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Meeting with Andrew Beveridge of eCOGRA


Sunday, March 12, 2006

Meeting with Andrew Beveridge of eCOGRA


I met up with Andrew Beveridge of eCOGRA - "e-Commerce Online Gaming Regulation and Assurance" - last Tuesday, at their London Offices in Berkeley Square. Andrew had invited me as an offshoot of our email correspondence over the Bella Vegas issue, and since I had long had issues I wanted to discuss with them, this was the ideal opportunity to get it on.

Andrew agreed to be recorded; unfortunately, I managed to run out of tape after the first 45 minutes and will have to rely on memory to report beyond the first two matters.

This report is very long, so I'm including navigation links which will take you to the relevant sections:

The Lake Palace incident and general dispute competence

Bella Vegas: the underage gambling issue

Independence of eCOGRA and conflict of interests

G4 - the "Global Gambling Guidance Group"

TGTR - "Total Gaming Transaction Review"

Concluding remarks




The Lake Palace incident and general dispute-competence


This regarded a highly contentious bonus-disqualification issue discussed at Casinomeister 18 months ago - see the Lake Palace do an Omni thread. To summarize the incident: the player made a large deposit, at Lake Palace Casino, for an advertised bonus and was refused it on the basis of his bonus-orientated play; the player complained to eCOGRA; Tex Reese, the Fair Gaming Advocate, found for the casino on the basis of the casino's catch-all "we reserve the right" clause; the player complained in the above thread, and after much fallout eCOGRA reversed their atrocious decision.

My question to Andrew was: what happened here? Why did you change your minds, and on what basis?


Before going onto the answer, I should preface my remarks here, exactly as I did to Andrew, by saying that eCOGRA was never set up to be another "Safebet" or "OPA" - a meaningless rubber stamp we can laugh off. From the outset, eCOGRA was a highly-touted, highly-publicised initiative between two of the biggest software providers, Microgaming and Cassava, and the recipient of much high-profile coverage from Bryan Bailey at Casinomeister, Brian Cullingworth via his Infopowa news service, and a lot of other high-profile press from other high-profile outlets. eCOGRA hit the ground running fast with all the adherent advantages to themselves and the casinos to which they issue the seals. The "downside" for eCOGRA - if I may express it that way - is that they must now answer to a higher set of values, and be prepared to be called to task and justify their decisions and actions to an extent that few other organisations have ever been required so to do.


eCOGRA have put themselves in the spotlight and must answer to the spotlight. In the following discussion I am extremely hard on the eCOGRA Fair Gaming Advocate; I make absolutely no apology for this.


So, what happened here?

Andrew was extremely upfront about this: he ran me over the basic events from his end, and stated unequivocally that both the casino representative responsible for bonus disqualification, and Tex Reese, the Fair Gaming Advocate, got it wrong. When he was alerted to the message board situation (by whom, I don't know), he got onto the manager of the Lake Palace group and between them they agreed that a mistake had been made at both ends, both by Lake Palace and eCOGRA, the mistake was rectified and the player was paid. There was no subsequent evidence that came to light to change the decision (this was suggested to me by one high-profile webmaster as the only reasonable justification for the decision reversal); this was simply a mistake.


My follow-up question was: how could such a remedial mistake be made? Bonus-disqualifications are the NUMBER ONE cause of player complaints; if a player has a problem with a casino, ninety five percent of the time a bonus will be a the root. If an online casino watchdog hasn't got their "rules of conduct between player and casino when a bonus is involved" handbook, something is wrong. Furthermore, this was an easy call, as no rules were infringed and the player was entitled. How could such a remedial mistake, on such a remedial issue, be made - and by such a highly touted organisation?

Andrew's response was to point out that this mistake has never been repeated subsequently: after maybe a thousand issues, this was the only one to have been so badly screwed up. In response to my interjection that this was something of a sign of inexperience, Andrew pointed out that Tex had had only about eight months' worth of experience of the job at that time, and had never come across a situation like this. As balance, Andrew also pointed out that they've received appreciative feedback from players on other issues.

In summary, and I quote: "It was a once off, we all learned from it, and that's an end of it."


I followed this up by asking why it was that a person inexperienced in these matters was put in the position of ever having to deal with them at all - why give such a job to an inexperienced person? Why not cast the net a bit wider and find someone with the know-how they'd need to handle these issues?

Andrew's response here was to say that bonus-disqualifications are only a part of the job. I, myself, may see them as the biggest area of contention, but they're only a part, and there are other aspects I am apparently not aware of.

What other aspects? At this point, I tried to elicit examples of player dispute management that would be beyond, for example, my own area of expertise, and that of many other people with long experience of the online gambling business - and people who would, in my opinion, be better qualified for such a job (I should point out I wasn't hankering after the job myself here).

What does Tex have to deal with that an experienced person, who would not make remedial bonus-disqualification errors, would not be up to scratch with?

Andrew and I back-and-forthed quite a bit here; he mentioned issues of game-fairness as a big area of player disquiet. I asked how you could handle this any way other than explaining politely to the player that as far as eCOGRA is concerned the games are certified fair by PWC? Andrew also spoke of general back office admin know-how, knowing the operators, being on good terms with them etc etc.

I don't dispute this is of value, but again I do not see this as a skill outside the competence of any reasonably intelligent person, whereas the nitty-gritty of bonus issues most definitely IS.


On this, Andrew and I ultimately disagree. My own feeling is that, based on this evidence, this key role went to the wrong person; Andrew's stance is that one mistake out of a thousand is acceptable and that the person doing this particular job is the right one. Fair enough; on this matter, he and I are not at one.

(Back to content links.)






Bella Vegas: the underage gambling issue


This relates to the matter discussed at length at the WinnerOnline forum in the Bella Vegas discussion, and about which Andrew and I exchanged emails.

Summary: Underage player deposited 17 times and cashed out three times; upon request of a substantial cash out - £13,000 GBP - she was investigated and found to be underage according to the jurisdiction she resides in, Nevada; eCOGRA, taking council from G4, recommended that the casino not pay her because of her underage status, as amongst other things this would open a whole can of worms and establish a dangerous precedent.


I don't dispute that Andrew made the "right" call on the above basis; however, my interest in re-raising this matter heads up between us was to ask if it would not have been, or yet be, possible to find a compromise that would NOT have so wholly disadvantaged the girl? Not to pay anything as a "debt" or "winnings", but to find a compromise solution, a goodwill gesture or something along these lines? There was an opportunity for quite a bit of kudos for all parties involved - could a solution not have been found?


Essentially, we didn't get any further on this than we did via our email exchange - my request to rethink and our follow up exchange; Andrew remains firm on this matter, that the risk of setting a dangerous precedent far outweighs any possible kudos from a player-friendly resolution. If an underage player successfully "circumvents" the casino controls on sign up until such a time as they cash out, payment is too slippery a slope to go down - what if it were a five year old? Also, Andrew draws the parallels with same situation on land - an underage player can play. Again, I pointed out that in my own experience security is VERY tight at the Vegas tables - ID checks are made for anyone who looks under 40 - and, again covering old ground, that walking into a casino is NOT the same as signing into a piece of software - the checks are right there and then.


Andrew turned things over to me here and asked if there were any reasonable options for a completely foolproof method that would guarantee no underage players, in my opinion. He contends that age-verification pre-deposit is not an option for casino operators, because it's basically an intrusive turn off and will just not work. In short, it's a practical impossibility to have foolproof system that does not discourage players. I pointed out that Cryptologic, for example, have a marginally "inconvenient" upfront check, in the form of a mailed pin number, before a player can physically cash out. Andrew pointed out that this is not an age-check, but an anti-fraud device, and though this is the kind of player "turn off" the operators dislike apparently working successfully, it is not a way of guarding against underage play.


At this point we arrived at a bone of contention: I said that, notwithstanding the difficulty of finding an acceptable solution, players are being DISADVANTAGED by receiving only their deposits back - as did this player. Andrew did not consider this unfair. To make the point, I gave the example of a player making 37 deposits into 37 casinos, placing one wager on one inside roulette bet, losing 36 deposits, winning on one, and on that one having the winnings confiscated and the deposit returned. This basically turns a 2.7% house edge into a near enough 100% house edge. Andrew took this point, but said that this is not happening in any great degree - he recalls only two such issues since the beginning.


To summarise Andrew's stance: there is no option for any form of compensation to this player on the basis of setting a dangerous precedent; to make age-verification checks at the point of signup is not a realistic option; and that fairness is achieved by the return of the players' deposits.

To summarise my own: I believe that a solution could have been achieved that would NOT have set an unfortunate precedent - one such was suggested by a webmaster halfway through the Bella Vegas thread; additionally, however difficult it might be to age-check at the outset, it is not acceptable to disadvantage potentially unwitting underage players with an inadequate system. It is up to the makers of the system to find an answer to the problem - to say that this is impossible is not acceptable.

(Back to content links)





Independence of eCOGRA and conflict of interests


eCOGRA is funded by Microgaming / Cassava; how can you pay the wages of those people who regulate you, without creating a conflict of interests?

I asked Andrew for a brief description of what constitutes the "independence" of eCOGRA: the three non-eCOGRA directors - Hirst, Catania and Galston - have no interest in the providers Microgaming and Cassava; these folk award - and potentially revoke - the seals; they also have "override" powers over the other directors, so in the event of disagreement between executive and non-executive directors, the independent panel's vote would carry; they're paid a nominal salary, but not enough, in Andrew's opinion, to jeopardise their integrity in favour of an eCOGRA casino.


On the direct matter of conflict of interests by being paid by those you regulate: Andrew points out that it's the licensees - in the case of Microgaming - who are being regulated, not the providers themselves (the case with Cassava is different); the licensees pay nothing. The providers would no doubt welcome somebody else stepping up to the plate and funding the initiative, but it's not happening. The setup is NOT ideal - Andrew acknowledges this - but to quote him directly, "It's not the best situation, but I think it works because of the way we've constituted the company in terms of giving the control of it to the independent directors."


I suggested that there were potential alternate models that may be regarded as better / more "independent" - such as the Player Committee of the old Online Player Association; would these be things to consider? This got us back to talking about dispute resolution again. Essentially, Andrew's stance if "if it isn't broke, don't fix it"; that said, he does not rule out the possibility of player-involvement down the line, and, as he pointed out, the fact of us sitting down having our discussion is evidence that doors are open in one form or another; also, he is in contact with players as and when is needed. In essence: the system works, though the imperfect system of funding by those you regulate is not ideal; beyond that, there is potential for a future broadening of the system from its currently slightly incestuous basis.

(Back to content links)



(At this point, my tape recorder clicked off. We were within five minutes of the end of our scheduled session, so I didn't bother to turn the thing over. This turned out to be a fine mistake, as we carried on for a further half hour, but I really didn't particularly want to interrupt the flow by fiddling with the equipment again. I'm left to report the rest from memory, so it will inevitably be a little sketchy, my memory being absolute crap.)




G4 - the "Global Gambling Guidance Group"


I'd intended to bring this matter up myself, but Andrew mentioned it before I had the chance.

G4 have a large set of "suggested practices". Microgaming casinos really do not do a particularly good job of respecting the guidelines, and Cassava even less so; is it credible to be hooked up with an organisation whose guidelines your members so disregard?


Andrew makes no bones of the fact that the G4 guidelines are simply impractical to implement for the members - the "age verification" guideline we had already covered in great deal, in which he made the case for age-verification upfront being a serious problem in terms of realistic implementation. It's also true that the "reality checks" guidelines are extremely taxing for online casinos. On the upside, G4 provides valuable backup - as an example, the Bella Vegas issue, in which Andrew liaised with G4 and accepted their guidance; there have been other spin-offs, for example the recent Kahnawake Gambling Commission interest in issues of player protection came about, amongst other reasons, as a result of the eCOGRA alliance with G4.


My own feeling here is that, difficulties notwithstanding and acknowledged, it is ironic that an alliance is formed where there is such disregard for the code of practice of one party on the part of the members of the other. Practicalities notwithstanding, it is ironic. At the same time, if eCOGRA consider there is player-benefit to be had as a result of the alliance, that the alliance should then not exist simply because of the serious infringement of the G4 code on the part of Microgaming / Cassava may also not be the optimal situation.

All things considered, I DO consider the code of practice's inadequate implementation an issue, though I acknowledge Andrew's points.

(Back to content links)





TGTR - "Total Gaming Transaction Review"


This was a matter already discussed at length at WOL, and I wasn't necessarily expecting anything new to crop up running it by Andrew; I did, however, want to outline concerns that have been raised.

For anyone unfamiliar with this, you can read up on it at the relevant TGTR egap page. In essence, it represents eCOGRA's "fair gaming guarantee".


My basic contention, and that of several other people, has always been that since the collection / verification of data process is secret, it can have little credibility or relevance to the gambling public - what is the point of a "fair gaming guarantee" about which we know absolutely nothing beyond being told that it exists?


Again, Andrew acknowledged the point, and he outlined reasons why PriceWaterhouseCooper have always kept this process a tightly guarded secret: risk from competitors, misinterpretation / misunderstanding of the facts etc. However, he also told me that PWC DO routinely conduct seminars on the subject - they were due to do one, if I recall this correctly, for the Alderney Gambling Commission this past weekend. He also told me that he has lobbied PWC for greater disclosure on the matter, for them to go beyond conducting question and answer sessions purely for close-knit sections of the gambling industry and start to look towards the possibility of reaching out to a wider audience, including possibly interested players / portal owners and such like. This hasn't happened yet, but he is apparently pushing for it.


Also, although this process is entirely outsourced and eCOGRA plays no part in it whatsoever, the basics of what is involved is not unknown to them - Andrew outlined a small part of it to me, including the odd-sounding name of one of the processes involved which I can't remember for the life of me. He also contends that it isn't excessively complex, and that a straightforward presentation of it, along the lines of what he has apparently lobbied PWC for, is enough to inform and ally concerns about the integrity of the data collection process.


Fair enough, and all this is good to know - so watch this space. If any of the above comes to pass, we can re-judge, and for my part I hope this happens. Until it DOES happen, one is inevitably left thinking that that which is entirely undisclosed and unexplained in any shape or form whatsoever cannot be regarded with much credibility.
If the games are "proven fair", show me HOW.

Hopefully this will now start to materialise.

(Back to content links)



At this point, Andrew was now left with ten minutes to prepare for the meeting he had been hoping to have at least a half hour to work on, so we shook hands and went our separate ways.


I hope the above is a faithful representation of Andrew's responses - particularly the last half hour that I failed to get on tape. I'd like to thank him for taking a decent chunk of his afternoon to speak to me, particularly in light of the fact that he and eCOGRA have taken a fair amount of flack from some of us. Although there are plenty of contentious issues remaining, it'd be fair to say that going heads up and getting things on the table was a positive step - and several new things did certainly come out that I was unaware of.

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1 Previous Comments


The whole thing is a play on words.

"He also told me that he has lobbied PWC for greater disclosure on the matter, for them to go beyond conducting question and answer sessions purely for close-knit sections of the gambling industry and start to look towards the possibility of reaching out to a wider audience, including possibly interested players / portal owners and such like. This hasn't happened yet, but he is apparently pushing for it.

For 4 years Ecogra have been assuring the games are fair. Seems to me if Beveridge were not working for Ecogra, he would question the validity of Ecogra assuring players the game is fair too.

By Blogger Gamblog UK, at 11:41 pm  


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