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MDawg
MDawg
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October 6th, 2026 at 8:19:22 AM permalink
I got the transcript of the April 23, 2026 hearing where these new regulations were adopted, but it doesn't answer the question.

What it does establish is that the wording of (i) was deliberate. Deputy AG Somps specifically corrected it to read “a negotiable instrument made payable to the patron,”

“I do want to correct a typo that's contained in Regulation 5.0472I where the word ‘payment’ is located or currently written. That should be replaced with the word ‘payable,’ so that entire provision would read, ‘a negotiable instrument made payable to the patron.’”

and the Commission then adopted that exact language.

So immediately before adoption, the draft apparently read:
“a negotiable instrument made payment to the patron”
which is grammatically nonsensical. He characterized the change as a typo correction, not a substantive change in the meaning of (i).

But there is a separate and much more interesting drafting change I mentioned above: the earlier February 5 version apparently used:
“a government or employer issued negotiable instrument”

whereas the final version became:
(h) A government entity; or
(i) A negotiable instrument made payable to the patron.

That is the substantive evolution worth investigating. The April 23 transcript only explains payment → payable; it does not explain why the earlier issuer-based limitation (“government or employer issued”) became the much broader-looking payee-based language (“made payable to the patron”).

And nothing says who must purchase the instrument, who must be the remitter, or that it must be funded from the patron's personal account.

So, as written, an LLC cashier's check made payable to ME and endorsed by me to the casino appears to fall within (i).

Whether Gaming intended that result is another matter. The transcript doesn't say.
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MDawg
MDawg
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Joined: Sep 27, 2018
October 6th, 2026 at 8:34:03 AM permalink
Quote: AutomaticMonkey

OK I get why a casino might not want to take corporate funding because of the potential of that kind of dispute, so why don't they just say "We don't accept any kind of corporate funding or credit?" What do they need legislation for?

Unless it's the kind of thing where one of the big players wants to implement the policy, but they're afraid a competitor with more risk tolerance is going to take all of that kind of action from them if they do, so they used their influence in the government to make everyone else do the same.
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The transcript also sheds some light on this.

It doesn't say that casinos pushed Gaming to adopt the rule because they were afraid of losing corporate-funded players to competitors.

What it does say is that this was developed jointly by Gaming and the casino industry over the better part of a year, through an AML working group involving casinos throughout Nevada. Gaming describes the purpose as addressing AML concerns, and specifically describes 5.047 as imposing “restrictions on business entities funding patrons' wagering activities.”

Chair Dreitzer also said the objective was to put “compliance over commerce.”

So apparently Gaming didn't want this left to individual casino policy and varying levels of risk tolerance. They wanted an industry-wide regulatory rule.

Whether part of the industry's motivation was exactly what you suggest—if we're going to stop taking this money, everybody else should have to stop too—the transcript doesn't say. But the casinos themselves were very much involved in drafting the rule.
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