My comment relates to concurrent tournaments. Where VDACS prohibits concurrent tournaments, it hurts players, dealers, and charities because VDACS is overreaching in limiting play in a way not authorized by statute. It creates an arbitrary limitation on legal poker tournaments, and it feels like an unreasonable limitation without a compelling regulatory need to ensure the integrity of charitable gaming. Why would the regulations add a prohibition on concurrent tournaments while the Code permits it? One reasonable fix to VDACS's error would be to strike proposed 11VAC20-30-90.F
