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Gaming Machine Harm Minimisation Measures Consultation Paper

Response Form

Your details

|Name |Christopher Byrne |

|Organisation (If applicable) |Yarraville Club Incorporated |

|Email address |manager@.au |

|Address |Yarraville Club |

| |135 Stephen Street |

| |YARRAVILLE. 3013 |

|Telephone | |

Please note:

All submissions will be published on the Department of Justice and Regulation’s website.

Please ensure that your submission does not include confidential, commercial-in-confidence or personal information.

The department reserves the right to not publish information that could be seen to be defamatory, discriminatory or unrelated to the review.

Questions: Gaming Machine Harm Minimisation Measures

These questions should be read in conjunction with the Gaming Machine Harm Minimisation Measures Consultation Paper

|Q.1. Is the current $200 per EFTPOS transaction limit appropriate? If not, what other regulatory measures would support the objectives of the |

|Act? |

|Whilst this limit has worked to assist in controlling withdrawals for gaming purpose, it has created inconvenience for non gaming customers |

|(I.e, restaurant, bistro and function room customers), many of whom wish to withdraw more than the $200 amount in one transaction. Perhaps |

|increasing the transaction limit from $200 to $300, which will assist these customers. |

|Q.2. Is the current $1,000 threshold for the payment of winnings by cheque appropriate? If not, what should be the limit and why? |

|The current threshold of $1000 before cheque payment has caused difficulty for many customers who are expecting to receive cash for their |

|winnings. Customers continue to get frustrated when their winnings are around the $1500-$2000 amount with many customers continuing to play |

|down there winnings to $999 to avoid having to take a cheque. |

|I suggest increasing the cheque threshold to $2000 and in addition, allow a combination of cash and cheque payment. Similar to arrangements |

|currently in place in Tasmania whereby a customer whose winnings exceed the cash payment amount can opt to take cash up to the cheque payment |

|amount and cheque for the remaining amount. |

|For example, if a customer wins $2000 under the current $1000 threshold, they could opt to take up to $1000 in cash and the remaining $1000 |

|would be paid by cheque. |

|Q.3. Should payment by EFT be permitted in addition to, or as a replacement for, payment by cheque? |

|EFT should be permitted as a way of paying large winnings to customers. This process could be facilitated within 24 hours allowing customers |

|to avoid the 5 day cheque clearance barrier currently in place with banks. |

|Process and procedures would need to be established to ensure fraud by venue staff and customers is not an issue. |

|Q.4. Are there other payment methods that should be considered for the payment of credits / winnings? |

|The possibility of customers having an account (similar to wagering) where they can deposit their winnings/money for use later. It may be |

|possible to implement this process but also ensure as part of the process that the account holder also becomes a pre-commitment registrant thus|

|assisting the customer in setting limits and reducing the chances of problem or excessive gambling. |

|This system could be implemented via the TITO or cashless gaming model. |

|Q.5. Should venue operators be able to exchange personal cheques for cash? |

|As a rule, most venues do not accept personal cheques as a payment form due to the risk of potential fraud. |

|Yarraville Club does not support this method being allowed. |

|Q.6. If cashless gaming and or TITO is introduced, how should they be regulated so that they are consistent with other measures that limit |

|access to cash? What harm minimisation measures should apply? |

|TITO should be regulated in line with other harm minimisation measures. TITO works well in the NSW and QLD model and Yarraville Club |

|encourages the Government to use these models as a guide. |

|Q.7. What opportunities are there to improve the way codes operate in Victoria? |

|Are there other models that would be more effective? If so, what are they? |

|Would a more prescriptive approach for all venue operators be better? Could the operation of codes be simplified? |

|Are there other matters that should be provided for in the Ministerial Direction for codes? |

|What requirements for loyalty schemes should be included in a code to promote responsible gambling? |

|Does the annual review process contribute to fostering responsible gambling? If not, why not? Are there other options to ensure that the codes |

|meet this aim? |

|Current codes appear to work well and Yarraville Club does not see any need for change. |

|The annual review process works well whereby staff and management have the opportunity to discuss and modify recesses to suit venue specific |

|needs. |

|Q.8. Should the requirement to interact with customers who are showing signs of distress from gambling be part of codes, or should a separate |

|offence be created for venue operators who fail to respond to suspected problem gambling? |

|Currently, venue staff and management do interact with customers and will assist or provide advice to customers who may be identified as having|

|a frustration or problem. |

|It is important to remember that venue staff in the most are not formally qualified to deal with problem gamblers. Identifying a problem |

|gambler is not always an easy process as unlike RSA, problem gamblers do not always show distinct signs that they are distressed or have a |

|problem. |

|Yarraville Club believes that more fact based research needs to be undertaken in this area before change is introduced. |

|Q.9. Are self-exclusion programs best administered by the industry or by another body? |

|The self exclusion program currently works fine, however, it should be able to be viewed online as opposed to traditional emails and paper |

|based exclusion information. |

|Online helps to protect customer privacy and can also be integrated into venue CCTV systems that may allow for facial recognition technology. |

|This technology would be a positive step In Assisting venue staff to identify an excluded customer In a Venue. |

|Cost considerations would need to be taken into account with this process. |

|Q.10. Should there be one self-exclusion program in Victoria? |

|Yes. |

|Q.11. How could self-exclusion programs be improved? |

|By putting them online and linking to CCTV cameras so that facial recognition technology could be used. Currently it is quite difficult for |

|venue staff to remember the faces of the excluded patron and it is even harder to identify them in the venue with many excluded patrons |

|changing their appearance regularly. |

|Q.12. Is the annual review useful or are there other ways to report on program trends and compliance? |

|Annual review is useful and allows venue staff and management to reflect on how the program has worked over the last 12 months. |

|Q.13. Should there be a separate offence for venue operators who knowingly allow self-excluded persons to enter or remain in the venue? |

|Yes. This would be consistent with making our industry a safer and better self regulated industry. Responsible operators would not knowingly |

|allow this to occur and the industry should penalise the irresponsible operators if they allow this to occur. |

|Definition around 'knowingly allow' would need to be clearly defined. |

|Q.14. Should a new requirement to undertake advanced responsible service of gaming training be introduced? |

|yes |

|Q.15. If so, who should be required to complete the advanced training and what content should the training include? |

|Management staff and venue operator/nominee |

|Q.16. Who should be responsible for the development and provision of the advanced training? |

|an external and qualified consultant in conjunction with industry and government. |

|Q.17. Do you think regional caps and municipal limits should be maintained? Why? |

|Yes. But they should be reviewed in line with the changing demographic and population numbers in the areas. |

|Q.18. Should regional caps be extended beyond the existing capped areas and if so, why? |

|No. Current system works well. |

|Q.19. Are the current regional cap and municipal limit levels appropriate? |

|They need to be adjusted up or down in line with the current demographic and population in the area. |

|New growth areas/suburbs are currently under serviced by community clubs. Government should look at a new zoning area for community clubs to |

|be established in new suburb areas. This zoning would allow community/sporting club facilities to be introduced by other clubs and the revenue|

|from gaming machines could assist in providing better community facilities. Currently new sites are only being set up by Hotels as zoning I. |

|These areas allows for tavern/hotel use and the cost of acquiring the land by a club operator is prohibitive and subsequently hotels are set up|

|and profits go to hotel operator and not the community. |

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Interested persons and organisations can make a submission on the issues raised in the Gaming Machine Harm Minimisation Measures Consultation Paper by completing this submission form.

This response form includes the questions from the Gaming Machine Harm Minimisation Measures Consultation Paper.

If you have any queries about this process please email the following address with the subject heading – Harm Minimisation Consultation Paper.

Email: liquorgamingandracingenquiries@justice..au

Submissions must be received by 5pm, Monday 16 January 2017.

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