I am the owner of Always Fun Casinos, LLC based in northern Virginia.  We provide casino entertainment for corporate events, private parties, and charities.  We have been in business for just over 20 years.  We provide casino entertainment at roughly 220 events a year.  These are casino nights and poker parties where no real gambling takes place.  I am looking to become a registered operator for Charitable Texas Holdem Poker Tournaments.  About a third of my clients are charitable organizations (“qualified organizations”) that have been very excited for the last 2 years about the idea of raising money for their charities via Texas Holdem tournaments.  

My comment pertains to regulation 11VA20-30-130 “Requirements regarding renting premises, agreements, and landlord participation”.  Most of the qualified organizations I work with have 1 or 2 large events a year where they have 150-200 guests attend.  They hold these events in ballrooms of large hotels or event venues.  To have the landlords of these hotels and event venues complete the Landlord Registration (Form 501) for a single event will be a show stopper.  These hotel corporations are not going to take the time or effort to gather all the information required (tax returns, etc.) for a single event.  Thus leaving the charitable organization with no place to conduct their charitable Texas Holdem poker tournament.

I do not believe the solution is to remove the Landlord Registration requirement altogether because it provides a valuable checks and balance for those charitable organizations conducting Texas Holdem poker tournaments on a regular basis (daily, weekly).  Instead, I suggest proving a waiver for landlords who rent their premises to qualified organizations to conduct Charitable Texas Holdem Poker tournaments only a limited number of times a year. I believe once a quarter or a maximum of 4 times a year would be a reasonable number of events that would fall within the proposed waiver guidelines.

Sincerely,

Matt D'Ercole

Owner, Always Fun Casinos