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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11/2/22  6:21 am
Commenter: Troy King / Loyal Order of Moose

Impact of 40% NET on Charitable Gaming on Fraternal Organizations

The use of proceeds helps the fraternal organizations maintain a safe environment for members of the local community to gather in other fund raising activities. Base on the current formula the fraternal organization is only left with 10% of the net proceeds to maintain operation. I must confess that, like BINGO, fraternal organization should be required to donate funds raised to support lawful religious, charitable, community, or educational purposes. As written it appear the gaming company still retains the 50% yet the fraternal organization is required to pay based on the total net before the vendor is paid. If the Commonwealth of Virginia is set on 40%, I would ask you to consider assess the vendor 20% and the fraternal organization 20% based on their split? This would still put a burden on the fraternal organization. What I would ask is you to consider 10% from the Fraternal and 10% from the vendor and utilize the same methodology as the 10% UOP for BINGO.

The fraternal organizations utilize their building for the local community to assemble when no other suitable facility are available. The Commonwealth of Virginia leaders may not see the impact of losing a fraternal unit in the community may impact. The funds generated by the organization is not always monetary but in the form of a meeting space, recreational kids sports banquets, local police meetings i.e. Crime Solvers in the TriCity or Hopewell/Prince George/Colonial Heights, Boy Scouts, Girl Scouts, AAU sports not to mention the numerous 501 (C) 3 organization surrounding the organization.

The leadership in the fraternal organizations live and work in the communities surrounding the organization and utilize this as an opportunity to meet various needs that the local governments can’t supply or offset costs. Given the cost of goods, rising energy costs, increase of insurance premiums, cost of maintenance to just list a few it shall be difficult to keep many of the smaller fraternal organization open. This will result in a reduction of gaming facilities to generate funds for religious, charitable, community, or educational purposes.    

As it stands now there has been a significant reduction in BINGO with many fraternal organizations no longer conducting BINGO due to low attendance. The cost of doing business through Charitable Gaming may have a third order of effect by fraternal organization eliminating the activity or simply surrendering their charters and closing. The MOOSE has fraternal lodges in the United States of America and Canada under a variety of state and provisional gaming laws. Many are not permitted to conduct any gaming yet they still exist. They exist but their charitable donations are significantly lower than the Commonwealth of Virginia. If that is the intent of our legislative branch, then change nothing and watch the donation decrease and see fraternal organizations close.

Please take into consideration during these hard times families have less to expendable income but are looking for a place to meet, socialize and raise funds for the community as they will continue to struggle to provide for school supplies and recreational activities for their children.    

CommentID: 204084