TechTalk #03– What CA’s Proposed Player-Dealer Rotation Rules Mean for Cardrooms

Welcome to Cardroom Tech Talk — where we break down the latest in gaming regulations, operations, and technology with real, unfiltered insights from the trenches.

We spent hours on Friday, February 14th, discussing the implications of the newest proposed regulations for California cardrooms, and here’s our take:

California’s DOJ is rolling out new gambling regulations that’ll reshape cardrooms statewide and the TPPPPS model they legally manage their games under.

What’s Changing?

The Bureau of Gambling Control (BGC) now wants the player-dealer position to rotate continuously every 40 minutes. No more long-standing third-party bankers backing third-party proposition players (TPPPPS). The goal? Eliminate anything that resembles a house bank.

This hits the California games segment of cardroom revenue hard (and seems specifically aimed at blackjack—probably to the dismay of Indian gaming, as baccarat is also a key game). Whether baccarat can be creatively run to mimic the experience without breaking regulations remains to be seen. Personally, I’ve seen some creative models and workarounds in the past and in other states to stay within the rules.

This regulation effectively eliminates the easy way for players to experience gambling at table games similar to those found in Vegas or Indian gaming casinos in California. According to the DOJ’s Initial Statement of Reasons, many games have allowed TPPPPS to hold the player-dealer position indefinitely, mimicking house-banked games, which is a violation under California law. Both Indian gaming interests and the state are pushing to see this go… but are they considering the fiscal and economic impact of eliminating the lifeblood for many cities that rely on cardroom taxes for 95% or more of their revenue? Let’s look at the proposal deadlines.

Proposal Deadlines:

• October 1, 2025: Regulations take effect.

• 60 days: Cardrooms must submit new game rules.

• 120 days: BGC will approve or deny submissions.

• Full compliance deadlines:

  • March 30, 2026 – Player-dealer rotation.

  • March 2, 2026 – Blackjack adjustments.

Economic Impact:

The Economic and Fiscal Impact Statement estimates a $396M annual revenue loss for cardrooms and a $198M gain for tribal casinos as players migrate. Expect approximately 311 job losses annually in the cardroom sector over the next decade.

That means we’re looking at a staggering $3.96 billion in cardroom revenue losses, a $1.98 billion gain for tribal casinos, and 3,110 jobs lost across the cardroom sector. Big numbers, big stakes.

This isn’t just about money. Cardrooms will need to completely overhaul operations. TPPPPS can’t hold the bank endlessly, and every seated player must take turns. Cardrooms might innovate with new games, rules, or creative alternatives, but the adjustment won’t be easy.

Why Does This Matter?

If you’ve played player-banked games, you know the issues: fronting your own money, constant rotation, more training on how the game works, and the game flow dying fast. These regulations might push more players to tribal casinos, or to out of state, where games run more smoothly without these hurdles.

Poker remains untouched, but here’s the kicker—poker isn’t the main cash cow for California cardrooms. Their bread and butter? California Table Games like these, which are now on the chopping block.

Legal Battles & What’s Next:

Cardrooms aren’t taking this quietly. Legal fights are brewing, with arguments that these regulations unfairly benefit tribal casinos. Public comments are open until April 2, 2025, with a virtual hearing the same day.

We’ll keep you updated as this unfolds. Until then, stay sharp, stay informed, and let’s keep the conversation going.

— Cardroom Tech Talk

💬 What’s the biggest tech headache in your cardroom right now? Drop a comment or reply—I might break it down in a future TechTalk.