I Don't Usually Say This...
But good for the Republicans:
Dear Secretary Paulson and Chairman Bernanke,
We are writing to request that you bring clarity to the Federal Reserve Board's (Board) and U.S. Department of the Treasury's (Treasury) proposed regulations to implement the Unlawful Internet Gambling Enforcement Act (UIGEA).
As proposed, these regulations do not provide clear guidance to the public, in particular those that engage in online skill games, or regulated industries regarding what constitutes "unlawful internet gambling." We believe that implementing such vague law and regulations, while holding the public and regulated industries liable for noncompliance, is an abdication of the federal government's responsibility to both the public and unregulated industries. In addition, vague UIGEA law and regulations could be unnecessarily burdensome and costly to the public and particularly small businesses.
Therefore, we urge the Board and Treasury to, before finalizing UIGEA regulations, clarify the specific activity that constitutes "unlawful internet gambling," providing guidance to both the public and the regulated industries that are tasked with blocking financial transactions related to "unlawful internet gambling." It is our understanding that the UIGEA intended to uphold state and federal laws regarding "unlawful internet gambling" that existed prior to UIGEA's date of enactment. Nevertheless, we encourage the Board and Treasury to confirm our understanding in its UIGEA regulations. To accomplish this, we request that you take the following actions.
First, transition the current rulemaking process to a formal rulemaking process involving an Administrative Law Judge (ALJ) or a similar official who can provide legal advice. This official should examine the various federal and state laws and determine precisely what constitutes "unlawful internet gambling" as well as which financial institutions a regulated industry is required to block under UIGEA law and regulations.
Second, we request that undertake Regulatory Flexibility Analysis to clearly evaluate the regulatory burden that would be imposed on businesses of all sizes but especially small businesses.
Simply put, we believe that it is possible that if UIGEA law and regulations are implemented with the vague language we described above, a judge may be eventually required to answer the question of "what is unlawful internet gambling." It makes fiscal sense to resolve this question before saddling the public, regulated industries, small businesses, and courts with uncertain UIGEA law and regulation.
We voted for UIGEA and support it now. As such, we have resisted legislative efforts which may have the effect of delaying interminably the implementation of UIGEA and its regulations. However, we are concerned about the legal and operational viability of a rule that leaves so much to interpretation and, accordingly, urge the Board and Treasury to take a more deliberative path to a workable rule as we have outlined in this letter.
Thank you for your consideration of our request. We look forward to your response.
Sincerely,
Judy Biggert
Jim Gerlach
Christopher Shays
Kevin McCarthy
Oh... and I'm still voting for Obama.
Thursday, July 31, 2008
Tuesday, July 29, 2008
A Sort of Homecoming
What a difference a few thousand miles can make.
I was up at 6:30AM in Dublin. It was already light and it had rained overnight. The temperature was around 70 - comfortable - as I hit the shower and did my very last minute packing. An hour later, I was in a cab traveling through the overcast city on the way to the airport. My final ride in Dublin. At least for the foreseeable future.
Ten hours later, I arrived at JFK where the temperature was a balmy 91 and the humidity was at least 80 percent. Hazy, hot and humid - a standard NYC summer day. My body is going to take some time to adapt, but one thing is for certain - stepping into that muggy parking lot outside the terminal felt like home. As did the ride from Kennedy to my mother's house in suburban Westchester County.
Idiots traveling at 60 MPH in the left hand lane. Pimped out Toyotas, Volkswagens and Escalades weaving through traffic. The countless black Lincoln Towncars making their myriad runs to and from the airports. People flipping the bird, shaking fists out the windows, tailgating. Chaos. Home.
Of course, as I sit here in the bedroom where I grew up, I realize this place isn't really home anymore. At least, not for me. It's most definitely my mother's house - she's lived here nearly 45 years, the last 20 of them on her own. Sure, it still looks pretty much the same from the outside, but when I walked in this afternoon, there were two electricians in finishing up the wiring in her brand new kitchen. It's modern and sleek. She's even put in a wine fridge. I don't recognize the place at all. Of course, the paint and wallpaper all look the same - at least for now. She's redoing all the walls next month.
By then, however, I'll be gone again. Off to Las Vegas, my new home, a glittering city in the middle of the desert a few thousand miles away.
What a difference a few thousand miles can make.
I was up at 6:30AM in Dublin. It was already light and it had rained overnight. The temperature was around 70 - comfortable - as I hit the shower and did my very last minute packing. An hour later, I was in a cab traveling through the overcast city on the way to the airport. My final ride in Dublin. At least for the foreseeable future.
Ten hours later, I arrived at JFK where the temperature was a balmy 91 and the humidity was at least 80 percent. Hazy, hot and humid - a standard NYC summer day. My body is going to take some time to adapt, but one thing is for certain - stepping into that muggy parking lot outside the terminal felt like home. As did the ride from Kennedy to my mother's house in suburban Westchester County.
Idiots traveling at 60 MPH in the left hand lane. Pimped out Toyotas, Volkswagens and Escalades weaving through traffic. The countless black Lincoln Towncars making their myriad runs to and from the airports. People flipping the bird, shaking fists out the windows, tailgating. Chaos. Home.
Of course, as I sit here in the bedroom where I grew up, I realize this place isn't really home anymore. At least, not for me. It's most definitely my mother's house - she's lived here nearly 45 years, the last 20 of them on her own. Sure, it still looks pretty much the same from the outside, but when I walked in this afternoon, there were two electricians in finishing up the wiring in her brand new kitchen. It's modern and sleek. She's even put in a wine fridge. I don't recognize the place at all. Of course, the paint and wallpaper all look the same - at least for now. She's redoing all the walls next month.
By then, however, I'll be gone again. Off to Las Vegas, my new home, a glittering city in the middle of the desert a few thousand miles away.
Monday, July 28, 2008
Resurrection
Yes, I know. I've said it before. I'm back. This time, I'm really going to give this the time and attention it deserves. I'm going to take a real shot at making this a worthwhile blog.
It's all been bullshit. I know that. You know that. Let's just call it water under the bridge and move on from there.
The fact is, I really have wanted to make this a worthwhile blog each and every time I've started (or restarted) posting here, but when you write for a living, the last thing you want to do is come home and write some more. At least, that's the last thing I wanted to do.
Now, however, I am at least temporarily unemployed. My contract is over. I've left my job of the last 40+ months and I'm sitting in a near empty Dublin apartment counting the hours until I fly back home to the states. It's been a good run, this last job, and I've done some work I'm proud of. I've worked with some great people and for a company that I truly like... it will be sad to leave the people and the job behind. Ireland, not so much, however.
It's not like Dublin is a bad city or that the Irish are bad people. Most folks here have been unfailingly nice, and the city is OK if you've never lived anywhere bigger than say, Podunk, Iowa. For someone who's spent any kind of time in places like New York, LA, San Francisco or even Des Moines, Dublin is just too small and dull to be a "livable" city. Sure, there's a pub on every corner and some pretty good music scattered around, but really, how much can you drink once you pass the age of 30 and your name's not Al?
Thankfully, there's a pretty good local poker scene in town, and I spent more than a few hours at the tables. I won some. I lost some and I made a few really good friends. For those times when I just had to get away, braving the foibles of Dublin airport put most of Europe just a few hours away. It's sad though when one of the best things you can say about a city is that it's easy to leave.
And leaving is what I'm doing now. For good this time. Sure, maybe I'll come back to visit, but tomorrow morning's cab ride to the airport is sure to be my last for quite some time, and that doesn't bother me a bit. It's been two years since I left my friends and family in the states, and that's long enough for me. I'm ready to go back and see where the road takes me. I don't have much in the way of plans laid out right now. I'm taking August off to wander up and down the eastern seaboard; Maine, Boston, NY, Philadelphia, Maryland and beyond. After that, it's a move back to the western US. Not California this time, but rather, Las Vegas.
I don't have any full time jobs lined up right now. Freelancing will be the name of the game to start. Oh, and I'll play some cards too. Not big stakes, and certainly not as my primary source of income. Hopefully I can grind some extra spending money that will give me the freedom to figure out what I want to do next and to maybe do some writing for myself. Here and in other formats long forgotten.
It's not much of a plan, but it's enough for me right now.
So, if anyone is still tuning into this little corner of the web, welcome back. I'll try to do better than I did before.
Yes, I know. I've said it before. I'm back. This time, I'm really going to give this the time and attention it deserves. I'm going to take a real shot at making this a worthwhile blog.
It's all been bullshit. I know that. You know that. Let's just call it water under the bridge and move on from there.
The fact is, I really have wanted to make this a worthwhile blog each and every time I've started (or restarted) posting here, but when you write for a living, the last thing you want to do is come home and write some more. At least, that's the last thing I wanted to do.
Now, however, I am at least temporarily unemployed. My contract is over. I've left my job of the last 40+ months and I'm sitting in a near empty Dublin apartment counting the hours until I fly back home to the states. It's been a good run, this last job, and I've done some work I'm proud of. I've worked with some great people and for a company that I truly like... it will be sad to leave the people and the job behind. Ireland, not so much, however.
It's not like Dublin is a bad city or that the Irish are bad people. Most folks here have been unfailingly nice, and the city is OK if you've never lived anywhere bigger than say, Podunk, Iowa. For someone who's spent any kind of time in places like New York, LA, San Francisco or even Des Moines, Dublin is just too small and dull to be a "livable" city. Sure, there's a pub on every corner and some pretty good music scattered around, but really, how much can you drink once you pass the age of 30 and your name's not Al?
Thankfully, there's a pretty good local poker scene in town, and I spent more than a few hours at the tables. I won some. I lost some and I made a few really good friends. For those times when I just had to get away, braving the foibles of Dublin airport put most of Europe just a few hours away. It's sad though when one of the best things you can say about a city is that it's easy to leave.
And leaving is what I'm doing now. For good this time. Sure, maybe I'll come back to visit, but tomorrow morning's cab ride to the airport is sure to be my last for quite some time, and that doesn't bother me a bit. It's been two years since I left my friends and family in the states, and that's long enough for me. I'm ready to go back and see where the road takes me. I don't have much in the way of plans laid out right now. I'm taking August off to wander up and down the eastern seaboard; Maine, Boston, NY, Philadelphia, Maryland and beyond. After that, it's a move back to the western US. Not California this time, but rather, Las Vegas.
I don't have any full time jobs lined up right now. Freelancing will be the name of the game to start. Oh, and I'll play some cards too. Not big stakes, and certainly not as my primary source of income. Hopefully I can grind some extra spending money that will give me the freedom to figure out what I want to do next and to maybe do some writing for myself. Here and in other formats long forgotten.
It's not much of a plan, but it's enough for me right now.
So, if anyone is still tuning into this little corner of the web, welcome back. I'll try to do better than I did before.
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