My comment relates to tipping. Where VDACS prohibits tipping dealers, it hurts dealers, players and charities because without being able to offer normal poker room compensation, charities will not be able to operate poker properly, and may not even play at all. Tipping is an integral dealers make a living wage throughout all of poker gaming. Why would the regs add a prohibition on players tipping dealers while the Code permits it? This feels like an arbitrary restriction. This shows VDACS doesn’t understand the poker industry AT ALL. One reasonable fix would be to strike this restriction on tipping.

My remark involves concurrent tournaments. VDACS' prohibition damages players, dealers, and charities because it goes beyond their mandate and lacks statutory backing. This random constraint on legal poker tournaments feels unwarranted without a compelling regulatory requirement to maintain charitable gaming integrity. Why do the regulations disallow concurrent tournaments when the Code approves them? One reasonable adjustment is to eliminate proposed 11VAC20-30-90.F.

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.

Thank you for your time.