Item Part 547 Minimum Technical Standard CNOGC Alternate Standard Justification

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25 C.F.R. § 547.2

Class II gaming system. All components, whether or 

not technologic aids in electronic, computer, 

mechanical, or other technologic form, that function 

together to aid the play of one or more Class II games, 

including accounting functions mandated by these 

regulations.

Player interface . Any component(s) of a Class II 

gaming system, including an electronic or technologic 

aid (not limited to terminals, player stations, 

handhelds, fixed units, etc.), that directly enables 

player interaction in a Class II game.

*547.2

Class II Gaming System. All components, whether or 

not technologic aids in electronic, computer, 

mechanical, or other technologic form, such as a Class 

II Mobile Gaming System, that function together to aid 

the play of one or more Class II games, including 

accounting functions mandated by these regulations.

Player Interface . Any component(s) of a Class II 

gaming system, including an electronic or technologic 

aid (not limited to terminals, player stations, 

handhelds such as a Class II Mobile Device, fixed units, 

etc.), that directly enables player interaction in a Class 

II game.

Integrity stays the same. Class II mobile gaming 

devices/systems are added to the list of items included 

in the Class II gaming system and Player Interface 

definitions to further define them.

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25 C.F.R. § 547.4(b)

Approved gaming equipment and software only. All 

gaming equipment and software used with Class II 

gaming systems must be identical in all respects to a 

prototype reviewed and tested by a testing laboratory 

and approved for use by the TGRA pursuant to 

§547.5(a) and (b).

*547.4(b)

Approved gaming equipment and software only. All 

gaming equipment, except for any Class II Mobile 

Device, and software used with Class II gaming 

systems must be identical in all respects to a prototype 

reviewed and tested by a testing laboratory and 

approved for use by the TGRA pursuant to §547.5(a) 

and (b). Any Class II Mobile Device used with a Class II 

Mobile Gaming System must comply with the 

applicable requirements for such device set by the 

Federal Communications Commission. The operation 

shall ensure that any Class II Mobile Gaming occurs 

only on a Class II Mobile Device utilizing game 

software that has been reviewed and approved for use 

by the TGRA.

With a Class II Mobile Gaming system, it would be 

difficult for an Independent Testing Laboratory (ITL) to 

test player owned devices such as cell phones and 

tablets. However, having the devices be FCC accredited 

(or similar) along with TGRA approved game software 

running on the device, we retain security and integrity 

of the gaming system. The requirement for the game 

software to be identical to a prototype tested by an ITL 

will remain the same.

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25 C.F.R. § 547.5(b)(l)(iv)

The testing laboratory's written report confirms that 

the operation of a player interface prototype has been 

certified that it will not be compromised or affected 

by electrostatic discharge, liquid spills, 

electromagnetic interference, or any other tests 

required by the TGRA;

*547.5(b)(l)(iv)

The testing laboratory's written report confirms that 

the operation of a player interface prototype, other 

than a Class II Mobile Device, has been certified that it 

will not be compromised or affected by electrostatic 

discharge, liquid spills, electromagnetic interference, 

radio frequency interference, or any other tests 

required by the TGRA. Any Class II Mobile Device must 

comply with the applicable requirements for such 

device set by the Federal Communications 

Commission;

Again, an ITL cannot test all player owned devices. We 

rely on the fact that these player owned devices have 

been vetted by an accredited organization (FCC or 

similar) to test for this along with other requirements 

being met before being offered to the public.

CNOGC Alternate Standards to

25 C.F.R. Part 547
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25 C.F.R. § 547.7(d)

Player interface. The player interface must exhibit a 

serial number and date of

manufacture and include a method or means to:

(1)Display information to a player; and

(2)Allow the player to interact with the Class II gaming 

system.

*547.7(d)

Player Interface .

(1)Any player interface, except for a

Class II Mobile Device, must exhibit a serial number 

and date of manufacture;

(2)At the time of Class II Mobile Gaming software 

installation and registration, a Class II Mobile Gaming 

Player Account shall be issued a unique identification 

number that shall be recorded by the operation. The 

Class II Mobile Device identification number shall not 

be transferable to a different Class II Mobile Device;

(3)Any player interface must include a method to: 

(i)Display information to a player; and 

(ii)Allow the player to interact with the Class II gaming 

system.

(4)Any player interface is restricted to one active log in 

per session.

While most technological devices have a serial 

number, this is something that would not be able to be 

recorded for our records. However, we will require the 

system to issue a unique identifier to that player 

owned account to supplement the physical serial 

number. The software on the player owned device will 

be required to display information along with allowing 

the player to interact with the system. Furthermore, 

we will require the system to only allow the player 

interface to be restricted to one active log in per 

session.

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25 C.F.R. § 547.16(b)

Disclaimers. The Player Interface must continually 

display:

(1)"Malfunctions void all prizes and plays" or 

equivalent; and

(2)"Actual Prizes Determined by Bingo (or other 

applicable Class II game) Play. Other Displays for 

Entertainment Only" or equivalent.

*547.16(b)

Disclaimers.

(1)Except for Class II Mobile Devices, the Player 

Interface must continually display:

(i)"Malfunctions void all prizes and plays" or 

equivalent; and

(ii)"Actual Prizes Determined by Bingo (or applicable 

Class II game) Play. Other Displays for

Entertainment Only" or equivalent.

(2)For Class II Mobile Devices, the information

in subsection (b)(1)(i)-(ii), must be displayed prior to 

initiating a session.

The information required to be presented to the player 

will be available at the beginning of the Player session. 

They will have to acknowledge this information before 

being allowed to play on their device.

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25 C.F.R. § 547.16(c)

Odds notification. If the odds of winning any 

advertised top prize exceeds 100 million to one, the 

Player Interface must display: "Odds of winning the 

advertised top prize exceeds 100 million to one" or 

equivalent.

*547.16(c)

Odds Notification.

(1)If the odds of winning any advertised top prize 

exceeds 100 million to one, the Player Interface 

(excluding any Class II Mobile Device) must display: 

"Odds of winning the advertised top prize exceeds 100 

million to one" or equivalent.

(2)For Class II Mobile Devices, the information 

required by subsection (c)(l) must be displayed to the 

player prior to the start of game play.

The information required in this section will be 

included at the beginning of play and they will 

acknowledge this before their session will begin.