Allied Charities of Minnesota


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  • 01 Mar 2021 07:33 | Allen Lund (Administrator)

    Testimony to the Senate State Government Finance and Policy and Elections Committee on Wednesday, March 3.

    Madam Chair, committee members, thank you for your time today.

    My name is Allen Lund. I am the executive director of Allied Charities of Minnesota (ACM). We are a 501c6 that represents licensed gambling organizations in Minnesota.

    ACM opposes SF746, a bill being sponsored by the Gambling Control Board that would change the current star rating system for charities. If enacted SF746 would no longer take into account our largest single expense, the taxes and fees that we are required to pay, when computing our rating. The current system takes all Lawful Purpose Expenditures (donations, taxes and fees) as a percentage of Net Receipts (sales minus prizes) to determine your rating. The proposed system takes donations only as a percentage of Allowable Expenses to determine your rating. The GCB has stated that this bill is tied to tax relief, but tax relief is nowhere to be found in the bill.

    ACM understands those that think that licensed charitable gambling organizations need to get more dollars to the bottom line for mission and community. Charities want that too. We welcome charities being evaluated, but we believe that the entire expense structure needs to be considered when looking at the ability of a charity to serve.

    ACM has offered alternatives that prior to organizations being rated would remove mandates that charities must pay in order to conduct charitable gambling in Minnesota. We must pay our taxes and fees. We must store our played games for a minimum of 3 ½ years. We must pay for our games, rent, bar ops and electronic revenue share. If a charity has sales of more than $750,000 in a fiscal year they must have an annual outside audit conducted by a CPA and the audit must be paid for. All of these things lessen our ability to get money to our bottom line for mission and community.

    The Osseo Lions (of which I am a member) does not own a building and has one site, a local bar. Monthly the Osseo Lions must pay rent to the bar, a bar electronics operation fee and an electronics revenue share fee that totals $10,000. That’s $120,000 annually that the Osseo Lions do not have available for donations, through no fault of their own. The Osseo/Maple Grove American Legion (of which I am also a member) has one site and pays none of those costs. Using the proposed rating system a person not familiar with either organization could come to a conclusion that the Legion (5 stars under the current system and 5 stars under the proposed system) is a better steward of funds than the Lions (4 stars under the current rating system and 1 star under the proposed rating system) when in reality both are well run organizations dealing with very different circumstances. That is not a fair and equitable comparison.   

    If enacted the average organization would go from 4 stars under the current system (1 to 5 possible stars) to 1 star under the proposed system (0 to 5 possible stars).   

    We also question the timing of this bill. These are unsettling times for all of us. Charities do not know what the future holds and many have been holding additional funds in reserve in order to survive the pandemic with the goal of serving far into the future. We all hope that a rating system that is fair and equitable to all charities can be developed and ACM stands ready to help with that. If the bill is to be progressed, we would ask that an effective date no earlier than July 1, 2023 be given in order for charities to have the time to react and attempt to comply with the change.

    There is currently a charitable gambling tax relief bill being offered in the Senate (SF1322) that reduces taxes on charities and also changes the star rating system to help ensure that relief goes where we all want it to go, into mission and community. SF746 does not do that.

    Thank you for your time today.

  • 12 Feb 2021 12:10 | Allen Lund (Administrator)
    DIALS: Via Office of Governor Tim Walz & Lt. Governor Peggy Flanagan, VERBATIM: “As hospitalizations and the COVID-19 positivity rate continue to decline and the state makes progress in vaccinating those most vulnerable, Governor Tim Walz today signed Executive Order 21-07 to continue supporting Minnesota’s economic recovery and make adjustments to COVID-19 mitigation measures . . . Executive Order 21-07, effective Saturday, February 13 at noon, takes steps to further reopen Minnesota’s economy safely, including:
    • Increasing the ‘not to exceed’ capacity in restaurants to 250, while leaving the maximum capacity at 50 percent
    • Increasing indoor entertainment ‘not to exceed’ capacity to 250, while leaving the maximum capacity at 25 percent
    • Increasing private events and celebrations ‘not to exceed’ capacity to 50, while leaving the maximum capacity at 25
    • Increasing gym and pool ‘not to exceed’ capacity to 250, while leaving maximum capacity at 25 percent, and reducing distancing requirement to 6 feet.
    • Allowing restaurants to stay open until 11 p.m.”
    WALZ: “Our small businesses have made enormous sacrifices for the health of their employees and communities,” said Governor Walz. “Today, we can make these cautious, common sense adjustments to support them because of the progress we have made controlling the spread of COVID-19 and getting the most at-risk Minnesotans vaccinated.” ORDER:

    EO 21-07 Final_tcm1055-468258.pdf

  • 04 Feb 2021 13:42 | Allen Lund (Administrator)


    Below are the 2021 Legislative session charitable gambling bills to date. You can find a copy of all bills at the ACM website under the NEWS tab at If you wish to bring any of the bills to the attention of your state legislators, and you do not know who represents you, you can find out who represents you at

    SF63/HF184 Authors (Senator Housley, Representatives Dettmer, Gruenhagen, Hamilton, Erickson, Theis). This bill would exempt sales tax on the lease or purchase of gambling equipment.

    SF0063-0.pdf HF0184.0.pdf

    SF195/HF142 Authors (Senators Anderson, Kiffmeyer, Representatives Dettmer , Gruenhagen, Hamilton, Erickson, Theis, Boe, Lueck). This bill would lower the combined receipt tax to 6/12/18/24% from the current 9/18/27/36%. The dollar triggers would remain the same ($0-$87,500/$87,500-$122,500/$122,500-$157,500/$157,500+).

    SF0195-0.pdf HF0142.0.pdf

    SF196/HF140 Authors (Senators Anderson, Kiffmeyer, Representatives Dettmer, Gruenhagen, Hamilton, Erickson, Theis, Boe, Koznick, Lueck). This bill would exempt lawful purpose donations (A codes 1-7, 9-26) from the gambling tax.

    SF0196-0.pdf HF0140.0.pdf

    SF197/HF143 Authors (Senators Anderson, Kiffmeyer, Representatives Dettmer, Gruenhagen, Hamilton, Erickson, Theis). This bill would remove the requirement of the outside annual audit ($750,000 in sales or greater). CPA audits of any licensed organization can be required by MNDOR when red flags are raised (late filing, late payments, fraudulent returns, failed to take corrective action, failure to comply).

    SF0197-0.pdf HF0143.0.pdf

    SF267/HF811 Authors (Senators Koran, Hoffman, Representative Dettmer). This bill would require an electronic manufacturer to sell to all who want to carry their product.

    SF0267-0.pdf HF0811-0.pdf

    SF368/HF96 Authors (Senators Ruud, Chamberlain, Koran, Dornink, Draheim, Representative Lueck). This bill would reduce the net receipt tax from 8.5% to 4.25% and reduce the combined receipts tax to 4.5% on the first $200,000 combined net receipts, 9% on $200,000 to $500,000 combined net receipts and 13.5% over $500,000 net receipts.

    SF0368-0.pdf HF0096-0.pdf

    SF391/HF531 Authors (Senator Housley, Representative Nash). This bill would allow a check or debit card for be used for the purchasing of raffle tickets over the phone.

    SF0391-0.pdf HF0531.0.pdf

    SF458/HF564 Authors (Senators Lang, Duckworth, Housley, Anderson, Kiffmeyer, Representatives Dettmer, Urdahl, Erickson). This bill would allow licensed veteran post to spend up to 50% of their annual gross profits on the repair, maintenance or improvement of real property and capital assets each year through July 1, 2031. The current limit is 5%.

    SF0458-0.pdf HF0564.0.pdf

    SF746/HF898 Authors (Senator Koran, Representative Huot). This bill would change the star rating system. Taxes and fees would no longer be factored into the ranking. Donations (A1-A7, A9-A17, and A19-A26) would be divided into expenses. Any organization who has more than $750,000 in annual sales and has less than 20% of donations divided by expenses will be placed on probation for one year. If still on probation at the end of one year the organization may face a license suspension or fine. ACM is opposed to this bill if not tied to tax relief. Our projection is that it will at least double the organizations being placed on probation.

    SF0746-0.pdf HF0898.0.pdf

    SF756/HF897 Authors (Senator Koran, Representative Huot). This bill allows a GCB board member to continue holding office on the GCB board until a successor is appointed.

    SF0756-0.pdf HF0897.0.pdf

    SF1322 Author (Senator Nelson). This bill would cut the combined receipt rates to 8/16/24/32%. It would change the star rating system to require an organization expend a minimum of 40% on LPE (All A Codes) to not be considered for probation.


    SF1637 (Senator Howe). This bill would consider emergency loans from lawful gambling funds for emergency expenditures made by congressionally charterd veteran's organizations to be repaid.


  • 01 Feb 2021 12:46 | Allen Lund (Administrator)


    I was asked by a legislator to comment on a change to the star rating system being proposed by the GCB (see attached). Below is what I sent back to the legislator.

    Thank you for the opportunity to review this. It took me some time to understand what the changes would mean and how they were getting at it.

    Here is some background on the GCB proposal. This proposal from the GCB changing the current star rating system is similar in design to what was in the tax bill last year along with our tax reduction. The message from the legislature then was that the state would give us tax relief (a 10% reduction) along with the tightening up of the star rating system (with GCB input) in return. The concern of some was that we would take that relief and put it into expenses, not donations. After voicing our concerns about what we viewed as an unwarranted increase we decided that we would not let our objections get in the way of tax relief. Our belief was that if there was a marked increase in the number of charities going on probation that there might be a change to the formula down the road.

    It now appears that the goal of the GCB is to tighten up the star rating system without tax relief being tied to it.

    I compared the current star system to the proposed star system using the GCB FY2020 figures. The current star system was suspended for FY2020 due to COVID (at ACM’s urging and ultimate support of the GCB and Governor). Normally there are roughly 40 to 50 organizations on probation in any given year. FY2020 had 85 organizations that would have been on probation using the current star rating system. The increase would have been due to COVID and the shutdown. Charities do not know when they might be shut down again and are reluctant to spend down their accounts worried that they will not have the money to restart or get through another shutdown. Many will be paying a UBIT penalty to both the federal and state this year because of that.

    The proposed star system changes things. Again using the FY2020 numbers, 98 organizations would have been put on probation, which is double from the previous average of 40 to 50. Normally there are roughly 13 VFW/Legion Posts that would be on probation and that number does not appear to change with the proposed system.

    The proposed star rating system has at its core the belief that charities are expense heavy. I do not believe that to be true. Almost all of our expenses are fixed. Cost of games, rent and wages are all set by market forces or state/federal statute. The one area that there is flexibility is gambling manager pay. Our detractors will tell you that we need to do our work on a volunteer basis. In a perfect world I may not disagree with them. But the reality is that getting people to work twenty to forty hours per week at no pay is no longer feasible.

    I also question whether the state has thought about putting more organizations on probation. I added up what that group of 98 paid in taxes/fees in FY2020 and (if my math is correct) it comes to over $18 million.

    We understand the desire to have more money go into donations, we want that too. We are just not sure that the proposed rating change does that. Without any accompanying tax relief the change would be additional pressure on charities to cut expenses where there is really very little to cut.

    We would also request that the star rating system be suspended for FY2021 that is now more than half over and has had us go through another shutdown. Now is not the time to have our operations judged when there is nothing that even resembles normalcy. Even under the current system the number of organizations that would end up on probation will grow much higher than 85.

    You might ask the GCB what their predictions are for the number of charities that would be on probation under the proposed changes to see if it differs much from what I see.

    In closing, if the proposal becomes statute we would be judged solely on our donations against our expenses. Taxes, which are our largest outlay, would no longer be counted. In my opinion taxes are our biggest issue, not our expenses. We are not going to get people to work for free and the vast majority of our gambling managers are not getting rich doing that job. After paying our expenses (53% of what we get to the bank) and taxes (27% of what we get to the bank) we have 20% left for donations. Our costs and taxes go up every year. We currently net 3 cents on every dollar wagered, that number has gone down every year for the past eight years. This proposed change will not stop that slide.

    Again, thank you for the opportunity. Any questions, please advise.



    GCB recommended updates to 349.15 star rating system under 21-01933 as of 25 January 2021 (1).pdf

  • 10 Jan 2021 14:20 | Allen Lund (Administrator)

    January 8, 2021

    Questions and Answers Regarding Resumption of Lawful Gambling Indoors

    Bingo Halls

    Question:  If bingo is conducted at a location where the primary business is the conduct of bingo (“bingo hall”), what is the site’s capacity limit under Executive Order 21-01?

    Answer:  Under the executive order, a bingo hall is considered to be a “venue providing indoor events and entertainment”.  Capacity is limited to 25% of the normal occupant capacity, not to exceed 150 people in the entire facility.  “Normal occupant capacity” means the applicable lawful capacity as established by state or local authorities in accordance with established codes and requirements.  This number may be higher than what your organization normally considers to be a “full” when the site is set up for the conduct of bingo.

    Keep in mind that on-site food and beverage consumption is prohibited after 10:00 pm and all social distancing requirements must be enforced.

    Meat Raffles

    Question:  When bars reopen for indoor drinking and dining on January 11, may meat raffles be conducted?

    Answer:  Yes. Meat raffles (awarding packages of meat as a paddlewheel, raffle, or tipboard prize) are allowed provided that they’re conducted in compliance with all social distancing and executive order requirements.

    Paddlewheel with a Table (“Tri-wheel”)

    Question:  When bars reopen for indoor drinking and dining on January 11, may paddlewheel with a table be conducted?

    Answer:  Yes.  Paddlewheel with a table is allowed provided that it’s conducted in compliance with all social distancing and executive order requirements.

  • 07 Jan 2021 11:33 | Allen Lund (Administrator)


    CLEVELAND (January 7, 2021) – Arrow International, Inc., the world’s largest manufacturer and distributor of charitable gaming products, has announced today that is has partnered with Platinum Equity to ensure its continued and expanded industry leadership.

    Founded in 1967, Arrow is the leading supplier of pull tabs, electronic pull tabs, bingo products and electronic bingo devices for charity. Headquartered in Cleveland, Ohio, Arrow has approximately 1,000 employees across four manufacturing facilities and a network of 40+ distribution facilities.

    The Gallagher family has retained a meaningful equity interest in the business and will continue to serve in leadership roles as part of the company’s management team.

    “Arrow has built a successful business through a combination of product innovation, customer service and entrepreneurial drive,” said Platinum Equity Managing Director Dan Krasner. “We look forward to joining forces with the Gallagher family, investing in growth and providing the operational tools the company needs to maximize its potential.”

    Arrow’s products help generate billions of revenue for charities, lotteries, tribes and non-profits, raising funds for a broad range of causes, including veterans clubs, fraternal organizations, local fire departments and first responders, children’s sports, religious organizations, healthcare causes, booster clubs and other community groups.

    “This is great news for our company, our customers and the future of our business,” said John Gallagher, Jr. “We sought a partner with the financial resources and operational know-how to help accelerate our growth, and a proven track record working with founders to take family-owned businesses to the next level. With Platinum’s partnership and support, we can accelerate our acquisition strategy, expand our product offerings and continue investing in technology and people, while maintaining the entrepreneurial spirit that has defined our culture for over 50 years. We are very excited about the opportunities that await us over our next 50 years.”

    The Arrow / Platinum combination has commenced and is in the process of obtaining final regulatory approvals.

    About Platinum Equity

    Platinum Equity is a global investment firm with approximately $23 billion of assets under management and a portfolio of approximately 40 operating companies that serve customers around the world. The firm is currently investing from Platinum Equity Capital Partners V, a $10 billion global buyout fund, and Platinum Equity Small Cap Fund, a $1.5 billion buyout fund focused on investment opportunities in the lower middle market. Platinum Equity specializes in mergers, acquisitions and operations – a trademarked strategy it calls M&A&O® – acquiring and operating companies in a broad range of business markets, including manufacturing, distribution, transportation and logistics, equipment rental, metals services, media and entertainment, technology, telecommunications and other industries. Over the past 25 years, Platinum Equity has completed more than 300 acquisitions.

  • 07 Jan 2021 09:09 | Allen Lund (Administrator)

    January 6, 2021

    Resuming the Conduct of Lawful Gambling at Sites Now Open for Indoor On-site Eating and Drinking


    In accordance with Executive Order 21-01, effective Monday, January 11 at 12:00 AM, the following restrictions affect lawful gambling above and beyond those restrictions in existing statute, executive order, and rule:


    1. Business Hours – Lawful gambling may be conducted until 10:00 p.m. each day;
    2. Capacity – In places of public accommodation (including bars, restaurants, and bingo halls), capacity is limited to 50% of the location’s normal capacity limits;
    3. These lawful gambling activities must be conducted in compliance with all applicable statutes, executive orders and rules, as well as Minnesota Department of Health and Centers for Disease Control and Prevention guidance.


    Restart Checklist

    Gambling managers are encouraged to use the Gambling Control Board’s “Checklist for Lawful Gambling Restart” as a to-do list for restarting lawful gambling activity at their sites.


    Paused Games

    In conformance with Executive Order 21-01 organizations, on January 11, 2021 organizations may resume play of games that were “paused” when Executive Order 20-99 went into effect on November 20, 2020.


    Restarting Paused Paper Pull-tab Games

    To resume play of a paused paper pull-tab game:

    1. Paused games may only be placed back into play at the site where they were originally in play.
    2. Audit the game (count the unsold and winning tickets).  The results of your audit should be identical to the game audit that was conducted when the game was paused.  If the amounts of your current game audit vary from the amounts of the November audit, close the game and report the results on your January monthly reports.
    3. Withdraw the game’s starting cash bank amount from your gambling bank account and place it in the game’s cash drawer at your site.
    4. When the game’s cash proceeds and starting cash bank were deposited into the gambling account in November, the amount taken for deposit should have been recorded in the “Funds added/removed” column of the game’s LG861 tracking form.  The “$ Cash out” column should then have been recorded as “$0”.  When placing money back into the game’s cash drawer, enter the amount added in the “Funds added/removed” and the “$ Cash out” columns.


    Restarting Paused Electronic Pull-tab Games

    1. Coordinate with the electronic-game distributor to resume play of paused electronic pull-tab games.
    2. In November, the amount taken for deposit should have been recorded on the LG861e in Column G (“Amount removed from cash drawer for deposit”). Double-check the LG861e form for November 2020 to ensure that it was completed correctly.
    3. Start a new LG861e form for January 2021.  Once the electronic game starting cash back has been placed into the cash drawer, enter that amount in Column B (“Amount in cash drawer at start of business day”).

  • 06 Jan 2021 14:53 | Allen Lund (Administrator)

    Today Governor Walz announced a loosening of restrictions. Bars and restaurants will be able to open for indoor dining on 01/11/2021 at 50% capacity. Dine-in service must end by 10 pm (10 pm curfew). 150 persons maximum. Maximum of six people per table, six feet apart. Bar seating will be allowed for two people, with six feet spacing between groups. Masked required to be in use when not eating or drinking. Reservations are required. 

  • 06 Jan 2021 10:38 | Allen Lund (Administrator)

    Press Release

    Pollard Banknote Announces The Acquisition Of Compliant Gaming

    WINNIPEG, Manitoba, December 30, 2020 /CNW/ – Pollard Banknote Limited (TSX: PBL) (“Pollard Banknote” or the “Company”) announced today that it has signed a definitive agreement, and closed the transaction, to purchase (“Acquisition”) 100% of the equity of Compliant Gaming LLC (“Compliant”), a leading provider of electronic pull‐tab gaming systems and products to the charitable gaming market.

    Compliant was founded in 2014 and offers a broad range of game content and system support in the growing area of electronic gaming and are currently the second largest supplier in the fast‐growing Minnesota market. Key to their success has been a robust technology platform and engaging game content.

    Electronic pull‐tabs were first introduced in Minnesota in 2012 to assist charitable organizations in fundraising and to help the state in funding the development of the US Bank Stadium in Minneapolis. Experienced in bars and restaurants, electronic pull‐tabs in Minnesota provide a gaming experience played on portable tablets, which are provided by the establishment to its customers. Since its start 8 years ago, this market for electronic pull‐tabs has grown exponentially, starting from zero in 2012 to generating almost $100 million USD in net gaming receipts (revenue less prize payouts) in the fiscal year ended June 30, 2020. It has been the fastest growing segment of the Minnesota charitable gaming market for the past 5 years.

    The acquisition of this technology for the charitable gaming market provides a new solution offering for our portfolio as Compliant’s portable, tablet‐based product is a strong complement to our Diamond Game kiosk‐based technology. Compliant brings a successful operation in the Minnesota market while positioning us strategically for new jurisdictions looking to enter the electronic side of the charitable gaming market, whether it be by tablet or kiosk.

    “We are very excited to be bringing the Compliant technology and market presence into our charitable gaming business and believe this will provide us with a valuable new product to help maintain Pollard’s leading presence in this market,” stated John Pollard, Co‐Chief Executive Officer of Pollard Banknote. “The impressive success the Compliant team has achieved in such a short period of time in Minnesota reflects the customer focus that is consistent with our own strategic approach, and we believe there is considerable opportunity for additional growth in this state. In addition, more and more jurisdictions are looking at alternative products and solutions to provide fundraising opportunities for local charities and we feel Compliant’s solutions provide an attractive alternative for good causes in new markets.”

    Frederick Reis, Founder of Compliant, stated “Compliant’s unique electronic pull‐tab and integrated bingo system is complementary to Pollard’s leadership position in the charitable gaming market, and Compliant’s expertise will enhance Pollard’s broad offering of charitable gaming products to customers throughout North America. We look forward to joining the Pollard team and to continuing to deliver our signature personal commitment to our customers and industry leading solutions for electronic gaming.”

    The total Acquisition purchase price is $19.0 million U.S. dollars (approximately $24.3 million CDN dollars using an exchange rate of $1.28 CDN dollar per U.S. dollar), prior to standard working capital adjustments and potential future earn‐out payments based on certain EBITDA targets. The purchase price was funded from existing Pollard Banknote cash resources and availability under our existing senior credit facilities. The Acquisition is expected to be accretive to Pollard Banknote’s net income prior to amortization of related purchase price accounting adjustments. The acquisition of Compliant has closed and is not contingent on any approvals or financing.

    The Compliant business will join our existing complement of charitable gaming focused businesses, including our Diamond Game eGaming business unit and our combined American Games and International Gamco paper‐based operations, in providing an extensive portfolio of products and solutions to charities across North America.

    John Pollard concludes, “In addition to retail excellence and outstanding games, digital innovation is a cornerstone of Pollard’s strategic objectives and the acquisition of Compliant further expands our digital expertise. Pollard Banknote is committed to expanding our leadership role in the charitable gaming market and focusing on technology‐based solutions that meet our strategic objectives as well as generating a strong financial return. We are honoured the Compliant team has joined us and we look forward to continuing their strong record of growth.”

    About Pollard Banknote

    Pollard Banknote is a leading lottery partner to more than 60 lotteries worldwide, providing high quality instant ticket products, licensed games, Schafer Systems and Fastrak retail merchandising solutions, and a full suite of digital offerings, ranging from world-class mkodo game apps to comprehensive player engagement and iLottery solutions, including strategic marketing and management services. The company is a proven innovator and has decades of experience helping lotteries to maximize player engagement, sales, and proceeds for good causes. Pollard Banknote also provides pull-tab tickets, bingo paper, and its Diamond Game and Oasis-branded electronic ticket machines to charitable and other gaming markets in North America. Established in 1907, Pollard Banknote is owned approximately 67.5% by the Pollard family and 32.5% by public shareholders, and is publicly traded on the TSX (PBL). For more information, please visit our website at

    Forward-looking Statements

    Certain statements in this press release may constitute “forward-looking” statements and information, which involve known and unknown risks, uncertainties, and other factors that may cause actual results, performance, or achievements to be materially different from any future results, performance, or achievements expressed or implied by such forward-looking statements. When used in this document, such statements include such words as “may,” “will,” “expect,” “believe,” “plan,” and other similar terminology. These statements reflect management’s current expectations regarding future events and operating performance and speak only as of the date of this document. There should not be an expectation that such information will in all circumstances be updated, supplemented, or revised whether as a result of new information, changing circumstances, future events, or otherwise. -30-

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