On behalf of IGT, I would like to thank the Virginia Lottery Board for the opportunity to submit the following suggestions for consideration regarding the Virginia Sports Betting Regulations. 

Comments on Regulations 11VAC5-70-10 – 11VAC5-70-80

IGT suggests that more detail is included when defining the different levels for licensing and permitting to clarify which license is required for an applicant.  It will be helpful if the regulations outline the specific roles and functions of the various levels that ensure that the licensing level is appropriate for the functions performed.   IGT would suggest a framework defined in a manner more consistent with other jurisdictions such as:

1.  Permit holder at the top (i.e. casino or other entity authorized to offer sports wagers)

2.  Sports wagering operator – a party that contracts with the permit holder to operate the sports book

3.   Sports wagering manufacturer – a party that manufactures or otherwise provides sports wagering or other gaming (i.e. PAM) technology

4.   Sports wagering service provider – a party that provides goods or services in support of sports wagering (geolocation, ID verification, data feeds, trading services, etc.)

IGT further suggests that the licensing framework is explicitly hierarchical, i.e. if you are an operator you do not also have to hold a manufacturer license and if you are a manufacturer, you don’t have to hold a service provider license.

Best Regards,

Sue Skrove

Regulatory Development

IGT