Virginia Regulatory Town Hall
Agency
Department of Agriculture and Consumer Services
 
Board
Department of Agriculture and Consumer Services, Charitable Gaming
 
chapter
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 Ends 11/23/2022
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11/9/22  6:06 pm
Commenter: Kenneth Niman Massanutten Fraternal Order of Eagles #4186

11VAC20-20-80. Bank accounts
 

D. All receipts from each session of bingo games, network bingo games, raffles, instant bingo, pull-tabs, seal cards, or electronic gaming shall be deposited by the second business day following the session at which they were received.

If I am understanding this requirement correctly, I will be required to go to the bank to make a deposit every day because every day we empty our electronic gaming machines. For example, I empty the machines on Monday, I would have to go to the bank by Wednesday to make a deposit. Then I empty the machines on Tuesday, I would have to go to the bank by Thursday to make deposit. Then I empty the machines on Wednesday, I would have to go to the bank by Friday to make a deposit, and so forth. This requirement is infeasible because…

1) Our club (as well as many fraternal clubs) are operated by volunteers. The expectation of having us going to the bank multiple times a week is infeasible.

2) Fraternal clubs like ours have Bylaws and as such we would have to change our Bylaws to be able to comply with this banking requirement. To change Bylaws takes time because there is a process to changing or adding to Bylaws.

3) Many times, we need to use the money we pull from the charitable gaming machines to maintain operation of our electronic charitable gaming. For example, we have electronic gaming drawers dedicated strictly for paying out winning tickets as they are cashed in. Sometimes, we pay out more than what the electronic gaming machines collected, and we must use the monies we pull out of the electronic gaming machines to reset our electronic gaming drawers.

CommentID: 205133