This is an improvement over the last Goals per round. The problem with number of amount of goals in a round is that you need to be fast to make a prediction that makes sense. After 15-20 predictions, your chances of winning are basically zero.
Faults+goals is more fair, as there are more potential successful predictions.
Fouls can appear a lot in matches without goals, but if a match has many faults from players of one or both teams, I am thinking of many goals in that match, except if both attacking players, and defenders make many faults but only goalkeepers play well with many good saves.
Not seriously.