'That's none of their business - are they trying to insinuate I'm not mentally capable of placing a bet?'

What would Racing Post readers make of the Gambling Commission's consultation on affordability checks? We approached a dozen of those who have written in, expressing a variety of views on the topic, and spent some time going through the consultation's questions with them.

They represented a spread of ages, albeit mostly over 50, and lived in different parts of Britain. What would they make of the commission's ideas about financial thresholds and the kind of information a bookmaker should seek in order to learn more about a customer's position? Read on . . .

Our consultees

John Chamberlain
Finance worker employed by Ladbrokes for several years to 2005, has been betting on sports all his adult life

David Dickinson
A former journalist who had a 20-year hiatus from betting while working as a BHA handicapper

Yvonne Foote
A former company director who has been betting on horseracing since childhood

"Jane"
A former betting shop worker who now derives much of her income from betting sites; she has asked for her name to be withheld

Roy Hall
Long retired, was a key figure at the Tote, where he worked for 36 years. A regular shop punter as well as betting online

John Livingstone-Learmonth
A writer and communications adviser, known as a leading expert on the wines of the Rhone Valley

Peter Melling
Retired following the sale of his business, has been betting on horses for around 15 years

John Randall
A dentist whose father was a bookmaker; unrelated to our own writer of the same name

Rick Reeves
A TV actor-turned-salesman whose credits included Dr Who and Upstairs, Downstairs

Gavin Shillito
An insurance underwriter descended from several bookmakers

Ash Symonds
A student and freelance journalist, including for the Cheltenham Post and Irish Field

Dave Tobutt
A sales director who tells us his great-grandparents trained a winner of the Waterloo Cup

The questions

How often do you gamble?

Twice or more per week 10
Once a week 1
Less than once a week, more than once a month 1
Once a month
Every 2 or 3 months
Once or twice per year
Never

Have you gambled online in the past four weeks?

Yes 10
No 2

To what extent do you agree or disagree that in the past 12 months, you or someone close to you has experienced negative consequences as a result of your gambling?

Strongly agree
Agree
Neither agree nor disagree 1
Disagree 1
Strongly disagree 10
Prefer not to say

To what extent do you agree or disagree that in the past 12 months, you have experienced negative consequences as a result of someone else's gambling?

Strongly agree
Agree
Neither agree nor disagree
Disagree 1
Strongly disagree 11
Prefer not to say

As might be expected, our consultees are regular gamblers. Only one still does most of their betting in a shop rather than online, Gavin Shillito telling us he hasn't used the internet to place a bet for more than a year. For him, the spirit of camaraderie among fellow punters is an important part of the attraction.

He worries that, even if affordability checks are not imposed on shop punters, there will still be a grievous impact on his pleasure through a loss of funding to racing and possibly the closure of some shops if betting industry income falls. "There's people who go into the bookies who probably don't have much else," he says.

"They're older, they don't have a lot of family, they go in there for a bit of company. Is that such a bad thing? It feels like an attack on an institution in the disguise of, let's protect everybody. The harm is going to far outweigh the potential positives."

Do you consider it likely that, if a financial vulnerability check were introduced, you would meet one of the thresholds for a check? [A net loss of £125 over 30 days or £500 in a year]

Yes 11
No 1
Prefer not to say

Do you consider it likely that, if a financial risk assessment were introduced, you would meet one of the thresholds for an assessment? [A net loss of £1,000 in a day or £2,000 in 90 days]

Yes 1
No 11
Prefer not to say

Our consultees almost all felt they would be likely to trigger the financial thresholds being considered for a vulnerability check but probably not the higher thresholds for the more in-depth risk assessment.

To what extent do you agree with the proposal that gambling operators be required to conduct light touch financial vulnerability checks based on public data when a certain net loss threshold is reached?

Strongly agree
Agree 4
Neither agree nor disagree 1
Disagree 4
Strongly disagree 3

To what extent do you agree with the proposal that gambling operators be required to conduct enhanced financial risk assessments where there are very unusual patterns of loss? The purpose of such an assessment would be to act on the indicator of harm of unusual patterns of loss and assess the gambling in the context of a customer's financial circumstances.

Strongly agree
Agree 3
Neither agree nor disagree 2
Disagree 1
Strongly disagree 6

These two questions seek approval of the principle behind the white paper's proposals, that betting operators should sometimes be obliged to investigate the finances of their customers. Some of our consultees saw merit in it. "If someone's been bankrupt and had financial problems . . . I do accept that some people need help," was one view.

But a majority objected. "I violently disagree," said Roy Hall. "That's off the Richter Scale, I'm afraid."

"It's entirely up to the individual how they handle their financial affairs and what they do with their money," said Peter Melling. "I can't see how any of this would stop a problem gambler from going down to the shop and buying endless scratch cards."

"I don't think affordability checks on people spending their own money on a legal pastime should be acceptable under any circumstances," said John Chamberlain and there were other responses along these lines.

Some worried about the security of any financial data handed over. Dave Tobutt noted: "We're not two steps away from some rogue operation setting up as a betting operator and taking in all this personal information and pillaging the individual. It's a stupid, ill thought-out process."

There was concern about how "unusual patterns of loss" would be defined or coded into an algorithm, given that any fan of jump racing is likely to risk a lot more in mid-March than for the previous two months. "What they need to do, if they genuinely want to do checks, is look for people whose stakes increase when they're losing more than when they're winning," said David Dickinson.

To what extent do you agree with the proposed threshold of a financial vulnerability check based on public data (eg bankruptcy) if a customer has a net loss of £125 in a rolling 30-day period?

Strongly agree
Agree
Neither agree nor disagree
Disagree 2
Strongly disagree 10

To what extent do you agree with the proposed threshold of a financial vulnerability check based on public data (eg. bankruptcy) if a customer has a net loss of £500 in a rolling 365 days?

Strongly agree
Agree
Neither agree nor disagree
Disagree 2
Strongly disagree 10

Laughable, that's how these low thresholds for vulnerability checks were seen by our consultees. The typical reaction was a mix of derision and outrage.

"Nonsense," said John Randall of the £500 per year threshold. Ludicrous and ridiculous were among the adjectives blurted out by others. "That's £1.50 a day."

It's actually £1.37, while the monthly limit works out at £4.17 per day. For some people, that's coffee money.

Roy Hall said: "My wife, every day she goes into town and has her coffee fix. She sometimes says, 'I do spend a lot in the cafe, don't I?' I say, 'For goodness' sake, you've got thousands in the bank, what are you worried about, spending £5 in the coffee shop?'

"Nobody's asking her to prove she can afford it and frankly nobody should ask her, it's nothing to do with anybody else. I think this check is absolutely stupid."

"I know a couple of owners," said Ash Symonds, "and when they fancy their horse, they go down the line, betting in hundreds. If they lose, they'll be straight past that threshold on one race."

"It's peanuts," said John Chamberlain. "They'll catch everyone I know. The football season's on and the American football as well now. If you're a regular sports bettor and you've got those as well as the horseracing, everyone I know would do that easily if they don't have a win."

Dave Tobutt questioned whether it was ever possible to save people from themselves, or whether it was desirable for the government to try. "I've worked on the docks in Liverpool and Newcastle and there'd be people who'd take pay on Thursday and be potless by Friday night. We see it the world over but that's human nature and I don't think legislation can completely change that."

Gavin Shillito pointed out that a punter could trigger the annual threshold by doing a 10p Lucky15 every day.

To what extent do you agree with the proposed threshold for a financial risk assessment related to binge activity of more than £1,000 in a relevant period of a rolling 24 hours?

Strongly agree
Agree 1
Neither agree nor disagree 2
Disagree 7
Strongly disagree 2

To what extent do you agree with the proposed threshold for an enhanced financial risk assessment related to significant losses over time of more than £2,000 in a rolling 90-day period?

Strongly agree
Agree 1
Neither agree nor disagree 3
Disagree 6
Strongly disagree 2

Our consultees believe they are unlikely to trigger these higher thresholds, so they see them as less of a threat. Some neutral views were expressed but the majority still argued against them.

Fundamentally, the mood was opposed to any one-size-fits-all type of check. "You don't know what their financial status is or what they can and can't afford to lose," said Peter Melling.

Roy Hall said: "If it was someone like me losing £2,000, you could make a case for my bookmaker contacting me and saying, 'Are you all right, can you afford this?' And then I decide whether I want to do anything. There are high rollers. A £5,000 bet to some of these people is pocket money."

"It's all about context," said John Livingstone-Learmonth, calling attention to the perspective of a racehorse owner. "If you've got £30,000 of horseflesh running, or even £500,000 of horseflesh . . . or think about someone who asks ten people out to dinner. They're going to be crossing that sort of threshold in three hours."

"The whole business of interfering in people's freedoms is shit," fumed Rick Reeves. "Everybody's different. These guys are trying to do something that can't be done.

"I don't think we should have any of these limits. There is no way of doing it without taking away basic freedoms from people who are not misbehaving and are not in trouble."

To what extent do you agree with the proposal that thresholds for the enhanced financial risk assessments are lower for those aged under 25 to £500 in a rolling 24-hour period and £1,000 in a rolling 90-day period?

Strongly agree
Agree 5
Neither agree nor disagree 1
Disagree 3
Strongly disagree 3

This proved the most sharply divisive question in the consultation, with some of our consultees readily accepting a need to treat young, novice gamblers differently while others were outraged by the idea.

"The government have lots of controls on people determined by their age, whether they can buy a drink or cigarettes or drive a car," said Roy Hall. "So, if the government want to bring in some controls on young people, I do not have a problem with that. Who am I to decide whether that should be 18, 21 or 25?

"There comes a point when the young get older and they're out of the shackles of government. If this whole thing was aimed at the young, I wouldn't have an issue with it. But they're treating us all like 25-year-olds and that I find incredibly offensive."

John Randall recalled: "I used to work in a betting shop when I was a student, in the late 60s. I remember a guy came in and he got a Yankee up and won £780, which bought him a car. But then we got a lot of kids coming in, wanting to emulate it and blowing money that they didn't really have.

"I think 25-year-olds now are a lot younger than when I was 25. So I would think it's probably reasonable."

Others favoured a level playing field for all gamblers over 18. "It would be unfair," said Gavin Shillito. "Are you saying they're completely in another category in terms of their social responsibilities? They have the same rights as those over 65."

Equally robust was John Chamberlain. "It's a legal pastime, it's their money, it's nothing to do with you. To me, 25 is quite old. It's not young. They can go to a pub and get drunk, can't they?"

"At 19, 20, 21, they're adults," added Jane. "I can't think there's any other area where they would have such restrictions imposed on them. They can take out a loan, buy a house and get married. I've got children in their 20s and I would hope that I've brought them up right. It's not anybody's else's job to impose those things upon them."

Our youngest consultee, Ash Symonds, was not dead against the concept of some additional protection for teenagers. "I'm 20 and I know when I was 18 I'd be nearly betting on most races that I could. It'd be pennies, but most races. Some days good, some days bad. It's the immaturity and the lack of knowledge, you don't know what you're doing until a good couple of years into it."

David Dickinson acknowledged that he was thoroughly experienced by 25 but he could see value in offering protection to novice gamblers, regardless of age. "Somebody who's 45 and never had a bet in their life is an inexperienced gambler, if they suddenly decide to get the bug. They can be just as vulnerable as an 18-year-old."

To what extent do you agree with the proposed definition of net loss for financial risk assessments which is that net loss is the loss of deposited funds with a particular operator, i.e. excluding bonus funds and restaked winnings?

Strongly agree
Agree 6
Neither agree nor disagree 3
Disagree 1
Strongly disagree 2

In other words, if you deposit £200, then use it to win £5,000 and then blow the lot, the Gambling Commission (GC) proposes to regard that as a net loss of £200 rather than £5,000. For most of our consultees who expressed a view, that approach seemed basically sound.

There were exceptions. John Livingstone-Learmonth pointed out that the definition confines itself to a person's betting with a single firm. "We've all done it, one year we're winning with Ladbrokes and losing with Hills and the next year it's the other way around," he said. So what might appear to be a concerning loss might in fact be a net profit.

Establishing the true position would require access to the whole of a person's betting history, but who wants to share that kind of information with any bookmaker who asks for it? "The more that one's trying to be precise with this, the more that the invasion of privacy and civil liberties is occurring."

He decried the lack of sophistication behind the imposition of thresholds. "Horseracing is finesse betting, [requiring the consideration of] weights, measures and all the other things we know about. They're trying to delve into this and say, 'Oh, he lost £100 that day' – a day when the horse stumbled out of the gate and was beaten a nose. I just don't think you can do that. If you leave it to an algorithm, everybody's going to be swept up in the net."

Jane added: "If somebody is matched betting, you're only seeing one side of the coin. You're not seeing that they're also laying it off somewhere else for a profit."

Should a betting operator get in touch to ask whether the net loss they're seeing is in fact the true position? "I don't think anybody would be entirely honest about it because they don't want to lose their account. So you're not going to admit to matched betting."

To what extent do you agree with the proposed approach to enable a recent overall net position to be taken into account when a threshold is met?

Strongly agree 1
Agree 10
Neither agree nor disagree
Disagree
Strongly disagree 1

To what extent do you agree with the proposed approach that would set a timeframe whereby a recent overall net position could be taken into account for seven days in relation to the binge threshold and 90 days for the losses over time threshold?

Strongly agree
Agree 1
Neither agree nor disagree 2
Disagree 6
Strongly disagree 3

Interestingly, the GC can't bring itself to use the word "profit" here. It refers instead to "a recent overall net position" but profit is what it means. If you lose £2,000 today but won £3,000 yesterday, they accept you shouldn't be triggering any thresholds.

That stance was uncontroversial except for Jane, who pointed out that each operator is only seeing part of the overall position of any customer engaged in matched betting.

But the commission wants to put restrictive limits on the length of time for which a past profit can be taken into account – just a week in some cases and never more than 90 days.

"Most punters would talk in years," said John Livingstone-Learmonth. "I had a good year or a bad year. We think in years because we think of calendars and fixtures and the seasons, jumps and Flat."

"They seem far too short to me," said Gavin Shillito. "I could have a bet on Saturday and not bet until the following Saturday."

John Chamberlain reckoned 90 days was far too short a period on which to judge someone's betting. "If you asked a fund manager, they'd say, unless it's five years, you're wasting your time."

To what extent do you agree with the proposed approach that would mean that a bet would only be counted as a loss when it is settled as a loser?

Strongly agree
Agree 7
Neither agree nor disagree 4
Disagree
Strongly disagree 1

The answer may seem self-evident but, as we know, money can be committed far in advance of a race and evidently the GC has heard concerns that a bingeing gambler could engage in this kind of betting without immediately triggering a threshold. Of course, a punter would usually be able to modify a long-term position with a lay bet through an exchange or by hedging on other possible outcomes, as some of our consultees noted. In any case, they agreed that the money shouldn't be counted as lost until it is lost.

To what extent do you agree that a financial vulnerability check would include publicly available data relating to an active county court judgement, high court judgement, administration order or decree, or equivalent?

Strongly agree
Agree 5
Neither agree nor disagree 1
Disagree 3
Strongly disagree 3

Few of our consultees liked this idea but opinion was split, some agreeing with the proposition on the grounds that the data mentioned is not confidential. As Rick Reeves put it: "Those kind of creatures are going to come out of the woodwork in the end, aren't they? If financial irresponsibility is part of a person's set-up, then sooner or later they're not going to be able to afford certain things."

Others, like Yvonne Foote, were conflicted: "It's very hard when you disagree fundamentally with the whole thing. Publicly available information, they can do anyway at any point when they choose, presumably."

None of our 12 consultees agreed with the idea that bookmakers should consider your job or your address when trying to guess at your wealthCredit: Alan Crowhurst (Getty Images)

To what extent do you consider that aggregated data should be included in a financial vulnerability check in relation to postcode?

Strongly agree
Agree
Neither agree nor disagree 1
Disagree 2
Strongly disagree 9

To what extent do you consider that aggregated data should be included in a financial vulnerability check in relation to a customer's stated employment status and job title, and cross-referencing to open source data about the average income for that occupation?

Strongly agree
Agree
Neither agree nor disagree
Disagree 6
Strongly disagree 6

None of our consultees could see any justification for the idea that bookmakers should consider your job or your address when trying to guess at your wealth. Several responses suggested it was both impractical and offensive ("Codswallop!"). "What business is it of theirs where I choose to live?" asked Peter Melling.

There's no reason to believe that a person must be like their neighbours, argued David Dickinson. "We know a few heavy gamblers and they don't live surrounded by other heavy gamblers. I'm a heavy gigger, I went to see Graham Nash and Squeeze last Friday, but I'm surrounded by people who never go to gigs."

John Randall was reminded of a car park attendant who used to work at York races. "All these lovely cars would come out and he'd say, 'They're all on bloody credit, you know!' I don't think the postcode or the car you're driving gives any idea of that kind of thing."

Roy Hall said: "If you actually wanted concrete proof of the prejudice that is riddled through the Anti-Gambling Commission, these are the questions that do it. Do we assume that a doctor is a safer bet than a postman? You have problems right through the strata of society and to pick on any particular one just shows that these people are riddled with prejudice."

Many of our consultees are retired and naturally resistant to the idea that a significant income stream should become an essential condition of being able to continue betting. "I go back to my dad, after he had a massive stroke," said Yvonne Foote. "He didn't drive a car, he didn't drink alcohol, he didn't have a cigarette.

"All he had was his pension and he probably spent a disproportionate amount of his pension on having a bet each day. But it wasn't going anywhere else and it got him through the day. It kept my dad alive, I have no doubt about it."

To what extent do you agree with the proposed requirements for data that must be included in an enhanced financial risk assessment for credit performance data and income and expenditure data, including current account turnover data?

Strongly agree
Agree
Neither agree nor disagree 2
Disagree 1
Strongly disagree 9

A 75 per cent vote for "strongly disagree" shows this is a question that got people's backs up. In particular, our consultees did not like the idea of their current accounts, or any data derived therefrom, being considered by a bookmaker.

Yvonne Foote pointed out that her account is a joint one with her husband, who has no interest in betting. "I will vehemently oppose his part of this account being included in my gambling," she said. "It's a principle. It doesn't bother me what they would actually see."

Dave Tobutt said he would be "mortified" at the idea of sharing such information with a bookmaker. "That's private information between you and the bank manager," said Peter Melling.

"This would be a total invasion of privacy," said John Livingstone-Learmonth. "I'm betting with tax-paid money, which is therefore discretionary spending. I can't think of other areas where I'm going to be thus penalised."

John Chamberlain considered the implications of bookmakers having to sift through such data. "Ladbrokes are gonna have to start employing a whole load of financial analysts. Who's gonna pay for that? They're gonna start turning customers down because if you're only a small punter, why would they keep you?"

"Nobody else needs to have access to that," said Jane, but unfortunately she reports having faced even more intrusive questions recently while trying to satisfy a bookmaker that she can afford her gambling. "'Why do you get disability payments? What's your disability?' That's none of their business. Are they trying to insinuate that I'm not mentally capable of placing a bet?"

To what extent do you agree with a 12-month timeframe for the validity of the financial vulnerability check?

Strongly agree
Agree 2
Neither agree nor disagree 2
Disagree 6
Strongly disagree 2

To what extent do you agree with a six-month timeframe for the validity of the financial risk assessment?

Strongly agree
Agree
Neither agree nor disagree 3
Disagree 6
Strongly disagree 3

If you're subjected to a financial check and pass it, how long should it be before the operator can put you through it again? The commission proposes minimum periods of either six months or 12, depending on the threshold that was triggered.

The arbitrary nature of those time limits was much commented on. "Who's to know what happens the day after?" asked Yvonne Foote.

"Your wife walks out or something else happens and you go on a binge. That doesn't make much sense to me."

"They're missing the point completely," said David Dickinson. "If you're a heavy but moderately achieving punter and you suddenly lose your job, I think 99 out of 100 will cut their punting right back and say, 'Look, I can't afford this any more, it was a luxury.' The 100th one is going to increase their stakes and that is going to happen almost immediately. So the idea of giving someone a tick for 12 months is just stupid."

Ash Symonds wondered whether some punters would be victimised. "If a bookmaker had this account on their radar and had a date every year when they were going to look at it, it could get very long in the tooth."

To what extent do you agree that it is proportionate that deposits and gambling may continue while a financial vulnerability check is taking place?

Strongly agree 1
Agree 7
Neither agree nor disagree 3
Disagree 1
Strongly disagree

To what extent do you agree that it is proportionate that gambling may continue while a financial risk assessment is taking place, but that further deposits would be paused?

Strongly agree
Agree
Neither agree nor disagree 4
Disagree 7
Strongly disagree 1

Should you be able to carry on betting while a bookmaker considers your finances? The GC is content to say yes, with the caveat that your ability to deposit more funds may be paused if you've triggered the more detailed of the proposed checks.

Our consultees did not like that caveat. 'Innocent until proven guilty' was a phrase used more than once.

David Dickinson was in a cynical mood. "My concern is that they are going to be more intrusive on winning punters."

We have not proposed any set requirements for how quickly a financial vulnerability check must be completed. Do you have any comments on whether such requirements would be necessary?

Our consultees saw risk in leaving punters in limbo while checks are conducted, particularly if their ability to deposit funds is to be restricted during this time.

Dave Tobutt saw no reason for delay. "If I want to go down the road and buy a Maserati, I think they'll have a check from the brokers in about ten minutes. If they're going to carry out these checks, they should be capable of being completed within 24 hours.

"They would have to set a timeframe," said Ash Symonds. "I wouldn't know how long it would take but as long as you know a date when you'll have findings, at least you're clear in your own mind about that."

"You don't want it open-ended," agreed Roy Hall. "It wouldn't apply to me because they've only got to ask me once for financial information and I shall tell them to piss off and close the account and that'll be the end of it.

"I don't think this is going to happen. I think government realise they've got themselves into a complete mess on this and it ain't gonna happen."

To complete the Gambling Commission's consultation on affordability checks, visit racingpost.com/consultation and follow the instructions.

The Racing Post also wants to hear from you: what has been your experience of affordability checks since the white paper was published at the end of April, and what do you think of the government's proposals? Have affordability checks affected your betting behaviour?

It's a chance for your voice to be heard. Email the Racing Post at editor@racingpost.com with the subject 'Affordability checks' to share your experiences, your thoughts about the government's proposals, and your contact details.

The Affordability Files:

'By the time our punters get to the third race on the opening day of the Cheltenham Festival, we'll be asking them for their P60s' 

'The elephant in the room' - are frictionless affordability checks a flight of fantasy? 

How the white paper miscalculated the impact of affordability checks on racing 

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