Doing the math

In our recent series of articles we’ve looked at practical ways to retain as many players as possible when performing financial checks. And if you’ve been following our advice, you should now be in possession of Open Banking data shared by your players.

Job done? Unfortunately not. In fact, what happens now is of vital importance when it comes to maximising customer retention. Because time is of the essence. 

To put things really simply: every single second your player has to wait for a decision, is a second during which they might decide to go and look elsewhere. We might not want to admit it but betting and gaming are fungible products, so that isn’t an idle threat, it is very real. 

On that basis, the goal must be to make decisions in seconds, rather than days (or even week).

But at the same time, of course, we must make the right decisions. Speed without accuracy isn’t just useless, it is actively dangerous. The good news? When financial data has been shared via Open Banking these two requirements need not be in competition with each other. As long as you are building or purchasing a platform that does the job correctly, you can make fast decisions in confidence.

Let’s talk about what that solution looks like first, before discussing what to look for in the data itself.

Building, or buying, a solution

As most people are aware, Open Banking data in itself isn’t particularly helpful. Like any other form of data, it must be interpreted before it delivers real insight. That means plugging it into a platform or product that does that job for you. 

What should that platform look like? Well, with our neutral hats on we would recommend ensuring that it:

• Accurately identifies salary or income payments over time. In most cases income is the most important variable you will be looking at, and it isn’t as simple as identifying payments in. The ability to detect a consistent income, whilst also allowing for some variation, is key.
• Categorises transactions as accurately as possible, but allows for and learns from corrections. Categorisation is central to understanding how a customer spends money, and whether there are any transaction types you may not want to see hidden in the data
• Surfaces key data as required (see below), but also allows for the compliance team to drill down into specific transactions if necessary. In most cases, decisions can be made without looking into the weeds, but in others, you will have to look at individual transactions. The right platform will support both models.
• Gives the compliance team control. Any solution needs to be customisable to the unique needs of your organisation. You have your own policies, and your own opinions about what is and isn’t relevant. In an ideal world the platform can make decisions (or at least recommendations) based on your compliance criteria - without human input.
• Provides transparency and consistency around decisions. The purpose of a platform of this type is ultimately to make accurate compliance decisions and - down the line - share them with the regulator when required. That means the platform should enable the storage of these decisions, with any accompanying data and reasoning alongside them, for review at any stage in the future.

I could go on, but this would become a very long blog post. The list above captures some of the key attributes of an effective solution. Let’s finish by briefly discussing the key data points that you may want to surface when you have it in place.

Key data points

Before going any further, let us be clear. We are not the UK Gambling Commission. Nor are we your compliance team. What follows is merely our own take on what you might choose to look for, albeit coming from a place where we have worked with a number of operators over the years on precisely this challenge.

It should also be understood that the goal of this process is not to give players a ‘score’. It is to look at specific compliance checks and either pass or fail those players based on current information. 

What follows is a limited list. There are so many things you might want to check we couldn’t possibly cover them all. But four that stand out would be:

• Income and disposable income. Reading between the lines of advice from the Gambling Commission, and having heard war stories from various audits, you can be sure you will need to have a reasonable handle on a customer’s income AND disposable income. As above, that means accurately detecting income (which isn’t a trivial challenge), and categorising spend in a way that enables a distinction between committed and discretionary spending - and then surfacing the result.
• Gambling spend. The other side of the central equation in this process. You should have a clear understanding of the amount a player spends with your business, and what that number is as a percentage of disposable income. You may also want to track total gambling spend. That is up to your own policies.
• Specific transactions and transfers. For many operators specific transaction types are a red flag. That might be payday loans, for example, or credit repayments that cannot be covered with disposable income. Alternatively, transfers in and out may be something an operator wants to check on. In many cases, isolating transfers over a certain amount can help speed up the decision-making process.
• Rates of change. With any metric, the static data may not tell the whole story. Many operators will want to look at rates of change, particularly when it comes to salary or gambling expenditure. Rapid rises and falls signify a risk, but equally they may simply reflect a consistent seasonal pattern. Fortunately a platform like ClearStake can automatically calculate these rates, and embed them into the decision engine. 

There is more to say on this topic. A lot more. If you’d like that conversation then by all means get in touch. Next time we’ll conclude this series with a look at handling customer comms following a decision, and how to manage the ongoing compliance process afterwards.

See you then!

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