Transcript of HBF Speech to APBGG, 23rd January 2018

Parliamentary All-Party Betting and Gaming Group

23 January 2018, Committee Room 4, House of Lords, 15:00 – 16:30

“Are bookmakers unfairly closing customer accounts?”

Simon Rowlands, Chair, Horseracing Bettors Forum


Firstly, may I thank the Group for inviting me, as Chair of the Horseracing Bettors Forum, to address them on the question of “are bookmakers unfairly closing customer accounts?”

In the correspondence leading up to this event, one of my fellow speakers was described as “neutral”, but HBF would like to emphasise that it does not wish to be seen as merely speaking for one side in this debate: it seeks co-operation and to work towards a fair resolution of any problems that there may be.

I will briefly explain what HBF is and what its aims are.

HBF was created in 2015 with the assistance of the British Horseracing Authority to understand and represent the hopes and concerns of those who bet upon, or who might bet upon, horseracing in Britain.

It has between 7 and 9 members, including me as Chair, and meets quarterly as well as corresponding extensively between those meetings. Its membership has been derived from public calls for interest, the most recent of which was last summer.

HBF is unfunded other than having minor expenses defrayed by the BHA. The Forum sees holding the BHA to account as one of its primary objectives, and the BHA has been supportive, including in this regard.

Previously, the betting public was – at least occasionally – seen as a key customer group in British racing but had no voice or means for raising concerns.

HBF has established a website, e-mail address and Twitter account, all with a view to engaging with the public it seeks to represent. Its members have also met with the public at racecourses and at racing clubs.

In the two and a half years since HBF’s inception, the subject most frequently raised with HBF has been that of the closure and restriction of betting accounts.

Contrary to some opinion, that has not just been from high-rolling gamblers but from small-staking ones as well, and not just from winners but sometimes from losers, too.

Account “closure” is self-explanatory, but it has become apparent that some “restrictions” are so draconian that they serve much the same end, while – the cynic might suggest – leaving the door ajar to a spin or two on the virtual roulette table.

There are countless anecdotes about bets being restricted to derisory sums, and bookmakers have confirmed that some customers have been “factored” to a minute fraction of the bets they request.

HBF understands the desire for sensible risk management, but it believes that restrictions and closures are being implemented too readily, and that the consequences of this for horseracing and for betting on the sport are harmful and are not being taken seriously enough.

HBF ran a survey of the betting public in 2016, to which there were nearly 1000 respondents, with 59% of those who stated that they had had accounts closed or restricted claiming to have suffered a reduction in interest in the wider sport as a consequence.

By extrapolating from the figures reported, in conjunction with information provided separately but confidentially to HBF by a leading bookmaker, HBF estimated that as many as 20,000 accounts had been closed in the previous six months.

The immediate harm to an individual bookmaker of wrongly restricting or closing the account of a given punter may be small, but the potential harm to the sport is much greater, as it could lose a lifelong fan.

Ultimately, if that happens often enough – and the evidence is that it is happening more than occasionally – then it threatens to poison the well for all concerned.

Risk management should not be taken to equal risk elimination. Betting on horseracing by its nature involves risk – whichever side of the counter you are on – and that is a significant part of its appeal compared to some alternatives.

It is crucial to betting on the sport, and to the sport itself, that it remains aspirational. That it should be possible, in theory, to turn a profit, or at least to lose less, by applying enough skill and discipline.

By acquiring that skill and knowledge, an individual may well become an advocate for, and contributor to, the sport of horseracing itself.

The modern betting landscape seems to have lent itself to a safety-first attitude to risk management. Where once it might have taken many bets to establish that a punter was “hot”, individuals are having accounts closed or restricted sometimes as a result of just a few bets.

Those bets do not have to have been successful, just to resemble the fingerprint of someone who may, possibly, be successful in the future. As an example, those who bet on horses who subsequently shorten in price seem to be prime targets for restriction.

The Chair will be familiar with the details provided by one of his constituents, who is present here, of that constituent’s severely restricted accounts. Those accounts have been for average bets of just £15 and have effectively done no more than break even over a number of years.

The individual’s apparent “crime”? It was that, in amongst those bets, he backed enough horses at odds longer than Starting Price to have aroused suspicion.

Incidentally, I would like at this point to acknowledge, and pay tribute to, the fine work done by the group Justice For Punters, in this specific instance and in the area of account restrictions and closures more widely.

In our survey, 20% of respondents claimed to have been closed (not just restricted) after less than 10 bets, 37% after 20 or fewer.

As a result, it seems likely that there are thousands of “false positives”: of people closed or restricted by accident.

This haste in applying closures and restrictions has led to some punters becoming more “inventive” at trying to get a bet on. HBF wishes to make it clear that it does not condone the adoption of aliases, of impersonation, and the like.

But this ensures a vicious circle, whereby bookmakers become increasingly suspicious of betting behaviour, and a small section of punters become more resourceful in trying to get round the restrictions imposed. The whole situation escalates.

The Horseracing Bettors Forum would like to be a part of breaking this vicious circle and of creating a better environment for the majority of the betting public. At present, too many “innocents” are being caught up in restrictions and closures aimed at discouraging the very few.

One part of the solution might be a minimum-bet commitment from bookmakers.

It is what HBF has called for in its Betting Charter – along with advanced protection of punters’ funds, greater clarity on Terms & Conditions and other items – and we have discussed the matter with a small number of co-operative bookmakers in Britain.

On a recent visit to Australia, I met with a leading corporate bookmaker and discussed minimum-bet commitments with them.

A number of States in Australia have now adopted this as a condition of licence, and those I spoke to in Victoria were notably enthusiastic about the initiative.

They believe it has led to them being able to set more informed markets and to serve a wider section of the betting public at little increase in initial cost.

They claim that subterfuge and cloak-and-dagger activity has virtually disappeared as all but the largest-staking punters have been able to get a reasonable bet on.

There are some differences between the betting landscape in Britain and Australia, but far more similarities. Several of the biggest corporate bookmakers in Australia are in fact owned by British betting companies.

Another, related, option is to offer punters “no frills” accounts, without promotions and/or best-odds guaranteed, but with this commitment to a minimum bet. This should be an option, rather than an obligation: different punters will want different things.

HBF would also like to see better communication between bookmakers and customers prior to closure or restriction.

At present, the first time a punter is likely to know that his or her business is no longer wanted is when he or she gets a generic e-mail advising that closure or restriction is a “trading decision” and not open to discussion.

We believe a customer should be told which behaviours may lead to this outcome – such as a suspicion of arbing, or line-tracking, or of holding multiple accounts under different identities – before closure becomes final and irreversible, so that those behaviours may be explained or changed.

This seminar’s title is “are bookmakers unfairly closing customer accounts?” In summary, HBF would argue that closures and restrictions are indeed unfair in some instances.

As much to the point, however, is that they are proving to be counter-productive, for the sport of horseracing, for those who would bet on it, and – we would argue – even for the bookmakers themselves in the longer run.

All concerned need to enter into dialogue about this matter – such as through the soon-to-be-formed Racing and Betting Liaison Group at the BHA – and HBF very much appreciates this Parliamentary Group’s willingness to set the ball rolling with this seminar.

Thank you.

HBF 2nd Annual Statement

HBF Chair’s Annual Statement, 2017

The Horseracing Bettors Forum recently had its second anniversary, marked by a regular meeting at Nottingham Racecourse at which new members were welcomed and departing members were thanked.

One item on the Agenda was to explain to those newcomers the evolution of HBF in those first two years, a summary of which constitutes some of what follows.

HBF is recognised officially by the BHA, which helped to establish it and continues to assist in its development, but it does not possess statutory powers. It cannot enforce change, however much it might wish for it, but it can seek to influence those who may.

To that end, much of the effort to this point has been in trying to establish HBF’s credibility and in establishing then nurturing relationships with bodies that have influence in the relevant areas.

From a standing start, HBF has persuaded the BHA to make a formal commitment to consider, where relevant, the interests of the betting public in any potential changes to procedures, and to have senior BHA representatives at all HBF meetings to explain BHA policy in matters which affect the British horseracing betting public.

The BHA has been both helpful and receptive, for which HBF is grateful, and HBF has found itself involved in positive developments in a number of areas.

These include: the initiative to reduce non-runners in British racing and their effect on betting markets; the move to 48-hour declarations for the Cheltenham Festival; transparency on balloting on the BHA website; the compulsory declaration of wind operations; and other data initiatives that should follow.

HBF recently contributed to the BHA’s consultation on the future of stewarding. In summary, HBF is in favour of raising standards but remains to be convinced that this will be achieved by an increase in paid stewarding. It recommends that new technologies are embraced and that existing expertise elsewhere within the BHA is harnessed more effectively.

A principal aim of any recommendations from the stewarding review should be to increase the confidence of the British horseracing and betting public in the running of the sport.

HBF is in discussion with BHA about how it can play its part in formal arrangements the latter intends making to bring the betting and racing industries together, under the auspices of the BHA, to the mutual benefit of all.

At the same time, HBF has had regular dealings with the Gambling Commission, including as a representative of the consumer on a GC working party to discuss betting-related matters, and it contributed to the Competition and Markets Authority’s important public consultation. HBF wishes to acknowledge the excellent work being undertaken at the same time by Justice for Punters in these and other areas.

HBF is encouraged to have been contacted recently by the All-Party Parliamentary Betting And Gaming Group to see if it would be interested in contributing to a discussion in Parliament about bookmakers restricting winning betting accounts.

Restrictions and closures of betting accounts (not necessarily just winning ones, either) has been the one topic above all others about which the public has contacted HBF over the last two and a bit years. As Chair, I recently discussed this matter with corporate bookmakers on a trip to Australia, where Minimum Bet Liabilities have not only been implemented but have been met with widespread enthusiasm.

HBF’s position is that betting on racing is a test of skill – which most of us fail! – and not just pure chance, and that it needs to remain aspirational. It needs to be possible that you can win at the game, or at least lose less, by applying skill and discipline. By acquiring skill and interest, the individual in question may well become a long-term supporter of, and advocate for, the sport itself.

To that end, and others, HBF has drawn up a Betting Charter which includes guidelines on minimum-bet guarantees, along with others on protection of funds, problem gambling, terms and conditions, the requirement for bettors to abide by fair and transparent rules in return, and others.

This Charter, which is intended to be for the benefit of all parties, was developed with the assistance of a small number of co-operative bookmakers, and with input from the BHA and the GC. The BHA recently indicated that it would support the Charter, which HBF will share with the public before the end of the year, seeking feedback.

HBF recently shared the Charter with the Association of British Bookmakers and the Remote Gambling Association, inviting those betting-industry trade bodies to help in framing the Charter and in bringing it to the attention of their members.

Achieving wider acceptance of the Betting Charter will be a particular focus for HBF in the year ahead, as will be understanding, explaining and perhaps influencing new pool-betting initiatives, playing a part in the delivery of improvements in horseracing which will also benefit those who bet on the sport, and fostering constructive relationships with others in horseracing and betting.

The message HBF puts out needs always to be informed by the concerns and aspirations of the British horseracing betting public it seeks to represent.

HBF hopes to put in greater effort to connect with that constituency and to understand and represent its views, be that through social media, its website and e-mail facility, or through public appearances and written material. It must, however, be understood that HBF members are giving up their own time for no monetary reward and there is a limit in what they can do.

Those HBF members now number eight, with five having left and four having joined since HBF’s inception, following a public call for new blood earlier this year. There will be public calls for new members in the future.

As Racing Post’s Lee Mottershead wrote recently “…through the creation of the Horseracing Bettors Forum, punters have gained a strong voice…”.

Whether as a future HBF member, or as someone sharing your views on pertinent issues with HBF, you can ensure that voice remains not only strong but effective.

Simon Rowlands

Chair, HBF, November 2017

HBF Response to BHA Non-Runner Measures

The Horseracing Bettors Forum welcomes the initiatives announced by the BHA regarding non-runners, and particularly commends the fact that the consequences to the betting public have been properly considered.

There are areas in which the BHA could have gone further – such as with the length of exclusion following self-certification and vets’ certificates – but the proposals seek to strike a sensible balance between competing interests, and crucially take into account the effect of non-runners on betting markets and the attractiveness of the sport more widely.

HBF raised the issue with the BHA shortly after HBF was created nearly two years ago, since when it has received a steady stream of correspondence on the matter. It is pleased that action will now be taken.

HBF will not hesitate to press for tougher measures if these initiatives fall short of having the desired effect of making British horseracing more appealing to the betting public at the same time as being fair to the sport’s participants.

HBF, 16th August 2017

Horseracing Bettors’ Forum press release concerning the SPRC

21st July 2017

The Horseracing Bettors’ Forum would like to publicly state that it has no confidence in the current Starting Price Regulatory Commission, the SPRC.  In today’s world regulatory bodies have to be open and accountable to their stakeholders and to clearly demonstrate the integrity of their decisions. The SPRC fails to do either of these.

There are no minutes published of meetings or discussions this organisation has and in their most recent report they dealt with a potential conflict of interest scenario by one, unnamed, committee member talking to another unnamed “distinguished lawyer”.  No reports of those discussions have been made available.

To ensure the integrity of the SP or starting price, one of the lynch pins of horse racing, not only must things be done but they must be seen to be done. The days of regulatory bodies handing out rulings without explanation or discussion are long past.

As representatives of people who bet we were shocked by the patronising attitude to bettors shown by the chairman Lord Donoughue’s  recent statement.,

“However, our SP caters mostly for the majority of average smaller punters, who do not wish or have time to engage in the bear garden of competitive pricing and are content to accept a fair price on their winners and losers. It is true that they might gain a few more shillings if they hunted down the very best prices”

He apparently has no idea of the modern betting world or of its participants.

He further has stated that “No one can ‘fix’ the SP”. This shows a degree of complacency totally incompatible with the imagination and preparedness needed in a modern regulatory body.

The SPRC has a long history of trying to deflect criticism by saying its critics are seeking to abolish the starting price system. We would like to reiterate that this is not HBF’s aim.

However HBF would like to see starting prices regulated by an open communicative organisation, responsive to the views of those it affects and with its members selected in a clear and open manner.

Horse racing, bettors and the betting industry deserve no less.

HBF Membership Refresh

The Horseracing Bettors Forum (HBF), created with the assistance of the British Horseracing Authority to represent the interests of those who bet on British horseracing, has announced four new Forum Members as part of a planned refresh of its membership ahead of its second anniversary.

Paul Johnson, Colin Hord, Colin Magee and Martin Hughes have been selected by HBF to represent the betting public and replace four of the original nine Forum Members.

Colin Hord has already replaced Jason Brautigam – who left the Forum late in 2016 – and was in attendance at the Monday 3 July HBF meeting.

Colin Magee, Martin Hughes and Paul Johnson will replace original HBF Forum Members Quen Emmenes, Glenn Alcoe and Scott Ferguson.

All four new Forum Members are passionate horseracing fans and the last three will be joining HBF in advance of the Forum’s second anniversary meeting, which is planned for Nottingham Racecourse in October.

Members will serve three-year terms and there will be another planned refresh of the HBF membership in 2018.

Simon Rowlands, who will remain as Chair of HBF for one further year, said:

“We were all very impressed with the standard of applications, which made the decisions regarding appointments difficult, and are confident that the new intake will ensure that the interests of the British horseracing betting public continue to be represented in an independent and insightful manner.

“I would like to thank Quen, Glenn and Scott for their sterling efforts over the last couple of years, without which the creation and early stages of the HBF would have been considerably more difficult.”

HBF has meetings roughly each quarter and has lobbied on behalf of the British horseracing betting public with bookmakers and with bodies such as The Gambling Commission, The Information Commissioner’s Office, The Starting Price Regulatory Commission, The BHA and The Racecourse Association.

HBF will continue to ensure a key customer group of British Racing is represented in the new Levy environment and is currently especially active in the areas of improved data provision for bettors, Non-Runners, the future of pool betting and the creation of a Betting Charter.

It may be contacted through its website at and its Twitter account at @HbfBritain.

The Forum Members

MATT BISOGNO, London, is a former software development project manager and consultant who is now managing director of the popular online racing community A passionate racehorse owner and syndicate manager, his betting is data-driven and he has contributed to previous BHA focus groups about betting.

COLIN HORD, London, works at the Civil Aviation Authority and has a degree in meteorology. He is the policy lead in the Safety and Airspace Regulation Division. He is a member of Kempton Park Racecourse and writes a blog with his betting selections.

MARTIN HUGHES, near Newcastle, worked at Barclays Bank plc for 19 years in various roles. For the past 8 years he has been a full-time bettor, adopting several approaches and becoming a specialist in in-running (without fast pictures).

PAUL JOHNSON, Leeds, worked for William Hill for over 30 years and is now a professional horseracing bettor. A keen racegoer who has visited 55 racecourses in the UK, he also advises on horseracing at Regulus Partners.

COLIN MAGEE, London, is an enterprise software executive and entrepreneur, and is a regular racegoer. He authored the first published book on how to program the Betfair API and is also owner of, a site which provides data analysis tools for bettors who wish to build their own systems.

SIMON ROWLANDS, (Chair), near Sheffield, is a self-employed horseracing analyst and writer who formerly worked as a betting-shop manager, racing editor for a national newspaper and for many years for Timeform. He was recently appointed to British racing’s Disciplinary Panel.

TANYA STEVENSON, Surrey, is from a bookmaking family and has many years of experience in the betting industry, including as betting expert on Channel 4 Racing. She has worked on BHA groups, Tattersalls Committee and is a judge of the Betting Shop Manager of The Year.

STEVEN TILLEY, Gloucestershire, has been a racing fan since he was a teenager and a member at Cheltenham racecourse for 30 years. He has written about betting for magazines and spoken at betting workshops, and mixes with punters across the spectrum from those in it purely for fun to those who take it very seriously. He has been a local councillor for the last 25 years.

Twitter Q & A

Via its twitter account and the hashtag #HBFQA, HBF recently hosted a Q&A for the general public. Here are those questions, and answers, in full.


HBF writes:

Such a directive would require legislation, and neither BHA nor HBF is empowered in that way. The Gambling Commission, which might be, is not minded to do so, though HBF continues in dialogue with GC about this and other matters. Nonetheless, HBF is seeking to define what it sees as good practice in this area and hopes to get backing to encourage bookmakers that adopting reasonable guidelines will be to their benefit and not just punters’.


HBF writes:

Racecourses are commercial entities that will pay the consequences if they misjudge such matters. With racecourse attendances still high, and remarkably few tracks having closed in recent decades, they might well disagree with your analysis. HBF cannot dictate to them. Nonetheless, the race-day experience is a valuable shop window for the sport and HBF would like to see easier access to information (WiFi, replays, results, announcements, seeing the horses before the race, interviews with racing professionals) and continued vigilance to ensure betting markets do not exploit the novice and the seasoned racegoer alike. One way this may be best achieved is through greater co-operation between racecourses. Last year’s industry updates suggests this is happening.


HBF writes:

HBF has suggested a pilot project in this area – believing that wholesale implementation at one go would encounter logistical problems and no small amount of opposition – such as in Group races or selected AW races. More widely, it is necessary to distinguish between dead weight and live weight, as the latter can occur in tandem with increased strength or other athletic enhancements. HBF sees this issue as meaningful, but it is down its list of priorities, including having taken soundings from a section of the betting public.


HBF writes:

HBF takes on issues it sees as clearly important without necessarily waiting for public feedback. Otherwise, though, it responds to concerns raised with it directly, by the public and from within the industry. HBF seeks to represent all punters. There are many, many more recreational than “professional” punters but it is important that betting on the sport remains aspirational and that those who seek to bet profitably (nearly all of us?!) are not short-changed. HBF made a positional statement with relevance to this on its website recently.


HBF writes:

Racing also measures in yards/furlongs for overall race distances but calculates rail movements in metres then converts them back into yards (!). HBF continues to apply pressure to increase accuracy, relevance and timeliness of data, including in terminology used.


HBF writes:

Some. HBF has discussed the first two with a small number of “friendly” bookies and drawn an example of the last-named to the attention of the Information Commissioner’s Office via the Gambling Commission. Some bookies seem to understand that blunt restrictions with inadequate explanation may seem expedient in short-term but could well have harmful consequences for all longer-term. We continue to lobby in this area.


HBF writes:

HBF has had no dealings with the Horserace Betting Levy Board, which is soon to discontinue. Prior to the creation of the HBF, the future Chair asked the HBLB that funding be made available into horseracing betting behaviour (what drives good and bad participation) but was told that was outside the HBLB’s remit. When it becomes clear who holds the purse strings, HBF may well be minded to push for research in a number of areas, of which best practice in watering could be one. HBF’s Chair raised issues with watering at a recent Going-Stick Working Party meeting but has heard no more of the matter since other than that the Working party’s scope will expand.


HBF writes:

A hypothetical question, as Exchanges are legal, here to stay and in Betfair’s case have, unlike some of their more conventional bookmaking rivals, regularly paid back into the sport. In addition to what some see as problems with them, Exchanges have appealed to a new type of punter and increased the interest of many existing ones.


HBF writes:

Sadly, HBF has made little progress in this area. The Forum has no statutory powers and can only seek to influence through dialogue and providing evidence. That is very difficult to do when some bookmakers refuse to engage with us. Nonetheless, HBF has put this suggestion to those bookmakers who HAVE engaged and have been encouraged by the response. If this is to happen more widely then it will be a long road, but HBF is committed to trying to bring improvements in this and other areas all the same.


HBF writes:

Little at present. Pretty much every group within horseracing believes it has a short-term interest in more racing or at least in preserving the status quo. HBF has made its views – similar to yours – clear in a positional statement on its website ( and in person to the BHA.


HBF writes:

HBF is not involved as a body in handicapping matters. But individuals on HBF have formally submitted views about official handicapping practices, some of which seem outdated. These include that greater transparency of ratings and the ratings process would improve understanding and promotion of the sport. We await developments.


HBF writes:

Others are better placed to answer this than HBF. However, HBF believes there is a very clear distinction between FOBTs (games of chance) and betting on horseracing (can be a game of skill, the acquiring of which may turn the individual in question into an advocate for the sport itself). HBF believes this distinction should have been emphasised much more in the past and must be in the future. Racing should be very conscious of how it is perceived and ask whether such a hand-in-glove association with FOBTs sends out the right message.


HBF writes:

HBF has pushed hard for improved data and made some progress, but there needs to be a change in culture within the sport about the need for accurate and meaningful data, delivered in a timely manner, and it is clear that will take time. Nonetheless, expect significant progress in coming months in some of those areas you have mentioned.
On SP, see remarks made elsewhere about the need for a culture change, though some of what is asked for (e.g. racecourse demographics) have commercial sensitivity. The 2016 industry updates revealed that there will be greater co-operation between racecourses, but not necessarily greater public openness. HBF asked for greater transparency in betting markets, but those – and other legitimate – concerns raised with the Starting Price Regulatory Commission have been ignored.


HBF writes:

The Forum has not discussed the Kempton Park situation, in part because it has received no representations about it. HBF understands that a pressure group has been created. While HBF would be opposed to anything which seriously threatened to erode the appeal of betting on horseracing in Britain, it can be asked whether that will be the consequence of the sport losing one – admittedly significant – racecourse out of 60 and having it replaced by another. It is also a reality – however unfortunate or not – that racecourses are assets owned by companies and not the sport itself.


HBF writes:

There is a Twitter account (@BallotedOut) which provides a welcome service, but this should not be left to private individuals. On the back of your query, HBF has specifically asked that BHA host the same for all races with clear betting consequences, and BHA has indicated that this matter will be formally discussed as early as this week. Thanks.


HBF writes:

HBF’s Chair raised this at a recent Going-Stick Working Party meeting and did not receive an explanation. Sedgefield is not alone in this, though some of the other omissions are down to courses having frost covers that could not be removed in time to take readings. Chair proposed “quickie” readings from which a wider going reading could be extrapolated an hour or so before racing (most readings are several hours, or sometimes a number of days, in advance). Awaiting a response from the GSWP.


HBF writes:

HBF does not have an official position on this issue, which the BHA has a race-planning department dedicated to trying to improve. But individual Forum members have submitted suggestions. We would urge you to make your own suggestions known, either through HBF or directly to such as


HBF writes:

The intention is to attract more runners, just not “dross” ones. That does not always happen, obviously! More widely, small fields in British racing do not go down well on the international stage. A minimum of 8 runners is the aim. This is really a concern for the likes of the race-planning department at the BHA.


HBF writes:

No consensus has been established at HBF, which is made up of a mix of glass-half-full and glass-half-empty individuals! HBF has been outside the loop on this but will be briefed about the situation at its July meeting and intends to make it clear that lowering deductions should at least be considered and that it will oppose attempts to squeeze the betting public for purely short-term gain.


HBF writes:

Don’t know! Not an HBF matter, but it underlines how there are intriguing angles in this sport. The sport will benefit from such questions being asked, and more easily explored and answered. HBF is very keen on there being an environment in which the beautiful complexity of horseracing analysis can flourish.


HBF writes:

HBF has raised the unsatisfactory nature of “privileged data” with BHA. Its existence runs counter to much that racing is trying to achieve and fuels the impression that racing is an “insider’s game”. HBF will raise this again at its next meeting – at which BHA will be present during a dedicated slot – and seek clearer official policy. This is part of the wider attempt to change culture around data, and that will take time.


The Horseracing Bettors Forum (HBF) is today inviting applications from the public to fill a small number of places on the Forum to replace existing members as part of a planned, refresh of its membership ahead of its second anniversary.

The HBF was established in September 2015 to understand the views of those who bet on British racing, and to represent those views to the individuals and bodies who make policy decisions in this area. The HBF was created with the assistance of the British Horseracing Authority (BHA), and maintains a good working relationship with the sport’s governing and regulatory body, but is independent of it.

The HBF comprises up to nine voluntary members, chosen for their knowledge of the betting environment and their ability to represent the betting public. Forum members meet four times a year and correspond extensively between those meetings. To that end, the HBF invites applications from members of the public interested in such a role. From this point on, HBF members will be asked to serve a three-year term.

Appropriate individuals are kindly requested to contact HBF at specifying in no more than 500 words why they would like to be considered for the role, including contact details (a CV is not required).

Preference will be given to applicants who:

  • Demonstrate a proven interest in the concerns of the British horseracing betting public
  • Give evidence of expertise in areas which will be useful to the HBF in achieving its goals
  • Are prepared to commit to assisting the HBF, such as through internal discussion and case-study work, in addition to being available to meet four times a year

All positions with HBF are unpaid, but reasonable travel expenses to official HBF meetings may be claimed by members in line with the BHA expenses policy. This is an opportunity to represent a group that is key to the future prosperity of the sport of horseracing and to make a positive difference.

The HBF is committed to equal opportunities and encourages diversity. The closing date for applications is Wednesday 31 May 2017.

Forum members will be appointed by the Chair following the HBF’s next scheduled meeting, which will be on Monday 3 July 2017, with a view to inducting new members in September or October 2017.

Further information about the activities of the HBF and its remit can be found on its website at

Notes to editors:

  1. The Horseracing Bettors Forum was created in August, 2015, with the assistance of the BHA to represent the perceived interests of those who bet upon, or who might bet upon, British horseracing.
  2. The HBF seeks to ensure that those interests are understood and taken into account in the relevant decision-making processes, for the good of both bettors and the sport of horseracing in Britain.
  3. The HBF consists of nine members – all voluntary and unpaid – who convene roughly once every three months to discuss issues that they feel are relevant to British horseracing punters. The HBF has no mandatory powers, but, where appropriate, it will seek to influence policy in accordance with its stated objectives.

Horseracing Bettors Forum News from meeting in March 2017

The seventh HBF meeting took place at the BHA offices in London on 20 March, 2017. The following is a summary of some of the matters considered and individuals contacted.

Contact with the betting public

  • HBF will look into arranging another “meet the HBF” day at a racecourse, possibly in the Midlands, following last September’s event at Doncaster racecourse
  • HBF will curate a Twitter Q&A in coming months
  • The Chair will shortly be participating in a Q&A through The Racing Forum site for racing fans

Future HBF membership

  • Chair will be replaced in September 2017 – at the end of a two-year tenure as agreed at the outset – but remain on the Forum for a minimum of a year to help with succession. Applications to be Chair were invited from existing members
  • HBF will also seek applications from the public to join the Forum, commencing in September or October 2017, as part of a planned refreshing process. This will coincide with two HBF members stepping down
  • BHA to assist in drafting and publicising application process

Subject matter representatives

  • HBF is looking to formalise how it deals with key issues and stakeholders by appointing HBF members to ownership of them. These include: bookmakers; the BHA; government bodies; and the betting public. Future appointments to the HBF will take these responsibilities, and the skills required to discharge them, into account

Meet the BHA (Nick Rust, CEO, and Paul Johnson, Head of Racing)

  • A regular slot of roughly an hour in which both parties give updates and discuss current topics of shared interest
  • Subjects discussed included: the funding of racing; the situation regarding non-runners; concerns about official description of going; concerns about race-distance measurements; concerns about the delay in bringing in new data streams and in ensuring the accuracy of existing ones; declaration procedures at Cheltenham and other major racing festivals; accusations of so-called picture piracy; the BHA’s commitment to consider the impact on punters of any new initiatives or of changes to existing policies (involving HBF if needed); the need for HBF’s involvement in shaping policy to be recognised publicly

In addition, HBF is currently engaged in a significant piece of work which involves liaison with the BHA, the Gambling Commission and with bookmakers. Two senior bookmaking representatives attended the latter stages of the meeting to this end. All being well, HBF will make a public statement on the matter when steps are sufficiently advanced.

HBF attendance at the March meeting from: Glenn Alcoe; Scott Ferguson; James Prosser; Simon Rowlands (Chair); Tanya Stevenson; Steven Tilley; Matt Bisogno; and Quen Emmenes

Next HBF meeting will be on the afternoon of Monday 03 July, 2017, at the BHA offices in London. It is anticipated that it will include attendance from representatives from the Gambling Commission – with whom HBF is discussing Rule 4 use among other matters – and the BHA. Other details to be finalised.

April 2017


Positional Statement on Consumer Law and Gambling

The Horseracing Bettors Forum notes the findings in the recent Kinloch vs Coral Bookmakers case in the Scottish Court regarding a bet placed on football.

While not wishing to comment on the outcome of the dispute itself, HBF is placing on record its concern about some of the remarks made in the course of the case about the degree of consumer protection – namely none – due to an individual which a Court chooses to identify as a “professional gambler”.

At point 150 in the Court’s findings this is portrayed as being synonymous with an individual “gambling with a view to profit”.

HBF maintains that nearly all gamblers act with a view to securing a profit, even though most of them fail in that regard.

Indeed, it is a crucial aspect of betting on horseracing and other sports that a punter is engaged in a game of skill, as opposed to pure chance, and that it remains an aspirational pursuit for the majority.

HBF expects that the consumer rights of the betting public at large are not waived on such a flimsy pretext. It will seek confirmation from the Gambling Commission as to what that body’s view is on this matter.

The full Court judgement can be read at:

April 2017

HBF Strengthens Link with UK Gambling Commission

Two representatives of the Gambling Commission attended the last Horseracing Bettors Forum Meeting in December to discuss matters raised by the HBF and as an early step in consolidating links between the two bodies.

Topics that were discussed included: Tracking Cookies/Spyware; The Application of Rule 4s; Dormant Accounts; Difficulties in Withdrawing Funds; and Future Contact Between HBF and The Gambling Commission.

The GC’s representatives emphasised the need for the public to be aware of the correct procedures to be followed if they have a complaint. In many cases, this involves exhausting the relevant operator’s complaints and disputes procedures, including, if necessary, reverting to an Alternative Dispute Resolution (ADR) body, available at no charge to the public. The GC then acts as the authority that oversees the activity of the ADR.

More details can be found at:

The GC’s regulatory focus is on evidenced breaches of the operator licence conditions and codes of practice. Where regulatory shortcomings are identified, the GC has a range of compliance and enforcement powers which can be used to raise standards within the industry to the benefit of consumers.

The GC does not directly resolve individual customer complaints and cannot help customers to get their money back from a bet placed.

On the specific matters discussed:

  • GC had shared with the Information Commissioner’s Office evidence of possible commercial misuse of tracking cookies brought to the attention of HBF.
  • GC understands that ICO will shortly be publishing updated cookie guidance and that ICO expects that organisations allow individuals to consent to having cookies placed on their devices. The latter implies that such software should not be placed on the landing page as, by so doing, it negates the opportunity for consumer consent.
  • HBF/GC was joined by one of the BHA’s Betting Investigators to discuss concerns about Rule 4 use and possible solutions. GC stated that it requires clarity and transparency about a company’s Rule 4 approach, but that decisions on – for instance – whether to apply Rule 4 deductions at time of withdrawal or time of bet placement are a commercial matter for those companies.
  • In response to expressed concerns about the potential for wider market manipulation through withdrawals and Rule 4s, the GC stated that it sees it as the Starting Price Regulatory Commission’s role to monitor the integrity of SPs. HBF has since restated its lack of confidence in the SPRC as a body and pointed out that SPs are only a small part of market operations that may have the potential of being compromised.
  • HBF was encouraged by GC’s public comments regarding alleged Rule 4 abuse made subsequent to the December meeting. GC has restated that anyone with clear evidence of improper activities regarding R4s should contact the GC, either directly or through HBF.
  • GC is monitoring possible issues regarding dormant accounts but has not received much indication of public concern about this matter. GC has made limited comments on this matter here:
  • It is ultimately for the Courts or the Competition and Markets Authority to rule on the fairness of dormant account charges. GC expects operators to take reasonable steps (and to provide evidence of this) to notify a customer before invoking charges, and it expects that such charges be reasonable and proportionate.
  • GC is also exploring concerns regarding difficulties in withdrawing funds (HBF had pointed out the asymmetry between procedures governing deposits, which tend to be easy, and withdrawals, which frequently are not).
  • GC expects operators to monitor both deposits and withdrawals as part of their regulatory obligations. It continues to educate the industry regarding the need to explain why checks are undertaken.
  • GC’s new website includes a page for consumers about identity checks [].

Both GC and HBF saw the discussions as an important early step in consolidating links between the two bodies and in clarifying matters of concern to each of them. There will be an ongoing dialogue, and it is likely that GC representatives will attend future HBF meetings on a selective basis.

HBF thanks the Gambling Commission for its time and efforts already. HBF invites the British horseracing betting public to contact it through the usual channels if wishing to query or develop further any of the points raised above.

Horseracing Bettors Forum, March 2017