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 concerns tipping. VDACS’ prohibition harms dealers, players, and charities because, without the ability to provide standard poker room compensation, charities cannot effectively operate poker games, possibly not playing at all. Tipping is essential for dealers’ livelihoods in the poker industry. Why do regulations prohibit tipping when the Code allows it? This arbitrary restriction suggests VDACS lacks understanding of the poker sector. A reasonable solution is to remove this tipping constraint.
My comment concerns the use of proceeds amount. VDACS mandates charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which devastates charitable poker. Charities would struggle to host tournaments, as they wouldn't raise sufficient funds to cover expenses and meet the required use of proceeds. A basic tournament budget reveals this formula's inadequacy. A solution is to apply the recently adopted pull tab formula to poker.
My comment concerns re-buys. VDACS mixes up "rebuys" and "add-ons," harming players, dealers, and charities. "Rebuys" occur when a player depletes their chips; restricting them before elimination is unworkable. VDACS imposes extra limitations with dubious reasoning, raising compliance costs due to poorly designed regulations. VDACS generates confusion with misaligned guidelines for the game and industry. A reasonable solution is to strike 11VAC20-30-100.H; if the aim is to limit tournament duration, § 18.2-340.33.16 already mandates a predetermined end time.
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.
In relation to player restrictions, 11VAC20-30-90.C-D unfairly imposes constraints on those with loose connections to poker games, adversely impacting players, dealers, and charities. These unnecessary limitations hinder the poker community's unity and game enjoyment, showcasing VDACS' unfamiliarity with the industry. A fitting amendment would be to repeal 11VAC20-30-90.C-D and only ban a dealer's family member from participating at their dealing table.
Regarding the calendar, VDACS' stipulation of operation periods based on calendar days and weeks hampers charity poker's optimal operation and effectiveness. This misconception fails to account for poker rooms' modified 24-hour cycles, causing chaos in reporting. A reasonable fix is to redefine "calendar day" as a 24-hour span determined by the charitable organization and make a conforming change to "calendar week."
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.
In regards to restricton on location, VDACS does not possess the power to formulate this rule. The Code distinctly sets this constraint for bingo and pull tabs, and deliberately omits it when it comes to poker.
