jamesedwards wrote: ↑Wed Feb 08, 2023 7:40 pmI was at ICE today, and spent some quality time with a rep from the Gambling Commission, and the Experian UK Head of Gaming. I discussed the impending government safer-gambling white paper from the perspective of a pro-gambler.
Below is a summary of what I learnt:
- There will be a clear and aligned set of specific guidelines that every Operator will need to adhere to.
- Operators will be expected to conduct a review of every new account application as well as churning through existing accounts every X period of time. There will also be a set of loss-based criteria (to be confirmed) that trigger further review. eg £1k in a day, £2k in 7 days, £5k in 3 months etc.
- The review will be facilitated by a third party Data Provider (eg Experian), who will check/compare data provided by the Customer against data on file and report back any anomalies and likely also an affordability score. The affordability score will be based on postcode, credit file, and top-line income/outgoings of bank accounts. If the customer is signed up to Open Banking then they will use this extra layer of granularity to provide a more accurate affordability score. Operators will use the affordability score to set appropriate spend limits.
- Customers will no longer need to provide wage slips and bank statements, unless required by exception. Operators' refusal to include consistent gambling winnings as income "should" be a thing of the past.
- There will be some element of single customer view to follow which aims to make sure the Customer's total gambling spend across all Operators is considered when conducting a review. There are many hurdles to overcome before anything can go live, not least GDPR. Interestingly the GC rep said they were hoping for something this year while the guy from Experian expected it to be several years down the line.
Best practise for pro-gamblers:
- Try and keep gambling withdrawals regular and consistent. eg the same value on the same day every month, as if you were receiving a salary. This will show as your 'income' in an affordability review.
- Keep as good a credit score as possible.
- Consider the affect your top-line income and expenditure may have on your affordability score.
- If you pass gambling withdrawals through your bank account to other investments/savings accounts be aware that these will show as expenditure on an affordability check. Be prepared to offer up proof of investments/savings balances if you are challenged.
- If your finances are in a particularly good state then consider signing up to Open Banking which will allow the affordability score to consider your exact gambling income/expenditure and have visibility of what you do with your withdrawals.
A year on from the above post, I met with the same chap today to discuss how things are moving forward.
Key updates:
- Everything is taking more time than initially expected due to complexities of process. But things are coming to a head and we should learn a lot more in the next few weeks.
- Trials are expected to be announced very shortly, for review in 3 months, followed by full go live in September.
- Checks will apply to new account applicants and existing accounts which trigger loss thresholds.
- The exact thresholds are still in review but will probably remain similar to what was initially proposed.
- The weighting of checks seems to be moving away from affordability (estimated income/expenditure, occupation, home ownership, postcode etc), and more towards individual vulnerability and signs of financial distress (CCJs, defaults, missed payments, high credit utilisation, high-interest short term credit etc).
- The process should mostly be seamless with no customer touchpoint required unless vulnerabilities are flagged.
- Single Customer View remains very complicated and sounds likely to be mothballed.