Thank you for the opportunity to comment on the proposed regulations.  Our major concern with the proposed regulations is the lack of any requirement or criteria for the issuance of a permit to manufacturers of electronic gaming systems.  Section 18.2-340.34 (A) of the charitable gaming statute requires that before a manufacturer may sell, offer to sell, or otherwise provide an electronic gaming system in Virginia, the manufacturer must obtain a permit from the department.  Section 18.2-340.34 (B) authorizes the department to prescribe in regulation criteria, consistent with the statute, for the issuance of such a permit.  Subdivision (B) contains minimal criteria for the issuance of a permit, but we would recommend that the department amend the proposed regulation to add additional criteria comparable to that required for suppliers in 11 VAC 15-31-20 (B), 1-7.  Moreover, we recommend that manufacturers be subjected to a background investigation prior to the issuance of a permit, similar to that required for suppliers under 11 VAC 15-31-20 (F).

We believe that these modifications to the proposed regulations are necessary to maintain the integrity of charity gaming in Virginia.  The proposed regulations contain very detailed and specific requirements for the electronic gaming systems, but no requirements for the companies and individuals that manufacture them for sale or lease in the Commonwealth.  Modifying the regulations to subject manufacturers to the same or similar requirements imposed on suppliers is reasonable and will not cause any hardship to the manufacturers.

Again, thank you for the opportunity to submit comments.  If you have any questions, or if you would like additional information, please do not hesitate to contact me.