Concurrent Tournaments 

The restrictions hurts players, dealers and the charities by overstepping its boundaries and not being authorized by statute. The limitation on legal poker tournaments seems excessive without a convincing a regulatory need to ensure charitable gaming is protected. Why would  regulations ban concurrent tournaments while the code allows them? A fair solution is to remove proposed 11VAC20-30-90 F.

Tipping

This restriction hurt dealers, players and charities. It stops normal poker room compensation. Tipping is vital for dealers income in the poker world. Why does the regulation prevent tipping when the code allows it? I reasonable solution is to remove the tipping constraint.

Amount of use Proceeds

VDACS requires charities to follow 11VAC20-20-110 for its use of proceeds formula. This would harm charities and not allow them to host poker tournaments. The formula would not allow charities to raise sufficient funds to cover expenses and meet the required use of proceeds. A solution is to apply the recently adopted pull tab formula to poker.

Rebuy

VDACS mistakes "rebuys" for "add-ons," negatively affecting players, dealers, and charities. "Rebuys" happen after a player loses all chips, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions, increasing administrative and legal costs due to ill-conceived regulations. VDACS's guidelines misalign with the game and industry, causing confusion. A sensible fix is to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

Operational Fees

The VDACS stipulates that charities can only pay operators a set fee for their services, not a proportion of the revenue. This is detrimental to charities since they remain responsible for the flat fee even if revenue drops. It's strange that VDACS imposes this kind of arbitrary constraint. A logical solution would be to remove the first two sentences of 11VAC20-30-60.P. Commissioner Guthrie has emphasized the importance of charities meeting their use of proceeds requirements. Beyond this, there is no need for the state to interfere in the management of charities' business activities.

Electromechanical Devices 

 The inflexible restriction on technology usage in poker operations by VDACS detrimentally affects dealers, players, and charities. In this modern age, technology is responsible for enhancing everything. The game operation is significantly improved in terms of efficiency, enjoyment, and accuracy when technology software and hardware are employed for management. Utilizing technology is far more favorable for maintaining the game's integrity than depending on manual tracking, which is prone to human errors. The suggested 11VAC20-20-90.O must be rescinded.

Player limitations

Pertaining to player constraints, 11VAC20-30-90.C-D places undue restrictions on individuals with tenuous connections to poker games, harming players, dealers, and charities. These excessive limitations impede the poker community's togetherness and enjoyment of the game, indicating VDACS' lack of industry insight. A practical resolution would be to abolish 11VAC20-30-90.C-D and restrict only family members of dealers from playing at the table they are dealing at.

Calendar

Where VDACS specifies periods of operation ties to calendar days and weeks, it harms charities and the ideal operation and efficiency of charitable poker. This definition misunderstands that poker rooms often operate on an adjusted 24-hour period and would wreak havoc on ordinary reporting requirements. One reasonable fix would be to Define “Calendar day” with respect to poker to mean the period of 24 consecutive hours as set by the charitable organization. And make the conforming change to the definition of “Calendar week”.

Badge

VDACS' requirement to display dealers' full names, including first and last names, puts dealers at risk of undue harassment or worse. This strays from the industry norm and dealers prefer consistency with other gaming environments. A logical solution is to mandate only the first name on badges.

Use of Proceeds

VDACS bans funds for fraternal activities, which is bad for charities because these groups help members in fun and social ways. VDACS' rule stops them from using poker money for their goal, causing issues with IRS rules. One solution is to not apply this rule to money from poker events.

Restrictions on Location

The success of tournaments would be determined by their presence in areas that align with the desired demographic, instead of being restricted to the organization's home base.