Dear VDACS,

I'd like to comment on concurrent tournaments. VDACS' ban negatively affects players, dealers, and charities as it exceeds their authority and isn't supported by statute. This unwarranted limitation on legal poker events seems unjustified without a pressing regulatory necessity to protect charitable gaming. Why do the regulations forbid concurrent tournaments while the Code permits them? A sensible fix is 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 want to address the use of proceeds amount. VDACS requires charities to follow 11VAC20-20-110 for its use of proceeds formula, which negatively impacts charitable poker. Charities would be incapable of hosting tournaments, not raising enough funds to meet expenses and the mandated use of proceeds. Assessing a simple tournament budget highlights this formula's inefficiency. A solution is to adopt the recently established pull tab formula for poker.

The idea that rebuys are only for people who haven't lost all of their chips doesn't make any sense, rebuys should be allowed at any tournament that the host allows.  Players like and I feel that it would help charities make more money.

Regarding player limitations, 11VAC20-30-90.C-D excessively constrains individuals indirectly associated with poker games, detrimentally affecting players, dealers, and charities. This unwarranted restriction disrupts the poker community's cohesion and game enjoyment. VDACS would not have implemented these rules if they were familiar with the industry. A reasonable correction would be to remove 11VAC20-30-90.C-D and only forbid a dealer's family member from playing at their table.

Thanks,

Ruben