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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11/23/22  8:14 am
Commenter: Beverly Bell, Fraternal Order of Eagles 871

Requested changes to published regs

As one of 1100 members of the Fraternal Order of Eagles 871, I'm writing to express my concerns about several proposed changes to the charitable gaming laws.

Paperwork -- The requirement to empty the electronic gaming machines and deposit the money every 48 hours will be impossible for us to follow.  We are mainly run by volunteers, several of whom hold down fulltime jobs, and simply don't have the manpower.  We could possibly abide by a 10-14 day timeline.  Secondly, the quarterly reports are overkill for an Aerie such as ours that only offer paper and electronic pull-tab games.  It seems the reports are designed primarily for clubs that have Bingo, Queen of Hearts, and other such games.  In fact, the reports reference Bingo numerous times.  I respectfully ask that you maintain current law that exempts clubs that only have electronic and paper pull-tabs.

Use of Proceeds -- FOE 871 is proud of our record of charitable donations.  We regularly contribute to national and community causes to combat heart disease and diabetes; to help our country's veterans and police officers; and to assist other charities such as animal shelters.  The Past Worthy State President Rock Ruark is a member of our Aerie.  Last year he raised $142,000 for Homes for Our Troops that builds specifically-adapted houses to fulfill the needs of disabled veterans.  In addition, we hold drives throughout the year to collect coats, food, and Toys for Tots.

However, our Aerie is housed in a 100-year old building in the historic part of Old Town.  We can pay our regular expenses and make some charitable contributions from bar and food sales, but we can't undertake any major renovations or repairs to keep our building safe without the electronic games.  Losing 40% would impose a hardship on us at a time when we are trying to make necessary and costly updates.  I ask that you reduce the percentage to 15%-20%.  

Tax -- While the 0.75% tax is low I am concerned that this figure will continue to rise throughout the years. (Calling it an "audit fee" is like Reagan calling taxes "revenue enhancers.")  Please be mindful of future raises.

In closing, I invite any Charitable Gaming Commission members to come to FOE 871 to learn more about our mission, our games, and our charitable contributions.

CommentID: 206027