This demonstrates that the SEC was convinced the evidence did not support a claim of intentional or reckless misconduct.

FORBES: Thoughts on the SEC's Public Response to Judge Rakoff

Last month two Justice Department prosecutors were suspended without pay for reckless misconduct for failing to disclose important information to the defense team of the late Alaska Senator Ted Stevens.

FORBES: The Clemens Verdict: Another Wild Pitch By The Department Of Justice

Citi, Crittenden and Tildesley all settled the charges without admitting or denying them, and Citi emphasized that the SEC was not charging Citi or any individual with intentional or reckless misconduct.

FORBES: Citi Pays SEC $75M Over Charges It Botched Subprime Disclosures