July 6, 2021
I would like to say that I disagree with the idea of lowering the fines for bad actors purposely or 'accidentally' filing incorrect information in the CAT. The low dollar amount for fines have already contributed to bad actors just paying fines as the cost of doing business. The whole point of the CAT system is to get all the players to accurately record their trades and other actions, so I don't understand how lowering fines for not accurately recording data is going to achieve the desired effect. The fines need to be higher than the amount of profit that was made. So 110% to a 200% fine of profits made, would be something that they would not be able to write off as the cost of doing business. We need to hold these players accountable and lowering the actionable response is not going to do anything if they can pay a measly fine and continue to circumvent the proper steps to record transactions. Thank you.