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9/9/20  9:37 pm
Commenter: Trevor Hayes, William Hill US

William Hill Comments Part 2

11 VAC 5-60-20(H) Request for self-exclusion

For Internet self-exclusion submissions: The Internet gaming system shall provide a link within the player’s Internet gaming account directly to an Internet self-exclusion application form and provide to the self-excluding individual for his or her acknowledgment the following statement: “I am voluntarily requesting exclusion from all Virginia Internet gaming. I also understand that the Department will share my information with Office of Charitable and Regulatory Programs and the Virginia Racing Commission, who may prohibit me from participating in further gaming activities regulated by those entities. I certify that the information I have provided is true and accurate, and that I have read and understand and agree to the waiver and release included with this request for Internet self-exclusion. I am aware that my digital signature authorizes the Department to prohibit me from participating in all account-based lottery games and to direct all holders of sports betting permits in Virginia to restrict my gaming activities. I am further aware that my digital signature authorizes the Department to share my information with the Office of Charitable and Regulatory Programs and the Virginia Racing Commission, who may further restrict my gaming activities. In accordance with this request and until such time as the Department removes my name from the self-exclusion list in response to my request to terminate my voluntary self-exclusion, I am aware and agree that during any period of self-exclusion any money or thing of value obtained by me in violation of the terms of my self-exclusion shall be subject to forfeiture and donated to the Commonwealth’s Problem Gambling Treatment and Support Fund.”

William Hill supports a simple self-exclusion mechanism, but for consistency, operators should provide a link on its mobile platform to the Virginia Lottery’s self-exclusion page, where a customer can complete the application, provide a signature, waiver request, etc. This is done efficiently in other jurisdictions and is easily understood by the person requesting to self-exclude.

11 VAC 5-80-20(C) Sports bettors’ bill of rights

A permit holder’s platform site must provide substantial and readily available information to enable players to make informed decisions about their gambling, including:

1. With regard to any sports bet, prominent publication of, at a minimum:

a. The handle of the bet;

This is a variable that changes with each bet; a person making one of the first bets on an event would be provided with different information than a person placing a wager immediately before an event starts. As this could create confusion for consumers, we recommend not including this requirement as consumers will be able to have access to other, useful information on our site.

11 VAC 5-80-20(C) Sports bettors’ bill of rights

1. With regard to any sports bet, prominent publication of, at a minimum:

b. The odds of winning the bet and the information used to calculate those odds;

William Hill’s “How to Bet Guide” and the applicable “House Rules” provide this information in a more user-friendly format.  If this regulation remains in its current, or similar format, we request clarification on what is meant by “odds.”

11 VAC 5-80-120(G) Protections for at-risk or problem bettors.

A permit holder shall develop and prominently publish procedures for honoring requests made by third parties to exclude or set limits for sports bettors. Such procedures shall include provisions for honoring requests to exclude sports bettors for whom the requester provides documentary evidence of sole or joint financial responsibility for the source of any funds wagered on sports betting on a platform owned by the permit holder, including:

1. Proof that the requester is jointly obligated on the credit or debit card associated with the sports bettor's wagers,

2. Proof of legal dependency of the sports bettor on the requester under state or federal law, or

3.Proof of the existence of a court order that makes the requester wholly or partially obligated for the debts of the individual for whom exclusion is requested; and

4. Provide for exclusion in situations in which the requester establishes the existence of a court order requiring the sports bettor to pay unmet child support obligations.

It would be onerous on an operator to have to verify the validity of supporting documents in what is a private matter between separate, third parties that do not involve the operator. Similar requirements are not placed on other businesses where a person could incur debt that another person is jointly responsible for and would create additional legal obligations for a sports betting operator that are not inherent in the operations.  We recommend removing this requirement from the final regulations.

(Continued on subsequent submission)

CommentID: 84654