Nearly two years ago, Sajid Javid MP, then Secretary of State for DCMS, proposed the £50 per spin threshold on FOBTs, whereby gamblers who wanted to bet more (up to £100) would need to interact with staff or obtain a player loyalty card. The introduction date was set for a year later. Based on the first six months of operation, DCMS produced an Evaluation which was made public on 21st January 2016.
The Campaign for Fairer Gambling (CFG) has commissioned an expert independent analysis of the Evaluation, which will be summarised in Part Two in the near future.
CFG also submitted FOI requests to DCMS. In order to take action against FOBTs, DCMS claims it needs robust and independent evidence. However, it did not see fit to obtain an external evaluation, so this DCMS Evaluation is not independent.
It transpires that DCMS had the following numbers of exchanges with listed organisations during the preparation of the Evaluation:
Association of British Bookmakers - 36
Gambling Commission - 33
FOBT supplier: SG Gaming - 32
FOBT supplier - Inspired Gaming - 30
Bookmaker - Gala Coral - 7
Bookmaker - Ladbrokes - 1
Total - 139
Whatever could have been the need for all these exchanges? As many as 15 of these exchanges were in the week before the Evaluation was published. It would be fascinating to learn if any of these exchanges were directed towards getting DCMS to change the text of the Evaluation!
The methodology used a comparison of Q2 and Q3 from 2015, after the introduction of the measure, with the same periods from 2014, before the measure. One glaring omission from the Evaluation data was the actual revenues for each of those four quarters.
The DCMS explanation is that "[It] was not provided actual revenue data by the industry." DCMS therefore estimated the revenues. As there are only two FOBT suppliers, and as total annual FOBT revenues are public information every six months, and as quarterly FOBT revenues for the major corporate bookies are public information, it is illogical that this data was not provided.
Four of the charts in the evaluation look informative. These charts are all weekly charts and show comparisons across £10 bin ranges, of up to £10, up to £20 etc, showing information for each of 2014 and 2015. Charts 8 and 9 show total B2 stakes per year, whereas charts 16 and 17 show total number of B2 plays. (B2 is the official name for FOBTs and also the game content on FOBTs which includes stakes in excess of £2 per spin.)
It would be interesting to dig deeper into the statistics behind the charts. This could then show the changes in weekly mean and median stakes per spin. However, DCMS denied access to the data on which the charts had been based, claiming a confidentiality exemption. DCMS itself fails to look at the impact on average stakes per spin in the Evaluation and clearly wants to avoid giving CFG the opportunity to do so.
The initial four-page draft of the Evaluation turned into a 36-page document. A couple of items on the first draft are very telling.
The draft states that: "There is evidence which indicates that regular interaction can give players a reality check". This is accompanied by a note that states: "Stakeholder opinion, not sure of evidence, will investigate." The final document states: "Stakeholders have indicated regular interactions can give players a reality check" but provides no supporting evidence.
So the bookies express an “opinion”, there is no evidence to support it, but it still goes in the Evaluation. The unproven theory that the measure would give players a “reality check” was a prime reason given for the measure.
The findings and conclusions of the first draft relate to sections on impact on customers, impact on business, and successful implementation of the regulation. However, in the final document there is no section on the "successful implementation of the regulation".
In the first draft one of the three precise questions asked under impact on players was "Do patterns of play indicate a change in player control?" This precise question does not appear in the final Evaluation. If it did, the precise answer would have been "No". Of course there were some changes, but these are not substantiated as "player control" based changes.
DCMS is now considering this Evaluation prior to proceeding with the 2016 Triennial Review of Stakes and Prizes. If Sajid Javid had ever listened to CFG, he would have known that his measure would be useless as a player control or reality check tool. But if his priority was to excuse government inertia on FOBTs, then he gave the bookies an extra two years.
With the prevalence of FOBT harm being independently established to a more robust standard than DCMS applied to this Evaluation, there is no excuse for DCMS to delay enacting the precautionary provision it enjoys. That is to reduce FOBT maximum stake per spin from £100 down to £2.