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.