I would like to comment on the use of proceeds amount. VDACS requires charities to blindly follow 11VAC20-20-110 for its use of proceeds formula, which HARMS charitable poker. Charities would be unable to host tournaments, failing to raise enough money for expenses and the required use of proceeds. Evaluating a simple tournament budget exposes this formula's incompetence. The remedy is to implement the newly adopted pull tab formula for poker where the ratio is acceptable and reasonable AND AGREED upon from the public.

Also, as far as the operating fees you all should strike the first two sentences of 11VAC20-30-60.P.  As Commissioner Guthrie has conveyed, what is important is that charities meet their use of proceeds. Beyond that, what interest does the state have in micromanaging charities’ business operations?  If revenue is down, the charity is still on the hook for whatever the flat fee is.  It’s bizarre that VDACS would impose this type of arbitrary restriction. Charitable organizations may have limited resources and staff, and overly complex regulations can make it difficult for them to navigate the rules and paperwork required to organize a charitable poker event. This can lead to a decreased likelihood of success and limit the impact of the fundraising effort which is what WE ARE FOCUSED ON.  We should ALL accept the support of charities helping our community.  It's important to note that Charitable poker events can be expensive to organize, and overly restrictive regulations may require charities to pay additional fees or meet costly compliance requirements. This can reduce the amount of money that ultimately goes towards the charitable cause. 

Limited participation: If regulations are too constricting, it may discourage individuals and organizations from participating in charitable poker events. This can limit the pool of potential donors and reduce the overall amount of money raised. 11VAC20-30-90.C-D restricts all sorts of people connected in some way to someone connected to a poker game (yes, it’s that tenuous) from playing in the tournament.  It is unduly restrictive for no reason. And, especially in the family/community environment that most poker rooms have, all these restrictions interfere with the poker community coming together and enjoying the game.  If VDACS were familiar with the poker industry, these rules would never have been included. Please get rid of the regulation 11VAC20-30-90.C-D, prohibiting only a family member of a dealer from playing at the table at which that family member is dealing. 

Lack of flexibility: Charitable poker regulations that are too rigid may limit the types of games and events that can be offered, which can reduce the appeal and excitement of the fundraising activity. This can limit the number of people who participate and ultimately reduce the amount of money raised for the charitable cause.  

Overall, while regulations are important for ensuring the safety and integrity of charitable poker events, they need to strike a balance between protecting the public and allowing charities to raise funds in an effective, reasonable, efficient manner. The public advises that VDACS should consider working WITH (not against) Pop's Poker to making informed, knowledgeable decisions and regulations.  If not we should all assume the Casino's are corrupting the charitable gaming industry.