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.
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.