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New Jersey requires any entity under a "commission based model" to get a license New Jersey requires any entity under a "commission based model" to get a license

10-04-2013 , 11:41 AM
I read through the comments and responses issued on September 30 regarding I-gaming regulations in NJ.

The NJ DGE stated it is clear that any entity that wants to enter into a "commission based" marketing agreement with an NJ operator will be required to obtain an ancillary license:

"COMMENT: Pokertrip suggests that entities providing services relating to marketing activities using commission-based business models obtain an ancillary casino service industry enterprise license under N.J.A.C. 13:69J-1.2(d).
RESPONSE: The Division has amended N.J.A.C. 13:69J-1.2(d) to make clear that these entities will be considered ancillary casino service industry enterprises."
New Jersey requires any entity under a "commission based model" to get a license Quote
10-04-2013 , 03:13 PM
I've searched this doc and no 13:69J-1.2(d) is listed in it.

http://www.nj.gov/lps/ge/docs/Regula...CHAPTER69J.doc

I'm guessing it did not exist the last time that page was updated.

Any thoughts on what this means? I would guess that this means that there is no back door for affiliates in NJ. Anyone and everyone that wants a part of the action is going to have to get licensed like software and location services as opposed to being just a vendor piggybacking on a room. Is that a fair assumption?

It is hard to make too educated of a guess when that reg is not described anywhere.

Could it maybe be a typo? This section seems to cover the situation closely, unless maybe affiliates will have their own subsection.

"13:69J-1.2C - Licensing of vendors doing non-gaming business"
New Jersey requires any entity under a "commission based model" to get a license Quote
10-04-2013 , 03:37 PM
Also, do you assume commission based marketing includes CPA?

By the way, thank you for all of your help on this topic over the past few years.

Last edited by John Mehaffey; 10-04-2013 at 03:54 PM.
New Jersey requires any entity under a "commission based model" to get a license Quote
10-04-2013 , 06:50 PM
http://www.nj.gov/oag/ge/docs/Propos...rnetgaming.pdf

I found the law in question there under proposed rules but before the affiliate language was added. It currently reads:

Quote:
Junket enterprises, junket representatives, and enterprises providing other services including, but not limited to, payment processing and related money-transmitting services, customer identity, age verification,and geo-location verification used in the conduct of Internet and mobile gaming, regardless of any such enterprise’s contractual relationship with an Internet gaming permit holder, shall be licensed as an ancillary casino service industry enterprise.
New Jersey requires any entity under a "commission based model" to get a license Quote

      
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