I have been going to Pop's for years and believe that they have the highest integrity for a poker room possible.  There are several changes that I think need to be made.

My comment pertains to concurrent tournaments. VDACS' prohibition negatively impacts players, dealers, and charities because it exceeds their scope and isn't supported by law. This baseless constraint on legal poker events appears unwarranted without a crucial regulatory need to safeguard charitable gaming. Why do the regulations prevent concurrent tournaments when the Code permits them? A reasonable change is to strike proposed 11VAC20-30-90.F.

My comment relates to tipping. Where VDACS prohibits tipping dealers, it hurts dealers, players and charities because without being able to offer normal poker room compensation, charities will not be able to operate poker properly, and may not even play at all. Tipping is an integral dealers make a living wage throughout all of poker gaming. Why would the regs add a prohibition on players tipping dealers while the Code permits it? This feels like an arbitrary restriction. This shows VDACS doesn’t understand the poker industry AT ALL. One reasonable fix would be to strike this restriction on tipping.

I'd like to discuss the use of proceeds amount. VDACS insists charities follow 11VAC20-20-110 for its use of proceeds formula, which damages charitable poker. Charities would find it challenging to host tournaments, as they wouldn't raise enough money for expenses and the necessary use of proceeds. Reviewing a simple tournament budget demonstrates this formula's ineptitude. The resolution is to implement the newly accepted pull tab formula for 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,

Herman