Talking Horses: affordability checks blur line between betting and gaming

No one who enjoys betting on racing would be expected to prefer form-filling to form study, but until 18 October, it is an option that many punters may want to consider.

That is the closing date for submissions to the Gambling Commission’s consultation on the implementation of “affordability” checks for customers of online gambling sites. It is almost certainly the last chance for ordinary punters to make their views known on plans that could have major implications for how – or even if – they can pursue their entirely legal hobby in future.

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The form you need is here, and though a detailed response to every question would represent several hours of your life that you won’t get back, there is no need to address any that do not seem relevant. The sections that are likely to matter most to racing punters begin at question 67.

Some background: the plan as currently envisaged is that an initial level of “unintrusive” financial vulnerability checks will be triggered when a punter has a net loss of £125 within a rolling 30-day period, or £500 over a rolling 365-day period. The checks would use publicly available information such as bankruptcy orders, or a significant history of unpaid debts.

Further checks will then be triggered by losses of £1,000 within a 24-hour period or £2,000 within a 90-day period. An important point to remember is that winnings outside the previous seven days (for the former trigger) and outside the previous 90 days (for the latter) will not be taken into consideration when calculating net loss.

Goodwood 1.35 Mount Olympus 2.10 Caviar Heights 2.45 Pink Satin 3.20 Grand Providence 3.55 Four Adaay 4.30 King Lear 5.05 Cairn Gorm (nb)

Bangor 1.50 Umndeni 2.25 Littel Flour 3.00 Quid Pro Quo 3.35 The Big Jetaway 4.10 Choirmaster 4.45 Taragrace

Ripon 4.20 Doom 4.55 Bill’s Baar 5.30 Chester Le Streak 6.00 Starproof 6.30 Golden Melody (nap) 7.00 Edwina Sheeran 7.30 All Dunn

Hamilton 4.40 Almarada Prince 5.15 Spectacular Style 5.45 Dc Flyer 6.15 Iris Dancer 6.45 Chinese Spirit 7.15 Retirement Beckons 7.45 Burtonlodge Beauty

For practical purposes, this means you could enjoy a Cheltenham Festival for the ages and finish £5,000 up, then lose £1,000 on the first afternoon at Aintree three weeks later and find that your account is locked pending checks – including a possible request for personal data such as bank accounts and payslips – when you want to use some of the remaining £4,000 profit for a bet on the Grand National two days later.

The white paper on reforms to gambling legislation which proposed the introduction of affordability checks envisaged that most would be “frictionless” and that the most intrusive requests for personal financial information would affect “only around 3% of online gambling accounts.”

Recent figures published by the Gambling Commission claim there are 31.9m active gambling accounts held by UK customers . Even 3% of that total would still represent several hundred thousand individuals, depending on how many have multiple accounts. Since the rate of problem gambling in the UK as a whole is around 0.3-0.5% of the population, a significant majority of those being asked for bank statements, payslips or other evidence of funds will be people who have been gambling safely and responsibly.

Some, of course, will supply the required information and carry on gambling. Others will refuse, or decide that it’s just too much hassle, and either abandon their perfectly legal hobby entirely or, perhaps more likely, find an operator in the unregulated grey market. And since a slice of betting revenue from legal, regulated firms is one of racing’s key income streams, either of the latter two options has the potential to put a big hole in the sport’s bottom line.

The basic aim of affordability checks is a reasonable one – to identify, and hopefully help, individuals who have an addiction to gambling. But the Gambling Commission’s proposals make the same basic mistake that has plagued the regulation of gambling for the last 20 years. They fail to appreciate the significant differences – in staking patterns, margins, cycles of profit and loss and more – that distinguish betting, on racing and other sport, from fixed-margin gaming products like roulette and online slots.

The fixed margin on roulette, for instance, is 2.7% on a European wheel with just one zero (rising to 5.2% in the US, where there is also a double zero). The margin is the same whether you gamble on single numbers at odds of 35-1, or red-or-black at even money. The size of your chip stack will vary far more dramatically if you do the former and not the latter, but ultimately, the wheel will grind its fixed margin from your stack as surely and steadily as a mill wheel grinds wheat into flour.

Betting is fundamentally different. The margin is not fixed, the odds can fluctuate and both staking patterns and swings of fortune from profit to loss can vary wildly from day-to-day or week-to-week. Gaming is a grind, while betting is a rollercoaster.

This means, in turn, that affordability checks that are appropriate for gaming could be entirely inappropriate – and unnecessary – for betting, as the example above shows. But the Gambling Commission – which has a distinctly chequered record when it comes to understanding the industry it is supposed to be regulating – seems intent on a one-size-fits-all policy.

This is not a point that anyone in the gambling industry will be making any time soon. The Gambling Commission acknowledges that gaming products are several times more likely than betting to be associated with problem gambling, but it feels like the instinct of those who run the industry’s biggest operators is to prioritise the defence of the risk-free profits from gaming.

Gambling’s main industry body, the Betting and Gaming Council, appears similarly conflicted. The clue is in the name. There are very few voices, in fact, that stand up for betting alone, and right now, it needs all the friends it can get. A reminder, then, that the consultation form is here, and that it closes on 18 October.