Action | Promulgation of regulations for Texas Hold’em poker tournaments by the Department of Agriculture and Consumer Services |
Stage | Proposed |
Comment Period | Ended on 5/10/2023 |
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.
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 essential for dealers’ financial well-being in the poker industry. Why would regulations ban tipping while the Code allows it? This baseless limitation suggests VDACS lacks knowledge of the poker field. A fair solution is to remove this tipping constraint.
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.