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.

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.

I want to address the use of proceeds amount. VDACS requires charities to follow 11VAC20-20-110 for its use of proceeds formula, which negatively impacts charitable poker. Charities would be incapable of hosting tournaments, not raising enough funds to meet expenses and the mandated use of proceeds. Assessing a simple tournament budget highlights this formula's inefficiency. A solution is to adopt the recently established pull tab formula for 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, 

Mel