Affordability – more than just a numbers game?
Is it just me or are the conversations and debate about affordability issues in the gambling and gaming sector focusing too much on trying to determine a definitive answer to the level of discretionary income and how much of that players should be ‘allowed’ to spend? Isn’t it time to also re-introd
uce some of those markers of financial harm e.g. increasing levels of debts, to the debate?
Having been involved professionally with assessing people’s finances for over 30 years I can confidently say that limiting the approach to assessing defined amounts will be a nightmare for policy makers, operators and customers. About twenty or so years ago I was involved with a project looking at simplifying the means test for government funded legal aid in the UK (bear with me!). At the time this involved some cutting-edge research around ‘gross income’ limits, removing ‘discretionary’ spend from the equation, and what to do about those with more complex finances such as the self-employed and company directors.
What did we learn from that?
Well firstly these tools are a blunt instrument, the myriad of different financial circumstances within the population means that for some the strive for simplicity will also mean inequity. Even determining what you mean by ‘income’ can be debated when we look at the self-employed etc. Those people who are asset rich but cash (income) poor (generally many elderly/retired) will also need to be considered. The issue of people using capital (i.e. savings or worse their pension pot) to gamble has to my knowledge never been included in debates (or guidance) about affordability.
Even if policy makers can agree on what such a ‘financial means assessment’ should look like for the gambling sector, next comes the vexed issue of how operators can implement this and the ‘holy grail’ of a single customer view (I think this will have to be a whole different blog!).
So with such difficulties over ‘assessing financial means’ surely we should also be making sure that some of the ‘markers of financial harm’ are also an essential element of affordability. In my view, not only do they provide much better definitive (albeit lagging) indicators that someone is gambling beyond their means, but crucially much of this information can be more easily obtained without the need for intrusive questioning, endless requests for information and time-sapping decision making by operators. They may not even turn out to be as ‘lagging’ as we first fear given how long some of the decisions on affordability can take!
I realise that in putting forward these arguments I may have to revise the content of one of our most popular training courses for operators but hey ho! It would be good to get other views on this.
Thanks Neil
Our next ‘Assessing Complex Customer Finances for affordability and source of wealth’ course for operators starts on 4th April.
