PIV Comments/Suggested Edits - 11 VAC 5-70-20 - Application Process
A. General Provisions
3. Applications and required fees for permits will be accepted by the Director only during the initial permit application period, and thereafter, during an annual renewal permit application period, as defined in these regulations.
 As the intent is for permits to have a three (3) year renewal period, we respectfully recommend using “renewal” rather than “annual” for clarity.
2. Information and documents submitted to the Director in a permit, license, or registration application shall be sworn under the penalties of perjury as to their truth and validity by the applicant or, if the applicant is not an individual, by an the chief executive officer or director of the applicant.
 We respectfully recommend allowing any officer or director of the applicant to provide such attestation, which is industry standard.
F. Effect of Permit, License, or Registration
2. Consistent with the policy described in subdivision 1 of this subsection, it is the intent of this chapter to:
(1) The creation of any property right in any permit, license, or registration required under this chapter;
(2) The accrual of any monetary value to the privilege of participation in sports betting operations; and
(3) The transfer of any permit, license, or registration issued under this chapter; and
 As Legislation specifically contemplates transfers, we want to ensure this Rule as written, does not circumvent that.