Kingsley Bartholomew’s thoughts on a National Tote

With the recent news of a National Tote Pool by the end of next year I thought I would share some of my views. 

Will turnover increase on Horse Racing in Australia ? 

In short the answer is NO, unless Tabcorp can re invigorate interest in pari-mutuel style wagering. 

Why it won’t increase ?

Tote turnover is in severe decline and has been for some time now. With no marketing directed at tote betting the young, modern-day recreational punter barely knows it exists, and if they do it’s through a best tote product offered by one of the Corporate Bookmakers. Nowadays very little of this money makes its way back into Tabcorp’s pools regardless of the bet size. In reality, a National Tote will deliver a more accurate final tote dividend due to the larger solitary pool of money with the same market percentage averaging 118%. The majority of punters are extremely habitual, once they are gone it is going to be very hard to get them back.

Ideas to stimulate interest and increase turnover

Jackpots – Punters love jackpots. I believe it would be a smart move for Tabcorp to continually create their own jackpots on exotics bet types for the main races of the day. The increased pool size due to the jackpot will help negate a high percentage of the marketing cost. 

Rebates for punters – The way rebates are structured now, the more you turnover the higher your rebate is. In my opinion this is a flawed and unfair system which fails for both the high turnover player and also the recreational punter. The high turnover player, who all tend to place their bets in the last few seconds before jump, nowadays struggle to make a decent profit because not only are the dividends being crunched shorter due to the rebates, but there is now barely any recreational money to win due to the lack of interest and uncompetitive nature of the tote pool.

I think there are two different ways Tabcorp could structure rebates. Firstly, offer an 8% to 10% rebate to ALL punters on ALL bet sizes for winning or losing bets placed over the internet. My second idea is to offer a staggered rebate depending on how early the bet was placed. I think this idea could create enormous interest and really help grow the pools. An extremely attractive rebate of at least 12% could be offered if a bet was placed say 30 minutes or more prior to the race. To keep it simple say 4% to 5% is offered for all other bets. What Tabcorp are giving away with the 12% rebate they will more than make up for with the higher influx of money from the high turnover player who is betting to win a certain percentage of the pool regardless of the size. This idea will only work if the ‘early rebate’ is too good to refuse, as placing your bet 30 minutes or more prior to the race is not an attractive proposition for the majority of punters.

Rebates for bookmakers – I have always been astounded that bookmakers are allowed to use the final tote dividends and offer an enhanced version of it. When corporate bookmakers in Australia first existed they weren’t allowed to offer tote products at all. After 5 or so years this rule changed. Prior to the UK Corporate invasion bookmakers used to trade punters money which was wonderful for all and helped build tote pools. Nowadays this barely exists as bookmakers profile customers and the majority restrict any punters they believe are not going to be economically viable rather than use their trading skills to manage a client. When the National Tote Pool begins many Corporate Bookmakers will once again undercut Tabcorp by offering products like Tote+5% etc with not a dollar seeing the light of day. A solution to this problem would not be to ban all corporates from offering tote products, but coercing them into directly placing all money taken on these products straight into the National Tote and rewarding them with a 8% to 10% rebate.

Bet Types – Punters love being able to win a lot of money for a small investment. ‘Pick the card’ or ‘Pick the exact finishing order’ style exotics could be introduced with a jackpot pool on Saturdays main race. 

Marketing – If the National Tote pools are any chance of increasing turnover then Tabcorp must divert a large portion of their marketing away from fixed odds betting. The recreational punter is losing their money at such a high rate now due to the high percentage fixed odds markets, not only are they unable to invest on upcoming races, they are rapidly losing interest in the sport. 

Technology and Data – The new age punter is no longer happy to stand in a TAB and place bets through a terminal. Tabcorp need to be encouraging new players into the market by offering free, up to date date, accurate historical data as well as being able to provide state of the art and versatile automated betting platforms for all levels of punters. 

To reinvigorate tote turnover on Australian Racing will not happen quickly, but I believe it certainly is achievable if Tabcorp take a long term investment approach rather than focusing on short term revenue. 

The State of #TheGreatGame

In the last 3 years percentages in racing fixed odds markets have crept up by 4 to 5 %. Horse racing SP fixed odds markets are now about 121%. That’s very high – to put it in perspective 121% equates to a head to head sport market of $1.65 each team. Further, racing markets are so lethargic at present that it mostly sits around 130% until 2 mins to go. Anyone betting into 130% is effectively betting into $1.50 head to head markets. Taking $1.50 in a head to head market most punters are going to lose their money very quickly and only the very, very sharpest will turn a long term profit. Betting at $1.50 head to head you lose your stake if you are wrong in 2 out of 4 bets. You are only 50% wrong but you lose 100% of your money. And I think this is bad for horse racing. If sophisticated gamblers like me can’t make money and recreational gamblers get the shits because they lose their money so quickly the industry suffers.

Obviously the percentages are increasing because bookies are being charged so much more by governments and principal racing authorities (PRA’s) for the products they bet on. These fee and tax increases have mostly come about with no industry consultation or uniformity. For the bookies it’s a shit fight, and of course many think they deserve their medicine – but we have reached the tipping point – there’s going to be casualties. Their businesses are no longer sustainable under the current fee and tax structures. If we start losing bookies we lose the forces of competition that create value for punters.

Impact of the POC tax

2 years ago the industry was humming along, prize money rising, plenty of winning punters and entertained recreational gamblers, and bookies were making reasonable profits. But the market wasn’t elastic – it had just absorbed a big product fee increase from PRA’s and was the highest taxed marketplace in the world. And then the SA Govt. announced their 15% POC tax. At the time I thought it was ill-thought and the industry couldn’t cope with it, and I still think I’m right. All the other states have followed and here we are.

TabCorp pushed for the introduction of the POC tax because they believed they were disadvantaged. And ironically whilst they pushed for this crushing tax to be introduced they closed their own corporate bookmaker brand LUXBET because it was a “loss making business”. From my research I believe now after its implementation that they have way too much advantage in the marketplace. And that advantage has come about because the implementation of the tax was not properly thought out.

I pored over their 2018 financial year annual report to try to deduce how POC would affect them. For FY18 TabCorp made $1.03 billion gross profit from the tote, $509 million gross profit on fixed odds through their retail network, and $416 million from fixed odds online bets. Why this is interesting is because 78% of their profit comes from revenue that is protected from their competitors because of their exclusive license agreements with state governments, and when you stack up that 78% figure against what their competitors pay in this new POC environment is where it seems grossly unfair to their competitors.

I have used Tabcorp’s FY2018 figures for my evaluation, and the POC tax only kicked in in NSW and Victoria at the start of this year, so you could think that TabCorp will be paying even more than 59% back to industry and government – but I highly doubt it as their chairwomen is on the record as saying “that we can’t be double taxed” and that the state governments would need to reimburse them if they were to be worse off under the new POC structure. So we can assume they probably pay about the same now as they did in 2018.

TabCorp always have been and probably always will be the foundation of the racing industry. They are a decent and progressive company and I enjoy betting with them, but they need to cede some advantage to their competitors if we are going to have a diverse marketplace. Under the current set-up no one would consider starting up as a corporate bookie, and if they did they would fail.

Tabcorp pay out 59% of their annual gross wagering revenue (and of which 78% is protected) back to industry and government, a considerable amount. With all the new taxes and fees Betfair pay 59%, SportsBet, Ladbrokes and BetEasy all pay 41%. The gap between what TabCorp pay and what the rest of the industry pay isn’t wide enough when you consider TabCorp have the exclusive right to the juggernaut retail and tote market in most of the country.

My facts and figures about TabCorp won’t be perfect as their financial reports are still pretty opaque, but even accounting for a small margin for error in my figures it’s still obvious things aren’t fair.

We need PRA’s and government to make things a bit financially easier for bookies, so in turn they will hopefully reduce their percentages, and make it easier for us to win or not lose more. I have some ideas and I’ve tried to be realistic with what both can do.

What government can do

TabCorp’s competitors deserve some relief. How that should look is complicated. PRA’s need all the revenue they can get so they continue to grow prize money and their sports. The industry those PRA’s run are huge economic drivers, and the governments know this, so it has to be the federal and state governments who get less.

I think that all state governments should cut their POC tax in half when applying it to sports that bookies pay product fees on (racing, NRL etc..) but it can remain at current levels on sports or events where they pay no product fees (NBA, NFL, elections etc…). And the federal government should do the same when applying GST. Further, the federal government also get over $100 million a year in GST receipts from yearling/tried horse sales and the breeding industry – every yearling/tried horse sold, or mare serviced by a stallion, attracts 10% GST. So this needs to be thrown into the argument because it’s punters who make the yearling sales happen.

BetEasy just released their results for the first quarter of this year. They were alarming as to how challenging the marketplace is. They are a mature business, and the third largest bookie in Australia and they lost $1 million for the quarter. Their gross revenue was $62 million (all in USD), taxes and fees were $25 million, wages, rent etc… $26 million, marketing $10 million and R and D $1.5 million. I don’t really see where they can cut costs to increase their profit. Their gross revenue or win margin was 8% so they could try and jack that up, but that just means we the punter pay for it.

Ladbrokes have forecast that POC tax will cost them double what their profit was last year. A proper blackout for them.

Clear evidence for relief on taxes.

What Principal Racing Authorities can do

The PRA’s across Australia do a fantastic job in a very challenging environment. I’ve always been able to organise meetings with them to give them my thoughts – which shows that anyone can have their ear. I have great respect for them.

Racing Victoria and their product fees

Racing Victoria have a crazy mechanism in their product fees which charge bookies a hybrid of a percentage of turnover, or a percentage of profit, whichever is higher, for the meeting a bookie works on. But they apply it on a per meeting basis. A bookie can take bets on Derby Day at Flemington and win 500K, then take bets on Melbourne Cup day and lose 500k. Racing Victoria would charge them 30% (150k) of what they won on Derby Day and then charge them 3% of their turnover when they lost on Cup Day, which hypothetically could be 50K. So they are square for the 2 days but still have to pay Racing Victoria 200k. It makes no sense and is manifestly unfair. There has to be consistency in the way RVL charge.

TopSport for the last 2 years have paid out 155% of their revenue on Victorian racing in product fees to RVL. That’s not a typo – it has actually cost them significant money to put up prices on Victorian racing.

I’ve spoken to the CEO’s of other major bookies and they all say they pay close to 100% of their revenue to RVL as well because of the per meeting charge. They say if the rule of charging per meeting was scrapped they would be able to reduce their percentages for punters.

RVL CEO Giles Thompson has said he’s aware and worried about the rising fixed odds percentages. Changing the per meeting charge will go a long way to helping punters.

Racing and Wagering Western Australia also apply their hybrid model on a per meeting basis. I’ve brought it up with both CEO’s and of course the bookies have long been campaigning against it. Let’s hope they change it.

Racing NSW and Betfair

As percentages have risen and fixed odds betting has become less inviting, punters look for other avenues, and Betfair is a great one, however Betfair markets on NSW and WA racing have their issues.

Racing NSW and Racing Western Australia make Betfair pay their product fees based on a punter’s turnover. All other jurisdictions charge BetFair 35% of their gross revenue. Betfair don’t charge their punters on turnover so product fees are a nightmare for them on NSW and WA horse racing.

Betfair have to charge punters betting on NSW twice as much as they do on say Victoria or Queensland racing just to keep what they pay to RNSW in product fees to 50% of their revenue. If they charged the normal rate they would pay RNSW 100% of their revenue. And that is also after they stop any punters trying to trade on Betfair on NSW racing. This is because RNSW charge Betfair for every bet a punter makes on Betfair but BetFair only charge their punters for their net position on a race.

All these factors lead to diminished liquidity on BetFair on NSW and WA racing. And when you can get a bet on it costs twice as much as betting on Victorian racing on Betfair.

Peter V’Landys and Racing NSW talk proudly about how they have captured and engaged the next generation of racegoers via the introduction of The Everest. It was a contrarian move by Peter and it has paid off well. But he needs to realise that others in the industry, like Betfair can be contrarian as well. BetFair is here to stay – it’s a great driver of turnover, is hugely popular with younger punters who RNSW so desperately want. The rest of the country’s PRA’s have embraced it – made it pay its fair share but also allowed it to prosper. It’s time for RNSW to do the same and charge BetFair on revenue. This is reinforced when you consider that the $45 million dollar Spring Carnival that RNSW just announced can happen because of the NSW government giving part of the newly collected POC tax to RNSW. Punters are paying for it, so please give us a break in return by charging Betfair less so they can charge punters less.

Wagering Summit

The industry is in a mess. Government and PRA’s have too much advantage in the current climate. The industry needs to meet in Canberra for a couple of days and sort out the best way forward where all participants have a chance. I’ve mooted the idea with some of the heavy hitters of the industry and they all say it’s a must event. The state and federal governments receive hundreds of millions of dollars off the industry each year, so they can at least give us a couple of days to work out a better way forward. I’ll be pushing hard for this.

Minimum bet limit rule changes

I’ve had a lot of correspondence with PRA’s about MBL rules. Here is a brief update.

9am raceday rule; this rule (that MBL doesn’t kick in until 9am race days) is about 50/50 to get changed. Regulators I’ve spoken to say that there is strong pushback from mid -tier bookies who say they won’t put prices up if they are forced to bet prior to 9am raceday. Regulators fear this will impact turnover. But the bookies who are threatening this simply copy the prices of all the market makers like SportsBet and Bet365. They can’t be protected for their own mediocrity. All the big bookies like Ladbrokes and Sportsbet are happy for the 9am rule to be abolished. Fingers crossed it is.

Betting limits look like they won’t change yet. I’m okay with that because you can still get on for decent amounts at present. PRA’s acknowledge that if there is further consolidation they will have to review limits.

I often have issues with some bookies who do everything they can to reject my bets or close my account. I’ve highlighted all the tricks the bookies play to PRA’s and they are making some changes to MBL rules to stop bookies always trying to find loopholes to stop betting certain punters.

Official Price Network

All PRA’s are reviewing their official price networks. With them agreeing that the rules need to be changed to create better value for punters. I’m hearing that they are looking at having a blended price of the 5 major bookies that would be the official price. I think that would work well.


Deductions need serious attention. PRA’s need to have their own deductions scale and enforce bookies betting on their races to use it. I think there should be a system where a market, no matter how much percentage there is in it, is regressed back to 110% and deductions for a scratched horse would be applied then. Many recreational gamblers don’t understand deductions so making them as light as possible is the best look for the industry. 110% is fair for all.

The growing disconnect between Racing Queensland and punters

I wrote to Racing Queensland (RQ) CEO Dr. Eliot Forbes when he was CEO of Tasmanian Racing and asked him what he thought of introducing a minimum bet limit in Tasmania. I was surprised but appreciative of his honesty when he said that Tasmanian Racing would not be introducing a minimum bet limit as they were too reliant on corporate bookmaker sponsorship and advertising – and they could not risk that revenue by upsetting corporate bookies. He is now CEO of Racing Queensland and he has carried that attitude with him to the the much larger Queensland Racing market.

Worse than this unethical and anti competitive attitude is his, and Racing Queensland’s, complete lack of listening to, and engaging with their best customers; the punter. I  recently wrote to Dr. Forbes again asking him what RQ would be doing now that both Racing NSW and Racing Victoria had both introduced minimum bet limits. I posted it on twitter with his and Queensland Racing Minister Grace Grace’s twitter handles attached. It got a lot of traction. You would think that they might take notice of this and engage with me or other punters about the issue – however I was simply told RQ and Dr. Forbes would not debate commercial policy on social media and therefore they would not give me (or any other punter) and further information on the matter. I also wrote Grace Grace and asked her opinion on RQ introducing a minimum bet limit. I have never received a response and I have followed up with her office 3 times requesting a response, but still haven’t got one.

Frustrated by their stonewalling I independently contacted an RQ board member (all participant groups except for the punter is represented on the RQ board) and asked to have their ear for 10 minutes to tell them what it’s like to be a punter in today’s environment. They said they were only too happy to talk to me but a few days later cancelled on me because they were told that management had already dealt with punters on the issue. I tried to contact Radio Tab to be able to go on one of their programs and stoke some debate about introducing a minimum bet limit. After many tries and no one interested I gave up on Radio Tab as well.

In my experiences advocating for a minimum bet limit in NSW and Victoria I have always been able to have my voice heard, and so have many other punters. Anyone can approach Bernard Saundry or Peter V’Landys and if you’re patient enough they will give you some time to tell them how you feel. It seems that Dr. Forbes couldn’t care less though, and this is even more ironic considering the difficult state RQ finds itself in. The Fair Wagering movement I started has 2,000 followers on twitter and has attracted 40,000 visitors to its website – significant numbers. As an individual I am very insignificant and but the movement I represent is not and it cannot be ignored. It mostly represents the next generation of punters who RQ are so dependent on if they are going to have any hope of growing and becoming as strong as Racing NSW and Racing Victoria.

Nothing repulses me more than the unethical, talentless, predatory bookmaking that took hold here over the last decade. It has yielded somewhat but Dr. Forbes and RQ have endorsed it and told us to invest elsewhere. RQ said in their media release about a minimum bet introduction that it is legislative hurdles that are stopping its introduction. If this is the case I want to see evidence that have consulted with Minister Grace about introducing a minimum bet limit and she has told them that they can’t. But there won’t be any evidence of that because if Dr. Forbes did approach the Queensland Govt. about introducing a min bet limit they would have said we’ll legislate anything you think is the right move, just like what happened in NSW and Victoria.

I think we should all keep campaigning for a minimum bet limit in Queensland for another year because Queensland racing is too exciting and means too much to all of us to be shut out of just yet. But if in a year RQ still won’t act ethically instead of financially and give the punter a fair go in the market place, we should all give up on Queensland racing and bet on racing in NSW and Victoria – at least there we are wanted and respected.

Response from Minister Tudge

Just wanted to update those that didn’t see through social media that Minister Tudge took the time to reply to my email(s). I’m trying to organise a meeting with Minister Tudge and hopefully Minister Xenophon to represent all punters in Australia with regards to minimum bet laws in sport.

If you would like to stay in touch with how things progress, please follow me on Twitter @lukeamac. Your support is not only appreciated, but required. Thanks and stay tuned for further updates.

Kind Regards,

Luke MacDonald


Kingsley Bartholomew’s responses to RVL minimum bet survey

6. Please provide your feedback on a potential MBL for all WSPs internet and telephone betting (any one Win, Win/Place or Each-way bet to lose $1,000; any one Place bet to lose $500)

I believe these limits are too low for Metropolitan racing. On course rails bookmakers are currently required to bet to win $5000 on Saturdays and $3000 on Wednesdays. The current limits are the lowest since I entered the industry in 1993. How can the racing industry expect to attract both continued and new professional investment from punters/syndicates with such low turnover limits being introduced ? WSP’s should be required to match the $3000 limit that is being proposed for on course bookmakers for all Metropolitan racing

7. Please provide your feedback on a potential MBL for Victorian Bookmakers (on-course face to face) – Metropolitan Rails (any one Win, Win/Place or Each-way bet to lose $3,000; any one Place bet to lose $1,500)

With the diminishing number of oncourse bookmakers and turnover I see the $3000 limit being the right balance. I personally would like it to remain higher but can understand the need to drop back to $3000 for Saturday racing, however a $5000 limit still should apply for carnival racing.

8. Please provide your feedback on a potential MBL for Victorian Bookmakers (on-course face to face) – Other metropolitan areas and all areas at country meetings (any one Win, Win/Place or Each-way bet to lose $1,000; any one Place bet to lose $500)

Agree with a $1000 limit

Probable exclusions:

9. Exclusion – Multi’s where the bet is not exclusively constituted on VTR product


10. Exclusion – All bets where both parties to a betting transaction are either WSPs, On-course Bookmakers or a combination of both

Disagree. Both WSP’s and on course bookmakers should have enough confidence in the prices that they display to take bets from all parties, whether it be a punter or fellow bookmaker. The whole idea of excluding anyone wishing to wager makes the marketplace inactive, dull and boring which leads to a higher percentage by bookmakers, decreased turnover and an increased lack of interest by professional punters. Bookmakers betting back with one another creates a surprising amount of market stimulation and turnover. The art and skill of trading by WSP’s has been very sadly lost in the modern day marketplace. I would love today’s risk managers to sit down with legendary bookmakers like Mark Read or Dominic Beirne. These two men were not only fearless in the betting ring but understood the need to trade money in order to profit. They lived and died by their own opinion. Racing jurisdictions make it far too easy nowadays for WSP’s to hide behind a call centre in Darwin treating Racing’s customers as they like.

11. Exclusion – Punters betting on credit

Disagree. Just an excuse for bookmakers not to bet. No one is forcing them to extend credit to a client if they don’t want to.

12. Exclusion – Exchange bets


13. Exclusion – Retail cash betting

Disagree. TABCORP will hide behind this rule to continue the shameful act of reducing limits on fixed odds betting to virtually $0 in agencies where they feel a professional punter is betting. This is a blight on the industry and should not be allowed. TABCORP should be working to put better systems in place to ensure their risk limits are managed more appropriately.

14. Excluded customer – Punters who act as commission agents

Disagree. WSP’s will hide behind this rule. Once again bookmakers should have the confidence to accept bets from all parties. It is very hard to prove who is a commission agent and who is not. Who makes the final decision ?

15. Excluded customer – Customers who have established accounts who have not yet completed the identification and verification requirements

Agree, as long as the ID and verification requirements are reasonable. William Hill for example require tax returns, bank statements, phone records etc. This is a complete invasion of privacy and obviously just another way a WSP is trying to get around doing what their core business is – BETTING.

16. Excluded customer – Customers whose accounts have previously been closed by WSPs for integrity concerns/regulatory issues etc.

Agree, as long as it is legitimate.

17. Commencement of MBL – on the day of the relevant race commencing 30 minutes prior to the Advertised Start Time (AST) for each particular race

Disagree. Completely inadequate and to be honest makes me embarrassed to be part of the industry in Australia. What gives the WSP’s the right to be able to frame their markets days in advance of a race and then have no obligation to have to accept a bet ? As punters you are asking us to invest our time and money in to creating POSSIBLE money making strategies so we can turn money over, yet you want us to wait 30 mins before a race before we can invest. Nobody is making the WSP’s frame a market prior to 30 mins out from the race. This is their choice. WSP’s are framing their markets days in advance, rejecting bets from punters who they deem to be smart and adjusting their markets accordingly. 30 mins out from a race, when the on course bookmakers frame their opening market, the prices have already been set for them in essence by the ‘smart’ punters who couldn’t get the set for a decent amount of money. As I said before, no one is forcing WSP’s to put their prices up prior to the 30 min mark and to be honest I think the marketplace would be better off if they didn’t.

18. Cessation of MBL – 2 minutes prior to the AST for each particular race

Disagree. This is even more embarrassing than the 30 min rule. If a WSP is too afraid to lay a horse to lose $1000 in the last 2 mins of betting then they should hand in their licence straight away. No serious professional money will exist in the fixed odds market place in the years to come if these petty rules are introduced. Open the marketplace up and let everyone bet.

19. Number of MBL transactions with each eligible customer limited to one betting transaction per runner in each race

Disagree. Why shouldn’t I be able to back them same horse twice at a different price. If I take $5 a horse the WSP can turn it in to $1.01 if they choose to. Another petty restriction that protects bookmakers. It should be the bookmakers responsibility to mange their risk limits efficiently

20. Complaints and enforcement process – online submission to RV inclusive of a declaration that the complaint does not relate to one of the exemptions

My personal experience with Racing NSW’s MBL has been very positive. William Hill and Classicbet are the only two corporates that I am still not able to trade with on NSW racing.

21. Racing Victoria invites respondents to provide comments on the issues raised in the MBL consultation paper

In my opinion the WSP’s have had too much influence on the proposed limits and restrictions in RV’s MBL. If RV are serious about protecting punters serious changes need to be made to the proposed MBL. ‘Closed’ on course betting rings (there were only 6 on course rails bookmakers at Caulfield on Saturday), higher bookmaker percentage due to RV’s taxation policy, decreasing pari-mutual pools and the current practices of many of the WSP’s make professional punting in Australia an extremely unattractive option. Very few punting organisations have an on course presence anymore and the major syndicates are completely disillusioned with the lack of volume in the tote pools in Australia as TABCORP continue to focus on their extremely profitable fixed odds products. I applaud RV for announcing the introduction of a MBL, but if you do not put THE PUNTER, racing’s number one funder first, then you may as well not introduce it at all.

Richard Irvine’s response to RVL minimum bet survey

6. Please provide your feedback on a potential MBL for all WSPs internet and telephone betting (any one Win, Win/Place or Each-way bet to lose $1,000; any one Place bet to lose $500):   $1,000 on non-metro meeting seems fair but all bookmakers with turnover over $5 million a year should have to lay horses to lose $2,000 on metro racing. The bookmakers with $5 million plus turnover all have large holds – some massive, they can easily handle 2k metro limits.

7. Please provide your feedback on a potential MBL for Victorian Bookmakers (on-course face to face) – Metropolitan Rails (any one Win, Win/Place or Each-way bet to lose $3,000; any one Place bet to lose $1,500):   Considering that the on-course ring is sadly shrinking rapidly I feel that this is fair enough and gives on-course bookies a better opportunity to manage their books.

8. Please provide your feedback on a potential MBL for Victorian Bookmakers (on-course face to face) – Other metropolitan areas and all areas at country meetings (any one Win, Win/Place or Each-way bet to lose $1,000; any one Place bet to lose $500):   Considering that the on-course ring is sadly shrinking rapidly I feel that this is fair enough and gives on-course bookies a better opportunity to manage their books.

Probable exclusions:

9. Exclusion – Multi’s where the bet is not exclusively constituted on VTR product:    Yes.

10. Exclusion – All bets where both parties to a betting transaction are either WSPs, On-course Bookmakers or a combination of both:    No. Bookmakers should be allowed to bet with each other. The one bet per horse at the price rule will solve the problem of bookies following other punters. Corporate bookies have been betting with on course bookies for years so there is no need to change the dynamic.  

11. Exclusion – Punters betting on credit:    This should be left open to the discretion of the bookmaker. But if they do not wish to offer credit to a punter then yes, the punter must be in credit in their account.

12. Exclusion – Exchange bets:    Yes.

13. Exclusion – Retail cash betting:    Yes.

14. Excluded customer – Punters who act as commission agents:    No. Far too grey area and allows bookmakers to avoid MBL by claiming someone is a commission agent.

15. Excluded customer – Customers who have established accounts who have not yet completed the identification and verification requirements:    No. Bookmakers will use this to get around MBL. What rules they have around betting before identification and verification requirements should be the same for all punters.

16. Excluded customer – Customers whose accounts have previously been closed by WSPs for integrity concerns/regulatory issues etc.:    Yes, but RVL must investigate these situations and find real evidence of integrity concerns. It’s another grey area where bookmakers will abuse the rule to avoid MBL.

17. Commencement of MBL – on the day of the relevant race commencing 30 minutes prior to the Advertised Start Time (AST) for each particular race:    NO! This would be a diabolical result for punters as we would miss out on so much value as the market moves while we’re banned from it. It goes completely against the RNSW rules (which you quote as the benchmark) of 9am on race day and 2pm on night meetings – this rule has worked well and even though it still disadvantages punters we have accepted it. Under the RNSW rule bookmakers still have the advantage of seeing how the market moves in previous days (many bookmakers have prices up 1,2 or 3 days before a race) before they are obliged to bet punters from 9am. This price discovery that bookmakers have is a real disadvantage to punters but we accept that we will always be disadvantaged – but this rule you put forward is insulting and would instantly end all the good will that was created when you announced your MBL plan. The fury that has been directed towards you and corporate bookmakers for over 5 years now would continue and we would reject entirely that you have listened to your customers and introduced a MBL.

Online bookmakers are highly sophisticated these days and the majority are linked up to Dynamic Race Odds or other odds comparison sites and instantly firm horses when they firm with another bookie. They can handle their liabilities with ease – they must bet all punters from 9 am up until jump time.

18. Cessation of MBL – 2 minutes prior to the AST for each particular race:    NO! Just as bad as the proposed rule above. The market moves the most in the last 2 minutes. Betfair kicks in and bookies start to push horses they are keen to lay. A horse that might be $2.50 with bookmakers with 2 mins to go can easily drift out to $3.50 with bookies in the 2 mins to jump time. Locking out some punters during this time is deeply unfair. Bookmakers only have to bet one person at the price they display which protects them from getting too large a liability. Any bookie that tells you otherwise is lying to suit their own lazy bookmaking.

19. Number of MBL transactions with each eligible customer limited to one betting transaction per runner in each race:    Yes. This is unfair to punters as a bookmaker who puts a price up should be willing to lay it to anyone – however, considering that we have to cede some ground we can accept this rule.

20. Complaints and enforcement process – online submission to RV inclusive of a declaration that the complaint does not relate to one of the exemptions:   Yes, however Tom Waterhouse as CEO of William Hill has been dishonest and evasive in his obsession with disobeying RNSW min bet law. His latest move is to deceptively claim that he suspects punters that he doesn’t want betting with him are terrorists or or organised crime figures and he has to report their financial activities to Austrac. He demands 3 years worth of incredibly detailed financial records off punters. No punter should have to give him that and many punters don’t even have the records he requires so have no hope of meeting them. Please be ready for him and his legal team as the do everything to avoid your authority. ClassicBet have also seemed to follow his lead.

21. Racing Victoria invites respondents to provide comments on the issues raised in the MBL consultation paper:    Victorian racing is the best gambling market in the world. We as punters are desperate to stay involved. At the least you must follow RNSW min bet laws – they are working very well for both punters and bookies. What you have proposed here is a watered down version. We deserve, and with respect, demand better. The bookies already have so much advantage. Many thanks for introducing a min bet limit and your consultative approach.

Betting in NRL – Open letter to Mr Todd Greenberg

Dear Mr Todd Greenberg,

As CEO of the NRL are you aware that many corporate bookmakers (some of which are your commercial partners) close or restrict accounts of winning gamblers/ gamblers who do not lose enough? I’m of the belief that the most important stakeholder in your game is the supporting public, a considerable amount of your supporters would place a bet on your sport throughout the season. Protection of your supporters when they have a wager on your sport would be very high on your agenda I’m sure.

A ‘gamble’ is defined as ‘to stake or risk money, or anything of value, on the outcome of something involving chance’. The problem we have when wagering on your sport is there is no chance element, if you win (amounts of bets and time vary), your account can be immediately limited or closed. There is only one side of the coin you can be on long term and that’s the losing side. This issue is the basis for many involving wagering in your sport; lack of clarity around identities gambling, offshore gambling, untraceable bets, match/ spot fixing and huge exploitation of problem gamblers by bookmakers here in Australia.

Clearly with this in mind, the NRL could not condone this behaviour, the question is, what will the NRL do about this issue?

Please see the accompanying letter that I sent to Social Services Minister Alan Trudge.

Of the two options contained, which would the NRL support?

Gambling on sport is a big community issue now and the NRL must take corporate bookmakers conduct seriously. I look forward to your response.

Many thanks,

Luke MacDonald

Sports betting – Open letter to Alan Tudge MP

Hi Mr Alan Tudge,

My name is Luke MacDonald from the Gold Coast. 5 years or so ago I was enticed into gambling on Australian sport by all the advertising that accompanied it.

Since then I have learned that the online sports gambling industry in Australia is for the most part a fraud and the majority of Australian bookmakers do not allow bettors the opportunity to win money. Everyone rightfully assumes a bookmaker is supposed to offer people the chance to win money.

I was heartened to hear that you and your Government accepted the recommendation of Barry O’Farrell’s recent review into online gambling to look into account closures and restrictions.

Your Government needs to decide if online sports gambling is a financial market place, or simply a business where bookmakers offer punters a service or product.

If you decide it is a financial market you need to introduce a nationwide minimum bet policy akin to what Racing NSW and Racing Victoria have done with their racing product in the jurisdictions they oversee. Financial markets in Australia are regulated to be fair to both sides of the transaction, and hence the same must apply to online sports gambling markets. Presently sports bettors have no rights and are treated appallingly. It should be noted that all on course gambling rings in Australia have always carried minimum bet obligations.

If you decide that bookmakers are simply carrying on a business – and deserve the same protections all businesses get under the Competition and Consumer Act – you must make online bookmakers (who employ client management techniques to ban or restrict winning gamblers/ gamblers who do not lose enough) warn their clients of what they face when betting with them. These bookmakers do not offer their clientele the chance to win money, it is imperative that anyone who signs up to these sites understands this.

The warning needs to be in plain black and white English, not buried in a whole lot of terms and conditions and state the following; “we will close or restrict your account if you win or don’t lose enough”. If account holders see this, acknowledge they understand the situation and are happy to keep betting, then that’s fine. But what cannot happen is online bookmakers taking over our sporting culture, while seeking to exploit losing gamblers and banning anyone who wins. Our community doesn’t need another poker machine industry.

Which of the options will you and your Government take?

Many thanks,

Luke MacDonald

Letter to Racing CEOs regarding min bet intro

Dear Sam,

You will have seen that Racing Victoria have followed Racing NSW and announced the introduction of a minimum bet law from October 1.

It can be seen as the turning point for the industry and punters; that a fair, equitable and socially responsible market is what the industry wants and deserves.

Now would be the perfect time for you as CEO to liaise with your board and begin the process of introducing a minimum bet law on racing in your state. It will have a profound longterm impact on your turnover, especially as punters who have been finding it hard to get their bets on gravitate to NSW and Victoria where they know their hard work will be rewarded.

By introducing a minimum bet law you will only be upholding on course bookmaker betting obligations which your state has had for all of time.

Do you plan to introduce a minimum bet law?

I, and all punters in Australia look forward to your response.

Many thanks,

Richard Irvine

Yearly Open Letter to Bernard Saundry

Hi Bernard,

Because the ethical argument was not strong enough for you to bring in a minimum-bet limit for corporate bookmakers last year, I will set them aside and give you the regulatory and marketplace conditions that support Racing Victoria implementing a minimum bet limit when you evaluate your Race Fields Legislation mid-way through this year.

State Govt. support

Last May you said “We agree with the notion that legitimate punters should be able to bet to win a minimum amount on Victorian races, however, there remain legal impediments and operational challenges for us to achieve this exclusively via a minimum bet condition within our Race Fields Policy.”

So I wrote to Racing Minister Pakula and presented him with your words. Minister Pakula responded with “RV is responsible for setting appropriate conditions for WSP’s operating on Victorian thoroughbred racing. If RV were to make similar changes as NSW to its Race Fields Policy, I would consider any request to underpin such a regime with legislation”.

Minister Pakula finished with “I expect RV to continue to monitor the impact of the changes in New South Wales and make any necessary changes to its Race Fields Policy to ensure there is a competitive balance between punters and bookmakers”.

If you genuinely do believe punters should be able to have a chance to win when punting on Victorian racing, then the minister has set proper framework for you to pursue it. It’s obvious he will back you up with the full force of the Govt. if you implement a minimum-bet law. Since you placed min-bet in the too hard basket last year we have seen nothing from you in terms of working with the State Govt. towards a resolution for punters. If you try and fail with State Govt. support we can accept that – but you doing nothing we can’t. Legal impediments and procedures are no longer an excuse to not introducing a min-bet law.

Wider Industry Support

All major corporate bookmakers in Australia; Sportsbet, TabCorp, Ubet, Ladbrokes, UniBet, Bet365, Topsport and Crownbet, along with all minor corporates have respected and adhered to RNSW’s introduction of a minimum bet law some 18 months ago. The only major corporate not to is the unconscionable William Hill – and that is partly due to Waterhouse arrogance, and partly due to the current taxation system.

Your three major corporate bookmaker partners; CrownBet, Sportsbet and TabCorp, already bet all legitimate punters to win at least $1,000 on all Victorian racing.

Your joint venture partner TabCorp COO Craig Nugent, commented on RSN Radio when asked about winning punters “We want all customers. We want to give sophisticated gamblers the very best of content, the very best of information. There is a problem currently in the sophisticated market and we think there needs to be a solution”.

Both the Australian Bookmakers Association and the Victorian Bookmakers Association fully support you introducing a minimum bet law.

I contacted Racing Australia and asked them their thoughts on min-bet laws. They responded with  “We believe a minimum bet law to be a credible solution for bookmakers and punters on the issue of corporate bookmaker obligations and account restrictions.”


The only opposition has come from the 100% foreign interests of the Australian Wagering Council (AWC). The best reason against introducing a minimum-bet law they can come up with is that winning punters take the best odds which disadvantages losing punters who receive worse odds. A deeply embarrassing notion. And deeply insulting to the intellect of all Australian punters.

This notion is so obviously against Racing Victoria ideals. It would be akin to you telling Damien Oliver to ride with an extra 3kg in races to bring him back to the field.

Of course, anyone who understands fixed-odds market dynamics realise that when a winning punter backs a horse, that horse does firm, but that pushes the price of other horses out creating better value for the losing punters that the AWC is so worried about. This dynamic is paramount to driving turnover.

Further, the conditions of RNSW min-bet laws only allow winning punters access to markets from 9am on race day. Fixed odds markets have usually been up for 24 hours prior to that with all corporates – plenty of time for unrestricted punters to have unfettered access to all odds. RNSW min-bet conditions are very favourable to bookmakers. We would accept the same set of conditions from you.

You give bookmakers a licence to lay every runner and take a margin for themselves. The AWC believe that modern bookmakers should find losing gamblers and take their money. You have a responsibility to the community to not allow them to change the narrative of what modern bookmakers are licensed to do.


I support your current tax structure. It is the most expensive fixed-odds tax punters and bookmakers have ever faced – but it is justified in the face of the massive migration from tote to fixed odds. Racing’s funding must be secure during this migration.

William Hill claim that they can’t bet winning punters because of the impost of your current tax structure. But William Hill are welcome to, and should, pass on the 1.5% – 3% turnover tax you placed on them onto the punter via their fixed-odds markets. We can handle that. If it means we win a little less, or lose a little more each year, so be it. Racing’s funding must always come first.

Your turnover tax doesn’t really suit corporates betting best tote. But best tote doesn’t suit racing’s funding and it also is irrelevant in the min-bet argument as it doesn’t include best tote betting. I think William Hill are failing to separate the two.

William Hill’s problem is not turnover tax, rather that they paid way too much to gain access to the Australian market.

William Hill’s 2015 results were very interesting. They “implemented client management and trading changes to address unprofitable turnover following race field fee increases.” And were hammered with 20% drop in turnover and 41% drop in net profit. A terrible result for William Hill and a bad result for Racing Victoria. Sportsbet, who have embraced a fair market place had polar opposite results; revenue up 46%, profit up 78%. Unequivocal evidence that you need an unrestricted marketplace.

I do feel that charging bookies turnover or gross-profit tax on a per meeting basis is very unfair and does nothing to encourage turnover and needs to be addressed. The mechanics of it are simply too hard for bookmakers to manage.

Your Best Customers

Winning punters are your best customers. Whether it’s Race 1 at 10am on a heat affected day at Echuca, or Race 10 on a bitterly cold autumn night at Cranbourne, we’re there turning over money for you – trying our best to back a winner. Yet, it feels we get no support from you.

If you introduce minimum bet laws, the short term financial implications for the industry will be negligible – but long term it will have a massive impact. Because this generation and the next generation of winning punters (your best customers) won’t be extinct and the legacy of the punter bookmaker contest that is such an important part of Victorian racing’s history will be intact.

The chorus of disenchanted punters has doubled in the last year and will continue to multiply until you act.


Richard Irvine