Why rich Open Banking data gives confidence in affordability decisions

“At higher levels of spend which may indicate harmful binge gambling or sustained unaffordable losses … there should be a more detailed consideration of a customer’s financial position”

With these words, the recently published UK Gambling white paper confirmed that the government was expecting operators to ensure that players losing over a certain amount (£1,000 in a day or £2,000 in the space of 3 months) to have confidence in their ability to afford it.

Unfortunately, we don’t know much more about what “a detailed consideration of a customer’s financial position” actually means yet. The outcome of the ongoing consultation may clear some of that up, and there are already hints in some of the language being used. But even before that happens, it might be worth evaluating the competing approaches to determining “a customer’s financial position” from a positive point of view. Which approach gives an operator the confidence they need to make fast, accurate affordability and source-of-funds decisions?

Before we discuss each in turn, let’s broadly categorise the options open to most operators at the moment. These are:

• A collection of ‘static’ data points, usually provided by a credit reference agency, that might include bankruptcy and court judgement history, credit history, and ONS data relating to average salaries and so on. Without explicitly calling this out, it appears the Gambling Commission envisage adding CATO data to this mix.
• Bank statements supplied by the customer, which if everything goes right include a recent 3 months worth of data.
• Bank data supplied via Open Banking (again with the customer’s consent) that covers the last 12 months up to the present day.

When making an affordability or source-of-funds decision, what an operator needs is certainty. And it is important to understand that this isn’t just for the purposes of meeting regulatory requi