My comment concerns concurrent tournaments. VDACS' prohibition harms players, dealers, and charities due to overreach and lack of statutory authorization. This arbitrary restriction on legal poker tournaments appears unreasonable without a strong regulatory need for ensuring charitable gaming integrity. Why do regulations prohibit concurrent tournaments when the Code allows it? A reasonable solution is to remove proposed 11VAC20-30-90.F.

I want to address tipping. VDACS’ restriction hurts dealers, players, and charities due to the inability to offer typical poker room compensation, affecting charity poker operations and potentially stopping play. Tipping is essential for dealers’ financial well-being in the poker industry. Why would regulations ban tipping while the Code allows it? This baseless limitation suggests VDACS lacks knowledge of the poker field. A fair solution is to remove this tipping constraint.

My comment pertains to the use of proceeds amount. VDACS demands charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which undermines charitable poker. Charities would struggle to organize tournaments, failing to generate sufficient funds for costs and the required use of proceeds. A basic tournament budget analysis reveals this formula's shortcomings. The answer is to apply the recently embraced pull tab formula to poker.

Thank you.