Virginia Regulatory Town Hall
Agency
Department of Agriculture and Consumer Services
 
Board
Department of Agriculture and Consumer Services, Charitable Gaming
 
chapter
Texas Hold’em Poker Tournament Regulations [11 VAC 20 ‑ 30]
Action Promulgation of regulations for Texas Hold’em poker tournaments by the Department of Agriculture and Consumer Services
Stage Proposed
Comment Period Ended on 5/10/2023
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4/19/23  6:35 pm
Commenter: Edward Rubin

Charitable Poker Tournaments
 

Concurrent Tournaments

 

  • My comment relates to concurrent tournaments. Where VDACS prohibits concurrent tournaments, it hurts players, dealers, and charities because VDACS is overreaching in limiting play in a way not authorized by statute. It creates an arbitrary limitation on legal poker tournaments, and it feels like an unreasonable limitation without a compelling regulatory need to ensure the integrity of charitable gaming. Why would the regulations add a prohibition on concurrent tournaments while the Code permits it? One reasonable fix to VDACS's error would be to strike proposed 11VAC20-30-90.F

 

 

 

  • My comment concerns concurrent tournaments. VDACS'; prohibition harms players, dealers, and charities due to overreach and lack of statutory authorization. This arbitrary restriction on legal poker tournaments appears unreasonable without a strong regulatory need for ensuring charitable gaming integrity. Why do regulations prohibit concurrent tournaments when the Code allows it? A reasonable solution is to remove proposed 11VAC20-30-90.F.

 

 

 

  • I'd like to comment on concurrent tournaments. VDACS'; ban negatively affects players, dealers, and charities as it exceeds their authority and isn't supported by statute. This unwarranted limitation on legal poker events seems unjustified without a pressing regulatory necessity to protect charitable gaming. Why do the regulations forbid concurrent tournaments while the Code permits them? A sensible fix is to strike proposed 11VAC20-30-90.F.

 

 

 

  • My remark involves concurrent tournaments. VDACS'; prohibition damages players, dealers, and charities because it goes beyond their mandate and lacks statutory backing. This random constraint on legal poker tournaments feels unwarranted without a compelling regulatory requirement to maintain charitable gaming integrity. Why do the regulations disallow concurrent tournaments when the Code approves them? One reasonable adjustment is to eliminate proposed 11VAC20-30-90.F.

 

 

 

  • I want to address concurrent tournaments. VDACS'; restriction hurts players, dealers, and charities due to overstepping its boundaries and not being authorized by statute. This arbitrary limitation on legal poker tournaments seems excessive without a convincing regulatory need to ensure charitable gaming is protected. Why would regulations ban concurrent tournaments while the Code allows them? A fair solution is to remove proposed 11VAC20-30-90.F.

 

 

 

  • My comment pertains to concurrent tournaments. VDACS' prohibition negatively impacts players, dealers, and charities because it exceeds their scope and isn't supported by law. This baseless constraint on legal poker events appears unwarranted without a crucial regulatory need to safeguard charitable gaming. Why do the regulations prevent concurrent tournaments when the Code permits them? A reasonable change is to strike proposed 11VAC20-30-90.F.

 

 

 

  • I'd like to discuss concurrent tournaments. VDACS'; ban on such events harms players, dealers, and charities as it goes beyond their purview and isn't authorized by statute. This arbitrary restriction on legal poker tournaments seems unreasonable without a significant regulatory need to uphold charitable gaming integrity. Why would regulations prohibit concurrent tournaments when the Code approves them? One logical fix is to eliminate proposed 11VAC20-30-90.F.
CommentID: 216522