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 pertains to tipping. VDACS’ prohibition negatively impacts dealers, players, and charities because it stops normal poker room compensation, hampering charity poker operations and potentially eliminating play. Tipping is vital for dealers’ income in the poker world. Why do the regulations prevent tipping when the Code permits it? This random restriction demonstrates VDACS’ misunderstanding of the poker industry. A reasonable change is to strike this restriction on tipping.

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.