My comment is about re-buys. VDACS incorrectly equates "rebuys" with "add-ons," adversely impacting players, dealers, and charities. "Rebuys" happen when a player runs out of chips, so it's unreasonable to limit them pre-elimination. VDACS introduces unwarranted restrictions, raising compliance costs due to ill-advised regulations. VDACS's guidelines are inconsistent with the game and industry, leading to confusion. An appropriate fix is to strike 11VAC20-30-100.H, and if the purpose is to control tournament duration, § 18.2-340.33.16 already prescribes a fixed end time.