As well, you have to love on page 44 the:
“5. Steps Taken to Minimize the Economic Impact on Small Entities
As discussed in the preamble to this final rule, the Agencies considered many approaches to minimize the burden of the rule on non-exempt participants, including small entities, while carrying out the mandates of the Act.”
First they fail to really describe what consitutes a “Small Entity” I’m assuming smaller banks. If thats the case its nice of this Admin to stick up for the “Little” guy. They ran the whole financial system to the shit, but hey we will give you a break and not keep you up to the higher standards of the “Big Entity” whomever they maybe.
At the end of the day after reading the regs they seem generally well thought out by rational people who don’t seem hell bent on destroying internet gambling and also don’t expect the banks to bend over backwards to stop everything. One thing I am missing in these final regulations are any references to IP blocking for ISP’s. That would truely be a killer. But zero refernces to it at all. Looks like the only reason Bush published these is to keep Obama from undueing UGIEA by executive order without it going before Congress first. As affiliates this maybe a blessing or a demise.