The Massachusetts Gaming Commission (MGC) has delivered its promised White Paper on the legal and regulatory challenges posed by daily fantasy sports.

The MGC announced plans to compile the White Paper (read it here) at a public hearing on the issue in October. The report’s release comes one day before state Attorney General Maura Healey holds a public hearing on the DFS consumer protection recommendations she unveiled in November.

The MGC notes that, on its face, DFS appears to be illegal under the state’s pool betting laws, which make no distinction between games of skill or chance. The state’s lottery laws may also hold potential pitfalls for DFS. That said, the MGC suggests that “the balance of Massachusetts law may make that reading illogical.”

The MGC also acknowledges that authorizing DFS could contravene the federal PASPA sports betting prohibition but suggests that the state might want to go ahead and take “clear and decisive state action” and “let the others react as they see fit.”