11VAC5-70-50. Sports Betting Permit Applications.

P. The application shall disclose all principal entities of the applicant.

V. Prior to issuance of a permit, an applicant awarded a permit shall pay to the Lottery a nonrefundable permit issuance fee of $250,000.

Comment: It is common that a principal entity has one or more wholly owned subsidiaries, of which, one may be a Sports Betting Permit Applicant. We ask that only the entity applying for the permit be required to pay the permit issuance fee and that fee is not required of parent companies or subsidiaries of any other principal entity than the applicant. Reading 11 VAC 5-70-60, it is unclear as to whether a “principal application” is reserved for individuals or if it also applies to “persons” as defined in 11VAC5-70-10.