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Originally Posted by
spbdawg
This is helpful. But is the entire investigation one giant conduct breach or 75+ unique conduct breaches? I could see it either way
Conduct breach means infraction. Each infraction is taken independently and you have 13 infractions or conduct breaches named in the NOA. Your orginal question was about the ACT fraud happening prior to the new structure. All infractions at this point are processed under the new structure (Level 1, 2, etc). It's why you see the infractions in the UNC case listed as Level 1 eventhough many of the infractions go back nearly a decade before the new system. Now the actual penalty portion will be under the new matrix UNLESS the older penalty process would have been lesser. This would only be for the ACT fraud stuff. Everything else will be under the new process and penalty matrix.
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