Nevada Changes Restricted Gaming License Requirements for Individuals
Effective February 28, 2022, the Applicant Services section of the Nevada Gaming Control Board’s (“Board” or “GCB”) Investigations Division significantly changed the forms required for individuals who are applying for a restricted gaming license. The change impacts all applications for (1) a Restricted Gaming License, (2) approval/licensure to participate in Restricted Gaming Revenue and (3) Licensure as an Officer, Director, Key Employee, or similar position in connection with a restricted gaming operation.
Different Forms and More Information
In addition to requiring restricted license applicants to complete two different forms, the change also requires more extensive and more detailed information that was previously required only in connection with a nonrestricted gaming license application. In some respects, the new requirements elevate components of the restricted license application to the equivalent of applying for a nonrestricted gaming license. Therefore, it is imperative for restricted gaming license applicants to understand the new forms, complete them accurately, and begin planning for how the additional information provided will also affect their background investigation as well as their ongoing compliance and reporting requirements.
The complexity, comprehensiveness and cost of Nevada’s gaming license application, background investigation and approval process depends on which of four general categories relates to the specific applicant: (1) gaming employees, (2) people associated with the gaming industry (such as service providers and people owning less than 5% of a gaming company), (3) people in a “restricted” gaming location (such as a bar that operates 15 or fewer slot machines) or (4) people in a “nonrestricted” gaming location (including key positions such as owners, operators, executive management, and Board members). The stringent and voluminous nature of the application requirements increases from category one to four, but the Board’s new changes that were publicly announced on January 26, 2022, makes part of the “restricted” category as exhaustive as the “nonrestricted” category.
Forms 7 and 7A Replace Forms 4 and 5
Previously, individuals seeking licensure in connection with a restricted gaming operation were required to complete and file a GCB Form 4 (Personal History Record) and, in most cases, a GCB Form 5 (Personal Financial Questionnaire). As of February 28, 2022, all individuals seeking licensure in connection with a restricted gaming operation will instead be required to complete and file a GCB Form 7 (Multi-Jurisdictional Personal History Disclosure Form) and a GCB Form 7A (Nevada Supplemental Personal History Disclosure Form). Previously, these lengthy and often complicated forms were only required of individuals seeking findings of suitability or licensure in connection with nonrestricted gaming operations.
For example, the Multi-Jurisdictional Personal History Disclosure Form is utilized in many U.S. jurisdictions, is a total of approximately 65 pages, and has two sections.
- The first section focuses on detailed personal history such as family and marital status, educational background, residence information, civil lawsuit and criminal court records, employment history, licensing history, and references.
- The second section focuses on a detailed financial statement that includes salary and tax information, personal assets and liabilities disclosures, bankruptcy filings, and any investments in the gaming entity related to the application.
The revised and updated restricted gaming application instructions and forms are available on the Board’s website at Nevada Gaming Control Board: Forms and Applications (nv.gov). The Board has advised that restricted gaming applications filed on or after February 28, 2022, without the GCB Forms 7 and 7A, where required, will be considered incomplete and will not be processed by the Board until all the new requirements are fulfilled.
All other GCB application forms required to be filed by individuals in connection with restricted gaming operations remain the same as before. If you have questions concerning these new restricted gaming application forms requirements and the resulting increase in the scope and depth of the associated background investigation, please contact Greg Giordano, Dennis Gutwald, A.G. Burnett, or Kelci S. Binau for assistance.
About McDonald Carano
McDonald Carano has been shaping Nevada’s legal, business, and policy landscape since our founding in 1949. With more than 60 lawyers and government affairs professionals working from offices in Las Vegas, Reno and Carson City, we are Nevada’s law firm for business. Our local, national and global clients include Fortune 500 corporations, fast-growth and mid-market companies, entrepreneurs and startups, non-profit organizations, government entities, and high-net-worth individuals. Our attorneys deliver cross-discipline, one-stop, commercial law and government affairs counsel. Our dedication to clients, innovative thinking and practical solutions based in sound business and legal judgments are at the heart of our practice. For more information, please visit mcdonaldcarano.com or send an email to email@example.com.
You have chosen to send an email to McDonald Carano. The sending or receipt of this email and the information in it does not in itself create an attorney-client relationship. If you are not already a client, you should not provide us with information that you wish to have treated as privileged or confidential without first speaking to one of our lawyers. If you provide information before we confirm that you are a client and that we are willing and able to represent you, we may not be required to treat that information as privileged, confidential, or protected information, and we may be able to represent a party adverse to you.
I have read this and want to send an email.