On behalf of IGT, thank you for the opportunity to provide feedback regarding the “Virginia Lottery Casino Gaming 11 VAC 5-90 emergency regulations” as published in The Virginia Register of Regulations March 29, 2021.   We seek confirmation of our understanding as well as consideration for the language changes below:

11VAC5-90-50. Investigations AA. Approval of institutional investors.  Based on our understanding the responsibility to seek a waiver as well as follow up actions are with each respective institutional investor and not the associated supplier or operator licensee. 

11VAC5-90-70. Applications for and issuance of supplier permits.  I. Portability. Identifies that each supplier permit is assigned to a property and outlines a transfer request process to support other properties.  We suggest that once a supplier permit is issued that it will authorize the provisions of goods and services it requires to any casino licensee within the Commonwealth of Virginia.

 11VAC5-90-150. Slot machines. K. Average payout percentage. 9. a. (1) restricts offering an award where the odds exceed 50 million to one.  As this limitation is not common across the industry, suggest the following language change to align with odds requirements which apply the odds to advertised awards and allows for disclosing odds of prizes which exceed the limit

11VAC5-90-150 Slot Machines. K. Average payout percentage. 9.

a. May not:

(1) Offer an winning combination advertised award where the odds exceed 50100 million to one, unless disclosed to the player; and

11VAC5-90-150. Slot machines. K. Average payout percentage 9. b. to be consistent with other jurisdictions and to allow for a wider offering of game types we suggest the addition of verbiage to allow game rules to disclose relevant details of outcome conditions.

11VAC5-90-150 K 9b. Shall be designed to ensure that all possible combinations in the game cycle are independent of each other, unless otherwise disclosed to the player.

Thank you again for the opportunity to comment and please contact me directly should you wish to discuss.