Via Medemi (109 comments on their thread, and still growing), BetFair (PDF file):
3 August 2007
Integrity in Sports Betting Issues Paper Consultation Co-ordinator Gambling Commission Victoria Square House Victoria Square Birmingham B2 4BP
INTEGRITY IN SPORTS BETTING ISSUES PAPER – BETFAIR RESPONSE
I am writing on behalf of Betfair in response to the Commission’s “Issues” paper of May 2007 but have restricted this response to those questions in the paper on which Betfair has a strong view. The questions from the Commission’s paper are reproduced below in italics, followed by the Betfair response.
• What evidence is there of the incidents giving rise to concern about the integrity of sports betting in Great Britain?
• Are additional measures necessary and appropriate to uphold integrity in sports betting in Great Britain and if yes what are they?
• What is the detailed breakdown of their cost?
The evidence suggests that incidents giving rise to concern about the integrity of sports betting in Great Britain are few and far between. This is perhaps contrary to the perception created by the media and skewed somewhat by the ‘purge’ that is taking place in British horseracing.
Betfair believes that the internal measures it has in place, together with its formal agreements with sporting regulators are necessary but sufficient to uphold the integrity of betting through the Betfair exchange. The cost of ‘policing’ a sport is not something Betfair is able to comment on, but by way of comparison, Betfair’s integrity department (which covers all sport globally) is 7 strong with an annual budget of around ?250,000.
• Should each type of bet in each sport be risk-assessed? If so, by whom?
• Do you consider some types of betting to present a greater risk of the integrity of sport than others?
• If you consider some types of bets to be riskier than others, should further measures be taken to regulate them?
• Should the Commission require the gambling industry to offer only certain categories of betting opporunities?
A risk assessment of each bet type is something which any betting operator would carry out as a matter of course. A betting exchange is reliant on the confidence of its customers that the markets it offers are fair, so will not want to offer a market which is perceived as open to corruption.
Some types of bet do present a greater risk to the integrity of a sport and they are generally those bets that occur within a sporting event as opposed to the outcome of the event itself.
In these cases it is perhaps the performance of one player that could be influenced for commercial gain. However, the vast majority of these types of bet have historically been offered by the spread betting firms (‘player performance’ indices most obviously) who will not be regulated by the Commission.
It is Betfair’s stance not to offer markets which pose integrity and/or perception concerns for sporting regulators. What might constitute such a market can be established through consultation with the sports and historically Betfair has taken the decision not to offer certain markets after such consultation. Betfair would always advocate a voluntary code of conduct between betting operators and sports governing bodies in this matter.
Restrictions imposed on betting operators in this area by the Commission (or any veto given to the sporting regulators) would obviously put UK licensed operators at a competitive disadvantage against operators not licensed by the Commission. In addition such restrictions would be undermined by the fact that they would not apply to spread betting firms and nor would they apply to betting operators in other EEA States who (pursuant to s.331 of the Act) would be allowed to advertise a betting market into the UK that a UK operator was not allowed to offer.
• Would integrity in sports betting be improved if there was a single source of results for each UK sport and if so, how do you suggest this might operate?
In short, no. The final result of any event is almost always taken from the governing body. The collection, presentation and distribution of sports results is an entire industry in itself. The speed with which results are available has to be balanced by accuracy and Betfair considers the data providers in place now, to be more than adequate. In Betfair’s experience customers do not have concerns with the sources used to settle markets providing the details of those sources are clearly stated within the operator’s rules.
Please let me know if you have any questions or require further clarity in relation to any of the above.
David O’Reilly Legal Counsel
The UK’-s Gambling Commission is keeping this issue under review. (PDF file)
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