The first thing I would like to say is that there is no question that the money generated from electronic pull tabs has helped all the fraternal organizations fulfill their obligations to their national organizational charities as well as many local endeavors. There have been examples shown in almost every comment. From sports teams, homeless shelters, Veteran causes, hospitals, schools, etc. 

With that said there are a few things I would ask you to consider;

1. Without any previous data to explain/ back up the percentage of how the "The Use of Proceeds" was calculated I would like your agency to explain where it came up with 40%? To go from zero to forty seems excessive to even a lay person. The monies generated from electronic pull tabs in most organizations that are given to charity probably fall within 15-20 %. Again there is no data to dispute or confirm this. To put regulations into effect without even knowing the amount of money given to charity under the current laws seems reckless. 
2. To tell a non profit organization that they can not maintain their building (rent/utilities/ salaries ) with money being generated by their members who play the electronic games is also unreasonable. It’s like telling a Major League Baseball manager he can pay a salary to the pitcher but not the catcher. The clubs that have these games rely on both paid and volunteer members to maintain the games/ count the money/ make bank runs. I can’t image anyone volunteering to do this job for no compensation and then force them to have separate bank accounts, make deposits to a bank every 48 hours and be on site every hour their Social Quarters are open. 
3. To make these regulations retroactive to July is again unreasonable. How do you pass laws/regulations on events that already have occurred? These Fraternals were operating within the guidelines that they knew were correct at the time they were doing it. 

How can you enforce regulations when there were no regulations?

I would like to comment in a positive way about how your agency has been transparent with these regulations and welcomed public comment. I have attended the workshops and meetings and although I think the cart is before the horse. I sincerely appreciate the effort your office has put forth.