it’s ok to lie- in a good cause!

Last year, the Gambling Commission wrote to the Betting and Gaming Council (‘BGC’) to ask it to stop referring to Health Survey statistics. It now transpires that it did so on behalf of the activist organisation, Gambling with Lives (‘GwL’)

Great Britain: Politics – is something rotten in the state of the West Midlands?
A novel solution to addressing ‘problem gambling’ was briefly glimpsed in parliamentary debate last week – the imposition of strict gambling controls on people in the West Midlands; leaving those living elsewhere in England to flutter as they see fit. 

During Wednesday’s Westminster Hall Debate on Gambling Harms, Sarah Coombes MP (Lab, West Bromwich) claimed that there were “168,000 people in the west midlands who say that problem gambling is devastatingly affecting their lives” and the lives of family members. Seconds earlier, Ms Coombes’s colleague, Jim Dickson MP (Lab, Dartmouth) had told the chamber, with the authority of the now defunct Public Health England (‘PHE’), that an identical number of people in the whole of England were experiencing ‘problem gambling’. Taken together, these statements appear to indicate that gambling may only be a problem for people living in the environs of Wolverhampton, West Bromwich, Walsall, Coventry and Birmingham (home of Britain’s Gambling Commission).

No sooner did this regional lockdown ‘public health approach to problem gambling’ hove into view, than it started to dissolve under the weight of wider MP interventions. Dawn Butler MP (Lab, Brent) argued that there are around 20,000 ‘problem gamblers’ in her constituency alone; and Cameron Thomas MP (LibDem, Tewkesbury) claimed (incorrectly) that PHE had put the national figure at 246,000. Other MPs insisted that there were in fact 1.3 million or more ‘problem gamblers’ in Great Britain – claims that rely on the misuse of official statistics, as defined by the Gambling Commission. 

In general, the debate was a poor advertisement for parliamentary discourse. One Liberal Democrat MP suggested that supporters of Liverpool FC would find themselves “unable to talk to their friends and family about the losses and their addiction” as a direct result of Ladbrokes becoming the club’s official betting partner; while Butler of Brent claimed, without providing a shred of evidence, that gambling was “more addictive than heroin”. According to National Health Survey (‘NHS’) estimates, the rate of DSM-IV gambling disorder lies between 0.1% and 0.2% of the adult population, compared with 3.1% of people showing signs of drug dependency and a similar proportion with mild or severe alcohol dependency). As flies to wanton boys are statistics to MPs; they use them for their sport.

Only one participant – Labour’s Jake Richards, Member for Rother Valley – appeared to notice what was going on, observing that, “we have heard a lot of statistics in this debate, but they vary because we just do not know what we are dealing with”. Mr Richards was half-correct in his diagnosis. The real reason for the confusion is that prevalence rates are based on responses to self-report surveys – and estimates vary significantly depending on how these are conducted. NHS Health Surveys have historically been conducted in-person, an approach considered to be the “gold standard” in terms of yielding accurate results (Sturgis & Kuha, 2022). The Gambling Commission’s Gambling Survey for Great Britain (‘GSGB’) is conducted online and is less likely to be reliable due to low response rates and topic salience bias (ibid.). GambleAware’s Annual Treatment Survey uses self-selected online panels (surveys of people who actively choose to spend their time filling out questionnaires) and, while these panels may have their uses, providing reliable population-level figures is not one of them.

The chief executive of the Gambling Commission, Andrew Rhodes recently lamented that arguments over which survey is more accurate distract from what really matters. He is correct – but this is a situation of the Commission’s own making. Repeated attempts by the regulator to undermine public confidence in Health Surveys in order to shore up the defences of the GSGB reflect poorly on those involved and have prompted activists to describe the use of NHS statistics as “a con”. If it is a con, then it appears that both HM Government and HM Opposition are in on it. In last week’s debate the shadow gambling minister, Louie French (Cons, Old Bexley and Sidcup), and the DCMS minister, Stephanie Peacock (Lab, Barnsley South) chose statistics from NHS Health Surveys rather than the GSGB. 

Last year, the Gambling Commission wrote to the Betting and Gaming Council (‘BGC’) to ask it to stop referring to Health Survey statistics. It now transpires that it did so on behalf of the activist organisation, Gambling with Lives (‘GwL’). On 2 October 2024, GwL wrote to the Commission to ask whether it would take action against the BGC for continuing to use NHS figures (which have the status of Accredited Official Statistics) in preference to those from the GSGB (which don’t). Eight days later, the Commission did precisely that – copying and pasting the GwL objections into an email to the trade body. It did so despite the fact that the BGC’s actions do not constitute misuse; while turning a blind eye to cases of actual misuse. The regulator will presumably now also take the DCMS and shadow minister to task for the ‘non-crime statistics incident’ of believing the NHS.

The publication of the NHS Adult Psychiatric Morbidity Survey and the GSGB 2024 this summer will put another couple of ‘problem gambling’ figures into the mix; and these will be supplemented next year by the Health Survey for England – unless the Commission intervenes (it has told the Department of Health and Social Care that it wishes to ‘manage’ statistics that compete with its own). The chances of clarity or coherence breaking out any time soon seem slim. 

Regulus Partners – February 2025

the growth illusion

UK: industry stats – the growth illusion
 
In September 2019 we wrote a blog titled ‘the myth of growth’, using UK data to show that gambling had not grown materially in real terms for twenty years. A lot has changed in five years: online gambling has grown by another 30% and lockdowns have transformed the way people consume entertainment in a lasting way. However, fundamentally nothing has changed: people are spending less on licensed gambling in Great Britain now than they were in FY19. There are a number of important reasons for this which should shape domestic policy and international comparison as well as UK-facing operations management.


 
The Gambling Commission’s annual industry stats for FY24 (to March) look optically robust. The top five online group operators, for which the Commission publishes monthly revenue each quarter, have continued to lose share as expected, meaning underlying growth was higher. In the more consolidated betting market, top-five (really 4) share loss was 0.7ppts to 86.7%, which meant betting licensees outside the top operators grew by 10% YoY while the top operators grew by just 3%. The difference in gaming was even more pronounced, with 3.0ppts of share lost to 67.5%, meaning gaming operators outside the top five grew by 20% YoY, vs. 4%. While there are some operational reasons for this difference in performance (biggest isn’t always most innovative and at least two of the top five have suffered from self-inflicted problems caused by weak leadership), we continue to believe that the biggest reason for the shift is an uneven regulatory landscape. In our view, the £5 slots limit which is now been brought in will help to level the regulatory landscape down (something many of the top five advocated for on the basis their performance against the black market wasn’t being judged), thereby pushing a material volume of future underlying demand growth into the black market. Stronger-than-visible growth concentrated principally into the gaming long-tail is a double-edged message for future growth and channelling therefore.
 
UK online growth has accelerated into calendar 2024 (see Financial Update on Q3), in part because of comps but also because of a dangerously misunderstood phenomenon: the lag effect of money printing and inflation. It has been a while since a gambling operator tried to blame a ‘cost of living crisis’ on poor operational performance. The real reason for the 2022 economic shock (which had a negligible impact on gambling) was a hangover from frantic state money printing during lockdowns; these have now washed through, but average salaries in 2023 were 15% higher than in 2019 (note the gambling sector is not 15% bigger), broadly based salary increases are still coming through (c. +5%), while the government continues to use deficit spending to fund the public sector, adding to inflation risk going forward. When the economy was sclerotic, but inflation was consistently c. 2%, then 4% growth meant something; with inflation likely to remain volatile regardless of central bank predictions, absolute growth is far less relevant than relative growth. Largely due to wage increases and inflation, we expect high single digit growth for online gambling in the UK subject to black market leakage, but we expect a relative decline in gambling revenue – with landbased gambling bearing the brunt.
 
FY23-4 marked a period of optical landbased recovery, with all landbased sectors except the struggling National Lottery in growth. However, while landbased sectors in total added a net £63m to Britain’s gambling industry (excluding pub gaming machines, likely down), online added £471m, or 88% of all growth. This is a clear case of channel shift at work in ‘frog boiling’ form: landbased sectors are relieved to see some absolute growth but are losing relative market share. Again, inflation is an enemy in disguse – revenue goes up as businesses become less relevant and more fragile.
However, three long-term consumer demand trends are much more sticky than channel shift.
 
The first is that the National Lottery has failed to maintain early levels of consumer interests (note, now under new ownership). This has been compensated for in part by the strong rise of the Charity Lottery sector, but this is a complementary rather than competitive product: nothing can replace a well-run lottery in terms of mass market customer engagement.
 
Second, is the slow rise of slots content as the digital experience proved more flexible and increasingly more appealing than Britain’s stunted landbased offer. The new online stake restrictions are likely stymie and probably reverse this trend, in our view.
 
Third, is the consistency of betting: football has overtaken horseracing in absolute revenue (by only 15% in FY24 after a generation of predicted doom for racing from betting commentators who preferred opinion to evidence), but betting maintains remarkably consistent in terms of revenue mix over twenty-five years despite all the hype over growth. The relative growth in slots has therefore partially mitigated the relative decline of National Lottery revenue to keep gambling expenditure as a proportion of Household Disposable Income relatively stable at c. 1% over 25 years (note, FY9 was low because of the implementation of the Smoking Ban, the loss of S16/21 machines, and the onset of a global recession). However, an underlying decline can be detected and if the National Lottery is not turned around then it is likely to become more visible, in our view.For all the hype about a changing landscape, very little is changing in terms of underlying consumer behaviour other than channel shift. British consumers are, if anything, gambling less, albeit with revenue concentrated in a smaller number of participants.
 
The growth visible in the FY24 industry stats offers more to be concerned about than relief for a recently battered industry. For the British gambling industry to have a future that is not a story of increasingly pronounced relative decline temporarily disguised by inflation, it needs to achieve ‘just’ two things, in our view:
 ensure the legislative and regulatory framework keeps high value players in the licensed ecosystem; the opposite is currently being achieved (note, London has already largely lost a c. £150-300m annual high roller casino segment taxed at a marginal rate of 50% – sufficiently specialist to disappear largely un-noticed) create products that have genuine mass-market appeal (the Charity Lottery sector is the unsung standout success story here) 
These two drivers of industry sustainability sound simple, but they are proving dangerously elusive to deliver.
 
UK: RET policy – money, money, money: why the levy is far from funny
“What operators rightly hate being told is that they ought to be contributing more than they are to RG programs without being told what they are actually paying for. They then readily form the suspicion that most of their money is spent on the cost of employing an army of hostile public and quasi-public officials. These officials are then perceived as having as their primary concern not the alleviation of suffering but the retention or expansion of their own jobs. This in turn, can be suspected of leading to the proliferation of regulations that have little or no empirical basis.”
Professor Peter Collins, 2003
 
The decision to impoae a safer gambling levy on licensed gambling operators in Britian is by far the most ill-considered of the policies contained within the previous British Government’s white paper on regulatory reform. It is also likely to be the most significant in the longer term, with far-reaching consequences for the functioning of the gambling market, harm prevention and policy coherence.  In this article, we set out why we believe the levy is bad policy, what its outcomes are likely to be and how some of its worst consequences might be mitigated.
Why the levy is bad policy
The imposition of the ‘safer gambling’ levy has been dressed up by proponents as self-evident. After all, what could be more reasonable than requiring gambling businesses to fund the treatment of people suffering gambling disorder as well as work to better understand harm and to prevent its occurrence? The polluter, as the trope goes, should pay. 
 
The problem is that is not how our society works. In the normal world, businesses pay taxes at rates set by HM Treasury, which are used to fund public services, including healthcare, research and education. Charities, community groups, and private businesses address gaps in what the state is prepared to fund. The safer gambling levy breaks this model by requiring treatment and other costs to be funded directly from the expenditures of gambling consumers. In so doing, it sets a precedent for levies to be funded against general retail businesses (to recover costs from compulsive buying behaviour), internet providers (internet use disorder), coffee shops and teahouses (caffeine use disorder), pubs and bars (alcohol use disorder), and restaurants (obesity) among others. Followed to its logical conclusion, it proposes a healthcare system paid for by citizens according to their lifestyle choices. There is a dark and unsettling logic to this if applied consistently – but no obvious justification for its imposition on gambling consumers alone.
 
Combined with the draft guidelines of the National Institute for Health and Care Excellence, the levy will make treatment providers dependent upon the NHS through the stipulation that they may not seek funding or engage with gambling businesses – effectively penalising those organisations that support the current regulations. One consequence of this model is that – contrary to the spin – the levy increases the dependence of treatment and harm prevention providers on the industry (as a number of public health figures have already observed). In replacing a voluntary system of funding with a tax, the government will tie financing to industry revenues. If consumer spending with licensed operators reduces, so will funding. Organizations lobbying for tighter restrictions on gambling consumers (or higher taxes on operators) will do so in the knowledge that new measures may negatively impact their own finances. The Department for Culture, Media and Sport has forecast a net market contraction of 8.2% as a result of its white paper reforms but this is speculative, and the impact could well be greater (particularly if modernising reforms for landbased operators are delayed). There is a very good chance that the levy brings in less than expected, which would be a major problem if the levy was underpinned by an actual budget or assessment of need. 
 
The levy has been justified by reference to two factors: concerns over the perception of research independence under current arrangements (regardless of whether those perceptions are grounded in fact)the fact that some operators have contributed derisory amounts under the voluntary system 
The first suggests that government policy is now dictated by perception (which is in turn influenced by lobbying) rather than actual evidence. The second is a red herring – no gambling business of any scale has been guilty of under-funding; and the parsimony of the few is poor justification for the creation of a new tax, although it does justify targeted intervention.
 
The levy is also likely to be wasteful. HM Revenue and Customs already collects c. £3.5bn in specific gambling duties (in addition to general taxes less Output VAT) from the gambling industry, under direction from HM Treasury. The levy, however, envisages the establishment of an entirely new tax system, designed to collect roughly £100m under a non-fiscal authority, overseen by a levy board. While a Levy Board works well in racing, it is independently supervised with formal betting input (a board seat) and levy collected pays for clearly defined common interest objectives, neither of which apply to the safer gambling levy (although they could). Without these governance guard rails, the potential for waste, error and fraud is enormous, in our view.
 
The suggestion that the levy Is ‘smart’ appears to be Ir of those Orwellian conceits that has come into vogue in recent years (such as the idea recently expressed in the Lancet that state control is freedom). The logic for determining who pays what – including the exemption of the National Lottery – appears non-existent beyond the results of a sector and product popularity contest among the levy’s engineers. The application of a 1.1% rate to online gambling is justified by the idea that: i) it is associated with higher rates of ‘problem gambling’; and ii) remote operators have lower operating costs. The first is solely true of online gaming and is not true for betting – the ‘problem gambling’ rate for online sports bettors in the most recent Health Survey for England was just 1.2% (albeit it is dangerous to leap to causality given that PG rates are principally set by a product’s popularity). The second is true for some remote operators some of the time – but not for the many others: plenty of landbased businesses have higher margins than plenty of online businesses and the channel has little to do with the outcome. More generally, the suggestion that efficiency should be penalised hardly fits with the Government’s growth agenda. There is a reason why tax policy is generally set by finance ministries and not by regulators. Ironically, based on the premise that online gambling operators are able to pay more because of higher margins, they should be able to offset any margin-reducing tax increases with a reduced Levy rate, though we doubt the logic will be applied so robustly.
 
The levy is not so much smart as unfair. To provide one example, operators of gaming machines in bingo clubs and arcades are required to pay; but pubs and social clubs providing precisely the same machines are not. Further, the way that the Government has presented the tax is misleading because it is levied on suppliers (at 1.1%) as well as B2C operators (at between 0.1% and 1.1%). The effective rate of the new tax will therefore be applied inconsistently and at rates higher than claimed since we do not believe a recoverability mechanism (ie, the way VAT works outside the gambling sector) has been proposed – and it would make no sense if it did since gambling suppliers exist to serve gambling customers, who are being taxed through gambling operators. There is an additional irony that this highly complex levy, with multiple and arbitrary rates across different gambling products and channels, comes as the government simultaneously seeks to copy another of the previous government’s soundbite-driven schemes, since it will: consult next year on proposals to bring remote gambling (meaning gambling offered over the internet, telephone, TV and radio) into a single tax, rather than taxing it through a three-tax structure. This will aim to simplify, future-proof and close loopholes in the system. Perhaps someone needs to tune the governments’ wireless.
 
What can we expect next?
It has been claimed that the ‘safer gambling’ levy will result in greater resources and more certainty for harm prevention services, which would be a good thing. It will probably (depending on events) bring in more money than under the voluntary system; but that is not the same thing. For one thing, it will involve the creation of new administrative bureaucracy for which no published budget exists (a major lacuna) and, given the way that the state spends money, is unlikely to be either modest or well governed.
 
Half of the funds left over after as yet unknown administrative costs will be allocated to the perennially over-stretched National Health Service, which will almost certainly prioritise its own services over the requirements of the Third Sector. The charities, who have in some cases been effectively and diligently providing treatment to people with gambling disorder for more than half-a-century, will now be required to bid for the funds that were previously theirs. Several harm prevention organizations have already started to shut down programmes (including training for licensees) and making members of staff redundant (up to 150, if reports are correct). Made dependent on the state, treatment providers may find that they are required to fall in line with radical public health ideologies, such as the belief that adults bear no responsibility for their actions and harm is solely the result of exposure to ‘addictive products’. This denial of human agency breaches a core tenet of psychotherapy and has the potential to cause enormous damage to vulnerable people by institutionalising victimhood.
 
A further 30% of net funds will be allocated to the conveniently vague domain of ‘harm prevention’. Rumour suggests that the commissioner will be either GambleAware or OHID. The former has already called for mandatory health messages on all gambling advertisements (including for the National Lottery and horseracing); while the latter has manufactured suicide statistics and proposed ‘plain packaging’ (no colours, logos or images) for all gambling products. GambleAware may be slightly less illiberal than OHID, but both have trouble distinguishing between harmful gambling and gambling – a blind spot that ultimately leads to long-term prohibition via a medium-term funding bonanza. We can only imagine what they might get up to with up to c. £30m a year.
 
The final 20% is allocated to research under UK Research and Innovation (‘UKRI’). It is to be hoped that UKRI demonstrates greater scientific rigour and moral neutrality in commissioning research than the Gambling Commission, GambleAware, or OHID. The risk, however, is that it becomes a slush fund for anti-gambling activism that will be used not just in Britain but internationally to campaign for the prohibition of gambling once all the funding that can be extracted has been. In recent years, a profusion of clearly agenda-driven journal papers and reports of low academic quality have been published – often as a consequence of Gambling Commission or government funding – alongside a very small number of high-quality studies. There is a risk that the levy will be used to fuel a propaganda engine for an international anti-gambling movement. The reason why activists have prioritised the levy above all other matters is because they know just how large the prize is – up to £20m per annum.
 
For all the high-minded rhetoric, the levy seems destined to result in disruption to treatment services, increased stigmatisation of gambling as a legitimate adult pastime, and the production of misinformation on an industrial scale which politicians and bureaucrats seek to lack the discipline or inclination to critically assess. 
 
What should be done now?
The safer gambling levy may be bad policy, but it is now policy, and it will come into force next year. The question is therefore what ought to be done by licensees and others. We make three suggestions:
 Governance – there is a good chance that money raised by the levy will be used inefficiently, unscientifically and inappropriately. The process for how funds are allocated and assessed therefore requires close public attention. Scrutiny should be applied to the levy’s governance arrangements and the process of evaluation in 2030. Given what has gone before, it would be naive to trust those responsible to mark their own homework Continued support – a large number of harm prevention organisations now face uncertain futures. It would be a mistake, in our view, for operators to cease their support for charities and other harm prevention organizations once the levy kicks in even at the cost of ‘paying twice’. Several important programmes now face defunding (in addition to those that have already fallen by the wayside); and operators need insights from these groups in order to inform their own ‘safer gambling’ initiatives – for the sake of disordered gamblers and the sustainability of effective treatment, a distinction must be made between the sunk cost of a pollicised levy and productive expenditure on mitigating the harms that the licensed gambling sector does cause or exacerbate Critical analysis – the levy is likely to result in an expansion of anti-gambling activism, particularly in the domain of ‘research’, which will reach into other jurisdictions. To date, the licensed gambling industry in Britain and other jurisdictions has done an extremely poor job of assessing and (where appropriate) rebutting bad science. It is critical that it develops both the technical capability to scrutinise research and the willingness to call out misinformation (including misinformation which seems to support the industry). There is a good case to be made for building this capability on an internation basis.Ironically, the new levy is at least in part the unwitting handiwork of some of the largest licensees in Britain’s gambling industry whose lobbying made the policy almost inevitable. The Betting and Gaming Council’s endorsement of the policy was unfathomable to us at the time and continues to be so; it makes a lobbyist’s job much easier in the short-term but the industry’s job far harder in the long-term. There is a lesson here which the industry should now be able to perceive – policymaking is difficult in this space; and the pursuit of easy fixes is liable to end in disaster. Unfortunately, the government may have to wait a little longer before it arrives at this epiphany.  

Regulus partners
Disclaimer; The analysis provided in this report represents the opinions of the authors. Any assessment of trends and change is necessarily subjective. The information and opinions provided herein are not intended to provide legal, accounting, investment or policy advice, nor should they be used as a forecast. Regulus Partners may act, or have acted, for any of the companies and other stakeholders mentioned in this report.

Abusing NHS statistics

UK: ‘We don’t need no thought control’ – why the Gambling Commission should leave NHS stats alone

In recent years, the Gambling Commission has been on the receiving end of criticism from all sides of the so-called gambling debate. Last year, the MP, Sir Philip Davies declared that the regulator was “out of control”, while the Social Market Foundation has described it as “not fit for purpose”. The Commission has not publicly endorsed either of these views – or advertised them on its website – presumably because it considers them to be untrue as well as unflattering. Last month, however, the Betting and Gaming Council (‘BGC’) was asked by the Commission to make claims about the prevalence of gambling harms which are probably false – and to publish them on its website.



In an email recently released under the Freedom of Information Act, the Commission wrote:
 
“We’ve been keeping an eye on use of GSGB [Gambling Survey for Great Britain] data and use of figures as the official statistic. We’ve noticed that BGC still refers to previous stats, it’s not a misuse of stat issue but we’d be keen for you to start using the official figure moving forwards.”
 

This invitation was politely declined by the BGC on the grounds that it has greater confidence in NHS statistics (which are accredited by the UK Statistics Authority) than in the Commission’s (which are not). The BGC is similarly unlikely to profess that its members are (to borrow from Blackadder) ‘head over heels in love with Satan and all his little wizards’; but the Commission can always try.  

 
The regulator’s entreaties should be considered in the light of the following circumstances:
i) the balance of evidence indicates that the GSGB substantially overstates levels of gambling and gambling harm in Britain
ii) the Gambling Commission knows this
iii) in asking the BGC to go along with the charade, the Commission is acting, at best, inconsistently
iv) the GSGB is already being used (and misused) by activists, seeking to reopen the Government’s Gambling Act Review.



We examine each of these points in turn.  

 
1. The balance of evidence
The GSGB may be the new source of official statistics, but this does not mean it provides a reliable picture of gambling prevalence in Britain. To believe that it does, it is necessary to subscribe to the following:
        i.            Every single official statistic on gambling and harmful gambling produced over the last 17 years – by the National Health Service (‘NHS’), the Department for Culture, Media and Sport and the Gambling Commission itself – has been substantially wrong
      ii.            The NHS has serially misreported the prevalence of health disorders in general – and continues to do so
    iii.            Audited data on actual customer numbers using licensed operators is incorrect (or there is a massive black market that failed to show up in previous studies and of which the Commission was previously unaware)
     iv.            The opinion of the independent review (conducted by Professor Sturgis of the London School of Economics) that the GSGB may substantially overstate true levels of gambling and gambling harm is misguided
 

To believe that all these things are true (and to cajole others into professing the same) requires more than blind faith and a sheriff’s badge. Tellingly, the Gambling Commission does not have very much confidence in the GSGB itself; and has issued guidance that key results should be used “with some caution” or not at all.


2. Withholding evidence (again)
The Gambling Commission’s defence of the GSGB has largely consisted of attacks on NHS statistics, claiming that they have under-reported rates of ‘problem gambling’. While scrutiny is important, undermining accredited official statistics on health is a step not to be taken lightly. Some sort of evidence is required. For this, the Commission has relied upon a 2022 study which claimed social desirability response bias (ie, the fact that people sometimes answer survey questions in what they consider to be an acceptable rather than accurate fashion) caused under-reporting of ‘problem gambling’ in NHS surveys. This ‘evidence’ was thoroughly debunked by Professor Sturgis as part of his independent review – but for reasons known only to the Commission, the analysis was suppressed. It required a Freedom of Information Act request to secure the release of the information. This is not the first time that the Commission has prevented publication of critical evidence – having previously withheld survey data on customer opposition to affordability checks. Disclosures also reveal the Commission was warned by its lead adviser, Professor Heather Wardle, that social desirability response bias was likely to be a “marginal factor” in explaining differences between the GSGB and Health Surveys (and that the dominant factor of topic salience bias resulted in over-reporting in the GSGB). 
 
3. Two-tier thought policing?
In recent years, various parties have taken highly selective approaches to the use of ‘problem gambling’ statistics – often ignoring official estimates in favour of more convenient alternatives. Last year, the National Institute for Economic and Social Research did so in a report funded by a Gambling Commission settlement – using a rate two or three times higher than the official statistic. There is no suggestion that the Commission objected to this. In public consultations, the Commission itself relied on ‘problem gambling’ prevalence rates from the 2018 Health Survey for England rather than lower figures from the 2021 edition (ie, the official statistics at that time). In a speech in Rome last month, the chief executive of the Commission, Andrew Rhodes criticised those who wished to “turn the clock back” to previous official statistics, and in the very same speech cited participation estimates from ‘previous official statistics’.

 
4. The weaponisation of research
The importance of all of this has been amply demonstrated in recent weeks. Both the Institute for Public Policy Research and the Social Market Foundation cited the GSGB’s inflated rates of ‘problem gambling’ in support of demands for ruinous and self-defeating tax rates (as high as 66% of revenue); while GambleAware has used the survey findings to call for tobacco-style health warnings to be slapped on all betting and gaming adverts (including those for the National Lottery). The Commission appears, therefore, to be encouraging the use of inaccurate statistics on gambling harms in the knowledge that they will be used in support of an anti-gambling agenda.

Perhaps Sir Philip had a point after all…

REGULUS PARTNERS NOVEMBER 2024

Speed Kills!

The British Horseracing Authority is committed to a reduction of fatalities in the sport of horse racing. To that end they have embarked on a number of initiatives to achieve that end

I want to focus on the National Hunt. An area that once again hit the headlines with the loss of 3 horses over the weekend at Cheltenham. Two appeared to be post race heart events. I’m told these are not attacks as we understand them. Both of these took place over the chase course, in the same race. One other horse fell in the Greatwood Hurdle and died

The time of this chase event was the fastest chase of the day. It was as quick an event as I’ve seen, and I’ve verified this view with other form judges. These days it has become a rarity to see horses actually fall in horse racing, it seems to have become unacceptable, even if the sport is supposed to revolve around jumping ability, and clearly that’s what people pay to see. I observed at Cheltenham, whilst reviewing races, how horses clear fences at this premier racetrack with ease. Often several feet above the birch.

This was also readily apparent in the 2024 Grand National, where the fences have been lowered, softened and landing areas eased, to such a degree that no horse fell in the entire race. What is of most note is horses no longer bend, or arch their backs to jump. They clear fences with speed undiminished. The first fence is fairly infamous for speed based falls, as the 40/34 strong field would be at their quickest at that stage.

Whilst the BHA, under Nick Rust embarked on a programme of overall diminution of fence heights and stiffness, the fatality rate in the Grand National is currently running equal to the highest percentage rate ever. Without comment from the BHA. Since the 1960s 29 horse fatalities have occurred where ground is either good or better than good. 43 if we include good to soft. Just 5 have died in ‘heavy’ ground, and no horse fatalities were registered when ground is officially ‘soft’

Of further note, long term injuries have increased in the sport for the 4th year in a row since 2020. The lowest rate of fatalities? In 2020, when the winter was the wettest on record

With these facts in mind, is the BHA approach gaining the required results? To me their approach is centred upon optics. Where they have defined form! If we have fatalities, make the test easier has been the code

I would argue their approach focusses on the difficulty in jumping hurdles, or chases, when they should be focussed on ground, and speed. In simple terms the horses have quickened up. This is the inevitable consequence of making the obstacles easier

When the Grand National fences were at their fiercest, in the 1960s, just 2 fatalities were registered. Can the BHA explain this? Anyone who wandered around the track in the 3 or 4 decades since then, could only have been impressed by the scale of the fences. It was what people tuned in to see. The BHA’s approach in my opinion has been naive on two fronts. It increased the rapidity of racing, and it made the sport’s showcase less compelling to the viewing public, as evidenced by television audiences worldwide

This is what happens when you allow a betting executive free reign to mess about with the sport, with optics as his focus. I recall his comments on the heavy ground 4 miler at the Festival, where several horses finished notably tired and jumping became ragged. There were no fatalities in that race, but the race was identified by Rust as having ‘more fallers and horses brought down.’ Hardly surprising at Cheltenham’s longest chase event! It became clear that Nick Rust’s epitath was to nailed to his views on horse welfare. He reduced the race by a quarter of a mile and questioned the participation of the amateur riders involved.

One final point, before I leave you to discuss these points. Remember Cheltenham’s ill fated 3rd last fence? A notorious obstacle, not because it was taxing, but because it was at a critical downhill part of the track, where horses were speeding up. They tended to overjump, and collapse with fatigue on the landing side.

Make me the CEO of British Racing – I would increase the height of fences once again, and their stiffness. Force horses to slow down several times a race. I would demand tracks water more assiduously in the winter to produce soft ground. I would do everything possible to slow these impressive animals down. Speed is the killer in British Racing. Not the difficulty of the obstacles they face

Racing and the whip

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Mark Souster

 
The debate about the whip, especially in jumps racing, is one of the  most important issues the sport has to confront. For some it is an existential threat. It has pitched traditionalists against reformers, heretics against the believers.
The focus on equine welfare and all that that entails – with fatalities high up the list too – will be on the Cheltenham Festival next week like never before. The scrutiny will be intense.

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Remember it was two years ago that six horses died at the Festival, three in the Grand Annual. The images of tired horses being whacked in the four mile amateur’s race run on soft ground and when only four finished triggered an outcry.
Paul and Clare Rooney who are among the sport’s biggest British owners, then announced they would boycott Cheltenham – albeit only temporarily as it turned out – on welfare grounds.
It led to a review and a marked shift change in public perception which racing is only now starting to come to terms with.
At the prompting of government responsibility for its ultimate resolution has been taken out of the hands of the BHA, and falls to a new independent Horse Welfare Board compromising experts as well as laymen and women.

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Its first report landed last month.  It is clear as day that stronger penalties for misuse of the whip appear to be a certainty by the autumn. “The overall number of offences (over 500 in 2018) remains unnecessarily high and the current penalties do not provide an adequate deterrent effect,” the board concluded.
In its wake, the BHA has announced a three-month consultation with racing insiders and the public on changes to the whip rules, with a view to deciding on and implementing changes by the end of October.
The number of whip offences fell to an all-time low of 410 last year, less than half the number from 2011. However, the board pointed to concern on the subject from the public and politicians.
It said racing had to demonstrate “a proactive, positive direction of travel in relation to the whip, taking steps to eliminate misuse and leading any discussions around the future removal of the whip for encouragement”.
Far deeper questions are also being raised. Should that consultation include questions about whether a horse should be disqualified when its rider breaks the whip rules and also whether the whip should be banned as a means of encouraging horses in races?
Could punishments for whip misuse even be extended to the trainer and owner who had employed a jockey found to be in breach?

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Barry Johnson, a former president of the Royal College of Veterinary Surgeons is the chair of the HWB. “This is a matter of public trust.”
The prevailing thought seems to be that racing needs to address these issues and be accountable if society is to continue to give them a ‘social license to operate.’ Well that is taking it too far.
Racing maybe facing a King Canute moment where the end result is the sport being swamped in a tide of public indignation.
But it needs to draw breath and compose itself and come out with persuasive and reasoned responses. Emotion must not be allowed to replace hard fact and cold analysis. For instance when presented with the evidence from the BHA the Rooneys changed their minds and good on them.

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We need to get to the core of fundamental questions: Why do we use the whip – for safety encouragement, or an element of both? Where and when did it start being used? Does it instigate a fight or flight reflex? Does it inflict pain?
If it doesn’t, as most contend, then it’s not cruel then why shouldn’t we continue to use it?  And why call it the whip which has such negative violent connotations?
Perhaps a controlled experiment and research would help. If a horse responds to the whip, is it because it focuses them? Does it make them try harder? Or simply stop?
Would we be better off without the whip, so we have lots of hands and heels riding, and maybe carry the whip only for safety?

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Do horses go faster with the whip? If not then why do we use them?  Especially as it’s always at the end of a race when they are all going slower because they are tired.
As one expert put it to me: “I’m sure if you had hit Seb Coe towards the end of a race he probably wouldn’t have been able to go any faster.”
So many questions and as yet too few answers.

Mark Souster

 

Mark Souster has been the racing writer at The Times since 2016. Before that he was rugby correspondent. In that role he was named sports journalist of the year by the Society of Editors and won sports scoop of the year for his revelations about England’s 2011 World Cup campaign. He has twice been nominated for sports news correspondent of the year.

Response to SP regulatory commission

Response to SP regulatory system – consultation

Former NJPC chief exec Clive Reams,  recently penned a letter in response to the criticism levelled at the SPRC, after the Grand National, advocating ‘no change’ to the SP system.  When the current mechanism was devised in the 1990’s he argued vehemently against the then proposed system whereby 5 bookmakers could govern the SP returns – as ‘a bookies benefit.’

Of course he was at the time in violent disagreement with a system being proposed where the largest five firms produced the SP’s. And of course he would have been right. To permit those same firms to control the returns, when their off course empires were of such high worth in comparison to a veritable ‘cottage industry’ – would clearly disfavour punters. Any notion of those same organisations using their on course positions to actually bet competitively – and disfavour their huge shop and mobile empires, would have been nonsensical.

Yet now, we see that same official arguing in favour of the current mechanism. Despite the fact that same system has been modified several times, to permit now as low as three trading on course bookmakers, not only to provide an SP, but importantly the shows, otherwise known as board prices

Mr Reams hasn’t been seen in the betting rings for many years to the best of my knowledge.

It’s my conviction the SP mechanism – in its current form, was practicably out of date shortly after its inception and requires thorough modernisation. Not abolishment.

The commission, in its call for responses to the system, makes clear it supports little to no change to the system. That we are afforded a workable and simple mechanism, which provides for such as guaranteed odds against SP. Why the commission feels ‘board’ prices would disappear in any revisions is beyond my understanding. Perhaps to scare people into the false belief that show odds would be consigned to the bin.

We already utilise industry odds in some meetings – Meydan and Longchamp for example. There’s no argument to support the commission’s assertion a system based on track bookie’s odds- is the only one which would support guaranteed odds

It’s rather apparent the SPRC depends upon the advice and views as reported by the press association staff, tasked with returning a fair SP from the racetracks. They are neither witness nor party to discussions between bookmakers – and their customers. Their honesty is not in question here- but they clearly cannot have the ground level experience to report accurately what is really transpiring.

The commission will also consult with the FRB, namely Robin Grossmith for his advice. Whilst Robin is a respected colleague of many years’ experience, it should be remembered that an important part of his remit is to secure payments for on course bookmaker’s data. He would naturally argue the system as working in a satisfactory manner – and without any knowledge or understanding of how the mechanism, currently being employed, affects off track companies. Most track firms care little for the impact their activities have on the wider betting community

The dynamics of betting have fundamentally changed in the last 20 years, whence the current system was put in place. In that time changes have been few and limited in nature. 20 years ago a pitch at Sandown at the top of the rail would have been worth well in excess of £100,000 – and very hard to come by. These days – those same pitches can be purchased for less than a third of that value- and with minimal interest, most certainly not from someone trying to get into racecourse bookmaking as a career! In the same 20 years- the average turnover per race to on track firms would have declined to not less than 1/6th the value of the late 1990’s. Midweek racing has declined in interest to customers to attend. Rings are often ghost towns. Few punters turn up, and in a cashless society they have less to spend with bookies trading. Mobile betting apps have taken over – being more aggressive in nature, easy to use, from funded accounts and related to offers. Racetracks have taken over betting at some tracks –and this new competition to the business a track bookmaker is afforded will have significant impact on their very existence.

My average midweek turnover, as a leading layer, in strong betting positions, is now routinely less than £500 a race- if I bet in any way sensibly. A risible figure. For this reason I rarely attend midweek fixtures. Nor do many of my colleagues. The only way to buck such turnover figures is to exceed exchange odds, then to risk arbing from other bookmakers. If a bookmaker does not offer a pure exchange price on a ‘fancied’ runner- it’s difficult to field any appreciable money for it

Bookmaker numbers have been shored up by some firms operating multiple positions. One bookmaker (John White) operates three positions at Kempton – a small ring as you are aware. Kempton – for example, routinely operates with a sample of around six firms – they are providing prices for a huge off course industry, from a venue where few punters turn up to bet

At the same time as this decline has been evidenced- the off track firms have increased in size, technology advances, and power. Where once betting rings were vibrant and busy, with standard place terms, minimum lay to lose guarantees – and by extension a useful ‘guide’ to SP’s – now they are ripe only to cheap manipulation of their odds. Huge multi national betting concerns can control a weak market with veritable pennies. This imbalance would simply be outlawed in any other financial sphere. It is important for the SP commission to give this point full consideration.

 

VOLUME OF RACING

Since 1995, and importantly in the era of Peter Saville at the BHB in 2005, the volume of actual meetings has soared from around 1000 annually – to 1450 currently. Racetracks have also focussed their business more towards Saturdays and providing cheap funded product. This has had a thoroughly negative effect to the turnover on track and split the punters interest between meetings. Further a customer can now sit at home and watch either ATR or RUK on his satellite – even watch live streaming racing on the likes of Bet365. All have had an entirely negative effect to bookmakers on track. In the same period the expenses of running an on course business have soared. Many bookmakers have quietly retired from the ring

RACECOURSE DATA TECHNOLOGY

In the last 20 years or so most firms now utilise software provided for them by RDT. The build of their system and its layout is specifically designed to facilitate easy wagers to and from exchanges. A wager can be practicably negotiated faster than on a web browser, a whole set of prices backed, or an entire position closed out. RDT receive a commission from Betdaq for such activities. Such software did not exist in said advanced form when the SPRC devised the mechanism in the 1990’s. All bookmaker software on track is designed to facilitate wagers with exchanges. It has caused a sea change in how bookmakers engage in business on track. They differ from their off track colleagues in that instead of being viewed as traditional ‘layers’ – balancing books with real money, they have metamorphosed to ‘traders’

TRADING

What should also be considered is the wholesale change in the approach by on course bookmakers to betting. When the mechanism was put in play, the majority of firms were traditional in nature. That is to say they were in the business of framing a book and accepting risk. This has fundamentally changed. The vast majority now ‘trade’ many wagers away with exchanges to create margin and keep risk levels low. In order to engage sufficient liquidity to make this practice work – prices must virtually mirror those available on exchanges. For example – a firm will typically offer 4/1 a horse for any variance on an exchange from 4.9 to 5.4. If the operator is lucky, he will be able to trade at 4/1 and hedge at 5.4 – bookmakers have become the new ‘arbers’

There’s little discernible difference between ‘show’ odds and exchange odds for the more fancied runners

Off track firms are, by extension, accepting wagers – and risk, on shows therefore based almost purely on exchange odds. This is a far from healthy system – and a central plank for lower levy returns – down over 50% in recent times. Most bets are accepted at board odds- rather than the more ‘protected’ SP returns. Off track firms do not ‘trade’ wagers in the manner in which on course firms do. To boot, since the shows being returned are up to one minute behind changes in exchange odds, off track firms find themselves subject to arbing from punters. This business is unprofitable and most bookmakers close accounts from those engaged in this practice. Such moves are unpopular and leave firms open to unjustified criticism.

THE STARTING PRICE

Let us consider the actual SP – in practice most track firms have stopped trading aggressively, or at all – it’s often too risky to bet to exchange odds and risk a sizeable wager which a bookmaker cannot trade, with the exchange, in the limited time before the off. Prices are revised downwards throughout the ring – or unavailable. Most books are structured and the operator is loathe to change it. Large operators, such as William Hill on course, are naturally particularly mindful to ‘bet well’ with one eye understandably on their important off course entity.  In my experience their returns are given considerable weight in any return. SP’s are, in practice, more favourable to the industry for these simple reasons.

There’s habitually a considerable difference between exchange SP’s and Bookmaker Sp’s

PRICE REVISIONS

It is common in circumstances to hear criticism of course bookmakers for failing to balance books by pricing up horses which they have not significantly laid, at times when they take substantial monies from legitimate hedging activity happening fast and late throughout the ring. Through the year we will hear many examples- the Grand National being a notable one, of an overround which disfavours punters betting at SP.

This is fairly easy to explain- since most track bookmakers are less ‘layers’ than  ‘traders’ . When they do catch late funds for a selection, they are far more about dealing with trading the wager profitably on exchanges. In the 1990’s – most firms would have been trying to balance their books by raising the prices of other runners to compensate, if you will. This is no longer necessary with the advent of betting exchanges and software dedicated to trading

Further, the notion that bookmakers should counter raise odds when there are often no punters to offer those odds to, is fanciful.

Finally, large entities sending money back to the tracks place their wagers as late as practicable, certainly never 20 minutes before the race for example. Again such practices, as in the likes of FOREX, would be viewed as questionable. Is racing somehow different? I am not suggesting they are not fully entitled to boss the SP’s, but there are issues of scale and timing.

 

SAMPLE SYSTEM

The current mechanism employs a bank of up to 25 firms at the largest meetings. At the lesser meetings it is exceptionally difficult to find 25 firms, betting within the commission’s guidelines, to return an SP. The SPRC has revised the number of bookmakers required to return an SP to below the level which caused such upset between the NJPC and the commission in the 1990’s, when 66 questions were tabled on the subject The commission has also modified what it permits to return a show to below the accepted industry standard terms and without requirement for a minimum ‘lay to lose’ figure.

At York’s Dante meet recently, I was one of only six firms in the whole ring, to offer an industry standard ¼ the odds a place in two 16-21 runner handicaps on one day, whilst the rest of the ring were legitimately offering a 1/5th. A bookmaker betting to a fifth in said instance could offer 25/1 a horse – whereas I would only be able to offer as low as 16/1. How does the commission handle such anomalies? Or where the favourite is odds on and all but a couple of firms are betting win only? Once again the sample is nowhere near that required for a fair SP, nor takes into account it is supposed to mirror standard terms off track to be seen as accurate – that is if there were appreciable monies to bet to. There are many examples of such cracks in the system throughout the year, which would not be evidenced if we had a system properly balanced by the true weight of money wagered on a race

We are of course well aware that the Grand National return in no way accurately reflected a fair return. Whilst I would argue that 1.66% per runner is by no means excessive- the truth remains the show embarrassed bookmakers on course, and will lead to customers choosing not to wager at the racetrack at all. Many firms were offering 9/1 the favourite – which was returned at 6/1- at the same time the exchange was offering 14.5 on Shutthefrontdoor.

The simple fact is the use of ‘SP Samples’ as a methodology for returning prices (especially where 5 of the 25 firms in the show represent major off track business) is clearly far too easy, and inexpensive, to control. In practice it’s fairly evident who the firms are that are part of the sample

Bookmakers not included in the sample are routinely ignored. Bookmakers within the sample are often asked to accept wagers at less than the odds they are currently displaying. Particularly at small meetings. Is there clear and incontrovertible evidence that this goes on? No. It is however, quite routine to be asked to ‘co-operate’ on shows in return for the crumbs off of a large concern’s table. If you co-operate – you benefit.

IS this system of hedging fair? Not if a wager is proffered ‘with hooks’. Any discussions with other firms will confirm this is precisely what goes on. It is totally acceptable for a large concern to wager to control a price which reflects the full weight of money. But not where said concerns can control a the market for such a tiny outlay and by openly requesting the bookmaker to cut his odds in return for a nominal wager.

WEIGHT OF MONEY

What should concern the SPRC, is the effect on a fair mechanism of such large concerns wagering with such a tiny entity as three to eight bookmakers trading an all weather track for example. What also should engage thinking, is the possibility of manipulation of weaker exchanges on small markets. Especially when one considers RDT controls well in excess of 90% of on course firms and produces software designed specifically to encourage the practice of trading. In reality, it is Betdaq- the weaker exchange of two, who govern on course returns. In my view this could be viewed as a cartel. It takes a tiny movement of exchange money – typically less than £10, to be followed by several on course layers.

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INDUSTRY PRICES

Why have off track concerns not called for control of their own SP’s to date? Two factors explain this anomaly

First, and rather obviously, where the SP itself is required to be revised downwards, it can be easily controlled in a market devoid of regular punters with a very small ‘hedging’ fund. Large concerns represented on course can constitute up to 50% of those available to govern an SP. Especially as the SPRC mandates that in the strongest rings at our festivals, only up to 25 firms are required to return the show. Hedging can therefore be restricted to just those firms. This is precisely what occurred at Aintree. Indeed one pivotal operator, running multiple pitches, informed me ‘where he was in the sample, he was 6/1, – where he was outside the sample – 9/1 about the favourite’.

If all operators are betting to the same commercial terms – there’s really no need to limit the number who return an SP, and it’s clearly a system which fails the means test in such areas.

Second – what concerns major operators off track, when one considers the issue of industry odds, is how their competitors would behave were the mechanism revised. Would, for example, an aggressive operator such as Paddy Power- buck the general acceptance of a new industry return by producing its own ‘enhanced’ SP. As things stand currently – everyone accepts the status quo, warts and all. Of course most firms would prefer an accurate industry SP, not based on exchange odds on course, but the elephant in the room remains their competitors

With the disappearance of John McCririck from television schemes – a major obstacle to industry odds has been removed

OVERVIEW

Centrally the landscape of betting is unrecognisable – were we to compare it with 1995.

The SP regulatory commission is recommending we keep a system where the ‘show’ odds for fancied horses directly mirror exchanges and where the SP is ‘protected’ by circumstances. Where small time traders – desperate for any bettors can be easily bullied by larger operators and where punters feel they are being cheated (unfairly) by track firms.

We are long overdue constructive change. I welcome this consultation

Proposals.

  1. On Course bookmakers to compile one fifth part of a new mechanism, only where there are an absolute minimum of 25 separate entities available to return an SP
  2. Those 25 firms must be betting to recognised tattersalls standards in every race they are engaged to return the SP. Modified terms can not be accepted
  3. At least 25 firms must be available offering a full each way service to return an SP
  4. Sample system to be totally abolished on course. All firms betting to standard tattersalls terms to be included in the returns
  5. Track bookmakers who wish to include their data in any new return, must undertake to lay any advertised price to a minimum of £100 – to include to other operators.
  6. Four fifths of the new mechanism to involve the 19 largest operators. These operators to include Betfair and racetrack bet
  7. Betfair’s SP can only be taken from their each way market
  8. Industry odds governed by weight of money and by provision of prices to SIS
  9. SPRC to consult with operators to produce a formula which most accurately reflects an operators liquidity – and therefore influence on the SP

Geoff Banks

10 June 2015

The 2015 cheltenham festival – the grubbie bookie’s view

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I suppose all racing fans grew up with great memories of Cheltenham in March. I recall as a boy, betting in the underaged class, on the Cheltenham rail into the members enclosure, nobody was surprised in those days to be served by a 13 year old – that you just couldn’t move for the absolute crush of humanity. Most of whom appeared to be called Mick. Although a few were Paddy’s. These days we’d invent a quango to count them by age, sex, social class and type of BMW

I prepare for Cheltenham months in advance by calling up the babestation offices to see if any of their talent is free. I got one. Brandy Brewer was her stage name. I think we should all have stage names, don’t you agree? So we downloaded an app (and you said I was a dinosaur?) put in our names and received new ‘porn star’ equivalents. I was Dan Cucumber. I was quite pleased with that.

I added two more lusty girls, bearing in mind sex sells. That I have absolutely no morals whatsoever. That it would upset the gambling commission. That some fellahs would hang around even after I’d emptied all their pocket change, asking daft questions like – how big are they when they’re out? You get the picture

Just in case any mary Whitehouse types were lurking, I threw in a couple of old grizzlies who have worked for me forever and never break a nail. We jumped into our Bentleys for the Cotswolds. And Mulllins.

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It’s all about Mullins you see. Henderson has voted himself a non runner these days, as he declares the entire season to date as ‘soft’. The galactacos of racing who’ve won very little of late. One day they’ll whisper in his ear that cotton wooling of stars is a miserable failure, horses need to race, and the giant that is Seven Barrows will wake up to find Paul Nicholls has been eating his lunch for months. I’d like to see that, Henderson is a decent chap and we desperately need competition

The run up to the great party gives our beloved journalists to call up their three favourite trainers. Pre requisite to any convo is to get in early and often the phrase ‘it’s a privilege’ – or you’re struck off ze list of approved hacks. Lesser trainers don’t have phones and who’s interested in Hobbs or Bradstock anyway?

ATR extend ‘Bookie hour’ to a 3 hour slot daily. Tarts..

It was all about Faugheen, Vautour, Douvan, Un De Sceaux, Annie Power and Don Poli. Throw in Peace and Co for good measure. The average SP of the first 4 mentioned this year in all races? 3/10. Gripping stuff we’ve been treated to. Thanks Willie- you deserve a few quid extra in your wages at Cheltenham

Of course we know now – only one got beat, courtesy of the biggest howler in racing for many a years as she grinned at the crowd and paddled the last. Been a long time since I heard such a moan. Genuine shock – the biggest fail at the Festival since I tried chatting up Emma Spencer. Multiple bets up and down the land were waiting on her due diligence. Walsh set it up and she fluffed her lines

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There will be those of you, reading this, who take the view betting is the dirty end of the sport. That it’s all about breeding and the majesty of the horse. You’re the type who adores a 5 runner race. You don’t care if Faugheen is 1/6 as he powers away from horses two stone inferior. You don’t care if The New One or Annie Power are doing the same in Haydock or Leopardstown. It’s all magnificent.

Actually, you’re already dead and on the Eastbourne hall of fame. Check yourself

Well for those of you who don’t care about betting or the bookies, give yourself a pinch. Because I assume you care about the finances underpinning the sport? You want owners properly rewarded, yes? Well to educate you, the Levy Board was about to have a crisis meeting had Annie duly obliged, such would the whole have been in the finances of the sport.

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(so good – I put it in twice..)

You see, racing is about the punters – they fund it. You think Steve Harman’s ‘racing right’ is coming to save you? Ha! The commercial acumen in racing has always lain with the bookies. They did their stones at Royal Ascot, King George and sundry other ‘biggies’. But you’re looking at their bottom lines – aren’t you?

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Modern racing festivals these days in betting terms are characterised by ‘offers’. Credit to some firms ie Betfair (did I just plug Betfair? I need a shower! Who described their offers as what they were- free bets. Companies who did not distinguish themselves led by Paddy Power and Boylesports, who fronted with money back offers – that were nothing of the kind. I think this odious practice should be stopped. Cats being kicked into trees has to stay 🙂

On the plus side, firms like Paddy Power are giving their customers some amazing offers – I’ve never seen the likes of some of the deals they do, even if you’re only getting an extra bet, it’s still a lot more than in days of yore. What concerns me, is they’re mainly targeted at racing. It simply cannot be good for the sport for the number one festival the vehicle for ‘new business,’ rather than profiting from the racing itself. Take Peace and Co for example. A rock solid 2/1 chance for months- 4/1 in the morning. Not good, not good at all.

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Thursday morning, Brandy broke a nail. It was so sudden I don’t think any of us expected it. The wailing and sobbing was akin to Annie Power’s departure from the festival. One moment – ten perfect porcelein fakes – the next- nine., Brandy wasn’t in the best of spirit. Punters were clambering over each other – not for her – but to press guinness sodden fivers in her hand for horses, fart and leave. What’s this about? This never happened at Babestation. She only had to flash her tatas and the phones would buzz. Anyway, to her eternal credit, this girl has guts for sure, she knuckled down and gave Vicky (AKA – Ritzy Jiggler) and Stephanie (Tara Cream) a hand in fending off the drunken. Some of which were bookies, a lot appeared to be jilted ex’s of Stephanie. Brandy will be back next year to entertain the masses we hope

In keeping with gambling commission edict 198.259 sub section 5 ‘dealing with total morons’ – we checked with everyone if they were over the age of 13 and not in fact in the paid employ of the commission itself trying to catch us out.

By Friday morning – I was in a shell shocked state, given depressing results, and the prospect of shaming myself on the Morning Line Saturday- my office had taken the phones off the hook and the website down. Come back Ffos Las, all is forgiven. Results outside the championship races were pretty fair – especially the ridiculous plunge on China Doll in the Queen Mother Champion Chase. Surely more likely to pull up than compete seriously?

It was a festival for the new. The performance of the meeting wasn’t the unchallenged Vautour for me – nor Faugheen, but the Denman-esque performance of Conygree. By the start of the 2nd circuit, he had many class performers firmly off the bridle. He quite simply ran them all into the ground. And who WAS that jockey??

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Surely the BHA should lamp Bradstock with a 60 day ban for ‘upstaging Mullins’? Well done to the authority, however, for having the last ‘laugh’ as usual and a whip ban in the gold cup to a lesser jockey – they never disappoint

Was it the best Festival in modern times? – that’s hard to say, Loads of talking points.  it certainly was out with the old and in with the new. Everyone knows I worry about the all enveloping nature of it. Months of discussing five runner graded events and odds on chances is something a caring authority wants to take very seriously, with the prospect of a repeat next year.
I have one suggestion, which will have some people nodding in approval, the purists in horror,  and the BHA copping a deaf un. That Mares race. 6 years in a row a grade one animal reducing the worst rated event at the meeting to somewhat of a procession. Not really the point is it? Not good for the finances non plus. Perhaps an upper rating level of some description? We all know Annie Power will line up again next year – but in reality she should be in the World Hurdle, and not hiding away in selling class.      NAP

I always mention the whiners. Taking a break from the Betfair Forum. Those who moan about Channel 4’s coverage could only be uber impressed at some of the amazing images treated to our screens, the features, the slo mo’s. Fine, I’m an occasional guest, but I’m entitled to an opinion and in comparison to the beeb? No comparison. Enjoy the float race Clare. Dreadful choice over the Grand National, really it is. But we’ll have Luck and Gok- fair trade.

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And finally, yes, you made it. To one jockey. Given the amounts of cash I’ve heaved out over the years over this man, the times I’ve cursed the man, you might be surprised I’m as teary as the rest of you at the departure of a legend. I think to put it into some kind of perspective,  the British public admire most the total and unadulterred energy he put into every ride. His iron will over sometimes doubtful horses. It’s a shame Jonjos stable has been in such miserable form this season or he would have signed off with more winners. AP has carried himself wih humility and class and gave every punter 100% commitment. That’s why they love him. And I will very much miss the very engine of National Hunt Racing.

The BHA – Acting in the best interests of Racing or Stakeholders?

It’s become routine these days to hear and read informed commentators, pundits, industry experts discussing the issue of small fields in racing, indeed last year the BHA undertook an expensive consultation into fixture levels in an attempt to combat the issue of small fields and lack of competitiveness in racing.

The result? More fixtures in 2015

BHA announces races attracting small fields will be deleted from the programme

The result? No races removed, a three month trial period suddenly introduced, and one deleted race restored in the face of opposition from horsemen

9 new board members with little, or no experience running racing, at the BHA. Two of these new directors have been appointed to ‘bed in’ six of the others. Tell me you’re joking, or have the stakeholders grabbed two important ‘blockers’ on the board?

The BHA announces the scrapping of small field events to address the appeal of the sport.

The result? The BHA backs down in the face of opposition from the trainers involved in the race and the NTF. It goes further in placing an NTF official to the BHA Board. I’m sure he’ll be supportive of an initiative which followed an expensive consultation.

What’s the value in an authority that doesn’t govern the sport with its best face in mind? Someone tell me.

After the removal of the best politician we’ve ever had in charge, Paul Bittar, from the equation we’re left with an entiely new board, in every sense of the word. Opposing these new directors – the stakeholders. Betting, Owners, trainers and racetracks and their interests. And they’re clearly out for what’s best for them, even if the sport cannot progress

Do you care? Or would you classify yourself as one of the silent apathetic ones- to criticise the sport is wrong, it’s just not done. To my mind, constructive criticism is a requirement and you should get involved and stop taking the guided tour

BITTAR

Quite what the Australian did wrong or whether he had just had enough is unclear. Nobody is asking the question. I didn’t always see eye to eye with Bittar during his tenure, I’m always going to take issue with the pace of change, but it’s clear he shared many of the same concerns. Particularly in regards to ‘stakeholders’ and their negative impact on the sport, and integrity issues relating to low funded racing we seem determined to produce more thereof.  He was capable of pulling the disparate parties together given time. Continue reading “The BHA – Acting in the best interests of Racing or Stakeholders?”

Cheltenham Open Festival- The Bookies Eye

I know the National Hunt season doesn’t really end with Aintree, it burbles on without it’s stars through the summer. I’d like to see it curtailed for a month – perhaps in June when Racing is so resplendent with riches such as Ascot and Epsom. For me, though, the season really starts with Cheltenham’s excellent ‘Open’ Meeting.

It needs a new title, because Open doesn’t do it justice, and we need Festivals in the winter, perhaps they should call it ‘The Tweed’ – it’s the only venue which accepts folk in that ridiculous garb. Children point and stare  – you can’t blame them..

For me, it’s suits. I pack several to go with the alternating seasons Prestbury affords us. I pick up the delightful Miss King and head off into the rainstorm. I talk, she texts her boyfriends and updates her facebook. It’s an odd relationship. I’ve become dull

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There will be a few of you who accuse me of using sex to sell betting tickets. All true. Don’t write to your MP or call the cops. I admit it.

We stop at what used to be the Hotel De La Bere, to pad JP’s income.  I read the paper, Stephanie has a text argument with one of her spotty friends. The office bombard me with calls, on bets we shouldn’t be laying. Disappointingly for a Bookie who works indoors at 72 degrees ambient, the sun has come out, and will wreck my takings

The bastard.

Friday isn’t as busy as Saturday for the Bookies. We work hard at offering a service not only at Cheltenham, but at the ‘away’ meetings. I’m glad I had Mick and Vicky dedicated to paying out, because Wolverhampton was on.  Hitler should have bombed Dunstall, I wouldn’t have minded speaking German then.What I made at Cheltenham, i gifted back to those betting at Wolverhampton. The decent people of Jockey Club stop by for a chat, they’re comfortable in the product and with good reason. People vote with their feet, the attendances are good, and racing needn’t always be seen as a vehicle for the Ladbrokes Life. JCR are experts at Festival meetings and I admire their sense of decency.

I’d like one day to persuade this influential body to see exchanges outlawed from bookie software on course , it’s a thorough cancer on service, and emptying the sport of money it deserves. Make sure you support me here if you value the flavour of the betting ring or I will ignore you at parties.

As a sidebar, people who bet at the All Weather don’t wear tweed, they’re known as bonus junkies. They scout around for ‘free bets’, – never go racing, – just sit at home in their underpants ‘greening up’. Sand racing is for camels, but we’re stuck with it, it seems. Don’t blame me, I can’t stop the fascination with grunge. Saville is a sick man, he’s hoping Jesus makes a comeback and performs a loaves and fishes trick on field sizes, with rocking horses to bolster poor fields. I wouldn’t be surprised to hear 68 fixtures being awarded to Comet 506b  (taken from York.) I mean it does have the perfect racing surface..

It’s not busy on friday, so Mick finds time for a hug. He’s a charmer and ‘The Rinser’ doesn’t work that hard. Here’s one of her, not on her phone, with my main man

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Friday night is a predictably boozy night in a gorgeous country pub. Everyone tells stories, – mostly lies. My favourite is telling everyone I was in the SAS, which I think everyone believes. Mick orders the fishcakes and is crestfallen when they offer us free fishcakes, by way of canapes, at the bar. He doubles up anyway.

Saturday dawns, The Morning Line tips all the favourites, Paddy Power makes me chuckle and the show hums along in entertaining style. They have someone on from Timeform, I’m glad he didn’t launch into an explanation of ‘Sectionals’ – probably gagged I expect. I wish people would stop whining about Ch4, we’re all so damned fussy about what we want to see, and my good friend Barry Orr and his x ray specs represent good value as a stand up comic 🙂

We arrive early at the track, the crowd looks substantial. Entrance fees are very fair, the track looks the business. Cheltenham is the class of National Hunt. Except for those odd plastic beakers they dosh out to customers in their lovely Golden Miller bar. The only mild blemish for me. I give the catering boss a hard time for flogging me an £85 bottle of Veuve in a kiddie cup. He tells me glasses are a health and safety issue. I ask him what the champagne comes in. He says he will feedback my comments..

The Centaur has a brash new screen, 6 hard working Bookies, the Magic Sign and Tote. They serve clods of Guiness, so everyone has their bet, farts and leaves us with the smell. I suppose given the results that’s about fair. We massage a victory. It’s very busy. Do we bet a bit better than outside? Yes we do, a half a point here and there, but we’re in business and our focus is service, not begging a bet. Besides, most traders outside don’t understand the concept of ‘sustainable margin.’ Punters are a fair lot. They just want to be treated with respect and I find most would rather they found Bookmakers who lay a fair bet and pay up with a smile. We don’t do ten pound offers, we leave that to the really BIG bookies. I’d see that outlawed when I’m in charge

We take just over 2000 bets, we don’t have any hedges, they’re for gardens. Results go in favour of the punters but I catch a break with one favourite actually winning me money and I walk away heavier than when i arrived as the punters clap me out. We peel off the bets as fast as we can and try to pay out with the same alacrity where possible. A customer with his money in my pocket isn’t wagering in the next. Punters climb over the weak and infirm to get on, experienced pensioners trample young fit men to get on. As far as we know we didn’t lay any 17 year old Gambling Commission stoodges any bets. But you can’t be too sure..they’ll write to me I expect. I don’t fancy my chances with Mrs Williams

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There’s no other way to describe the Racing on offer than exhilarating. Horses that looked done in, walked all over, came back to win or held on. We were lucky with one of Geraghty’s- Druid’s Nephew, who ran too free and got under his fences, but jumping is the game. Cheltenham tends to offer some of the most unpredictable finishes in the Sport. Some horses turn in going easy and flop, and others, like Caid Du Berlais, whose jockey supplanted whip for cattle prod. It’s the very soul of National Hunt racing. I understand why the track dominates the code.

I recall one slightly inebriated looking fellah who walked up to me, gambling commission plant methinks. I lay him a bet.

‘tenner each way on Budweiser’ he slurred, displaying his opt out of gambling forever card

‘Don’t you mean Buywise Sir?’

‘Err, yeah, sorry, er, repetition, you know, – been drinking for four days, – where am I?’

He loses his money. Well, to be fair, 13 year olds shouldn’t be betting- and no mistake..

A couple of suggestions to friends in charge to improve the quality of winter racing. Do away with both Jumpers bumpers on the all weather, as well as ‘racecourse gallops’. It’s time to force the stars back to work in races which struggle for quality entrants. I know you’re all looking at each other round the board table at that one.

Saturday night is predictably good, another beautiful Cotswold pub and a few bottles of the firm’s champagne to reward the team for looking after my clients. They guzzle as if its their last, particularly ‘The Rinser’

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Sunday is predictably quiet, although the racing remains competitive. The day starts with the shock news of Dessie Hughes’ passing. A minutes silence is strictly observed as we watch replays of the mighty Hard Eustace, as if we needed reminding! Many Bookies turned their boards off and I didn’t hear anyone talking in the ring. A great tribute to a legend.

One odds on chance at the meeting is all,  a load of great finishes, punters and bookmakers alike celebrated a great trainer, the gate staff are the same people the track has employed for years, the views remain beautiful, – the Open became a showcase for two decent fellahs, Phillip Hobbs and Richard Johnson. Little wonder the season tends to revolve around this jewel in the Cotswolds

Put fifty pounds in the box on your way out. Thanks

Six more fixtures

I don’t want to bore you with statistics, sometimes they can prove meaningless, but there’s one stat that cannot be ignored in the sport we hold so dear. From 2008-2014, the horse population has declined by 1600, around 10%, that’s to say horses in training. In the same period – the number of races has grown by 15%. I hesitate to coin the phrase ‘the net result thereof’ – but you have to admit there appears a strong correlation in these two figures. More races – less horses..

Next year- six more fixtures. I want to make clear from the outset, I was given more than fair opportunity by the British Racing Authority to state the case on behalf of those of us who believe there’s simply too much racing. I was simply out-voted, or failed to press my arguments, indeed I think it’s fair to say my view stood pretty much alone in the face of data and reports compiled by important racing entities, to include the Racecourse Association, Arena leisure and Jockey Club. Racecourse Media Group, and Attheraces. The Levy Board also support the current level, based on data provided by big betting.

The consultation group doesn’t include any elements of Betting..

The aforementioned ‘pick five’ of racing (excluding Bet365, who oddly declined any participation, perhaps they don’t see us as serious?) Ladbrokes, Betfred, Coral, William Hill, Betfair broadly agreed with the current levels. This, despite their complaints on field sizes, elements of planning with competing fixtures devaluing certain races they sponsor, quite understandable, – that .

As to the influential Horseman’s Group? I honestly don’t know where they stand.

The BHA? As usual they get the blame, despite only controlling 200 odd fixtures themselves. One has to bear in mind, the OFT stripped the body of its powers in effect, and this is the result. I believe they definitely favour a reasonable cut. After all, the consultation was their plan. They weren’t prepared for the various stake holders to play rough, with spurious claims as to what any kind of cull would cost, without mind to the potential benefits in a raising of the bar on quality.

The sport is losing TV viewers and racegoers midweek. Bookmakers are the dominant sponsors, even if some view that as distasteful. Cheltenham lost six sponsors for their major festival races alone.  The margin in betting has seriously declined, so has racing’s market share of the betting cake and lay to lose is a cancer on the sport. I’m sure racing’s most important group of tracks would prefer to move to a more balanced sponsors book given the pervasive influence of betting, but can’t find sufficient alternate companies at the current time. After all our tv networks and newspapers are literally stuffed with adverts from gaming empires. I’m aware some of you don’t care, nor understand the long term impact of this. But a full moon is coming.

Ladbrokes, one of the largest operators in betting worldwide, have already told you of their concern as to the viability of racing as a betting product. Were you listening, or did you put it down to their failures as a company to deliver a competitive digital platform?

In order for the BHA to ‘monetise’ the sport abroad, to betting, and to new sponsors, they must deliver on field sizes, and control the level of ‘grunge’ – low quality racing put on exclusively for betting, and stop the tendency for our best meetings to compete with England vs Moldova. An instant fail.

The critical Asian market, we base some of our Levy upon, bases itself on numbers betting, – often backing several in a race. The odds permit this kind of play. How does that fit with a five runner race at Southwell? Indeed, of what interest are such events to our betting public – other than the professional players? None. Of course, I’m painfully aware to some track bosses this is of no importance right now, but change is coming with the new media rights negotiations.

In the face of the spirit of change from the Authority, Arena leisure have threatened legal action.  Yes folks, the same group who benefitted from the whole Good Friday concession is now holding the sport to ransom over their demands for a gothically dull floodlit mile for predominately low class horses at Gosforth Park. In much the same way as Pat Cosgrave was delivered back to racing – by lawyers, and their assertions. Tracks aren’t about to permit any reduction in their share of a media rights cake that has seen Bookmakers pay more than a hundred million more in recent times in fees to racing, with racetracks the primary beneficiary, and they’re not going to let a good thing go lightly..

We’ve reacted to the threat to field sizes by actually increasing the number of fixtures. Hard to believe it’s true. One is bound to question the purpose behind expensive consultation processes, other than to witness a circling of the wagons from ‘stakeholders.’ They simply refuse to countenance change, even if its utterly clear this is exactly what the sport requires to prosper.

The consultation discussed the removal of races that attracted low turnouts midweek. What’s wrong with that? It also discussed reducing the grade in certain races, to grow field sizes because we have more horses of very poor quality. This is to embark on a programme of lowering the overall quality of the programme still further. That wouldn’t be my choice, but I believe there are those who would use rocking horses if it made up a race.

All weather is on the increase, despite poor attendances, which adequately demonstrate the public have no appetite for it. The fare is largely unappealing. Racetracks focus our jewels in a one hour slot on Saturdays, often opposing more popular sports such as soccer. The midweek continues to be run down to the extreme. Sunday night racing, distressingly, has now appeared on the calendar. Nobody trumpeted that. Hardly surprising.

Few of these measures are customer focussed or about increasing quality. They evidence of an Authority boxed in the corner. Placed there by the office of fair trading. What a mess they made, ignorants with clipboards.

I’m fully aware though, there’s a strong body of fans and insiders who believe the current volume of the sport is farce.  That to prune the programme by less than 1% and move a few races about won’t change things much. It’s a view I’ve heard many times from my customers, read constantly on social networking. Most of these views are the punters of course. The vital stakeholders group in racing who don’t have a seat at the top table, as things stand currently. They are joined though by a few brave souls from the training ranks, and some well intentioned journalists.

As we keep lowering the bar on quality, we make the whole thing just that bit less interesting to bet on. The USA has seen a dramatic decline in interest and betting in the sport. Excessively dull as a product. That’s precisely where we’re heading. Believe it’s true. The global data is fully at odds from that argued by the Levy Board and Betting.

Of course, I know we can offer some superb product, and accept we can’t always have group ones. Anyone at Ascot last weekend on British Champions Day can only be thoroughly impressed by the event. Cheltenham, Aintree, York and Goodwood showcase the best of Racing. Horseracing in Britain can be utterly superb at times. I want no mistake made that I have the utmost faith in the sport. Yet we seem to be choosing the route as driven by big betting, and backed up by their highly questionable data. I don’t want to dwell on the tracks themselves. If they’re paid to race in front of empty stands, they will do just that. It’s a business. They will inevitably favour the current level. Many have impressive debt levels to service.

People are persuaded by betting by two very simple phrases. ‘Every race contributes to the Levy’ and ‘if we don’t provide racing when the punters are in the shops, we will simply sell rival products.’ Data is brought out to back up this argument. As a colleague correctly pointed out, it’s hard to take the argument for a cut in the volume of racing forward when the data appears to show we could lose substantially from any cut in the programme. I argue in a different vein. No data has been produced, nor analysed, to show what would happen to the sport’s finances were we to embark on a programme which raised the overall bar on quality. No figures have been produced to show that in fact were we to raise the average field sizes by just one – from the current average of 7 to 8 horses a race, that the extra business we would ‘field’ would more than balance any loss in the total volume. Horses would seek other opportunities.

I hope I have made that simple point well.

Let me explain big betting for those who do not understand it. No, I’m not here to discuss those who ‘get on.’ Broadly speaking, what the multiples desire is ‘product’ – lots of it. The successful supergiant will deliver as many betting opportunities as they can in an hour. Racing is marginalised as a product in comparison to gaming, which is the engine of their businesses, and other sports such as soccer. The actual number of races put on every week, make the sport relatively inexpensive to bookmakers in real terms, and they generate noise and footfall in the LBO’s. They get so many spins of the wheel. Anyone who’s remotely threatening in the modern betting environment is closed down with alacrity.

What’s our future? I believe the data rights deals racetracks have enjoyed likely heftily squeezed by the bookmakers, and we will see racetracks close.  The bookmakers simply carry far more commercial nous. Midweek racing most weeks has simply collapsed. Even our finest races ‘carve up’ between a select few, whilst lesser owners struggle at the cost of keeping their horse as the balance between prize money at the highest level and most of the programme is thoroughly disproportionate We can make more of the product.

We can grow, by embarking on a programme to cull more fixtures and move the overall quality and competitiveness right of centre. How many of you are prepared and supportive of the battle the BHA faces in forcing change, or to contribute financially towards a more interesting programme? The simple fact of life – we need a robust BHA, thoroughly in charge of what’s best for Racing. How vocal will you be in support of the surgery we actually require? I don’t see many leaders. We need a few more prepared to serve the sport and not eat its lunch.

Racetracks are feeding off rich machine based pickings from Betting, whilst many fixtures deliver a very poor product much of the time. Their focus has to be in deliverance of a better product for bettors. Not holding their hand out because 8 races makes more money than 7. Poor thinking

If I’m ever asked to stand to post and serve the sport I love in a capacity other than pricing up races, by people who seek and desire constructive change, I shall of course, but will evidently have to climb over a few stakeholders on the way! Geoff Banks October 2014