A sports betting platform must possess the following features:
Cash transfers and automatic deposits are prohibited or restricted
Games display credits/spending as cash[2]
[1] We respectfully recommend removing this section as it may be a carryover from Lottery Rules. Further we recommend clarifying that promoting breaks in play can be solved with responsible gaming “reality checks” that promote breaks in wagering/play.
[2] We respectfully recommend removing subsections 10 & 11. Subsection 10 disallows the use of PayNearMe, which is a commonly utilized vendor in the online sports wagering space accounting for approximately 5% of deposits via cash deposits at CVS, 7-11, and Family Dollar stores. Allowing this service encourages patronization of these aforementioned stores inside the Commonwealth to utilize this service, and increase chances of them spending money in the store, thus an increase in sales tax. Subsection 11 is not applicable to sports wagering.
[3] Sports Wagering Permit Holders utilize many marketing-technology vendors in their platform to ensure a seamless, secure, and innovative consumer experience. We want to ensure this provision does not restrict our use of engineering and marketing-technology vendors.
D. A permit holder shall maintain a reserve in the form of cash, cash equivalents, an irrevocable letter of credit, a bond, or a combination thereof in an amount approved by the Department and sufficient to pay all prizes and awards offered to a winning sports bettor.[1]
E. A permit holder shall implement and prominently publish the following on its platform, or within the Terms and Conditions inside of the platform:[2]
The permit holder shall honor any sports bettor's request to withdraw funds by the later of days[3] after receipt of the request or 10 days after submission of any tax reporting paperwork required by law, unless the permit holder believes in good faith that the sports bettor has engaged in either fraudulent conduct or other conduct that would put the permit holder in violation of this chapter, in which case the permit holder may decline to honor the request for withdrawal for a reasonable investigatory period until its investigation is resolved if it provides notice of the nature of the investigation to the sports bettor. For the purposes of this subdivision, a request for withdrawal shall be considered honored if it is processed by the permit holder but delayed by a payment processor, a credit card issuer, or the custodian of a segregated account; and
[1] We respectfully recommend reserve requirement be “only tickets or bets that are settled, plus the amount of outstanding and unsettled bets”. Prizes and awards are specific to lottery, not sports wagering.
[2] We respectfully recommend covering these items in Terms and Conditions.
[3] It appears the number of days was omitted from drafting of rules.