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Consultation response

Summer 2023 consultation – Proposed changes to LCCP and RTS: Consultation Response

This response sets out our position in relation to the consultation on the proposed changes to LCCP and Remote Gambling and Software Technical Standards.

Introduction - Financial vulnerability and financial risk

The response for this topic provides a summary of the key inputs to our decision making on both financial vulnerability checks and financial risk assessments. During this programme of work, we continued engagement with government, Parliament, other domestic and international regulators, the financial sector, industry and bodies and individuals with an interest in gambling.

A summary of the responses to the 2023 consultation on the topic of financial vulnerability and financial risk

We received close to 2000 written responses to the 2023 consultation on this topic. The majority of respondents were members of the public, with large numbers of them stating that they are gambling consumers responding as individuals and that their gambling would meet one of the thresholds for financial vulnerability checks or financial risk assessments.

A summary of the responses to the 2020 to 2021 consultation and call for evidence exercise

This part of our response covers responses to the 2020 to 2021 exercise on the topic of financial risk checks. The other proposals from that consultation and call for evidence exercise were covered in our earlier response to the 2020 to 2021 consultation, which introduced new remote customer interaction requirements, whilst the financial risk content was earlier covered by our update on our next steps following the 2020 to 2021 consultation and call for evidence exercise.

A summary of new research, data and evidence

Consumer research

During the consultation period, we sought views of consumers on the specific policy proposals from our 2023 consultation through both the consultation exercise and through our consumer research.

This research is part of our Consumer Voice programme, where we use a mix of quantitative and qualitative methods to gather views, opinions, and insights from gambling consumers. This Consumer Voice work complements our nationally representative statistics on gambling participation and the prevalence of problem gambling but goes into more depth on key issues and emerging areas of interest. As part of this Consumer Voice work, we considered it important to progress consumer research to augment the consumer perspectives in the consultation. This brought in additional perspectives from the consumer in response to the proposals and allowed more in-depth exploration of the issues with a range of consumers. Alongside this response, we published the consumer research which we commissioned.

Updated YouGov data on discretionary income

The 2020 to 2021 consultation and call for evidence on remote customer interaction included information about average discretionary income from YouGov. This indicated the average levels of discretionary income per calendar month of different age groups as at January 2020. In each age group, there are individuals who have very limited discretionary income. In this response, we provide updated information about average discretionary income as at February 2024, which we have obtained from YouGov.

Open banking data modelling

Open banking protocols enable individuals’ financial data to be shared between banks and third-party service providers.

In 2023 the Gambling Commission purchased a sample of open banking data from YouGov Finance. This dataset includes the details of banking transactions from 4,000 individuals in Great Britain, each of whom have given their consent for their data to be used for research. It comprises over 12 million individual transactions, of which 253,916 are non-lottery gambling transactions, by 2,034 unique gamblers. At least one year of transactions is available for each gambler, with an average of 966 days and a standard deviation of 222 days. The data spans the period up to August 2023.

This publication sets out the results of an analysis of open banking data. A data modelling approach was taken to consider the proportion of individuals whose rate of gambling spend exceeded certain thresholds. We consider the overlap between the groups of individuals exceeding the different thresholds, as well as whether the thresholds are still reached when considering spend at each gambling operator separately compared to overall gambling spend.

Alongside this response, we published a technical report on the open banking data-modelling exercise.

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