(1) root cause: the degree of weaknesses in the CMS - in a strong CMS violations are generally the result of minor weaknesses in the compliance risk management system;

(2) severity: the type of consumer harm - more severe harm results in a higher level of supervisory concern;

(3) duration: length of time of the violation - persistence causes greater supervisory concerns than violations that occur for a brief period; and

(4) pervasiveness: the extent of the violations and resulting consumer harm - violations that affect a large number of consumers raises greater supervisory concern.