Without being able to offer normal poker room compensation, charities will not be able to operate poker properly, and may not even play at all.  Tipping is an integral dealers/staff make a living wage throughout all of poker gaming

Why would the regulations add a prohibition on players tipping dealers/staff while the Code permits it?

This feels like an arbitrary restriction and shows VDACS doesn’t understand the poker industry AT ALL.

My remark involves the use of proceeds amount. VDACS obliges charities to comply with 11VAC20-20-110 for its use of proceeds formula, which ruins charitable poker. Charities would face difficulties hosting tournaments, as they couldn't generate adequate funds for costs and the necessary use of proceeds. Examining a basic tournament budget shows this formula's ineffectiveness. The fix is to apply the recently introduced pull tab formula to poker.

In relation to badges, VDACS' rule to print dealers' complete names, comprising first and last names, puts dealers at risk for unwarranted harassment or graver outcomes. This conflicts with the industry standard, and dealers seek alignment with other gaming contexts. An appropriate adjustment is to require the badge to display only the first name.