Vermont Regulator Approves Latest Sports Wagering Procedures

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With little fanfare or discussion, the Vermont Department of Lottery Board of Directors Monday unanimously approved “enhanced procedures” for sports betting with the understanding that the regulations may be amended going forward. The vote is an important step in the process to launch wagering by early 2024.

Toward the end of the 12-minute meeting, Lottery Commissioner Wendy Knight answered questions about whether any kind of wagering on horse racing would be allowed. Knight said that parimutuel wagering is explicitly illegal in Vermont and will be not be on the state’s bet menu.

So far, the lottery has received written public comments from five stakeholders, most recently BetMGM and the geolocation service GeoComply. Operators have pushed back on some procedures, and Knight told the board Monday that her staff has incorporated some suggested language from the public comments that would offer “clarity and didn’t conflict with the law.” In particular, any reference to “business days” has already been or will be changed to “calendar days,” and the words “shall” and “may” were updated where needed.

Staff did not address comments regarding issues that “exist in other states and are becoming the industry strandard,” Knight said, but the latest version of the procedures shows that at least some of the public comments have been added. The procedures can continue to be massaged as legal wagering moves forward.

The lottery posted updated procedures Friday that included suggestions from some operators. While multiple operators have asked for a change to the rule requiring them to provide source code to Gaming Laboratories International during the testing and certification process, that requirement remains intact — for now.

Responsible gambling updates included

GeoComply focused on a single addition to the rules, suggesting an alternative way for operators to verify potential customers in the know-your-customer process. The company’s Director of Government Relations, Brittney Martino, suggested adding “historical behavioral account, device, and location verification” to Section 2.4, arguing that it has been an effective method to “strengthen the account creation process” and creates “less friction” for customers.

The latest updated procedures include that suggestion, including the following:

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  • Explicitly banning proxy betting.
  • Defining “collegiate sports tournament” as one that involves at least four teams, which ultimately allows for betting on any team in such a tournament held in the state. The language is similar to that in Massachusetts, and both states prohibit betting on local college teams unless they are playing in such a tournament.
  • Clarifying that the “owner of a team” is anyone with a 5% or larger stake.
  • Removing a section that would have required “a brief description of a sporting event and wagering proposition.”
  • Loosening language that would have required operators to indicate which fields are “required” on a registration form. Multiple operators suggested such language would require them to change existing forms.
  • Adding a section to strengthen responsible gaming tenets which read, “Operators will ensure that individuals on the Self-Exclusion List do not receive direct marketing, telemarketing promotions, player club materials, or other targeted promotional materials related to Sports Wagering.”
  • Updating a section regarding exclusion lists with comments from several operators, now allowing for wagers made before a player joins a self-exclusion list or is added to an involuntary exclusion list to be settled and distributed.

The board also briefly discussed what should happen to unclaimed funds from a dormant account, and staff clarified that if a patron could not be located, the unclaimed funds would be sent to the state treasurer’s office.


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