My comment concerns concurrent tournaments. VDACS' prohibition harms players, dealers, and charities due to overreach and lack of statutory authorization. This arbitrary restriction on legal poker tournaments appears unreasonable without a strong regulatory need for ensuring charitable gaming integrity. Why do regulations prohibit concurrent tournaments when the Code allows it? A reasonable solution is to remove proposed 11VAC20-30-90.F.

My comment 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.

My comment concerns the use of proceeds amount. VDACS mandates charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which devastates charitable poker. Charities would struggle to host tournaments, as they wouldn't raise sufficient funds to cover expenses and meet the required use of proceeds. A basic tournament budget reveals this formula's inadequacy. A solution is to apply the recently adopted pull tab formula to poker.

Thank you for your consideration,

Mark