Memorandum from Committee of Registered
Clubs Association (CORCA) (DGB 20)
INTRODUCTION
1.1 The Committee of Registered Club Associations
(CORCA) comprises the organisations listed above and is the country's
leading forum for non-profit making private members' clubs. Collectively
CORCA organisations represent about 5,000 such clubs with an individual
membership of around 3 million. CORCA clubs operate on the mutuality
principle; there is no private gain. Any financial surpluses realised
are retained for the benefit of club members as a whole. The majority
of CORCA clubs are registered either as Friendly Societies or
Industrial and Provident Societies.
1.2 There are emerging aspects of the draft
Gambling Bill and the accompanying policy document which are a
cause for concern to CORCA, although the actual draft clauses
on pubs and clubs have yet to be published. Mindful of the Committee's
approaching deadline for submitting evidence, we make this present
submission on the basis of the information currently available,
and trust that the Committee will be prepared to consider any
further representations when the full draft Bill is available
to us.
CLUB BINGO
2.1 Paragraphs 4.40 to 4.42 of the policy
document Cm 6014-iv make clear that CORCA clubs and the like will
have to apply for an "additional bingo operating licence"
if in any period of seven days a club's bingo stakes or prizes
have totalled £1,000 or more. Under Sections 40 and 41 of
the Gaming Act, 1968 CORCA clubs have been able to play bingo
without regulatory interference, ie no additional permit or licence
is required and there are no compliance visits by the authorities;
the practice is entirely self regulating—it is merely necessary
for clubs to ensure that they observe monetary and other requirements
set out in the Act.
2.2 The need for an additional bingo licence
would be a further bureaucratic burden on private clubs involving,
as it must, an extra cost—no licence without the inevitable
initial fee (and presumably an annual fee thereafter). And the
proposed threshold of £1,000 a week is derisory in comparison
with the stake and prize levels typically involved in commercial
bingo. Under the current law clubs can play bingo well above £1,000
a week and in CORCA's view they pose no competitive threat to,
and are not comparable with, licensed bingo halls. Smaller bingo
halls are likely to be more threatened by the larger commercial
chains. Further, any margin a club makes from playing bingo is
not private gain but a much-needed (in some cases essential) contribution
to club funds to maintain financial viability.
2.3 CORCA asks the Committee to seriously
consider whether licensing private members' club bingo is really
a necessary component of the Government's strategy for the regulation
of gambling. If the £1,000 threshold is actually adopted,
we estimate that possibly 15 per cent or more of CORCA clubs could
be brought within the licensing regime. This would not only be
onerous for the clubs sector but would considerably add to the
licensee population under regulatory control and thus the administrative
workload. Club officials could be exposed to the risk of offence
action because of misunderstanding of the requirement to obtain
a licence or through inadvertence. And the Government's approach
seems oddly at variance with the Licensing Act 2003 where the
long-established distinction between private clubs and commercial
premises has been retained in the field of liquor licensing.
RIGHTS OF
ENTRY
3.1 Under the Gaming Act 1968 there is no
regulators right of entry to premises which are not licensed under
the Act. CORCA clubs do not normally obtain licences under the
Act but the majority do register for the use of gaming machines
under Part III. Paragraph 3.79 of Cm 6014-iv says that the Government
"will broadly maintain the special position of members' clubs".
We trust that CORCA clubs, which are after all private premises,
will not become subject to any wide-ranging or indeed routine
power of entry by regulators. Our fear is that with the presence
of gaming machines (currently subject only to Part III registration
and no inspections) and the potential requirement for an "additional
bingo operating licence" clubs will become liable to inspections
and compliance checks more suited to the commercial gambling industry.
We may wish to revisit this topic when the remaining clauses of
the draft Bill are published, if the Committee will allow.
CONCLUSION
4.1 We respectfully submit that a Bill which
would confer significant deregulation of hard gambling should
not unnecessarily increase the regulatory burden on more benign
social and recreational activities in private members clubs.
If the Committee requires any further information
or amplification of the points made in this submission, CORCA
will be happy to co-operate.
December 2003
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