How The MGCB Ensures Fair Gambling For Its Retail And Online Patrons

Written By Drew Ellis on March 1, 2024 - Last Updated on March 4, 2024
Man fixing and testing a slot machine. The MGCB Gaming Lab Manager Robert Franklin recently discussed how fair gambling is ensured for Michigan casino patrons.

March is Problem Gambling Awareness Month. When dealing with problem gambling, it’s also important to acknowledge fair gambling.

The Michigan Gaming Control Board recently detailed the steps they take to ensure fairness in gambling in the state – both in commercial and online gambling – as part of the Double Down Michigan podcast.

MGCB Executive Director Henry Williams spoke with Gaming Lab Manager Robert Franklin. The pair covered a number of important topics related to fair gambling.

If you’ve wondered just how casino games are tested and regulated in Michigan, we’ve got the answers for you.

What is the Gaming Lab?

The Gaming Lab is a section of the MGCB responsible for testing games and software. The testing occurs before games make their way onto the floors of commercial casinos or the apps of Michigan online casinos.

“The primary focus is to review, as part of the approval process, all submissions made for gaming software, or gaming hardware,” Franklin said on the podcast.

“They will review that documentation and then make a judgment call as to whether or not that that product should be approved or not, based upon its adherence to the applicable administrative rules or technical standards that govern that particular type of gaming device or software.”

Along with a lot of work approving slot machines, the Gaming Lab is also responsible for making sure all table games meet regulations and standards as well.

The Gaming Lab includes staff that:

  • Review games from the MGCB offices
  • Oversee critical gaming systems at Detroit’s three commercial casinos
  • Conduct inspections of data centers around the state that are used to house the IT infrastructure for internet gaming platforms
  • Assist in the criminal investigations for suspected illegal gaming activities

How are casino games tested for fairness in Michigan?

Testing a new game or product is an extensive process in Michigan. And, there’s a lot that goes into making sure a game meets all the standards of the MGCB.

“Our gaming activities taking place in the state of Michigan, operate in a consistent manner and in a regulated manner,” Franklin said on the podcast.

“As a patron, if I go into a casino at 10 a.m. on a Monday, or 10 p.m. on a Saturday, I can have an assurance that if I sit down at my favorite slot machine, it’s going to operate correctly and as designed. … I should have assurance that table games are going to be conducted in a uniform and regulated manner and that the rules of the game are not going to change from minute to minute or day-by-day.”

Independent testing

Even before a game reaches the MGCB Gaming Lab for review, it is first sent to one of four independent test laboratories approved by the board.

Those four laboratories are Gaming Labs International, BMM, Ecogra and Gaming Associates.

“When a gaming supplier wishes to have a product approved by the lab, their first step will be to send that all of that information – the source code, the help screen documentation – to one of our approved and licensed test laboratories that that game will be tested against our current administrative rules and technical standards,” Franklin said.

“A letter will be issued to that gaming supplier attesting that it either does or does not meet the standards for the state of Michigan, whether it’s for commercial casino gaming or internet gaming. Then when that gaming supplier wishes to make a submission to the lab, we take all of that information that they in effect sent to the independent test lab, we get that from the supplier, and then we review it as well, to make sure that we concur with the findings of the independent test lab.”

RNG and RTP standards

Further, slot machines are held to administrative rules and technical standards. They define how a slot machine is to be designed and how it is to operate. Specifically, that relates to the use of a Random Number Generator (RNG) and the machine’s Return To Player (RTP) percentage.

The RNG assures that all game outcomes take place in a randomized fashion. It dictates the outcome of an event of an electronic gaming device. The RNG picks a number out of a range of numbers from zero to how many game outcomes a slot has.

An RNG assigns a number to each symbol on each reel. When a patron plays the game, the RNG then randomly picks a number for each reel to come up with an outcome. If that combination of numbers matches a winning combo, the player wins.

So, while you may look at a series of symbols as a winning combination, that series is actually just a number code to the RNG that happens to match one of the winning options of the game.

RTP is the percentage of money that has been wagered on a slot machine that gets paid back to the customers over its theoretical lifetime.

In Michigan, administrative rules that mandate RTP on all slot games can’t be lower than 80% and can’t be greater than 100%.

What that doesn’t mean is that you can expect to get back 80-100% of your money each time you play. It simply means over the lifetime of the slot, it will pay that percent that was wagered.

“What that means from a practical standpoint is that one should not sit down at a slot machine, let’s say for two hours and feed $1,000 into that slot machine wagering and expect to get back $800 at the end of that gaming session. That’s not how RTP works,” Franklin said.

Digital signatures

Once the MGCB has approved the game and feels it has the proper standards to be released to the public, it then goes through the process of getting a digital signature of the product it reviewed.

To do that, the MGCB uses a hash algorithm.

Specifically, a hash algorithm is a math program that takes an input file. It’s like a software program for a slot machine, and reads every character of that software program and converts it and condenses it down to an alphanumeric signature. That signature represents the software as it was reviewed at that moment in time.

They capture and record the digital signature, which for these slot games is 40 characters. And, when they go back to test the game again over a given period of time, the Gaming Lab expects to get that same digital signature in return.

And, should that software be modified, the signature will change. That allows the Gaming Lab to know that the game they reviewed has since been changed.

“After a game has been approved for use by the gaming laboratory we have members of the gaming lab who will go out to our three Detroit casinos and they will inspect every new slot machine that is deployed to the casino floor,” Franklin said.

“If the digital signature that they get after running that slot machine software through a hash algorithm that we store on a laptop is different than what we approved initially, we know that software is no longer approved. It was never approved by the board, or maybe it was at one point, but it’s been altered somehow.”

How frequently does the MGCB test slot games?

Once a game is approved, it doesn’t just get to live on a casino floor forever.

The Gaming Lab tests games regularly, but in a randomized fashion. The casino audit section conducts periodic performance audits to make sure the slots are operating in accordance with their approved RTP numbers.

“Another thing that we do, is the lab, on a monthly basis, will create a randomized list of slot machines that exist that are in production in our commercial casinos here in Detroit. And, that will be shared with the enforcement staff at each of the casinos,” Franklin said.

“Through our enforcement regulation officers will go out and they will field hash, or they will inspect the machines that were listed for that month’s inspection.”

That doesn’t just go for commercial games either. The MGCB conducts monthly audits of the games available on Michigan’s 15 different online casino platforms.

“(Operators) will send us a list of all of the games that are active in a production server available for play by the public here in Michigan,” Franklin said.

“They will provide us not only with the listing of games, but all of the associated digital signatures for that game. We will take that list, we will import it and bump it up against our database of approved digital signatures. If anything that comes back is not found, that’s a flag for us that we need to now research that game and find out why it’s reporting digital signatures that we’ve never approved and that we have no record of.”

Dispelling myths to ‘cheat the system’ at casinos

Many regular casino customers have their superstitions or beliefs about how to get an advantage on the gaming floor.

Franklin provided a lot of thoughts on these approaches and “myths” for success.

“It’s really key from a regulatory standpoint, and when you’re talking about fairness, a game needs to be designed such that anytime you hit the spin button, you don’t know what the outcome is going to be,” Franklin said. “It’s going to be randomized, it’s going to be controlled by that RNG. There’s no way to predict or know what’s going to happen.”

So, if you find yourself waiting for someone to leave a “cold” machine, you are likely wasting your time.

“Because they are all required to use an RNG to create the outcome of the game, a slot machine is never ever hot. A slot machine is never ever due to win, or never ever cold,” Franklin said. “When you sit down at a slot machine, you have the same odds, the same probability of winning a prize, on your first bet as you do on your 1,000th bet.”

Franklin added that no patron will have the ability to control the outcome of the machines. That is what makes the RNG testing crucial for fair play.

“We have administrative rules that that dictate, in effect, that all games have to be controlled by a RNG in such a way that past game events and past game outcomes cannot in any way predict future game outcomes,” Franklin said. “So rubbing the screen of a slot machine is not going to do anything. That sort of thinking will only result in heartache.”

How do you address a fairness dispute?

If you feel there is an issue of fairness with a game at a commercial or online casino, you have options that will be taken seriously.

The MGCB has processes in place to file a complaint that will be heard by the Gaming Lab.

First, contact the casino or online operator to try and get the issue resolved. As a customer, their goal should be keeping you happy and feeling positive about your experience.

Should that not resolve the issue, then you can begin the MGCB patron dispute process.

If at a commercial casino, contact one of the regulation officers who is at the casino. Obtain a patron dispute form. In some cases, a regulation officer could do immediate testing of the machine. That officer will get its digital signature and make sure the game is operating as intended.

If the issue is online, you can go to the MGCB website. Download a patron dispute form to address the issue and document it.

In both cases, fill out the form and submit it. A regulation officer will then review it to try and determine if there was a violation based on regulation standards.

No matter what the MGCB determines, each individual who files a dispute will receive a follow-up. It may not be in their favor. But they will receive feedback as to what the board came to that determination.

You can find patron dispute forms for each gaming option in the state at the MGCB website.

Photo by PlayMichigan
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Drew Ellis

Drew Ellis is currently the Lead Writer of He was the former Lead Writer of PlayMichigan, the No. 1 source for online gambling news in Michigan. A lifelong resident of the state, Ellis has been working in various forms of media since 1998, including more than a decade in the sports betting industry prior to transitioning into US casino markets in 2020.

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