It appears that if a non-compliance issue is exposed during a self-audit and DCJS is allowed to impose a fine or penalty on self-reporting of that violation, this then becomes self-incrimination and may be a Fifth Amendment issue. 

This raises many questions and doesn't solve anything obvious.  What if a mistake is made on the self-audit, does it automatically become an assumed fraud, and thereby subject to two violations, the original violation (which could have been human error) and a potentially fraudulent self-audit (again could have been human error)?  Does this shift all the audit responsibilities on the back of the company and what/where is the gain?  What is the purpose?   Without knowing what is included in this "self audit" there is nothing to base a determination of reasonableness.   For many companies this new process just creates yet another burden. 

I am under the impression we are charged with reducing and streamlining regulations, yet this just moves the paperwork and responsibility onto the back of company. 
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