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.

My observation concerns operator fees. The VDACS stipulates that charities can only pay operators a set fee for their services, not a proportion of the revenue. This is detrimental to charities since they remain responsible for the flat fee even if revenue drops. It's strange that VDACS imposes this kind of arbitrary constraint. A logical solution would be to remove the first two sentences of 11VAC20-30-60.P. Commissioner Guthrie has emphasized the importance of charities meeting their use of proceeds requirements. Beyond this, there is no need for the state to interfere in the management of charities' business activities.

In relation to badges, VDACS' rule to print dealers' complete names, comprising first and last names, puts dealers at risk for unwarranted harassment or graver outcomes. This conflicts with the industry standard, and dealers seek alignment with other gaming contexts. An appropriate adjustment is to require the badge to display only the first name.

My comment pertains to the use of proceeds amount. VDACS demands charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which undermines charitable poker. Charities would struggle to organize tournaments, failing to generate sufficient funds for costs and the required use of proceeds. A basic tournament budget analysis reveals this formula's shortcomings. The answer is to apply the recently embraced pull tab formula to poker.