July 6, 2021
Please do NOT cap the fines associated with CAT errors.
Large financial institutions, especially GSIBs, have the resources necessary to ensure that they remain compliant with federal policies.
Decreasing monetary fines for negligence or willful ignorance of these policies will create an incentive for firms to ignore requirements for following guidelines. They will treat small fines as \"just the cost of doing business.\"
This incentivizes the poor behavior that led to the 2008 crash and continues to contribute to the Wall Street corruption evidenced by continuous lawsuits and SEC punishments over the last 13 years.
To best support maintaining a strong U.S. dollar, systemic trust is critical for both domestic retail investors and international partners.
A well-regulated and strongly enforced market, without any limits in monetary fines for negligence, will ensure that our markets are free from the corruption that exists in out adversaries, like the corrupt markets in Russia and China.
Effective punishment against poor market compliance is an important factor in effective national defense as much as it is a best practice for an effective free market.