Dear VDACS,

My comment pertains to concurrent tournaments. VDACS' prohibition negatively impacts players, dealers, and charities because it exceeds their scope and isn't supported by law. This baseless constraint on legal poker events appears unwarranted without a crucial regulatory need to safeguard charitable gaming. Why do the regulations prevent concurrent tournaments when the Code permits them? A reasonable change is to strike proposed 11VAC20-30-90.F.

My comment concerns tipping. VDACS’ prohibition harms dealers, players, and charities because, without the ability to provide standard poker room compensation, charities cannot effectively operate poker games, possibly not playing at all. Tipping is essential for dealers’ livelihoods in the poker industry. Why do regulations prohibit tipping when the Code allows it? This arbitrary restriction suggests VDACS lacks understanding of the poker sector. A reasonable solution is to remove this tipping constraint.

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 want to address re-buys. VDACS confuses "rebuys" and "add-ons," detrimentally affecting players, dealers, and charities. "Rebuys" occur after a player exhausts their chips; it's impractical to limit them before elimination. VDACS complicates the game with superfluous restrictions, resulting in higher compliance costs due to poorly formulated regulations. VDACS's guidelines are out of sync with the game and industry, generating confusion. A logical solution is to strike 11VAC20-30-100.H; if the objective is to limit tournament duration, § 18.2-340.33.16 already establishes a predetermined end time.

Thank you for your time,

Terrance