11 VAC 15-22-10. Definitions.

The proposed revised definition of "Pack" reads as follows:

"Packet" Pack means sheets of bingo paper or electronic facsimiles assembled in the order of games to be played. This may or may not include specials, winner-take-alls and jackpots, but shall not include any winner-take-all, Lucky Seven or raffle.

It is requested that the definition as it is proposed to be revised be changed to read as follows:

Pack means sheets of bingo paper or electronic facsimiles assembled in the order of games to be played. This may include specials, and jackpot, but shall not include any winner-take-all, jackpots, Lucky Seven or raffle.

The purpose of the change is to require that cards for jackpot games be sold separately from the bingo cards or sheets used for any other bingo game.

11 VAC 15-22-70(A)(9).

The proposed revised language reads as follows:

9. Each A record of the name and address of each winner for all seal cards, pull-tabs and instant bingo prizes of $250 and over along with the winning ticket and seal card; and

It is suggested that the language as it is proposed to be revised be changed to read as follows:

9. A record of the name and address of each winner for all seal cards, along with the winning ticket and seal card, to be maintained for 90 days after the session; and

The purpose of this amendment is to reduce the storage requirements for these bulky items, as it is believed not necessary to have to retain those items for three years. In every case, it should be possible to resolve any question about a seal card deal within 90 days.

11 VAC 15-22-70(B)(4).

The language of the Regulation reads as follows:

4. Receipts for all raffle prizes valued at $500 or more on which prize winners must provide printed name, residence address and the amount and description of the prize received; and

It is suggested that the language be changed to read as follows:

4. Receipts for all raffle prizes valued at $500 $600 or more on which prize winners must provide printed name, residence address and the amount and description of the prize received; and

The purpose of this suggestion is to bring the prize winner identification requirement in line with the requirement of the Internal Revenue Service (IRS) that winners of $600 or more must be identified on a W2-G form to be filed with the IRS and maintained by the organization.

Please consider the bingo volunteer who has completed the work during a session of bingo being able to purchase seal card tickets during the next session,where the winner must hold a winning number, symbol or letter in order to have a chance to win that game (not instant pull-tab tickets). Since winners cannot be determined on a seal card game until the box is completely sold and seal card number is revealed, there is no way of anyone knowing if all prizes have been paid out as there would be in the sale of only instant pull-tab games. There is also no way of a volunteer having the advantage over others because no one is a guaranteed winner who holds a chance at winning the game until the game is over and the winning numbers, letters, or symbols have been revealed.

11 VAC 5-15-20 D & E and the proposed 10% UOP does not take into account the decreases in the bingo playing population, demographic differences, and the advantages some groups have over others, specifically: (i) organizations that own their own facility can be their own charity and can open their building for gaming four days per week as compared to other facilities which are only allowed to open two times; (iii) organizations with social quarters can sell instants 24/7 (these sales exceeded $70 million several years ago); and (iv) organizations do not have to pay the 1+ % audit fee.  Finally, the 10% does not take into account that the vast majority of the money collected is paid out in prizes, the supplies to conduct charitable gaming, audit fees and other proper gaming and business expenses.  A 5% use of proceeds after payment of all gaming and reasonable business expenses will help level the playing field and ensure that a significant portion of the money collected from charitable gaming (after prizes, paper costs, audit fees, etc....) will be utilized for the intended charitable purposes.

 

 

15 VAC 15-22-40 W  should be revised to eliminate the limitation on advertising to only qualified organizations. Others, such as hall owners, should be allowed to promote the organizations that utilize their facilites.  

15 VAC 15-22-100 E  1  should be revised to eliminate the "management" (which is now a defined term), restriction because it prevents groups from consulting with and tapping into the gaming experience and knowledge hall owners may have. Landlords would still be restricted from participating in the "...operation or conduct...." (now defined terms) of games.  

11 VAC-15-22-100 A should include a restriction which only allows the 501(c) qualified organization which owns its own building the ability to directly rent it out to other quailified organizations who will conduct charitable gaming in its facility.  This will eliminate any sub-letting which circumvents the purpose and intent of the extra 2 day gaming privilege.