MLB/PGA/NBA Comment letter - part 1 of 3
September 1, 2020
Kevin Hall Executive Director Virginia Lottery
600 East Main Street Richmond, VA 23219
Re: Draft Sports Betting Regulations
Dear Executive Director Hall:
The undersigned sports governing bodies submit this letter in response to the Virginia Lottery Board’s (the “Board”) solicitation of comments to its draft regulations to implement Virginia’s sports betting law. Before addressing our proposed amendments, we would like to express our appreciation to the Board for including many of the provisions we recommended in our May 29, 2020, letter to you. For the reasons set forth below, we urge the Board to amend the following: the definition of “sports betting supplier” (11VAC5-70-10); the section requiring regulated entities to provide account-level betting information to the Board (11VAC5-70-230(C)); the section limiting sports governing bodies’ ability to receive real-time information from regulated entities (11VAC5- 70-230(M)); and the section relating to sports governing bodies’ ability to use information received related to integrity investigations (11VAC5-70-230(K)).