I want to address concurrent tournaments. VDACS' restriction hurts players, dealers, and charities due to overstepping its boundaries and not being authorized by statute. This arbitrary limitation on legal poker tournaments seems excessive without a convincing regulatory need to ensure charitable gaming is protected. Why would regulations ban concurrent tournaments while the Code allows them? A fair solution is to remove 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.

My remark involves the use of proceeds amount. VDACS obliges charities to comply with 11VAC20-20-110 for its use of proceeds formula, which ruins charitable poker. Charities would face difficulties hosting tournaments, as they couldn't generate adequate funds for costs and the necessary use of proceeds. Examining a basic tournament budget shows this formula's ineffectiveness. The fix is to apply the recently introduced pull tab formula to poker.

Thank you for bringing poker to fruition!