Under its current penalty regime the FCA follows a five-step framework when calculating a financial penalty. Interestingly in this case, the FCA reduced the financial penalty calculated in respect of Invesco Perpetual's breaches of the investment restrictions in COLL 5.2 by 50% from £25,813,069 to £12,906,534 at step 2 of its current penalties policy. The FCA explained that it considered that the original penalty calculated under the current penalties policy would have been disproportionate to Invesco Perpetual's breaches of COLL. This was because: