The city’s letter and settlement offer to the SEC, sent Monday, said Miami was “frustrated by the [SEC] staff’s unwillingness to provide a clear explanation of why fraud charges are appropriate.”

City officials insisted that “numerous cities, counties and states have engaged in similar transactions during the past several years in order to meet fiscal challenges.”

“Even today, with all of the publicity that has been directed at the transfers, the city’s accounting professionals and auditors remain of the view that the capital transfers did not violate generally accepted accounting principles,” city officials wrote.

Additionally, Miami officials argued that it would be “wholly inappropriate” and “unjust” for the SEC to press charges against individuals. “The evidence in the record firmly demonstrates that various city employees, including Gomez and those who sought to vet the transfers thoroughly, are conscientious executives who acted in good faith at all times.”

Miami Commission Chairman Francis Suarez said he hopes the SEC will consider the fact that the city has increased its reserves and tightened financial controls since the 2009 bond issue.

“The city has to offer something to the SEC that would give the SEC a measure of comfort and confidence that whatever the allegations were, they are not going to be repeated,” he said.

The investigation marks the second time Miami has faced allegations of financial wrongdoing from the SEC.

In 2001, the agency concluded that Miami had quietly shifted money from the capital budget to fill holes in the general fund. City officials then issued $116.5 million worth of bonds, including one bond issue to help cover pension costs.

A judge subsequently issued a cease-and-desist order banning Miami from controversial budget transfers.

The SEC is conducting a third investigation into city bonds used to finance the Marlins Ballpark.