The Financial Conduct Authority (FCA) has fined Merrill Lynch International $20 million for incorrectly reporting 35,034,810 transactions and failing to report another 121,387 transactions between November 2007 and November 2014. The size of the fine – the highest imposed for transaction reporting failures to date – reflects the severity of Merrill Lynch's misconduct, failure to adequately address the root causes over several years despite substantial FCA guidance to the industry and a poor history of transaction reporting compliance, consisting of a private warning issued in 2002 and a fine of $225,000 in 2006. The FCA has used a penalty of $2.25 per line of incorrect or non-reported data for the first time rather than the $1.50 per line used in the three most recent transaction reporting cases because past fines have not been high enough to achieve credible deterrence. "Proper transaction reporting really matters.