I am writing in support of the following comments previously entered by our Aerie’s Secretary on the proposed Charitable Gaming Regulations (including electronic gaming provisions). I wholeheartedly believe these views represent the official position of Petersburg Aerie 882 (including our Auxiliary) with respect to the proposed regulations. I’d greatly appreciate your consideration of the impact the proposed regulations could have on our future charitable endeavors.

PREVIOUS COMMENTS (from our secretary):

1. Proposed regulation:
The proposed regulations require that 40% of an organizations electronic gaming Adjusted Gross receipts must be used for the organizations charitable purpose.

Comment:
This requirement is excessive. In the case of our organization, it would result in unsustainable ongoing net operating loses.
Proposed Solution:
Change this requirement to between 10% to a maximum of 15%.

2. Proposed Regulation:
Clarification that salaries and wages of employees whose primary responsibility is to provide services for the principal benefit of the organizations members do not qualify as a reasonable and proper business expense.

Comment:
We are confused by this proposed regulation. It makes no distinction between profits derived from charitable gaming activities open to the public and those that are limited to our members.
We have one of the oldest continuing bingo game operations in the Commonwealth of Virginia. We annually donate over $150,000.00 to local charities, police, fire, EMS and to provide scholarships
to local students. The majority of these contributions come profits generated from our bingo operations which is open to the public and operated by volunteers from our organization. We understand and agree with the regulations prohibiting bingo profits from being used to benefit our members.

Electronic gaming is a different animal. It was introduced to our organization in 2012. Prior to its introduction our organization was in an increasing financial decline. We worried about our continued existence. Electronic gaming was a financial lifeline. It allowed us to stabilize our financial operation and begin to grow our fund balances.
Our business model has evolved to where our social quarters is dedicated to enhance our members electronic gaming experience. We serve discounted food and beverages to encourage attendance in our social quarters. We encourage our members to responsibly participate in electronic gaming as it is the only source of profits to sustain our organization.
Electronic gaming is restricted to members of the Eagles and the Auxiliary. Spouses, siblings, guests, and the public are prohibited from participating in electronic gaming. 100% of the profits
from electronic gaming are derived from our members. We fail to see any logic in the Virginia Department of Agriculture and Consumer Services limiting these member derived profits from benefiting members.
Proposed solution:
Allow the salaries and wages of all employees to be charged as a reasonable and proper business expense of the electronic gaming account with the portion directly attributable to electronic gaming to be charged to "Use of Proceeds".