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9/2/20  3:02 pm
Commenter: Penn National Gaming, Inc., and Penn Interactive

PIV Comments/Suggested Edits - 11 VAC 5-70-280 - Geolocation Systems
  1. At least every 90 days a permit holder shall provide the Director evidence that the geolocation system is updated to the latest solution, whenever a new solution is implemented.[1]


  1. The Director may issue additional geolocation requirements in the form of a technical bulletin.[2]


[1] This requirement is not seen in most states with online wagering and we believe it should be removed. Geolocation requirements should not change often, unless the Geolocation provider has updated their solution. Therefore, providing evidence every 90 days for something that will not likely change seems overly burdensome for both permit holders and the Director. Instead, permit holders should notify the Director whenever a new solution is implemented.


[2] When new requirements are added to the technical bulletin, it would be helpful for permit holders to know how long they have to work on technical changes, in order to be compliant. We ask that Lottery consider adding “Permit Holders may have up to 30 days to submit a plan informing the Director their timeline and plan for technical compliance with the bulletin.” We’d also ask that this not be specific to geolocation, but to any new technical requirements that are issued to permit holders, by Lottery.

CommentID: 84392