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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10/30/22  3:54 pm
Commenter: Bedford Moose Lodge #1897

Charitable Gaming Regulations will harm charities

In reading the proposed new gaming regulations, I am struck by how they could adversely affect charitable donations. I am also concerned that the regulations do not take into consideration how the standard electronic machine contracts work. I also believe that these regulations are based on unrealistic monetary figures. I will use the specifics of our lodge to show how these regulations will effectively end charitable gaming in organizations like ours.

An average week for our lodge is $3601.00 total net. Our contract with our machine provider is a 50% split. We keep 50% and they get 50%. So our portion of that money is $180050. Out of our half, per your proposed regulations, we would be required to pay out 40% or $720.20 in charitable donations leaving the lodge with $1080.30. Which looks good, on paper and in theory. But there are other costs that must be covered as well. Electricity, heat/AC, equipment (such as registers and barcode readers), phone, internet, labor costs, insurance, etc. All of these and many more are costs that come with having the electronic machines in our locations. There are very few, if any, lodges that have food and beverage sales that will cover the costs of these needs. Please reconsider these regulations or amend them on a tiered/income basis. The future of our organizations and the charities we help depends on it. 

CommentID: 204074