Right now the system was set up with controls in place around something like a change in bank account information. We have certain flags right now that are picking up claims or applications for this program by people who just yesterday had changed their direct deposit information. That seems suspicious, so we're able to ask questions. Right now, even without enhanced controls we have a situation like that.
We have other situations where we find one practitioner who has 4,000 clients, and 3,900 of their clients have qualified for the program. There could be an innocent explanation for that, but maybe not. If that person is either inciting fraud or committing fraud on behalf of 3,000 people, we think it's important to have a criminal sanction at the end.
Criminal sanctions that are being sought are to deter people operating at scale, because merely asking them to pay back the money won't have the deterrent effect we need.