Richard Kalm!
What is the purpose of this?  Now you are requiring rooms to provide itemized lists of expenses from the room.  This was just dropped in the lap of charities and now your people are meeting with room owners after the fact to tell them what to do.  No notice that this is happening?  What is the deal, are you not shutting down the rooms fast enough because there are many rooms that follow the rules?  Now you are just changes stuff on the fly so cause issues.

Next issues, how about some real direction on the new rules!  Your inspectors are going into rooms making rulings on processes that are devoid of all common sense.  Case in point:

Player wins a big pot and asks the charity for $5 in singles and hands the charity worker a $5 chips.  The charity then logs it as a $5 cash out.  The player then gives the dealer the $5 tip.

According to the inspector that was at a room recently, this is not allowed because it’s just like tipping with chips.  The inspector then told the room manager that they were to stop doing this.  How in the world would anyone make this leap????   The whole reason you imposed the “No tipping with chips” rule was to keep dealers from palming chips and cashing them out for cash later.

Did you do any thinking at all when you decide to make up rules?  The old way that most rooms employed was as follows:

Player wins a hand and drops a $1 chip into a tip cup.  This tip cup was never touched by the dealer.  After the dealers down/shift, another PLAYER would walk the tip cup up to the charity and cash out the cup.  The PLAYER would then hand the cash to the dealer.

I feel this is in line with your latest rule:

Effective September 1, 2013, tips may not be accepted in the form of chips. Cash tips will continue to be allowed; however, cash tips must be provided in accordance with Rule 409(11) which states, “A person employed by or an agent of a lessor, location, or licensed supplier may accept cash tips at a licensed millionaire party event.”

The dealer never accept the chips.  Can you guys not see this?  Oh wait, as stated in this blog by Sherri Welsh:

There are concerns, Kalm said, that dealers could swipe chips during games and then cash them in to the charity at the end of the night for hundreds of dollars.

Yes, and they could still do that now in a room where they don’t follow rules.  This changes nothing for your concerns Mr. Kalm!  If they room was allowing dealers to cash out chips for HUNDREDS OF DOLLARS before the changes, they would still do it after the changes.  You are only hurting the dealers and rooms that follow the rules.

How about this:  TRAIN THE CHARITIES and tell them that the dealers cannot cash in chips.  Remember, they are the ones that have the power to enforce all the rules.  The Michigan Charitable Gaming Association offered to work with you on a training project that could have helped.  You are worried about “improperly completed paperwork” but do nothing to help train the charities.

How about we all get a committee of charities, room owners, dealers and players to figure out the proper way to regulate the industry?  You could make some common sense changes that will help protect the charities, make it easier to regulate and will not destroy the industry.  Instead, you are trying to make these changes which only eliminate competition for casinos and do nothing to help charities at all.  Can you explain why you are trying to eliminate competition for casinos?

I’m sicken every time I think about what you are doing to the charities in Michigan.  Your wonderful Governor Snyder transferred oversight to you so that you could help keep charities from getting swindled and cheated since the MGCB was better suited to handle the industry.  Instead, you FAILED at your job completely.  Instead of trying to fix the industry, you are trying to regulate it out of existence with the proposed changes so you don’t have to do your job!

I guess since you were just reappointed to your position for another 6 years, you are guaranteed a check while charities lose out on this great fundraiser, dealers are losing on tips, and rooms will be forced to close because of your incompetence.

Sincerely,
Scott Miller
Charity Fundraising Chairman
Poker Dealer
Poker Player