October 28, 2019

Nevada: CSF Weighs-in on Gaming Commission Proposed Regulations on Charitable Games and Lotteries Affecting Partner Conservation Organizations

Contact: Aoibheann Cline, Western States Coordinator

On September 26, the Congressional Sportsmen’s Foundation (CSF) provided a comment letter to the Nevada Gaming Commission (Commission) on proposed amendments to charitable lottery and charitable game rules.

CSF works with and relies on the efforts of national and in-state conservation partners to further our mission of protecting and advancing hunting, angling, recreational shooting and trapping. Many of these partners rely on the ability to fundraise through raffles and auctions at chapter events, and larger national events hosted within Nevada to provide support for agencies such as the Nevada Department of Wildlife and other conservation efforts.

The Commission proposed Regulation 4A following the passage of AB 117 to apply charitable lottery and game regulations statewide rather than on a county-by-county basis for uniformity in regulation and enforcement. However, CSF found several provisions of Regulation 4A required amendments to avoid inadvertent negative impacts to CSF’s partner organizations.

CSF provided comments on the application process, youth participation restrictions without statutory direction or intent, online ticket sale requirements, and the arbitrary statutory cap of $500,000. The Commission was responsive to CSF’s concerns and issued updated proposed regulations to be heard by the Commission on October 24.   

On October 24, CSF testified in front of the Commission regarding outstanding concerns on proposed Regulation 4A, including accepting fair market value as documentation for prize value at the time of application, burdensome restrictions on youth participation, out-of-state resident participation, and recognition of individual chapter organizations as separate qualified organizations from the national organization in light of the statutory limit of $500,000 in total prizes offered per year.

The Commission amended the youth participation limitations by clarifying that no one under 21 years old could participate in charitable games, defined as poker, blackjack and bingo, which were not of concern to CSF. The Commission favorably amended restriction that no one under 18 years old could participate in charitable lotteries without a parent or guardian present, which would have been detrimental to our partner organization’s ability to engage youth and influence recruitment, retention, and reactivation efforts. The parent or guardian language was removed and under the new regulation, youth under 18 years old are only prohibited from participating in cash-prize lotteries, which is not a typical activity for our partner organizations.

The Commission also clarified that qualified organizations may submit documentation for items donated over $1,000 in value up to seven days following the event, demonstrating its understanding that items are often donated up to the day of.

CSF stands with Nevada’s more than 163,000 hunters and anglers that spend $409 million annually. In 2018, they supported 5,326 jobs and generated $28.16 million for the Nevada Department of Wildlife through the American System of Conservation Funding.

CSF appreciates the NV Gaming Board and Commission’s dedication and responsiveness throughout this regulatory process as well as their acknowledgement of the importance of wildlife and wildlife conservation in Nevada at the October 24 Commission meeting.

Studies conducted at both the state and federal level have found that the number of hunters and trappers have been on a generally declining trend over the past several decades. To increase recruitment, retention, and reactivation (R3) of hunters and trappers, which initiative do you think would have the greatest impact?

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