I'd like to discuss concurrent tournaments. VDACS' ban on such events harms players, dealers, and charities as it goes beyond their purview and isn't authorized by statute. This arbitrary restriction on legal poker tournaments seems unreasonable without a significant regulatory need to uphold charitable gaming integrity. Why would regulations prohibit concurrent tournaments when the Code approves them? One logical fix is to eliminate proposed 11VAC20-30-90.F.

I’d like to discuss tipping. VDACS’ ban on tipping harms dealers, players, and charities as it disallows standard poker room compensation, hindering charity poker operations and possibly preventing play. Tipping is crucial for dealers’ livelihoods in the poker sector. Why would regulations prohibit tipping when the Code approves it? This arbitrary constraint reveals VDACS’ lack of understanding of the poker domain. One logical fix is to eliminate this tipping restriction.

I'd like to discuss the use of proceeds amount. VDACS insists charities follow 11VAC20-20-110 for its use of proceeds formula, which damages charitable poker. Charities would find it challenging to host tournaments, as they wouldn't raise enough money for expenses and the necessary use of proceeds. Reviewing a simple tournament budget demonstrates this formula's ineptitude. The resolution is to implement the newly accepted pull tab formula for poker.

My comment relates to re-buys. VDACS confuses "rebuys" and "add-ons". This is harmful to players, dealers and charities. Rebuys" happen once a player loses all chips; a rule limiting them before elimination is unfeasible. VDACS imposes extra restrictions with questionable rationale, increasing administrative and legal costs for compliance with ill-suited regulations. VDACS creates confusion with guidelines misaligned with the game and industry. Since "rebuys" occur after chip loss, it's illogical to limit them before player elimination. VDACS' rule adds unnecessary constraints and associated compliance costs due to poorly conceived regulations. The published guidelines demonstrate a lack of understanding of the game and industry, causing confusion. One reasonable fix to this is to strike 11VAC20-30-100.H. If the justification is to limit the duration of a tournament, § 18.2-340.33.16 already provides that tournaments must have a predetermined end time (which is strange in its own right).

Thank you.