THIS CASE WAS ISSUED FOR THE FOLLOWING REASONS (1) THE SERIOUSNESS OF RESPONDENT'S VIOLATIONS AS DESCRIBED ABOVE; (2) THE ECONOMIC BENEFIT ACCRUING TO RESPONDENT AS A RESULT OF THE VIOLATIONS; (3) ANY HISTORY OF SUCH VIOLATIONS; (4) GOOD FAITH EFFORTS BY THE RESPONDENT TO COMPLY WITH APPLICABLE UIC REQUIREMENTS; (5) THE ECONOMIC IMPACT OF THE PENALTY ON THE VIOLATOR. THE PROPOSED CIVIL PENALTY IS $31,500.