The COINS Architecture for Regulatory Independence

Gaming regulators must ensure that the gaming industry within their jurisdiction complies with all legislative requirements including the timely and accurate payment of revenue taxes. Very large sums of public money are involved. The process is always one of high visibility and interest to the public. Regulatory responsibilities must be executed in a manner that not only adheres to the highest ethical standards, but that also must carefully avoid even the slightest appearance of impropriety.

There are a number of ways that regulatory and supporting agencies obtain data on which to base their revenue tax calculations. They may use periodic reports generated by various information systems (e.g., slot managment systems) at each casino site and subsequently provided to the regulators. The information system that holds the "raw" data belongs to the casino, and they effectively "own" the information. This wide separation from the "raw" data and the limited formats used for "standard" reports places limits on the ability of the regulator to efficiently perform audits or forensic investigations. It also makes the regulator highly dependent on the casinos for all information, and can result in delays in obtaining "special request" information and the introduction of errors (especially if re-entry of data into a Regulator's information system is required).

Sometimes a monolithic "video poker"-style central information system is used, where a single vendor controls the flow of information all of the way from the EGD (slot machine, video poker machine, etc.) or other data source (table games, count rooms) to the regulator end user. This can place more information more quickly in the hands of the regulators, but the system vendor still owns the system (or at a minimum, owns critical components of it, components that are often proprietary), and thus effectively "owns" and controls the data that passes through it. And those "video poker"-style system vendors are also often vendors of gaming products and services to the casinos being regulated. Aside from the perceptions of conflicts that could arise from "the fox watching the henhouse," use of these type systems effectively forces competing casino products and service vendors out of the picture, or requires them to make extensive, expensive, or cumbersome modifications to their own systems in order for them to support their competitor's products!

And of course, regulators can implement their own independent, centralized and open system that collects raw or minimally-processed data from each casino by linking directly (through a simple interface) to each casino's information system(s) (e.g., slot accounting/management system) of the casino's choice. The regulator takes posession of, or "owns" the detailed data that they need almost as soon as it is generated (near-real-time) and has immediate and efficient access to it as needed to support their mission. They can improve the way they process and use the collected data as they see fit. A fairer, more competitive market opportunity exists for different vendors of casino systems and services, and casino owners have a greater selection of who they will obtain their products and services from. And of course, all of these things can help contribute to a positive public perception of the revenue reporting and auditing process.

The COINS product (Casino Operations Information and Notification System) from Gaming Regulation Technologies implements the architecture discussed in the above paragraph. It was designed by regulators for regulators to provide independent, secure, real-time Electronic Gaming Device (EGD) data collection from multiple gaming locations regardless of the Slot Accounting/Management System used by a particular casino.