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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11/2/22  12:14 pm
Commenter: Brooke Archambeau, Government Relations, Virginia Moose Association

PLEASE Lower UOP Percentage and Reconsider Eligible Expenses

The Virginia Moose Association, comprised of 83 lodges and 68 chapters of Women of the Moose, helps to sustain our fraternal twin cities of Mooseheart and Moosehaven.  In addition, we provide monetary donations and safe places in our communities for organizations like Boy Scouts, Girl Scouts, senior organizations, and countless others to have a clean and local place to meet.  We make donations to local animal shelters, domestic violence shelters, food banks, Salvation Army programs, K9s for Warriors, VetsHouse, the Safe Surfin Foundation (online safety for kids), and provide scholarships for many of our local high school graduates to continue their education in Virginia's colleges and universities.

The proposed regulations set forth a use of proceeds mandate as high as 40% on electronic gaming.  This means that after a split with the gaming company (usually 50%), our lodges can reasonably expect to deposit around 5% of the total gross proceeds of an electronic game.  That money is used to support our charitable endeavors, but is in some of our smaller lodges also used to keep the doors open and provide safe, clean meeting places.  The regulatory use of proceeds percentage should be less than 40% if we want to keep our lodges open.  The cost of maintaining a lodge include power, utilities, building maintenance, and payroll.  If these are cut and lodges have to close because their proceeds are so heavily regulated, it does not just impact the Moose - it impacts the organizations that we support as well.  In addition to my work with Moose, I am a local Girl Scout troop leader.  Our lodge donated space weekly for 17 girls, aged 5-14, to meet and learn valuable life lessons together.  The lodge also built and maintains a cabin meeting space for the Boy Scout Pack/Troop 215 to meet and work with 60 boys and young men weekly.  The large hall has been donated for several events in our community.  I would really hate to have to explain that we can't host these events or have to charge other nonprofits to use the space because we can not afford to keep the utilities running in those areas of the building once these use of proceeds regulations go into effect.  If we are charging 10% gross use of proceeds on bingo, which is open to the public, why is the use of proceeds amount proposed for the social quarters 40%?  Please reconsider this percentage so that lodges can maintain their facilities for fraternal and community use.

In addition, the proposed regulations prohibit the use of proceeds from gaming toward payroll expenses.  Many of our lodges operate on a volunteer basis, but some of them have grown to the point that they can no longer reasonably expect to be staffed fully by volunteers.  While I do not support the use of proceeds exclusively for payroll purposes, it is reasonable to expect that lodges have payroll expenses that are not supported by fraternal fundraising outside of gaming proceeds alone.  Many lodges have moved to paid employees because having them has brought a level of professionalism that is more appealing to potential members that visit our lodges.  Please reconsider this prohibition so that we can maintain the levels of professionalism and decorum that our organization has come to expect.

We appreciate your consideration of these requests.

CommentID: 204086