11VAC5-70-270. Sports Betting Platform Requirements.

B. Before a permit holder is issued its permit, all equipment and software used in conjunction with its operation shall be submitted to an independent testing laboratory approved by the Director.

Comment: If the previous comments (see 11VAC5-70-200) regarding the allowance of a 90-day window post-launch for a permit holder to submit an independent testing laboratory certification to the Department is approved, then we ask this subsection also explicitly state that a permit holder can operate during the 90-day certification period. The Department may also consider, as an additional precaution, to limit the 90-day window to products that have already received recent independent testing laboratory certifications for other USA jurisdictions.

K. Unless approved in advance by the Director, a permit holder or a supplier providing a permit holder’s sports betting platform may not rescind a wager posted in the sports betting platform.

Comment: Can you please define the words “rescind” and “posted” in this context? Is the intention to mean that a permit holder cannot remove a market (or void an event and thereby cancelling all wagers on said event) without Director approval or is it intended to mean that the permit holder cannot cancel a wager without Director approval? Generally the operator’s House Rules contains a definition of error that allows “errors” to be no action and thereby void events/odds and cancel wagers made on said errors. In addition, we ask that a mutual agreement between the player and the permit holder regarding the rescission of a wager prior to the start of the event should be permissible without Director approval.