Are There Really “Gambling Trailers” to Keep a Gaming License Alive?

There are indeed “pop-up casinos” that periodically appear on the sites of closed or demolished gaming establishments. The license attached to an establishment can outlive the establishment—but only if the owners know the rules and play by them wisely.

Nevada Gaming Regulation No. 9 pertains directly to the closing of a licensed establishment. According to regulation 9.010.2, “any licensee who surrenders, abandons or quits his licensed establishment, or who closes all of his licensed games for a period exceeding 1 month, shall … surrender his license to the board.” But, for those looking to keep their licenses, here’s the happy catch: “The board may … authorize closing for longer periods; however, such extension will not permit closing for an entire calendar quarter.” So there’s the key—don’t let the place stay closed for an entire calendar quarter.

The law being the law, it’s actually a little more complicated than that: Depending on the type of license, the reason for closure and possible prior approval of the Gaming Control Board, the pop-ups can pop up much less frequently than once a quarter.

At 9.010.4, the regulation says “subsection 2 shall not apply if the board authorizes closure of any licensed gaming establishment … because of natural disaster, fire or other physical destruction of the licensed gaming establishment.” That suggests that planned demolition and redevelopment by the licensee would allow the Gaming Control Board to extend the license as long as necessary if fees and taxes are paid. This apparently would have applied to Boyd Gaming’s Stardust/Echelon site, for example, before its recent sale to Genting.

Sometimes establishments have odd intervals for those pop-up parties. The Review-Journal reported in November 2010 that Henderson’s Roadhouse Casino operated 16 slot machines for “one day a year” to maintain the location’s grandfathered, unrestricted gaming license.

Smithsonian magazine said in January that a pop-up gambling trailer must appear at the former site of the Moulin Rouge “every two years” to keep the license active. And single-day, 16-machine tents and trailers have also reportedly been at the vacated sites of The Beach and the Showboat.

Given the variables, should you find yourself in need of closing your gambling joint, consult an attorney. Those licenses are valuable, and once a site has lost one, it can be forever.

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