[18] As noted in an earlier section, we respectfully recommend defining “Managerial Capacity” to ensure that middle level management employees with a title of “manager” are not subject to principal level application licensing and fees.

11VAC5-70-70. Sports Betting Supplier Applications.

2. A principal who will be employed in a managerial capacity for a sports betting platform may submit the principal application together with a supplier license application.[19]

11VAC5-70-80. Sports Betting Vendor Registrations.[20]

[20] We would respectfully recommend clarifying which entities and providers fall under vendor registrations versus Supplier Licensing consistent with other major jurisdictions: (1) Vendors should be limited to ancillary services such as payment service providers and affiliate marketers; (2) Suppliers limited to those entities providing services to register players, and those specific to the data and risk management components of sports wagering.

B. The Director may issue a sports betting employee license to an individual upon:

7. Provided confirmation via written letter or email that within the 365 days before the application is submitted, the applicant has not served as a Board member or been employed by the Department; and[21]