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.

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 remark involves the use of proceeds amount. VDACS obliges charities to comply with 11VAC20-20-110 for its use of proceeds formula, which ruins charitable poker. Charities would face difficulties hosting tournaments, as they couldn't generate adequate funds for costs and the necessary use of proceeds. Examining a basic tournament budget shows this formula's ineffectiveness. The fix is to apply the recently introduced pull tab formula to poker.

My comment is about 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.

Thank you for your time,

Chris