My comment relates to concurrent tournaments. Where VDACS prohibits concurrent tournaments, it hurts players, dealers, and charities because VDACS is overreaching in limiting play in a way not authorized by statute. It creates an arbitrary limitation on legal poker tournaments, and it feels like an unreasonable limitation without a compelling regulatory need to ensure the integrity of charitable gaming. Why would the regs add a prohibition on concurrent tournaments while the Code permits it? One reasonable fix to VDACS's error would be to strike 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.

I'd like to comment on the use of proceeds amount. VDACS requires charities to blindly follow 11VAC20-20-110 for its use of proceeds formula, which harms charitable poker. Charities would be unable to host tournaments, failing to raise enough money for expenses and the required use of proceeds. Evaluating a simple tournament budget exposes this formula's incompetence. The remedy is to implement the newly adopted pull tab formula for poker.

Regarding badges, VDACS' stipulation to print dealers' full names, with first and last names, exposes them to unnecessary harassment or more severe consequences. This diverges from industry standards, and dealers favor uniformity across gaming settings. A reasonable remedy is to require only the first name on badges.