January 4, 2012

Ms. Erin Williams

Acting Program Manager

Department of Charitable Gaming

Post office Box 1163

Richmond, Virginia 23218

Dear Ms. Williams:

On behalf of the Virginia Charitable Bingo Association (VCBA) I am pleased to forward the following comments in regards to proposed regulations 11VAC 15-40. I have also posted this letter to the Virginia Regulatory Town Hall website.

Our leadership has expended much time considering these proposed regulations. As a result we are very concerened that if certain portions of the regulations are left as is the document could create a new unintended and almost identical new business similar to interent cafe style gaming which would take away significanctly from the intended purpose of assisting charities playing bingo. As you are aware we are very sensitve to this issue as we have just spent considerable energy defeating that industry.

Given the above we recommend several criticaly important additions to 11VAC 15-40:

1. Clear definitions must be established for both a "stand alone device," and a "hand held device." It is our suggestion that a "stand alone device," be defined as, "any electronic terminal that is used at any time solel for electronic pull tabs at a time other than a regularly scheduled bingo game," and that a "hand held device," be defined as, "any electronic terminal that plays the session game of bingo concurrent with electronic pull tabs."

2. The number of stand alone devices must be strictly limited. We suggest changing the number from one to every fifty (50) permisable occupants under the Uniform Statewide Building Code to one per every one hundred (100) occupants, with consideration that every location be allowed at least one.

3. The number of hand held devices must also be strictly limited. We suggest that electronic pull tab hand held devices may only be played if purchased along with a bingo package during a regulalry scheduled bingo session.

We applaud you and Mr. Alverez for your continued high level of customer service and exceptional inclusion of everyone throughout this process. Thank you for your attention to this matter and if you have any questions please feel free to contact me at anytime.

Sincerely,

Matthew Benka

CC: The Honorable Memebers of the Board of Charitable Gaming

Mr. Andy Alverez