I am writing on behalf of the Board for Mount Jackson Moose Lodge 979.

We respectfully request the following changes to the proposed regulations:

•  Reasonable and proper business expenses (definition)
  • Removal of the exception to "salaries and wages" to match the definition as defined in code 18.2-340.16. 

In order to maintain gaming, our Lodge needs to be able to pay the employees who will be managing and maintaining the gaming, which for our small Lodge is an always available option.

• 11VAC20-20-70 Bank Account section D
  • Modification to the one week requirement for bank deposits to gaming account.

For our small Lodge, this requirement will be difficult and will require additional time and resources.  We currently make weekly deposits of all funds to all our accounts.

• 11VAC20-20-40 Charitable gaming authorization for electronic gaming section B
  • Removal of the additional $200 fee specifically for electronic gaming.

The addition of this fee (in addition to the general gaming fees) appears redundant.