Re: PPA has released its UIGEA regulations comment talking points
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This doesn't preclude the regs from defining unlawful Internet gambling. If they have to put together a 1,000 page guide, so be it. If it's so hard, the banks won't be able to do it either, so they'll overblock it. It seems this is precisely our point. This is an unfunded mandate on our banks, and they shouldn't have to absorb the costs.
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There's no such thing as an "unfunded mandate" on private entities, the concept only applies to governmental units, like States. Legislatures pass laws governing private entities/citizens, the cost of complying with those laws is borne by those affected by the laws, period.
If your point is overblocking will occur, then why not make that point directly rather than inferentially via asking Treasury to do something that is probably unconstitutional and at least unprecedented, that is, taking a position regarding the interpretation of federal criminal laws and state laws not relating to banking?
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