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
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4/20/23  6:02 pm
Commenter: Rae Ditto

Speaking to regs
 

Poker has its own rules why hinder a great game! Please see below

 

My comment concerns concurrent tournaments. VDACS' prohibition harms players, dealers, and charities due to overreach and lack of statutory authorization. This arbitrary restriction on legal poker tournaments appears unreasonable without a strong regulatory need for ensuring charitable gaming integrity. Why do regulations prohibit concurrent tournaments when the Code allows it? A reasonable solution is to remove proposed 11VAC20-30-90.F.

I’d like to comment on tipping. VDACS’ ban negatively affects dealers, players, and charities since normal poker room compensation is impossible, hindering charity poker operations, and potentially eliminating play. Tipping is vital for dealers’ income in the poker world. Why do the regulations forbid tipping while the Code permits it? This random limitation implies VDACS doesn’t comprehend the poker industry. A sensible fix is to strike this restriction on tipping

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.

CommentID: 216609