In 2003, while the FTC was considering changes to the HPA, I sent the following letter on behalf of the club.

March 30, 2003

Federal Trade Commission
Bureau of Consumer Protection
Division of Enforcemant
Attn: Mr. Neil Blickman
600 Pennsylvania Avenue, NW
Washington, DC 20580

Dear Mr. Blickman:

I am writing on behalf of the membership of the Casino Chips and Gaming Tokens Collectors Club (CC & GTCC). With over 2500 members, the CC & GTCC is the largest member club of the American Numismatists Association (ANA). As collectors of casino chips and casino tokens, we are very concerned with protecting the hobby against counterfeiting and the introduction of non-genuine items.

Since the passing of the Hobby Protection Act (HPA) thirty years ago, there has been a remarkable change in the numismatic hobby relating to casino chips and casino tokens. In 1973, there were few collectors and casino chips and tokens had little collector’s value. During the 1980’s and 1990’s, the growth of legalized gaming helped spawn growth in the hobby and caused the value of these collectibles to increase.

Casino chips and tokens have always been widely accepted and utilized numismatic items, used in exchange for cash in casinos. These chips and tokens are the accepted currency in the casino and in many casinos, are the only items with monetary value that can be used for gaming purposes.

At the time when the Hobby Protection Act was passed, there was not an active and organized group of citizens who collected casino chips and casino tokens. The reason for counterfeiting these items at that time was to pass them off in the casino for face value. With the advent of a strong and vibrant group of collectors, many casino chips and tokens now have a collector’s value far in excess of face value. These chips and tokens are generally from casinos that have closed or from casinos that have issued replacements, rendering the previous issue obsolete.

We in the hobby are pleased that the Hobby Protection Act covers the broad definition of “imitation numismatic” items, and consider casino chips and casino tokens to be fully covered under the act. But we also feel that the time has come to amend that HPA to specifically include casino chips and casino tokens. Technological advances over the past thirty years have made reproduction possible and the vast increase in the value in the collector’s market has made counterfeiting much more profitable.

It certainly was not possible to anticipate the change in the industry, the technological advances and the boom in the hobby of casino chip and token collecting three decades ago. A modification would now clarify and bring up to date the HPA and deter those who might consider counterfeiting casino chips and tokens.

I am requesting that the Hobby Protection Act be amended to add the words “casino chips, casino tokens” to Section 304.1(f). The last line of that section would then read “Such term includes coins, tokens, paper money, casino chips, casino tokens, and commemorative medals.”

Thank you for your consideration. Please feel free to contact me with any questions at the address above, by telephone at 610-668-4273 or by email at president@ccgtcc.com .

Very truly yours,

Nate Pincus
President, CC & GTCC