On behalf of the Virginia Charitable Bingo Association am writing to request four extremely important revisions to the charitable poker regulations. 

Concurrent Tournaments

The ability of a charity to play concurrent tournaments is critical for that organization to make money for its charitable purpose. There is no legitimate reason either commercial or regulatory for the Department to prohibit concurrent tournaments. Additionally, the Virginia General Assembly did not oppose this concept and to the best of my knowledge not one member of the General Assembly, the Department or the Governor’s office has ever expressed a concern about concurrent tournaments before, during or after the legislative process. The regulations should immediately be revised to allow for and encourage concurrent tournaments. 

Use of Proceeds 

The Department’s proposal to tax charities on the prize money is absolutely ridiculous. The charities already pay too much tax to Virginia and we get very little regulatory oversight or support in return.   

Tipping 

I am not aware of one professional card dealer in the world who cannot be tipped in one way or another. How are the charities going to be able to find qualified card dealers and pay them without allowing for tipping? The Department has made its biggest mistake with these regulations by not allowing for tipping. Without tipping charities will not be able to pay dealers properly and the charities will end up with unqualified card dealers putting the entire operation at risk of being perceived as unprofessional and unqualified. The Department should want excellent card dealers and should know that tipping is the only way charities can afford qualified and ethical dealers! 

Landlord / Operator Restrictions 

Recommend the Department strike the requirement for landlords to register. This regulation is completely unnecessary and was never included in the legislation.