That's an interesting hypothesis, but I'm afraid it is subjective opinion. Many casinos have adopted or adapted the FL rules about this kind of wagering. The simple test is this, imo: If no bonus were involved, would you bet half or all of your bankroll on one game and then go on to grind the balance with near even money bets? Not likely, and would you consider that to be 'responsible gambling'? I wouldn't, but that is subjective.
As a reminder eCOGRA purports:
The underlying philosophy of eCOGRA is based on the achievement of the objectives of player protection, fair gaming and responsible conduct by operators
Responsible Gaming is codified within the eGAP (Generally Accepted Practice) document, specifically under Player Protection 103 and attending regulations.
A cursory reading of the regulations does not disclose any mention or reference to a Bonus or Bonus play. One can confidently conclude the application of a Bonus does not in any way alter the operation of the
Responsible Gaming principle.
The stated
Objective of
Responsible Gaming within eGAP reads (in greater part), A responsible gaming environment shall be established, enforced and monitored .
Section 103 R10.1 compels the member Casino to provide a clear home page link to providing Player advice with respect to:
A warning that gaming could be harmful if not controlled and kept in moderation (underlining mine)
In seeking to exercise control over their gaming Players may (should) avail themselves to
Efficient Bankroll Management (EBM) both prior and during game play. Bet size management is but one vital component of protecting Players funds against loss. EBM is completely harmonious with the principle of
Responsible Gaming.
The Casino T+Cs, in particular #13, seeks to impede Player access to EBM by prohibition and penalty. Profits will suffer confiscation and deposits returned. Deposits are not refunded should the Player lose wagers applying EBM.
Such prohibition can only intend to expose and render the Players funds at a manifestly greater risk of loss (and reciprocal Casino profit). In the process control (ie bet size) over the Players funds is diminished in direct defiance of the aforementioned published
Responsible Gaming regulation and objective.
Indeed, on any rational reading, the Casinos T+C #13 is the very antithesis of the principle on which eCOGRAs
Responsible Gaming purports to stand.
It must follow that the Casinos T+Cs #13 is invalid for as long as the Casino remains under the auspices of eCOGRA regulation and policy. A properly advised player, and a properly argued case, would ordinarily be entitled to a favorable outcome on complaint to eCOGRA.
Of course it must be said the extent of eCOGRAs commitment to
Responsible Gaming will affect the outcome of any such appeal. One could also argue the case on the basis of what constitutes
Fair Gaming, which for the present, will be left for another day.
...