I want to address concurrent tournaments. VDACS' restriction hurts players, dealers, and charities due to overstepping its boundaries and not being authorized by statute. This arbitrary limitation on legal poker tournaments seems excessive without a convincing regulatory need to ensure charitable gaming is protected. Why would regulations ban concurrent tournaments while the Code allows them? A fair solution is to remove proposed 11VAC20-30-90.F.

My comment pertains to tipping. VDACS’ prohibition negatively impacts dealers, players, and charities because it stops normal poker room compensation, hampering charity poker operations and potentially eliminating play. Tipping is vital for dealers’ income in the poker world. Why do the regulations prevent tipping when the Code permits it? This random restriction demonstrates VDACS’ misunderstanding of the poker industry. A reasonable change 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 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, 

Andrew