“Managerial Capacity” means an employee performing the function of an officer or director of the company.[1]
[1] We respectfully recommend defining “Managerial Capacity” as set forth to ensure that the licensing of Principal Employees does not include employees in middle-level management positions of permit holders.
“Sports betting” means placing wagers on professional sports, college sports, sporting events, and any portion thereof, and includes placing wagers related to the individual performance statistics of athletes in such sports and events. “Sports betting” includes any system or method of wagering approved by the Director. “Sports betting” does not include placing a wager on a college sports event in which a Virginia public or private institution of higher education is a participant nor does “sports betting” include placing a wager on sports events organized by the International Olympic Committee.[1], [2]
[1] We respectfully recommend incorporating what is in legislation, to ensure the language of the rule is not misconstrued to mean that a NCAA Basketball Tournament cannot be wagered on, if the University of Virginia makes it to the tournament.
§ 58.1-4039. Events on which betting is prohibited; penalty.
1. No person shall place or accept a bet on youth sports.
2. No person shall place or accept a proposition bet on college sports.
3. No person shall place or accept a bet on Virginia college sports
C. The prohibitions in subdivisions A 1 and A 3 shall be limited to the single game or match in
which a youth sports or Virginia college sports team is a participant. The prohibitions shall not be
construed to prohibit betting on other games in a tournament or multigame event in which a youth
sports or Virginia college sports team participates, so long as such other games do not have a
participant that is a youth sports or Virginia college sports team.
[2] The Olympics were not specifically prohibited in Legislation, we would respectfully request the opportunity to allow wagering on such events overseen by the IOC. Wagering on the Olympics is allowed in several major jurisdictions and can be offered with no threat to the general public and an opportunity for revenue for the State of Virginia.
“Sports betting supplier” or “Supplier” means a person who: (a) manages, administers, or controls wagers initiated, received or made on a sports betting platform; (b) manages, administers, or controls the games on which wagers are initiated, received, or made on a sports betting platform; or (c) maintains or operates the software or hardware of a sports betting platform, including data providers, geolocation services, customer registration and/or verification integration, and customer account management.[1]
[1] As written, it is unclear whether the intent is for subsection C to include data providers. The language we recommend removing from subsection c) is a duplication of what is covered under supplier in subsection a) and subsection b). Additionally, we recommend using the language customer registration and verification for clarity.