SECURITIES REGULATION -- CONSENT DECREES -- SECOND CIRCUIT CLARIFIES THAT A COURT'S REVIEW OF AN SEC SETTLEMENT SHOULD FOCUS ON PROCEDURAL PROPRIETY.

The article discusses the U.S. Court of Appeals for the Second District's ruling in the 2014 case U.S. Securities and Exchange Commission (SEC) v. Citigroup Global Markets Inc. which deals with American securities regulations, consent decrees, and the court's determination that a review of an SEC settlement should focus on procedural propriety. America's economic recovery in the wake of a financial crisis is examined, along with judicial enforcement power and agency settlement discretion.