The largest banks have been able to get away with repeated violations of the law because the only penalty they have faced has been fines. Governor O’Malley will implement a DMV-style points-accrual system that will assign points to infractions committed by financial firms and their affiliates. He will make the points system fully transparent—so that employees, creditors, and investors all have access to them and can make decisions based off them—and have the end result be the revocation of an entity’s right to operate. This approach will send a strong message to institutions that racking up repeat violations of the law will have real consequences, and it will give them the opportunity to pursue course-correcting measures if they rack up points. To further deter wrongdoing, each major fraud or violation could come with its own penalties, through increased FDIC insurance premiums or increased capital requirements.