PIV Comments/Suggested Edits - 11 VAC 5-70-290 - Player Accounts
D. If a permit holder determines that the information provided by a player to make a deposit or process a withdrawal is inaccurate or incapable of verification; fails to verify the identity of the player; or the player violates the policies and procedures of the permit holder, the permit holder shall, within its own discretionary timeframe ten days, require the submission of additional information from the player that can be used to remedy any violation or failure to verify the identity or funds deposit or withdrawal information of the player. If such information is not provided or does not result in verification of the player’s identity or deposit or withdrawal information, the permit holder shall:
1. Immediately suspend the player account and not allow the player to place wagers;
2. Submit any winnings attributable to the player to the Director for distribution to the Problem Gambling Treatment and Support Fund established pursuant to § 37.2-314.2.;
3. Refund the balance of deposits made to the account to the source of such deposit or by issuance of a check; and
4. Deactivate the account.
 We respectfully ask the Lottery to reconsider this 10-day window. Ten days to act/provide documents before deactivating an account could create a negative customer experience. We ask that this timeframe be left up to permit holders to determine.
 Additionally, for this section, it notes that winnings should be pushed to VA Problem Gambling Treatment and Support Fund, and we must refund balance of deposit. We assume the intent of the rule was net of any wagers, but the rule does not explicitly specify 'remaining' balance, nor does it specify what happens to bets that are placed, but not yet settled. This creates questions of whether these wagers get voided or carry on and operator has to then refund again. Other concerns remain about refunding the player in these scenarios, which we believe is alleviated if the 10-day mandate is removed.
G. A player account may be funded using:
- A debit card;
- A credit card;
- An electronic bank transfer, including a transfer through third parties;
- An online or mobile payment systems that supports online money transfers;
- Winnings or payouts;
- Reloadable prepaid card; and
 We recommend including cash and reloadable prepaid cards as approved deposit methods. Both of these deposit methods are allowed in most all jurisdictions with legalized online sports wagering and are industry standard deposit methods.
H. Funds may be withdrawn from a player account through:
- Cashier’s check, wire transfer, or money order by the permit holder made payable to the player and issued directly or delivered to the player’s address on file with the permit holder;
- Credits to the player’s debit card;
- Credits to the player’s credit card;
- Electronic bank transfers, including transfers through third parties;
- Online or mobile payment systems that support online money transfers;
- Reloadable prepaid cards; or
- Any other means approved by the Board.
 Recommend also allowing reloadable prepaid cards for withdrawals.
R. A permit holder shall suspend a player account if:
- The permit holder knows or has reason to know of:
- Illegal activity related to the account;
- A negative account balance;
- Five failed ACH deposit attempts within a 24-hour period; or
 It is worth noting that ACH attempts can fail for reasons outside of the patron’s control and should be considered for a future definition of “failed”.