Well, it's more about relevancy rather than the penalty. However it is advisable to keep your links below hundred, opines Tedster I've worked with similar situations and I've found that websites often can perform better whem the the total number of links on each page is kept minimal. Google does recommend keeping it below 100 - and i usually aim for much lower than that. Further, if there are many repetitions of an keyword in the text it could be a cause for concern and could actually be harmful.

Yet another member, Walkman mentions that he's managed with about 900 links, I have ALL my links in the front page; 900 or so
in a css menu that activates when they highlight a certain category. My traffic increased and all pages are in the index.

Perhaps it boils down to what you are using your footer links for, is it a sitmap or other links which are not all that relevant viz. the Privacy Policy, Terms of Use, Contact Us .etc.

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