No. First of all, it's “up to”, right? As I mentioned, really, like any other enforcement agency, you have a continuum of enforcement, and you go to the maximum only in the most egregious cases where you really want to set an example.
Secondly, the way the process works is the examination by one part of the organization and then a decision to proceed with actually a levying of an AMP, of suggesting an AMP. One of my colleagues--actually, it's Mr. Katz here--will make that initial decision. The other parties can then make representations saying that's inappropriate, and that either the facts are wrong or the amount is wrong, etc. Then we will send it to a panel of three commissioners who, until that point in time, know nothing about it and will look at it totally objectively.
Essentially, they hear the accusation and they hear the defence, and they decide. If they decide to levy an administrative monetary penalty, you have the right to appeal to a Federal Court of Appeal. The Federal Court of Appeal will set us straight if we get it wrong.