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I have a problem with Microgaming reports . The payout % reports.
How can anyone feel that the games are honest ? Is their ever a real test?
Price Waterhouse Cooper's reports were not an audit. Not Even close . They only state the arithmetic is correct . Their must be a real test . Maybe I'am just too cynical .
After reading Ecogras operators requirements this is my take on their "fair gaming " regulations.
1. They test rng's 2 times a year.
2. Monthly evaluations of operators calculations. This only makes sure the logs show the operators total payouts for total number of plays is similar to the theoretical payback % .
3 Their is no random testing of the payback %.
In a bricks and mortar casino this would be O.K. The slot machines are stationary. In cyber space a commissioner can not pull a virtual machine for testing in a lab. This is why this methodology is of no value .
It appears PWC does not Even make the reports anymore .PWC never said in any report the games were fair. Their was a clause in each report that stated " This report shows only payback % as calculated by review of raw data logs. We can not certify the actual amount of payments to players.We do not review back office practices "
This quote from the PWC report I paraphrased . It has been about a year since I read one .
Below is ALL the Regulations ecogra has to garuantee the games you play are fair. Ecogra does not want independent random testing of their seal of approval holders.
Actual Copy of "fair gaming requirements" as copied from Ecogra .
106 SOFTWARE DEVELOPMENT AND MAINTENANCE
OBJECTIVE:
Software shall be developed, implemented and maintained in a manner representative of best practice standards.
METHODOLOGY:
The eCOGRA Review Department shall confirm the software providers use a recognised software development methodology to develop and maintain software.
MINIMUM REQUIREMENTS:
Software and Application Documentation SP O
106.R.1 The following information regarding software and applications used for or run on the system must be available:
106.R.1.1. Functional specifications and user manuals.
106.R.1.2. Acceptance testing procedures. The software supplier of the system must possess an appropriate acceptance testing strategy to be applied to all changes to the system.
106.R.1.3. Version control procedures.
106.R.1.4. Change control procedures.
106.R.2 All documentation relating to development and testing shall be retained for a minimum period of twelve months.
Change Control SP O
106.R.3 Change control procedures shall be implemented in line with the change management procedures and shall cater for the following:
106.R.3.1. Approval procedures for changes to software.
106.R.3.2. A policy addressing emergency change procedures.
106.R.3.3. Procedures for testing and migration of changes.
106.R.3.4. Segregation of duties between the developers, quality assurance team, the migration team and users.
106.R.3.5. Procedures to ensure that technical and user documentation is updated as a result of a change.
106.R.4 The test environment must be isolated physically and logically from the live operational systems.
SUGGESTED PRACTICES:
Software Provider / Operator Policies SP O
106.P.1 A policies and procedures document between software providers and operators shall be in place setting out reasonable maintenance and support service levels.
107 TOTAL GAMING TRANSACTION REVIEW
OBJECTIVE:
Games shall be independent and fair.
METHODOLOGY:
The eCOGRA Review Department shall use appropriate methods to confirm that this objective is met. The average payout percentage (being the percentage of winnings to wagered amounts) shall be reviewed on a monthly basis. The output of the random number generator shall be reviewed at least bi-annually and shall incorporate appropriate statistical tests.
MINIMUM REQUIREMENTS – ALL GAMES:
Payout Percentages SP O
107.R.1 Data log files shall be reconciled on a monthly basis to movements on player accounts.
107.R.2 Each game must have a theoretical / estimated statistical return to the player of at least 90% using optimal game play strategy.
107.R.3 All games must have a combined average actual statistical return to player of at least 92%.
107.R.4 The theoretical statistical return percentage for a particular game type should be no less than that of the equivalent game in free play mode.
MINIMUM REQUIREMENTS – BLACKJACK, ROULETTE AND VIDEO POKER GAMES:
Random Number Generator SP O
107.R.5 The results of games must be random, except where clearly disclosed if different game-rules apply.
107.R.6 The output obtained through the use of the RNG in games shall be proven to be:
107.R.6.1 Statistically independent.
107.R.6.2 Uniformly distributed over their range.
107.R.7 The RNG shall pass generally accepted statistical tests for randomness (uniformity and independence).
RNG Seeding SP O
107.R.8 The method used for seed-set generation shall be described (without disclosing intellectual property rights) in adequate detail to enable an assessment of the methodology applied.
107.R.9 Re-seeding must not be performed in a manner that results in a predictable output.
MINIMUM REQUIREMENTS – SLOT GAMES:
Payout Distribution SP O
107.R.10 Wagering activity, including wins, should be distributed amongst an acceptable population of players.
SUGGESTED PRACTICES
None.
108 SERVER CONNECTIVITY REQUIREMENTS
OBJECTIVE:
Minimum game server connectivity requirements shall be met to ensure that players are protected from losses due to connectivity problems.
METHODOLOGY:
The eCOGRA Review Department shall use appropriate methodologies to confirm that this objective is met.
MINIMUM REQUIREMENTS:
Continuity SP O
108.R.1 All information required for completing an incomplete game shall be recoverable by the system.
108.R.2 The system shall enable players to complete interrupted games, within a reasonable timeframe, whether from loss of communication with the end-player device or an event on the system.
SUGGESTED PRACTICES:
Continuity SP O
108.P.1 In the event that the software does not allow a game to be completed, all bets relating to the incomplete game should be returned to the players of that game.
Here is an article from Jetset about old PWC scheme http://www.best-bonuses.com/articles/article37.htm sounds OK for me and I think eCOGRA copied it
I have read the requirements many times. I understand rng's probability and the details of Ecogra's requirements for operators.
Ecogra does an excellent job for certain Issues .
1. Underage gambling
2. Problem Gambling
3. Safegaurding personal and financial data
4. Player disputes
5. Quick payments
Ecogra's requirements do NOT produce satisfactory results on these Issues
1. Random testing for determining estimated payback percentage
2. Anonymous testing for payback percentage
Here is a hypothetical to show the difference between Ecogra and the nevada gaming commission
Hypothetical situation:
commissioner C1 = Nevada gaming commissioner
commissioner C2 = Ecogra not have to answer to anyone pretend inspector of B.S. regulations
Our tasks for our commissioners.
1. Check the pay back % on 3 different slot machines.
2. Make sure the decks in a 5 deck game of blackjack are true and correct.
Commissioner C1 Goes to casino pulls the microchips out of 3 machines Then he can run tests in the lab... Walks over to blackjack area. He can randomly select a table. Remove cards from table. Check the cards
Inspector C2 Twice a year (not without notice) lab tests the RNG’s. Monthly Reviews raw logs. Compares payback (actual) to payback (theoretical).
Same with blackjack.
Can anyone see the problem?
Their is no audit. A casino can use programs with dummy accounts to cheat. Winning hands go to the dummy account. I get the losing hand. No matter what regulations you make they can find a way to cheat. If their is the will their is a way.
Independent anonymous random testing of actual game play .Ecogra is completely against testing of this type. This position gives the appearance they are cheating.
Ecogra is good for controlling problem and under age gambling.
The safeguard of deposits and payment of winnings.
Security and privacy Issues.
Ecogra is much too close to Microgaming for anyone to believe the payback percentage reports.