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  4:50 pm
Commenter: Anonymous

Unfair Advantage to Fraternal orders

After reading through all of the proposed and passed regulations for electronic pull-tabs, it appears to give an inordinate amount of control to fraternal orders. The way that the legislation reads fraternal orders are going to have a monopoly on this revenue generating source. In effect, the other non-profit organizations will become solely reliant on the good will or support of these entities instead of being able to generate the necessary funds to continue their own good works. There is very limited oversight of where the funds are disbursed to and whether or not they are disseminated fairly. Often the funds are given to other non-profits based on political reasons rather than necessity. 

I would suggest that a review of what qualifications are needed to have these revenue streams. All of the non-profits are required to file 990 and 990T so banning the use of the machines in other non-profits forms a monopoly and advantage to these fraternal orders. In addition, the ability for these fraternal orders to have these machines available in publicly available spaces will further damage any of the non-profits ability to become relatively self sustaining. 

CommentID: 204089