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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11/19/22  5:24 pm
Commenter: American Legion Post 162 (Lorton)

New Regulations are too restrictive

New Charitable Gaming Requirements

Forcing VSOs to expend social quarters gaming proceeds to outside organizations and not use them for the mission of the organization makes absolutely no sense. The American Legion Charters meet the same criteria as organizations we must donate to. 

Areas of concern in the proposed regulations are as follows: 

1. The proposed requirements mandate that organizations have a manager/employee on site and working while electronic gaming is being played.  This is the entire time a social quarter is open.  We operate mainly on volunteers, and this would require us to pay employees to be present.

2. Using 40% UOP with proposed restrictions is an unattainable percentage for the organizations. We must pay the manufacturers their fair share and what’s left isn’t enough to cover the authorized business expenses.  Revisit the 40% UOP requirement for electronic pull tabs and adjust the requirement to a lower figure of 10%.

3. The charter for the American Legion's purpose is fraternal, patriotic, historical, charitable, and educational, and is to preserve and strengthen comradeship among its members. We are the very definition of what UOP can be used for.  Allow the use of gaming funds used within the organization and to support membership functions such as appreciation dinners.

4. The proposed reconciliation requirements were taken from Bingo that is easily accomplished after each session. Trying to accomplish this on a never-ending game or partially played game is hugely cumbersome and almost impossible to complete with accuracy. In the social quarters, a box of pull-tabs could take days or even weeks to complete, it is impractical to empty the machine to count how many tickets are left.

5. In today’s world, checks are all but obsolete.  Online purchases require a credit card, as does gas, food, hotel, or transportation for a needy family.  Allow the use of credit cards for authorized expenditures and donations, that are paid from the gaming account.  The credit card statement and/or receipt can be tied to the account.

CommentID: 205718