The Company appealed to the Banking Supervision Department to review this decision. As part of the appeal, the Company requested to lower the amount of the sanction, inter alia in view of Section 1(1) of the Banking Rules (Service to the Customer) (Maximum Reductions of Financial Sanction Amounts), 5771–2011 (hereinafter: the "Reduction Rules"). That Section makes a reduction possible in cases where the banking corporation did not contravene any of the directives listed in the Section in the five years that preceded the subject breach.
After further examining the Company's appeal, it was decided to take into account that the last time a breach by the Company resulted in the imposition of a financial sanction was more than five years prior to the date of these contraventions. As a result, the amount of the financial sanction imposed on December 23, 2018 totaling NIS 1,500,000 was reduced by 10 percent to NIS 1,350,000.