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Title 31 - Facts or fiction?

 
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lvbear584



Joined: 07 Jun 2006
Posts: 140

PostPosted: Jul Mon 02, 2007 4:23 pm    Post subject: Title 31 - Facts or fiction? Reply with quote

Now that Nevada has given up Regulation 6a and falls under the federal statutes, there has been much confusion among Nevada casinos. In the first two days of Title 31's applicability to Nevada casinos, the following happened to me in Reno:

(1) One casino claimed it now has the right to make photocopies of any identification I produce, rather than merely writing down the information. They did not know where this is specifically stated. I couldn't find such a provision.

(2) Another casino told me that the Nevada Gaming Control Board will no longer investigate refusals to cash chips if the casino claims its refusal is based on its interpretation of Title 31. If this is correct, the potential for abuse by casinos is enormous.

(3) A casino claims it now has the right to refuse to cash chips without seeing and photocopying government-issued identification on cashouts in excess of $2999.99 but less than $10,000.01. I was told, "no more accepting a player's card as ID, and no more use of physical description without ID in Multiple Transaction Logs."

(4) One casino insisted on ID for any cashout over $2000, using an unknown provision in Title 31 as the excuse.

(5) One cashier told me I'm "guilty" of "staturing" (I assume she meant structuring) for requesting the basis of her purported authority to refuse to cash less than $10,000.01 of chips without my showing ID. She also threatened confiscation of my chips, which included $1600 of chips from a different casino.

(6) One casino cashed $4200 in chips without any questions whatsoever; no ID, no player's card, nothing.

(7) Several casinos told me "money plays" is no longer allowed "under Title 31," but another store allowed several anonymous table max money plays bets in a row. I read the comments in the Federal Register (Volume 72, No.122/June 26, 2007/35008 31 CFR Part 103 RIN1506-AA84 -- IV. Section-by-Section Analysis, C. Other Amendments 2), which deals with "money plays" but could not find a prohibition of it. Perhaps some casinos are making it "policy" to not allow it, but it's business as usual for others?

(8) Some casinos refused to discuss any aspects of Title 31, but others gave me information sheets similar to the Regulation 6a booklets that used to be freely handed out.

It appears that the relevant information is scattered throughout several bodies of law and regulations, with constant references back and forth. Casinos appear ignorant and confused, though they have had months to prepare for this. Once everything settles down, we should be able to continue business as usual, though having to take extra care to avoid unnecessary harassment.

It would be great if someone would compile a list of the pertinent sections of Title 31 as they relate to casino patrons. I would do it, but simply lack the time right now.

My biggest fear is that the Nevada Gaming Control Board will refuse to get involved when a casino lies and claims a Title 31 issue. The small bit of protection we get from Gaming in chip cashing refusal incidents might be gone entirely.

Has anyone else experienced changes in cage procedures since July 1?

---------------------

My casino-related website: www.TheBearGrowls.com
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stan_allen



Joined: 19 Dec 2005
Posts: 1129

PostPosted: Jul Mon 02, 2007 4:34 pm    Post subject: Title Thirty-Fun Reply with quote

It's a safe bet that I'll never encounter any of the fallout from these procedures as my gaming budgets are always so paltry, but for those of us who might like to see the language of "Title 31", can you recommend a link or other resource?

Legal lingo always fascinates me, and it will be fun to imagine the ill-informed and confused casino staff attempting to interpret the rules - though not so fun if I had a bigger bankroll!
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lvbear584



Joined: 07 Jun 2006
Posts: 140

PostPosted: Jul Mon 02, 2007 4:49 pm    Post subject: A little background Reply with quote

for those of us who might like to see the language of "Title 31", can you recommend a link or other resource?

For a brief overview, see:

http://gaming.nv.gov/documents/pdf/industry_ltr_131.pdf

More:

http://www.access.gpo.gov/nara/cfr/waisidx_04/31cfr103_04.html

---------------------------------

Until June 30, Nevada casinos were exempt from Title 31. Nevada Regulation 6a was enforced by the Nevada Gaming Control Board. Though I am certainly not a fan of the Board, I think trying to get federal employees to compel a casino to obey the law will be next to impossible. The Board, by voluntarily abdicating its enforcement of 6A, really dropped the ball for patrons and casinos, too. This will be an expensive mess with many lawsuits before all is said and done.

-------------------------------

My casino-related website: www.TheBearGrowls.com
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CaSwede



Joined: 28 Feb 2006
Posts: 866

PostPosted: Jul Mon 02, 2007 7:00 pm    Post subject: Reply with quote

Wow, this could be big. I have no expierence with this, and you seem to be on top of this subject.

This one really got me concerned:
"(5) One cashier told me I'm "guilty" of "staturing" (I assume she meant structuring) for requesting the basis of her purported authority to refuse to cash less than $10,000.01 of chips without my showing ID. She also threatened confiscation of my chips, which included $1600 of chips from a different casino."

Confiscate your chips??? What could a person do if you are put in this situation other than yell at the top of your voice? This could be a nasty situation. Twisted Evil
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lvbear584



Joined: 07 Jun 2006
Posts: 140

PostPosted: Jul Tue 03, 2007 12:23 pm    Post subject: Chip confiscation Reply with quote

Confiscate your chips??? What could a person do if you are put in this situation other than yell at the top of your voice? This could be a nasty situation. Twisted Evil

MGM Grand in Las Vegas has done this at least three times that have been reported in the mainstream media. Twice the Gaming Control Board has ordered MGM Grand to pay the victim; the third case is still pending. Here's a link to more information, which includes links to the news articles about all three MGM Grand cases:

http://www.thebeargrowls.com/?p=56

To my knowledge, the only two northern Nevada casinos that have attempted to harass patrons in this unethical manner are the Peppermill Reno and the Lakeside Inn South Lake Tahoe.

Peppermill eventually backed down and paid when threatened with a Gaming complaint. Lakeside Inn refused to pay until ordered to do so by Gaming. Unfortunately, Gaming did not assess any penalty for the casino's despicable actions, so there is no disincentive for them to continue to do it.
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lvbear584



Joined: 07 Jun 2006
Posts: 140

PostPosted: Jul Tue 03, 2007 12:28 pm    Post subject: Gaming will continue to investigate refusals to cash chips Reply with quote

Another casino told me that the Nevada Gaming Control Board will no longer investigate refusals to cash chips if the casino claims its refusal is based on its interpretation of Title 31. If this is correct, the potential for abuse by casinos is enormous.

An email posted today on www.bj21.com Green Chip, re-posted here with permission.:

Your question regarding the redemption of chips relative to Gaming Regulation 6A and Title 31 was forwarded to me for a response.

As far as we're concerned the Board will continue to respond to patron complaints concerning a licensee's refusal to redeem their chips. We view this as more of a Gaming Regulation 12.060 issue than a 6A or Title 31 issue. Reporting issues under Title 31 may become an issue for the licensee, but the redemption of their chips is specifically addressed in Reg. 12 and we would expect the licensees to continue to abide by that regulation. At the same time we will continue to investigate complaints from patrons as we have done in the past.

Hopefully this addresses your question and concerns. Thank you very much for your interest.

Jerry Markling
Chief of Enforcement
Nevada Gaming Control Board
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Ryder



Joined: 05 Feb 2006
Posts: 222

PostPosted: Jul Thu 12, 2007 10:00 pm    Post subject: Reply with quote

I think lvbear584 should work for Dateline
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stan_allen



Joined: 19 Dec 2005
Posts: 1129

PostPosted: Jul Fri 13, 2007 8:25 am    Post subject: Growling Title Reply with quote

No, Dateline should work for lvbear584, and the show's name should be changed to "The Bear Growls".

John Stossel could run the exposé portion of the show.

visitreno.com board members can pose as patrons for the undercover stings.

Now I'm thirsty - Hey, bartender, give me one of those Singapore Stings.
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