I want to address re-buys. VDACS confuses "rebuys" and "add-ons," detrimentally affecting players, dealers, and charities. "Rebuys" occur after a player exhausts their chips; it's impractical to limit them before elimination. VDACS complicates the game with superfluous restrictions, resulting in higher compliance costs due to poorly formulated regulations. VDACS's guidelines are out of sync with the game and industry, generating confusion. A logical solution is to strike 11VAC20-30-100.H; if the objective is to limit tournament duration, § 18.2-340.33.16 already establishes a predetermined end time.

My comment concerns the use of proceeds amount. VDACS mandates charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which devastates charitable poker. Charities would struggle to host tournaments, as they wouldn't raise sufficient funds to cover expenses and meet the required use of proceeds. A basic tournament budget reveals this formula's inadequacy. A solution is to apply the recently adopted pull tab formula to poker.

My comment relates to tipping. Where VDACS prohibits tipping dealers, it hurts dealers, players and charities because without being able to offer normal poker room compensation, charities will not be able to operate poker properly, and may not even play at all. Tipping is an integral dealers make a living wage throughout all of poker gaming. Why would the regs add a prohibition on players tipping dealers while the Code permits it? This feels like an arbitrary restriction. This shows VDACS doesn’t understand the poker industry AT ALL. One reasonable fix would be to strike this restriction on tipping.

My comment concerns concurrent tournaments. VDACS' prohibition harms players, dealers, and charities due to overreach and lack of statutory authorization. This arbitrary restriction on legal poker tournaments appears unreasonable without a strong regulatory need for ensuring charitable gaming integrity. Why do regulations prohibit concurrent tournaments when the Code allows it? A reasonable solution is to remove proposed 11VAC20-30-90.F.

Thank you,

Todd