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North Suburban Youth Association LITTLE CANADA GAMBLING ORDINANCE - N.S.Y.A. AREAS OF CONCERN 815. Lawful Gambling 2. N.S.Y.A. does not maintain a legal address in Little Canada other than receiving mail at the Little Canada Bingo Hall, where we hold a lease. It concerns us that we could be denied renewal as a result of this language. If that were to happen, N.S.Y.A. would probably cease to exist as a contributor to youth activities in the North Suburban area. We would prefer language that would grandfather us in immediately as long as legal and operational requirements are being met. 815.015 Number of Licenses b. We have no concern currently regarding this issue,however, we would suggest the maximum number to be seven. It could be possible in the future to have more than five organizations at the bingo hall if an existing organization which operates two days per week decided to drop one of their days. 815.020 Approval of bingo hall licenses and premise permits 7. Two annual audits are currently required by Minnesota Statute. One is required by the Attorney General's Office for nonprofit organizations that raise in excess of $100,000 annually. The second, by the Minnesota Department of Revenue which requires a gambling audit within 6 months of the end of each fiscal year. Each of the above audits must be prepared by an independent Certified Public Account. The cost of each of these audits is very high, and to provide the city with a third audit would be redundant and cost prohibitive. We would prefer a requirement by the city for the organizations to submit a copy of either of the two audits already required, or both. The dates for submittal could be consistent with state requirements. 815.025 Continuing Regulation of Charitable Gambling Organizations D. The state does not require an organization to use a C.P.A. for daily bookkeeping or monthly tax reporting. C.P.A.'s are required by statute for annual audits only. N.S.Y.A. does its bookkeeping and monthly reporting internally and does not want to be required to hire an expensive C.P.A. for this function. The State statutes requires that we maintain expenses at less that 50% of our net profit. In order to maintain this expense level we strive to keep our costs down in every aspect of our gambling activity. In addition this allows more funds for distribution for lawful purpose contributions to the community. Aside from the restrictive ordinance in Roseville, we can think of no other cities with this requirement including the tightly regulated cities of St. Paul and Minneapolis. We would respectfully ask that the first sentence in (D) be eliminated. E. This is the same requirement we previously addressed in 815.020, 7. We would recommend using the state mandated audits and their time schedules. Page 17