Gaming Laboratories International, LLC (GLI) appreciates the opportunity to comment on the proposed rules regarding the regulation of sports wagering and looks forward to assisting the Virginia Lottery Board in further refining the details of these rules as well as provide recommendations on additional rules as seen fit.  We hope the below feedback is useful and we are available at any time to clarify or further discuss any of the items presented below.

The GLI team agrees completely with principal objectives for sports wagering as stated by the Virginia Lottery Board – avoid overly-prescriptive rules, do not create a barrier to entry, ensure the integrity of sports wagering conducted in the state of Virginia and ensure player fairness.

The proposed rules were compared to existing sports wagering rules and regulations including, but not limited to, Tennessee, New Jersey, Washington DC, Indiana, and Iowa. The below comments were collected in effort to identify areas within the proposed rules that may warrant either additional clarification and or consideration.

While many of the comments are focused on layout of the document, others are focused on the content of the requirements themselves.  Within this section is a list of some high-level comments.

• • GLI suggests that the Draft Sports Betting Regulations fully cover the provisions of the Chapter 40 (§ 58.1-4030 et seq.) of Title 58.1 of the Code of Virginia and maintains consistency where possible.
  • GLI requests that clarity be provided on what would be considered a “independent testing laboratory approved by the Director” as mentioned in 11 VAC 5-70-270.  For further details regarding the importance of setting quality standards for testing laboratories, please reference GLI’s comments to the Comparative Governance and Regulatory Structures of Gaming Regulation Related to Expanded Legalized Gaming Activities in the Commonwealth of Virginia, Exhibit 9, prepared for the Joint Legislative Audit and Review Commission on August 5, 2019.
  • It has also been mentioned in 11 VAC 5-70-270.S that additional system specifications may be specified through the issuance of technical bulletins. GLI strongly suggests adoption of the GLI-33 Standard for Event Wagering Systems, as direct referenced in 11 VAC 5-70-300.A Minimum Internal Control Standards. Most sports wagering markets in the U.S. have already incorporated GLI-33 adoption into their rules and regulations which have ensured security of the sports wagering systems and provided guidance for sports wagering operations. The standard is regularly revisited to ensure it maintains pace with current technology and regulatory objectives and is scrutinized by rigorous review and comment processes for regulators and the industry.  It is an open standard and portends no competitive advantage to GLI.  It is published and maintained to facilitate regulatory efficiency and consistency, while still providing jurisdictions with sufficient flexibility to adapt to any unique characteristics of their market.

Thank you for the opportunity to share our thoughts with the commission.  Please let us know if we may be of any further assistance on this or any other matter.

Sincerely,

GAMING LABORATORIES INTERNATIONAL, LLC