Bonding Requirement in 11VAC 15-50-140.B.14 should be redefined.  Surety Bonds are legally binding contracts entered into by 3 parties--the principal, the obligee, and the surety. The obligee, a government entity, requires the principal, typically a business owner or contractor, to obtain a surety bond as a guarantee against future work performance.

The way the regulation is currently written, the government agency (VDACS) is not the obligee, instead the regulation has the charitable organization the obligee.  Having an operator obtain a separate surety or surety bond for each qualified organization they provide their services is redundant and would be very costly for operators.  All other states that allow for charitable Texas Holdem Poker tournaments that have the requirement for the operator to obtain a surety bond, does so with the state agency being the obligee.  See charitable gaming laws of Michigan, New Hampshire, and Washington DC.

The suggested solution is to modify the regulation so the operator is bonded with VDACS as part of the operator registration process.