The requirement of the proposed 40% use of proceeds would greatly impact the financial stability of our organization and could cause us to become insolvent. A 15 to 20% rate would be much less of an impact on operations.

 

In 11VAC20-20-70 Bank account section D - modify this section from the second business day requirement to a weekly requirement. Our club is operated mostly by volunteers and the expectation for the Treasurer to make deposits essentially every other day is not feasible.

 

In 11VAC20-20-40, section B, the addition $200.00 fee specifically for electronic is redundant as we already pay a $200.00 general gaming fee. Please remove this fee from the guidance.