As a long term member of a medium to small size bingo operation, I am all for any new regulation that would help bingo operations increase its customer base, and improve charitable gaming for our customers. I believe the use of electronic pull tab, instant bingo machines would help us all, but probably the bigger operations much more than the medium to small operations. As a smaller operation, I do have, and has always had a concern with the CGC's regulation governing the payment of reasonable fees for the preparation of the quarterly and annual financial report. It states under Section 11 VAC15-40-50 'Conduct of Bingo' that:

N. Individuals who are not members of an organization or are members who do not participate in any charitable gaming activity may be paid reasonable fees for the preparation of the quarterly and annual financial reports.    

Our interpretation of that paragraph is that we can only pay reasonable fees for financial report preparation to someone outside of our membership (i.e, bookkeeper or CPA at a much higher cost) or to someone inside our membership (who don't participate in the operation of bingo).  Why?   We suggest the regulation should read:  

N. Individuals who are not members of an organization, or members of the organization who provide the accounting functions for the organization may be paid reasonable fees for the daily accounting, and preparation of the quarterly and annual financial reports.

CGC allows a member of an organization to receive a reasonable fee for being a caller, for providng security, and for managing the game, but not for doing the difficult job of daily, quarterly, and annual accounting. Small to medium operations do not necessarily have the funds to hire this function out, nor do we have enough individuals who are not a part of the operation of bingo who have this skill set.  Financial reporting is very important and smaller operations need someone to consistently provide this service to thems at a low cost. Thanks for your consideration.