I feel the people making these legislations are so uninformed and ignorant of the poker community that I’ve actually started looking into moving out of the state of Virginia as a result of the legislation you wish to put in place. Therefore these are my suggestions. Ask yourselves, is this really the reputation we want as a state? Picking on the small guys to further the he agenda of large casinos?
The god you serve would be highly disappointed. 

My comment relates to concurrent tournaments. Where VDACS prohibits concurrent tournaments, it hurts players, dealers, and charities because VDACS is overreaching in limiting play in a way not authorized by statute. It creates an arbitrary limitation on legal poker tournaments, and it feels like an unreasonable limitation without a compelling regulatory need to ensure the integrity of charitable gaming. Why would the regulations add a prohibition on concurrent tournaments while the Code permits it? One reasonable fix to VDACS's error would be to strike proposed 11VAC20-30-90.F

My comment relates to tipping. Where VDACS prohibits tipping dealers, it hurts dealers, players and charities because without being able to offer normal poker room compensation, charities will not be able to operate poker properly, and may not even play at all. Tipping is an integral dealers make a living wage throughout all of poker gaming. Why would the regs add a prohibition on players tipping dealers while the Code permits it? This feels like an arbitrary restriction. This shows VDACS doesn’t understand the poker industry AT ALL. One reasonable fix would be to strike this restriction on tipping.

My comment relates to the amount of the use of proceeds. VDACS requires charities to blanketly follow 11VAC20-20-110 for its use of proceeds formula. This destroys charitable poker. Charities couldn’t afford to host any tournaments. A tournament wouldn’t raise enough money to pay its bills and also meet this use of proceeds amount. Anyone who can run a simple budget for a tournament will realize that this formula is an incompetent approach. The fix is to apply the recently adopted formula for pull tabs to poker.

My comment relates to re-buys. VDACS confuses "rebuys" and "add-ons". This is harmful to players, dealers and charities. Rebuys" happen once a player loses all chips; a rule limiting them before elimination is unfeasible. VDACS imposes extra restrictions with questionable rationale, increasing administrative and legal costs for compliance with ill-suited regulations. VDACS creates confusion with guidelines misaligned with the game and industry. Since "rebuys" occur after chip loss, it's illogical to limit them before player elimination. VDACS' rule adds unnecessary constraints and associated compliance costs due to poorly conceived regulations. The published guidelines demonstrate a lack of understanding of the game and industry, causing confusion. One reasonable fix to this is to strike 11VAC20-30-100.H. If the justification is to limit the duration of a tournament, § 18.2-340.33.16 already provides that tournaments must have a predetermined end time (which is strange in its own right).

My comment relates to operator fees. VDACS requires that charities may only pay a fixed fee to an operator for services, and not a percentage of the revenue. This hurts charity. 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. One reasonable solution is to 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.

My comment relates to electromechanical devices. When VDACS flatly restricts the use of technology in poker operations, it hurts dealers, players, and charities. In the 21st century, technology makes everything better. The game operation is made so much more efficient, enjoyable, and accurate when we use technology software and hardware to help manage it. Technology is significantly more beneficial to maintaining the integrity of the game than tracking everything by hand and subject to human error. The proposed 11VAC20-20-90.O should be removed.

My comment relates to player limitations. 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. This harms players, dealers, and charities because 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.

My comment relates to the calendar: Where VDACS specifies periods of operation ties to calendar days and weeks, it harms charities and the ideal operation and efficiency of charitable poker. This definition misunderstands that poker rooms often operate on an adjusted 24-hour period and would wreak havoc on ordinary reporting requirements. One reasonable fix would be to Define “Calendar day” with respect to poker to mean the period of 24 consecutive hours as set by the charitable organization. And make the conforming change to the definition of “Calendar week”.

My comment relates to badges. Where VDACS requires printing each dealers’ full name, including first and last names on their badge, it harms dealers because publicizing dealers’ names exposes them to undue harassment or worse. The industry norm is not to print last names, and dealers don’t want to be in a place that is divergent from all other gaming environments. one reasonable fix to VDACS's error would be to require only printing the first name on the badge.

My comment relates to the use of proceeds where VDACS prohibits using funds for fraternal activities. This is harmful to charities because Fraternal organizations are chartered to serve their members in social and recreational ways as a part of their mission. VDACS applies 11VAC20-20-110.D across the board resulting in an absurdity that fraternal organizations can’t use charitable poker funds for their charitable purpose. This would frustrate our compliance with IRS rules for using our charitable funds for our charitable mission. One reasonable fix to VDACS's error would be to provide that 11VAC20-20-110.D shall not apply to fund generated by the charity from hosting poker tournaments.

Competitions would thrive in regions that cater to the appropriate target audience, rather than being confined to the location of the organization itself.