The LSB seeks to set it at £10m as a “credible deterrent” and  to give the LSB “the flexibility to exercise its discretion and judgement” when setting a penalty.  It may be appropriate for the LSB to apportion any penalty between the regulatory and representative arms in case one or the other has in fact been doing its job properly. The matter of fines is one question in the consultation paper, Compliance and Enforcement. The consultation closes on 28 October.