11 Stake Retention     

11.1.1

Stake Retention to create jackpots or rollover prizes has been legal for bingo clubs since the introduction of the Gambling Act 2005 in September 2007. Stake Retention is simply retaining stake money to be used as prizes in future sessions. Retained stake is returned as a jackpot, bonus or an enhanced game prize at a later date and cannot be taken as par fee or as any other retrospective charge. 

11.1.2

Any stake monies paid by customers and used for future prizes must be clearly identified as such on the Charges To Play Notice, with the contents of the retained stake pot being separately accounted for and a full audit trail of all its in-coming and out-going transactions maintained. 

It states in (2) (f)…a bingo licence may not be subject to… 

a) preventing or limiting an arrangement whereby the fact that a prize is not won or claimed in one game of bingo increases the value of the prizes available in another game of bingo. 

b) preventing a condition being attached to a Bingo Operating Licence which prohibits or limits the roll-over of prizes between bingo games. Neither the Secretary of State nor the Gambling Commission may attach a condition relating to the roll-over of prizes. 

This permits the provision of retained stake and its use for rollover jackpots which may not be prohibited or limited by the conditions of the Bingo Licence. 

11.4.1

Part 5, Section 91 of the 2005 Gambling Act permits an arrangement whereby a prize not won or claimed in one game of bingo increases the value of the prizes available in another game of bingo. 

11.4.2

While no particular restrictions currently apply to the use or administration of Retained Stake, it would be prudent to maintain an accurate and comprehensive record of all transactions both in and out of the collected stake pool. 

11.4.3

If you use stake retention in particular games, it is important to ensure that your records are comprehensive and reflect the amounts held per game. 

11.4.4

In keeping records for the playing of this type of game, it is important to ensure that your procedures comply with the ‘Licence Conditions and Codes of Practice’ licence condition 4.2.1 ‘Protection of Customer Funds – Disclosure to Customers which states: 

a) Licensees who hold customer funds must set out clearly in the terms and conditions under which they provide facilities for gambling information about whether customer funds are protected in the event of insolvency, the level of such protection and the method by which this is achieved. 

b) In this condition ‘customer funds’ means the aggregate value of funds held to the credit of customers including, without limitation. 

c) cleared funds deposited with the licensee by customers to provide stakes in, or to meet participation fees in respect of, future gambling. 

11.4.5

Section 5 Cash Handling in the LCCP – Licence condition 5.1.1 states… 

• Licensees, as part of their internal controls and financial accounting systems, must have and put into effect policies and procedures concerning the handling of cash, and cash equivalents (i.e. bankers drafts, cheques and debit cards), designed to minimise the risk of crimes such as money laundering, to avoid the giving of illicit credit and to provide assurance that gambling activities are being conducted fairly. 
• The proportion or how much stake is being retained and on what game, must be shown on the ‘Charges to Play notice. 
• Providing that there is a clear audit trail of income and winnings for each ticket identified as having retained stake, the accumulated stakes can be recorded per ticket, or as a club ‘pot’, as detailed in your company policy.