Iowa Gaming Supplier Regulatory Overview

Introduction

The Iowa Racing and Gaming Commission ("IRGC") was created in 1983 with the passage of the Pari-Mutuel Wagering Act. In July 1989, legislation was enacted allowing the IRGC to license qualified sponsoring organizations to conduct gambling games on excursion gambling boats. Iowa currently has 19 operating commercial casinos, one of which is a riverboat, 16 of which are land-based, and two of which are racinos.¹ In addition to its commercial casinos, Iowa also has four tribal casinos.² The commercial casinos employ approximately 15,662 people and generate $1.4 billion in gross gaming revenue annually.³

Iowa requires that manufacturers and distributors of gaming devices be licensed through the IRGC. There are separate licenses for manufacturers and distributors.

Individuals or entities that conduct operations at a casino gaming facility, but do not fall within the definition of a manufacturer or distributor, are considered to be vendors and must receive a Vendor's License.⁴

Potential applicants should note that the information below is taken from Iowa law, administrative rules, and the IRGC's website, as application materials are only available upon request of potential applicants. Interested persons should contact the IRGC for further information regarding application materials.

Manufacturer's License

A manufacturer is a person or entity that designs, assembles, fabricates, produces, constructs, or otherwise prepares a product, or a component part of a product, or any implement of gambling usable in the lawful conduct of gaming within the state.⁵

Licenses are issued on an annual basis, and applications and fees are due on the first of April.⁶ The license fee for a Manufacturer License is $250.00.⁷

Applications are only available upon request directed to the IRGC. An application should include personal identifying information, such as full name, residence, and date of birth.⁸ Additionally, an application should include whether the applicant has:

1. A felony conviction;
2. An addiction to alcohol or a controlled substance; or
3. A history of mental illness.⁹

An applicant should also submit pictures, fingerprints, and descriptions of physical characteristics to the IRGC for a background check.¹⁰

Distributor's License

A distributor is any individual or entity that sells, markets, or otherwise distributes gambling devices or associated gambling equipment usable in the lawful conduct of gaming within the state.¹¹

Licenses are issued on an annual basis and applications and fees are due on the first of April.¹² The license fee for a Distributor License is $1,000.00.¹³

Applications are only available upon request directed to the IRGC. An application should include personal identifying information, such as full name, residence, and date of birth.¹⁴ Additionally, an application should include whether the applicant has:

1. A felony conviction;
2. An addiction to alcohol or a controlled substance; or
3. A history of mental illness.¹⁵

An applicant should also submit pictures, fingerprints, and descriptions of physical characteristics to the IGRC for a background check.¹⁶

Vendor's License

Individuals or entities that conduct operations at a casino gaming facility but do not fall within the definition of a manufacturer or distributor are considered to be vendors and must receive a Vendor's License.¹⁷ All employees of a licensed Vendor who deliver goods to the casino site must be licensed as Vendor Employees.¹⁸

Applications are only available upon request directed to the IRGC. An applicant must complete a form and have an authorized representative from the facility for which the vendor wishes to do business sign the form.¹⁹

Disclosure and Reporting Requirements

A Manufacturer's Licensee or a Distributor's Licensee must provide the IRGC with written notice showing shipment of gambling devices to an operator.²⁰ Prior to installation at the gaming facility, the manufacturer or distributor must deliver the games to a location specified by the IRGC, so that the items may be inspected and approved for use in a state gaming facility.²¹

Sports Betting

Iowa became the eleventh state to legalize sports betting in May 2019, when Governor Kim Reynold signed S 617 into law.²² The state launched sports betting on August 15, 2019, and currently offers betting on collegiate, professional, and international events.²³ Licensees permitted to operate a gambling structure are the only entities required to be licensed.²⁴ There are not any vendor or supplier licenses at this time.

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¹American Gaming Association, State of the States 2019: The AGA Survey of the Commercial Casino Industry, https://www.americangaming.org/wp-content/uploads/2019/06/AGA-2019-State-of-the-States_FINAL.pdf; American Gaming Association, State of Play: Iowa, https://www.americangaming.org/state/iowa/ (last visited Aug. 20, 2019).
²American Gaming Association, State of Play: Iowa, https://www.americangaming.org/state/iowa/ (last visited Aug. 20, 2019).
³American Gaming Association, State of the States 2019: The AGA Survey of the Commercial Casino Industry, https://www.americangaming.org/wp-content/uploads/2019/06/AGA-2019-State-of-the-States_FINAL.pdf.
⁴Iowa Admin. Code r. 491-6.14(1).
⁵Iowa Code § 99.F.1(18).)
⁶Iowa Code § 99.F.17(1).
⁷Iowa Code § 99.F.17(1).
⁸Iowa Code § 99.F.6(1).
⁹Iowa Code § 99.F.6(1).
¹⁰Iowa Code § 99.F.6(2).
¹¹Iowa Code § 99.F.1(6).
¹²Iowa Code § 99.F.17(1).
¹³Iowa Code § 99.F.17(1).
¹⁴Iowa Code § 99.F.6(1).
¹⁵Iowa Code § 99.F.6(1).
¹⁶Iowa Code § 99.F.6(2).
¹⁷Iowa Admin. Code r. 491-6.14(1).
¹⁸Iowa Admin. Code r. 491-6.14(3).
¹⁹Iowa Admin. Code r. 491-6.14(2)..
²⁰Iowa Code § 99.F.17(5).
²¹Iowa Code § 99.F.17A.
²²Eric Ramsey, Sports Betting Legislative Lasso: Iowa Gets In; Tennessee Next In Line, Legal Sports Report (May 20, 2019), https://www.legalsportsreport.com/32623/sports-betting-bills-may-20/.
²³Ashly Richardson, Sports Betting Takes Root in Iowa Casinos, 6 News (Aug. 16, 2019), https://www.wowt.com/content/news/Sports-betting-takes-root-in-Iowa-casinos-546639711.html.
²⁴Iowa S 617 (2019), Iowa Code § 99.F.7(A).