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.

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 statement pertains to the topic of electromechanical devices. The inflexible restriction on technology usage in poker operations by VDACS detrimentally affects dealers, players, and charities. In this modern age, technology is responsible for enhancing everything. The game operation is significantly improved in terms of efficiency, enjoyment, and accuracy when technology software and hardware are employed for management. Utilizing technology is far more favorable for maintaining the game's integrity than depending on manual tracking, which is prone to human errors. The suggested 11VAC20-20-90.O must be rescinded.