Proposed 11VAC20-30-90.F not allowing concurrent poker tournaments.
This limitation/restriction is arbitrary and it is not supported by the current statute. This restriction negatively impacts players, dealers and the charity. Proposed 11VAC20-30-90.F should be stricken from these regulations.
Proposed subsection 2 of 11VAC20-30-100.D prohibits tipping dealers/staff.
Prohibiting tipping dealers/staff is absolutely preposterous! Prohibiting tips to dealers/staff is like prohibiting tips to servers! Dealers & staff of poker rooms rely on tips for their livelihood. Without tips, dealers & staff won't make sufficient income and will likely have to pursue alternate jobs that provide more income. This, in turn, negatively impacts players (like me) as well as the charity since the poker room could easily end up understaffed and unable to operate. Tipping should be left to the discretion of the players. Proposed subsection 2 of 11VAC20-30-100.D should be stricken from these regulations.
Adhering to 11VAC20-20-110 for use of proceeds formula.
This formula simply doesn't make fiscal sense for charitable poker. Poker tournaments do not generate enough money to allow for a reasonable prize pool, operating expenses plus the donation amount required by 11VAC20-20-110. A reasonable solution is to apply the recently introduced pull tab formula to poker.
11VAC20-30-100.H limiting number of "rebuys" before a player is eliminated.
It seems that VDACS is confusing "rebuys" with "add-ons." "Rebuys" occur after a player depletes their chips; restricting them before elimination is unworkable. Ensuring compliance with a non-sensical regulation like this is impossible and simply raises the cost to operate a tournament. This regulation only serves to hurt the game, the players, dealers and the charity. 11VAC20-30-100.H should be stricken from these regulations.
11VAC20-30-60.P stipulates that charities pay operators a set fee for their services.
This requirement is also a mathematical error. Operators should be paid a proportion of the revenue, not a flat fee. Tournament revenue will naturally vary. If a tournament's revenue is below average, a fixed fee will hurt the charity while a proportion of the revenue payment would be more fair to the charity. The initial two sentences of 11VAC20-30-60.P should be removed.
11VAC20-20-90.O restricts the use of technology.
This rigid restriction on employing technology in poker operations negatively impacts dealers, players, and charities. In the 21st century, technology serves to better all aspects of our lives. By incorporating technology software and hardware in the game's operation, it becomes more efficient, precise, and enjoyable. Using technology will preserve the game's integrity much more than manually recording everything and risking human mistakes. The proposed 11VAC20-20-90.O should be abolished.
11VAC20-30-90.C-D restricts people allowed to play in a tournament.
This regulation excessively constrains individuals indirectly associated with poker games from playing in a tournament. This unwarranted restriction disrupts the poker community's cohesion and game enjoyment. It unfairly hurts the game, the players, dealers and charities. 11VAC20-30-90.C-D should be removed. The only restriction should be to forbid a dealer's family member from playing at their table.
Calendar days and weeks.
Stipulating operation periods based on calendar days and weeks hampers charity poker's optimal operation and effectiveness. This misconception fails to account for poker rooms' modified 24-hour cycles, causing chaos in reporting. A reasonable fix is to redefine "calendar day" as a 24-hour span determined by the charitable organization and make a conforming change to "calendar week."
Dealer Badges
The requirement to print each dealers’ full name, including first and last names on their badge, harms dealers because publicizing dealers’ names exposes them to undue harassment or worse. The industry norm is not to print last names. Dealers don’t want to be in a place that is divergent from all other gaming environments. This requirement should be changed to allow only printing the first name on the badge.
Regulation 11VAC20-20-110.D applied across the board.
Applying 11VAC20-20-110.D across the board doesn't let funds be used for fraternal activities. This negatively affects charities as these groups provide social and recreational support to members. This rule disallows using poker funds for their goals, creating IRS compliance issues. Poker event funds should be exempt from this rule.
Proposed 11VAC20-30-90.G limiting where poker games can be hosted.
The success of poker tournaments will likely be determined by their presence in areas that align with the desired demographic. The Code particularly enforces this limitation for bingo and pull tabs, and logically leaves it out for poker. VDACS does not possess the power to formulate this rule. Proposed 11VAC20-30-90.G should be stricken from these regulations.
