PIV Comments/Suggested Edits - 11 VAC 5-70-50 - Sports Betting Permit Applications
B. The narrative component of the application shall include information describing:
5. If applicable:
b. The identity of any partner, subcontractor, or other affiliate through which the applicant wishes to demonstrate compliance with the requirements of this chapter; and
 We respectfully recommend defining affiliate in the definition section as follows to ensure there is clarity about which entities or persons fall under this definition. “Affiliate” means a person that, directly or indirectly, through one or more intermediaries, controls or is controlled by an internet gaming operator.
T. The Director may award a sports betting permit after consideration of the application and based on:
9. Whether the applicant has the financial ability to purchase and maintain adequate liability and casualty insurance and to provide an adequate surety bond.
 We respectfully recommend setting forth a maximum-security bond.
15. Whether at the time of application the applicant is a defendant in litigation involving the integrity of its business practices; and
 We respectfully recommend more specific language rather than “integrity of business practices” for litigation. It is unclear which litigation this would include.
U. If during the initial application period, the Director receives more applications for permits than are authorized under the Sports Betting Law, the Director shall:
2.Qualitatively compare the remaining applications and award permits only to the top two-thirds of the remaining applicants who meet all the qualifications of a permit holder and are not otherwise disqualified from holding a permit; and
 We respectfully recommend clarification of rule, as in its current interpretation, this could increase number of possible permits if Lottery received large enough number of applicants.