From the day it was announced in late July, Citigroup’s proposed $75 million settlement with the Securities and Exchange Commission had plenty of critics. One of them, our colleague Susan Beck, wrote that the proposed deal unfairly punished Citi shareholders for their own victimization, letting unnamed members of Citi’s senior management off the hook for failing to disclose some $40 billion in subprime-related exposure.

As Beck and other early skeptics like Dealbook’s Andrew Ross Sorkin pointed out, the SEC’s settled complaint against Citi didn’t name any individuals. Instead, the SEC filed a separate administrative action against former chief financial officer Gary Crittenden and former investor relations head Arthur Tildesley Jr. Beck wondered just what Manhattan federal district court judge Jed Rakoff — who famously rejected a $33 million settlement between the SEC and Bank of America last year — would have said about that.

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