11  VAC 5-80-20 Sports bettors’ bill of rights

theScore Bet respectfully suggests the following modifications to provide bettors with information relevant to their bet-making decisions.  The following modifications are in line with the type of information that will allow bettors to make informed decisions and which sports betting operators can reasonably provide to patrons.

C. A permit holder’s platform site must provide substantial and readily available information to enable players to make informed decisions about their gambling, including:

1. [With regard to any sports bet, prominent publication of] Readily available information related to, at a minimum:

a. [The handle of the bet] The potential payout for wagers based on the amount of money being risked;

b. [The odds of winning the bet and the information used to calculate those odds] The posted odds; and

c. [3.] The payout [amounts and a schedule of payouts] procedures.

11 VAC 5-80-50 Underage betting

theScore Bet respectfully suggests that the below procedure should be added in order to allow permit holders to implement an additional age-verification procedure to verify that no sports bet is placed by or on behalf of an individual under the age of 21, which follows registration and identity verification procedures for mobile sports book operators in other jurisdictions including NJ, IN, CO, NV, PA etc.

6.  Verifying the individual’s identity via an online “Know Your Customer” (KYC) process using third-party KYC and age-verification solutions of a licensed sports betting vendor.

11 VAC 5-80-80 Corporate responsible gambling policies

theScore Bet respectfully suggests that identifying the accountable staff members for a permit holder should be addressed in the Internal Controls and therefore recommends that B.3 be deleted.  theScore Bet recognizes the importance of responsible gaming and as an organization takes responsible gaming matters very seriously but does not feel that identifying particular individual(s) on a public facing webpage, whether by title and/or name, is appropriate or furthers a permit holder’s commitment to our enforcement of responsible gaming matters.  Further, theScore Bet believes that B.1 sufficiently addresses the permit holder’s commitment to responsible gambling and problem gambling prevention.

B. Each permit holder’s corporate policy should address the following:

[3.  Senior executive staff members are accountable for responsible gambling policies and programs;]

11 VAC 5-80-90 Sports betting platform features

theScore Bet respectfully suggests the following modifications to Section 2. 

2. Features [Ample opportunities for]that allow a player to take note of the passage of time

theScore Bet respectfully suggests the following modifications to Section 3.

3. Features [Game designs] that allow for [promote] breaks in play and avoidance of excessive play

theScore Bet respectfully suggests deleting Section 4 as it does not apply to sports betting.

[4. All new games and technology are screened for adherence to responsible gaming standards]