In-running (In-play) betting: Issues paper Consultation responses form Name: Mike Stadler Job title:professional Punter Organisation:Self Address: Email: If you are responding on behalf of an organisation, please indicate which type of organisation: Industry body Government body Local authority Regulatory body Charity Help Group Faith Group Other Please specify
If you are responding as an individual, please indicate your own interest: I am a full-time professional punter, who has evolved with the betting exchanges over the last 8 yrs. +/- 90% of my business is 'in-running' - mainly 60% horse-racing, 30% cricket, 10% Rugby/Golf. Instructions Anyone responding to the In-running (In-play) betting: Issues paper consultation document should use this response template. The closing date for receipt of responses by the Commission is Wednesday 6 August 2008. Below are the questions we are seeking responses to, please add your comments in the spaces provided below each question. There is space at the end of the list for any other comments. Responses should be sent to consultation@gamblingcommission.gov.uk or posted to Consultation Coordinator Gambling Commission Victoria Square House Victoria Square Birmingham B2 4BP Gambling Commission May 2008 The Gambling Commission regulates gambling in the public interest. It does so by keeping crime out of gambling, by ensuring that gambling is conducted fairly and openly, and by protecting children and vulnerable people from being harmed or exploited by gambling. The Commission also provides independent advice to government on gambling in Britain. For further information or to register your interest in the Commission please visit our website at: www.gamblingcommission.gov.uk
In-running betting Q1. Do you have any evidence that in-running betting puts the licensing objectives at risk (eg lack of fairness or openness inherent in in-running betting, or a risk of causing harm to vulnerable people)? This question needs to be answered in 2 distinct ways : 1)Online Betting Companies/Spread firms. Online companies allow you to bet with them, either through their website, or on the telephone. Both mechanisms are unfair to a successful punter, in that, there is no process in place, that protects the punter from being on hold, while a sporting event may change. Typically, if the event changes in the betting companies favour, a bet will be offered - if not, it will not be. For unsophisticated online users, they are undoubtedly being robbed of a fair chance.. I would estimate, at least 30% of the time. The betting companies will tell you, they need to refer the bet etc, to a head trader. I could accept this, if the bets are consistently big.. but, if that's the case, why cant they have a distinct process for 'low value stake punters' - e..g. if a punter, wants to back, a football team, for say 20 pounds, to win 50 pounds, why cant an automated process take over, in which his bet is accepted within 10 secs, or cancelled? Spread firms are notorious for leaving their clients on hold, till the sporting event moves
in their favor, and then.. saying the bet is accepted. This is just theft. Once again, they will tell you, head traders have to be consulted, to manage risk. This is just an excuse.. why don't the Gambling Commission open accounts with the spread firms, and see how many times you are put on hold, or see, how long on average, it takes for a bet to be accepted. If it varies by more than 20%, surely, there is a necessity for a definite process, so, the punter can accept it or not. The on-line companies/spread firms, have never been regulated, and is just wrong to expect on-line exchanges to be regulated, and not them. They are by far and away, the worst culprits at abusing in-running punters. 2) Betting Exchanges On-line exchanges have a fixed time period, which is clearly made clear to users, after which bets will be submitted to the exchange. This is a definite process, without human intervention, and greatly adds transparency/fairness. Q2. Do you have any information about the customer profile in the in-running betting market (ie is it made up predominantly of specialist, knowledgeable betting customers)?
I talk to a lot of co-punters who trade the cricket markets/horse mkts, and we are firmly of the opinion the majority of people playing these mkts are professionals, who totally understand all the key elements of the mkt, Novice punters are protected by these professionals, as they make the mkts v efficient, and.. if a novice makes a mistake on entering a bet, he will only lose a nominal amount, should he wish to reverse the mistake. It is in every-ones interests to make these mkts efficient, as the provide protection for all..and the current safeguards that are in-place, are in my view, sufficient. Technological advantages Q3. Do you have evidence as to whether players in in-running markets are aware of time delays and faster feeds? Do you have evidence that suggests that the level of awareness satisfies the fair and open licensing objective and that any advantage is fair? In-running punters are aware of the time delays on exchanges.. but, as has been stated above, there is no process in place for a time delay with an online betting company/spread firm, and this is where the greatest injustice lies. Faster feeds, are over-stated. If a feed is really slow (e.g. Setanta Golf.. has become so slow, compared to Sky, over the past yr, the liquidity in these events has been greatly reduced. People know what the time delays are, and bet accordingly.
Maybe a dedicated feed service could be created, funded by exchange/on-line firms, which would have the best known feed details.. and maybe, exchanges should mention in the mkt guidelines, which feed they are using, to suspend the mkt. Q4. Does the existing provision in the Commission's Remote Technical Standards sufficiently deal with the issue of variable time delays in feeds and ensure that there is sufficient awareness of and openness around this advantage? Yes. Q5. Does the variable speed available for broadband internet cause unfairness between betting customers should there be a warning highlighting the advantage of a high-speed internet connection? I It is impossible to create a level playing field, and the mkt guidelines warn users, that all users have different computers/software/bband speed. This warning is enough. Q6. Is the use of 'bots' widespread amongst in-running betting customers and is their use fair and open? Bot software is varied.. some is widely used, some made for each individual. To help inrunning exchange users, software interfaces have become quite common (Gruss has over
1000 users - and for 5 pounds a mth, its hardly restrictive in price). If people want to trade in-running, this tool greatly levels the playing field.. and others, such as Betfair Rapid is free, thou, its not as functional just yet. I believe Betdaq will soon be offering a free tool as well. Trading Rooms Q7. Do trading rooms offer a significant advantage for their customers over other betting customers or does skill and knowledge, in relation to the events concerned, outweigh the technological advantages of a trading room? Do the advantages offered by a trading room put other betting customers elsewhere at a disadvantage and is there awareness that trading rooms are being used by skilled betting customers? Trading rooms greatly aid the playing field. If a user wants to test his ability in-running, for 30 pounds a day, he can.. and decide whether its something he can do.this is a very low barrier to entry.. and I think, the more trading rooms, the more efficient the mkts, which aids all people.. in my view, trading rooms, should be encouraged.i don't understand the argument that they are putting other customers at a disadvantage.. no customer is closed to these facilities.. if they don't wish to bet, or cant utilise a trading room, no-one forces them to bet.
Time delays in bet processing Q8. Are in-running betting customers fully aware of the time delays in place for processing bets, do they ensure fairness, and should they be clearly displayed for every market? Do you have evidence that customers are being disadvantaged by time delays? The time delays are always stated on a in-running mkt.. and people are totally aware of them. The current time delay of 1 sec for horse-racing, and 5 secs for ckt/football etc, is just right, and doesn't need change. People that complain about time delays, should stop betting, and move onto something else. They are making arguments, to try and put these mkts/companies into disrepute, by people who do not understand the process. If people are consistently losing, they will stop trading in the mkt, and it will die. This is not the case.. so, are the people just consistently stupid/love losing, or, are the complainers just wasting every ones time? I favor the latter. Online betting companies are cheats, and should be made to stick to a definite process. They wont, and I don't expect u will make them.. but, this is unfair. Cheating and integrity in sports betting Q9. Do you have any evidence that in-running betting encourages cheating offences to take place, in comparison to ante-post betting, and is there any evidence that in-running betting poses a specific or greater risk to integrity in
sports betting? By its very nature, by creating in-running opportunities, you have to create more opportunities for cheating/integrity issues.the data collection by Betfair, should provide data miners with opportunities to protect the gambling public. In my view, there are now better safeguards. Problem Gambling Q10. Does the nature of in-running betting raise specific issues or concerns about problem gambling? No.. Spread Betting Q11. Do betting customers with traditional bookmakers and betting exchanges also take part in spread betting and is it a direct competitor to in-running betting? Absolutely, and all traditional bookmakers/spread firms, should be encouraged to have a definitive process put in place, for the acceptance of bets. This process must include a cut-off
time period.. and.. there is no reason why they shouldn't be made to produce stats, which show for example, 95% of all bets, confirmed within.. say 1 min. If.. say 30% of all bets currently take more than 1 min.. is that acceptable? We need to start collating these stats, and they should be encouraged to meet industry standards. (set by the GC).. Other issues around in-running betting Q12. Are there any other issues relating to in-running betting that the Commission should be aware of and that you consider relevant? With the increasing pace of technological change, the number of sporting areas with wireless bband, will increase. People who believe they have an edge, will go to these events, and try and trade. I believe the commission should state whether this is fair. In my view, you cannot stop people, therefore, you might as well make all people aware of it, and declare it open to all. By and large, the free mkt will regulate itself. Any other comments
I would like to see the GC have a full-time data analyser, whose job it is, to review historical data from the leading exchanges, and spot trends - for instance, whether certain tennis players are more likely to win/lose, when betting on them, has shown dubious betting patterns.. or whether certain trainers/jockeys, have similar patterns, allied to money been placed against them on the exchanges. If there is a statistical correlation, the betting public should be made aware of the instances, and be aware of the enquiry that ensues. The fact that people may know they are being watched, may encourage, greater fair play. Victoria Square House Victoria Square Birmingham B2 4BP T 0121 230 6666 F 0121 230 6720 www.gamblingcommission.gov.uk