My comment relates to concurrent tournaments. Where VDACS prohibits concurrent tournaments, it hurts players, dealers, and charities because VDACS is overreaching in limiting play in a way not authorized by statute. It creates an arbitrary limitation on legal poker tournaments, and it feels like an unreasonable limitation without a compelling regulatory need to ensure the integrity of charitable gaming. Why would the regs add a prohibition on concurrent tournaments while the Code permits it? One reasonable fix to VDACS's error would be to strike 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.

My comment relates to re-buys. VDACS confuses "rebuys" and "add-ons". This is harmful to players, dealers and charities. Rebuys" happen once a player loses all chips; a rule limiting them before elimination is unfeasible. VDACS imposes extra restrictions with questionable rationale, increasing administrative and legal costs for compliance with ill-suited regulations. VDACS creates confusion with guidelines misaligned with the game and industry. Since "rebuys" occur after chip loss, it's illogical to limit them before player elimination. VDACS' rule adds unnecessary constraints and associated compliance costs due to poorly conceived regulations. The published guidelines demonstrate a lack of understanding of the game and industry, causing confusion. One reasonable fix to this is to strike 11VAC20-30-100.H. If the justification is to limit the duration of a tournament, § 18.2-340.33.16 already provides that tournaments must have a predetermined end time (which is strange in its own right).