Rule%20Summary%20-%20Eugene%20Freer%20pay%20out-PT

Rule Petition Amend WAC 230-15-320 (4) April 2026 – Initiate Rule Making Tab X: April 2026 Commission Meeting Agenda. Statutory Authority 9.46.070 Who Proposed the Rule Change? Eugene Freer – TIL Gaming Background Petitioner Eugene Freer would like to amend WAC 230-15-320 (4) to increase the prize threshold from $3,000 to $5,000 for when surveillance rooms are required to use pan-tilt-zoom cameras (PTZ) to verify winning hands, amounts of the wager, amounts of the pay out and players who have won the prize. Currently, house-banked card rooms are required to have a closed-circuit television (CCTV) system with fixed cameras over each gambling table to view gambling activities and areas to include, but not limited to, cards, wagers, and the chip tray. These fixed cameras over each table provide an overview shot of the entire table and are not zoomed in on individual player faces, cards, wagers, and/or payouts. These fixed camera views must be retained for seven days. The petitioner believes the amendments are necessary because higher wager limits of $400 have increased the frequency of prize payouts over $3,000. The increased frequency of prize payouts at the $3,000 level has led to surveillance observers dedicating more of their time capturing the required information in WAC 230-15-320 and less time with other duties, such as overall monitoring and oversight of gambling operations. The increased frequency of prize payouts at the $3,000 level has also required the retaining of more surveillance video footage involving PTZ’s which take up more hard drive space on DVR’s. Attachments: • Petition • WAC 230-15-320 Policy Considerations WAC 230-15-320 (4) requires camera coverage for certain prizes won, specifically prizes over $3,000 which often include jackpot prizes. Note: Jackpot prizes involve player funds which are more strictly controlled in rules. A PTZ camera can zoom in close on gambling tables to more definitively show exact wagers made, card values and suits, and specific player faces at gambling tables. This is important information to capture for dispute resolution involving large prizes. For reference, below is the history of the rule requiring house-banked card rooms to use PTZ cameras to verify winning hands, amounts of the wager, amounts of the pay out and players who have won the prize: Note: in 2023, the commission approved an increase to the wagering limits from $300 to $400. The prize minimum triggering the surveillance observer to use the PTZ camera stayed at $3,000. Regulatory Considerations Commission staff did not identify any regulatory concerns. • Staff feel that an increase in the prize threshold to $5,000 will not diminish the ability for dispute resolution. Technology related to surveillance equipment has advanced significantly since 2001 when the rule was first developed. Card rooms now utilize digital surveillance systems with high-definition cameras to view gambling tables. Other WAC rules require at a minimum one fixed camera over each gambling table. In most cases, these fixed high-definition cameras can usually capture most of the required information required in WAC 230-15-320. • Staff reviewed the Commission’s database for the last six years for any complaints regarding large jackpots/payouts in combination with any violations of WAC 230-15-320. Staff did not identify any complaints concerning large payouts nor a situation where the required PTZ was needed for dispute resolution. The petitioner’s request would still require the PTZ in addition to the fixed cameras. • Staff do not anticipate additional time or staffing for inspections to test for compliance with a higher prize threshold of $5,000. Staff Recommendation Under the requirements of the Administrative Procedure Act, the Commission must act on a petition within 60 days of receiving it. Your options are: 1) Initiate rule-making proceedings by filing the rule as proposed for further discussion; or 2) Deny the petition in writing, a) stating the reasons for denial and specifically address the concerns stated in the petition, or b) where appropriate, indicate alternative means by which the agency will address the concerns raised in the petition.