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