PIV Comments/Suggested Edits - 11 VAC 5-70 - 260, 270
11VAC5-70-260. House Rules. *UPDATED*
- House rules shall include minimum and maximum wagers, as approved by the Director.
 We respectfully suggest removing the need to list maximum wager amounts in house rules. Different wagers have varying thresholds, which will depend on various factors, and players may not always be able to wager as much on something as the listed "maximum" might otherwise show. Further, if an operator lists a maximum amount, and wants to take a wager that exceeds that, they shouldn’t be capped by this rule.
11VAC5-70-270. Sports Betting Platform Requirements. *UPDATED*
K. Unless approved in advance by the Director. a permit holder or a supplier providing a permit holder’s sports betting platform may not rescind a wager posted in the sports betting platform, unless it is included in the permit holder’s approved house rules.
L. A sports betting platform shall prevent past posting of wagers and the voiding and cancellation of wagers after the outcome of an event is known.
M. If a player has a pending wager and the player subsequently self-excludes, the wager shall be cancelled and the funds and account balance shall be returned to the player in accordance with the permit holder’s internal controls.
N. M. At least once every 24 hours, a sports betting platform shall perform an authentication process on all software used to offer, record, and process wagers to ensure there have been no unauthorized modifications. As part of this authentication process, the sports betting platform must be able to detect if any system component is determined to be invalid in the event of an authentication failure.
O. In the event of an authentication failure, the permit holder’s Information Security Officer and the Director must be notified within 24 hours of the failure. The results of all authentication attempts shall be recorded by the sports betting platform and maintained for a period of 90 days.
N. In the event of an authentication failure, the permit holder will send a weekly report to the Director. The results of all authentication attempts shall be recorded by the sports betting platform and maintained for a period of 90 days.
P. O. A sports betting platform shall have controls in place to review the accuracy and timeliness of any data feeds used to offer or settle wagers. If an incident or error occurs that results in a loss of communication with the data feeds used to offer or redeem wagers, such error shall be recorded in a log capturing the date and time of the error, the nature of the error, and a description of its impact on the system’s performance. Such information shall be maintained for a minimum period of two years.
Q. P. A permit holder and a supplier providing a permit holder’s sports betting platform shall grant the Director access to wagering systems, transactions, and related data as deemed necessary and in the manner required by the Director.
R. Q. A sports betting platform shall provide a mechanism for the Director to query and export, in the format required by the Director, all sports betting platform data.
S. R. Additional system specifications may be specified by the Director through the issuance of a technical bulletin.
 We respectfully recommend allowing operators to unilaterally rescind wagers in accordance with their approved house rules. Palpable errors are rare, but they do happen, and operators should be able to handle these situations based on house rules that are approved by the VA Lottery.
 We respectfully ask this rule to be removed. It allows a patron to self-exclude when they know a wager is going to lose, just to get the refund. For example, a patron may have a future wager on a team to win the Super Bowl. As soon as they know the team won’t make the playoffs, they self-exclude to get the refund.
 The 24 hours to report an authentication failure seems too short, since there can be reasons for the failure and a need to research and verify on the permit holder’s side. We will be tracking these failures and can send a weekly or biweekly report to the Director. Any unusual or suspicious cases would be reported and follow the protocol for that separately.