Proposed Comments
I thought that it would be a good idea to have a thread devoted to proposed comments. So I will post my first two proposed comments.
The first comment concerns opposition to the creation of a list of UIG businesses.
Jennifer J. Johnson
Secretary, Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, DC 20551
Dear Secretary Johnson,
"Under II. E. 6. of Supplementary Information to the proposed PROHIBITION ON FUNDING OF UNLAWFUL INTERNET GAMBLING, the agency requests comments on the feasibility of creation of a list of unlawful internet gambling businesses. In my opinion, the creation of such a list is not practical or judicious.
Under the UIGEA, the term unlawful internet gambling is essentially defined as any internet gambling that violates any applicable state or federal law. However, the power to interpret state or federal laws is granted to the judiciary branch of government; not to the executive. So how can any government agency determine whether any business is engaged in unlawful internet gambling? Interpretation of the laws affecting internet gambling of all 50 states and the federal government and applying these laws to determine which businesses are violating them would place any agency in the position of being judge and jury for any potential business.
Besides being extremely costly, I believe that any such judgment should be left to the judiciary branch and not any government agency. Without some judicial ruling about any business engaged in internet gambling how can an agency insure that such business is engaged in unlawful internet gambling?
In my opinion, the Agencies discussion about the difficulties of creating a list of businesses engaged in unlawful internet gambling is correct. In my opinion, the Agencies cannot establish, maintain and update such a list."
Sincerely
JPFisher55
TE, and others, let me know what you think. Also, anyone feel free to copy or other use this comment.
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