I have reviewed these draft regulations both from the perspective of the founder of a nonprofit organization, which gives me an intimate understanding of the burdens and obstacles that these types of organizations face, and as a current candidate for the state senate, who is thus mindful of the impact of such legislation on the individual, especially as pertains to potential infringements on their rights. 

As an overarching point and guiding principle, it’s unclear to me why these regulations should be different (and especially more stringent) than the regulations that apply to for-profit casinos and gambling businesses. As a proponent of the free market, I, of course, do not want to see businesses punished for making a profit, but I also don’t believe we should be making it harder for organizations that have charitable pursuits to succeed. As an example, the provision in these draft regulations that relates to the holding of concurrent tournaments is problematic. It is my understanding that for-profit organizations can conduct concurrent tournaments at a much wider level than what would be allowed for the charities to do even if this restriction was removed. This is illogical. We should let these organizations operate in a way that makes sense for them. 

Additionally, I am neither a gaming participant nor expert in gaming, but I do, from my own work, have a thorough understanding of the nonprofit sector. The draft regulations relating to the use of proceeds seem to be government overreach and ill-considered. For instance, under these regulations a 501(c)(10), which IS allowed to participate in gaming, would be disallowed from using their proceeds in the manner dictated by the IRS in order to maintain their standing. Is that a mistake or are these regulations intended to prohibit 501(c)(10)’s from continuing to participate in gaming? Either way, this is problematic.