11 VAC 5-80-50 Underage betting

B. A permit holder shall promptly refund any money wagered by or on behalf of a minor. A permit holder may withhold and, if practicable and as approved by the Department, redistribute to other winners any prize won by a minor…

Comment: What is the intention of “…redistribute to other winners…”? This may not be practical in house-banked fixed-odds sports wagering where not all players receive the same odds on the same event. Also, if all player accounts are age-verified at time of account creation, it would logically follow that a minor would not be able to create an account. In the event that a minor, without implied or actual knowledge of the permit holder, places wagers on another’s account (a non-minor), what is the requirement of the permit holder to refund those wagers? We ask that wagers made on an age-verified account should not be refunded.

C. A permit holder shall make available, prominently publish, and facilitate parental control procedures to allow parents or guardians to exclude minors from access to any sports betting platform.

Comment: Other regulations already require password protection on the player account. Such passwords would prevent unauthorized access to fund, withdraw, and wager. Is this sufficient to meet the obligation of this regulation? If not, could the Department provide further guidance as to what “exclude minors from access” is intended to mean?