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.

Concerning player limitations, 11VAC20-30-90.C-D excessively restricts individuals with even distant connections to poker games from participating in tournaments. This unwarranted constraint negatively impacts players, dealers, and charities, disrupting the poker community's unity and enjoyment. Such rules wouldn't exist if VDACS understood the industry. A logical solution would be to eliminate 11VAC20-30-90.C-D and only prohibit a dealer's family member from playing at the table where they are dealing.

I would also like to address the matter of electromechanical devices. VDACS's blanket restriction on the utilization of technology in poker operations adversely impacts dealers, players, and charities. In the 21st century, technology contributes to the enhancement of all things. The game's operation becomes significantly more efficient, enjoyable, and accurate when managed using technology software and hardware. Employing technology is more effective in maintaining the game's integrity compared to manual tracking, which is vulnerable to human errors. The suggested 11VAC20-20-90.O should be withdrawn