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  9:03 pm
Commenter: Stephen Urquhart / Hampton Elks Lodge

New Gaming Rules & Regulations

I understand our Governor said the proposed regulations are a Death Sentence for Lodges. He is spot on correct.

The 40% proposed use of proceeds is way to high, unfair and will surely burden most lodges and will positively close Hampton Elks. Have you considered a tier system based on income in lieu of one size ( 40% ) fits all? Please reduce the 40% to 15%.

The proposed reg requiring on site staff will surely close Hampton lodge. In today’s society, hospital ICU patients are camera monitored by a remote person. Checking out at Walmart, Target and ordering at McDonald's no longer require staff. Our Lodge learned during covid to make our Lodge available and keep our doors open. We added a vending machine, obtained a payout Kiosk and state of the art Security with quick response. We at Hampton Elks currently do not need or require on site staff. Please consider the future times we live in and remove this requirement or consider a waiver for those set up like Hampton. We are notified and can visually see every entry into our building. I cannot see or understand why staff must be on-site. Many business are doing more with less Staff. Technical advances have made this possible. Having staff on site is moving backwards. What is the rational and justification that would have us return to the 1970’s? Our machines are only available for use by our members and their bona fide guests in our Private Social Quarters and designated areas and ARE NOT open to the public. I could understand the regulation if we were open to the public and did not know the people in the Lodge and if they were not held accountable by our own strict rules of conduct required of members. However, these are members and should not have to be babysat to play electronic gaming machines that don not require an attendant to operate. 

We support and spend funding on Vet’s, books for students, no kid sleeps on the floor, food bank, blood drives, feeding the homeless and hungry. Our raffles and fund raising is one way we obtain funding to support many many Hampton Charities. Making it difficult or impossible for us to raise funds. I believe your taking away our rights to have a private Lodge.

The bank deposit requirement seems unrealistic and why does it matter. We at Hampton are almost all volunteer and this requirement will put much stress on a small Lodge. As long as all the Mooney is accounted for and coded to the correct accounts, the Lodge should have the ability to make deposits at their convenience. Seems we are trying to have one set of rules as though on size fits all. 

Some of what I have read and interpreted as you are mixing Bingo with Electric gaming. The two are way different. Most lodges have gone out of the Bingo business. As rules changed and large Bingo operations opened, we were forced to quit Bingo. Seems this is happening again with all the changes to electronic gaming. We are not competition for anyone. Just a small lodge trying to keep our doors open and do some good in the neighborhood.


CommentID: 206090