I cringe when I see questions to the effect of "What's the worst they could do to us?"
Given that this rule was made final exactly one year ago today, I don't understand how a vendor can tell you with a straight face that it won't be ready with a 6-month grace period after you hit your 101st transfer. It's probably time for a "produce or else" discussion with the vendor.
As for a definitive answer on the penalties, I don't know.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8