Hot topic alert: FRC Parliamentary Debate & GC Blog
More Financial Risk Check (FRC) discussion last week and this, with a ‘next steps’ blog post being published by the Gambling Commission on Friday and the eagerly anticipated parliamentary debate taking place yesterday.
Regarding the blog post, there wasn’t a wealth of new information. Tim Miller reiterated what he and Andrew Rhodes stated at ICE, that the enhanced FRCs will be rolled out via a pilot scheme involving a selection of operators, to test how data sharing will work in practice. The pilot scheme is expected to last between 4 and 6 months, during which participating operators will not be required to act on information they receive but will be expected to continue protecting consumers by implementing existing player protection controls.
Light touch 'vulnerability’ checks will be implemented, initially at a higher threshold than outlined in the consultation, however we will see that threshold drop to the originally proposed level over the course of the summer. Interestingly, the Commission expressly stated that they will not require gambling businesses to consider an individual’s personal details, such as their post code and job title as part of these checks. In the current framework it’s tricky to understand how this will work, as to our knowledge customer address is a key data point being used by all existing solutions. However, a roll back from the Commission’s recent hard line around collection and use of occupation very early in the customer journey will be welcomed by operators (but maybe less so by the ones who’ve recently been forced to invest significant resource into implementing this process, following a regulatory assessment).
Regarding the parliamentary debate, as expected it was very well attended, particularly and unsurprisingly by MPs representing constituencies which house horse racing courses within them. Whilst many of the finer key points were raised and debated, for example what we really mean by frictionless and the use of which type of data can be described as such, more than one minister showed themselves to have negligible understanding of the complex matter at hand, never mind the industry and its consumers as a whole (we won’t name names). The black market issue was touched on a few times and referenced by gambling minister Stuart Andrew in his summing up, but really, it didn’t feel like a major collective concern.
Remaining conspicuous by its absence within both updates, is how operators will be expected to handle consumers off the back of vulnerability and enhanced FRCs being conducted. For us at Betsmart Towers, and for our many UK clients, its startling how little consideration has apparently been given to this key element of making the checks work. Whether they’re mandated at the currently proposed thresholds or not, whether they are facilitated by use of CATO, SCORE, Open Banking or something else, the detail which sits behind the checks and their outcomes will be imperative in defining whether the changes have a positive impact on protecting the vulnerable or not.
The Commission have promised further detail will be published imminently, via their consultation response, which is due to land next month. We very much hope that the response will include full and detailed information to enable operators to begin planning the process flows required to support implementation and ensure that responsible consumers are truly impacted as little as possible. Furthermore, we hope that the results of the pilot schemes will be transparent and that all key stakeholders will be provided an opportunity to contribute to any future discussions which arise as a result.
Building efficient, operational processes to ensure compliance with new regulation is never easy, but luckily it sits right in Betsmart’s sweet spot. To learn more about how your company could benefit from our collective 100+ years of experience, don’t hesitate to get in touch.