[Skallagrim]

Was my post to long to get the point across? The folks who write these regs have realized what I have been saying all along: applying various state laws written mostly in the early 1900's which may or may not apply to poker, the internet, bridge, backgammon, and all the other gray things, is an intellectual and legal nightmare.

To placate the anti-gambling folks the current regs basically encourage banks to do what Frist and the DOJ could not achieve through legislation: ban transactions to all for-money games.

If we are going to stop this we have to get them to realize how much otherwise perfectlty legal US businesses will suffer. We must also emphasize that the banks who care about having such businesses as customers will be driven crazy trying to comply.

Hence the way out is not to force them to make the defintion they refuse to make, but to have the regs say explicitly that the required bank practices/policies ALSO DONT HAVE TO MAKE THAT DEFINITION. The regs should say that the banks need only have a policy to prevent transactions to sportsbooks (and maybe online casinos) unless they are banks in Louisianna, Illinois, Washington, and the few other states that have very specific laws regarding internet play - those banks have to comply with those laws too.

To require the banks to do anything else will either harm legal US businesses or require the banks to do some seriously costly work. Seriously costly work is - per the UIGEA statute - good grounds to not require it.

Skallagrim

PS - much as I, as an attorney, would look forward to litigation (and understand the opportunity - and danger - that litigation brings), I, as an online poker player, would much rather see regs that dont stop me from playing until a lawyer gets a court to say I can.