Anchor text penalty - manual or just algorithmic?

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Since Penguin has integrated into the algorithm, can overuse of exact match keywords result in a manual action or does it only arise in the form of an algorithmic penalty?
 
I believe its purely algorithmic and haven't seen it the other way around.
 
Manual penalties for links only occur after the algorithm catches enough weirdness in the link graph, like spotting out PBNs or unnatural amounts of spam coming in.

Anything that they can do algorithmically, they will. There's not enough man-power on the planet to hand out manual penalties for anchor text over-optimization. Why even bother when they can do it with the algorithm.

The real question then becomes "how far can I push it" or "is there a certain amount I can push it before I reach statistical significance where the algorithm is sure that I'm doing it on purpose"... Can you fly under the radar?
 
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