Virginia Regulatory Town Hall
Department of Agriculture and Consumer Services
Department of Agriculture and Consumer Services, Charitable Gaming
Charitable Gaming Regulations [11 VAC 20 ‑ 20]
Action Promulgation of Charitable Gaming Regulations by Department of Agriculture and Consumer Services, including electronic gaming provisions
Stage Proposed
Comment Period Ended on 11/23/2022
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10/24/22  11:43 am
Commenter: Peter S Jachode, Moose Lodge 715, Lynchburg Virginia

New regulations

Please let me begin by saying that I understand and agree with much of what is expected of our organizations pertaining to charitable gaming funds accountability and reporting requirements. At a recent so called training session I spoke up saying that these proposed changes could potentially cause the demise of many of the states fraternal and non-profit charitable organizations. Many of us are actually stop gaps for needs in our local communities helping fund food banks, church needs, police departments, fire departments, child sports programs, community members in distress, and the list goes on and on. Also noted was the fact that these reporting requirements were retroactive back to July 1 2022. This, we will call information session was in October, how does that make any sense ? I did say so called training session because the only real information was the completion of the basic bingo reporting forms. Any real new electronic gaming filing instructions, use of proceeds requirements, and how to go backwards when you have filed the 3rd quarter report already. Many of the participants left stating that the session was a waste of time, and it was. Others left with a bad taste in their mouth regarding charitable gaming regulations as a whole. Now, as I previously mentioned all the small holes filled by our efforts will indeed benefit from the new accountability programs for our electronic gaming accounts and the real problem at hand is the fact that most likely all of the organizations have been using a lot or most of these funds for operation costs. The allowable costs are probably minimal compared to what the funds were really needed for. Most people, if not all, had to use these funds to run the social environment of the organization such as food, beer, liquor, entertainment, improvements, IRS fines, maintenance, and in many cases, payroll. That is the "rub" so to speak. not all that many years ago we were told that this day would come and to prepare for it now. We were also told not so many years ago to transfer money monthly from the pull tab account to the operations account. This utilization of these funds became commonplace and it seems as if it was/is almost impossible to operate a social quarters as a stand alone revenue stream. With todays increased costs across the board, to include food, beer, labor, increased taxes, etc. and all paying members expecting private club pricing, not commercial establishment pricing, we have put ourselves behind the 8 ball, so to speak. I am sure that when the pull tab accounts were just that, pull tabs, they did not create much interest and now with electronic gaming the numbers have caught every body's attention. (this includes the IRS by the way) 

What" my point you may be asking, well the big issue here boys and girls is that we have inadvertently shot OURSELVES in the foot. The regulations and reporting seems to me just a part of being a charitable gaming organization. The percentage is the only real part that I think needs clarified. Why the increase ? It also helps to complicate the process and if more information was used to determine all these proposed regulations, I would think that the continuing decline of charitable bingo within these organizations would be indicative of a much bigger problem with organizations like ours that help our communities and parent organizations. 

End of Part One

Fraternally, Peter Scott Jachode

CommentID: 194941