My comment concerns re-buys. VDACS mixes up "rebuys" and "add-ons," potentially negatively impacting players, dealers, and charities. "Rebuys" occur when a player depletes their chips; restricting them before elimination just does not work. VDACS imposes extra limitations with dubious reasoning, raising compliance costs due to poorly designed regulations. VDACS generates confusion with misaligned guidelines for the game and industry.  A reasonable solution is to strike 11VAC20-30-100.H; if the aim is to limit tournament duration, § 18.2-340.33.16 already mandates a predetermined end time.