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.

My remark involves tipping. VDACS’ prohibition damages dealers, players, and charities because it prevents standard poker room compensation, impacting charity poker operations and possibly preventing play. Tipping is crucial for dealers’ earnings in the poker sphere. Why do the regulations disallow tipping when the Code approves it? This arbitrary constraint indicates VDACS is unfamiliar with the poker sector. One reasonable adjustment is to eliminate this tipping restriction.

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.

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.

Thanks