General Comment – It would be helpful for the regulations to contain a section providing a description of which types of sports events are permitted.  The statute and the draft regulations contain authorizations and resections in multiple sections.

11VAC5-70-10 – Definition of “Cheating” – In second to last line, “agers” should be “wagers.”

11VAC5-70-10 – Definition of “Principal” – Clause (ii) should include “or other ownership interest” as is included in the statutory definition.

11VAC5-70-20 – This section should include a statement about the confidentiality protections applicable to information submitted by applicants.

11VAC5-70-30 – This section should include a statement about the confidentiality protections applicable to investigations.

11VAC5-70-130(C)(1) – Should the requirement for a licensee to at all times “wear or otherwise prominently display” an identification card be applicable in non-public areas of a facility engaged in online or mobile sports betting? Perhaps identification cards should be readily presentable upon request of an authorized officer in such areas?

11VAC5-70-250(B)(1) – Personal information should be subject to confidentiality.

11VAC5-80-100(E)(5) –  This section is missing the applicable number of days in the following phrase:

The permit holder shall honor any sports bettor's request to withdraw funds by the later of [____] days after receipt of the request or 10 days after submission of any tax reporting paperwork…

11VAC5-80-110 – May a player have a separate account with each licensee?