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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11/21/22  10:18 am
Commenter: Sean Counihan, American Legion Post 162 (Lorton)

Promulgation of Charitable Gaming Regulations by Department of Agriculture and Consumer Services

Please accept the following comments as the official position of the Finance Officer of the American Legion - Lorton Post 162.

1) The proposed requirement to have us empty the gaming machines and make a deposit every two days in unsustainable for our Post.   As a community of veterans, we are all volunteers in which the majority of us still have full-time employment outside of the Post Hall.  Due to this fact, we basically have short list of members that are able to empty the machines on a weekly basis, and we are normally scrambling every weekend to find an elected officer who can be present.  We respectfully ask that you reconsider the deposit requirement and make it weekly.

1a.) Additionally, there are times that our gaming proceeds are low due to either low attendance or increased payouts.  due to this, there are weeks, when we cannot make a deposit, since we need to replenish the cash for payouts.

2) Our post is rebuilding after an electrical fire (in the attic) destroyed the building in 2019.  We are 90% complete, with only the kitchen needing to be restored/renovated.  Due to the fact that we do not have a functioning kitchen, our primary source of income is the charitable gaming machines.  These machines account for over 75% of our income, and we to be able to utilize these proceeds to continue to operate.  Without the use of these funds for normal day to day business expenses, we will be forced to close our doors within months.

Thank you for you time in reviewing these comments and please take into account that this policy is written in a way that is will significantly effect the ability of Veteran Service Organizations (like the American Legion) to not only operate, but also administer services to all Veteran's and Service Members in need.


Sean Counihan; Finance Officer - American Legion, Lorton VA Post 162

CommentID: 205792