11VAC5-70-220. Integrity Monitoring.

A. A permit holder shall maintain membership in the Global Lottery Monitoring System (GLMS) or other integrity monitoring association…

Comment: While we are not opposed to the specific mention of the Global Lottery Monitoring System in the regulation, we ask that other integrity monitors be named, like SWIMA, or, in the alternative, that the Department remove the names of all integrity monitors from regulation and instead publish a list of approved integrity monitors. We also ask to keep the option for permit holders, integrity monitors, or others to petition for inclusion on the Department’s list.

G. A permit holder may void or cancel wagers related to suspicious wagering activity only after receiving the approval of the Director.

Comment: Will regulation also address how the permit holder should handle the funds that were wagered/held prior to the integrity notification being sent to the Director should the settlement of the wagers occur before the receipt of approval to void the event/cancel the wager from the Director?

H. A permit holder’s integrity monitoring system shall be accessible to the Director via remote access…

Comment: Please consider revising to “The integrity monitoring system provider shall be accessible…” or, in the alternative, provide guidance to the integrity monitoring system providers and permit holders as to the requirements of the integrity monitoring system.

I. …data may not be revealed in whole or in part, except: … 3. An accredited sports governing body as required by the Director pursuant to the sports betting law.

Comment: What is the modifier “accredited” intended to mean? This appears to be the only reference to the phrase “accredited sports governing body”. What is the difference between an “accredited sports governing body” and a “sports governing body”?