MPF exam MPF Intermediaries question: maximum pecuniary penalty

Answer: D. $12,000,000

Answer: $12,000,000. The penalty may not exceed the greater of $10,000,000 and 3 times the profit gained or loss avoided.Working:1. 3 x $4,000,000 = $12,000,000.2. Compare with $10,000,000: the greater is $12,000,000.Why not the others:• $1,200,000: that reads "3 times" as 30% of the profit.• $4,000,000: that is only the profit itself.• $10,000,000: $10,000,000 is the cap only when it is greater than 3 times the profit.Watch out: Treating $10,000,000 as an absolute ceiling.Rule: Pecuniary penalty cap = greater of $10,000,000 or 3 x profit gained/loss avoided.Source: MPF Study Notes, Tenth Edition (June 2026; examinable from 1 Oct 2026), section 7.2.6(d)(iv) (checked 31 Oct 2026)