1. Please remove the exception to salaries and wages to match the definition as defined in Code 18.2-340.16. In order to maintain gaming, our organization needs to be able to pay the employees who maintain and manage our club.
2. 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.
3. 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.
4. 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.