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.

I'd like to discuss the issue of operator fees. VDACS dictates that charities are only allowed to pay a fixed fee to operators for their services, as opposed to a percentage of the revenue. This creates difficulties for charities, as they are required to cover the flat fee even when revenue is low. It's odd that VDACS would establish such an arbitrary rule. A practical solution would be to delete the first two sentences of 11VAC20-30-60.P. Commissioner Guthrie has stressed the significance of charities meeting their use of proceeds. Beyond this aspect, the state shouldn't be involved in micromanaging charities' business dealings.

I'd like to discuss the issue of electromechanical devices. VDACS's rigid restriction on employing technology in poker operations negatively influences dealers, players, and charities. In the 21st century, technology serves to better all aspects of our lives. By incorporating technology software and hardware in the game's operation, it becomes more efficient, enjoyable, and precise. Relying on technology proves to be much more beneficial for preserving the game's integrity than manually recording everything and risking human mistakes. The proposed 11VAC20-20-90.O should be abolished.

Pertaining to player constraints, 11VAC20-30-90.C-D places undue restrictions on individuals with tenuous connections to poker games, harming players, dealers, and charities. These excessive limitations impede the poker community's togetherness and enjoyment of the game, indicating VDACS' lack of industry insight. A practical resolution would be to abolish 11VAC20-30-90.C-D and restrict only family members of dealers from playing at the table they are dealing at.

My comment addresses the calendar: VDACS' outlined operational periods connected to calendar days and weeks impede the proper operation and efficiency of charitable poker. This misjudgment neglects poker rooms' customary adjusted 24-hour periods, disrupting ordinary reporting. A practical solution is to define "calendar day" as a 24-hour sequence determined by the charity and modify the "calendar week" definition accordingly.

In relation to badges, VDACS' rule to print dealers' complete names, comprising first and last names, puts dealers at risk for unwarranted harassment or graver outcomes. This conflicts with the industry standard, and dealers seek alignment with other gaming contexts. An appropriate adjustment is to require the badge to display only the first name.

I have a comment about use of proceeds. VDACS bans funds for fraternal activities, which is bad for charities because these groups help members in fun and social ways. VDACS' rule stops them from using poker money for their goal, causing issues with IRS rules. One solution is to not apply this rule to money from poker events.

Restriction on Location - VDACS lacks the jurisdiction to establish this regulation. The Code explicitly imposes this restriction concerning bingo and pull tabs while excluding it in relation to poker.