IDEA Growth would like to submit the following comment regarding the proposed “Sports bettors’ bill of rights.” 

11VAC5-80-20 Sports bettors' bill of rights

IDEA Growth’s members are concerned about Section C of the sports bettors’ bill of rights.  This provision would require the permit holder to display the handle for each particular bet; the odds of winning; how those odds are calculated; the payout amounts and the schedule of payouts. These provisions seem a bit out of place in the context of sports betting; rather they seem better suited to house-banked games of chance, pari-mutuel horse racing, or else a lottery.  Handle is relevant to pari-mutuel wagering pools where the handle wagered on each outcome directly affects the payout odds, whereas that is not the case in sports betting. Lotteries can publish the payout on any particular drawing and the odds of winning because there are only so many possible combinations of outcomes, and a casino can do the same for a slot machine, however that is again not the case in sports betting.  Requiring operators to disclose handle for a particular football game would disclose commercially sensitive and potentially proprietary information without actually giving the customer any information that would help inform their decision to place a wager or not.

Providing this information is problematic in the context of sports betting.  With respect to wagers that have odds, the odds are generally set to try to balance the amount of money bet on each side of any particular event, such that the players are betting against each other rather than “the house.”  Operators’ methods of accomplishing this are proprietary and they provide no useful information to the players.

If the player is to be provided the amount of the handle at the time he or she places the bet, this would have to be accomplished through a continuously updated meter that would display in the betting app.  This would require operators to be continuously updating those totals in real time on hundreds or thousands of events (particularly with respect to in-game bets and proposition bets).  This would be enormously difficult information for operators to provide; it would significantly clutter and confuse the user interface, and it would be of little or no use to the overwhelming majority of players.   No other state has adopted these sorts of requirements, and we are aware of no foreign regulatory regime that includes such provisions. 

IDEA Growth’s members support transparency with respect to players with respect to non-proprietary information that players can use, but they do not believe the disclosures required in Section C meet that standard and we respectfully request that they be modified or removed. 

Furthermore, iDEA Growth’s members are concerned with Section B’s restriction on the use of alternative dispute resolution measures. Provisions mandating the use of measures short of litigation as an initial step to resolving disputes are commonly employed by businesses in a wide variety of industries including gaming and sports betting.  To deny permit holders the use of these tools will lead to additional expense that ultimately gets passed on to consumers.  Virginia law provides for the use of arbitration and other alternative dispute resolution procedures and the General Assembly did not choose to limit their use in the sports betting law.  For that reason, iDEA supports the restrictions on alternative dispute resolution being struck from the regulations.