I love the venue at pops poker!!!

I I love Pop’s poker game I feel relaxed when ever I’m there

Prohibiting the use of technology does not make much sense in today's time. It allows for a more convenient experience. It does not interfere or cause issues so restricting the use of technology only creates a hindrance instead of anything useful.

Pops is a good family orientated establishment The employees are very nice that work there. I enjoyed the free roll games. 

My remark involves concurrent tournaments. VDACS'; prohibition damages players, dealers, and charities because it goes beyond their mandate and lacks statutory backing. This random constraint on legal poker tournaments feels unwarranted without a compelling regulatory requirement to maintain charitable gaming integrity. Why do the regulations disallow concurrent tournaments when the Code approves them? One reasonable adjustment is to eliminate proposed 11VAC20-30-90.F.

Pops is a good family orientated establishment The employees are very nice that work there. I enjoyed the free roll games. 

Here is the list of issues and my suggestions for them

• I want to address concurrent tournaments. VDACS'; restriction hurts players, dealers, and charities due to overstepping its boundaries and not being authorized by statute. This arbitrary limitation on legal poker tournaments seems excessive without a convincing regulatory need to ensure charitable gaming is protected. Why would regulations ban concurrent tournaments while the Code allows them? A fair solution is to remove 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 remark involves the use of proceeds amount. VDACS obliges charities to comply with 11VAC20-20-110 for its use of proceeds formula, which ruins charitable poker. Charities would face difficulties hosting tournaments, as they couldn't generate adequate funds for costs and the necessary use of proceeds. Examining a basic tournament budget shows this formula's ineffectiveness. The fix is to apply the recently introduced pull tab formula 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 observation concerns operator fees. The VDACS stipulates that charities can only pay operators a set fee for their services, not a proportion of the revenue. This is detrimental to charities since they remain responsible for the flat fee even if revenue drops. It's strange that VDACS imposes this kind of arbitrary constraint. A logical solution would be to remove the first two sentences of 11VAC20-30-60.P. Commissioner Guthrie has emphasized the importance of charities meeting their use of proceeds requirements. Beyond this, there is no need for the state to interfere in the management of charities' business activities.

• My remark pertains to electromechanical devices. Imposing an outright restriction on technology use in poker operations by VDACS negatively affects dealers, players, and charities. In today's world, technology enhances all aspects of life. Utilizing technology software and hardware to manage the game improves efficiency, enjoyment, and accuracy. Relying on technology is far more advantageous for preserving the game's integrity than manually tracking everything and being prone to human error. The suggested 11VAC20-20-90.O should be eliminated.

• With respect to player limitations, 11VAC20-30-90.C-D imposes unwarranted restrictions on people with remote links to poker games, negatively affecting players, dealers, and charities. These excessive constraints obstruct the poker community's bonding and game enjoyment, a result of VDACS' unfamiliarity with the industry. A suitable proposal would be to strike 11VAC20-30-90.C-D and prevent only a dealer's family member from playing at the table they are dealing.

• Pertaining to the calendar, VDACS' prescribed periods of operation tied to calendar days and weeks damage charities and the ideal functioning of charitable poker. This misunderstanding overlooks poker rooms' usual adjusted 24-hour timeframe, complicating reporting. A sensible amendment is to define "calendar day" as a continuous 24-hour period set by the charity, and adjust the "calendar week" definition to match.

• My observation concerns badges: VDACS' requirement to display dealers' full names, including first and last names, puts dealers at risk of undue harassment or worse. This strays from the industry norm and dealers prefer consistency with other gaming environments. A logical solution is to mandate only the first name on badges.

• I have a comment about use of proceeds. VDACS bans funds for fraternal activities, which is bad for charities because these groups help members in fun and social ways. VDACS' rule stops them from using poker money for their goal, causing issues with IRS rules. One solution is to not apply this rule to money from poker events.

• VDACS lacks the jurisdiction to establish this regulation. The Code explicitly imposes this restriction concerning bingo and pull tabs while excluding it in relation to poker.

Concurrent Tournaments

The community need Pops Poker to come back online fully. There’s a large community of players who love the game but also love networking and having positive conversations with everyone who comes out. Since playing at Pops poker I truly enjoyed the establishment and conversation with their staff and other patrons.

Strike proposed 11VAC20-30-90 cDG. Friendly poker game are good for families get together. 

The purpose of the 2020 charitable poker bill was to allow charities to replace lost bingo dollars AND to have a popular fundraiser available as a way to help charities in the face of the Casinos and Sports Book, and expanded Rosies operations.  These proposed poker regulations as written, effectively nullify the entire opportunity.  The Charities must be able to play concurrent tournaments because their customers will demand the variety!  ALL poker rooms tip their dealers and for the charities it is essential since the law will not allow the play of cash games as an additional chance for tips.  Can you imagine telling barbers and waitresses that tips are now illegal.  This punishes the charities and the dealer and supervisors, crushing any entrepreneurs hope to run a poker operation.  And why can't an owner of a building to be used for charitable poker also hire dealers and become a licensed poker operator?  Another effort to squash small business opportunities while allowing this overlap for massive Casinos, Sports Book, and Rosies.  It makes sense to protect the charities and make sure they are performing properly but to restrict the possible business opportunities that could come from charitable poker is unthinkable.  Have the regulatory body inspect and audit and get out of the way and let small businesses thrive as they serve charities.  One thing is certain, if the Casino and Sports Book and Rosies regulations were written in this proposed fashion, they never would have made it to this site!  

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

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.

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”.

I would like to provide feed back on the regulations proposed on poker there is absolutely no reason to side concurrent tournaments and tipping is a major part to the game it is a show to the dealers that you respect the job they do. I have been playing poker for 20 years and I do not understand why anyone would feel these restrictions would help the play it seams to me to be a blatant attempt to tie the hands of all but the largest casinos. 

Thank you for you time 

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 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 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.

• I'd like to discuss the use of proceeds amount. VDACS insists charities follow 11VAC20-20-110 for its use of proceeds formula, which damages charitable poker. Charities would find it challenging to host tournaments, as they wouldn't raise enough money for expenses and the necessary use of proceeds. Reviewing a simple tournament budget demonstrates this formula's ineptitude. The resolution is to implement the newly accepted pull tab formula for poker.
• 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.

• I’d like to comment on tipping. VDACS’ ban negatively affects dealers, players, and charities since normal poker room compensation is impossible, hindering charity poker operations, and potentially eliminating play. Tipping is vital for dealers’ income in the poker world. Why do the regulations forbid tipping while the Code permits it? This random limitation implies VDACS doesn’t comprehend the poker industry. A sensible fix is to strike this restriction on tipping.
• I'd like to comment on re-buys. VDACS confounds "rebuys" and "add-ons," causing harm to players, dealers, and charities. "Rebuys" take place once a player's chips are gone, making it nonsensical to limit them before elimination. VDACS adds extra constraints without clear justification, leading to increased compliance costs due to unsuitable regulations. VDACS's published guidelines create confusion, not aligning with the game and industry. A rational remedy is to strike 11VAC20-30-100.H, and if the intent is to restrict tournament length, § 18.2-340.33.16 already stipulates a predetermined end time.
• 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.
•  

Concerning badges 

Industry standards are that poker dealers 

should only have their first name on their name tag

This should apply to VDCAS also 

• I'd like to discuss the issue of electromechanical devices. VDACS's rigid restriction on employing technology in poker operations negatively influences dealers, players, and charities. In the 21st century, technology serves to better all aspects of our lives. By incorporating technology software and hardware in the game's operation, it becomes more efficient, enjoyable, and precise. Relying on technology proves to be much more beneficial for preserving the game's integrity than manually recording everything and risking human mistakes. The proposed 11VAC20-20-90.O should be abolished.

• I'd like to comment on concurrent tournaments. VDACS'; ban negatively affects players, dealers, and charities as it exceeds their authority and isn't supported by statute. This unwarranted limitation on legal poker events seems unjustified without a pressing regulatory necessity to protect charitable gaming. Why do the regulations forbid concurrent tournaments while the Code permits them? A sensible fix is to strike proposed 11VAC20-30-90.F.

• I'd like to discuss the use of proceeds amount. VDACS insists charities follow 11VAC20-20-110 for its use of proceeds formula, which damages charitable poker. Charities would find it challenging to host tournaments, as they wouldn't raise enough money for expenses and the necessary use of proceeds. Reviewing a simple tournament budget demonstrates this formula's ineptitude. The resolution is to implement the newly accepted pull tab formula for poker.

Why are you crushing the charities? The General Assembly has already taken charities to the brink of extinction.  Bingo is declining, and most people  - C3s and C4s - can't use the pull tabs.  Poker is the only lifeline we have.  Charities who take care of medical research, or education, or at risk youth, or religious outreach are being strangled.  Aren't these issues important to you anymore?  Are Casinos the only revenue stream you care about?  I doubt that they will care about our local causes.  Shame on you all for creating regulations that destroy a perfectly good charitable fundraising opportunity.  

• With respect to player limitations, 11VAC20-30-90.C-D imposes unwarranted restrictions on people with remote links to poker games, negatively affecting players, dealers, and charities. These excessive constraints obstruct the poker community's bonding and game enjoyment, a result of VDACS' unfamiliarity with the industry. A suitable proposal would be to strike 11VAC20-30-90.C-D and prevent only a dealer's family member from playing at the table they are dealing.

Why is that the rules and regulations are constantly changing to award the larger casinos and to keep  smaller businesses like Pop's Poker allowing people to play poker here closer to home when casinos are making large amounts of profits in their pockets and Pop's is not!!

1. Proposed 11VAC20-30-90.F not allowing concurrent poker tournaments.
   • This limitation/restriction is arbitrary and it is not supported by the current statute.  This restriction negatively impacts players, dealers and the charity.  Proposed 11VAC20-30-90.F should be stricken from these regulations.
     
     
2. Proposed subsection 2 of 11VAC20-30-100.D prohibits tipping dealers/staff.
   • Prohibiting tipping dealers/staff is absolutely preposterous!  Prohibiting tips to dealers/staff is like prohibiting tips to servers!  Dealers & staff of poker rooms rely on tips for their livelihood.  Without tips, dealers & staff won't make sufficient income and will likely have to pursue alternate jobs that provide more income.  This, in turn, negatively impacts players (like me) as well as the charity since the poker room could easily end up understaffed and unable to operate.  Tipping should be left to the discretion of the players.
     Proposed subsection 2 of 11VAC20-30-100.D should be stricken from these regulations.
     
3. Adhering to 11VAC20-20-110 for use of proceeds formula.
   
   • This formula simply doesn't make fiscal sense for charitable poker.  Poker tournaments do not generate enough money to allow for a reasonable prize pool, operating expenses plus the donation amount required by 11VAC20-20-110.
     A reasonable solution is to apply the recently introduced pull tab formula to poker.
     
     
4. 11VAC20-30-100.H limiting number of "rebuys" before a player is eliminated.
   • It seems that VDACS is confusing "rebuys" with "add-ons." "Rebuys" occur after a player depletes their chips; restricting them before elimination is unworkable. Ensuring compliance with a non-sensical regulation like this is impossible and simply raises the cost to operate a tournament.  This regulation only serves to hurt the game, the players, dealers and the charity.
     11VAC20-30-100.H should be stricken from these regulations.
     
     
5. 11VAC20-30-60.P stipulates that charities pay operators a set fee for their services.
   • This requirement is also a mathematical error.  Operators should be paid a proportion of the revenue, not a flat fee.  Tournament revenue will naturally vary. If a tournament's revenue is below average, a fixed fee will hurt the charity while a proportion of the revenue payment would be more fair to the charity.
     The initial two sentences of 11VAC20-30-60.P should be removed.
     
6. 11VAC20-20-90.O restricts the use of technology.
   • This rigid restriction on employing technology in poker operations negatively impacts dealers, players, and charities. In the 21st century, technology serves to better all aspects of our lives. By incorporating technology software and hardware in the game's operation, it becomes more efficient, precise, and enjoyable. Using technology will preserve the game's integrity much more than manually recording everything and risking human mistakes.
     The proposed 11VAC20-20-90.O should be abolished.
7. 11VAC20-30-90.C-D restricts people allowed to play in a tournament.
   • This regulation excessively constrains individuals indirectly associated with poker games from playing in a tournament.  This unwarranted restriction disrupts the poker community's cohesion and game enjoyment.  It unfairly hurts the game, the players, dealers and charities.
     11VAC20-30-90.C-D should be removed.  The only restriction should be to forbid a dealer's family member from playing at their table.
     
     
8. Calendar days and weeks.
   • Stipulating 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."
     
     
9. Dealer Badges
   • The requirement to print each dealers’ full name, including first and last names on their badge, harms dealers because publicizing dealers’ names exposes them to undue harassment or worse. The industry norm is not to print last names.  Dealers don’t want to be in a place that is divergent from all other gaming environments.
     This requirement should be changed to allow only printing the first name on the badge.
     
     
10. Regulation 11VAC20-20-110.D applied across the board.
    • Applying 11VAC20-20-110.D across the board doesn't let funds be used for fraternal activities.  This negatively affects charities as these groups provide social and recreational support to members. This rule disallows using poker funds for their goals, creating IRS compliance issues.
      Poker event funds should be exempt from this rule.
11. Proposed 11VAC20-30-90.G limiting where poker games can be hosted.
    
    • The success of poker tournaments will likely be determined by their presence in areas that align with the desired demographic.  The Code particularly enforces this limitation for bingo and pull tabs, and logically leaves it out for poker.  VDACS does not possess the power to formulate this rule.
      Proposed 11VAC20-30-90.G should be stricken from these regulations.

The authors of these regs have only made it more restrictive and prohibitive with the proposed regulations. Shouldn't they be helping charities? Seems more like they're on the casino payroll. 

Dealers should be able to be tipped. The are allowed to be tipped at the casino. 

Poker tournaments have no set ending time bc it is the last man standing.

The restrictions of who can play is beyond broad and negatively will affect the tournaments. 

Concurrent tournaments should be allowed.  This ban isn't supported by the statute.

Immediate family members is way too broad and restrictive and should only include members of a person's household. This definition should match it's definition in other areas of law.

Bottom line, these regs are beyond restrictive to the non -profits and the department is making it more difficult instead of helping.

I wanted to express/share my feelings on the charitable poker issues that you are considering.  First of all,  these events are well organized,  fun and brings a community together.  Regarding some off the rules and regulations that are being considered including concurrent tournaments, tipping and amount of use of proceeds.  After reading these restrictions seem to be inconsistent and arbitrary since they direct conflict with the current code that is in place.  Why would different groups be subject to different rules and regulation?  That simply does not make sense.  As a charitable event having such strict requirements on the economic levers also does not make sense.  These events are subject to many uncontrollable variables, such as number of participants.  To inflict financial risk to the event organizers makes these events less likely to happen.  I would like to end by saying that Pops Poker is a well run group.  I have been attending these events for a number of years and have always felt welcome, safe and part of a nice group of people.  

Comment #1: I'd like to address concurrent tournaments. VDACS'; ban on such events negatively affects players, dealers, and charities as it goes beyond their purview and isn't authorized by statute. This arbitrary restriction on legal poker tournaments seems unreasonable and frivolous without a foundational regulatory precedent designed to uphold charitable gaming integrity. Why would regulations prohibit concurrent tournaments when the Code approves them? Solution: Strike the restrictive proposed 11VAC20-30-90.F

Comment #2: I want to address tipping. VDACS’ restriction hurts dealers, players, and charities due to the inability to offer typical poker room compensation, affecting charity poker operations and potentially stopping play. Tipping is a standard and fully accepted nationwide form of compensation. Tipping is essential for a poker dealer’s financial survival no different than a restaurant waiter or airport baggage handler. Why would regulations ban tipping while the Code allows it? This limitation has no fundamental nor practical base and suggests VDACS lacks a basic operational knowledge of the poker field. A sound solution would be to remove this tipping constraint by striking subsection 2 of 11VAC20-30-100.D.

Comment #3: My comment concerns the use of proceeds amount. VDACS’ mandate requiring charities to adhere to 11VAC20-20-110 for its use of proceeds formula is not financially viable and makes the running of successful charitable poker events impractical. Charities would struggle to host tournaments, as they wouldn't raise sufficient funds to cover expenses while meeting the required use of proceeds mandate.  The detailed analysis of a basic tournament budget would refute the required formula.  A solution is to apply the recently adopted pull tab formula to poker.

Comment #4:  My remark pertains to re-buys. VDACS confuses "rebuys" for "add-ons," negatively affecting players, dealers, and charities. "Rebuys" become possible when a player has lost his entire starting chip stack, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions while increasing administrative and legal costs due to ill-conceived regulations. VDACS guidelines misalign with the game and industry thus causing confusion. A sensible fix would be to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

Comment #5: My remark pertains to the issue of operator fees. The VDACS mandates that only a fixed fee can be paid to an operator by charities for their services, rather than a percentage of the revenue. This negatively impacts charities because if the revenue decreases, the charity still has to pay the predetermined flat fee. It's peculiar that VDACS adds such an arbitrary limitation. A sensible approach would be to eliminate the initial two sentences of 11VAC20-30-60.P. As Commissioner Guthrie has expressed, the crucial aspect is that charities fulfill their use of proceeds obligations. Beyond that, what role does the state have in overseeing the business operations of charities?

Comment #6:  My remark pertains to electromechanical devices. Imposing an outright restriction on technology use in poker operations by VDACS negatively affects dealers, players, and charities. In today's world, technology enhances all aspects of life. Utilizing technology software and hardware to manage the game improves efficiency, enjoyment, and accuracy. Relying on technology is far more advantageous for preserving the game's integrity than manually tracking everything and being prone to human error. The suggested 11VAC20-20-90.O should be eliminated.

Comment #7:  Concerning player limitations, 11VAC20-30-90.C-D excessively restricts individuals with even distant connections to poker games from participating in tournaments. This unwarranted constraint negatively impacts players, dealers, and charities, disrupting the poker community's unity and enjoyment. Such rules wouldn't exist if VDACS understood the industry. A logical solution would be to eliminate 11VAC20-30-90.C-D and only prohibit a dealer's family member from playing at the table where they are dealing.

Comment #8:  My comment relates to the calendar: Where VDACS specifies periods of operation ties to calendar days and weeks, it impairs charities and the optimum operational efficiency of charitable poker events. 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 a poker related “Calendar Day” to mean the period of 24 consecutive hours as set by the charitable organization. In addition, make the same logical change to the definition of “Calendar Week”.

Comment #9:  My comment relates to badge. Where VDACS requires printing each dealers’ full name, including first and last names on their badge, it harms dealers because publicizing dealer 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.

Comment #10:  My comment involves the use of proceeds. VDACS prohibits funds for fraternal activities, hurting charities because these organizations aim to serve members through social and fun activities. VDACS' rule bars them from using poker funds for their purpose, making IRS compliance difficult. One solution is to not apply this rule to funds from poker tournaments.

Comment #11:  My comment addresses Restriction on Location. The success of tournaments would be determined by their presence in areas that align with the desired demographic, instead of being restricted to the organization's home base. VDACS lacks the jurisdiction to establish this regulation. The Code explicitly imposes this restriction concerning bingo and pull tabs while excluding it in relation to poker. The simple solution would be to strike the proposed 11VAC20-30-90.G.

I'd like to discuss concurrent tournaments. VDACS' ban on such events harms players, dealers, and charities as it goes beyond their purview and isn't authorized by statute. This arbitrary restriction on legal poker tournaments seems unreasonable without a significant regulatory need to uphold charitable gaming integrity. Why would regulations prohibit concurrent tournaments when the Code approves them? One logical fix is to eliminate proposed 11VAC20-30-90.F.

I’d like to discuss tipping. VDACS’ ban on tipping harms dealers, players, and charities as it disallows standard poker room compensation, hindering charity poker operations and possibly preventing play. Tipping is crucial for dealers’ livelihoods in the poker sector. Why would regulations prohibit tipping when the Code approves it? This arbitrary constraint reveals VDACS’ lack of understanding of the poker domain. One logical fix is to eliminate this tipping restriction.

I want to address the use of proceeds amount. VDACS requires charities to follow 11VAC20-20-110 for its use of proceeds formula, which negatively impacts charitable poker. Charities would be incapable of hosting tournaments, not raising enough funds to meet expenses and the mandated use of proceeds. Assessing a simple tournament budget highlights this formula's inefficiency. A solution is to adopt the recently established pull tab formula for poker.

I'd like to comment on re-buys. VDACS confounds "rebuys" and "add-ons," causing harm to players, dealers, and charities. "Rebuys" take place once a player's chips are gone, making it nonsensical to limit them before elimination. VDACS adds extra constraints without clear justification, leading to increased compliance costs due to unsuitable regulations. VDACS's published guidelines create confusion, not aligning with the game and industry. A rational remedy is to strike 11VAC20-30-100.H, and if the intent is to restrict tournament length, § 18.2-340.33.16 already stipulates a predetermined end time.

My remark pertains to the issue of operator fees. The VDACS mandates that only a fixed fee can be paid to an operator by charities for their services, rather than a percentage of the revenue. This negatively impacts charities because if the revenue decreases, the charity still has to pay the predetermined flat fee. It's peculiar that VDACS adds such an arbitrary limitation. A sensible approach would be to eliminate the initial two sentences of 11VAC20-30-60.P. As Commissioner Guthrie has expressed, the crucial aspect is that charities fulfill their use of proceeds obligations. Beyond that, what role does the state have in overseeing the business operations of charities?

I would like to address the matter of electromechanical devices. VDACS's blanket restriction on the utilization of technology in poker operations adversely impacts dealers, players, and charities. In the 21st century, technology contributes to the enhancement of all things. The game's operation becomes significantly more efficient, enjoyable, and accurate when managed using technology software and hardware. Employing technology is more effective in maintaining the game's integrity compared to manual tracking, which is vulnerable to human errors. The suggested 11VAC20-20-90.O should be withdrawn.

Concerning player limitations, 11VAC20-30-90.C-D excessively restricts individuals with even distant connections to poker games from participating in tournaments. This unwarranted constraint negatively impacts players, dealers, and charities, disrupting the poker community's unity and enjoyment. Such rules wouldn't exist if VDACS understood the industry. A logical solution would be to eliminate 11VAC20-30-90.C-D and only prohibit a dealer's family member from playing at the table where they are dealing.

• In relation to the calendar, VDACS' designation of operation periods based on calendar days and weeks negatively impacts charitable poker's operation and efficiency. This misapprehension disregards poker rooms' typical adjusted 24-hour schedule, creating reporting issues. A suitable remedy is to redefine "calendar day" as a 24-hour interval established by the charitable organization, and make a corresponding change to the "calendar week" definition.

• My observation concerns badges: VDACS' requirement to display dealers' full names, including first and last names, puts dealers at risk of undue harassment or worse. This strays from the industry norm and dealers prefer consistency with other gaming environments. A logical solution is to mandate only the first name on badges.

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.

It should be legal, it's going to happen anyways and other states make phenomenal money on taxes 

For years folks have attempted to re-address the issue of charitable gaming use of proceeds; these poker regulations present a chance to finally get it right. As the proposed poker regs address the use of proceeds, no charity will be able to fulfill its obligations and host the events. The new adopted regulations for electronic pull tab devices are analogous to poker since one uses a manufacturer as its partner and one may use a poker operator as its partner. A charity cannot host electronic pull devices without a manufacturer, charities will not be able to host profitable poker tournaments without an operator. The use of proceeds must be based off of Gross proceeds MINUS prizes! This ADJUSTED GROSS PROCEEDS for poker, should yield a 20% Use of Proceeds from the poker tournaments. Think of this 20% Use of Proceeds like the “tax” or the “tithe” that the charity must produce, use properly and demonstrate to the regulatory authority its compliance. Once an audit ensures compliance, why would the regulatory authority have any interest in the expenses or other uses of the charitable revenue. This would be comparable to the IRS auditing a tax payer, ensuring that the proper taxes were paid and then insisting on reviewing the inner workings of the business; ludicrous. AUDIT REGULARLY, INSPECT REGULARLY, ENSURE USE OF PROCEEDS ARE LEGITIMATE AND MOVE ON! Lets encourage charitable gaming and hence encourage charity being given in our Commonwealth.

   My wife is from Virginia and I am looking at relocating. I deal poker now at Encore but have dealt in New Hampshire for six years. I am trying to figure out why don't you run the charity poker the way we do in New Hampshire. Charities make millions in New Hampshire. Many workers make a living wage. Its a win win for all..

Please have cash game at pops. We love them. Don’t want to travel to casinos 

I'm an experienced long time  (33 years!) poker player and I also work in the service industry as a bartender/server almost my entire life.   My coworkers, friends & family find that you all are trying to deny the poker dealers tips is appalling! It sounds like you guys are denying the growth of jobs.  I've played in all casinos across the country and EVERY dealer gets tipped.  I would ask the writers of the regulations to put their feet in the shoes of the charities - would YOU accept the way these are being written????  By not allowing this, you are certainly crushing the charities that are attempting to sponsor the poker tournaments and you are encouraging  dealers to work at the casinos and avoid any charitable poker opportunities.

I'd like to discuss the use of proceeds amount. VDACS insists charities follow 11VAC20-20-110 for its use of proceeds formula, which damages charitable poker. Charities would find it challenging to host tournaments, as they wouldn't raise enough money for expenses and the necessary use of proceeds. Reviewing a simple tournament budget demonstrates this formula's ineptitude. The resolution is to implement the newly accepted pull tab formula for poker.

Dear VDACS,

Poker has become a hobby of mine and of many others in my and surrounding communities.  Many of us have been playing poker together for many years and consequently established a local social community of poker players.  Pop's was the local poker room where we would gather to have some fun and catch up on the news.  Without getting into the nitty gritty details, Pop's had to shut down.  This had the consequence of breaking up our poker community and forcing us to travel long distances to play poker.

Another benefit of playing poker at Pop's was that it was a charitable game.  This meant it had the additional benefit of donating money into the local community.

It has been brought to my attention that VDACS' is developing a set of poker regulations for charitable games and in particular, charitable poker.  This is good news.  However, several of your proposed regulations, in my humble opinion, will have a significant negative consequence on the game and how it is played.

See examples below:

Example 1: 11VAC20-30-90.F (concurrent tournaments) should be eliminated or significantly modified because it places an unreasonable limitation of only allowing one game to be played at a a time.  Many of us have other responsibilities at home and work that prevent us from showing up at one specific time.  I personally feel Pop's should have the flexibility to set up a game when sufficient people are present.

Example 2:  11VAC20-20-90.O (electromechanical devices) should be eliminated or significantly modified because this regulation is prohibiting the use of software and hardware that is used to increase the number of hands being played over time and improves the integrity of the game.

Example 3:  11VAC20-30-90.G (location restriction) should be eliminated or significantly modified because Pop's is a convenient location for our poker community and we don't want to have to drive all over creation looking for a game. I am too old for this.

Please feel free to contact me if you have any additional questions.

Sincerely,

Carl Esche

I am a student who was the recipient of a scholarship granted to me by one of the charities that played charitable poker for a short time.  This group enabled me to study abroad and have exposure to a life-changing experience that I would never have had otherwise.  There are many young people like me who apply for scholarships from these charities, and are given the funds to fulfill our dreams.  It saddens me to know that other young, vibrant people will not be able to have that privilege.  You've taken away the ability for charities to grant these fund to all of us. I cannot imagine that the years we spent studying about our wonderful, benevolent country are over.  Students like me should all voice our opinions and let you know that what you are doing is harmful to the future leaders of America. A look at many of today's elected leaders will reveal that scores have been afforded opportunities like mine by charities similar to the ones you are regulating.  Please think more clearly about all of those you are impacting.  Make these regulations a profitable investment in tomorrow's leaders. 

 VDACS mistakes "rebuys" for "add-ons," which negatively affects the players and dealers, and charities. "Rebuys" happen after a player loses all chips, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions, increasing administrative and legal costs due to ill-conceived regulations. VDACS's guidelines misalign with the game and industry, causing confusion. A sensible fix is to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

tipping has always been a custom at poker games ... it allows dealers to supplement there income and for players to show their appreciation to the dealer when winning a hand ... most of all , it is showing gratitude for players not having to rotate the deal amungst themselves by having someone doing the tedious job of dealing 

 So do they unuderstand that the 21st century technology contributes to the ENHANCEMENT of all things.  VDACS's blanket restriction on the utilization of technology in poker operations adversely impacts dealers, players, and charities. The game's operation becomes significantly more efficient, enjoyable, and accurate when managed using technology software and hardware. Employing technology is more effective in maintaining the game's integrity compared to manual tracking, which is vulnerable to human errors. The suggested 11VAC20-20-90.O should be withdrawn.

I just read the comment by Scottie Seward,  dated April 20th, 2023 @ 3:20PM.

Allow me to agree with Mr. Seward's comments and add a very important point -

Mr.  Seward's comment refers to mistakes that VDACS has made in the drafting of these charitable poker regulations.  This mistake along with others, is proof that the people that have been tasked with writing this proposed draft have NO EXPERTISE in the field of Poker or Charitable Gaming in general!

A simple look at VA statute demands that the authors of such regulations are experts on the subject matter. 

Virginian's deserve better. 

My observation concerns the calendar: VDACS' specification of operational periods linked to calendar days and weeks negatively affects charitable poker's efficiency and functioning. This misinterpretation overlooks poker rooms' adjusted 24-hour operations, disrupting reporting requirements. A logical solution is to redefine "calendar day" as a 24-hour period set by the charity, and adjust the "calendar week" definition accordingly.

I write this public comment as Counsel for Cheers–a Virginia nonprofit entity which qualifies to hold a Virginia charitable gaming license–to address 3 issues on the proposed regulations: (1) "No Tipping"; (2) "Ban on Concurrent Tournaments"; and (3) "Use of Proceeds". For the reasons stated herein, the 3 regulations addressed in this comment will not withstand a challenge in Court given that they violate state and federal law, are discriminatory, arbitrary, and capricious, conflict with the Virginia Code, and exceed the authority granted by the Virginia General Assembly to regulate the conduct of Texas Hold’em poker tournaments for eligible charities like Cheers.

Texas Hold’em Poker was legalized by the General Assembly in 2020, under the auspices of SB 936, for the benefit of qualifying charities and signed into law by Governor Northam. In 2022, the General Assembly passed SB 402, which vested the power in VDACS to write regulations in order to effect the purposes of SB 936, i.e., the legalization of Texas Hold’em Poker. Notably, the definitions from SB 936 remained intact, except that SB 394 – also passed in 2022 – added one additional limitation that charitable organizations could not host Texas Hold’em games which had “no predetermined end time” or where the players wagered “actual money or poker chips that [had] cash value.”

Since July 1, 2022, VDACS has been tasked with writing the regulations.[1]  It has taken nine months to finally release those regulations for comment.  During that time, nonprofit charities – which had a legal right under SB  936 to play poker free from criminal penalty and had successfully played the game in 2020-2021 without any prosecution – were faced with a minimum civil penalty of $25,000 if they continued to host games.  So, they waited in good faith for VDACS to complete the regulations and re-open the game.

Having reviewed the draft regulations with my client, I offer two (2) key observations:

• They are strikingly inconsistent with regulations on casino gaming (or even like forms of charitable gaming); and
• They are intentionally designed so that charitable Texas Hold’em Poker will fail.  

Permit me to elaborate.

• “No Tipping.”  11VAC20-30-60(P).  The most offensive regulation states that dealers for Texas Hold’em games/tournaments cannot be “tipped.”  There is no basis in state law for this prohibition, either in SB 936 or elsewhere.   As a practical matter, service employees – especially those in the gaming industry – rely on “tips” for their income.  This is an accepted custom and practice for those who work at the tables.  There is zero restriction in Virginia on dealers at professional casinos, who play for much higher stakes, receiving tips; neither the casinos nor their employees would stand for that.  From a broader perspective, there is no state or federal law which precludes service employees for private companies from getting tips from satisfied customers. Conversely, this regulation would contravene existing state and federal laws that protects employee’s rights–as part of their “wage”–through the receipt of “tips” from their employer. See Va. Code § 40.1-28.9(B) (“determining wage of tipped employee”); see also Fair Labor Standards Act (“FLSA”), 29 U.S.C. 203 et seq. (§ 3(m)(2)(A)). In essence, this prohibition would violate public policy–under both state and federal law–by stripping protections set in place for employees since the Great Depression.  That is inhumane. In short, this regulation is inconsistent with state and federal law and industry practice and is only intended to have charitable gaming fail.

• “Ban on Concurrent Tournaments.” 11VAC20-30-90(F). Another offensive rule prohibits “concurrent tournaments.”  In other words, only one tournament can be played at a time. (Imagine a restaurant serving only one party at a time).  The purpose of SB 936 was to allow qualified charities to host “poker tournaments” and “poker games” which are defined terms. SeeVa. Code § 18.2-340.16.  Nothing in those definitions suggests or infers that only one tournament can be played at a time.  Again, that would be wildly inconsistent with the rules applied to private casinos, where industry practice is that dozens of games are played at one time, with the winning players advancing to the “final table.”[2]  Again, there is no articulated reason for this restriction other than it will make Texas Hold’em Poker financially unfeasible for charities and, therefore, cause this expansion of charitable gaming to fail. The Code is clear: it permits “Texas Hold’em pker tournaments[.]” See Va. Code § 18.2-340.28:2 (“Conduct of Texas Hold’em poker tournaments…”) (all five subsections–“(A)”-“(E)”–contain the word in plural form: “tournaments”). The Virginia General Assembly (“GA”) used the word “tournaments”–in its plural form–rather than “tournament”–in its singular form–and the GA’s intent is determined by giving words their ordinary, plain meaning in interpreting the foregoing. See, e.g., Mirant Potomac River, LLC v. Commonwealth, No. 2067-08-2, 2009 Va. App. LEXIS 287, at *18-20 (Ct. App. June 23, 2009) (court engaging in statutory interpretation to the word “purchase” and applying its ordinary meaning because the term is “unambiguous”). State agencies are not afforded great deference when a court reviews an agency’s regulation that conflicts with statute, and “regulations must neither exceed the scope of the authority delegated nor be inconsistent with it.” See id., 2009 Va. App. LEXIS at *15-16 (citations omitted). The proposal for banning concurrent tournaments violates Va. Code § 18.2-340.28:2(A)-(E) and would be an exercise of authority beyond the scope permitted by the GA. See, e.g., id., 2009 Va. App. LEXIS at *31 (holding that “Board’s regulation prohibiting compliance through any acquisition of allowances exceeds the scope of its authority” under the Code). 

• “Use of Proceeds.”  11VAC20-30-170.  For years, VDACS has permitted charities the flexibility to conduct games and pay related expenses, without adding gratuitous rules not faced by private gaming entities.  The best example of this is the rule utilized for “electronic pull tabs,” in which charitable operators are expected to pay a minimum of 20% of the “adjusted gross” from the game for the benefit of the charity.[3]  As long as the charities meet that standard, the remaining division for associated costs (e.g., rent, insurance, labor, etc.) is not relevant.  However, when it comes to Texas Hold’em Poker, VDACS is demanding that charities follow the “bingo” standard in that 10% of the unadjusted gross must be paid to the charity, before deducting winnings.  That standard ignores the fact that payouts in Texas Hold’em must be consistent with casino games, which have a much tighter margin, or else customers will go elsewhere.  In addition, Texas Hold’em tournament requires the use of specialized personnel, i.e., professional dealers, while bingo callers are typically volunteers.  There are increased costs from rent, security, insurance, and game supplies.  The bottom line is that a Texas Hold’em operation is much more like a professional casino operation than Bingo which can be played in any venue.    The proposed rules regarding “use of proceeds” would, again, destroy the ability of charities to play this game.

These are just a sampling of the regulations that we find extraordinary.  Again, the easiest test for the logic of a regulation is as follows: “Does a professional casino follow this rule if it is conducting the same activity?” If the answer is “no,” then the rule is presumptively discriminatory against charities.  That alone renders it “arbitrary and capricious,” especially since charities that play these games are already subject to scrutiny by the IRS to ensure compliance with their charitable mission. There is no need for VDACS to duplicate that review. 

These proposed regulations–as addressed above, supra, and in the public comments to date–stifle the ability to properly conduct Texas Hold’em poker tournaments. For the foregoing reasons, they will not withstand a challenge in Court given that they violate state and federal law, are discriminatory, arbitrary, and capricious, conflict with the Virginia Code, and exceed the authority granted by the Virginia General Assembly to regulate the conduct of Texas Hold’em poker tournaments for charities. 

In summary, we believe the regulations are fundamentally anti-charity and anti-poker.  We ask that they be revisited across the board.  Thank you.  

Sincerely,

J. Chapman Petersen, Esq.

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.

I'd like to discuss concurrent tournaments. VDACS' ban on such events harms players, dealers, and charities as it goes beyond their purview and isn't authorized by statute. This arbitrary restriction on legal poker tournaments seems unreasonable without a significant regulatory need to uphold charitable gaming integrity. Why would regulations prohibit concurrent tournaments when the Code approves them? One logical fix is to eliminate the proposed regulation

Regarding tipping. VDACS’ prohibition damages dealers, players, and charities because it prevents standard poker room compensation, impacting charity poker operations and possibly preventing play. Tipping is crucial for dealers’ earnings in the poker sphere. Why do the regulations disallow tipping when the Code approves it? This arbitrary constraint indicates VDACS is unfamiliar with the poker sector. One reasonable adjustment is to eliminate this tipping restriction.

I want to address the use of proceeds amount. VDACS requires charities to follow 11VAC20-20-110 for its use of proceeds formula, which negatively impacts charitable poker. Charities would be incapable of hosting tournaments, not raising enough funds to meet expenses and the mandated use of proceeds. Assessing a simple tournament budget highlights this formula's inefficiency. A solution is to adopt the recently established pull tab formula for poker.

My remark pertains to re-buys. VDACS mistakes "rebuys" for "add-ons," negatively affecting players, dealers, and charities. "Rebuys" happen after a player loses all chips, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions, increasing administrative and legal costs due to ill-conceived regulations. VDACS's guidelines misalign with the game and industry, causing confusion. A sensible fix is to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

Thank you for listening to my feedback and considering these changes.

Rod

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.

In addition, I have serious 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.

Thank you for your time, and serious, educated and knowledgable consideration.

I would also like to comment pertaining to the use of proceeds amount. VDACS demands charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which undermines charitable poker. Charities would struggle to organize tournaments, failing to generate sufficient funds for costs and the required use of proceeds. A basic tournament budget analysis reveals this formula's shortcomings. The answer is to apply the recently embraced pull tab formula to poker. My comment pertains to the use of proceeds amount. VDACS demands charities to adhere to 11VAC20-20-110 for its use of proceeds formula, which undermines charitable poker. Charities would struggle to organize tournaments, failing to generate sufficient funds for costs and the required use of proceeds. A basic tournament budget analysis reveals this formula's shortcomings. The answer is to apply the recently embraced pull tab formula to poker. 

My comment on 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. The proposed regulations make me wonder if the persons putting forward these restrictions actually have any knowledge of how charitable poker works. 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.

I'd like to also discuss the issue of operator fees. VDACS dictates that charities are only allowed to pay a fixed fee to operators for their services, as opposed to a percentage of the revenue. This creates difficulties for charities, as they are required to cover the flat fee even when revenue is low. It's odd that VDACS would establish such an arbitrary rule. A practical solution would be to delete the first two sentences of 11VAC20-30-60.P. Commissioner Guthrie has stressed the significance of charities meeting their use of proceeds. Beyond this aspect, the state shouldn't be involved in micromanaging charities' business dealings.

Speaking on the restriction on electromechanical devices, I submit that Imposing an outright restriction on technology use in poker operations by VDACS negatively affects dealers, players, and charities. In today's world, technology enhances all aspects of life. Utilizing technology software and hardware to manage the game improves efficiency, enjoyment, and accuracy. Relying on technology is far more advantageous for preserving the game's integrity than manually tracking everything and being prone to human error. The suggested 11VAC20-20-90.O should be eliminated.

Pertaining to the calendar, VDACS' prescribed periods of operation tied to calendar days and weeks damage charities and the ideal functioning of charitable poker. This misunderstanding overlooks poker rooms' usual adjusted 24-hour timeframe, complicating reporting. A sensible amendment is to define "calendar day" as a continuous 24-hour period set by the charity, and adjust the "calendar week" definition to match.

Pertaining to badges, VDACS' mandate to include dealers' full names, featuring first and last names, endangers dealers by making them vulnerable to undue harassment or worse. This deviates from the industry norm, and dealers prefer conformity with other gaming environments. A sensible fix is to necessitate displaying only the first name on badges. It's extremely easy to find someone online if one knows the full name, and possibly follow up with some nefarious action.

I'd like to also comment on use proceeds. VDACS disallows funds for fraternal activities, which is harmful to charities as these groups focus on social and recreational services for members. VDACS' rule keeps them from using poker money for their mission, causing problems with IRS rules. A reasonable adjustment is to exclude funds raised through poker events from this rule.

VDACS creates a limitation on where an organization may host poker games.

Tournaments would be successful in the areas that serve the proper demographic, not necessarily where the organization is based. VDACS does not have the authority to create this rule. The Code specifically provides this limitation regarding bingo and pull tabs, and leaves it out with respect to poker.  Strike proposed 11VAC20-30-90.G. 

I'd like to comment on concurrent tournaments. VDACS' ban negatively affects players, dealers, and charities as it exceeds their authority and isn't supported by statute. This unwarranted limitation on legal poker events seems unjustified without a pressing regulatory necessity to protect charitable gaming. Why do the regulations forbid concurrent tournaments while the Code permits them? A sensible fix is to strike proposed 11VAC20-30-90.F.

I’d like to discuss tipping. VDACS’ ban on tipping harms dealers, players, and charities as it disallows standard poker room compensation, hindering charity poker operations and possibly preventing play. Tipping is crucial for dealers’ livelihoods in the poker sector. Why would regulations prohibit tipping when the Code approves it? This arbitrary constraint reveals VDACS’ lack of understanding of the poker domain. One logical fix is to eliminate this tipping restriction

I'd like to discuss concurrent tournaments. VDACS' ban on such events harms players, dealers, and charities as it goes beyond their purview and isn't authorized by statute. This arbitrary restriction on legal poker tournaments seems unreasonable without a significant regulatory need to uphold charitable gaming integrity. Why would regulations prohibit concurrent tournaments when the Code approves them? One logical fix is to eliminate the proposed regulation

Regarding tipping. VDACS’ prohibition damages dealers, players, and charities because it prevents standard poker room compensation, impacting charity poker operations and possibly preventing play. Tipping is crucial for dealers’ earnings in the poker sphere. Why do the regulations disallow tipping when the Code approves it? This arbitrary constraint indicates VDACS is unfamiliar with the poker sector. One reasonable adjustment is to eliminate this tipping restriction.

I want to address the use of proceeds amount. VDACS requires charities to follow 11VAC20-20-110 for its use of proceeds formula, which negatively impacts charitable poker. Charities would be incapable of hosting tournaments, not raising enough funds to meet expenses and the mandated use of proceeds. Assessing a simple tournament budget highlights this formula's inefficiency. A solution is to adopt the recently established pull tab formula for poker.

My remark pertains to re-buys. VDACS mistakes "rebuys" for "add-ons," negatively affecting players, dealers, and charities. "Rebuys" happen after a player loses all chips, so limiting them beforehand is illogical. VDACS imposes unnecessary restrictions, increasing administrative and legal costs due to ill-conceived regulations. VDACS's guidelines misalign with the game and industry, causing confusion. A sensible fix is to strike 11VAC20-30-100.H; if limiting tournament duration is the goal, § 18.2-340.33.16 already requires a set end time.

Thank you for listening to my feedback and considering these changes.

Dear VDACS,

I'd like to discuss concurrent tournaments. VDACS' ban on such events harms players, dealers, and charities as it goes beyond their purview and isn't authorized by statute. This arbitrary restriction on legal poker tournaments seems unreasonable without a significant regulatory need to uphold charitable gaming integrity. Why would regulations prohibit concurrent tournaments when the Code approves them? One logical fix is to eliminate proposed 11VAC20-30-90.F.

I’d like to discuss tipping. VDACS’ ban on tipping harms dealers, players, and charities as it disallows standard poker room compensation, hindering charity poker operations and possibly preventing play. Tipping is crucial for dealers’ livelihoods in the poker sector. Why would regulations prohibit tipping when the Code approves it? This arbitrary constraint reveals VDACS’ lack of understanding of the poker domain. One logical fix is to eliminate this tipping restriction.

I'd like to discuss the use of proceeds amount. VDACS insists charities follow 11VAC20-20-110 for its use of proceeds formula, which damages charitable poker. Charities would find it challenging to host tournaments, as they wouldn't raise enough money for expenses and the necessary use of proceeds. Reviewing a simple tournament budget demonstrates this formula's ineptitude. The resolution is to implement the newly accepted pull tab formula for poker.

Regarding rebuys, I believe that we should have them, it is the best way to keep the customers here, and people like rebuy tournaments.  There is no reason to restrict people based on rebuys.  The ONLY time a rebuy occurs in normal play is once people have lost all of their chips, so this is very contradictory to logic.

Thank you very much,

David

 I wish to high light 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/staff make a living wage throughout all of poker gaming. 

it's IMPERATIVE for me also to mention that VDACS'; ban negatively affects players, dealers, and charities as it exceeds their authority and isn't supported by statute. This unwarranted limitation on legal poker events seems extremely unjustified without a pressing regulatory necessity to protect charitable gaming. Why do the regulations forbid concurrent tournaments while the Code permits them?

A sensible fix is to strike proposed 11VAC20-30-90.F. 

Concurrent tournaments need to be changed.dealers accepting tips. Needs to be addressed 

In tournament we should be able to rebuy after you bust!

My comment concerns concurrent tournaments. VDACS' prohibition harms players, dealers, and charities due to overreach and lack of statutory authorization. This arbitrary restriction on legal poker tournaments appears unreasonable without a strong regulatory need for ensuring charitable gaming integrity. Why do regulations prohibit concurrent tournaments when the Code allows it? A reasonable solution is to remove 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.

Thank you for your consideration,

Mark