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.

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.

My comment relates to the amount of the use of proceeds. VDACS requires charities to blanketly follow 11VAC20-20-110 for its use of proceeds formula. This destroys charitable poker. Charities couldn’t afford to host any tournaments. A tournament wouldn’t raise enough money to pay its bills and also meet this use of proceeds amount. Anyone who can run a simple budget for a tournament will realize that this formula is an incompetent approach. The fix is to apply the recently adopted formula for pull tabs to poker.

My remark pertains to re-buys. VDACS mistakes "rebuys" for "add-ons," negatively affecting players, dealers, and charities. "Rebuys" happen after a player loses all chips, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions, increasing administrative and legal costs due to ill-conceived regulations. VDACS's guidelines misalign with the game and industry, causing confusion. A sensible fix is to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

Thank you,

Andrew