11VAC20-20-119 Use of Proceeds Restrictions Will Shut Our Lodge Down

As currently written, the Use of Proceeds section 11VAC20-20-119 will effectively close our Lodge.  We do not believe that the original intent of the gaming law was to shut down our Moose lodge.  However, the regulations as written by this board will indeed have the effect of shutting us down.  As such, we believe the regulations are invalid and do not  accord with the actual intent, meaning or spirit of the gaming law.

Use of Proceeds should allow for the base functions of our Fraternal organization, which includes the operations required to keep our building operational.

Background

We estimate that 75% of our operational costs of our small Lodge are paid for by the proceeds from the pull-tab game.   The meager output of these pull-tabs pay for the mortgage, electricity, heating, cleaning,  employees, building/accident insurance, and the sundry other items which keep the doors of the Lodge open.   

This is all funded by our members who alone are allowed to play (and which provides no profit as per our Federal charter and tax returns), and allows us to perform our community services. The Lodge provides a base of organization for our members (who are very active community participants) who use the Lodge and its facilities furthers that community agenda and brotherhood.

Summary

Closing our Lodge would be a loss to our community, and a slap in the face to our active community members.  We believe these regulations are not in accord with the spirit of the gaming law, and as such, should be remedied. 

Use of Proceeds should allow for the base functions of our Fraternal organization, which includes the operations required to keep our facilities open.