My statement pertains to the topic of operator fees. VDACS requires that charities may only compensate operators with a fixed fee for services, rather than a fraction of the revenue. This negatively impacts charities, since they are still liable for the flat fee even if revenue decreases. It's unusual that VDACS would apply such an arbitrary restriction. An appropriate response would be to remove the initial two sentences of 11VAC20-30-60.P. Commissioner Guthrie has communicated the importance of charities achieving their use of proceeds. Beyond that, VDACS should not care to meddle in charities’ operations.