I agree. These types of fines are relatively small potatoes on the earnings that occurred during this time. Having worked for a large US bank for a large portion of my career, everyone is typically trained yearly in an online course that covers records management practices and what to do. I know this because I was accountable for records management practices at the bank. The other question is, what happened internally? How come internal audit didn't catch this back in 2018-2019 time period?

At the end of the day, it's often more profitable, and in the shareholder's best interest to say I am sorry, vs. actually follow policy. At the end of the day, regardless if the C-level knew about it or not, they are accountable. And even if one of the largest banks in the US has to pay a relatively paltry fine like this, the CEO and the management chains that were participatory in this behavior should forgo bonuses. That will change things. Otherwise, this behavior will continue.