DRAFT GAMBLING BILL
Memoranda from 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 5000 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, i.e. 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% 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.
NPW
8.12.2003
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