1. Please 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 to 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 day is not feasible.

 

 

4. In 11VAC20-20-40, section B, the addition $200.00 fee specifically for electronic is redundant as we already pay a $200.00 general gaming fee. Please remove this fee from the guidance.

 

 

You can read and post comments on the following website. Feel free to copy and post my comments if you wish. The more comments that are posted the better chance we have of getting the Commission to understand our business. The deadline for posting comments is end of day November 23, 2022.