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gordonm888
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gordonm888
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May 7th, 2016 at 12:22:32 PM permalink
Quote: mrsuit31

Start by reading the Indian Gaming Regulatory Act...



I have scanned this and also read about it in Wikipedia. I have gone into the Federal Register to search documents from the National Indian Gaming Commission and have gone onto legal sites to try to understand more about North Carolina laws regarding gaming regulation.

Briefly, this is what I found;

The Indian Gaming Regulatory Act defines casino gambling as Class III Gaming and defines Bingo and similar activities as Class II gaming. Bizarrely, the regulation of Class II gaming (Bingo) is left to the Federal Government and is performed by the National Indian Gaming Commission. The regulation of Class III Gaming is left to the States and is to be executed through State-Tribal Pacts. Items to be regulated that are specifically called in law are out are: money transactions, financial reporting, background checks on casino employees and rules related to prevention of money laundering. The purpose of "ensuring that games are honest" is expressly mentioned in the law as one of the purposes for regulation but I have not found any specific requirements regarding "ensuring honest games" that are mentioned in the Indian Gaming Regulatory Act. Presumably this is left to the State-Tribal Pacts.

North Carolina has a record of strictly forbidding gambling of any kind. No sports betting, Bingo or online gambling has ever been permitted. Until 2009 the only type of gambling in the state was the one Indian casino. In 2009 a state lottery was approved and a year or two ago a second Indian casino opened. That's it -there has never been any other gaming activity for NC State to regulate. So far, I have been unable to identify a NC State office or agency that regulates gaming -but that doesn't mean it doesn't exist. I just haven't found it yet.
So many better men, a few of them friends, are dead. And a thousand thousand slimy things live on, and so do I.
MathExtremist
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May 7th, 2016 at 12:27:18 PM permalink
Quote: RS

There's a guy on BJTF (BJGenius007) who's been saying this kind of nonsense for a while now, particularly regarding blackjack, where the ASM clumps the cards. But, he also has absolutely no proof, likely blaming the machine for bad variance.

Innumeracy + confirmation bias + mistrust of gaming regulators = conspiracy theory.

Also, since the shufflers use true random number generators based on the decay of radioactive particles like Cesium-137, you should always sit on the far side of the table from the card shufflers to avoid radiation poisoning.
"In my own case, when it seemed to me after a long illness that death was close at hand, I found no little solace in playing constantly at dice." -- Girolamo Cardano, 1563
mrsuit31
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May 7th, 2016 at 1:00:47 PM permalink
Quote: MathExtremist

Innumeracy + confirmation bias + mistrust of gaming regulators = conspiracy theory.

Also, since the shufflers use true random number generators based on the decay of radioactive particles like Cesium-137, you should always sit on the far side of the table from the card shufflers to avoid radiation poisoning.



In virtually all compacts they also expressly state that the facilities must follow a set of Minimum Internal Controls (MICs). These would include equipment use and approval.

Most of the time you can pull the compacts up on the state websites and review the actual contracts. However, I'm not sure if you can pull the MICs...
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gordonm888
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gordonm888
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May 7th, 2016 at 1:01:02 PM permalink
Quote: MathExtremist

If a top-tier vendor like Sci Games gets caught doing something fishy in some remote gaming jurisdiction, their manufacturing license is in jeopardy not just in that jurisdiction but in Nevada and everywhere else. The Nevada Gaming Control Board has the absolute authority to revoke any vendor's license if they deem the vendor "unsuitable" for any reason. E.g., in 2013 the California gaming regulators issued a finding of unsuitability for Galaxy Gaming (specifically Rob Saucier) based primarily on actions in Washington state. Nevada has issued several million+ dollar fines for failing to have sufficient internal controls to prevent money laundering, or for the unauthorized use of a slot key in another casino's machines (without changing anything). Imagine what they'd do if it were discovered that SHFL's shufflers were actually rigged. For a publicly-traded company like Scientific Games (the parent of Bally and therefore SHFL) the risk is far too great relative to the potential gains.

And there aren't any potential gains. After all, what's in it for SHFL to provide a gaffed shuffler like that? They lease the units to casinos for a flat amount, not a percentage of win, so it doesn't matter how well the game performs. SHFL makes the same amount regardless. Does it seem plausible to you that the executives of a publicly-traded company would put a significant chunk of revenue on the line (and invite a massive shareholder lawsuit) just so a handful of customers could make a few extra bucks per month?



Got it. I understand - there are major business disincentives for SHFL to do this and little apparent incentive to do so. I think this is a very good argument.

Quote:


You didn't answer my question from before. What are your source's qualifications, and why do you believe them over your own common sense?



Regarding my source's qualifications, they are casino-specific -but I won't say any more than that. Sorry, I am protecting my source. Also, I have not been pounding on my source's credentials and asking people to believe this.

I have maintained a degree of skepticism about what my source told me because I know that people have a natural tendency to b---s--t about stuff like this in order to seem important and "in the know." I also realize that sometimes people will know "a little bit" and make up stuff to fill in the blanks in the story -which can lead to an erroneous or highly-distorted picture.

But what leant an air of credibility to what I heard was the amount of detail in the account and the manner and tone it which it was told to me. We all have a built-in lie detector that we use every day of our lives, and I did not immediately dismiss what was said to me as a lie.

So, my question is: Who is in charge of assuring that the games in this NC casino are honest? Is this a credible story? (many in this forum are of the opinion it is not and they have been pretty persuasive) And if we had a casino in a state with no history of gaming regulation, is it possible that abuses might occur?
So many better men, a few of them friends, are dead. And a thousand thousand slimy things live on, and so do I.
gordonm888
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gordonm888
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May 7th, 2016 at 1:58:11 PM permalink
Okay. Big news. There apparently is NO regulation by North Carolina State of the Cherokee casinos.

Here is an internet link to the Eastern Band of Cherokee Indians/ North Carolina State Pact establishing the right to the have a casino. Its only one page of text and a second page of signatures -so click on this and read it!

EBCI/North Carolina Pact

The phrase important to our discussion is:

"WHEREAS, existing regulatory controls and criminal sanctions are adequate to fill the policies and purposes set forth in the Compact."

Therefore, the right to a casino was granted by the State of North Carolina without requiring that its operation be subject to the authority of any specific state regulatory agency. "Existing regulatory controls" were agreed to be adequate in a state that had never had any prior gambling activity of any kind.

On August 3, 2012 there is a Federal Register notice announcing the Dept of Interior's approval of an expansion of this pact to include allowing "table games with dealers." I cannot find a copy of the text of this expansion agreement, but newspaper articles report that the amendment to the pact defined the fraction of casino revenue from these games that would go to public education in North Carolina.

I am trying to keep an open mind, but I am concluding that North Carolina Indian casinos are indeed "unregulated." I realize that is completely contrary to the situation in many other states.
So many better men, a few of them friends, are dead. And a thousand thousand slimy things live on, and so do I.
mrsuit31
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May 7th, 2016 at 2:03:30 PM permalink
Quote: gordonm888

Okay. Big news. There apparently is NO regulation by North Carolina State of the Cherokee casinos.

Here is an internet link to the Eastern Band of Cherokee Indians/ North Carolina State Pact establishing the right to the have a casino. Its only one page of text and a second page of signatures -so click on this and read it!

EBCI/North Carolina Pact

The phrase important to our discussion is:

"WHEREAS, existing regulatory controls and criminal sanctions are adequate to fill the policies and purposes set forth in the Compact."

Therefore, the right to a casino was granted by the State of North Carolina without requiring that its operation be subject to the authority of any specific state regulatory agency. "Existing regulatory controls" were agreed to be adequate in a state that had never had any prior gambling activity of any kind.

On August 3, 2012 there is a Federal Register notice announcing the Dept of Interior's approval of an expansion of this pact to include allowing "table games with dealers." I cannot find a copy of the text of this expansion agreement, but newspaper articles report that the amendment to the pact defined the fraction of casino revenue from these games that would go to public education in North Carolina.

I am trying to keep an open mind, but I am concluding that North Carolina Indian casinos are indeed "unregulated." I realize that is completely contrary to the situation in many other states.



This seems to be an add on to the "original compact" they refer to several times in that single page. I would assume that "original compact" sets out those controls they reference.

Edit: The title and first paragraph make it clear there is a previous compact that this is simply adding the right to have electronic bingo and electronic raffle games.

This document is not "the compact".
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Wizardofnothing
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May 7th, 2016 at 2:16:19 PM permalink
Why are you suddenly so concerned about this- just curious- you seem to be really bothered by what your friend told you
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MathExtremist
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May 7th, 2016 at 3:20:21 PM permalink
Quote: gordonm888

Okay. Big news. There apparently is NO regulation by North Carolina State of the Cherokee casinos.

Tribal sovereignty precludes it. That's like suggesting that the Nevada Gaming Commission has the authority to regulate the casinos in Canada or Germany.

But if you think the casino is wholly unregulated, that's factually wrong:
http://www.cherokee.org/OurGovernment/Commissions/GamingCommission/AbouttheCommission.aspx
"In my own case, when it seemed to me after a long illness that death was close at hand, I found no little solace in playing constantly at dice." -- Girolamo Cardano, 1563
gordonm888
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gordonm888
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May 7th, 2016 at 4:16:52 PM permalink
Quote: mrsuit31


This seems to be an add on to the "original compact" they refer to several times in that single page. I would assume that "original compact" sets out those controls they reference.

Edit: The title and first paragraph make it clear there is a previous compact that this is simply adding the right to have electronic bingo and electronic raffle games.

This document is not "the compact".



Hmm, you are correct, good catch.

After considerable research, here is the current complete pact netween NC and the EDCI as fully amended to include the regulations on Table Games

Current Version of NC/Cherokee Pact

The full pact has a long list of regulations on video games and slot machines including requirements for certification of video game equipment by an accredited external laboratory. There is a short section, Section 6 D, on Regulation of Table Games, requiring that any table game devices be compliant with 25 CFR 542.12 and that 25 CFR 542.12 shall serve as the Minimum Internal Controls for Gaming Equipment on.

In all of the pact, there is no language about automated shufflers or external certification testing of any equipment other than slot machines and video games. This is also true for the Federal Regulations promulgated in 25 CFR 542.12. Here is a link to those regulations.

Minimum Internal Controls For Live Table Gaming 25 CFR 542.12

The current version of the pact does indeed establish a Certification Commission, jointly appointed by the Tribe and the NC Governor, to approve casino equipment and to review any issues . It is comprised of three appointees who shall be paid $9,000 to $12,000 per year and who must meet at least quarterly!

But that is it -that is the only regulatory body created in the pact. Three political appointees who meet 4 times per year.

And no requirements regarding automated shufflers.
So many better men, a few of them friends, are dead. And a thousand thousand slimy things live on, and so do I.
MathExtremist
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May 7th, 2016 at 5:00:35 PM permalink
Quote: gordonm888

In all of the pact, there is no language about automated shufflers or external certification testing of any equipment other than slot machines and video games.
...
And no requirements regarding automated shufflers.

Read more closely:
Quote: Cherokee Compact, Section 6, REGULATION OF GAMING ACTIVITY

(D) Regulation of Live Table Gaming
(3) All equipment utilized in the conduct of live table gaming must receive approval and certification from the Tribal Gaming Commission prior to being placed into operation



I get the sense that you're trying to demonstrate that the Cherokee casino is crooked. Why exactly is that?
"In my own case, when it seemed to me after a long illness that death was close at hand, I found no little solace in playing constantly at dice." -- Girolamo Cardano, 1563

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