NOTE #4

 

SECTION:

11VAC15-50-40. Operator registration.

sub-section: H (main section)

 

ORIGINAL:

H. Operators shall ensure that a copy of a detailed invoice is provided to the qualified organization for each poker tournament it administers on behalf of the qualified organization. The invoice shall reflect the following:

 

COMMENT:

The issue that I take here is that an invoice needs to be created for each poker tournament.  There may be several tournaments daily at any given location.  I suggest a “daily” summary of tournaments or list of tournaments with the subsequent information listed for each tournament but NOT several invoices, only a single invoice for each day.

 

PROPOSED CHANGE:

 

H. Operators shall ensure that a copy of a detailed invoice is provided to the qualified organization for each

 

day of poker tournaments

 

 

poker tournament

 

 

it administers on behalf of the qualified organization. The invoice shall reflect the following:

 

NOTE #5

 

SECTION:

11VAC15-50-60. Operation and conduct of Texas Hold'em poker tournaments.

sub-section: C.2

 

ORIGINAL:

a. During a poker tournament, if the qualified organization is managing, operating, and conducting its own poker tournament, then a game manager must be physically present during the entire duration of the poker tournament. If an operator is administering the poker tournament, then the operator's tournament manager and charitable host representative must be physically present during the entire duration of the poker tournament.

 

COMMENT:

Tournaments often go for many hours at a time.  It is unreasonable to demand that a charitable host representative (a volunteer) would be present for the duration of the entire tournament.  I suggest that they are present for the wrap up of the paperwork for the tournament and provide a form of consistent oversight of the operations of the tournament, but not to, by regulation, be physically present the entire time.  Even the tournament director will most likely be a few different operations company representatives that will be present during the during of the company, effectively sharing this responsibility. This would be similar to a home owner being required to sit on site for the duration of time that the contractor is building his or her house.

 

PROPOSED CHANGE:

 

a. During a poker tournament, if the qualified organization is managing, operating, and conducting its own poker tournament, then a game manager must be physically present during the entire duration of the poker tournament. If an operator is administering the poker tournament, then the operator's tournament manager

 

 

 and charitable host representative

 

 

or alternative operations manager or supervisor

 

 

must be physically present during the entire duration of the poker tournament.

 

NOTE #6

 

SECTION:

11VAC15-50-140. Requirements regarding contracts.

sub-section: B.24

 

ORIGINAL:

24. If the operator leases a facility for the purposes of administering the qualified organization's poker tournament, then the written contract shall prohibit the landlord from serving as an operator and meets the conditions set forth in 11VAC15-50-90.

 

COMMENT:

There is no reason to prohibit this overlap between landlord and operator, however, if the overlap exists, it should be disclosed.

 

PROPOSED CHANGE:

 

24. If the operator leases a facility for the purposes of administering the qualified organization's poker tournament, then the written contract shall

 

 

prohibit

 

 

allow

 

 

the landlord

 

 

from serving

 

 

to serve

 

 

as an operator and meets the conditions set forth in 11VAC15-50-90

 

 

 

Provided that the landlord/operator properly disclose this overlap in roles.