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As we await news on the 14th November a further nail in the UIGEA coffin is hammered in by the Center for Regulatory Effectiveness (CRE) who advice Congress. They just don't like it.
The PDF of the full report can be found HERE.[PDF]
http://www.federalreserve.gov/SECRS/...-1298_25_1.pdf
It is clear that there is a long way to go. This is NOT good for PRTY. The city want a removal of uncertainty. If regulations are stricter it will wipe out FullTilt and PokerStars - good for PRTY. It the law is scraped, PRTY can re-enter the US or merge with US land based casinos. The worst is this current "unknown" position that appears to be dragging on and on.
CRE Report Blasts the UIGEA and its Proposed Rules[Poker News]
The Center for Regulatory Effectiveness (CRE), an agency that provides Congress with independent analyses of regulations, recently released a report giving the proposed statutes that would be used to enforce the Unlawful Internet Gambling Enforcement Act (UIGEA) a big thumbs down.
The CRE has several problems with the UIGEA. First, the UIGEA and its proposed banking rules are so unspecific when it comes to defining online gambling transactions that government agencies really have no idea what it will cost companies to implement.
This violates the Paperwork Reduction Act (PRA). The CRE report gave several examples of how the UIGEA does not meet the rules of the PRA and came to this conclusion:
“Since the (Treasury) Department has not yet reliably determined the small business impact of the proposed rules, they do not have the record for certifying that they have met the burden reduction requirements of the PRA and will not have such a record until they develop a Revised Initial Regulatory Flexibility Analysis. Accordingly, the Office of Management and Budget should withhold approval until the necessary record is developed and provided to the public for comment.
The CRE also took the government to task for including the estimates cost of several items the UIGEA will require, such as “establishing transaction codes and merchant/business category codes that are required to accompany the authorization request.” The CRE report reads: “The complete burden associated with this very extensive labeling requirement (computer programming, coordination with tens of thousands of participating financial institutions and merchants, testing, training, software, hardware, etc.) need to be included in the PRA estimate.”
And to show just how ineffective the UIGEA may be when it comes to smaller banks, the CRE warned that “Because merchants, including gambling businesses, are not included in the Information Collection Request [ICR], they may be able to exercise the 'public protection' provisions of the PRA and not be subject to any penalty for not complying with information collection aspects of the rule.”
Here are the CRE’s conclusions on the matter:
* The Treasury Department has not provided a specific, objectively supported estimate of burden as required by the PRA.
* The Treasury Department has not provided a record supporting the certification that they have reduced the burden on businesses to the extent practical, with a particular emphasis on small businesses, as required by the PRA.
* The Treasury Department has not made the further efforts to reduce the paperwork burden on small business with fewer than 25 employees as required by the PRA.
And here’s the CRE’s recommendation:
* Since the Information Collection Request does not substantively comply with the PRA, the Office of Management and Budget should send it back to the Department for revision and correction. The revised ICR should be provided to the public for comment prior to approval.
The PDF of the full report can be found HERE.[PDF]
http://www.federalreserve.gov/SECRS/...-1298_25_1.pdf
It is clear that there is a long way to go. This is NOT good for PRTY. The city want a removal of uncertainty. If regulations are stricter it will wipe out FullTilt and PokerStars - good for PRTY. It the law is scraped, PRTY can re-enter the US or merge with US land based casinos. The worst is this current "unknown" position that appears to be dragging on and on.
CRE Report Blasts the UIGEA and its Proposed Rules[Poker News]
The Center for Regulatory Effectiveness (CRE), an agency that provides Congress with independent analyses of regulations, recently released a report giving the proposed statutes that would be used to enforce the Unlawful Internet Gambling Enforcement Act (UIGEA) a big thumbs down.
The CRE has several problems with the UIGEA. First, the UIGEA and its proposed banking rules are so unspecific when it comes to defining online gambling transactions that government agencies really have no idea what it will cost companies to implement.
This violates the Paperwork Reduction Act (PRA). The CRE report gave several examples of how the UIGEA does not meet the rules of the PRA and came to this conclusion:
“Since the (Treasury) Department has not yet reliably determined the small business impact of the proposed rules, they do not have the record for certifying that they have met the burden reduction requirements of the PRA and will not have such a record until they develop a Revised Initial Regulatory Flexibility Analysis. Accordingly, the Office of Management and Budget should withhold approval until the necessary record is developed and provided to the public for comment.
The CRE also took the government to task for including the estimates cost of several items the UIGEA will require, such as “establishing transaction codes and merchant/business category codes that are required to accompany the authorization request.” The CRE report reads: “The complete burden associated with this very extensive labeling requirement (computer programming, coordination with tens of thousands of participating financial institutions and merchants, testing, training, software, hardware, etc.) need to be included in the PRA estimate.”
And to show just how ineffective the UIGEA may be when it comes to smaller banks, the CRE warned that “Because merchants, including gambling businesses, are not included in the Information Collection Request [ICR], they may be able to exercise the 'public protection' provisions of the PRA and not be subject to any penalty for not complying with information collection aspects of the rule.”
Here are the CRE’s conclusions on the matter:
* The Treasury Department has not provided a specific, objectively supported estimate of burden as required by the PRA.
* The Treasury Department has not provided a record supporting the certification that they have reduced the burden on businesses to the extent practical, with a particular emphasis on small businesses, as required by the PRA.
* The Treasury Department has not made the further efforts to reduce the paperwork burden on small business with fewer than 25 employees as required by the PRA.
And here’s the CRE’s recommendation:
* Since the Information Collection Request does not substantively comply with the PRA, the Office of Management and Budget should send it back to the Department for revision and correction. The revised ICR should be provided to the public for comment prior to approval.