I agree with you on this, as it has already been evident some penalties still do not work, and holding isn't really working at all either.
I have seen clipping penalties called at 52 though, and I've increased it a small amount. Then again, it could not be as sensitive as it was in M25 and maybe it still won't be called that much more after moving it up, but I'll find out tonight after some games, and after having increased it.