To provide some background, under the Basel Committee's guidelines, financial institutions are required to backtest their Value-at-Risk (VaR) models to ensure accuracy and reliability. If the number of daily losses exceeding the predicted VaR threshold—known as "exceptions"—is too high, the model may be deemed inadequate. Specifically, if a bank experiences more than four exceptions to their 1-day 99% VaR across the last 250 trading days, they might face regulatory penalties for having an insufficiently calibrated risk model.

Which of the following scenarios is most likely to result in a penalty?