The research and analysis across all areas and stakeholder sectors has identified a range of themes for consideration. Broadly these themes can be grouped into the following key areas:
- technical capability, functionality and cost;
- implementation timetables;
- cost of implementation;
- impact of future technology on changes to devices;
- regulatory environment;
- sector wide approach;
- strategy effectiveness;
- commercial impact; and
- customer service implications.
9.1.1 Technical theme – capability, functionality, cost
The research undertaken through this project has clearly identified that the technological capacity is available to consider the options as proposed in the brief. Capability is not the primary issue; it is more a question of the cost, timing and effectiveness of the strategies. A detailed examination of the deployment of technology is located in Appendix D. The research demonstrates that the removal of devices or functionality is relatively straight forward, and requires minimal investment on behalf of the banks, however the other minimisation strategies being proposed eg, tracking and monitoring of transactions in gaming environments requires significant technological development and financial investment from the banking sector.
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9.1.1.1 Implementation timetables
It is reported by the banks and others in the financial services sector that from their initial high level assessment of the various proposals put forward by this research that:
- to remove/relocate ATMs and/or removal or limiting of functionality could take up to 6 months to comply;
- the more significant investment is being able to track and monitor transactions originating from gaming areas. This will require the implementation of a new naming standard for gaming retail locations. This new naming standard would have to be implemented nationally requiring the cooperation of all governing bodies and participating member institutions. Given the initial high-level assessment of this proposal, it is reported that any likely implementation could potentially take up to two years to implement. Further, given current sector system development work, it is anticipated that the implementation of any new naming standard could not commence until 2003. The effective outcome being that compliance would not be achieved until 2005 at the earliest; and
- the implementation of the new naming standard is only the first phase of the technological investments that would be required to satisfy a tracking and monitoring facility. Further work to communication systems, switching systems and host systems would be required. At this stage the industry is not in a position to provide an indication of how long this development work would take. Detailed investigation would be required as part of the next phase of consultation with the sector.
9.1.1.2 Cost of implementation
Based on discussions with the banks and others in the financial services sector at this stage the government can expect any such technological investment to represent anything up to and over a $20 million investment by the industry. This figure is only representative of an indicative estimate on the banks behalf. It does however provide a good indication of the scale of any investment that would be required.
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9.1.1.3 Impact of future technology
Discussions were held with the banks on the likely impact of future technology, eg smart cards, and 3G mobile telephones. It is widely agreed that this technology has the capacity to increase access to funds away from ATM and EFTPOS. However, given the current reliance on physical cash with which to game at this stage the technology potentially has limited impact. If however, Internet ‘pokie’ machines with electronic access become widely available there are significant implications for the financial services industry. These include:
- consumers will be able to access funds electronically via their mobile phones and then disperse those funds electronically via the ‘pokie’ machine; and
- the same scenario holds true for smart cards. This raises concerns on the effectiveness of focussing current regulatory efforts around limiting only ATM and EFTPOS access. The logical conclusion is that any such legislation cannot be specifically device specific or orientated, as the industry will be continually faced with technological changes that legislation is unable to keep pace with. It may be more appropriate to refocus regulation towards targeting the individual’s account and not the means by which they access it.
The approach of the research has focussed primarily on technology and its development within the financial services arena. Gaming is also heavily reliant on future technological developments. This research has discovered ATMs in the United States that have in built gaming facilities. The research has also identified ‘poker’ machines with in built EFTPOS facilities. The initial view of the financial services sector in Australia is that they would not support the development of such technology.
However, there is need to be aware of the potential of entrepreneurial activities of independent operators who may not be held by the same understanding of social responsibility. These developments fall outside the scope of this project and as such have not been fully researched.
9.1.2 Regulatory/legislation
There is currently a myriad of regulatory and legislative responses from the states and territories with regard to problem gambling. It is clear that there is no common agreement from the states and territories as to what represents effective legislation to minimise the negative impact of problem social gambling in relation to accessibility to cash and associated facilities.
Whilst, there has been some identification of a link between access to cash and credit and problem gambling, it is not yet clear whether strategies around ATM/EFTPOS are actually effective.
Given the recent level of activities by the states and territories within this area there is a need for a more consistent national regulatory framework to assist states in the formulation of policy. The advantage of a consistent approach is that it enables states to effectively respond to issues, and allows respective sectors (retailers, gaming venues, gaming, financial) to be more proactive, responsive and accountable.
An agreed national approach led by the Commonwealth would enable the capacity to engage the various stakeholders to participate more effectively in management strategies. Such an approach could avoid the need for regulatory responses.
9.1.3 Sector wide approach
State and territory governments currently receive the benefits of legalised gambling in the form of tax revenues. With the research now guiding us towards causal links between ATM/EFTPOS cash access and problem gambling, a number of state/territory initiatives to date have therefore focused responsibility primarily on the financial services sector to help resolve the issue of ATM/EFTPOS access. As demonstrated by the range of socially responsive problem gambling strategies, clearly accountability for problem gambling in the community is broader than simply government response. In addition, responsibility for minimising problem gambling through access to cash is broader than the responsibility of the financial sector. Response to this issue must include the roles of all key players within and across the various sectors. This includes the gaming sector, financial sector, community sector, gaming venues, poker machine manufacturers, licensees, and peak industry bodies.
Any strategies with regard to responsible gambling should focus on all the relevant stakeholders and their respective responsibilities. For example, restricting EFTPOS transactions in a hotel is technically relatively easy to implement, however without the cooperation of the hotelier any technical solution can readily be circumvented thus reducing the likely effectiveness of the strategy. Furthermore, by restricting or removing ATM access in gaming locations, this will not prevent problem gamblers arriving at the gaming location with money in hand. Consequently, again responsibility falls on the hotelier to ensure patrons use the gaming machines in a responsible manner. This responsibility is in total keeping with gaming venues’ current responsibility to ensure they manage their business in line with current codes of practice. It is important that any solutions include all stakeholders’ commitment. Stand-alone solutions can be easily circumvented and rendered ineffective without considered agreement by all parties.
This sharing of responsibilities between stakeholders should also reflect the relative commercial importance of gaming to each stakeholder. It is clear that both the hotelier and poker machine manufacturers receive substantial financial income from the deployment of gaming machines. Financial service providers in contrast receive no income from the operation of the gaming machines. Any changes to ATM/EFTPOS facilities will require a financial commitment by the banks, yet they receive no direct income from the poker machines. Consultations have highlighted the need for equity in response to these issues and equal commitment and financial backing from all parties rather than one particular player.
As such, from a policy development perspective, it will be important to consider all stakeholders’ roles and responsibilities to ensure equity in accountability. There is scope to consider more comprehensive solutions if all respective parties are included in the strategy development and subsequent implementation. The notion of equity in accountability and responsibility has come forward as a key consideration for all stakeholders.
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9.1.4 Strategy effectiveness
State/territory legislators to date have primarily focused on access to ATM and EFTPOS terminals without the availability of substantial empirical evidence (either historical or current) that such strategies are effective in reducing problem gambling. Further, there is virtually no international evidence to guide decisions around the effectiveness of similar strategies. This focus has driven solutions, which in the main do not include or take into account the respective roles of the stakeholders, across the industry. Furthermore the legislation has not considered current or future trends in the deployment of new technologies.
State/territory governments have put in place a wide range of measures to restrict access to ATM and EFTPOS facilities within gaming locations. The financial services sector has indicated their support of measures that minimise the impact of problem gamblers. It is suggested that before further or wider legislation is proposed that the respective cost and benefit analysis be undertaken – how much is the strategy to implement, and what is the expected outcome /impact of the strategy.
Cost benefit analysis is critically important when one considers that there are independent ATM operators in the market. These organisations are considerably more reliant on income-generated funds from ATMs. As such there is a need to be confident that strategies are appropriate and effective.
The same issue is present for small rural providers where they are dependent, as are their customers, on the capacity to provide facilities and services in a range of environments.
There is a need for an agreed approach that provides a range of consistent strategies, clarity with regard to outcome and expected impacts, cost benefit analysis as part of the development phase, consultation with key stakeholders, and appropriate review and evaluation strategies such as longitudinal impact studies.
9.1.5 Commercial impact
There are anecdotal reports from representatives of the financial services sector that the experience of South Australia has impacted the smaller operators to such an extent that the make up of the market has changed. Specifically, it has been reported that the changes in South Australia have impacted on the smaller players more significantly than the larger players.
There is a wide range of options available to the government. These range from the wholesale removal of ATMs from gaming locations to the tracking and monitoring of transactions generated in gaming locations. The commercial implications for stakeholders vary in degree as one moves through the spectrum of options.
9.1.6 Customer service implications
Harm minimisation strategies need to balance the particular requirements of problem gamblers against the general servicing requirements of the wider population. To vary limits between different types of retail locations potentially has significant consumer impact and may create customer confusion. It is felt by a number of banks that they would soon withdraw ‘cash out’ of EFTPOS altogether at gaming locations rather than implement no or varying limits.
These types of customer service issues would be replicated and be accentuated in locations such as casino complexes where multiple retail operations are present and operate as entertainment facilities, rather than merely gaming.
Other customer service implications are foreseen for rural and remote locations where financial services are provided through hotels as banks close branches in such locations. Changes to access in these environments would potentially have a substantial impact.
The wider customer service issues for consumers used to accessing cash in such locations – the removal of such services has wide implications for example, consumers being forced to leave hotels and search for available ATMs late at night raises potential issues of litigation in the case of any criminal events.