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  4:10 pm
Commenter: Claude Davenport, American Legion Post 72

Requested changes to proposed regulations

My name is Claude Davenport.  I am a life member in both the American Legion Post 72 in Warrenton, VA and the Veterans of Foreign Wars Post 9835 in Fauquier County.  I am the current Finance Officer at American Legion Post 72.  I thank you for the opportunity to make comment.


These are my areas of concern in the proposed regulations: 

  1. The proposed requirements mandate that organizations have a manager/employee on site and working while electronic gaming is being played. 
  • I request consideration on wages and salaries related to gaming activities be an allowable expense.


  1. 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.
  • I request restoring the language that allows direct real property expenses to be an allowable expense.


  1. Using 40% of adjusted net gross is a crippling percentage to the qualified organizations. 
  • I request the same 10% as articulated for Bingo.


  1. Our Post received a 3x5 post card from the OCRP with the reporting requirement, without listing acceptable expenses.  This requires the Finance Officer to rework the last quarter’s profit & loss reports.  The P&L's have already been included in the Post official business minutes. 
  • I request consideration on initiating the new reporting requirement at the upcoming new fiscal year reporting period. That will allow time for the Post to setup the bookkeeping systems and rework existing documents and reports.


  1. The proposed electronic pull tab reconciliation requirements appear to be a template from the Bingo regulations.  Bingo reconciliation is accomplished after each session. Trying to accomplish this on a never-ending electronic pull tabs or partially played paper pull tab game is extremely cumbersome and difficult to complete with accuracy. A box of pull-tabs can take days or even weeks to complete, and it is impractical to empty the machine to count how many tickets are left.
  • I request consideration on electronic pull tabs follow the weekly invoicing by the manufacturer and wait till a paper pull tab box is finished. 


  1. The requirement to deposit electronic pull tab receipts with two days of a “session” is not feasible.  The electronic pull tabs play is ongoing.  The payouts require transferring funds from the machine to the drawer.  Attempting to balance the machines every two days would require making deposits two to three times a week.  Some banks limit the number of deposits per month.
  • I request consideration on linking the electronic pull tabs reconciliation and deposit requirements coincide with the machine manufacturers invoicing at once a week.


  1. Paper check can be laborious time consuming, adding more strain to the finance officer’s responsibilities.  Online banking is a standard today.  Online purchases require a credit card. 
  • I request consideration on allowing online banking for checks and debit cards for the gaming bank accounts.
CommentID: 205624