21 March 2014

46 Waring Taylor St, PO Box 805

Wellington 6140, New Zealand

Phone +64 4 495 7200

Fax +64 4 495 7222

Website www.dia.govt.nz

Applications to Make and Amend Game Rules for Casino Table Games

The Secretary for Internal Affairs (the Secretary), subject to appropriate consultation, is able to make, amend or revoke rules under section 367 of the Gambling Act 2003 (the Act).

The Department of Internal Affairs (the Department) has received separate applications from casino operators to amend and/or make rules for casino table games. Explanations of the applications are provided within this document, and full versions of the proposed new game rules are attached and available on the Department’s website at www.dia.govt.nz.

The applications include amendments of a technical nature, amendments to introduce new side-wagers or variations to existing games, and applications for table games not currently played in New Zealand casinos. This consultation document references each application in turn.

If amendments to the rules were to be made, the Secretary would also incorporate the changes, where necessary, into the Gambling Act (Casino Gambling Equipment) Minimum Standard pursuant to section 327 of the Act.

The Department invites you to review and submit on the proposals. Details of how to make your submission are at the end of this paper.

Thank you for your attention in this matter.

Yours sincerely

Heather McShane

Manager, Operational Policy

Regulatory & Compliance Operations

New Games

Game rule applications have been received for the following new casino table games.

Dragon 21

This proposed game combines elements from Blackjack and Baccarat. The game provides for two Blackjack hands (titled Tiger and Dragon). Like Baccarat, players have the option to wager on either hand or wager on a tie.

The hand which achieves a point count closest to 21 wins.

The proposed game provides for side wagering options similar to Perfect Pairs in the rules of Baccarat.

The full rules for this proposed game are attached to this paper as Appendix A.

Lunar Poker

This proposed game is a variation of poker in which players try to make a poker hand which beats the dealer’s hand. The game provides players with the option of obtaining additional cards, similar to standard draw poker, in pursuit of the best hand.

The game also provides for an additional wagering option which provides for increased payouts depending on the hand achieved.

The full rules for this proposed game are attached to this paper as Appendix B.

Big Raise Stud Poker

This proposed game is a variation of poker, similar to Three Card Poker, but using two community cards. The object is to make the best poker hand using the player’s three cards and the shared community cards.

The game provides for one side wagering option which is decided on the player’s first three cards.

The full rules for this proposed game are attached to this paper as Appendix C.

Electronic Tai Sai

Electronic Tai Sai is a game whereby participants wager on the outcome of a manual Tai Sai game through the use of player terminals. Tai Sai has been an approved table game since 1998.

The nature of play is the same as Electronic Roulette (a game approved for operation in New Zealand casinos since 2003) and Electronic Money Wheel (a game approved in 2008 but never deployed in New Zealand casinos). Players establish credit, wager and receive results through electronic terminals while the game itself is managed by a dealer who inputs the results of the dice.

The electronic terminals provide players with all information necessary to play the game including a help function and a display of the time. The terminal also allows players to view the previous winning numbers for up to 10 games.

Electronic Tai Sai is a game that has the potential to operate at a faster pace than its fully manual counterpart as players interact with the game through terminals rather than manually placing wagers and the duties of a dealer are mostly automated.

The applicant has proposed a minimum 30 second wagering period be stipulated in the rules.

Tai Sai has to date been a minor game in casino game mixes.

The full rules for this proposed game are attached to this paper as Appendix D.

New Side Wagers and Game Variations

Blackjack

House Money – side wager (proposed new rule 15D)

A player would have the option of placing this side wager at the time of placement of his or her initial wager.

The outcome of this wager is dependent on the first two cards dealt to the player. The player will win if these first two cards are Ace-King of the same suit, a pair, or in a sequence.

A player who wins a House Money wager has the option of either taking the payout or leaving the wager and payout (or part thereof) in the House Money betting area. If the player elects to leave the wager and payout in play, it becomes part of the original Blackjack wager.

The full text of proposed new rule 15D and the proposed new Appendix to the rules depicting the House Money table layout is attached in Appendix E.

Let it Ride – side wager (proposed new rule 15E)

This proposed wagering option is similar to the proposed House Money wagering option. A player would have the option of placing this side wager at the time of placement of his or her initial wager.

The outcome of this wager is dependent on the first two cards dealt to the player. The player would win if these first two cards are in sequence or of the same suit.

A player who wins a Let it Ride wager has the option of either taking the payout or leaving the wager and payout (or part thereof) in the Let it Ride betting area. If the player elects to leave the wager and payout in play, it becomes part of their original Blackjack wager.

The full text of proposed new rule 15E and the proposed new Appendix to the rules depicting the Let it Ride table layout are attached as Appendix E.

Lucky Match Wager – side wager (proposed new rule 15F)

This is a proposed side wager which a player may make at the time of placing his or her initial wager and before any cards are dealt.

A Lucky Match Wager would win if the first two cards dealt to the player have the same face value or if the first three cards dealt to the player are of the same suit with the same face value.

It is proposed that only one side wager out of ‘Perfect Pairs’, ‘Any Pairs’ or ‘Lucky Match Wager’ can be in use on any one Blackjack table at a time.

The full text of proposed new rule and the proposed new Appendix to the rules depicting the Lucky Match Wager is attached at Appendix E.

Free Bet Blackjack- new variation (proposed new rule 20)

This proposed variation of Blackjack offers a player a chance to:

a)	‘double down’ for free with a first two card total of 9, 10 or 11; or

b)	‘split’ for free when his or her first two cards are pairs of Aces, twos, threes, fours, fives, sixes, sevens, eights or nines.

This variation also allows players the option of making an additional side wager called ‘Push 22’. This wager wins when a dealer’s hand totals 22.

This version of Blackjack reduces a casino’s theoretical hold from the standard game of Blackjack.

The full text of proposed new rule 20 and the proposed new Appendix to the rules depicting the Free Bet Blackjack table layout are attached at Appendix E.

Baccarat

Any Pair’s Wager – side wager (proposed new rule 11C)

This proposed side wager offers players the option of placing an Any Pair’s wager before any cards are dealt in the round of play.

An Any Pair’s Wager would win when either:

a)	the wager has been placed on the Player’s Hand and the first two cards dealt to the Player’s Hand are a pair; or

b)	the wager has been placed on the Banker’s Hand and the first two cards dealt to the Banker’s Hand are a pair.

Winning wagers are paid at odds of either 11 to 1 or 10 to 1, depending on the pay scale in use by the casino (which must be displayed).

Any Pair’s Wagers are currently permitted under the Blackjack rules.

The full text of the proposed new rule 11C is attached at Appendix F.

Lucky Match Wager – side wager (proposed new rule 11D)

This proposed side wager (similar to the Lucky Match Wager proposed for Blackjack) would be made by a player at the time of placement of his or her initial wager and before any cards are dealt.

A Lucky Match Wager would win when:

a)	the wager has been placed on the Player’s Hand and the first two cards dealt to the Player’s Hand have the same face value (with differing odds depending upon suit) or the first three cards dealt to the Player’s Hand are of the same suit with the same face value; or

b)	the wager has been placed on the Banker’s Hand and the first two cards dealt to the Banker’s Hand have the same face value (with differing odds depending upon suit) or the first three cards dealt to the Banker’s Hand are of the same suit with the same face value.

It is proposed that only one side wager out of ‘Perfect Pairs’, ‘Any Pairs’ or ‘Lucky Match Wager’ can be in use on a Baccarat table at a time (new rule 11A.2 below).

The full text of the proposed new rule 11D is attached at Appendix F.

2 to 1 Baccarat – new variation (proposed new rule 13)

This is a proposed variation on Baccarat where the casino pays winning wagers on the Player’s Hand or Banker’s Hand at 2 to 1 (rather than 1 to 1) when the hand is won with a three card point count of 8 or 9.

The casino would also have the option of setting the payment of winning wagers on the Banker’s Hand to odds of 1 to 2 (rather than 1 to 1) where the Banker’s hand wins with a Point Count of 6. This choice of odds is currently available in regular Baccarat pursuant to rule 5.11.

The full text of the proposed new rule 13 is attached at Appendix F.

Ante Up Baccarat – new variation (proposed new rule 14)

This proposed variation of Baccarat would require players to place an ‘ante’ to participate in the game. The applicant states this enables casinos to offer lower entry games.

The ante increases the house edge in addition to the standard theoretical return associated with Baccarat. The rules state that the ante can represent no more than 12.5 per cent of the table minimum wager.

Ante Up Blackjack is a currently approved in the Blackjack rules.

The full text of the proposed new rule 14 is attached at Appendix F.

Introduction of alternative payout odds – Rule 5.10 (amended)

This proposed amendment would allow casinos the option of specifying alternate payout odds of 9 to 1 (rather than 8 to 1) for a winning Tie bet.

The proposed full text of rule 5.10 with changes tracked is attached at Appendix F.

Technical Amendments

Baccarat

Rule 6.6 (new) - use of pre-shuffled cards

This proposed new rule would allow cards that have been pre-checked, pre-shuffled and sealed by the card manufacturer to be introduced to a table without having to undergo any further chemmy shuffle or riffle shuffle process.

The full text of the proposed new rule 6.6 is attached at Appendix F.

Rule 7.7 (amended) – shuffle and cut of pre-shuffled cards

This proposed amendment would provide the casino operator with an alternative to the current requirement to “burn” cards from the shoe (discarding a set number of cards) when new decks are introduced to the table. The alternative is identical to that practice used in Blackjack under rule 8.1.

The proposed amendment to rule 7.7 is attached at Appendix F.

Rule 7.9 (amended and relocated to new rule 4.1A) - point value of cards

This proposed amendment to and relocation of rule 7.9 is to provide greater clarity to the point value qualifications associated with rule 4.1 and the need to burn cards under rule 7.7.

The proposed deletion of rule 7.9 and the full text of rule 4.1A is attached at Appendix F.

Rule 8.5 (amended) – removal of dealing restriction

This proposed amendment would remove the restriction of using one dealing style only during the course of Baccarat when the game is conducted using a card shoe or a non-continuous shuffler.

The proposed amendment to rule 8.5 is attached at Appendix F.

Rule 11A.2 (new) – clarification of use of side wagers

This proposed addition is to clarify that only one of Perfect Pairs, Any Pairs or Lucky Match Wagers can be in use at any one table. All three wagering options involve making pairs from the initial deal.

The proposed full text of the proposed new rule 11A.2 is attached at Appendix F.

Rule 11A.3 (amended) – clarification of where a player may place an Perfect Pairs Wager

This proposed amendment clarifies that players may place a Perfect Pairs wager on the Player’s Hand and the Banker’s Hand in one round of play. The applicant states that the original rule does not make it clear that a player can do this and, as currently drafted, creates confusion over whether a Perfect Paris wager is restricted to one hand only.

The proposed amendment to rule 11A.3 is attached as Appendix F.

Minor amendments around capitalisation of text

The applicant proposes a number of minor drafting changes to the rules to reflect that defined terms as set out in the interpretation section should be capitalised in the text of the rules. For example, Continuous Shuffle, Player’s Hand and Banker’s Hand rather than continuous shuffler, Player’s hand and Banker’s hand.

A copy of these changes is available on request.

Blackjack

Rule 3.6 (new) – option of using an electronic game results display

This proposed new rule would allow a casino operator to use an electronic game results display for recording and displaying the most recent game results.

The full text of the proposed new rule 3.6 is attached at Appendix E.

Rule 6.6 (new) - use of pre-shuffled cards

This proposed new rule would allow cards that have been pre-checked, pre-shuffled and sealed by the card manufacturer to be introduced on a table without having to undergo any further chemmy shuffle or riffle shuffle process.

The full text of the proposed new rule 6.6 is attached at Appendix E.

Rule 8.6 (amended) – clarifying use of continuous shuffler

The purpose of this proposed amendment is to allow cards collected by the dealer to be returned directly to the continuous shuffler rather than via the discard rack.

The full text of the proposed amended rule 8.6 is attached at Appendix E.

15B.2 and 15C.3 (amended) – clarification of where players may place a Perfect Pairs or Any Pairs wager

These proposed amendments are to allow a wager on Perfect Pairs or Any Pairs to not have to correspond to the player’s initial wager (i.e. to allow players to wager on other boxes), but that each box is subject to a maximum of three such wagers.

The full text of proposed amended rules 15B.2 and 15C.3 are attached at Appendix E.

Minor amendments around capitalisation of text

As with Baccarat, the applicant proposes a number of minor drafting changes to the rules to ensure that defined terms as set out in the interpretation section should be consistently capitalised in the text of the rules.

A copy of these changes is available on request.

Ultimate Texas Hold-Em

Rule 8.4 (amended) – to allow use of a new automatic shuffler

The applicant proposes to amend rule 8.4 to allow an alternative dealing style. The purpose of making this amendment is to allow the use of a particular kind of automatic shuffler that would be incompatible with the current dealing sequence specified in rule 8.4

The proposed text of amended rule 8.4 is attached an Appendix G.

Submissions

The proposed amendments described above will be assessed in accordance with the purposes of the Gambling Act 2003.

Some of the purposes of the Gambling Act (relevant to this proposal in particular) are to:

Prevent and minimise the harm caused by gambling, including problem gambling

Ensure the integrity and fairness of games

Limit opportunities for crime and dishonesty

Facilitate responsible gambling

We ask you to make your submission with these particular purposes in mind.

Analysis of Harm

In particular, the Department assesses the potential effect of such applications with respect to harm minimisation and prevention. As such, we ask you specifically to comment on whether the proposals may raise harm prevention and minimisation issues that you believe require consideration.

Context

It is important to analyse identified risks in the context and environment for which approval is sought. Any form of gambling analysed in isolation would be found to be potentially harmful.

A number of harm prevention and minimisation initiatives and requirements are in place in casinos. Casino operators have host responsibility programmes, problem gambler identification policies including exclusion procedures, and staff training in harm prevention and minimisation. Casinos must also make information about problem gambling freely available and display signage encouraging responsible gambling.

Assessment of Application against relevant guidelines

The Department of Internal Affairs will form its assessment of the application under the 'Operational Policy Harm Prevention, Harm Minimisation and Responsible Gambling Guidelines'. These guidelines require the Department to take, in the absence of evidence, a precautionary approach in decision making where there is a reasonable concern that significant and/or widespread harm may occur. In the absence of evidence, the Department makes an assessment of these proposals against known harm determinants.

A copy of these guidelines can be found on the Department’s website at:

http://www.dia.govt.nz/pubforms.nsf/URL/GamingOperationalPolicy.pdf/$file/GamingOperationalPolicy.pdf

The Gambling Commission is responsible for assessing whether changes in the casino environment constitute an overall increase in opportunities for casino gambling. The introduction of any new games or wagering options would require an application to the Gambling Commission for such an assessment to take place.

If any amendments are made, a notice will be published in the New Zealand Gazette stating that the game rules have been amended, made or revoked and the date on which the changes take effect.

Please address your submissions to:

Sue Clarke

Policy Advisor, Operational Policy

Department of Internal Affairs Te Tari Taiwhenua

PO Box 805

Wellington 6140

Alternatively, you can send your submission to sue.clarke@dia.govt.nz

Should you require further information on these proposals or the nature of the products, please contact Sue on the above email address or on telephone number 04 495 9438 or Angus Hyatt, Senior Advisor, on 04 495 7271.

Any submissions need to be received by 5 pm on 2 May 2014.

The ante is defined in a proposed addition to section 1.0 of the rules for Baccarat and in full states: ‘”Ante” means a flat rate participation fee of not more than 12.5% of the table minimum wager payable to the casino operator and used in a game of Ante Up Baccarat in accordance with section 14.’

2

XX March 2014

Released 1 February 2011

Angus Hyatt

2014-03-19

Clarkesu

Department of Internal Affairs