I am a member of the Commonwealth's Charitable Gaming Board and a lawyer.  I have no interest in any organizations that conduct, own, serve as landlord to, or otherwise participate in charitable gaming in the Commonwealth.  

Our collective goal should be to protect the charities by allowing them to compete with casinos, historic horse racing, and games of chance.  The proposed regulations are antithetical to that goal.

I echo the words of many of the other comments already submitted; namely:

a.  The proposed regulation (11 VAC 20-30-130 (G)(1) seeks to bar a landlord form also being an operator of a poker tournament.  Such a regulation is not authorized by the legislature.

b.  The proposed regulation 11 VAC 20-30-90F restricts concurrent poker tournaments from being played.  The charities need to have the ability to have tournaments start at different times with some overlap.  This is permitted by code.

c. VDACS cannot create a new rule of play.  Simply such power is not authorized by code.

d. Tipping should be allowed.  This provision directly impacts service employees.

I respectfully request that the regulations as proposed not be passed.