On legendary and superstar there are fouls i get at least one direct freekick per game and overall fouls range from anywhere from 2 to 6 - also AI does get booked but not seen many reds. Penalties are infrequent and definitely should be more - ive had maybe 5 since release but it seems to change patch on patch - this patch ive had one last patch zero as an example. Other than penalties fouls have been improved since 18 and 19 definitely. Legendary is the best mode overall for me but its tough at times - but this is the mode i see most fouls and most varied AI attacks and long shots
I think I only have one more level to go up to Super Star. The issue is that I'm finding Top Player sufficiently challenging in terms of scoring goals but teams are not scoring against me. Even when they get pretty clear cut chances. I find myself getting annoying when the CPU misses!
I'll move up to Super Star soon....