Problem Gambling - ATM | EFTPOS Functions and Capabilities (September 2002) KPMG Consulting

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Problem Gambling - ATM | EFTPOS Functions and Capabilities 

1. Executive summary 

1.1 Introduction

In 1998 the Productivity Commission was asked to undertake the first national independent inquiry into the economic and social impacts of the gambling industries and the effects of the different regulatory structures that surround those industries. One of the key recommendations of the subsequent report was the establishment of Ministerial Council on Gambling. The Commonwealth also established a National Advisory Body on Gambling to provide advice on gambling issues. In December 1999 the Prime Minister announced the establishment of the Ministerial Council on Gambling with specific accountability for:

  • stopping the further expansion of gambling in Australia;
  • the impacts of problem gambling on families and communities
  • Internet gambling; and
  • consumer protection.

The Commonwealth response to problem gambling is co-ordinated through the Department of Family and Community Services (FACS). This project commissioned by FACS is the first step in the process of investigation to inform policy development in relation to access to cash through ATM and EFTPOS facilities within gambling environments.

The purpose of the investigation undertaken by KPMG Consulting was to:

  • provide comprehensive information on current and future Automatic Teller Machine (ATM) and EFTPOS functionality; and
  • to inform the development of a national harm minimisation strategy on specific initiatives available or possible to limit access to cash and credit through ATM and EFTPOS in gambling environments.

The research is indicative of a more holistic approach by the Commonwealth to addressing the impacts of problem gambling in the wider community. The focus is very much on engaging all parties associated with the provision of gambling, including the ATM and EFTPOS operators, who provide facilities to service consumers within these environments.

1.2 Key themes

The key themes to emerge from the research are:

  • There is an increasing recognition that Governments have an obligation to protect the vulnerable through strategies to minimise the harm that arises as a result of problem gambling.
  • Technological change is so rapid that it is unlikely that the focus on the device (ATMs and EFTPOS) and its associated regulation is sustainable as a strategy to minimise the harm that results from problem gambling for the individual, their families and the wider community.
  • Ultimately the device (ATMs and EFTPOS and gaming machines) will become irrelevant as technology moves to cashless transactions.
  • There is a lack of clear research to inform and substantiate the current array of harm minimisation strategies. Rather the strategies tend to have evolved from untested assumptions based in response to the rapidly emerging concern regarding the likely relationship between access to funds in gaming environments and problem gambling.
  • Potential solutions will be multi dimensional involving a range of sectors with differing viewpoints and business objectives, and frequently in conflict.
  • The needs of the social gambler need to be considered concurrently with those of the problem gambler.
  • There is emerging community recognition of shared responsibility with the growing recognition of social obligations within this arena for all stakeholders.

1.3 Moving forward

There is a substantial level of agreement across the industry1 for the need for a national operational approach, with all stakeholders accepting they have community service obligations towards minimising problem gambling.

It is important that the next steps build on the current commitment and momentum that has been generated through this project. In addition, given the lack of evidence to support the effectiveness of strategies associated with limiting cash and access to credit, an agreed approach would provide the framework within which to track and monitor the full range of strategies.

A range of opportunities exist to build on current activities and maximise shared responsibility across the industry in responding to problem gambling within the context of access to cash and credit. These include:

  • The development of a national operational approach that establishes the parameters to guide informed decisions and choices on the array of potential options and arrangements.
  • A shift away from the control of problem gambling through ATM and EFTPOS device focused strategies towards a broader focus on access to accounts for the means of securing cash and/or credit.
  • The development of a strategy in relation to access to cash and credit within gaming locations.
  • A focus on prevention through the curtailment of the deployment of new technologies that could be seen as problematic and providing extended opportunities unnecessarily to either increase access to cash and credit and gaming as well as potential implications for providers, devices and facilities.
  • Exploration of the concept of shared responsibility with all relevant stakeholders taking greater responsibility and accountability for the development, implementation and ongoing maintenance of harm minimisation strategies within gaming environments.
  • Reviewing legislation that guides the location of ATMs in the gaming environment.
  • Development of specific and targeted education strategies with regard to the use of ATM and EFTPOS facilities within gaming environments and the use of ATM facilities to present messaging and information with regard to problem gambling.
  • The provision of a range of self-help strategies within gaming environments to assist the problem gambler to manage their behaviour.

1.4 Recommendations

Recommendation 1: That the Commonwealth government in conjunction with the states and territories, and in consultation with the industry sectors and the community sector, establish a national operational approach to provide the context within which states develop and implement harm minimisation strategies for problem gambling within the context of access to cash and/or credit.

Recommendation 2: That such an approach provide guidance on:

  • the parameters within which strategies can be considered, for example the impact of various strategies on rural communities and relationships to other government agendas and policy directions;
  • key consultative mechanisms and processes including identification of critical stakeholders;
  • the concept of shared responsibility;
  • access to international literature, global benchmarks, research, and organisational contacts;
  • identification of any current best practice;
  • effective cost benefit analysis;
  • appropriate monitoring and review mechanisms;
  • structures for sharing information across jurisdictions; and
  • the identification of accountability for compliance.

Recommendation 3: That the agreed approach shift emphasis away from the control of problem gambling through device focussed strategies towards a broader focus on the individual’s access to accounts for the means of securing cash and/or credit.

Recommendation 4: Within the approach identified in recommendation 3, there needs to be the development of a strategy in relation to access to cash and credit within gaming locations. Such a strategy should incorporate:

  • customer access to funds within their accounts;
  • access defined at the account and device level;
  • monitoring and control of the introduction of new technologies for cash and/or credit accessibility within the gaming environment; and
  • technology around gaming.

Recommendation 5: That the Commonwealth move to negotiate with the states and territories to implement policy to curtail the deployment of technologies that would be considered problematic within the context of managing the negative impacts of problem gambling in the community. That this not be exclusive of a range of technologies but specifically include:

  • the use of Smart Cards and 3G mobile phone technology;
  • Poker machines with in built EFTPOS;
  • E.bank;
  • M.bank/m.commerce;
  • Wireless technology such as Bluetooth; and
  • ATMs with in built gaming capacity.

Recommendation 6: That the Commonwealth government, in conjunction with the states and territories, liaise with the key stakeholder groups to establish clarity with regard to roles and responsibilities within the harm minimisation and social responsibility context. Within this context discussion should occur as to the most appropriate strategies for which the various stakeholders should take primary responsibility.

Recommendation 7: That the Commonwealth government undertake a review of the location and placement of ATMs with regard to their proximity to gaming areas to ensure that the intent of the legislation is being adhered to. Such a review may consider increasing requirements to ensure ATMs are not in visible sight of patrons in the gaming area.

Recommendation 8: That the Commonwealth government negotiate with the states and territories to ensure that all ATMs that serve gaming locations do not enable access to credit accounts.

Recommendation 9: That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services industry to generate in cooperation with other stakeholders, marketing literature specifically targeted to gaming locations including ATM screen messages, dispensing of ATM leaflets and the printing of messages on ATM and EFTPOS receipts.

Recommendation 10: That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services sector to develop an educational strategy targeted at informing the general community of ATM and EFTPOS functionality within gaming environments.

Recommendation 11: That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services sector to develop a strategy that supports self-help strategies for banking consumers who require assistance in managing finances as a result of gaming issues.

2. Project approach 

2.1 Purpose of the consultancy

The purpose of the independent investigation into Automatic Teller Machines (ATM) and EFTPOS capabilities and transaction functionality is to:

  • provide comprehensive information on current and future Automatic Teller Machine (ATM) and EFTPOS functionality; and
  • to inform the development of a national harm minimisation strategy on specific initiatives available or possible to limit access to cash and credit through ATM and EFTPOS in gambling environments.

Specifically the requirements of the project were to:

  • Investigate current ATM and EFTPOS functions and capabilities including:
    • links and access to credit accounts, draw down facilities and other ‘credit type’ accounts;
    • commercial issues for non bank owned ATMs/EFTPOS; and
    • current technologies and their capabilities.
  • Investigate future ATM and EFTPOS functions that could limit or change access capabilities (including access to credit) including:
    • technical feasibility of changes to functions and capabilities;
    • possible convergent technologies (eg Smartcard) that could be linked to financial transactions;
    • technological requirements for change;
    • financial institutions and other stakeholders and their role in changes to technology;
    • the commercial viability of specific function ATMs;
    • the commercial viability of convergent technologies; and
    • timeframes for the introduction of new technologies.

 2.2 Our approach

The project was undertaken in four stages: project establishment; research and analysis; impact analysis; and reporting.

Our approach to the research consisted of two key areas of focus:

  • desk based research and analysis (quantitative); and
  • primary research capturing a range of methods – face-to-face interviews, group sessions, telephoneinterviews and questionnaires (qualitative).

In the desk based research and analysis we aimed to investigate the current legislative and operating framework for ATMs andEFTPOS. Key issues investigated included:

  • current regulatory requirements as they relate to the gaming, gambling, and banking industries;
  • current practices as they relate to the gaming and gambling industries;
  • functionality of both bank and non-bank owned ATMs; and
  • accessibility to credit and draw down facilities.

A list of the websites accessed and documentation researched is at Appendix B.

In the primary research and analysis we aimed to capture information and the views and perceptions of the key financial sector stakeholders. These stakeholders included:

  • the 4 major banks (ANZ, Commonwealth Bank, National Australia Bank, and Westpac);
  • Australian Bankers Association;
  • Reserve Bank of Australia2;
  • Australian Competition and Consumer Commission;
  • major providers of non-bank ATMs and EFTPOS in the gaming and gambling environment; and
  • major gaming and gambling providers (via the industry and sector peak bodies).

A list of the key organisations consulted is at Appendix A. The third stage of the project focused on examining the impact of any potential change on the various sectors.

The purpose of this stage was to gain a broad understanding of the issues confronting the banking and finance and gaming and gambling industries as they relate to limiting ATM/EFTPOS functionality and capability in the gaming and gambling sectors. It was envisaged that any changes or increases in regulation might have commercial implications across both industries, in particular for gambling and gaming venues and ATM/EFTPOS infrastructure providers. An impact analysis was undertaken to confirm commercial implications that may arise from the introduction of specific function ATMs and for convergent technologies.

2.3 Key areas of investigation

The following summarises the key areas of investigation undertaken for the project within the sectors of interest.

2.3.1 Financial services sector

Key issues considered included:

  • functionality and capacity of ATM/EFTPOS;
  • accessibility including location, venue, services and access to cash and/or credit;
  • technology – current and future technological developments;
  • products – use of different financial sector products and devices (credit, debit, redraw);
  • consideration of the role of various deployers;
  • potential impacts of alternative propositions – commercial, customer service; and
  • potential impacts on ATM and EFTPOS providers.

2.3.2 Regulatory environment

Key areas considered included:

  • current regulations across jurisdictions;
  • consistency of regulations between banks and non banks;
  • global comparison;
  • future considerations;
  • any known inputs/outcomes of regulations;
  • potential impacts of regulatory change; and
  • capacity for regulatory change.

2.3.3 Community sector

Key areas considered included:

  • impact of potential changes on the social gambler; and
  • ATM/EFTPOS accessibility in gambling and gaming environments.

2.3.4 Gaming/gambling sector

Key areas considered included:

  • commercial impact of any regulatory or technological change;
  • impact on social gamblers; and
  • impact on customer service.

The project methodology was formulated with, and approved by, the project steering committee.

3. Background 

3.1 Introduction

3.1.1 The Commonwealth Government’s role in relation to gambling

The regulation of gambling has traditionally been a state and territory responsibility. However the Commonwealth is seen to have a leadership role in coordinating a national response to problem gambling. The Commonwealth also has a direct responsibility in relation to the use of the Internet for gambling, a rapidly expanding industry.

The Commonwealth response to problem gambling is co-ordinated through the Department of Family and Community Services (FACS). Their role includes working with other Commonwealth Departments and Agencies to:

  • develop partnerships with state and territory governments, the gambling industry, and community groups to facilitate a coordinated response to gambling issues;
  • increase priority given to the prevention and treatment of problem gambling within the Commonwealth's programs;
  • develop measures to inform and assist groups with special needs in regards to gambling issues, such as youth, Aboriginal and Torres Strait Islanders, and people from culturally diverse backgrounds;
  • monitor the social consequences of banning interactive gambling; and
  • foster research and public awareness on gambling. 3

3.2 Gambling in Australia

As at 30 June 2000, the expenditure in the Australian gambling industry (including racing, all forms of gaming and sports betting) totalled $13.3 billion.4 The greatest contributor was gaming machines, contributing approximately 57% of total expenditure5.

The flow on effects of this expenditure is that the industry is a significant contributor to state revenue and employment. The Australian Bureau of Statistics estimates that 220,000 Australians are either directly or indirectly employed in the gambling industry by approximately 11,000 businesses6.

In 1998, the Productivity Commission was asked to undertake the first national independent inquiry into the economic and social impacts of the gambling industries, and the effects of the different regulatory structures that surround those industries. The final report of this inquiry, Australia’s Gambling Industries was released in December 1999.

The report found that over 7,000 industries provide gaming services in Australia with the majority of business located in New South Wales, Victoria and Queensland. The Productivity Commission estimates that the value added from gambling is approximately 1.5% of gross domestic product with over 40% of income derived in clubs. In 1997-1998, gambling businesses generated $11 billion in net takings and $650 million in commissions, of which over 50% was generated from gaming machines in clubs, pubs, taverns and bars7.

Problem gambling has become a major social concern in Australia. Although the majority of Australians who gamble do so in a responsible manner, a small percentage (approximately 2% of the Australian adult population) has problems with gambling or is ‘at risk’. Whilst this is a relatively small percentage of the population, there is a ‘multiplier effect’ with an additional 5 to 10 persons adversely affected by a problem gambler’s actions8.

3.2.1 Definition of problem gambling

Problem gambling as defined within the Productivity Commission report is a condition that contributes to:

  • the loss of self-control over gambling/gaming behaviour, such as the frequency of gambling, and the value wagered; and/or
  • a pattern of gambling behaviour that negatively affects other important areas of one’s life.9

3.2.2 Characteristics of problem gambling

One characteristic of problem gambling is the loss of control over gambling, especially over the scope and frequency of gambling, the level of wagering, the amount of leisure time devoted to gambling, and the negative consequences deriving from this loss of control.10 Problem gambling can also be defined as any pattern of gambling behavior that negatively affects other important areas of an individual’s life, such as relationships, finances or employment. The mental disorder of ‘pathological’ gambling is seen to lie at one end of a broad continuum of problem gambling behaviour.11

There are a number of features widely recognised as characteristics of problem gambling, although not all of these aspects have to be present in a person who is regarded as having problem gambling behaviour. They include:

  • Personal and psychological characteristics such as difficulties in controlling expenditure, anxiety, depression or guilt over gambling, thoughts of suicide or attempted suicides; use of gambling as an escape from boredom, stress or depression; thinking about gambling for much of the time; and giving up formerly important social or recreational activities in order to gamble.
  • Gambling behaviours, such as chasing losses, spending more time or money on gambling than intended and making repeated but failed attempts to stop gambling.
  • Interpersonal problems, such as gambling-related arguments with family members, friends and work colleagues; relationship breakdown, or lack of time with the family.
  • Job and study problems, such as poor work performance, lost time at work or studying, and resignation or termination due to gambling.
  • Financial effects, such as large debts, unpaid borrowings, and financial hardships for the individual or family members (either in the present, in the case of high gambling commitments out of current earnings, or in the future, in the case of assets that are liquidated to finance gambling)
  • Legal problems, such as misappropriation of money, passing bad cheques, and criminal behaviour due to gambling. In severe cases, these may result in court cases and prison sentences.12

The Productivity Commission Report13 identified that there may be causal links that can lead to a dependence on legal gambling. The Productivity Commission report also identified that the gambling environment plays a major role in causing problem gambling. The following factors were identified as examples:

  • as gambling opportunities become more accessible, this allows an impulsive person much greater opportunity to gamble;
  • some gambling forms such as gaming machines involve repetitive, but random rewards for further play – which conditions behaviour in some people to gamble persistently; and
  • the gambling environment, including the promotional activity of the industry, may compound (or at least, not negate) certain erroneous beliefs that gamblers have about winning.

Control of the gambling environment including restriction of access to funds via ATMs and EFTPOS in the gambling environment was identified in the Productivity Commission report as being one of a range of measures to address the gambling problem.

3.2.3 Commonwealth response to problem gambling

The challenge for all governments in Australia is to find a response that balances the right of individual Australians to gamble, the interests of industry,14 and the responsibilities of governments for overall community welfare.

One of the key recommendations of the Productivity Commission report was the establishment of Ministerial Council on Gambling. The National Advisory Body on Gambling was subsequently convened to advise the Commonwealth on issues related to gambling. The aim of both groups is to achieve a national approach to the challenge of problem gambling and the negative social impacts for the Australian community.

In the 2001-02 Budget the Commonwealth announced the allocation of $8.4m to be used to develop national public awareness and education campaigns on gambling issues and to support problem gambling related research projects.

3.2.3.1 Ministerial Council on Gambling

The Ministerial Council on Gambling includes all state and territory Ministers responsible for gaming regulation. The Commonwealth Minister for Family and Community Services is the Chair of the Council, and a representative from the Community and Disability Services Ministers' Conference is also a member.

To achieve its objective of addressing the negative impacts of problem gambling across all States and Territories, the Ministerial Council on Gambling focuses on:

  • the accessibility of gambling (including interactive gambling) and in particular its relationship to the level of problem gambling;
  • an appropriate regulatory and educative framework for gambling which includes appropriate consumer protection; and
  • support for problem gamblers (with the acceptance of problem gambling as an important social issue and recognition of the important role of information, counselling and support services for problem gamblers and those close to them)<15

The Ministerial Council has identified key areas for national research including:

  • national approach to definitions of problem gambling and consistent data collection;
  • feasibility and consequences of changes to gaming machine operation;
  • best approaches to early intervention and prevention to avoid problem gambling;
  • longitudinal study of problem gamblers to identify what policy measures would work for them; and
  • benchmarks and on-going monitoring studies to measure the impact and effectiveness of strategies introduced to reduce the extent and impact of problem gambling, including studies of services that exist to assist problem gamblers and how effective these services are.

Research is managed through the newly established Australian Gambling Research Secretariat.16

3.2.3.2 National Advisory Body on Gambling

The National Advisory Body on Gambling brings together community, industry and academic representatives to develop a balanced approach and inform the Commonwealth Minister for Family and Community Services on gambling issues. This advisory body is currently drafting a National Harm Minimisation Strategy on Problem Gambling, and is expected to outline the best focus for new research, harm minimisation measures, appropriate areas for community education and public awareness, and possible areas for Commonwealth intervention.17

3.3 Social and community service obligations of the financial sector

The concept of social responsibility for the financial sector is not new. Many financial institutions are active in, and supportive of community based initiatives and have been for many years. In addition responsible management of credit facilities and services has been one part of the management of financial institutions in Australia.

In recent times the financial sector has engaged with government with regard to the concepts of mutual obligation and social responsibility. Capacity to respond to problem gambling is not seen by the financial sector to be solely a government responsibility. To date, much of the attention and focus of strategies to tackle problem gambling have been in the arena of education, communication and social and health services. This focus is now broadening to consider the role of the financial sector and the potential role that it can play in responding to problem gambling issues.

3.3.1 The Productivity Commission Report

One of the key themes of the Productivity Commission report was for an increased role for consumer protection in the gambling environment, specifically:

  • Informed consent - an increase in the exposure of gamblers to basic information regarding the price and nature of gambling and the potential for ‘excessive consumption’; and
  • Consumer control - incorporating spending controls and pre-commitments18

The Productivity Commission National Gambling Survey ‘found that problem gamblers were more likely than non-problem players to withdraw money from an ATM at a venue whilst playing the pokies’.19

Consequently, the Commission suggested that limiting the access to ATMs and credit was a high priority as a consumer protection measure as part of a package of responsible gambling and harm minimisation prevention measures.

3.4 Regulatory environment

State and territory gambling and gaming regulators have commenced a period of review within their individual jurisdictions with the view to:

  • slowing the proliferation of gambling, particularly gaming machines;
  • increasing the focus on gambling related harm minimisation;
  • clarifying the responsibilities associated with gaming/gambling by the individual in licensed gaming venues and other industry stakeholders; and
  • maximising the social and economic benefits of gambling while minimising the potential harm and costs to individuals, their families and the wider community.

To achieve the above broad objectives state and territory governments (and the associated regulators) have undertaken reviews of policy and regulations with respect to gambling and gaming and as a result, most states have implemented, or are considering implementing, harm minimisation strategies.

One of the harm minimisation strategies adopted by all states and territories, in one form or another, is the restriction of ATM and EFTPOS facilities in gaming machine areas within licensed gaming venues (hotels, clubs and casinos).

3.5 Industry overview

The following sections capture the results of the desktop and primary research. It aims to highlight the key research findings, issues and impacts across the key areas of interest. This includes the:

  • regulatory environment;
  • gaming/gambling sector;
  • community sector; and
  • the financial services sector.

At the completion of the sections we have drawn together the key themes from the research, consultations and subsequent analysis providing some comment and conclusions.

4. State and territory regulatory environment 

This section of the report reviews:

  • the current state and territory regulatory framework for the use of ATM and EFTPOS facilities in the Australian gambling environment;
  • potential or pending regulatory models in the Australian states and territories to strengthen the limitations to cash and credit (cash advances) as part of a ‘package’ of responsible gambling and harm minimisation measures;
  • where applicable, the methodology and approaches adopted by state and territory governments in regulating cash facilities (ATMs and EFTPOS); and
  • the impact of measures implemented to restrict the access of cash and credit in the gambling environment. Particularly the impacts (both positive and negative) on problem gamblers, recreational and non-gamblers, licensed gaming venue operators and the banking sector.

4.1.1 State and territory regulation of ATM and EFTPOS

It is generally accepted that following the release of the Productivity Commission findings and recommendations the states and territories commenced, or accelerated, the introduction of gambling harm minimisation strategies.

Since 1999 all Australian states and territories have either introduced or strengthened voluntary and/or mandatory responsible gambling and harm minimisation measures.

It should be noted that various states had already limited the physical access to ATMs in the casino environment, either in legislation or codes of practice, prior to the findings of the Productivity Commission.

4.1.2 Regulatory framework

Responsible gambling and harm minimisation legislation and regulation varies between states and territories. The only common legislation adopted by all states and territories is prohibiting minors from gambling and the provision of credit (by the gaming venue to the patron).20

Responsible gambling and harm minimisation measures have been implemented in each state via:

  • mandatory Acts and Regulation;
  • voluntary Codes of Practice either implemented and administered by government regulators and/or other industry stakeholders; and
  • a combination of regulation supported by codes of practice.

It is clear the extent of regulation varies between gambling sectors (e.g. gaming machines, wagering, lotteries) within each state and territory. In general, the regulation of gaming machines in licensed gaming venues (casinos, clubs and hotels) is tighter than other forms of gambling. This is a result of the increased prevalence of gaming machines and the community’s concerns regarding this prevalence and the perceived ‘harm’ associated with gaming machines.

The following table summaries the extent of state and territory regulation of ATM and EFTPOS accessibility and functionality.

Table 1: ATM and EFTPOS access and functionality by Australian states and territories
State Date Legislation/Regulation Regulator Focus of Regulation Cash Facility Type Physical location outside gaming/ gambling area No cash advances on credit card or EFTPOS of ATMs 21 Daily and/or transaction limits Comments
TAS   Code of Practice - Provision of cash for gaming. Referenced by Rule 11 of the Gaming Control Act, Tasmanian Gaming Commission Rules. Tasmanian Gaming Commission Licensed premises gaming operators (hotels, clubs and casinos) EFTPOS. ATMs not allowed in licensed premises (except the casinos). EFTPOS not allowed in gaming area or in close proximity to keno or coin change areas. EFTPOS not allowed to access cash from credit cards. N/A Cash can be provided if staff satisfied patron is not experiencing difficulties with gaming.

All transactions done in good faith. If cash from a particular transaction is used (in part) for gaming then no further transactions allowed unless staff satisfied the second transaction not used for gaming or staff did not know the first transaction was used for gaming.

If cash is provided in good faith and the patron uses cash for gaming, the person will be required to leave the restricted area.

Signage is displayed at machine promoting responsible gambling.
NSW Apr ‘00 Gambling Legislation Amendment (Responsible Gambling) Act 1999/ Regulations 2000 included harm minimisation/ responsible gambling measures across all forms of gambling. Following the implementation of this Act, relevant changes were made to the specific acts/regulations governing the various forms of gaming/gambling to bring them in line with the legislation in the Responsible Gambling Act. New South Wales Department of Gaming and Racing Responsible gambling measures applied to all forms of gambling however ATM/EFTPOS access only applied to hotels and clubs. ATMs and EFTPOS Cash facilities must not be located in areas where gambling activities are conducted. This regulation already applied to the Casino. Debit only - No cash advance capabilities allowed via EFTPOS or ATMs. N/A Where ATMs and EFTPOS terminals are located at a racecourse or TAB, the Gambling help line number must be displayed;

The Act regulated the requirement for the peak industry bodies of hotels and clubs in NSW to develop a Responsible Gambling Code of Practice.
  Apr ‘02 New Gaming Machine Act 2001/regulation 2002 - The regulation confirms harm minimisation measures and controls over hotel and clubs operating gaming machines. Casino Control Act 1992. New South Wales Department of Gaming and Racing. Licensed premises gaming operators (hotels and clubs) - new regulations will be incorporated in the Casino Control regulation 2001. ATMs and EFTPOS ATMs and EFTPOS facilities not to be located in an area where gaming machines are located. Debit only - No cash advance capabilities allowed via EFTPOS or ATMs. N/A Prohibition on location of cash dispensing facilities (ATMs/EFTPOS) introduced as part of the Liquor Amendment (Responsible Gambling) Regulation 2000 and Registered Clubs Amendment (Responsible Gambling) Regulation 2000. These regulations allowed venues to apply for exemptions to the restrictions on the basis of geographic location of venue, venue layout, access to other facilities within 5km, transaction traffic.

New Gaming Machines Regulations 2002 encapsulates both changes, and the Liquor Administration Board has discretion for allowing exemptions on the grounds detailed above. It is intended the new regulations will be introduced to the Sydney Casino.
SA Jan '02 The Statutes Amendment (Gambling Regulation) Act 2001/regulations 2002 implemented changes to the Gaming Machines Act 1992. Office of the Liquor and Gambling Commissioner Licensed premises gaming operator. ATMs and EFTPOS. ATMs and EFTPOS facilities not to be located in an area where gaming machines are located. Cash advances allowed on credit cards via EFTPOS and ATMs. Transactions limited to one transaction to a maximum of $200 cash for any one debit or credit. On a date yet to be proclaimed, cash facilities on the premises are not allowed to enable a person to obtain cash more than once on any debit or credit cards on any one day.

Under the powers of the Act, the Gaming License Holders must formulate and adopt a Code of Practice. To date the Casino has a draft code with respect to responsible gaming.
QLD   QOGR guidelines for applicants for Gaming Machine Licenses or increase in gaming Machines Queensland Office of Gaming Regulation Queensland Office of Gaming Regulation (QOGR) Licensed premises gaming operators (hotels and clubs) ATMs and EFTPOS. ATMs and EFTPOS facilities not to be located in gambling area (including TAB/keno outlets). Patrons must not have to go through gaming area to access cash facilities. Debit only - No cash advance capabilities allowed via EFTPOS or ATMs. N/A Guidelines are not retrospective.
  29/5/02 Queensland responsible Gambling Code of Practice. Gambling Policy Directorate of Queensland Treasury with advice from the Responsible Gambling Advisory Committee. Hotels, clubs, casinos, TAB, keno, race clubs, lottery agents, bingo operators. ATMs and EFTPOS ATMs not to be located in close proximity to gambling areas. (Applicable to Casino, clubs, hotels and Keno outlets). Debit only - No cash advance capabilities allowed via EFTPOS or ATMs. N/A Following a review of voluntary compliance, minimum standards may be set and codified into legislation.

The Government will retain the right to legislate in any area of gambling at any time.
ACT Draft form Gambling and Racing Control Regulations 2001 (draft) incorporating Gambling Industry Code of Practice. ACT Gambling and Racing Commission All operators in the ACT gambling industry. ATMs and EFTPOS ATMs not to be located in close proximity to gambling areas. Debit only - No cash advance capabilities allowed via EFTPOS or ATMs. N/A The Gambling and Racing Control Act provided for the development of an industry wide Code of Practice.

The Code is contained within the Gambling and Racing Control Regulation (in draft form). The Code included a discussion paper and community consultation/submissions.
  Draft form Gaming Machine Act ACT Gambling and Racing Commission Licensed premises gaming operators (hotels and clubs). ATMs and EFTPOS Not permitted in the gaming area of the licensed premises. Debit only - No cash advance capabilities allowed via EFTPOS or ATMs. N/A The ACT Gambling and Racing Commission is in the process of reviewing the Act. A policy paper has been developed based on submissions as party of a consultation process, interstate developments and research commissioned by the Commission.

The Commission is considering the removal of ATMs from the licensed premises, removing the access to credit accounts and potentially limit on the daily cash amounts (incorporated in the Code of Practice).
WA   No formal regulations due to size of industry. There are no gaming machines outside of the casino. Western Australian office of Racing, Gaming and Liquor. Casino. ATMs and EFTPOS ATMs and EFTPOS not to be located in close proximity to the gaming area. Debit only - No cash advance capabilities allowed via EFTPOS or ATMs. N/A  
NT Aug '01 Gaming Machine Act. By direction of the Director of Licensing. (Under section 161 of the Act - directions and guidelines issued from time to time. Northern Territory Treasury - Racing, Gaming and Licensing. Hotels and clubs. ATMs and EFTPOS Not to be located in proximity to gaming products. Debit only - No cash advance capabilities allowed via EFTPOS or ATMs. Yes, see comments Withdrawal from EFTPOS in excess of $250 per day is required to be approved by a licensed Gaming Machine Manager.

Patrons should be able to access ATMs and EFTPOS machines without going through the approved gaming area.
VIC   New Gaming Legislation (Amendment) Bill 2002 (passed 11/6/02) introduces regulation of ATM and EFTPOS facilities in the Casino (Casino Control Act 1991) and clubs and hotels (Gaming Machine Control Act 1991). Victorian office of Gambling Regulation. Casinos, hotels and clubs. ATMs (EFTPOS not addressed in current legislation). ATMs not allowed in gaming area - outlined in the Casino and Gaming Authority rules. Debit only - No cash advances from credit cards allowed from ATMs in hotels and clubs however the same rule did not apply to the Casino. A limit of $200 in any one transaction from a debit or credit card New bill introduces new sections to the respective Acts to strengthen ATM/EFTPOS physical access and functions;

ATM/EFTPOS facilities not allowed in gaming areas. With respect to Casino, they must be a distance of 50 meters between casino entrance and cash facility;

Cash advances from credit accounts banned.

In summary the table indicates that:

  • all states and territories have banned ATM and EFTPOS facilities in the gambling/gaming area of the licensed gaming venue; 
  • it is generally accepted that EFTPOS facilities are restricted from payment for gambling products, and ‘cash out’/ ‘cash advance’ capabilities via credit cards. However credit cards can be used for food and beverage purposes in licensed gaming venues;
  • South Australia is the only state that allows cash advance transactions linked to credit from ATMs;
  • the extent of regulation varies greatly between states and territories. For example, in Queensland restrictions to the access of ATM and EFTPOS facilities is incorporated in the recently introduced Queensland Responsible Gambling Code of Practice. The Code is voluntary and covers all forms of gambling.
  • The Code allows for the legislation of minimum standards (within the Code) if there is no evidence of voluntary compliance; and in contrast, NSW introduced ‘umbrella’ mandatory responsible gambling legislation (1999), and subsequently strengthened ATM/EFTPOS legislation with respect to access in the gambling venue.

4.1.3 Harm minimisation/responsible gambling measures

The following section identifies approaches taken by the states and territories to limit ATM/EFTPOS functions in gaming and gambling venues.

4.1.3.1 Tasmania – licensed venue operator responsible to monitor transactions

In addition to banning the location of cash facilities in the gambling/gaming area, Tasmania further restricted the access to cash by banning ATMs from licensed gaming premises. This measure supports the key theme of the Tasmanian Code of Practice being the responsibility of staff to monitor withdrawals and ensure the cash withdrawn is not being used to participate in gaming.

This Code places responsibility solely with the licensed gaming venue operator and staff. The guidelines state:

If cash is provided as part of a transaction and that cash is used for gaming, then no further cash transactions will be permitted unless the staff member:

  • Is reasonably satisfied that the cash being obtained will not be used for the purpose of gaming; or
  • Could not reasonably be expected to know that the first transaction was used for the purposes of gaming

If cash is provided under the above circumstances but the patron uses the cash for gaming, then the patron is required to leave the restricted gaming area.22

When the Tasmanian Gaming Commission first developed the rules in September 1999, the guidelines banned ATMs from licensed gaming venues and EFTPOS facilities were not to be used for dispensing cash. This was opposed, particularly by rural venues where patrons relied on EFTPOS transactions because banks had left their community. Therefore the guidelines were amended to allow cash dispensing from EFTPOS.

To date the regulator has suggested the key factor limiting the overall effectiveness of the various codes of practice is the inability of venue operators to monitor multiple transactions by patrons, particularly in larger licensed gaming venues. Gaming patrons who wish to utilise multiple EFTPOS transactions for gaming purposes will wait until staff at a particular venue change shifts or will access cash from another area of the venue to avoid detection. Similarly, venue operators have claimed difficulty in enforcing the Commission’s rules due to the large number of staff working at venues.

In an effort to ensure compliance, the Commission requires venue operators to develop internal controls to ensure compliance with the Code and Rules. The most common approach adopted by venues is additional signage and authorisation of EFTPOS withdrawals by senior gaming staff.

4.1.3.2 South Australia- Limitations on the number and dollar amount of ATM and EFTPOS transactions, issues with implementation and impact

The South Australian Government introduced legislative amendments (effective January 2002) to the Gaming Machine Act 1992 introducing a cash withdrawal limit of $200 per transaction from any one debit or credit card in gaming venues. To date South Australia is the only state or territory to introduce transaction limits (Victoria has passed legislation but it is yet to be implemented).

The legislation still allows multiple transactions of $200 amounts. The only restriction cap is the multiple amounts reaching the maximum daily cash withdrawal limit per card imposed by the bank, a feature of all credit and debit cards.

With respect to the successful implementation of this legislation:

  • all the banks have the capacity to introduce the $200 limit per transaction to ATMs. It is the responsibility of the individual licensed gaming venue to contact the bank and request the software change as the banks are unable to identify ATMs in licensed gaming venues to implement a ‘blanket’ change;
  • as at the time of implementation (January 2002) only Westpac and the Commonwealth bank had the software/technical capabilities to introduce the limit to the EFTPOS systems (again at the request of the individual venues). The South Australia regulator has been advised by ANZ and NAB that system upgrades are required to enable EFTPOS cash withdrawal limits to be introduced. As yet there is not time frame for implementation; and
  • in the interim the regulator has requested individual gaming venues to introduce internal management practices/controls to ensure the $200 transaction limit is enforced.

Given the relative short period since the legislation was introduced (January 2002) there is no available data regarding the effectiveness and impact of this legislation on gambling stakeholders.

To further strengthen the limit on transactions, the South Australian government has legislated (on a date yet to be proclaimed) to restrict a patron to one transaction per debit or credit card per day to a maximum of $200 at a licensed gaming venue.

Considering the current software issues impeding the successful implementation of the first phase of the legislation, it is suggested progression to the next phase will be determined by the pace of software development by the banks.

We understand the effectiveness of phase two of the legislation is reliant on the EFTPOS and ATM systems being linked and having the capacity to monitor transactions within an individual gaming venue. We understand the banks have advised the South Australia regulator the two systems do not currently have the capacity to interact.

4.1.3.3 ACT – review of the current regulation of gambling, issues to be considered

The ACT is currently developing a voluntary Code of Practice for all forms of gambling in the territory (under the legislative power of the ACT Gambling and Racing Control Act 1999).

The Code specifically addresses the location of ATM and EFTPOS facilities, providing support to the relevant Acts regulating casino gaming, gaming machines and betting.

The following issues were considered by the regulator in developing ATM and EFTPOS guidelines within the Code:

  • Should there be a restriction on gaming licensees on the provision of facilities that enable a patron to access cash at a gaming licensee’s premises? And if so, what should the restriction be?
  • The ACT Gaming Machine Act 1987 provided for cash facilities to be located outside the gaming area. However in many cases the facilities were located within a few metres of gaming machines. Should cash facilities be excluded from the licensed gaming premises altogether?
  • Should the Code only permit cash withdrawals from cash facilities that require a patron to interact with staff, thus removing the anonymity of ATMs and making excessive and repeat withdrawals obvious?
  • Should all cash facilities be restricted to a cash withdrawal limit that would permit other forms of entertainment, but restrict excessive expenditure on gaming?
  • Should ATMs located at a gaming venue display screen messages in relation to responsible gambling and problem gambling?
  • Should it be mandatory for cash facilities provided by a gaming licensee to show account balances following each transaction?
  • Should there be a restriction that prohibits access to credit accounts through cash facilities in licensed gaming premises?23

After considering the above issues the following regulations with respect to cash facilities in the gambling environment were adopted in the draft Code of Practice:

  • a gambling licensee for a facility must not place a cash withdrawal facility so that it can be seen from the gambling area of the facility; and
  • the gambling licensee must not install or make available for gamblers an ATM or EFTPOS facility in the facility from which cash can be withdrawn by the gambler from the account other than a savings or cheque account.

In addition to the development of a Code of Practice, the ACT Gambling and Racing Commission is in the process of reviewing the Gaming Machine Act 1987 to ensure the Act ‘meets the needs of the ACT community’.

The Commission developed a Policy Paper (December 2001) based on public consultation, developments in other states and territories, recent research projects completed by the Commission and the Commission’s own experience. The following points specifically relate to the discussions in the Commission’s Policy Paper (December 2001):

  • public responses to the Policy Paper suggested the removal of the capability of EFTPOS facilities to issue cash. The Commission questioned this measure because EFTPOS ensures provider/customer interaction and excessive transactions by the customer may become obvious to the provider;
  • the Commission considered the restriction to debit accounts only via EFTPOS and ATMs had some merit, as adopted in some other states. However one consideration was the use of credit cards by patrons for food and beverage purchases;
  • a total ban on cash facilities in licensed gaming premises was dismissed by the Commission because it ignored the other uses of cash facilities by patrons at the venue;24 and
  • overall, the Commission questioned the benefit of restrictions on the availability of cash through cash facilities as an effective harm minimisation strategy. The Commission suggested:
    • problem gamblers will simply open different accounts and/or withdraw money from different outlets;
    • any cash withdrawal limit would still allow significant cash withdrawal (eg $200 per day is still $1400 per week);
    • there are many other sources of cash that can be accessed if the person wishes to (eg: go to the bank during the day in preparation);
    • restrictions on withdrawals were likely to be a major inconvenience to other patrons;
    • patron safety in withdrawing money in a venue rather than on the street is a major factor to be considered; and
    • problems of changing software of ATMs only in gaming venues.

In 2001 the Commission engaged the Australian Institute of Gambling Research (AIGR) at the (University of Western Sydney) to undertake a ‘Survey of the Nature and Extent of Gambling and Problem Gambling in the ACT – July 2001’.

The AIGR survey replicated the Productivity Commission National Gambling Survey question regarding the extent gambling participants used ATMs at a venue when playing poker machines. It should be noted the AIGR survey refined the question to link the withdrawal of money from an ATM for direct use in gaming machines. The following table shows the results of the AIGR survey compared with the Productivity Commission survey.

Table 2:  How often do you withdraw money from an ATM at a venue to play the machines? 25 PC National Survey 1999 and ACT Gambling 2001 Survey Results
Participant response Never or rarely (%) Often or always (%)
PC ACT PC ACT
Recreational players 90.0 88.9 4.6 3.2
Problem gamblers (SOG 5+) 47.0 38.5 37.8 46.9
Problem gamblers (SOG 10+) 25.2 10.2 58.7 73.6

The AIGR report commented:

‘the ACT 2001 survey indicated that problem gamblers in the ACT are 3 to 4 times more likely than recreational gamblers to withdraw money from ATMs for the purposes of gambling at the venue. These figures suggest that there is a positive correlation between problem gambling severity and the likelihood of using ATMs at the venue. These findings may have some bearing on debate concerning the relationship between withdrawal limits and accessibility to money and problem gambling prevalence’26

Based on the findings of the AIGR and the Productivity Commission surveys, the Commission considered the removal of ATMs from licensed gaming venues, as opposed to removal of both ATMs and EFTPOS from venues. The Commission suggested the benefits of EFTPOS only facilities were:

  • patrons generally withdraw lower cash limits (via limits imposed by the venue). The venue can also impose maximum withdrawal limits (as is the case in some retail outlets) or a limit could be imposed via the Code of Practice;
  • staff would become aware of repeat transactions by patrons. This ‘exposure’ may support identification of potential problem gamblers, promotion of self exclusion, promotion of problem gambling counselling/assistance or exclusions imposed by the licensed gaming premises;
  • patrons who wish to access cash are still able to do so via EFTPOS (from debit cards only); and
  • problem gamblers will be subjected to ‘breaks in play’ by either engaging with the EFTPOS operator of leaving the venue to access an ATM facility.

Based on the outcomes of the Policy Paper a Second Stage Consultation Paper has been issued for public comment. The Paper makes recommendations for changes to the Gaming Machine Act and the principles and approaches in developing these recommendations.

The Commission made the following recommendations as part of a number of harm minimisation measures:

  • ATMs to be prohibited from the gaming licensee’s premises;
  • the current restrictions on other cash facilities such as EFTPOS that prohibit them from being available within a gaming area should be maintained; and
  • the placement of ‘limits’ of the amount of cash available per day may be included in the mandatory Code of Practice (however no limit has been defined).

Essentially, if the above recommendations are adopted cash transactions would only be allowed on debit cards via EFTPOS facilities, with the potential for licensees to impose a limit on the number of cash transactions per day and/or a limit on the cash amount withdrawn.

At a minimum, the direct benefits may be: 

  • ‘breaks in play’ and loss of anonymity that is usually sought by excessive or problem gamblers;
  • no capability to access cash advances on credit cards; and
  • allow for the payment of food via credit or debit card and still have the capacity to access cash from debit cards.

The potential issues with such a model may be: 

  • identification of a suitable cash amount limit or number of ‘cash out’ transactions that strikes a balance between harm minimisation strategies and access to cash by recreational and non-gamblers;
  • the impact on services levels of venue staff and inconvenience to non gambling patrons; and
  • the technical issues surrounding implementation and monitoring.

4.1.3.4 Victoria – banning ATM cash advances and imposing transaction limits

Victoria recently passed legislation to strengthen the regulation of ATM and EFTPOS accessibility and functionality in gaming venues. Two of the key measures were:

  • a cash withdrawal limit of $200 per transaction from a debit or credit card; and
  • banning cash advances on credit cards from ATM machines.

It is our understanding the Victorian government has had positive discussions with the banking sector regarding the logistics of introducing the $200 transaction limit.

The above measures will effectively restrict patrons to accessing own cash funds (noting EFTPOS is not able to offer cash advance on credit cards).

4.1.4 Conclusions

In summary:

  • the states and territories have strengthened restrictions on the access to cash via ATM and EFTPOS following the findings and recommendations of the Productivity Commission;
  • the extent of ATM and EFTPOS regulation varies from state to state and between gambling sectors, for example, Tasmania has adopted an approach that places primary responsibility and accountability for responsible gambling on the venue;
  • South Australia is in the process of adopting mandatory limitations to restrict access to cash and credit taking away any responsibility from the gambler or the venue;
  • in each state and territory the regulation of ATM and EFTPOS has been one aspect of a range of responsible gambling measures. However considering the relative infancy of responsible gambling measures/programs there has not been any formal review of the effectiveness of the measures and the impact on the various gambling stakeholders;
  • the Productivity Commission National Gambling survey, and the ACT government commissioned survey showed a link between the frequent use of ATMs by problem gamblers however the scope of these surveys did not extend to exploring usage patterns of cash facilities by problem and recreational gamblers (i.e. number of transactions, average withdrawal, spending pattern of money withdraw, source of funds etc);
  • the regulators talk of a real need to conduct further research into this issue and collect baseline data on a national level to review. Both avenues of research would:
    • measure the effectiveness of the current regulations; and
    • assist with the formulation of more effective measurement and future evaluation.
  • regulators have identified that the problem to date has been an overall lack of specific research and baseline data into the linkages between problem gambling and access to cash, hence the current position where each state has implemented varied approaches to the same problem; and
  • all state and territory gambling regulators acknowledge the need to restrict access to cash and credit by problem gamblers and there is a general sentiment by regulators that there is a need for a consistent, national approach.

5. ATM and EFTPOS - International experience 

This section of the report reviews ATMs and EFTPOS in the international gambling environment.

In undertaking this desktop review we have focused on gambling in the United States, Canada and the United Kingdom considering the relative maturity of gambling in these countries and the increased focus of these countries on problem gambling.

This section of the report:

  • where possible, identifies state and Commonwealth regulation surrounding the use of ATMs and EFTPOS in the gambling environment;
  • identifies international research relating to access to cash facilities and the prevalence of problem gambling;
  • the impacts associated with the regulation of cash access; and
  • identifies issues within United States, Canada and the United Kingdom that have either promoted or inhibited the development of responsible gambling strategies, particularly with respect to ATMs and EFTPOS.

In undertaking the above research we have primarily completed desktop research, sending requests for relevant information to key stakeholders, including:

  • problem gambling and gaming industry research organisations;
  • gambling and gaming industry stakeholders, for example casino and gaming associations and the United States National Indian Gaming Association; and
  • relevant state and province gambling regulators.

In total, information requests were sent to 18 organisations, of which 10 responded.

5.1 United States

In the United States gaming licences are granted to private enterprise with the regulation and licensing conducted at a state level.

The following table highlights the extent of the various forms of gambling in American states:

Table 3: Total number of States by form of gambling in the United States of America 27
United States Gambling at a Glance
Form of gambling Number of states
Charitable bingo and/or games 46
Casinos and gaming 11
Indian Casinos 23
Indian Bingo 30
Lottery operated games 37
Parimutuel wagering (racing, wagering) 41

The American Gambling Association identified:

  • of the 50 states, only Hawaii, Utah and Tennessee have no legalised gambling;
  • in 1989 the United States Congress passed the Indian Gaming Regulatory Act (IGRA) allowing the development of casinos on Indian reservations. There are now approximately 260 Indian Reservation casinos in the United States;
  • gambling revenue generated from the Native American Casinos provides the primary source of funding for tribal governments;
  • gambling in each state is regulated by the states with the exception of Indian gaming which is regulated by the IGRA, a federal act;
  • in the early 1990s, the ‘riverboat states’ (Iowa, Illinois, Indiana, Missouri, Mississippi and Louisiana) commenced the operation of casinos on large riverboats; and
  • prior to 1990 only Nevada and Atlantic City allowed legalised casinos. There are now a total of 11 states offering commercial casinos. The state of Nevada alone offers approximately 430 individual casinos.

5.1.1 National Gambling Impact Study Commission (NGISC) Report

The NGISC report was the culmination of a two-year study into the social and economic implications of gambling in the United States. The Commission was created by public law and represented the most comprehensive review of the United States gambling industry.

The scope of the study incorporated six major themes:

  1. a review of existing policies and practices of all levels of government with respect to the legalisation of gambling;
  2. an assessment of the relationship between gambling and crime levels, and the regulatory practices to address the relationship;
  3. an assessment of problem gambling and the resulting social and economic impacts;
  4. an assessment of impacts on individuals, families, social institutions generally, the general economy, and particularly in depressed economic areas;
  5. an assessment of the extent to which gambling provided revenues to states, local, and Native American Tribal Governments, and the extent to which possible alternative revenue sources may exist for such governments; and 
  6. an assessment of Internet gambling and its impacts.

Based on the findings of the study, the Commission made a total of 76 individual recommendations. The recommendations centred on improvements to gambling regulation, problem and pathological gambling, Internet gambling, Native American Gambling and gambling impacts on people and places.

The following recommendation related directly to the access of ATM and ‘credit machines’

"7-1 Because the easy availability of automatic teller machines and credit machines encourages some gamblers to wager more than they intended, the Commission recommends that states, tribal governments, and pari-mutuel facilities ban credit card cash advance machines and other devices activated by debit or credit cards from the immediate area where gambling takes place’28

The following comments from the NGISC report give an indication of the current gambling environment in the United States. In particular, the forces driving problem gambling and harm minimisation regulation, the depth of problem gambling research, and the extent of legislation adopted by the states:

  • available information regarding the economic and social impacts of gambling is inadequate ‘for informed discussion let alone decision’29;
  • ‘in almost every state, whatever policy exists towards gambling is more a collection of incremental and disconnected decisions, than the result of deliberate purpose’30. One of the criticisms of the various levels of government involved in the gambling industry was the short term pursuit of revenues rather than the long term impacts on public welfare;
  • with respect to the regulation of the commercial casino environment, the NGISC suggests the states with casinos have adopted two very different approaches to their regulation, depending on the state government’s perceived public purpose of casinos:
  • the Nevada approach – weighted towards gambling as a business. The public purpose of gambling in Nevada being the maximising economic benefits (tax revenue, jobs, investment). This approach emphasises granting gambling a relatively free hand to respond to market demands (location, number of facilities, types of gambling, technological innovations). This approach to regulation has been a key factor in establishing Nevada as the centre of casino gaming in the United States; and 
  • the New Jersey approach – focuses on the potential negatives of gambling. The result being a more in-depth role with respect to regulation and monitoring. The casinos have a strict and comprehensive regulatory structure.

The NGISC recommended further research into the prevalence and causes of problem gambling as a priority. The Commission respectfully asked all states to act on all the recommendations surrounding problem and pathological gambling.

Following the release of the National Gambling Study Impact Commission report Congressman LaFalce of New York State introduced legislation to Congress in September 1999 (the Gambling ATM and Credit/Debit Reform Act) to remove ATMs, credit card terminals, debit card point of sale machines and other electronic cash machines:

  • from gambling halls (bingo halls); and
  • banning casinos and other gaming establishments from having ‘cash facilities’ on the gambling floor.

This bill did not proceed and was re-introduced by Congressman LaFalce in July 2001. It is understood the bill has been referred to the Congress Sub-committee on Financial Institutions and Consumer Credit and as yet has no co-sponsor.31

LaFalce argued the proposed legislation is implementing one of the major recommendations of the National Gambling Impact Study Commission.

The American Gaming Association (AGA) argue the NGISC recommendation was directed to the states as the primary regulators and any legislation at a federal level intrudes on the states rights to regulate gambling as they see fit, and sets a dangerous precedent. In addition, the AGA argues the wider ramifications of such legislation may extend to shopping centres,‘any place where those who want to impose their views on others who think individuals might be tempted to ‘overindulge'.32

The AGA president, Frank Fahrenkopf suggested that the bill would not find the necessary support.33 By comparison, this proposed legislation is considered the absolute minimum regulatory standard in Australia.

In March 2002 the American Gaming Association completed a review of the ‘Statues and Regulations in Commercial Casino States Concerning Responsible Gaming’. The following table shows responsible gaming measures (and restrictions on practicespromoting gaming).

Table 4: Indication of gambling measures by state within the United States of America34
Statutes and Regulations in Commercial Casino States Concerning Responsible Gaming
State Colorado Illinois Indiana Iowa Louisiana Michigan Mississippi Missouri New Jersey Nevada Dakota
Help line  

I

   

I

I

I

I

I

I

 
Advert. restrictions                

I

   
Alcohol service      

I

R

   

I

     
Credit restrictions  

I

 

I

R

 

I

 

I

I

 
Employee training      

I

R

I

I    

I

 
Empl. P.G. prev.        

R

           
Loss limits

I

           

I

   

I

Marketing/direct mail             I    

I

 
Signage  

I

 

I

I

I

I

 

I

I

 
Public awareness        

I

I I

I

     
Self exclusion  

R

   

R

I

I

I

I

   
Treatment funding    

I

I

I

I I

I

I

 

I

Table key:  I = Implemented  R = Regulated by yet to be implemented

The following comments relate to the above table:

  • there are currently no regulations in Colorado or Indiana that addresses problem gambling;
  • Illinois places restrictions on the issuing of credit and cashing of cheques by casino operators;
  • in Iowa a casino operator is not allowed to accept a credit card to purchase gambling products;
  • in Louisiana procedures prevent any person placed on a self exclusion list from having access to credit or from receiving complimentary services such as cashing cheques;
  • interestingly, Indiana and South Dakota have no formal responsible gambling regulation but funds are allocated for the treatment of problem gambling;
  • in Michigan, ‘Electronic Funds Transfer Terminals’ are not allowed to be within 50 metres of the casino floor. Taking the restriction a step further, Michigan has identified future technology as a risk and has prohibited the installation of any game that is played with a device that allows a player to operate the game by transferring funds from a debit or credit card;
  • in March 2000 a bill was introduced in Michigan to ban ATMs from the casino however the bill was opposed by the Bankers Association and was subsequently not passed; and
  • in Nevada a person may request to be placed on an exclusion list so credit cannot be extended to that person in any Nevada casino.

The table and associated comments highlight that responsible gambling and harm minimisation approaches by the United States are at best ‘patchy’. Even when some states have looked to regulate cash and credit access, the approaches are inconsistent. The impacts, if any, at this stage are unclear.

It is evident that the greater the reliance a state places on the gambling industry to support their economy, the greater the reluctance the regulator has to impose regulation that may significantly impact on gambling revenue.

The current federal bill before Congress, legislating a ban on cash and credit machines from the gambling area has struggled to receive support and suggests the overall reluctance of government and regulators to introduce any measures that may have a significant impact on the gambling industry.

Therefore it is unlikely the United States will accelerate further development of harm minimisation and responsible gambling legislation in the short term.

5.1.2  A case study – Iowa Racing and Gaming Commission – Credit machines and ATMS in the gambling environment

In 1999 the Iowa Racing and Gaming Commission (IRGC) introduced an administrative rule effectively prohibiting the location of ‘satellite terminals’ (ATMs and credit machines) on a gambling boat or within a racetrack.

This caused some concern and debate by the Administrative Rules Review Committee (a Committee chartered to review rules implemented by Iowa Government agencies/departments) because the rule sought to adopt failed legislation.

For several years the Iowa General Assembly debated a proposal to legislate the ban of credit machines however every proposal was unsuccessful. Therefore if legislating a ban was unsuccessful it was argued no rule could be made to have the same effect.

After some debate about the proposed total ban of credit machines and ATMs from the gambling venues, the IRGC compromised by amending the rule to ‘ban only those satellite terminals which give credit to the customer through the use of a credit card’ effectively allowing ATMs to remain at the gambling venue. In response the Administrative Rules Committee would allow the strengthening of this rule to move ‘ATMs (debit cards) away from the gambling floor’.

It is important to highlight the subtle differences in the mechanisms for gambling patrons to access credit. Credit machines fall into two categories, in both cases the licensed gaming venue operator does not issue credit, they only facilitate the issuing of credit by a financial institution:

  • in the first case, the customer inserts a credit card into the machine to initiate the approval process; a printer under the supervision of the venue staff then issues a cheque (which may be made out to the venue) for the loan amount. A service charge is imposed for this transaction. The customer then signs the cheque and is cashed by the venue. In this case the facility is actively involved in the transaction; and
  • in the second case, either the credit company (financial institution) employee controls the machine or the machine itself accepts credit cards and automatically dispenses a cash advance (similar to ATM capabilities in the Australian environment). In this case the venue plays a more passive involvement.

In the Iowa example, the IGRC argued that it had the authority to implement the rule to ban credit machines because the Iowa Gambling Code contained provisions such as:

  • banning venues from providing credit or loans; and
  • accepting credit cards as payment for gaming products.

The IGRC argued the ‘objective sought’ in those provisions was to prevent the immediate access to credit by the patron.

This raised the issue of whether statutory regulation prohibiting a venue from providing credit can extend to when the gaming venue is only a passive participant (only providing floor space).

The counter argument was that the legislation was only really intended to restrict gambling venues in Iowa from providing credit (the provision of credit by the venue to the patron is common in Nevada and New Jersey).

5.1.2.1 Access to casino credit

Casino credit is different from credit issued by commercial credit card companies and financial institutions. In some casino jurisdictions, cashing of cheques is the only form of credit offered (as in Iowa). In other jurisdictions casino credit is an expanded form of cheque cashing, in that ‘markers’ are signed by the customer as counter cheques. The period between when the cheque is signed and when it is presented by the venue to the bank is the defined time period for that credit. In the traditional sense, some casino states allow gaming venue licensees to issue lines of credit to approved patrons.

Access to credit in the casino states falls under the following categories:

  • a known, regular gambler at the individual casino – the gambler would have an established line of credit with the casino. Generally, the state regulators do not regulate/monitor these arrangements. The issuing of a line of credit is at the discretion of the individual casino;
  • an unknown gambler who requests to play on credit. The gambler must pass a credit check (undertaken by a third party organisation on behalf of the casino) and a line of credit is established;
  • cash advances on credit cards via the cashier’s cage. As noted in the Iowa case, the casino takes a passive role in the extension of this form of credit; and
  • cashing of cheques, which may be seen as a short-term extension of credit.

The research would indicate that regulating the access to credit (directly from the casino or a financial institution) is of greater significance than the regulation of ATM machines in the United States gaming environment.

5.2 Canada

The Canadian gambling industry is based on the concept of charity gaming with all casino gaming facilities owned by the government. All profits from gambling must be for a charitable cause. The government is effectively the gaming operator and main beneficiary. The following table shows the extent of the various gambling forms in Canada.

Table 5: Total number of provinces and territories by form of gambling in Canada35
Canada Gambling at a Glance
Form of gambling Number of Provinces and Territories
Charitable bingo and/or games 12
Casinos and gaming 7
Native Casinos 2
Native Bingo 9
Lottery operated games 12
Parimutuel wagering (racing, wagering) 12

There has been significant growth in the Canadian gambling industry since the introduction of slot machines and full-scale casinos. There are approximately 60 casinos in Canada. With this growth there has been an increase in the level of public scrutiny of the industry. The research was unable to locate specific information with respect to the regulation of ATMs/EFTPOS in Canadian casino environment, other than within British Columbia where ATMs are not allowed within the casino.

Given the growth of the industry and the potential conflicting interest of the government there has been an increased requirement for transparency in policy, accountability and a greater focus on the social costs of the expansion of gambling.

As with the United States the regulation of gambling varies significantly between provinces. However a number of provinces have established agencies to undertake problem gambling research and community education to address the social costs associated with gambling.

Again, as with the United States, the progression of harm minimisation and responsible gambling initiatives are in their infancy and have not extended beyond identifying the requirement to undertake further research into problem gambling and further development of existing harm minimisation and responsible gambling programs.

5.3 United Kigdom

In examining the gambling industry in the United Kingdom the research examined the Budd Report. This report has been highly controversial and has generated much debate within the community and gambling sectors. The following is a brief overview of the findings of the report.

5.3.1 The Budd Report

In July 2001 the Great Britain Department for Culture, Media and Sport (principal agency for the regulation of gambling in Great Britain) completed a review of the Great Britain gambling industry (the ‘Budd’ report).

The terms of reference included:

  • a review of the current state of the industry and potential changes in the future considering trends in e-commerce, general leisure and entertainment trends and international trends in gambling;
  • the social impacts of gambling and the costs and benefits;
  • making recommendations for the kind and extent of regulation with regards to:
    • the need to protect the young and vulnerable;
    • preventing gambling being carried out that promotes crime;
    • preventing gambling being infiltrated by organisation that promote money laundering;
    • creating an environment that allows creates commercial opportunities and maximises the UK’s economic welfare; and
    • consideration of the availability and effectiveness of problem gambling programs and recommendations to improve this facet of the industry.36

The scope of the review was broad given it was the first significant review of all forms of gambling in Great Britain. As a result there was significant focus on reviewing and updating legislation and regulation of the industry, which was, in some instances long overdue.

5.3.2 Provision of credit and access to ATMs

The current position is that Casino operators cannot provide credit. Payments for chips must be by cash, cheque or debit card. Cheques can also be exchanged for cash therefore this is one form of short-term credit. Unlike the Australian environment, gaming machines can only be operated by coins or tokens.

The Budd report acknowledges cheques used to pay for gambling in the casino environment may be linked to overdraft facilities offered by Banks (a form of credit). Similarly, people are able to use credit cards to withdraw cash from ATMs, which were increasing in prevalence in arcades in the UK. It should be noted that ‘arcades’ refers to amusement arcades that allows minors to access gaming machines (low betting and winning limits).

In the bingo club environment, ATMs are being installed that can only accept debit cards. The Great Britain Gaming Board has negotiated with the British Casino Association to limit ATMs to debit cards only.

During the course of the review, the British Casino Association (BCA) suggested that credit cards should be accepted in the casino environment on the basis that it would be inconsistent to allow the use of cheques on overdraft accounts but not allow credit cards. The BCA also argued that credit cards have the capacity to reject transactions if limits are exceeded; however the same could not be said for cheque transactions.

Ultimately the Budd report recommended that credit cards be permitted to purchase gambling products (chips), which are not able to be used in poker machines in the casino environment. The review panel could not distinguish between a casino ‘chip’ and any other product that people purchased via their credit cards. The Budd report considered gaming machines to ‘present special opportunities for fast and repetitive play: adding credit cards to the mix would further add to the risk’.37

Therefore the Budd report recommended banning both debit and credit cards from being used for the payment of gaming machines. With respect to the availability and location of ATMs, the Budd report recommended:

‘The location of ATMs should be required to be such that players have to take a break from gambling to obtain more funds. The Gambling Commission should issue guidelines setting out the restrictions on where ATMs may be situated’38

The Budd report acknowledged international trends regarding the relocation of ATMs was the driver for this recommendation.

5.3.3 Conclusions

The majority of the recommendations of the Budd Report focused on improved regulation and legislation of gambling in Great Britain, particularly in light of the ‘criminal element’ that may have existed in the past.

In part, some of the recommendations in the report are contradictory and have been quite controversial. For example, continuing to prohibit gambling in hotels whilst allowing the growth in casinos (in the UK environment these are similar to clubs in Australia). Or, allowing credit cards to be used to purchase gambling in the casino environment whilst restricting the location and function of ATMs in the gaming machine environment.

It is suggested the contradictory nature of the report is due to the need for a review of gambling in Great Britain with a goal of improving the gambling environment for the majority of participants, at a time when there is an international focus on problem gambling.

5.4 Summary – international and Australian environment

Despite the relative size of the gambling industry in the United States, United Kingdom and Canada, there is an overall absence of integrated regulations supporting responsible gambling and harm minimisation initiatives. Some states are more advanced than others in this area however even the ‘progressive’ states have an ‘ad hoc’ approach that does not assist in the development of effective regulatory packages.

To date restrictions to the access and functionality of cash access facilities have not been a priority by the respective state and local governments.

The key findings of the review of current regulation and research surrounding ATM and EFTPOS in the international and Australian environment in the gambling environment are:

  • the extent of cash and credit access in the United States is very prevalent, and there is a perceived reluctance by the majority of stakeholders in the industry to ‘over regulate’ gambling. As a result the progression of problem gambling research and the implementation of harm minimisation and responsible gambling measures is relatively slow;
  • all Australian states and territories have acknowledged the need to regulate access to cash and credit in the gambling environment and all have adopted varied approaches in addressing this issue. The key reason for the varied approaches is the lack of specific research to identify measures that would have a positive impact on problem gamblers; and
  • in saying this, it is not suggested that the current approach adopted by the states and territories will have no positive impact. However, there is currently no benchmark data or continued data collection to measure the effectiveness of these approaches over time.

6. Community sector 

Within this area of research community representatives on the National Advisory Body on Gambling and the Community Service Ministers Advisory Committee were approached to contribute their views. In addition representatives from other key services such as gambling support services and community support agencies were approached.

The key issues identified from the responses were:

  • Self-exclusion - A number of stakeholders indicated that self-exclusion provides a good solution to balancing the needs of all consumers. Self-exclusion was seen to allow the person with the gambling problem the capacity to address their needs without infringing on the rights of others. The capacity to implement self-exclusion deeds whereby an individual self-excludes themselves from the ATMs in all casinos and gaming environments was an option put forward. This allows people to limit their own behaviour whilst not negatively influencing the broader community group. Others referred to the need to include a third party as part of the self-exclusion program. This could be someone like a problem gambling counsellor who together with the individual maintained authority to put in place exclusion conditions.
  • Impact on families - The opportunity for problem gamblers to access credit accounts through ATMs in gambling venues and the impact of credit based gambling on household incomes was raised as a particular concern. The flow effect of problem gamblers’ actions was deemed a very difficult management problem.
  • Impact on the social gambler – The opinion here was quite mixed with several stakeholders citing studies that indicated that social gamblers do not in the main use ATMs in gaming venues and studies highlighting the overuse of ATMs by problem gamblers in these venues. This group believed that the inconvenience to social gamblers if ATMs were removed was minor.
  • Rural and regional centres – Several stakeholders referred to the need to recognise the diversity of roles played by hotels across Australia. In particular, the family hotel in rural and regional centres that operates in a different environment to metropolitan based hotels. With the departure of banking facilities from rural and regional towns, hotels are taking on a greater role as financial providers in their respective communities. Others disputed this indicating that people under the age of 18 years in rural communities cannot access cash through hotels or gaming venues and that there are other facilities available in these communities for accessing cash such as post offices or supermarkets.
  • Availability of ATMs – Most stakeholders perceive that ATM and EFTPOS facilities at gaming venues provide ready access to cash to people with gambling problems. Several stakeholders believed that ATMs were too accessible in gaming venues and whilst not present on the gaming floor they were within easy reach. Several advocated strongly that they be removed from gaming venues altogether. All agreed that ATMs should be removed from gaming floors.

    Stakeholders referred to the Productivity Commission’s report where it was identified that social gamblers in the main don’t use ATMs at gaming venues and thus the impact would be marginal.

    Other views however suggested that ATMs located outside hotels and gaming venues were more susceptible to crime and that forcing people to leave the venue to access an ATM would exacerbate this.
  • Fixed limits on transactions - Several stakeholders saw the current debate around fixed limits as problematic. There is concern that the limit be high enough to be practical but not so high as to cause problems for people on limited fixed incomes (such as pensioners) with gambling problems. Others advocated for fixed cash limits per person per account per day, rather than one limit as people have access to multiple accounts. If this was not possible then it was suggested that there be a limit on the number of withdrawals a person could make per day.
  • Access to credit and cheque cashing – Most stakeholders indicated a strong view that access to credit should be unavailable in gaming venues. In addition, many indicated that people should not be able to cash cheques as this was another key source of ready cash that could be used for gambling.
  • Educational strategies - The need to support any changes with adequate education of patrons with regard to informing why limitations are applied to ATM and EFTPOS facilities in gaming venues was raised by most stakeholders. The view was expressed that if people were well informed of requirements then the impact would be minimal. Other strategies related to responsible gambling messages on screens of machines that could alert customers to self-exclusion facilities, gambling support services and help lines.
  • Shared responsibility - A number of stakeholders referred to the need for all stakeholders to accept some responsibility for the identification and implementation of harm minimisation strategies. There was a strong sense that unless all key stakeholders such as the banks, venue operators and policy makers worked together that the capacity for strategies to be successful was limited. Some stakeholders within the community services sector see the financial and gaming sectors as resistant to considering strategies with regard to ATM and EFTPOS facilities and functions.
  • Future legislation/regulation – Several stakeholders commented that the focus of future legislation and regulation should be preventative with the view advocated that any product that is harmful to members of the community needs to be regulated and controlled.
  • National approach – There was consensus from all stakeholders that there should be an agreed national approach to dealing with the issues associated with problem gambling, including regulation and legislative responses.

6.1 Summary

In summary, there is a diversity of view with regard to ATM and EFTPOS facilities in gaming environments and associated harm minimisation strategies. All supported the investigation of placing cash limits and removing access to credit within the gaming environment. All agreed that reducing access to cash was important as part of a range of harm minimisation strategies.

Some respondents are supportive of measures to remove ATMs from the gaming environment but not from the premises altogether and others believed they should be removed altogether. Any limits placed on ATM and EFTPOS functionality and capability need to take into consideration the needs of the community for financial services.

There was a strong view that self limiting by people was a useful strategy as well as direct assistance measures such as gambling help signs and telephone numbers around ATM and EFTPOS facilities.

7. Gaming industry associations 

The purpose of the consultation with the gaming industry peak bodies was to obtain the gaming sector’s collective views on potential changes to ATM and EFTPOS access and functionality in the gaming environment.

7.1 Key issues

The following table represents the comments provided through the consultations and reflect the diversity of views within the gaming sector.

Table 7: Key issues that came forward through consultation with the gaming sector operators
Impacts / Issue Comments
One withdrawal limit – promotes maximum ‘cash out’
  • Promotes people accessing maximum available cash regardless of need. This potentially promotes increased spending habits.
  • Potentially encourages patrons to access cash from a bank branch en route to the venue. Daily limit applying to ATMs is generally $1,000; within the branch environment no withdrawal limits apply. Withdrawal limits may potentially promote the problem.
Lack of research and data
  • No research conducted to date on this issue.
  • No evidence that restricting cash access has positive impacts on problem gamblers.
Problem gamblers access cash outside gambling environment
  • Problem gamblers will change habits and access cash via other ATMs and EFTPOS facilities outside the gambling environment. Urban areas offer regular opportunities to access cash.
Security risks
  • Patrons having to leave premises to access funds promotes personal security risks.
Negative economic impact on regional areas
  • In some rural communities EFTPOS and ATMs at gaming venues are the only avenues to access cash (no bank representation). The inability to access sufficient cash for day-to-day use promotes shift in consumer spending to those communities that have bank facilities and a reduction in consumer spending in the local community.
  • Rural communities can least afford further impediments to economic sustainability.
Venues do not just provide gaming
  • Casinos in particular offer a range of entertainment and accommodation options and are seen as a destination. Domestic and international guests make the conscious decision to visit casinos. Moving ATMs outside the casino premises would have significant negative commercial impacts
Models introducing withdrawal limits (cash and no. of transactions)
  • Some associations have already had considerable dialogue with the banking industry on ATMs and it has been suggested limits on transactions and dollar limits in venues is unworkable.
Self imposed limits
  • Introduction of technology/infrastructure that allows gamblers to set own gambling limits.
Government should focus on promoting responsible gambling
  • As opposed to promoting the issue of problem gambling, which implies all people who gamble have a problem.
Increase focus on problem gambling treatment
  • Increase focus on treating the individual problem gambler as opposed to gambling product modifications;
  • The government focuses on providing assistance programs to treat alcoholics, not modify the liquor products. The same approach/focus could apply to the treatment of problem gambling.
  • NSW and Victoria governments have recognised that substantial modifications to products will not assist the majority of problem gamblers.
ATM and EFTPOS issues debated and regulation changes at a State and Territory level
  • Gambling Associations have presented numerous submissions and continued discussions/negotiation with state and territory governments with respect to harm minimisation strategies (including ATM and EFTPOS). This has result in changes to the current regulatory position. There is concern by some operators that a national approach to this issue may potentially ‘unravel’ the progress that has been achieved to date.

In addition, in 2001 the Australian Casino Association (ACA) undertook an independent survey research into the attitudes of Australians to gambling. The survey was based on a sample size of 3,000. The research indicated that only 3% of respondents felt access to ATMs was a cause of problem gambling.39

The ACA suggested the advancement of cashless/card-based gaming might contribute to excessive expenditure. ‘Our members have flagged concerns with any moves to cashless gaming. Australians in general use ‘plastic’ cards poorly as shown in recent credit card debt reports. Patrons place little to no value on a plastic card or token, but understand coin and notes as having real value’.40 It was suggested by some respondents that market forces will dictate the uptake of technological advances in the gambling industry.

7.2 Summary

The underlying messages from the gaming operators were:

  • research and data collection that either supports or rejects the need to introduce changes to ATM and EFTPOS (and other harm minimisation measures) is needed; and
  • measures that can identify problem gamblers, rather than generic strategies which may have a negative impact on recreational or non-gamblers is required.

8. Financial services sector 

The following diagram highlights the relationship of the financial services sector to the ATM/EFTPOS device and the gambler.

This diagram highlights the relationship of the financial services sector to the ATM/EFTPOS device and the gambler

8.1.1 ATM/EFTPOS functionality

The first area of interest examined was the current functions of ATMs and EFTPOS within Australia and internationally.

The research focused on identifying the functionality of both bank and non-bank ATMs including accessibility to various product facilities. A complete report on this area of research can be found at Appendix D. From this research a series of issues were identified.

  • Accessibility of accounts is increasing - The rise of off-premise payment devices has led to increased account accessibility for account holders. Off-premise payment devices include bank and non-bank ATMs, EFTPOS terminals, and evolving payment channels, such as mobile telephony.

    Both the number of bank and non-bank ATMs and EFTPOS in Australia have strongly increased over recent years.

    Bank ATMs tend to be located at bank branches, retail areas and other high consumer traffic areas. Non-bank ATMs are focussed on areas with high consumer traffic where convenient access to funds is desired. Recently, there has been growing numbers of ATM placements in grocery stores, petrol stations, and smaller merchant stores.

    ATMs are available in a variety of sizes, with differing functionality to suit various environments and purposes. For example, ATMs at bank branches tend to be larger with extensive financial transaction functionality; where as ATMs in merchant stores tend to be small to accommodate limited space.

    In the United States, ATMs have been designed specifically for the gambling environment. They have developed numerous ATMs that deliver fast and ready access to accounts. These include ATMs that are built onto the individual gambling machine, and ATMs that offer PIN-less credit card cash advances.
  • Use of payment devices is increasing - Account holders are accessing their accounts more frequently, and withdrawing greater amounts. This holds true for both credit card accounts and debit card accounts. This may be due to increased availability of the payment channel by merchants, increased convenience, and promotion of the channel by the merchant (eg the ability to purchase vending machine soft-drinks via mobile telephony could be promoted by the vendor).
  • Devices in the market currently have limited one-to-one marketing capabilities - To provide one-to-one marketing based on the accountholders account details and transaction behaviour; the payment device must be integrated with bank information systems. The most common form of ATM in the market is PC-based, which is not designed to be integrated into bank systems. The newer ATMs are web-enabled and are designed for this purpose.

    There are a number of factors that suggest the use of one-to-one marketing functionality in the Australian market will be limited in the near future:
    • although increasing, the current spread of web-enabled ATMs is low;
    • the integration with bank systems to gain the one-to-one marketing functionality is likely to require extensive resources; and
    • the growing number of non-bank ATMs may not have access to the necessary bank systems.
  • Smart cards provide opportunities for one-to-one marketing, account control, and payment convenience, but are limited in their market spread - Smart card transactions are classed as contact or contactless. Contact smart cards require insertion into a smart card reader and tend to be favoured by financial institutions dealing with high value transactions. Alternatively, contactless cards simply require a close proximity to smart card readers. This is more typical for uses that require a fast card interface, such as mass transit. In this case, payments can be made without the card even leaving the person’s pocket.

    The amount of data and applications that can be stored on a smart card varies, generally from 32K to 128K. Cards of this capacity are able to store multiple applications on the one card. The applications can be loaded prior to issuance by the vendor, and post-issuance by others through ATMs, the Internet and other devices.

    To date, smart cards have been implemented for a wide range of purposes, including by governments for benefit access, by vendors and merchants as part of loyalty programs, and in transport and parking environments.

    Although smart cards offer opportunities for applications that may provide one-to-one marketing and account control, the dispersion of smart cards in the Australian market is still quite low, as is the spread of EFTPOS and ATMs that can accept them. However, this is likely to increase given the heavy push by vendors, and the declining cost of administration that smart cards offer.
  • Credit Facilities (Mortgage Backed Personal Lines)- Banks and other financial institutions increasingly offer customers accounts that support the combined product features of more traditional transactional and lending facilities e.g. mortgage accounts that provide customers with transactional facilities including credit cards. Lenders also provide customers with the opportunity to access established credit lines e.g. capability to withdraw funds from a mortgage account.

    The purpose of these relatively new products is to provide customers with the flexibility and opportunity to pay-off mortgage debt early whilst still retaining access to basic transactional services. The emphasis is very much on customer convenience. Providers put in place parameters to control access to the facilities offered within these packages. These measures ensure that proper credit management is exercised so enabling the customer to make most use of the in-built product flexibility but also ensuring that the institution maintains its position as a responsible lender.

    Given the context of problem gambling, the ability to control customer access to account facilities e.g. credit card usage, re-draw can be viewed at two levels. Firstly, customers are already subject to daily transactional limits. It then becomes a question of whether those limits are satisfactory for gambling environments and how they can be monitored and enforced. Secondly, should those facilities e.g. re-draw be made available to customers for the purpose of gambling. As already indicated the purpose of such a feature is to provide customers with ‘ready access’ to ‘pre-approved’ credit, once the credit facility is in place institutions may argue that it is not appropriate to tell customers how to spend their money. Equally, monitoring expenditure would prove problematic given that no measures are in place to perform those activities.

    The main issue surrounding re-draws and other mortgage backed credit facilities is the potential size of the credit line available to customers. However, access to these facilities can be and are controlled in very much the same way as more traditional transactional and credit products. The issue remains that the necessary control mechanisms for problem gamblers are not in place e.g. the capacity of the system to determine whether a customer is accessing mortgage backed credit in a gaming location.

8.1.2 Consultation with the financial services sector

The second phase of research involved consultation with banks, non-banks, governing bodies and terminal manufacturers. Structured interviews confirmed our understanding of the current operating environment and key issues facing the financial services sector.

Where appropriate individual financial services organisations have provided formal responses as part of the research. In general these responses have taken the form of answers to the specific questions that were originally raised as part of this brief. The following represents an overall summary of the response by the financial services sector with appropriate input from other relevant stakeholders.41

The following key issues were raised through the consultations with the financial services sector:

42 This was identified as representing a significant capital investment in software development on behalf of the issuing banks. The banks indicated that before any such investment was made they would need to evaluate whether it was still commercially viable to continue to provide ATM and EFTPOS terminals to this market segment.

Removal of ATMs
The main clearing banks have relatively few ATMs deployed at locations that serve gaming environments. As such legislation requiring the relocation of any such ATMs represents minimal impact to these organisations. However, the commercial impact for certain operators e.g. the independents who may have up to 50% or more of their ATMs at such sites was seen to be significant. Equally, some of the smaller regional financial institutions potentially may face a relatively larger impact. In some instances the revenue generated by ATMs located at gaming venues may help off set the financial cost of running the wider network. There are however other opportunities within the market place for these independent operators. This includes the placement of ATMs at chemists, petrol stations, movie theatres, shopping centres and a variety of other locations.

Implementation of Minor Changes
As already indicated it is anticipated that to become compliant with minor changes restricting access would take at least six months e.g. further restrictions on the value of transactions or the removal of functionality. As a sector, costs associated with such a set of changes are roughly estimated to be in the region of $2-$3m.

The main issue identified with such changes is that each state/territory is implementing or considering such change in a piece meal fashion. Such an ad hoc approach has the potential to escalate costs significantly particularly when involving the major banks.

Implementation of Major Changes
The major system changes discussed need to be fully specified before accurate costs can be provided and the likely implementation period. However, at this stage the changes discussed may take between eighteen months and two years to implement at an initial cost to the financial services sector approaching if not exceeding $20m.

  • Alternative Approaches - The following alternative approaches to ATM and EFTPOS legislation were discussed with financial services sector stakeholder group.

    Focused education programme
    It is understood by the stakeholder group that a number of education programmes already operate to help minimise problem gambling. However, there is the opportunity for more focused campaigns in and around the terminals. For example, it is possible to run educational adverts on the screens of the ATMs. Equally, ATMs are able to dispense information leaflets along with cash. Both ATM and EFTPOS receipts can carry appropriate advertising messages.

    Furthermore, the financial services sector felt that a potentially powerful harm minimisation strategy is ‘self-help’. Through this process financial service providers could become involved in the more general harm minimisation strategies. In addition, financial service providers could focus on helping customers with ‘money’ issues e.g. lowering the level of the daily cash limit and potentially withdrawing the customer’s bank card.

    Stronger working relationships within the sector
    The financial services sector recognises its community obligations and those specifically associated with the issue of problem gambling. However as already indicated, if harm minimisation strategies are to prove effective in the long-term, greater co-operation is required amongst all parties associated with gaming.

    The financial services sector has indicated that it is ready to work with the other industry sectors e.g. gaming and hoteliers, as well as the community sector and government, to help generate practical working solutions to the issue.

8.1.3 Future ATM and EFTPOS functions

This area of research focused on emerging trends and changes to capabilities and functionality in the ATM/EFTPOS financial services sector to limit or change access capabilities. This included an assessment of possible future limitations or changes to access, their technical feasibility and commercial implications. The following issues emerged through the research.

  • Removal of terminals (ATM and EFTPOS) - Technically this is a very straightforward option. Terminals can be removed with very limited or no technical changes required. However, the commercial impact for certain operators e.g. the independents who may have up to 50% or more of their ATMs at such sites is very significant. Equally, the smaller regional financial institutions potentially face a similar major commercial impact. In some instances the revenue generated by ATMs located at gaming venues may help offset the financial cost of running the wider network. The potential outcome of such a strategy may well be to reduce the level of competition in the acquiring marketplace as the independent and smaller players are forced to withdraw from some markets altogether.
  • Removal of functionality at the device level - Technically this is a relatively straightforward solution to implement. Functionality can be turned off at the device. Generally ATM operators remove credit card functionality on machines located in gaming areas. Exceptions may occur if retailers insist on the functionality remaining. Operators can also remove the capability of retailers to dispense cash through EFTPOS terminals. New Australian Prudential Regulation Authority reporting requirements whereby EFTPOS acquirers need to detail purchases and cash advances through terminals, further enables this solution.
  • Decline transactions at the issuer level (financial service) - There is the option of removing functionality at the card issuer level. If transactions originate from gaming areas the card issuer has the capability to decline the customer request. However, issuers would need to know the nature of the environment in which the ATM/EFTPOS terminal is located i.e. a gaming venue. This solution is potentially attractive as it places all responsibility back on to the institution that manages the customer relationship. Legislation could focus on the financial services sector and not be concerned with current or future independent operators and advances in technology. However, a drawback identified was being able to identify the nature of the transaction.

    To identify a transaction as originating from a gaming venue the following system developments were identified as necessary:
    • new financial services sector naming categories and sub-categories for gaming locations and different types of gaming location;
    • communications between terminals and host systems need to be able to carry the new naming standards;
    • host systems and switches need to be able to process the new information contained within the payment; and
    • the authorisation system needs to be able to make a decision based on the new information available within the payment message.
  • Tracking of customer transactions/data - To be able to track and monitor transactions originating from gaming locations the above measures need to be implemented. Technically the financial services sector indicated that this represents a very significant investment from the financial institutions.

    To be able to operate a single limit for a single customer is only possible if one centralised switch was established across Australia. In such a scenario all transactions originated by a customer could be monitored from a single data source. Without a central switch it becomes unfeasible to attempt such monitoring unless the customer has already imposed such a limit. Where such limits are not imposed by the customer each bank would need to store the transaction history of all usage captured by other banks.

    What is seen as more feasible is a card issuer tracking and monitoring transactions generated by its own customer base. As already indicated this solution still represents a significant investment by the banks. However, there is at least some practical scope for implementation. To achieve this banks would need to be able to monitor account transactions and then aggregate all transactions within one customer view. For example, if a customer holds more than one account with a bank, the institution would need to be able to track all gaming transactions that might occur on any of the relevant accounts to ensure they were viewing the full picture for that individual customer.

    To track and monitor gaming transactions on an account basis represents a more straightforward solution. There is no need for the bank to aggregate all activity.
  • Credit and cash limits - The ability to impose transactions limits based on available credit is reliant on the above system developments being in place. For example, the ability to impose ‘gaming limits’ on ATMs and EFTPOS terminals within single or multiple sites, requires banks to be able to track and monitor cash withdrawal transactions originating in gaming locations. This same level of investment is also required if card issuers need to track and monitor the number of gaming transactions that occur within a specific time period.

    Once a process is in place to track and monitor transactions the banks only need apply the gaming limit to customer accounts. As with the daily withdrawal limit, the gaming limit could be a ‘blanket’ limit applied across all accounts.

    Legislation is in place across South Australia that limits the value of cash that can be withdrawn in gaming areas. In South Australia the solution was geared around the devices. There was the option to operate the withdrawal limits at the card issuer level. However, this represents a longer implementation period and is potentially more costly. Yet as already stated the implementation of such an approach at the issuer level is more cost-effective in the long-term, and it does require the issuer to recognise that transactions are being originated from a gaming area. Request for cash above the agreed withdrawal limit in these circumstances would simply be declined.

    A number of financial services sector stakeholders voiced concern about the commercial viability of EFTPOS devices deployed in certain retail segments if further restrictions are applied to the amount of funds that can be dispensed through an EFTPOS terminal. Many financial institutions voiced a preference for simply removing the cash withdrawal facility altogether in certain types of retail locations.

8.2 Emerging Themes

The issues arising from the three phases of work form a number of common themes. These themes revolve around the ability of the financial services sector and independent operators to effectively respond to Commonwealth and state/territory governments concerns about the negative social impact of problem gambling

  • Holistic approach - It is clear that strategies promoted by Commonwealth and state governments need to be co-ordinated. This co-ordination needs to happen at a number of levels as detailed below:
    • if legislation is deemed necessary then it needs to be consistent across all states;
    • all parties associated with problem gambling need to be held accountable including the financial services, hotelier and gaming industries; and
    • ultimately, given stakeholders can only do so much to support and/or assist the situation, final responsibility rests with individual consumer’s behaviour.
  • Commercial Impact - Clearly different solutions have varying levels of commercial impact and the impact varies according to the commercial nature of the operators business. For example, independent operators are commercially more dependent on terminals located within gaming areas than banks and other financial institutions. Equally, larger banks are better able to absorb any increase in operating costs e.g. terminal upgrades.

    At this stage it is unrealistic to expect that operators will provide detailed financial information on the potential commercial impact of various solutions. The Commonwealth government would need to be far more specific about its intentions before operators would invest the necessary time to investigate the likely financial impacts. However, operators have been prepared to discuss at a high level the financial pros and cons of the different approaches as detailed earlier.
  • Device Neutral Solutions - The financial services sector agreed that legislation particular to device types could at best only have a limited short-term impact. As new gaming and financial services technology emerges governments would be faced with continually needing to adopt new legislation.
  • Customer Impact

    Privacy
    Consumer privacy is protected through legislation. Definitions of consumer privacy extend to cover data generated within payments systems e.g. ATM and EFTPOS transactions. However, if new legislation was passed then it becomes over-riding of any previous legislation. Consideration will need to be given to the potential backlash from consumers if it required financial institutions to track and monitor payments.

    Customer Service
    All financial institutions that were interviewed expressed varying levels of concern on the wider customer service implications. It is acknowledged that any initiatives are only targeted at a very small minority of customers i.e. problem gamblers. However, the various proposals being considered have varying degrees of impact on the wider customer base.
  • Existing community responsibilities of service providers - Commonwealth and state/territory initiatives to minimise the negative impact of problem gambling are comprehensively supported by the individual institutions and governing bodies spoken to as part of this research. Most financial services institutions have quite explicit and detailed objectives to support the communities within which they operate. These are available publicly at most financial service outlets.

    This community responsibility manifests itself through a number of strategies including:
    • Lending is undertaken in a socially responsible manner i.e. providing levels of credit that directly reflect the financial capability of individual customers. Hence, the active credit management of customer accounts is integral to the day-to-day activities of banking institutions. It is in the interest of such institutions to minimise customer bad debt whether its root cause e.g. problem gambling, drug addiction or general financial mismanagement.
    • As part of a socially responsible lending strategy banking organisations have taken specific measures in relation to the provision of services at gaming locations. Research has demonstrated that the majority of acquiring institutions have withdrawn access to credit accounts in these specific environments. Access to credit accounts is often only available when the retailer has insisted on the functionality being available (this is not referring to redraw capacity).
    • Many acquirers are involved in the provision of low-key advertising to encourage gamblers who recognise that they may have a problem to seek help. For example, receipts may carry the telephone number of a gambling help line. Equally, the ATM itself may carry stickers or leaflets conveying a similar message.

8.3 Summary

The financial services sector is fully supportive of effective measures to minimise the negative social impact of problem gambling. However, it is difficult for the financial services sector to decide upon effective strategies when a number of issues remain outstanding. They include:

  • The capacity of the banking community to readily identify and differentiate between problem and social gamblers in a manner that can be viewed as being non-discriminatory.
  • The need for metrics to be established to measure the effectiveness of any strategies put in place. The availability of evidence to support which strategies are most effective. Given the measures adopted at state level, the availability of empirical evidence that demonstrates the degrees of success for various strategies.
  • Given the lack of confirmation of what might constitute effective harm minimisation strategies within financial services, it is hard to promote to the wider customer base and shareholders, solutions that could directly impact the commercial operations of the service providers. It is unclear to what extent the government is prepared to impact on the success of commercial lines of business. This applies not only to service providers but also to retail outlets.
  • Strategies need to be balanced between providing a general level of customer service and providing a structure of support for problem gamblers. It is not clear to the financial services sector what ideas or views the Commonwealth or state governments have on achieving this balance i.e. where should the line be drawn.
  • Legislation is widely viewed as a measure of last resort. Given the lack of definition around the problem and the relatively unknown likely effectiveness of potential solutions, it is potentially more prudent for Commonwealth and state governments to take account of measures already in place.
  • Equally, given the pace at which technology changes, it is difficult to envisage how ‘device specific’ legislation can keep pace with developments in the gaming and financial services sectors.

9. Key themes 

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.

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.

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.

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.

10. Recommendations 

There are a myriad of strategies that have been identified through this project that are currently in place or being considered. However a key finding has been that there does not seem to be any research undertaken by government or independent parties to measure the impact of any responsible gambling and harm minimisation measures, particularly in relation to ATM and EFTPOS initiatives. In addition, the preliminary impact analysis regarding cost and customer service would indicate that there are substantial implications in these areas associated with various strategies.

As such we have not sought to recommend to substantially increase the range of strategies in place, but rather for the government to consider the development of a framework within which to guide decisions within this arena, in particular, mechanisms to assess appropriateness and effectiveness of strategies.

The following recommendations focus on the development of a national approach to harm minimisation strategies regarding access to cash and credit. The recommendations focus on harm reduction and prevention of further harm, incorporating strategies that encourage and support the industry segments to share responsibility for problem gambling, including the curtailment of further deployment of new technologies, access to credit facilities and a range of educational and self help strategies. It is important that the strategies are not seen in isolation as each area of recommendation builds on the previous.

10.1 Development of a national operational approach

With the establishment of appropriate parameters there will be substantial capacity for governments to make informed choices on the array of potential options and arrangements. The establishment of a national operational approach would provide a foundation on which to base the way forward for the government response in this area. As such the subsequent recommendations provide opportunities for more immediate action at relatively low cost to stakeholders and minimum disruption to consumers at a wider level.

A national operational approach should constitute an advisory document that helps states/territories determine which strategies are most appropriate. Such an approach would provide guidance with regard to:

  • the parameters within which strategies can be considered, for example the impact of various strategies on rural communities and relationships to other government agendas and policy directions;
  • key consultative mechanisms and processes including identification of critical stakeholders;
  • the concept of shared responsibility;
  • access to international literature, global benchmarks, research and organisational contacts;
  • identification of any current best practice;
  • guidance regarding effective cost benefit analysis;
  • guidance regarding appropriate monitoring and review mechanisms;
  • structures for sharing information across jurisdictions; and
  • identification of accountability for compliance.

Recommendation 1:  That the Commonwealth government, in conjunction with the states and territories, and in consultation with the industry sectors and the community sector, establish a national operational approach to provide the context within which states develop and implement harm minimisation strategies for problem gambling within the context of access to cash.

Recommendation 2:  That such an approach provide guidance on:

  • the parameters within which strategies can be considered, for example the impact of various strategies on rural communities and relationships to other government agendas and policy directions;
  • key consultative mechanisms and processes including identification of critical stakeholders;
  • the concept of shared responsibility;
  • access to international literature, global benchmarks, research, and organisational contacts;
  • identification of any current best practice
  • effective cost benefit analysis;
  • appropriate monitoring and review mechanisms;
  • structures for sharing information across jurisdictions; and
  • identification of accountability for compliance.

All stakeholders agree that legislation particular to device types can at best only have a limited short-term impact. As new gaming and financial services technology emerges government would be faced with continually needing to adopt new legislation. As such it is recommended that the focus shift away from the control of problem gambling through device focussed strategies towards a broader focus on access to accounts for the means of securing cash.

Recommendation 3: That the approach shift emphasis away from the control of problem gambling through device focussed strategies towards a broader focus on the individual’s access to accounts for the means of securing cash.

Recommendation 4: Within the approach in recommendation 3 there needs to be the development of a strategy in relation to access to cash within gaming locations. Such a strategy should incorporate:

  • customer access to funds within their accounts;
  • access defined at the account and device level;
  • monitoring and control of the introduction of new technologies for cash accessibility within the gaming environment; and
  • technology around gaming.

The approach needs to recognise that all providers are not covered by the same governing bodies – eg, bankers and non banking operators and that amongst financial institutions there is a marked difference in the scale of operation between the top four banks and the other financial institutions.

Technically, the potential solutions put forward as part of the research can be implemented with varying degrees of ease and capacity. For example the tracking and monitoring of transactions may appear an effective measure to minimise access, however it would be premature to recommend the implementation of any such measures given the significant investment required and the lack of empirical evidence indicating the likely success. Therefore the recommendations below provide opportunities for more immediate action or enhancement of existing capacities.

Within this context the recommendations focus on two key areas, further prevention of problem gambling and harm reduction strategies to minimise harm to those already with a problem.

10.2 Prevention – curtailment of deployment of new technologies

Within the context of a more holistic approach to problem gambling there is scope to implement strategies that curtail the deployment of new technologies that could be seen as problematic and providing extended opportunities unnecessarily to either increase access to cash and gaming as well as potential implications for providers, devices and facilities. For example poker machines with inbuilt EFTPOS facilities and ATMs with inbuilt gaming capability substantially increase a person’s access to funds for the direct purpose of gaming. It is therefore proposed that regulation and/or policy be implemented that identifies these technologies and severely curtails or prohibits their introduction into the wider gaming environment. Specifically such regulation should apply to:

  • the use of Smart cards and 3G mobile phone technology; - clubs are developing loyalty schemes given the potential of smart card technology to support these schemes. The ramifications are significant for regulators seeking to control access to funds.
  • poker machines with in built EFTPOS;
  • E bank;
  • Wireless technologies such as Bluetooth;
  • M.bank/m.commerce; and
  • ATMs with inbuilt gaming capacity.

Recommendation 5: That the Commonwealth move to negotiate with the states/territories to implement policy to curtail the deployment of technologies that would be considered problematic within the context of managing the negative impacts of problem gambling in the community. That this not be exclusive of a range of technologies but specifically include:

  • the use of Smart Cards and 3G mobile phone technology;
  • Poker machines with in built EFTPOS;
  • E.bank;
  • M.bank/m.commerce;
  • Wireless technologies such as Bluetooth; and
  • ATMs with in built gaming capacity.

10.3 Harm reduction – shared responsibility

There is no real clarity with regard to the roles and responsibilities of the various stakeholders across the sectors and as such the application of changes and the introduction of strategies have fallen on various stakeholders to differing degrees. It is clear that all relevant stakeholders need to take accountability for the development, implementation and ongoing maintenance of harm minimisation strategies within and external to gaming locations. All stakeholders have expressed a willingness to participate in the development of strategies and believe it is important for them to partake in establishing a reform agenda. A starting point would be to consider the following as a part of the shared responsibility mandate:

  • hoteliers to ensure the responsible use by patrons of gaming facilities. This includes ensuring monitoring and controlling access not only to cash on the premises but also to the gaming devices themselves. This is fully in line with current responsibilities for the sale and consumption of alcohol on the premises;
  • banks to take on increased responsibilities with regard to targeted marketing information, both around the use of ATMs in the gaming environments and through messaging on receipts and leaflets; and
  • poker machine operators/owners – a percentage of the revenues generated from the machines could be deployed into cash access strategies, equally sharing responsibility with the banks. This could operate on similar lines to liquor license arrangements.

Recommendation 6: That the Commonwealth government, in conjunction with the states and territories, liaise with the key stakeholder groups to establish clarity with regard to roles and responsibilities within the harm minimisation and social responsibility context. Within this context, discussion could occur as to the most appropriate strategies the various stakeholders should take primary responsibility for.

10.3.1 ATM functionality

Current legislation requires that banks do not locate ATMs in designated gaming areas. In reality ATMs are often to be found at the entrance to, or in close proximity to gaming areas. Clearly this is in keeping with the law, however not potentially with the intent or spirit of the law. This policy needs to be reviewed as the purpose of the legislation was to remove ready access in and around gaming locations and there is a strong view that this is not being achieved. Current legislation is not clear as to who has direct day-to-day responsibility for the location of the machine. Consideration should be given to strategies that place ATMs at a defined distance away, and not in line of sight to the gaming area.

Recommendation 7:  That the Commonwealth government, in conjunction with the states and territories, undertake a review of the location and placement of ATMs with regard to their proximity to gaming areas to ensure that the intent of the legislation is being adhered to. Such a review may consider increasing requirements to ensure ATMs are not in visible sight of patrons in the gaming area.

10.3.2 Removing access to credit facilities

As part of the commitment to responsible lending in the community financial service providers as a general principle do not make available the credit card functions on ATMs located within gaming areas. There are anomalies whereby retailers insist on the credit function being available to customers. There is already in place a national policy not to provide cash advances through EFTPOS. It is therefore recommended that credit facilities be turned off in all gaming locations. Credit is defined as credit accounts and the ability to raise credit facilities eg, loans, further credit cards. It does not include overdrafts or redraw facilities as discussed previously. It is considered that established daily cash withdrawal limits already cover access to overdrafts and redraw facilities.

This recommendation builds on established industry practices.

Recommendation 8:  That the Commonwealth government negotiate with the states and territories to ensure that all ATMs that serve gaming locations do not enable access to credit accounts.

10.3.3 Education strategies

There is clear opportunity for more specific and targeted education of consumers around ATM/EFTPOS facilities. Given the current technology this can take the form of ATM screen messaging including presentation of help numbers and warning messages. Messages could also inform the customer around transactions, for example cash limits and the length of time they have been in the gaming venue.

ATMs could dispense information leaflets in the form of vouchers as part of the cash transactions. This could carry similar information/messages as above. Similarly, the EFTPOS could print receipts with help numbers and messages.

In addition, specific education could be undertaken by the banks with regard to the use of ATM and EFTPOS machines in gaming locations that educates the community on ATM and EFTPOS provisions and why they may be different within the gaming environment. This could be marketed within the context of social responsibility and responsiveness to problem gambling.

Recommendation 9:  That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services industry to generate in cooperation with other stakeholders marketing literature specifically targeted to gaming locations including ATM screen messages, dispensing of ATM leaflets and the printing of messages on ATM and EFTPOS receipts.

Recommendation 10:  That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services sector to develop an educational strategy targeted at informing the general community of ATM and EFTPOS functionality within gaming environments.

10.3.4 Self Help strategies

Ultimately the problem gambler is required to share some responsibility in dealing with their gambling behaviour. There are ranges of strategies in this area that are being implemented overseas and could be considered here. They include the individual implementing a self-exclusion deed whereby the individual excludes themselves from the ATMs in all casinos and gaming environments. Further, there is already capacity for individuals to place withdrawal limits on specific accounts. This allows people some capacity to address their own behaviour whilst not negatively impacting on the broader community group.

It is therefore recommended that these capacities form part of the discussions with the industry and be considered in the full range of educational strategies.

Recommendation 11:  That the Commonwealth government, in conjunction with the states and territories, negotiate with the financial services sector to develop a strategy that supports self-help strategies for banking consumers who require assistance in managing finances as a result of gaming issues.

11. Getting it right – principles for change 

The research highlighted that there is a substantial level of agreement across all sectors for the need for a national operational approach; with all stakeholders accepting they have community service obligations towards minimising problem gambling.

As such it is important that the next steps build on the current commitment and momentum that has been generated through the project. In addition, given the lack of evidence to support the effectiveness of strategies an agreed approach would provide the framework within which to track and monitor the full range of strategies.

The current ‘ad hoc’ approach at state level has resulted in inconsistent impacts being incurred by stakeholders as they continue to meet varying and differing legislation.

11.1 Development of a national operational approach

It is important that the Commonwealth government considers moving towards the establishment of an agreed national approach. As part of this the Commonwealth government in conjunction with the states and territories, and through consultation with the industry sectors, should identify what constitutes the most appropriate approach to take the issue forward. In developing the approach it will be important to consider the following:

  • establishing an agreed definition of what problem gambling is amongst all stakeholders. Currently, such understanding primarily sits with social policy makers and this research has shown that there is a lack of wider understanding from other stakeholder groups.
  • in addition to establishing an agreed definition, it will be important to articulate and generate some broader understanding of the key influences and drivers that contribute to problem gambling. For example, it has been difficult to substantiate any clear causal link between problem gambling and ATM/EFTPOS functionality. Without such understanding stakeholders struggle to appreciate the potential benefits of the current range of strategies being recommended and implemented.
  • addressing the shortcomings in the current process with regard to stakeholder involvement and participation, for example the limited consultation with respective financial service providers on the strategies put forward by the states.

11.2 Principles for change

The following principles are provided as a guide on which to base future decision-making within this arena. There are eight key principles that have evolved from the research and consultations that consistently drive all stakeholder feedback. These principles are inclusive of their varying positions while having at their core the issues that arise from problem gambling for the individual and the wider community.

  • Government has an obligation to protect the vulnerable through strategies to minimise the harm that arises as a consequence of their individual behaviours. This obligation is differentially applied at both the Commonwealth and state level and across the various industry stakeholder groups.
  • Strategies must balance the needs of the social gambler with minimising the harm that can arise for problem gamblers when accessing funds and/or credit. Additionally, strategies must also balance the needs of the general customer with the need to minimise harm for the problem gambler in their relationship with financial institutions.
  • Regulation will not keep pace with technology changes, if anything technological innovation will change the landscape when considering issues associated with problem gambling.
  • The focus needs to be on the individual and their access to funds, not on the device, as ultimately the device will become irrelevant as technology moves to cashless transactions.
  • Evidence of effectiveness of differing strategies and approaches needs to guide future decision making especially where there is a direct impact on the wider community and differing impact on the various industry sectors.
  • To achieve effective solutions and outcomes, future strategies should be underpinned by recognition of the shared responsibility across the various industry sectors (eg, financial services, community sector, gaming venues, poker machine operators and manufacturers).
  • Consultation should be inclusive across sectors and aimed at balancing the implications of proposed strategies to maximise their effectiveness while recognising cost and business obligations.
  • It needs to be recognised that any solutions will inherently present a conflict of interest for the various stakeholders with regard to balancing business objectives with social and community service obligations.

The various sectors involved in this project have shown a willingness and keen interest to contribute in this arena of investigation, particularly given the importance of the implications of strategies on their operations. Further research and consultation should endeavour to include these key groups in a more coordinated way, placing greater responsibility on the individual sectors to collectively, identify roles, responsibilities, implications, cost benefit analysis and monitoring procedures to give effect to any agreed strategies.

Appendix A - List of stakeholders consulted 

Appendix A List of stakeholders consulted
Stakeholder group description Organisation
Australian Gambling Regulators: Queensland Office of Gaming Regulation
Queensland Treasury Gambling Policy Directorate
New South Wales Department of Gaming and Racing
Northern Territory Treasury, Racing Gaming and Licensing
Department of Racing, Gaming and Liquor, Western Australia
South Australia Office of the Liquor and Gambling Commission
Tasmanian Gaming Commission
Victorian Office of Gambling Regulation
ACT Gambling and Racing Commission
Australian researchers Professor Jan McMillen, Australian Institute of Gambling Research
Professor Alex Blaszczynski, Head of the Department of Medical Psychology, Westmead Hospital and Chair of Psychology, Department of Psychology, The University of Western Sydney.
Australian Gambling Associations Clubs Australia
Australian Gaming Council
Australian Casino Association
International Organisations - direct contact and responses via email Alberta Gaming and Liquor Commission
British Columbia Gaming Policy and Enforcement Branch
American Gaming Association
Iowa Racing and Gaming Commission
South Dakota Gaming Commission
Mississippi Gaming Commission
Nevada Gaming Control Board
Responsible Gambling Council (Ontario)
United States National Council on Problem Gambling;
Wynne Resources (Canada);
Financial Services Sector (industry) ANZ Stephen Carroll - Director
ANZ Jane Nash Head of Government Regulatory Affairs
APCA Brian Saville - Senior Manager
APCA Phil Timms - Acting Director, Public Affairs
Cashcard Australia David Ryan - Business Project Manager
Cashcard Australia Greg Monaghan - Chief Operating Officer
Cashcard Australia Peter Blackett - Head of Self Service Solutions
Commonwealth Bank Mick Chivell - Alliance Manager
Commonwealth Bank John Cairn - Government and Industry Affairs
Commonwealth Bank Gavin Napier - National Executive ATMs
Diebold Australia John Mobbs - Executive Manager Business Process
Diebold Australia Reg Bohler - Managing Director
Diebold Australia Grant Bowyer - Professional Services Manager
Electronic Banking Solutions Paul Edwards - Account Manager
ETT Australia Mark Schnitzerling - National Business Development Manager
ETT Australia Lance Robinson - General Manager Sales
NAB Geoff Coffill - General Manager Strategic Development
NAB Jeremy Dean - General Manager Channel & Process Optimisation
NAB Robert Newton - Application & Process Manager Electronic Payments
GAPP Consulting Clint Walkenhorst - Manager Self Service Delivery
St George Bank Barbara Livesey - Director
Westpac Manoj Sharma - Head of Electronic Payments
Community sector
Adelaide Central Miission Mark Henly
Justice and International Mission
Unit, Synod of Victoria and Tasmania,
Uniting Church in Australia
Dr Mark Zirnsak
Gamblers Southern Help Chris Freethy
Gamblers Help Line Jim Hickson
Anglicare Tasmania Revd. Canon Christopher Jones, National Advisory Body on Gambling
Human Services SA David Winderlich
Gamblers Help Northern Judy Abbott
Other parties
Conrad Casino Mary Marquass, National Advisory Body on Gambling
Australian Hotels Association Richard Mulcahy, National Advisory Body on Gambling

Appendix B - References and source documents 

B.1 Australian Regulators

  • South Australian Office of the Liquor and Gambling Commissioner, Licensee Update, October 2001, Volume 3, Issue 3, Notice to Gaming Machine Licensees
  • South Australia Gaming Machines Act 1992
  • South Australian Office of the Liquor and Gambling Commissioner, Liquor Licensing and Gambling Information Booklet
  • Parliament of Victoria, Gaming Legislation Amendment Bill, 5 June 2002
  • Victorian Office of Gambling Regulation, Proposed Gaming Machine Control (Responsible Gambling Information) Regulations, Regulatory Impact Statement
  • Northern Territory Treasury – Racing Gaming and Licensing, Draft Responsible Gambling Code of Practice
  • Northern Territory Treasury – Racing Gaming and Licensing, Brief on Gaming Machine Issues to Licensees, 9 July 2001
  • Tasmanian Gaming Commission, Gaming Control Act 1993, Tasmanian Gaming Commission Rules
  • Queensland Government Treasury, Responsible Gambling Advisory Committee, Queensland Responsible Gambling Code of Practice, 29 May 2002
  • Queensland Office of Gaming Regulation, Brief to Applicants for a Gaming Machine License of Increase in Gaming Machines
  • New South Wales Department of Gaming and Racing, Information Sheet 14/00 – Guidelines for Exemption from Cashing of Cheques and Location of Cash Dispensing Facilities Registered Clubs and Hotels, September 2000
  • NSW Gambling Legislation Amendment (Responsible Gambling) Act 1999 No. 49, updated 2 April 2002
  • New South Wales Department of Gaming and Racing, Information Sheet 2/02 – Gambling Harm Minimisation Requirements for Race Clubs and TAB Limited Outlets, January 2002
  • New South Wales Department of Gaming and Racing, Legislation Bulletin, March 2002 – Gaming Machines Act 2001 and Gaming Machines Regulation 2002
  • New South Wales Department of Gaming and Racing, Regulatory Impact Statement, Proposed Gaming Machines Regulation 2002 -
  • ACT Gambling and Racing Commission, Gaming Code of Practice, Discussion Paper, April 2002
  • ACT Gambling and Racing Commission, Development of the Gambling Industry Code of Practice, Consultation Paper, December 2001
  • ACT Parliamentary Counsel’s Office, Gambling and Racing Control Regulations 2001 (Draft Exposure)
  • ACT Gambling and Racing Commission, Review of the Gaming Machine Act 1987, Second Stage Consultation Paper, December 2001
  • ACT Gambling and Racing Commission, Review of the Gaming Machine Act 1987, Policy Paper, December 2001
  • Australian Institute of Gambling Research, Gambling Regulatory Regimes, Regulatory Structures, Powers and Processes Governing Australia’s Gambling Industries, March 2000

B.2  Australian Research Reports

  • Hing, N and Dickerson, M, Responsible Gambling, Australian Voluntary and Mandatory Approaches (summary), research commissioned by the Australian Gaming Council
  • Blaszcynski, A., Harm Minimization Strategies in Gambling, An Overview of International Initiatives and Interventions, prepared on behalf of Australian Gaming Council
  • Australian Institute of Gambling Research, ACT Needs Analysis: Gambling Support Services, August 2001, commissioned by ACT Gambling and Racing Commission
  • Australian Institute of Gambling Research, Survey of the Nature and Extent of Gambling and Problem Gambling in the ACT, July 2001, commissioned by ACT Gambling and Racing Commission
  • Productivity Commission Inquiry Report, Australia’s Gambling Industries, November 1999

B.3 International publications and research

  • National Gambling Impact Study Commission, National Gambling Impact Study Commission Report, June 1999
  • Cabot, A., Thompson, W., Tottenham, A. & Braunlich, C. International Casino Law (Third Edition), 1999, Institute for the Study of Gambling and Commercial Gaming

B.4 International periodicals, papers, correspondence and legislation

  • International Gaming and Wager Business
  • State of the States, the American Gaming Association survey of Casino Entertainment, 2002
  • State of Iowa Racing and Gaming Commission, Administrative Rules Committee correspondence
  • U.S. House of Representatives, Press Release ‘LaFalce calls for crackdown on credit card gambling’, 19 July 2001
  • U.S. House of Representatives, Press Release ‘LaFalce calls for crackdown on credit card gambling’, 8 September 1999
  • Canada West Foundation, Canada’s Gambling Regulatory Patchwork: A Handbook, October 1999
  • American Gaming Association, Statutes and Regulations in Commercial Casino States Concerning Responsible Gaming, March 2002
  • State of Michigan, Gaming Control and Revenue Act 1997

B.5 Organisations contacted and associated website search

  • Gaming Studies Collection, University of Nevada
  • Gaming Studies Research Centre, University of Nevada
  • Wynne Resources, Alberta Canada
  • The Responsible Gambling Council, Ontario
  • National Centre for Responsible Gambling, United States
  • National Counselling on Problem Gambling Inc, United States
  • Institute for the Study of Gambling and Commercial Gaming, University of Nevada
  • Centre for Research into the Social Impacts of Gambling, University of Plymouth
  • Nevada Gaming Control Board, Research Centre
  • American Gaming Association
  • National Indian Gaming Association
  • Alberta Gaming and Liquor Commission 
  • British Columbia, Gaming Policy and Enforcement Branch
  • Indiana Gaming Association
  • Iowa Racing and Gaming Commission
  • Michigan Gaming Control Board
  • Mississippi Gaming Commission
  • South Dakota Commission on Gaming

B.6 Websites searched

  • Australian Institute for Gambling Research, University of Western Sydney
  • Problem Gambling Research Program, University of Melbourne
  • National Association for Gambling Studies Gambling Research Unit, University of Sydney
  • Alberta Institute for Gambling Research, Canada
  • Canada West Foundation
  • Institute for problem Gambling, United States
  • Problem Gambling Research Group, University of Windsor, UK
  • United States Gambling Research Institute
  • European Association for the Study of Gambling
  • Gam Care
  • The Colorado Division of Gaming
  • Illinois Gaming Board
  • Missouri Gaming Division
  • New Jersey, Division of Gaming Enforcement

B.7 References and source documents for Card Statistics

B.7.1.1 CardFlash/CardTrak

  • ATM Slots’ CardFlash, 23 April 2002 
  • Casino ATM Clients,’ CardFlash, 10 May 2002 
  • GCA Signs 76 QuikCash Contracts,’ CardFlash, 5 April 2002

B.7.2 ‘Phone Payments,’ CardFlash, 05 April 2002 

  • POS Check Service’ CardFlash, 5 August 2002
  • POS Photos,’ CardFlash, 9 May 2002
  • Think Before You Withdraw,’ CardTrak, 30 April 1999

B.7.3 TowerGroup 

  • Kalignite: Enabling the Future of Intelligent Self-Service Terminals’ TowerGroup, May 2001
  • R. Bell, ‘The Rise and Evolution of ATMs – A Brief History,’ TowerGroup, February 2000

B.7.4 Web Sites

B.7.5 Other

  • Briney ‘A Smart Card For Everyone?’ Information Security, March, 2002 
  • Acer Selects Arterium for its Smart Card Management Bureau’ PR Newswire February 10, 2002
  • ‘ANZ rolls out first smart card application’, Cards International January 11, 2002
  • B.O'Connell, ‘Next-Generation ATMs Proliferate; Got fees? Big banks see Web-enabled ATMs as cash cows,’ Corporation Bank Technology News, section: NEWS, Vol. 15, No. 4, Pg. 7, April 2002
  • ‘Brooktrout and CTI LABS team with Pepsi Cola Germany at CeBIT to deliver a mobile fulfillment solution for consumers,’ PR Newswire European, 13 March 2002
  • C.Bowen ‘Welfare Agencies Seek Benefits From Chip Cards’ Card Technology, January, 2002
  • Dial-a-Coke Flags Mobile E-commerce,’ Australian Financial Review, 25 July 2001
  • EFT REPORT, ‘EFT Network Strategies Shift to Address New ATM Realities,’ Vol. 25, No. 5, March 6, 2002 – References Dove Consulting’s ‘2002 ATM Deployer Study’
  • Global Cash Access Offers States Option to Block EBT Cards At Gaming Locations,’ NewsEdge, 3 May 2002
  • Visa And SKT Launch First Wireless Payment System Using EMV And Infrared’ Canadian Corporate Newswire, May 22, 2002

Appendix C - Glossary of terms 

3G - Third generation wireless service that can has transmission speeds up to 2Mbps, enabling high-quality wireless audio and video.audio and video.

ATM – automatic teller machine

Cash out – the facility that enables customers to withdraw cash at EFTPOS

Community services sector - the community services sector consists of services aimed towards improving the community as a whole, improving the well being of families, children, and individuals, and protects children and youth. This sector consists of primarily not-for-profit organisations whose services include, but are not limited to, family support services, financial counselling, social workers, and advocacy services.

Contactless cards – cards that you don’t swipe - you just need to hold them in proximity to a device. There is no need for physical contact.

Converging technologies - converging technologies is an expression used to describe the increasing ability of devices, communication channels, and telephony to share the same technology, allowing similar services to be shared over different platforms (e.g. email, Internet, telephone).

Credit - Credit accounts and the ability to raise credit facilities eg, loans, further credit cards. It does not include overdrafts or redraw facilities.

Debit card – card that customers insert in ATMs or swipe through an EFTPOS. Gives access to the customer’s savings or cheque accounts and enables direct access to funds.

Device neutral – Solutions that are not focused on devices, ie ATM and EFTPOS

Deployers – organizations that install ATMs and/or EFTPOS.

Draw down – the act where a customer utilises funds that have been authorised by the bank. These funds are made available through a line of credit, for example a mortgage.

E.bank – electronic banking

EFTPOS – electronic funds transfer point of sale

Financial services sector - the Financial Services sector includes banks, non-bank financial institutions, investment bankers and brokerage firms, asset management firms, investment and venture capital firms, mortgage bankers, consumer lenders, commercial lenders, and leasing companies.

Gaming/gambling industry - the gaming/gambling industry consists of organisations that have an involvement in casinos, charitable gambling, gaming machines, interactive gambling, keno, lotteries, betting and wagering.

Harm minimisation - harm minimisation aims to improve health, social and economic outcomes for both the community and the individual by preventing anticipated harm and reducing actual harm.

Host system – system upon which a number of applications are run and accessed by different parties

M.bank/m.commerce – mobile banking/ mobile commerce - performing transactions in transit, using wireless technology.

Michigan Gaming Control Board "Casino" means a building in which gaming is conducted. "Casino enterprise" means the buildings, facilities, or rooms functionally or physically connected to a casino, including but not limited to any bar, restaurant, hotel, cocktail lounge, retail establishment, or arena or any other facility located in a city under the control of a casino licensee or affiliated company

Nevada Gaming Control Act "Casino” means the room or rooms wherein gaming is conducted and includes any bar, cocktail lounge or other facilities housed therein as well as the area occupied by the games, except restricted gaming operations as defined by NRS 463.0189.

One-to-one marketing – a term used to describe marketing efforts that are tailored to the individual. The marketing activities are based on the information about the individual that the marketer holds.

Problem gambling - problem gambling is a condition that contributes to either the loss of self-control over gambling/gaming behaviour, such as the frequency of gambling, and the value wagered; and/or a pattern of gambling behaviour that negatively affects other important areas of one’s life.

Regulatory industry - the regulatory industry consists of organisations that are responsible for the formulation of state wide or nation-wide industry-focused policies and legislation, and the enforcement and monitoring of industry compliance. For example, the activities of the Queensland Office of Gambling Regulation includes the review and development of gambling policies and legislation, ensuring industry compliance with gaming legislation, conducting probity investigations and evaluating internal controls, gambling equipment and gambling rules.

Smart Cards – A plastic card, normally the size of a credit card, that has a microprocessor embedded in it that can store information and applications.

Social (or recreational) gambling - social gambling requires that the participant has control over his/her gambling behaviour and activities, and is participating for entertainment purposes.

Wireless technology – Computer networks are connected by radio instead of wires and can be used for transmitting voice, data, video, and images.

Appendix D - Device functionality 

D.1 ATMs

ATMs have evolved in both their transactional functionality and their communication functionality.

ATMs initially began as simple cash dispensing machines. While this is still their primary function, they can now offer a wider range of transaction capabilities including account information and fund transfers, and support marketing initiatives through receipt coupons and advertisements. The ability to deliver individually customised messages to the consumer is also now technically possible.

D.1.1 PC-Based ATMs

PC-based ATMs are the most commonly implemented ATM43 . They allow limited one-to-one marketing and customisation, as they are not linked directly to customer databases.

Being PC-based provides programmers with access to a range of PC development tools; allowing vendor ATMs to be customised and applications can be developed in-house. However, these ATMs are not equipped to be easily integrated into banking information systems. This has led to ATMs being treated in a ‘silo’ fashion, quite separate to the rest of the banking channels.44

The range of applications being developed for PC-based ATMs has grown from being solely cash dispensing, to dispensing products, providing customer information, and being used in marketing initiatives. The below table lists some of the nontraditional ATM functions currently available:



Table 8: Non traditional ATM functions45
Function type Examples
Dispensing Stamps, event tickets, travel tickets, phone cards, coupons
Demanded printing Statements, forms and documents
Advertisements Bank products and services, non-bank products and services, community service messages

Companies are taking advantage of ATM functionality and are providing a wider range of services to the customer. The graph below shows the percent of United States financial institutions that are offering the non-traditional services. Generally Australia would follow the US pattern.

The graph below shows the percent of United States financial institutions that are offering the non-traditional services.

Source: Dove Consulting 2002 ATM Deployer Study

D.2 Web-enabled ATMs

Marketing messages that are customised at the individual customer level requires the ATM to be integrated with the bank’s other information systems, such as customer relationship management systems. ATMs now being produced provide the possibility of being integrated into these systems, as they are web-enabled.

The technology underlying web-enabled ATMs allow for greater functionality possibilities, including46 :

  • additional Internet TCP/IP communications links can aid the interfacing of an ATM with other bank systems, necessary for one-to-one communications over the ATM;
  • operating in the Windows NT/2000 framework allows ATM applications to be developed using contemporary tools;
  • they can access a broader choice of peripherals (e.g. printers, smart card read/writers); and
  • the standardised message standards (ISO 8583 and OFX) improve communication possibilities.
Table 9: Technical improvements in open web enabled ATMs47
Enhanced functional environment Specific advancements
ATM peripherals Universal serial bus (USB) support for ATM peripherals
Windows Open Services Architecture Extensions for Financial Services (WOSA/XFS) standard based ATM peripheral drivers.
Application software Active XFS based ATM application peripheral interface
Windows NT2000 operating system base
Object component applications model
Communication software ISO 8583 international messaging standard
Open Financial Exchange (OFX) messaging standard

These improvements translate into ATMs that can provide a wider range of more personalised services to the customer. Specific examples of functions that are being performed by web-enabled ATMs are described below:

Cheque-cashing ATMs

In the United States, 7-Eleven has installed NCR’s V.com TM kiosk. This ATM-based kiosk allows the cashing of paychecks, money order purchases, wire transfers (sending and receiving), bill payment and statement printing. The Internet-enabled terminal can accept cash, checks or credit cards as means of payment.48

Personalised ATMs

NCR has trialed major Australian bank software that allows users to customise the ATM screen, such as the colours, graphics, font styles, and placement and appearance of buttons and touch areas. It also allows the user to have a 'usual' transaction option to speed the cash dispensing process.49

Talking ATMs

In the United States, Bank of America has deployed 7,000 'talking ATMs' with the aim of having 3,000 talking ATMs operational by the end of 2002.50

Smart Cards

Many ATMs are able to read smart cards as well as the traditional magnetic strip cards.

Software has also been developed that allow applications to be uploaded to, or deleted from, smart cards through ATMs, such as Gemplus' GemXpresso Lite and Cards etc’s Arterium software51.

D.3 Deployment of Web-enabled ATMs

The spread of web-enabled ATMs has been low. As of May 2001, TowerGroup estimated that only 2% of all ATMs were webenabled, and in Dove Consulting’s 2002 ATM Deployment Study, they found that in the United States only 5% of financial institutions and 6% of ISOs had deployed web-enabled ATMs.

According to TowerGroup, there are 5 factors driving the conversion to Web-enabled ATMs52 :

  1. cessation of OS/2 support by IBM by end of 2003;
  2. drive to hardware independence;
  3. relative ease of development under Windows NT;
  4. explosion of machines with new functionality, being driven by the retail market; and
  5. inclusion of the self-service channel into an integrated architecture with the banking enterprise.

However, simply having web-enabled ATMs does automatically result in added functionality. For an ATM to provide one-to-one services that are tailored to the individual’s account profile and transaction behavior, the ATM needs to be integrated with other bank systems.

Progress towards one-to-one marketing appears positive:

  • the number of ATMs worldwide that were dedicated or equipped for one-to-one marketing is predicted to increase from less than 1000 in 2001 to 80,000 in 200553 ; and
  • the chart below shows that 50% of large financial institutions in the United States want to link their CRM systems to their ATMs to provide a personalised experience to users54. Generally Australia would follow the US pattern.

The chart below shows that 50% of large financial institutions in the United States want to link their CRM systems to their ATMs

Source: Dove Consulting 2002 ATM Deployer Study

D.3.1 Different types for different purposes

Different models of ATMs have developed to suit the purpose and situation in which they are used. For example:

  • on-premise ATMs55 tend to offer relatively extensive financial transaction and customer information services, are relatively larger, and have a higher cash dispensing capacity;
  • ATMs located in busy retail areas tend to be slimmer with limited account functionality. This market encompasses the growing non-bank owned ATMs; and
  • ATMs located in small stores tend to be small, have restricted cash capacity (usually refilled by the merchant), and are offered as an alternative, or in place of, EFTPOS or credit.
Table 10: Three ATMs that are currently available in Australia that vary greatly in their purpose, size and functionality:
Product criteria HERACLES by Diebold EASYPOINT 53 by NCR Nano Cash by TRANAX
Purpose On premise/Off-premise large shopping mall Off-premise shopping mall/large retail merchant Off-premise small merchant
Functions
  • Cash dispensing
  • Cheque book ordering
  • Balance details
  • Account enquiry
  • Envelope deposit for cheques & cash
  • Business deposit
  • Transaction statement printing
  • Passbooks updating
  • Electronic fund transfer
  • Electronic purse
  • Cash dispensing
  • Balance details
  • Internet-enabling ‘Self-Service TouchPoints’
    e.g. iATMglobal.net allows online movie, event or travel ticketing and other web-based facilities.
  • Cash dispensing
  • Balance details
  • 2nd cassette can be used for additional products (stamps, phone cards) denomination.
Card reader & access
  • Motorized magnetic card reader/writer plus chip card contact
  • Dip card reader
  • Swipe type card reader
Printer
  • Impact or thermal receipt printer
  • Passbook printer with turn page
  • 40 column graphics thermal printer
  • Capacity up to 145mm receipts
  • 80mm wide thermal printer
Customer Interface
  • 10' LCD
  • Infrared proximity sensor
  • Speakers for enhanced audio capability
  • Touch screen option
  • 7.5' VGA color flat panel screen
  • 6' LCD with 256 color 320 x 240 resolution
  • 10 advertisement screens
Cash Dispenser Module
  • Up-to 4 cassettes
  • 1 or 2 denomination options
  • 1st cassette (1500 #notes)
  • 2nd cassette option (500 #notes or products such as stamps, phone cards).
Other features
  • Wide range of communication options (X25, ISDN, TCP/IP)
  • Diebold Professional Services for customer specific application development
  • Web applications
  • UPS or card return on power failure option
  • PC memory extension option
  • CD-ROM 48X option
  • Modem 56K V.90 Internal modem
  • 56K modem and dial up connection
Dimensions
  • Height: 1475mm.
  • Width: 670mm.
  • Depth: 893mm.
  • Height: 614mm
  • Width: 470mm
  • Depth: 470mm
  • Height: 521mm
  • Width: 277mm
  • Depth: 500mm
Sample unit picture  Sample HERACLES by Diebold  Sample EASYPOINT 53 by NCR  Sample Nano Cash by TRANAX

D.4 EFTPOS

EFTPOS terminals also vary in functionality to cater for different merchant uses and situations. For example some EFTPOS terminals are designed to be mobile, some have applications that allowing the terminal to process loyalty scheme transactions, and more EFTPOS machines are extending past the basic magnetic strip credit and debit cards to also read smart cards.

Table 11: Three EFTPOS terminals that are currently available, that vary in the types of cards that they accept and the additional functionality that they offer
Product criteria Omni 3300 by Verifone K71i KeyPay by Keycorp K23-506 by Keycorp
Purpose Smaller merchant Medium to large retail merchant
(K71 series has 50% of Australian market)
Large retail chains requiring advanced schemes.
Transaction types
  • Debit, credit, loyalty, EBT
  • Can support multiple applications, such as payment and loyalty.
  • Debit, credit and smartcard
  • Has up to four mini smartcard modules (ID-000) that provide simultaneous support for multiple smartcard schemes including Visa Cash and Mondex.
  • Credit, debit and smartcard
  • Internet Capable: advanced multiapplication and Internet TCP/IP communications capability.
  • Can support applications such as loyalty, messaging, advertising and ticketing.
Features/Options
  • 32-bit microprocessor
  • Flash memory: 1 MB (expandable to 2 MB)
  • SRAM: 512 kB (expandable to 1 MB)
  • 128 x 64 pixel graphical LCD display
  • Magnetic Card Reader: Triple track (tracks 1, 2, 3),
  • Peripheral Ports: Two RS-232 ports and two telco ports support peripherals including PINpads, check readers, smart card readers and bar-code wands
  • Printer: Integrated thermal printer with graphics capabilities
  • High-speed dial modem
  • Smartcard reader
  • Line x 16 character LCD display
  • RAM: 128 kB (can extend to 512kB)
  • Flash memory: 512 kB (can extend to 896kB)
  • Magnetic card reader: Two track
  • RS232 serial link (for host communications)
  • RS-232 serial link (for printer or ECR)
  • Options
  • Graphics LCD
  • 122 x 32 dot matrix
  • 128 x 64 dot matrix
  • Two track magnetic card reader
  • RS-485 serial link
  • EMV Customer smartcard reader
  • RAM: 256 kB
  • Flash memory: 2 Mbytes
  • Magnetic card reader: tracks 1 /2, 2/3
  • Real time clock
  • SAM (security access module) slots
  • RS232 interface
Sample unit picture  Sample Omni 3300 by Verifone  Sample K71i KeyPay by Keycorp  Sample K23-506 by Keycorp

Some of the more advanced EFTPOS services that have been implemented in the United States include extending the processing of payment instruments beyond cards, tightening security by incorporating photo identification, and numerous wireless developments. Examples of these are provided below:

Processing Multiple Payment Instruments

QuikCash Plus Web,56 produced by Global Cash Access (GCA) has been installed in casinos in the United States.

The EFTPOS terminal allows casinos to process multiple types of financial transactions through the one device, including debit, credit cash advance, TeleCheck cheque guarantee, Western Union(R) Money Transfer(SM), QuikCredit and Central Credit.

The manual input of customer information is also minimised as it uses GCAs database to match customer profiles for automatic printing of customer names and addresses. The database holds data on over five million gaming customers.

Vital’s POS Check Service,57 by Vital Processing Services accepts credit, debit, EBT and cheque transactions in the United States.

Vital Processing Services performs the authorisation and capture, to clearing and settlement of check transactions. They also fund, bill and statement merchants for the cheque transactions.

Photo Identification

True ID System,58 by Hypercom and Identico Systems displays the customers’ photo when performing transactions.

The customer’s photo ID is scanned into the system when they provide a cheque, debit or credit card to the merchant and stored with the payment information. On subsequent uses by the customer, the system displays the stored photograph of the customer on the POS terminal.

Wireless

PowerSwipe59, by Creditel, is a card-reading device that attaches to a mobile phone, allowing credit card terminal capabilities for both smart cards and magnetic stripe cards.

Wireless solution using infrared & smart cards60 is being developed by Visa International and SK Telecom (SKT) in Singapore that will allow transactions using Visa debit or credit payments to be conducted over mobile phones.

Visa cardholders and SKT subscribers will be able to make payments by beaming an infrared signal from the mobile phone to an infrared receiver on point-of-sale terminals, vending machines, subway stalls, tollgates, buses and other payment locations.

The cardholder's payment details are stored on an EMV chip within the handset.

D.5 Mobile telephony

Mobile telephone users can purchase a product and have the bill added directly to their mobile phone account. Examples of the use of this technology include:

Magic4 has developed a bar-coding solution that enables financial transactions to be conducted via mobile phones through SMS messaging, and billed to the mobile phone account61.

NextPark62, by Voicebit Ltd is a parking control scheme operating in Finland.

Drivers register as a NextPark user on the Oulo Telephone Company website. When parking, the user dials the NextPark number and states how long they want to park for.

Users can pre-pay, have the bill invoiced to an address, charged to a user's phone bill, or settled on the NextPark website.

NextPark also provides a service warning of parking expiration via SMS, and a parking history monitoring page on their website that shows a record of parking locations, length of parking stay, and the costs.

Pepsi Cola Germany63: To purchase a drink from the vending machine, the customer dials a toll-free number displayed on the machine, the customer is authenticated as being a registered user and is able to charge the purchase to the phone account.

Coca Cola64: To pay for drinks from Coca-Cola vending machines at Central Station in Sydney, consumers dial a telephone number using their Telstra mobile, make a selection of drink which is then dispensed, and the cost of the drink is added to their mobile phone bill.

D.6 Smart cards

D.6.1 Technical details

Capacity

Smart cards vary in the amount of memory that they contain, which affects the number and types of applications that can be run. Consequently, smart card prices also vary.

  • 32K smart cards allow the same card to be used for multiple applications65.
  • 64K or 128K cards are available for high-capacity applications66.
  • Gemplus has produced a prototype card with 256MB of flash memory67.

Applications can be loaded onto the smart card by the vendor, prior to issuance, or by merchants post-issuance. Post-issuance, software development kits are available that allow developers to upload new applications via EFTPOS terminals, ATMs and the Internet68.

Platforms
Table 12: Three main smart card platforms69:
Vendor Platform Name Primary Use
Mondex Multos Financial smart card applications
Microsoft Windows for Smart Cards Network security applications
Sun Microsystems Java Card GSM & m-commerce applications
Transaction Method

Smart cards can be classed as either contact, or contact-less, depending on how the transaction is performed.

Contact smart cards require insertion into a smart card reader with a direct connection to a conductive micro module on the surface of the card (typically gold plated). It is via these physical contact points, that transmission of commands, data, and card status takes place. Financial institutions dealing with high value transactions typically use the contact style architecture.

Image depcits the differences between contact and contactless smart cards

Alternatively, contactless cards simply require a close proximity to readers to register transactions via antennae in both the reader and the card providing a link between the two.

Most contactless cards also derive the internal chip power source from this electromagnetic signal. The range is typically two to three inches for non-battery powered cards, and this is ideal for applications such as mass transit, which require very fast card interface.70

Information Access 71

Smart cards can be designed to allow different modes of access:

  • Anyone can access - Some smart cards require no password and anyone holding the card can have access (eg. to the patient's name and blood type on a MediCard, which can be read without the use of a password).
  • Cardholder only - The most common form of password for cardholders is a PIN (Personal Identification Number) and increasingly biometric-based access.
  • Third party only - Some smart cards can only be accessed by the party who issued it (eg. an electronic purse can only be reloaded by the issuing bank).

The architecture of smart cards can divide information on the card into different sections to assist in securing the information accordingly:

  • information which is read only;
  • information which is added only;
  • information which is updated only; and
  • information with no access available.

D.7 Current applications

Accessing benefits72

Smart cards have been used in Andaluca, Spain, to administer benefits since 1994 (called the TASS project) through public kiosks.

The card holds personal identifying information, which may include the cardholder’s fingerprints. When accessing benefits from the kiosk, the cardholder’s fingerprints are scanned and checked against those stored on the card, verifying the cardholder’s identity.

The data collected from the transactions can be analysed to show how the services are used.

About 20% of 6 million cardholders are enrolled to use the kiosks.

Reward programs73

ANZ is using a smart card loyalty system produced by Axiomatique International, Welcome Real-time's Asia-Pacific subsidiary. The cardholder’s recency, frequency and monetary value behavioral data will be stored on smart cards issued by program participants, which can be updated at each transaction.

Direct marketing software in the merchant's POS terminal interacts with behavioral data in the card to deliver targeted rewards.

ANZ is upgrading 1 million Visa-branded credit cards and 80,000 POS terminals to accept smart cards.

Visa has also developed a Smart Rewards Platform, which integrates payment and rewards transactions at in-store checkouts as well as online checkouts.74

D.8 International gambling scene

The United States have implemented many innovative gambling payment devices that aim to provide customers with faster, more convenient, access to funds. Global Cash Access is the core provider of payments devices to casinos and gambling institutions in the United States. Below is a description of some of their products.

Casino Cash Plus 3-in-1 ATM75

This ATM has a roll-over feature which provides a user, who is first denied a standard ATM transaction, the option of obtaining funds via a POS debit transaction and/or a pinless credit card cash advance.

QuikPlay ATM76

In essence, the QuikPlay ATM is a miniature ATM attached to every machine.77

A full rollout of the QuikPlay ATM to the market is anticipated by first quarter 2003. As described by GamingHub:78

‘The first part of the action is wireless, as the player swipes a debit card and punches in a PIN to request cash from the player's own bank account.

The return approval (via land line) bounces back to the casino server and the funds are delivered through the slot monitoring system.

The machine's EZ Pay printer then splits out a bar-coded ticket than can be reinserted to get the credits, or used in any other machine on the EZ Pay system.’

Customers are able to control spending via daily limits that they set with the ATM card issuer as well as by limits set by the QuikPlay System.

The ATM also supports GCA's Self Transaction Exclusion Program (STEP), which allows gaming patrons to exclude themselves from access to their own funds from cash access devices in the GCA network.

D.9 Device-related problem gambling initiatives

Blocking social welfare benefits79

Global Cash Access (GCA) offers an option for states that issue Electronic Benefit Transfer (EBT) cards to block access at the company's network of ATM and EFTPOS terminals.

STEP program

Self Transaction Exclusion Program (STEP) allows gaming patrons to exclude themselves from access to their own funds from terminals that are part of the GCA network.

‘Think’ program 80

Includes:

  • Point-of-decision messages on the devices;
  • Pre-recorded message played on telephone handsets;
  • 24-hour, toll-free help line number for the NCPG hotline; and
  • Other consumer and employee education materials that may be used by gaming properties as optional elements of the program.

Appendix E - Card statistics in Australia 

E.1 Cards and accounts

Number of Customer Payment Accounts in Australia

While the number of accounts has not shown consistent growth, the number of cards per account has increased, as has the overall number of cards in Australia. This suggests that in some cases, multiple numbers of people are able to access the one account.

Number of cards per Customer Payment Account in Australia

Number of Cards in Australia

E.2 Monthly EFTPOS transaction-volume and value (AUD$)

EFTPOS transactions have increased substantially over the last five years, with the value of EFTPOS transaction growing at a slightly stronger rate than the volume of EFTPOS transactions.

Monthly POS Volume

Monthly POS Value

E.3 Monthly credit card transaction-volume and value (AUD$)

The use of credit cards is clearly growing in popularity among consumers, as shown by the strong increase in usage. The volume of credit card transactions has increased at an annual rate of 38% over the last seven years.

Value of Monthly Credit Card Transactions

Monthly Volume of Credit Card Transactions

E.4 Credit card cash advance from an ATM - volume and value (AUD$)

Cash advances through ATMs using credit cards within Australia are also steadily increasing, though at a slower rate than credit card payments. This is likely to be due cash advances being exempt from interest-free periods that are offered on many credit card accounts.

Monthly Value of Cash Advances

Monthly Volume of Cash Advances

E.5 Average transaction amount from ATMs and EFTPOS

Although the growth rate of ATM and EFTPOS withdrawals is very similar (ATM withdrawals have increased by an annual average of 5%, as compared to 3% for EFTPOS), greater amounts are withdrawn from ATMs.

Average Transaction Amounts ($)

E.6 Device growth

Non-bank ATMs are increasing their share of the growing ATM market. The distribution of EFTPOS terminals also shows relatively strong growth.

ATMs in Australia

Number of ATM & EFTPOS Devices

E.7 Credit card delinquency in the USA and Australia

Australia’s credit card delinquency rate is much lower than that in the United States. The following graph represents the United States delinquency rates.

Credit Delinquencies

USA Source: American Bankers Association

% of Credit Delinquencies in Australia

Australia Source: KPMG Consulting Research

E.8 Credit card charge-offs in the USA and Australia

Australia’s average charge-off rate is approx 2.15%81, which is much lower than that experienced by the United States’ market which is represented in the following graph.

USA Credit Card Charge-off Rates

Source: US Federal Reserve

E.9 Smart card market82

As at November 2001, there were 233 million bank smart cards in the world83. According to Chris Fendley, CEO of Ecard84: in the UK, 32 million cards are changing to chip cards and ATMs are being changed to chip card technology; and by 2006, Asia will finish changing over its cards to chip cards and converting its terminals to accommodate the chip cards. According to TowerGroup there will be nearly 30 million chip-based credit cards in the U.S. by the end of the year, up 71% from 17.5 million at the end of 2001.85

Global Smart Card Market By Industry, 2001-2003

Source: epaynews.com, originally sourced from SchlumbergerSema, March 2002

Global Smart Card Market by Region, 2001-2003

Source: epaynews.com, originally sourced from Frost & Sullivan, using 2000 as base year

Regional Breakdown of Financial Smart Cards, 1999-2004

Appendix F - Financial sector consultation questions results 

The following questions were used as a guide for the consultations with the financial sector. Included is a summary of the responses received from the sector in response to each question.

  1. Does the banking sector have an overall national policy specifically relating to ATMs/EFTPOS and in particular their use in gaming venues? If so, does this policy include issues associated with access within a venue, frequency of access to funds and location of machines?

    The banking sector operates credit limits on customer credit and debit accounts. These limits reflect the financial capability of individual customers as assessed by banking institutions. Consequently there is no specific national policy relating to access to funds. Rather individual institutions make credit decisions about individual customers.

    On an operational basis this translates into limits on the total value of money that can be withdrawn from bank accounts within a 24-hour period regardless of whether access is through an ATM or EFTPOS terminal. No specific limits apply to whether the money is withdrawn in gaming or non-gaming locations. Daily limits of approximately $1000 are normal but can be increased upon request. This limit does not apply to purchases.

    A voluntary practice exists on credit cards and their use within gaming areas. Bank operators remove the credit functionality from ATMs that service gaming environments. This is also the case for independent operator Cashcard. This is in keeping with banks acting as responsible service providers within the community.

    Wider ATM legislation does exist restraining the placement of ATMs within specified gaming areas. However, as already stated this legislation only relates to the physical location of ATMs and not to access of funds. Equally, EFTPOS facilities are available within certain gaming locations e.g. NSW TAB outlets.
     
  2. At what point is legislation/regulation implemented – is it at local bank level or is the responsibility that of the venue, the acquirer or credit scheme?

    Retail operators are responsible for ensuring ATMs are not located within gaming areas. In practice, machines are located with the initial support of ATM operators who are also aware of legislation regarding the placement of ATMs.

    Within certain states/territories ATM operators within casinos provide deposit functionality. It is a moot point as to whether this is legislated for or is ‘encouraged’ by state/territory governments.
     
  3. What is the role of merchant acquirers in the financial transaction process, their relationship with banks and gaming venues and their role in developing software to address regulation?

    Merchant acquirer is understood to refer to non-bank ATM/EFTPOS operator. In Australia non-bank operators have successfully penetrated the ATM market but not the EFTPOS market. However, despite their successes non-bank operators are still reliant on banks for access to the ATM clearing system. This sponsorship arrangement is critical as long as non-bank institutions remain barred from direct participation in the clearing system.

    Gaming venues represent a good source of income for bank and non-bank ATM operators. Such sites can generate in excess of 12,000 transactions per ATM. This compares to an industry average of approximately 5,000 transactions. But non-bank ATM operators are potentially more reliant on such high volume sites given the ‘more commercial’ nature of their ATM business line.

    ATMs are increasingly located away from traditional sites e.g. bank branches. Bank and non-bank operators alike favour high throughput sites. This has generated premium-pricing arrangements between operators and the retailers. Contracts of between 3 and 5 years are commonplace. In such a competitive environment it is the non-bank operators who are increasingly winning out as banks find it hard to commercially justify increased retail pricing arrangements.

    If government were to impose further restrictions on ATM access, as of the nature indicated in the background documentation, the main responsibility for compliance would sit with the card issuer. Non-bank ATM operators can remove functionality at the terminal e.g. credit card withdrawals. However, responsibility for the tracking and management of ‘gaming’ transactions sits with the card issuer and not the acquirer. Indeed, even removing functionality from ATMs can be achieved at the issuer level. This potentially removes the need for any upgrades to the actual ATM.

    Cash limits, functionality; the card issuer can control differentiation in level of service or product, access – all centrally. This is a more cost-effective approach to addressing access issues.
  1. Who sells ATM machines and what is the role of an ATM machine provider i.e. do they design the machine to specification? Do they have any responsibility for implementation of regulation/legislation?

    ATM manufacturers deliver machines to the specification as requested by the customer. Clearly they must comply with the latest health and safety standards. Equally, manufacturers are continually developing new models of ATM with enhanced features. However, it is the client who ultimately determines what the machine specification will be.

    If legislation were passed requiring certain features to be present on ATMs then clearly the manufacturer would need to comply e.g. certain United States have moved towards an environment where ATMs are required to carry digital video cameras. However, the scenarios currently put forward as part of this research should have no material impact on the manufacturer.
     
  2. Do financial institutions hold information on frequency of use of ATMs and EFTPOS facilities in gaming venues and if so is it available?

    No. No information is available in specific relation to gaming venues. ATM and EFTPOS volumes are recorded for account management purposes. However, to be able to identify which transactions originated from gaming locations would require new naming standards for terminals located within such environments.
     
  3. Can credit cardholders still obtain cash advances through an ATM that has the ‘withdrawal from a credit card account’ option deleted?

    If the credit card function has been removed from an ATM then customers cannot obtain a cash advance on their credit account. However, credit cards do enable access to other types of account e.g. savings accounts, mortgage accounts with redraw facilities.

    In the latter example a credit card could be used to obtain cash against a credit line eg the mortgage. Legislation would have to be specific to bar these types of transactions if that is the intent of the government.
     
  4. Can credit card holders obtain credit funds from ATMs that have the ‘withdrawal from credit card account’ option deleted by going through accounts such as overdrafts, equity access loans and re-draw facilities on home loans? If so, what types of restrictions are possible at gambling venue ATMs using current technology?

    Refer to response to Question 6.

    It is possible for all terminals located within gaming venues to be classified as such. Transactions generated from such locations would carry the relevant ‘retail code’ allowing the card issuer to identify ‘gaming related’ transactions. Host systems would require changes to be able to process and make decisions based on the new transaction code. Equally, new industry naming standards would be necessary. The naming standards would allow issuers to identify ‘gaming’ transactions generated from terminals operated by third parties.
     
  5. Regardless of commercial viability:
    1. Do all or any financial institutions have the capacity to limit individual withdrawals per time period through ATMs and/or EFTPOS for persons requesting this service?

      All banks operate daily limits re: cash withdrawals. These limits are normally in the region of $1000 per day. This limit applies to withdrawals made via EFTPOS and ATM.
       
    2. Do all or any financial institutions have the capacity to set withdrawal limits per transaction on EFTPOS and/or ATMs at individual gaming venues or specific group merchants?

      A new industry-naming standard would be required. A general category could be developed for gaming locations. Then sub-categories could be developed to identify particular types of establishment eg casinos, hotels, TAB.
       
    3. Do all of any financial institutions have the capacity to set withdrawal limits per time period on EFTPOS and/or ATMs at individual gaming venues or specific merchants?

      Refer to 8(a).

      Gaming credit limits could be established within the overall daily withdrawal limit. However, as well as new naming standards, banks would need to develop their core systems. All transactions identified as originating from gaming locations would be placed against the daily gaming limit.
       
  1. In each of the above (Q8) if there is a capacity to set these limits, are these limits set by financial institutions or can they be set by individual merchants and can the limits be varied to suit individual circumstances?

    Card issuers will set the daily account limits for customers.

    Merchants can operate ‘floor’ limits for amounts under a certain value. Floor limits are agreed with the retailer’s bank.

    Individuals can request their bank to put in place non-standard limits.
     
  2. Do all or any financial institutions have the capacity to implement the following model:

    ‘Set a limit of one withdrawal per day at a gaming venue up to a maximum of $200 (or such other amount). That is, once a withdrawal of say, $50 had been made, no other withdrawal could be made from that ATM or other EFTPOS facilities at that venue for the rest of the day.’
    If the new naming standards were in place, banks could apply a limit for all transactions generated in gaming locations.
     
  3. Can ATMs and/or EFTPOS differentiate between Australian and overseas credit cards? If so, is it possible, using current technology, to restrict access by Australian cardholders while allowing overseas cardholders access? What are the options for future technology use?

    Banks can already differentiate between domestic and foreign issued credit cards. The cards themselves carry code on the magnetic stripe that identifies them as such.

    ATM operators can block credit cards at the ATM i.e. if a domestic credit card is inserted in the ATM then the ATM can refuse the card immediately.
     
  4. Is it possible for ATMs to provide ‘screen statements’ of spending over a given period, using current or future technology?

    ATMs already provide printed ‘mini-statements’. These statements are not full statements and only provide details of the most recent transactions. ATMs can also support ‘balance’ enquiries on accounts.

    In the UK Midland Bank deployed machines that supported screen statements. ‘Statement machines’ provide the full monthly transaction history.

    There is no technical reason why the functionality of statement machines and ATMs could not merge. However, the industry does face the on-going challenge of balancing the provision of cash against other services.
     
  5. Is it possible to restrict gambling venue EFTPOS machines so that there is no cash withdrawal or a withdrawal limit? If so, is this commercially viable?

    Technically it is possible to achieve either scenario. Indeed, the latter example is the strategy currently adopted in South Australia. However, the issue is whether operators can implement such strategies and remain commercially viable.

    The South Australian example has illustrated how increased operating costs can effectively remove smaller operators from certain business lines. Physical upgrades to terminals can mean the difference between profitable and non-profitable EFTPOS terminals.

    Any further restriction of EFTPOS access, whether requiring software, systems or physical upgrades, will force all operators to review the provision of this service. It can be anticipated that certain operators would withdraw from certain business lines rather than bear the expense of upgrade costs.
     
  6. In general - is current ATM/EFTPOS technology available that is not being utilised, that could assist in minimising spending by problem gamblers?

    Banks have access to technology (velocity checking) that identifies ‘patterns’ of transactions. This has historically been used to identify fraudulent transactions. Such technology could be applied to transactions originating from gaming locations. However, as already mentioned, new naming standards need to be in place to identify gaming venues.
     
  7. Do financial institutions have ongoing research into, and development of, ATM and EFTPOS technology and software? If so, are these coordinated and available to all institutions? What type of budget if any, is provided for development of technology and software?

    Financial institutions operate ATM and EFTPOS budgets. These budgets cover the on-going operation of the networks, purchase of new equipment and expansion (new business). A relatively small amount of budget is used for development and testing purposes. And each institution will research technology that is relevant to its own commercial circumstances.

    Terminal manufacturers invest heavily in the on-going development of technology and software. The financial services industry as a whole benefits from such investment i.e. availability of improved terminals. Manufacturers might also take the lead on innovative new features eg digital cameras within ATMs.
  1. If new regulations/legislation were introduced would each merchant acquirer and or bank need to develop their own technology for major changes to ATMs/EFTPOS to which they link?

    Australian Payments Clearing Association (APCA) is accountable for managing the Australian payments clearing systems. Any naming changes for gaming locations would be handled by this authority. APCA would ensure that all institutions participating in the clearing systems comply with any new regulatory standards on message types. Member banks would meet any costs for development.

    Work to host systems and terminals would be the responsibility of the banks. That does not mean that banks would not attempt to recover some costs from merchants eg through higher merchant fees.
     
  2. Is there any evidence that financial institutions are developing technologies that may by-pass ATMs and EFTPOS and allow access to credit accounts? If so, would this have any possible application in a gambling venue?

    Wireless technology enables customers to access banks accounts via devices such as mobile telephones. 3G telephones will be available in Australia in 2003. Banks will utilise and support this technology as customer demand increases. In the UK Barclays bank provides mobile telephones to its customers at a discount price.

    The ultimate implication for gaming is that customers will be able to access funds via a mobile telephone and then transmit those funds directly to the gaming machine. This will make redundant any legislation specific to ATMs and EFTPOS terminals.
     
  3. It is understood that most, if not all financial institutions are able to set global limits on withdrawals for individuals who request this service. Is it possible for financial institutions to develop technology that would allow a person to set a withdrawal limit (including no withdrawals) on ATMs or EFTPOS located at the specific gaming venue) or all gaming venues)?

    Devices within gaming areas need to be identified as being located within a gaming area. It then becomes technically possible to place ‘gaming limits’ on customer accounts. Those limits can be generally applied or individuals could request tailored limits.
     
  4. Specifically, what changes to technology would be required (and what are the associated costs) to enable banks to implement limits to ATMs and EFTPOS cash facilities that:
    1. Limits an amount per transaction
      No financial institution is in a position to provide costs associated with all potential scenarios. This would only be possible if the government was to engage in further consultation around specific propositions. Equally, upgrades to technology can only be discussed in detail through further consultation.

      Blanket limits can be put in place to restrict an ATM/EFTPOS transaction to $200.

      Any requests for further amounts are simply not authorised by the host system.
       
    2. Limits the number of transactions per day or per 24 hour period
      As above. All banks operate a daily ‘value’ limit of approximately $1000. Rather than track the value of transactions banks could track the volume.

      Potentially very significant cost implications with significant work required to core systems.
       
    3. Limits per person
      Individual limits are already available.
       
    4. Limits per card Individual limits relate to specific products.
      Individual limits relate to specific products.

      One single limit covering all product types represents significant development work. This single view of the customer is what banks have aspired to for 10 years. It is true that banks have made good progress to date. However, a single credit profile is still a good way off for most institutions.
       
    5. Limits on account type or card type (credit vs debit card)
      Limits already apply to different product types.
       
    6. Limits in a) – e) applying to individual gaming venues
      As already discussed, a naming convention is required for gaming locations. It then becomes technically possible to differentiate the level of service provided on products in such locations.
       
    7. Limits in a) – e) applying to all gaming venues
      As above.
       
    8. Combinations of the above
      As above.

      Some examples of different combinations are:
      • Limit a person to accessing non-borrowed funds only, up to a maximum amount per person per 24-hour period in all gaming venues in a State/Territory. (i.e. A person is limited to one withdrawal transaction per day at Hotels up to $200. The ABC hotel has one ATM and 3 EFTPOS facilities. A person makes a withdrawal of $50 at the ATM on his ANZ savings card. The person should not be able to access any further funds at any of the other facilities in the hotel with the same or other cards and should not be able to access funds at another hotel for the next 24 hours)

        The above scenario is only possible if the customer only has cards issued by the same institution. And only then if the institution is able to establish a single view of the customer i.e. can identify and track activity across all product types and channels.

        If a customer holds cards issued by more than one institution then a central switch is required. The central switch would need to monitor all transactions using a unique customer ID. No central switch exists and no unique customer ID exists.

        Once the single view of the customer is established then transactions can be tracked. However, the new naming convention is also necessary to establish gaming locations.
         
      • As above but limits only apply to a single venue

        Once the central monitoring capability is established then it is irrelevant whether transactions originate either from one or multiple gaming locations.
         
      • Maximum withdrawal limit, per card, per day (i.e. limits only last until midnight and then resets), per gaming venue

        As above. The only issue is one limit per gaming venue. If a customer visits a number of locations then the system needs to carry a number of fields to accommodate each location.

        The above three examples assumes that ATMs and EFTPOS facilities are linked in a way that for example, a withdrawal from an ATM at a venue is recognised by the EFTPOS at the same or other venue for the purpose of establishing an overall limit either at that venue or all venues.

        ATMs and EFTPOS work off central systems. However, there is currently no facility to track and monitor transactions generated
        from specific locations. The only limit in place is the $1000 cash withdrawal limit.
  1. Following on from Question 19, to what extent could the following limits be implemented by (and what are the associated costs of) altering the design of / reconfiguring ATM/EFTPOS facilities located in gaming venues? 86
    The banks are not presently in a situation to provide costs on individual solutions. Further consultation with the industry would be required.

    Limits on an amount per transaction
    This tactic is straightforward and in keeping with current State legislation.

    Limits on the number of transactions per day or per 24 hour period
    As already stated, this requires banks to track the volume of transactions and not the value. This potentially requires significant work.

    Limits per person
    As above. $1000 daily cash withdrawal limit is already in place.

    Limits per card
    As above. Limits per person relates to limits per product. If a person has more than one product then the daily limit is increased.

    Limits (and prohibitions) on account type or card type (i.e. credit and borrowed funds)
    As above.

    The above limits should be assessed in the following combinations:
  • Limit a person to accessing non-borrowed funds only, up to a maximum amount per person per 24-hour period from all ATM/EFTPOS facilities located within a gaming venue.
    As already stated, monitoring capability needs to be established along with a naming convention for different types of gaming location.Once this is in place any number of different controls can be applied.
     
  • As above but limits only apply to a single ATM/EFTPOS facility
    As above.
     
  • Maximum withdrawal limit, per card, per day (i.e. limits only last until midnight and then resets), per all ATM/EFTPOS facilities within a gaming venue.
    As above.
     
  • As above but limits only apply to a single ATM/EFTPOS facility.
    As above.
     
  • Any other relevant combination.
    As above.

Footnotes

  1. Industry refers to all the sectors involved in the discussion and management of problem gambling, that is the financial services sector, the community sector, the gaming industry and the regulators within the various states and territories.
  2. The RBA report – Reform of Credit Card Schemes in Australia had not been released prior to the completion of this research.
  3. Department of Family and Community Services, Gambling Policy and Support Internet Site http://www.facs.gov.au/internet/facsinternet.nsf/aboutfacs/programs/comm...
  4. Tasmanian Gaming Commission (2001)
  5. Department of Family and Community Services, Gambling Policy and Support Internet site http://www.facs.gov.au/internet/facsinternet.nsf/aboutfacs/program/commu...
  6. Australian Bureau of Statistics 1999.
  7. Australian’s Gambling Industries Productivity Commission report, December 1999
  8. ibid
  9. Australian’s Gambling Industries Productivity Commission report, December 1999
  10. Select Committee on Gambling, ACT, 1999 p 12 based on Hraba and Lee
  11. Volberg, Moore, Christiansen, Cummings and Banks, 1998, p 350
  12. Australian’s Gambling Industries Productivity Commission report, December 1999
  13. ibid
  14. For definitions of the various stakeholders captured within the term ‘industry’ within the context of this report please refer to Appendix C Glossary of terms.
  15. www.facs.gov.au/internet/facsinternet.nsf/aboutfacs/programs/community-g...
  16. It should be noted that the individual states and territories also undertake research in accordance with their own needs and interests
  17. www.facs.gov.au/internet/facsinternet.nsf/aboutfacs/programs/community-g...
  18. Productivity Commission Australian Gambling Industry Report, p 44, figure 11
  19. Productivity Commission Australian Gambling Industry Report, p 44
  20. It should be noted that South Australia do allow cash advances allowed on credit cards via ATM and EFTPOS.
  21. EFTPOS cannot issue cash out on credit card.
  22. Tasmanian Gaming Commission Licensed Premises Gaming Operators Code of Practice – Provision of Cash for Gaming
  23. ACT Gambling and Racing Commission, Code of Practice, Discussion Paper, April 2001
  24. ACT Gambling and Racing Commission, Gaming Act 1997, Policy Paper, December 2001
  25. Source: Australian Institute for Gambling Research – Survey of the Nature and Extent of Gambling and Problem Gambling in the ACT
  26. Australian Institute of Gambling Research, Survey of the Nature and Extent of Gambling and Problem Gambling in the ACT, July 2001, p125-126
  27. Source: International Gaming and Wagering Business publication, October 2000 & American Gaming Association website.
  28. National Gambling Impact Study Commission, section 7, p 30
  29. NGISC – overview p6
  30. NGISC – overview p7
  31. It is understood that the bill did not proceed due to a range of matters being deferred as a consequence of the events of September 11 2001 in the United States
  32. American Gaming Association, website fact, Facts Sheets- ATM/Credit in Casinos
  33. Las Vegas Review-Journal, July 20 2001
  34. Source: American Gaming Association, March 2002
  35. Source: International Gaming and Wagering Business publication, October 2000. * Total of 12 provinces
  36. Department for Culture, Media and Sport, Gambling Review Body, Gambling Review Report, July 2001
  37. Department for Culture, Media and Sport, Gambling Review Body, Gambling Review Report, page 125, July 2001
  38. IBID
  39. This information was provided by the ACA during the consultations.
  40. Australian Casino Association questionnaire response dated 9 July 2002.
  41. Appendix F contains a summary of the response to the key questions to be addressed as part of the project brief.
  42. *Not all stakeholders felt able to provide an indicative figure on the likely scale of investment required to undertake such work given the lack of detailed specifications. However, from information collected a figure of $20m serves as a reasonable indication on the degree of investment required by the financial services industry.
  43. Richard Bell, 'The Rise and Evolution of ATMs – A Brief History,’ TowerGroup, February 2000
  44. Richard Bell, ‘The Rise and Evolution of ATMs – A Brief History,’ TowerGroup, February 2000
  45. Source: TowerGroup
  46. Richard Bell, ‘The Rise and Evolution of ATMs – A Brief History,’ TowerGroup, February 2000
  47. Source: TowerGroup
  48. http://www.ncr.com/repository/articles/self-service/new_age_atms.htm
  49. http://www.ncr.com/repository/articles/self-service/new_age_atms.htm
  50. Brian O'Connell, ‘Next-Generation ATMs Proliferate; Got fees? Big banks see Web-enabled ATMs as cash cows,’ Corporation Bank Technology News, section: NEWS, Vol. 15, No. 4, Pg. 7, April 2002.
  51. A. Briney ‘A Smart Card For Everyone?’ Information Security, March, 2002; ‘Acer Selects Arterium for its Smart Card Management Bureau’ PR Newswire February 10, 2002.
  52. TowerGroup, ‘Kalignite…..’
  53. Brian O'Connell, ‘Next-Generation ATMs Proliferate; Got fees? Big banks see Web-enabled ATMs as cash cows’. Bank Technology News, Sec: News, Vol. 15, No. 4, Pg. 7, April, 2002 – Referencing Celent Communications’ March 2002 report ‘Advanced-Functionality ATMs: The Next Generation.'
  54. EFT REPORT, ‘EFT Network Strategies Shift to Address New ATM Realities,’ Vol. 25, No. 5, March 6, 2002 – References Dove Consulting’s ‘2002 ATM Deployer Study
  55. An on-premise ATM is the term used to define financial institution owned ATMs that are located at the bank branch.
  56. CardFlash, ‘GCA Signs 76 QuikCash Contracts,’ 5 April 2002
  57. CardFlash, ‘POS Check Service’ 5 August 2002
  58. CardFlash, ‘POS Photos,’ 9 May 2002
  59. CardFlash, ‘Phone Payments,’ 05 April 2002
  60. Visa And SKT Launch First Wireless Payment System Using EMV And Infrared’ Canadian Corporate Newswire, May 22, 2002
  61. http://www.magic4.com/press/pr/singapore-250401.html - Magic4 Internet Site
  62. http://www.voicebit.fi/news_show1.asp?id=62 - Voicebit Internet Site and Presswire
  63. PR Newswire European, ‘Brooktrout and CTI LABS team with Pepsi Cola Germany at CeBIT to deliver a mobile fulfillment solution for consumers,’ 13 March 2002
  64. Australian Financial Review, ‘Dial-a-Coke Flags Mobile E-commerce,’ 25 July 2001
  65. A. Briney ‘A Smart Card For Everyone?’ Information Security, March, 2002
  66. ibid
  67. ibid
  68. ibid
  69. ibid
  70. Gemplus Smartcard Basics http://www.gemplus.com/basics/index.htm
  71. KPMG Consulting
  72. C.Bowen ‘Welfare Agencies Seek Benefits From Chip Cards’ Card Technology, January, 2002
  73. ‘ANZ rolls out first smart card application’ Cards International, January 11, 2002
  74. 'Visa U.S.A. (What's New)’ Chain Store Age Executive, June 2002
  75. CardFlash, ‘Casino ATM Clients,’ 10 May 2002
  76. CardFlash, ‘ATM Slots’ 23 April 2002
  77. GamingHub, ‘Debit Cards At The Slots Closer Than Ever’ 6 March 2002 http://www.gaminghub.com/jsps/featuredarticle.jsp
  78. GamingHub, ‘Debit Cards At The Slots Closer Than Ever’ 6 March 2002 http://www.gaminghub.com/jsps/featuredarticle.jsp
  79. NewsEdge, ‘Global Cash Access Offers States Option to Block EBT Cards At Gaming Locations,’ 3 May 2002. & Global Cash Access Internet site (http://www.globalcashaccess.com)
  80. CardTrak, ‘Think Before You Withdraw,’ 30 April 1999
  81. Merrill Lynch 2000 report
  82. Epaynews.com (http://www.epaynews.com/statistics/scardstats.html)
  83. Epaynews.com, original source: Celent Communications , November 2001
  84. M. Mack, “Smart Cards To Get Boost In Australia” Newsbytes, April 19, 2002
  85. “Smart Cards Set To Grow?” ATM & Debit News, January 31, 2002
  86. The combinations are based on an assumption that the proposed methodology (i.e. altering / reconfiguring cash facilities) would not be capable of imposing an individual withdrawal limit (whether per person or per card) that would apply across all gaming venues over a given period.

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