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 comment relates to the amount of the use of proceeds. VDACS requires charities to blanketly follow 11VAC20-20-110 for its use of proceeds formula. This destroys charitable poker. Charities couldn’t afford to host any tournaments. A tournament wouldn’t raise enough money to pay its bills and also meet this use of proceeds amount. Anyone who can run a simple budget for a tournament will realize that this formula is an incompetent approach. The fix is to apply the recently adopted formula for pull tabs to poker.