I'd like to comment on concurrent tournaments. VDACS' ban negatively affects players, dealers, and charities as it exceeds their authority and isn't supported by statute. This unwarranted limitation on legal poker events seems unjustified without a pressing regulatory necessity to protect charitable gaming. Why do the regulations forbid concurrent tournaments while the Code permits them? A sensible fix is to strike proposed 11VAC20-30-90.F.

I’d like to comment on tipping. VDACS’ ban negatively affects dealers, players, and charities since normal poker room compensation is impossible, hindering charity poker operations, and potentially eliminating play. Tipping is vital for dealers’ income in the poker world. Why do the regulations forbid tipping while the Code permits it? This random limitation implies VDACS doesn’t comprehend the poker industry. A sensible fix is to strike this restriction on tipping.

I'd like to comment on the use of proceeds amount. VDACS requires charities to blindly follow 11VAC20-20-110 for its use of proceeds formula, which harms charitable poker. Charities would be unable to host tournaments, failing to raise enough money for expenses and the required use of proceeds. Evaluating a simple tournament budget exposes this formula's incompetence. The remedy is to implement the newly adopted pull tab formula for poker.

Thank you for your timing and consideration.