Hi,

Thank you for giving me the opportunity to speak and comment on the regulatory actions that are taking place with Charity Poker. I know it is hard to read through these changes but i really hope this will make a impact on your decision.  Please read all the below comments. Thank you. 

I want to comment about concurrent tournaments. VDACS's 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 also want to comment on 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 also want to comment about the use of proceeds amount. VDACS demands charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which undermines charitable poker. Charities would struggle to organize tournaments, failing to generate sufficient funds for costs and the required use of proceeds. A basic tournament budget analysis reveals this formula's shortcomings. The answer is to apply the recently embraced pull tab formula to poker. 

I also want to comment on 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. 

I also want to comment on operator fees. VDACS insists that charities must pay operators a fixed fee for services, rather than a percentage of the revenue. This is harmful to charities, as they are still obligated to pay the flat fee even if revenue declines. It is odd that VDACS would include such an arbitrary restriction. A reasonable resolution would be to strike the opening two sentences of 11VAC20-30-60.P. As Commissioner Guthrie has pointed out, it is vital for charities to comply with their use of proceeds. Beyond this, the state should not be involved in the minutiae of charities' business operations. 

I also want to comment on electromechanical devices. By imposing a flat restriction on the use of technology in poker operations, VDACS causes harm to dealers, players, and charities. In contemporary times, technology is key to improving various aspects of life. Leveraging technology software and hardware for game management results in increased efficiency, pleasure, and accuracy. The use of technology is significantly more advantageous in safeguarding the game's integrity than manually tracking information and being susceptible to human error. The recommended 11VAC20-20-90.O needs to be revoked. 

I want to also comment on 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. 

I want to also comment on the calendar: VDACS' outlined operational periods connected to calendar days and weeks impede the proper operation and efficiency of charitable poker. This misjudgment neglects poker rooms' customary adjusted 24-hour periods, disrupting ordinary reporting. A practical solution is to define "calendar day" as a 24-hour sequence determined by the charity and modify the "calendar week" definition accordingly. 

I also want to comment on badges: VDACS' requirement to show dealers' full names, incorporating first and last names, subjects them to undue harassment or worse scenarios. This contradicts the industry norm, and dealers desire consistency with other gaming surroundings. A practical solution is to mandate only the first name on badges. 

I also want to comment on the use of proceeds. VDACS prohibits funds for fraternal activities, hurting charities because these organizations aim to serve members through social and fun activities. VDACS' rule bars them from using poker funds for their purpose, making IRS compliance difficult. One solution is to not apply this rule to funds from poker tournaments. 

Finally, I want to comment on the restriction on location. Competitions would thrive in regions that cater to the appropriate target audience, rather than being confined to the location of the organization itself.

I want to stress once more that I am very serious about these requets and I hope that these comments are taken very seriously. 

Thank you.