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.

In addition, I have serious concerns tipping. VDACS’ prohibition harms dealers, players, and charities because, without the ability to provide standard poker room compensation, charities cannot effectively operate poker games, possibly not playing at all. Tipping is essential for dealers’ livelihoods in the poker industry. Why do regulations prohibit tipping when the Code allows it? This arbitrary restriction suggests VDACS lacks understanding of the poker sector. A reasonable solution is to remove this tipping constraint.

Thank you for your time, and serious, educated and knowledgable consideration.

I would also like to comment pertaining to the use of proceeds amount. VDACS demands charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which undermines charitable poker. Charities would struggle to organize tournaments, failing to generate sufficient funds for costs and the required use of proceeds. A basic tournament budget analysis reveals this formula's shortcomings. The answer is to apply the recently embraced pull tab formula to poker. My comment pertains to the use of proceeds amount. VDACS demands charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which undermines charitable poker. Charities would struggle to organize tournaments, failing to generate sufficient funds for costs and the required use of proceeds. A basic tournament budget analysis reveals this formula's shortcomings. The answer is to apply the recently embraced pull tab formula to poker. 

My comment on re-buys. VDACS mixes up "rebuys" and "add-ons," harming players, dealers, and charities. "Rebuys" occur when a player depletes their chips; restricting them before elimination is unworkable. VDACS imposes extra limitations with dubious reasoning, raising compliance costs due to poorly designed regulations. VDACS generates confusion with misaligned guidelines for the game and industry. The proposed regulations make me wonder if the persons putting forward these restrictions actually have any knowledge of how charitable poker works. A reasonable solution is to strike 11VAC20-30-100.H; if the aim is to limit tournament duration, § 18.2-340.33.16 already mandates a predetermined end time.

I'd like to also discuss the issue of operator fees. VDACS dictates that charities are only allowed to pay a fixed fee to operators for their services, as opposed to a percentage of the revenue. This creates difficulties for charities, as they are required to cover the flat fee even when revenue is low. It's odd that VDACS would establish such an arbitrary rule. A practical solution would be to delete the first two sentences of 11VAC20-30-60.P. Commissioner Guthrie has stressed the significance of charities meeting their use of proceeds. Beyond this aspect, the state shouldn't be involved in micromanaging charities' business dealings.

Speaking on the restriction on electromechanical devices, I submit that 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.

Pertaining to the calendar, VDACS' prescribed periods of operation tied to calendar days and weeks damage charities and the ideal functioning of charitable poker. This misunderstanding overlooks poker rooms' usual adjusted 24-hour timeframe, complicating reporting. A sensible amendment is to define "calendar day" as a continuous 24-hour period set by the charity, and adjust the "calendar week" definition to match.

Pertaining to badges, VDACS' mandate to include dealers' full names, featuring first and last names, endangers dealers by making them vulnerable to undue harassment or worse. This deviates from the industry norm, and dealers prefer conformity with other gaming environments. A sensible fix is to necessitate displaying only the first name on badges. It's extremely easy to find someone online if one knows the full name, and possibly follow up with some nefarious action.

I'd like to also comment on use proceeds. VDACS disallows funds for fraternal activities, which is harmful to charities as these groups focus on social and recreational services for members. VDACS' rule keeps them from using poker money for their mission, causing problems with IRS rules. A reasonable adjustment is to exclude funds raised through poker events from this rule.

VDACS creates a limitation on where an organization may host poker games.

Tournaments would be successful in the areas that serve the proper demographic, not necessarily where the organization is based. VDACS does not have the authority to create this rule. The Code specifically provides this limitation regarding bingo and pull tabs, and leaves it out with respect to poker.  Strike proposed 11VAC20-30-90.G.