HBF Positional Statements
Positional Statements (last edited, May 2017)
STARTING PRICES HBF remains concerned that the mechanisms which lead to starting prices are insufficiently robust for the modern betting environment. In particular, it is concerned about the size, representativeness and anonymity of the sample used on-course to establish SPs. HBF made a submission to the Starting Price Regulatory Commission’s consultation process in September 2015, and wrote an open letter in March 2016 expressing its concerns about the conclusions of the report into that consultation, both of which may be found elsewhere on this site. As of May 2017, SPRC has repeatedly failed to answer HBF’s questions or to provide details of the SPRC’s “Nominations Committee”, through which its members are appointed.
ACCOUNT CLOSURES AND RESTRICTIONS HBF has had considerable correspondence from the betting public regarding the issue of account closures and restrictions. While it acknowledges that bookmakers have a right to manage risk in a manner appropriate to their profession, and that there is – at least currently – no obligation for them to lay a bet in any given circumstance, it is deeply concerned that some of the strategies employed are having a detrimental effect on betting and on horseracing itself. Many customers of bookmakers are more obviously customers of British racing, or could become so, and they deserve good service levels. Betting on horseracing involves skill and discipline, quite distinct from games of pure chance, and it is important that honest endeavour from those who have, or might develop, a passion for the sport is not met automatically with punitive action. HBF conducted a public survey in April 2016 into account closures and restrictions – a summary of which can be found elsewhere on this site – and wrote around that time to a dozen major bookmakers to express their concerns and to seek constructive debate. There was a variety of responses, and in some cases no response at all. A representative of one of those major bookmaking firms attended part of HBF’s June 2016 meeting, at which discussions were fruitful. There has been increased media coverage of the issue since, including in The Guardian (https://www.theguardian.com/sport/2016/jun/13/punters-body-say-bookies-closed-20000-bettting-accounts). HBF continues to work towards heightening awareness and finding solutions that are acceptable to the interested parties.
As a result of previous work in this area, HBF is seeking for provision within a revised ABP (or possible Punters’ Charter) for a feedback and appeal loop as recourse for punters’ inadvertently caught up in arb’ing and other anti-competitive practice backwash.
ADDITIONAL PUNTER-FRIENDLY DATA HBF believes that an increase in the reliability and scope of data provided for those who follow and bet on the sport of horseracing would be beneficial, especially as the sport competes against other recreational pursuits and against the sport in jurisdictions where data is much more extensive. HBF recognises that some data improvements are likely to be neither easy nor cheap, and it looks forward to working with the BHA and Racecourse Association to come up with sensible and affordable initiatives in this area.
May 2017: HBF welcomes news that, in line with prior recent work on UK jump tracks, all UK flat tracks have been re-measured and race distances updated or start positions revised. HBF has been assured that the placement of furlong markers would be surveyed at the same time and is seeking confirmation of the findings in that area.
More broadly in the information space, HBF continues to be frustrated by the pedestrian progress made by BHA in terms of providing data on such as wind operations and mares in foal. HBF continues to chase for the introduction of this data into the public domain.
RACE PLANNING AND THE FIXTURE LIST HBF recognises that significant reductions in the British racing fixture list would not be possible without harmful consequences to employment and to the sustainable number of racecourses. Against that backdrop, however, it wishes to see the fixture list stabilised, rather than increased, with due attention paid to race planning in terms of avoiding clashes and maximising potential and interest. More is sometimes less, and more racing in recent decades has meant less prospect of even committed racing enthusiasts following all that is going on. HBF has already been asked by BHA for feedback and looks forward to further constructive dialogue in this area.
NON RUNNERS HBF is concerned about the impact that non-runners are having on specific betting markets and on the attractiveness of betting on the sport as a whole. Rules regarding self-certification and the ability to withdraw on account of the going seem too permissive, and this has also been the message HBF has received from some of the British betting public. It has communicated these concerns to the BHA and anticipates being part of the ongoing discussions about this matter.
TERMS & CONDITIONS HBF supports work undertaken by CMA to review general practices with regards to account opening offers in the gambling space. Whilst much of the CMA review remit is outside of horse racing specifically, its findings are hoped to make for a fairer landscape for those who bet on UK racing. HBF looks forward to CMA’s next update in June 2017.
IESNARE / TRACKING CODES HBF believes that the downloading and storing of tracking codes, such as iovation’s iesnare, without customer consent is unacceptable. Online bookmakers should not be allowed to store any data on a customer that is not logged on to their site. HBF is further concerned by allegations that such information, which may be deemed to be personal data, is being shared by companies using the iovation service. HBF is heartened that these – wider than horse racing – issues are being pursued by UKGC.
AUTHORISED BETTING PARTNERS HBF was broadly supportive of British racing’s policy on Authorised Betting Partners (ABPs), which sought to recognise and reward those bookmakers who make a fair contribution back to the sport in the UK. With the new funding mechanism having become law, HBF is currently drafting a proposal which covers areas such as punter protection, the right to a feedback loop on account restriction, and greater transparency around customer verification at the account opening stage, as well as a minimum liability obligation. HBF seeks to have these requirements recognised as an entry to “ABP 2.0” status or, perhaps more likely, a subsequent similar initiative.
MISCELLANEOUS After representations by HBF, rules regarding the compulsory parading of horses before racing have been tightened. HBF is also working with RCA and BHA to improve protocols for reporting of race measurements, timings and accurate ground descriptions, all of which it sees as being important to ensure the confidence of the British horseracing betting public.