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Let UK poker players keep automated rebuys and top-ups

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Please allow poker sites regulated by the UK for the first time to continue

* automated rebuys in rebuy tournaments

* automatic top up of cash game table stakes.

Please suspend Remote Technical Standard (RTS) 14A i)

 

Background:
The Remote Technical Standards which will now apply to poker sites operating in the UK include Remote Technical Standard (RTS) 14

Quote:

"RTS aim 14
To ensure that products are designed responsibly and to minimise the likelihood that they exploit or encourage problem gambling behaviour.

RTS requirement 14A
Gambling products must not actively encourage customers to chase their losses, increase their stake or increase the amount they have decided to gamble, or continue to gamble after they have indicated that they wish to stop.

RTS implementation guidance 14A
a. By actively encourage, we mean the inclusion of specific features, functions or information that could reasonably be expected to encourage a greater likelihood of the behaviours described occurring. For example:
i. the amount of funds taken into a product should not be topped up without the customer choosing to do so on each occasion, e.g. when a customer buys-in at a poker table they should have to choose to purchase more chips to play at the table - automatic re-buys should not be provided
ii. written or graphical information should not encourage customers to try to win back their losses
iii. customers who have chosen to exit a game should not be encouraged to continue playing by, for example, being offered a free game. 
b. This requirement is not intended to prevent operators from offering special features or well-known games such as blackjack that allow customers to increase their stake on the occurrence of specific events (e.g. split)."

 

We entirely support the aims of this technical standard. It is surely right to establish rules to prevent problem gambling. Any automatic escalation of stakes or stake level is indeed a potential area of concern. The trouble is that the example used in this RTS of poker fails to understand poker. In truth, automatic re-buys and top-ups in poker do not result in the loss of decision making and gambling control that this rule is designed to address:

Rebuy Tournaments
When a player chooses to enter a rebuy tournament they do so fully informed of the game type and structure. It is a positive choice at the outset to choose a "rebuy" rather than a “freezeout” tournament (wherein only one initial buy-in is permitted). Poker players are aware at the outset of a rebuy tournament of the way that the option to rebuy alters the game play of the tournament; they are aware of the cost of making multiple rebuys, which also result in a larger prize-pool and total number of chips in the tournament.

Typically players will choose a strategy based upon a maximum number of rebuys at the outset. Even if a player has control issues, any potential loss of control is limited by some key factors. Firstly, the rebuys are only possible when the player's chip-stack is below a specified threshold, but most importantly the rebuy period is time limited. It is not the case that rebuys offer unlimited escalation as could be the case with non peer to peer gambling. 

When selecting automatic rebuy in a poker tournament, it is not a commitment to continue rebuying indefinitely. Post any automated rebuy period the game proceeds and the player makes the normal poker betting choices (raise/bet, check, fold). Poker offers continual player choice and control over each bet and time to choose whether to keep the automatic rebuy in place or not.

There is also no loss of stake control during the rebuy period itself as there is sufficient time for the player to reassess whether their preferred strategy is to continue to rebuy if a hand is lost. Automated rebuy is just making a strategic choice for the single next instance.

Not having automated rebuys slows game play during the rebuy period. This introduces an issue of fairness where UK players have to take time to make the rebuy decision whereas others do not, resulting in fewer hands dealt to tables with UK players. Now this is not a large disadvantage, but the impact on game fairness is real.

Cash Game – Automated Top Up
Cash game poker strategy and in game choices are affected by the relative stack size [amount of chips] held by a player compared to the size of the game's blinds and the stack sizes of the other players in each hand. A player choosing to play “deep” [a maximum buy-in stack size] will, if playing well, make different choices to an equally skilled player with a “short” [significantly less than maximum]stack.

The changes in optimal play according to stack size are many, complex and profound. Cards that would be folded “short” are bet when “deep”. The choice between calling or raising can and does differ depending upon the player's remaining stack size. Players choosing an automatic top up are not escalating their betting or stakes, but rather they are standardising their stake at the start of each hand in order to play in their preferred “deep” strategy.

This standardisation is particularly important for those many players who choose to play multiple tables at the same stakes at the same time. Players routinely play 4, 10 or even 20+ tables at a time. For those that do not understand poker this might appear shocking or a symptom of problem gambling but for poker players choosing to multi-table it is in fact the opposite. By spreading the stakes at risk across multiple tables the variance in results due to chance is reduced and the ability to use skill is increased as more skilled decisions are made in the same time. Multi tabling does not really escalate stakes, it reduces them and instead increases the number of skilled choices made.

Having an automatic top up does not alter the strategy of multi table play, it just makes it a bit easier as the player choosing a “deep” strategy can be confident that at the start of each hand on each table their stack was “deep” and thus their game strategy across the tables remains consistent.

With automatic top up removed players would face having a different decision and different strategy on different tables played at the same time. This would be a significant disadvantage for such players compared to the non-UK players who do not face this complication. This would affect the fairness of the game to the disadvantage of UK players.

It should be noted that a player distracted from their play for whatever reason (say falling asleep or a mere distraction) would not face additional losses as a result of automated top up. If the players fails to respond within a hand to the routine betting decisions within every poker hand they are "sat out" the top up is suspended and no additional money is put at risk. This would not necessarily be the case for non peer to peer gambling.

Suspending Remote Technical Standards
The Gambling Commission have already agreed to suspend RTS 8 regarding automated play until these 2009 Remote Technical Standards can be properly consulted upon and amended. That rule is of far greater significance than this small part of RTS 14 where a poor example of poker was used without full understanding of the implications for UK players in the new regulatory environment where UK players in a peer to peer game of skill are playing within an international player pool where others do not face the same restriction.

Once fully consulted upon we are sure that the evidence will show that automated top ups and rebuys in poker do not encourage problem gambling, escalating stakes or loss of control. These features have been an industry standard for some years with no evidence to suggest they have increased problem gambling, indeed the Swedish regulator's report suggested that online poker is a relatively low risk gambling product.



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