To whom it may concern,

I want to address concurrent tournaments. VDACS' restriction hurts players, dealers, and charities due to overstepping its boundaries and not being authorized by statute. This arbitrary limitation on legal poker tournaments seems excessive without a convincing regulatory need to ensure charitable gaming is protected. Why would regulations ban concurrent tournaments while the Code allows them? A fair solution is to remove proposed 11VAC20-30-90.F.

My remark involves tipping. VDACS’ prohibition damages dealers, players, and charities because it prevents standard poker room compensation, impacting charity poker operations and possibly preventing play. Tipping is crucial for dealers’ earnings in the poker sphere. Why do the regulations disallow tipping when the Code approves it? This arbitrary constraint indicates VDACS is unfamiliar with the poker sector. One reasonable adjustment is to eliminate this tipping restriction.

My remark involves the use of proceeds amount. VDACS obliges charities to comply with 11VAC20-20-110 for its use of proceeds formula, which ruins charitable poker. Charities would face difficulties hosting tournaments, as they couldn't generate adequate funds for costs and the necessary use of proceeds. Examining a basic tournament budget shows this formula's ineffectiveness. The fix is to apply the recently introduced pull tab formula to poker.

My observation relates to re-buys. VDACS misinterprets "rebuys" as "add-ons," negatively impacting players, dealers, and charities. "Rebuys" arise after a player loses all chips, so constraining them before elimination is untenable. This provisions should be stricken.

Thank you for your time and consideration,

Brian