HBF support of letter sent to UKGC regarding account verification

HBF was a counter-signatory to the following letter from Brian Chappell, representing a group called Justice For Punters, sent to the CEO of the UK Gambling Commission on 1 July 2016, regarding account verification. At the time of writing, HBF understands that Brian has had acknowledgement of receipt of his letter but no other reply.

Dear Ms Harrison


Customer account verification


In November 2014 the Gambling Commission (GC) introduced a new customer account verification process, with excellent objectives, namely the prevention of underage gambling, money laundering and other crime.


As signatories to this letter we are not certain how successful this initiative has been, because to our knowledge no data is in the public domain.  There does, however, seem to be some confusion in the gambling community as to how it is being implemented 18-20 months on.  Our concerns are based on feedback from customers, bettors, punters, gamblers, whatever term you wish to choose.


In early 2015 it soon became apparent that bookmakers were interpreting the new guidelines in differing ways.  Some would verify accounts covertly with no documents asked for; some would ask for additional documents, e.g. a utility bill, copies of both sides of debit cards and a driving licence photograph or similar, with all documents requested early after registration; and others would ask for the same additional documents before withdrawing money.  Unfortunately, there is one more category. Some bookmakers without providing a good reason are:


1.       rejecting scans of documents and photographs, again and again

2.       requesting  that ‘selfies’ are taken whilst holding the said documents

3.       requesting  that ‘selfies’ taken whilst holding the said documents are signed by a lawyer

4.       asking for full bank statement records 

5.       asking for full bank statement records to be signed by a bank manager


Irrespective of the money-laundering regulations, this is completely unacceptable practice, where no good reason is given and/or evidence provided that the police have been informed of suspicious customer behaviour.


Even worse, when customers have taken their cases to alternative dispute resolution they have lost due to the application of unfair terms and conditions, meaning these intrusive requests to withdraw their own money or to obtain a promised free bet of say £25.00 have had to be carried out. 


In our experience, these additional requests rarely, if ever, happen when customers lose, meaning they are not completed for social responsibility reasons concerning problem gambling (see your recent fines). They appear to happen only when someone is trying to withdraw winnings or obtain promised promotions. 


Obviously, these requests cause delays which can be very significant, sometimes lasting for weeks or months, and are verging on defamation of character, because no good reason has been given for these privacy intrusions.


There are also cases, where customers are able to afford it, of legal action progressing against bookmakers for the recovery of funds being withheld because of these processes.  It is our prediction that none of these cases will enter a court room due to the bookmakers knowing a truly independent person (a judge) will not find for them. 


Whilst we fully support the original concept, we also have to say that some bookmakers are abusing a good initiative for their own ends.  Due to the latter observation, we feel it is only fair that the GC urgently reviews this process, including consultation with consumers who bet on a very regular basis, not just internal committees and bookmakers.  The GC’s recent bookmaker fines concerning social responsibility would also support our observations.


We do hope you can appreciate why this issue is very important to consumers.  Some certainly feel it is verging on defamation of character, primarily due to bookmakers commonly refusing to enter into any form of sensible customer service dialogue.  This would not be acceptable in any other industry.


A standard procedure agreed and monitored by the GC is urgently required. 


Yours sincerely, 


Brian Chappell                                                                   Simon Rowlands

Founder, Justice for Punters                                      Chair, on behalf of Horseracing Bettors Forum 


NB: Signed on behalf of both organisations and other individuals who wish to remain anonymous.

Meet HBF Members at Doncaster, September 7th

Horseracing Bettors Forum, September 2016 Meeting

The next Horseracing Bettors Forum meeting will take place at Doncaster Racecourse before racing on 7 September 2016.

For practical reasons, it will not be possible to make the meeting open to the public, but HBF will have public representation on the course throughout the afternoon.

HBF invites the betting and horseracing public to meet with HBF members during that day, to find out in greater detail what HBF has done, and hopes to do, and to make known their own suggestions and observations to HBF members.

Details of where to find the HBF stall at Doncaster will be publicised nearer the time, probably including through an advert in the official racecard.

HBF wishes to thank Arena Racing and Doncaster Racecourse for their considerable assistance already in this matter and looks forward to meeting members of the public at Doncaster on 7 September.

HBF statement regarding non-runners in British racing, 7 July 2016

Following a small but significant amount of correspondence from the British horseracing public, as well as expressions of concern from its own members, the Horseracing Bettors Forum discussed the issue of non-runners at its meeting on 6 June 2016.

HBF members were unanimous in wishing to convey to the BHA the Forum’s belief that the high incidence of non-runners in British racing is disruptive and unwelcome to bettors, while the reasons given for many of those non-runners stretches credulity and undermines the wider appeal of the sport.

BHA has since confirmed that it is currently conducting its own review of the situation and that HBF’s input will be considered as a part of that and of subsequent discussions on this matter.

Among the observations/suggestions made (which are given in full below), HBF proposes that the trigger point for self-certification – beyond which trainers may have their right to self-certify withdrawn – should be lowered.

Additionally, it proposes that: the BHA veterinary team conducts work on the reasonable length of recovery for common ailments and for the findings to inform mandatory suspension levels; that horses declared as non-runners on account of the going should not be allowed to run on the same or very similar going for a significant time after their withdrawal for that stated reason; and that this should go hand in hand with increasing public and professional confidence in official descriptions of the going.

HBF has also conducted a forensic study of non-runners in one area of British racing in recent times and is likely to recommend that non-runners in circumstances which are harmful to betting markets and which could be construed as suspicious be investigated thoroughly on an individual basis.

The study also revealed that just over 10% of declared horses in turf Flat races became non-runners since the end of May, 2014, that the incidence of non-runners was less in higher-class races, and that it increased as going became more extreme.

The following are the full list of HBF’s current observations and recommendations:

  • A high incidence of non-runners creates uncertainty in betting markets and discourages participation. This is particularly true of late non-runners
  • Some of the consequences of non-runners – including Rule 4 deductions, amended each-way terms and unexpectedly altered race scenarios – are frustrating, off-putting and occasionally costly to punters, and therefore to the sport
  • A certain incidence of non-runners is inevitable, due to unforeseen events, but HBF believes the level is much too high and that steps need to be taken to improve matters
  • HBF understands that the trigger point for self-certification, beyond which trainers may have their right to self-certify withdrawn, is 20% on the Flat and 15% over jumps. This seems much too high and needs to be revisited
  • More leniency could be applied when trainers have withdrawn horses in a timely manner, well in advance of the event
  • HBF would like to see work conducted by the BHA’s veterinary team on the reasonable length of recovery for common ailments, and for the findings to inform mandatory suspension levels for horses who miss races for those declared ailments
  • In general, public confidence in the system might well increase if horses were not permitted to run for a longer period after being declared non-runners, for whatever reason. This can be justified on the grounds of integrity (to counter suggestions that the system is being “gamed”), and welfare (should horses that were reported as “lame” on one day be allowed to run shortly after?) besides anything else
  • Horses declared as non-runners on account of the going should not be allowed to run on the same or very similar going for a significant time after their withdrawal for that stated reason
  • The possibility of a horse becoming a non-runner on account of the going should be flagged up much more clearly and much more widely. For instance, “will not run if going is unsuitable” (if it appears at all) is of no use to a punter unless it is known what “unsuitable” is imagined to be in this context
  • The guidelines for non-runners on account of the ground appear too permissive. Connections may want the absolutely ideal circumstances for their horses, but this should be balanced against the consequences of non-runners to the betting and race-going public, to other racing professionals (including jockeys), and to the good reputation of the sport
  • Tightening of ground-related non-runners needs to be accompanied by a greater confidence in the official description of the going and of how the going is arrived at (e.g. watering)
  • It should not be possible for an apprentice to be replaced by a fully-fledged jockey, or vice versa, on account of a non-runner, other than in extremis. Again, this is important for the reputation of the sport, as well as for the consequences such changes have on betting markets and on the attractiveness of betting on the sport

HBF, 07 July 2016

Horseracing Bettors Forum press release, 13th June 2016

The Horseracing Bettors Forum (HBF), created in 2015 with the assistance of the BHA to represent the views of those who bet on British racing, has received a considerable amount of correspondence from the public regarding the issue of account closures and restrictions.

Anecdotally, many horseracing bettors find their accounts closed or restricted (sometimes to such a degree that they might as well be closed) due to activity which bookmakers deem to be unprofitable or potentially unprofitable.

As a result, and in order to get a better appreciation of the situation, HBF undertook a survey of the horseracing betting public through its website (http://ukhbf.org/account-restrictionclosure-survey/). The survey was open from 3 April to 30 April 2016.

  • There were 878 respondents
  • They reported over 4000 restricted accounts in the previous 6-month period
  • They reported over 1000 closed accounts in the previous 6-month period
  • 520 respondents (59.2%) stated that account closures and restrictions had reduced their interest in betting on horseracing
  • 94% claimed not to have been given a reason for closure or restriction or to have been told no more than that it was a “trading decision”

By using figures given separately to HBF by some bookmakers for the actual number of accounts closed by their firms in the period of the survey, HBF estimates that 20,000 British accounts were closed by bookmakers over the last six months with probably twice that number restricted.

In view of the fact that bettors may have had several accounts closed, HBF estimates at least 7000 individuals are affected.

The experience of having an account closed or restricted, sometimes for no obvious reason and with no warning or formal explanation, can clearly be a negative one and have wider ramifications.

HBF figures suggest about 4000 bettors will have a reduced interest in horse racing every six months if this continues. This will clearly affect racing’s income from betting.

Just before this survey was undertaken, HBF wrote to representatives of a dozen leading bookmakers, spelling out their concerns, suggesting some measures that could be implemented and inviting further discussion.

There was a mixture of responses, from positive to negative, and, in some cases, no response at all.

As part of the most recent HBF meeting, on 6 June, Forum members met with one of those representatives. Talks were encouraging, and HBF hopes to use them as a basis for future discussion.

A fuller summary of the survey findings will appear on HBF’s site in due course.