Gambling. Who decides what’s affordable?

The big news breaking in the gambling sector, is the United Kingdom Gambling Commission move to establish ‘affordability thresholds’ for customers betting with UK operators. From next may customers will be required to provide evidence of affordability if they with so gamble in excess of state-imposed spending limits, which could be as low as £100 a month!

Remember, folks, this is a rolling check. People’s gambling habits change by the month. Don’t imagine you can prove you’re not a drug dealing peddler by the provision of one bank statement! In the brave new world of regulation EVERYONE is assumed to be a money launderer

I don’t know about you, but this Big Brother approach scares the pants off me. An official in Birmingham instructing how much I spend every month on my hobby? At what stage did their policy advisors decide they should embark on policy more suited to China?

And to make it work will ultimately require linkage between operators. The sharing of your financial data, otherwise known as the ‘single customer view’ mandates operators to ‘pool’ information about their customers. Rival companies being asked to share confidential information with each other on their customers, and their activity. How does that go when you have a good customer, who loses? You’re going to share that with Bet365?

And yet, the major betting companies dutifully sent along their compliance officers to consider such plans, with commission officials. Giving false credence to plans drawn up by 5 year old zealots.

This represents, of course, a precedent for state-controlled spending. It also assumes that gambling presents a special case, as distinct for example to drinking or smoking. Neither which is subject to such intervention. Both of those addictive products considerably more harmful, but no checks because politicians know such moves would be deeply unpopular, and of course both politicians, and anti gambling lobbyists all drink! It’s more about self interest than common sense

Far easier attack gambling when half the population don’t gamble at all. A ready-mix pool of disapproving busy bodies. There’s nothing like the curtain twitching cretinous git, shaking their finger at another, from the anonymity of Twitter, scribing in their underpants. ‘I don’t gamble’ they say. Or the ubiquitous ‘I haven’t had a bet for 3 weeks’ – the stuff of anti gambling BOTS which fester the world wide web, influencing opinions

Gambling operators certainly deserved the rub they had from critics, during the era of fixed odds betting terminals in betting shops. Voracious machines they were. Combine that with voluminous advertising from gambling companies and it wasn’t hard to agree we had crossed the line here. Times have changed however, and I firmly believe the vast majority of gambling companies have cleaned up their act. Responsible gambling messages not only abound, but the message is actually evidencing results.

Affordability checks won’t save a single individual from problem gambling. Not one. But it will seem as if the regulator is ‘doing something.’ That may sound glib, but there is absolutely no evidence that such measures will have any meaningful effect, other than to shut down gambling for millions in the regulated market

Opposition to such plans, from bettors who refuse to provide data, quite reasonably, has not been considered by those who dreamed up such policies. They dismiss the rights of individuals to bet, if, that is, they refuse to heave up their financial data for all to see.

That would include, of course, government agencies. The taxman.

There have been some eye watering fines on gambling companies, imposed by the Commission, with regularity. I am surprised however that the level, and number of these. It hasn’t struck those dishing out fines with apparent glee, that perhaps the scale of ‘non compliance’ is down to human factors. Many of the companies fined have millions of customers, all subject to these new rules

How difficult would it be to spot the ones operators reasonably miss? Especially when one considers the new breed of ‘give me my money back, I was vulnerable’ fraudsters. Again ill considered by regulators.

Remarkably the incredibly vague basis for regulatory action for fines has not been challenged by operators before now. A Commission emboldened to continue with imposition of fines based enirely on their own ‘judgement call’ on whether an operator had been seen to do enough, because noone, as yet has marched them into the High Court for judiciary review.

The regulations are, quite simply, unworkable. A roadmap to fines and lost licenses

Take for example expensive ‘affordability background checking tools’ The commission now demands we pay for these. Equally they tell those same operators ‘not to rely on affordability background checking tools.’ Stupid, right? That’s because they absolutely know they don’t work.

Why wouldn’t you challenge infantile regulations? It’s simple, all the time you’re appealing enforcement, you’re sitting without a license. And the UKGC marks its own homework. It becomes a commercial decision for the operators. Pay up, and keep your license, or spend months fighting them in court, earning nothing. It makes better business sense to smile and pay up

In the short term, of course.

There are two basic codes in play here

Rule 1. Consumers are fully aware there’s no law mandating they have to accede to these checks

Rule 2. Consumers are fully aware there are black market alternatives, just a click of the mouse away

Under the proposals, we would have public officials looking into your spending habits, and determining how much is affordable in your gambling every month. The choice of the individual to spend, as he or she sensibly determine, is being marginalised. We are being given our pocket money by the state.

One can only imagine the mind-boggling calculations which will be required. The over estimation of areas of spend deemed for ‘good causes’ as set against spending on our addictions, it brings in the question of morality, with those against gambling determining whether another can, or should be gambling.

Is gambling somehow sufficiently different to warrant such actions by the state? Is it desirable, or just the slippery slope to officials to tell us how much we can spend on drink, going to the football, or other leisure activities. Once you allow these people control over your life, a dangerous precedent has been set. One should recall that of late credit cards were banned as a method of paying for your wagering. It was an important step to ensuring people only bet as they could afford. Highly successful messaging, encouraging people to control their spend is actively employed by operators, at great expense. It has lent itself to universally low problem gambling levels. Just 0.2% of the population

Why is such success being ignored? Why is the general public being told what they can, or can not spend their money on, and how much?

Has the gambling sector and its customers so failed that is deserving of such treatment? Well in an era of responsible gambling tools and pro-active interventions, I think the companies have been entirely successful implementing fair policies on its customers. Things are firmly moving in the right direction, I see little necessity for a Gambling Commission to intervene so destructively in people’s lives in order to be considered relevant. Especially in the eyes of a media, chasing sensationalist ‘oh dear me’ stories. There’s always a temptation by regulators to be making draconian moves in support of the cluck cluck brigade

As for the consumer? Why does the Comission imagine they’re going to happily share their payslips and annual accounts with operators? In the knowledge that information has to be pooled with other operators and government departments? So far, the answer is a resounding no from consumers. Many have simply turned off their gambling. Turnover in the industry down by not less than a third.

Regulators at the gambling commission have worked themselves into a self-interested approach. Revered by those who oppose gambling, despite clear and incontrovertible evidence that such measures simply don’t work. Most especially in the online world where companies have millions of customers. How many ‘intervention calls’ is it humanly possible to make? It is frankly astonishing that regulations have been set down which fail to respect the hearts and minds of ordinary people.

Commission thought is dominated by a “prevailing vision” which seals itself off from any empirical evidence that is inconsistent with that vision.

And if, as it should, the single customer wallet idea fails the information security test, individual customers will be tied to one operator for their spend, or avoid reasonable withdrawal of winnings.

Looking at the inability of so many companies, with impressive compliance departments, companies like Entain for example. Fined relentlessly by the gambling commission, for the same failures. Now under investigation by the Australian regulators for AML failings. At what point do governments or judges intervene to restore basic common sense?

It seems to me, that whilst these companies sold themselves to these new measures, because they saw a golden opportunity to collect, and profit thereby, from unprecedented levels of data from customers, have scored the biggest corporate own goal in history.

They signed up to measures without thought for the rightful views of their customers. They signed up to profit from the data. Only to find the measures they agreed to implement (in the absence of primary legislation by the way) as totally unworkable. The consequences for such companies indeed grave. Worse though for medium and small gambling operators. They cannot survive the slashing of their customer base and turnover in a scramble to ‘comply.’ The hefty cost attaching to affordability tools, which don’t work. Extra staffing. And let’s face it, clients simply saying no.

Depressingly as a small to medium scale operator, I’m painfully aware companies like my own, as so ill considered by a commission mired in dogma. Pressing a notably socialist agenda, because it keeps the impressive budgets, and funds their anti gambling chums. They make grand speeches telling everyone how many fines they’ve issued, treat the operators like children who have made no effort. All in transparent effort to placate the anti gambling community. Embarked on the destruction of the very industry they represent.

If I sound angry, or exasperated, it’s because I am. I’ve never seen an industry butchered so casually, by those who would see it die. The Gambling Commission undertook extensive consultation on affordability measures. 16,000 responded, overwhelmingly against the plans, and were ignored. People are having their gambling account closed, many who’s accounts have existed, without issue, for decades. Now they are either unwilling to provide the financial data, or simply unable to adequately prove their worth. The Commission pays no regard for the likely millions who will see their passtime dissappear in such way. Large gambling companies evidently profit by the data, selling the information on, and using the information gained to close unprofitable accounts. And the Commision ignores this. Very clearly the black market is the beneficiary of plans designed to throttle gambling in the UK, and they deny its importance. And many sports, notably horse and greyhound racing, will see their funding and sponsorship slashed. Industries which are part of our heritage. Yet they tally on.

I know how I feel about all this. I was recently asked by Bet Victor for a copy of my payslip. Whilst I haven’t had one of those for years, the prospect of sharing my worth with the operator’s staff in Gibraltar isn’t one I relish. I closed an account I’d had for three decades. There isn’t a single operator I would share my data with. Entain, for example retain your personal data for 7 years, ponder that one for a moment..

The information commissioners office offers no protection from companies domiciled abroad. Be aware all the soldiers are lined up against gamblers

I’d rather have my bets on the black. But for the time being, I’ve simply stopped betting.

I’m not alone

Geoff Banks

http://www.geoffbanks.bet

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