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
Previous Comment     Next Comment     Back to List of Comments
11/19/22  3:53 pm
Commenter: M. Conrad Agresti

What is the goal of imposing a new administrative burden upon charitable organizations

The justification of the Legislative and Executive branches of the Commonwealth of Virginia to levy new and costly administrative burden upon charitable organizations - especially Congressionally Chartered Veterans Service Organizations, such as the Veterans of Foreign Wars of the United States - has not been met by the proposed regulations.  

There is no cited altruistic or financial benefit to the Commonwealth of imposing these regulations.  The term "unable to determine" appears throughout the cost/benefit analysis.  Approval of these regulations would therefore force taxpayers to buy the proverbial "pig in a poke" - signing-up for a costly administrative and regulatory bureaucracy that likely will not pay for itself.

Additionally, since VSOs have a Congressionally mandated role to care for veterans and their survivors, honor the dead, and educate the public on the sacrifices veterans in preserving the fragile democracy that cradles our communities, imposing discordant financial support mandates literally takes comfort and succor from those mandated protectants. 

VFWs within the Commonwealth provide tens of thousands of dollars in scholarships to middle and high-school students annually - without regard to race, creed, ethnicity, sexual orientation, or religion.  Most, if not all, of the funds used for these scholarships is derived from charitable gaming.  Directing the monies elsewhere, including to an insatiable government bureaucracy, would reduce this direct support to the burgeoning leaders this country so desperately needs to nurture.

The answer is clear.  Defeat these proposed regulations.  Let the charitable work of IRS-certified charities continue unabated.  There is no need for Virginia to establish a bureaucracy to review the approval process/decision of a federal bureaucracy.  That these proposed rules suggest that is sufficient blatant overreach to vote against these proposed regulations.

CommentID: 205717