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 concerns re-buys. VDACS mixes up "rebuys" and "add-ons," harming players, dealers, and charities. "Rebuys" occur when a player depletes their chips; restricting them before elimination is unworkable. VDACS imposes extra limitations with dubious reasoning, raising compliance costs due to poorly designed regulations. VDACS generates confusion with misaligned guidelines for the game and industry. A reasonable solution is to strike 11VAC20-30-100.H; if the aim is to limit tournament duration, § 18.2-340.33.16 already mandates a predetermined end time.