Virginia Regulatory Town Hall
Agency
Department of Agriculture and Consumer Services
 
Board
Department of Agriculture and Consumer Services, Charitable Gaming
 
chapter
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 Ends 11/23/2022
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11/23/22  7:19 am
Commenter: Lisa Tillman FOE 871 ALVA

Un Fair Changes to Gming Regulations
 
Proposed Charitable Gaming Regulations
 

I am the Worthy President of Alexandria Aerie 871 Fraternal Order of Eagles. Our Aerie has a membership of 1200 including the Auxiliary. We donate a tremendous amount of money to our community, state and national charities. I propose the following changes to the regulations:

  1. Remove the exception to salaries and wages to match the definition as defined in Code 18-2-340.16. In order to maintain gaming, our organization needs to be able to pay the employees who maintain and manage our club.
  2. The requirement of the proposed 40% use of proceeds would greatly impact the financial stability of our organization and could cause us to become insolvent. A 15 - 20% rate would be much less of an impact on operations.
  3. in 11VAC20-20-70 Bank account section D - modify this section from the second business day requirement to a weekly requirement. Our club is operated mostly by volunteers and the expectation for the Treasurer to make deposits essentially every other business day is not feasible.
  4. In 11VAC20-20-40, section B, the addition of the $200.00 fee specifically for electronic gaming is redundant as we already pay a $200.00 general gaming fee. Please remove the fee from the guidelines.

Thank you for your consideration.

 

Lisa

CommentID: 206024