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.

I’d like to discuss tipping. VDACS’ ban on tipping harms dealers, players, and charities as it disallows standard poker room compensation, hindering charity poker operations and possibly preventing play. Tipping is crucial for dealers’ livelihoods in the poker sector. Why would regulations prohibit tipping when the Code approves it? This arbitrary constraint reveals VDACS’ lack of understanding of the poker domain. One logical fix is to eliminate this tipping restriction.

I want to address the use of proceeds amount. VDACS requires charities to follow 11VAC20-20-110 for its use of proceeds formula, which negatively impacts charitable poker. Charities would be incapable of hosting tournaments, not raising enough funds to meet expenses and the mandated use of proceeds. Assessing a simple tournament budget highlights this formula's inefficiency. A solution is to adopt the recently established pull tab formula for poker.

I'd like to comment on re-buys. VDACS confounds "rebuys" and "add-ons," causing harm to players, dealers, and charities. "Rebuys" take place once a player's chips are gone, making it nonsensical to limit them before elimination. VDACS adds extra constraints without clear justification, leading to increased compliance costs due to unsuitable regulations. VDACS's published guidelines create confusion, not aligning with the game and industry. A rational remedy is to strike 11VAC20-30-100.H, and if the intent is to restrict tournament length, § 18.2-340.33.16 already stipulates a predetermined end time.

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?

I would like to address the matter of electromechanical devices. VDACS's blanket restriction on the utilization of technology in poker operations adversely impacts dealers, players, and charities. In the 21st century, technology contributes to the enhancement of all things. The game's operation becomes significantly more efficient, enjoyable, and accurate when managed using technology software and hardware. Employing technology is more effective in maintaining the game's integrity compared to manual tracking, which is vulnerable to human errors. The suggested 11VAC20-20-90.O should be withdrawn.

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.

• In relation to the calendar, VDACS' designation of operation periods based on calendar days and weeks negatively impacts charitable poker's operation and efficiency. This misapprehension disregards poker rooms' typical adjusted 24-hour schedule, creating reporting issues. A suitable remedy is to redefine "calendar day" as a 24-hour interval established by the charitable organization, and make a corresponding change to the "calendar week" definition.

• My observation concerns badges: VDACS' requirement to display dealers' full names, including first and last names, puts dealers at risk of undue harassment or worse. This strays from the industry norm and dealers prefer consistency with other gaming environments. A logical solution is to mandate only the first name on badges.

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.

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