Gambling Review White Paper update

[WisdomOfCrowds]

I'd love to see what evidence the Gambling Commission has to show why they feel such steps are necessary.

They should be explaining that if the Government does (a) this will lead to (b). If the Government does (c) this will lead to (d).

In these assessments, they should reflect the adverse knock-on consequences of such actions too, not just show what the percentage drop in addiction would be.

Problem gambling could be stopped at a stroke if all gambling was banned but the first casualty would be the loss of thousands of jobs in the racing industry.

Is that really a price worth paying? No.

Ultimately, help should be available for those with gambling problems but the rest of us should be free to spend our own money in whatever way we choose. Proportionality seems to have got lost in all of this.

The ridiculous way that 'gambling winnings' are discarded sums up the Gambling Commissions lack of understanding of the industry and very much raises concerns that their sole agenda is to make gambling as difficult as possible.

[aperson]

"Explaining this in the consultation document, the commission states "a big win a number of years ago may well not have any bearing on risk now". Then, without any attempt at explanation, it makes the leap to determining the time period in which winnings can be considered winnings should not be years, or 12 months, but one week."

This really stood out for me and I noticed it before reading the Racing Post article. It's a point really worth making in the consultation. If they were to settle on 3 months for both checks I imagine a lot of people here would be OK. But a week is a joke, and shows no understanding of the nature of long run profitability and the variability thereof. Not only that it directly contradicts their own reasoning. They also seem to assume anyone profitable must have had a lucky big win and not have a long run edge that they can exploit day in day out.

Maybe it's a minor point but when they talk about losses and how long they should be relevant for they always refer losses of bets and not markets. I imagine in reality someone like Betfair would look at a loss in a market but again it just shows how clueless the gambling commission are.

[ShaunWhite]

Maybe it's a minor point but when they talk about losses and how long they should be relevant for

It's net deposits over a given period that are deemed to be 'losses'. No panic about losing streaks if you have the bank to take it.

[Euler]

Ideally, because of seasonality, you would say a rolling year.

[Derek27]

I wish they would explain what they mean by "spend"?

If you gamble £1000 and get a return of £950, have you "spent" £1000 or £50?

[WisdomOfCrowds]

I wish they would explain what they mean by "spend"?

If you gamble £1000 and get a return of £950, have you "spent" £1000 or £50?

Derek, it's quite simple mate, you will have spent £50 for the first 7 days, then the £950 in winnings will be chalked off on day 8, meaning you've then spent £1000.... I'm only kidding. Who knows? We haven't got a clue.

Whatever rules we end up with, they've got to be transparent and relatively easy to understand. A person should be able to work out what they're allowed to 'spend' and that calculation should match up with the bookmakers assessment too. Otherwise, everything will become arbitrary and chaos will ensue.

There must also be some right of appeal. We can't have the bookmakers being judge, jury and executioner.

[ShaunWhite]

We've been through all this before. "spent" is what you've deposited. You "spent" £1000 putting money in your account and until you withdraw it again it remains "spent". What you do with it while it's in your Betfair account isn't relevent.

[Derek27]

We've been through all this before. "spent" is what you've deposited. You "spent" £1000 putting money in your account and until you withdraw it again it remains "spent". What you do with it while it's in your Betfair account isn't relevent.

You're definition and the idiot who wrote the paper's definition may be different. If it's deposits, that means as soon as you've deposited over £1K you've spent too much!

[jamesedwards]

We've been through all this before. "spent" is what you've deposited. You "spent" £1000 putting money in your account and until you withdraw it again it remains "spent". What you do with it while it's in your Betfair account isn't relevent.

I don't believe this to be correct.

My expectation is that the thresholds will be based on losses. So when you first lose £1000 in a 24-hr period Betfair will be obliged to run a review, most likely an automated process using a credit agency to provide an "affordability score", based on debt, expenditure, bank account income etc. You'll probably know nothing about it if your score is sufficient, things will just carry on as normal.

If your score comes back too low then Betfair will need to conduct a manual review and the customer may well be asked to provide further supporting material. This is the bit we don't yet have visibility of and we have no idea how Betfair will handle this. And their form on this kind of thing is hardly encouraging! I have expressed to a couple of Betfair account managers how important it is for their "professional" customers to have as much advance visibility of the process, thresholds, and influencing factors as possible.

Assuming you pass (automatically or manually) then you will be whitelisted for 6 months before being tested again when you next lose £1000 in a 24-hr period, in which case the process starts over.

[firlandsfarm]

Did I miss it or is there no comment from GC about accounts with multiple bookmakers? Can you 'spend' (whatever that is) up to the limit with each bookmaker? In which case and assuming that a savvy punter will always try to get the best odds reaching 'spend' limits and switching to a different bookmaker may be pushing the punter into less favourable odds which could make their losses worse! In other words the Government/GC will be dictating to punters they cannot buy at the best/cheapest price. Is there any other product where the Government doesn't allow you to buy at best price?

[WisdomOfCrowds]

Single Customer View has got to be integral to all this.

Realistically, for this to work, all gambling would have to be cashless with every betting outlet having to record a person's 'spend' and 'losses' through Single Customer View.

Do we know how 'on course' cash betting is going to assessed? I think it's going to be ignored.

What about excessive purchase of lottery tickets?

Where do casinos and slot machine venues fit in?

Many of those with problems are likely to find ways around any restrictions. Many of those who are restricted but don't have problems will simply give up.

[Michael5482]

Single Customer View has got to be integral to all this.

Realistically, for this to work, all gambling would have to be cashless with every betting outlet having to record a person's 'spend' and 'losses' through Single Customer View.

Do we know how 'on course' cash betting is going to assessed? I think it's going to be ignored.

What about excessive purchase of lottery tickets?

Where do casinos and slot machine venues fit in?

Many of those with problems are likely to find ways around any restrictions. Many of those who are restricted but don't have problems will simply give up.

I can answer one of your questions. The National Lottery is covered by different legislation so that's why it's not included in the white paper or any gambling reforms. There's no plans to review the current National Lottery legislation.

This what the Right Honorable Stewart Andrew on behalf of Department for Culture, Media & Sport informed me. Other than that he didn't have much to say, didn't answer anything else mainly because I think they have no idea with the practicalities of what there doing never mind implementing any of it.

[weemac]

Never mind 24 hours: a £1,000 loss is to be expected, even almost guaranteed for many users, within 24 minutes when an exchange crashes.

When that happens - and it will - game over.

[aperson]

Maybe it's a minor point but when they talk about losses and how long they should be relevant for

It's net deposits over a given period that are deemed to be 'losses'. No panic about losing streaks if you have the bank to take it.

I hope you're right on this Shaun. The consultation when talking about defining losses for the "financial risk assessments" states;

"2. For the purposes of the thresholds at paragraph 1:
b. a net loss is defined as the stake and loss within the relevant period of deposited funds with a particular operator. This does not include
the following:
the loss of accrued bonus funds, or
the loss of restaked winnings during the relevant time period.
c. a net loss may also take into account the net position of a customer who was in an overall net positive position in the period immediately
preceding the relevant time period. A period immediately preceding a relevant period means:
7 days for a relevant period of a rolling 24 hours, or
90 days for a relevant period of a rolling 90 days."

This seems to back up what your saying that it is deposits that matter, however table D on page 48 of the document doesn't mention anything about depositing money in the context of losses, while table C on the preceding page does.

There's also something saying "The proposed basis of the thresholds for gathering information as part of both financial vulnerability checks and financial risk assessments is monies staked and lost during the relevant time period." No mention of deposits there.

This example given also mentions withdrawing then redepositing so hopefully that is the relevant thing;

"A further example of this might be that a customer places £400 on online slots with an online gambling operator and wins £5,000 (including initial stake).
They withdraw those winnings. A few days later, the Cheltenham Festival begins and the customer deposits £1,000. They stake and lose all of the £1,000
during a 24 hour period. Although in that 24 hour period the net loss is £1,000, the customer still has a net positive position of £3,600 over the week, and
this would not therefore trigger a financial risk assessment under the current proposals. In some cases, there may be notable changes in staking behaviour
or other indicators of harm and a customer interaction could be appropriate."

Also what is the meaning of deposited? It seems likely the are referring to money deposited from a bank account to a betting operator. But can't it also just refer to money held in an account? "I have money deposited with Betfair"

If it sounds like I'm overthinking this it's because I clearly am

[ShaunWhite]

I hope you're right on this Shaun.

I wouldn’t lean too heavily on the views of random strangers

If in doubt then start a dialog with Betfair, they're the most important link in your supply chain so that's a given anyway really. Don't get drawn into the idea that they're the enemy, ours is a B2B relationship with them and 'professionalism' works both ways.