Competitions would thrive in regions that cater to the appropriate target audience, rather than being confined to the location of the organization itself.

My comment relates to the use of proceeds where VDACS prohibits using funds for fraternal activities. This is harmful to charities because Fraternal organizations are chartered to serve their members in social and recreational ways as a part of their mission. VDACS applies 11VAC20-20-110.D across the board resulting in an absurdity that fraternal organizations can’t use charitable poker funds for their charitable purpose. This would frustrate our compliance with IRS rules for using our charitable funds for our charitable mission. One reasonable fix to VDACS's error would be to provide that 11VAC20-20-110.D shall not apply to fund generated by the charity from hosting poker tournaments.

My comment relates to the calendar: Where VDACS specifies periods of operation ties to calendar days and weeks, it harms charities and the ideal operation and efficiency of charitable poker. This definition misunderstands that poker rooms often operate on an adjusted 24-hour period and would wreak havoc on ordinary reporting requirements. One reasonable fix would be to Define “Calendar day” with respect to poker to mean the period of 24 consecutive hours as set by the charitable organization. And make the conforming change to the definition of “Calendar week”.