In November 2011, for neither the first nor the last time, Judge Jed Rakoff of the Southern District of New York initiated a headline-grabbing conflict with the U.S. Securities and Exchange Commission by rejecting the agency’s multimillion-dollar consent judgment with Citigroup Inc. Judge Rakoff’s target was the SEC’s long-standing “neither admit nor deny” settlement policy, which dates back to the 1970s and permits defendants to settle cases without admitting facts or the SECs’ allegations of wrongdoing.