Stakeholder/Public Comment for JCAR Agency Report: Internet Sports Betting  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Comments  
Public  
Hearing/  
Written  
LSBA  
LIGA  
Change/no  
change  
Name/Org  
Rule  
Comment  
Agency rationale  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
LSBA  
432.711(c)  
Definition of “Affiliate marketer”:  
Add to end of subrule: who have an  
agreement with an internet gaming  
operator to be compensated based  
on the number of registrations, the  
number of depositing registrations,  
or a percentage of adjusted gross  
receipts.  
Change  
Definition modified  
resulting in change to  
rule 432.722(3)(f) and  
432.729(1)(a)(i)  
Andrea Hansen, Written  
(Honigman LL)  
on behalf of  
LSBA  
432.711(c)  
The current definition of “affiliate  
marketer” is very broad. Change to:  
“Affiliate marketer” means entities  
and individuals involved in  
Change  
Definition modified  
resulting in change to  
rule 432.722(3)(f) and  
432.729(1)(a)(i)  
Rhea Loney,  
Penn Interactive  
promoting, marketing, and directing  
business to online gaming sites, on  
their own behalf, and who have an  
agreement to be compensated by a  
sports betting or internet gaming  
operator licensee based on the  
number of registrations, the  
number of depositing registrations,  
or a percentage of adjusted gross  
revenue.”  
Bob DeVries,  
Governmental  
Consultant  
Services Inc., on  
behalf of NBA-  
MLB-PGA Tour  
(Leagues)  
Written  
LSBA  
432.711(c)  
Insert language to clarify and limit  
scope of who is considered an  
affiliate marketer. Change language  
to: “Affiliate marketer” means  
entities and individuals whose core  
business function involves  
promoting, marketing, and directing  
business to online gaming sites. This  
term shall not apply to entities not  
Change  
Definition modified  
resulting in change to  
rule 432.722(3)(f) and  
432.729(1)(a)(i)  
primarily in the business of  
promoting, marketing and directing  
business to online gaming sites.  
Propose changing definition:  
“Affiliate marketer" means a person  
or entity involved in whose primary  
business (unction is promoting,  
marketing, and directing business to  
online gaming site.”  
Bob DeVries,  
Governmental  
Consultant  
Services Inc., on  
behalf of NBA-  
MLB-PGA Tour  
Written  
LSBA  
432.711(c)  
Change  
Definition modified  
resulting in change to  
rule 432.722(3)(f) and  
432.729(1)(a)(i)  
Alternatively, we recommend  
amending the Affiliate Marketer  
definition to expressly exempt  
sports governing bodies, in light of  
the fact that the Michigan  
Legislature specifically considered  
the leagues' role in the sports  
betting market in designing the  
requirements relating to official  
league data.  
Trevor Hayes,  
William Hill  
Written  
Written  
LSBA  
LSBA  
432.711(m)  
432.711(p)  
In definition of “Key person”  
we respectfully request a revised  
definition of “key person” to only  
capture those employees with  
direct oversight or control of  
operations in Michigan, including a  
clearer definition of the word  
“director” as used in (i) and (vi).  
Definition of “Prohibited person”:  
Employee participation/risk  
No change  
The definition aligns with  
statutory language  
Mike Phelan,  
Pokagon  
Gaming  
Change  
Definition changed to no  
longer prohibit person  
licensed under Gaming  
Control and Revenue Act  
or the Indian Gaming  
Regulatory Act from  
Authority  
creating accounts or  
placing wagers. Added a  
new (v), as this is not  
currently in the draft.  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 2  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
LSBA  
432.711(p)  
Definition of “Prohibited person”:  
The highlighted sections should not  
be in the definition of prohibited  
person. A prohibited person is not  
allowed to set up an account. These  
individuals are allowed to set up an  
account they just cannot place  
wagers on certain events. We would  
suggest that these sections be put  
in a separate rule on conduct that is  
prohibited, similar to how it is done  
in the Gaming Act Rules.  
No change  
Resolved with the  
amendment to R  
432.775(1), R 432.776(1)  
and R 432.751a(2)  
Seth Young,  
PointsBet  
Written  
LSBA  
432.711(p)  
Definition of “Prohibited person”:  
does this prohibit an employee of  
an operator’s casino from wagering  
with the operator’s platform  
Change  
Definition changed to no  
longer prohibits person  
licensed under Gaming  
Control and Revenue Act  
or the Indian Gaming  
Regulatory Act from  
creating accounts or  
placing wagers.  
provider?  
Seth Young,  
PointsBet  
Written  
Written  
LSBA  
LSBA  
432.711(q)  
432.711(x)  
Definition of “Publicly traded  
corporation”: Is the Board going to  
recognize a publicly traded  
corporation on the ASX for purposes  
of the requirements of the rules?  
Definition of “Targeted mailing”:  
Would this prohibit cross-selling  
customers from a sports betting  
platform to a casino?  
No change  
No change  
The Board relies on  
reporting to the US  
Securities and Exchange  
Commission  
Seth Young,  
PointsBet  
R 432.774 prohibits  
targeted mailing to  
persons on the self-  
exclusion list  
Andrea Hansen  
on behalf of  
FanDuel  
Andrea Hansen  
on behalf of  
FanDuel  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
Written  
LIGA  
LSBA  
LSBA  
432.711  
Add definition of ex parte  
communication  
No change  
No change  
No change  
Limits Board discretion  
432.721a  
Proposed adding “operator” along  
with “platform provider”  
Covered in R 432.721  
Unnecessary  
432.721f(2) - (3)  
Suggests language is duplicative of  
other subrules  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 3  
Bill Brooks on  
behalf of Quinto  
Singleton on  
behalf of  
Nottawaseppi  
(NHBP)  
Robert Russel,  
RMC, on behalf  
of DraftKings  
Written  
Written  
LSBA  
LSBA  
432.721k(2)  
432.722  
Not all vendors will have an actual  
representative in Michigan to  
receive services and other persons  
required to be licensed likely will  
have no presence in the state  
Change  
Removed “within  
Michigan.”  
clarity relating to sports betting  
“data providers” and “provider  
hosting live sports betting data”;  
Would like additional clarification  
which providers fall into these  
categories and which are not  
included.  
No change  
MGCB provided verbal  
verification  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
LSBA  
LSBA  
432.722  
Replace “regarding” with “directly  
impacting”  
No change  
Change  
Contrary to the  
definition of supplier  
MCL 432.403(ee)  
Definition modified  
resulting in change to  
rule 432.722(3)(f) and  
432.729(1)(a)(i)  
432.722(3)(f)  
Definition of “Affiliate marketer”:  
Add to end of subrule: who have an  
agreement with an internet gaming  
operator to be compensated based  
on the number of registrations, the  
number of depositing registrations,  
or a percentage of adjusted gross  
receipts.  
Mike Phelan,  
Pokagon  
Gaming  
Written  
LSBA  
432.723(11)(c)  
Occ. Licensing:  
Reciprocity provision was removed,  
request it be added back in  
Change  
Board added language  
allowing exemption from  
occupational licensing if  
licensed by  
Authority  
governmental entity.  
Can still require  
registration  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Robert Russel,  
RMC, on behalf  
of DraftKings  
Written  
Written  
LSBA  
LSBA  
432.723(2)  
432.723(2)  
Encompassing too large group of  
employees; add “deployment of  
code to production of”  
Suggest including "deployment of  
code" language to limit who is  
included in occupational licensing.  
Change  
Change  
Board identified persons  
having direct impact on  
integrity of gaming  
Board identified persons  
having direct impact on  
integrity of gaming  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 4  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Written  
LSBA  
432.723(1)  
Subpart (1) could be overly  
burdensome  
No change  
There is a mechanism in  
place for a sports betting  
operator or sports  
betting supplier to  
provide an explanation,  
such as a job description,  
to support an allegation  
that a position should  
not require an  
occupational license.  
Board identified persons  
having direct impact on  
integrity of gaming  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
LSBA  
432.723(2)  
Limit scope of occupation licensing  
only to individuals that make  
changes to hardware or software  
having ability to affect the outcome  
of a game  
Change  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
Written  
Written  
LSBA  
LSBA  
LSBA  
LSBA  
432.723(2)  
Limit the scope of who is required  
to be licensed  
Change  
Board identified persons  
having direct impact on  
integrity of gaming  
Board identified persons  
having direct impact on  
integrity of gaming  
Removed 723(2)(c) and  
(d)  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Robert Russel,  
RNC, on behalf  
of DraftKings  
432.723(2)(a) and (b)  
432.723(2)(c)  
432.724  
Encompassing too large group of  
employees; add “deployment of  
code to production of”  
Change  
Vague and unclear  
Change  
Asking for clarification that  
employers are permitted to pay  
occupational licensing fees on  
behalf of their employees  
No change  
Operators or platform  
providers can pay  
occupational license fees  
Andrea Hansen  
on behalf of  
FanDuel  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
LSBA  
LSBA  
432.724(3)(c)  
432.724(8)  
Occupational license application fee Change  
is extremely high given there is only  
one level.  
Board lowered  
application fee from  
$500 to $250.  
Occupational license should be  
payable every two years concurrent  
with the renewal  
Change  
(7) Strike “each year”  
(a) add “annual fee”  
(b) add “annual fee”  
(c) add “biennial fee”  
Language was added to  
clarify that relevant legal  
criteria under federal  
Indian law will be used to  
Mike Phelan,  
Pokagon  
Gaming  
Written  
LSBA  
432.725b(3)  
Supplier licensing:  
Change  
The contingent rule regarding  
whether a supplier qualifies as “an  
arm of the tribe” should only apply  
Authority  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 5  
if the tribe who is in a relationship  
with the supplier claims that the  
supplier is an arm of the tribe. The  
determination of whether the  
supplier qualifies as an “arm of the  
tribe” should be based on objective  
criteria informed by proper analysis  
of federal Indian law. See, e.g.,  
People v. Miami Nation Enterprises,  
386 P.3d 357 (2016)  
establish arm of tribe  
status.  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
LSBA  
LSBA  
432.729(1)(a)  
Inserted “internet” before “sports  
betting platform provider”  
Change  
Change  
Omission in the original  
draft  
432.729(1)(a)(i)  
Definition of “Affiliate marketer”:  
Add to end of subrule: who have an  
agreement with an internet gaming  
operator to be compensated based  
on the number of registrations, the  
number of depositing registrations,  
or a percentage of adjusted gross  
receipts.  
Definition modified  
resulting in change to  
rule 432.722(3)(f) and  
432.729(1)(a)(i)  
Andrea Hansen  
on behalf of  
FanDuel  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Written  
Written  
LSBA  
LSBA  
432.729(1)(a)(iv)  
432.729(1)(a)(iv)  
Inserted “internet” before “sports  
betting platform provider”  
Change  
Omission in the original  
draft  
Add “that directly affects internet  
sports betting”  
No change  
If the business “directly  
affects internet sports  
betting”, it is likely a  
supplier, not a vendor  
Change “in a” to “during the prior”  
calendar year  
No change  
No Change  
The registration should  
be obtained when the  
vendor crosses the  
$100,000 threshold.  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
LSBA  
432.729(1)(a)(iv)  
Suggest deleting (1)(a)(iv) and  
limiting (1)(a)(vi) to other persons  
who provide more than $100,000  
worth of goods and/or services in a  
calendar year that are specifically  
related to the operation sports  
If the goods and/or  
services are specifically  
related to sports betting,  
the person is likely to be  
a supplier not a  
vendor. Board needs  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 6  
betting as deemed necessary by the  
board.  
authority to determine  
other persons that  
require vendor  
registration.  
Mike Phelan,  
Pokagon  
Gaming  
Written  
LSBA  
432.729(1)(a)(v)  
“Data Warehouses” may not be the Change  
best term -- “Data Centers” seems  
more accurate.  
“Data Center” is a more  
appropriate term  
Authority  
Andrea Hansen  
on behalf of  
FanDuel  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Bill Brooks on  
behalf of Quinto  
Singleton on  
behalf of  
Written  
Written  
Written  
LSBA  
LSBA  
LSBA  
432.731(1)  
432.732a  
Change “and” to “and/or”  
No change  
Servers must be located  
within this state  
Limit source code to those deemed  
to be a critical component  
No change  
No change  
Lab needs source code  
for any component, not  
just critical components  
Term is commonly  
referred to and known in  
the industry as GAT.  
Point of rules is  
432.732a(2)  
What is a Gaming Authentication  
Tool  
Nottawaseppi  
(NHBP)  
“software must be  
designed with a method  
to permit the validation  
of software.  
Andrea Hansen, Written  
(Honigman LL)  
on behalf of  
Rhea Loney,  
Penn Interactive  
LSBA  
432.732a(3)  
Submitting source code to any  
entity, even a third-party testing  
laboratory, could become a security  
breach to any operator or supplier’s  
platform and open up the platform  
to unnecessary risk. We  
No change  
Board needs source code  
to evaluate the  
submission and ensure  
the submitted software  
is what was approved  
respectfully suggest the following  
substitute language, “The internet  
gaming platform provider or  
internet gaming supplier shall verify  
the hashes of critical components.”  
Provide automatic approval for  
software updates to reduce  
unnecessary delays and increased  
regulatory costs.  
Mike Phelan,  
Pokagon  
Gaming  
Written  
LSBA  
432.732a(7)  
No change  
Handling of software  
updates is sufficiently  
addressed under the  
self-monitoring of  
Authority  
gaming platform critical  
components and change  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 7  
approval requirements  
of the administrative  
rules.  
MGCB  
Written  
Written  
LSBA  
LSBA  
432.732b(1)  
432.734(1)  
Change “and” to “or”  
Change  
Change “and” to “or, or  
both” to make less  
burdensome  
As a result of the change  
to R 432.634, a change is  
made to R 432.734 for  
consistency purposes  
Lloyd D.  
Levenson  
(Cooper  
Levenson)  
We are in favor of Rules being put in Change  
place that will allow multi-state  
poker agreements should the  
legislature pass such a bill  
authorizing same.  
Andrea Hansen  
on behalf of  
Kambi  
Andrea Hansen  
on behalf of  
FanDuel  
Andrea Hansen  
on behalf of  
FanDuel  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
Written  
Written  
Written  
LSBA  
LSBA  
LSBA  
LSBA  
LSBA  
432.734  
Can odds-making components be  
made outside of the US?  
No change  
Technical bulletins  
provide clarification  
432.735(4)  
432.736(4)  
432.737a  
432.739  
Change “and” to “or”  
Change “and” to “or”  
Change “and” to “or”  
Change  
Change “and” to “or, or  
both” to make less  
burdensome  
Change “and” to “or, or  
both” to make less  
burdensome  
Change  
No change  
No change  
Must be done jointly  
Mike Phelan,  
Pokagon  
Gaming  
In order to avoid confusion and  
possible conflict, this provision  
should be coordinated with (or,  
possibly, combined with)  
432.634(1), which addresses  
substantially the same subject  
matter.  
432.734(1) addresses  
wagering components  
only (which must be  
located in Michigan),  
while this provision  
addresses all critical  
components. Some  
components will be  
subject to both  
Authority  
requirements, while  
certain non-wagering  
components will only be  
subject to this provision.  
Change to “or, or both”  
to make less  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
LSBA  
432.739(1)  
Change “and” to “and/or”  
Change  
burdensome  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 8  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
LSBA  
432.739(2)(c)  
Version 2 of Standard GLI-19 should Change  
be “version 3”  
With GLI-19 change from  
version 2 to version 3, it  
is necessary for  
consistency purposes to  
add section (2)(c)(vi)  
Change “and” to “or, or  
both” to make less  
burdensome  
Clarified to now provide:  
“An internet sports  
betting platform  
provider must promptly  
notify any affected  
sports betting operators  
on behalf of which it  
accepts internet sports  
betting wagers of any  
issues impacting the  
integrity of internet  
sports betting.  
Andrea Hansen  
on behalf of  
FanDuel  
Seth Young,  
PointsBet  
Written  
Written  
LSBA  
LSBA  
432.739(3)  
Change “and” to “or”  
Change  
Change  
432.743(12)  
(integrity monitoring) Recommend  
tightening this up. If we think  
there’s an issue, we will notify the  
integrity monitor/the Board, but it  
should be the job of the  
Board/integrity monitor to  
disseminate these notifications  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
LSBA  
LIGA  
432.741(7)  
R 432.745  
Add “Any such decision by the  
Board may be appealed under the  
Administrative Procedures Act,  
1969 PA 306, MCL 24.201 to  
24.328.”  
No change  
No change  
Not provided for in the  
APA  
Seth Young,  
PointsBet  
Request authorizing fixed odds  
horse racing wagering  
A request for  
authorization can be  
submitted to the Board  
via the events category  
and wager type approval  
process  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Written  
LSBA  
432.745(2)  
Propose removing the requirement  
of test or experimental test periods  
for event categories and wager  
types  
No change  
Test or experimental  
period not required for  
all event categories or  
wager types and will not  
result in operational  
inefficiencies  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 9  
Monique Field-  
Foster, Warner  
Norcross + Judd  
LLP, on behalf  
of National  
Written  
LSBA  
432.745(7)(e)  
Insert “on the decisions of game  
officials” to any wager on the injury  
of a participant in an event  
No change  
The proposed insertion is  
too broad. In addition,  
any sports- governing  
body has a mechanism to  
submit a request to the  
Board to prohibit  
Football League  
wagering on a particular  
wager type.  
Seth Young,  
PointsBet  
Written  
Written  
LSBA  
LSBA  
432.745(9)  
Are there punitive measures for  
intentionally offering an  
unauthorized or prohibited event?  
No change  
No change  
The Board has discretion  
to take disciplinary  
action up to an including  
license revocation.  
This is meant to allow  
wagering on an event  
approved by the Board  
when the outcome is  
known to select  
Seth Young,  
PointsBet  
432.745(10)  
What are the standards for  
determining if the outcome is  
publicly known?  
individuals before it is  
publicly announced  
“is necessary” is the  
language used in  
Monique Field-  
Foster, Warner  
Norcross + Judd  
LLP, on behalf  
of National  
Football League  
Monique Field-  
Foster, Warner  
Norcross + Judd  
LLP, on behalf  
of National  
Football League  
Monique Field-  
Foster, Warner  
Norcross + Judd  
LLP, on behalf  
of National  
Written  
Written  
Written  
LSBA  
LSBA  
LSBA  
432.745(12)(c)  
432.745(15)  
Change “is necessary” to “would  
reasonably”  
No change  
No change  
No change  
MCL 432.410(4)  
Change “is necessary” to “would  
reasonably”  
“is necessary” is the  
language used in  
MCL 432.410(4)  
432.746  
Sections (2)(a)(iv) and  
(v), (3)(a), (6)(d)(i)  
Proposed insertion:  
“To the fullest extent permitted  
under applicable law, all  
information submitted to the Board  
relating to the terms on which  
official league data is offered, and  
the processes by which such data is  
compiled and distributed, will be  
Contrary to the intent of  
the Freedom of  
Information Act  
MCL 15.231-15.246  
Football League  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 10  
maintained by the Board in  
confidence.”  
Robert Russel,  
RMC, on behalf  
of SportRadar  
and DraftKings  
Written  
LSBA  
432.746(1)(a)(iii)  
Suggestion to strike 746(1)(a)(iii)  
“The method of data collection  
must not violate any applicable  
terms of admittance to an event or  
terms of service of a website.”  
While we need appropriate  
safeguards, these should be  
balanced to avoid creating undue  
market restrictions. This restriction  
on the data collection would be  
unique to Michigan and not in any  
other state or international  
jurisdiction. The Rule suggests that  
using publicly  
Change  
Board struck language as  
suggested.  
available schedules for offering  
betting markets or confirming final  
scores of a sporting event to payout  
tier 1 or tier 2 sports bets may be a  
violation of Rule 746.  
Robert Russel,  
RNC, on behalf  
of SportRadar  
Written  
LSBA  
432.746(1)  
Our recommendation is to make 3  
modest adjustments to the  
conditions imposed by Rule 746 as  
follows:  
Change  
Board struck R  
432.746(1)(a)(iii)  
a) Conditions on data collection  
activity to be limited to collection  
occurring within the jurisdiction of  
Michigan;  
b) Conditions on data collection  
activity relating to US-based sports  
to be limited to those who make  
available official league data on  
commercially reasonable terms and  
whose governing bodies have  
notified the MGCB for the purposes  
of using official league data in  
Michigan, and;  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 11  
c) Conditions on collection or  
distribution of data to be limited to  
live data associated with offering  
tier  
2 sports bets.  
Robert Russel,  
RNC, on behalf  
of SportRadar  
Written  
Written  
Written  
LSBA  
LSBA  
LSBA  
432.746(1)(a)(iii)  
432.746(1)(a)(iii)  
432.746(1)(a)(iii)  
Suggest striking (iii) or replacing  
with “For sports taking place in the  
United States where the sports  
governing body has made official  
league data available on  
commercially reasonable terms in  
the state of Michigan, the method  
of data collection must comply with  
any applicable terms of admittance  
to an event or terms of service of a  
website.”  
Suggest striking (iii) or replacing  
with “For sports taking place in the  
United States where the sports  
governing body has made official  
league data available on  
commercially reasonable terms in  
the state of Michigan, the method  
of data collection must comply with  
any applicable terms of admittance  
to an event or terms of service of a  
website.”  
Change  
Change  
Change  
Board struck language as  
suggested.  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Board struck language  
Andrew  
Winchell,  
FanDuel  
Suggest striking (iii) or replacing  
with “For sports taking place in the  
United States where the sports  
governing body has made official  
league data available on  
Board struck language as  
suggested  
commercially reasonable terms in  
the state of Michigan, the method  
of data collection must comply with  
any applicable terms of admittance  
to an event or terms of service of a  
website.”  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 12  
Andrea Hansen, Written  
(Honigman LL)  
on behalf of  
Rhea Loney,  
Penn Interactive  
LSBA  
432.746(1)(a)(iii)  
We respectfully request that the  
rule requiring “the method of  
collection must not violate any  
applicable terms of admittance to  
an event or terms of service of a  
website” to be removed. This rule  
prevents the use of public  
Change  
Board struck language as  
suggested.  
information (websites) from being  
used to settle a wager.  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
LSBA  
LSBA  
432.746(1)(a)(iii)  
432.746(6)(g)(iv)  
Add: “This subsection does not  
apply if the data collection is  
collected pursuant to an agreement  
with the applicable sports governing  
body or is publicly available.”  
Insert “generally” before  
“complete…” and insert “based on  
industry standards for the relevant  
athletic events.”  
No change  
Change  
This rule doesn’t prevent  
what they propose  
Bob DeVries,  
Governmental  
Consultant  
Services Inc., on  
behalf of NBA-  
MLB-PGA Tour  
(Leagues)  
Accepted proposed  
changes with slight  
modification to provide  
clarity and guidance on  
how prescribed criteria  
will be evaluated.  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Written  
Written  
LSBA  
LSBA  
432.746(2)(d)  
432.746a(7)  
Add “sports governing body  
headquartered in the United States”  
No change  
Change  
Already limited in (2)(a)  
to a sports governing  
body headquartered in  
the United States  
Add at beginning: Except  
as otherwise provided in  
these rules or applicable  
state or federal law.  
Bill Brooks on  
behalf of Quinto  
Singleton on  
behalf of  
Nottawaseppi  
(NHBP)  
This needs to be subject to  
state/tribal/federal rules regarding  
KYC. For example, no payout if  
player refuses to provide  
identification.  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Written  
Written  
LSBA  
LSBA  
432.751(1)(c)  
432.751(1)(c)  
Would like internet sports betting  
accounts and internet wagering  
accounts to interface from the  
participants perspective  
Authorize participants to be able to  
use same account for internet  
gaming and internet sports betting  
Change  
Change  
Board inserted language  
in a new 432.751(2)  
allowing integrated  
accounts with conditions  
Board inserted language  
allowing integrated  
Robert Russel,  
Regulatory  
Management  
Counselors, PC  
accounts with conditions  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 13  
Robert Russel,  
RMC, on behalf  
of GAN and  
Written  
LSBA  
432.751(1)(c)  
Propose adding:  
Change  
Board inserted language  
allowing integrated  
accounts with conditions  
“Notwithstanding the foregoing, the  
internet sports betting account may  
be integrated with an internet  
wagering account from the  
DraftKings  
authorized participant’s perspective  
allowing participants to have one  
account/sign-in that will provide  
access to both sports betting and (if  
applicable) internet gaming while  
still providing the accounting  
capability of separating sports  
betting and internet wagering upon  
request.”  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
LSBA  
LSBA  
432.751(1)(c)  
432.751a(2)  
Authorize participants to be able to  
use same account for internet  
gaming and internet sports betting  
Change  
Change  
Board inserted language  
allowing integrated  
accounts with  
conditions.  
Andrea Hansen  
on behalf of  
FanDuel  
Add “This subsection shall not be  
construed to prevent an individual  
from creating an internet sports  
betting account and depositing  
funds to such an account even if  
they are prohibited from certain  
placing certain wagers.”  
A prohibited person may  
be able to make certain  
wagers  
Andrea Hansen  
on behalf of  
FanDuel  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
Written  
LSBA  
LIGA  
432.751a(3)  
432.751a(3)  
Change “demonstratable” to  
“demonstrable”  
Change  
Grammatical  
Add “Such standards shall be  
satisfied by the use of a customer  
attestation that they are not a  
prohibited person at the time of  
account creation.”  
No change  
Customer attestation  
may work in some cases  
but not others. Board  
retains discretion to  
determine if licensee has  
met this obligation  
Trevor Hayes,  
William Hill  
Written  
LSBA  
432.753(1)  
We request further clarification on  
how we should comply with  
detecting unauthorized use of  
accounts  
No change  
The authorized  
participant information  
page must include  
information advising  
authorized participants  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 14  
how to detect  
unauthorized use of their  
accounts  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Written  
Written  
Written  
LSBA  
LSBA  
LSBA  
432.753(2)(c)  
432.753(2)(c)  
432.751a  
Remove “upon 24-hours-notice”; no No change  
specified period but “as required by  
the board”  
Authorized participant  
should be given  
opportunity to change  
their self-imposed  
limitations and Board  
retains authority to set a  
different period.  
Robert Russel,  
RNC, on behalf  
of DraftKings  
Remove “upon 24-hours-notice”; no No change  
specified period but “as required by  
the board”  
Authorized participant  
should be given  
opportunity to change  
their self-imposed  
limitations and Board  
retains authority to set a  
different period.  
Identity verification  
addressed in the rules;  
specific procedures to be  
addressed in internal  
controls  
Kimberly  
Provided recommendations for  
accuracy of data in identity  
authentication  
No change  
Sutherland,  
LexisNexis Risk  
Solutions  
Trevor Hayes,  
William Hill  
Written  
Written  
LSBA  
LSBA  
432.755(a)(vii)  
432.755c  
We respectfully request (vii) to be  
amended to allow for a mobile  
number to satisfy this requirement.  
Add: belonging to another  
authorized participant. This Rule  
does not prohibit an authorized  
participant from transferring funds  
between his or her own wagering  
accounts.  
No change  
Change  
A mobile number will  
satisfy this requirement  
Andrea Hansen  
on behalf of  
FanDuel  
Added to end: belonging  
to another authorized  
participant.  
Andrea Hansen  
on behalf of  
FanDuel  
Written  
LSBA  
432.755c  
Propose inserting “belonging to  
another authorized participant”  
Change  
Clarifies it is intended to  
prevent one authorized  
participant from  
transferring funds to  
another authorized  
participant  
Andrea Hansen, Written  
(Honigman LL)  
LSBA  
432.755c  
Insert “This Rule does not prohibit  
an authorized participant from  
Change  
Added to end:  
“belonging to another  
GRAY  
= comment received but did not result in a change to draft GOLD  
= duplicate comment not submitted separately  
Internet Sports Betting Public Comment – page 15