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Betfair Cross Matching Algorithm

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Dear Gambling Commission,

Betfair, operating under a Remote Betting Intermediary License operate a gambling exchange and on that exchange they implement algorithms they call Cross Matching. This Cross Matching involves Betfair effectively insider trading on their exchange by matching some incoming bets with an internal account without offering them to other customers. This occurs even when the requested odds (or even better odds) are being offered by another customer.

In your Enforcement Report 2017-2018 you mention that you have looked into the Cross Matching Algorithms without finding any issues.

I would therefore like you to provide:
1. Copies of all documentation regarding cross matching provided by Betfair.
2. Copies of all documentation regarding cross matching provided by any third party.
3. Copies of all correspondece between yourself and Betfair regarding cross matchinhg.
4. Any internal reports regarding cross matching.
5. Any other reports or correspondence that contain technical details on the workings of the cross matching algorithm.

Yours faithfully,

T Sanders

Freedom of Information, Gambling Commission

Dear Sir/Madam

Thank you for your request for information which we are processing as a request under the Freedom of Information Act 2000.

We aim to deal with all requests promptly and in any event, no later than 20 working days in line with the statutory requirement. In this case 23/07/2019

If you have any queries about this email, please contact us.

Kind regards

Freedom of Information Team

GAMBLING COMMISSION
4th Floor
Victoria Square House
Victoria Square
Birmingham B2 4BP
Tel: 0121 230 6666
www.gamblingcommission.gov.uk

This email and any files transmitted with it are intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please return it to the address it came from indicating that you are not the intended recipient and delete it from your system. Do not copy, distribute or take action based on this email. Freedom of Information requests can be submitted either by email ([email address]) or by writing to: FOI request Gambling Commission Victoria Square House Victoria Square Birmingham B2 4BP Please clearly state that your request is under the Freedom of Information Act.

Freedom of Information, Gambling Commission

1 Attachment

Dear Sir/Madam

 

On 25 June 2019 you submitted a request made under the Freedom of
Information Act 2000 (FOIA). You requested the following information.

 

Betfair, operating under a Remote Betting Intermediary License operate a
gambling exchange and on that exchange they implement algorithms they call
Cross Matching. This Cross Matching involves Betfair effectively insider
trading on their exchange by matching some incoming bets with an internal
account without offering them to other customers. This occurs even when
the requested odds (or even better odds) are being offered by another
customer.

 

In your Enforcement Report 2017-2018 you mention that you have looked into
the Cross Matching Algorithms without finding any issues.

 

I would therefore like you to provide:

1. Copies of all documentation regarding cross matching provided by
Betfair.

2. Copies of all documentation regarding cross matching provided by any
third party.

3. Copies of all correspondence between yourself and Betfair regarding
cross matching.

4. Any internal reports regarding cross matching.

5. Any other reports or correspondence that contain technical details on
the workings of the cross matching algorithm.

 

 

Your request is very wide as you have requested all information the
Commission holds relating to ‘cross matching’ and as you have not
specified any further criteria, we can only search our systems for ‘cross
matching’. Our search reveals that there are 5,143 emails and 41,864 other
items that meet this search term. Please see attached document which
provides evidence of this.

 

Section 12 of the FOIA makes provision for public authorities to refuse
requests for information where the cost of dealing with them would exceed
the appropriate limit, which for public authorities, such as the
Commission, is set at £450. This represents the estimated cost of one
person spending 2.5 working days in determining whether the department
holds the information, locating, retrieving and extracting the
information.

 

Within the statutory timeframe. we estimate that we could process searches
that would result in the retrieval of approximately 100 items. We have
worked this out at 10 minutes per item to locate and retrieve each item.
In order for us to provide you with any information within the statutory
time limit you would need to provide us with very specific search criteria
and or time frame.

 

Until we are able to process the search and retrieval of the information
you have requested, that we can provide within the statutory time limit,
we are unable to ascertain if other exemptions will apply to the material
retrieved which would also prevent disclosure.

 

Please note, your refined request would be processed as a new request and
the 20 working day statutory time limit would apply.

 

Review of the decision

 

If you are unhappy with the service you have received in relation to your
Freedom of Information request and wish to make a complaint or request a
review of our decision, you should write to FOI Team, Gambling Commission,
4th floor, Victoria Square House, Victoria Square, Birmingham, B2 4BP.

 

If you are not content with the outcome of your complaint, you may apply
directly to the Information Commissioner (ICO) for a decision. Generally,
the ICO cannot make a decision unless you have exhausted the complaints
procedure provided by the Gambling Commission. The ICO can be contacted
at: The Information Commissioner’s Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire SK9 5AF.

 

Kind regards

Freedom of Information Team

 

GAMBLING COMMISSION

4th Floor

Victoria Square House

Victoria Square

Birmingham B2 4BP

Tel: 0121 230 6666

[1]www.gamblingcommission.gov.uk

 

 

 

This email and any files transmitted with it are intended solely for the
use of the individual or entity to whom they are addressed. If you have
received this email in error please return it to the address it came from
indicating that you are not the intended recipient and delete it from your
system. Do not copy, distribute or take action based on this email.
Freedom of Information requests can be submitted either by email
([email address]) or by writing to: FOI request Gambling
Commission Victoria Square House Victoria Square Birmingham B2 4BP Please
clearly state that your request is under the Freedom of Information Act.

References

Visible links
1. http://www.gamblingcommission.gov.uk/

We don't know whether the most recent response to this request contains information or not – if you are T Sanders please sign in and let everyone know.