Robert Goodman's recent testimony (November 2, 1995) before your committee on S.704, The Gambling Study Commission Act, is so filled with unsubstantiated allegations, innuendos and deceptive rhetoric, that I feel compelled to set the record straight. His testimony attempts to cloak his moral indignation at legalized casino gambling in a more objective, or academic cloth, of "economic planning” alternatives, but his "research" to date appears, simply, to be his personal hypothesis in search of evidence to support his cynicism for the industry. I take particular umbrage at his statement referring to my company as follows: "The federal government has an obligation to study the large national and, in some cases, even multi-national, corporations such as Promus...to investigate their corporate practices in such areas as securities regulation, anti-trust, corruption...and compliance with the reporting and regulatory requirements which concern cash transactions, in order to combat money laundering activities." Had Mr. Goodman desired to be current or accurate in his information, he should have known that "Promus" changed its name to Harrah's Entertainment, Inc. on June 30, 1995, and has been trading on the New York Stock Exchange under the Harrah's name since that time. Mr. Goodman simply appears ignorant of the pervasive existing regulation of our industry, and unaware that his advocacy of a federal study will result, in essence, in the federal government studying itself. Harrah's Entertainment, Inc. is a publicly traded stock company, as are many other large casino entertainment companies, scrutinized by the stringent requirements of public reporting of financial and financially impacting information to the Securities and Exchange Commission and the New York Stock Exchange, by the Federal Trade Commission for trademarks and marketing programs, by the Federal Communications Commission for media advertising, by the U.S. Treasury Department and the Internal Revenue Service for Currency Transaction Reporting, by the U.S. Department of Justice for acquisitions, 1023 Cherry Road. Memphis, TN 38117-5423 and with regard to Native Americans, by the Bureau of Indian Affairs through the Indian Gaming Regulatory Act. Either Mr. Goodman is unaware of these all-encompassing regulations by these governmental agencies, or he simply would ignore them to regulate the regulators. Mr. Goodman also fails to account for the state and local regulatory agencies by which Harrah's and our industry are scrutinized. Each state where we are legally permitted to operate casino entertainment facilities has a gaming commission that requires licensing of each casino company and every employee who desires to work in a casino, from the rank and file to key management. Before licensure, each key management person is subjected to a State Police and F.B.I. background investigation that requires the individual to waive all rights of privacy for an open and full investigation. Those of us who are in the casino industry are proud to work with colleagues and competitors who we know have passed the stringent requirements for such licensing. Mr. Goodman's eagerness for the federal government to inject itself into the state regulatory processes is an overt display of arrogance and contempt for state government's ability to govern its own affairs. I am also appalled at Mr. Goodman's loose implication that Harrah's Entertainment, Inc. would have anything to do with violations in any of the areas he suggests for study. He appears unaware that the U.S. Treasury Department and the Internal Revenue Service strictly enforce Currency Transaction Reporting requirements which enlist casinos as reporting agencies helping the federal government in combatting potential "money laundering activities." Apparently, he distrusts "large national and, in some cases, even multi-national corporations." How ironic, though, that a “large national” federal government does not evoke his same distrust. Mr. Goodman's remarks in the public arena were unfortunate in clouding the issues and appealing to emotional and baser instincts of anti-gaming advocates. Harrah's Entertainment, Inc. does not envision itself as simply a "casino gaming" company, but rather, a casino entertainment company that seeks to provide its guests with an "entertainment experience" that not only encompasses gaming, but the entire spectrum of entertainment with restaurants, gift shops, live music, gaming excitement, and interaction with guests seeking a positive experience. In our view, the exigencies of the day demand a more useful expenditure of public monies in areas of true need rather than a diversion of public funds to a commission for study of an industry already more closely scrutinized than any other. If, despite this, the study commission goes forward, we should at least protect the integrity of the process and its objectives. We can only do that by enlisting unbiased individuals for participation in the process, seeking qualified representatives and equal representation from all segments of the industry, including those who can be objective from the outside, and pursuing research without any preconceived conclusions. Mr. Goodman's remarks about Harrah's Entertainment, Inc. suggest that he does not meet those minimal qualifications. Rather, his place is clearly at Hampshire College where he can, presumably, do less harm and enjoy his subjective excesses, rather than in or near any responsible position associated with an anaysis of the gaming industry. I trust that you and the members of the committee will dedicate yourselves to the fair principles of the process. COMMISSION ON THE REVIEW OF THE NATIONAL POLICY TOWARD GAMBLING Washington: 1976 For sale by the Superintendent of Documents, U.S. Government Printing Office Washington, D.C. 20402 Stock No. 052-003-00243-4/Catalog No. Y 3.G14:1/976-2 COMMISSION ON THE REVIEW OF THE NATIONAL POLICY TOWARD GAMBLING 2000 M STREET, N.W. WASHINGTON, DC 20036 15 October 1976 Honorable Gerald R. Ford President of the United States Washington, D.C. Honorable Nelson A. Rockefeller President of the Senate Washington, D.C. Honorable Carl Albert Speaker of the House of Representatives GENTLEMEN: In accordance with the provisions of sections 804-808 of Public Law No. 452, Ninety-first Congress, the Commission on the Review of the National Policy Toward Gambling has the honor to submit its final report of findings and recommendations. Respectfully yours. Charles H. Maria Charles H. Morin Chairman iii |