PLEASE consider the following specific changes to the regulations.

Part II - Charitable Gaming Organizations- Article 1 – Permits

C. “A permit shall be valid only for activities, location, days, dates, and times as listed on the permit.”

Request:  Additional language: An organizations local, district, state and National Conventions are an exception to the permit and will be granted with advanced notice to the department.

Reason: Conventions for our organizations are not open to the public. Organizations use these larger organizational conventions and business meetings to socialize with other chapters and fundraise for our charities and Lodges. Dates are set well in advance so notice can be given to the department.

“An organization that conducts electronic gaming must have a separate electronic gaming authorization on its permit” 

Request: remove requirement.

Reason: If the electronic gaming is now reportable under the permit, and above it specifies “activities” , we request that “electronic gaming” be an acceptable activity that is listed on the permit. No separate permit should be required.

D.  2.  “For electronic gaming, the minimum percentage shall be 40% of its electronic gaming adjusted gross receipts.”

Request: Lower percentage to 20% of its electronic gaming adjusted gross receipts.

Reason: 40% is too high. The money received from gaming is NEEDED for Lodges to stay open. The time in volunteer hours to the communities we serve is more valuable in many instances than simply donating cash. If organizations are required to spend even more hours raising funds to keep the doors open, there will be less if no hours left to fulfill our hours of charitable duties to the community. Lodges have relied on this income to pay our expenses. This high of a percentage will force many to close their doors and all benefit to the communities we serve will be lost.

G. “An organization…..to reapply for a permit at the end of one year from the date of revocation.”

Request: Change “end of one year” to 90 days.

Reason: The remainder of section G calls for …”substantial efforts toward meeting its remedial business plan”. A Lodge working on their remedial plan will also need the income from the electronic gaming as part of the plan. A one year waiting period is too long. We feel 90 days is sufficient to show improvement.

11VAC20-20-30. Charitable gaming permit application process for raffles, bingo, paper pull-tabs, network bingo, paper instant bingo, and paper seal cards.

J. “An organization wishing to change……effective date.”

Request: Add part 2. “An organization’s local, district, state and National Conventions are an exception to the permit amendment requirement.  Authorization will be granted with advanced notice to the department.

Reason: To allow organizations to attend and sell raffles during conventions both in state and out of state as law allows for the benefit of the organization and it’s charities, without the lengthy process of a permit amendment.

M.  Any permitted… by the department.

Request: remove the words ” or electronic gaming devices”

Reason: Clarification. 11VAC20-20-30 does not govern the electronic gaming. Electronic gaming machines are not permitted at Bingo effective 7/01/22. 

11VAC20-20-40. Charitable gaming authorization for electronic gaming.

A.  “The operation of electronic gaming is a privilege that may be granted or denied by the department. A social organization desiring to operate … thereto.”

Request: Removal of sentence one.

Reason: Redundant. The law now requires electronic gaming to be part of an organizations charitable gaming and it is covered under 11VAC20-20-20 A. If an organization cannot conduct charitable gaming, electronic device gaming is no different.

Request:  Add at the end of paragraph 2. “An organization must list Electronic Gaming as an activity on the charitable gaming permit or if wishing to add electronic gaming after the permit is issued, request an amendment to the permit to add electronic gaming.

Reason: Electronic gaming is simply an electronic version of paper pull tabs. It is charitable gaming and should fall under one permit.

B. “A Social Organization…submit a non-refundable fee.. of $200.00 in addition to the fee prescribed for the charitable gaming permit.

Request: Lower or completely remove the additional fee.

Reason: Charitable gaming is charitable gaming. It is all accounted for on one form and should be covered under one permit. Lodges that did not conduct Bingo and ONLY offered the weekly Queen of Hearts drawing still paid the same for the permit as those also doing bingo. The permit fee should be for charitable gaming period.

H. “A Social Organization may cancel its scheduled electronic gaming session…”

Request: Eliminate the entire paragraph.

Reason: Electronic gaming machines are free standing machines accompanied by a payout machine somewhere in the premises. There are no “sessions”. Members and their guests come in whenever a facility is open and can play the electronic games. Lodges are private organizations and should be able to close for a day or modify their hours without the approval, permission, or forgiveness of charitable gaming.

K. “A social organization authorized to operate and conduct electronic gaming shall expend, at a minimum, 40% of its electronic gaming adjusted gross receipts…”

Request: Lower the percentage to 20%.

Reason: 40% is too high. The money received from gaming is NEEDED for Lodges to stay open. The time in volunteer hours to the communities we serve is more valuable in many instances than simply donating cash. If organizations are required to spend even more hours raising funds to keep the doors open, there will be less if no hours left to fulfill our hours of charitable duties to the community. Lodges have relied on this income to pay our expenses. This high of a percentage will force many to close their doors and all benefit to the communities we serve will be lost.

Article 2 Conduct of Games, Rules of play, Electronic Bingo

11VAC20-20-60. Conduct of bingo, paper instant bingo, paper pull-tabs, paper seal cards, event games, network bingo, electronic gaming, and raffles.

*This entire section seems to have been written when electronic gaming was allowed as a part of Bingo. These regulations do not make sense as applied to electronic gaming done in the Private Social Quarters of Organizations whose electronic gaming is for the use of its members and bona fide guests only!

I. “ A game manager who is a bona fide member of the organization and is designated by the organization’s management as the person responsible for the operation of the bingo game or electronic gaming during a particular session shall be present any time a bingo game or electronic gaming is conducted.

Request: Removal of the verbiage “electronic gaming”. 

Reason: The electronic gaming conducted in the private social quarters of an organization is open to the organizations members and bona fide guests only. The electronic machines do not require an attendant for the operation of the machines. Sometimes there is no one playing the electronic machines, or one person. This regulation requires a “gaming manager” on duty to watch and or monitor the one person playing? This regulation was written for the electronic gaming that occurred during bingo sessions open to the public. A gaming manager should be present any time the facility is open to the public and charitable gaming is occurring. ***In today’s world, grocery check out is self serve and monitored via camera. Patients in ICU are monitored remotely, via computers and cameras, gas pumps are self serve, monitored by cameras. Some Lodges, like Hampton #366 recently invested 4K in a new state of the art security system that monitors all activities remotely. If the verbiage “electronic gaming” is not removed, please add that electronic gaming may be monitored remotely.

L. 2. “Pay for all charitable gaming supplies and electronic gaming supplies, including the use of the electronic gaming device, only by a check drawn on the charitable gaming account of the organization.

Request: additional verbiage to state, “ a check or electronic funds transfer drawn on…”

Reason: Electronic funds transfer is the most efficient way to pay invoices and is already in effect in many organizations. Paper checks are an outdated form of payment.

T. ‘All Bingo…must occur within the time specified…permit”

.0 Remove verbiage “electronic gaming sales” and “electronic gaming.”

Reason: Once again, these are the regulations that accompanied the electronic gaming open to the public attached to a bingo session. This regulation is not conducive to the electronic gaming done in a private social quarters.

U. Paper…session.

Request: Remove verbiage “electronic gaming”.

Reason: Electronic gaming is no longer permitted during bingo sessions per law.

11VAC20-20-80. Bank Accounts

D. All receipts…deposited by the second business day…received.

Request: Remove verbiage “electronic gaming”.

Reason: This regulation was written for electronic gaming conducted in conjunction with electronic gaming played during “open to the public” bingo. Lodges do not have specified “sessions” and to require Lodges to empty the machines and make deposits that frequently is an undo burden. Electronic gaining from the social quarters should be reported weekly.

11VAC20-20-90 Recordkeeping.

A.2. “ A session reconciliation form:…by the game manager:

Request: Remove verbiage “electronic gaming”

Reason: This regulation was written for electronic gaming conducted in conjunction with electronic gaming played during “open to the public” bingo. Lodges do not have specified “sessions” and to require Lodges to empty the machines and make deposits that frequently is an undo burden. Electronic gaining from the social quarters should be reported weekly. Also, there is not an “electronic gaming reconciliation form” for social quarters electronic gaming.

11VAC20-20-110. Use of Proceeds

A. All payment…pursuant to 11VAC20-20-80 A.

Request: Add verbiage as follows: “…by check or electronic funds transfer…”.

Reason: Electronic funds transfer is the most efficient way to pay invoices and is already in effect in many organizations. Paper checks are an outdated form of payment.