That probably is an accurate amount of wagering for the casino to win $100 on average.
But it is also true that most players will bust out long before that. Everything is skewed because the volume of play generated by players on winning streaks, while losing streaks on $100 bankrolls are pretty short. If you looked at the number of players who lost exactly $100 on blackjack, the median amount of wagering would be much, much, much lower than that figure.
The “based on wagering” model is not the biggest problem here. The biggest problem is that the average lifetime player value decreases under this system because the old system was not a true 35%, it was much better.
BTW, Ryan seems like a nice guy but I don’t think the bosses over there lay awake all night trying to figure out how to pay us all more money!