There has been a lot of talk regarding Section 111 Civil Money Penalties and now the proposal is finally here. We have summarized the key points below and attached a brief document with links to easily analyze and determine what they mean to you as a Responsible Reporting Entity (RRE).
Civil Money Penalties (CMP) will be imposed in the following instances:
– Failure to report or delayed reporting
– Reporting inconsistent data
– Error tolerance threshold is exceeded
Civil Money Penalties (CMP) will not be imposed if:
– The RRE complies with reporting thresholds or exceptions
– Does not exceed error tolerance thresholds
– Makes a good faith effort to submit on time
Game plan would be:
– Making sure clean data is provided in a timely fashion
