Written evidence submitted by Mike Langdon

1)     Affordability checks undertaken by bookmakers at present should be banned immediately and if introduced should only be conducted by independent qualified individuals.

2)     Individuals should be allowed to opt out of any of these affordability checks by signing a personal waiver that they will take all responsibilities for their losses.

3)     Segregate Sports Betting from Casino & Gaming with separate sites and prohibit cross selling of the casino product. These are two different activities with different skill and risk levels. The bookmakers want to sell on to increase and guarantee profitability, so these need to be separate if safety is the genuine concern.

4)     Use Machine Learning algorithms to identify problem gamblers in the same way they are used for restricting winning accounts. This will work without additional information, bookmakers have more than enough to assess each bettor. The GC could agree and standardise these algorithms, after all the research should have optimised the detection patterns. See point 2 for the waiver.

5)     The White paper fails to make use of its own data. For instance, those over 55 according to the data presented are no risk as problem gamblers. The affordability checks proposed fail to take any account of this or other data contained in the paper.

6)     There is no reference to Betting Exchanges and how these will be incorporated. These turnover substantial amounts on a daily basis.

7)     Offer some real meaningful training to punters at risk, not trite 5-point bullet points. This would include bank management, risk management, loss mitigation and signs and signals of problem gambling etc. Where is GC on this?

8)     There should be no betting introductory offers including free bets/spins. Offers solely to new customers to be prohibited.

9)     Betting restrictions limiting bettors to pitiful amounts should be lifted and bookmakers should be forced to lay to a minimum value of £2000 liability at advertised prices. A similar initiative has worked successfully in Australia.

10)  Why are scratch cards and lotteries not part of any legislation given the levels of participation and the inherent risks.