My remark involves concurrent tournaments. VDACS' prohibition damages players, dealers, and charities because it goes beyond their mandate and lacks statutory backing. This random constraint on legal poker tournaments feels unwarranted without a compelling regulatory requirement to maintain charitable gaming integrity. Why do the regulations disallow concurrent tournaments when the Code approves them? One reasonable adjustment is to eliminate proposed 11VAC20-30-90.F.

I’d like to comment on tipping. VDACS’ ban negatively affects dealers, players, and charities since normal poker room compensation is impossible, hindering charity poker operations, and potentially eliminating play. Tipping is vital for dealers’ income in the poker world. Why do the regulations forbid tipping while the Code permits it? This random limitation implies VDACS doesn’t comprehend the poker industry. A sensible fix is to strike this restriction on tipping.

My comment pertains to 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.

My comment relates to re-buys. VDACS confuses "rebuys" and "add-ons". This is harmful to players, dealers and charities. Rebuys" happen once a player loses all chips; a rule limiting them before elimination is unfeasible. VDACS imposes extra restrictions with questionable rationale, increasing administrative and legal costs for compliance with ill-suited regulations. VDACS creates confusion with guidelines misaligned with the game and industry. Since "rebuys" occur after chip loss, it's illogical to limit them before player elimination. VDACS' rule adds unnecessary constraints and associated compliance costs due to poorly conceived regulations. The published guidelines demonstrate a lack of understanding of the game and industry, causing confusion. One reasonable fix to this is to strike 11VAC20-30-100.H. If the justification is to limit the duration of a tournament, § 18.2-340.33.16 already provides that tournaments must have a predetermined end time (which is strange in its own right).

Thank you,

James