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 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.

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.