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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11/10/22  6:55 pm
Commenter: Frank Burns

Burdensome Financial and Regulatory Requirements

As an Elks Lodge, with Arlington-Fairfax Lodge #2188, we have participated in compliance with Charitable gaming requirements for decades with a robust bingo operation.  As a former Federal regulator, I can state with conviction that new, proposed regulatory requirements on virtually all non-profit, volunteer-operated enterprises will compromise the existence of many small entities that have served Virginia for years.  For many reasons following COVID, we can no longer operate the full-scale bingo operation that supported much of our charitable programs for years.  However, new  and expanded regulatory burdens, such as requiring separate bank accounts and burdensome accounting detail for even our occasional "50-50 games" and occasional "fundraisers" will cause us to give up even that.  For us, net revenue from charitable and other gaming will never again exceed $10-20K per year.  However, both of those actually contribute to our charitable endeavors.  We struggle to stock the freezers at the USO Lounges at Reagan National Airport and Fort Myers throughout the year, to provide backpack lunches to schools in Arlington and Fairfax Counties, and small college scholarships to a small number of local high-school seniors.  The list of what we try to do is fairly extensive.  However, these regulations, and more significantly, the threat of "punishment" for "non-compliance" with confusing and burdensome financial tracking requirements hinder our ability to continue these efforts.  Given the purpose and significant issues of this legislation and regulations, small non-profit organizations such as ours are not significant players.  As a former regulator, I know that you can craft requirements that will allow you not to have to waste your time and efforts on organizations such as ours.  We are not worthwhile players in this enterprise, and you should not waste Government resources tracking the activity of nonplayers!

CommentID: 205149