My comment pertains to concurrent tournaments. VDACS' prohibition negatively impacts players, dealers, and charities because it exceeds their scope and isn't supported by law. This baseless constraint on legal poker events appears unwarranted without a crucial regulatory need to safeguard charitable gaming. Why do the regulations prevent concurrent tournaments when the Code permits them? A reasonable change is to strike 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.

My remark pertains to re-buys. VDACS mistakes "rebuys" for "add-ons," negatively affecting players, dealers, and charities. "Rebuys" happen after a player loses all chips, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions, increasing administrative and legal costs due to ill-conceived regulations. VDACS's guidelines misalign with the game and industry, causing confusion. A sensible fix is to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

Thanks for your help.