Mitigation Framework: Why and when we should mitigate a penalty: Record keeping
It is important that a record is kept of all the factors considered and how the decisionon the total amount of mitigation allowed was reached. The reasons can then be explained (without quoting the individual percentages) to the trader at the same time the penalty assessment is made and notified.
Each case is individual and so must be considered on its own merits, however for some simple examples that may assist the decision process, see VCP11750. However, don’t forget that these are only guidelines.