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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11/17/22  2:05 pm
Commenter: Susan Moore VFW Post 4411


Donating 40% of electronic gaming proceeds isn't a realistic percentage for our  organization. We're required to pay the manufacturer 50% of proceeds and what’s left is barely enough to cover our gaming expenses and an occasional authorized business expense. Recommend the 40% donation requirement for electronic gaming be reduced to 10%.  If the 40% isn't reduced, we honestly may be required to completely eliminate electronic gaming from our social quarters.

The congressional charter for the VFW states that our purpose is fraternal, patriotic, historical, charitable, and educational, and is to preserve and strengthen comradeship among its members.  We're the very definition of what non-profit proceeds can be used for.  We should be allowed to use 90% of gaming proceeds to support our own organization.

Notifying the organizations three months after the beginning of the reporting period is unacceptable.   We require more notice to know what data we're required to provide in order to comply with any new guidelines.  Our  Gaming Manager and Quartermaster are volunteers who're employed in other positions so they're only able to donate a few hours a week to the VFW.

In our social quarters, a box of pull tabs could take weeks to complete.  It's impractical to empty the machine to count how many tickets are left.  Request  reconciliation be allowed after a full box of pull tabs is depleted.

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