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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11/16/22  11:23 am
Commenter: Don Ridenhour, Moose Charities Board Member

Charitable gaming changes simple math

Here is some simple math to explain how these new laws and regulations affect our Virginia Moose Lodge's operations. The electronic games pay out approximately 92% in money and free plays. That leaves 8% to be evenly split between the gaming company and Lodge. Of the 45 the Lodge receives, as it stands, they have to give away 40% to charity and .75% of the gross receipts to the state in taxes. The rest is limited on that which it can be spent to operate the Lodge and keep the doors open.

So here's is the math in simple figures as this layman sees it:

$100 (Actual money played) - $92 (payout) = $8 (split)

$8 (split) - $4 (Gaming company portion) = $4 (Lodge portion)

$4 (Lodge portion) - $1.60 (40% to charity) = $2.40 (Lodge portion)

$2.40 (Lodge portion) - $.75 (or more to state from Gross revenues*) = $1.75 (Lodge portion)

* may also include in play prizes and free plays which makes the total higher

So, when all is said and done, the Lodge only receives $1.75 out of every $100 spent to spend the way the State tells us to spend it. We are being told that we are limited on the things we can spend this money to keep our doors open which includes paying salaries and other basic operational expenses. We are also being told that the gross revenues include the free plays, money actually spent, and prizes that show up on our gaming reports which in no way reflect actual money spent or received by the Lodge.

Our members, and it is only members who play these games in our Lodges, freely come into our Lodges and spend their money as they see fit. They understand that the money they spend will be used to help our mission of caring for children in need, our seniors in their old age, and our communities. If we are not allowed to use that money to support our operations, we will be put in a position of severe hardship and many Lodges may be forced to close and we will all lose.

Prior to these new regulations we were able to use proceeds, less the 10% or more we gave to other charitable endeavors, in any way that would benefit our Lodges to help them grow. This in turn increased revenue for everyone, both our charitable giving in the community and our mission as moose members. We ask that you return to the prior regulations of 10% to charity and free use of proceeds while keeping the new fees. This will allow us to continue to operate in a beneficial manner to all concerned and also contribute to the state by paying the fees requested. That way we all win and we can continue to contribute. Don't punish us for those who abuse the system but instead use the money collected to focus on them instead of the institutions that have been playing by rules all along such as our fraternal units.

Lastly, I urge each of you to go out into your communities and visit the institutions, such as the 83 Moose Lodges in Virginia, and see the impact they have upon the communities they serve. Read the mission statements of these organizations affected by your regulations and look at the unintended consequences these new regulations will have on these organizations. I think that once you have done this you will find that we do an amazing amount of service for our communities, our schools, social service programs, fire and police departments, and many other organizations. By doing this we take pressure off of state and local governments by fulfilling needs right at the source.

Thank you for your time.

CommentID: 205479