N.Y. Comp. Codes R. & Regs. tit. 9, § 5116.9
(b) Any player rewards club system established pursuant to a marketing plan shall be open to any member of the public who is playing the authorized video lottery game at which the complimentary service is being offered. In addition, any system shall require the video lottery gaming agent to establish and maintain a system of detailed internal control procedures controlling the player rewards club program, prior to the implementation of such program, which procedures shall be maintained by a designated department approved by the commission; provided, however, that if complimentary goods or services will be issued based upon the occurrence of an event that may occur in the normal conduct of a video lottery game, the video lottery gaming agent shall submit for commission approval, in writing, a description of the internal control procedure governing the issuance of a complimentary, at least 10 days prior to the commencement of the program. Such approval shall be deemed to have been granted if it is not denied, in writing, within the 10-day period, and, provided, that such internal control procedures shall address, at a minimum: