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 remark involves tipping. VDACS’ prohibition damages dealers, players, and charities because it prevents standard poker room compensation, impacting charity poker operations and possibly preventing play. Tipping is crucial for dealers’ earnings in the poker sphere. Why do the regulations disallow tipping when the Code approves it? This arbitrary constraint indicates VDACS is unfamiliar with the poker sector. One reasonable adjustment is to eliminate this tipping restriction.

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