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  3:22 pm
Commenter: Johnnie Moore

Charitable Gaming Regulations

As a lifetime member of the Fraternal Order of Eagles (Aerie 680), and many of my 76 years of age, as a member of the Staunton Moose (1635) and the Staunton Elks Lodge (#351), I would like to use this public form to address my disagreement with several of the newly proposed gaming regulations.  

First, the proposed 40% tax on the net proceeds from the machines to go entirely to charities fails to take into account many of the generated operational costs of the organization to stay open and carry out its missions to the members, their communities, and the goals of our nation.  I propose instead 15-20% but certainly no more.  Your recommendation would close many smaller and newer chapters and I feel fails to recognize our charitable purposes.  

Secondly, I agree to the need for prompt and accurate reporting on these machines but your specified amount of time between reports is way too soon.  This is especially true for smaller organizations where machines are not played frequently.  Also, consideration is not given for continuity of completion these records and the fact that many do their reports using volunteer members.  Too frequently reporting will jeopardize this procedure and replace their accuracy and the ability to get competent volunteer members.  

Thank you for allowing me to voice some of my concerns.


CommentID: 205962