JEFFERSON CITY -- Although members of the Missouri Gaming Commission claim they aren't actively advocating an increase in the state's $500 gambling loss limit, the panel's paid staff has prepared a report listing problems with the rule.

Saying the commission intends to continue studying the effects of the $500 gambling loss limit on riverboat casinos, the report makes a one-sided case for ending the regulation.

The report has generated few public comments since its release several days ago, but it is being widely distributed among members of the General Assembly by both gaming commission personnel and employees of gambling firms operating in Missouri.

An aide in Gov. Mel Carnahan's office, who said he was aware of the report, said the findings were being "studied" in the executive office.

The staff report suggests there are competitive concerns about the loss limit. "The available data from other states suggested that Missouri riverboats would be at a competitive disadvantage when compared to states that do not have either bet or loss limits. This presumption appears to be accurate," the reports says.

The report also says "data available from currently operating Missouri riverboats clearly shows that the $500 loss limit has eliminated a certain segment of the Missouri market that is available to adjoining states" that don't impose loss limits. The limit's aim is to protect gamblers from excessive losses and was used by pro-gaming forces to portray the new industry as concerned about gaming losses by those who couldn't afford them.

In its report, the commission includes numerous statistics, all designed to convince legislators and state officials of the economic advantages of removing the individual loss limit. One of the most striking set of statistics shows a dramatic difference between the win per admission on Missouri boats and their counterparts in Illinois and Iowa. Neither of these states places a limit on losses. Iowa's original statute had the same limit as Missouri, but it was removed last summer in an effort to boost casino earnings.

The commission lists three major arguments for lifting the ban.

-- It claims the limit is "inherently anti-consumer because it limits the number of units a player has to compete against the house, while the house has an unlimited number of units to use against the player." This means that if a player wagers $25 a bet in a blackjack game and is faced with a loss limit of $500, he is limited to a 20-unit losing streak. The house, however, can withstand an unlimited winning streak by the player. The report says that "the odds, which are already in favor of the house, are dramatically increased to the detriment of the player."

-- The report also claims the limit is "extremely inconvenient, particularly for those patrons who have absolutely no intention of wagering more than $500." In order to see that the limit is observed, there is an elaborate system requiring bettors to have "script" before buying chips or tokens. The script is validated by casino employees as the patron purchases chips, but the report says enforcement is "far from foolproof." It blames the loophole on "confusion and inconvenience" created by 1,500 customers in a confined area. The report alleges that an "unfavorable impression" of the loss limit "likely has the effect of reducing the number of return-trip patrons. The limit also tends to reduce customers for slot machines, the commission staff argues.

-- And, finally, the report contends the limit creates several problems for enforcement personnel. Currently the state assigns seven officers to each of the riverboats, which operate 18 to 21 hours a day, requiring a large portion of enforcement time for checking compliance with the loss limit. The commission argues that enforcement of the limit can never be 100 percent successful because of several methods used to circumvent the law.

All of this is causing Missouri to lose tax revenue that it could be receiving if the limit were removed, the gaming report states.

Two statewide church groups, Southern Baptists and United Methodists, that opposed the casino gambling proposals said they had not read the report and would not comment on it until it had been studied.