As a disabled vet, i do not concur wit the need to force VFW’s and other VSOs to expend social quarters gaming proceeds to outside organizations and not use them for the mission of the organization. The VFW Congressional Charter states the purpose of the organization is fraternal, patriotic, historical, charitable, and educational, and is to preserve and strengthen comradeship among its members. It meets the same criteria as other charitable organizations. We work with the Virginia Department of Veterans Services to ensure ALL veterans and their families are taken care of, support our military and their families, as well as other local charities. 

Areas of concern in the proposed regulations are as follows: 

1. The proposed requirements mandate that organizations have a manager/employee on site and working while electronic gaming is being played. This is the entire time a social quarter is open. The sheer number of hours would require us to pay these employees. Most of our workers are volunteers.   

1A. Allow the wages and salaries related to gaming activities be charged to use of proceeds (UOP) with the remainder being charged to business expenses.

2. Organizations must be able to provide a safe and secure area to play the machines and this requires us to use the proceeds from the gaming to help keep the social quarters up to speed.

2A. Restore the language that allows direct real property expenses to be charged to UOP with remainder charged to business expense.

3. Using 40% UOP with proposed restrictions is an unattainable percentage inserted by gaming Industry to inappropriately restrict other recreational gaming. We must pay the manufacturers their fair share and what’s left isn’t enough to cover the authorized business expenses. 

3A. Revisit the 40% UOP requirement for electronic pull tabs and adjust the requirement to the traditional lower figure of 10%.

4. The congressional charter for the VFW states that its purpose is fraternal, patriotic, historical, charitable, and educational, and is to preserve and strengthen comradeship among its members.

4A. We are the very definition for which UOPs are intended. Continue to allow the use of gaming funds to be used within the organization and to support membership functions such as appreciation dinners inter alia.

5. Letting the organizations know what is allowed and required 3 months after the beginning of the reporting period is unacceptable and then telling them to just do the best they can is not in accordance with realistic legislative interests.  

5A. Establish a grace period to allow the organizations to update their business processes and reporting requirements to comply with the procedural guidelines but with no catastrophic increase in UOP requirements.

6. The proposed reconciliation requirements were taken from Bingo that is easily accomplished after each session. Trying to accomplish this on a never-ending game or partially played came is onerous and unduly cumbersome and almost impossible to perform  accurately. In the social quarters, a box of pull-tabs might take days or even weeks to complete, and it is impractical to empty the machine to count how many tickets are left.

6A. Revisit the daily reconciliation procedures and adopt procedures that are less cumbersome for both paper and electronic pull tabs. A proposal is to reconcile when each box is completed.

7.  Paper checks are all but obsolete with electronic transfers and credit cards having replaced them.  Online purchases require a credit card, as do gas, food, hotel, or transportation for a needy family.

7A. Allow the use of credit cards for authorized expenditures and donations which are paid from the gaming account. The credit card statement and/or receipt can be directly tied to the account.