This will be the first time this organization has been required to file a form 102.  Previously, we maintained a single gaming checking account.  This form will require two separate checking accounts, one for paper pull tabs and one for electronic pull tabs, which means we will need to modify our accounting, bookkeeping and banking infrastructure and will not be able to accurately complete the form until this is set up.  I can't see the logic in this requirement, and it imposes a rather burdensome process since all disbursements go for the same purposes. furthermore, all disbursements are required to be by check.  I currently have no paper checks for my gaming account.  All disbursements are made via electronic transfer, so the requirement for checks imposes another useless burden.

It appears the legislation requires a daily charitable gaming cash reconciliation.  The gaming activity at my facility is such a low volume that currently reconcile my gaming proceeds weekly and in some cases. bi-weekly.  Requiring a daily accounting imposes another unnecessary burden we have neither the time nor staff with which to comply.

The use of proceeds outlined in the implementation legislation directly prohibits the charitable exempt purposes an IRS 501 (c) (19)-1(c) must follow.

In conclusion:

Eliminate the need for separate checking accounts for pull tab games or allow a grace period for an organization set up such a burdensome accounting and banking system.

Eliminate the requirement for daily cash reconciliations.

Allow use of proceeds that conform to IRS 501 (c) (19)-1(c).