My remark involves concurrent tournaments. VDACS' prohibition damages players, dealers, and charities because it goes beyond their mandate and lacks statutory backing. This random constraint on legal poker tournaments feels unwarranted without a compelling regulatory requirement to maintain charitable gaming integrity. Why do the regulations disallow concurrent tournaments when the Code approves them? One reasonable adjustment is to eliminate proposed 11VAC20-30-90.F.

My comment relates to tipping. Where VDACS prohibits tipping dealers, it hurts dealers, players and charities because without being able to offer normal poker room compensation, charities will not be able to operate poker properly, and may not even play at all. Tipping is an integral dealers make a living wage throughout all of poker gaming. Why would the regs add a prohibition on players tipping dealers while the Code permits it? This feels like an arbitrary restriction. This shows VDACS doesn’t understand the poker industry AT ALL. One reasonable fix would be to strike this restriction on tipping.

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.

I'd like to comment on re-buys. VDACS confounds "rebuys" and "add-ons," causing harm to players, dealers, and charities. "Rebuys" take place once a player's chips are gone, making it nonsensical to limit them before elimination. VDACS adds extra constraints without clear justification, leading to increased compliance costs due to unsuitable regulations. VDACS's published guidelines create confusion, not aligning with the game and industry. A rational remedy is to strike 11VAC20-30-100.H, and if the intent is to restrict tournament length, § 18.2-340.33.16 already stipulates a predetermined end time.

Thanks for listening,

Addie