Part 2 of PokerNews’ exclusive interview with embattled Full Tilt Poker front man Howard Lederer (pictured) was posted on Tuesday afternoon, just hours after he recapped the formation of Full Tilt in Part 1. You can read a write-up of Part 1 of the Howard Lederer interviewif you haven’t already right here on PocketFives’ home page. The interview was filmed at the Palazzo in Sin City 10 days ago. Watch Part 2 nowand discuss the video in this Poker Community thread.

Part 2, which lasted a hair over 30 minutes, began with PokerNews COO Matt Parvis discussing the last-minute passage of the Unlawful Internet Gambling Enforcement Act, or UIGEA, in late 2006. Lederer called the bill “a shock,” but admitted that the process of deciding to remain in the United States post-UIGEA was “simple.”

Lederer rehashed, “It was a pretty simple process. We knew that just because PartyPokerleft doesn’t mean it was the correct decision to leave or that we were the same as Party. They were a company that had offered all sorts of games, house-backed games… [Full Tilt and PokerStars] were privately held companies that had never offered anything but pokerin their entire history.” PartyPoker’s parent company, bwin.party, is publicly traded on the London Stock Exchange.

Lederer told viewers that the company sought several legal opinions from “very reputable” attorneys in Las Vegas and elsewhere in the U.S. “You really had to look at the law and what it had to say about poker, and it didn’t say anything about poker,” Lederer said of the UIGEA. “So, then you’re really left with them trying to interpret what this law means about poker… We didn’t ever receive any opinions to the contrary. When we got legal opinions, they were all unanimous that the UIGEA didn’t cover poker.”

Lederer admitted there was “zero struggle” in deciding to remain in the U.S. market following the passage of the UIGEA in late 2006. The bill was tacked onto an unrelated piece of must-pass legislation at the urging of then-Senate Majority Leader Bill Frist.

Parvis then asked Lederer about payment processing changes from 2006 to 2007, the first year following the UIGEA’s passage. Remember, the UIGEA forbid transactions from financial institutions to “unlawful internet gambling” sites, but did not spell out what the three-word term meant.

“Payment processing wasn’t a part of my daily duties,” Lederer responded. “I know that there was a change from 2006, where I think the only ACH processing was with Neteller… After the UIGEA, there were different processors offering ACH. I would hear about them here or there, but it wasn’t my area. Whenever I heard about a new payment processor offering ACH, I was assured by Ray and company counsel that those processors and payments were transparentand that the banks knew.”

Lederer described a trip to Dublin after Black Friday in which Full Tilt CEO Ray Bitar (pictured) produced a transparency letter from a processor the poker room was doing business with. And whereas the Black Friday indictments indicated that the poker rooms in question were attempting to “buy” banks for the purposes of payment processing and classifying poker transactions as “toys” and other non-related items, Lederer countered, “I don’t think Full Tilt invested in any of these banks.”

In the first amended complaint to the Black Friday indictments filed in September 2011, U.S. prosecutors charged that Lederer was among those operating a “global Ponzi scheme” by being unable to cover player deposits. “I was certainly aware of the balance sheets in terms of cash coverage,” Lederer told PokerNews, “but I had never seen a financial document that answered [this]question: Do we have more cash in company accounts than we have in player liability?

Producing a document that answered whether Full Tilt had enough capital on-hand was a tall order. Lederer explained to PokerNews readers and concerned poker players, “In March, April, and May 2008, I endeavored to have the company’s financial department produce a document that could answer that fundamental question. That wasn’t necessarily the easiest document to produce. By early summer 2008, that document was being produced on a weekly basis.”

Lederer doubted the Kahnawake Gaming Commission, Full Tilt’s regulator at the time, ever asked for a cash coverage document. Also on the payment processing front, an e-mail from a Full Tilt customer surfaced asking whether his money would be held in a trust. This simple question resulted in a lengthy e-mail chain featuring Bitar, customer service, and a person known only as “Co-Conspirator 1,” whom Lederer would not confirm the identity of.

In the end, Bitar crafted a response to the customer that read, “Players’ funds at FTP are kept in several deposit accounts throughout the world, all of which are separate and distinct from our operating accounts. Funds are transferred from player deposit accounts to FTP operating accounts only after we have earned them. After FTP’s earnings accumulate, we make periodic transfers of earnings from deposit accounts to operating accounts.”

Bitar said in a separate internal e-mail, “Customer funds will always be at risk.”

Lederer closed by saying Full Tilt’s complexity and failure to update its structure over time could have contributed to its rather abrupt demise: “My greatest regret in all of this is that we were operating as a California LLC. We’re a Dublin company, but the ultimate ownership is still this California LLC and it’s using an operating agreement that was crafted for a startup in 2003. That was our inexperience and that was our laziness.”

PocketFives has learned that Parts 3 and 4 will be published on Wednesday on PokerNews.