Abstract: Since 2018 ‘Affordability’ has become a critical regulatory priority in the UK gaining greater traction worldwide throughout the COVID-19 pandemic. In 2021 the Gambling Commission (GC) released formal guidance instructing operators to conduct affordability assessments using certain thresholds and triggers as a proxy for harm such as amount spent, speed of losses, frequency of wagering, and length of play sessions. May 25, 2021, the GC “concluded that stronger requirements are needed for operators to identify a range of indicators of harm and take appropriate action more often and at an earlier stage”. The authors conducted research from 2014-2020 interviewing 10,500 regular electronic machine gamblers in land-based casinos in three countries including the UK administering the PGSI and FLAGs a risk instrument that can be used to identify those spending beyond affordable limits including gambling with money that does not belong to them (e.g., gambling with misappropriated funds). The research shows that these players typically spend and play less than other regular gamblers. As a result, current methods of identifying high-risk gamblers that rely on the length of session and amount wagered are unlikely to find and assist these vulnerable over-spenders, even though they are more likely to be experiencing negative consequences due to their gambling. This session will highlight the value of a new Affordability Model specifically adapted for accommodating changes in play patterns due to COVID-19. The session will describe the survey results, construct creation and testing, behavioral cues using machine data that can be used to identify these at-risk players and the resulting profiles of ‘Overspenders’ in terms of beliefs, motives, risky practices, obsession with gambling, and the experience of negative consequences. Managerial and regulatory implications are presented.