Gone through it now - the points I made were:
PRL should have the right to force a forensic audit in the event of a significant breach (or reason for suspicion for active cheating) - not have to enter what's essentially a plea bargain, whereby Sarries opted to take relegation instead. Noncompliance results in expulsion from PRL and the league structure - apply to RFU for permission to rejoin at the bottom.
Independent investigators (such as Lord Dyson) should have the right to demand players' tax returns (I don't know if this would form part of a "normal" forensic audit). Devil's in the detail for definition of "connected party".
All monies from club (or connected party) to player (or connected party) to be considered as salary unless explicitly exempted in the regulations (so ANYTHING new or dodgy is considered within the cap until discussed; no leeway for creativity).
Given the stepped arrangements for fines (£0.50 per £1; £1 per £1; £3 per £1) the steps should not stop at £350k - I suggested £5 per £1 for >£350k; £10 per £1 for >£1M.
There should be no upper limit for points deductions (currently 5 points per £50k over £350 (starting at 5 points); but maximum of 35 points); just keep on going at 5 points per £50k. Currently a £650k breach gets the same deduction as a £2M breach!
Breaches over multiple years should result on sanctions (well points deductions) over multiple years (neither combined nor concurrent for 1 year).
Breaches under the current £350k limit are dealt with the same way as currently - but with a statement saying that a club has transgressed; but not (necessarily) by how much.
To take the Saracens example (breaches of £1,100k; £98k and £906k)
2016-17 would have resulted in a fine of (25k+100k+600k+3250k+1000k) £4,975k and a points deduction of 80 points
2017-18 would have resulted in a fine of (25k+48k) £73k
2018-19 would have resulted in a fine of (25k+100k+600k+2780k) £3,505k and a points deduction of 60 points
Fines all payable now, first (80) points deducted this year; second (60) points deduction next year (at whatever level they're playing) all to have been applied as of November 2019.
Current season's breach to be calculated at the end of the season when it's known how large the breach.
Further punishment for not opening up the books mid-season as was part of the deal struck in November - well, PRL decided on 70 point deduction, but I'd have preferred something like "all league points earned are voided" so ending up the season on -80 - though I'd rather PRL had the right to force the forensic audit, rather than having to compromise with a plea deal.
Of course, I'd be making those the rules, and applying them henceforth, NOT retrospectively (which is where PRL have pissed me off).
