Concurrent Tournaments

The proposed regulations attempt to add an unreasonable limitation on charitable gaming.  If the General Assembly had intended to add this limitation against running concurrent tournaments, they would have done so in the Code.  The General Assembly, through the Virginia State Code, has "occupied the field" in this area, VDACS should not attempt to limit the charities to a greater extent than the Code.

Tipping

The proposed regulations prohibit tipping dealers.  Tipping is a normal part of poker.  If tipping is not allowed, then dealers will be unable to make a living wage, making it difficult for the charities to hire qualified dealers.

Badge Identification

The proposed regulations require printing of each dealers' full name on a name badge.  This is a safety risk.  Printing the dealers full name on the badge exposes them to undue harassment or even worse.  The norm for the industry is not to print last names and VDACS should follow suit.

Use of Proceeds

The proposed regulations prohibit the organizations from using funds for fraternal activities.  The main purpose of many of these organizations are set up for fraternal purposes.  At one point the regulations require the funds raised to be spent on the mission of the organization(s), but here insists that the funds cannot be spent on fraternal activities, when the mission of many of these organizations is fraternal activities (i.e. VFWs).