What a UK casino VIP programme actually changes in 2026

A tier label sits at the top of every rewards page, promising faster service, bigger limits and a person on the other end of the phone. None of that is fiction, and none of it changes the rules the Gambling Commission writes for every operator it licences. A higher tier at a UK casino buys relationship perks. It does not buy exemption from the stake cap, the wagering cap or GAMSTOP. That gap between the marketing word and the rule is the page’s working question.

The figures and licences below were verified against the Gambling Commission’s public register on 7 November 2026.

Payments, payout speed and the limits that govern them

A VIP tier sits on top of the same Faster Payments rails and the same debit-card acquirers that every other account uses. The change is upstream, in how the operator reviews a withdrawal, not in how the money moves.

Faster Payments runs underneath every UK payout

Bank transfers inside the United Kingdom travel through the Faster Payments Service, launched in 2008 and operated by Pay.UK. The service runs around the clock, with most payments landing instantly or within a couple of minutes; the scheme sets a £1,000,000 per-transaction limit, although individual banks impose their own ceilings below that figure. The Bank of England does not process payments directly but oversees the system’s safety and stability and provides final settlement. None of that changes when an account moves up a tier — Faster Payments carries the money either way, with the same upper bound, on the same rails.

Apple Pay sits on the same tokenised layer

Apple Pay is developed and operated by Apple Inc., launched on 20 October 2014 and opened to UK-issued cards on 14 July 2015. Card data is protected through tokenisation, replacing the actual card number with a device-specific Device Primary Account Number and generating a dynamic security code for each transaction. In-store payments use near-field communication, and on iPhones with Face ID a purchase is authenticated by double-clicking the side button; on Touch ID models, by double-clicking the Home button. Apple states that a supported card from a participating issuer is required, and that Apple Pay is not available in all markets. A higher loyalty tier at a casino does not change the tokenisation path; it changes how quickly a withdrawal after Apple Pay is reviewed, not how the original deposit travels.

AstroPay and the wider wallet picture

AstroPay was founded in 2009 and is headquartered in Uruguay; it operates as a global digital wallet offering online payments, virtual and physical debit cards, and peer-to-peer transfers. Its UK entity, Larstal Limited, is an electronic money institution authorised by the Financial Conduct Authority under the Electronic Money Regulations 2011. Other AstroPay entities sit in the Isle of Man, Brazil and Denmark, each under its home regulator. From a UK player’s seat, the regulator matters more than the headquarters: Larstal Limited is the body whose authorisation shows up on a deposit page, and that authorisation governs disputes and safeguarding. AstroPay serves users across markets including Argentina, Australia, Brazil, Canada, Colombia, Denmark, Spain, the United Kingdom, the United States and Uruguay — a footprint that tells a player the wallet is not exotic, just non-bank.

What a tier actually moves on payouts

Higher-tier accounts are sometimes reviewed for faster withdrawal processing once identity and source-of-funds checks are complete, though the underlying payment rails stay the same. The mechanism is review, not rail: a flagged large withdrawal may sit in a manual check queue regardless of tier, because the check is a regulatory requirement, not a courtesy. Two numbers deserve attention. The Financial Conduct Authority and Gambling Commission rules require source-of-funds checks to be satisfied before a payout above certain thresholds is processed, and the operator’s own payment team decides when that paperwork is complete. A tier can move a withdrawal to the front of the queue; it cannot move it past the queue.

Bonuses, free spins and the wagering cap

The single most expensive line in any VIP welcome pack sits a player is unlikely to read closely. Wagering requirements — the multiplier applied to a bonus before it can be withdrawn — are the mechanism by which a casino recoups the headline figure.

The 10x ceiling is the page’s own arithmetic

Since 19 December 2025 the Gambling Commission has capped wagering requirements at 10x for bonuses offered to UK players, and banned mixed-product offers such as a sports bet that pays out in casino spins. A £100 bonus now requires at most £1,000 of qualifying play before withdrawal; a £500 bonus, at most £5,000. The cap is per bonus, not per account, so a multi-stage welcome pack is read as separate bonuses, each capped independently. That structure is the reason a page on VIP programmes has to put a number on turnover before it puts a number on value: the headline is the bonus, the real cost lives one layer down.

How long a 10x bonus takes to clear

Take a £200 bonus at the 10x ceiling: required turnover is £2,000. At a £1 stake per spin and a 2.5-second minimum spin duration that the Commission also enforces, £2,000 in wagers is 2,000 spins of five seconds each, which works out to roughly 2.78 hours of continuous play. At a £0.20 stake the same turnover is 10,000 spins, or about 6.94 hours. That is the band — between roughly 2.8 hours at a £1 stake and nearly seven hours at a 20p stake — in which a player with a 10x-capped bonus at £200 clears the requirement through slot play alone. The arithmetic is mechanical, and the figure the page should carry is the band itself, not one number from it.

Free spins and the same ceiling

Free spins awarded by a VIP tier count towards wagering the same way a cash bonus does: any winnings are bonus funds until the wagering requirement is met, and the 10x cap binds the multiplier. A pack of 50 spins at £0.10 per spin is, in bonus terms, a £5 headline at 10x, meaning £50 of qualifying turnover; the same 50 spins at £1 each is £50 of headline at 10x, meaning £500 of qualifying turnover. The free-spin headline looks lighter than the cash-bonus headline for the same number of spins, and it is, but only because the stake-per-spin is smaller.

The cost in expected loss

Expected loss = required turnover × (1 − RTP). A £200 bonus with £2,000 in required turnover at a 96% RTP costs £80 in expected loss; at 94% RTP, £120. Those figures sit on top of the bonus itself: the £200 is paid out only after the £2,000 has been wagered, and the £80 (or £120) is what the player statistically loses along the way. A welcome pack that reads “£500 bonus” carries the same arithmetic at five times the figure, which is why a 10x cap is binding only at the edge of what an operator is willing to advertise.

Top 10 UK casino VIP and loyalty programmes compared

The ranking below is drawn from the Gambling Commission’s public register on 7 November 2026. Every licence is verified; no bonus terms are carried because the wagering cap and the responsible-gambling rules apply to every operator on the list.

The wider landscape, in numbers

The Commission’s public register listed 139 businesses holding an active remote casino operating licence on 18 September 2026. The register can be searched online and downloaded in full as CSV or Excel files. The register’s domain list records each website against the licence account that runs it, with a status of Active, Inactive or White Label; on 18 September 2026 it held 1065 active and 361 white-label domain entries.

How the table is read

The columns below are licence holder and GB remote casino licence, then domain status on the register, then subject support — the same shape every site in this set ships, with the wording chosen here. “Subject support” carries the operator’s own published positioning on VIP or loyalty programmes, where the research turns anything up.

Three brands share a single licence account — Ladbrokes, Coral and Gala Bingo, all under LC International Limited — and another two, Virgin Games and Jackpotjoy, run under Gamesys Operations Limited. The duplication is not a redundancy; it is the structure of a market in which one corporate group can run several consumer-facing brands under a single Commission licence. A reader comparing loyalty programmes across the table is comparing brand-level pages that all sit on top of one regulated entity each, with the responsible-gambling and stake rules identical across the lot.

Coral — wide-floor brand with the LC stack behind it

Coral (coral.co.uk) is listed on the register as an active domain of account 54743, LC International Limited, which holds the active remote casino operating licence 054743-R-330863-014. Coral runs a tiered loyalty programme published on its promotions page, with named levels that move up with tracked activity. Because Coral shares its licence with Ladbrokes and Gala Bingo, the responsible-gambling controls — GAMSTOP enrolment, deposit prompts, reality checks — apply identically across all three. The distinction is brand-level: a Coral loyalty tier is paid in Coral perks, not Ladbrokes perks, and a player moving across the three brands finds a different rewards page rather than a different regulator.

BetVictor — a single-operator loyalty stack

BetVictor is listed as an active domain of account 39576, BV Gaming Limited, holding the active remote casino operating licence 039576-R-319370-028. The brand’s VIP programme is positioned around a personal host for higher tiers and a points-based loyalty scheme underneath. Because BetVictor is the only consumer brand on BV Gaming’s licence in this set, the loyalty conditions on the page are also the conditions on the licence: no shared-brand confusion, one operator, one rule book. That single-stack structure is what a player who reads terms closely tends to find clearest.

Virgin Games — white-label structure

Virgin Games is listed on the register as a white-label domain of account 38905, Gamesys Operations Limited, which holds the active remote casino operating licence 038905-R-319430-022. A white-label site trades under another company’s licence, which is the Gamesys licence here. The brand runs its own promotions and its own VIP framing on its site, but the regulatory layer beneath — Commission oversight, LCCP conditions, GAMSTOP integration — is Gamesys’s to satisfy. Virgin Games players moving into a higher tier move within Gamesys’s compliance envelope.

Ladbrokes — the LC cluster’s flagship

Ladbrokes is listed on the register as an active domain of account 54743, LC International Limited, with the same active remote casino operating licence 054743-R-330863-014 as Coral and Gala Bingo. The loyalty programme is published on Ladbrokes’s own promotions page; a higher tier earns a personal account manager, tailored promotions and priority withdrawal review. The mechanics are the same as Coral’s, because the operator behind the page is the same. What differs is the brand front and the bettor mix the tier is calibrated for: Ladbrokes has historically skewed toward sports, which is the segment its VIP terms read.

Jackpotjoy — Gamesys brand for casino-first players

Jackpotjoy is listed as an active domain of account 38905, Gamesys Operations Limited, with the licence 038905-R-319430-022. As with Virgin Games, the regulatory backbone is Gamesys, and the brand’s VIP framing is calibrated to its audience — slots and bingo rather than sports. Loyalty tiers move on tracked slots and bingo play, and the rewards on offer (free spins, prize draws, a host for the top tier) reflect that mix. Two brands on one licence mean two separate loyalty programmes written by the same compliance team.

PokerStars — a single-vertical loyalty scheme

PokerStars is listed as an active domain of account 39108, Stars Interactive Limited, holding the active remote casino operating licence 039108-R-319334-026. Stars Interactive runs only this consumer-facing brand on the licence in this set, so its loyalty conditions are uniquely its own. PokerStars’s tier programme is calibrated to poker rake and casino turnover combined; the higher tiers pay in tournament tickets, prize multipliers and a personal contact. The vertical is what gives this brand its narrowness: a player looking for the deepest slots-loyalty scheme finds shallower rewards here, because the programme is built around poker points.

Gala Bingo — bingo-led, LC-backed

Gala Bingo is listed as an active domain of account 54743, LC International Limited, holding the active remote casino operating licence 054743-R-330863-014. As the third LC brand in the table, Gala Bingo shares its regulator and its responsible-gambling framework with Coral and Ladbrokes, and runs a loyalty programme shaped around bingo play. Higher tiers trade tracked bingo spend for a personal host and event invitations. A reader comparing Gala Bingo to Coral has to compare brand-level mechanics: the regulatory floor is identical.

William Hill — multi-vertical loyalty under WHG

William Hill is listed as an active domain of account 39225, WHG (International) Limited, holding the active remote casino operating licence 039225-R-319373-015. William Hill is the only consumer brand on this licence in the table, and its loyalty programme runs across sports, casino and bingo on a single points structure. The breadth is real: a sports bettor and a slots player sit on the same loyalty ladder, which is unusual in a market where most operators split the verticals. The regulatory layer is single-brand too, which makes terms easier to read against the licence they sit on.

Grosvenor Casinos — high-street heritage

Grosvenor Casinos is listed as an active domain of account 57924, Rank Interactive (Gibraltar) Limited, holding the active remote casino operating licence 057924-R-334666-005. The brand runs a loyalty programme that links online play to its land-based casino estate; higher tiers earn hospitality, event invitations and a personal host. The retail connection is what makes the programme legible — points are tracked across both channels — and is the differentiator versus operators without a high-street footprint.

Midnite — newer stack, single brand

Midnite is listed as an active domain of account 42647, Dribble Media Limited, holding the active remote casino operating licence 042647-R-321653-022. Midnite runs a single-brand loyalty scheme across sports and casino, with named tiers that earn free bets, free spins and a host at the top. Because the licence sits on Dribble Media alone in this set, the programme is read against one set of compliance obligations. The newer licence position is the relevant comparison: a younger operator with one licence, one programme, no shared-brand ambiguity.

The fundamentals a UK player actually moves inside

A VIP tier is the top of a pyramid; the pyramid’s other layers are the rules every player shares, regardless of status. The shape of that pyramid is what changes the value of a tier.

Licences and the public register

The Gambling Commission’s public register is the whole test of whether a brand holds a UK remote casino licence. Anything that fails the register fails the page. The register is downloadable as CSV or Excel, with the licence account, the licence number, the trading names and the domains all listed. The reading is mechanical: find the brand, confirm the licence number, note the account holder. That sequence is what every UK-facing comparison above performs.

Stake caps, deposit limits and the floor they set

Online slots carry a maximum stake per game cycle — £5 for players aged 25 and over (from 9 April 2025) and £2 for 18-24 (from 21 May 2025). There is no state-set deposit or loss ceiling; operators must prompt a customer to set a financial limit before the first deposit (from 31 October 2025). Since 31 October 2021 auto-play is banned, a slot spin may not be faster than 2.5 seconds, and losses disguised as wins are banned. A higher loyalty tier changes none of those figures. The stake cap is the same on a fresh account as on a top-tier one.

The 10x wagering ceiling

The 10x wagering-requirement cap that came into force on 19 December 2025 binds every bonus offer at a licensed UK casino. It applies regardless of tier, regardless of brand, regardless of whether the offer is a VIP welcome pack or a one-off free-spin drop. That ceiling is what gives the calculation earlier in the page its shape.

Identity, age and the minimum the regulator insists on

Name, address and date of birth are verified before the first deposit or any play, and have been since 7 May 2019. Minimum age is 18. A VIP tier cannot exempt an account from either requirement; the verification happens before a tier is even assigned, because tier assignment depends on tracked activity, and tracked activity cannot start before an account is verified.

Legality, regulation and what the licence actually buys

A licensed UK casino operates inside a specific regulatory envelope; an offshore casino operates outside it. The difference is the page’s other working question.

The Gambling Act 2005, and what flows from it

The Gambling Commission is the regulator, sponsored by DCMS, under the Gambling Act 2005 — which covers Great Britain (England, Scotland, Wales), not Northern Ireland. Since the Gambling (Licensing and Advertising) Act 2014 any operator taking customers in Great Britain needs a Commission licence wherever it is based; a Curaçao, Maltese or Gibraltar licence is not a substitute. Online casino is licensable. That is the regulatory floor every operator in the table stands on.

What changes in 2026 and what does not

The 10x wagering cap, the £5/£2 slot stake cap and the financial vulnerability checks that began in February 2025 are the year’s structural changes. The 21% Remote Gaming Duty was raised to 40% from 1 April 2026 — model only, check with HMRC — which is an operator-side figure, not a player-side one. Players pay no tax on gambling winnings in the UK.

Offshore and what an unlicensed site cannot offer

Providing gambling to people in Great Britain without a licence is an offence under section 33 of the Gambling Act 2005. The Commission disrupts illegal sites through cease-and-desist notices, search-engine delisting, and payment and hosting referrals, but has no ISP-blocking power. No penalty is aimed at the player; what the player loses on an unlicensed site is protection — no GAMSTOP, no Commission complaints route, no approved ADR. That last point is what a tier cannot create either: ADR sits on the licence, not on the loyalty programme.

Responsible gambling and the rules a tier cannot lift

A higher tier might shorten a withdrawal review queue; it does not shorten the responsible-gambling framework every licence carries.

GAMSTOP is mandatory, not optional

GAMSTOP, the national online self-exclusion scheme, is a mandatory condition of every online licence since 31 March 2020, with periods of six months, one year or five years; the period cannot be cancelled early. A tier cannot exempt an account, because the condition is on the operator, not on the customer. A player who has self-excluded cannot be marketed to a higher tier, cannot be moved up a tier, and cannot be re-engaged; the operator’s licence is the lever that enforces that.

Deposit prompts and reality checks

Since 31 October 2025 operators must prompt a customer to set a financial limit before the first deposit. Reality checks are also mandatory, surfacing at intervals during play. Auto-play is banned since 31 October 2021, and a slot spin may not be faster than 2.5 seconds. None of those controls move with tier. A top-tier player gets the same prompt before the first deposit, the same reality check interval and the same minimum spin duration as a new sign-up.

Financial vulnerability and source-of-funds checks

Financial vulnerability checks run at £150 net deposits in a rolling 30 days (from 28 February 2025) using public data only; the wider financial risk assessments are announced but not yet in force. Source-of-funds checks sit on top of that — a separate, deeper review at higher withdrawal thresholds. A higher tier does not exempt an account from either; the operator’s licence obliges the check.

Where help is found

The National Gambling Helpline is run by GamCare, with GambleAware funding treatment and research. Both are independent of any operator and outside any loyalty programme. A tier cannot route a player past GamCare; a player who needs the helpline gets the helpline, regardless of the loyalty status.

Crypto, anonymity and what a “VIP account manager” is and is not

A dedicated VIP account manager is one of the more heavily marketed perks in this space. The page’s job is to put it in the right place.

The host is a relationship, not an identity bypass

A dedicated VIP account manager is a relationship-management perk, not an anonymity feature, and it sits on top of identity checks that every licensed-casino player completes regardless of tier. The host is the operator’s interface with the player: a single contact who knows the account, processes withdrawals faster when paperwork is in order, and tailors offers. None of those functions bypass the verification. The host’s job is to keep the account inside the rules.

Crypto and the licensed-casino position

Crypto is not a payment rail the UK-licensed casino set in this table advertises as a deposit method. The Commission’s position is that anonymous play is not possible at a licensed site, which rules out the crypto path that an offshore VIP programme might use. A player holding bitcoin at a non-UK casino is outside the Commission’s licence net; the same player at a UK-licensed operator is on a debit card, a bank transfer or a regulated e-wallet. The two paths do not overlap, and a tier at one does not translate to the other.

The credit-card ban and the e-wallet ceiling

From 14 April 2020 the Gambling Commission banned the use of credit cards to fund gambling across all online and offline gambling products in Great Britain, except non-remote lotteries paid for face-to-face; debit card and bank transfer deposits were unaffected by the ban. The Commission estimated that around 800,000 UK consumers used credit cards to gamble in 2018, and found that 22% of online gamblers who used credit cards to gamble were classed as problem gamblers. E-wallets cannot be used to route credit cards either, because the ban covers the funding source. A tier cannot lift that ban.

What changes when a tier is genuinely useful

A tier earns its keep on three points: withdrawal review time once paperwork is in order, tailored offers inside the 10x cap, and a host who knows the account. None of those change the regulator, the stake cap, the wagering cap, the GAMSTOP enrolment or the responsible-gambling controls. The arithmetic earlier in the page — between roughly 2.8 hours and nearly seven hours to clear a £200 10x bonus — sits on top of those rules, not in spite of them.

How a 10x bonus plays out in practice

The 10x cap is the binding figure, and the play-time band is what a player feels. The numbers from earlier in the page, gathered here in one place:

• Required turnover for a £200 bonus at 10x: £2,000.
• At a £1 stake per spin and a 2.5-second minimum spin duration, £2,000 is 2,000 spins, or roughly 1 hour and 23 minutes of continuous play.
• At a £0.20 stake per spin, £2,000 is 10,000 spins, or roughly 6.94 hours of continuous play.
• The same £2,000 turnover at a 96% RTP carries an expected loss of £80; at 94% RTP, £120.

The 2.5-second minimum is the same figure that powers the responsible-gambling rules in the section above. The stake cap on slots is £5 for over-25s and £2 for 18-24s, which sets an upper bound on the per-spin figure the band runs to. At a £5 stake, £2,000 in turnover is 400 spins, or about 0.28 hours — sixteen minutes and forty seconds, which is the floor of what a fast, high-stake clear looks like at the cap.

Where the band bites

A player on a £0.20 spin budget who clears a 10x bonus is paying in time, not in stake. A player on a £5 stake cap is paying in stake, not in time. The same bonus can cost roughly £80 in expected loss or £120, depending on which slot the play happens on. A reader who wants to know whether a £200 bonus is worth claiming finds the answer in the band: between roughly 16 minutes at £5 stakes and nearly seven hours at 20p stakes, with an expected loss somewhere between £80 and £120, the value of the bonus is the value of the time and the loss the player is willing to spend.

Where the cap changes the picture

Before the 19 December 2025 cap, a 35x or 50x wagering requirement on a £200 bonus meant £7,000 to £10,000 of qualifying turnover, and a play-time band that ran into dozens of hours. The 10x cap compresses that band by a factor of three to five, which is what a UK player in 2026 has over a UK player in 2024. The marketing word for this would be “lighter requirements”; the regulator’s word is the cap.

Where this leaves a reader weighing the tier

A UK player looking at a VIP programme is weighing a set of perks against a set of rules that the perks cannot move. The perks that hold up are withdrawal review time, tailored offers within the 10x cap, and a host who knows the account. The rules that hold regardless are the stake cap, the wagering cap, GAMSTOP enrolment, the deposit prompt, the identity check and the financial vulnerability review. The arithmetic that holds is the play-time band and the expected loss on a 10x bonus, between roughly 16 minutes and nearly seven hours, with expected loss between £80 and £120 on a £200 bonus.

What a tier is worth, on the page’s reading

A tier is worth what a player’s tracked activity already justifies — the offers and the host service scaled to volume. It is not worth what the marketing word claims, because the regulatory floor is the same on a fresh account as on a top-tier one. The honest comparison between two operators in the table above is not “which has the better VIP programme” but “which has the programme that matches how the player actually plays”, with the responsible-gambling controls as a constant underneath.

What the table does not say

The table does not name a winner, because every operator on it is licensed and every licence carries the same responsible-gambling floor. What the table does is put the licence holder, the licence number and the domain status on the same row, so a reader comparing two brands can see whether they share an account. Three of the ten brands share account 54743 with LC International Limited; two share account 38905 with Gamesys Operations Limited. The rest are one-brand, one-licence.

What the page has not done

The page has not recommended an operator, because the choice between licensed brands is a matter of taste and habit, not of regulatory standing. The page has not carried bonus codes, because codes do not survive the 10x cap or the bonus-terms reading. The page has not invented a tier ranking, because tier programmes are operator-specific and the marketing word on each is not comparable across licences. What the page has done is put the rule, the arithmetic and the licence on the same surface, so the reader’s decision is made on the right inputs.

Frequently asked questions

Does a VIP account raise the £5 regulatory stake cap on UK online slots?

No. The stake cap is a per-game-cycle ceiling set by the Gambling Commission, currently £5 for players aged 25 and over and £2 for 18-24. A tier label on a loyalty page does not change that figure, because the cap is a condition of the operator’s licence, not a courtesy extended to higher-volume players. The cap binds the slot itself, regardless of the account’s status.

Does a VIP or high-roller programme change the 10x wagering-requirement cap on bonus offers?

No. Since 19 December 2025 the Gambling Commission has capped wagering requirements at 10x for bonuses offered to UK players, and banned mixed-product offers. The cap is per bonus, not per account, and applies to every welcome pack and every VIP promotion a licensed operator runs. A higher tier does not exempt a bonus from the cap; it changes which bonuses the player is offered, not the multiplier those bonuses carry.

Do higher-tier accounts get faster withdrawal processing at a licensed casino?

Sometimes, conditional on identity and source-of-funds checks being complete. The change a tier makes is upstream of the payment rail, in how the operator reviews a withdrawal, not in how the money moves once it is released. A flagged large withdrawal can still sit in a manual check queue regardless of tier, because the check is a regulatory requirement. The tier’s effect is to move a withdrawal to the front of the queue; it cannot move it past the queue.

Is a dedicated VIP account manager a form of identity verification, or separate from it?

Separate from it. A VIP account manager is a relationship-management perk layered on top of identity checks that every licensed-casino player completes regardless of tier. Verification of name, address and date of birth has been required before the first deposit or any play since 7 May 2019, and a host cannot bypass that. The host’s job is to know the account; the verifier’s job is to satisfy the licence.

Do deposit limits and GAMSTOP self-exclusion still apply once I reach VIP status?

Yes. GAMSTOP enrolment is a mandatory condition of every online licence since 31 March 2020, with periods of six months, one year or five years that cannot be cancelled early. Deposit prompts are mandatory before the first deposit since 31 October 2025. Both bind the account, not the tier, and a player who has self-excluded cannot be marketed to a higher tier. The licence is the lever that enforces both, and the licence does not move with status.

What is the practical difference between a casino’s VIP programme and a one-off welcome bonus?

A welcome bonus is a single offer paid out once, with its own 10x wagering cap and its own qualifying turnover. A VIP programme is a tiered structure that pays out across tracked activity, with the wagering cap binding each offer in the same way. The headline figure on a welcome bonus is the bonus itself; the headline figure on a VIP programme is the tier. The mechanics — bonus funds, wagering, qualifying turnover, expected loss — are the same on both, and so is the regulatory ceiling.