Concurrent Tournaments

-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

Tipping

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.

The Amount of Use of Proceeds

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.

Rebuys

My comment concerns 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. 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.

Operator Fees

My observation concerns operator fees. The VDACS stipulates that charities can only pay operators a set fee for their services, not a proportion of the revenue. This is detrimental to charities since they remain responsible for the flat fee even if revenue drops. It's strange that VDACS imposes this kind of arbitrary constraint. A logical solution would be to remove the first two sentences of 11VAC20-30-60.P. Commissioner Guthrie has emphasized the importance of charities meeting their use of proceeds requirements. Beyond this, there is no need for the state to interfere in the management of charities' business activities.

Electromechanical Devices

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.

Player Limitations

My observation addresses player restrictions. 11VAC20-30-90.C-D imposes unnecessary limitations on those even remotely linked to poker, harming players, dealers, and charities. These constraints hinder the poker community's camaraderie and enjoyment, reflecting VDACS' lack of industry knowledge. An appropriate remedy would be to strike 11VAC20-30-90.C-D and disallow family members of dealers from playing at their dealing table.

Calendar

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.

Badge

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.

Use of Proceeds

My comment is about the use of proceeds. VDACS doesn't allow funds for fraternal activities, which hurts charities since these organizations serve members socially and recreationally. VDACS' rule makes it impossible for them to use poker funds for their purpose, making it hard to follow IRS rules. A good fix is to exempt funds from poker tournaments from this rule.

Restriction on Location

My comment is about the use of proceeds. VDACS doesn't allow funds for fraternal activities, which hurts charities since these organizations serve members socially and recreationally. VDACS' rule makes it impossible for them to use poker funds for their purpose, making it hard to follow IRS rules. A good fix is to exempt funds from poker tournaments from this rule.