Thank you for taking the time to read my comments.

My comment pertains to concurrent tournaments. VDACS' prohibition negatively impacts players, dealers, and charities because it exceeds their scope and isn't supported by law. This baseless constraint on legal poker events appears unwarranted without a crucial regulatory need to safeguard charitable gaming. Why do the regulations prevent concurrent tournaments when the Code permits them? A reasonable change is to strike proposed 11VAC20-30-90.F.

I want to address tipping. VDACS’ restriction hurts dealers, players, and charities due to the inability to offer typical poker room compensation, affecting charity poker operations and potentially stopping play. Tipping is essential for dealers’ financial well-being in the poker industry. Why would regulations ban tipping while the Code allows it? This baseless limitation suggests VDACS lacks knowledge of the poker field. A fair solution is to remove this tipping constraint.

I'd like to comment on the use of proceeds amount. VDACS requires charities to blindly follow 11VAC20-20-110 for its use of proceeds formula, which harms charitable poker. Charities would be unable to host tournaments, failing to raise enough money for expenses and the required use of proceeds. Evaluating a simple tournament budget exposes this formula's incompetence. The remedy is to implement the newly adopted pull tab formula for poker.

I'd like to comment on re-buys. VDACS confounds "rebuys" and "add-ons," causing harm to players, dealers, and charities. "Rebuys" take place once a player's chips are gone, making it nonsensical to limit them before elimination. VDACS adds extra constraints without clear justification, leading to increased compliance costs due to unsuitable regulations. VDACS's published guidelines create confusion, not aligning with the game and industry. A rational remedy is to strike 11VAC20-30-100.H, and if the intent is to restrict tournament length, § 18.2-340.33.16 already stipulates a predetermined end time.

Rashad