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.

My remark involves tipping. VDACS’ prohibition damages dealers, players, and charities because it prevents standard poker room compensation, impacting charity poker operations and possibly preventing play. Tipping is crucial for dealers’ earnings in the poker sphere. Why do the regulations disallow tipping when the Code approves it? This arbitrary constraint indicates VDACS is unfamiliar with the poker sector. One reasonable adjustment is to eliminate this tipping restriction

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.