The government puts itself in a difficult position when it goes into the business of mandating prices and business terms. Leaving aside the economic issues, there are complicated issues as to privacy and data security.  

Notable that an enforcement action was brought wholly on the basis of deficient procedures (which, in fairness, looked pretty deficient) without any finding of harm to customers.  

Penalty amounts are an area in need of examination, particularly when combined with the complexity of trade reporting.  

Or perhaps if FINRA could explain why the collected data is important, or how FINRA makes use of the data, that would help explain the penalty amount. It would also make the rules more comprehensible, if one understood the uses that were made of the data.  

The FTX debacle was arguably the direct result of the prior Administration's refusal to allow crypto to operate within a regulated environment. Had banks been permitted to provide custody of crypto asset, investors would have likely custodied with regulated banks, not with FTX.