[1] We recommend providing the Sports Bettors Bill of Rights via a link on the platform accessible to patrons linking them to the VA Lottery website.
C. A permit holder’s platform site must provide substantial and readily available information to enable players to make informed decisions about their gambling, including:
3. The payout amounts and a schedule of payouts.
[1] We respectfully recommend removing this Section. While the odds will be displayed for sports wagering, the remaining information is outside of industry standard and it is unclear if it is above what’s included in the player’s transactional history, inclusive of previous wagers and amount of those wagers.
[1] Each patron is required to agree to Terms and Conditions prior to registering for the application. Would suggest this be sufficient for purposes of meeting the intent of this rule as “published”.
[2] Most Customer Service Teams for online sports wagering will communicate with patrons through a software chat platform pursuant to industry standards.
B. A permit holder shall promptly refund any money wagered by or on behalf of a minor. A permit holder may withhold and, if practicable and as approved by the Department, redistribute to other winners any prize won by a minor upon a good faith determination, following reasonable investigation, that the minor misrepresented his age in order to place a sports bet.
C. A permit holder shall make available, prominently publish, and facilitate parental control procedures to allow parents or guardians to exclude minors from access to any sports betting platform.[3]
[1] We recommend more contemporary and up to date age-verification procedures which include use of a licensed third party Know Your Customer (KYC) vendor which using the information provided by the patron, checks public records to ensure the information provided is accurate and the patron is 21+. This is all done online through the sports wagering platform registration process.
[2] We recommend maintaining manual verification documents in a secure manner as prescribed by the VA Lottery as these may be required for Suspicious Activity Reporting or Fraud Reporting, if needed at a later date.
[3] Sign in procedures to the app will include protections that limit the ability for a minor to access the platform. However, in addition we will provide links to parental controls that are accessible on different devices.
[1] We are unaware of any Sports Governing Body providing any such lists to operators in any other state. In order for any operator to have the ability to block these patrons with full confidence, permit holders would need more than a first and last name, as there could be multiple people named “Alex Smith”, for example, who could register. Instead, these lists would need to include PII to identify these persons with the utmost accuracy.