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
11/22/22  5:37 am
Commenter: Charles Burke, District 4, VA Moose Association

VA Electronic Charitable Gambling Regulactions

I am writing for our District's 11 Lodges and its 8,541 members. I am, also, commenting on potential problems for all of Virginia Moose Association (VMA) lodges, with 56,754 membership. 

I agree that fraternal organizations should not total rely on gaming. But with the decline in volunteerism and inflation it has become a integral part, in order to meet charitable obligations and benefits to members. The new required 40% of adjust gross of electronic gambling obligated to charities (which we normally only get 50% of), plus not allowed to use any of it for payrolls or other lodge expenses, is excessive. This will require very many lodges to reduce operation benefits, reduced hours, lose of members and some smaller lodges even closing. This will reduce the gambling income and funds available for charities. In the last 6 months District 4 donated $37,946 ($4.60 per capita) and all the VMA lodges sum donated $347,297 ($6.11 per capita). In the previous 12 months the District donated $59,355 ($6.99 per capita) and VMA $464,854 ($8.19 per capita). (Approximately 50% of members rarely come into, if ever, the lodges.)  This does not include the multiple thousands donated by Lodges to local & State charities, or other Moose units in VA donations, such as Moose Legions, WOTM Chapters, Districts, Council of Higher Degrees or VMA itself.

Suggest reducing required adjusted gross donations to 10% and allow a portionate mount applied to payrolls and expenses. The Lodges amenities benefits the gambling and the gambling benefits the other amenities. You can't separate one without effecting the other. 

Other requirements need to be studied more closely, but don't have enough allowable space to address.


CommentID: 205888