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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11/22/22  11:49 am
Commenter: Kevin Mallory, Fraternal Order Of The Eagles, Aerie 4548

Charitable Gaming Regulations

To whom it may concern,

I am a trustee of The Fraternal Order Of The Eagles, Aerie 4548 in Williamsburg, VA.  I would like to ask you to reconsider some of the regulations that are currently under discussion. The proposed changes to the Charitable Gaming Regulations threatens to close us down along with many other similar clubs across the state. 

Our proposed changes are as follows:

1. The requirements of the use of proceeds at 40% would impact our financial stability and force our organization to close. I recommend a reasonable rate of 15% or 20% max.

2. Please remove the exception of salaries to pay our employees as stated in 18-2-340.16. We need to pay the salaries and insurance of the employees to run our organization!

3. In 11VAC-20-70 banking deposits must be made in two business days. Please change this to once a week.

4. Remove the 200.00 fees for electronic gaming in 11VAC20-20-40. We already pay a 200.00 gaming fee. An additional fee seems redundant. 

I leave you with these questions to ask yourselves when you meet to discuss these matters. We have donated $60,000 last fiscal year to our local charities as well as a few national charities. If we are forced to close, along with other similar organizations across the state, who will fill the void to help these charities? If we close our doors and our employees are forced to be laid off, who will pay their bills with a broken unemployment system??

I greatly appreciate your consideration on these proposed changes. I invite you to come by our club to see for yourselves what we are all about.


Kevin Mallory

CommentID: 205939