PIV Comments/Suggested Edits - 11 VAC 5-70 - 180 200, 210, 220
11VAC5-70-180. Requests from Sports Governing Bodies. *UPDATED*
- By written request in the form and format required by the Director, a sports governing body may ask the Director to restrict, limit, or prohibit sports betting on its sporting events, or to restrict the types of bets on such sporting events that may be offered by a permit holder.
- For any request made by a sports governing body under subsection A.:
- The requester shall bear the burden of establishing to the satisfaction of the Director that the relevant betting or other activity poses a significant and unreasonable integrity risk; any steps the sports governing body has taken in relation to that activity, and any other relevant information surrounding the relevant betting or other activity relating to the sports governing bodies’ concern to significant and unreasonable integrity risk.
 This language is in the rules of other jurisdictions and to date, to the best of our knowledge, there has never been an instance where the Sports Governing Body (“SGBs”) has utilized the provision. In addition, the permit holder would request that when the SBGs make such request to the Director, it provide all permit holders notice of such request.
 In order for permit holders to provide input around possible integrity risks and requests to limit wagering by Sports Governing Bodies, the requesting SGBs should provide pertinent information relating to the integrity risk, including any steps they have taken in regard to such activity.
11VAC5-70-200. System Integrity and Security Assessment. *UPDATED*
- Either bBefore beginning operations, or within 90 days of beginning operations, and annually thereafter, the permit holder shall engage an independent professional approved by the Director to perform a system integrity and security assessment of its sports betting operations.
 We respectfully request the rule allow that the system integrity and security assessment be allowed to be completed within 90 days of going live, which is consistent with other jurisdictions, and ensures that the limited number of entities providing this service not be overwhelmed prior to launch and delay launch of online sports wagering in VA.
11VAC5-70-210. Minors and Prohibited Players. *UPDATED*
- A permit holder may not permit wagers to be placed by minors and shall maintain a system approved by the Director through which it verifies that wagers are not made by minors.
 We respectfully recommend approving and utilizing the same online registration flow that is approved in all other major jurisdictions with online sports wagering. This includes the use of licensed Know-Your-Customer (KYC) companies who are able to verify the identity, address and age of anyone registering, and ensuring they are at least 21 years of age, after the patron submits their information during the online registration process.
11VAC5-70-220. Integrity Monitoring. *UPDATED*
- A permit holder shall maintain membership in the Global Lottery Monitoring System (GLMS) or other integrity monitoring association or contract with an integrity monitoring system provider as approved by the Department.
 Penn National Gaming, like almost every other sports wagering operator, is a member of Sports Wagering Integrity Monitoring Association (SWIMA). We strongly encourage the VA Lottery to adopt SWIMA as an approved integrity monitoring association.