Citigroup agreed to settle the SEC's charges by paying $285 million, but neither admitted nor denied the charges. The SEC has reached similar agreements with Goldman Sachs ( GS ) and JPMorgan Chase ( JPM ). Rakoff has been strongly opposed to this practice by the SEC and made his stance on the case clear in a Nov.9 hearing. "Last time I checked, correct me if I'm wrong, anyone can make an allegation," said Rakoff told SEC lawyer Matthew Martens, according to a New York Times report. "The mere fact that you say it's so does not make it so unless it's proved." Other issues included why the SEC was recovering only $160 million in illicit profits when investors lost about $700 million. He also didn't think too much of the $95 million the bank has to pay out as an additional penalty for the violation.