Problem Gambling - ATM/EFTPOS functions and capabilities (in gambling venues) 

• 8.1.1 ATM/EFTPOS functionality
• 8.1.2 Consultation with the financial services sector
• 8.1.3 Future ATM and EFTPOS functions
• 8.2 Emerging Themes
• 8.3 Summary

The following diagram highlights the relationship of the financial services sector to the ATM/EFTPOS device and the gambler.

8.1.1 ATM/EFTPOS functionality

The first area of interest examined was the current functions of ATMs and EFTPOS within Australia and internationally.

The research focused on identifying the functionality of both bank and non-bank ATMs including accessibility to various product facilities. A complete report on this area of research can be found at Appendix D. From this research a series of issues were identified.

• Accessibility of accounts is increasing - The rise of off-premise payment devices has led to increased account accessibility for account holders. Off-premise payment devices include bank and non-bank ATMs, EFTPOS terminals, and evolving payment channels, such as mobile telephony.
  
  Both the number of bank and non-bank ATMs and EFTPOS in Australia have strongly increased over recent years.
  
  Bank ATMs tend to be located at bank branches, retail areas and other high consumer traffic areas. Non-bank ATMs are focussed on areas with high consumer traffic where convenient access to funds is desired. Recently, there has been growing numbers of ATM placements in grocery stores, petrol stations, and smaller merchant stores.
  
  ATMs are available in a variety of sizes, with differing functionality to suit various environments and purposes. For example, ATMs at bank branches tend to be larger with extensive financial transaction functionality; where as ATMs in merchant stores tend to be small to accommodate limited space.
  
  In the United States, ATMs have been designed specifically for the gambling environment. They have developed numerous ATMs that deliver fast and ready access to accounts. These include ATMs that are built onto the individual gambling machine, and ATMs that offer PIN-less credit card cash advances.
  
• Use of payment devices is increasing - Account holders are accessing their accounts more frequently, and withdrawing greater amounts. This holds true for both credit card accounts and debit card accounts. This may be due to increased availability of the payment channel by merchants, increased convenience, and promotion of the channel by the merchant (eg the ability to purchase vending machine soft-drinks via mobile telephony could be promoted by the vendor).
  
• Devices in the market currently have limited one-to-one marketing capabilities - To provide one-to-one marketing based on the accountholders account details and transaction behaviour; the payment device must be integrated with bank information systems. The most common form of ATM in the market is PC-based, which is not designed to be integrated into bank systems. The newer ATMs are web-enabled and are designed for this purpose.
  
  There are a number of factors that suggest the use of one-to-one marketing functionality in the Australian market will be limited in the near future:
• although increasing, the current spread of web-enabled ATMs is low;
• the integration with bank systems to gain the one-to-one marketing functionality is likely to require extensive resources; and
• the growing number of non-bank ATMs may not have access to the necessary bank systems.
  
• Smart cards provide opportunities for one-to-one marketing, account control, and payment convenience, but are limited in their market spread - Smart card transactions are classed as contact or contactless. Contact smart cards require insertion into a smart card reader and tend to be favoured by financial institutions dealing with high value transactions. Alternatively, contactless cards simply require a close proximity to smart card readers. This is more typical for uses that require a fast card interface, such as mass transit. In this case, payments can be made without the card even leaving the person’s pocket.
  
  The amount of data and applications that can be stored on a smart card varies, generally from 32K to 128K. Cards of this capacity are able to store multiple applications on the one card. The applications can be loaded prior to issuance by the vendor, and post-issuance by others through ATMs, the Internet and other devices.
  
  To date, smart cards have been implemented for a wide range of purposes, including by governments for benefit access, by vendors and merchants as part of loyalty programs, and in transport and parking environments.
  
  Although smart cards offer opportunities for applications that may provide one-to-one marketing and account control, the dispersion of smart cards in the Australian market is still quite low, as is the spread of EFTPOS and ATMs that can accept them. However, this is likely to increase given the heavy push by vendors, and the declining cost of administration that smart cards offer.

• Credit Facilities (Mortgage Backed Personal Lines)- Banks and other financial institutions increasingly offer customers accounts that support the combined product features of more traditional transactional and lending facilities e.g. mortgage accounts that provide customers with transactional facilities including credit cards. Lenders also provide customers with the opportunity to access established credit lines e.g. capability to withdraw funds from a mortgage account.
  
  The purpose of these relatively new products is to provide customers with the flexibility and opportunity to pay-off mortgage debt early whilst still retaining access to basic transactional services. The emphasis is very much on customer convenience. Providers put in place parameters to control access to the facilities offered within these packages. These measures ensure that proper credit management is exercised so enabling the customer to make most use of the in-built product flexibility but also ensuring that the institution maintains its position as a responsible lender.
  
  Given the context of problem gambling, the ability to control customer access to account facilities e.g. credit card usage, re-draw can be viewed at two levels. Firstly, customers are already subject to daily transactional limits. It then becomes a question of whether those limits are satisfactory for gambling environments and how they can be monitored and enforced. Secondly, should those facilities e.g. re-draw be made available to customers for the purpose of gambling. As already indicated the purpose of such a feature is to provide customers with ‘ready access’ to ‘pre-approved’ credit, once the credit facility is in place institutions may argue that it is not appropriate to tell customers how to spend their money. Equally, monitoring expenditure would prove problematic given that no measures are in place to perform those activities.
  
  The main issue surrounding re-draws and other mortgage backed credit facilities is the potential size of the credit line available to customers. However, access to these facilities can be and are controlled in very much the same way as more traditional transactional and credit products. The issue remains that the necessary control mechanisms for problem gamblers are not in place e.g. the capacity of the system to determine whether a customer is accessing mortgage backed credit in a gaming location.

8.1.2 Consultation with the financial services sector

The second phase of research involved consultation with banks, non-banks, governing bodies and terminal manufacturers. Structured interviews confirmed our understanding of the current operating environment and key issues facing the financial services sector.

Where appropriate individual financial services organisations have provided formal responses as part of the research. In general these responses have taken the form of answers to the specific questions that were originally raised as part of this brief. The following represents an overall summary of the response by the financial services sector with appropriate input from other relevant stakeholders.⁴¹

The following key issues were raised through the consultations with the financial services sector:

• Definition of the problem - All financial services sector stakeholders consulted are supportive of government initiatives to minimise the negative social impact of problem gambling on the community. This is entirely consistent with organisations operating as responsible companies within their own respective communities. Indeed, many financial institutions are active sponsors of community-based initiatives and have been for many years. Equally, the financial services sector encourages any attempts to secure consistency of approach across all jurisdictions.
  
  There is widespread debate within the sector as to what actually constitutes problem gambling. Given the lack of a clear definition the financial services sector struggles to envisage what strategies may prove effective or not. Subsequently, it is currently difficult for the financial institutions to envisage what combination of financial services and non-financial services strategies may prove the most successful harm minimisation approaches.
• Effectiveness of legislation - Current state and territory legislation has primarily focused on access to cash within gaming locations through ATM and EFTPOS terminals. Indeed, it is clear that the states and territories continue to look to adopt a range of different options around controlling device access. Whilst supporting the general aims of this legislation the financial services sector is unclear as to how effective these measures have, or will prove to be. The issue of effectiveness is further clouded by the different measures that providers are forced to comply with across the states and territories.
  
  Those consulted agreed in principle that for harm minimisation strategies to be effective all relevant financial services sectors need to be involved e.g. gaming, hotelier, manufacturing and financial services. If all relevant financial services sectors were able to work on agreed definitions of the gaming problem then this would potentially help generate the most effective approaches to reducing the impact of problem gambling. For example, as part of this consultation process a number of potential ideas were put forward to the financial services sector. Some solutions represent a significant capital investment on behalf of the sector e.g. tracking and monitoring of transactions generated from within gaming areas. However, without the wider support of all relevant parties the effectiveness of such a solution may not be able to be realised.
  
  The financial services sector is of the view that the level of investment should reflect the potential expected benefit to the community. Current initiatives to control the value of cash that can be dispensed in gaming locations are relatively low cost to implement. However, the effectiveness of such an approach is yet unproven. The tracking of transactions may potentially represent the most effective solution but is clearly the highest cost to implement. A decision-making framework needs to be developed to determine what strategies represent the most cost-effective solution.
  
• Technology - The advance of technology further complicates the debate on the relative effectiveness of legislation around ATMs and EFTPOS devices. The financial services sector is in general agreement that strategies should be ‘device neutral’.
  
  The current focus of state legislation is around restricting access to cash and/or credit through EFTPOS and ATMs devices in the belief that this will help limit the incidence of problem gambling. However, there is a view in the financial services sector that technology will soon out pace the current legislation and this will potentially make redundant any future similar legislation. Advanced telephone and smart card technology are just two examples of how the current legislative requirements can be circumvented.
  
  For example, it is clear that current technology can support consumers accessing funds through a mobile telephone and then using those funds to purchase an increasing range of good and services. There in no reason why gambling could not take place on an appropriately enabled poker machine or via the Internet as is already the case in the United States. In such situations customers have access to funds without using a traditional device i.e. an ATM or EFTPOS terminal. Consequently, if the government focus remains on the device then new legislation may be required each time a new form of technology is deployed in the market.
  
  If in the long-term, harm minimisation strategies are to prove effective there is an emerging view in the financial services sector that the role of the card issuer needs to be addressed rather than issues of regulation relating to such devices Ultimately it is the card issuer who authorises a cash transaction and not the acquiring party e.g. the organisation not operating the ATM or EFTPOS terminal. If strategies are to prove flexible and responsive to a changing environment then this is likely to be better managed at the issuer and not the acquirer level.
• Customer Impact - As identified through government research problem gamblers constitute a small percentage of gamblers in general and similarly a small percentage of banking customers, although they represent a large percentage of the revenue source. The potential solutions to problem gambling however have implications for the wider consumer population.
  
  The financial services sector identified that solutions that focus on restricting access to cash within gaming areas would have an impact on the customer base. These facilities exist because they satisfy customer demands for convenience of service. It has been identified that ATMs deployed in such retail locations prove a good investment for independent operators. In general, ATM transaction volumes are significantly higher in such sites than the more traditional bank branch locations.
  
  Further, it was identified that the varying of limits between gaming and non-gaming venues may prove equally inconvenient and confusing for customers. Banks indicated that they already make significant investment in communicating to customers about what services are available and to whom. This message becomes potentially harder to communicate if services notably vary by retail outlet type. Casino entertainment complexes are a good example of where different withdrawal limits may be imposed differentially when compared to similar facilities in the general community.
  
  The tracking and monitoring of transactions was identified as having customer implications. This activity is undertaken in a similar form by some banks on credit cards to prevent fraud. However, the general deployment of this technology to track all transactions to categorise usage represents a significant departure from current practice. The banks commented that the use of information to control access to funds might result in significant negative customer reaction. Currently customers are restricted to a daily $1,000 cash withdrawal limit to prevent the impact of fraud. Customers may argue that it is up to them as to how they spend that $1,000 and further restrictions could be seen as being overly intrusive.
  
• Potential impact of harm minimisation strategies - It was not possible through the research for the financial services sector to provide a detailed financial analysis of the various harm minimisation strategies without greater clarity as to the precise nature of the more likely options. However, at a high level the financial services sectors have been able to provide indicative estimates that can serve to illustrate the potential scale of necessary capital investment and the likely commercial ramifications.
  
  Minor system/device changes
  To implement changes at the device level to restrict access to cash was identified as relatively straightforward. The upgrade of equipment could occur quickly and the cost to the operator is seen as relatively small. The implementation of withdrawal limits in South Australia provides a good example of this. However, even this modest change was identified as having caused some of the smaller financial services players and independent operators to review the provision of services to this sector. Through the consultative process a number of the smaller independent financial services sectors questioned the long-term commercial viability of providing EFTPOS facilities in gaming locations if further reforms were passed.
  
  EFTPOS currently provides the retailer with two levels of service; namely, purchases and ‘cash out’. If potential reform was to further limit or vary the amount of a cash withdrawal then the financial services sector saw this as having two potential significant impacts:
• operators will simply withdraw the cash out option on EFTPOS at gaming locations; or
• operators will withdraw from supplying EFTPOS facilities to gaming locations in general or particular types of gaming location.
ATMs at gaming locations do not represent a significant investment for the four main banks however some smaller players and the independent operators are more reliant on revenue generated from such sites. Consequently, any changes would have a differential impact on these players when compared to others. For example, the complete withdrawal of ATMs from gaming locations would not impact the commercial viability of any of the financial institutions. The same can be said for the removal of certain functionality or further restriction on access. Yet for independent operators however they may need to balance the cost of making the necessary changes against the level of profit generated by a particular ATM.

In general, relatively minor changes tend to fall within the remit of the acquiring organisation i.e. the institution that owns/manages the ATM and/or EFTPOS device. As such the necessary investment is relatively small. However, the effectiveness of the solutions is potentially limited. Major changes as proposed in the project briefing questions are very much focused at the issuer i.e. the institution that operates the customers’ account(s). These measures will require significantly more investment but potentially represent the most effective strategies available.

Major System Changes
Discussion occurred with the financial institutions regarding the ability to track and monitor transactions that originate from gaming locations. Initial thinking indicates that new merchant naming standards and messaging formats would be required. Furthermore, host systems would have to be developed to action the content of the messages. The likely initial financial services sector investment (excluding the non bank deployers) associated with any such development work is roughly estimated to be in the order of up to and above $20m.⁴² This was identified as representing a significant capital investment in software development on behalf of the issuing banks. The banks indicated that before any such investment was made they would need to evaluate whether it was still commercially viable to continue to provide ATM and EFTPOS terminals to this market segment.

Removal of ATMs
The main clearing banks have relatively few ATMs deployed at locations that serve gaming environments. As such legislation requiring the relocation of any such ATMs represents minimal impact to these organisations. However, the commercial impact for certain operators e.g. the independents who may have up to 50% or more of their ATMs at such sites was seen to be significant. Equally, some of the smaller regional financial institutions potentially may face a relatively larger impact. In some instances the revenue generated by ATMs located at gaming venues may help off set the financial cost of running the wider network. There are however other opportunities within the market place for these independent operators. This includes the placement of ATMs at chemists, petrol stations, movie theatres, shopping centres and a variety of other locations.

Implementation of Minor Changes
As already indicated it is anticipated that to become compliant with minor changes restricting access would take at least six months e.g. further restrictions on the value of transactions or the removal of functionality. As a sector, costs associated with such a set of changes are roughly estimated to be in the region of $2-$3m.

The main issue identified with such changes is that each state/territory is implementing or considering such change in a piece meal fashion. Such an ad hoc approach has the potential to escalate costs significantly particularly when involving the major banks.

Implementation of Major Changes
The major system changes discussed need to be fully specified before accurate costs can be provided and the likely implementation period. However, at this stage the changes discussed may take between eighteen months and two years to implement at an initial cost to the financial services sector approaching if not exceeding $20m.
• Alternative Approaches - The following alternative approaches to ATM and EFTPOS legislation were discussed with financial services sector stakeholder group.
  
  Focused education programme
  It is understood by the stakeholder group that a number of education programmes already operate to help minimise problem gambling. However, there is the opportunity for more focused campaigns in and around the terminals. For example, it is possible to run educational adverts on the screens of the ATMs. Equally, ATMs are able to dispense information leaflets along with cash. Both ATM and EFTPOS receipts can carry appropriate advertising messages.
  
  Furthermore, the financial services sector felt that a potentially powerful harm minimisation strategy is ‘self-help’. Through this process financial service providers could become involved in the more general harm minimisation strategies. In addition, financial service providers could focus on helping customers with ‘money’ issues e.g. lowering the level of the daily cash limit and potentially withdrawing the customer’s bank card.
  
  Stronger working relationships within the sector
  The financial services sector recognises its community obligations and those specifically associated with the issue of problem gambling. However as already indicated, if harm minimisation strategies are to prove effective in the long-term, greater co-operation is required amongst all parties associated with gaming.
  
  The financial services sector has indicated that it is ready to work with the other industry sectors e.g. gaming and hoteliers, as well as the community sector and government, to help generate practical working solutions to the issue.

8.1.3 Future ATM and EFTPOS functions

This area of research focused on emerging trends and changes to capabilities and functionality in the ATM/EFTPOS financial services sector to limit or change access capabilities. This included an assessment of possible future limitations or changes to access, their technical feasibility and commercial implications. The following issues emerged through the research.

• Removal of terminals (ATM and EFTPOS) - Technically this is a very straightforward option. Terminals can be removed with very limited or no technical changes required. However, the commercial impact for certain operators e.g. the independents who may have up to 50% or more of their ATMs at such sites is very significant. Equally, the smaller regional financial institutions potentially face a similar major commercial impact. In some instances the revenue generated by ATMs located at gaming venues may help offset the financial cost of running the wider network. The potential outcome of such a strategy may well be to reduce the level of competition in the acquiring marketplace as the independent and smaller players are forced to withdraw from some markets altogether.
  
• Removal of functionality at the device level - Technically this is a relatively straightforward solution to implement. Functionality can be turned off at the device. Generally ATM operators remove credit card functionality on machines located in gaming areas. Exceptions may occur if retailers insist on the functionality remaining. Operators can also remove the capability of retailers to dispense cash through EFTPOS terminals. New Australian Prudential Regulation Authority reporting requirements whereby EFTPOS acquirers need to detail purchases and cash advances through terminals, further enables this solution.
  
• Decline transactions at the issuer level (financial service) - There is the option of removing functionality at the card issuer level. If transactions originate from gaming areas the card issuer has the capability to decline the customer request. However, issuers would need to know the nature of the environment in which the ATM/EFTPOS terminal is located i.e. a gaming venue. This solution is potentially attractive as it places all responsibility back on to the institution that manages the customer relationship. Legislation could focus on the financial services sector and not be concerned with current or future independent operators and advances in technology. However, a drawback identified was being able to identify the nature of the transaction.
  
  To identify a transaction as originating from a gaming venue the following system developments were identified as necessary:
• new financial services sector naming categories and sub-categories for gaming locations and different types of gaming location;
• communications between terminals and host systems need to be able to carry the new naming standards;
• host systems and switches need to be able to process the new information contained within the payment; and
• the authorisation system needs to be able to make a decision based on the new information available within the payment message.
  
• Tracking of customer transactions/data - To be able to track and monitor transactions originating from gaming locations the above measures need to be implemented. Technically the financial services sector indicated that this represents a very significant investment from the financial institutions.
  
  To be able to operate a single limit for a single customer is only possible if one centralised switch was established across Australia. In such a scenario all transactions originated by a customer could be monitored from a single data source. Without a central switch it becomes unfeasible to attempt such monitoring unless the customer has already imposed such a limit. Where such limits are not imposed by the customer each bank would need to store the transaction history of all usage captured by other banks.
  
  What is seen as more feasible is a card issuer tracking and monitoring transactions generated by its own customer base. As already indicated this solution still represents a significant investment by the banks. However, there is at least some practical scope for implementation. To achieve this banks would need to be able to monitor account transactions and then aggregate all transactions within one customer view. For example, if a customer holds more than one account with a bank, the institution would need to be able to track all gaming transactions that might occur on any of the relevant accounts to ensure they were viewing the full picture for that individual customer.
  
  To track and monitor gaming transactions on an account basis represents a more straightforward solution. There is no need for the bank to aggregate all activity.
  
• Credit and cash limits - The ability to impose transactions limits based on available credit is reliant on the above system developments being in place. For example, the ability to impose ‘gaming limits’ on ATMs and EFTPOS terminals within single or multiple sites, requires banks to be able to track and monitor cash withdrawal transactions originating in gaming locations. This same level of investment is also required if card issuers need to track and monitor the number of gaming transactions that occur within a specific time period.
  
  Once a process is in place to track and monitor transactions the banks only need apply the gaming limit to customer accounts. As with the daily withdrawal limit, the gaming limit could be a ‘blanket’ limit applied across all accounts.
  
  Legislation is in place across South Australia that limits the value of cash that can be withdrawn in gaming areas. In South Australia the solution was geared around the devices. There was the option to operate the withdrawal limits at the card issuer level. However, this represents a longer implementation period and is potentially more costly. Yet as already stated the implementation of such an approach at the issuer level is more cost-effective in the long-term, and it does require the issuer to recognise that transactions are being originated from a gaming area. Request for cash above the agreed withdrawal limit in these circumstances would simply be declined.
  
  A number of financial services sector stakeholders voiced concern about the commercial viability of EFTPOS devices deployed in certain retail segments if further restrictions are applied to the amount of funds that can be dispensed through an EFTPOS terminal. Many financial institutions voiced a preference for simply removing the cash withdrawal facility altogether in certain types of retail locations.

8.2 Emerging Themes

The issues arising from the three phases of work form a number of common themes. These themes revolve around the ability of the financial services sector and independent operators to effectively respond to Commonwealth and state/territory governments concerns about the negative social impact of problem gambling

• Holistic approach - It is clear that strategies promoted by Commonwealth and state governments need to be co-ordinated. This co-ordination needs to happen at a number of levels as detailed below:
• if legislation is deemed necessary then it needs to be consistent across all states;
• all parties associated with problem gambling need to be held accountable including the financial services, hotelier and gaming industries; and
• ultimately, given stakeholders can only do so much to support and/or assist the situation, final responsibility rests with individual consumer’s behaviour.
  
• Commercial Impact - Clearly different solutions have varying levels of commercial impact and the impact varies according to the commercial nature of the operators business. For example, independent operators are commercially more dependent on terminals located within gaming areas than banks and other financial institutions. Equally, larger banks are better able to absorb any increase in operating costs e.g. terminal upgrades.
  
  At this stage it is unrealistic to expect that operators will provide detailed financial information on the potential commercial impact of various solutions. The Commonwealth government would need to be far more specific about its intentions before operators would invest the necessary time to investigate the likely financial impacts. However, operators have been prepared to discuss at a high level the financial pros and cons of the different approaches as detailed earlier.
  
• Device Neutral Solutions - The financial services sector agreed that legislation particular to device types could at best only have a limited short-term impact. As new gaming and financial services technology emerges governments would be faced with continually needing to adopt new legislation.
  
• Customer Impact
  
  Privacy
  Consumer privacy is protected through legislation. Definitions of consumer privacy extend to cover data generated within payments systems e.g. ATM and EFTPOS transactions. However, if new legislation was passed then it becomes over-riding of any previous legislation. Consideration will need to be given to the potential backlash from consumers if it required financial institutions to track and monitor payments.
  
  Customer Service
  All financial institutions that were interviewed expressed varying levels of concern on the wider customer service implications. It is acknowledged that any initiatives are only targeted at a very small minority of customers i.e. problem gamblers. However, the various proposals being considered have varying degrees of impact on the wider customer base.
  
• Existing community responsibilities of service providers - Commonwealth and state/territory initiatives to minimise the negative impact of problem gambling are comprehensively supported by the individual institutions and governing bodies spoken to as part of this research. Most financial services institutions have quite explicit and detailed objectives to support the communities within which they operate. These are available publicly at most financial service outlets.
  
  This community responsibility manifests itself through a number of strategies including:
  
• Lending is undertaken in a socially responsible manner i.e. providing levels of credit that directly reflect the financial capability of individual customers. Hence, the active credit management of customer accounts is integral to the day-to-day activities of banking institutions. It is in the interest of such institutions to minimise customer bad debt whether its root cause e.g. problem gambling, drug addiction or general financial mismanagement.
  
• As part of a socially responsible lending strategy banking organisations have taken specific measures in relation to the provision of services at gaming locations. Research has demonstrated that the majority of acquiring institutions have withdrawn access to credit accounts in these specific environments. Access to credit accounts is often only available when the retailer has insisted on the functionality being available (this is not referring to redraw capacity).
  
• Many acquirers are involved in the provision of low-key advertising to encourage gamblers who recognise that they may have a problem to seek help. For example, receipts may carry the telephone number of a gambling help line. Equally, the ATM itself may carry stickers or leaflets conveying a similar message.

8.3 Summary

The financial services sector is fully supportive of effective measures to minimise the negative social impact of problem gambling. However, it is difficult for the financial services sector to decide upon effective strategies when a number of issues remain outstanding. They include:

• The capacity of the banking community to readily identify and differentiate between problem and social gamblers in a manner that can be viewed as being non-discriminatory.
  
• The need for metrics to be established to measure the effectiveness of any strategies put in place. The availability of evidence to support which strategies are most effective. Given the measures adopted at state level, the availability of empirical evidence that demonstrates the degrees of success for various strategies.
  
• Given the lack of confirmation of what might constitute effective harm minimisation strategies within financial services, it is hard to promote to the wider customer base and shareholders, solutions that could directly impact the commercial operations of the service providers. It is unclear to what extent the government is prepared to impact on the success of commercial lines of business. This applies not only to service providers but also to retail outlets.
  
• Strategies need to be balanced between providing a general level of customer service and providing a structure of support for problem gamblers. It is not clear to the financial services sector what ideas or views the Commonwealth or state governments have on achieving this balance i.e. where should the line be drawn.
  
• Legislation is widely viewed as a measure of last resort. Given the lack of definition around the problem and the relatively unknown likely effectiveness of potential solutions, it is potentially more prudent for Commonwealth and state governments to take account of measures already in place.
  
• Equally, given the pace at which technology changes, it is difficult to envisage how ‘device specific’ legislation can keep pace with developments in the gaming and financial services sectors.

41. Appendix F contains a summary of the response to the key questions to be addressed as part of the project brief.
42. *Not all stakeholders felt able to provide an indicative figure on the likely scale of investment required to undertake such work given the lack of detailed specifications. However, from information collected a figure of $20m serves as a reasonable indication on the degree of investment required by the financial services industry.