Ep 339: UKGC sets risk and friction benchmark for affordability pilot

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As scheduled last Friday witnessed the UK gambling commission launch its pilot program on affordability checks. The commission kickstarts is six month program to test the viability of on intrusive checks on custom deposits beginning at a 500 pound net loss threshold and moving on to 150 pound net loss by February, 2025. Prior to launch, the commission issued a technical update, citing the pilot's principal objectives of identifying high risk accounts. and maintaining frictionless checks for recreational customers. Can the pilot fulfill its primary objectives against critics who advise the commission not to use affordability as a measure of customers' wellbeing, meanwhile of significance to policy proceedings? NatGen published its two-year review of impacts of credit card wagering in which the report found no significant impact with high-risk customers. This will be the focal point to kickstart the week on iGaming Daily, where I'm joined by SBC's content director, Ted Memwear. Welcome Ted. How was your weekend? Have a good one. Good, good. Relaxing weekend. I heard that you were queuing for Oasis tickets. How did it go? Yeah, I was queuing. So, uh, let me, long story here, Ted, long story, as the whole of the whole world knows. I woke up at six o'clock in the morning, logged in about half six, quarter to seven on every single platform to try and get tickets. And I only really got in, well, I got in on Ticketmaster about two o'clock in the afternoon where they were charged about 350 pound, which was over the rate, over the advertised rate. But luckily my brother-in-law came in, stepped in and managed to get me a ticket. So I was successful in getting a ticket, just not me directly, but I don't care cause I'm going to go, I'm going to go see Oasis again. Well done. Well done on your weekend endeavors. Yeah. Thank you. Yeah. I've not seen him since. Yeah. It was, how long was it now? I was, I was 15 years old when I last saw them. And I remember saying to my mom and dad at the time, like, oh, I'm going with my friend and his parents are coming with us. That they wasn't, it's just me and a group of me is going to see Oasis. Uh, when we was like 15, it was mental. So see him again. Yeah. I'm buzzing for it. Was it Lego Manchester slang for you on our gaming daily and buzzing for it. But then it was a kick in the teeth because Saturday was such a great day of getting tickets and then Sunday United lost three and all to Liverpool. So. swings and roundabouts, I suppose. You can't have it all your own way, James. I know, I know. I still aim to have it on my own way. I still aim. Well, we're going to talk about the affordability checks in the UK Gamma Commission on the episode Ted. But before we do, it's time to mention the support of today's podcast. And it's a company who are bigger than Oasis. They're bigger than Oasis. And that is OptiMove, the number one CRO marketing solution for the R gaming market. Listeners out there, you can still grab your free month of OptiMove by visiting optimove.com forward slash SBC. I will leave the links in the description below and do not worry. It will not be as tedious as getting going through Ticketmaster. So it will be an easy process. But Ted, on to the UKGC, on to the main stuff. Yes. August is here. August is gone. Sorry. Shall we say it's just gone. How significant is its pilot to UKGC as governing, but more importantly to the gambling review. Okay, to put it bluntly, this is the most important mechanism of how the government and the gambling commission want to rewire the UK gambling sector's protections and engagements with customers. As you know, the commission has bet big on affordability as the best measure to gauge a customer's well-being to gamble. Uh, and that goes against other less technical duties or recommendations that were made, such as mandatory financial checks at thresholds, cross operated data sharing, and mandatory checks of loss limits thresholds, i.e. a customer loses that he has to be, he has to go for a one-to-one customer engagement with customer care teams. Uh, for the gambling review, I believe that alongside the restructuring of the RE, the rent levy by the NHS, this is the government's biggest reform. And it's also the reform that indicates kind of the generational changes of the gambling review. affordability checks are viewed as the intelligence led measures on which the gap the government wants to build its platform for the future monitoring and integrity of the gambling sector. So to put it bluntly, the regulatory the regulatory stakes and ambitions have never been this high. Yeah, I don't think it's out of the realms to say that this is kind of a vital piece of the puzzle for the gambling review and just to shape the future regulations of gambling in the UK. And kind of with that, do you actually feel that the commission is confident in achieving its objectives of the pilot program? Because I feel like everything that's come from the gambling review, from the whole process, it's not been the most confident to deal with. We've not felt confident going through the whole process, but do you feel the commission are confident that they're going to achieve their objectives with this? I think prior to the launch of the pilot, this is an important factor to gauge in. It's a six-month program and the commission has justified its key priorities based on checks on the pilot program being unintrusive on the majority of recreational customers and frictionless. And whether The program itself is the best method to identify high-risk customers. Uh, on the frictionless dynamics, the commission stands by its assessment that it will not impact 90% of GAMP of UK GAMP and customers signing on to book bookmakers or operators with the remaining eight facing light checks. And 2% will be required kind of one-to-one into, um, customer interventions before they sign on. Right. So really they are the ones who are going to be. be impeded on and those are the high-risk customers that are being kind of highlighted or that want to be identified. Again, on identifying high-risk customers, Helen Rhodes stated that testing on how operators can be, that the testing is given limited information to understand the severe and financial difficulties that a customer might be in. And I think that you've got to kind of split the pilot into two objectives. whether it can achieve its frictionless remit. But I think the tricky bit is identifying high-risk customers just because there is no direct science of whether even financial affordability checks can cover that measure. So what we're seeing is the kind of feedback was that the UK GC is being accused of trying to fit customer care protocols into a big box called affordability. Yeah. Okay. Yeah. For me, it's going to be interesting to see if the UKGC can kind of strike that balance between protecting vulnerable players and maintaining what they say is a seamless experience for the broader gambling public. Maybe, maybe I'm, I'm a sceptic at heart, but I hope they'll do. I hope, I hope they'll find that balance, but it's going to be interesting for me to watch it because I'll let people, I'll let the listeners gather my thoughts on them on this. But for you, we've talked about the objectives, and you've broken into the balance of the percentage of players of what they're in to do with the light touches, and the 2% who will be communicated for one-on-ones. But how has the pilot been structured to fulfill its objectives of being that frictionless and identifying its customers? Okay. So the pilot will now proceed to, is divided into four segments, but the main, the two principle criteria are frictionless and the identification of high-risk customers. The first stage of the pilot is it will conduct kind of a first scheme on frictionless interactions. And this is where the UKGC will apply kind of can 80% of customers come in. without being on the financial data that is available to them via CreditCorp, credit store agencies, without, with it being completely frictionless, right? So no interactions. They can just check off the data. The program then advances onto another layer, which is frictionless part two, again, applying kind of deeper data checks and credit reference, with credit references to agencies and the support of operators. The final two proceedings are a quantitative stage on reviewing the procedures themselves and a qualitative stage at the end of the procedures, interviewing the customers that have gone through the processes. What were the loop, what were the fault lines? Where did the pilot stumble? So it is a comprehensive assessment of how they wish to kind of technically apply it onto operators. Okay. And. Just clarity on this, the pilot, it won't be undertaken in a kind of a live environment, correct? Yes. Right. Does this not harm the proceedings? Are operators actually prepared for the changes? You see, this will be the other big test of the pilot program. So in the six months transferring it, by February, they wanted to then transfer or have kind of a mechanism in place. transfer it onto a live environment for operators. So that is the confidence of the commission and the credit agencies that it is working with that the pilot can be moved to live environment by the end of February. Here, I think that perhaps the commission might intervene and add one further stage or intervention on how the check on how the checks are applied. What we've seen from the past two years of gambling reports and PLC feedback is that they've spent multi-million pounds in new applications and applying kind of vigorous checks on the consumers prior to sign up and prior to first deposit. But again, the other thing is that the reports are coming back from gambling PLC. So that is just one segment of UK gambling. At the end of the day, it's whether the pilot and his framework can be applied to all levels of operators. And as it stands, the £150 deposit limit that's set to be enforced by February 2025. But is this contingent on the findings of the pilot result? Do you think it will change further down the line? This is the big question about what the final solution looks like. And in my opinion, look, if the checks are, if it does what it says on the tin and the checks are unintrusive at the, at the levels of the UK GC pledge, then I think that they should be commended. You have to remember that UK gambling will be the first market to go through this process of adding a layer of affordability checks on customer protections. and customer signups. The for me, what really kind of stands out is that kind of objective or determination on affordability as a measure to, um, to identify high risk customers. Uh, again, I'll revert back to there's no exact science for that. There's many variables as to why a customer is high risk. And I think that just adding the affordability checks mark on that will not fulfill that. It might be an objective that has to be resorted by the Gammon Commission. I think flexibility is kind of key in this whole process. I mean, if you're testing something in a non-live environment, there's absolutely no guarantee of what you think is a perfect process. Once it goes into a live environment, it will replicate the non-live environment success. UKGC, they have to be flexible with this. I think they've indicated that they will be. But again, I think flexibility is the key thing moving forward for this. And moving on to the NatGen report, cited that no impact by the credit card ban on high-risk gambling. Not the outcome policymakers wanted or happy things, happy days. A good question here. And again, I'm going to stay impartial and say, yes, yes. And look, yes and no, right? This is an assessment, the two year assessment carried out on the credit card ban of UK gambling, which, and let's remember this, the majority of operators did support at the time, right? There was really not a lot of friction against them. And What the study determined was that high risk gamblers, and again, this is going back to the riskiest segment of our business is still very misunderstood. And I think what researchers or what stakeholders are learning is that you can't just apply these kind of overbearing terms to analyze a segment that is so unique. So high risk gamblers did not change their behaviors. But At the same time, there wasn't a layer of protection by the fact that they knew that they could no longer gamble with credit cards. What happened is that because these are risky customers, they still managed to gamble. They still found a means outside the system to borrow money, which was outside of the financial systems. And it was kind of an uncontrollable element. Um, the framework could not oversee, um, there has been a success to the credit card ban, uh, the majority of UK customers are aware of it. And it also changed behaviors for kind of medium to low limit players in how they engage with gambling, with gambling companies financially. Okay. So by the time everyone agreed on this, it was deemed a good policy to introduce. Obviously the It's not made that big of an impact if none at all. So what actually determines whether a good or bad policy has been implemented for UK gambling. James, you are. Okay. Oh, here. And, uh, I think that this is one thing we, we try and kind of reflect on our SBC, right? That it is not a bad thing. for a governing body or a UK authority to have high regulatory ambitions, man, and they should be supported by the industry. But what you see is, I think, stakeholders and the media, and everyone wants kind of a blunt response to what is happening, right, or a determination. With the UK gambling review and with the credit card ban, I think the assessment is overall, did these policies take UK gambling to a better platform or a more, you know, or a more protective framework for customers? And I think in the credit card ban, it did. I think no one can deny that. I'll just finalize by saying, look, with the gambling review, this isn't a blunt outcome that you should be looking for, but you should be just analyzing the process. And I think it's vital for everyone to get on the same page. Yeah. We have, you know, we can all be part of, of correcting the, the wrongs or fault lines of the industry. But from a regulator's point of view, I mean, I think if you're a regulator, you've got a plan until you get punched in the face. And that is part of the process of overseeing a gambling review, which has taken four years, right? we're getting towards a settlement stage, right? It's how the reforms land and how they're applied now. Okay. I suppose any policy that doesn't have a negative effect is a positive policy, so to say. Um, but like I said, we're going to the settlement stage now and Ted, you will be all over this on SBC news. No doubt. So the listeners out there, keep your eyes peeled on SBC news for anything breaking when it comes to the white paper. Also keep your ears tuned in because Ted will be back to walk us through any and all developments that we do get. But apart from that. This has been iGamingDaily, I've been James Ross, I've been joined by Ted Manweir, thank you for listening.

Ep 339: UKGC sets risk and friction benchmark for affordability pilot
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