I find the statement "Subbies have cited him directly" interesting in the context that Subbies* does not have a stated citing commissioner as such; the manpower simply does not exist at amateur level to review every bit of footage for untoward incidents.
*A term that covers all manner of aspects, depending on the poster's understanding of the landscape, and typically glaring lack thereof...
There is a section in the Competition Rules dealing with citing powers in this regard:
28. CITING BY UNION OFFICIALS
28.1 Members of the Judiciary, members of the Union’s Board, the Executive Director, members of the Union’s staff, or match officials may at their discretion cite an affiliated club or club member on an alleged breach of the Laws of the Game, and/or Code of Conduct, and/or Competition Playing Rules.
I can't remember this being used, as it isn't usually required. It can give rise to claims of bias if not used wisely, particularly as almost everyone listed in that clause is a volunteer member of a Subbies Club.
If an incident is of a serious enough nature, Clubs should start the citing process themselves and not hide behind the Board, Judiciary, or Subbies Staff.