[omgwtf]

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I can tell you a lot of effort was put into generating the points. While it may seem wonderful to have UIG undefined, the regs put banks in the position of either overblocking or of having to prove allowed transactions are "lawful". Also, the reg authors admitted they were unable to define UIG. Given this admission, it seems we could gain by pushing them in this area. There are other pro-poker reasons to support a definition as well.

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Maybe you can explain the thinking behind these talking points. I can be persuaded.

On the face of it all, UIGEA is quite ambiguous and fails to define what transactions must be blocked. At this point, I can't see any outcome to the PPA strategy other than a regulatory interpretation of UIG that includes poker.

It seems that the two available strategies are:
1) Poker doesn't fit the UIGEA definition of UIG, so regulators should officially and explicitly declare poker to not be considered UIG. (Does anyone who can win at poker really think this has better than a runner-runner chance?)
2) Make the case that UIGEA is too ambiguous and not defined enough to form regulations that would block only UIG. The regulators were given the impossible task of writing guidelines to prohibit a category of transactions, but congress didn't adequately provide the criteria for determining whether a transaction should be prohibited. The inescapable result is that legal transaction will be blocked, prohibited transactions allowed, and the compliance burden on banks will be too high. The regulations can't be written until congress properly defines how to determine which transactions are prohibited. If this argument is successful and UIGEA goes back to congress, the whole process opens up again.

One other point: I've seen several people mention "state laws". I'm definitely not a banking expert, but it seems that federal regulations should be based on federal law, not state laws.