UKGC Remote Gambling Consultation - Starts this week

[Richas]

The UKGC (The UK Gambling Commission) is having a consultation on remote gambling and the Licence Conditions and Codes of Practice (LCCP).

They have just said in their newsletter that this will begin later this week.

This is important because every major poker and casino site will have to get a UK Licence next year if they want UK customers and the conditions within the LCCP will apply to all players, not just those in the UK.

Essentially those LCCP regulatory rules will be the new default standard for online poker/casinos that the sites need to comply with.

The Chair of the UKGC has made clear that two major parts of the consultation will be:
1) Player fund protection
(post the Full Tilt debacle. That had a big impact upon the regulator and the politicians and the new tax law (Point of Consumption) will include new powers for the commission on player funds).
2) Poker Regulation
Currently the UK has one tiny poker licencee and so little or no experience of online poker regulation. It does have the legislative structure and powers to do the job well but they will need to be encouraged to do so.

I will be doing a poker based submission to the consultation but anyone with any interest in remote gambling should be looking to submit their views to the consultation.

There is no shortage of issues, pick your fave and have your say. Reversal of withdrawals? Misleading Bonuses? Terrible terms that mean that winning a jackpot means a few thou a month not a jackpot? Lack of disclosure of RTP? No game description to allow you to work out optimal play?

This is the chance to ask for the rules you want. Also the rules will apply to the big software suppliers like PlayTech ad Microgaming not just their front organisations.

Have fun.

 

[Richas]

The consultation docs are out

1) Proposed changes to the LCCP

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2) Proposed changes to player fund protection

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Close date is 4 Dec so someone at the UKGC is going to be doing some work over Xmas.

 

[threescatters]

The consultation docs are out

1) Proposed changes to the LCCP

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2) Proposed changes to player fund protection

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Close date is 4 Dec so someone at the UKGC is going to be doing some work over Xmas.

Cant get these links to work

 

[Richas]

Cant get these links to work

Try for player funds:

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For Licence Condistions and Code of Practice This is the link but it seems to be broken today:

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This is the link to all consultations:

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and the LCCP link is down from there today.

Makes me glad I downloaded a copy of the longer LCCP PDF as their website is flakey.

 

[Richas]

I have a 23 page PDF draft response to the Player Fund protection consultation available here

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The consultation doc that gives the questions context is here

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My draft is poker dominated, as that's my thang, but I did include the progressive jackpot Joyland/Playtech issue and my stuff under Question 18 re network liabilities might be of interest to some.

Comments welcome, it is a draft. I argue each bit with 100% commitment in the draft but tell me I am wrong and I will listen and maybe change my POV.

This is a real chance for far better player fund protection, let's not miss it.

 

[Nifty29]

I have a 23 page PDF draft response to the Player Fund protection consultation available here

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The consultation doc that gives the questions context is here

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My draft is poker dominated, as that's my thang, but I did include the progressive jackpot Joyland/Playtech issue and my stuff under Question 18 re network liabilities might be of interest to some.

Comments welcome, it is a draft. I argue each bit with 100% commitment in the draft but tell me I am wrong and I will listen and maybe change my POV.

This is a real chance for far better player fund protection, let's not miss it.

I admire your tenacity and will attempt to peruse your submissions over the weekend

On the subject of poker....I haven't played for a while and was wondering where you would recommend I try out to get started again. All I want is a fair game with decent tournaments. Sorry for the derail (feel free to PM if u like). I love me a spot of Omaha

 

[threescatters]

I admire your tenacity and will attempt to peruse your submissions over the weekend

On the subject of poker....I haven't played for a while and was wondering where you would recommend I try out to get started again. All I want is a fair game with decent tournaments. Sorry for the derail (feel free to PM if u like). I love me a spot of Omaha

PokerStars AINEC

 

[jetset]

Congratulations on a very well-considered submission, Richas.

It's a long read but a very interesting one, and I find myself in agreement with most of your conclusions, which are clearly presented in what I believe to be an unbiased manner.

Good idea to illustrate some of your contentions with case histories, too!

 

[vinylweatherman]

What I think would really help the UKGC is for them to form a "players' panel", with members nominated by other players and important and well respected advocates (like Bryan for example) in the industry. Operators too could nominate some of their most trusted loyal VIP players.

This would enable the UKGC to see the industry from the players' point of view, and it might show what is REALLY going on, rather than what the UKGC are told is going on by it's licensees and offshore jurisdictions.

I had a look at their players' fund proposals, and it seems the biggest issue is that whatever they propose, it would not have helped in most of the high profile failures where there was intentional fraud on the part of the operators in order to use players' funds in an attempt to rescue the business from failure without getting caught.

With the infamous Purple Lounge case, both players and the LGA were lied to by Purple Lounge execs, with players getting the usual "technical issues" BS to buy time, and with the most troublesome complainants getting the "technical issues" sorted personally in order to make them go quiet. So long as the UKGC rely on self reporting, another Purple Lounge fiasco will not be prevented.

What it WILL (probably) prevent is the honest operator accidentally finding itself unable to cover players' balances, and then having the shortfall exposed via a "run on the bank" scenario as players are spooked into a herd mentality and try to withdraw all at once.

Of course, it's not just about players' funds, Revenue and Customs also need to make sure that operators don't use the money needed to pay the taxes to bail themselves out, and here it seems a far more robust solution has been found to ensure that the taxes get paid no matter what. Players may feel it unfair that government get to have 100% guarantees against the loss of tax revenue in the event of operator failure, whilst players have to make do with a higher risk system which cannot ever offer 100% protection.

Maybe the UKGC should follow the HMRC approach by having an offshore operator provide a UK based guarantor who is ultimately legally responsible where players lose out via operator fraud, or otherwise circumvention of the systems for guaranteeing players' funds.

Unlike the UK, remote gambling companies are allowed to hide the beneficial owners behind trusts, shell companies, etc, whereas the UKGC don't just license companies, individual names employees and the owners need their own individual licenses and background checks. Given that this will be a fully legal framework, there can be no justification for hiding the ownerships in this way.

Another requirement should be that UKGC licensees cannot also mix US operations with the UK ones, as another "black Friday" event over there could bring down a company leading to the potential inability to pay it's UK and EU players on demand due to part of their player funds having been seized by the DoJ. It's what we saw with Full Tilt, and there was no certainty that UK and EU players would ever see their money, and this could have happened had Full Tilt's owners decided to just walk away rather than work out a takeover that included the restoration of players' funds. Purple Lounge DID just "walk away", and before this, TUSK (Casino Action) only worked out a solution for it's casino players, poker players lost everything. Even worse, they were overseen by eCogra at the time, which made players feel extra safe (same with Purple Lounge).

 

[Nifty29]

You wouldn't by any chance be wanting to BE on that player's panel would you

The main problem is that bureaucrats won't give much weight to just some bunch of gamblers wanting to put their ore in on the subject, which makes the whole thing a waste of time.

In the end, Whitehall will do whatever suits Whitehall best, and whatever will appease the lobby group with the deepest pockets. Just like any other democracy.

 

[vinylweatherman]

You wouldn't by any chance be wanting to BE on that player's panel would you

The main problem is that bureaucrats won't give much weight to just some bunch of gamblers wanting to put their ore in on the subject, which makes the whole thing a waste of time.

In the end, Whitehall will do whatever suits Whitehall best, and whatever will appease the lobby group with the deepest pockets. Just like any other democracy.

It hadn't crossed my mind

However, it shouldn't be a long term fixed panel, there would be a danger of it's members "going native" due to exposure to the Whitehall ways. A regular turnover of members would ensure that there was regular input of fresh views.

The consultation itself goes some way towards involving players, but it's a "one off" snapshot of opinions. It does not address how players begin to feel about the new framework once it has been implemented.

An alternative would be some kind of regular consultation, or even a public meeting, where the views of players can be regularly sought. This would have the benefit of allowing ANY player to take part if they felt a particular issue has not been dealt with.

It will take a while for players to see how they have ended up better protected under the new regime, and what the cost has been (such as fewer promotions).

If it looks like "lobby groups" with deep pockets are taking over, then maybe players need to start their own. There is also the matter of a bill going before parliament that seeks to place draconian restrictions on the powers of deep pocketed lobby groups to influence government composition and policy. most especially in the run up to an election.

 

[Richas]

The consultation itself goes some way towards involving players, but it's a "one off" snapshot of opinions. It does not address how players begin to feel about the new framework once it has been implemented.

It does not involve players at all unless they get off their butts and submit something. On the Point of Consumption Tax consultation there were 40 submissions, only one was by an individual, the other 39 were all industry groups or firms or campaign groups like the Salvation Army (they have a record of responding on all things gambling in UK consultations with a fairly moderate regulation good but do more to protect type of position that would horrify US church groups). Anyway here is the full list:

• Albert Poggio (Government of Gibraltar)
• Alderney Gambling Control Commission
• Bingo Association
• British Horseracing Authority
• Federation of Racecourse Bookmakers
• Gibraltar Betting and Gaming Association
• Gibraltar Gambling Commissioner
• Government of Gibraltar
• Hi-Growth eGaming Companies Forum
• Isle of Man Government
• National Casino Industry Forum (NCiF)
• Northern Ireland Department for Social Development
• Northern Ireland Horse Racing Group
• Remote Gambling Association
• The Salvation Army
• Sport and Recreation Alliance
Gambling companies and other businesses:
• 888 Holdings Plc
• 32Red Plc
• BDO LLP
• Bedfred
• Bet365 Group Ltd
• Betfair Ltd
• bwin.party digital entertainment Plc26
• Dictao
• Ernst & Young LLP
• Gala Coral Group Ltd
• Gambling Data
• GBI Racing Ltd
• IG Group Holdings Plc
• International Game Technology
• Ladbrokes Plc
• Paddy Power Plc
• Pokerfuse
• The Rank Group Plc
• Sportech Plc
• Sporting Index Group Ltd
• UC Group Ltd
• Victor Chandler International Ltd
• William Hill Plc

The closest to a player voice in this list was Pokerfuse, a poker media outlet, I had my differences with their response but at least they thought they were helping players (mostly they were, love you Hood). I know they are submitting to this one too.

Gibraltar had 4 submissions, poker players 2, slots/blackjack/roulette players had a combined total of 0. I lost count of the casinos.

Now this consultation might get more individuals to bother but 2 mainly poker focussed player submissions is just not enough. If you want player fund safety, excessive fees, bonus issues and/or unfair terms and conditions addressed on the games you play then YOU need to write something down on those one or two questions you care about most and reply to BOTH consultations (player funds and rules) to have your say. If you want real info on RTP rates and real info on games that show a way to get to optimal play then ASK FOR IT!

 

[vinylweatherman]

It would help if the document was available. I keep on getting "not available" or 404 errors trying to reach it either through the links or their website.

I expect the same is true for the industry submissions, but they are geared up to ensure that their own views get put forward, and have paid people to do the research, prepare the submissions, and even to ensure the PR is taken care of. This already places individual players at a disadvantage, as they don't generally have "staff" to take care of things.

If it wasn't for you, I bet most players here would not even have known this was taking place.

It seems the poker community were better prepared, but they had suffered considerable losses from the lack of protection of players' funds. When TUSK failed, casino players were quickly taken care of and didn't lose out in the end. It was different for poker players. Purple Lounge seems to have been the first time casino players have been stung by a sudden failure of a high profile Microgaming casino, and not had their balances taken on by Casino Rewards as before.

 

[Richas]

I have a draft of the second UKGC submission on the Licensing Conditions and Code of Practice.

It is heavily poker focussed and a bit of an essay/treatise on poker cheating. Under that the main recommendations are licensing for all third party software for in game poker use, bringing poker data suppliers into regulation via licensing, warnings for players re the criminal sanctions possible, a call for cheats to be prosecuted and better information gathering by the Commission on poker cheating.

This poker history/treatise is most of the 45 page document.

More general casino stuff - Q1 has a bit on misleading bonuses. Q8 calls for an end to reverse withdrawals and some unfair charges for money transfers, Q32 for self exclusion option for all UK operators with one call and possible "vertical" exclusion.

Affiliates might be interested in the LCCP social responsibility extension to them proposed by the UKGC under Q4 and Q5 though I don't address this in my response.


My draft submission available here:

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UKGC document being responded to here:

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Comments welcome.

 

[incrediblestuff]

Somehow missed most of the follow ups in this thread, i commend your involvement!
May i inquire what your prerogative/main target is going to be in the site "www.richas.com" that is appearing in your response as footnote?

 

[Nifty29]

Somehow missed most of the follow ups in this thread, i commend your involvement!
May i inquire what your prerogative/main target is going to be in the site "www.richas.com" that is appearing in your response as footnote?

I don't think it is to sell soap powder

Richas is putting a lot of time and effort into this....he will want a return on that I assume.

Interesting the parts about limits on transactions charges etc. The ewallets charge what they charge...if the fees the casinos are allowed to charge don't cover the actual expense, then it is going to come out of the player's pocket.

Add that to the "no reverse period" rules, and it means many more transactions and many more fees for the house as players will need to make fresh deposits. What's worse is that the casino already covers deposit costs in most cases, so a large increase in those means, again, more cost to the player. There is only a certain amount an operator can absorb. Profit for online casinos depends on volume and strict cost control. I just don't see how UK operators will be able to offer high RTP (at least as high as currently) when they have to pay 15% turnover tax and higher transaction costs. It might be that only the really big guys will be able to do it, which means less competition, which means less for the consumer. The UK could very well end up with a supermarket type scenario where a few huge companies own almost all the supermarkets, which means they can charge/offer what they like because you pretty much cannot go elsewhere.

LIke others have said, I just don't see it being the "white knight" that people like VWM etc seem to think. Once Governments get involved in these kinds of things, it becomes a conga line of suckholes all drinking from the gravy train at the expense of the punter. I hope I'm wrong.

 

[Richas]

Somehow missed most of the follow ups in this thread, i commend your involvement!
May i inquire what your prerogative/main target is going to be in the site "www.richas.com" that is appearing in your response as footnote?

Personal blog site that I have never got around to launching - no commercial goals.

I responded to the treasury consultation on tax as an individual and so of the 40 responses recieved 39 were named. I wanted an online identity that would make the submission more transparent by letting it be named as from the richas personal blogsite so anyone that interested could see it.

I think consultations on a range of issues should be opened up to consumers/citizens rather than being a vehicle for lobbying by commercial interests.

I hope that is clear enough, if not please shout.

 

[Richas]

Interesting the parts about limits on transactions charges etc. The ewallets charge what they charge...if the fees the casinos are allowed to charge don't cover the actual expense, then it is going to come out of the player's pocket.

Add that to the "no reverse period" rules, and it means many more transactions and many more fees for the house as players will need to make fresh deposits. What's worse is that the casino already covers deposit costs in most cases, so a large increase in those means, again, more cost to the player. There is only a certain amount an operator can absorb. Profit for online casinos depends on volume and strict cost control. I just don't see how UK operators will be able to offer high RTP (at least as high as currently) when they have to pay 15% turnover tax and higher transaction costs. It might be that only the really big guys will be able to do it, which means less competition, which means less for the consumer. The UK could very well end up with a supermarket type scenario where a few huge companies own almost all the supermarkets, which means they can charge/offer what they like because you pretty much cannot go elsewhere.

You may be right Cazenove certainly sees the tax as a big barrier to smaller entrants, though why with a B2C model I don't quite get. There is a risk of the market being big players only but I think that is likely in any white market - the branding and marketing power will tend to fewer larger suppliers just as has happened in every industry in every era. The big eat the small. Then we get in to competition issues which is differet to straight consumer protection.

As for costs for transactions, I have no problem with charges that relate to the sites costs for that. It may be that they need to get e-wallets to shift their pricing structure so it is not all on deposits and nowt for withdrawals but the principle that surcharges for things like card transactions should relate to the real costs is well established. Hiding the hit on the consumer in hidden charges is worse than having the real cost in the product.

As for reversals, I do see your point but they are so awful for problem gamblers that they should not be allowed. A responsible industry would not test the resolve of players to withdraw and then market bonuses to them if they do not withdraw, it is unethical. Trapping players money on site for days vs instant deposit is just not right.

A white market with all payment methods allowed cuts the cost for sites. Terms for regular players can be discussed with the transaction providers, the premium charged for "gambling" as a whole because of fraud should be able to be reduced for regular players using the same system without fraud for a series of transactions. Today sites get ripped off by providers because they are not regulated enough and not socially responsible enough in terms of protecting vulnerable players who many fall in to fraud.

 

[incrediblestuff]

Don't shy away from commercial goals, or at least don't exclude them, like stated by me and a few members, there is a lot of effort obviously going on from your side, i wouldn't find it a negative at all if there was a site, be it blog styled or whatever, that had a few affiliate links, a donate button, or whatever you can think of that fits your standards.

I hope you do launch it after all, and of course totally up to you if you put in anything moderately commercial.
I would gladly put that blog as a link on my own site, and i think you could also apply for webmeister status here, and put a link in your sig, as i feel a lot of the members here, and of course Cm, and team have a lot of respect for your efforts!

Hope i am not out of line here ^^

 

[Richas]

Don't shy away from commercial goals, or at least don't exclude them, like stated by me and a few members, there is a lot of effort obviously going on from your side, i wouldn't find it a negative at all if there was a site, be it blog styled or whatever, that had a few affiliate links, a donate button, or whatever you can think of that fits your standards.

I hope you do launch it after all, and of course totally up to you if you put in anything moderately commercial.
I would gladly put that blog as a link on my own site, and i think you could also apply for webmeister status here, and put a link in your sig, as i feel a lot of the members here, and of course Cm, and team have a lot of respect for your efforts!

Hope i am not out of line here ^^

TBH I don't want the commercial side at all. I don't need the cash or the work with it and it would compromise my position on my other bug bears - getting better self exclusion and problem gambling support and annoying the commercial lobby against FOBTs and the US casino types who oppose online gambling in their own self interest.

It's just easier to have no commercial interest.

I do plan to launch the blog soon though.

 

[Richas]

I have now made my submissions to the UKGC Player fund protection consultation and to the Licence Conditions Code and Practice consultation.

You can check them out here:

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Both are very poker focussed, there is a call to ban the reverse withdrawal facility, a little bit on bonuses (LCCP doc Q1) and a bit about progressive jackpots (player funds protection document), a bit on making withdrawal fees match the cost of transaction....

They are pretty long essay style documents with a lot on poker cheating and poker software stuff.

Here's the deal - I have made my submission. if you disagree - have your say. It is important that players get a voice, even if it is one that disagrees with me. Put your own submission in - the deadline is one month from today - 4 December 2013.

If you do support some of the things I have said, tell the UKGC that too.

It does not matter if you are a UK resident or not - this new licensing regime will affect any site that serves UK customers. The player fund protection will apply to not just the UK as will the s/w licensing and getting network operators regulated for the first time (not just the skins).

 

[Richas]

Consultation Close Date 4th Dec

I have now made my submissions to the UKGC Player fund protection consultation and to the Licence Conditions Code and Practice consultation.

You can check them out here:

You do not have permission to view link Log in or register now.

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Both are very poker focussed, there is a call to ban the reverse withdrawal facility, a little bit on bonuses (LCCP doc Q1) and a bit about progressive jackpots (player funds protection document), a bit on making withdrawal fees match the cost of transaction....

They are pretty long essay style documents with a lot on poker cheating and poker software stuff.

Here's the deal - I have made my submission. if you disagree - have your say. It is important that players get a voice, even if it is one that disagrees with me. Put your own submission in - the deadline is one month from today - 4 December 2013.

If you do support some of the things I have said, tell the UKGC that too.

It does not matter if you are a UK resident or not - this new licensing regime will affect any site that serves UK customers. The player fund protection will apply to not just the UK as will the s/w licensing and getting network operators regulated for the first time (not just the skins).

I wanted to flag up that these two consultations close in just under 2 weeks time - on the 4th December.

If you want the UKGC regulator to do anything to help online gamblers or the online gambling industry this is your chance. You don't need to do a full blown response as I have - if you have one thing you want them to do....tell them. Whatever the personal gripe that you have with regulation (or lack of it), whatever bit of industry behaviour you hate or want to make sure is still allowed - tell them.

The rules will affect UK and non UK residents so anyone can have their say. The GRA certainly have!

If you want help with which consultation or under which question in which consultation your bugbear fits under just ask, I will try and help. Even if you disagree with what I said I'll help because it is important players views are heard.

 

[Richas]

I wanted to flag up that these two consultations close in just under 2 weeks time - on the 4th December.

If you want the UKGC regulator to do anything to help online gamblers or the online gambling industry this is your chance. You don't need to do a full blown response as I have - if you have one thing you want them to do....tell them. Whatever the personal gripe that you have with regulation (or lack of it), whatever bit of industry behaviour you hate or want to make sure is still allowed - tell them.

The rules will affect UK and non UK residents so anyone can have their say. The GRA certainly have!

If you want help with which consultation or under which question in which consultation your bugbear fits under just ask, I will try and help. Even if you disagree with what I said I'll help because it is important players views are heard.

Consultations close 4 Dec - if the regulator or industry does stuff you don't like and you did not tell them about it via this, its on you.