Software ID and press enter to display the log options. Place a 1 on the option line next to each log and press enter to display the result.

SY-52-ADC-11-11-497 Page 17 of 22 Select the CHKVNHASH option to display the Comparison report.

Select the CMPVNHASH option to display the Comparison report.

SY-52-ADC-11-11-497 Page 18 of 22

Select the CHVNMFST option to display any exceptions found during the verification process against the Manifest file.

An exception report has been added to the signature process. If an object is found in the manifest file but not in the compared libraries an error message is displayed on this report.

SY-52-ADC-11-11-497 Page 19 of 22

Terms and Conditions: This Report is issued solely for the benefit of the Client for use only for and limited to the specific jurisdiction or standards referenced in the Report. This Report may not be relied upon for any reason by any person or entity other than the Client including, but not necessarily limited to, the manufacturer or developer of the items, a non-GLI Laboratory, or a Regulator not named in the Report (“a Third Party”). Any report produced by GLI is proprietary to GLI and the Client, because it contains confidential information of commercial value, the exposure of which to third parties could adversely affect both GLI and the Client. Accordingly, such confidential information is supplied in confidence, on the strict condition that no part of it will be reprinted or reproduced or transmitted to any parties external to the original contract without the prior written approval of the Parties. In particular, it will not be exposed to any person or organization which may be in competition with any of the Parties without the prior written approval of that Party. The testing performed by GLI is proprietary to GLI and/or various regulators. No third party may use, rely or refer to a GLI evaluation report, test report, certification document or test results without written permission of GLI and the respective regulator. Notwithstanding the above, the Parties may disclose confidential information if required to do so by regulatory agencies, pursuant to the laws and regulations of an applicable jurisdiction or by an order of a properly designated Court of Law in a relevant jurisdiction. However, in either case the Parties agree to immediately notify the other party of such a request. Notwithstanding the above, any regulator may reprint, reproduce and transmit any document or information to any party that the regulator, in their sole discretion, deems appropriate.

SY-52-ADC-11-11-497 Page 20 of 22 The certification established by this Report applies exclusively to tests conducted on the specific items submitted by the Manufacturer identified by the words “Certification of:” on the first page of this Report. It is the responsibility of the manufacturer and/or developer of the items submitted to apply for, obtain and maintain all necessary gaming licensure in each jurisdiction in which they do business, including state and tribal jurisdictions, where applicable. The Electrostatic Discharge Testing performed by GLI is intended only to simulate techniques observed in the field being used to attempt to disrupt the integrity of Electronic Gaming Devices. During the course of testing, GLI checks for marks, symbols or documents indicating that a device has undergone product safety or RoHS compliance testing, if required. GLI also performs a cursory review of information accompanying the items submitted, where possible and when provided, for evidence that the items have undergone compliance testing for Electromagnetic Interference (EMI), Radio Frequency Interference (RFI), Magnetic Interference, Liquid Spills, Power Fluctuations, Electrostatic Immunity, Electro Magnetic Compatibility and Environmental conditions. Compliance with any such regulations related to the aforementioned testing is the sole responsibility of the manufacturer and/or developer of the items submitted; GLI accepts no responsibility, makes no representations and disclaims any liability with respect to all such non-gaming testing. The test methods used, excluded tests, and actual data showing the test results are available to the Recipient upon written request. All items identified in the “Certification of:” section on the first page of the report are considered certified as of the date shown in the “Date of Report:” section on the first page of the original GLI issued Report. All of the items are certified for use until such time notification is sent indicating that an item is no longer permitted to be used within the jurisdiction specified. Additional information regarding the validity of this certification can also be obtained via GLIAccess and/or the Evaluation and Certification Guide, which is available on the gaminglabs.com website. Use of the Certified Mark represents the users agreement to permit, allow and accommodate authorized representatives of GLI to perform a surveillance audit of the use of the Mark and to permit an authorized representative of the American Association of Laboratory Accreditation (A2LA) to perform a surveillance audit, at their discretion and at their expense, to confirm that the use of the Mark in no way implies that A2LA endorses or certifies any of the Marks, services or processes of the company, group or organization requesting the use of the GLI Certified Mark.

SY-52-ADC-11-11-497 Page 21 of 22 GLI WARRANTS TO THE RECIPIENT THAT ALL SERVICES PROVIDED BY GLI HEREUNDER HAVE BEEN PERFORMED IN ACCORDANCE WITH ESTABLISHED AND RECOGNIZED TESTING PROCEDURES AND WITH REASONABLE CARE IN ACCORDANCE WITH APPLICABLE LAWS. GLI DOES NOT MAKE, AND EXPRESSLY DISCLAIMS, ALL OTHER WARRANTIES OF ANY KIND, EXPRESSED OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF NON-INFRINGEMENT, MERCHANTABILITY, SUITABILITY OR FITNESS FOR A PARTICULAR PURPOSE. GLI DOES NOT WARRANTY ANY TESTING OR RESULTS FROM A NON-GLI LABORATORY. WITHOUT LIMITING ANY OF THE FOREGOING, UNDER NO CIRCUMSTANCES SHOULD THE CERTIFICATION ESTABLISHED BY THIS REPORT BE CONSTRUED TO IMPLY ANY ENDORSEMENT OR WARRANTY REGARDING THE FUNCTIONALITY, QUALITY OR PERFORMANCE OF THE SUBJECT HARDWARE OR SOFTWARE, AND NO PERSON OR PARTY SHALL STATE OR IMPLY ANYTHING TO THE CONTRARY. THE LIABILITY AND OBLIGATIONS OF GLI HEREUNDER, AND THE REMEDY OF THE RECIPIENT, UNDER OR IN CONNECTION WITH THIS AGREEMENT SHALL BE LIMITED TO, AT GLI’S OPTION, REPLACEMENT OF THE SERVICES PROVIDED OR THE REFUND BY GLI OF ANY MONIES RECEIVED BY IT FOR THE SERVICES PROVIDED. IN NO EVENT SHALL GLI BE RESPONSIBLE TO THE RECIPIENT OR ANY THIRD PARTY FOR ANY CONSEQUENTIAL, INCIDENTAL, DIRECT, INDIRECT OR SPECIAL DAMAGES, INCLUDING WITHOUT LIMITATION DAMAGES FOR LOST PROFITS OR REVENUE, BUSINESS INTERRUPTION, OR PUNITIVE DAMAGES, EVEN IF GLI HAD BEEN ADVISED OF THE POTENTIAL FOR SUCH DAMAGES AND WHETHER SUCH DAMAGES ARISE IN CONTRACT, NEGLIGENCE, TORT, UNDER STATUTE, IN EQUITY, AT LAW OR OTHERWISE. ALL RIGHTS AND REMEDIES OF THIRD PARTIES RELATING TO PRODUCTS AND SERVICES THAT ARE THE SUBJECT OF THE CERTIFICATION ESTABLISHED BY THIS REPORT SHALL BE THE EXCLUSIVE RESPONSIBILITY OF THE RECIPIENT AND GLI EXPRESSLY DISCLAIMS ANY LIABILITY WHATSOEVER IN CONNECTION WITH SUCH THIRD PARTY RIGHTS AND REMEDIES. GLI AND THE RECIPIENT ACKNOWLEDGE AND AGREE THAT THE SERVICES PROVIDED BY GLI HEREUNDER COULD NOT BE RENDERED BY GLI UNDER THE TERMS PROVIDED HEREIN WITHOUT AN INCREASE IN COST IF GLI WAS REQUIRED TO PROVIDE ANY WARRANTIES IN ADDITION TO, OR IN LIEU OF, OR WAS REQUIRED TO ASSUME ANY LIABILITY IN EXCESS OF, THE FOREGOING.

SY-52-ADC-11-11-497 Page 22 of 22

If you should have any questions regarding this information, please feel free to contact our office.

Sincerely, GAMING LABORATORIES INTERNATIONAL, LLC

Christine M. Gallo Vice President of Technical Compliance and Quality Assurance

c:

mt

Mr. Jim Slattery, Bally Technologies

June 14, 2013 Mr. Roderick Thomas Penn National Gaming, Inc. 825 Berkshire Blvd Wyomissing, PA 19610 RE: Evaluation of New Penn Universal Management Application (PUMA) 12.0.0 REF: SY-286-PNG-13-01 World Headquarters 600 Airport Road Lakewood, NJ 08701 Phone (732) 942-3999 Fax (732) 942-0043 www.gaminglabs.com

Dear Mr. Thomas, Based on a request from Penn National Gaming, Inc (Penn), Gaming Laboratories International, LLC has reviewed the Penn Universal Management Application (PUMA) 12.0.0. The Penn Universal Management Application (PUMA) is a means of unifying existing Penn National Gaming (Penn) property specific player tracking systems that do not normally interact with each other into a single universal card system. PUMA centrally manages the core functionality shared across the participating Penn properties. It bridges the typically independent Aristocrat Oasis and Bally ACSC systems at the property level, while providing access to data stored at the Universe level to thirdparty systems such as Hotel, Point-of-Sale and Kiosk systems. PUMA, at a high level, interacts with gateways via web services interfaced using the XML communication protocol. PUMA acts as a central point of integration for key functionality through out the participating properties including: · ·

Worldwide Locations World Headquarters Lakewood, New Jersey

U.S. Regional Offices Colorado Nevada

International Offices GLI Africa GLI Asia GLI Australia Pty Ltd GLI Austria GmbH GLI Europe BV GLI Italy GLI South America

· ·

Cross property card recognition Creates portability with a single card that can be used across the Penn Universe, allowing patrons to: o Earn Select rewards at all participating Penn Universe properties. o Redeem select rewards at all participating Penn Universe properties. o Earn Tier points at all participating Penn Universe properties. Management of patron exclusion at the local, regional, and national levels. Setting and managing tiers and expiration dates for patrons.

Mr. Roderick Thomas SY-286-PNG-13-01 June 14, 2013 Page 2 of 7

While the above functionality is controlled by PUMA, the base functionality still resides with the base player tracking system resident at each individual property. Penn National Gaming operates numerous properties across multiple jurisdictions. These properties are utilizing either the Aristocrat Oasis system or the Bally ACSC system. Each of these systems acts as the Monitoring and Control System for the slot floor, as well as the player tracking system. PUMA allows for the integration of these unrelated systems to share key data between each other. Day to day interactions at the property level will be mostly unaffected by the deployment of PUMA as most interactions with the player tracking system will remain as they are today. Once PUMA is deployed, it will allow for: · · · · · · · ·

Player Master ID Centralized PIN functionality Centralized Exclusion Codes Active Directory Integration Centralized Tier Management Universal Tier Points Universal Comps Centralized Data

System Software: The Penn Universal Management Application shall be divided into multiple sub systems. They are loosely coupled in nature and provide maintainability and scalability. The core system implements hub and spoke framework via gateways. The following items make up the core aspect of the PUMA: Coordinator Service (Coordinator.Service.exe) ·

Responsible for Health Check, Active Directory Group Sync, Tier Credit Expiration, Stop Code Expiration, Penn Universal Keep Alive.

LAWS Engine (Laws.Service.exe) ·

Responsible for rating processing, tier point aggregation, tier point calculation, tier evaluation and promotion, tier updates, tier demotions, comp expirations, and enforcement of all Penn Universal Business Rules.

Mr. Roderick Thomas SY-286-PNG-13-01 June 14, 2013 Page 3 of 7

PUSH Engine (Pushengine.Service.exe) ·

Responsible for stop/status code enforcement updates, PIN creation/updates, tier creation/updates, player enrollment/updates, player restrictions evictions creation/updates, and patron merge requests.

Puma Web App (HA.Halo.PlayerPin.dll) ·

Handles all Player PIN related functionality (PIN CREATE, PIN RESET).

Penn Universal Management Application (PUMA) 12.0.0

File Name

Version

GLI Verify® CDCK Signature

Laws.Service.exe

12.0.0

51CB

Pushengine.Service.exe

12.0.0

D1A6

Coordinator.Service.exe

12.0.0

9F8F

HA.Halo.PlayerPin.dll

12.0.0

BE5E

GLI Verify® SHA-1 Signature 6906364FC405D3325C2621F9 CA7F51E7E0B98E3F BD542E5F94D7081ECFBBAF FEA6DB1295766A736F A4E26BB5A3201DDAFF2AB DCFFCA740D217A2D198 40BA83469895789E71FC92C 962F0EAD3534C7E2F

GLI Verify® v5.3 is an application developed by Gaming Laboratories International, LLC (GLI) to generate CDCK and SHA-1 signatures on files, folders, DVD, CD and Compact Flash media. GLI Verify® v5.3 can be downloaded from GLI’s website at www.gaminglabs.com. Or contact GLI Compliance at 1-888-GLI-REGS (454-7347) or E-Mail at [email protected]. GLI Verify® - Verification Procedure: 1. 2. 3. 4. 5.

Select the ‘File’ radio button Click on the folder icon to browse and specify the file you wish to signature If a different seed is needed, click the seed box and enter a new seed Click the “Verify” button The program will generate a CDCK and SHA-1 signature and display the results

Mr. Roderick Thomas SY-286-PNG-13-01 June 14, 2013 Page 4 of 7

The PUMA was tested in conjunction with Aristocrat Oasis 11.6.2 (SuperPlayMate v11.10.5902, x2S v11.10.5902.21, S2S Client Service v11.10.5900.101, PitBOSS v11.10.5902, FloorLogix v11.10.5900.101, Sentinel III v2.4.24.1, nk.nb0 v2.4.16, and Non-Cash Gateway v11.10.5900) as well as ACSC S1150_1 and Penn Universe Phase III Card Encoding Custom Modifications. Although testing was conducted with the above listed versions, connectivity is not limited to only these versions, please consult with the appropriate supplier. Conclusion: Please note, this report is not an approval for any jurisdiction. A functional evaluation of the PUMA 12.0.0 has been conducted. Based on this full evaluation of the current Gaming Laboratories International, LLC Standard Series of regulations, it has been determined that, in its current implementation, there are no functionalities that impact regulatory compliance and, therefore does not require additional testing unless specifically requested by a regulatory agency. The addition of any functionality, such as interaction with electronic funds, would require GLI to reevaluate the product and scope of this report. The final determination of whether this product should be certified by Gaming Laboratories International, LLC remains with the regulator(s).

Terms and Conditions: This Report has been prepared and submitted at the request of Penn National Gaming, Inc. (the Recipient) and is issued solely for the benefit of the Recipient and no other party, and may not be relied upon for any reason by any person or entity other than the Recipient including, a “Third Party”, notwithstanding the fact that a copy of the Report may be delivered or otherwise made available to a Third Party. In this regard, the Recipient and any Third Party will be deemed to have acknowledged that nothing in this Report is intended to create, nor shall it be deemed or construed to create, any relationship between (a) Gaming Laboratories International, LLC (GLI) and the Recipient other than that of independent entities contracting with each other solely for the purpose of the preparation and submission of the Report; and (b) GLI and a Third Party. Neither GLI nor the Recipient, nor any of their respective employees or representatives, shall be construed to be an agent, employer or representative of the other.

Mr. Roderick Thomas SY-286-PNG-13-01 June 14, 2013 Page 5 of 7

The analysis provided by this Report applies exclusively to tests conducted using current and retrospective methods developed by Gaming Laboratories International, LLC (GLI) on the specific items submitted by the Recipient. It is the responsibility of the manufacturer and/or developer of the items submitted to apply for, obtain and maintain all necessary gaming licensure in each jurisdiction in which they do business, including state and tribal jurisdictions, where applicable. Compliance with any safety or other non-gaming regulations related to the aforementioned testing is the sole responsibility of the manufacturer and/or developer of the items submitted; GLI accepts no responsibility, makes no representations and disclaims any liability with respect to all such non-gaming testing. The test methods used, excluded tests, and actual data showing the test results are available to the Recipient upon written request. With respect to analysis of new tables games, new paytables for electronic devices and other undertakings where GLI provides a mathematical review, the Recipient agrees to and acknowledges that due to complex mathematical processes, approximations and rounding errors that necessarily occur during any mathematical review, the results herein shall be understood by the recipient to be approximations and may fall within a range approximating the true mathematical results.

Mr. Roderick Thomas SY-286-PNG-13-01 June 14, 2013 Page 6 of 7

GLI WARRANTS TO THE RECIPIENT THAT ALL SERVICES PROVIDED BY GLI HEREUNDER HAVE BEEN PERFORMED IN ACCORDANCE WITH ESTABLISHED AND RECOGNIZED TESTING PROCEDURES AND WITH REASONABLE CARE IN ACCORDANCE WITH APPLICABLE LAWS. GLI DOES NOT MAKE, AND EXPRESSLY DISCLAIMS, ALL OTHER WARRANTIES OF ANY KIND, EXPRESSED OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF NON-INFRINGEMENT, MERCHANTABILITY, SUITABILITY OR FITNESS FOR A PARTICULAR PURPOSE. GLI DOES NOT WARRANTY ANY TESTING OR RESULTS FROM A NON-GLI LABORATORY. WITHOUT LIMITING ANY OF THE FOREGOING, UNDER NO CIRCUMSTANCES SHOULD THE ANALYSIS PROVIDED BY THIS REPORT BE CONSTRUED TO IMPLY ANY ENDORSEMENT OR WARRANTY REGARDING THE FUNCTIONALITY, QUALITY OR PERFORMANCE OF THE SUBJECT HARDWARE OR SOFTWARE, AND NO PERSON OR PARTY SHALL STATE OR IMPLY ANYTHING TO THE CONTRARY. THE LIABILITY AND OBLIGATIONS OF GLI HEREUNDER, AND THE REMEDY OF THE RECIPIENT, UNDER OR IN CONNECTION WITH THIS AGREEMENT SHALL BE LIMITED TO, AT GLI’S OPTION, REPLACEMENT OF THE SERVICES PROVIDED OR THE REFUND BY GLI OF ANY MONIES RECEIVED BY IT FOR THE SERVICES PROVIDED. IN NO EVENT SHALL GLI BE RESPONSIBLE TO THE RECIPIENT OR ANY THIRD PARTY FOR ANY CONSEQUENTIAL, INCIDENTAL, DIRECT, INDIRECT OR SPECIAL DAMAGES, INCLUDING WITHOUT LIMITATION DAMAGES FOR LOST PROFITS OR REVENUE, BUSINESS INTERRUPTION, OR PUNITIVE DAMAGES, EVEN IF GLI HAD BEEN ADVISED OF THE POTENTIAL FOR SUCH DAMAGES AND WHETHER SUCH DAMAGES ARISE IN CONTRACT, NEGLIGENCE, TORT, UNDER STATUTE, IN EQUITY, AT LAW OR OTHERWISE. ALL RIGHTS AND REMEDIES OF THIRD PARTIES RELATING TO PRODUCTS AND SERVICES THAT ARE THE SUBJECT OF THE ANALYSIS PROVIDED BY THIS REPORT ARE PROVIDED SOLELY BY THE RECIPIENT AND NOT BY GLI AND GLI EXPRESSLY DISCLAIMS ANY LIABILITY WHATSOEVER IN CONNECTION WITH SUCH THIRD PARTY RIGHTS AND REMEDIES. GLI AND THE RECIPIENT ACKNOWLEDGE AND AGREE THAT THE SERVICES PROVIDED BY GLI HEREUNDER COULD NOT BE RENDERED BY GLI UNDER THE TERMS PROVIDED HEREIN WITHOUT AN INCREASE IN COST IF GLI WAS REQUIRED TO PROVIDE ANY WARRANTIES IN ADDITION TO, OR IN LIEU OF, OR WAS REQUIRED TO ASSUME ANY LIABILITY IN EXCESS OF, THE FOREGOING.

Mr. Roderick Thomas SY-286-PNG-13-01 June 14, 2013 Page 7 of 7

If you should have any questions regarding this information, please feel free to contact our office.

Sincerely, GAMING LABORATORIES INTERNATIONAL, LLC

Christine M. Gallo Sr. Director of Technical Compliance & Quality Assurance

mt/am

June 17, 2015 World Headquarters 600 Airport Road Lakewood, NJ 08701 Phone (732) 942-3999 Fax (732) 942-0043 www.gaminglabs.com

Mr. John Glennon Chief Information Officer Massachusetts Gaming Commission 101 Federal Street Boston, MA 02110 REF:

OS-497-PLP-15-01

RE:

On-site inspection conducted at Plainridge Park Casino

Dear Mr. Glennon: On the date of June 12, 2015, Gaming Laboratories International, LLC (GLI) personnel completed an on-site inspection at Plainridge Park Casino, located in Plainville, Massachusetts. The inspection was conducted in one part: 1. Software audit on 1,499 Electronic Gaming Positions (EGPs) to determine compliance with sections of 205 CMR 143.00: Gaming Devices and Electronic Gaming Equipment and 143.09: Electronic Table Game Systems The details and the outcome of the Electronic Gaming Devices are as follows: Part 1–Software Audit Worldwide Locations World Headquarters Lakewood, New Jersey

U.S. Regional Offices Colorado Nevada

International Offices GLI Africa GLI Asia GLI Australia Pty Ltd GLI Austria GmbH GLI Europe BV GLI Italy GLI South America

Gaming Laboratories International, LLC conducted a software audit on Electronic Gaming Positions (EGPs). The purpose of the software audit was to ensure that the software being used in the gaming devices was approved under the adopted standards of the Commonwealth of Massachusetts. GLI personnel verified and recorded the software identification numbers and generated the respective signatures for each piece of software. The recorded information was then compared to the information within the central GLI database to determine the approval status of the software.

Mr. Glennon June 17, 2015 OS-497-PLP-15-01 Page 2 of 3

Within the 1499 EGPs audited, there were a total of 7488 pieces of software verified. The summary of the status for these software programs is listed below: **Please note that one IGT machine could not be tested because the machine was missing a hard drive. **Please note that 2 Multi Media machines contained software that was approved by another test lab. GLI was supplied with the certification report that indicates that the software was approved for Massachusetts. Approved

7481

Not Approved

0

Non-Mandatory Upgrade

5

Revoked

0

Not GLI Tested

2

Total number of items verified

7488

Status Descriptions: Approved (AP) - Signifies items that have been tested against and approved under the GLI-11 standards for Gaming Devices in Casinos and/or under the GLI-13 standards for OnLine Monitoring and Control Systems (MCS) and Validation Systems in Casinos. Non-Mandatory Upgrade (NU) - Signifies items that had been previously tested against and approved under the GLI-11 standards for Gaming Devices in Casinos and/or under the GLI-13 standards for On-Line Monitoring and Control Systems (MCS) and Validation Systems in Casinos and were subsequently assigned a ‘Non-Mandatory Upgrade’ status. The Gaming Laboratories International, LLC recommended ‘Non-Mandatory Upgrade’ status indicates there were enhancement(s) to the items that would not affect the integrity of the game and therefore, would not warrant a revocation. These are not mandatory replacements. In addition, there were ‘Non-Mandatory Upgrade’ (NU) programs have been conditionally revoked. The details are included on the attached spreadsheet. Not GLI Tested (NGT) - Signifies items that have not been submitted to GLI for testing against any standards, therefore have not been tested or approved by GLI.

Mr. Glennon June 17, 2015 OS-497-PLP-15-01 Page 3 of 3

All testing details can be found in the attached On-Site Inspection Slot File document which has been saved onto a USB thumb drive. If you have any questions or require any additional information, please feel free to contact our office. Sincerely, GAMING LABORATORIES INTERNATIONAL, LLC

Robert Schrader Director for Field Inspections and Operations

GLI Internal Department Reference: PC-FI-001/42/168/187/188/167/11/72 dls

June 15, 2015 Mr. John Glennon Chief Information Officer Massachusetts Gaming Commission 101 Federal Street Boston, MA 02110

World Headquarters 600 Airport Road Lakewood, NJ 08701 Phone (732) 942-3999 Fax (732) 942-0043 www.gaminglabs.com

REF:

OS-497-PLP-15-02

RE:

On-site inspection conducted at Plainridge Park Casino

Dear Mr. Glennon: On the date of June 12, 2015, Gaming Laboratories International, LLC (GLI) personnel completed an on-site inspection at Plainridge Park Casino, located in Plainville, Massachusetts. The objective of the engagement was to confirm compliance with to determine compliance with all pertinent sections of 205 CMR 143.00: Gaming Devices and Electronic Gaming Equipment. The inspection was conducted in four parts: 1. Inspected the Bally Technologies ACSC CMS/SMS 11.5.1.2 2. Communication / Cashless (Freeplay) Testing of 1,499 Electronic Gaming Positions (EGPs) 3. Software Verification on 10 Global Cash Access, Inc. Ticket Redemption Terminal Kiosks 4. Progressive Increment Testing Part 1 - System Inspection Overview

Worldwide Locations World Headquarters Lakewood, New Jersey

U.S. Regional Offices Colorado Nevada

International Offices GLI Africa GLI Asia GLI Australia Pty Ltd GLI Austria GmbH GLI Europe BV GLI Italy GLI South America

Gaming Laboratories International, LLC personnel were on-site to inspect the Bally Technologies ACSC CMS/SMS 11.5.1.2. The system inspection process consisted of verifying that the controlled files match those that have been tested and approved by Gaming Laboratories International, LLC and to ensure they comply with the Rules and Regulations set forth by the Commonwealth of Massachusetts (205 CMR 143.03: On-Line Monitoring and Control Systems (MCS) and Validation System, 143.05: Bonusing Systems, 143.06: Promotional Systems and Penn Universal Management Application (PUMA) module residing on the ACSC system, 143.13: Player User Interface Systems): Progressive Increment Testing, 143.02. The files are deemed controlled files after analyzing their functions with the participation of the system manufacturer. The signatures for each controlled file are then generated using the same tools used in the laboratory. These signatures are compared to the signatures that are stored in our system archives and reflected on the certification report(s).

Mr. Glennon June 15, 2015 OS-497-PLP-15-02 Page 2 of 6

System Inspected Bally Technologies ACSC (CMS/SMS) 11.5.1.2

Manufacturer: System Name: Version:

System Software Verified

File Name

Version

CASPGMXX/ SMSPGMXX

11.5.0 E1150_12 11.5.0 E1150_12 11.5.0 E1150_12 11.5.0 E1150_12 Penn Universe Mod Pack IV Emergency Pack 11.5.0 E1150_12 Penn Universe Mod Pack IV Emergency Pack 11.5.0 E1150_12 22.40 Build 11 201.82 Build 2 202.33 Build 1 IIVUX1300 0A0204_10 Penn FixPack 5

XCAPGMXX ACSCGUI_INSTALLER .exe ACSC.ear

TSPENNMOD1

TSPUMAPGM1

Gearbox.exe ETSService.exe GNSService.exe iVIEW 13.02.04 \Apps TSPENFIXXX

GLI Verify® CDCK Signature N/A N/A FD7E BD1D

BEE995D20D78FA7E1265D04 80199731EA52479F0 254549DB407F7E023C912EF9 2CD40E9A74F27035 768CC4BBB0385577656749A 9BEF936F402FBBA2A 78F1F37416A1B4F9DBC04A BCFB50D9BB50CC1445

GLI File Number

GLI Status*

SY-52-ADC-11-11

AP

SY-52-ADC-11-11

AP

SY-52-ADC-11-11

AP

SY-52-ADC-11-11

AP

N/A

8AC7CDE69978B158462DD8 75A04A45B918C2BDB4

SY-286-ADC-13-01

AP

N/A

28C90EAD7B01067158B0EA3 8125B24CC51B96500

SY-286-ADC-13-01

AP

SY-08-ADC-14-01

AP

SY-08-ADC-14-02

AP

SY-52-ADC-14-08

AP

SY-497-ADC-15-02

AP

SY-129-ADC-15-02

AP

SY-497-ADC-15-01

AP

SY-497-ADC-15-01

AP

19AE 891C E317 593C N/A

TSPENIDS

N/A

N/A

TSPENIDPC

N/A

N/A

AP = APPROVED

GLI Verify® SHA-1 Signature

1DE24CB8E161968BA050D45 A9025CE183BA81C98 C7FA4BEF6BBC3F279D34E4 6D07070C61A604CCEB 20F73934DFE2B93A904A79A 7BA0C46601CD5ABD5 509B89716E86F3D462D539D AA28E3DF34F171F5C 8D157BFB7C04E667826C79F E7E184AD93B51BEEC 07E56775EA1CE9B04990925 E0B042DB433DDBC48 1C3E24A669CB15DAF7FDFF 6F188BA0412EFB6A7F

Mr. Glennon June 15, 2015 OS-497-PLP-15-02 Page 3 of 6

The IDS Integration interface is a service that allows for the ACSC system to communicate with the Commonwealth of Massachusetts Department of Revenue (DOR) Winnings Intercept Service. This service allows properties in Massachusetts to deduct any outstanding amount owed to the State from a player's jackpot winnings. This information is verified with the DOR using first name, last name, and Taxpayer ID Number (Social Security). When a jackpot is processed that exceeds the reporting threshold, a request is sent to the DOR database from the ACSC system. A response is then sent back with information on any amount outstanding. The player is then paid, minus the amount owed. GLI performed a functional review of the IDS service based on design documents and specifications provided by both Bally/ACSC and the DOR. A test system environment was prepared and verified to have identical software using signature validation. This test system was connected to the DOR database that stores the outstanding debt amounts. Several test cases were observed using various jackpot amounts and debt amounts. In all cases observed by GLI, the ACSC system successfully withheld the correct amount from the cash dispensed to the player. Part 2 - Communication / Cashless (Freeplay) Testing of 1,499 EGPs GLI personnel conducted operational bill and ticket testing on the 1499 Gaming Positions in order to verify proper operation and communication between the Gaming Positions and the Bally ACSC CMS/SMS 11.5.1.2, by verifying that all games accurately credit and report game activity information to and from the SAS host. The data was collected from each machine and compared to the system meter test reports to ensure it was accurately reported to the system. Cashless functionality “Free Play” was also tested (205 CMR 143.04: Cashless Systems) during the communications test. Free play is Non-Cashable Electronic Promo (NCEP) which is promotional credits awarded to the player as part of a marketing promotion. These credits are restricted from being cashed out however a patron can upload any unused promo points back to their account by removing the player card from the machine. Subsequent to the test results, Gaming Laboratories International, LLC is satisfied that

1,499 Gaming Positions passed operational bill/ticket testing and passed cashless functionality testing and are communicating properly with the Bally ACSC CMS/SMS 11.5.1.2 at the Plainridge

Park Casino in Plainville, Massachusetts.

**Please note that one IGT EGD could not be tested because the machine was missing a hard drive.

Mr. Glennon June 15, 2015 OS-497-PLP-15-02 Page 4 of 6

Part 3 –Software Verification – 10 Global Cash Access Kiosks During the third part of the inspection, GLI personnel verified the software for 10 Global Cash Access, Inc. kiosks. The kiosk inspection consisted of verifying that the installed files match those that have been tested and approved by Gaming Laboratories International, LLC to assure they comply with the Rules and Regulations set by the Commonwealth of Massachusetts (205 CMR 143.07: Kiosks). The signatures for each controlled file are then generated using the same tools used in the laboratory. These signatures are then compared to the signatures that are stored in our software archive and reflected on the certification report(s). GLI personnel verified the software installed on the 10 Global Cash Access, Inc. kiosks identified below: Kiosk ID Number

Kiosk Serial Number

K001 K002 K003 K004 K005 K006 K007 K008 K009 K010

1600049 1600041 1600045 1600043 1600046 1600050 1600048 1600047 1600042 1600044

The following files were operating as part of the Global Cash Access, Inc. kiosks. These files allow the devices to operate in conjunction with the Bally Technologies ACSC CMS/SMS 11.5.1.2. These files have been verified with the correct values as displayed in the following table:

File Name

Version

Verify +® CDCK Signature

CXC5.exe

15.0.23.0

8CC1

PXC5.exe

5.0.19.0

E602

*AP = APPROVED

Verify +® SHA-1 Signature

0942C98F7B533C20411DC6 83114E3E95860093A1 FD164CB9679DDEE25C6D0 67BB12993A4742CF4FF

*NU = Non-Mandatory Upgrade

GLI File Number

GLI Status*

SY-73-GAC-15-01

NU

SY-73-GAC-15-01

AP

Mr. Glennon June 15, 2015 OS-497-PLP-15-02 Page 5 of 6

In addition to verifying the approval status for each Global Cash Access, Inc. kiosk file, GLI conducted Phase II testing which consisted of testing the disbursement of funds of tickets inserted as well as testing the bill breaking features on each kiosk. The test results were evaluated for accuracy by comparing the recorded information against the system report. Subsequent to the test results, Gaming Laboratories International, LLC is satisfied that the 10 Global Cash Access, Inc. kiosks passed Phase II testing and are communicating properly with the Bally ACSC CMS/SMS 11.5.1.2. Part 4 – Progressive Increment Testing During the fourth and final part of the inspection, GLI personnel verified the progressive increment rates on 546 EGD’s. (143.02: Progressive Gaming Devices) This was done by documenting the start and end progressive values into the test form. The difference was verified by calculating the expected increase using the configuration supplied by the casino and the amount played on a gaming terminal during the bill and ticket testing. Subsequent to the test results, Gaming Laboratories International, LLC is satisfied that the increment rate of the 546 progressive EGD’s have been tested and confirmed to be accurate.

Conclusions Passed X

# of Gaming Position 1,499 # of Gaming Position 1,499 Kiosks # of Kiosks 10

Bally Technologies ACSC (CMS/SMS) Version 11.5.1.2 Failed Incomplete

Passed 1,499

Bill/Ticket Testing Failed 0

Incomplete 1

Passed 1,499

Cashless Functionality Testing Failed 0

Incomplete 1

Software Verification Passed Failed Incomplete 10 0 0

Redemption Testing Passed Failed Incomplete 10 0 0

The identification information for the EGDs tested can be found in the attached On-Site Inspection Slot File document.

Mr. Glennon June 15, 2015 OS-497-PLP-15-02 Page 6 of 6

Thank you for your continued relationship as we work to meet your on going, on-site testing needs. If you should have any questions regarding this information, please feel free to contact our office. Sincerely, Gaming Laboratories International, LLC

Robert Schrader Director of Field Test Engineering

GLI Internal Department Reference: PC-FI-001/11/72/123/70/168/188/167/184/189/187 dls

PENN NATIONAL

G A M I N G, I N C.

June 9, 2015 Mr. John R. Glennon Chief Information Officer Massachusetts Gaming Commission 101 Federal Street 23rd Floor Boston, MA 02110 Dear John: As you are aware, before Plainridge Park Casino (PPC) can pay any single jackpot in excess of $1,200, Section 51 of the Massachusetts Gaming Act requires that the casino “ascertain whether the winner of the cash or prize owes past-due child support to the commonwealth or to an individual to whom the IV-D agency is providing services and to ascertain whether the winner of the cash or prize owes any past-due tax liability to the commonwealth”. To accommodate this rule and at the request of the Department of Revenue (DOR), the ACSC casino management system (ACSC) to be used at PPC was modified to facilitate the intercept requirement. The ACSC program has been modified to interface directly with DOR’s Interagency Data Services Web Platform (IDS) to accomplish this task. As I understand it, the involvement between the ACSC and IDS systems is minimal with ACSC querying the IDS system with a name and SS# of a patron and the IDS system sending back a match or no-match message. If a match, then the IDS system transmits the amount of the jackpot to be intercepted and a transaction code. The base ACSC version being used at PPC has been GLI certified to Massachusetts standards. However, it is my understanding that the ACSC-IDS interface module has not yet been GLI certified since GLI has never been given standards by the Massachusetts Gaming Commission against which to certify it. By tomorrow afternoon (June 6, 2015) we will begin using the PPC ACSC system for preopening player card sign-up and in less than two weeks (June 22) the full system will be operational with actual playing patrons. On June 22, we will need to use the ACSC-IDS interface module for any jackpot winners. Since the ACSC-IDS interface module is a part of ASCS system, we assume it is required to be GLI certified pursuant to 205 CMR 143, unless that module can be considered a non-gaming ancillary system. Since GLI certification for the ACSC-IDS interface module cannot be obtained prior to June 22, we believe we will need a temporary variance or exemption from 143.03 to allow us to use that module prior to GLI certification. Secondarily, we respectfully request that MGC provide GLI with certification standards for the ACSC-IDS interface module so that GLI can complete their certification of that module. 

825 Berkshire Boulevard



Wyomissing, PA 19610



610.373.2400



We have tested the full PPC ACSC system (including the ACSC-IDS interface module) in our test environment and have not experienced any significant unresolved issues. As such, we are confident that it will work properly in the production. However, since the ACSC-IDS interface module is a new module that, to our knowledge, has never been used or GLI certified in any jurisdiction, we would expect some reasonable forbearance should any aspect of that module experience problems. If you have any questions or would like to discuss further, feel free to contact me at 610-4012946. Sincerely, _Jim Baldacci_________________________________ Jim Baldacci Deputy Chief Compliance Officer



825 Berkshire Boulevard



Wyomissing, PA 19610



610.373.2400



Prototypes that require an MGC Permit Manufacturer Ainsworth Aristocrat

Bally

IGT

Konami

Multimedia WMS

Model A560 Helix Upright Verve Veridan Viridian Viridian WS Pro Curve Pro Curve 3R Pro 27/27 Pro V22/22 Pro V32 Pro V32 5R Pro Wave Pro Stepper Pro Stepper 3R Pro V32 5R Pro V32 Crystal Dual LCD Crystal Dual MLD G20 G20 Bar Top G23 G23 MLD V2 S3000 SAVP Universal Slant ADV 3 ADV 5 KP3 Monuments Podium Revolution Player Classic Player HD Blade Stepper Blade Video S23 Slant

TO:

Chairman Crosby, Commissioners Cameron, McHugh, Stebbins and Zuniga

FROM: Mark Vander Linden, Director of Research and Responsible Gaming CC:

Roberta Gregoire, Plainridge Park Casino, Compliance Manager

DATE:

June 18, 2015

RE:

Responsible Gaming Initiatives at Plainridge Park Casino

Background Embedded in the Expanded Gaming Act are numerous provisions to mitigate problem gambling and promote responsible gaming. Consistent with this direction, the MGC worked with a range of stakeholders to create a Responsible Gaming Framework (RGF). The RGF has informed the development of gaming regulation in Massachusetts and provided an overall orientation to responsible gaming practice and policy for licensees and the Commission. In order for the Plainridge Park Casino (PPC) to open, several key responsible gaming initiatives must be operational and policies approved by the MGC. These include 1) Voluntary Self-Exclusion program, 2) Voluntary Credit Suspension program, 3) GameSense Information Center, and 4) a PPC Responsible Gaming Plan. Voluntary Self-Exclusion • •

The Voluntary Self-Exclusion (VSE) Program provides patrons one means of addressing problem gambling behavior by prohibiting their entrance to the gaming area of the gaming establishment or any area in which pari-mutuel or simulcasting wagers are placed. The VSE policies and procedures meet the requirements of 205 CMR 133; G.L. c 23K, § 45(f), Voluntary-Self Exclusion. The VSE Program became operational on June 12th. Persons may enroll through the MA Council on Compulsive Gambling or the MGC. When PPC opens, Penn Security staff have been trained as designated agents and prepared to enroll patrons and enforce the program, as well as MGC Agents and GameSense Advisors.

Voluntary Credit Suspension • The Voluntary Credit-Suspension (VSC) Program allows patrons who do not wish to voluntarily self-exclude an option to impose some restrictions on their personal access to financial credit within the casino. • The VSC policies and procedures meet the requirements of 205 CMR: 138.44, Patron Request for Suspension of Credit Privileges. When PPC opens, staff will be prepared to enroll patrons and enforce the program.

GameSense Info Center • The GameSense Information Center or (GSIC) will be the central hub at PPC for information and resources on positive play as well as at-risk and problem gambling. • The GSIC will be staffed by GameSense Advisors (GSA). Three of the four GSAs began training on June 4th and will be prepared for PPC to open on June 22nd. • GSAs will provide a range of responsible gaming and problem gambling information to any casino guests or off-the clock PPC employees from 10 AM to 2AM. GameSense Advisors will also be the primary respondents to those seeking to enroll or gain more information regarding Voluntary Self-Exclusion and Play Management tools. • The GSIC meets the requirements of G.L. c 23K, § 9(a)(8)(ii) specifying an on-site space for independent substance abuse and mental health counseling service. Plainridge Park Casino Responsible Gaming Program • The PPC Responsible Gaming Program outlines policies, procedures and programs consistent with the MGC’s expectations that gaming be conducted in a manner to minimize harm. The PPC Responsible Gaming Program has adopted initiatives that address each of the six strategies of the MGC Responsible Gaming Framework. Highlighted in the plan are efforts to incorporate and adopt the GameSense branding strategy and GameSense Info Centers, Play Management tools (when available), protections for vulnerable and underage populations, responsible alcohol service practices and responsible marketing policies. • Moving forward, I will continue to work with Plainridge Park Casino’s Responsible Gaming Committee to strengthen these strategies and ensure they are successfully implemented within the gaming establishment. Conclusion The key responsible gaming initiatives and policies outlined in this memo are in place and meet the Commission’s high expectations and statutory and regulatory requirements.

Plainridge Park Casino Diversity Report Monday, June 15, 2015

Construction Workforce Diversity

The Licensee reports that during the month of May the workforce consisted of approximately 200-250 workers; 19% is minority and 4% is female. This compares to goals of 16% and 7%, respectively. Also, 7% of the workforce were veterans. Cumulative Workforce Data through May 31, 2015: Category Minority Women Veteran Total Workforce Diversity

Goal % 16% 7% 3% 26%

Actual % 17% 4% 7% 33%

Variance 1% -3% 4% 2%

Construction Sub-contracts

As of May 31, 2015 the Licensee has authorized the contractor to award $97.5M in subcontracts. Of this, 32% ($25,200,000) has been awarded to businesses that are owned by Minority, Women and Veterans. Category MBE WBE VBE Total Diversity Spend

Spend $9,750,000 $12,675,000 $8,775,000 $25,200,000

Goal % 4% 7% 3% 14%

Actual % 10% 13% 9% 32%

Variance 6% 6% 6% 18%

Pre-Opening FF&E Diversity Spend Category MBE Spend WBE Spend VBE Spend Total Diversity Spend

Spend Goal % $403,837 6.0% $2,784,160 12.0% $2,141,259 3.0% $5,329,255 21.0%

Actual % 2.7% 18.7% 14.4% 35.8%

Variance -3.3% 6.7% 11.4% 14.8.0%

1|Page

Plainridge Park Casino Diversity Report Monday, June 15, 2015 Operations Operations Workforce -

Plainridge Park Casino hosted multiple job fairs including one in Plainville and one in each of the surrounding communities as per their respective host and surrounding community agreement. Additionally they hosted a culinary job fair at their property on May 23, 2015. The data is still unfolding as Plainridge Park Casino is projected to hire 70 more employees in the near future. Over 7,000 candidates applied for positions at the category 2 casino; 354 were from Plainville. The top three towns (Attleboro,16%; North Attleboro,17%; Plainville,12%) account for 29% of the total employees hired. Seventy Seven (77%) of employees hired were MA residents; of those, 65% reside within a 20 mile radius of Plainridge Park Casino. Category MA Residents Host/Surrounding Community Within 20 Mile Radius (in MA) Diversity/Ethnic Minorities

Goal % X 90% 10%

Actual % 77% 36% 65% 14%

Variance X -54% 4.0%

Gaming Licenses Submitted Type of License Key Gaming Gaming Service Grand Total

Number of Employees 38 180 209 427

Operations Diversity Spend

When fully operational, Plainridge Park Casino estimates a total annual vendor spend of $9 million with an estimated spend of $4.75 million with Massachusetts firms. Category MBE Spend WBE Spend VBE Spend Total Diversity Spend

Spend $28,853 $120,004 $1,195 $150,051

Goal % 6.0% 12.0% 3.0% 21.0%

Actual% 5.2% 21.6% 0.2% 27.0%

Variance -0.8% 9.6% -2.8% 6.0%

2|Page

MASSACHUSETTS GAMING COMMISSION DIVERSITY REPORT 06/18/2015

On February 28, 2014, Penn National Gaming received the Commonwealth of Massachusett’s only Category 2 Gaming License to construct a slots parlor at the Plainridge Racecourse, an exisiting harness racing track in Plainville, MA. Construction on the Plainridge Park Casino began on March 14, 2014. During the construction of their $250 million gaming facility the project employed approximately 300 individuals and awarded contracts of $97.5M total with about $25 million to minority, women and veteran owned businesses. Plainridge Park Casino's grand opening is planned for June 24, 2015 offering new employment opportunities to approximately 500 individuals.

Construction Workforce

16%

14%

17%

16%

18%

Workforce Diversity

Minority

Women

Goal % 14% Actual %

14%

Veterans

16% 17%

7% 4%

7%

12%

Goal %

10% 14%

10%

10%

7%

8%

Actual %

7%

6%

8% 6%

4%

4%

4%

2% 0%

10%

Goal Actual

12%

2% Minority

Women

Veterans

0%

Goals vs Actual Cumulative through May 2015

Goal

Workforce Goals: 16% Minority, 7% Women, 0% Veterans Actual: 17% Minority, 4% Women, 7% Veterans

Construction Vendor Diversity MBE

WBE

Goal Host/Surrounding Community Residents 90% Actual Host/Surrounding Community Residents Actual MA Residents

VBE 13%

Goal % 14% Actual % 12%

10%

4%

7%

10%

13%

9%

10%

3%

90%

9%

80%

Goal %

Actual %

6%

Local Workforce 90% 36% 77%

77%

70%

7%

8%

Actual

Goal: 10% Ethnic Minorities

4%

50%

3%

4%

60% 36%

40%

2%

30%

0%

MBE

WBE

20%

VBE

10%

Goals vs Actual Cumulative through May 2015

0%

Procurement Goals: 4% Minority, 7% Women, 3% Veterans Actual: 10% MBE, 13% WBE, 9% VBE

Goal Host/Surrounding Community Residents

Construction Vendor Diversity

69%

Minority Business EnterpWoman Business EnterpVeteran Business Enterprise 10% 13% 8%

VBE 8% $7.8 M

Balance 69% $67.28 M

WBE 13% $12.68 M

Spend

Goal %

Actual %

Variance -0.80%

MBE Spend

$28,853

6.00%

5.20%

WBE Spend

$120,004

12.00%

21.60%

9.60%

VBE Spend

$1,195

3.00%

0.20%

-2.80%

Total Diversity Spend

$150,051

21.00%

27.00%

6.00%

Balance Minority Business Enterprise Woman Business Enterprise

MBE 10% $9.75 M

Actual MA Residents

Operations Diversity Spend Category

Balance

Actual Host/Surrounding Community Residents

Veteran Business Enterprise Total Construction Subcontracts = $97.5 M Cumulative through May 2015

The terms MBE, WBE, and VBE are commonly used to refer to Minority Business Enterprise, Women Business Enterprise, and Veterans Business Enterprise.

CONTACT INFORMATION Jill Lacey Griffin Director of Workforce, Supplier and Diversity Development Massachusetts Gaming Commission E-mail: [email protected]

E-mail: [email protected] Website: WWW.MASSGAMING.COM

Average Wage Scale Adherence License Condition 18-11 on page 30 of the license conditions document of the gaming license requires that the average wage scale adhere to those submitted in the RFA-2 Application. The chart below compares the Projections from the RFA-2 Application to the Total forecasted payroll of Plainridge Park Casino submitted to the Commission on June 15, 2015.

Plainridge Park Casino FT PT # FTES Payroll Benefits Total Payroll

RFA-2 Projection 482 246 575 $17,416,200 $5,584,980 $23,001,189

First Year PPC Projection 428 190 523 $16,025,388 $7,001,934 $23,027,322

Variance -54 -56 -52 -$1,390,812 $1,416,954 -26,133

Penn National Gaming/Plainville Demographic Data – Host/Surrounding and Nearby Community Profile

Unemployment Rate Massachusetts

4.7%

Norfolk County

4.2%

Plainville - Host Community Total Population

North Attleboro

8,264

Total Population

28,712

Male

4,046

Male

13,993

Female

4,218

Female Population by Race

14,719

Population by Race White

94.2%

White

92.5%

Black

1.1%

Black

1.5%

American Indian

0.1%

American Indian

0.2%

Asian

3.1%

Asian

3.5%

Hispanic

1.8%

Hispanic

Unemployment Rate 4.5% Mansfield

Total Population

2.4%

Unemployment Rate 5.0% Wrentham

7,360

Total Population

Male

3,625

Male

Female

3,735

Female

10,955 5,400

Population by Race

5,555 Population by Race

White

92.6%

White

97.1%

Black

2.6%

Black

0.6%

American Indian

0.1%

American Indian

0.2%

Asian

2.8%

Asian

1.0%

Hispanic

2.1%

Hispanic

Unemployment Rate 4.1% Foxborough

Total Population

1.2%

Unemployment Rate 4.4%

Attleboro-Nearby Community 5,625

Total Population

Male

2,722

Male

Female

2,903

Female

43,886 21,294 22,299

Population by Race

Population by Race White

90.3%

White

87.1%

Black

2.8%

Black

3.0%

American Indian Asian

0.2% 4.1%

American Indian Asian

Hispanic

2.4%

Hispanic

0.2% 4.5% 6.3%

Unemployment Rate 4.5%

Unemployment Rate 5.2%

The demographic data contained in the community profiles was obtained from the 2010 U.S. Census Bureau data files. Unemployment rates are preliminary percentages for March 2015 as reported by the U.S. Bureau of Labor Statistics for March 2015.

Employee & Vendor Diversity Report June 11, 2015

Current Team Members- Goals • • • •

427 Hired and On-boarded Diversity 14% Local 36% MA Hires 77%

Current TM Residence Info – Top 10 NORTH ATTLEBORO

3%

3%

3%

3%

3%

ATTLEBORO

17%

PLAINVILLE

4%

MANSFIELD

5%

FRANKLIN

16%

5%

TAUNTON PAWTUCKET NORTON

6%

FOXBORO

6%

12% 7%

7%

PROVIDENCE WRENTHAM WOONSOCKET CUMBERLAND BROCKTON SEEKONK

Gaming Licenses Submitted Type of License

Number of TM’s

Gaming

180

Key

38

Registrant

209

Grand Total

427

Pre-opening FF&E Diversity Spend 22.00% 20.00%

*Percentages of eligible spend 18.7%

18.00% 16.00%

14.4% WBE Spend

14.00% 12.0%

WBE Goal

12.00%

MBE Spend

10.00%

MBE Goal VBE Spend

8.00% 6.0%

VBE Goal

6.00% 3.0%

2.7%

4.00% 2.00% 0.00%

WBE Spend

MBEof Spend Percentage Eligible Spend

Category WBE Spend MBE Spend VBE Spend Total Diversity Spend

Spend $2,784,160 $403,837 $2,141,259 $5,329,255

Actual % 18.7% 2.7% 14.4% 35.8%

VBE Spend Goal % 12.0% 6.0% 3.0% 21.0%

Variance 6.7% -3.3% 11.4% 14.8%

Operations Diversity Spend 22.00%

21.6%

*Percentages of eligible spend

20.00% 18.00% 16.00%

WBE Spend

14.00% 12.0%

WBE Goal

12.00%

MBE Spend

10.00%

MBE Goal VBE Spend

8.00% 5.2%

6.00%

6.0%

VBE Goal 3.0%

4.00% 2.00% 0.2% 0.00%

WBE Spend

MBEof Spend Percentage Eligible Spend

Category WBE Spend MBE Spend VBE Spend Total Diversity Spend

Spend $120,004 $28,853 $1,195 $150,051

Actual % 21.6% 5.2% 0.2% 27.0%

VBE Spend Goal % 12.0% 6.0% 3.0% 21.0%

Variance 9.6% -0.8% -2.8% 6.0%

Post Opening Action Plan • Continue to attend diversity supplier events • Vendor licensing fair – Hosted by Blackstone Valley Chamber of Commerce

• Maintain spend with pre-opening FF&E vendors • Addition of new licensed diversity suppliers to bid process

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Floor plan and status of inspections for final approval – As per 205 CMR 151.02 Plainridge Park Casino (PPC) had submitted their floor plan. The floor plan contained all information required information required by 205 CMR 151.02. The Massachusetts Gaming Commission’s Gaming Agents completed a physical comparison with the floor plan against the actual floor. Several numbering discrepancies were discovered with the slot machine and camera numbers. Staff reported these discrepancies to PPC staff and the floor plan was corrected and anew corrected floor plans were delivered to the 3 required locations. The floor plan is ready for final approval.

•

Hours of operation – As per 205 CMR 138.28 PPC must submit the hours of their gaming day. PPC has submitted their gaming day hours as starting at 6:00 am and finishing at 5:59:59 am the following day.

•

Internal controls submission and approvals – As per 205 CMR 138.02 at least 60 days prior to commencing gaming operations PPC must submit the proposed system of internal controls. PPC has met their filing requirement. PPC’s internal controls include: a. Administrative controls which include policies and procedures designed to assure that all activities and transactions are instituted and completed in accordance with the applicable policy and/or procedure. b. Accounting controls which include policies and procedures to assure that all activities and transactions are accurately reported and recorded in accordance with GAAP. c. Reporting controls which include policies and procedures for the timely reporting of economic and social impact reports, and standard financial and statistical reports and information in accordance with 205CMR. d. Surveillance controls as detailed in 205CMR 141. e. Physical controls which include the safeguarding of PPC’s assets, both by organizational safeguards (segregation of duties) and physical safeguards (restricted physical access, locks, etc). f. An Information Technology network security plan as described in 205CMR. In their submissions PPC requested nine (9) variances from the regulations. Seven (7) variances were approved by Executive Director Day. (See attachment A) The Internal controls were review by the IEB Staff including Gaming Agents and Financial Investigators as well as by outside consultants. The Internal controls have been found to be incompliance with the regulations of the Massachusetts Gaming Commission, and have been approved by Executive Director Day.

•

Security Plan – As per 205 CMR 138.14 PPC has submitted their security plan. Currently this has been reviewed by staff and returned to PPC with comments. The final approval process should be completed by the end of this week. Approval pending.

•

Surveillance Plan – As per 205 CMR 141 PPC has submitted a comprehensive surveillance plan. The plan has been reviewed by members of the IEB and found to be in compliance with the regulations of the Massachusetts Gaming Commission, and have been approved by Executive Director Day.

•

Critical Incident Preparedness plan/Emergency Response Plan – As per 205 CMR 138.22 PPC has submitted a comprehensive Critical Incident preparedness plan. The plan has been reviewed by members of the IEB and found to be in compliance with the regulations of the Massachusetts Gaming Commission, and have been approved by Executive Director Day.

•

AML/Title 31 Plan (Currency transaction reporting) – As per 205 CMR 138.40 PPC has submitted their AML/Title 31 plan. The plan was reviewed by an outside consulting team as well as IEB financial Investigators. The plan was found to be in compliance with the regulations of the Massachusetts Gaming Commission, and have been approved by Executive Director Day.

•

Slot Management Plan – As per 205 CMR 143, 144, and 145 PPC has submitted their slot management plan. The plan was reviewed by IEB Gaming Agent staff and outside consultants. The plan was found to be in compliance with the regulations of the Massachusetts Gaming Commission, and have been approved by Executive Director Day.

•

Monitoring of PPC test opening – During the test on June 22nd and June 23rd we will be monitoring PPC for compliance of the regulations and their approved submissions. We will be monitoring how effectively they have trained their staff and their ability to carry out their new functions. We will also be looking at how well the maintain the integrity of the gaming establishment.

(Attachment A)

May 26,2015 Mr. Lance George Vice President/General Manager Plainridge Park Casino 301 Washington Street Plainville, MA 02762 Dear Mr. George: On behalf of Plainville Gaming and Redevelopment, LLC, d.b.a. Plainridge Park Casino (hereinafter, "PPC"), by letter dated May 8, 2015, you requested variances from 205 CMR 138.00 pursuant to 205 CMR 102.03(4)(a). However, 205 CMR 138.00 includes a variance process that applies specifically to internal controls. Accordingly, my response follows the process described in 205 CMR 138.02(6)(a). I've included below a portion of each request followed by my response: 205 CMR 138.02(1): PPC: This section requires that a licensee submit to the Commission at least 60 days prior to commencing operations a proposed minimum system of internal procedures and administrative and accounting controls (hereinafter, "internal controls"). Although a verbal approval was granted on April 8, 2015, PPC is seeking formal approval to waive the 60 day requirement. Response: I appreciate your concern expressed in this paragraph. 205 CMR 138 will not be effective until approximately June 5, 2015 when the regulation is published by the Secretary of State. As the regulation is not effective and you have submitted a proposed system of internal controls you have complied with this section except for 205 CMR 138.02(4)(h)(i) which requires a certification from your "Chief Legal Officer" be included with your initial submission. As sufficient time remains to obtain this certification, the proposal is likely to achieve the same outcome as if the provision contained in 205 CMR 138.00 were incorporated. This variance is granted and shall be identified in the written approval issued in accordance with 205 CMR 138.02(2). 205 CMR 138.02(3) and 138.02(4)(h)(i): PPC: These sections require that the internal controls submission include a certification by the gaming licensee's chief legal officer that the submitted procedures conform to M.G.L. c.23K, 205 CMR 138.00 and any applicable regulations referenced therein. PPC does not employ a chief legal officer at the property location; however, the on-site compliance manager is familiar with, and able to certify to, compliance with the internal controls. Response: G.L. c.23K, § 25(d) provides: "Each applicant for a gaming license shall submit to the commission: (ii) a certification by the applicant's chief legal officer that the submitted procedures conform to this chapter and any regulations promulgated hereunder". I cannot grant a variance from a statutory requirement. Also, the requirement envisions a legal review of the proposed internal controls by an attorney for compliance with the statute and regulation. Where the individual you have proposed to make the required certification is not a lawyer, she\he does 1

not satisfy the "chief legal officer" requirement. Accordingly, the proposal does not meet the statutory requirement, and is not at least equivalent to the relevant provisions contained in 205 CMR 138.02(3) and 138.02(4) (h)(i) and is denied. 205 CMR 138.15(l)(a): PPC: Paragraph two of this section requires that access may be permitted to count rooms while a count is not in progress with a valid reason and permission of the IEB Agent on duty. PPC requests that a variance be granted so that PPC provides notice, rather than obtains permission, from the IEB Agent on duty when an employee or other person designated with an "A" access code must access the count room when a count is not in process. Response: The proposal, provided the notice is provided to the IEB agent on duty and clearly states the reason the access is needed and is reasonably in advance of the time the access will occur, is at least equivalent to the relevant provisions contained in 205 CMR 138.15(1)(a). The proposal, with the noted modification, is likely to achieve the same outcome as if the provision contained in 205 CMR 138.00 were incorporated. This variance shall be identified in the written approval issued in accordance with 205 CMR 138.02(2). 205 CMR 138.19(3)(a): PPC: This section requires that access to the count room be controlled by a locking door maintained by the Security department. PPC requests that a variance be granted so that the count room door can be controlled by the Surveillance department. Response: The proposal that the Security Department controls the access into the mantrap which leads to the cage and count room and Surveillance controls the doors from the mantrap to the cage and count room, is an enhancement over the minimum requirement for count room access (which allows for single department control) and accordingly is at least equivalent to the relevant provisions contained in 205 CMR 138.19(3)(a). The proposal is likely to achieve the same outcome as if the provision contained in 205 CMR 138.00 were incorporated. This variance is granted and shall be identified in the written approval issued in accordance with 205 CMR 138.02(2). 205 CMR 138.19(3)(c): PPC: This section requires a light system that illuminates one or more lights in the surveillance department and at each count room door, for purposes of maintaining constant surveillance on the entrance and exits to the count room. PPC requests a variance so that instead of a light system, the surveillance department could receive an audible and visual alert on the alarm display screen each time the count room door opens. Response: The proposal that the surveillance department receives an audible and visual alert on the alarm display screen each time the count room door opens, is at least equivalent to the relevant provisions contained in 205 CMR 138.19(3)(c). The proposal is likely to achieve the same outcome as if the provision contained in 205 CMR 138.00 were incorporated. This variance is granted and shall be identified in the written approval issued in accordance with 205 CMR 138.02(2)

2

205 CMR 138.19(11): PPC: This section requires that all persons present in the count room during the counting process, except agents of the IEB, wear as outer garments, only a full-length, one-piece, pocketless garment with openings only for arms, feet, and neck. PPC requests a variance so that security personnel may wear their uniforms in the count room. Response: The proposal that security personnel may wear their uniforms in the count room, provided that the security guard(s) presence in the count room is infrequent and they may not touch the money or paperwork while in the count room, is at least equivalent to the relevant provisions contained in 205 CMR 138.19(11). The proposal, with the noted modification, is likely to achieve the same outcome as if the provision contained in 205 CMR 138.00 were incorporated. This variance is granted and shall be identified in the written approval issued in accordance with 205 CMR 138.02(2) 205 CMR 138.33(7): PPC: This section requires that, whenever currency, a gaming voucher, or a coupon is found inside a bill changer but outside of the slot cash storage box during collection of slot cash storage boxes, a form with the date, amount, and asset in which the unsecured drop was found be completed and placed in a locked accounting box in the count room upon completion of the count. However, PPC does not maintain an accounting box in the count room and respectfully requests a variance from this provision. PPC procedure is for the completed form to be delivered directly to the Revenue Audit department upon completion of the count. Response: 205 CMR 138(7) actually states, "Whenever currency, a gaming voucher or a coupon is found inside a bill changer but outside of the slot cash storage box ("unsecured drop") during the collection of slot cash storage boxes, a count team member and a member of the casino security department shall complete and sign a form which includes the asset number in which the unsecured drop was found, the date the unsecured drop was found, and the total value of the unsecured drop. The unsecured drop and the original form shall be transported to the count room and counted and recorded with the contents removed from the corresponding slot cash storage box. The duplicate of the form shall be placed in a locked accounting box. Upon completion of the count, the original form shall be placed in a locked accounting box located in the count room. The accounting department will retrieve the original form and reconcile it to the duplicate." Provided that in the proposed procedure the locked box in the count room is replaced with direct delivery of the original form by a member of the Security Department to the Revenue Audit Department and is reconciled to the duplicate of the form dropped into the accounting lock box then the proposal is likely to achieve the same outcome as if the provision contained in 205 CMR 138.00 were incorporated. This process needs to be consistent with 205 CMR 138 (8). This variance is granted and shall be identified in the written approval issued in accordance with 205 CMR 138.02(2).

3

205 CMR 138.48(12): PPC: This section requires that a count room supervisor complete Department of Treasury Counterfeit Note Report and place the container and report on the banking table. PPC requests a variance that would permit the Security Department supervisor personnel (supervisor or above) to complete the Department of Treasury form and surrender the note or coin to the office of the on-site Commission agent, IEB, or local law enforcement. Response: The proposal that permits the Security Department supervisor personnel (supervisor or above) to complete the Department of Treasury form; provided, the supervisor maintains control of and surrenders the note or coin according to procedures prescribed by the Secret Service, is at least equivalent to the relevant provisions contained in 205 CMR 138.48(12). It is the responsibility of PPC to confirm the procedures with the Secret Service. The proposal, with the noted modification, is likely to achieve the same outcome as if the provision contained in 205 CMR 138.00 were incorporated. This variance, as modified, is granted and shall be identified in the written approval issued in accordance with 205 CMR 138.02(2) 205 CMR 138.49: PPC: This section requires that a gaming accounting supervisor and/or member perform the function of the bill validator drop at kiosks. PPC requests a variance that would allow a cage supervisor and/or cage employee to perform this function. Response: This proposal would allow a cage supervisor and/or cage employee to drop the Gaming Voucher Redemption Machines (kiosks). The proposal is likely to achieve the same outcome as if the provision contained in 205 CMR 138.00 were incorporated. This variance is granted and shall be identified in the written approval issued in accordance with 205 CMR 138.02(2)

Attachment: PPC variance request

4

To:

Ralph Sacramone, Executive Director, Massachusetts Alcoholic Beverages Control Commission

From: Paul Connelly, Director, Division of Licensing, Massachusetts Gaming Commission Re:

Gaming Beverage License: Plainville Gaming and Redevelopment, LLC

Date:

June 16, 2015

On 6/11/2015, pursuant to M.G.L. c. 23K § 26 and 205 CMR 136.00, the Massachusetts Gaming Commission granted gaming beverage license MGCGBL1 to Plainville Gaming and Redevelopment, LLC (d.b.a. “Plainridge Park Casino”).

MASSACHUSETTS GAMING COMMISSION _____________________________________________________________ MEMORANDUM To: Chairman Crosby and Commissioners Cameron, McHugh, Stebbins and Zuniga From: Derek Lennon and Jeremy Howland CC: Public Meeting Packet 6/18/2015 Date: 6/18/2015 Re: Temporary Tax Reporting Process ________________________________________________________________________ 205 CMR 140.00 implements M.G.L. c.23K, §55, which establishes the taxable amount of revenue the Commonwealth is to receive on a daily basis. A category 2 licensee is required to pay a daily 40% tax on gross gaming revenues (GGR), as well as a 9% assessment on gross gaming revenues to the race horse development. Gross gaming revenue is calculated as the amount gambled, less the amount paid to patrons less promotional play. The Massachusetts Gaming Commission has contracted with a private vendor to establish a central monitoring system. The central monitoring system will provide an independent reading of slot machine meters to calculate the estimated amount of tax liability for each gaming day. MGC will not be able to implement the central monitoring system by June 24th. Pursuant to 205 CMR 140.02 paragraph (3) and (4): (3) Gaming licensees shall estimate slot machine drop provided that such estimates are calculated through a system of reading and recording slot machine meters, which methodology has been submitted by the gaming licensee and approved by the commission. Gaming licensees shall submit to the commission a daily slot machine drop estimate, calculated in accordance with such approved methodology, with each daily required tax deposit. (4) In the absence of use of a central monitoring system by the commission, a gaming licensee may use the estimated slot machine drop outlined in 205 CMR 140.03(3) Plainridge Park Casino (PPC) has provided MGC revenue staff with a sample tax audit package and accompanying supporting documentation that is used in another jurisdiction. MGC staff has been trained by PPC on Bally’s ACSC version 11.5 accounting system for revenue audit and verification processes. Based on the sample package, as well as the training provided by PPC MGC has been able to develop an interim daily revenue report package for usage in developing a daily tax bill. On a weekly basis MGC revenue staff will review a combination of targeted and random assets and adjustments

transactions based on the reports submitted to MGC. This process will be used until the central monitoring system is implemented. Because there has been no live play of machines and there has not been an actual drop and reconciliation on the floor I can only make a recommendation based on the controls I have been presented. The processes, procedures, reports and trainings that have been explained and demonstrated to me allow me to recommend the Commission approve the process for estimated slot machine drop for tax reporting. If there are any substantial problems witnessed on June 23, 2015 after the first test day of live play, I will come back to the Commission with a revised procedure prior to the Commission issuing an operations certificate. The process for review and remittance of daily taxes will be as follows: 1. PPC performs its daily revenue audit for previous day activity (estimated completion late afternoon early evening) 2. PPC sends tax package to MGC. 3. MGC reviews tax package and prepares invoice to send to PPC. 4. PPC processes payment same day via electronic payment site established by MGC. This process is estimated to take 48 hours. We could require the payment to be made the same day PPC completes its tax audit, however, this would require the MGC to not review the package prior to a payment being issued and the invoice to be generated by PPC rather than MGC based on a submission from PPC. Below is an example of what an invoice would look like: Net Accrued Daily Play Meters: Net Estimated Daily Payouts: Non-Negotiable Promos:

Plus (+) Minus (-) Minus (-)

$_________________ $_________________ $_________________

Gross Gaming Revenue: Category 2 Tax Rate: Total Tax Due:

$_________________ 40% $ (GGR*40%)

Gross Gaming Revenue: Racehorse Development Fund Assessment: Total Assessment Due:

$_________________ 9% $ (GGR*9%)

MASSACHUSETTS GAMING COMMISSION _____________________________________________________________ MEMORANDUM To: Chairman Crosby and Commissioners Cameron, McHugh, Stebbins and Zuniga From: Derek Lennon and Jeremy Howland CC: Public Meeting Packet 6/18/2015 Date: 6/18/2015 Re: Lottery Agreement ________________________________________________________________________ § 15 and 18 of C. 23K states: Section 15. No applicant shall be eligible to receive a gaming license unless the applicant meets the following criteria and clearly states as part of an application that the applicant shall: (1) agree to be a licensed state lottery sales agent under chapter 10 to sell or operate the lottery, multi-jurisdictional and keno games; demonstrate that the lottery and keno games shall be readily accessible to the guests of the gaming establishment and agree that, as a condition of its license to operate a gaming establishment, it will not create, promote, operate or sell games that are similar to or in direct competition, as determined by the commission, with games offered by the state lottery commission, including the lottery instant games or its lotto style games such as keno or its multi-jurisdictional games;… (6) demonstrate to the commission how the applicant proposes to address lottery mitigation… Section 18. In determining whether an applicant shall receive a gaming license, the commission shall evaluate and issue a statement of findings of how each applicant proposes to advance the following objectives: (1) protecting the lottery from any adverse impacts due to expanded gaming including, but not limited to, developing cross-marketing strategies with the lottery and increasing ticket sales to out-of-state residents;

When the Massachusetts Gaming Commission executed the “Determination of Issuance of a License to Operate a Category 2 Gaming Establishment” (License) on February 28, 2014 to Plainridge Park Casino (PPC), it was determined the aforementioned criteria had been met. Section V condition 6(d) of the License required compliance with the terms and conditions of lottery agreements. On June 16, 2015 PPC and the Massachusetts State Lottery entered into a Lottery Sales Agent Agreement (Agreement). Below are a few of the pertinent sections to demonstrate that the Agreement incorporates the requirements of C. 23K as well as the License condition to maintain a category 2 license. Section Seven “Additional Obligations of the Agent” The Agent agrees: 7.1 To (i) prominently display point-of-sale and other promotional material supplied by the Lottery at the designated location, and (ii) engage in other mutually agreed marketing and crosspromotional campaigns to promote the sale of Lottery Tickets and all other Lottery products, including, but not limited to, such initiatives as more precisely described in Schedule C;… 7.11 To be bound to any additional terms and conditions that the Agent agrees to in Schedule D, attached hereto and which is expressly incorporated herein and made a part hereof, to further mitigate the impact of expanded gaming on the Lottery and its mission. 7.12 To supply in Schedule D, attached hereto and which is expressly incorporated herein and made a part hereof, any additional information about the Agent that further mitigates the impact of expanded gaming o the Lottery and its mission. 7.13 To not create, promote, operate or sell lottery style games that are similar to or in direct competition with games offered by the Lottery, including the Lottery’s Instant Games, draw games, Pull-Tabs, or its other lotto style games, including without limitation, Keno or Jackpot Poker or its multi-jurisdictional games. Notwithstanding anything else in this Agreement, Lottery acknowledges Agent’s intent is to operate a Category 2 gaming facility, and therefore this Agreement shall not be interpreted to restrict Agent from promoting and operating any gambling machines, games, contests, pari-mutuels, sweepstakes, promotions or other events that are allowed by Category 2 gaming facilities under Massachusetts law (including but not limited to authorized ‘lucky draw’ contests and similar promotional events as are commonplace in the casino industry), except that so long as the Lottery offers a Keno product, the Lottery Keno product will be the only keno offering within both the racing and casino facilities at Plainridge Park Casino.

7.15 To strategically place and make readily accessible, in locations intended to reasonably maximize patron utilization and revenue to the Commonwealth, Lottery Tickets, other Lottery products and Lottery Equipment, including, without limitation, PAT(s) and Lottery Equipment required to cash Lottery Tickets, throughout the Agent’s place of business where there is high visibility and high volume patron traffic… 7.16 To strategically offer, in a location intended to reasonably maximize patron utilization and revenue to the Commonwealth, “Keno,” Jackpot Poker,” and other “Keno-style” games (the “Keno Games”) in bars, pouring establishments and other locations throughout the Agent’s place of business and reasonably promote such Keno Games throughout the Agent’s place of business and at locations where Keno Games are offered… 7.17 To mitigate adverse impacts to the Lottery due to expanded gaming by working regularly and collaboratively with the Lottery in the development and implementation of cross-promotion campaigns and other marketing and promotional strategies and programs, including but not limited to, increasing ticket sales to out-of-state residents all as mutually agreed. For illustrative purposes these activities may include: (i) Through the promotion of Lottery Products on-site at the Agent’s place of business, including the prominent posting of all Lottery-issued POS promotional materials and signage (provided no competing casino name or logo shall appear on any promotional materials or signage that is posted on Agent’s premises); (ii) In conjunction with the Agent’s promotions to on-site out-of-state patrons: (iii) By permitting the Lottery to advertise in the Agent’s closed network system using Lottery produced ads; and As set forth in Schedule C attached hereto and made a part hereof subject to the mutual agreement of the parties. 7.18 To not engage in any advertising, marketing, and/or promotional initiatives that undercut or otherwise negatively impact the Lottery or other Lottery licensed sales agents. Notwithstanding anything else in this Agreement, Lottery acknowledges Agent’s intent is to operate a Category 2 gaming facility and nothing herein shall limit Agent’s advertising, marketing and promotion of its own gaming offerings… Schedules B through D attached and incorporated by reference into the Agreement identify specific aspects of the efforts utilized to promote the Lottery and mitigate the potential impacts of expanded gaming on the Lottery. Below is a brief description of each: • Schedule B identifies the location and approximate amount of Lottery equipment that will be located throughout PPC including at least 4 additional PATs, on-line ticket and instant ticket sales at the gift shop and Keno offerings in at least 2 restaurant bars.

•

•

Schedule C identifies the methods and describes the marketing and cross-promotional campaigns PPC has agreed to undertake to promote the Lottery, Keno, and sale of Lottery Tickets. Schedule D identifies the other jurisdictions in which Penn National Gaming operates casinos where the state lottery serves as the regulatory body for both gaming and lottery. It speaks to Penn’s collaborative history as helping to drive lottery sales in those jurisdictions.

By evidence of a fully executed Lottery Sales Agent Agreement, and incorporation of the requirements of Chapter 23K into the Agreement, as of 6/18/2015, PPC is still in compliance with Section V condition 6(d) of their Category 2 License.

MEMORANDUM

To:

Stephen Crosby, Chair Gayle Cameron, Commissioner Enrique Zuniga, Commissioner James F. McHugh, Commissioner Bruce Stebbins, Commissioner

From:

Catherine Blue

Date:

June 18, 2015

Re:

Delegation of Authority to Commissioner Cameron to Issue Temporary Certificate of Operation ______________________________________________________________________________ REQUEST: The the Commission delegate to Commission Cameron the authority to issue a temporary certificate of operation to the category 2 gaming licensee, Plainridge Park Casino after observation of the test period and review of the results of the test period.

DISCUSSION: The Commission may not approve a Category 2 gaming establishment to open for business, begin gaming operations or operate a slot machine until the Commission has issued a certificate of operation pursuant to 205 CMR 151. 205 CMR 151 requires that the category 2 gaming licensee demonstrate compliance with the requirements of G.L. c. 23K, 205 CMR, and the conditions imposed by the category 2 gaming license issued by the Commission.

The category 2 gaming licensee will come before the Commission on June 18 to demonstrate compliance with many of the requirements of c. 23K, 205 CMR and the conditions imposed by the category 2 license. However, compliance with certain requirements will not be established until the category 2 licensee completes an evaluation and test period as described in 205 CMR 151.03. The test period is scheduled for June 22, 2015 and the results will be

reviewed on June 23, 2015. The category 2 gaming establishment is scheduled to open to the general public on June 24, 2015, subject to the receipt of an operations certificate from the Commission.

I am requesting that the Commission delegate to Commissioner Cameron the authority to observe and review the results of the June 22, 2015 test period, and, in Commissioner Cameron’s discretion, to determine that based upon her review of the test results, a temporary certificate of operation be issued to the category 2 gaming licensee. I am further requesting that Commissioner Cameron be delegated authority to sign a temporary certificate of operation for the period beginning at 12:01 am June 24 and continuing through the earlier of 12:01am June 26 or the approval of a final certificate of operation by the full Commission. Commissioner Cameron will report on the results of the test period and the category 2 licensee’s compliance with the requirements of 205 CMR 151 at the Commission’s public meeting on June 25, 2015.

MASSACHUSETTS GAMING COMMISSION PURSUANT TO THE POWER AND AUTHORITY GRANTED TO IT BY CHAPTER 23K OF THE MASSACHUSETTS GENERAL LAWS, HEREBY PRESENTS THIS OPERATION CERTIFICATE TO

Plainville Gaming and Redevelopment, LLC ON THE PREMISES OF THE CATEGORY 2 GAMING ESTABLISHMENT LOCATED IN PLAINVILLE, MASSACHUSETTS WITH

1250 SLOT MACHINES / 0 TABLE GAMES / ____ GAMING POSITIONS. THIS CERTIFICATE IS SUBJECT TO THE LICENSEE’S COMPLAINCE WITH CHAPTER 23K OF THE GENERAL LAWS, THE REGULATIONS OF THE MASSACHUSETTS GAMING COMMISSION PROMULGATED THEREUNDER, AND ALL OTHER APPLICABLE LEGAL REQUIREMENTS.

EFFECTIVE JUNE 24, 2015

Commissioner Commissioner

Chairman

Commissioner Commissioner

MASSACHUSETTS GAMING COMMISSION PURSUANT TO THE POWER AND AUTHORITY GRANTED TO IT BY CHAPTER 23K OF THE MASSACHUSETTS GENERAL LAWS, HEREBY PRESENTS THIS OPERATION CERTIFICATE TO

Plainville Gaming and Redevelopment, LLC ON THE PREMISES OF THE CATEGORY 2 GAMING ESTABLISHMENT LOCATED IN PLAINVILLE, MASSACHUSETTS WITH

1250 SLOT MACHINES / 0 TABLE GAMES / ____ GAMING POSITIONS. THIS CERTIFICATE IS SUBJECT TO THE LICENSEE’S COMPLAINCE WITH CHAPTER 23K OF THE GENERAL LAWS, THE REGULATIONS OF THE MASSACHUSETTS GAMING COMMISSION PROMULGATED THEREUNDER, AND ALL OTHER APPLICABLE LEGAL REQUIREMENTS.

EFFECTIVE JUNE 24, 2015 THROUGH JUNE 25, 2015

Gayle Cameron, Commissioner