Comment #1: I'd like to address concurrent tournaments. VDACS'; ban on such events negatively affects 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 and frivolous without a foundational regulatory precedent designed to uphold charitable gaming integrity. Why would regulations prohibit concurrent tournaments when the Code approves them? Solution: Strike the restrictive proposed 11VAC20-30-90.F

Comment #2: I want to address tipping. VDACS’ restriction hurts dealers, players, and charities due to the inability to offer typical poker room compensation, affecting charity poker operations and potentially stopping play. Tipping is a standard and fully accepted nationwide form of compensation. Tipping is essential for a poker dealer’s financial survival no different than a restaurant waiter or airport baggage handler. Why would regulations ban tipping while the Code allows it? This limitation has no fundamental nor practical base and suggests VDACS lacks a basic operational knowledge of the poker field. A sound solution would be to remove this tipping constraint by striking subsection 2 of 11VAC20-30-100.D.

Comment #3: My comment concerns the use of proceeds amount. VDACS’ mandate requiring charities to adhere to 11VAC20-20-110 for its use of proceeds formula is not financially viable and makes the running of successful charitable poker events impractical. Charities would struggle to host tournaments, as they wouldn't raise sufficient funds to cover expenses while meeting the required use of proceeds mandate.  The detailed analysis of a basic tournament budget would refute the required formula.  A solution is to apply the recently adopted pull tab formula to poker.

Comment #4:  My remark pertains to re-buys. VDACS confuses "rebuys" for "add-ons," negatively affecting players, dealers, and charities. "Rebuys" become possible when a player has lost his entire starting chip stack, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions while increasing administrative and legal costs due to ill-conceived regulations. VDACS guidelines misalign with the game and industry thus causing confusion. A sensible fix would be to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

Comment #5: My remark pertains to the issue of operator fees. The VDACS mandates that only a fixed fee can be paid to an operator by charities for their services, rather than a percentage of the revenue. This negatively impacts charities because if the revenue decreases, the charity still has to pay the predetermined flat fee. It's peculiar that VDACS adds such an arbitrary limitation. A sensible approach would be to eliminate the initial two sentences of 11VAC20-30-60.P. As Commissioner Guthrie has expressed, the crucial aspect is that charities fulfill their use of proceeds obligations. Beyond that, what role does the state have in overseeing the business operations of charities?

Comment #6:  My remark pertains to electromechanical devices. Imposing an outright restriction on technology use in poker operations by VDACS negatively affects dealers, players, and charities. In today's world, technology enhances all aspects of life. Utilizing technology software and hardware to manage the game improves efficiency, enjoyment, and accuracy. Relying on technology is far more advantageous for preserving the game's integrity than manually tracking everything and being prone to human error. The suggested 11VAC20-20-90.O should be eliminated.

Comment #7:  Concerning player limitations, 11VAC20-30-90.C-D excessively restricts individuals with even distant connections to poker games from participating in tournaments. This unwarranted constraint negatively impacts players, dealers, and charities, disrupting the poker community's unity and enjoyment. Such rules wouldn't exist if VDACS understood the industry. A logical solution would be to eliminate 11VAC20-30-90.C-D and only prohibit a dealer's family member from playing at the table where they are dealing.

Comment #8:  My comment relates to the calendar: Where VDACS specifies periods of operation ties to calendar days and weeks, it impairs charities and the optimum operational efficiency of charitable poker events. 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 a poker related “Calendar Day” to mean the period of 24 consecutive hours as set by the charitable organization. In addition, make the same logical change to the definition of “Calendar Week”.

Comment #9:  My comment relates to badge. Where VDACS requires printing each dealers’ full name, including first and last names on their badge, it harms dealers because publicizing dealer names exposes them to undue harassment or worse. The industry norm is not to print last names, and dealers don’t want to be in a place that is divergent from all other gaming environments. one reasonable fix to VDACS's error would be to require only printing the first name on the badge.

Comment #10:  My comment involves the use of proceeds. VDACS prohibits funds for fraternal activities, hurting charities because these organizations aim to serve members through social and fun activities. VDACS' rule bars them from using poker funds for their purpose, making IRS compliance difficult. One solution is to not apply this rule to funds from poker tournaments.

Comment #11:  My comment addresses Restriction on Location. The success of tournaments would be determined by their presence in areas that align with the desired demographic, instead of being restricted to the organization's home base. VDACS lacks the jurisdiction to establish this regulation. The Code explicitly imposes this restriction concerning bingo and pull tabs while excluding it in relation to poker. The simple solution would be to strike the proposed 11VAC20-30-90.G.