Betting Exchanges Consultation Responses

The Betting Exchanges Consultation was issued by the Board in July 2010 and closed on 20th September (with a period permitted for further representations until 23rd November 2010). The Levy Board welcomed views from all interested parties and invited responses on various questions relating to and arising out of the issue of whether certain users of betting exchanges should be regarded as being leviable bookmakers for the purpose of the Levy. The consultation paper, along with associated documents, can be found here. The responses to the paper are as follows:


1. Response from Individual.pdf
2. Response from Individual.pdf
3. Association of British Bookmakers.pdf
4. Betfair.pdf
5. Response from Individual.pdf
6. Federation of Racecourse Bookmakers.pdf
7. Global Betting Exchange UK Ltd.pdf
8. Response from Individual.pdf
9. Response from Individual.pdf
10. Response from Individual.pdf
11. Response from Individual.pdf
12. Response from Individual.pdf
13. Racing.pdf
14. Response from Individual.pdf
15. Response from Individual.pdf
16. Response from Individual.pdf
17. Response from Individual.pdf
18. Response from Individual.pdf
19. William Hill.pdf

The Levy Board allowed any other consultee who wished to make any further representations to supply them for consideration before 5pm on Tuesday 23rd November 2010. The Levy Board agreed to consider representations from a third party who had not made a submission before the first deadline. Further submissions are as follows:

1. Betfair rebuttal of Racings submission to HBLB Betting Exchanges Consultation.pdf
2. Betfair comment on submissions to the HBLB Betting Exchanges Consultation.pdf
3. Further response from individual 1.pdf
4. Association of British Bookmakers.pdf
5. Federation of Racecourse Bookmakers response to Betfair comment on submissions.pdf
6. Federation of Racecourse Bookmakers response to Betfair comment on submissions (Annex 1).pdf
7. Response from individual.pdf
8. Response from individual.pdf
9. Response from individual.pdf
10. Racing.pdf
11. Further response from individual 17.pdf
12. William Hill.pdf

The Levy Board has received further documents (see below). These were received after the deadline for further representations of 5pm on Tuesday 23rd November 2010. It will be a matter for the Board to consider in due course whether to take account of these late materials and their significance.

1. Betfair Additional Letter.pdf
2. Federation of Racecourse Bookmakers Explanatory Note.pdf

The Levy Board has since received two legal opinions from Lord Pannick QC and Michael Fordham QC on the issues raised in the consultation. A summary of the conclusions reached in the two legal opinions has been received from HBLB's solicitors, Herbert Smith LLP. These are available here:

Michael Fordham QC Opinion.pdf
Lord Pannick QC Opinion.pdf
Summary of Conclusions.pdf

The Levy Board invited any interested party wishing to express any views on the two legal opinions to do so by 8th April 2011. The responses are as follows:

1. Betfair Response.pdf
2. Simon Mehigan QC opinion (Part of Betfair Response).pdf
3. Federation of Racecourse Bookmakers Response.pdf
4. Conor Quigley QC opinion (Part of Federation of Racecourse Bookmakers Response).pdf
5. Response from Individual.pdf
6. Racings Response.pdf
7. Dinah Rose QC and Ben Jaffey opinion (Part of Racings Response).pdf
8. Kevin Prosser QC opinion (Part of Racings Response).pdf
9. Response from Individual.pdf

The Levy Board has received additional advice notes from Michael Fordham QC and Lord Pannick QC:

Legal Advice Note of Michael Fordham QC 8th April.pdf
Legal Advice Note of Lord Pannick QC 14th April.pdf
Legal Advice Note of Michael Fordham QC 11 May.pdf
Legal Advice Note of Lord Pannick QC 11 May.pdf


The Board has also considered two further documents, as below:

Olswang letter to Paul Roy 19th April.pdf
Board Paper for Levy Board Meeting 20th April.pdf

Last Updated: 12 October 2017