Probably just as relevant here as the other thread



Cross post from PokerStars Steve in the NVG thread

http://forumserver.twoplustwo.com/29.../#post44712249

This at least looks like good news for Stars players, it seems scripts will be OK.

I tend to enter tournaments on the train home via mobile broadband. By using the auto top up I am protecting my investment.

If I have to manually "make a decision" and am disconnected I will basically be booted out of the tournament and will lose my investment.

New Draft:

Petition to the Gambling Commission – Poker rebuy & top up

To: Jenny Williams (Commissioner and Chief Executive) Gambling Commission

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


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 prizepool 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 chipstack 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 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 necesarily 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.

Last call for changes and for a volunteer to post it on change.org

At least run a spell check through it. I saw at least one "necesarily" just glancing through very quickly (just above Suspending Remote Technical Standards)


Or, if you're happy to wait I can probably have a look through tomorrow, but prob not until lunchtime. Bed time for me now though.

Published here:

http://www.change.org/p/jenny-willia...ys-and-top-ups

How does it look (not as the originator) - OK? Anything wrong with it?

Looks fine.

Why not sign it then? Billy no mates is feeling lonely.

I tried. The site javascript doesn't work for me. Haven't had a chance to try to figure out the problem.

Tried in IE (instead of Firefox) and was able to sign.

I posted in the Stars announcement thread, I don't think we need another thread but if anyone disagrees and thinks a new thread would increase the profile/be appropriate - feel free.

Recruiting tweeters with a decent poker audience might work better.

Indeed. I tweeted, but I don't have a big audience. Might start the ball rolling though.

Signed, tweeted and shared on Facebook. Thanks for your hard work Richas and others.

Richas, while you make some valid points, some of the message seems contrived. Can you honestly say that you have no motivation whatsoever to have this rule overturned because you want to be able to wipe out a fish's br in cash games without them having to look at their br every time they reload to see how much money they've lost? Your petition assumes that all players using automatic top ups are applying that option strategically. The truth is that when you put someone on tilt, sometimes they will just keep playing and would rather not look at their br until they're done or forced to because they've busted--that is the type of "problem gambling" the rule is designed to prevent. Something about pleading with a government agency to allow fish to use the automatic top up option seems passively predatory to me--though giving you the benefit of the doubt I do not think you intended it to come across that way. But still, you must ask yourself if it hurts you more to have to click "Add Chips" on one of your 10-20 tables (...??) once you lose a big hand or fall below a desired chip stack level, or if it helps more those who might be tossing away their br while on megatilt. While your government may not understand the situation in those precise terms, that is the scale on which your claims will be weighed. Further, I would assert that the vast majority of players, since the majority of players are losing, are not using the automatic top up option bc they are playing 10-20 tables, they are using that option on 4 or likely fewer tables bc they don't want to see their brs until they've exhausted or multiplied their true "bullet," which would be the amount they deposited just a few days or weeks prior.

Now, I do understand that there is much money to be made hunting fish and megatilters, and that it is a part of the game, and I am not saying that I think the new rule, nor any rule, should be designed to change the nature of the game into such that the idea of busting a fish's br in one session can be chalked up as a part of how the game "used to be," but it sounds to me like your government is attempting to take steps to protect the vast majority of its online poker players from tilting away their rent money. That notion is a bit too paternalistic for my taste, and so I do not agree with it, yet the rule does seem to address the problem that your government has deemed is worthy of tackling. Therefore, I must conclude that your government is not likely to find much of your message, on its face, to be sincere. I suggest you refine your method of attacking this issue of federal paternalism. Perhaps you might alter portions of the petition to reflect these concerns and focus more on the fact that what a player deposits has been his choice, and that all subsequent gameplay decisions, such as playing with the automatic top up option, are simply a part of the game, and yes, for some, a part of their strategic style.

Well yes. You see I'm not a cash game grinder. I play a bit of poker as a rec. Even on rebuys I like the 2R1A structure.

I used to be +ev and have not deposited for years but I play at micro level and I don't multi table much at all, today I seem to have a minor leak or two :-)

I tend to browse the net, listen to the radio and just play. Hence I'm posting here whilst playing.

For me the loss of these features is a mere irritant, not a big deal. That is why when I read the RTS document 2 years ago no alarms flashed when I read this rule. they should have done but it is not that important to my experience.

An argument I left out of the petition was the risk that this rule encourages automation and cheating. My history with the UKGC is lobbying for action on player fund protection, prosecuting cheats, bringing third party softeware in to licencing, preventing data mining, encouraging them to make explicit that running bots or banned software (by the TOS) risks prosecution.

My other big thing is protecting the vulnerable and campaigning for a national online self exclusion scheme.

If you think I am the avenging angel for pros or grinders seeking to rip off fish then you have the wrong guy, I want scanning software banned for instance.

now those positions are not really crowd pleasing around here but cest la vie, all they show is I am not quite the guy you think.

Edit: in a petition it is not the petitioners job to put the opposing position's arguements for them. There may be a tiny level of protection here but I don't think it offers a real gain or rewal help. As you say the compulsive will just click anyway, the issue is to help them and that is where behavioural analytics might be able to help.

I am a strong advocate of protections for the vulnerable. I believe that regulations in the US states as well as overseas should require more extensive controls for the prevention and detection of problem gambling in online poker, including universal options (self-limits and self-exclusions which are enforced across all licensed platforms, when requested by the player), behavior analytics, warnings and account locking (requiring affirmative action by players to unlock) upon flag detection and a more robust proactive help referral system by trained site personnel.

That said, I think you are barking up the wrong tree. First, "tilting" and "problem gambling" are not equivalent; nor is tilting necessarily indicative of or a precursor to problem gambling. Your posited "megatilter" is just as likely to risk their entire bankroll with or without auto-topup, but that is the nature of the game. I don't think it is in the purview of government regulation to prevent someone from losing their bankroll due to tilt.

In contrast, the problem or compulsive gambler is going to risk their financial health, not just their online bankroll. The auto-topup feature will not promote this behavior; nor will banning the feature work towards preventing it. Behavior analytics are necessary to detect the warning signs, including large lifetime deposits, multiple short-term deposits or consistent loses.

My benchmarks for flagging behavior are:

• a. The Player’s lifetime deposits to their account reach the benchmark amounts of $2,500.00, $20,000.00, $100,000.00, $500,000.00 and $1,000,000.00;
• b. The Player makes five deposits to their account within any 7-day period without any intervening withdrawals;
• c. The Player makes ten deposits to their account within any 30-day period without any intervening withdrawals; or
• d. The Player makes no withdrawals from their account within any 120-day period, where the Player has participated in wagering in each of the four successive 30-day periods.

These should trigger account deposit locking, with these provisions:

Those are real protections for players suffering from problem or compulsive gambling. So far, no regulatory authority has implemented such protections. Until they do, online poker will remain a high risk to the small vulnerable population. Banning a software feature like auto-topups will make no difference to this population.

We have had a response from the UKGC and I think it is good news.

I am though seeking some clarification. I think it says rebuys/top ups will be ok for now so long as players behaviour is monitored and that it will be consulted upon when the whole Remote Tchnical Standard is consulted upon (soonish). I only had 90 mins warning before it went on the UKGC blog so could not get clarification before it went live.

http://licensingadvertisingact.blogs...uto-rebuy.html





Comments welcome.

Meh, not sure I agree with this as an indicator of much at all. I mean, I haven't made a withdrawal since I don't know when, got to be over a year. I haven't played any meaningful volume since some time last summer, but I definitely "wagered" in many successive 30 day periods. I just left a small amount in there for playing for fun when I stopped grinding, and the balance goes up or down a few dollars after whatever I play, and I just leave it in there. Lol-volume, but I'm probably up something trivial like $50 since then, and having to withdraw and deposit again to avoid triggering this is just pointless movement of money.

There must be plenty of players like me who don't lose, but don't win enough worth withdrawing either who just want to play a few games a month for the enjoyment of trying to outplay someone with a few pennies as a side bet so it isn't just the bingo play you encounter in play money games.

All this triggers, per my guide, is a lockout from making deposits until the player unlocks the account by checking an option in their account or contacting customer support. It's not a big deal for players like you, but could help someone who has a problem.

Super work, Richas! You deserve all the credit.

Now it's mainly a matter of getting the sites to take a closer look and abort their plans, if any, to block auto-rebuys/topups.

Thanks, I have to say I am pleased to have got a positive response in just a week from the UKGC

You are right, there is another step in chasing up Stars et al even though it has been published by the UKGC giving them the opportunity to keep them.

Ugh, sorry, misread, thought you said account locking, but you actually said account deposit locking. Carry on....

Indeed. It's nice that someone seems to be listening to and responding to interested parties.
Thanks again for your efforts.

Well that was a quick response from UKGC, good job.

I think this means no change for now - which is the best outcome IMO.

Has Pokerstars said they will no longer be removing auto top for UK players?