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
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11/23/22  12:49 pm
Commenter: James Michael Dunham

Charitable Gaming - Use of Credit Card

We were told in the training that we could not use Credit Cards to make donations and payments that were UOP Eligible.  By taking away this important tool, the Virginia Regulators are putting an unneeded limit in the ways we can perform business functions.

By taking away our ability to use a credit card I feel this significantly hampers our ability to function and that this decision was made without due consideration.  Here are some of the reasons.
1.  Speed of making the donation.  When writing a check, oftentimes the checks are charged back to the account several days to several months later.  Making it more difficult for our accounting processes (since this is a "cash" accounting process).  Credit card use means I can tie the donation to, if not a specific exact day, certainly I an get it limited to a two or three  day range.  
2.  Logistical Complexity of making the donation.  Not every charitable institution likes receiving donations via check (even if they do accept them).  It means they have to hold off on planning for spending until the check clears.  It also adds time and effort into a process for the charitable gaming organization (in this case our VFW Post a 501c19).  
Examples:  Specific to our VFW Post
Required Donations to the Veterans of Foreign Wars National Programs (National Military Services, VFW National Home for Children, VFW Program Support for Scholarship Programs, Teacher of the Year, etc).  National Convention Registration.  
Required Donations to the Veterans of Foreign Wars State Programs (Buddy Poppy, Virginia Veterans Fund), State Convention Registration.
OUTSIDE of the VFW - Wreaths Across America, FeedMore (CVFB), Warrior Hike, Sportable (Adaptive Sports Programs).  
All of these and numerous others the donations were made via Credit Card (which the post pays the bill for).
3.  Online Retailers  - I don't know how your office might do an office supplies purchases, but I am betting that no one actually has to write a check to get things.  Especially for smaller non-profit entities we order hundreds of things online (flags we give away to schools, children, fire departments, other veterans in our community, coffee we donate to our local firehouse and police stations), Office Supplies, things that are donated out by request (including things we have purchased for the Veterans Administration Hospital I should add - who specifically requested we get the items and then give the physical item to them).  
4.  Specific Items we use for our Non-Profit Functions.  Our service officer cell phone (paid by the post - try getting a cell phone and saying you want to pay by check).  We purchase food/drinks for donation (we sponsor family day cookouts at military units, and we have "public" days at our post when any veteran is welcome to come in - Army Birthday, Navy Birthday, Marine Corps Birthday, Veterans Day, Memorial Day, etc - all done as our support for the wider veterans community and not just for our members).  
5.  Donations in some cases can't even be made at all via check - so these would need to stop.  We have a standing practice where our service officer can set up a temporary (two or three day) stay for a veteran in need at a hotel, extended stay, etc.  Those are simply not possible if we try to do it via a "check" process.  
6.  Credit Card Rewards - when using a Credit Card (not debit card) we also receive rewards (i.e. cash back) that our Charitable Organization can then use for other things. 
7.  Safety of use - if someone skims the Debit Card or manages to get ahold of a blank, unsigned check and then gets it cashed, the money is gone from the account until a dispute is approved.  If someone skims the Credit Card - we simply can dispute the charge and not pay the bill (so we are not out the funds during this process).  Debit Cards take the money directly out of the account (meaning the money is gone and we may not notice until the charges are reviewed).  
8.  The same "auditing" process can be accomplished by simply our ability to use the Charitable Gaming UOP to "reimburse" ourselves for the credit card bill - a copy of the bill can be supplied along with the bank account statement to show which charges were UOP allowed.  
These are only some of the many reasons why I disagree with the decision.  In this "online" world - the physical writing of checks is a thing of the past.  By limiting us to check and direct charges to our accounts - it is less safe for our organization and offers no real protection for the integrity of Charitable Gaming.  


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