[Uglyowl]

November 23, 2007

Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551

Dear Secretary Johnson:

I am writing with comments for the proposed regulations for implementing the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA). The current regulations as they stand now, would likely force financial institutions to block not only illegal internet gambling transactions as intended (sports gambling), but also many legal gambling transactions (skill games, horse racing, dog racing, and fantasy sports).

The UIGEA ,as originally written by gambling opponents, was intended to make illegal all wagering transactions in the United States. Congress did not pass this version of the bill, but a “watered-down” version that dealt with funding for what is already unlawful and not expanding the definition of unlawful. If the regulations as written stand, there would be in effect, a law against all gambling in the United States, which is not what was voted on and signed by the President. Gambling (other than sports gambling) is based on 50 different state laws, and it is unfair to the financial institutions and American citizens to have laws determined by the tens of thousands of banks interpretations.

Thank you for your consideration.

Sincerely,


"uglyowl"