Virginia Regulatory Town Hall
Agency
Department of Agriculture and Consumer Services
 
Board
Department of Agriculture and Consumer Services, Charitable Gaming
 
chapter
Texas Hold’em Poker Tournament Regulations [11 VAC 20 ‑ 30]
Action Promulgation of regulations for Texas Hold’em poker tournaments by the Department of Agriculture and Consumer Services
Stage Proposed
Comment Period Ended on 5/10/2023
spacer
Previous Comment     Next Comment     Back to List of Comments
4/20/23  5:44 pm
Commenter: Don Holtz

Poker Regulations in Virginia
 

With the restrictions that you want to impose, it would hamper the success of venues hosting Texas hold-em poker.  I think that if we limit the number of tables to one table, or one single tournament, it would be detrimental to operate under that format.

Please allow tipping to staff and dealers, it is no different than tipping in a restaurant.  Otherwise, we would not be able to attract quality people to administer the game with integrity.

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.

My remark pertains to re-buys. VDACS mistakes "rebuys" for "add-ons," negatively affecting players, dealers, and charities. "Rebuys" happen after a player loses all chips, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions, increasing administrative and legal costs due to ill-conceived regulations. VDACS's guidelines misalign with the game and industry, causing confusion. A sensible fix is to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

Thank you for your time reading this,

Don

CommentID: 216591