My understanding of the regulations is that, before imposing a penalty, the commissioner has to issue a warning and then put together a case, which can take years. In my opinion, the amounts don't pose a major financial threat, even if this is expanded, but so much the better if it is. The process is too cumbersome and too complicated. I don't think a $50,000 penalty can be imposed multiple times; it may happen once, after a lengthy process.
Is that how you understand the regulations?