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Washington residents: Please ask the Washington Gambling Commission to allow NLHE

I've submitted a comment to the Gambling Commission requesting a change in the rules. You can do the same through this form. It doesn't require an act of Congress - it only requires a boring administrative process to be initiated! We can do this!

Currently, Washington Administrative Code (WAC) 230-15-135 restricts the number of wagers per round of betting at four (Section 1(b)) and the maximum size of a wager to $300 (Section 1(c)). As I'm sure you have figured out, this effectively makes NLHE dead in Washington. There's a better poker scene in New Mexico, for God's sake.

So here's the deal: a WAC is established by the appropriate agency, which in this instance is the Gambling Commission. The Revised Code of Washington (Section 11 at the URL) is how the state Legislature provides the Gambling Commission the authority to set the rules referenced above. But it's the Commission that decides what the rules are, and the Commission can entertain rule changes from the public. The Commission just makes the rules up.

As it happens, I am a Washington state employee. So trust me when I say that being an asshole in these rule change requests won't get you very far. But also know that people are willing to change these rules - they just have to be convinced why it needs to be changed, because without a sufficiently clear reason to change it, there's a tendency to stay with the status quo.

So fellow Washingtonians, please ask them to change the rule! And if you think you've given a fairly good pitch to them, please share it here. Thanks!
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Comments

  • pepguardiolapepguardiola Posts: 21Subscriber
    Hi everyone, I just wanted to provide an update. I’ve been contacted by the gambling commission to discuss this matter next week. My argument will be centered around how a capped game effectively makes turn and especially river play non-existent.

    Does anyone have any talking points I should adopt?
  • dpbuckdpbuck Posts: 2,060Subscriber
    I lived in Washington for just over 12 years before recently moving to Texas. I have a lot of experience in those Spread Limit Games. Generally speaking, is the point of your conversation to explain why moving from SL to NL better for the poker economy, or better for the state, or both?

    I'd imagine we want to take the tact of pointing to successful poker economies across the country. Washington is larger in population and overall economy (GDP) than a lot of states with "booming" poker economies: Wisconsin, Iowa, and Oklahoma all have smaller populations and lower standards of living, but have thriving poker economies, generating revenue for participating parties and communities. The spread limit caps stunt poker growth.

    I'd also image we want to stay away from the poker strategy talking points (such as river play non-existent). Unless the gaming commission is looking at this straight through the lens of strategy diversification, I don't see the benefit of that point. Capped/Spread Games are just a different strategy. Meaning if we take that tact that we need to remove betting caps, then we effectively are saying all limit games are "less strategic", which we all know isn't the case.

    Those are my two cents anyway. I've shared this post with some of my poker playing friends still in Washington for their thoughts as well.
  • pepguardiolapepguardiola Posts: 21Subscriber
    dpbuck wrote: »
    I lived in Washington for just over 12 years before recently moving to Texas.

    I am originally from Texas and moved up here!

    Thanks for your response, I think you’re right. I don’t want to strike a snobby tone; I just want to make the point that it’s a Solomon-esque “solution”.

    I’m not sure how much of the commission’s interest will be placed in improving the state’s “poker economy”, but it couldn’t hurt. Thanks for the useful comparison states, and for flagging this for your friends.
  • pepguardiolapepguardiola Posts: 21Subscriber
    I may as well leave this story from tonight that illustrates the stupidity of these regulations quite well.

    I'm at an action table where most everyone is between 25 and 40. We've got a 7-2 $5 bounty going and one guy has been badgering everyone to get a straddle going. Table is 6-handed.

    I'm in the BB and UTG straddles to $6. So the guy to his left straddles to $9. And then the guy to his left straddles to $12. This means that the button is facing three straddles, is first to act, and is forbidden from raising, because bets were capped before a single card was dealt.
  • brickbrick Posts: 129Subscriber
    Limits in Washington have consistently increased over the years. From 24 to 40 to 100 and now 300. Asking for a 500 limit with 5 bet cap would be the mostly likely to be approved. Of course you could ask for the moon but it might not be approved.
    Thanked by 1CycleV
  • JS84JS84 Posts: 33Subscriber
    brick wrote: »
    Limits in Washington have consistently increased over the years. From 24 to 40 to 100 and now 300. Asking for a 500 limit with 5 bet cap would be the mostly likely to be approved. Of course you could ask for the moon but it might not be approved.

    This might be a good solution if they are reluctant to make it no limit. I live in AZ, and we only have spread limit, but the bet limits are 100BB ($2/3 max bet is $300, $3/5 max bet is $500, one casino has an unposted $5/10 that plays everyone once in a while, but I have no idea the limits there). It plays pretty much like no limit. Occasionally you'll see two guys with deep stacks in a pot and there be multiple max bets, but usually a max bet is effectively an all-in for one of the players. We also have a cap at 4 bets (original plus 3 raises), but pretty rare that you see a need for a 5-bet at most of these games.

    Just curious, what are the blind in this $300 max bet game?
  • brickbrick Posts: 129Subscriber
    1-3 300 max bet
  • CycleVCycleV Posts: 1,196Subscriber
    I may as well leave this story from tonight that illustrates the stupidity of these regulations quite well.

    I'm at an action table where most everyone is between 25 and 40. We've got a 7-2 $5 bounty going and one guy has been badgering everyone to get a straddle going. Table is 6-handed.

    I'm in the BB and UTG straddles to $6. So the guy to his left straddles to $9. And then the guy to his left straddles to $12. This means that the button is facing three straddles, is first to act, and is forbidden from raising, because bets were capped before a single card was dealt.

    This isn't about the SL regulations, this is about a dumb casino rule that allows multiple straddles. Getting the casino to only allow one straddle max would prob be an easier fix.

    Yes, this could still be circumvented by blind raises vs straddles, but I'm not too worried bout 1/3 donks figuring this out.
  • brickbrick Posts: 129Subscriber
    I haven't played at a casino in Washington that allows more than one straddle. Multiple blind raises yes....
    due to the four bet cap I have seen lots of straddles and two blind raises to cap the betting PF.
  • pepguardiolapepguardiola Posts: 21Subscriber
    CycleV wrote: »
    This isn't about the SL regulations, this is about a dumb casino rule that allows multiple straddles. Getting the casino to only allow one straddle max would prob be an easier fix.

    If you want to be pedantic, in this particular instance it’s both the law and the casino. But it’s not as if my chief objection to the max on number of bets is centered around these straddle scenarios. If the casino didn’t allow straddles at all, I’d hate the rule and would still want it changed. This straddle scenario merely highlights its absurdity.
  • pepguardiolapepguardiola Posts: 21Subscriber
    edited February 2018
    Hi guys, just another update.

    The Gambling Commission has agreed to hear my petition at the February 8 open meeting. I'm preparing a memo to present.

    The way this will work, if I'm successful, is that the commissioners will order the commission staff to begin a rulemaking process.

    This is a formal process where the staff and interested parties reflect upon what the law actually says (i.e., the Revised Code of Washington), and the staff determines whether the administrative rules need to be modified. Those administrative rules are the Washington Administrative Code.

    Usually, these processes are begun when an interest group or a company in the industry files a complaint. So it's a little funny that it's just a guy that wants to play poker the way it's meant to be played.

    The law, as the legislature wrote it, (RCW 9.46.010) requires that the commission regulate gambling in order "to promote the social welfare of the people by limiting the nature and scope of gambling activities". This is the commission's raison d'etre. You can see why something called "no limit hold'em" would be seen as antithetical to "limiting the nature and scope of gambling activities".

    The staff of the commission is reluctant to recommend a new rulemaking process, because the administrative code on this matter was changed fairly recently, in 2016. The casinos asked the commission to increase the maximum bet size from $100 to $300, I think. Or, at least, that was the outcome of the process. One of the takeaways from the process, according to the attorney, is that the commissioners were interested in limiting losses on a single hand to $1200.

    So I'm simply going to recommend that if they still want to do that, they should limit buy-ins to $1200.

    I'm also going to argue that the restriction on bet sizes makes it impossible for a player to play a hand in a mathematically correct manner, and that this is not good for social welfare. (If you have 88 vs. KQ on a JT23 board, you can't make a correct bet in a $450 pot on the turn, for example, because you can't bet more than $300.)

    Given some of the correspondence with the attorney (who has been helpful), I'm not sure of the sophistication of my audience, so developing my argument for the meeting has been challenging. The commissioners are part-time employees who have main jobs; public records suggest they get paid maybe $3000/yr for being commissioners. One commissioner is a firefighter in his main job, for example.

    Although I don't think the argument that "no one can make a living playing poker in this state" would be an effective one, I will have to shy away from coming close to that argument, because the law also states that it's intent is to "restrain all persons from seeking profit from professional gambling activities in this state". I would think a strict interpretation of that would make casinos illegal, and its not clear to me what the intent there is. But it would see the legislature doesn't want any Bart Hansons here.

    So, that's where things are now. Wish me luck on Thursday.
    Thanked by 2dpbuck CycleV
  • pepguardiolapepguardiola Posts: 21Subscriber
    Update, post 1 of 3
    Time for another update! Unfortunately, my petition was unanimously rejected. I've broken this update up into three posts, due to the length. The third post will contain my prepared remarks.

    There are 5 commissioners on the commission, but you need 3 to get a petition approved. Except today, only 3 commissioners were present, so I needed to go 3-0. Tough task.

    Chairman Sizemore seemed to best understand and appreciate my argument. But given my experience with state commissions, it's not unusual for the chair of the commission to be reserved in their commentary unless there is a split vote amongst the other commissioners, and so he didn't have much to say. The one point of critique he offered is that if the rules were moved to have a $1200, another request would soon come in to raise it to $5,000, or $10,000. Chairman Sizemore voted last, and like the others voted to reject, but I suspect that's more because a "yes" vote wouldn't have changed the outcome.

    Commissioner Troyer was very skeptical of my petition. He was worried about "big stacks bullying other players". He wasn't convinced by my proposal to limit buy-ins to $1200, arguing that if two winning players had $4500 each, either one of them could make a single $4500 bet. I responded that it is possible for a single player to lose $4500 in a given hand under the current rules, which he sort of wrinkled his nose at. Commissioner Troyer also adopted the "slippery slope" argument. I found him particularly frustrating. When the Commissioners are deliberating, you of course don't interrupt them. But there no longer is an opportunity at that point to respond to the deliberations they're having between themselves, so I couldn't interject to point out that a casino or a card room would likely impose their own caps on buy-ins - just as they do now.

    Commissioner Patterson had three points in her vote to reject the petition: 1) it may, in the Legislature's eyes, amount to an expansion of gambling activity that the Legislature didn't intend to empower the Commission to do; 2) the matter was recently the subject of a rule-making in 2016, when the max bet was increased from $100 to $300; and, 3) the $1200 buy-in limit was not a sufficient limit, given their typical framework that they are in the business of limiting the size of wagers.
  • pepguardiolapepguardiola Posts: 21Subscriber
    Update, post 2 of 3
    I was pretty disappointed that no commissioner asked me to elaborate on the unintended consequences and reckless play that I alluded to in my remarks. I was also disappointed that they seemed unaware that plenty of states have the sort of rules I proposed (or even ones that were less restrictive), and they manage to do fine. I wish I had made that point in my prepared remarks, and was kicking myself for not doing so.

    Another point I was kicking myself about not making is that, in the 2016 rulemaking they had, its quite unlikely they ever had a participant in the process representing the interests of poker players. That rulemaking was initiated because of a request from the casinos and card rooms, but as you are all aware, they don't necessarily have poker players' interests in mind.

    The commission staff member that spoke on the matter (who recommended the Commissioners reject my petition) also argued that the limit on a $1200 was poorly defined - could someone just buy in again an hour later for another $1200? She hypothesized a $1200 in 24 hours rule, without endorsing one.

    I think Commission staff's disapproval of my petition is rooted in a few elements:
    - they just had a rulemaking on this recently;
    - it would be more work for them;
    - they don't understand my point;
    - they didn't bother to research how other jurisdictions handle this matter.

    I'm pretty disappointed in how it appears the Commission staff handled this matter. No member of staff, other than the attorney (who was very helpful) bothered to reach out to me. In fairness, perhaps because of the recency of the 2016 rulemaking on this, they were already familiar will these arguments and how other jurisdictions handle these things - and they just understood that it was a non-starter with the commissioners.

    The attorney offered to put me in touch with some legislators and gaming industry stakeholders (i.e., casino white-collar types) that may be interested in working with me to get some legislation going. That will take years, but I'm up for it I think. I believe the standard to change the law on matters like this is a 60% threshold. (I would argue the statute itself doesn't need to be changed, there just needs to be an update regarding legislative intent.)
  • pepguardiolapepguardiola Posts: 21Subscriber
    Update, post 3 of 3
    Prepared remarks:
    Washington state does not have legal no limit hold’em. It has something that sort of, kind of, maybe in a certain light, looks like no-limit hold’em, the way a game of kickball looks like a baseball game from far away. It has a form of hold’em, bound by all too prescriptive rules that come with their own unintended consequences.

    What do I mean by all this?

    The singular, defining characteristic of no-limit hold’em is that, at any point in the hand, you or your opponents can put their entire stack of chips in play. This single characteristic colors the entire character of the game; it shapes the math of the game. It is the essence of the game. The mere possibility that the next bet can be for your entire stack of chips shapes how you should approach each and every hand. It’s what gave the game its nickname, “The Cadillac of Poker.”

    I understand the Commission’s raison d’etre is “to promote the social welfare of the people by limiting the nature and scope of gambling activities”. And I understand the concern that a game with “no limit” in its name is seen as antithetical to this principle of limiting the nature and scope of gambling activities.

    I can understand how one may believe that limits on the number of bets, and on the size of bets, are appropriate to meet this principle. I’ve petitioned you, and I’m here before you today, to convince you that this is a false dichotomy. The “social welfare of the people” is undervalued under the current rules, and the current rules to not achieve the intended goals. They even have some unintended negative consequences.

    The prescriptive rules I’ve mentioned are two specific ones. First, the restriction on the number of bets in a given round of betting is capped at four.

    Second, the size of any given raise is capped at $300. This is the more egregious of the two.

    These restrictions restrain players, in all too frequent circumstances, from performing some of the essential strategic tasks in the game. The flexibility to make a bet of a size that denies the opponent the proper odds to continue in the hand with a positive expected value is key. The current rules prohibit this in many circumstances.

    The nature of “The Cadillac of Poker” I described above is absent from what casinos and card rooms in Washington misleadingly, if unintentionally, call no-limit hold’em. What is played here in Washington is something functionally more like “spread-limit hold’em” - a vastly less popular form of the game that is played almost exclusively in areas where regulations prevent no-limit hold’em from existing. There is, for example, no World Series of Poker event for spread-limit poker.

    In some reasonably frequent circumstances, I think these rules achieve the opposite of their intended ends, leading players to lose more money than they otherwise would. I’d be happy to provide such an example upon request. The restrictions create circumstances where it is mathematically impossible for the player with the best hand to play correctly, because he has been deprived of the ability to shape the size of the bet appropriately to the size of the pot.

    When this happens – when the player with the best hand cannot, mathematically, play the game correctly - the game is no longer a game of skill. It is simply a lottery. And in many circumstances, the rules unintentionally encourage reckless play. This is not good for social welfare.

    There are four rounds of betting in a hand of hold’em, and if players were to make the maximum bet size of $300 for each of four bets on four rounds of betting, a player could theoretically lose over $4500 in a given hand. If the goal was to limit losses in a given hand to $1200, the current rules do not achieve those ends.

    The maximum bet size is not the appropriate unit of analysis. The Commission should completely abandon concerns about bet size, at least in the scope of this game. There is a much simpler, less intrusive way to abide by the principle of “limited scope and nature”, while also letting the game breathe.

    The Commission should simply restrict the maximum buy-in from a given player to $1200 in any game of no-limit hold’em. In a proper game of no-limit hold’em, in a given hand, a player can only lose what’s in front of him or her. Or more precisely, a player can only lose what’s in front of him or her, or what’s in front of his or her opponent, whichever is smaller. A simpler way to put this is that, in actual no-limit hold’em, the maximum bet size is the amount of money the player has. If the Commission wants to limit losses to $1200, it will have effectively done so if it simply restricts buy-ins to $1200. Restricting the buy-in to this size would do just as good of a job of achieving the Commission’s goal as the current rules, but without spoiling the nature of the game.

    Changing the current rules to the rule I’ve proposed would also allow casinos and card rooms to offer a greater selection of poker games. It would also keep Washington players that are serious about the game, as I am, in Washington casinos and card rooms, rather than sending them elsewhere. And it would let people in Washington play the way it was meant to be played.

    To summarize, my complaint here isn’t simply that the current rules produce a much less exciting and interesting game - although that is very much true as well. My complaint is that the current, well-intentioned rules destroy the very nature of the game, encourages reckless play that otherwise wouldn’t occur, and encourages players like myself to leave the state when the itch to play strikes. Thank you for your time
  • poseidonposeidon Posts: 88Subscriber
    edited April 2018
    but tribal casinos in WA has $500 max bet. Will tribal casinos have NLHE too when the city decides to uplift the cap? Because tribal casinos are the nuts
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