I oppose regulation that will force Veterans of Foreign Wars (VFWs) and other Veteran Service Organizations (VSOs) to vector the distribution of social quarters gaming proceeds away from our organization’s congressionally chartered mission and toward external establishments. I am deeply concerned that the below mentioned portions of the proposed regulation will hinder my post’s ability to accomplish that mission.  Specifically:

1. For our organization to continue to provide a safe and secure area for social quarters gaming, we need to use the proceeds from gaming to properly maintain and secure the social quarters.  

1A. Recommendation: Restore the language that allows direct real property expenses to be charged to Use of Proceeds (UOP) with remainder charged to Business Expense.

2. The proposed regulation’s 40% UOP calculation (with restrictions), represents an unattainable bar for organizations like ours. For instance, we must pay the manufacturers their fair share and remaining funds would not reasonably meet the authorized business expenses. 

2A. Recommendation. Revisit the 40% UOP requirement for electronic pull tabs and adjust the requirement to a lower figure of 10%.

3. The congressional charter for the VFW states that our purpose is fraternal, patriotic, historical, charitable, and educational, and is to preserve and strengthen comradeship among its members. Our purpose is the very definition of what UOP should support.

3A. Recommendation: Insert language in the proposed regulation that will allow us to continue to use gaming funds to support our mission and support membership functions.

4. Full and proper implementation of the proposed regulation (no later than 3 months after the beginning of the reporting period) is unachievable and unfair to our administrators who are trying to do to the right thing.

4A. Recommendation: Work with organizations like ours (who do not have deep accounting capabilities) to establish an iterative process that will allow us to update our business processes and reporting requirements to comply fully with the new guidelines.

5. The proposed daily reconciliation requirements are not reasonable to implement for all gaming situations. For instance, daily reconciliation of Bingo after each session is relatively easy to accomplish. Daily reconciliation of Pull-tabs however, is cumbersome and would be nearly impossible to complete with accuracy.

5A. Recommendation: Revisit the daily reconciliation procedures and enlist organization like ours to help adopt procedures that are achievable as well as meet the spirit and intent of the new regulation. For example, perhaps develop an ‘event driven’ reconciliation schedule for certain games. For Pull-tabs, that might mean reconciling when each box is completed.

6. In today’s world, checks are all but obsolete. Supporting our mission requires the primary use of credit.

6A. Recommendation: Allow the use of credit cards for authorized expenditures and donations that are funded from the gaming account. The credit card statement and/or receipt can be tied to the account.