Proposal: Auditable “High-Risk Gambling Indicators” (Regulatory Definition)

This document proposes a regulatory definition and an initial, auditable indicator set for identifying patrons at materially elevated risk of gambling-related harm in mobile sports wagering.

• Deterministic calculations: indicators are rule-based (or have a rule-based “bright line” trigger) so an auditor can reproduce the result from raw logs.
• Event-level logging: operators retain a tamper-evident log of deposits, wagers, wins/losses, withdrawals, cancellations, limit changes, and RG-tool use.
• Indicator event log: when an indicator is met, the operator records an entry with (a) indicator ID, (b) timestamp, (c) inputs/values (e.g., deposit_count=5), (d) time window, and (e) action taken.
• Uniform definitions: key computed terms (e.g., “net loss”) use a single statewide definition; “promotional credits” are excluded from loss calculations unless the rule explicitly includes them.
• Cross-operator option: for the strongest protections, indicators can be calculated at a statewide layer across all operators (especially net loss and deposit escalation), but the indicator definitions should work per-operator if statewide integration is not yet implemented.

Financial/Payment Markers

• HR-01: Rapid deposit frequency — ≥ [N] deposits in a rolling 24-hour period.
• HR-02: Rapid deposit escalation — the patron’s total deposits over the last 7 days are ≥ [X]× the patron’s typical 7-day deposits baseline (e.g., median of prior 8 weeks).
• HR-03: Large net loss in short window — net loss exceeds [$X] in [7] days (or exceeds [Y%] of typical monthly discretionary income, if the jurisdiction adopts an affordability framework).
• HR-04: Repeated failed/denied deposits — ≥ [N] failed deposit attempts within [24] hours.
• HR-05: Multiple payment instruments — ≥ [N] distinct payment methods added or used within [7] days.
• HR-06: Withdrawal reversal / cancellation — ≥ [N] cancelled or interrupted withdrawals within [30] days (or cancellation rate ≥ [Z%]).

Behavioral/Session Markers

• HR-07: Extended active wagering sessions — active wagering time exceeds [T] hours in a day on [M] or more days in a rolling [14]-day period.
• HR-08: Overnight wagering pattern — ≥ [P%] of wagers placed between [12:00 a.m.–6:00 a.m.] on [M] or more nights in [14] days.
• HR-09: In‑play / micro‑bet intensity — ≥ [N] in‑play wagers in a single session or ≥ [N] wagers within [60] minutes, sustained over [K] sessions in [7] days.

Loss-Chasing Markers

• HR-10: Deposit-after-loss (“chasing”) pattern — within [10] minutes after a net losing sequence of ≥ [$X], the patron makes a new deposit, and this pattern repeats ≥ [N] times in [7] days.
• HR-11: Stake escalation after losses — average stake size in the 24 hours after a net losing day is ≥ [X]× the patron’s baseline stake size.

Responsible-Gambling Tool Signals

• HR-12: Repeated limit increases — ≥ [N] increases to deposit/loss limits within [30] days, or any increase above a high threshold set by rule.
• HR-13: Repeated timeouts / previous self-exclusion — repeated short timeouts (≥ [N] in [30] days) or any prior self-exclusion within [24] months.

• Calibration approach: start with conservative thresholds; evaluate false positives and missed harms quarterly; revise through transparent rule updates.
• Tiering option: define Tier 1 (friction + messaging), Tier 2 (mandatory limits/timeouts), Tier 3 (hard stop). If the statute mandates a hard stop, reserve it for the most predictive indicators or for multi-indicator combinations.
• Equity/fairness review: require periodic disparate-impact analysis and publish aggregate results; adjust indicators that create unjustified bias.
• Privacy: avoid collecting sensitive external data unless strictly necessary; use minimization, retention limits, and purpose limitation (no marketing use).
• Auditability: require third-party system audits and regulator access to event logs sufficient to replicate indicator triggers and operator responses.