The Securities and Exchange Commission, facing growing judicial scrutiny over how it resolves enforcement matters, was asked by a federal judge in Milwaukee to provide a “factual predicate” for a proposed settlement with a company accused of accounting fraud.

Certain provisions of the SEC’s settlement with Milwaukee-based Koss Corp. were “vague,” US District Judge Rudolph Randa said in a filing. The settlement also didn’t provide enough information to show that penalties against chief executive officer Michael Koss were fair, the judge wrote.

Randa’s decision comes less than a month after a federal judge in New York rejected the agency’s $285 million settlement with Citigroup, saying he hadn’t been given enough facts to approve the agreement.

The ruling by US District Judge Jed Rakoff, which Randa cited in his opinion, challenged settlement practices the SEC has had in place for decades and sparked a debate over whether the agency is reaching agreements that lack tough sanctions.

The SEC has appealed Rakoff’s ruling.