
As for common experience, a consent judgment that does not involve any admissions and that results in only very modest penalties is just as frequently viewed, particularly in the business community, as a cost of doing business imposed by having to maintain a working relationship with a regulatory agency .... If the allegations of the Complaint are true, this is a very good deal for Citigroup; and, even if they are untrue, it is a mild and modest cost of doing business.
-- US District Court Judge Jed S. Rakoff, rejecting a settlement between the SEC and CitiGroup, in which CitiGroup is accused of both selling and shorting bad investments for a $160 million profit while investors lost $700 million, 28 November 2011