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  5:22 pm
Commenter: Debbie Hall FOE #3204 Auxiliary

Concerns regarding proposed regulations for Charitable Gaming

Thank you for taking a moment to read our comments regarding the changes to Charitable Gaming Rules.

The Fraternal Order of Eagles is an organization whose motto is "People Helping People".

Like many non-profit organizations, we are a volunteer organization with only a few employees who are compensated.  Many of our volunteers are employed full time outside of our organization.

The FOE Aeries in the State of Virginia donate, on a regular basis, well over 1 million dollars a year to a variety of national, state, and local organizations, as well as to local people in need. 

I am concerned about the newly proposed regulation regarding the 40% of "Adjusted Gross Net Receipts" regarding the electronic gaming.  The way I read that; it would actually be 80% of our organization's portion of the receipts.  That is an outrageously high percentage.  15-20% of Adjusted Gross Net Receipts would be a more palatable adjustment.   This would allow small organizations to keep the lights on in their social rooms.  The higher percentage would, without a doubt, close the doors of many of our smaller Aeries.  At this point in time, and in the economic crisis that many people are facing, closing those doors would be devastating to so many needy families in many areas of Virginia.

I am also concerned about the requirement for multiple checking accounts to separate monies.  There is a vast number of accounting software available to do this task.  Earmarked portions of funds should be sufficient for any bookkeeping system to separate the destination of the checks written from a main account.  Separate accounts create needless paper and files.

There is also an unreasonable proposal to have daily drops for gaming.  Small Clubs, running solely on volunteers, would have a difficult time meeting that requirement.  As stated earlier, many of our volunteers work full time and have families. Turn around on daily gaming can be a time-consuming activity and would put undue burden on our volunteers. Some of our smaller clubs have little activity at times on the games, and have no actual need to do daily deposits.

Please take the time to reconsider your entire proposed bill.  Talk to the clubs who will be directly affected by the proposed measures.  And above all, talk to the charities who will be directly affected if we are forced to close our doors.

Thank you for your time

Debbie Hall

FOE #3204 Virginia Beach Auxiliary



CommentID: 205989