On Tuesday last week, Andrew Rhodes, CEO of the UK Gambling Commission, published an open letter to readers of the Racing Post.
In many ways, this is a welcome development. Whilst I will never be anything other than a supporter of The Racing Post, it cannot be doubted that some of their recent coverage relating to affordability checks has muddied the waters rather than provide clarity on an issue where it is desperately needed.
But what was more interesting was a subtle change in language that suggests that for the Gambling Commission, and perhaps for operators themselves, the penny is starting to drop when it comes to what is and isn’t possible around ‘frictionless’ affordability checks.
Because in a key passage, Mr Rhodes said the following:
“It’s estimated that just 3 percent of accounts would undergo financial risk assessments. And by our estimates at most just a tenth of that 3 percent would not have a frictionless check via credit reference agency or open banking data.”
The emphasis on the word ‘or’ has been added by me, because that small little word marks a significant change of tack by the Commission.
Until now, the implication has been that these checks will be ‘passive’ (ie the player either does not know they are happening, or simply gives consent by clicking a button). That has caused some confusion and uncertainty, because it is hard to understand precisely how a passive check like this could actually do the job of protecting players.
The ‘or’ now suggests that Open Banking may well be the first option for these checks, rather than a fall-back position. And this is entirely welcome, because (as I have said before) Open Banking seems to be the ‘least bad’ approach to performing these checks in a way that protects players whilst being as frictionless as possible.
I may be guilty of reading too much into these words, but I don’t believe the Gambling Commission would use them lightly. It feels as if the phase of attempting to tell every vested interest what they want to hear is over, and the move towards practical, workable solutions to the affordability problem is beginning.
The simple fact is this: there is no passive check out there that can come close to properly answering the key questions every compliance officer needs to answer when a player’s spend goes over a certain level, namely:
A credit reference agency, seemingly the great white hope up until a few days ago, will not have the data that answers those questions (if anyone believes they will, they are welcome to get in touch with me and explain what that consists of).
To the best of my knowledge, the only way to answer these questions is through the sharing of bank data. And Open Banking is the smartest, simplest way to do that. We know - when our customers switch their financial checks to ClearStake they see a 160% increase in the number of players who go through those checks and continue betting.
It appears that this particular penny is starting to drop. The sooner it does, and the sooner the industry gets behind the inevitable and makes these checks as simple and painless as possible for all concerned, the better. They are the only way to ensure that we protect players (which is the whole point, remember) whilst ensuring as many as possible complete those checks and continue to stake at levels they can afford.
Let’s hope that is what Mr Rhodes was hinting at, and solve this problem for good.