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The Case for Electronic Filing of Gaming License Applications

Barth F. Aaron, Esq.

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Remember the last time you completed a gaming license application? Answer the questions, print, review, and repeat. Sign where appropriate. Then address an envelope, find the right postage or overnight delivery fee and take the packet to the post office or Fed Ex or UPS and waiting to confirm that the agency had actually received your application.

There has to be a better way. Retailers do it thousands of times each day. Almost every employer accepts job applications every day this way. Other government agencies accept applications every day by electronic filing. Many courts even require that documents be filed electronically. And now, even the Nevada Gaming Control Board has broken the ice and accepts Gaming Employee Registration applications, renewals and changes online, electronically. So why not business entity, qualifier or key employee license applications? There is no good reason.

The gaming licensing process in its modern form started in Nevada and then New Jersey in the 1970’s. Other gaming regulators adopted the application forms, to one degree or another, and the licensing process from these founding agencies and now in the 21st century the process seems embedded in 20th century technology. And that is the problem. The world has changed, technology has changed and people are now accustomed to doing everything online, from Kindle to downloading new apps.

It is time for gaming regulators to step into the 21st century. The Nevada Gaming Control Board has taken a bold step by allowing Gaming Employee Registration applications to be filed online. The benefits are clear. The application is filed immediately. The employing HR department has access to reports showing pending, active and terminated employee registrations. HR also has access to upcoming renewal deadlines. And most convenient to the employee, the registration can be quickly and easily transferred to a new employer without the old process of refiling an application with each job change.

Similar benefits can be seen with entity, qualifier and key employee application electronic filings. The information can be entered and checked on the computer. Unlike a paper application, the electronic system will verify that all questions are answered – remember when you forgot to enter the credit card security code on your last online purchase, you were stopped in your tracks and told to enter the missing information before you could move on. The application goes directly to the gaming agency and is immediately available for its processing.

Security is the major concern of both applicants and regulators. After all, key personal information from some important people is contained in gaming license applications. But the internet can be even more secure than paper, as will be discussed in future white papers. As society has migrated to conducting its business electronically, so have criminals, but it was not long ago when identity theft was conducted by taking mail from someone’s mail box. It can still be a viable option. We just hear about electronic thefts because they are bigger or more widespread. But the crime is not new. And there are systems to combat hacking. Most of us have used that secure “https” web address identity to complete financial transactions, from online banking to payment for online purchases. Secure Socket Layer communication provides one level of security for online transmission of sensitive information. There are others.

Security of online transmissions is no longer a concern. Paperless transactions are the now, not just the future. The American Gaming Association has been pursuing an electronic gaming application project with support from the Association of Gaming Equipment Manufacturers. The industry wants e-filing. Gaming regulators need to take the next step and accept electronic filing of applications.