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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11/20/22  4:18 pm
Commenter: Larry Konieczny, Dale City Moose 2165

Virginia Gaming Law

am submitting this for your consideration. Under the current gaming regulations, many organizations that provide monetary and facility support to their surrounding community and their charitable organization’s missions will not be able to sustain operations nor provide a safe haven for their members.



PROPOSED: Forty percent UOP on the adjusted net gross proceeds for Charitable Organizations is unreasonable and unsustainable. After paying the Gaming Company’s share, the remainder would not be enough to cover any authorized business expenses.

CONSIDER:  Review the forty percent UOP requirement for electronic pull tabs and adjust it to a more equitable figure of ten percent.


PROPOSED: Ten percent UOP on the gross of paper pull-tabs does not leave the organization much left, after paying for the game, to cover other supporting expenses.

CONSIDERATION: Ten percent of the net is more reasonable.



PROPOSED: Organizations will be required to have a gaming manager on site while gaming is being played.

CONSIDERATION:  Allow wages and salaries related to gaming activities to be charged to UOP with the remainder charged to allowable business expenses.



We need to offer a safe and comfortable place for our members to play. This includes but is not limited to lighting, heating, AC, etc.   

CONSIDERED:  Allow direct real property expenses to be charged to UOP with the remainder to allowable business expenses.



Being notified at the end of the reporting period did not give many organizations ample time to incorporate the new rulings and to correctly report.

CONSIDERATION:  Establish a grace period to allow Organizations to update their business processes and reporting requirements to comply with the new guidelines:


I request the Commission to take under consideration the following requests:

  • Revisit the daily reconciliation procedures for paper and electronic pull tabs. Allow electronic pull tabs to follow the weekly invoicing by the Gaming Company and wait till a paper pull-tab box is finished.
  • Depositing electronic pull tab receipts within two days is extreme. I request looking at making it weekly.
  • Request allowing online banking or credit cards for expenditures and donations paid from the gaming account.



Larry Konieczny


Dale City Moose 2165

CommentID: 205746