Here’s the Ticket
The hottest current legal topic is the proposed new regulations drafted by the Maryland State Lottery and Gaming Agency (MLGCA) for all amusement games in the state of Maryland. These regulations were drafted despite significant opposition input from MAMOA. Some of the key regulations would require every game operator to register all of their skill-based redemption and merchandiser games operated in Maryland and receive a tag with MLGCA, report every time a machine is to be moved and receive a new tag, has a $30 maximum prize limit, and by unintended consequences may even prohibit any one under age 21 from playing redemption-related amusement games, as amusement games would also now fall under federal gaming laws. And of course in the near future there will be fees for registration and tags as well as submitting games for Agency approval.
The next phase is a public hearing on the proposed regulations that takes place on June 27. Larry Bershtein, MAMOA President and MAMOA have put a lot of time and effort into going through all of the issues that these regulations present and why they are broad and over-reaching and are not what the legislators intended when they ambiguously placed the regulation of amusement games under the Lottery and Gaming Agency.
What This Could Mean
MAMOA has done an excellent job of submitting a well thought out legal and logical response. I was very impressed. The comments start out: “The regulations for Electronic Gaming Devices should not be enacted as written. The regulations are confusing, in places internally contradictory, unduly burdensome to an already troubled industry, and not at all in line with the legislative intent of the enabling legislation.”
MLGCA has previously heard many of the amusement industry objections and they still went ahead and even expanded the regulations. It would appear that they are on a mission to put together a huge Agency that will require a huge budget to hire the manpower necessary to cover the many street and FEC locations. The money will need to come from associated fees paid for by game operators who simply cannot afford it. We are all hopeful that common sense will prevail and are glad to see that MAMOA is doing its best on the industry’s behalf. We are all awaiting the outcome of the hearing.
I hope that every amusement game operator, FEC, amusement park and arcade owner will take the time read the response and understand why the draft regulations as they are proposed are a disaster waiting to happen.
To read the full MAMOA Comments on Proposed Regulations Title 36, Subtitles 06.02 and 06.02, click here.
