Maryland casinos asked the state last March to permit their blackjack dealers to draw a card on a "soft 17" hand — a hand adding up to 17 including an ace, which can be counted as a 1 or an 11 — instead of having to stand pat.
The effect of such a rule change might seem as thin as a casino chip — experts say it raises the dealer's advantage by about 0.2 percent — but anything that tilts the balance between dealers and players is considered serious within the industry. In blackjack, players try to score higher than the dealer without going over 21.
"To have the ability to hit on soft 17 will increase the house advantage, which will increase revenue, tax dollars and make us comparable with other markets," the casinos wrote in a 2014 memorandum — obtained by The Baltimore Sun under a public records request — proposing more than 50 rules changes.
State regulators said no to the blackjack request. They also denied the casinos' proposal to cut the deck in a way that would allow more cards to be in play, resulting in more hands and fewer shuffle interruptions. But they accepted the casinos' proposal to increase the amount that on-site automatic teller machines can dispense to players per day from $1,000 to $2,500, potentially making more money available for gambling. Many banks impose their own limits on withdrawals.
Regulators also accepted a number of other suggestions — about three dozen in all — as part of an annual give-and-take that illustrates the Maryland Lottery and Gaming Control Agency's collaborative approach to regulating the state's five casinos.
Each year, the gambling establishments are invited to propose changes to regulations they believe have become unnecessary or outmoded — sometimes because of new technology — since Maryland voters approved slot machines in 2008.
"In many cases, when states start out, they start with overly restrictive processes," said Robert Norton, president and general manager of Maryland Live, the state's largest casino.
The goal is a regulatory system that "is safe and secure and as minimally intrusive … as possible," said Stephen Martino, director of the gaming control agency.
All of the 2014 changes approved by regulators still must be reviewed in Annapolis by the General Assembly's Joint Committee on Administrative, Executive and Legislative Review before being permitted to take effect.
The state faces a delicate balancing act in overseeing casinos. On the one hand, it must safeguard the public's interest by ensuring casinos don't possess unfair advantages. On the other, it collects hundreds of millions of dollars a year of revenue from casinos for various programs, so it doesn't want to bog them down with rules that prevent them from operating efficiently.
"We want state revenues clearly maximized," Martino said. "I think our job on the casino side, though, is very much that of a regulator. We're there to call balls and strikes."
Each year, regulators sift through suggestions from the casinos — this year's are expected to be made in the spring — and decide which ones to accept.
Last year, "we had about 57 proposals and we went ahead and took action on about 38," said Charles LaBoy, the state's assistant director for gaming. "It took us several months of internal reviews."
The regulators compared Maryland's blackjack rules with those of other states.
Maryland is generally considered player-friendly for blackjack. For example, Maryland casinos pay 3-to-2 on a blackjack, which occurs when a player reaches a perfect 21 by drawing an ace and 10-value card. That means a $10 bet yields $15. Some casinos in other states have blackjack payouts of 6-to-5.
Competition in Maryland plays a role. With five casinos and a sixth on the way, the state has become one of the country's most saturated gambling markets. The competition between Maryland Live and Horseshoe Casino Baltimore — less than 12 miles apart — is particularly fierce.
"Gamblers are there to gamble, but they aren't completely dumb," said Christian Harder, a highly ranked professional poker player from Annapolis. "They try to get where the better games are."
Players like Maryland's rule requiring dealers to stand on all 17s.
Blackjack offers players the best odds of any game of chance in casinos, with the house holding a slight edge for players correctly applying basic strategy. Allowing the dealer to hit a soft 17 would increase that edge "typically about 0.2 percent," said Eliot Jacobson, a blackjack expert who does consulting for casinos.
The rules vary widely by state and, sometimes, even from casino to casino.
"Vegas casinos can do just about anything they want with their blackjack. There is very little regulation on blackjack rules in Nevada," Jacobson said.
The recommendation to allow dealers to hit on 17 was among those presented jointly by all of the casinos. Horseshoe, the state's newest casino, participated in the suggestions even though it didn't open until August.
But Maryland decided that "changing the rules to essentially lower the payout to players was rather one-sided," LaBoy said. "We looked at surrounding jurisdictions for that. Pennsylvania does not hit on a soft 17."
LaBoy said regulators tried to be accommodating where they could.
For example, they granted the casinos' request to change the rule requiring them to write checks — without the option of paying cash — to customers who hit a jackpot of $5,000 or more.
"There was no explanation as to why such a requirement was in place," LaBoy said. "One could speculate that this requirement is in place to prevent patrons from leaving the casino with large amounts of cash or prevent them from gambling the winnings."
Regulators raised the threshold to $25,000. They also agreed with the casinos to raise the daily ATM limits and to eliminate the $250 limit on individual ATM transactions.
Norton said Maryland Live patrons must often walk over to adjacent Arundel Mills mall to withdraw more money. He called the transaction limit "a nuisance customers don't understand. That's one of the larger complaints that we get."
Horseshoe agrees that changing the ATM rules meets customer demand, said Alex Dixon, the casino's assistant general manager.
"This is a great example of something where the operators collectively worked together," Dixon said.