The proposed 11VAC20-30-90.F prohibiting concurrent tournaments should be eliminated. This random constraint on legal poker tournaments is unwarranted without a compelling regulatory requirement to maintain charitable gaming integrity. The Code approves concurrent tournaments and the regulations should comply with code.
Strike subsection 2 of 11VAC20-30-100.D. Tipping dealers/staff in a poker room is integral to their wages and room operation. Disallowing tips in a poker room is like disallowing tips for restaurant servers and staff. Simply foolish!
Charity poker rooms should use the ecently adopted formula for pull tabs. Requiring charities to follow 11VAC20-20-110 for its use of proceeds formula makes it fiscally impossible for them to host tournaments. A tournament doesn’t raise enough money to pay a typical prize, pay operation costs AND meet the 11VAC20-20-110 use of proceeds amount.
Strike 11VAC20-30-100.H. VDACS confuses "rebuys" and "add-ons." "Rebuys" occur when a player depletes their chips; restricting them before elimination is unworkable. This generates confusion with misaligned guidelines for the game and industry. If the aim is to limit tournament duration, § 18.2-340.33.16 already mandates a predetermined end time.
Strike the first two sentences of 11VAC20-30-60.P. VDACS stipulates that charities pay operators a set fee for their services. This is detrimental to charities since they remain responsible for the flat fee even if revenue drops. Charities should be allowed to pay operators a percentage of the revenue - that way the proportion is constant for all parties.
Strike 11VAC20-20-90.O. Poker game operation is so much more efficient, enjoyable and accurate when we use technology software and hardware to help manage it. Technology is significantly more beneficial to maintaining the integrity of the game than tracking everything by hand and subject to human error.
Strike 11VAC20-30-90.C-D. It is unduly restrictive. The poker community is a family. The only restriction should be to prohibit only a family member of a dealer from playing at the table at which that family member is dealing.
Regarding the calendar, VDACS' stipulation of operation periods based on calendar days and weeks hampers charity poker's optimal operation and effectiveness. This misconception fails to account for poker rooms' modified 24-hour cycles, causing chaos in reporting. A reasonable fix is to redefine "calendar day" as a 24-hour span determined by the charitable organization and make a conforming change to "calendar week."
Require only printing a dealer's first name on their badge. Publicizing dealers’ names exposes them to undue harassment or worse. The industry norm is not to print last names, and dealers don’t want to be in a place that is divergent from all other gaming environments.
Provide that 11VAC20-20-110.D shall not apply to fund generated by the charity from hosting poker tournaments. Fraternal organizations are chartered to serve their members in social and recreational ways as a part of their mission. Applying 11VAC20-20-110.D across the board means that fraternal organizations can’t use charitable poker funds for their charitable purpose. This goes against compliance with IRS rules to use charitable funds for the stated charitable mission.
Strike proposed 11VAC20-30-90.G. Poker tournaments are successful in areas that serve the proper demographic, not necessarily where the organization is based.
