VP, financial transaction regulations and whales

There could be another way in which financial transaction reporting requirements could lead to federal civil rights laws applying to protect advantage players. The regulations for casinso to have enough reserves to pay for large jackpots is generally accepted to be what has lead casinos to not be able to toss out advantage video poker players. To be able to hold a reserve to pay a jackpot, or a royal, the casino has to show certain moneys are being held in reserve. But in order to hold such reserves the casino has to submit its books to federal transaction rules, including the rules on circulation of adverse transaction reports, such as I and others discussed on this board recently in regard to the Griffin investigation reports being adverse transaction reports under the rules relating to the Federal Fair Credit Reporting Act.

What happens when every bet itself is over the $10K reporting requirement? The federal rules in holding reserves certainly would apply to every bet. They might apply to bets at the 2.5K level which is the level where CTR tracking must begin, but CTR reports are not actually required to be turned in. The federal transaction reserve rules apply to payouts as low as $250, for 5 cent slot players.

Just some additional thoughts to apply to countering casino heat!

Don't you think that someone could have thought of this before you? Really, if that could be done, it would have by now.

Get a life Clark!!!!!!!!!

Few players have liked the idea of admitting any financial transaction records applied to them or that those pesky regulations could be applied in their favor. As a quick example, only about 15 attorneys in the world specialize in player representation. While many of them have a civil rights background, few of them would be also specialists in the areas of housing discrimination or credit reporting discrimination. It would take this multi-area experience to have tried this before. I. Nelson Rose has a sub-board on bjrnet.com and was the only one to have anything posted, in regard to an item Arnold Snyder had, in his, Blackjack Wisdom, book, about how the regulations to keep reserves available for paying large jackpots put casinos under the civil rights requirements of financial rules in general. That is one attorney of 15, in a highly specialized area of law, and where few of those attorneys share information (reason--most such cases are settled out of court and remaining quiet is part of maintaining a competitive edge). Rose has only posted on the video poker angle on this possible protection. DD posted in a prior thread that he though the Hyland group may have used the credit reporting angle against Griffin Investigations and I replied that I thought not because the team operations would have been hindered in that admitting that financial report regulations apply to casino playing in general might have left them open to bringing the IRS into team bankroll transactions etc.

I would trade team management problems for an open environment.

I added in this thread that the trigger levels for reporting, may apply to individual bets, and with reports being triggered for each bet there may be civil rights issues to protect the right to make an individual bet, even though reports are made for each session, not bet.

These are uncharted questions. I think you and other like minded posters might just like to check over one statement from Don Lancaster's website (link through tinaja.com): if you have an idea you assume is so good it had to have been tried before, don't be too sure. Many such ideas are thought of by far more than ever try it because it is so news or unusual that they assume someone else has tried it and failed with it.

The first time a cash transaction is made that puts a player over the 10K in 24 hour limit the needed information is obtained. The exact amount needn't be recorded until the conclusion of the session. When a high roller frequents a casino and has had CTRs done previously they often do not even bother mentioning it to the player.

how early triggering may link that session's playing to the civil rights regulations, during the session, by reason of already requiring a CTR. The session is protected if the start of playing can be considered part of the reporting process. The session is not necessarily protected, if the reporting process is not "tolled," until the end of the session.

I think part of this you may have had in mind even though you did not state this. Thankyou for responding and apparently seeing this.

This is the entire issue on whether the casino is thereby bound to various civil rights laws and rules, by reason of their submitting to CTR and other reporting demands.

The previous related thread I mention again to point out that I am sure you have information about the Hyland team, in regard to Griffin reports being adverse credit reports under federal rules. I don't doubt that at all. I in no way am questioning that; I am just expressing my opinion that this legal tactic was not pushed as it would be an admission that would grant agencies like the IRS some right to sit in on sensitive team meetings and in on bankroll disbursements and disbursements of winnings. So my take is that the Hyland team probably did not push this issue strongly: "they had other fish to fry."