Penalty limitation for minor breaches: proportional penalties with hearing and mitigation for voluntary disclosure.

Officers shall not impose penalties for minor breaches or easily rectifiable documentation mistakes absent fraud or gross negligence; penalties must be commensurate with the facts and severity of the breach. No penalty may be imposed without affording an opportunity of being heard, and orders must specify the breach and legal basis. Voluntary pre-discovery disclosure is a mitigating factor. Fixed-sum or fixed-percentage penalties are excluded from these disciplines.

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