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Citigroup

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FY2019 Annual Report · Citigroup
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2019 ANNUAL REPORT

I

T

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N A Mission of Enabling 
Growth and Progress

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We protect people’s savings and help them make the purchases — 
from everyday transactions to buying a home — that improve the 
quality of their lives. We advise people on how to invest for future 
needs, such as their children’s education and their own retirement, 
and help them buy securities such as stocks and bonds.

What You Can Expect From Us &  
What We Expect From Ourselves
Citi’s mission is to serve as a 
trusted partner to our clients by 
responsibly providing financial 
services that enable growth and 
economic progress. Our core 
activities are safeguarding assets, 
lending money, making payments 
and accessing the capital markets 
on behalf of our clients. We have 
200 years of experience helping 
our clients meet the world’s 
toughest challenges and embrace 
its greatest opportunities.  
We are Citi, the global bank —  
an institution connecting millions 
of people across hundreds of 
countries and cities.

These capabilities create an obligation to act responsibly, do 
everything possible to create the best outcomes, and prudently 
manage risk. If we fall short, we will take decisive action and learn 
from our experience.

We strive to earn and maintain the public’s trust by constantly 
adhering to the highest ethical standards. We ask our colleagues  
to ensure that their decisions pass three tests: they are in 
our clients’ interests, create economic value, and are always 
systemically responsible. When we do these things well, we make 
a positive financial and social impact in the communities we serve 
and show what a global bank can do.

We work with companies to optimize their daily operations, 
whether they need working capital, to make payroll or export  
their goods overseas. By lending to companies large and small,  
we help them grow, creating jobs and real economic value at home 
and in communities around the world. We provide financing and 
support to governments at all levels, so they can build sustainable 
infrastructure, such as housing, transportation, schools and other 
vital public works.

 
 
Financial Summary

In billions of dollars, except per-share amounts, ratios and direct staff

Global Consumer Banking Net Revenues

Institutional Clients Group Net Revenues

Corporate/Other Net Revenues

Total Net Revenues

Net Income

Diluted EPS — Net Income

Diluted EPS — Income from Continuing Operations

Assets

Deposits

Citigroup Stockholders’ Equity

Basel III Ratios — Full Implementation1

Common Equity Tier 1 Capital

Tier 1 Capital 

Total Capital

Supplementary Leverage

Return on Assets

Return on Common Equity

Return on Tangible Common Equity

Book Value per Share

Tangible Book Value per Share

Common Shares Outstanding (millions)

Total Payout Ratio

Market Capitalization

Direct Staff (thousands)

Totals may not sum due to rounding.

1  Please see Key Capital Metrics on page 3.

2019

2018

$

33.0

$

32.3

$

$

39.3

2.0

74.3

19.4

8.04

8.04

$

$

38.3

2.2

72.9

18.0

6.68

6.69

$

1,951

$

1,917

1,071

193

11.8%

13.4%

16.0%

6.2%

0.98%

10.3%

12.1%

1,013

196

11.9%

13.5%

16.2%

6.4%

0.94%

9.4%

11.0%

$ 82.90

$ 75.05

70.39

2,114

122%

169

200

$

63.79

2,369

109%

$

123

204

1

Letter  
to Shareholders
Dear Fellow Shareholders,

In 2019, Citi delivered our most 
profitable year since 2006.  
The $19.4 billion we earned  
on $74.3 billion in revenues  
was $1.4 billion higher than in 
2018. Our earnings per share  
of $8.04 were up more than 
20% compared with the year 
before. We drove 4% underlying 
revenue growth across our 
Consumer and Institutional 
franchises.1 We have grown 
loans and deposits for  
16 consecutive quarters.

We continued to make progress 
toward the financial targets we have 
laid out. We are on a path to return 
approximately $62 billion of capital 
to our shareholders, exceeding our 
commitment. To date, we have returned 
approximately $53 billion, including a 
portion of the roughly $22 billion we 
gained regulatory approval to return 
over the 2019 Comprehensive Capital 
Analysis and Review cycle. Most 
importantly, we closed out 2019 on a 
high note, with a Return on Tangible 
Common Equity of 12.1%, just above our 
12% target and 120 basis points higher 
than in 2018.2

These results reflect how well our 
model can perform, even in an 
uncertain environment. Coming out 
of a tough fourth quarter of 2018 
for the markets and our industry, 

2

we entered 2019 amid widespread 
predictions of a global recession and 
potential turn of the business cycle. 
Against that backdrop, the growth 
we drove came — as we said it would 
— from working collaboratively and 
creatively with clients to manage 
and grow their businesses in an 
increasingly complex environment 
characterized by trade routes shifting 
and supply chains realigning. We 
again proved the value of our global 
client network and unmatched ability 
to connect people and businesses to 
opportunities worldwide. 

The year concluded with several 
economic storm clouds lifting. The U.S. 
and China signed a Phase 1 trade deal, 
the new United States-Mexico-Canada 
Agreement was ratified and Brexit was 

Michael L. Corbat 
Chief Executive Officer

at last confirmed. At Citi, we emerged 
in a strong competitive position in 
terms of capital, liquidity, technology 
and, importantly, talent. Changes to 
my management team include a new 
President of Citi and CEO of Global 
Consumer Banking, Jane Fraser; a new 
CEO of our Institutional Clients Group, 
Paco Ybarra; a new CFO, Mark Mason; 
and new heads of our three regions. 
Our positive position across all of 
those areas permitted us to realize the 
benefits of investments we have made 
over the past several years in high-
growth, high-return areas across the 
franchise. We also continued to invest 
in our infrastructure and culture of 
compliance and controls, in light of the 
enduring need to be an indisputably 
strong and stable institution.

 In our Global Consumer Bank, we 
sustained momentum by generating 
4% annual underlying revenue 
growth with contributions from all 
three regions: the U.S., Mexico and 
Asia.3 Since establishing a client-
centric structure in our largest 
Consumer market, the U.S., our 
strategy of unifying Branded Cards 
and Retail Banking has yielded a 
steady stream of compelling new 
products and value propositions, 
from digital lending to flexible 
payments. We are targeting a 
significant opportunity to redefine 
scale not according to the traditional 
metrics of assets and footprint but 
with digitally driven experiences. 

The strong revenue growth we saw in 
Branded Cards and $6 billion in U.S. 
digital deposit sales — five times that 
of the previous year — are signs that 
our integrated client-centric strategy 
is working. Two-thirds of our digital 
deposit sales came from outside our 
physical footprint and half came from 
our card customers with no prior 
retail banking relationship with us. 
We also expanded our relationship 
with American Airlines to offer a 
new savings account designed to 
deepen relationships from cards-only 
customers to multi-relationship clients. 

And we announced a partnership with 
Google to explore launching a new 
checking account on Google Play in 
2020, aimed at expanding the reach 
and breadth of our customer base. 
In Asia, we entered into new credit 
card partnerships with digital leaders 
Grab, Lazada and Indian e-commerce 
juggernaut Paytm. In Mexico, we 
continued to leverage Citibanamex’s 
extraordinary prestige and leading 
market position to deliver double-
digit growth in earnings before taxes 
even in a muted market environment. 

Our Institutional Clients Group turned 
in an equally strong performance, 
driving balanced 4% underlying 
revenue growth across our franchise 
that serves corporate (including 90% 
of Fortune 500 firms), investor and 
government clients and ultra high net 
worth households and individuals.4 
International Financing Review 
summed up the source of our market 
and wallet share gains when it named 
Citi 2019 Bank of the Year: “Citi is a 
truly global — and unique — corporate 
bank that joins the developed and 
developing world.” Those connections 
run deep between our banking teams 
and clients and across products, 
sectors, markets and regions. 

CITIGROUP — KEY CAPITAL METRICS

Common Equity Tier 1 Capital Ratio1

Supplementary Leverage Ratio1

TBV/Share2

12.1%

12.6%

12.4%

11.9%

11.8%

7.1%

7.2%

6.7%

6.4%

6.2%

$60.61

$64.57

$60.16

$63.79

$70.39

4Q’15

4Q’16

4Q’17

4Q’18

4Q’19

1  Citigroup’s Common Equity Tier 1 Capital Ratio and Supplementary Leverage Ratio for 2017 and prior years 
are non-GAAP financial measures. For additional information, please see “Capital Resources” in Citi’s 2017 
Annual Report on Form 10-K.

2  Tangible Book Value (TBV) per share is a non-GAAP financial measure. For a reconciliation to reported 

results, please see “Tangible Common Equity, Book Value Per Share, Tangible Book Value Per Share and 
Returns on Equity” in Citi’s 2019 Annual Report on Form 10-K.

2019 NET REVENUES1

2019 Net Revenues: $72.3 Billion

BY REGION

North America
47%

Europe, 
Middle East 
and Africa 
(EMEA)
17%

Latin America
14%

Asia2
22%

BY BUSINESS

Global 
Consumer 
Banking (GCB)
45%

ICG Banking
30%

ICG Markets and 
Securities Services
25%

ICG — Institutional Clients Group

1  Results exclude Corporate/Other revenues 

(of $2.0 billion) and are non-GAAP financial measures.

2 Asia GCB includes the results of operations of GCB 

activities in certain EMEA countries.

Our industry-leading Treasury and 
Trade Solutions (TTS) business is the 
backbone of our institutional franchise 
because our global client network 
makes Citi the first call to manage 
cash, process payments and create 
solutions to supply chain challenges 
and provides opportunities for clients 
in multiple markets and currencies. 
TTS has established itself within 
our firm and industry as a pioneer 
in steering the shift from analog 
to digital platforms and processes. 
In partnership with fintech firms, 
including Feedzai, HighRadius and 
Cachematrix, TTS is actively exploring 
artificial intelligence, machine learning 
and blockchain applications to 
automate cash management, foreign 
exchange and fraud protection to 
consolidate its position as the premier 
global commerce banking platform.

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Our Markets and Securities Services 
business continues its strong 
performance having topped the 
Greenwich Associates’ Global Fixed 
Income Dealer rankings for the fourth 
consecutive year. Securities Services 
grew deposit balances versus the 
prior year through new mandates and 
organic growth from existing clients. 
Citi Private Bank retained the award 
for the Best Global Private Bank from 
the Financial Times for the second 
year, finishing 2019 with year-over-
year growth across product areas. 

To enhance how we serve midsized 
companies that value our global 
reach, we realigned our organizational 
structure to have Citi Commercial 
Bank report into the Institutional 
Clients Group globally. This new 
alignment leverages the full 
breadth of solutions provided by 
our client network and gives us new 
opportunities to continue to build and 
develop our top talent. 

A year after we aligned our structure to 
create a holistic client coverage model 
in the form of the unified Banking, 
Capital Markets and Advisory (BCMA) 
team, our share rose year-over-year 
across mergers and acquisitions (M&A) 
and equity and debt capital markets. 
Our increased share shows how we 
can deliver a full suite of services to 
clients who rely on us to sustain steady 
transactional flow. BCMA fulfilled its 
mandate by executing on an even 
higher share of the year’s significant 
deals. We were financial advisor to U.S. 
biotech firm Celgene on its $96.8 billion 
merger with Bristol-Myers Squibb, the 
largest-ever healthcare M&A deal. We 
were lead financial advisor to Raytheon 
on its all-stock merger with United 
Technologies’ aerospace unit. We also 
were joint global coordinator and 
bookrunner on Alibaba Group’s nearly 
$13 billion secondary listing in Hong 
Kong, the largest global follow-on deal 
in the sector and a sign of confidence 
in an important hub for Citi, the region 
and the world. 

In 2019, the expectations of consumer 
and institutional clients continued 
to converge. Both groups want 
simple, seamless experiences that 

4

are not just best of bank but best 
in life, prompting us to allocate 
substantial resources and mindshare 
to exceeding our clients’ evolving 
expectations of engaging with Citi on 
their channel of choice.

Our strategy to capture the abundant 
opportunities inherent in this trend 
is threefold. First, we partner with 
startups that value our model, global 
client base and brand to test and 
deploy new technologies at scale. 
Second, we invest in firms with 
demonstrable growth potential and 
ability to create solutions that deliver 
real benefits to our firm and clients. 
And third, we develop proprietary 
solutions through our internal D10X 
incubation program and network 
of Innovation Labs. Regardless of 
source, our intent is the same: tapping 
technology to eliminate client pain 
points and frustrations, streamline 
our processes, and deliver holistic, 
integrated products and services to 
customers and clients of all sizes 
and sectors more seamlessly and 
efficiently than peers. That strategy 
is showing results, and Citi’s digital 
leadership has been recognized in 
each region. Citi was named Best 
Digital Bank in Asia by Euromoney, 

principles for responsible firms, I 
found the lively debate that ensued 
healthy and reassuring, but for us 
at Citi, the approach is not new. 
The statement said simply that 
companies should take the interests 
of all stakeholders — including 
shareholders, colleagues, clients, 
suppliers and communities — into 
account when making decisions. 
With every action we take, we 
strive to demonstrate the value we 
contribute and the values we uphold. 
Ultimately, taking stakeholder 
interests into account benefits our 
shareholders. We have been on this 
journey for some time and welcome 
the actions companies are taking 
to hold themselves accountable to 
higher environmental, social and 
governance standards. 

We also see this as a positive 
development because these 
expectations arise from the higher 
levels of trust and credibility 
businesses have built, notably with 
their own people. Research reveals 
that a global majority do not trust 
the media or government to do the 
right thing for them or for society. 
Still, three out of four believe their 
own employer will. As colleagues 

As colleagues and clients want to work 
for, and do business with, companies that 
affirmatively reflect their own priorities 
and principles, more firms intent on 
attracting and retaining top talent are 
rising to the challenge.

Best Digital Bank in Mexico by Global 
Finance and the firm with the Most 
Desirable Mobile Banking Features 
in the U.S. by Business Insider 
Intelligence.

In August, when the Business 
Roundtable — an organization of 
CEOs of major U.S. companies, of 
which I am a member — announced 
a revised statement of purpose and 

and clients want to work for, and 
do business with, companies that 
affirmatively reflect their own 
priorities and principles, more firms 
intent on attracting and retaining top 
talent are rising to the challenge.

As for Citi’s concrete commitments, 
our businesses seek out opportunities 
to address challenges that impact our 
clients and communities.

 
 
Our government clients around the 
world urgently need infrastructure. 
The G20 has estimated that nearly 
$100 trillion is needed for global 
infrastructure spending by 2040, but 
there is a spending gap of $18 trillion. 
Citi’s Public Finance team is playing its 
part by financing, among other critical 
projects, the two largest airport public-
private partnerships in U.S. history. We 
also financed the construction of new 
subway systems in Panama and Peru, 
helping two fast-growing metropolises 
in dynamic emerging economies reduce 
traffic and carbon emissions.

In the communities we serve, one 
particular infrastructure gap is 
increasingly pressing: affordable 
housing. As urban populations soar and 
cities become less affordable for many, 
what has long been an acute shortage 
is becoming a crisis. In 2019, Citi ranked 
first among U.S. financiers of affordable 
housing for the 10th year in a row. 
We financed over $6 billion worth of 
affordable rental housing projects. In 
partnership with developers, nonprofits 
and governments, our Citi Community 
Capital team has helped to create or 
preserve nearly 500,000 affordable 
units over the past decade.

We have been on the front lines and 
in charge of leading our industry 
with our sustainability strategy since 
joining the United Nations Environment 
Programme Finance Initiative in 
1997 and co-founding the Equator 
Principles in 2003. That is the first 
framework developed by responsible 
financial institutions to assess and 
manage the environmental and social 
risks associated with project finance. 
Flash forward to September 2019 and 
Climate Week in New York: Citi was the 
only U.S. bank to sign on to the United 
Nations’ Principles for Responsible 
Banking, joining a coalition of 130 

There are few areas where the gap 
between the scale of the need and of the 
progress to date is wider than in the field 
of inclusive finance.

global financial firms that have agreed 
to align their business practices related 
to climate risks and opportunities with 
the UN’s Sustainable Development 
Goals and the Paris Agreement. 

In 2013, Citi achieved our first  
10-year $50 billion Environmental 
Finance Goal three years early, and in 
2019, we exceeded our second 10-year 
$100 billion Environmental Finance 
Goal four years ahead of schedule. In 
2019, we were a founding signatory of 
the Poseidon Principles, a voluntary 
framework aimed at reducing the 
carbon emissions of maritime 
shipping. We are also on track to 
achieve our goal of sourcing 100% 
renewable electricity across our global 
operations in 2020.

There are few areas where the gap 
between the scale of the need and 
of the progress to date is wider than 
in the field of inclusive finance. With 
the world’s unbanked population 
estimated at 1.7 billion, our Inclusive 
Finance unit has worked with teams 
across our firm over the last decade 
to provide more than 3.3 million 
entrepreneurs, 3 million of them 
women, with access to capital and 
financial services in 34 countries in 
partnership with the U.S. International 
Development Finance Corporation, 
formerly OPIC. The Citibanamex 
Transfer account has attracted over 
10 million customers, 80% formerly 
unbanked. The Citi Foundation’s 
Pathways to Progress program, which 
started in 2014 in 10 cities and went 

global three years later, has helped 
prepare more than 850,000 youth 
for the jobs of today through paid 
internships, mentorship, workforce 
training and leadership development. 
We have invested $140 million in this 
initiative to date and will soon be 
announcing its next stage.

The financial results we reported and 
the positive economic and social impact 
that we and our model have on our 
clients and communities have never 
been more closely connected. The 
Mission and Value Proposition at the 
front of this report describes not just 
what we do but how and why we do 
it. As we prepare to host our second 
Investor Day, in 2020, I have never felt 
better about our financial strength and 
competitive position, as measured by all 
the relevant metrics: revenues, returns, 
income and capital. I have also never 
felt better or more confident about 
who we are, what we stand for, and the 
lasting value of the many things we do 
for our clients, our communities, our 
shareholders, our people and all of our 
stakeholders worldwide. While there is 
no shortage of challenges ahead, I am 
confident in our ability to continue to 
rise and meet them.

Sincerely,

Michael L. Corbat
Chief Executive Officer, Citigroup Inc.

1  Excludes the impact of foreign exchange (FX) translation (constant dollars), as well as pretax gains on sale in 2018 of approximately $150 million on a 
Hilton portfolio sale in North America Global Consumer Banking (GCB) and approximately $250 million on an asset management business in Latin America 
GCB. For a reconciliation of revenues in constant dollars to reported results for Citi’s consumer business (GCB) and institutional business (Institutional 
Clients Group), see Slide 31 of Citi’s Fourth Quarter 2019 Earnings Review available on Citi’s investor relations website. As used throughout, Citi’s results of 
operations in constant dollars and excluding the gains on sale are non-GAAP financial measures.
2  Return on Tangible Common Equity (ROTCE) is a non-GAAP financial measure. ROTCE in 2018 excludes a one-time benefit of $94 million due to the 

finalization of the provisional component of the impact, based on Citi’s analysis, as well as additional guidance received from the U.S. Treasury 
Department, related to the Tax Cuts and Jobs Act. For the components of the ROTCE calculation, see “Capital Resources—Tangible Common Equity,  
Book Value per Share, Tangible Book Value per Share and Returns on Equity” in Citi’s 2019 Annual Report on Form 10-K included with this letter.

3  Excludes the impact of FX translation, as well as the gains on sale in North America GCB and Latin America GCB described in endnote 1. For a reconciliation 
of revenues in constant dollars to reported results, see the tables in “Global Consumer Banking—Latin America GCB” and “Global Consumer Banking—Asia 
GCB” in Citi’s 2019 Annual Report on Form 10-K included with this letter.

4  Excludes the impact of FX translation. For a reconciliation to reported results, see Slide 31 of Citi’s Fourth Quarter 2019 Earnings Review available  

on Citi’s investor relations website.

5

Global Consumer Banking

Citi’s Global Consumer Bank (GCB), a global leader in 

banking, credit cards and wealth management, is a 
critical growth engine for Citi. With a strategic focus on 
the U.S., Mexico and Asia, the Global Consumer Bank 
serves more than 110 million clients in 19 markets. 

In 2019, the Global Consumer Bank 
successfully executed its strategy 
to drive growth. It demonstrated 
the power and potential of its new, 
integrated client-centric operating 
model in the U.S., grew loans 
and deposits globally, introduced 
an array of industry-first digital 
capabilities and expanded its 
ecosystem of partners, one of the 
most powerful in the industry.

With the full power of the 
franchise together for the first 
time in GCB’s largest market, U.S. 
Consumer Banking implemented 
a strategy to deepen relationships 
across Cards and Retail and 
provide seamless experiences 
to customers nationwide. 

Capitalizing on our distinct model, 
we launched an array of new 
products and digital capabilities, 
forged new and expanded 
partnerships, and introduced new 
value propositions to grow and 
retain multi-relationship clients. 

Globally, we continued to 
introduce industry-leading 
digital capabilities, redesign the 
client experience, and embed 
our services in the most popular 
social and e-commerce platforms, 
enabling customers to bank 
anytime, anywhere, on their 
channel of choice. Clients and the 
industry took note. We generated 
double-digit growth in digital and 
mobile users globally, and client 

engagement and satisfaction 
meaningfully improved. Citi was 
recognized with a number of 
industry awards, including Best 
Digital Bank in Asia (Euromoney), 
Best Digital Bank in Mexico (Global 
Finance) and Most Desirable 
Mobile Banking Features in the 
U.S. (Business Insider Intelligence).

Importantly, Citi continued to 
execute strategic multi-year 
investments in key growth areas 
— U.S. Branded Cards, Mexico and 
Technology — to drive a superior 
experience for clients, enhance 
our infrastructure and controls, 
strengthen cybersecurity and 
deliver value for Citi shareholders.

6

GCB operates 2,348 branches and 
generated $7.4 billion in pre-tax 
earnings in 2019. At year-end 2019, the 
business had $291 billion in deposits, 
$300 billion in loans and $176 billion in 
assets under management.

The world’s largest credit card issuer, 
Citi is a global leader in payments, 
with over 138 million accounts and 
$564 billion in annual purchase sales, 
and unrivaled partnerships with 
premier brands across Branded Cards 
and Retail Services. At year-end, card 
receivables were $175 billion. 

Branded Cards
Branded Cards provides payment, 
credit and lending solutions to 
consumers and small businesses, with 
55 million accounts globally. In 2019, 
Branded Cards generated annual 
purchase sales of $476 billion and 
ended the year with a loan portfolio of 
$122 billion.

Globally, we continued to strengthen 
our value propositions, expand 
co-brand partnerships, and provide 
new digital capabilities that make 
purchases faster, convenient and 
more rewarding. 

In the U.S., we launched several new 
products to lay the foundation for 
a more integrated, multi-product 
relationship model. These included our 
new Rewards+SM card, a unique value 
proposition that provides cardmembers 
with the ability to earn more points 
on everyday purchases, as well as 
relationship-based offers that leverage 
our proprietary ThankYou® and Citi® 
Double Cash rewards products. 

We expanded digital lending with 
two new solutions, Citi Flex Loan 
and Citi Flex Pay. Citi Flex Loan 
enables customers to convert a 

portion of their credit line into a fixed 
rate personal loan, while Citi Flex 
Pay enables customers to finance 
purchases by converting eligible 
purchases into a fixed payment plan. 
We continued to innovate and enhance 
our industry-leading ThankYou 
Rewards platform. We also enabled our 
real-time Pay with Points functionality.

To deepen relationships with existing 
cardmembers, we announced an 
expanded partnership with American 
Airlines. Our proprietary Citi Flex Pay 
capabilities will be available to our 
American Airlines co-brand cardholders, 
and our existing lending partnership will 
expand to include a deposit product, 
the Citi Miles AheadSM Savings Account, 
which will launch in 2020 to American 
Airlines co-brand cardholders who reside 
within the U.S. but outside locations in 
which Citi has a retail branch.

Internationally, we launched a suite of 
new products and digital capabilities. In 
Asia, we introduced co-brand and white 
label credit card partnerships with 
digital leaders, including Grab, Lazada 
and Paytm, with over 10 partnerships 
now live. We also launched an industry-
first digital payment solution called Citi 
PayAll that enables cardmembers to 
settle big-ticket purchases in-app while 
earning rewards points. The feature 
launched in Hong Kong, Singapore, 
Thailand and the UAE. To date, nearly 
half of all credit card accounts and 
more than half of new loans in Asia are 
acquired digitally. 

In Mexico, Citibanamex remains one of 
the leaders in the credit card segment, 
with strong market share, compelling 
reward programs, ThankYou® Rewards 
and Premia, as well as market-leading 
promotions, including more than  
2,500 agreements with retailers  
and businesses.

Globally, we continued to introduce industry-
leading digital capabilities, redesign the client 
experience, and embed our services in the 
most popular social and e-commerce platforms, 
enabling customers to bank anytime, anywhere, 
on their channel of choice. 

. JANUARY
3 

Citi launches new no-annual-fee 
credit card, Citi Rewards+ card, 
accelerating points-earning potential 
on everyday purchases 

16

Citi releases unadjusted or “raw” pay 
gap for women and U.S. minorities 

22

Citi announces inaugural green  
bond issuance 

30 

J.D. Power recognizes Citi with mobile 
app certification 

Citi tops Greenwich Associates’ global 
fixed income dealer rankings for 
fourth consecutive year 

. FEBRUARY
7

Citi launches new high-yield savings 
account in U.S.

13

Citi announces it will power Texas 
operations with clean, renewable energy 

Citi ranked Top in Quality in Greenwich 
Associates’ 2018 Asian Equities Survey 

20

Community-based organizations across 
the U.S. receive $10 million through 
Citi Foundation-funded LISC program 
to help train American workers for 
growing job sectors

7

2019Citi Entertainment®, the bank’s award-
winning global entertainment access 
program, and its live music platform, 
Citi Sound Vault, continued to provide 
cardmembers with exclusive access to 
extraordinary music experiences. In 
2019, in partnership with Live Nation, 
Citi offered cardmembers access to 
more than 8,000 events with many of 
the world’s biggest names in music.

Retail Services
Retail Services is one of North 
America’s largest and most 
experienced retail credit solution 
providers of private label and co-brand 
credit cards for retailers. The business 
serves 83 million customer accounts 
for iconic brands, including Best Buy, 
L.L.Bean, Macy’s, Exxon Mobil, Sears, 
Shell, Tractor Supply Company and 
The Home Depot. 

In 2019, Retail Services continued to 
enhance value propositions, including 
partnering on new rewards benefits 
for Tractor Supply Personal Credit 
cardholders with a membership to the 
Neighbor’s Club, the company’s free 
loyalty program.

Retail Services generated purchase 
sales of $88 billion and ended the year 
with a loan portfolio of $53 billion.

Retail Banking
With a high-touch, segment-driven 
relationship model that serves clients 
across the full spectrum of consumer 
banking needs, Citibank serves as a 
trusted advisor to its retail, wealth 
management and small business 
clients at every stage of their 
financial journey. 

Through Citibank, Citi Priority, Citigold 
and Citigold Private Client, we serve 
clients across the full spectrum of 
the wealth continuum so once they 
become a Citi customer, they can stay 
a Citi customer as their needs evolve.

8

Citi CEO  
Michael Corbat  
Opens  
State-of-the-Art  
Facility in  
Sioux Falls

In September, Citi CEO Michael Corbat officially 
marked the opening of Citi’s new state-of-the-art 
operations site in Sioux Falls, extending a nearly  
four-decades-long commitment to South Dakota. 

Mike was joined at the ribbon-cutting ceremony by South Dakota Lieutenant 
Governor Larry Rhoden; U.S. Senators John Thune and Mike Rounds; Sioux 
Falls Mayor Paul TenHaken; and U.S. Representative Dusty Johnson along 
with Citi colleagues, local business leaders and members of the community.

At the event, Mike discussed the pride we feel in the role that Citi has 
played as a catalyst of growth in the city and shared how Citi’s $72 million 
investment affirms our commitment to Sioux Falls and South Dakota. 

Since 1981, when Citi opened a credit card operations center in Sioux Falls, 
the breadth of work has diversified, expanding to 22 business functions, 
including credit operations, technology, finance, treasury and transactions, 
and customer service. 

The new building features open-concept working spaces to foster greater 
collaboration — a design Citi is using with its new buildings around 
the world. Additionally, the site has been certified with a LEED Gold 
designation from the U.S. Green Building Council, a testament to Citi’s 
commitment to sustainability. 

The modern four-story facility occupies 150,000 square feet on 19 acres in 
the southwest corridor of Sioux Falls. The new space features an abundance 
of natural light and panoramic views throughout the building, coupled with 
collaborative workspaces, new amenities and cutting-edge technology, 
making it a great place to come to work.

Citi has played an integral role in the Sioux Falls community, impacting 
a large number of nonprofit partners through Citi Foundation grants, 
investments, training, volunteerism and service. 

Citi has a legacy of employee volunteerism and support for a number of 
nonprofit partners in Sioux Falls and South Dakota, including the Sioux 
Empire Housing Partnership, which helps families in South Dakota fulfill the 
dream of home ownership. As part of Citi’s Pathways to Progress initiative, 
the Citi Foundation has invested in local organizations, expanding the skills 
of over 4,000 young people, and for more than a decade, Citi has partnered 
with the rural development organization Dakota Resources, which serves 
low-to-moderate income communities across the state. 

GLOBAL CONSUMER BANKINGIn 2019, Citi 
continued to 
provide a breadth 
of products, 
services and digital 
capabilities to meet 
the needs of our 
individual, small 
business and wealth 
management clients 
worldwide.

In the U.S., Citi continued to evolve 
its retail bank model to drive national 
scale. In its six core strategic markets, 
Citi is a deposit leader, maintaining 
the highest average deposits per 
branch versus peers for the past six 
years. To deepen and acquire client 
relationships outside our branch 
footprint, we deployed a digitally 
led challenger strategy to drive 
incremental growth by leveraging the 
strength of our brand, the national 
scale and quality of our credit card 
franchise, and our leading wealth 
management capabilities. 

New products were introduced for 
customers beyond our branch footprint, 
including Citi Accelerate Savings®, a 
digital high-yield savings account, and 
Citi ElevateSM Checking, a digital high-
yield checking account. Digital deposit 
sales reached $6 billion in 2019, five 
times that of the prior year. To further 
drive national scale and embed our 
services on the platforms consumers 
use most, we announced our intent to 
explore providing checking accounts to 
consumers nationwide through Google 
Pay in 2020.

Across the U.S., Citi continued to 
advance financial inclusion and the 
economic strength and growth of 
communities. Citi’s Access Account, a 
checkless bank account with no or low 
monthly fees, no overdraft fees, the 
ability to link to a savings account, and 
access to Citi’s digital, retail and ATM 
channels, has been one of its fastest-
growing products. Introduced in 2014, 
the account addresses the needs of 
a range of customers, particularly 
first-time and younger consumers, 
as well as often overlooked portions 
of the U.S. market, including low-
income individuals, senior citizens and 
immigrants, by reducing the risks of 
overdrawn accounts and coinciding fees. 

Through retail bank and small business 
credit card lending, as well as supply 
chain financing through its institutional 
bank, Citi invested more than $10.6 
billion in small business lending in 2019, 
bringing its total for the decade to 
nearly $100 billion. 

In Mortgage, having successfully 
transitioned direct servicing to Cenlar, 
Citi continued to intensify its focus on 
originations. Our mortgage business, 
which provides loans for home purchase  
and refinance transactions in the  
U.S., originated $16.9 billion in new  
loans in 2019.

Citi was proud to receive the #1 rating 
in customer satisfaction across the 
retail banking industry by the American 
Customer Satisfaction Index following 
being top rated among national banks in 
2016 and 2017.

In Wealth Management, we continued 
to enhance our capabilities, investing in 
our offerings and digital tools to meet 
a wider spectrum of customer needs. 
Through Citi Priority, we serve the 
needs of emerging affluent clients. With 
Citigold and Citigold Private Client, we 
provide institutional-grade, personalized 
wealth management services, including 
dedicated wealth teams, digital planning 
tools, fund access, and a range of 
exclusive privileges, preferred pricing 
and benefits to affluent clients around 
the globe. 

. FEBRUARY
25

Citi wins multiple Debt Capital  
Markets awards

26

Citi Singapore introduces Citi PayAll, 
enabling credit card payments for  
rent and education on mobile devices

Citi launches digital onboarding  
for institutional clients through 
CitiDirect BE®

. MARCH
4

Citi wins top awards for innovation in 
structured products

8

Citi hires women-owned firms to lead 
distribution of $1 billion Citi bond 
issuance in celebration of International 
Women’s Day

15

Citi signs U.S. Equality Act 

26

Citi announces it will build digital 
consumer payments businesses  
for institutions

28

Citi introduces new Citi Wealth Advisor 
Digital Financial Planner 

. APRIL
4

United Nations Development 
Programme and Citi Foundation jointly 
host second Asia Pacific Youth Co:Lab 
Summit 

9

2019Citibanamex Drives 
Inclusive Finance with 
Innovative CoDi QR 
Digital Payments  
Solution 

In 2019, Citibanamex showcased 
how an innovative financial 
inclusion effort is delivering 
on the firm’s mission to enable 
growth and economic progress. 
In partnership with Banco 
de México, Mexican financial 
authorities and other banks, 
the innovative new electronic 
payments platform Cobro 
Digital, or CoDi, was launched. 

CoDi will enable more than 5.5 
million digital clients to transfer 
money and make payments of 
up to 8,000 pesos (US$400) 
per transaction with ease and 
at no cost using Quick Response 
(QR) codes. 

At the announcement in Mexico City at its headquarters, the 
Palacio de los Condes de San Mateo de Valparaíso, Ernesto Torres 
Cantú, CEO of Citi Latin America, noted that “Citibanamex has 
consistently led and promoted the process of financial inclusion. 
More than 50% of the progress toward financial inclusion in this 
country in the past six years has been made through Citibanamex.”

In a country where 80% of payments are made in cash and 
40 million Mexican adults don’t have a bank account, CoDi will 
change the way Mexicans transfer money and pay each other. 
Fundamentally, it aims to be a tool to help people improve their 
quality of life, leave cash behind and encourage financial inclusion. 

CoDi is redefining the way charges and payments are made in 
Mexico — allowing monetary transactions to be more efficient and 
secure. The QR code, generated via Citibanamex Móvil and/or the 
Transfer app, can be read immediately, shared via text message or 
printed to facilitate payments for products or services. Users can 
perform these transactions directly from mobile phone to mobile 
phone. In addition, there will be lower commission costs, as well 
as a reduction in the use of cash.

The CoDi innovation has global consumer potential. The new 
platform is also simple and works with all smartphones, banks and 
telephone carriers. 

The CoDi story goes beyond growth. It is a key example of how 
we are reinforcing our commitment to offer Mexico’s best banking 
experience while driving financial inclusion and using new 
technologies to meet the expectations, needs and preferences of 
each of our clients. 

10

GLOBAL CONSUMER BANKINGIn the U.S., we offered Citigold clients 
commission-free purchases on 
ETFs and enhanced digital planning 
capabilities with Citi® Wealth Advisor, 
a digital financial planning solution 
for creating custom financial plans 
focused on the needs and goals that 
matter most. For the third consecutive 
year, Citi was named the Best Bank for 
High Net Worth Families by Kiplinger. 

In Asia, we continued to enhance 
the client experience, unveiling a 
revitalized Citigold Private Client 
experience in China and launching 
Citibank Global Wallet in 13 markets, 
a market-first product that provides 
unrivaled convenience in foreign 
currency withdrawal and spending. 

In Mexico, Citibanamex is one of the 
most well-regarded and historically 
significant financial institutions in the 
country, with top brand recognition, 
leading market share and an extensive 
retail branch network complemented 
by rapid digital and mobile user 
growth. In 2019, Citi continued to pace 
its strategic investments in technology, 
modernizing its branch and ATM 
network and digitizing its products and 
client base. Digital account opening 
was rolled out in branches across the 
country — a 12-minute experience from 
start to finish — while new, redesigned 
mobile app functionality is driving 
robust mobile user growth, up 50% 
for the year. 

Citibank Global Wallet allows clients in 
Asia Pacific to use their ATM card to 
withdraw cash or spend and transact 
overseas, as well as conduct online 
purchase transactions in 12 currencies.

. APRIL
8

Citi launches Volunteer Africa 2019 

14

Paco Ybarra named Head of the ICG 
and Japan

16

Citi launches biometric authentication 
for institutional clients in Asia Pacific 

Citi inaugurates new offices at Abu 
Dhabi Global Market 

17

Citi issues nine structured green bonds 
to finance sustainable development

24

Citi releases 2018 Global Citizenship 
Report 

26

Citi enters into partnership with 
Vietnam-based FinTech Payoo 

. MAY
7

Citi launches Citi Verify real-time data 
validation service for institutions

14

Citi and Paytm collaborate to launch 
Paytm First Card 

20

Citi Named Celent’s 2019 Model Bank 
of the Year, recognized for eight global 
treasury solutions initiatives 

11

2019Institutional Clients Group

Citi’s Institutional Clients Group (ICG) enables economic 

progress, growth and sustainability for our clients and 

for the world through our unparalleled global network. 

The Institutional Clients Group 
includes five main business lines: 
Banking, Capital Markets and 
Advisory, Commercial Banking, 
Markets and Securities Services, 
Private Banking, and Treasury and 
Trade Solutions (TTS). Working 
together, we provide innovative 
solutions to meet the complex 
needs of corporations, financial 
institutions, public sector entities, 
investment managers and ultra 
high net worth clients. 

With a physical presence in  
98 countries, local trading  
desks in 77 markets and a 
custody network in 63 markets, 
we facilitate approximately  
$4 trillion in financial flows 
daily. We support 90% of Global 
Fortune 500 companies in their 
daily operations and help them  
to hire, grow and succeed. 

Our network-driven strategy 
allows us to offer an integrated 
suite of wholesale banking 
products and services to clients 
who value our unmatched country 
presence and who require a 
financial services partner that can 
help them grow in any country 
where they do business. This 
includes multinationals that are 
expanding globally, particularly 
in the emerging markets, and 
emerging markets companies that 
are growing beyond their home 
market/region. 

We are uniquely positioned to 
take advantage of important, 
evolving global trends, including 
mobility, fintech, wellness and 
sustainability; deliver responsible, 
objective advice; and provide 
stellar execution to lead 
transformation for our clients.

Banking, Capital 
Markets and Advisory
Banking, Capital Markets and 
Advisory listens, collaborates and 
problem solves, working tirelessly 
on behalf of our corporate, 
financial institution, public sector 
and sponsor clients to deliver 
a range of strategic corporate 
finance and advisory solutions that 
meet their needs, no matter how 
complex. Dedicating ourselves to 
these relationships and ensuring 
our client experience stands above 
all else, we leverage the breadth 
of our unmatched global network 
to provide debt capital raising, 
merger and acquisition (M&A), and 
equity-related strategic financing 
solutions, as well as issuer services. 
By serving these companies, we 
help them grow, creating jobs and 
economic value at home and in 
communities worldwide.

12

Citi executed several landmark 
underwriting and advisory 
transactions for clients in 2019. Citi 
acted as financial advisor and lead 
provider of committed financing to 
Occidental Petroleum Corporation on 
its acquisition of Anadarko Petroleum 
Corporation, a transaction valued at 
$57 billion that was the third largest 
energy acquisition globally and the 
largest in North America in the last 
20 years. Its $21.8 billion bridge 
loan facility is the second largest in 
energy globally and the largest in 
North America. Citi served as Celgene 
Corporation’s financial advisor on its 
announced merger with Bristol-Myers 
Squibb Company, creating a premier 
innovative biopharma company in the 
largest healthcare M&A transaction in 
history. Citi is serving as lead financial 
advisor to Raytheon on its all-stock 
merger with United Technologies’ 
aerospace business. The transaction, 
which has a combined enterprise value 
greater than $155 billion, represents 
the largest aerospace and defense 
transaction in history. Citi is also 
serving as lead financial advisor to 
LVMH Moët Hennessy Louis Vuitton 
SE and is providing committed 
financing for its definitive agreement 
to acquire Tiffany & Co. in a $16.9 
billion transaction, the largest luxury 
acquisition in history. This transaction 
is expected to close in mid-2020.

Citi was a joint global coordinator and 
joint bookrunner on Alibaba Group’s 
$12.9 billion Hong Kong secondary 
listing, which was the largest global 
technology follow-on in history and 
the largest ever follow-on by a Chinese 
issuer. Citi acted as global coordinator, 
as well as sole financial advisor, 
debt structuring agent, hedging 
coordinator, documentation agent and 
facility agent on a €10.4 billion bridge 
facility package for CK Hutchison 
Group Telecom Holdings Limited 
(CKHGT) to support the creation of 
a new telecom holding company. 
Additionally, Citi acted as global 
coordinator and bookrunner on a €4.2 
billion and £800 million bond offering 
for CKHGT. Citi also acted as global 
coordinator, bookrunner, mandated 
lead arranger and facility agent on the 
€4.2 billion dual-maturity term loan 
facilities and €360 million three-year 
revolving credit facility for CKHGT. 
Proceeds of the bond offering and 
term loan were used for repayment of 
the bridge facility. 

Citi advised on a $20 billion three-
part strategic liability management 
transaction for Petróleos Mexicanos 
(Pemex). Citi acted as a joint lead 
manager and joint bookrunner 
on a $7.5 billion offering of senior 
unsecured bonds to refinance short-
term debt, joint dealer manager on 
Pemex’s $7.2 billion dual Exchange 

With a physical presence in 98 countries, 
local trading desks in 77 markets and a 
custody network in 63 markets, we facilitate 
approximately $4 trillion in financial flows 
daily. We support 90% of Global Fortune 500 
companies in their daily operations and help 
them to hire, grow and succeed.

. MAY
21

Singapore Management University 
partners with Citi Ventures to  
offer experiential learning in  
financial technology 

23

Citi hires veteran-owned firms 
exclusively to distribute recent  
$3.0 billion bond issuance

31

Citi recognized for Innovation, 
Leadership in derivatives clearing

. JUNE
8

Citi celebrates its 14th Annual  
Global Community Day with 110,000 
Citi volunteers

11

Citi and Grab announce launch of Citi-
Grab credit card across Southeast Asia 

18

Citi is a founding signatory of the 
Poseidon Principles 

19

Citi Hong Kong invests in renewable 
energy credits 

25

Citi enables seamless rewards points 
redemption at checkout for ThankYou 
cardmembers 

26

Citi Payment Outlier Detection 
launches in 90 countries using artificial 
intelligence and machine learning 

30

Citi exceeded its $100 Billion  
Environmental Finance Goal 

13

2019Offers, and joint dealer manager on 
Pemex’s $5 billion cash tender offer. 
Citi also structured a convertible 
equity portfolio financing solution for 
NextEra Energy Partners (NEP) and 
KKR to fund a renewables portfolio, 
a unique structure that met the 
strategic, corporate finance and return 
objectives of both clients. Under the 
agreement, KKR will acquire an equity 
interest in structured partnership 
with NEP that owns a geographically 
diverse portfolio of 10 utility-scale 
wind and solar projects across the 
United States, collectively consisting 
of approximately 1,192 megawatts.

Markets and Securities 
Services
Markets and Securities Services 
relies on global breadth and product 
depth to provide an enhanced client 
experience. Our sales and trading, 
distribution and research capabilities 
span a broad range of asset classes, 
providing customized solutions that 
support the diverse investment and 
transaction strategies of investors and 
intermediaries worldwide. 

We further streamlined our Markets 
operating model to drive better client 
service in 2019, combining FXLM and 
G10 Rates to create a single Rates 
and Currencies business line. As our 
clients continued to evolve and require 
a broad range of services, we also 
announced the formation of Equities 
and Securities Services, an integrated 
offering supporting the pre-trade, 
execution and post-trade requirements 
of our clients. This includes broad 
trading and execution capabilities for 
electronic and complex structured 
products, financing and hedging 
solutions, and clearing, custody and 
funds services.

Our digital channel, Citi VelocitySM, 
gives unprecedented access to 
capital markets intelligence and 
execution. More than 87,000 client 
users in 160 countries count on our 
#1 ranked platform to help them 
navigate markets and make trading 
decisions. Through our web, mobile 
and trading applications, clients can 

14

Citi provided the $116 million affordable housing construction loan and $12.5 million 
permanent loan for the 14-story, 407-unit development serving people with disabilities 
and/or mental illness who have experienced homelessness, as well as families and 
veterans overcoming homelessness.

find proprietary data and analytics, 
Citi research and market commentary, 
access to fast, seamless and stable 
execution for foreign exchange 
(FX) and rates trades, and a suite 
of sophisticated post-trade analysis 
tools. Citi Velocity’s API Marketplace 
gives clients unparalleled access to 
Citi’s extensive proprietary data and 
content library.

Last year, we continued our support 
of the communities in which we live 
and work. Our annual e for Education 
campaign raised $8.15 million in 
2019 to benefit education-focused 
nonprofits. Since its inception in 2013, 
the global philanthropic initiative 
has raised more than $37 million to 
help tackle childhood illiteracy and 
improve access to quality education. 
Throughout the nine-week campaign, 
our Foreign Exchange business 
donated $1 for every $1 million traded 
on its electronic platforms, including 
Citi Velocity, Citi’s flagship trading 
platform for institutional clients, 
and CitiFX Pulse for corporate and 
custody clients. This year, Citi has 
expanded the campaign to include a 
broader range of electronically traded 
products, including local market bonds 
and futures and cash equities. 

We retained our ranking as the 
world’s largest fixed income dealer, 
according to Greenwich Associates’ 
annual benchmark study, which marks 
the fourth year running that Citi has 
secured the top spot. We ranked #1 in 
sales quality and trading quality, as 
well as #1 in e-trading.

Private Bank
The Private Bank is dedicated to 
helping the world’s wealthiest 
individuals, families and law firms 
protect and responsibly grow their 
wealth. Our unique business model 
enables us to focus on fewer, larger 
and more sophisticated clients who 
have an average net worth above 
$100 million. Clients enjoy a highly 
customized experience, with access 
to a comprehensive range of products 
and services spanning investments, 
banking, lending, custody, wealth 
planning, real estate, art, aircraft 
finance and lending, and more. 

In everything we do, we emphasize 
personalized advice, competitive 
pricing and efficient execution. As 
part of the ICG, the Private Bank is 
able to connect clients’ businesses to 
banking, capital markets and advisory 
services, as well as to our other 
institutional resources.

INSTITUTIONAL CLIENTS GROUPBecause our clients are increasingly 
global in their presence and in their 
financial needs, our unrivaled Global 
Client Service enables them to have 
dedicated local bankers in as many 
regions of the world as they require. 
They are, therefore, able to enjoy 
seamless, cross-border service from 
a worldwide team working together 
as one.

A growing number of our clients 
seek to align their investments with 
their personal values. Investing 
with Purpose is our philosophy and 
methodology for sustainable and 
impactful investing. We help clients 
articulate their Investing with Purpose 
goals and objectives, provide them 
with comprehensive advice and offer 
in-house investment management that 
incorporates environmental, social 
and governance principals, as well as 
partner with asset managers to deliver 
relevant themes and strategies. 

Our offering is continuously evolving 
in order to address and anticipate 
our clients’ changing needs. Included 
among our latest evolutions is the 
Private Capital Group, serving 1,400 
family-owned businesses, family 
offices and private capital firms in 
75 countries. We have extensive 
experience with the challenges 
that families and their Family Office 
executives regularly face, and we 
address their needs by combining 
the personalized service of a private 
bank with sophisticated cross-border 
strategies that are typically reserved 
for major institutions.

We are committed to helping our 
clients preserve their wealth for 
themselves, for their families and for 
future generations. As well as working 
with their other advisors to create 
appropriate structures and strategies, 
we help prepare their heirs for future 
responsibilities as wealth owners and 
leaders of the family business.

Treasury and Trade 
Solutions
Treasury and Trade Solutions 
provides integrated cash 
management, working capital 
and trade finance solutions to 
multinational corporations, financial 
institutions and public sector 
organizations around the globe.  
With the industry’s most 
comprehensive suite of digitally 
enabled platforms, tools and 
analytics, TTS leads the way in 
delivering innovative and tailored 
solutions to its clients. Specific 
offerings include payments and 
receivables, liquidity management 
and investment services, commercial 
card programs, and trade services 
and trade finance. Based on the belief 
that client experience is the driver of 
sustainable differentiation, TTS has 
focused its efforts on transforming 
its business to deliver a seamless, 
end-to-end client experience 
through the development of its 
capabilities, client advocacy, network 
management and service delivery 
across the entire organization.

Investing with Purpose is our philosophy and 
methodology for sustainable and impactful 
investing. We help clients articulate their Investing 
with Purpose goals and objectives, provide them 
with comprehensive advice and offer in-house 
investment management that incorporates 
environmental, social and governance principals, 
as well as partner with asset managers to deliver 
relevant themes and strategies.

. JULY
2

Citibank named Best Bank for High Net 
Worth Families by Kiplinger for third 
straight year

3

Citi is first major U.S. bank to endorse 
Principles for Responsible Banking

11

Citi Ireland awarded Best Investment 
Bank by Euromoney 

19

Citi named Asia’s Best Digital Bank  
and Best Bank for Transaction Services 
by Euromoney

25

Citi named Top Asia Equities Research 
and Sales House by Clients by 
Institutional Investor magazine

30

Citi launches biometric authentication 
for institutional clients in Latin America

. AUGUST
2

Citi unveils new Citigold® Private Client 
experience in China

25

Citi releases For Better or Worse, Has 
Globalization Peaked? GPS report 
reviewing the advantages of globalization 
and its role in increasing disparities 

26

Citi APIs for Treasury Services reach 
new milestone: over 150 million API calls 
processed by clients globally 

15

2019TTS continues its pursuit of 
delivering the best possible 
experience to its clients, launching 
leading-edge solutions and 
leveraging co-creation sessions held 
in the Innovation Labs, which in 
2019 celebrated its 10th anniversary. 
The team’s success is based on the 
foundation of the industry’s largest 
proprietary network, with banking 
licenses in 98 countries and globally 
integrated technology platforms. In 
2019, Euromoney magazine named 
TTS the World’s Best Bank for 
Transaction Services in its annual 
Awards for Excellence.

TTS continues to transform itself to 
be the financial platform for global 
commerce. Digital technology is driving 
change across the industry, and Citi is 
adapting by migrating our capabilities 
to a digital platform. In 2019, digital 
onboarding went live in 25 countries — 
covering 58% of our global volumes. 
And we took our advisory dialogue 
with clients to new levels to help them 
accelerate their transformational 
journey to a new digital decade. Since 
the inception of digital onboarding, we 
have led over 3,000 advisory sessions 
with clients across our Digital Advisory, 
Treasury Diagnostics and Innovation 
Lab practices to help them grow, 
improve risk controls and enhance 
financial returns. 

CitiConnect®, our API connectivity 
platform, reached a new milestone 
with more than 157 million API 
calls processed by clients in 2019, 
compared with 18 million in 2018, 
representing a growth rate of 
750%. Core to our drive to digital is 
implementing a strategy where we 
combine our proprietary solutions 
and partner with fintech companies 
like HighRadius and Cachematrix, 
and key industry players like PayPal, 
making the services available on our 
industry-leading global network.

In 2019, we launched many innovative 
services for our clients, including 
Citi®’s Payment Outlier Detection 
in 90 countries, with advanced 
analytics, artificial intelligence 
and machine learning to help 
proactively identify outlier payments; 
and Cross-Currency Sweeps, a 
liquidity management solution that 
aggregates foreign currency balances 
into a currency and account of choice. 
We provided clients with an enhanced 
Supplier Finance offering, now with 
WorldLink® Payment Services, giving 
our clients access to the combined 
strength of two powerful platforms. 
We also introduced Citi® Global 
Collect, a collaboration between 
our TTS and Foreign Exchange 
businesses  — a new cross-border 
platform to help clients manage 
collecting cross-border business-to-
business payments by digitizing the 
transaction process and embedding 
FX capabilities. 

TTS continues to transform itself to be the 
financial platform for global commerce. 
Digital technology is driving change across 
the industry, and Citi is adapting by migrating 
our capabilities to a digital platform.

16

INSTITUTIONAL CLIENTS GROUPICG Recognition

•  Citi retained its ranking as the world’s largest fixed income dealer, according 
to Greenwich Associates’ annual benchmark study, which marks the fourth 
year running that Citi has secured the top spot. Citi also ranked #1 in sales 
quality and trading quality, as well as #1 in e-trading, and was #1 overall in 
U.S. fixed income market share. CitiDirect BE® was ranked #1 by Greenwich 
Associates’ digital banking benchmark study, claiming the top rank for the 
13th consecutive year.

•  In addition to being named International Financing Review’s Bank of the 
Year, Citi was awarded the Best Global Bank for Governments and was 
named Global Equity Derivatives House, Global Emerging Markets Bond 
House and EMEA Bond House of the Year.

•  Citi was awarded the Financial Times’ The Banker and PWM Global Private  
Banking awards for Best Global Private Bank and Best Private Bank for  
Customer Service. Additionally, we won Best Global Private Bank for Global 
Families and Family Offices. The Private Bank was also named Best Private 
Bank for Net Worth of US$25 million or more by Global Finance.

•  Global Finance named Citi Best Global Transaction Bank, Best Global Bank 
for Cash Management, Best Global Mobile Cash Management Solution and 
Best Online Cash Management in Asia. Additionally, Citi was named Best 
Bank for Cash Management and Liquidity Management in Latin America, 
as well as Best Bank for Payments and Collections in both Latin America 
and North America. Citi was also honored as Best Investment Bank for New 
Financial Technology Globally and in North America, as well as Best Private 
Bank in North America. Global Finance also bestowed several trade finance 
awards upon Citi, including Best Bank for Trade Finance in Frontier Markets 
and Best in North America and the United States.

•  Citi earned top honors from Euromoney as the World’s Best Bank for  

Corporates and Best Bank for Transaction Services Globally and in Asia.  
Euromoney also named Citi Central and Eastern Europe’s Best  
Investment Bank. 

•  Celent awarded Citi its Model Bank of the Year award, reflecting our  
ongoing efforts to drive transformational innovation and digitization.

•  Citi was named Derivatives Clearing Bank of the Year by GlobalCapital for 

the sixth straight year.

•  Citi maintained top position as the largest affordable housing lender in the 
United States, according to Affordable Housing Finance magazine’s annual 
survey of affordable housing lenders. This marked the 10th consecutive 
year that Citi has earned this distinction.

•  Citi ranked #1 in Web Based Analytics and #3 Overall in the Institutional  
Investor inaugural Global Fixed Income Research Poll. In 2019, Citi was a 
leader in Institutional Investor’s ranking of global equity firms coming in at 
second place, an increase of two spots from the previous year.

•  Citi received a number of regional accolades, including Best Bank in Asia 
from CorporateTreasurer magazine, Best Bank for Emerging European, 
Middle Eastern and African Currencies from FX Week, and ABS Bank of the 
Year from GlobalCapital as part of its European Securitization Awards. 

•  Citi was named Most Innovative Investment Bank for Equity-Linked 

 Products from The Banker.

. SEPTEMBER
4

Citi Board elects Alexander Wynaendts 
and Grace Dailey to Board of Directors

Citi expands annual e for Education 
campaign across a broader range of 
electronically traded products

5

Citi opens state-of-the-art operations 
site in Sioux Falls

10

Citi unveils its roster of 41 para athletes 
one year out from Tokyo 2020

18

Citi ranked Best in Overall U.S. Fixed 
Income Market Share, Quality

19

Citi releases Energy Darwinism, GPS 
report exploring the path to getting to 
net zero carbon

25

Retail Services and Tractor Supply 
Company launch new 5% back in 
rewards for credit cardholders

. OCTOBER
10

Citi joins United Nations Global 
Investors for Sustainable  
Development Alliance

16

Citi launches cross-currency sweeps for 
liquidity management

24

Jane Fraser named President of Citi 
and Head of Global Consumer Banking

17

2019Environmental, Social and Governance:
Citi as a Corporate Citizen

Citi, as a global bank, employer and philanthropist, is 

focused on catalyzing sustainable growth through 
transparency, innovation and market-based solutions.

From climate change to social 
inequality to financial inclusion, 
there are numerous challenges 
facing society today. Citi is 
committed to contributing to 
solutions that address these 
issues. We collaborate both 
internally across our business 
units and externally with 
stakeholders to maximize our 
impact. We continue to learn 
from our experience and to 
bring diverse stakeholders to the 
table to help us understand what 
leadership looks like on these 
evolving issues. 

Citi has the scale and capabilities 
to finance and support the 
institutions — governments, 
corporations, nonprofits and 
aid organizations — that can 
contribute to the future that we 
want and the future that our 
communities deserve. 

This section of the report is not 
intended to be a comprehensive 
collection of our efforts but 
rather a sample of highlights to 
demonstrate how we deploy our 
products, people and financial 
resources to help build more 
inclusive, resilient and sustainable 
communities. Issues core to 
our environmental, social and 
governance efforts include:

Sustainable Growth and 
Climate Change
The impacts of climate change 
are becoming increasingly clear 
— not just the physical effects of 
a warming planet as it threatens 
communities and reshapes 
urban infrastructure but also the 
economic impacts as every sector 
examines its material risks and 
opportunities associated with 
these changes. 

In 2015, as part of the launch 
of Citi’s Sustainable Progress 
strategy, we made a bold, 10-
year commitment, our $100 
Billion Environmental Finance 
Goal, to help reduce the impacts 
of climate change through 
environmental finance activities 
around the world. In 2019, 
we exceeded our $100 billion 
goal, more than four years 
ahead of schedule, thanks to 
increasing focus on the need 
to solve the problem, growth in 
environmental finance activity 
in the global market, and 
the development of new and 
innovative financial products 
such as lending linked to key 
environmental, social and 
governance indicators. We have 
also achieved our environmental 
footprint goals and are on track 
to achieve our 100% renewable 
energy goal in 2020.

18

Environmental, Social and Governance:

Citi as a Corporate Citizen

The $100 billion target we have just 
completed was only one step in a long 
journey — a marker on a path rather 
than an end goal. We have made 
significant commitments in support 
of a sustainable, low-carbon economy 
and are on the record for our strong 
support of the Paris Agreement. 
We have also been recognized as a 
leader in climate risk assessment and 
disclosure and were the first major U.S. 
bank to publish a Task Force on Climate-
Related Disclosures report in 2018.

The science is clear: climate change 
is a monumental challenge, and we 
need to move toward a low-carbon 
global economy. While scaling financial 
flows to low-carbon solutions is a 
critical aspect of the transition, we 
also need a more holistic approach 
that supports the transition of 
existing carbon-intensive sectors. In 
addition to helping clients realize the 
opportunities inherent in transitioning 
to a low-carbon economy, we are 
conducting sophisticated analyses 
of the risks associated with our own 
and our clients’ exposure to a variety 
of transition scenarios. We are also 
assessing our exposure to climate 
hazards to inform business continuity 
and resilience planning.

As we look ahead toward our new 
Sustainable Progress 2025 strategy, 
we look forward to continuing to 
collaborate with our clients on climate 
finance opportunities, as well as to 
better understand the challenges that 
need to be addressed by Citi, and the 
financial sector overall, in order to 
drive positive change.

For more information on our 
sustainability efforts, please visit  
citi.com/citi/sustainability.

Financial Capability and 
Access to Capital 
Citi is committed to developing 
financial solutions that are safe, 
transparent and accessible — ones 
that provide real economic value, 
including for those whose financial 
needs are currently unmet. This 
year, Citi is on track to reach a 
major milestone — $1 billion in 
lending toward financial inclusion 
across the globe. We seek out 
innovative partnerships with financial 
institutions, telecommunications 
and fintech providers, government 
agencies, consumer goods companies 
and others that have close 
relationships with the unbanked and 
the underserved segments of society. 
Our partners are trusted leaders in 
their sectors who understand the 
needs of their local markets.

$100 Billion Environmental Finance Goal: Financial Highlights, 2014–2019

. OCTOBER
31

Citi releases 2019 mid-cycle stress test 
disclosures

. NOVEMBER
4

Citi announces new Miles Ahead 
Savings Account exclusively for Citi/
AAdvantage cardholders

7

Citi wins Best Corporate/Institutional 
Digital Bank in Asia Pacific from Global 
Finance magazine

Citi sponsors the 2019 World Para 
Athletics Championships in Dubai 
as part of partnership with the 
International Paralympic Committee

11

Citi enters into mentor-protégé 
partnership with Roberts & Ryan 
Investments, a service-disabled veteran-
owned institutional broker-dealer 

12

Citi launches Regulatory Initial Margin 
Calculation Service to help clients 
comply with uncleared margin rules 

Business Insider Intelligence recognizes 
Citi as having the Most Desirable 
Mobile Banking Features in the U.S. for 
second consecutive year

19

Citi helps clients collect cross-border 
B2B payments with new platform, Citi® 
Global Collect

Citi introduces new digital high-yield 
account with no ATM fees in U.S.

19

2019We recently launched a $150 million 
Citi Impact Fund to invest our own 
capital in U.S.-based companies that 
are applying innovative solutions to 
help address four societal challenges: 
workforce development; sustainability; 
financial capability; and physical 
and social infrastructure. We are 
also actively seeking opportunities 
to invest in businesses that are led 
or owned by women and minority 
entrepreneurs. This work complements 

Citi Impact 
Fund will make 
investments in 
double bottom-
line startups with 
an emphasis 
on women 
and minority 
entrepreneurs.

our existing environmental, social 
and governance efforts and aims 
to highlight the ability to achieve 
financial returns while also making a 
positive societal impact.

The Future of Work 
According to the U.S. Department of 
Labor, there are 7 million jobs at any 
one time that employers can’t fill. 
Our Pathways to Progress initiative 
is designed to help close this job-
skills mismatch by providing young 
people with the tools they need 
through training, work experience and 
entrepreneurial opportunities. 

Since 2014, the Citi Foundation has 
invested more than $194 million to 
impact the lives of youth globally. 
This support has enabled community 
organizations and municipal leaders 
to connect more than 850,000 young 
people around the world to jobs, paid 
internships, mentorship, workforce 
training and leadership development. 
And these efforts have leveraged the 
time and talent of thousands of Citi 
employee volunteers.

We continue to believe that 
empowering young people, 
providing early work experience 
and financial knowledge, incubating 
an entrepreneurial mindset, and 
creating networks and access to role 
models are each integral to enabling 
youth to build a stronger future for 
themselves, their families and their 
communities. As we look ahead, we 
remain committed to tackling the 
youth unemployment challenge. 

One example of these efforts is 
Scaling Enterprise, a $100 million loan 
guarantee facility launched by Citi, 
the U.S. International Development 
Finance Corporation (DFC) (formerly 
OPIC) and the Ford Foundation in 2019. 
Through this facility, we are able to 
provide earlier-stage financing in local 
currency to companies that expand 
access to products and services for 
low-income communities in emerging 
markets. Loans and working capital 
in local currency and at affordable 
rates can enable innovative social 
impact companies to achieve scale, 
greater efficiencies and lower costs. 
Scaling Enterprise will facilitate vital 
growth financing to companies that 
are expanding access to finance, 
agriculture, energy, affordable 
housing, water and sanitation to 
low-income households in emerging 
markets. In the first two transactions 
under Scaling Enterprise, the partners 
have committed $5 million in financing 
to InI Farms to help smallholder 
banana and pomegranate farmers 
in India access export markets and 
increase incomes by up to 20%, as 
well as $5 million in financing to d.light 
to expand access to off-grid solar 
energy in Kenya.

Citi has also partnered with the U.S. 
International Development Finance 
Corporation to expand microfinance 
loans to women in emerging markets 
around the world. In 2019, we 
committed to work with the DFC, 
the U.S. Agency for International 
Development and private sector 
partners to mobilize an additional  
$500 million for women in Latin 
America. In Tunisia, we recently 
announced the launch of a $10 million 
loan guarantee facility, which will 
provide growth financing to more 
than 17,000 microentrepreneurs, 
approximately 65% of them women. 
And in Jordan, Citi provided $5 million 
to Microfund for Women, which will now 
be able to give loans to an additional 
10,000 underserved Jordanian women.

20

ENVIRONMENTAL, SOCIAL AND GOVERNANCE:  CITI AS A CORPORATE CITIZEN“When we set our business priorities, we focus heavily on the balance of our 
business — the importance of not being overly reliant on any one product or 
geography and the benefits of that diversification to strong and consistent 
financial performance. We think about our people in much the same way.

To be a healthy, high-performing organization, we need a well-balanced 
team that is representative of the places where we operate, in every part of 
the world. It’s simply smart business.”

— Michael L. Corbat, CEO

The Citi Foundation will reaffirm its 
philanthropic commitment, and we 
will complement these investments 
with youth-focused efforts happening 
across Citi, including programs that 
are helping us build a more diverse 
talent pipeline while also preparing the 
next generation for today’s workforce.

Talent and Diversity
At Citi, we actively seek diverse 
perspectives at all levels of our 
organization because we know that it 
will improve performance and boost 
innovation. Over the last two years, 
we have elevated the conversation 
around race, gender and equal 
pay for equal work. Our increased 
transparency, which in turn breeds 
accountability and credibility, is a force 
for change both inside and outside 
our company. We’ve pushed ourselves 
beyond our comfort zone — not just 
to acknowledge the stark realities 
laid bare in the statistics around pay 
equity but also to recognize the social 
and cultural forces that produced 
them. We are being open about our 
data, what it means and what needs to 
be done to meet our goals. 

In 2019, we made a decision to be 
transparent about a statistic that our 
CEO has described as “disappointing” 
and “ugly”: our unadjusted or “raw” 
pay gap for women and U.S. minorities. 
The analysis showed that Citi’s median 
pay for women globally was 71% of the 
median for men and that the median 
pay for U.S. minorities was 93% of 
the median for non-minorities. For 
our company, the data reaffirm the 

importance of goals we announced in 
2018 to increase our representation of 
women and U.S. minorities in senior 
and higher paying roles at Citi. We 
know that is the only effective way for 
us to meaningfully reduce our raw pay 
gap over time. We also disclosed that 
on an adjusted basis, women globally 
are paid on average 99% of what men 
are paid at Citi. We also repeated the 
assessment for U.S. minorities and 
are pleased that after actions in 2018, 
there was no statistically significant 
difference between what U.S. minorities 
and non-minorities are paid at Citi. 
Following our review, we once again 
made appropriate pay adjustments as 
part of the 2019 compensation cycle. 
While we recognize that we have much 
more to do, we are proud of where we 
are headed. 

We know that engagement with our 
people throughout their career paths 
at Citi, along with a commitment to 
being a company with values that 
they can be proud of, is essential to 
our success. We are innovating how 
we engage with, recruit and develop 
talent; we are using data more 
effectively to pinpoint our challenges 
and areas of opportunity for 
improvement; and we have increased 
accountability for our representation 
goals among people managers. In 
2019, we built out our predictive 
analytics team to help us better 
understand how we attract, retain  
and promote top talent.

. NOVEMBER
20

Citibank rated #1 in Customer 
Satisfaction by American Customer 
Satisfaction Index

21

Citi wins top honor as World’s Best 
Digital Bank; wins multiple FX Week  
Best Bank awards

29

The Citi Alumni Network extends into  
100 countries; membership in 2019 
reached 25,000 worldwide

. DECEMBER
2

Citi ranked seventh overall out of 300 
firms in Newsweek’s inaugural index of 
America’s Most Responsible Companies

9

Citi launches City Builder, a data-driven 
platform to support investments in U.S. 
Opportunity Zones

13

International Financing Review magazine 
names Citi Bank of the Year 

16

Citi and PayPal extend partnership to 
institutional payments 

20

Citi earns 35 spots on Bank Investment 
Consultant’s Top 100 Bank Advisors  
list for 2019

21

2019Citi is a proud partner of the International Paralympic Committee.  
For more information on the partnership visit citi.com/IPC.

© 2020 Citigroup Inc. All rights reserved. Citi, Citi and Arc Design and other marks used herein are service marks of Citigroup Inc. or its 
affiliates, used and registered throughout the world.

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM 10-K 

(Mark One)

ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT 
OF 1934

For the fiscal year ended December 31, 2019 

OR

TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT
OF 1934
For the transition period from        to  
Commission file number 1-9924 
Citigroup Inc.
(Exact name of registrant as specified in its charter)

Delaware

(State or other jurisdiction of incorporation or organization)

388 Greenwich Street, New York

NY

(Address of principal executive offices)

52-1568099

(I.R.S. Employer Identification No.)
10013
(Zip code)

(212) 559-1000 
(Registrant's telephone number, including area code)

Securities registered pursuant to Section 12(b) of the Securities Exchange Act of 1934 formatted in Inline XBRL:  See Exhibit 99.01

Securities registered pursuant to Section 12(g) of the Act:  none

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes 

No 

Indicate by check mark if the registrant is not required to file reports pursuant to Section 13 or Section 15(d) of the Act. Yes 

    No 

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during 
the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements 
for the past 90 days. Yes 

    No 

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to be submitted pursuant to Rule 405 of 
Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit such files).   
Yes 

     No 

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer, smaller reporting, or an emerging 
growth company. See the definitions of "large accelerated filer," "accelerated filer," "smaller reporting company" and “emerging growth company” in 
Rule 12b-2 of the Exchange Act.

Large accelerated filer

Accelerated filer

Non-accelerated filer

Smaller reporting company
Emerging growth company

If an emerging growth company, indicate by check mark if the registrant has elected not to use the extended transition period for complying with any new or 
revised financial accounting standards provided pursuant to Section 13(a) of the Exchange Act.  Yes 

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes 

    No 

The aggregate market value of Citigroup Inc. common stock held by non-affiliates of Citigroup Inc. on June 30, 2019 was approximately $158.0 billion.

Number of shares of Citigroup Inc. common stock outstanding on January 31, 2020: 2,106,486,793 

Documents Incorporated by Reference: Portions of the registrant’s proxy statement for the annual meeting of stockholders scheduled to be held on April 21, 
2020 are incorporated by reference in this Form 10-K in response to Items 10, 11, 12, 13 and 14 of Part III.

Available on the web at www.citigroup.com

    
FORM 10-K CROSS-REFERENCE INDEX

Item Number

Part I

1.

Business

Page

4–27, 112–115,
118, 146,
294–295

1A. Risk Factors

46–55

1B. Unresolved Staff Comments

Not Applicable

Properties

Not Applicable

Part III

10.

Directors, Executive
Officers and Corporate
Governance

11.

Executive Compensation

12.

Security Ownership of
Certain Beneficial Owners
and Management and
Related Stockholder
Matters

14.

Principal Accounting Fees
and Services

Part IV

298–300*

**

***

****

*****

* For additional information regarding Citigroup’s Directors, see

“Corporate Governance” and “Proposal 1: Election of Directors” in
the definitive Proxy Statement for Citigroup’s Annual Meeting of
Stockholders scheduled to be held on April 21, 2020, to be filed
with the SEC (the Proxy Statement), incorporated herein by
reference.

** See “Compensation Discussion and Analysis,” “The Personnel and

Compensation Committee Report,” and “2019 Summary
Compensation Table and Compensation Information” and “CEO
Pay Ratio” in the Proxy Statement, incorporated herein by
reference.

*** See “About the Annual Meeting,” “Stock Ownership” and “Equity

Compensation Plan Information” in the Proxy Statement,
incorporated herein by reference.

**** See “Corporate Governance—Director Independence,” “—Certain
Transactions and Relationships, Compensation Committee
Interlocks and Insider Participation” and “—Indebtedness” in the
Proxy Statement, incorporated herein by reference.
***** See “Proposal 2: Ratification of Selection of Independent

Registered Public Accounting Firm” in the Proxy Statement,
incorporated herein by reference.

Legal Proceedings—See
Note 27 to the Consolidated
Financial Statements

276–282

13.

Certain Relationships and
Related Transactions and
Director Independence

4.

Mine Safety Disclosures

Not Applicable

Part II

Market for Registrant’s
Common Equity, Related
Stockholder Matters and
Issuer Purchases of Equity
Securities

128–129, 152–154,
296–297

15.

Exhibits and Financial
Statement Schedules

2.

3.

5.

6.

7.

Selected Financial Data

10–11

Management’s Discussion
and Analysis of Financial
Condition and Results of
Operations

6–29, 58–111

7A. Quantitative and Qualitative

Disclosures About Market
Risk

58–111, 147–151,
172–207, 214–267

8.

9.

Financial Statements and
Supplementary Data

124–293

Changes in and
Disagreements with
Accountants on Accounting
and Financial Disclosure

Not Applicable

9A. Controls and Procedures

116–117

9B. Other Information

Not Applicable

2

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CITIGROUP’S 2019 ANNUAL REPORT ON FORM 10-K 

OVERVIEW

MANAGEMENT'S DISCUSSION AND 
  ANALYSIS OF FINANCIAL CONDITION AND 
  RESULTS OF OPERATIONS

Executive Summary

Summary of Selected Financial Data

SEGMENT AND BUSINESS—INCOME (LOSS) 
  AND REVENUES
SEGMENT BALANCE SHEET
Global Consumer Banking
North America GCB
Latin America GCB
Asia GCB

Institutional Clients Group
Corporate/Other

OFF-BALANCE SHEET 
  ARRANGEMENTS

CONTRACTUAL OBLIGATIONS

CAPITAL RESOURCES

RISK FACTORS

Managing Global Risk Table of Contents

MANAGING GLOBAL RISK

SIGNIFICANT ACCOUNTING POLICIES AND  
  SIGNIFICANT ESTIMATES

DISCLOSURE CONTROLS AND 
  PROCEDURES

MANAGEMENT’S ANNUAL REPORT ON 
  INTERNAL CONTROL OVER FINANCIAL 
  REPORTING

FORWARD-LOOKING STATEMENTS

REPORT OF INDEPENDENT REGISTERED 
  PUBLIC ACCOUNTING FIRM

FINANCIAL STATEMENTS AND NOTES 
  TABLE OF CONTENTS

CONSOLIDATED FINANCIAL STATEMENTS

NOTES TO CONSOLIDATED FINANCIAL 
  STATEMENTS

FINANCIAL DATA SUPPLEMENT

SUPERVISION, REGULATION AND OTHER

CORPORATE INFORMATION

Executive Officers

Citigroup Board of Directors

4

6

6

10

12
13
14
16
18
20
22
27

28

29

30

46

57

58

112

116

117

118

119

123

124

132

293

294

298

298

299

3

OVERVIEW

Citigroup’s history dates back to the founding of the City
Bank of New York in 1812.

Citigroup is a global diversified financial services holding 

company whose businesses provide consumers, corporations, 
governments and institutions with a broad, yet focused, range 
of financial products and services, including consumer 
banking and credit, corporate and investment banking, 
securities brokerage, trade and securities services and wealth 
management. Citi has approximately 200 million customer 
accounts and does business in more than 160 countries and 
jurisdictions.

At December 31, 2019, Citi had approximately 200,000 

full-time employees, compared to approximately 204,000 full-
time employees at December 31, 2018.

Citigroup currently operates, for management reporting 

purposes, via two primary business segments: Global 
Consumer Banking (GCB) and Institutional Clients Group 
(ICG), with the remaining operations in Corporate/Other. For 
a further description of the business segments and the products 
and services they provide, see “Citigroup Segments” below, 
“Management’s Discussion and Analysis of Financial 
Condition and Results of Operations” and Note 3 to the 
Consolidated Financial Statements.

Throughout this report, “Citigroup,” “Citi” and “the 

Company” refer to Citigroup Inc. and its consolidated 
subsidiaries.

Additional information about Citigroup is available on 

Citi’s website at www.citigroup.com. Citigroup’s recent 
annual reports on Form 10-K, quarterly reports on Form 10-Q 
and proxy statements, as well as other filings with the U.S. 
Securities and Exchange Commission (SEC), are available 
free of charge through Citi’s website by clicking on the 
“Investors” tab and selecting “SEC Filings,” then “Citigroup 
Inc.” The SEC’s website also contains current reports on Form 
8-K and other information regarding Citi at www.sec.gov. 

For a discussion of 2018 versus 2017 results of operations 

of GCB in North America, Latin America and Asia, ICG and 
Corporate/Other, see each respective business’s results of 
operation in Citi’s 2018 Annual Report on Form 10-K.

Certain reclassifications, including a realignment of 
certain businesses, have been made to the prior periods’ 
financial statements and disclosures to conform to the current 
period’s presentation. For additional information on certain 
recent reclassifications, see Note 3 to the Consolidated 
Financial Statements.

Please see “Risk Factors” below for a discussion of the 
most significant risks and uncertainties that could impact 
Citigroup’s businesses, financial condition and results of 
operations.

4

As described above, Citigroup is managed pursuant to two business segments: Global Consumer Banking and Institutional 
Clients Group, with the remaining operations in Corporate/Other.

The following are the four regions in which Citigroup operates. The regional results are fully reflected in the segment results 
above.

(1)  Latin America GCB consists of Citi’s consumer banking business in Mexico.
(2)  Asia GCB includes the results of operations of GCB activities in certain EMEA countries for all periods presented.
(3)  North America includes the U.S., Canada and Puerto Rico, Latin America includes Mexico and Asia includes Japan. 
Note:  As of the fourth quarter of 2019, Citi’s commercial banking businesses previously reported as part of GCB in North America, Latin America and Asia, including 
approximately $28 billion in end-of-period loans and approximately $37 billion in end-of-period deposits, are reported in ICG for all periods presented. 

5

 
MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION 
AND RESULTS OF OPERATIONS

EXECUTIVE SUMMARY 
As described further throughout this Executive Summary, 
Citi’s 2019 results reflected steady progress toward improving 
its profitability and returns, despite an uncertain revenue 
environment, as strong client engagement drove balanced 
growth across businesses and geographies:

•  Citi had solid underlying revenue growth in every region 
in Global Consumer Banking (GCB), excluding the 
impact of foreign currency translation into U.S. dollars for 
reporting purposes (FX translation), as well as pretax 
gains on sale in 2018 of approximately $150 million on 
the Hilton portfolio in North America GCB and 
approximately $250 million on an asset management 
business in Latin America GCB.

•  Citi had balanced performance across the Institutional 
Clients Group (ICG), with solid results in fixed income 
markets, treasury and trade solutions, investment banking 
and the private bank, while equity markets revenues were 
negatively impacted by a challenging environment.
•  Citi demonstrated strong expense discipline, resulting in 

expenses that were largely unchanged from the prior year, 
as well as positive operating leverage, even as Citi 
continued to make investments in the franchise. Citi’s 
positive operating leverage and continued credit discipline 
resulted in an improvement in pretax earnings.

•  Citi reported broad-based loan and deposit growth across 

GCB and ICG.

•  Citi returned $22.3 billion of capital to its shareholders in 
the form of common stock repurchases and dividends; 
Citi repurchased approximately 264 million common 
shares, contributing to a 9% reduction in average 
outstanding common shares from the prior year. 
•  Despite continued progress in capital returns to 

shareholders, Citi’s key regulatory capital metrics 
remained strong.

While global growth has continued and the underlying 

macroeconomic environment remains largely positive, 
economic forecasts for 2020 have been lowered and various 
economic, political and other risks and uncertainties could 
create a more volatile operating environment and impact Citi’s 
businesses and future results. For a discussion of risks and 
uncertainties that could impact Citi’s businesses, results of 
operations and financial condition during 2020, see each 
respective business’s results of operations, “Risk Factors” and 
“Managing Global Risk” below. Despite these risks and 
uncertainties, Citi intends to continue to build on the progress 
made during 2019 with a focus on further optimizing its 
performance to benefit shareholders, while remaining flexible 
and adapting to market and economic conditions as they 
develop.

2019 Results Summary

Citigroup
Citigroup reported net income of $19.4 billion, or $8.04 per 
share, compared to net income of $18.0 billion, or $6.68 per 
share, in the prior year. Net income increased 8%, primarily 
driven by a lower effective tax rate and higher revenues, 
partially offset by higher cost of credit, while expenses were 
largely unchanged. Earnings per share increased 20%, driven 
by higher net income and the 9% reduction in average shares 
outstanding due to the common stock repurchases. Results in 
2019 included a net tax benefit of approximately $0.35 per 
share related to discrete tax items, including an approximate 
$0.6 billion benefit from reductions in Citi’s valuation 
allowance related to its deferred tax assets, primarily recorded 
in Corporate/Other (see “Significant Accounting Policies and 
Significant Estimates—Income Taxes” below).

Citigroup revenues of $74.3 billion increased 2%, or 4% 

excluding the impact of FX translation and the gains on sale in 
the prior year (see “Executive Summary” above), reflecting 
higher revenues across GCB and ICG, partially offset by lower 
revenues in Corporate/Other.

Citigroup’s end-of-period loans increased 2% to $699 
billion. Excluding the impact of FX translation, Citigroup end-
of-period loans also grew 2%, as 3% aggregate growth in GCB 
and ICG was partially offset by the continued wind-down of 
legacy assets in Corporate/Other. Citigroup’s end-of-period 
deposits increased 6% to $1.1 trillion. Excluding the impact of 
FX translation, Citigroup’s end-of-period deposits also grew 
6%, primarily driven by 7% growth in GCB and 6% growth in 
ICG, excluding the impact of FX translation. (Citi’s results of 
operations excluding the gains on sale as well as the impact of 
FX translation are non-GAAP financial measures. Citi 
believes the presentation of its results of operations excluding 
the impact of FX translation and gains on sale provides a 
meaningful depiction for investors of the underlying 
fundamentals of its businesses.)

Expenses
Citigroup operating expenses of $42.0 billion were largely 
unchanged, as efficiency savings and the wind-down of legacy 
assets offset volume-driven growth and continued investments 
in the franchise. Operating expenses in GCB and Corporate/
Other were down 1% and 5%, respectively, while ICG 
operating expenses increased 2%. 

Cost of Credit
Citi’s total provisions for credit losses and for benefits and 
claims of $8.4 billion increased 11%. The increase was 
primarily driven by higher net credit losses in both Citi-
branded cards and Citi retail services in North America GCB, 
as well as higher overall cost of credit in ICG.

Net credit losses of $7.8 billion increased 9%. Consumer 

net credit losses of $7.4 billion increased 7%, primarily 
reflecting volume growth and seasoning in the North America 
cards portfolios. Corporate net credit losses increased to $392 

6

million from $205 million in the prior year, reflecting a 
normalization in credit trends.

For additional information on Citi’s consumer and 
corporate credit costs and allowance for loan losses, see each 
respective business’s results of operations and “Credit Risk” 
below.

Capital
Citigroup’s Common Equity Tier 1 (CET1) Capital ratio was 
11.8% as of December 31, 2019, compared to 11.9% as of 
December 31, 2018, based on the Basel III Standardized 
Approach for determining risk-weighted assets. The decline in 
the ratio primarily reflected the return of capital to common 
shareholders, partially offset by net income and a reduction in 
risk-weighted assets. Citigroup’s Supplementary Leverage 
ratio as of December 31, 2019 was 6.2%, compared to 6.4% as 
of December 31, 2018. For additional information on Citi’s 
capital ratios and related components, see “Capital Resources” 
below.

Global Consumer Banking
GCB net income of $5.7 billion increased 7%. Excluding the 
impact of FX translation, net income increased 8%, driven by 
higher revenues, partially offset by higher cost of credit. GCB 
operating expenses of $17.6 billion decreased 1%. Excluding 
the impact of FX translation, expenses were largely 
unchanged, as efficiency savings offset continued investments 
in the franchise and volume-driven growth.

GCB revenues of $33.0 billion increased 2%. Excluding 

the impact of FX translation and the gains on sale in both 
North America GCB and Latin America GCB in the prior year, 
revenues increased 4%, driven by growth in all three regions. 
North America GCB revenues of $20.4 billion increased 3%, 
and 4% excluding the gain on sale in the prior year, primarily 
driven by growth in Citi-branded cards and Citi retail services, 
partially offset by lower retail banking revenues. In North 
America GCB, Citi-branded cards revenues of $9.2 billion 
increased 6%, and 8% excluding the gain on sale in the prior 
year, primarily reflecting volume growth and spread 
expansion. Citi retail services revenues of $6.7 billion 
increased 2%, primarily driven by organic loan growth and the 
full-year benefit of the L.L.Bean acquisition. Retail banking 
revenues of $4.5 billion decreased 2%, as the benefit of 
stronger deposit volumes was more than offset by lower 
deposit spreads.

North America GCB average deposits of $153 billion 
increased 3%, average retail banking loans of $49 billion 
increased 3% and assets under management of $72 billion 
grew 20% (including the benefit of market movements). 
Average Citi-branded card loans of $90 billion increased 3%, 
while Citi-branded card purchase sales of $368 billion 
increased 7%. Average Citi retail services loans of $50 billion 
increased 3%, while Citi retail services purchase sales of $88 
billion increased 2%. For additional information on the results 
of operations of North America GCB in 2019, see “Global 
Consumer Banking—North America GCB” below.

International GCB revenues (consisting of Latin America 
GCB and Asia GCB (which includes the results of operations 
in certain EMEA countries)), of $12.6 billion increased 1%. 

7

Excluding the impact of FX translation and the gain on sale in 
Latin America GCB in the prior year, international GCB 
revenues increased 4%. On this basis, Latin America GCB 
revenues increased 4%, primarily driven by an increase in 
cards revenues and improved deposit spreads. Asia GCB 
revenues increased 4%, primarily reflecting higher deposit, 
investment and cards revenues. For additional information on 
the results of operations of Latin America GCB and Asia GCB 
in 2019, including the impact of FX translation, see “Global 
Consumer Banking—Latin America GCB” and “Global 
Consumer Banking—Asia GCB” below.

Year-over-year, excluding the impact of FX translation, 
international GCB average deposits of $124 billion increased 
5%, average retail banking loans of $71 billion increased 4%, 
assets under management of $104 billion increased 16%
(including the benefit of market movements), average card 
loans of $25 billion increased 3% and card purchase sales of 
$108 billion increased 6%.

Institutional Clients Group
ICG net income of $12.9 billion increased 3%, primarily 
driven by higher revenues and a lower effective tax rate, 
partially offset by higher expenses and cost of credit. ICG 
operating expenses increased 2% to $22.2 billion, primarily 
driven by higher compensation costs, investments and 
volume-driven growth, partially offset by efficiency savings.
ICG revenues of $39.3 billion increased 3%, reflecting a 

1% increase in Banking revenues and a 5% increase in 
Markets and securities services revenues. The increase in 
Banking revenues included the impact of $432 million of 
losses on loan hedges within corporate lending, compared to 
gains of $45 million in the prior year.

Banking revenues of $21.9 billion (excluding the impact 

of gains (losses) on loan hedges within corporate lending) 
increased 3%, driven by solid growth in treasury and trade 
solutions, investment banking and the private bank. 
Investment banking revenues of $5.2 billion increased 4%, as 
strength in debt underwriting was partially offset by lower 
revenues in both equity underwriting and advisory. Advisory 
revenues decreased 3% to $1.3 billion, equity underwriting 
revenues decreased 2% to $973 million and debt underwriting 
revenues increased 10% to $3.0 billion.

 Treasury and trade solutions revenues of $10.3 billion 
increased 4%, and 6% excluding the impact of FX translation, 
reflecting strong client engagement and volume growth, 
partially offset by the impact of lower interest rates. Private 
bank revenues of $3.5 billion increased 2%, driven by higher 
lending and deposit volumes as well as higher investment 
activity, partially offset by spread compression. Corporate 
lending revenues declined 16% to $2.5 billion. Excluding the 
impact of gains (losses) on loan hedges, corporate lending 
revenues were largely unchanged, as growth in the 
commercial loan portfolio was offset by lower volumes in the 
rest of the portfolio.

Markets and securities services revenues of $17.8 billion 
increased 5%, including a pretax gain of approximately $350 
million on Citi’s investment in Tradeweb in the second quarter 
of 2019, recorded in fixed income markets. Fixed income 
markets revenues of $12.9 billion increased 10%, reflecting 

growth across rates and currencies as well as spread products, 
including the Tradeweb gain. Equity markets revenues of $2.9 
billion decreased 15%, primarily driven by lower revenues 
across cash equities, derivatives and prime finance. Securities 
services revenues of $2.6 billion were largely unchanged, but 
increased 4% excluding the impact of FX translation, 
reflecting higher net interest revenue due to higher deposits 
and higher interest rates, particularly in emerging markets, as 
well as higher client volumes. For additional information on 
the results of operations of ICG in 2019, see “Institutional 
Clients Group” below.

Corporate/Other
Corporate/Other net income was $801 million, compared to 
$186 million in the prior year, primarily reflecting the benefit 
of discrete tax items. Operating expenses of $2.2 billion 
decreased 5%, as the continued wind-down of legacy assets 
more than offset higher infrastructure costs. Corporate/Other 
revenues of $2.0 billion decreased 8%, primarily driven by the 
continued wind-down of legacy assets, partially offset by 
gains on investments. For additional information on the results 
of operations of Corporate/Other in 2019, see “Corporate/
Other” below.

8

This page intentionally left blank. 

9

RESULTS OF OPERATIONS

SUMMARY OF SELECTED FINANCIAL DATA—PAGE 1

In millions of dollars, except per share amounts

2019

2018

2017

2016

2015

Citigroup Inc. and Consolidated Subsidiaries

Net interest revenue

Non-interest revenue

Revenues, net of interest expense

Operating expenses

Provisions for credit losses and for benefits and claims

Income from continuing operations before income taxes
Income taxes(1)
Income (loss) from continuing operations

Income (loss) from discontinued operations, net of taxes
Net income (loss) before attribution of noncontrolling
interests

Net income attributable to noncontrolling interests
Citigroup’s net income (loss)(1)

Earnings per share

Basic

Income (loss) from continuing operations

Net income (loss)

Diluted

Income (loss) from continuing operations

Net income (loss)

Dividends declared per common share

Common dividends

Preferred dividends

Common share repurchases

$

$

$

$

$

$

$

$

$

47,347 $

46,562 $

45,061 $

45,476 $

26,939

26,292

27,383

25,321

74,286 $

72,854 $

72,444 $

70,797 $

42,002

8,383

41,841

7,568

42,232

7,451

42,338

6,982

23,901 $

23,445 $

22,761 $

21,477 $

4,430

5,357

29,388

6,444

19,471 $

18,088 $

(6,627) $

15,033 $

47,093

30,184

77,277

44,538

7,913

24,826

7,440

17,386

(4)

(8)

(111)

(58)

(54)

19,467 $

18,080 $

(6,738) $

14,975 $

17,332

66

35

60

63

90

19,401 $

18,045 $

(6,798) $

14,912 $

17,242

8.08 $

8.08

6.69 $

6.69

(2.94) $

(2.98)

4.74 $

4.72

8.04 $

6.69 $

(2.94) $

4.74 $

8.04

1.92

6.68

1.54

(2.98)

0.96

4.72

0.42

4,403 $

3,865 $

2,595 $

1,214 $

1,109

17,875

1,174

14,545

1,213

14,538

1,077

9,451

5.43

5.41

5.42

5.40

0.16

484

769

5,452

Table continues on the next page, including footnotes.

10

SUMMARY OF SELECTED FINANCIAL DATA—PAGE 2

Citigroup Inc. and Consolidated Subsidiaries

In millions of dollars, except per share amounts, ratios and direct staff

2019

2018

2017

2016

2015

At December 31:

Total assets

Total deposits

Long-term debt
Citigroup common stockholders’ equity(1)
Total Citigroup stockholders’ equity(1)
Average assets

Direct staff (in thousands)

Performance metrics

Return on average assets
Return on average common stockholders’ equity(1)(2)
Return on average total stockholders’ equity(1)(2)
Return on tangible common equity (RoTCE)(1)(3)
Efficiency ratio (total operating expenses/total revenues)
Basel III ratios(1)(4)
Common Equity Tier 1 Capital(5)
Tier 1 Capital(5)
Total Capital(5)
Supplementary Leverage ratio
Citigroup common stockholders’ equity to assets(1)
Total Citigroup stockholders’ equity to assets(1)
Dividend payout ratio(6)
Total payout ratio(7)
Book value per common share(1)
Tangible book value (TBV) per share(1)(3)

$ 1,951,158

$

1,917,383

$ 1,842,465

$

1,792,077

$

1,731,210

1,070,590

1,013,170

248,760

175,262

193,242

231,999

177,760

196,220

959,822

236,709

181,487

200,740

929,406

206,178

205,867

225,120

907,887

201,275

205,139

221,857

1,978,805

1,920,242

1,875,438

1,808,728

1,823,875

200

204

209

219

231

0.98%

0.94%

(0.36)%

0.82%

0.95%

10.3

9.9

12.1

56.5

9.4

9.1

11.0

57.4

(3.9)

(3.0)

8.1

58.3

6.6

6.5

7.6

59.8

8.1

7.9

9.3

57.6

11.81%

11.86%

12.36 %

12.57%

12.07%

13.36

15.97

6.21

13.46

16.18

6.41

8.98%

9.27%

9.90

23.9

121.8

82.90

70.39

$

10.23

23.1

109.1

$

75.05

$

63.79

14.06

16.30

6.68

9.85 %

10.90

         NM

         NM

70.62

60.16

14.24

16.24

7.22

13.49

15.30

7.08

11.49%

11.85%

12.56

8.9

77.1

$

74.26

$

64.57

12.82

3.0

36.0

69.46

60.61

(1)  2017 includes the one-time impact related to enactment of the Tax Cuts and Jobs Act (Tax Reform). 2019 and 2018 reflect the tax rate structure post Tax Reform. 

For additional information, see “Significant Accounting Policies and Significant Estimates—Income Taxes” below. RoTCE for 2017 excludes the one-time impact 
from Tax Reform. 

(2)  The return on average common stockholders’ equity is calculated using net income less preferred stock dividends divided by average common stockholders’ 

equity. The return on average total Citigroup stockholders’ equity is calculated using net income divided by average Citigroup stockholders’ equity.

(3)  For information on RoTCE and TBV, see “Capital Resources—Tangible Common Equity, Book Value Per Share, Tangible Book Value Per Share and Returns on 

Equity” below.

(4)  Citi’s risk-based capital and leverage ratios for 2017 and prior years are non-GAAP financial measures, which reflect full implementation of regulatory capital 

adjustments and deductions prior to the effective date of January 1, 2018.

(5)  As of December 31, 2019, 2018, and 2017, Citi’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the Basel III 
Standardized Approach, whereas the reportable Total Capital ratio was the lower derived under the Basel III Advanced Approaches framework. For all prior 
periods presented, Citi’s Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios were the lower derived under the Basel III Advanced Approaches 
framework.

(6)  Dividends declared per common share as a percentage of net income per diluted share.
(7)  Total common dividends declared plus common stock repurchases as a percentage of net income available to common shareholders (Net income, less preferred 

dividends). See “Consolidated Statement of Changes in Stockholders’ Equity,” Note 10 to the Consolidated Financial Statements and “Equity Security 
Repurchases” below for the component details. 

NM  Not meaningful

11

SEGMENT AND BUSINESS—INCOME (LOSS) AND REVENUES

CITIGROUP INCOME

In millions of dollars

Income (loss) from continuing operations

Global Consumer Banking

  North America

  Latin America
  Asia(2)
Total

Institutional Clients Group

  North America

  EMEA

  Latin America

  Asia

Total

Corporate/Other

Income (loss) from continuing operations

Discontinued operations

Less: net income attributable to noncontrolling interests

Citigroup’s net income (loss)

2019

2018

2017(1)

% Change 
 2019 vs. 2018

% Change 
 2018 vs. 2017

$

$

$

$

$

$

$

3,224 $

3,087 $

901

1,577

802

1,420

5,702 $

5,309 $

3,511 $

3,675 $

3,867

2,111

3,455

3,889

2,013

2,997

12,944 $

12,574 $

825

205

19,471 $

18,088 $

(4) $

66

(8) $

35

1,829

516

1,197

3,542

2,494

2,828

1,637

2,416

9,375

(19,544)

(6,627)

(111)

60

19,401 $

18,045 $

(6,798)

4 %

12

11

7 %

(4)%

(1)

5

15

3 %

NM

8 %

50 %

89

8 %

69%

55

19

50%

47%

38

23

24

34%

NM

NM

93%

(42)

NM

(1)  2017 includes the one-time impact related to enactment of Tax Reform. For additional information, see “Significant Accounting Policies and Significant Estimates

—Income Taxes” below.

(2)  Asia GCB includes the results of operations of GCB activities in certain EMEA countries for all periods presented.
NM Not meaningful

CITIGROUP REVENUES

In millions of dollars

Global Consumer Banking

  North America

  Latin America
  Asia(1)
Total

Institutional Clients Group

  North America

  EMEA

  Latin America

  Asia

Total
Corporate/Other

Total Citigroup net revenues

2019

2018

2017

% Change 
 2019 vs. 2018

% Change 
 2018 vs. 2017

$

$

$

$

$

20,398 $

19,829 $

5,238

7,335

5,309

7,201

32,971 $

32,339 $

13,459 $

13,522 $

12,006

5,166

8,670

39,301 $
2,014

74,286 $

11,770

4,954

8,079

38,325 $
2,190

72,854 $

19,570

4,794

7,081

31,445

14,578

10,878

4,814

7,552

37,822
3,177

72,444

3 %

(1)

2

2 %

— %

2

4

7

3 %
(8)

2 %

1 %

11

2

3 %

(7)%

8

3

7

1 %

(31)

1 %

(1)  Asia GCB includes the results of operations of GCB activities in certain EMEA countries for all periods presented.

12

SEGMENT BALANCE SHEET(1)—DECEMBER 31, 2019

Citigroup
parent
company-
issued
long-term
debt and
stockholders’
equity(3)

Corporate/
Other
and
consolidating
eliminations(2)

Total
Citigroup
consolidated

Global
Consumer
Banking

Institutional
Clients
Group

$

7,076 $

69,363 $

117,480 $

— $

87

1,168

1,150

290,270

39,071

68,077

250,968

265,260

126,481

387,036

94,648

253,463

267

9,712

240,932

9,394

40,795

(321,540)

—

—

—

—

—

—

193,919

251,322

276,140

368,563

686,700

174,514

—

$

$

$

$

406,899 $

1,447,219 $

97,040 $

— $

1,951,158

291,049 $

767,666 $

11,875 $

— $

1,070,590

2,229

549

417

1,472

20,847

90,336

164,096

118,788

27,082

64,758

71,215

233,614

14

557

17,550

32,053

14,518

19,769

—

—

—

150,477

—

(343,719)

406,899 $

1,447,219 $

96,336 $

(193,242) $

—

—

704

193,242

406,899 $

1,447,219 $

97,040 $

— $

166,339

119,894

45,049

248,760

106,580

—

1,757,212

193,946

1,951,158

In millions of dollars

Assets

Cash and deposits with banks
Securities borrowed and purchased under
agreements to resell

Trading account assets

Investments

Loans, net of unearned income and allowance
for loan losses

Other assets
Net inter-segment liquid assets(4)

Total assets

Liabilities and equity

Total deposits
Securities loaned and sold under agreements
to repurchase

Trading account liabilities

Short-term borrowings
Long-term debt(3)
Other liabilities
Net inter-segment funding (lending)(3)

Total liabilities
Total stockholders’ equity(5)
Total liabilities and equity

(1)  The supplemental information presented in the table above reflects Citigroup’s consolidated GAAP balance sheet by reporting segment. The respective segment 

information depicts the assets and liabilities managed by each segment. 

(2)  Consolidating eliminations for total Citigroup and Citigroup parent company assets and liabilities are recorded within Corporate/Other. 
(3)  Total stockholders’ equity and the majority of long-term debt of Citigroup reside on the Citigroup parent company balance sheet. Citigroup allocates stockholders’ 

equity and long-term debt to its businesses through inter-segment allocations as shown above.

(4)  Represents the attribution of Citigroup’s liquid assets (primarily consisting of cash, marketable equity securities and available-for-sale debt securities) to the 

various businesses based on Liquidity Coverage Ratio (LCR) assumptions.

(5)  Corporate/Other equity represents noncontrolling interests.

13

 
 
 
 
 
 
 
 
 
GLOBAL CONSUMER BANKING

Global Consumer Banking (GCB) consists of consumer banking businesses in North America, Latin America (consisting of Citi’s 
consumer banking business in Mexico) and Asia. GCB provides traditional banking services to retail customers through retail banking, 
Citi-branded cards and Citi retail services (for additional information on these businesses, see “Citigroup Segments” above). GCB is 
focused on its priority markets in the U.S., Mexico and Asia with 2,348 branches in 19 countries and jurisdictions as of December 31, 
2019. At December 31, 2019, GCB had approximately $407 billion in assets and $291 billion in deposits.

GCB’s overall strategy is to leverage Citi’s global footprint and be the pre-eminent bank for the affluent and emerging affluent 

consumers in large urban centers. In credit cards and in certain retail markets, Citi serves customers in a somewhat broader set of 
segments and geographies.

In millions of dollars, except as otherwise noted

2019

2018

2017

% Change 
 2019 vs. 2018

% Change 
 2018 vs. 2017

Net interest revenue

Non-interest revenue

Total revenues, net of interest expense

Total operating expenses

Net credit losses

Credit reserve build

Provision for unfunded lending commitments

Provision for benefits and claims
Provisions for credit losses and for benefits and claims 
  (LLR & PBC)

Income from continuing operations before taxes

Income taxes

Income from continuing operations

Noncontrolling interests

Net income

Balance Sheet data and ratios (in billions of dollars)

Total EOP assets

Average assets

Return on average assets

Efficiency ratio

Average deposits

Net credit losses as a percentage of average loans

Revenue by business

Retail banking
Cards(1)
Total

Income from continuing operations by business

Retail banking
Cards(1)
Total

$

$

$

$

$

$

$

$

$

$

$

$

$

$

28,205

4,766

32,971

17,628

7,382

439

1

73

7,895

7,448

1,746

5,702

6

5,696

407

389

1.46%

53

277

2.60%

12,549

20,422

32,971

1,842

3,860

5,702

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

27,374

4,965

32,339

17,786

6,884

568

—

103

7,555

6,998

1,689

5,309

7

5,302

388

378

1.40%

55

269

$

2.48%

12,627

19,712

32,339

1,851

3,458

5,309

$

$

$

$

26,277

5,168

31,445

17,229

6,462

1,029

—

116

7,607

6,609

3,067

3,542

9

3,533

389

380

0.93%

55

267

2.39%

12,089

19,356

31,445

1,320

2,222

3,542

3 %

(4)

2 %

(1)%

7 %

(23)

100

(29)

5 %

6 %

3

7 %

(14)

7 %

5 %

3

3

(1)%

4

2 %

— %

12

7 %

Table continues on the next page, including footnotes.

4 %

(4)

3 %

3 %

7 %

(45)

—

(11)

(1)%

6 %

(45)

50 %

(22)

50 %

— %

(1)

1

4 %

2

3 %

40 %

56

50 %

14

Foreign currency (FX) translation impact

Total revenue—as reported

Impact of FX translation(2)

Total revenues—ex-FX(3)
Total operating expenses—as reported

Impact of FX translation(2)

Total operating expenses—ex-FX(3)
Total provisions for LLR & PBC—as reported

Impact of FX translation(2)

Total provisions for LLR & PBC—ex-FX(3)
Net income—as reported

Impact of FX translation(2)

Net income—ex-FX(3)

$

$

$

$

$

$

$

$

32,971 $

32,339 $

—

32,971 $

17,628 $

—

17,628 $

7,895 $

—

7,895 $

5,696 $

—

5,696 $

(146)

32,193 $

17,786 $

(100)

17,686 $

7,555 $

(24)

7,531 $

5,302 $

(16)

5,286 $

31,445

(270)

31,175

17,229

(154)

17,075

7,607

(53)

7,554

3,533

(42)

3,491

2 %

2 %

(1)%

— %

5 %

5 %

7 %

8 %

3 %

3 %

3 %

4 %

(1)%

— %

50 %

51 %

Includes both Citi-branded cards and Citi retail services.

(1) 
(2)  Reflects the impact of FX translation into U.S. dollars at the 2019 average exchange rates for all periods presented.
(3)  Presentation of this metric excluding FX translation is a non-GAAP financial measure.
Note:  For information on the impact of Citi’s January 1, 2020 adoption of the new accounting standard on credit losses (CECL), see “Risk Factors—Operational Risks” 
below and Note 1 to the Consolidated Financial Statements.

15

 
NORTH AMERICA GCB

North America GCB provides traditional retail banking and Citi-branded and Citi retail services card products to retail and small 
business customers in the U.S. North America GCB’s U.S. cards product portfolio includes its proprietary portfolio (including the Citi 
Double Cash, Thank You and Value cards) and co-branded cards (including, among others, American Airlines and Costco) within Citi-
branded cards as well as its co-brand and private label relationships (including, among others, Sears, The Home Depot, Best Buy and 
Macy’s) within Citi retail services. 

At December 31, 2019, North America GCB had 687 retail bank branches concentrated in the six key metropolitan areas of New 

York, Chicago, Miami, Washington, D.C., Los Angeles and San Francisco. Also as of December 31, 2019, North America GCB had 
approximately $50.3 billion in retail banking loans and $160.5 billion in deposits. In addition, North America GCB had approximately 
$149.2 billion in outstanding card loan balances.

In millions of dollars, except as otherwise noted

2019

2018

2017

% Change 
 2019 vs. 2018

% Change 
 2018 vs. 2017

Net interest revenue
Non-interest revenue(1)
Total revenues, net of interest expense

Total operating expenses

Net credit losses

Credit reserve build

Provision for unfunded lending commitments

Provision for benefits and claims

Provisions for credit losses and for benefits and claims

Income from continuing operations before taxes

Income taxes

Income from continuing operations

Noncontrolling interests

Net income

Balance Sheet data and ratios  (in billions of dollars)

Average assets

Return on average assets

Efficiency ratio

Average deposits

Net credit losses as a percentage of average loans

Revenue by business

Retail banking

Citi-branded cards

Citi retail services

Total

Income from continuing operations by business

Retail banking

Citi-branded cards

Citi retail services

Total

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

19,869

529

20,398

10,154

5,583

469

1

19

6,072

4,172

948

3,224

—

3,224

232

1.39%

50

$

$

$

$

$

$

$

$

$

19,006

823

19,829

10,230

5,085

460

—

22

5,567

4,032

945

3,087

—

3,087

227

1.36%

52

152.8

$

148.0

$

18,298

1,272

19,570

9,867

4,737

926

—

33

5,696

4,007

2,178

1,829

(1)

1,830

232

0.79%

50

151.0

2.97%

2.78%

2.67%

4,529

9,165

6,704

20,398

196

1,742

1,286

3,224

$

$

$

$

4,600

$

8,628

6,601

19,829

312

1,581

1,194

$

$

3,087

$

4,565

8,578

6,427

19,570

251

1,009

569

1,829

5 %

(36)

3 %

(1)%

10 %

2

100

(14)

9 %

3 %

—

4 %

—

4 %

4 %

(35)

1 %

4 %

7 %

(50)

—

(33)

(2)%

1 %

(57)

69 %

100

69 %

2 %

(2)%

3

(2)

(2)%

6

2

3 %

(37)%

10

8

4 %

1 %

1

3

1 %

24 %

57

NM

69 %

(1)  2018 includes an approximate $150 million gain on the Hilton portfolio sale. 
NM  Not meaningful

16

 
 
 
 
 
 
2019 vs. 2018 
Net income increased 4%, as higher revenues and lower 
expenses were partially offset by higher cost of credit.

Revenues increased 3%. Excluding the impact of the $150 

million gain on the Hilton portfolio sale in the prior year, 
revenues increased 4%, reflecting higher revenues in Citi-
branded cards and Citi retail services, partially offset by lower 
retail banking revenues.

Retail banking revenues decreased 2%, as the benefit of 

stronger deposit volumes was more than offset by lower 
deposit spreads. Average deposits increased 3%. Assets under 
management increased 20%, including the benefit of market 
movements. Citi expects that retail banking revenues will 
likely be impacted by the lower interest rate environment in 
the near term. 

 Cards revenues increased 4% (5% excluding the Hilton 

gain). In Citi-branded cards, revenues increased 6% (8% 
excluding the Hilton gain), primarily driven by volume growth 
and spread expansion. Average loans increased 3% and 
purchase sales increased 7%.

Citi retail services revenues increased 2%, primarily 
driven by organic loan growth and the full-year benefit of the 
L.L.Bean portfolio acquisition. Average loans increased 3% 
and purchase sales increased 2%. 

 Expenses decreased 1%, as efficiency savings more than 

offset ongoing investments and higher volume-related 
expenses.

Provisions increased 9%, primarily driven by higher net 

credit losses. Net credit losses increased 10%, driven by 
higher net credit losses in Citi-branded cards (up 10% to $2.9 
billion) and Citi retail services (up 9% to $2.6 billion). The 
increase in net credit losses reflected volume growth and 
seasoning in both cards portfolios. The net loan loss reserve 
build increased 2%, reflecting volume growth and seasoning 
in both cards portfolios. 

For additional information on North America GCB’s retail 

banking and its Citi-branded cards and Citi retail services 
portfolios, see “Credit Risk—Consumer Credit” below.

For information on the impact of Citi’s January 1, 2020 

adoption of the new accounting standard on credit losses 
(CECL), see “Risk Factors—Operational Risks” below and 
Note 1 to the Consolidated Financial Statements.

As previously disclosed, Sears has continued to close 
stores since it exited bankruptcy. Although Citi retail services 
will continue to be impacted from reduced new account 
acquisitions and lower purchase sales, Citi does not currently 
expect an immediate or ongoing material impact on its 
consolidated results. For additional information on the 
potential impact from a deterioration in or failure to maintain 
Citi’s co-branding and private label credit card relationships, 
see “Risk Factors—Strategic Risks” below.

17

LATIN AMERICA GCB

Latin America GCB provides traditional retail banking and Citi-branded card products to retail and small business customers in 
Mexico through Citibanamex, one of Mexico’s largest banks. 

At December 31, 2019, Latin America GCB had 1,419 retail branches in Mexico, with approximately $11.7 billion in retail 
banking loans and $23.8 billion in deposits. In addition, the business had approximately $6.0 billion in outstanding card loan balances.

In millions of dollars, except as otherwise noted
Net interest revenue
Non-interest revenue(1)
Total revenues, net of interest expense
Total operating expenses
Net credit losses
Credit reserve build
Provision for unfunded lending commitments
Provision for benefits and claims

Provisions for credit losses and for benefits and claims (LLR &
PBC)
Income from continuing operations before taxes
Income taxes
Income from continuing operations
Noncontrolling interests
Net income
Balance Sheet data and ratios (in billions of dollars)
Average assets
Return on average assets
Efficiency ratio
Average deposits
Net credit losses as a percentage of average loans
Revenue by business
Retail banking
Citi-branded cards
Total
Income from continuing operations by business
Retail banking
Citi-branded cards
Total
FX translation impact
Total revenues—as reported(1)
Impact of FX translation(2)

Total revenues—ex-FX(3)
Total operating expenses—as reported

Impact of FX translation(2)

Total operating expenses—ex-FX(3)
Provisions for LLR & PBC—as reported

Impact of FX translation(2)

Provisions for LLR & PBC—ex-FX(3)
Net income—as reported

Impact of FX translation(2)

Net income—ex-FX(3)

$

$
$
$

$
$

$

$

$

$

$

$

$

$

$

$
$

$
$

$
$

$

2019

2018

2017

3,639
1,599
5,238
2,883
1,109
(38)
—
54

1,125
1,230
329
901
—
901

35
2.57%
55
22.8
6.45%

3,585
1,653
5,238

600
301
901

5,238
—
5,238
2,883
—
2,883
1,125
—
1,125
901
—
901

$

$
$
$

$
$

$

$

$

$

$

$

$

$

$

$
$

$
$

$
$

$

3,681
1,628
5,309
2,900
1,131
84
—
81

1,296
1,113
311
802
—
802

33
2.43%
55
22.7
6.50%

3,744
1,565
5,309

596
206
802

5,309
(23)
5,286
2,900
(13)
2,887
1,296
(6)
1,290
802
(3)
799

$

$
$
$

$
$

$

$

$

$

$

$

$

$

$

$
$

$
$

$
$

$

3,491
1,303
4,794
2,721
1,083
113
—
83

1,279
794
278
516
5
511

35
1.46%
57
21.8
6.08%

3,324
1,470
4,794

332
184
516

4,794
(117)
4,677
2,721
(59)
2,662
1,279
(32)
1,247
511
(19)
492

% Change 
 2019 vs. 2018
(1)%
(2)
(1)%
(1)%
(2)%
NM
—
(33)

(13)%
11 %
6
12 %
—
12 %

% Change 
 2018 vs. 2017
5 %
25
11 %
7 %
4 %

(26)
—
(2)

1 %
40 %
12
55 %

(100)

57 %

6 %

(6)%

—

4

(4)%
6
(1)%

1 %
46
12 %

(1)%

(1)%
(1)%

— %
(13)%

(13)%
12 %

13 %

13 %
6
11 %

80 %
12
55 %

11 %

13 %
7 %

8 %
1 %

3 %
57 %

62 %

(1)  2018 includes an approximate $250 million gain on the sale of an asset management business. See Note 2 to the Consolidated Financial Statements.
(2)  Reflects the impact of FX translation into U.S. dollars at the 2019 average exchange rates for all periods presented.
(3)  Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM  Not meaningful

18

 
 
 
 
 
 
The discussion of the results of operations for Latin America GCB below excludes the impact of FX translation for all periods 
presented. Presentations of the results of operations, excluding the impact of FX translation, are non-GAAP financial measures. For a 
reconciliation of certain of these metrics to the reported results, see the table above.

2019 vs. 2018 
Net income increased 13%, primarily reflecting lower cost of 
credit, partially offset by lower revenues.

Revenues decreased 1%, including a gain on sale 
(approximately $250 million) of an asset management 
business in the prior year. Excluding the gain on sale, revenues 
increased 4%, reflecting higher revenues in both retail banking 
and cards.

Retail banking revenues decreased 4%. Excluding the 

gain on sale, retail banking revenues increased 3%, as 
improved deposit spreads were partially offset by lower 
average loans (down 3%), reflecting the ongoing slowdown in 
overall economic growth and industry volumes in Mexico. 
Assets under management increased 13%, including the 
benefit of market movements, while average deposits were
largely unchanged, as clients transferred money to 
investments. Cards revenues increased 6%, primarily driven 
by continued volume growth, reflecting higher purchase sales 
(up 7%) and average loans (up 3%), as well as higher rates.

Expenses were largely unchanged, as efficiency savings 

offset ongoing investment spending and volume-driven 
growth.

Provisions decreased 13%, primarily driven by a modest 

net loan loss reserve release (compared to a net loan loss 
reserve build in the prior year) and lower net credit losses, 
reflecting lower volumes in retail banking. 

For additional information on Latin America GCB’s retail 
banking and its Citi-branded cards portfolios, see “Credit Risk
—Consumer Credit” below.

For information on the impact of Citi’s January 1, 2020 

adoption of the new accounting standard on credit losses 
(CECL), see “Risk Factors—Operational Risks” below and 
Note 1 to the Consolidated Financial Statements.

19

ASIA GCB

Asia GCB provides traditional retail banking and Citi-branded card products to retail and small business customers. During 2019, Asia 
GCB’s most significant revenues in Asia were from Hong Kong, Singapore, South Korea, Australia, India, Taiwan, Thailand, 
Philippines, Indonesia and Malaysia. Included within Asia GCB, traditional retail banking and Citi-branded card products are also 
provided to retail customers in certain EMEA countries, primarily Poland, Russia and the United Arab Emirates. 

At December 31, 2019, on a combined basis, the businesses had 242 retail branches, approximately $62.8 billion in retail 
banking loans and $106.7 billion in deposits. In addition, the businesses had approximately $19.9 billion in outstanding card loan 
balances. 

In millions of dollars, except as otherwise noted(1)

2019

2018

2017

% Change 
 2019 vs. 2018

% Change 
 2018 vs. 2017

Net interest revenue

Non-interest revenue

Total revenues, net of interest expense

Total operating expenses

Net credit losses

Credit reserve build (release)

Provision (release) for unfunded lending commitments

Provisions for credit losses

Income from continuing operations before taxes

Income taxes

Income from continuing operations

Noncontrolling interests

Net income

Balance Sheet data and ratios (in billions of dollars)

Average assets

Return on average assets

Efficiency ratio

Average deposits

Net credit losses as a percentage of average loans

Revenue by business

Retail banking

Citi-branded cards

Total

Income from continuing operations by business

Retail banking

Citi-branded cards

Total

FX translation impact

Total revenues—as reported

Impact of FX translation(2)

Total revenues—ex-FX(3)
Total operating expenses—as reported
Impact of FX translation(2)
Total operating expenses—ex-FX(3)
Provisions for credit losses—as reported

Impact of FX translation(2)
Provisions for credit losses—ex-FX(3)
Net income—as reported

Impact of FX translation(2)

Net income—ex-FX(3)

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

4,697

2,638

7,335

4,591

690

8

—

698

2,046

469

1,577

6

1,571

122

1.29%

63

$

$

$

$

$

$

$

$

$

4,687

2,514

7,201

4,656

668

24

—

692

1,853

433

1,420

7

1,413

119

1.19%

65

101.1

$

0.88%

98.0

$

0.86%

4,283

2,918

7,201

943

477

1,420

7,201

(123)

7,078

4,656

(87)

4,569

692

(18)

674

1,413

(13)

1,400

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

4,435

2,900

7,335

1,046

531

1,577

7,335

—

7,335

4,591

—

4,591

698

—

698

1,571

—

1,571

20

4,488

2,593

7,081

4,641

642

(10)

—

632

1,808

611

1,197

5

1,192

114

1.05%

66

94.6

0.85%

4,200

2,881

7,081

737

460

1,197

7,081

(153)

6,928

4,641

(95)

4,546

632

(21)

611

1,192

(23)

1,169

— %

5

2 %

(1)%

3 %

(67)

—

1 %

10 %

8

11 %

(14)

11 %

3 %

3

4 %

(1)

2 %

11 %

11

11 %

2 %

4 %

(1)%

— %

1 %

4 %

11 %

12 %

4%

(3)

2%

—%

4%

NM

—

9%

2%

(29)

19%

40

19%

4%

4

2%

1

2%

28%

4

19%

2%

2%

—%

1%

9%

10%

19%

20%

 
 
(1)  Asia GCB includes the results of operations of GCB activities in certain EMEA countries for all periods presented.
(2)  Reflects the impact of FX translation into U.S. dollars at the 2019 average exchange rates for all periods presented.
(3)  Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM  Not meaningful

The discussion of the results of operations for Asia GCB below excludes the impact of FX translation for all periods presented. 
Presentations of the results of operations, excluding the impact of FX translation, are non-GAAP financial measures. For a 
reconciliation of certain of these metrics to the reported results, see the table above.

2019 vs. 2018 
Net income increased 12%, primarily driven by higher 
revenues, partially offset by modestly higher cost of credit.
Revenues increased 4%, primarily driven by growth in 

retail banking. 

Retail banking revenues increased 5%, primarily driven 

by higher investment revenues due to improved market 
sentiment and higher deposit revenues. Investment sales 
increased 8%, assets under management grew 17%, including 
the benefit of market movements, average deposits increased 
6% and average loans increased 5%. Retail lending revenues 
declined 1%, as continued growth in personal loans was more 
than offset by lower mortgage revenues due to spread 
compression.

Cards revenues increased 1%, including a modest 

episodic gain in the current year, as continued growth in 
average loans (up 3%) and purchase sales (up 6%) was largely 
offset by spread compression.

 Expenses were largely unchanged, as efficiency savings 

were offset by ongoing investment spending and volume-
driven growth.

Provisions increased 4%, as higher net credit losses 
reflecting volume growth and seasoning were partially offset 
by a lower net loan loss reserve build in the current year. 
Overall credit quality remained stable in the region. 

For additional information on Asia GCB’s retail banking 

portfolios and its Citi-branded cards portfolio, see “Credit 
Risk—Consumer Credit” below.

For information on the impact of Citi’s January 1, 2020 

adoption of the new accounting standard on credit losses 
(CECL), see “Risk Factors—Operational Risks” below and 
Note 1 to the Consolidated Financial Statements.

21

significantly impact client activity levels, bid/offer spreads and 
the fair value of product inventory. For example, a decrease in 
market liquidity may increase bid/offer spreads, decrease 
client activity levels and widen credit spreads on product 
inventory positions. 

ICG’s management of the Markets businesses involves 
daily monitoring and evaluation of the above factors at the 
trading desk as well as the country level. ICG does not 
separately track the impact on total Markets revenues of the 
volume of transactions, bid/offer spreads, fair value changes of 
product inventory positions and economic hedges because, as 
noted above, these components are interrelated and are not 
deemed useful or necessary individually to manage the 
Markets businesses at an aggregate level.

In the Markets businesses, client revenues are those 
revenues directly attributable to client transactions at the time 
of inception, including commissions, interest or fees earned. 
Client revenues do not include the results of client facilitation 
activities (e.g., holding product inventory in anticipation of 
client demand) or the results of certain economic hedging 
activities.

ICG’s international presence is supported by trading 
floors in approximately 80 countries and a proprietary network 
in 98 countries and jurisdictions. At December 31, 2019, ICG 
had approximately $1.4 trillion in assets and $768 billion in 
deposits, while two of its businesses—securities services and 
issuer services—managed approximately $20.3 trillion and 
$17.5 trillion in assets under custody as of December 31, 2019 
and 2018, respectively. 

INSTITUTIONAL CLIENTS GROUP

Institutional Clients Group (ICG) includes Banking and 
Markets and securities services (for additional information on 
these businesses, see “Citigroup Segments” above). ICG 
provides corporate, institutional, public sector and high-net-
worth clients around the world with a full range of wholesale 
banking products and services, including fixed income and 
equity sales and trading, foreign exchange, prime brokerage, 
derivative services, equity and fixed income research, 
corporate lending, investment banking and advisory services, 
private banking, cash management, trade finance and 
securities services. ICG transacts with clients in both cash 
instruments and derivatives, including fixed income, foreign 
currency, equity and commodity products.

ICG revenue is generated primarily from fees and spreads 

associated with these activities. ICG earns fee income for 
assisting clients with transactional services and clearing and 
providing brokerage and investment banking services and 
other such activities. Such fees are recognized at the point in 
time when Citigroup’s performance under the terms of a 
contractual arrangement is completed, which is typically at the 
trade/execution date or closing of a transaction. Revenue 
generated from these activities is recorded in Commissions 
and fees and Investment banking. Revenue is also generated 
from assets under custody and administration, which is 
recognized as/when the associated promised service is 
satisfied, which normally occurs at the point in time the 
service is requested by the customer and provided by Citi. 
Revenue generated from these activities is primarily recorded 
in Administration and other fiduciary fees. For additional 
information on these various types of revenues, see Note 5 to 
the Consolidated Financial Statements.

In addition, as a market maker, ICG facilitates 
transactions, including holding product inventory to meet 
client demand, and earns the differential between the price at 
which it buys and sells the products. These price differentials 
and the unrealized gains and losses on the inventory are 
recorded in Principal transactions. Mark-to-market gains and 
losses on certain credit derivatives (used to hedge the 
corporate loan portfolio) are also recorded in Principal 
transactions, (for additional information on Principal 
transactions revenue, see Note 6 to the Consolidated Financial 
Statements). Other primarily includes realized gains and 
losses on available-for-sale (AFS) debt securities, gains and 
losses on equity securities not held in trading accounts and 
other non-recurring gains and losses. Interest income earned 
on assets held, less interest paid on long- and short-term debt 
and to customers on deposits, is recorded as Net interest 
revenue.

The amount and types of Markets revenues are impacted 
by a variety of interrelated factors, including market liquidity; 
changes in market variables such as interest rates, foreign 
exchange rates, equity prices, commodity prices and credit 
spreads, as well as their implied volatilities; investor 
confidence and other macroeconomic conditions. Assuming all 
other market conditions do not change, increases in client 
activity levels or bid/offer spreads generally result in increases 
in revenues. However, changes in market conditions can 

22

 
In millions of dollars, except as otherwise noted

2019

2018

2017

Commissions and fees

Administration and other fiduciary fees

Investment banking

Principal transactions
Other(1)
Total non-interest revenue

Net interest revenue (including dividends)

Total revenues, net of interest expense

Total operating expenses

Net credit losses

Credit reserve build (release)

Provision (release) for unfunded lending commitments

Provisions for credit losses

Income from continuing operations before taxes

Income taxes

Income from continuing operations

Noncontrolling interests

Net income

EOP assets (in billions of dollars)

Average assets (in billions of dollars)

Return on average assets

Efficiency ratio

Revenues by region

North America

EMEA

Latin America

Asia

Total

Income from continuing operations by region

North America

EMEA

Latin America

Asia

Total

Average loans by region (in billions of dollars)

North America

EMEA

Latin America

Asia

Total

EOP deposits by business (in billions of dollars)

Treasury and trade solutions

All other ICG businesses

Total

$

$

$

$

$

$

$

$

$

$

4,462

2,756

4,440

8,562

1,829

22,049

17,252

39,301

22,224

394

71

98

563

16,514

3,570

12,944

40

12,904

1,447

1,493

$

4,651

$

2,806

4,358

8,742

941

21,498

16,827

38,325

21,780

208

(109)

116

215

16,330

3,756

12,574

17

12,557

1,438

1,449

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

4,456

2,721

4,666

7,527

1,711

21,081

16,741

37,822

21,187

465

(285)

(161)

19

16,616

7,241

9,375

57

9,318

1,375

1,395

0.86%

57

0.87%

57

0.67%

56

$

13,459

$

13,522

$

12,006

5,166

8,670

39,301

3,511

3,867

2,111

3,455

12,944

188

87

40

73

388

536

232

768

$

$

$

$

$

$

$

$

$

$

$

$

$

$

11,770

4,954

8,079

38,325

3,675

3,889

2,013

2,997

12,574

174

81

42

77

374

509

218

727

$

$

$

$

$

$

$

14,578

10,878

4,814

7,552

37,822

2,494

2,828

1,637

2,416

9,375

159

69

42

72

342

469

208

677

% Change 
 2019 vs. 2018

% Change 
 2018 vs. 2017

(4)%

4 %

(2)

2

(2)

94

3 %

3

3 %

2 %

89 %

NM

(16)

NM

1 %

(5)

3 %

NM

3 %

1 %

3

3

(7)

16

(45)

2 %

1

1 %

3 %

(55)%

62

NM

NM

(2)%

(48)

34 %

(70)

35 %

5 %

4

— %

(7)%

2

4

7

8

3

7

3 %

1 %

(4)%

47 %

(1)

5

15

3 %

8 %

7

(5)

(5)

4 %

5 %

6

6 %

38

23

24

34 %

9 %

17

—

7

9 %

9 %

5

7 %

(1)  2019 includes an approximate $350 million gain on Citi's investment in Tradeweb in the second quarter. 2017 includes the approximate $580 million gain on the 

sale of a fixed income analytics business.

NM  Not meaningful

23

 
 
ICG Revenue Details

In millions of dollars

Investment banking revenue details

Advisory

Equity underwriting

Debt underwriting

Total investment banking

Treasury and trade solutions
Corporate lending—excluding gains (losses) on loan hedges(1)
Private bank

Total Banking revenues (ex-gains (losses) on 
  loan hedges)
  Corporate lending—gains (losses) on loan hedges(1)
Total Banking revenues (including gains (losses) on loan 
hedges), net of interest expense
Fixed income markets(2)
Equity markets

Securities services
Other(3)
Total Markets and securities services revenues, net 
  of interest expense

Total revenues, net of interest expense

Commissions and fees
Principal transactions(4)
Other(2)
Total non-interest revenue

Net interest revenue
Total fixed income markets(5)

Rates and currencies

Spread products/other fixed income

Total fixed income markets

Commissions and fees
Principal transactions(4)
Other

Total non-interest revenue

Net interest revenue
Total equity markets(5)

2019

2018

2017

% Change 
 2019 vs. 2018

% Change 
 2018 vs. 2017

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

1,259 $

1,301 $

973

2,984

991

2,719

5,216 $

5,011 $

10,293

2,921

3,458

9,914

2,913

3,398

1,123

1,121

3,126

5,370

9,279

2,623

3,108

21,888 $

21,236 $

20,380

(432) $

45 $

(133)

21,456 $

12,884 $

21,281 $

11,661 $

2,908

2,631

(578)

17,845 $

39,301 $

782 $

7,661

1,117

9,560 $

3,324

12,884 $

9,225 $

3,659

12,884 $

1,121 $

775

172

3,427

2,631

(675)

17,044 $

38,325 $

705 $

7,134

380

8,219 $

3,442

11,661 $

8,486 $

3,175

11,661 $

1,267 $

1,240

110

2,068 $

2,617 $

840

810

2,908 $

3,427 $

20,247

12,369

2,879

2,366

(39)

17,575

37,822

628

7,001

619

8,248

4,121

12,369

8,901

3,468

12,369

1,282

494

(21)

1,755

1,124

2,879

(3)%

(2)

10

4 %

4

—

2

3 %

NM

1 %

10 %

(15)

—

14

5 %

3 %

11 %

7

NM

16 %

(3)

10 %

9 %

15

10 %

(12)%

(38)

56

(21)%

4

(15)%

16 %

(12)

(13)

(7)%

7

11

9

4 %

NM

5 %

(6)%

19

11

NM

(3)%

1 %

12 %

2

(39)

— %

(16)

(6)%

(5)%

(8)

(6)%

(1)%

NM

NM

49 %

(28)

19 %

(1)  Credit derivatives are used to economically hedge a portion of the corporate loan portfolio that includes both accrual loans and loans at fair value. Gains (losses) 
on loan hedges include the mark-to-market on the credit derivatives and the mark-to-market on the loans in the portfolio that are at fair value. The fixed premium 
costs of these hedges are netted against the corporate lending revenues to reflect the cost of credit protection. Citigroup’s results of operations excluding the 
impact of gains (losses) on loan hedges are non-GAAP financial measures.

(2)  2019 includes an approximate $350 million gain on Citi's investment in Tradeweb in the second quarter. 
(3)  2017 includes the approximate $580 million gain on the sale of a fixed income analytics business.
(4)  Excludes principal transactions revenues of ICG businesses other than Markets, primarily treasury and trade solutions and the private bank.
(5)  Citi assesses its Markets business performance on a total revenue basis, as offsets may occur across revenue line items. For example, securities that generate Net 

interest revenue may be risk managed by derivatives that are recorded in Principal transactions revenue. For a description of the composition of these revenue line 
items, see Notes 4, 5 and 6 to the Consolidated Financial Statements.

NM  Not meaningful

24

The discussion of the results of operations for ICG below excludes (where noted) the impact of gains (losses) on hedges of accrual 
loans, which are non-GAAP financial measures. For a reconciliation of these metrics to the reported results, see the table above.

2019 vs. 2018
Net income increased 3%, driven primarily by higher revenues 
and a lower effective tax rate, partially offset by higher 
expenses and higher cost of credit.

Revenues increased 3%, reflecting higher Banking 
revenues (increase of 1% including the gains (losses) on loan 
hedges) and higher Markets and securities services revenues 
(increase of 5%). Excluding the impact of the gains (losses) on 
loan hedges, Banking revenues were up 3%, driven by higher 
revenues in treasury and trade solutions, investment banking 
and the private bank, as corporate lending was largely 
unchanged. Markets and securities services revenues were up 
5%, including a gain in the second quarter of 2019 from Citi’s 
investment in Tradeweb, as higher revenues in fixed income 
markets were partially offset by lower equity markets 
revenues.

Citi expects that ICG’s revenues will likely be impacted 

by the lower interest rate environment in the near term.

Within Banking:

• 

• 

Investment banking revenues increased 4%, reflecting 
gains in wallet share despite a decline in the overall 
market wallet. Debt underwriting increased 10%, 
reflecting gains in wallet share, primarily in investment 
grade underwriting, across North America, EMEA and 
Asia. Equity underwriting revenues decreased 2%, 
reflecting a decline in market wallet, particularly in Asia 
and EMEA, partially offset by gains in wallet share. 
Advisory revenues decreased 3%, largely due to a 
comparison to a strong prior year as well as a decline in 
market wallet, partially offset by gains in wallet share.
Treasury and trade solutions revenues increased 4%. 
Excluding the impact of FX translation, revenues 
increased 6%, reflecting strength in all regions, driven by 
growth across both net interest and fee income. Revenues 
increased in the cash business, primarily driven by strong 
client engagement and solid growth in deposit and 
transaction volumes, partially offset by spread 
compression in the second half of 2019 due to the impact 
of lower interest rates. Revenue growth in the trade 
business was driven by improved spreads, due to growth 
in structured loans as well as the ability to continue to 
utilize distribution capabilities to optimize the balance 
sheet and drive returns, while supporting clients. Average 
deposits increased 10%, reflecting growth across regions. 
Average trade loans declined 3%, driven by North 
America, EMEA and Asia (for additional information, see 
“Liquidity Risk—Loans” below).

•  Corporate lending revenues decreased 16%. Excluding 
the impact of gains (losses) on loan hedges, revenues 
were largely unchanged versus the prior year, as growth in 
the commercial loan portfolio was offset by lower 
volumes in the rest of the portfolio. 

•  Private bank revenues increased 2%, driven primarily by 

North America and Asia, partially offset by Latin 
America. The increase in revenues reflected strong client 
activity, driving higher lending and deposit volumes, as 
well as higher capital markets revenues, partially offset by 
lower deposit spreads.

Within Markets and securities services:

•  Fixed income markets revenues increased 10%, including 

the Tradeweb gain, reflecting higher revenues across all 
regions. Non-interest revenues increased due to higher 
corporate and investor client activity as well as improved 
market activity, particularly in rates and spread products. 
The increase in non-interest revenues was partially offset 
by a decline in net interest revenues, reflecting a change 
in the mix of trading positions in support of client activity 
as well as higher funding costs, given the higher interest 
rate environment in the first half of the year.

Rates and currencies revenues increased 9%, 
primarily driven by higher G10 rates and currencies 
revenues in North America, Asia and EMEA, reflecting a 
more favorable operating environment in the second half 
of 2019, with higher corporate and investor client activity. 
Local markets rates and currencies revenues increased 
modestly despite declining currency volatility.

Spread products and other fixed income revenues 

increased 15%, including the Tradeweb gain, reflecting 
higher revenues in both North America and EMEA. The 
increase in revenues was driven by higher client activity 
as well as an improved trading environment, particularly 
in flow trading and financing products. This increase in 
revenues was partially offset by lower structured products 
revenues, reflecting a challenging trading environment.
•  Equity markets revenues decreased 15%, driven by lower 
revenues across cash equities, equity derivatives and 
prime finance, particularly in North America and Asia. 
Cash equities revenues decreased largely due to lower 
client volumes. Despite strong corporate and investor 
client activity, equity derivatives revenues decreased due 
to the impact of a less favorable trading environment, 
given lower market volatility, as well as a comparison to a 
strong prior year. The decline in prime finance revenues 
was primarily driven by lower client activity and lower 
financing balances. Non-interest revenues decreased, 
primarily driven by lower principal transaction and 
commissions and fee revenues, due to lower client 
activity and a less favorable trading environment, as well 
as a change in the mix of trading positions in support of 
client activity.
Securities services revenues were largely unchanged 
versus the prior year. Excluding the impact of FX 
translation, revenues increased 4%, reflecting higher 
revenues in Asia and Latin America. The increase in 
revenues was driven by higher net interest revenue due to 
higher deposit volumes and higher interest rates, 

• 

25

particularly in emerging markets, as well as higher client 
activity.

Expenses increased 2%, as higher compensation, volume-

related expenses and continued investments were partially 
offset by efficiency savings and a benefit from FX translation.
Provisions increased $348 million, driven by an increase 
in net credit losses of $186 million, and an increase in the net 
loan loss reserve build of $162 million. Both the increase in 
net credit losses and the higher loan loss reserve build largely 
reflected a normalization of credit trends.

For information on the impact of Citi’s January 1, 2020 

adoption of the new accounting standard on credit losses 
(CECL), see “Risk Factors—Operational Risks” below and 
Note 1 to the Consolidated Financial Statements.

26

CORPORATE/OTHER

Corporate/Other includes certain unallocated costs of global staff functions (including finance, risk, human resources, legal and 
compliance), other corporate expenses and unallocated global operations and technology expenses and income taxes, as well as 
Corporate Treasury, certain North America legacy consumer loan portfolios, other legacy assets and discontinued operations (for 
additional information on Corporate/Other, see “Citigroup Segments” above). At December 31, 2019, Corporate/Other had $97 
billion in assets.

In millions of dollars

Net interest revenue

Non-interest revenue

Total revenues, net of interest expense

Total operating expenses

Net credit losses

Credit reserve build (release)

Provision (release) for unfunded lending commitments

Provision for benefits and claims
Provisions (benefits) for credit losses and for benefits and
claims

Income (loss) from continuing operations before taxes

Income taxes (benefits)

Income (loss) from continuing operations

Income (loss) from discontinued operations, net of taxes
Net income (loss) before attribution of noncontrolling
interests
Noncontrolling interests

Net income (loss)

NM Not meaningful

2019

2018

2017

% Change 
 2019 vs. 2018

% Change 
 2018 vs. 2017

$

$

$

$

$

$

$

$

$

1,890 $

124

2,014 $

2,150 $

(8) $

(60)

(7)

—

(75) $

(61) $

(886)

825 $

(4)

821 $

20

801 $

2,361 $

(171)

2,190 $

2,275 $

21 $

(218)

(3)

(2)

(202) $

117 $

(88)

205 $

(8)

2,043

1,134

3,177

3,816

149

(317)

—

(7)

(175)

(464)

19,080

(19,544)

(111)

197 $

(19,655)

11

(6)

186 $

(19,649)

(20)%

NM

(8)%

(5)%

NM

72 %

NM

100

63 %

NM

NM

NM

50 %

NM

82 %

NM

16 %

NM

(31)%

(40)%

(86)%

31

—

71

(15)%

NM

(100)%

NM

93 %

NM

NM

NM

2019 vs. 2018 
Net income was $801 million, compared to net income of $186 
million in the prior year. Net income was largely driven by an 
income tax benefit of $886 million, compared to an income 
tax benefit of $88 million in the prior year. The increase in the 
income tax benefit primarily reflected the reduction in the 
valuation allowance related to Citi’s deferred tax assets and a 
pretax loss in the current year (see “Significant Accounting 
Policies and Significant Estimates—Income Taxes” below). 
The pretax loss was largely driven by lower revenues from 
legacy assets, partially offset by higher gains on investments. 
The pretax loss also reflected higher cost of credit, partially 
offset by lower expenses.

Revenues decreased 8%, driven by the continued wind-

down of legacy assets, partially offset by gains on 
investments.

Expenses decreased 5%, as the continued wind-down of 

legacy assets was partially offset by higher infrastructure 
costs.

Provisions increased $127 million to a net benefit of $75 
million, primarily due to a lower net loan loss reserve release, 
partially offset by lower net credit losses.

Citi expects that Corporate/Other results will likely be 

impacted by ongoing investments in infrastructure and 
controls as well as lower interest rates and lower investment 
gains during 2020.

27

OFF-BALANCE SHEET ARRANGEMENTS

Citigroup enters into various types of off-balance sheet 
arrangements in the ordinary course of business. Citi’s 
involvement in these arrangements can take many different 
forms, including without limitation:

• 

• 

• 

purchasing or retaining residual and other interests in 
unconsolidated special purpose entities, such as 
mortgage-backed and other asset-backed securitization 
entities;
holding senior and subordinated debt, interests in limited 
and general partnerships and equity interests in other 
unconsolidated special purpose entities; and
providing guarantees, indemnifications, loan 
commitments, letters of credit and representations and 
warranties.

Citi enters into these arrangements for a variety of 
business purposes. For example, securitization arrangements 
offer investors access to specific cash flows and risks created 
through the securitization process. Securitization arrangements 
also assist Citi and its customers in monetizing their financial 
assets and securing financing at more favorable rates than Citi 
or the customers could otherwise obtain.

The table below shows where a discussion of Citi’s 
various off-balance sheet arrangements may be found in this 
Form 10-K. In addition, see Note 1 to the Consolidated 
Financial Statements.

Types of Off-Balance Sheet Arrangements Disclosures in 
this Form 10-K 

Variable interests and other
obligations, including
contingent obligations,
arising from variable
interests in nonconsolidated
VIEs

Letters of credit, and lending
and other commitments
Guarantees

See Note 21 to the Consolidated
Financial Statements.

See Note 26 to the Consolidated
Financial Statements.
See Note 26 to the Consolidated
Financial Statements.

28

CONTRACTUAL OBLIGATIONS

The following table includes information on Citigroup’s contractual obligations, as specified and aggregated pursuant to SEC 
requirements: 

In millions of dollars
Long-term debt obligations—principal(1)
Long-term debt obligations—interest payments(2)
Operating lease obligations(3)
Purchase obligations(4)
Other liabilities(5)
Total

Contractual obligations by year

2020

2021

2022

2023

2024

Thereafter

Total

$ 37,257 $ 38,083 $ 27,090 $ 20,128 $ 16,023 $

110,179 $ 248,760

7,548

6,313

5,244

4,470

3,877

34,220

61,672

801

584

34,561

695

538

474

572

532

218

425

316

127

314

324

114

935

752

3,742

3,046

1,622

37,116

$ 80,751 $ 46,103 $ 33,656 $ 25,466 $ 20,652 $

147,708 $ 354,336

(1)  For additional information about long-term debt obligations, see “Liquidity Risk—Long-Term Debt” below and Note 17 to the Consolidated Financial Statements.
(2)  Contractual obligations related to interest payments on long-term debt for 2020–2024 are calculated by applying the December 31, 2019 weighted-average interest 

rate (3.28%) on average outstanding long-term debt to the average remaining contractual obligations on long-term debt for each of those years. The “Thereafter” 
interest payments on long-term debt for the remaining years to maturity (2025–2098) are calculated by applying current interest rates on the remaining contractual 
obligations on long-term debt for each of those years.

(3)  For additional information about operating leases, see Note 26 to the Consolidated Financial Statements.
(4)  Purchase obligations consist of obligations to purchase goods or services that are enforceable and legally binding on Citi. For presentation purposes, purchase 
obligations are included in the table above through the termination date of the respective agreements, even if the contract is renewable. Many of the purchase 
agreements for goods or services include clauses that would allow Citi to cancel the agreement with specified notice; however, that impact is not included in the 
table above (unless Citi has already notified the counterparty of its intention to terminate the agreement).

(5)  Other liabilities reflected on Citigroup’s Consolidated Balance Sheet includes accounts payable, accrued expenses, uncertain tax positions and other liabilities that 
have been incurred and will ultimately be paid in cash; legal reserve accruals are not included in the table above. Also includes discretionary contributions in 2018 
for Citi’s employee-defined benefit obligations for the pension, postretirement and post employment plans and defined contribution plans. 

29

CAPITAL RESOURCES 

Overview
Capital is used principally to support assets in Citi’s 
businesses and to absorb credit, market and operational losses. 
Citi primarily generates capital through earnings from its 
operating businesses. Citi may augment its capital through 
issuances of common stock, noncumulative perpetual 
preferred stock and equity issued through awards under 
employee benefit plans, among other issuances. Further, Citi’s 
capital levels may also be affected by changes in accounting 
and regulatory standards, as well as U.S. corporate tax laws 
and the impact of future events on Citi’s business results, such 
as changes in interest and foreign exchange rates, as well as 
business and asset dispositions.

During 2019, Citi returned a total of $22.3 billion of 

capital to common shareholders in the form of share 
repurchases (approximately 264 million common shares) and 
dividends. 

Capital Management
Citi’s capital management framework is designed to ensure 
that Citigroup and its principal subsidiaries maintain sufficient 
capital consistent with each entity’s respective risk profile, 
management targets and all applicable regulatory standards 
and guidelines. Citi assesses its capital adequacy against a 
series of internal quantitative capital goals, designed to 
evaluate its capital levels in expected and stressed economic 
environments. Underlying these internal quantitative capital 
goals are strategic capital considerations, centered on 
preserving and building financial strength. The Citigroup 
Capital Committee, with oversight from the Risk Management 
Committee of Citigroup’s Board of Directors, has 
responsibility for Citi’s aggregate capital structure, including 
the capital assessment and planning process, which is 
integrated into Citi’s capital plan. Balance sheet management, 
including oversight of capital adequacy, for Citigroup’s 
subsidiaries is governed by each entity’s Asset and Liability 
Committee, where applicable. 

Based on Citigroup’s current regulatory capital 
requirements, as well as consideration of potential future 
changes to the U.S. Basel III rules, management currently 
believes that a targeted Common Equity Tier 1 Capital ratio of 
approximately 11.5% represents the amount necessary to 
prudently operate and invest in Citi’s franchise, including 
when considering future growth plans, capital return 
projections and other factors that may impact Citi’s 
businesses. However, management may revise Citigroup’s 
targeted Common Equity Tier 1 Capital ratio in response to 
changing regulatory capital requirements as well as other 
relevant factors. 

For additional information regarding Citi’s capital 

planning and stress testing exercises, see “Stress Testing 
Component of Capital Planning” below.

Current Regulatory Capital Standards
Citi is subject to regulatory capital standards issued by the 
Federal Reserve Board, which constitute the U.S. Basel III 
rules. These rules establish an integrated capital adequacy 
framework, encompassing both risk-based capital ratios and 
leverage ratios.

Risk-Based Capital Ratios
The U.S. Basel III rules set forth the composition of regulatory 
capital (including the application of regulatory capital 
adjustments and deductions), as well as two comprehensive 
methodologies (a Standardized Approach and Advanced 
Approaches) for measuring total risk-weighted assets. Total 
risk-weighted assets under the Advanced Approaches, which 
are primarily models based, include credit, market and 
operational risk-weighted assets. The Standardized Approach 
generally applies prescribed supervisory risk weights to broad 
categories of credit risk exposures. As a result, credit risk-
weighted assets calculated under the Advanced Approaches 
are more risk sensitive than those calculated under the 
Standardized Approach. Market risk-weighted assets are 
currently calculated on a generally consistent basis under both 
approaches. The Standardized Approach excludes operational 
risk-weighted assets.

The U.S. Basel III rules establish stated minimum 

Common Equity Tier 1 Capital, Tier 1 Capital and Total 
Capital ratios for substantially all U.S. banking organizations, 
including Citi and Citibank, N.A. (Citibank). Moreover, these 
rules provide for both a fixed 2.5% Capital Conservation 
Buffer and, for Advanced Approaches banking organizations, 
such as Citi and Citibank, a discretionary Countercyclical 
Capital Buffer. These capital buffers would be available to 
absorb losses in advance of any potential impairment of 
regulatory capital below the stated minimum risk-based capital 
ratio requirements. Any breach of the buffers to absorb losses 
during periods of financial or economic stress would result in 
restrictions on earnings distributions (e.g., dividends, equity 
repurchases and discretionary executive bonuses), with the 
degree of such restrictions based upon the extent to which the 
buffers are breached. The Federal Reserve Board last voted to 
affirm the Countercyclical Capital Buffer amount at the 
current level of 0% in March 2019.

Further, the U.S. Basel III rules implement the “capital 
floor provision” of the so-called “Collins Amendment” of the 
Dodd-Frank Act, which requires Advanced Approaches 
banking organizations to calculate each of the three risk-based 
capital ratios (Common Equity Tier 1 Capital, Tier 1 Capital 
and Total Capital) under both the U.S. Basel III Standardized 
Approach and the Advanced Approaches and comply with the 
lower of each of the resulting risk-based capital ratios.

30

The following table sets forth Citi’s GSIB surcharge as 

determined under method 1 and method 2 for 2019 and 2018:

Method 1

Method 2

2019

2018

2.0%

3.0

2.0%

3.0

Citi’s GSIB surcharge effective for both 2019 and 2018 
was 3.0%, as derived under the higher method 2 result. Citi’s 
GSIB surcharge effective for 2020 will remain unchanged at 
3.0%, as derived under the higher method 2 result. Citi expects 
that its method 2 GSIB surcharge will continue to remain 
higher than its method 1 GSIB surcharge. Citi’s GSIB 
surcharge effective for 2021 will not exceed 3.0%, and Citi’s 
GSIB surcharge effective for 2022 is not expected to exceed 
3.0%.

Transition Provisions
Generally, the U.S. Basel III rules contain several differing, 
largely multi-year transition provisions, with various “phase-
ins” and “phase-outs.” With the exception of the non-
grandfathered trust preferred securities, which do not fully 
phase-out of Tier 2 Capital until January 1, 2022, all other 
transition provisions have occurred and were entirely reflected 
in Citi’s regulatory capital ratios beginning January 1, 2018. 
Moreover, the GSIB surcharge, Capital Conservation Buffer 
and any Countercyclical Capital Buffer (currently 0%) 
commenced phase-in on January 1, 2016, and became fully 
effective on January 1, 2019. 

Tier 1 Leverage Ratio
Under the U.S. Basel III rules, Citi is also required to maintain 
a minimum Tier 1 Leverage ratio of 4.0%. The Tier 1 
Leverage ratio, a non-risk-based measure of capital adequacy, 
is defined as Tier 1 Capital as a percentage of quarterly 
adjusted average total assets less amounts deducted from Tier 
1 Capital. 

GSIB Surcharge
The Federal Reserve Board imposes a risk-based capital 
surcharge upon U.S. bank holding companies that are 
identified as global systemically important bank holding 
companies (GSIBs), including Citi. The GSIB surcharge 
augments the Capital Conservation Buffer and, if invoked, any 
Countercyclical Capital Buffer.

Under the Federal Reserve Board’s rule, identification of 

a GSIB is based on the Basel Committee on Banking 
Supervision’s (Basel Committee) GSIB methodology, which 
primarily looks to five equally weighted broad categories of 
systemic importance: (i) size, (ii) interconnectedness, (iii) 
cross-jurisdictional activity, (iv) substitutability and (v) 
complexity. With the exception of size, each of the categories 
is composed of multiple indicators of equal weight, amounting 
to 12 indicators in total. 

A U.S. bank holding company that is designated a GSIB 
is required, on an annual basis, to calculate a surcharge using 
two methods and is subject to the higher of the resulting two 
surcharges. The first method (“method 1”) is based on the 
Basel Committee’s GSIB methodology described above. 
Under the second method (“method 2”), the substitutability 
category is replaced with a quantitative measure intended to 
assess a GSIB’s reliance on short-term wholesale funding. In 
addition, method 1 incorporates relative measures of systemic 
importance across certain global banking organizations and a 
year-end spot foreign exchange rate, whereas method 2 uses 
fixed measures of systemic importance and application of an 
average foreign exchange rate over a three-year period. The 
GSIB surcharges calculated under both method 1 and method 
2 are based on measures of systemic importance from the year 
immediately preceding that in which the GSIB surcharge 
calculations are being performed (e.g., the method 1 and 
method 2 GSIB surcharges to be calculated by December 31, 
2020 will be based on 2019 systemic indicator data). 
Generally, Citi’s surcharge determined under method 2 will 
result in a higher surcharge than its surcharge determined 
under method 1.

Should a GSIB’s systemic importance change year-over-

year such that it becomes subject to a higher surcharge, the 
higher surcharge would not become effective for a full year 
(e.g., a higher surcharge calculated by December 31, 2020 
would not become effective until January 1, 2022). However, 
if a GSIB’s systemic importance changes such that the GSIB 
would be subject to a lower surcharge, the GSIB would be 
subject to the lower surcharge beginning with the next 
calendar year (e.g., a lower surcharge calculated by December 
31, 2020 would become effective January 1, 2021).

31

 
Supplementary Leverage Ratio
Citi is also required to calculate a Supplementary Leverage 
ratio, which differs from the Tier 1 Leverage ratio by also 
including certain off-balance sheet exposures within the 
denominator of the ratio (Total Leverage Exposure). The 
Supplementary Leverage ratio represents end of period Tier 1 
Capital to Total Leverage Exposure, with the latter defined as 
the sum of the daily average of on-balance sheet assets for the 
quarter and the average of certain off-balance sheet exposures 
calculated as of the last day of each month in the quarter, less 
applicable Tier 1 Capital deductions. Advanced Approaches 
banking organizations are required to maintain a stated 
minimum Supplementary Leverage ratio of 3.0%.

Further, U.S. GSIBs, including Citi, are subject to 
enhanced Supplementary Leverage ratio standards. The 
enhanced Supplementary Leverage ratio standards establish a 
2.0% leverage buffer in addition to the stated 3.0% minimum 
Supplementary Leverage ratio requirement, for a total 
effective minimum Supplementary Leverage ratio requirement 
of 5.0%. If a U.S. GSIB fails to exceed the 5.0% effective 
minimum Supplementary Leverage ratio requirement, it will 
be subject to increasingly onerous restrictions (depending 
upon the extent of the shortfall) regarding capital distributions 
and discretionary executive bonus payments. 

Prompt Corrective Action Framework
In general, the Prompt Corrective Action (PCA) regulations 
direct the U.S. banking agencies to enforce increasingly strict 
limitations on the activities of insured depository institutions 
that fail to meet certain regulatory capital thresholds. The PCA 
framework contains five categories of capital adequacy as 
measured by risk-based capital and leverage ratios: (i) “well 
capitalized,” (ii) “adequately capitalized,” (iii) 
“undercapitalized,” (iv) “significantly undercapitalized” and 
(v) “critically undercapitalized.”

Accordingly, an insured depository institution, such as 
Citibank, must maintain minimum Common Equity Tier 1 
Capital, Tier 1 Capital, Total Capital and Tier 1 Leverage 
ratios of 6.5%, 8.0%, 10.0% and 5.0%, respectively, to be 
considered “well capitalized.” In addition, insured depository 
institution subsidiaries of U.S. GSIBs, including Citibank, 
must maintain a minimum Supplementary Leverage ratio of 
6.0% to be considered “well capitalized.” Citibank was “well 
capitalized” as of December 31, 2019.

Stress Testing Component of Capital Planning
Citi is subject to an annual assessment by the Federal Reserve 
Board as to whether Citigroup has effective capital planning 
processes as well as sufficient regulatory capital to absorb 
losses during stressful economic and financial conditions, 
while also meeting obligations to creditors and counterparties 
and continuing to serve as a credit intermediary. This annual 
assessment includes two related programs: the Comprehensive 
Capital Analysis and Review (CCAR) and Dodd-Frank Act 
Stress Testing (DFAST).

For the largest and most complex firms, such as Citi, 
CCAR includes both a quantitative evaluation of a firm’s 
capital adequacy under stress and a qualitative evaluation of 
its abilities to determine its capital needs on a forward-looking 

32

basis. As part of the CCAR process, the Federal Reserve 
Board evaluates Citi’s capital adequacy, capital adequacy 
process and its planned capital distributions, such as dividend 
payments and common stock repurchases. The Federal 
Reserve Board assesses whether Citi has sufficient capital to 
continue operations throughout times of economic and 
financial market stress and whether Citi has robust, forward-
looking capital planning processes that account for its unique 
risks. The Federal Reserve Board may object to Citi’s annual 
capital plan based on quantitative grounds. If the Federal 
Reserve Board objects to Citi’s annual capital plan, Citi may 
not undertake any capital distribution unless the Federal 
Reserve Board indicates in writing that it does not object to 
the distribution. 

Based on recent changes to the Federal Reserve Board’s 
Capital Plan Rule, the qualitative objection to a firm’s capital 
plan will no longer apply. However, all CCAR firms, 
including Citi, will continue to be subject to a rigorous 
evaluation of their capital planning process. Firms with weak 
practices may be subject to a deficient supervisory rating, and 
potentially an enforcement action, for failing to meet 
supervisory expectations. For additional information regarding 
CCAR, see “Risk Factors—Strategic Risks” below. 

DFAST is a forward-looking quantitative evaluation of 

the impact of stressful economic and financial market 
conditions on Citi’s regulatory capital. This program serves to 
inform the Federal Reserve Board and the general public as to 
how Citi’s regulatory capital ratios might change using a 
hypothetical set of adverse economic conditions as designed 
by the Federal Reserve Board. In addition to the annual 
supervisory stress test conducted by the Federal Reserve 
Board, Citi is required to conduct annual company-run stress 
tests under the same adverse economic conditions designed by 
the Federal Reserve Board.

Both CCAR and DFAST include an estimate of projected 
revenues, losses, reserves, pro forma regulatory capital ratios, 
and any other additional capital measures deemed relevant by 
Citi. Projections are required over a nine-quarter planning 
horizon under two supervisory scenarios (baseline and 
severely adverse conditions). All risk-based capital ratios 
reflect application of the Standardized Approach framework 
under the U.S. Basel III rules. Moreover, the Federal Reserve 
Board has deferred the use of the Advanced Approaches 
framework indefinitely.

In addition, Citibank is required to conduct the annual 
Dodd-Frank Act Stress Test. The annual stress test consists of 
a forward-looking quantitative evaluation of the impact of 
stressful economic and financial market conditions under 
several scenarios on Citibank’s regulatory capital. This 
program serves to inform the Office of the Comptroller of 
the Currency as to how Citibank’s regulatory capital ratios 
might change during a hypothetical set of adverse economic 
conditions and to ultimately evaluate the reliability of 
Citibank’s capital planning process.

For additional information on potential changes to the 

stress testing component of capital planning and assessment 
process applicable to Citi, see “Regulatory Capital Standards 
Developments” below.

Citigroup’s Capital Resources 
Citi is required to maintain stated minimum Common Equity 
Tier 1 Capital, Tier 1 Capital and Total Capital ratios of 4.5%, 
6.0% and 8.0%, respectively. Citi’s effective minimum capital 
requirements are presented in the table below.

Furthermore, to be “well capitalized” under current 
federal bank regulatory agency definitions, a bank holding 
company must have a Tier 1 Capital ratio of at least 6.0%, a 
Total Capital ratio of at least 10.0% and not be subject to a 
Federal Reserve Board directive to maintain higher capital 
levels. 

The following tables set forth Citi’s capital components 
and ratios as of December 31, 2019, September 30, 2019 and 
December 31, 2018:

Effective 
Minimum 
Requirement(1)

In millions of dollars, except ratios

2019

2018

Advanced Approaches

Standardized Approach

Dec. 31,
2019

Sept. 30,
2019

Dec. 31,
2018

Dec. 31,
2019

Sept. 30,
2019

Dec. 31,
2018

Common Equity Tier 1 Capital

$

137,798

$

138,581

$

139,252

$

137,798

$

138,581

$

139,252

Tier 1 Capital

Total Capital (Tier 1 Capital +
Tier 2 Capital)

Total Risk-Weighted Assets

   Credit Risk

   Market Risk

   Operational Risk

Common Equity Tier 1 Capital 
ratio(2)
Tier 1 Capital ratio(2)
Total Capital ratio(2)

155,805

158,033

158,122

155,805

158,033

158,122

181,337

183,996

183,144

193,682

196,354

195,440

1,135,553

1,145,091

1,131,933

1,166,523

1,197,050

1,174,448

$

771,508

$

776,367

$

758,887

$ 1,107,775

$ 1,134,584

$ 1,109,007

57,317

306,728

61,125

307,599

63,987

309,059

58,748

—

62,466

—

65,441

—

10.0%

8.625%

12.13%

12.10%

12.30%

11.81%

11.58%

11.86%

11.5

13.5

10.125

12.125

13.72

15.97

13.80

16.07

13.97

16.18

13.36

16.60

13.20

16.40

13.46

16.64

In millions of dollars, except ratios
Quarterly Adjusted Average Total Assets(3)
Total Leverage Exposure(4) 

Tier 1 Leverage ratio

Supplementary Leverage ratio

Effective
Minimum
Requirement

Dec. 31, 2019

Sept. 30, 2019

Dec. 31, 2018

$

1,957,039

$

1,960,675

$

4.0%

5.0

2,507,891

2,520,352

7.96%

6.21

8.06%

6.27

1,896,959

2,465,641

8.34%

6.41

(1)  Citi’s effective minimum risk-based capital requirements during 2019 and 2018 are inclusive of the 100% and 75% phase-in, respectively, of both the 2.5% 

Capital Conservation Buffer and the 3.0% GSIB surcharge (all of which must be composed of Common Equity Tier 1 Capital).

(2)  Citi’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the Basel III Standardized Approach, whereas the 

reportable Total Capital ratio was the lower derived under the Basel III Advanced Approaches framework for all periods presented.

(3)  Tier 1 Leverage ratio denominator. Represents quarterly average total assets less amounts deducted from Tier 1 Capital.
(4)  Supplementary Leverage ratio denominator.

Common Equity Tier 1 Capital Ratio 
Citi’s Common Equity Tier 1 Capital ratio was 11.8% under 
the Basel III Standardized Approach at December 31, 2019, 
compared to 11.6% at September 30, 2019 and 11.9% at 
December 31, 2018. The quarter-over-quarter increase was 
primarily due to net income of $5.0 billion, a reduction in 
credit risk-weighted assets and beneficial net movements in 

Accumulated other comprehensive income (AOCI), partially 
offset by the return of $6.2 billion of capital to common 
shareholders. The decline year-over-year was primarily due to 
the return of $22.3 billion of capital to common shareholders, 
partially offset by net income of $19.4 billion in 2019, 
beneficial net movements in AOCI and a reduction in risk-
weighted assets.

33

Components of Citigroup Capital

In millions of dollars

Common Equity Tier 1 Capital
Citigroup common stockholders’ equity(1)
Add: Qualifying noncontrolling interests

Regulatory capital adjustments and deductions:
Less: Accumulated net unrealized gains (losses) on cash flow hedges, net of tax(2)
Less: Cumulative unrealized net gain (loss) related to changes in fair value of financial liabilities
   attributable to own creditworthiness, net of tax(3)
Less: Intangible assets:
  Goodwill, net of related DTLs(4)
    Identifiable intangible assets other than MSRs, net of related DTLs

Less: Defined benefit pension plan net assets
Less: DTAs arising from net operating loss, foreign tax credit and general business credit 
   carry-forwards(5)
Total Common Equity Tier 1 Capital (Standardized Approach and Advanced Approaches)

Additional Tier 1 Capital
Qualifying noncumulative perpetual preferred stock(1)
Qualifying trust preferred securities(6)
Qualifying noncontrolling interests

Regulatory capital deductions:
Less: Permitted ownership interests in covered funds(7)
Less: Minimum regulatory capital requirements of insurance underwriting subsidiaries(8)
Total Additional Tier 1 Capital (Standardized Approach and Advanced Approaches)

Total Tier 1 Capital (Common Equity Tier 1 Capital + Additional Tier 1 Capital)
   (Standardized Approach and Advanced Approaches)

Tier 2 Capital

Qualifying subordinated debt
Qualifying trust preferred securities(9)
Qualifying noncontrolling interests
Eligible allowance for credit losses(10)
Regulatory capital deduction:
Less: Minimum regulatory capital requirements of insurance underwriting subsidiaries(8)
Total Tier 2 Capital (Standardized Approach)

Total Capital (Tier 1 Capital + Tier 2 Capital) (Standardized Approach)
Adjustment for excess of eligible credit reserves over expected credit losses(10)
Total Tier 2 Capital (Advanced Approaches)

Total Capital (Tier 1 Capital + Tier 2 Capital) (Advanced Approaches)

$

$

$

$

$

$

$

$

$

$

December 31,
2019

December 31,
2018

$

175,414 $

154

123

(679)

21,066

4,087

803

12,370

137,798 $

17,828 $

1,389

42

1,216

36

177,928

147

(728)

580

21,778

4,402

806

11,985

139,252

18,292

1,384

55

806

55

18,007 $

18,870

155,805 $

158,122

23,673 $

23,324

326

46

13,868

36

37,877 $

193,682 $

(12,345) $

25,532 $

181,337 $

321

47

13,681

55

37,318

195,440

(12,296)

25,022

183,144

(1) 

Issuance costs of $152 million and $168 million related to noncumulative perpetual preferred stock outstanding at December 31, 2019 and 2018, respectively, are 
excluded from common stockholders’ equity and netted against such preferred stock in accordance with Federal Reserve Board regulatory reporting requirements, 
which differ from those under U.S. GAAP. 

(2)  Common Equity Tier 1 Capital is adjusted for accumulated net unrealized gains (losses) on cash flow hedges included in AOCI that relate to the hedging of items 

not recognized at fair value on the balance sheet.

(3)  The cumulative impact of changes in Citigroup’s own creditworthiness in valuing liabilities for which the fair value option has been elected, and own-credit 

valuation adjustments on derivatives, are excluded from Common Equity Tier 1 Capital, in accordance with the U.S. Basel III rules. 
Includes goodwill “embedded” in the valuation of significant common stock investments in unconsolidated financial institutions. 

(4) 

Footnotes continue on the following page.

34

(5)  Of Citi’s $23.1 billion of net DTAs at December 31, 2019, $12.4 billion was includable in Common Equity Tier 1 Capital pursuant to the U.S. Basel III rules, 

while $10.7 billion was excluded. Excluded from Citi’s Common Equity Tier 1 Capital as of December 31, 2019 was $12.4 billion of net DTAs arising from net 
operating loss, foreign tax credit and general business credit carry-forwards, which was reduced by $1.7 billion of net DTLs primarily associated with goodwill 
and certain other intangible assets. Separately, under the U.S. Basel III rules, goodwill and these other intangible assets are deducted net of associated DTLs in 
arriving at Common Equity Tier 1 Capital. DTAs arising from net operating loss, foreign tax credit and general business credit carry-forwards are required to be 
entirely deducted from Common Equity Tier 1 Capital under the U.S. Basel III rules. Citi’s DTAs arising from temporary differences are less than the 10% 
limitation under the U.S. Basel III rules and therefore not subject to deduction from Common Equity Tier 1 Capital, but are subject to risk-weighting at 250%. 

(6)  Represents Citigroup Capital XIII trust preferred securities, which are permanently grandfathered as Tier 1 Capital under the U.S. Basel III rules. 
(7)  Banking entities are required to be in compliance with the Volcker Rule of the Dodd-Frank Act, which prohibits conducting certain proprietary investment 

activities and limits their ownership of, and relationships with, covered funds. Accordingly, Citi is required by the Volcker Rule to deduct from Tier 1 Capital all 
permitted ownership interests in covered funds.

(8)  50% of the minimum regulatory capital requirements of insurance underwriting subsidiaries must be deducted from each of Tier 1 Capital and Tier 2 Capital.
(9)  Represents the amount of non-grandfathered trust preferred securities eligible for inclusion in Tier 2 Capital under the U.S. Basel III rules, which will be fully 

phased-out of Tier 2 Capital by January 1, 2022. 

(10)  Under the Standardized Approach, the allowance for credit losses is eligible for inclusion in Tier 2 Capital up to 1.25% of credit risk-weighted assets, with any 
excess allowance for credit losses being deducted in arriving at credit risk-weighted assets, which differs from the Advanced Approaches framework, in which 
eligible credit reserves that exceed expected credit losses are eligible for inclusion in Tier 2 Capital to the extent that the excess reserves do not exceed 0.6% of 
credit risk-weighted assets. The total amount of eligible credit reserves in excess of expected credit losses that were eligible for inclusion in Tier 2 Capital, subject 
to limitation, under the Advanced Approaches framework was $1.5 billion and $1.4 billion at December 31, 2019 and 2018, respectively. 

35

Citigroup Capital Rollforward 

In millions of dollars
Common Equity Tier 1 Capital, beginning of period
Net income
Common and preferred stock dividends declared
 Net increase in treasury stock
Net change in common stock and additional paid-in capital
Net change in foreign currency translation adjustment net of hedges, net of tax
Net change in unrealized gains (losses) on debt securities AFS, net of tax
Net change in defined benefit plans liability adjustment, net of tax
Net change in adjustment related to change in fair value of financial liabilities 
    attributable to own creditworthiness, net of tax
Net change in ASC 815—excluded component of fair value hedges
Net decrease in goodwill, net of related DTLs
Net decrease in identifiable intangible assets other than MSRs, net of related DTLs
Net decrease in defined benefit pension plan net assets
 Net increase in DTAs arising from net operating loss, foreign tax credit and 
      general business credit carry-forwards
Other
Net decrease in Common Equity Tier 1 Capital

Common Equity Tier 1 Capital, end of period
    (Standardized Approach and Advanced Approaches)
Additional Tier 1 Capital, beginning of period
Net decrease in qualifying perpetual preferred stock
Net increase in qualifying trust preferred securities
Net change in permitted ownership interests in covered funds
Other
Net decrease in Additional Tier 1 Capital

Tier 1 Capital, end of period
    (Standardized Approach and Advanced Approaches)
Tier 2 Capital, beginning of period (Standardized Approach)
Net change in qualifying subordinated debt
Net change in eligible allowance for credit losses
Other
Net change in Tier 2 Capital (Standardized Approach)
Tier 2 Capital, end of period (Standardized Approach)
Total Capital, end of period (Standardized Approach)
Tier 2 Capital, beginning of period (Advanced Approaches)
Net change in qualifying subordinated debt
Net change in excess of eligible credit reserves over expected credit losses
Other
Net change in Tier 2 Capital (Advanced Approaches)
Tier 2 Capital, end of period (Advanced Approaches)
Total Capital, end of period (Advanced Approaches)

$

$

$
$

$

$
$

$
$
$
$

$
$
$

Three Months Ended
December 31, 2019

Twelve Months Ended 
 December 31, 2019

138,581 $
4,979
(1,401)
(5,119)
92
972
(160)
15

82
(27)
432
45
187

(883)
3
(783) $

137,798 $
19,452 $
(1,493)
—
49
(1)
(1,445) $

155,805 $
38,321 $
(408)
(46)
10
(444) $
37,877 $
193,682 $
25,963 $
(408)
(33)
10
(431) $
25,532 $
181,337 $

139,252
19,401
(5,512)
(17,290)
(98)
(321)
1,985
(552)

123
25
712
315
3

(385)
140
(1,454)

137,798
18,870
(464)
5
(410)
6
(863)

155,805
37,318
349
187
23
559
37,877
193,682
25,022
349
138
23
510
25,532
181,337

36

Citigroup Risk-Weighted Assets Rollforward (Basel III Standardized Approach) 

In millions of dollars

 Total Risk-Weighted Assets, beginning of period

Changes in Credit Risk-Weighted Assets
General credit risk exposures(1)
Repo-style transactions(2)
Securitization exposures
Equity exposures(3)
Over-the-counter (OTC) derivatives(4)
Other exposures(5)
Off-balance sheet exposures(6)
Net decrease in Credit Risk-Weighted Assets

Changes in Market Risk-Weighted Assets
Risk levels(7)
Model and methodology updates

Net decrease in Market Risk-Weighted Assets

Total Risk-Weighted Assets, end of period

Three Months Ended
December 31, 2019

Twelve Months Ended 
 December 31, 2019

$

1,197,050 $

1,174,448

2,821

(19,681)

(277)

1,590

(13,283)

4,639

(2,618)

(26,809) $

(4,718) $

1,000

(3,718) $

10,376

(7,420)

980

5,013

(6,669)

9,290

(12,802)

(1,232)

(6,847)

154

(6,693)

1,166,523 $

1,166,523

$

$

$

$

(1)  General credit risk exposures include cash and balances due from depository institutions, securities, and loans and leases. General credit risk exposures increased 
during the three and 12 months ended December 31, 2019, mainly driven by growth in commercial and retail loans and increases in investment securities.
(2)  Repo-style transactions include repurchase and reverse repurchase transactions as well as securities borrowing and securities lending transactions. Repo-style 

transactions decreased during the three and 12 months ended December 31, 2019, driven by volume reduction and matured deals.

(3)  Equity exposures increased during the three months ended December 31, 2019, primarily due to increased exposures from existing investments. Equity exposures 
increased during the 12 months ended December 31, 2019, primarily due to an increase in market value of investments and increased exposures from existing 
investments.

(4)  OTC derivatives decreased during the three and 12 months ended December 31, 2019, primarily due to decreases in notionals.
(5)  Other exposures include cleared transactions, unsettled transactions and other assets. Other exposures increased during the three months ended December 31, 

2019, primarily due to increases in centrally cleared derivatives and various other assets. Other exposures increased during the 12 months ended December 31, 
2019, primarily due to the recognition of right-of-use (ROU) assets in accordance with the adoption of ASU No. 2016-02, Leases (Topic 842), effective January 1, 
2019, as well as increases in centrally cleared derivatives and various other assets.

(6)  Off-balance sheet exposures decreased during the three months ended December 31, 2019, primarily due to a decrease in standby letters of credit. Off-balance 
sheet exposures decreased during the 12 months ended December 31, 2019, primarily due to decreases in standby letters of credit and loan commitments.
(7)  Risk levels decreased during the three months ended December 31, 2019, primarily due to a decrease in exposure levels subject to Stressed Value at Risk and 

Incremental Risk charges. Risk levels decreased during the 12 months ended December 31, 2019, primarily due to a decrease in exposure levels subject to 
Stressed Value at Risk.  

As set forth in the table above, total risk-weighted assets 

under the Basel III Standardized Approach decreased from 
year-end 2018, due to decreases in market risk-weighted assets 
and credit risk-weighted assets. Market risk-weighted assets 
decreased from year-end 2018 primarily due to a net reduction 
in exposure levels. The decrease in credit risk-weighted assets 
was primarily due to decreases in standby letters of credit and 
loan commitments as well as volume reduction and matured 
deals in repo-style transactions and changes in OTC derivative 
trade activity, partially offset by increases in loan exposures, 
the recognition of right-of-use (ROU) assets in accordance 
with the adoption of ASU No. 2016-02, Leases (Topic 842), 
effective January 1, 2019, and an increase in market value of 
investments.

37

Citigroup Risk-Weighted Assets Rollforward (Basel III Advanced Approaches) 

In millions of dollars
 Total Risk-Weighted Assets, beginning of period
Changes in Credit Risk-Weighted Assets
Retail exposures(1)
Wholesale exposures(2)
Repo-style transactions(3)
Securitization exposures(4)
Equity exposures(5)
Over-the-counter (OTC) derivatives(6)
Derivatives CVA(7)
Other exposures(8)
Supervisory 6% multiplier
Net change in Credit Risk-Weighted Assets
Changes in Market Risk-Weighted Assets
Risk levels(9)
Model and methodology updates
Net decrease in Market Risk-Weighted Assets
Net decrease in Operational Risk-Weighted Assets(10)
Total Risk-Weighted Assets, end of period

Three Months Ended
December 31, 2019

Twelve Months Ended 
 December 31, 2019

$

1,145,091 $

1,131,933

6,140

(3,007)
(8,761)
153
1,764

(2,992)
(6,651)

8,394

101
(4,859) $

(4,808) $
1,000
(3,808) $

(871) $
1,135,553 $

4,959

(9,288)
(3,184)
5,889
4,924

8,508
(15,034)

14,282

1,565
12,621

(6,824)
154
(6,670)

(2,331)
1,135,553

$

$

$

$
$

(1)  Retail exposures increased during the three months ended December 31, 2019, primarily due to seasonal spending for qualifying revolving (cards) exposures. 
Retail exposures increased during the 12 months ended December 31, 2019, primarily due to increases in consumer loans, partially offset by decreases due to 
annual parameter updates.

(2)  Wholesale exposures decreased during the three months ended December 31, 2019, primarily due to decreases in commercial loans partially offset by increases in 

investment securities. Wholesale exposures decreased during the 12 months ended December 31, 2019, primarily due to annual model parameter updates 
reflecting Citi’s loss experience, partially offset by increases in commercial loans and investment securities.

(3)  Repo-style transactions include repurchase and reverse repurchase transactions as well as securities borrowing and securities lending transactions. Repo-style 

transactions decreased during the three and 12 months ended December 31, 2019, driven by volume reduction and matured deals.

(4)  Securitization exposures increased during the 12 months ended December 31, 2019, due to increased exposures from existing deals.
(5)  Equity exposures increased during the three months ended December 31, 2019, primarily due to increased exposures from existing investments. Equity exposures 
increased during the 12 months ended December 31, 2019, primarily due to an increase in market value of investments and increased exposures from existing 
investments.

(6)  OTC derivatives decreased during the three months ended December 31, 2019, primarily due to a reduction in notionals. OTC derivatives increased during the 12 

months ended December 31, 2019, primarily due to approved model changes, partially offset by a reduction in notionals.

(7)  Derivatives CVA decreased during the three months ended December 31, 2019, primarily due to exposure decreases and changes in credit spreads. Derivatives 

CVA decreased during the 12 months ended December 31, 2019, primarily due to approved model changes, exposure decreases and changes in credit spreads.
(8)  Other exposures include cleared transactions, unsettled transactions, assets other than those reportable in specific exposure categories and non-material portfolios. 
Other exposures increased during the three months ended December 31, 2019, primarily due to increases in centrally cleared derivatives and various other assets. 
Other exposures increased during the 12 months ended December 31, 2019, primarily due to the recognition of ROU assets in accordance with the adoption of 
ASU No. 2016-02, Leases (Topic 842), effective January 1, 2019, and increases in centrally cleared derivatives and various other assets.

(9)  Risk levels decreased during the three months ended December 31, 2019, primarily due to a decrease in exposure levels subject to Stressed Value at Risk and 

Incremental Risk charges. Risk levels decreased during the 12 months ended December 31, 2019, primarily due to a decrease in exposure levels subject to 
Stressed Value at Risk.  

(10)  Operational risk-weighted assets decreased during the 12 months ended December 31, 2019, primarily due to changes in operational loss severity and frequency.

decrease in operational risk-weighted assets was primarily due 
to changes in operational loss severity and frequency.

As set forth in the table above, total risk-weighted assets 

under the Basel III Advanced Approaches increased from year-
end 2018 primarily due to an increase in credit risk-weighted 
assets, partially offset by decreases in market and operational 
risk-weighted assets. The increase in credit risk-weighted 
assets was primarily due to recognition of ROU assets in 
accordance with the adoption of ASU 2016-02, changes in 
OTC derivatives trade activities and increases in securitization 
exposures, loan exposures and equity exposures, partially 
offset by decreases in derivatives CVA and wholesale 
exposures mainly due to annual model parameter updates. 
Market risk-weighted assets decreased from year-end 2018, 
primarily due to a net reduction in exposure levels. The 

38

Supplementary Leverage Ratio
The following table sets forth Citi’s Supplementary Leverage 
ratio and related components as of December 31, 2019, 
September 30, 2019 and December 31, 2018:

In millions of dollars, except ratios

Tier 1 Capital

Total Leverage Exposure

On-balance sheet assets(1)
Certain off-balance sheet exposures:(2)

   Potential future exposure on derivative contracts
   Effective notional of sold credit derivatives, net(3)
   Counterparty credit risk for repo-style transactions(4)
   Unconditionally cancelable commitments
   Other off-balance sheet exposures

Total of certain off-balance sheet exposures

Less: Tier 1 Capital deductions

Total Leverage Exposure

Supplementary Leverage ratio

December 31, 2019

September 30, 2019 December 31, 2018

$

$

$

$

155,805

1,996,617

169,478

38,481

23,715

70,870
248,308

550,852

39,578

2,507,891

6.21%

$

$

$

$

158,033

2,000,082

176,546

41,328

24,362

70,648
246,793

559,677

39,407

2,520,352

6.27%

$

$

$

$

158,122

1,936,791

187,130

49,402

23,715

69,630
238,805

568,682

39,832

2,465,641

6.41%

(1)  Represents the daily average of on-balance sheet assets for the quarter.
(2)  Represents the average of certain off-balance sheet exposures calculated as of the last day of each month in the quarter. 
(3)  Under the U.S. Basel III rules, banking organizations are required to include in Total Leverage Exposure the effective notional amount of sold credit derivatives, 

with netting of exposures permitted if certain conditions are met. 

(4)  Repo-style transactions include repurchase or reverse repurchase transactions as well as securities borrowing or securities lending transactions.

As set forth in the table above, Citigroup’s Supplementary 

Leverage ratio was 6.2% at December 31, 2019, compared to 
6.3% at September 30, 2019 and 6.4% at December 31, 2018. 
The quarter-over-quarter decrease was primarily driven by a 
reduction in Tier 1 Capital resulting from the return of $6.2 
billion of capital to common shareholders and a preferred 
stock redemption, partially offset by net income and beneficial 
net movements in AOCI, as well as a decrease in average off-
balance sheet exposures. The year-over-year decrease was 
primarily driven by a reduction in Tier 1 Capital resulting 
from the return of $22.3 billion of capital to common 
shareholders, as well as an increase in average on-balance 
sheet assets, partially offset by net income and beneficial net 
movements in AOCI, as well as a decrease in average off-
balance sheet exposures.

39

Capital Resources of Citigroup’s Subsidiary U.S. 
Depository Institutions 
Citigroup’s subsidiary U.S. depository institutions are also 
subject to regulatory capital standards issued by their 
respective primary federal bank regulatory agencies, which are 
similar to the standards of the Federal Reserve Board. 

The following tables set forth the capital components and 

ratios for Citibank, Citi’s primary subsidiary U.S. depository 

institution, as of December 31, 2019, September 30, 2019 and 
December 31, 2018:

Effective 
Minimum 
Requirement(1)

In millions of dollars, except ratios

2019

2018

Advanced Approaches

Standardized Approach

Dec. 31,
2019

Sept. 30,
2019

Dec. 31,
2018

Dec. 31,
2019

Sept. 30,
2019

Dec. 31,
2018

Common Equity Tier 1 Capital

$ 130,791

$

130,067

$

129,091

$ 130,791

$

130,067

$

129,091

Tier 1 Capital

Total Capital (Tier 1 Capital + 
Tier 2 Capital)(2)
Total Risk-Weighted Assets

   Credit Risk

   Market Risk

   Operational Risk

Common Equity Tier 1 Capital 
ratio(3)(4)
Tier 1 Capital ratio(3)(4)
Total Capital ratio(3)(4)

132,918

132,198

131,215

132,918

132,198

131,215

145,989

932,432

144,829

946,433

144,358

926,229

157,324

155,735

155,154

1,019,916

1,047,550

1,032,809

$ 664,828

$

664,014

$

654,962

$ 990,319

$ 1,005,337

$

994,294

29,167

238,437

41,867

240,552

38,144

233,123

29,597

—

42,213

38,515

—

—

7.0% 6.375%

14.03%

13.74%

13.94%

12.82%

12.42%

12.50%

8.5

10.5

7.875

9.875

14.26

15.66

13.97

15.30

14.17

15.59

13.03

15.43

12.62

14.87

12.70

15.02

In millions of dollars, except ratios
Quarterly Adjusted Average Total Assets(5)
Total Leverage Exposure(6) 
Tier 1 Leverage ratio(4)
Supplementary Leverage ratio(4)

Effective
Minimum
Requirement

Dec. 31, 2019

Sept. 30, 2019

Dec. 31, 2018

$

1,459,851

$

1,451,352

$

4.0%

6.0

1,951,701

1,952,628

9.10%

6.81

9.11%

6.77

1,398,875

1,914,663

9.38%

6.85

(1)  Citibank’s effective minimum risk-based capital requirements during 2019 and 2018 are inclusive of the 100% and 75% phase-in, respectively, of the 2.5% Capital 

Conservation Buffer (all of which must be composed of Common Equity Tier 1 Capital).

(2)  Under the Advanced Approaches framework, eligible credit reserves that exceed expected credit losses are eligible for inclusion in Tier 2 Capital to the extent that 

the excess reserves do not exceed 0.6% of credit risk-weighted assets, which differs from the Standardized Approach in which the allowance for credit losses is 
eligible for inclusion in Tier 2 Capital up to 1.25% of credit risk-weighted assets, with any excess allowance for credit losses being deducted in arriving at credit 
risk-weighted assets.

(3)  Citibank’s reportable Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios were the lower derived under the Basel III Standardized Approach for 

all periods presented.

(4)  Citibank must maintain minimum Common Equity Tier 1 Capital, Tier 1 Capital, Total Capital and Tier 1 Leverage ratios of 6.5%, 8.0%, 10.0% and 5.0%, 

respectively, to be considered “well capitalized” under the revised Prompt Corrective Action (PCA) regulations applicable to insured depository institutions as 
established by the U.S. Basel III rules. Citibank must also maintain a minimum Supplementary Leverage ratio of 6.0% to be considered “well capitalized.”

(5)  Tier 1 Leverage ratio denominator. Represents quarterly average total assets less amounts deducted from Tier 1 Capital.
(6)  Supplementary Leverage ratio denominator.

As indicated in the table above, Citibank’s capital ratios at 

December 31, 2019 were in excess of the stated and effective 
minimum requirements under the U.S. Basel III rules. In 
addition, Citibank was also “well capitalized” as of December 
31, 2019. 

40

Impact of Changes on Citigroup and Citibank Capital Ratios 
The following tables present the estimated sensitivity of 
Citigroup’s and Citibank’s capital ratios to changes of $100 
million in Common Equity Tier 1 Capital, Tier 1 Capital and 
Total Capital (numerator), and changes of $1 billion in 
Advanced Approaches and Standardized Approach risk-
weighted assets and quarterly adjusted average total assets, as 
well as Total Leverage Exposure (denominator), as of 
December 31, 2019. This information is provided for the 
purpose of analyzing the impact that a change in Citigroup’s 

or Citibank’s financial position or results of operations could 
have on these ratios. These sensitivities only consider a single 
change to either a component of capital, risk-weighted assets, 
quarterly adjusted average total assets or Total Leverage 
Exposure. Accordingly, an event that affects more than one 
factor may have a larger basis point impact than is reflected in 
these tables.

Common Equity 
Tier 1 Capital ratio

Impact of
$100 million
change in
Common 
Equity
Tier 1 Capital

Impact of
$1 billion
change in 
risk-
weighted 
assets

0.9

0.9

1.1

1.0

1.1

1.0

1.5

1.3

Tier 1 Capital ratio

Total Capital ratio

Impact of
$100 million
change in
Tier 1 Capital

0.9

0.9

1.1

1.0

Impact of
$1 billion
change in 
risk-
weighted 
assets

1.2

1.1

1.5

1.3

Impact of
$100 million
change in
Total Capital

0.9

0.9

1.1

1.0

Impact of
$1 billion
change in 
risk-
weighted 
assets

1.4

1.4

1.7

1.5

In basis points
Citigroup

Advanced Approaches

Standardized Approach

Citibank

Advanced Approaches

Standardized Approach

In basis points

Citigroup

Citibank

Tier 1 Leverage ratio

Supplementary Leverage ratio

Impact of
$1 billion
change in 
quarterly 
adjusted 
average total 
assets

0.4

0.6

Impact of
$100 million
change in
Tier 1 Capital

0.4

0.5

Impact of
$1 billion
change in 
Total 
Leverage 
Exposure

0.2

0.3

Impact of
$100 million
change in
Tier 1 Capital

0.5

0.7

Citigroup Broker-Dealer Subsidiaries
At December 31, 2019, Citigroup Global Markets Inc., a U.S. 
broker-dealer registered with the SEC that is an indirect 
wholly owned subsidiary of Citigroup, had net capital, 
computed in accordance with the SEC’s net capital rule, of 
$10.1 billion, which exceeded the minimum requirement by 
$6.9 billion. 

Moreover, Citigroup Global Markets Limited, a broker-

dealer registered with the United Kingdom’s Prudential 
Regulation Authority (PRA) that is also an indirect wholly 
owned subsidiary of Citigroup, had total capital of $21.4 
billion at December 31, 2019, which exceeded the PRA's 
minimum regulatory capital requirements. 

In addition, certain of Citi’s other broker-dealer 

subsidiaries are subject to regulation in the countries in which 
they do business, including requirements to maintain specified 
levels of net capital or its equivalent. Citigroup’s other 
principal broker-dealer subsidiaries were in compliance with 
their regulatory capital requirements at December 31, 2019. 

41

Total Loss-Absorbing Capacity (TLAC) 
The table below details Citi’s eligible external TLAC and LTD 
amounts and ratios, and each effective minimum TLAC and 
long-term debt (LTD) ratio requirement, as well as the surplus 
amount in dollars in excess of each requirement. 

As of December 31, 2019, Citi exceeded each of the 

minimum TLAC and LTD requirements, resulting in a $14 
billion surplus above its binding TLAC requirement of LTD as 
a percentage of Total Leverage Exposure.

In billions of dollars, except ratios

December 31, 2019

External 
TLAC

LTD

Total eligible amount

$

289

$

127

% of Standardized Approach risk-
  weighted assets
Effective minimum requirement(1)(2)

Surplus amount

% of Total Leverage Exposure

Effective minimum requirement

Surplus amount

24.7%

22.5

26

$

10.9%

9.0

22

11.5%

5.1%

9.5

50

$

4.5

14

$

$

(1)  External TLAC includes method 1 GSIB surcharge of 2.0%.
(2)  LTD includes method 2 GSIB surcharge of 3.0%.

For additional information on Citi’s TLAC-related 
requirements, see “Liquidity Risk—Long-Term Debt—Total 
Loss-Absorbing Capacity (TLAC)” and “Risk Factors—
Compliance, Conduct and Legal Risks” below.

Regulatory Capital Treatment—Implementation and 
Transition of the Current Expected Credit Losses (CECL) 
Methodology
In February 2019, the U.S. banking agencies issued a final rule 
that provides banking organizations an optional phase-in over 
a three-year period of the “Day One” adverse regulatory 
capital effects resulting from adoption of the CECL 
methodology. 

The rule is in recognition of the issuance by the Financial 
Accounting Standards Board of ASU No. 2016-13, Financial 
Instruments—Credit Losses (Topic 326). The ASU introduces 
a new credit loss methodology, the CECL methodology, which 
requires earlier recognition of credit losses while also 
providing additional transparency about credit risk. The ASU 
was effective for Citi as of January 1, 2020. For additional 
information regarding Citi’s adoption of the CECL 
methodology, see Note 1 to the Consolidated Financial 
Statements.

Citi and Citibank have elected the transition provisions 
provided by the U.S. banking agencies’ rule. Accordingly, the 
“Day One” regulatory capital effects resulting from adoption 
of the CECL methodology commenced phase-in on January 1, 
2020, and will be fully reflected in Citi’s regulatory capital as 
of January 1, 2023. Based on Citi’s regulatory capital position 
as of December 31, 2019, the estimated impact of adopting the 
CECL methodology would reduce Citi’s Common Equity Tier 
1 Capital ratio under the Standardized Approach by 
approximately 25 basis points in total, or approximately 6 

42

basis points per year on January 1 of each year over the 
transition period. The actual basis point impact of adopting 
CECL on Citi’s regulatory capital ratios may change, if Citi’s 
capital position changes over time. 

The Federal Reserve Board has issued a statement that it 

plans to maintain its current framework for calculating 
allowances on loans in the supervisory stress test for the 2020 
and 2021 supervisory stress test cycles, and to evaluate 
appropriate future enhancements to this framework as best 
practices for implementing CECL are developed. However, 
banking organizations are required to incorporate CECL into 
their stress testing methodologies, data and disclosure 
beginning in the cycle coinciding with their first full year of 
CECL adoption (2020 for Citi). 

Regulatory Capital Standards Developments
The U.S. banking agencies and the Basel Committee issued 
numerous proposed and final rules on a variety of topics in 
2019. In the U.S., the most significant rule finalized in 2019 
relates to the calculation of risk-weighted assets for derivative 
contracts, while the Stress Capital Buffer proposal from 2018 
has not yet been finalized. The Basel Committee, among other 
things, finalized revisions to the minimum capital 
requirements for market risk and proposed revisions to its 
credit valuation adjustment risk framework.

U.S. Banking Agencies

Standardized Approach for Counterparty Credit Risk
In November 2019, the U.S. banking agencies released a final 
rule to introduce the Standardized Approach for Counterparty 
Credit Risk (SA-CCR) in the U.S. SA-CCR will replace the 
Current Exposure Method (CEM), which is the current 
methodology used to calculate risk-weighted assets for all 
derivative contracts under the Standardized Approach, as well 
as risk-weighted assets for derivative contracts under the 
Advanced Approaches in cases where internal models are not 
used. In addition, SA-CCR would replace CEM in numerous 
other instances throughout the regulatory framework, 
including but not limited to the Supplementary Leverage 
Ratio, single counterparty credit limits and legal lending 
limits. 

Under SA-CCR, a banking organization would calculate 
the exposure amount of its derivative contracts at the netting 
set level. Multiple derivative contracts would generally be 
considered to be under the same netting set as long as each 
derivative contract is subject to the same qualifying master 
netting agreement. SA-CCR also introduces the concept of 
hedging sets, which would allow a banking organization to 
fully or partially net derivative contracts within the same 
netting set that share similar risk factors. Moreover, SA-CCR 
incorporates updated supervisory and maturity factors to 
calculate the potential future exposure of a derivative contract, 
and provides for improved recognition of collateral. Under the 
proposal, the exposure amount of a netting set would be equal 
to an alpha factor of 1.4 multiplied by the sum of the 
replacement cost and potential future exposure of the netting 
set.

The mandatory compliance date of the final rule is 
January 1, 2022, with early adoption permitted beginning 
April 1, 2020. Citi’s SA-CCR implementation efforts are 
already underway. Citi is currently evaluating a decision on its 
intended implementation date for SA-CCR, including 
consideration of the impact of SA-CCR on both Citigroup’s 
and Citibank’s regulatory capital ratios.

Stress Capital Buffer
In April 2018, the Federal Reserve Board issued a proposal 
that is designed to more closely integrate the results of the 
quantitative assessment in CCAR with firms’ ongoing 
minimum capital requirements under the U.S. Basel III rules.

Specifically, the proposed rule would replace the existing 
Capital Conservation Buffer, currently fixed at 2.5% under the 
U.S. Basel III rules, with (i) a variable buffer known as the 
Stress Capital Buffer (as described below), plus (ii) for U.S. 
GSIBs, the GSIB’s then-current GSIB surcharge, plus (iii) the 
Countercyclical Capital Buffer, if any. These three 
components would constitute the new Capital Conservation 
Buffer under the Standardized Approach. The Stress Capital 
Buffer (SCB) would be based upon the maximum decline in a 
bank holding company’s Common Equity Tier 1 Capital ratio 
under the severely adverse scenario of the supervisory stress 
test. Under the April 2018 proposal, the SCB would be subject 
to a floor of 2.5%. 

The proposed rule would also modify certain assumptions 

currently required in supervisory stress tests, including 
continued capital distributions during the nine-quarter capital 
planning horizon and balance sheet growth assumptions.

A final rule has not yet been issued. Senior staff at the 
Federal Reserve Board have indicated publicly that they plan 
to finalize certain components of the proposal for application 
in the 2020 CCAR cycle, and that they may re-propose certain 
other elements of the proposal to better balance the need to 
preserve the dynamism of stress testing while reducing 
unnecessary volatility, among other things. Senior staff at the 
Federal Reserve Board have also indicated publicly that they 
are considering two options in place of the “dividend add-on,” 
which was a component of the SCB under the April 2018 
proposal: setting the Countercyclical Capital Buffer at a higher 
baseline level during normal times, or raising the floor of the 
SCB higher than 2.5%. The potential re-proposal may also 
address certain other elements of the original proposal, such as 
the relative timing between stress testing results and the 
submission of a firm’s capital plan, and the consequences of 
breaching a buffer.

TLAC Holdings
In April 2019, the U.S. banking agencies released a proposal 
that would create a new regulatory capital deduction 
applicable to Advanced Approaches banking organizations for 
certain investments in covered debt instruments issued by 
GSIBs. The proposed rule is intended to reduce systemic risk 
by creating an incentive for Advanced Approaches banking 
organizations to limit their exposure to GSIBs. 

Under the U.S. Basel III rules, investments in the capital 

of unconsolidated financial institutions are subject to 
deduction to the extent that they exceed certain thresholds. 

43

Under the proposed rule, an investment in a “covered debt 
instrument” would be treated as an investment in a Tier 2 
capital instrument and, therefore, would be subject to 
deduction from the Advanced Approaches banking 
organization’s own Tier 2 Capital in accordance with the 
existing rules for investments in unconsolidated financial 
institutions. Covered debt instruments would include 
unsecured debt instruments that are “eligible debt securities” 
for purposes of the TLAC rule, or that are pari passu or 
subordinated to such securities, in addition to certain 
unsecured debt instruments issued by foreign GSIBs.

To support a deep and liquid market for covered debt 
instruments, the proposed rule provides an exception from the 
approach described above for covered debt instruments held 
for 30 days or less for market-making purposes, if the 
aggregate amount of such debt instruments does not exceed 
5% of the banking organization’s Common Equity Tier 1 
Capital. 

The proposed rule does not specify a proposed effective 

date for the new regulatory capital deduction. If adopted as 
proposed, Citi does not expect the proposed rule to have a 
material impact on its regulatory capital.

Basel Committee 

Revisions to the Minimum Capital Requirements for 
Market Risk
In January 2019, the Basel Committee issued a final standard 
that revises the market risk capital framework—the so-called 
Fundamental Review of the Trading Book, or FRTB. The final 
rule revises the assessment process under the Advanced 
Approaches to determine whether a bank’s internal risk 
management models appropriately reflect the risks of 
individual trading desks, and clarifies the requirements for 
identification of risk factors that are eligible for internal 
modeling. In addition, the risk weights for general interest rate 
risk and foreign exchange risk under the Standardized 
Approach have been recalibrated. 

If the U.S. banking agencies were to adopt the Basel 
Committee’s revised market risk framework unchanged, Citi 
believes its market risk-weighted assets could increase 
significantly. The ultimate impact on Citi, however, will 
depend upon the specific provisions of any final rule.

Leverage Ratio Treatment of Client-Cleared Derivatives
In June 2019, the Basel Committee on Banking Supervision 
issued a final standard that revises its leverage ratio 
framework to align the leverage ratio measurement of client-
cleared derivatives with the measurement as determined per 
the Basel Committee’s standardized approach for measuring 
counterparty credit risk exposures, as used for risk-based 
capital requirements. Under the Basel Committee’s leverage 
ratio framework, the leverage ratio exposure measure is 
generally not adjusted for physical or financial collateral, 
guarantees or other credit risk mitigation techniques, including 
initial margin received from clients. However, the final rule 
permits both cash and non-cash forms of initial margin and 
variation margin received from clients to mitigate replacement 
cost and potential future exposure for client-cleared 

derivatives only. The Basel Committee stated in the rule that 
this revision balances the robustness of the leverage ratio as a 
non-risk-based safeguard against unsustainable sources of 
leverage with the policy objective of promoting central 
clearing of standardized derivative contracts.

In the U.S., the Basel Committee’s leverage ratio 
framework and leverage ratio exposure measure are most 
closely aligned with the Supplementary Leverage Ratio and 
Total Leverage Exposure, respectively. As part of the SA-CCR 
final rule discussed previously, the U.S. agencies amended the 
Supplementary Leverage Ratio requirements in a manner 
similar to the Basel Committee. This particular aspect of the 
U.S. SA-CCR final rule will likely benefit Citi’s 
Supplementary Leverage Ratio modestly upon 
implementation. 

Credit Valuation Adjustment Risk—Targeted Revisions
In November 2019, the Basel Committee on Banking 
Supervision issued a consultative document that proposes a 
targeted set of revisions to the credit valuation adjustment 
(CVA) risk framework previously finalized in December 2017. 
The revisions aim to align the revised CVA risk framework, in 
part, with the revised market risk capital framework that was 
finalized in January 2019. The Basel Committee also sought 
feedback on a possible adjustment to the overall calibration of 
capital requirements calculated under their CVA risk 
framework.

The U.S. agencies may consider revisions to the CVA risk 

framework under the U.S. Basel III rules in the future, based 
upon any revisions adopted by the Basel Committee.

44

Tangible Common Equity, Book Value Per Share, Tangible 
Book Value Per Share and Returns on Equity
Tangible common equity (TCE), as defined by Citi, represents 
common stockholders’ equity less goodwill and identifiable 
intangible assets (other than MSRs). Other companies may 
calculate TCE in a different manner. TCE, tangible book value 
(TBV) per share and return on average TCE are non-GAAP 
financial measures. Citi believes the presentation of TCE, 
TBV per share and return on average TCE provides alternate 
measures of capital strength and performance that are 
commonly used by investors and industry analysts.

In millions of dollars or shares, except per share amounts

Total Citigroup stockholders’ equity

Less: Preferred stock

Common stockholders’ equity

Less:

    Goodwill

    Identifiable intangible assets (other than MSRs)

$

$

2019

193,242

17,980

175,262

22,126

4,327

    Goodwill and identifiable intangible assets (other than                       
      MSRs) related to assets held-for-sale (HFS)

—

Tangible common equity (TCE)

Common shares outstanding (CSO)

Book value per share (common equity/CSO)

Tangible book value per share (TCE/CSO)

$

$

148,809

2,114.1

82.90

70.39

In millions of dollars

2019

At December 31,

2018

2017

2016

2015

$

$

$

$

$

$

$

$

196,220

18,460

177,760

22,046

4,636

—

151,078

2,368.5

75.05

63.79

$

$

$

$

200,740

19,253

181,487

22,256

4,588

32

154,611

2,569.9

70.62

60.16

$

$

$

$

225,120

19,253

205,867

21,659

5,114

72

179,022

2,772.4

74.26

64.57

For the Year Ended December 31,
2017(1)

2016

2018

221,857

16,718

205,139

22,349

3,721

68

179,001

2,953.3

69.46

60.61

2015

16,473

204,188

176,505

Net income available to common shareholders

$

18,292

$

16,871

$

14,583

$

13,835

$

Average common stockholders’ equity

Average TCE

Return on average common stockholders’ equity
Return on average TCE (RoTCE)(2)

177,363

150,994

10.3%

12.1

179,497

153,343

9.4%

11.0

207,747

180,458

209,629

182,135

7.0%

8.1

6.6%

7.6

8.1%

9.3

(1)  Year ended December 31, 2017 excludes the one-time impact of Tax Reform. For a reconciliation of these measures, see “Significant Accounting Policies and 

Significant Estimates—Income Taxes” below.

(2)  RoTCE represents net income available to common shareholders as a percentage of average TCE.

45

RISK FACTORS

The following discussion sets forth what management 
currently believes could be the most significant risks and 
uncertainties that could impact Citi’s businesses, results of 
operations and financial condition. Other risks and 
uncertainties, including those not currently known to Citi or its 
management, could also negatively impact Citi’s businesses, 
results of operations and financial condition. Thus, the 
following should not be considered a complete discussion of 
all of the risks and uncertainties Citi may face.

STRATEGIC RISKS

Citi’s Ability to Return Capital to Common Shareholders 
Consistent with Its Capital Planning Efforts and Targets 
Substantially Depends on the CCAR Process and the Results 
of Regulatory Stress Tests.
Citi’s ability to return capital to its common shareholders 
consistent with its capital planning efforts and targets, whether 
through its common stock dividend or through a share 
repurchase program, substantially depends, among other 
things, on regulatory approval, including through the CCAR 
process required by the Federal Reserve Board (FRB) and the 
supervisory stress tests required under the Dodd-Frank Act. 
The ability to return capital also depends on Citi’s results of
operations and effectiveness in managing its level of risk-
weighted assets and GSIB surcharge. Citi’s ability to 
accurately predict, interpret or explain to stakeholders the 
outcome of the CCAR process, and thus to address any market 
or investor perceptions, may be limited as the FRB’s 
assessment of Citi’s capital adequacy is conducted using the 
FRB’s proprietary stress test models. In addition, all CCAR 
firms, including Citi, will continue to be subject to a rigorous 
evaluation of their capital planning practices, including, but 
not limited to, governance, risk management and internal 
controls. For additional information on Citi’s return of capital 
to common shareholders in 2019 as well as the CCAR process, 
supervisory stress test requirements and GSIB surcharge, see 
“Capital Resources—Overview” and “Capital Resources—
Current Regulatory Capital Standards—Stress Testing 
Component of Capital Planning” above and the risk 
management risk factor below. 

The FRB has stated that it expects leading capital 

adequacy practices to continue to evolve and to likely be 
determined by the FRB each year as a result of its cross-firm 
review of capital plan submissions. Similarly, the FRB has 
indicated that, as part of its stated goal to continually evolve 
its annual stress testing requirements, several parameters of 
the annual stress testing process may continue to be altered, 
including the severity of the stress test scenario, the FRB 
modeling of Citi’s balance sheet and the addition of 
components deemed important by the FRB. 

Citi will be required to incorporate the current expected 

credit losses (CECL) methodology into its stress testing 
methodologies, data and disclosure beginning with the 2020 
supervisory stress test cycle. The FRB has stated that it plans 
to maintain its current framework for calculating allowances 
on loans in the supervisory stress test for the 2020 and 2021 

46

supervisory stress test cycles, and to evaluate appropriate 
future enhancements to this framework as best practices for 
implementing CECL are developed. The impacts on Citi’s 
capital adequacy of incorporating CECL on an ongoing basis, 
and of other potential regulatory changes in the FRB’s stress 
testing methodologies, remain unclear. For additional 
information regarding the CECL methodology, including the 
transition provisions related to the “Day One” adverse 
regulatory capital effects resulting from adoption of the CECL 
methodology, see “Capital Resources—Current Regulatory 
Capital Standards—Regulatory Capital Treatment—
Implementation and Transition of the Current Expected Credit 
Losses (CECL) Methodology” above and Note 1 to the 
Consolidated Financial Statements.

In addition, in 2018, the FRB proposed to more closely 
integrate the results of the quantitative assessment in CCAR 
with firms’ ongoing minimum capital requirements under the 
U.S. Basel III rules. Proposed changes to the stress testing 
regime include, among others, introduction of a firm-specific 
“stress capital buffer” (SCB), which would be equal to the 
maximum decline in a firm’s Common Equity Tier 1 Capital 
ratio under a severely adverse scenario over a nine-quarter 
CCAR measurement period, subject to a minimum 
requirement of 2.5%. The FRB proposed that the SCB would 
replace the capital conservation buffer in Citi’s ongoing 
regulatory capital requirements for Standardized Approach 
capital ratios. The SCB would be calculated by the FRB using 
its proprietary data and modeling of each firm’s results. 
Accordingly, a firm’s SCB would change annually based on 
the supervisory stress test results, thus potentially resulting in 
year-to-year volatility in the calculation of the SCB. For 
additional information on the FRB’s proposal, including 
calculation of the SCB, see “Capital Resources—Regulatory 
Capital Standards Developments” above.

Although various uncertainties exist regarding the extent 

of, and the ultimate impact to Citi from, these changes to the 
FRB’s stress testing and CCAR regimes, these changes would 
likely increase the level of capital Citi is required or elects to 
hold, including as part of Citi’s estimated management buffer, 
thus potentially impacting the extent to which Citi is able to 
return capital to shareholders.

Macroeconomic, Geopolitical and Other Challenges and 
Uncertainties Globally Could Have a Negative Impact on 
Citi’s Businesses and Results of Operations.
Citi has experienced, and could experience in the future, 
negative impacts to its businesses and results of operations as 
a result of macroeconomic, geopolitical and other challenges, 
uncertainties and volatility. For example, protracted or 
widespread trade tensions, including changes in trade policies, 
which have resulted in retaliatory measures from other 
countries, could result in a further reduction or realignment of 
trade flows among countries and negatively impact businesses, 
sectors and economic growth rates. In addition, adverse 
developments or downturns in one or more of the world’s 
larger economies would likely have a significant impact on the 
global economy or the economies of other countries because 
of global financial and economic linkages. Additional areas of 
uncertainty include, among others, geopolitical tensions and 

conflicts, natural disasters, pandemics and election outcomes. 
For example, it was reported in January 2020 that a novel 
strain of coronavirus which first surfaced in China, had spread 
to several other countries, resulting in various uncertainties, 
including the potential impact to Asian and global economies, 
trade and consumer and corporate clients.

Governmental fiscal and monetary actions, or expected 

actions, such as changes in interest rate policies and any 
program implemented by a central bank to change the size of 
its balance sheet, could significantly impact interest rates, 
economic growth rates, the volatility of global financial 
markets, foreign exchange rates and capital flows among 
countries. For example, in 2019, the FRB reduced its 
benchmark U.S. interest rate three times to add additional 
stimulus to the U.S. economy. The interest rates on Citi loans 
are typically based off or set at a spread over a benchmark 
interest rate, including the U.S. benchmark interest rate, and 
are therefore likely to decline as benchmark rates decline. By 
contrast, the interest rates at which Citi pays depositors are 
already low and unlikely to decline much further. 
Consequently, declining loan rates and largely unchanged 
deposit rates would likely compress Citi’s net interest revenue. 
Citi’s net interest revenue could also be adversely affected due 
to a flattening of the interest rate yield curve (e.g., a lower 
spread between shorter-term versus longer-term interest rates), 
as Citi, similar to other banks, typically pays interest on 
deposits based on shorter-term interest rates and earns money 
on loans typically based on longer-term interest rates. For 
additional information on Citi’s interest rate risk, see 
“Managing Global Risk—Market Risk—Net Interest Revenue 
at Risk” below.

Despite the U.K.’s official withdrawal from the European 

Union (EU) as of January 31, 2020, numerous uncertainties 
continue to exist regarding the U.K.’s future relationship with 
the EU. For example, the terms of the U.K. withdrawal 
continue to be negotiated between the U.K. and the EU, 
including their future trading relationship. It remains unclear 
whether the parties will be able to agree on terms prior to the 
end of the currently scheduled transition period on December 
31, 2020. If no agreement is reached on terms of the exit in a 
timely manner, it would likely result in what is commonly 
referred to as a “no deal” or “hard” exit scenario. A hard exit 
scenario would result in the U.K. and EU losing reciprocal 
financial services license-passporting rights and require the 
U.K. to deal with the EU as a third-country regime, but 
without an equivalence regime or transition period in place. A 
hard exit scenario could cause severe disruptions in the 
movement of goods and services between the U.K. and EU 
countries and negatively impact financial markets and the 
U.K. and EU economies. Citi’s business and operations could 
be impacted by these and other factors, including the 
preparedness and reaction of clients, counterparties and 
financial markets infrastructure. For information about Citi’s 
actions to manage the U.K.’s exit from the EU, see “Managing 
Global Risk—Strategic Risk—Exit of U.K. from EU” below. 
Further, the economic and fiscal situations of some EU 
countries have remained fragile, and concerns and 
uncertainties remain in the U.K. and Europe over the resulting 
effects of the U.K.’s exit from the EU.

47

These and additional global macroeconomic, geopolitical 

and other challenges, uncertainties and volatilities have 
negatively impacted, and could continue to negatively impact, 
Citi’s businesses, results of operations and financial condition, 
including its credit costs, revenues in its Markets and 
securities services and other businesses, and AOCI (which 
would in turn negatively impact Citi’s book and tangible book 
value).

Citi, Its Management and Its Businesses Must Continually 
Review, Analyze and Successfully Adapt to Ongoing 
Regulatory and Legislative Uncertainties and Changes in the 
U.S. and Globally.
Despite the adoption of final regulations and laws in numerous 
areas impacting Citi and its businesses over the past several 
years, Citi, its management and its businesses continually face 
ongoing regulatory and legislative uncertainties and changes, 
both in the U.S. and globally. While the areas of ongoing 
regulatory and legislative uncertainties and changes facing Citi 
are too numerous to list completely, various examples include, 
but are not limited to (i) potential fiscal, monetary, regulatory 
and other changes arising from the U.S. federal government 
and others; (ii) potential changes to various aspects of the 
regulatory capital framework applicable to Citi (see the capital 
return risk factor and “Capital Resources—Regulatory Capital 
Standards Developments” above); and (iii) the terms of and 
other uncertainties resulting from the U.K.’s exit from the EU 
(see the macroeconomic challenges and uncertainties risk 
factor above). When referring to “regulatory,” Citi is including 
both formal regulation and the views and expectations of its 
regulators in their supervisory roles.

Ongoing regulatory and legislative uncertainties and 
changes make Citi’s and its management’s long-term business, 
balance sheet and budget planning difficult or subject to 
change. For example, U.S. and other regulators globally have 
implemented and continue to discuss various changes to 
certain regulatory requirements, which would require ongoing 
assessment by management as to the impact to Citi, its 
businesses and business planning. Business planning is 
required to be based on possible or proposed rules or 
outcomes, which can change dramatically upon finalization, or 
upon implementation or interpretive guidance from numerous 
regulatory bodies worldwide, and such guidance can change. 
Moreover, U.S. and international regulatory and 
legislative initiatives have not always been undertaken or 
implemented on a coordinated basis, and areas of divergence 
have developed and continue to develop with respect to the 
scope, interpretation, timing, structure or approach, leading to 
inconsistent or even conflicting requirements, including within 
a single jurisdiction. For example, in May 2019, the European 
Commission adopted, as part of Capital Requirements 
Directive V (CRD V), a new requirement for major banking 
groups headquartered outside the EU (which would include 
Citi) to establish an intermediate EU holding company where 
the foreign bank has two or more institutions (broadly 
meaning banks, broker-dealers and similar financial firms) 
established in the EU. While in some respects the requirement 
mirrors an existing U.S. requirement for non-U.S. banking 
organizations to form U.S. intermediate holding companies, 

the implementation of the EU holding company requirement 
could lead to additional complexity with respect to Citi’s 
resolution planning, capital and liquidity allocation and 
efficiency in various jurisdictions. Regulatory and legislative 
changes have also significantly increased Citi’s compliance 
risks and costs (see the implementation and interpretation of 
regulatory changes risk factor below).

Citi’s Continued Investments and Efficiency Initiatives May 
Not Be as Successful as It Projects or Expects. 
Citi continues to leverage its scale and make incremental 
investments to deepen client relationships, increase revenues 
and lower expenses. For example, Citi continues to make 
investments to enhance its digital capabilities across the 
franchise, including digital platforms and mobile and cloud-
based solutions, as well as make investments in risk 
management and controls. Citi also has been investing in 
higher-return businesses, such as the U.S. cards and wealth 
management businesses in Global Consumer Banking (GCB) 
and treasury and trade solutions, securities services and other 
businesses in Institutional Clients Group (ICG). Citi also 
continues to execute on its previously disclosed investment of 
more than $1 billion in Citibanamex. Further, Citi has been 
pursuing efficiency improvements through various technology 
and digital initiatives, organizational simplification and 
location strategies, which are intended to self-fund Citi’s 
incremental investment initiatives as well as offset growth-
driven expenses.

Citi’s investments and efficiency initiatives are being 

undertaken as part of its overall strategy to meet operational 
and financial objectives, including, among others, those 
relating to shareholder returns. There is no guarantee that these 
or other initiatives Citi may pursue will be as productive or 
effective as Citi expects, or at all. Citi’s investment and 
efficiency initiatives may continue to evolve as its business 
strategies and the market environment change, which could 
make the initiatives more costly and more challenging to 
implement, and limit their effectiveness. Moreover, Citi’s 
ability to achieve expected returns on its investments and costs 
savings depends, in part, on factors that it cannot control, such 
as macroeconomic conditions, customer, client and competitor 
actions and ongoing regulatory changes, among others.

Uncertainties Regarding the Transition Away from or 
Possible Discontinuance of the London Inter-Bank Offered 
Rate (LIBOR) or Any Other Interest Rate Benchmark Could 
Have Adverse Consequences for Market Participants, 
Including Citi. 
LIBOR is extensively used as a “benchmark” or “reference 
rate” across financial products and markets globally. The U.K. 
Financial Conduct Authority (FCA) has raised questions about 
the future sustainability of LIBOR, and, as a result, the FCA 
obtained voluntary panel bank support to sustain LIBOR only 
until 2021, and LIBOR is expected to be discontinued as early 
as January 1, 2022. In addition, following guidance provided 
by the Financial Stability Board, other regulators have 
suggested reforming or replacing other benchmark rates with 
alternative reference rates. Accordingly, the transition away 
from and discontinuance of LIBOR or any other benchmark 

48

rate presents various uncertainties, risks and challenges to 
financial markets and institutions, including Citi. These 
include, among others, the pricing, liquidity, value of, return 
on and market for financial instruments and contracts that 
reference LIBOR or any other applicable benchmark rate.

Citi issues, trades, holds or otherwise uses a substantial 

amount of securities or products that reference LIBOR, 
including, among others, derivatives, corporate loans, 
commercial and residential mortgages, credit cards, 
securitized products and other securities. The transition away 
from and discontinuation of LIBOR presents significant 
operational, legal, reputational or compliance, financial and 
other risks to Citi. For example, LIBOR transition presents 
various challenges related to contractual mechanics of existing 
floating rate financial instruments and contracts that reference 
LIBOR and mature after 2021. Certain of these instruments 
and contracts do not provide for alternative benchmark rates, 
which makes it unclear what the future benchmark rates would 
be after LIBOR’s cessation. Even if the instruments and 
contracts provide for a transition to alternative benchmark 
rates, the new benchmark rates may significantly differ from 
the prior rates. As a result, Citi may need to proactively 
address any contractual uncertainties or rate differences in 
such instruments and contracts, which would likely be both 
time consuming and costly. In addition, the transition away 
from and discontinuance of LIBOR could result in disputes, 
including litigation, involving holders of outstanding 
instruments and contracts that reference LIBOR, whether or 
not the underlying documentation provides for alternative 
benchmark rates. Citi will also need to develop significant 
internal systems and infrastructure to transition to alternative 
benchmark rates to both manage its businesses and support 
clients.

For additional information about Citi’s ongoing 

management of LIBOR transition risk, see “Managing Global 
Risk—Strategic Risk—LIBOR Transition Risk” below.

Citi’s Ability to Utilize Its DTAs, and Thus Reduce the 
Negative Impact of the DTAs on Citi’s Regulatory Capital, 
Will Be Driven by Its Ability to Generate U.S. Taxable 
Income.
At December 31, 2019, Citi’s net DTAs were $23.1 billion, net 
of a valuation allowance of $6.5 billion, of which $10.7 billion 
was excluded from Citi’s Common Equity Tier 1 Capital under 
the U.S. Basel III rules (for additional information, see 
“Capital Resources—Components of Citigroup Capital” 
above). Of the net DTAs at December 31, 2019, $6.3 billion 
related to foreign tax credit carry-forwards (FTCs), net of a 
valuation allowance. The carry-forward utilization period for 
FTCs is 10 years and represents the most time-sensitive 
component of Citi’s DTAs. The FTC carry-forwards at 
December 31, 2019 expire over the period of 2020–2029. Citi 
must utilize any FTCs generated in the then-current-year tax 
return prior to utilizing any carry-forward FTCs. 

The accounting treatment for realization of DTAs, 
including FTCs, is complex and requires significant judgment 
and estimates regarding future taxable earnings in the 
jurisdictions in which the DTAs arise and available tax 
planning strategies. Citi’s ability to utilize its DTAs will 

primarily be dependent upon Citi’s ability to generate U.S. 
taxable income in the relevant tax carry-forward periods. 
Although utilization of FTCs in any year is generally limited 
to 21% of foreign source taxable income in that year, overall 
domestic losses (ODL) that Citi has incurred in the past allow 
it to reclassify domestic source income as foreign source. 
Failure to realize any portion of the net DTAs would have a 
corresponding negative impact on Citi’s net income and 
financial returns. 

Citi does not expect to be subject to the Base Erosion 
Anti-Abuse Tax (BEAT), which, if applicable to Citi in any 
given year, would have a significantly adverse effect on both 
Citi’s net income and regulatory capital. 

For additional information on Citi’s DTAs, including 
FTCs, see “Significant Accounting Policies and Significant 
Estimates—Income Taxes” below and Notes 1 and 9 to the 
Consolidated Financial Statements.

Citi’s Interpretation or Application of the Complex Tax Laws 
to Which It Is Subject Could Differ from Those of the 
Relevant Governmental Authorities, Which Could Result in 
the Payment of Additional Taxes, Penalties or Interest.
Citi is subject to various income-based and non-income-based 
tax laws of the U.S. and its states and municipalities, as well 
as the numerous non-U.S. jurisdictions in which it operates. 
These tax laws are inherently complex and Citi must make 
judgments and interpretations about the application of these 
laws, including the Tax Cuts and Jobs Act (Tax Reform), to its 
entities, operations and businesses. Citi’s interpretations and 
application of the tax laws, including with respect to Tax 
Reform, withholding, stamp, service and other non-income 
taxes, could differ from that of the relevant governmental 
taxing authority, which could result in the payment of 
additional taxes, penalties or interest, which could be material.

Citi’s Presence in the Emerging Markets Subjects It to 
Various Risks as well as Increased Compliance and 
Regulatory Risks and Costs.
During 2019, emerging markets revenues accounted for 
approximately 37% of Citi’s total revenues (Citi generally 
defines emerging markets as countries in Latin America, Asia
(other than Japan, Australia and New Zealand), Central and 
Eastern Europe, the Middle East and Africa). Although Citi 
continues to pursue its target client strategy, Citi’s presence in 
the emerging markets subjects it to a number of risks, 
including limitations of hedges on foreign investments, 
foreign currency volatility, sovereign volatility, election 
outcomes, regulatory changes and political events, foreign 
exchange controls, limitations on foreign investment, 
sociopolitical instability (including from hyperinflation), 
fraud, nationalization or loss of licenses, business restrictions, 
sanctions or asset freezes, potential criminal charges, closure 
of branches or subsidiaries and confiscation of assets. For 
example, Citi operates in several countries that have, or have 
had in the past, strict foreign exchange controls, such as 
Argentina, that limit its ability to convert local currency into 
U.S. dollars and/or transfer funds outside of those countries. 
Moreover, if the economic situation in an emerging 
markets country where Citi operates were to deteriorate below 

49

a certain level, U.S. regulators may impose mandatory loan 
loss or other reserve requirements on Citi, which would 
increase its credit costs and decrease its earnings (see 
“Strategic Risk—Country Risk—Argentina” below for 
additional information on emerging markets risk). In addition, 
political turmoil and instability have occurred in certain 
regions and countries, including Asia, the Middle East and 
Latin America, which have required, and may continue to 
require, management time and attention and other resources 
(such as monitoring the impact of sanctions on certain 
emerging markets economies as well as impacting Citi’s 
businesses and results of operations in affected countries).

Citi’s emerging markets presence also increases its 
compliance and regulatory risks and costs. For example, Citi’s 
operations in emerging markets, including facilitating cross-
border transactions on behalf of its clients, subject it to higher 
compliance risks under U.S. regulations that are primarily 
focused on various aspects of global corporate activities, such 
as anti-money laundering regulations and the Foreign Corrupt 
Practices Act. These risks can be more acute in less developed 
markets and thus require substantial investment in compliance 
infrastructure or could result in a reduction in certain of Citi’s 
business activities. Any failure by Citi to comply with 
applicable U.S. regulations, as well as the regulations in the 
countries and markets in which it operates as a result of its 
global footprint, could result in fines, penalties, injunctions or 
other similar restrictions, many of which could negatively 
impact Citi’s results of operations and reputation (see the 
implementation and interpretation of regulatory changes and 
legal and regulatory proceedings risk factors below).

A Deterioration in or Failure to Maintain Citi’s Co-
Branding or Private Label Credit Card Relationships, 
Including as a Result of Any Bankruptcy or Liquidation, 
Could Have a Negative Impact on Citi’s Results of 
Operations or Financial Condition.
Citi has co-branding and private label relationships through its 
Citi-branded cards and Citi retail services credit card 
businesses with various retailers and merchants globally, 
whereby in the ordinary course of business Citi issues credit 
cards to customers of the retailers or merchants. Citi’s co-
branding and private label agreements provide for shared 
economics between the parties and generally have a fixed 
term. The five largest relationships, which include Sears, 
constituted an aggregate of approximately 11% of Citi’s 
revenues in 2019. These relationships could be negatively 
impacted by, among other things, the general economic 
environment, declining sales and revenues or other operational 
difficulties of the retailer or merchant, termination due to a 
contractual breach by Citi or by the retailer or merchant, or 
other factors, including bankruptcies, liquidations, 
restructurings, consolidations or other similar events. 

Over the last several years, a number of U.S. retailers 

have continued to experience declining sales, which has 
resulted in significant numbers of store closures and, in a 
number of cases, bankruptcies, as retailers attempt to cut costs 
and reorganize. For example, despite its exit from bankruptcy 
in 2019, Sears continues to close stores and experience 
declining sales (for additional information regarding Citi retail 

services’ co-brand and private label credit card products 
relationship with Sears, see “Global Consumer Banking—
North America GCB” above). In addition, as has been widely 
reported, competition among card issuers, including Citi, for 
these relationships is significant, and it has become 
increasingly difficult in recent years to maintain such 
relationships on the same terms or at all. 

While various mitigating factors could be available to 

Citi if any of the above events were to occur—such as by 
replacing the retailer or merchant or offering other card 
products—these events, particularly bankruptcies or 
liquidations, could negatively impact the results of operations 
or financial condition of Citi-branded cards, Citi retail services 
or Citi as a whole, including as a result of loss of revenues, 
increased expenses, higher cost of credit, impairment of 
purchased credit card relationships and contract-related 
intangibles or other losses (for information on Citi’s credit 
card related intangibles generally, see Note 16 to the 
Consolidated Financial Statements).

Citi’s Inability in Its Resolution Plan Submissions to Address 
Any Shortcomings or Deficiencies Identified or Guidance 
Provided by the FRB and FDIC Could Subject Citi to More 
Stringent Capital, Leverage or Liquidity Requirements, or 
Restrictions on Its Growth, Activities or Operations, and 
Could Eventually Require Citi to Divest Assets or 
Operations.
Title I of the Dodd-Frank Act requires Citi to prepare and 
submit a plan to the FRB and the FDIC for the orderly 
resolution of Citigroup (the bank holding company) and its 
significant legal entities under the U.S. Bankruptcy Code in 
the event of future material financial distress or failure. On 
December 17, 2019, the FRB and FDIC issued feedback on 
the resolution plans filed on July 1, 2019 by the eight U.S. 
GSIBs, including Citi. The FRB and FDIC identified one 
shortcoming, but no deficiencies, in Citi’s resolution plan 
relating to governance mechanisms. For additional 
information on Citi’s resolution plan submissions, see 
“Managing Global Risk—Liquidity Risk” below. 

Under Title I, if the FRB and the FDIC jointly determine 

that Citi’s resolution plan is not “credible” (which, although 
not defined, is generally believed to mean the regulators do
not believe the plan is feasible or would otherwise allow the 
regulators to resolve Citi in a way that protects systemically 
important functions without severe systemic disruption), or 
would not facilitate an orderly resolution of Citi under the 
U.S. Bankruptcy Code, and Citi fails to resubmit a resolution 
plan that remedies any identified deficiencies, Citi could be 
subjected to more stringent capital, leverage or liquidity 
requirements, or restrictions on its growth, activities or 
operations. If within two years from the imposition of any 
requirements or restrictions Citi has still not remediated any 
identified deficiencies, then Citi could eventually be required 
to divest certain assets or operations. Any such restrictions or 
actions would negatively impact Citi’s reputation, market and 
investor perception, operations and strategy. 

Citi’s Performance and the Performance of Its Individual 
Businesses Could Be Negatively Impacted if Citi Is Not Able 
to Effectively Compete for Highly Qualified Employees.
Citi’s performance and the performance of its individual 
businesses largely depends on the talents and efforts of its 
diverse and highly skilled employees. Specifically, Citi’s 
continued ability to compete in its businesses, to manage its 
businesses effectively and to continue to execute its overall 
global strategy depends on its ability to attract new employees 
and to retain and motivate its existing employees. If Citi is 
unable to continue to attract and retain the most highly 
qualified employees, Citi’s performance, including its 
competitive position, the successful execution of its overall 
strategy and its results of operations could be negatively 
impacted.

Citi’s ability to attract and retain employees depends on 

numerous factors, some of which are outside of its control. For 
example, the banking industry generally is subject to more 
comprehensive regulation of executive and employee 
compensation than other industries, including deferral and 
clawback requirements for incentive compensation. Citi often 
competes in the market for talent with entities that are not 
subject to such comprehensive regulatory requirements on the 
structure of incentive compensation, including, among others, 
technology companies. Other factors that could impact Citi’s 
ability to attract and retain employees include its culture and 
the management and leadership of the Company as well as its 
individual businesses, presence in the particular market or 
region at issue and the professional opportunities it offers. 

Financial Services Companies and Others as well as 
Emerging Technologies Pose Increasingly Competitive 
Challenges to Citi.
Citi operates in an increasingly competitive environment, 
which includes both financial and non-financial services firms, 
such as traditional banks, online banks, financial technology 
companies and others. These companies compete on the basis 
of, among other factors, size, quality and type of products and 
services offered, price, technology and reputation. Emerging 
technologies have the potential to intensify competition and 
accelerate disruption in the financial services industry. 

Citi competes with financial services companies in the 

U.S. and globally that continue to develop and introduce new 
products and services. In recent years, non-financial services 
firms, such as financial technology companies, have begun to 
offer services traditionally provided by financial institutions, 
such as Citi. These firms attempt to use technology and mobile 
platforms to enhance the ability of companies and individuals 
to borrow money, save and invest. To the extent that Citi is not 
able to compete effectively with these and other firms, Citi 
could be placed at a competitive disadvantage, which could 
result in loss of customers and market share, and its 
businesses, results of operations and financial condition could 
suffer. For additional information on Citi’s competitors, see 
the co-brand and private label cards risk factor above and 
“Supervision, Regulation and Other—Competition” below. 

50

OPERATIONAL RISKS

A Disruption of Citi’s Operational Systems Could Negatively 
Impact Citi’s Reputation, Customers, Clients, Businesses or 
Results of Operations and Financial Condition.
A significant portion of Citi’s operations relies heavily on the 
secure processing, storage and transmission of confidential 
data and other information as well as the monitoring of a large 
number of complex transactions on a minute-by-minute basis. 
For example, through GCB and treasury and trade solutions 
and securities services businesses in ICG, Citi obtains and 
stores an extensive amount of personal and client-specific 
information for its retail, corporate and governmental 
customers and clients and must accurately record and reflect 
their extensive account transactions.

With the evolving proliferation of new technologies and 

the increasing use of the internet, mobile devices and cloud 
technologies to conduct financial transactions, large global 
financial institutions such as Citi have been, and will continue 
to be, subject to an increasing risk of operational disruption or 
cyber or information security incidents from these activities 
(for additional information, see the cybersecurity risk factor 
below). These incidents are unpredictable and can arise from 
numerous sources, not all of which are in Citi’s control, 
including, among others, human error, fraud or malice on the 
part of employees, accidental technological failure, electrical 
or telecommunication outages, failures of computer servers or 
other similar damage to Citi’s property or assets. These issues 
can also arise as a result of failures by third parties with which 
Citi does business, such as failures by internet, mobile 
technology and cloud service providers or other vendors to 
adequately safeguard their systems and prevent system 
disruptions or cyber attacks. 

Such events could cause interruptions or malfunctions in 

the operations of Citi (such as the temporary loss of 
availability of Citi’s online banking system or mobile banking 
platform), as well as the operations of its clients, customers or 
other third parties. Given Citi’s global footprint and the high 
volume of transactions processed by Citi, certain errors or 
actions may be repeated or compounded before they are 
discovered and rectified, which would further increase these 
costs and consequences. Any such events could also result in 
financial losses as well as misappropriation, corruption or loss 
of confidential and other information or assets, which could 
negatively impact Citi’s reputation, customers, clients, 
businesses or results of operations and financial condition, 
perhaps significantly.

Citi’s and Third Parties’ Computer Systems and Networks 
Have Been, and Will Continue to Be, Susceptible to an 
Increasing Risk of Continually Evolving, Sophisticated 
Cybersecurity Activities That Could Result in the Theft, Loss, 
Misuse or Disclosure of Confidential Client or Customer 
Information, Damage to Citi’s Reputation, Additional Costs 
to Citi, Regulatory Penalties, Legal Exposure and Financial 
Losses.
Citi’s computer systems, software and networks are subject to 
ongoing cyber incidents such as unauthorized access, loss or 
destruction of data (including confidential client information), 
account takeovers, unavailability of service, computer viruses 

51

or other malicious code, cyber attacks and other similar 
events. These threats can arise from external parties, including 
cyber criminals, cyber terrorists, hacktivists and nation state 
actors, as well as insiders who knowingly or unknowingly 
engage in or enable malicious cyber activities.

Third parties with which Citi does business, as well as 
retailers and other third parties with which Citi’s customers do 
business, may also be sources of cybersecurity risks, 
particularly where activities of customers are beyond Citi’s 
security and control systems. For example, Citi outsources 
certain functions, such as processing customer credit card 
transactions, uploading content on customer-facing websites 
and developing software for new products and services. These 
relationships allow for the storage and processing of customer 
information by third-party hosting of or access to Citi 
websites, which could lead to compromise or the potential to 
introduce vulnerable or malicious code, resulting in security 
breaches impacting Citi customers. Furthermore, because 
financial institutions are becoming increasingly interconnected 
with central agents, exchanges and clearing houses, including 
as a result of the derivatives reforms over the last few years, 
Citi has increased exposure to cyber attacks through third 
parties. While many of Citi’s agreements with the third parties 
include indemnification provisions, Citi may not be able to 
recover sufficiently, or at all, under the provisions to 
adequately offset any losses Citi may incur from third-party 
cyber incidents.

Citi has been subject to intentional cyber incidents from 

external sources over the last several years, including (i) 
denial of service attacks, which attempted to interrupt service 
to clients and customers, (ii) data breaches, which obtained 
unauthorized access to customer account data and (iii) 
malicious software attacks on client systems, which attempted 
to allow unauthorized entrance to Citi’s systems under the 
guise of a client and the extraction of client data. While Citi’s 
monitoring and protection services were able to detect and 
respond to the incidents targeting its systems before they 
became significant, they still resulted in limited losses in some 
instances as well as increases in expenditures to monitor 
against the threat of similar future cyber incidents. There can 
be no assurance that such cyber incidents will not occur again, 
and they could occur more frequently and on a more 
significant scale.

Further, although Citi devotes significant resources to 

implement, maintain, monitor and regularly upgrade its 
systems and networks with measures such as intrusion 
detection and prevention and firewalls to safeguard critical 
business applications, there is no guarantee that these 
measures or any other measures can provide absolute security. 
Because the methods used to cause cyber attacks change 
frequently or, in some cases, are not recognized until launched
or even later, Citi may be unable to implement effective 
preventive measures or proactively address these methods 
until they are discovered. In addition, given the evolving 
nature of cyber threat actors and the frequency and 
sophistication of the cyber activities they carry out, the 
determination of the severity and potential impact of a cyber 
incident may not occur for a substantial period until after the 
incident has been discovered. Also, while Citi engages in

certain actions to reduce the exposure resulting from 
outsourcing, such as performing security control assessments 
of third-party vendors and limiting third-party access to the 
least privileged level necessary to perform job functions, these 
actions cannot prevent all third-party-related cyber attacks or 
data breaches.

Cyber incidents can result in the disclosure of personal, 

confidential or proprietary customer or client information, 
damage to Citi’s reputation with its clients and the market, 
customer dissatisfaction and additional costs to Citi, including 
expenses such as repairing systems, replacing customer 
payment cards, credit monitoring or adding new personnel or 
protection technologies. Regulatory penalties, loss of 
revenues, exposure to litigation and other financial losses, 
including loss of funds, to both Citi and its clients and 
customers and disruption to Citi’s operational systems could 
also result from cyber incidents (for additional information on 
the potential impact of operational disruptions, see the 
operational systems risk factor above). Moreover, the 
increasing risk of cyber incidents has resulted in increased 
legislative and regulatory scrutiny of firms’ cybersecurity 
protection services and calls for additional laws and 
regulations to further enhance protection of consumers’ 
personal data. 

While Citi maintains insurance coverage that may, 
subject to policy terms and conditions including significant 
self-insured deductibles, cover certain aspects of cyber risks, 
such insurance coverage may be insufficient to cover all 
losses. 

For additional information about Citi’s management of 
cybersecurity risk, see “Managing Global Risk—Operational 
Risk—Cybersecurity Risk” below.

Changes to or Incorrect Assumptions, Judgments or 
Estimates in Citi’s Financial Statements Could Cause 
Significant Unexpected Losses or Impacts in the Future.
U.S. GAAP requires Citi to use certain assumptions, 
judgments and estimates in preparing its financial statements, 
including the estimate of the allowance for credit losses, 
reserves related to litigation, regulatory and tax matters 
exposures, valuation of DTAs and the fair values of certain 
assets and liabilities, among other items. If Citi’s assumptions, 
judgments or estimates underlying its financial statements are 
incorrect or differ from actual or subsequent events, Citi could 
experience unexpected losses or other adverse impacts, some 
of which could be significant. For example, Citi has incurred 
losses related to its foreign operations that are reported in the 
foreign currency translation adjustment (CTA) components of 
Accumulated other comprehensive income (loss) (AOCI). In 
accordance with U.S. GAAP, a sale or substantial liquidation 
of any foreign operations, such as those related to Citi’s legacy 
businesses, would result in reclassification of any foreign CTA 
component of AOCI related to that foreign operation, 
including related hedges and taxes, into Citi’s earnings. For 
additional information on Citi’s accounting policy for foreign 
currency translation and its foreign CTA components of AOCI, 
see Notes 1 and 19 to the Consolidated Financial Statements.
In addition, changes to financial accounting or reporting 
standards or interpretations, whether promulgated or required 

52

by the FASB or other regulators, could present operational 
challenges and could also require Citi to change certain of the 
assumptions or estimates it previously used in preparing its 
financial statements, which could negatively impact how it 
records and reports its financial condition and results of 
operations generally and/or with respect to particular 
businesses (see the changes to financial accounting and 
reporting standards risk factor below). For additional 
information on the key areas for which assumptions and 
estimates are used in preparing Citi’s financial statements, see 
“Significant Accounting Policies and Significant Estimates” 
below and Notes 1 and 27 to the Consolidated Financial 
Statements.

Changes to Financial Accounting and Reporting Standards 
or Interpretations Could Have a Material Impact on How 
Citi Records and Reports Its Financial Condition and 
Results of Operations.
Periodically, the Financial Accounting Standards Board 
(FASB) issues financial accounting and reporting standards 
that may govern key aspects of Citi’s financial statements or 
interpretations thereof when those standards become effective, 
including those areas where Citi is required to make 
assumptions or estimates. For example, the FASB’s new 
accounting standard on credit losses (CECL), which became 
effective for Citi on January 1, 2020, requires earlier 
recognition of credit losses on loans and held-to-maturity 
securities and other financial assets. The CECL methodology 
requires that lifetime “expected credit losses” be recorded at 
the time the financial asset is originated or acquired. The 
expected credit losses are adjusted each period for changes in 
expected lifetime credit losses. The CECL methodology 
replaces the multiple existing impairment models under U.S. 
GAAP that generally required that a loss be “incurred” before 
it was recognized. The CECL methodology represents a 
significant change from existing GAAP and may result in 
material changes to Citi’s accounting for financial instruments. 
Citi’s ongoing estimates of its expected credit losses will 
depend upon its CECL models and assumptions, existing and 
forecasted macroeconomic conditions and the credit quality, 
composition and other characteristics of Citi’s loan and other 
applicable portfolios. These factors are likely to cause 
variability in Citi’s expected credit losses under CECL 
compared to previous GAAP and, thus, impact its results of 
operations and regulatory capital. For additional information 
on this and other accounting standards, including the expected 
impacts on Citi’s results of operations and financial condition, 
see Note 1 to the Consolidated Financial Statements. 

Citi May Incur Significant Losses and Its Regulatory Capital 
and Capital Ratios Could Be Negatively Impacted if Its Risk 
Management Processes, Strategies or Models Are Deficient 
or Ineffective.
Citi utilizes a broad and diversified set of risk management 
and mitigation processes and strategies, including the use of 
risk models in analyzing and monitoring the various risks Citi
assumes in conducting its activities. For example, Citi uses 
models as part of its comprehensive stress testing initiatives 
across Citi. Citi also relies on data to aggregate, assess and 

manage various risk exposures. Management of these risks is 
made even more challenging within a global financial 
institution such as Citi, particularly given the complex, diverse 
and rapidly changing financial markets and conditions in 
which Citi operates as well as that losses can occur from 
untimely, inaccurate or incomplete processes caused by 
unintentional human error.

These processes, strategies and models are inherently 

limited because they involve techniques, including the use of 
historical data in many circumstances, assumptions and 
judgments that cannot anticipate every economic and financial 
outcome in the markets in which Citi operates, nor can they 
anticipate the specifics and timing of such outcomes. Citi 
could incur significant losses, and its regulatory capital and 
capital ratios could be negatively impacted, if Citi’s risk 
management processes, including its ability to manage and 
aggregate data in a timely and accurate manner, strategies or 
models are deficient or ineffective. Such deficiencies or
ineffectiveness could also result in inaccurate financial, 
regulatory or risk reporting.

Moreover, Citi’s Basel III regulatory capital models, 

including its credit, market and operational risk models, 
currently remain subject to ongoing regulatory review and 
approval, which may result in refinements, modifications or 
enhancements (required or otherwise) to these models. 
Modifications or requirements resulting from these ongoing 
reviews, as well as any future changes or guidance provided 
by the U.S. banking agencies regarding the regulatory capital 
framework applicable to Citi, have resulted in, and could 
continue to result in, significant changes to Citi’s risk-
weighted assets. These changes can negatively impact Citi’s 
capital ratios and its ability to achieve its regulatory capital 
requirements as it projects or as required.

CREDIT RISKS

Credit Risk and Concentrations of Risk Can Increase the 
Potential for Citi to Incur Significant Losses.
Credit risk arises from Citi’s lending and other businesses in 
both GCB and ICG. Citi has credit exposures to counterparties 
in the U.S. and various countries and jurisdictions globally, 
including end-of-period consumer loans of $310 billion and 
end-of-period corporate loans of $390 billion at year-end 
2019. A default by a borrower or other counterparty, or a 
decline in the credit quality or value of any underlying 
collateral, exposes Citi to credit risk. Despite Citi’s target 
client strategy, various macroeconomic, geopolitical and other 
factors, among other things, can increase Citi’s credit risk and 
credit costs (for additional information, see the co-branding 
and private label credit card, macroeconomic challenges and 
uncertainties and emerging markets risk factors above). 

While Citi provides reserves for expected losses for its 
credit exposures, such reserves are subject to judgments and 
estimates that could be incorrect or differ from actual future 
events. Under the new CECL accounting standard, the 
allowance for credit losses reflects expected losses, rather than 
incurred losses, which could lead to more volatility in the 
allowance and the provision for credit losses as forecasts of 
economic conditions change. In addition, Citi’s future 
allowance may be affected by seasonality of its cards 

53

portfolios based on historical evidence showing that (i) credit 
card balances along with 30+ days past due balances increase 
during the third and fourth quarters each year as the holiday 
season approaches; and (ii) during the first and second 
quarters, borrowers use tax refunds to pay down balances 
while delinquent balances from the prior third and fourth 
quarters are charged off. For additional information, see the 
incorrect assumptions or estimates and changes to financial 
accounting and reporting standards risk factors above. For 
additional information on the impact of CECL, see Note 1 to 
the Consolidated Financial Statements. For additional 
information on Citi’s credit and country risk, see each 
respective business’s results of operations above and 
“Managing Global Risk—Credit Risk” and “Managing Global 
Risk—Strategic Risk—Country Risk” below and Note 14 to 
the Consolidated Financial Statements. 

Concentrations of risk, particularly credit and market 

risks, can also increase Citi’s risk of significant losses. As of 
year-end 2019, Citi’s most significant concentration of credit
risk was with the U.S. government and its agencies, which 
primarily results from trading assets and investments issued by 
the U.S. government and its agencies (for additional 
information, including concentrations of credit risk to other 
public sector entities, see Note 23 to the Consolidated 
Financial Statements). In addition, Citi routinely executes a 
high volume of securities, trading, derivative and foreign 
exchange transactions with non-U.S. sovereigns and with 
counterparties in the financial services industry, including 
banks, insurance companies, investment banks, governments, 
central banks and other financial institutions. Moreover, Citi 
has indemnification obligations in connection with various 
transactions that expose it to concentrations of risk, including 
credit risk from hedging or reinsurance arrangements related 
to those obligations (for additional information about these 
exposures, see Note 26 to the Consolidated Financial 
Statements). A rapid deterioration of a large borrower or other 
counterparty or within a sector or country where Citi has large 
exposures or guarantees or unexpected market dislocations 
could cause Citi to incur significant losses. 

LIQUIDITY RISKS

The Maintenance of Adequate Liquidity and Funding 
Depends on Numerous Factors, Including Those Outside of 
Citi’s Control, Such as Market Disruptions and Increases in 
Citi’s Credit Spreads.
As a global financial institution, adequate liquidity and 
sources of funding are essential to Citi’s businesses. Citi’s 
liquidity and sources of funding can be significantly and 
negatively impacted by factors it cannot control, such as 
general disruptions in the financial markets, governmental
fiscal and monetary policies, regulatory changes or negative 
investor perceptions of Citi’s creditworthiness, unexpected 
increases in cash or collateral requirements and the inability to
monetize available liquidity resources. Citi competes with 
other banks and financial institutions for deposits, which 
represent Citi’s most stable and lowest cost of long-term 
funding. The competition for retail banking deposits has 
increased as a result of online banks and digital banking, 
among others. Furthermore, given the decline in interest rates, 

a growing number of customers have transferred deposits to 
other products, including investments and interest-bearing 
accounts, and/or other financial institutions. This, along with 
slower growth in deposits, has resulted in a more challenging 
environment for Citi. For additional information on the impact 
of interest rates, see the macroeconomic challenges and 
uncertainties risk factor above. 

Moreover, Citi’s costs to obtain and access secured 
funding and long-term unsecured funding are directly related 
to its credit spreads. Changes in credit spreads are driven by 
both external market factors and factors specific to Citi, and 
can be highly volatile. For additional information on Citi’s 
primary sources of funding, see “Managing Global Risk—
Liquidity Risk” below. 

Citi’s ability to obtain funding may be impaired if other 

market participants are seeking to access the markets at the 
same time, or if market appetite declines, as is likely to occur 
in a liquidity stress event or other market crisis. A sudden drop 
in market liquidity could also cause a temporary or lengthier 
dislocation of underwriting and capital markets activity. In 
addition, clearing organizations, central banks, clients and 
financial institutions with which Citi interacts may exercise 
the right to require additional collateral based on their 
perceptions or the market conditions, which could further 
impair Citi’s access to and cost of funding.

As a holding company, Citi relies on interest, dividends, 
distributions and other payments from its subsidiaries to fund 
dividends as well as to satisfy its debt and other obligations. 
Several of Citi’s U.S. and non-U.S. subsidiaries are or may be 
subject to capital adequacy or other regulatory or contractual 
restrictions on their ability to provide such payments, 
including any local regulatory stress test requirements. 
Limitations on the payments that Citi receives from its 
subsidiaries could also impact its liquidity. 

The Credit Rating Agencies Continuously Review the Credit 
Ratings of Citi and Certain of Its Subsidiaries, and a Ratings 
Downgrade Could Have a Negative Impact on Citi’s 
Funding and Liquidity Due to Reduced Funding Capacity 
and Increased Funding Costs, Including Derivatives 
Triggers That Could Require Cash Obligations or Collateral 
Requirements.
The credit rating agencies, such as Fitch, Moody’s and S&P, 
continuously evaluate Citi and certain of its subsidiaries. Their 
ratings of Citi and its more significant subsidiaries’ long-term/
senior debt and short-term/commercial paper are based on a 
number of factors, including standalone financial strength, as 
well as factors that are not entirely within the control of Citi 
and its subsidiaries, such as the agencies’ proprietary rating 
methodologies and assumptions, and conditions affecting the 
financial services industry and markets generally.

Citi and its subsidiaries may not be able to maintain their 

current respective ratings. A ratings downgrade could 
negatively impact Citi’s ability to access the capital markets 
and other sources of funds as well as the costs of those funds, 
and its ability to maintain certain deposits. A ratings 
downgrade could also have a negative impact on Citi’s 
funding and liquidity due to reduced funding capacity and the 
impact from derivative triggers, which could require Citi to 

54

meet cash obligations and collateral requirements. In addition, 
a ratings downgrade could have a negative impact on other 
funding sources such as secured financing and other margined 
transactions for which there may be no explicit triggers, and 
on contractual provisions and other credit requirements of 
Citi’s counterparties and clients that may contain minimum 
ratings thresholds in order for Citi to hold third-party funds. 
Some entities could have ratings limitations on their 
permissible counterparties, of which Citi may or may not be 
aware.

Furthermore, a credit ratings downgrade could have 
impacts that may not be currently known to Citi or are not 
possible to quantify. Certain of Citi’s corporate customers and 
trading counterparties, among other clients, could re-evaluate 
their business relationships with Citi and limit the trading of 
certain contracts or market instruments with Citi in response to 
ratings downgrades. Changes in customer and counterparty 
behavior could impact not only Citi’s funding and liquidity but 
also the results of operations of certain Citi businesses. For 
additional information on the potential impact of a reduction 
in Citi’s or Citibank’s credit ratings, see “Managing Global 
Risk—Liquidity Risk” below.

COMPLIANCE RISKS

Ongoing Interpretation and Implementation of Regulatory 
and Legislative Requirements and Changes in the U.S. and 
Globally Have Increased Citi’s Compliance and Other Risks 
and Costs.
Citi is continually required to interpret and implement 
extensive and frequently changing regulatory and legislative 
requirements, resulting in substantial compliance, regulatory 
and other risks and costs. In addition, there are heightened 
regulatory scrutiny and expectations in the U.S. and globally 
for large financial institutions, as well as their employees and 
agents, with respect to, among other things, governance, risk 
management practices and controls. A failure to comply with 
these requirements and expectations or resolve any identified 
deficiencies could result in increased regulatory oversight and 
restrictions.  

Over the past several years, Citi has been required to 

implement a significant number of regulatory and legislative 
changes across all of its businesses and functions, and these 
changes continue. The changes themselves may be complex 
and subject to interpretation, and will require continued 
investments in Citi’s global operations and technology 
solutions. In some cases, Citi’s implementation of a regulatory 
or legislative requirement is occurring simultaneously with 
changing or conflicting regulatory guidance, legal challenges 
or legislative action to modify or repeal existing rules or enact 
new rules. Moreover, in some cases, there have been entirely 
new regulatory or legislative requirements or regimes, 
resulting in large volumes of regulation and potential 
uncertainty regarding regulatory expectations as to what is 
required in order to be in compliance. 

Examples of regulatory or legislative changes that have 
resulted in increased compliance risks and costs include (i) a 
proliferation of laws relating to the limitation of cross-border 
data movement and/or collection and use of customer 

information, including data localization and protection and 
privacy laws, which also can conflict with or increase 
compliance complexity with respect to other laws, including 
anti-money laundering laws; and (ii) the FRB’s “total loss 
absorbing capacity” (TLAC) requirements, including, among 
other things, consequences of a breach of the clean holding 
company requirements, given there are no cure periods for the 
requirements. 

Increased and ongoing compliance requirements and 

uncertainties have resulted in higher costs for Citi. For 
example, Citi employed roughly 30,000 risk, regulatory and 
compliance staff as of year-end 2019, out of a total employee 
population of 200,000, compared to approximately 14,000 as 
of year-end 2008 with a total employee population of 323,000. 
These higher compliance costs can require management to 
incur additional expense, including potentially away from 
ongoing business investment initiatives.

Extensive and changing compliance requirements can 

also result in increased reputational and legal risks for Citi, as 
failure to comply with regulations and requirements, or failure 
to comply with regulatory expectations, can result in 
enforcement and/or regulatory proceedings (for additional 
discussion, see the legal and regulatory proceedings risk factor 
below).

Citi Is Subject to Extensive Legal and Regulatory 
Proceedings, Examinations, Investigations and Inquiries 
That Could Result in Significant Penalties and Other 
Negative Impacts on Citi, Its Businesses and Results of 
Operations.
At any given time, Citi is defending a significant number of 
legal and regulatory proceedings and is subject to numerous 
governmental and regulatory examinations, investigations and 
other inquiries. The global judicial, regulatory and political 
environment has generally been challenging for large financial 
institutions. The complexity of the federal and state regulatory
and enforcement regimes in the U.S., coupled with the global 
scope of Citi’s operations, also means that a single event or 
issue may give rise to a large number of overlapping 
investigations and regulatory proceedings, either by multiple 
federal and state agencies and authorities in the U.S. or by 
multiple regulators and other governmental entities in different 
jurisdictions, as well as multiple civil litigation claims in 
multiple jurisdictions. Citi can be subject to enforcement 
proceedings not only because of violations of law and 
regulation, but also due to a failure, as determined by its 
regulators, to have adequate policies and procedures, or to 
remedy deficiencies on a timely basis.

U.S. and non-U.S. regulators have been increasingly 

focused on “conduct risk,” a term used to describe the risks 
associated with behavior by employees and agents, including 
third parties, that could harm clients, customers or the integrity 
of the markets, such as improperly creating, selling, marketing 
or managing products and services or improper incentive 
compensation programs with respect thereto, failures to 
safeguard a party’s personal information, or failures to identify 
and manage conflicts of interest. In addition to the greater 
focus on conduct risk, the heightened scrutiny and 
expectations generally from regulators could lead to 

55

investigations and other inquiries, as well as remediation 
requirements, more regulatory or other enforcement 
proceedings, civil litigation and higher compliance and other 
risks and costs. 

Further, while Citi takes numerous steps to prevent and 

detect conduct by employees and agents that could potentially 
harm clients, customers or the integrity of the markets, such 
behavior may not always be deterred or prevented. Banking 
regulators have also focused on the overall culture of financial 
services firms, including Citi. In addition to regulatory 
restrictions or structural changes that could result from 
perceived deficiencies in Citi’s culture, such focus could also 
lead to additional regulatory proceedings.

In addition, the severity of the remedies sought in legal 

and regulatory proceedings to which Citi is subject has 
remained elevated. U.S. and certain international 
governmental entities have increasingly brought criminal 
actions against, or have sought criminal convictions from,
financial institutions and individual employees, and criminal 
prosecutors in the U.S. have increasingly sought and obtained 
criminal guilty pleas or deferred prosecution agreements 
against corporate entities and individuals and other criminal 
sanctions from those institutions and individuals. These types 
of actions by U.S. and international governmental entities 
may, in the future, have significant collateral consequences for 
a financial institution, including loss of customers and 
business, and the inability to offer certain products or services 
and/or operate certain businesses. Citi may be required to 
accept or be subject to similar types of criminal remedies, 
consent orders, sanctions, substantial fines and penalties, 
remediation and other financial costs or other requirements in 
the future, including for matters or practices not yet known to 
Citi, any of which could materially and negatively affect Citi’s 
businesses, business practices, financial condition or results of 
operations, require material changes in Citi’s operations or 
cause Citi reputational harm.

Further, many large claims—both private civil and 
regulatory—asserted against Citi are highly complex, slow to 
develop and may involve novel or untested legal theories. The 
outcome of such proceedings is difficult to predict or estimate 
until late in the proceedings. Although Citi establishes accruals 
for its legal and regulatory matters according to accounting 
requirements, Citi’s estimates of, and changes to, these 
accruals involve significant judgment and may be subject to 
significant uncertainty, and the amount of loss ultimately 
incurred in relation to those matters may be substantially 
higher than the amounts accrued. In addition, certain 
settlements are subject to court approval and may not be 
approved.

For additional information relating to Citi’s legal and 

regulatory proceedings and matters, including Citi’s policies 
on establishing legal accruals, see Note 27 to the Consolidated 
Financial Statements.

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56

Managing Global Risk Table of Contents

MANAGING GLOBAL RISK

   Overview
CREDIT RISK(1)
   Overview

   Consumer Credit

   Corporate Credit

   Additional Consumer and Corporate Credit Details

       Loans Outstanding

       Details of Credit Loss Experience

       Allowance for Loan Losses

       Non-Accrual Loans and Assets and Renegotiated Loans

       Forgone Interest Revenue on Loans

LIQUIDITY RISK

    Overview

    Liquidity Monitoring and Measurement

    High-Quality Liquid Assets (HQLA)

    Loans

    Deposits

    Long-Term Debt

    Secured Funding Transactions and Short-Term Borrowings

    Credit Ratings
MARKET RISK(1) 
   Overview

   Market Risk of Non-Trading Portfolios

        Net Interest Revenue at Risk

        Interest Rate Risk of Investment Portfolios—Impact on AOCI 

        Changes in Foreign Exchange Rates—Impacts on AOCI and Capital

        Interest Revenue/Expense and Net Interest Margin (NIM)

        Additional Interest Rate Details

   Market Risk of Trading Portfolios

        Factor Sensitivities

        Value at Risk (VAR)

        Stress Testing

OPERATIONAL RISK

  Overview

  Cybersecurity Risk

COMPLIANCE RISK

REPUTATION RISK

STRATEGIC RISK

   Overview

   Exit of U.K. from EU

   LIBOR Transition Risk

   Country Risk

       Top 25 Country Exposures

        Argentina

       FFIEC—Cross-Border Claims on Third Parties and Local Country Assets

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(1)   For additional information regarding certain credit risk, market risk and other quantitative and qualitative information, refer to Citi’s Pillar 3 Basel III Advanced 

Approaches Disclosures, as required by the rules of the Federal Reserve Board, on Citi’s Investor Relations website.

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MANAGING GLOBAL RISK

Citi’s risks are generally categorized and summarized as 

Overview
For Citi, effective risk management is of primary importance 
to its overall operations. Accordingly, Citi’s risk management 
process has been designed to monitor, evaluate and manage 
the principal risks it assumes in conducting its activities. 
Specifically, the activities that Citi engages in, and the risks 
those activities generate, must be consistent with Citi’s 
mission and value proposition, the key principles that guide it 
and Citi's risk appetite.

Risk management must be built on a foundation of ethical 

culture. Under Citi’s mission and value proposition, which 
was developed by its senior leadership and distributed 
throughout the Company, Citi strives to serve its clients as a 
trusted partner by responsibly providing financial services that 
enable growth and economic progress while earning and 
maintaining the public’s trust by constantly adhering to the 
highest ethical standards. As such, Citi asks all employees to 
ensure that their decisions pass three tests: they are in Citi’s 
clients’ interests, create economic value and are always 
systemically responsible. In addition, Citi evaluates 
employees’ performance against behavioral expectations set 
out in Citi’s leadership standards, which were designed in part 
to effectuate Citi’s mission and value proposition. Other 
culture-related efforts in connection with conduct risk, ethics 
and leadership, escalation and treating customers fairly help 
Citi to execute its mission and value proposition.

Citi’s Company-wide risk governance framework consists 

of the key policies, standards and processes through which 
Citi identifies, assesses, measures, monitors and controls risks 
across the Company. It also emphasizes Citi’s risk culture and 
lays out standards, procedures and programs that are designed 
to set, reinforce and enhance the Company’s risk culture, 
integrate its values and conduct expectations into the 
organization, providing employees with tools to assist them 
with making prudent and ethical risk decisions and to escalate 
issues appropriately. 

Citi selectively takes risks in support of its underlying 
customer-centric strategy. Citi’s objective is to ensure that 
those risks are consistent with its mission and value 
proposition and principle of responsible finance; that they are 
identified, assessed, measured, monitored and controlled; and 
that they are captured in Citi’s risk/reward assessment. 

Citi’s risk appetite framework, which is approved by the 

Citigroup Board of Directors, includes both a risk appetite 
statement, which articulates the aggregate level and types of 
risk that Citi is willing to accept in order to achieve its 
business objectives, as well as the overall approach through 
which risk appetite is established, communicated and 
monitored. It is built on quantitative boundaries, which 
include risk limits or thresholds, and on qualitative principles 
to guide behavior. Citi’s risk appetite framework is 
comprehensive, incorporating all risks, enterprise-wide and 
applicable across products, functions and geographies.

follows:

•  Credit risk is the risk of loss resulting from the decline in 

• 

credit quality or the failure of a borrower, counterparty, 
third party or issuer to honor its financial or contractual 
obligations.
Liquidity risk is the risk that the Company will not be able 
to efficiently meet both expected and unexpected current 
and future cash flow and collateral needs without 
adversely affecting either daily operations or financial 
conditions of the Company. The risk may be exacerbated 
by the inability of the Company to access funding sources 
or monetize assets and the composition of liability 
funding and liquid assets.

•  Market risk (including price risk and interest rate risk) is 
the risk of loss arising from changes in the value of Citi’s 
assets and liabilities resulting from changes in market 
variables, such as interest rates, exchange rates or credit 
spreads. Losses can be exacerbated by the negative 
convexity of positions, as well as the presence of basis or 
correlation risks.

•  Operational risk is the risk of loss resulting from 

inadequate or failed internal processes, systems, human 
factors or from external events. It includes the reputation 
and franchise risk impact associated with business 
practices or market conduct in which Citi is involved. It 
also includes the risk of failing to comply with applicable 
laws and regulations, but excludes strategic risk (see 
below).

•  Compliance risk is the risk to current or projected 

financial conditions and resilience arising from violations 
of laws, rules or regulations, or from nonconformance 
with prescribed practices, internal policies and procedures 
or ethical standards. It also includes the exposure to 
litigation (known as legal risk) from all aspects of 
banking, traditional and nontraditional. Compliance risk 
spans across all risk types outlined in the risk governance 
framework.

• 

•  Reputation risk is the risk to current or projected financial 
conditions and resilience arising from negative public 
opinion.
Strategic risk is the risk to current or anticipated earnings, 
capital, or franchise or enterprise value arising from poor 
but authorized business decisions (in compliance with 
regulations, policies and procedures), an inability to adapt 
to changes in the operating environment or other external 
factors that may impair the ability to carry out a business 
strategy. Strategic risk also includes:

•  Country risk, which is the risk that an event in a 
country (precipitated by developments within or 
external to a country) will impair the value of Citi’s 
franchise or will adversely affect the ability of 
obligors within that country to honor their 
obligations. Country risk events may include 
sovereign defaults, banking crises, currency crises, 
currency convertibility and/or transferability 
restrictions or political events.

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Citi manages its risks through a “three lines of defense” 

model: (i) business management; (ii) Independent Risk 
Management and Independent Compliance Risk Management 
and other control functions; and (iii) Internal Audit. The three 
lines of defense collaborate with each other in structured 
forums and processes to bring together various perspectives 
and to lead the organization toward outcomes that are in 
clients’ interests, that create economic value and that are 
systemically responsible.

First Line of Defense: Business Management
Through Citi’s business management (“frontline units” or the 
“first line of defense”), each business owns the risks inherent 
in or arising from its businesses, and is responsible for 
identifying, assessing and controlling those risks to ensure 
they are within risk appetite, establishing and operating 
controls to mitigate those risks, including concentration risks, 
performing manager assessments of the design and 
effectiveness of internal controls, implementing appropriate 
procedures to fulfill its risk governance responsibilities and 
promoting a culture of compliance and control.

The first line of defense is composed of Citi’s businesses 

(Institutional Clients Group (ICG) and Global Consumer Bank 
(GCB)), supporting clients globally as well as in regions and 
countries that execute Citi’s strategy locally. In addition, there 
are functional teams, such as Enterprise Infrastructure, 
Operations and Technology (EIO&T) that support the Citi 
CEO in a first line capacity. The CEOs of each region, 
business, EIO&T and certain functional teams report to the 
Citigroup CEO. 

Businesses at Citi organize and chair committees, 
councils, steering groups and other forums that cover risk 
considerations with participation from Independent Risk 
Management, Independent Compliance Risk Management and 
other control functions. These are often conducted across lines 
of defense and may include matters related to capital, assets 
and liabilities, business practices, business risks and controls, 
mergers and acquisitions, the Community Reinvestment Act 
and fair lending and incentives.

Second Line of Defense: Independent Risk Management; 
Control Functions
Citi’s Independent Risk Management (IRM) and Independent 
Compliance Risk Management (ICRM) together with other 
control functions (Finance, Human Resources, Legal) set 
standards that Citi and its businesses and products are required 
to adhere to in order to manage and oversee risks, including 
conformance with applicable laws, regulatory requirements, 
policies and other relevant standards of ethical conduct. IRM 
and ICRM provide credible challenge to first line units in their 
assessment and management of risk. In addition, among other 
responsibilities, IRM, ICRM and the control functions provide 
advice and training to Citi’s businesses and establish tools, 
methodologies, processes and oversight of controls used by 
the businesses to foster a culture of compliance and control. 
Where certain activities of control functions constitute first 
line activity, such activities are subject to appropriate review 
and challenge.

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Independent Risk Management
The Independent Risk Management organization sets 
standards for the business and actively manages and oversees 
aggregate credit, market (price, FX and interest rate), liquidity, 
strategic, operational, compliance and reputation risks across 
the Company, including risks that span categories, such as 
concentration risk. 

Independent Risk Management is organized to align to 

businesses, regions, risk types and to Citi-wide, cross-risk 
functions or processes. There are teams that report to an 
independent Chief Risk Officer (CRO) for Citi’s businesses 
(business CROs) and regions (regional CROs). In addition, 
there are teams that report to the heads for certain risk 
categories (e.g., Global Market Risk) and for certain 
foundational risk areas (e.g., Global Risk Review). All of the 
risk heads, together with the business and regional CROs, 
report to the Citigroup CRO.

The head of Independent Risk Management is the 
Citigroup CRO, who reports directly to the Citigroup CEO 
and to the Citigroup Risk Management Committee (RMC) of 
the Board of Directors. As part of its responsibilities, the RMC 
approves the appointment and removal of the CRO. The CRO 
has regular and unrestricted access to the full Citigroup Board, 
as well as the Risk Management Committee of the Board, to 
discuss risks and issues identified through Independent Risk 
Management’s activities, including instances in which the 
CRO’s assessment differs from that of the business or the 
CEO, and instances in which the business or the CEO may not 
be adhering to the risk governance framework. 

Independent Compliance Risk Management
The Independent Compliance Risk Management organization 
is an independent risk management function that is designed to 
oversee and credibly challenge products, functions, 
jurisdictional activities and legal entities in managing 
compliance risk, as well as promoting business conduct and 
activity that is consistent with Citi’s mission and value 
proposition and the compliance risk appetite. Citi’s objective 
is to embed an enterprise-wide compliance risk management 
framework and culture that identifies, escalates, measures, 
monitors, reports and controls compliance risk across the three 
lines of defense. For further information on Citi’s compliance 
risk framework, see “Compliance Risk” below.

The Citigroup Chief Compliance Officer reports to the 

Citigroup CEO and has regular and unrestricted access to 
committees of the Citigroup and Citibank Boards of Directors, 
including the Audit Committees, Risk Management 
Committees and the Ethics, Conduct and Culture Committee 
of the Citigroup Board. 

Human Resources
Human Resources (HR) provides leadership with respect to 
Citi’s human capital strategy, which is primarily focused on 
ensuring employees are appropriately rewarded for 
demonstrating Citi values and leadership standards and for 
maintaining a pipeline of new and developing talent to meet 
Citi’s changing business needs.

HR is primarily composed of and organized around the 

core global disciplines of compensation and benefits, 
performance management, talent acquisition, talent and 
diversity and workforce relations, with consideration for 
support to Citi businesses, products and functions and second 
line of defense responsibilities. Through its disciplines, HR 
advises business management, escalates identified risks and 
establishes policies, standards or processes to manage risk. 
The Head of HR reports to the Citigroup CEO and 
interacts regularly with the Personnel and Compensation 
Committee of the Citigroup Board of Directors. In addition, 
the Head of HR has regular and unrestricted access to the full 
Citigroup Board of Directors, as well as to the Audit 
Committee of the Board of Directors.

Legal
Citi Legal is responsible for advising Citi’s lines of business 
and control functions in order to facilitate the prudent 
management of Citi’s exposure to legal risk. 

Citi Legal’s organizational structure is designed to insulate 
it from potential conflicts of interest that could undermine its 
role in providing advice in regard to legal obligations and 
exposures of Citi. 

Activities within Citi Legal include providing legal advice 
to Citi’s businesses and other functions on the interpretation of 
legal and regulatory requirements, including contractual 
requirements, and on managing and mitigating legal exposure 
based on a proper understanding of legal requirements; 
providing legal advice to promote the reporting of Citi’s and 
its subsidiaries obligations to identify legal matters to 
regulators and investors, as required by law; helping to 
identify current and emerging legal risks that arise in the 
context of Citi’s provision of products and services to its 
clients; attending meetings of the Board of Directors and 
committees of the Board to facilitate the oversight role of 
these bodies; and participating in management committees and 
forums where legal risk should be considered and evaluated.

The General Counsel leads Citi Legal and reports directly 

to the Citigroup CEO. The General Counsel meets regularly 
with the Board of Directors, the Audit Committee, the Risk 
Management Committee, the Ethics, Conduct and Culture 
Committee and the Nomination, Governance and Public 
Affairs Committee and is involved in the discussion of legal 
issues that arise in the context of items being presented to the 
Board and its committees.

Finance
Finance’s mission is to serve as an advisor to the business, 
delivering timely, accurate and complete information to each 
of its constituencies, accompanied by insightful analytics, and 
operating in a cost-efficient manner with highly effective 
controls.

The Finance organization, led by the Chief Financial 
Officer (CFO), is composed of a set of core, global disciplines 
(capital planning, controllers, corporate M&A, corporate 

treasury, financial planning and analysis, investor relations and 
tax). Through the disciplines, Finance advises business 
management, escalates identified risks and establishes 
policies, standards or processes to manage risk. Also reporting 
to the Citigroup CFO are a set of product, geographical and 
legal entity Finance Officers who, along with their teams, 
interact with the global finance disciplines in the execution of 
their responsibilities. 

Citi’s CFO reports directly to the Citigroup CEO. The 
CFO chairs or co-chairs several management committees that 
serve as key governance and oversight forums for business 
activities. In addition, the CFO has regular and unrestricted 
access to the full Citigroup Board of Directors as well as to the 
Audit Committee of the Board of Directors.

Third Line of Defense: Internal Audit
The role of Internal Audit is to provide independent and timely 
assurance to the Citigroup and Citibank Boards, the Audit 
Committees of the Boards, senior management and regulators 
regarding the effectiveness of governance, risk management 
and controls that mitigate current and evolving risks and 
enhance the control culture within Citi. 

The Internal Audit function has designated Chief Auditors 

responsible for assessing the design and effectiveness of 
controls within the various business units, functions, 
geographies and legal entities in which Citi operates, including 
specific Chief Auditors for Finance, ICRM and Independent 
Risk Management. 

The Citigroup Chief Auditor manages Internal Audit and 

reports functionally to the Chair of the Citigroup Audit 
Committee and administratively to the CEO of Citigroup. 
Internal Audit’s responsibilities are carried out independently 
under the oversight of the Audit Committees, and Internal 
Audit employees accordingly report to the Citigroup Chief 
Auditor and do not have reporting lines to either first or 
second line of defense management.

Citigroup Board of Directors and Committees of the Board
Citigroup’s Board of Directors actively oversees Citi’s risk-
taking activities and holds management accountable for 
adhering to the risk governance framework. Directors review 
reports prepared by and receive presentations from 
management, and exercise independent judgment to question, 
probe and challenge recommendations of and decisions made 
by management. 

The standing committees of the Citigroup Board of 
Directors are the Executive Committee, Risk Management 
Committee, Audit Committee, Personnel and Compensation 
Committee, Ethics, Conduct and Culture Committee, 
Operations and Technology Committee and Nomination, 
Governance and Public Affairs Committee. In addition to the 
standing committees, the Board establishes additional 
committees as necessary or appropriate in response to 
regulatory, legal or other requirements.

60

stress testing at the company, business, geography and product 
levels. These stress-testing processes typically estimate 
potential incremental credit costs that would occur as a result 
of either downgrades in the credit quality or defaults of the 
obligors or counterparties.

For additional information on Citi’s credit risk 
management, see Note 14 to the Consolidated Financial 
Statements. 

CREDIT RISK

Overview
Credit risk is the risk of loss resulting from the decline in 
credit quality or the failure of a borrower, counterparty, third 
party or issuer to honor its financial or contractual obligations. 
Credit risk arises in many of Citigroup’s business activities, 
including:

• 
• 
• 
• 

consumer, commercial and corporate lending; 
capital markets derivative transactions; 
structured finance; and 
securities financing transactions (repurchase and reverse 
repurchase agreements, and securities loaned and 
borrowed).

Credit risk also arises from settlement and clearing 
activities, when Citi transfers an asset in advance of receiving 
its counter-value or advances funds to settle a transaction on 
behalf of a client. Concentration risk, within credit risk, is the 
risk associated with having credit exposure concentrated 
within a specific client, industry, region or other category.

Credit risk is one of the most significant risks Citi faces as 

an institution. For additional information, see “Risk Factors—
Credit Risk” above. As a result, Citi has a well-established 
framework in place for managing credit risk across all 
businesses. This includes a defined risk appetite, credit limits 
and credit policies, both at the business level as well as at the 
Company-wide level. Citi’s credit risk management also 
includes processes and policies with respect to problem 
recognition, including “watch lists,” portfolio reviews, stress 
tests, updated risk ratings and classification triggers. 

With respect to Citi’s settlement and clearing activities, 
intraday client usage of lines is monitored against limits, as 
well as against usage patterns. To the extent that a problem 
develops, Citi typically moves the client to a secured 
(collateralized) operating model. Generally, Citi’s intraday 
settlement and clearing lines are uncommitted and cancelable 
at any time.

To manage concentration of risk within credit risk, Citi 
has in place a correlation framework consisting of industry 
limits, an idiosyncratic framework consisting of single name 
concentrations for each business and across Citigroup and a 
specialized framework consisting of product limits.

Credit exposures are generally reported in notional terms 

for accrual loans, reflecting the value at which the loans as 
well as loan and other off-balance sheet commitments are 
carried on the Consolidated Balance Sheet. Credit exposure 
arising from capital markets activities is generally expressed 
as the current mark-to-market, net of margin, reflecting the net 
value owed to Citi by a given counterparty. 

The credit risk associated with these credit exposures is a 
function of the idiosyncratic creditworthiness of the obligor, as 
well as the terms and conditions of the specific obligation. Citi 
assesses the credit risk associated with its credit exposures on 
a regular basis through its loan loss reserve process (see 
“Significant Accounting Policies and Significant Estimates—
Allowance for Credit Losses” below and Notes 1 and 15 to the 
Consolidated Financial Statements), as well as through regular 

61

CONSUMER CREDIT
Citi provides traditional retail banking, including small 
business banking, and credit card products in 19 countries and 
jurisdictions through North America GCB, Latin America 
GCB and Asia GCB. The retail banking products include 
consumer mortgages, home equity, personal and small 
business loans and lines of credit and similar related products 
with a focus on lending to prime customers. Citi uses its risk 
appetite framework to define its lending parameters. In 
addition, Citi uses proprietary scoring models for new 
customer approvals. 

As stated in “Global Consumer Banking” above, GCB’s 
overall strategy is to leverage Citi’s global footprint and be the 
pre-eminent bank for the affluent and emerging affluent 
consumers in large urban centers. In credit cards and in certain 
retail markets, Citi serves customers in a somewhat broader 
set of segments and geographies. As of the fourth quarter of 
2019, Citi’s commercial banking businesses previously 
reported as part of GCB in North America, Latin America and 
Asia, including approximately $28 billion in end-of-period 
loans, are now reported in ICG for all periods presented. 

Consumer Credit Portfolio
The following table shows Citi’s quarterly end-of-period consumer loans:(1)

In billions of dollars

Retail banking:

Mortgages

Personal, small business and other

Total retail banking

Cards:

Citi-branded cards

Citi retail services

Total cards

Total GCB

GCB regional distribution:

North America

Latin America
Asia(2)

Total GCB
Corporate/Other(3)

Total consumer loans

4Q’18

1Q’19

2Q’19

3Q’19

4Q’19

$

$

$

$

$

$

$

80.6

37.0

117.6

116.8

52.7

169.5

287.1

$

$

$

$

$

67%

6

27

100%

80.8

37.3

118.1

$

$

81.9

37.8

119.7

$

$

111.4

$

115.5

$

48.9

160.3

278.4

$

$

66%

6

28

100%

49.6

165.1

284.8

$

$

66%

6

28

100%

83.0

37.6

120.6

115.8

50.0

165.8

286.4

$

$

$

$

$

66%

6

28

100%

15.3

302.4

$

$

12.6

291.0

$

$

11.7

296.5

$

$

11.0

297.4

$

$

85.1

39.7

124.8

122.2

52.9

175.1

299.9

66%

6

28

100%

9.6

309.5

(1)  End-of-period loans include interest and fees on credit cards.
(2)  Asia includes loans and leases in certain EMEA countries for all periods presented.
(3)  Primarily consists of legacy assets, principally North America consumer mortgages.

For information on changes to Citi’s end-of-period 

consumer loans, see “Liquidity Risk—Loans” below.

62

Overall Consumer Credit Trends
The following charts show the quarterly trends in 
delinquencies (90+ days past due (90+ DPD) ratio) and the net 
credit losses (NCL) ratio across both retail banking and cards 
for total GCB and by region. 

Global Consumer Banking

Latin America GCB

North America GCB

North America GCB provides mortgage, home equity, 
small business and personal loans through Citi’s retail banking 
network and card products through Citi-branded cards and Citi 
retail services businesses. The retail bank is concentrated in 
six major metropolitan cities in the United States (for 
additional information on the U.S. retail bank, see “North 
America GCB” above).

As of December 31, 2019, approximately 75% of North 
America GCB consumer loans consisted of Citi-branded and 
Citi retail services cards, which generally drives the overall 
credit performance of North America GCB (for additional 
information on North America GCB’s cards portfolios, 
including delinquency and net credit loss rates, see “Credit 
Card Trends” below).

As shown in the chart above, the net credit loss rate in 

North America GCB increased quarter-over-quarter, primarily 
driven by seasonality in Citi retail services portfolios. The 90+ 
days past due delinquency rate also increased quarter-over-
quarter, primarily due to seasonality in the cards portfolios.
The net credit loss rate and 90+ days past due 

delinquency rate increased year-over-year, primarily driven by 
seasoning of more recent vintages in Citi-branded cards and an 
increase in net flow rates in later delinquency buckets in Citi 
retail services.

Latin America GCB operates in Mexico through
Citibanamex, one of Mexico’s largest banks, and provides
credit cards, consumer mortgages and small business and 
personal loans. Latin America GCB serves a more mass-
market segment in Mexico and focuses on developing multi-
product relationships with customers.

As shown in the chart above, the net credit loss rate in 

Latin America GCB decreased quarter-over-quarter, primarily 
due to seasonality in the cards portfolio, while the 90+ days 
past due delinquency rate remained broadly stable.

The net credit loss and 90+ days past due rate decreased 
year-over-year, primarily due to the growth in recent vintages 
for cards as well as a slower pace of acquisitions in the retail 
portfolios during 2019.

Asia(1) GCB 

(1)  Asia includes GCB activities in certain EMEA countries for all periods 

presented.

Asia GCB operates in 17 countries in Asia and EMEA
and provides credit cards, consumer mortgages and small 
business and personal loans.

As shown in the chart above, the net credit loss rate in 
Asia GCB decreased quarter-over-quarter, primarily due to 
seasonality, while the 90+ days past due delinquency rate 
remained broadly stable quarter-over-quarter. Year-over-year, 
the net credit loss and the 90+ days past due delinquency rate 
remained broadly stable.

The stability in Asia GCB’s portfolios reflects the strong 

credit profiles in the region’s target customer segments. 
Regulatory changes in many markets in Asia over the past few 
years have also resulted in stable portfolio credit quality.

For additional information on cost of credit, loan 
delinquency and other information for Citi’s consumer loan 
portfolios, see each respective business’s results of operations 
above and Note 14 to the Consolidated Financial Statements.

63

Credit Card Trends
The following charts show the quarterly trends in 
delinquencies and net credit losses for total GCB cards, North 
America Citi-branded cards and Citi retail services portfolios, 
as well as for Citi’s Latin America and Asia Citi-branded cards 
portfolios.

Global Cards

North America Citi Retail Services

North America Citi-Branded Cards

North America GCB’s Citi-branded cards portfolio issues 

proprietary and co-branded cards. As shown in the chart 
above, the net credit loss rate in North America Citi-branded 
cards was relatively stable quarter-over-quarter, while the 90+ 
days past due delinquency rate increased, driven by 
seasonality.

The net credit loss and 90+ days past due delinquency rate 

increased year-over-year, primarily driven by seasoning of 
more recent vintages.

Citi retail services partners directly with more than 20 

retailers and dealers to offer private label and co-branded 
cards. Citi retail services’ target market is focused on select 
industry segments such as home improvement, specialty retail, 
consumer electronics and fuel.

Citi retail services continually evaluates opportunities to 
add partners within target industries that have strong loyalty, 
lending or payment programs and growth potential.

As shown in the chart above, the net credit loss and 90+ 

days past due delinquency rate in Citi retail services increased 
quarter-over-quarter, primarily due to seasonality.

The net credit loss rate and 90+ days past due delinquency 

rate increased year-over-year, primarily driven by an increase 
in net flow rates in later delinquency buckets.

Latin America Citi-Branded Cards

Latin America GCB issues proprietary and co-branded 

cards. As shown in the chart above, the net credit loss rate in 
Latin America Citi-branded cards decreased quarter-over-
quarter, primarily due to seasonality, while the 90+ days past 
due delinquency rate remained stable.

The net credit loss and 90+ days past due delinquency rate 

decreased year-over-year, primarily due to growth in recent 
vintages.

64

Asia Citi-Branded Cards(1)

(1)  Asia includes loans and leases in certain EMEA countries for all periods 

presented.

Asia GCB issues proprietary and co-branded cards. 
As set forth in the chart above, the net credit loss rate in 

Asia Citi-branded cards decreased quarter-over-quarter, 
primarily due to seasonality, while the 90+ days past due 
delinquency rate remained broadly stable.

Year-over-year, the net credit loss rate and 90+ days past 

due delinquency rate remained broadly stable.

For additional information on cost of credit, delinquency 

and other information for Citi’s cards portfolios, see each 
respective business’s results of operations above and Note 13 
to the Consolidated Financial Statements.

North America Cards FICO Distribution
The following tables show the current FICO score 
distributions for Citi’s North America cards portfolios based 
on end-of-period receivables. FICO scores are updated 
monthly for substantially all of the portfolio and on a quarterly 
basis for the remaining portfolio.

Citi-Branded Cards

FICO distribution(1)

Dec 31,
2019

Sept. 30,
2019

Dec 31,
2018

  > 760

   680–760

  < 680

Total

42%

41

17

41%

41

18

42%

41

17

100%

100%

100%

Citi Retail Services

FICO distribution(1)

Dec 31,
2019

Sept. 30,
2019

Dec 31,
2018

   > 760

   680–760

  < 680

Total

25%

42

33

24%

43

33

25%

42

33

100%

100%

100%

(1)  The FICO bands in the tables are consistent with general industry peer 

presentations. 

Both the Citi-branded cards’ and Citi retail services’ 
cards FICO distributions remained stable as of year-end 2019.
For additional information on FICO scores, see Note 14 

to the Consolidated Financial Statements.

65

Additional Consumer Credit Details

Consumer Loan Delinquencies and Ratios

In millions of dollars, except EOP loan
amounts in billions
Global Consumer Banking(3)(4)
Total

Ratio

Retail banking

Total

Ratio

North America

Ratio
Latin America
Ratio

Asia(5)

Ratio

Cards
Total

Ratio

North America—Citi-branded

Ratio

North America—Citi retail services

Ratio
Latin America
Ratio

Asia(5)

Ratio

Corporate/Other—Consumer(6)

Total

Ratio
Total Citigroup
Ratio

$

$

124.8 $

50.3

11.7

62.8

$

175.1 $

96.3

52.9

6.0

19.9

EOP
loans(1)
December
31,

90+ days past due(2)

30–89 days past due(2)

December 31,

December 31,

2019

2019

2018

2017

2019

2018

2017

299.9 $

$

2,737
0.91%

$

2,550
0.89%

$

2,378
0.84%

$

3,001
1.00%

$

2,864
1.00%

2,687
0.95%

$

$

438
0.35%
146
0.29%
106
0.91%
186
0.30%

2,299
1.31%
915
0.95%
1,012
1.91%
165
2.75%
207
1.04%

$

$

416
0.36%
135
0.29%
108
0.95%
173
0.30%

2,134
1.26%
812
0.88%
952
1.81%
171
3.00%
199
1.03%

$

$

415
0.35%
134
0.29%
112
0.96%
169
0.29%

1,963
1.19%
768
0.85%
845
1.72%
151
2.80%
199
1.01%

$

$

816
0.66%
334
0.67%
180
1.54%
302
0.48%

2,185
1.25%
814
0.85%
945
1.79%
159
2.65%
267
1.34%

$

$

752
0.64%
265
0.56%
185
1.62%
302
0.52%

2,112
1.25%
755
0.82%
932
1.77%
170
2.98%
255
1.32%

747
0.64%
256
0.55%
181
1.55%
310
0.52%

1,940
1.18%
698
0.77%
830
1.69%
153
2.83%
259
1.31%

542
2.51%
3,229
1.06%

$

$

9.6 $

309.5 $

$

$

278
3.02%
3,015
0.98%

$

$

382
2.63%
2,932
0.97%

$

$

557
2.58%
2,935
0.91%

$

$

295
3.21%
3,296
1.07%

$

$

362
2.50%
3,226
1.07%

(1)  End-of-period (EOP) loans include interest and fees on credit cards.
(2)  The ratios of 90+ days past due and 30–89 days past due are calculated based on EOP loans, net of unearned income.
(3)  The 90+ days past due balances for North America—Citi-branded and North America—Citi retail services are generally still accruing interest. Citigroup’s policy is 

generally to accrue interest on credit card loans until 180 days past due, unless notification of bankruptcy filing has been received earlier.

(4)  The 90+ days past due and 30–89 days past due and related ratios for North America GCB exclude U.S. mortgage loans that are guaranteed by U.S. government-
sponsored agencies since the potential loss predominantly resides within the agencies. The amounts excluded for loans 90+ days past due and (EOP loans) were 
$135 million ($0.5 billion), $211 million ($0.7 billion) and $305 million ($0.8 billion) at December 31, 2019, 2018 and 2017, respectively. The amounts excluded 
for loans 30–89 days past due (EOP loans have the same adjustment as above) were $72 million, $86 million and $93 million at December 31, 2019, 2018 and 
2017, respectively.

(5)  Asia includes delinquencies and loans in certain EMEA countries for all periods presented.
(6)  The 90+ days past due and 30–89 days past due and related ratios exclude U.S. mortgage loans that are guaranteed by U.S. government-sponsored agencies since 
the potential loss predominantly resides within the agencies. The amounts excluded for loans 90+ days past due and (EOP loans) were $172 million ($0.4 billion), 
$367 million ($0.8 billion) and $663 million ($1.2 billion) at December 31, 2019, 2018 and 2017, respectively. The amounts excluded for loans 30–89 days past 
due (EOP loans have the same adjustment as above) were $55 million, $122 million and $164 million at December 31, 2019, 2018 and 2017, respectively.

66

 
Consumer Loan Net Credit Losses and Ratios

In millions of dollars, except average loan amounts in billions
Global Consumer Banking
Total

Ratio

Retail banking

Total

Ratio

North America

Ratio
Latin America
Ratio

Asia(4)

Ratio

Cards
Total

Ratio

North America—Citi-branded

Ratio

North America—Citi retail services

Ratio
Latin America
Ratio

Asia(4)

Ratio

Corporate/Other—Consumer(3)

Total

Ratio
International
Ratio

North America

Ratio

Other(5)
Total Citigroup
Ratio

Average
loans(1)
2019

Net credit losses(2)(3)
2018

2019

2017

284.1 $

$

7,382
2.60 %

$

6,884
2.48%

6,462
2.39%

$

$

119.7 $

48.5

11.5

59.7

$

164.4 $

89.8

49.9

5.7

19.0

$

11.9 $

—

11.9

—
296.0 $

$

$

$

910
0.76 %
161
0.33
494
4.30
255
0.43

6,472
3.94 %
2,864
3.19
2,558
5.13
615
10.79
435
2.29

$

$

(6)
(0.05)%
—
—
(6)
(0.05)
—
7,376
2.49 %

$

$

913
0.78%
126
0.27
545
4.58
242
0.41

5,971
3.72%
2,602
2.97
2,357
4.88
586
10.65
426
2.25

$

$

24
0.14%
42
6.00
(18)
NM
—
6,908
2.33%

923
0.79%
135
0.29
550
4.40
238
0.42

5,539
3.60%
2,447
2.90
2,155
4.73
533
10.06
404
2.17

156
0.57%
82
4.32
74
0.29
(21)
6,597
2.22%

(1)  Average loans include interest and fees on credit cards.
(2)  The ratios of net credit losses are calculated based on average loans, net of unearned income.
(3)  As a result of Citigroup's entry into agreements in 2016 to sell its Argentina and Brazil consumer banking businesses, these businesses were classified as HFS at 
the end of the fourth quarter of 2016. Loans HFS are excluded from this table as they are recorded in Other assets. In addition, as a result of HFS accounting 
treatment, approximately $128 million of net credit losses (NCLs) were recorded as a reduction in revenue (Other revenue) during 2017. Accordingly, these NCLs 
are not included in this table. The sales of the Argentina and Brazil consumer banking businesses were completed in 2017. 

(4)  Asia includes NCLs and average loans in certain EMEA countries for all periods presented.
(5)  2017 NCLs reflected a recovery related to legacy assets.

67

 
 
 
 
Loan Maturities and Fixed/Variable Pricing of
U.S. Consumer Mortgages 

Greater
than 1 
year
but 
within
5 years

Due
within
1 year

Greater
than 5
years

Total

$

$

3 $
92
95 $

118 $ 46,887 $ 47,008
9,223
8,801
330
448 $ 55,688 $ 56,231

$

$

430 $ 35,975

18
19,713
448 $ 55,688

In millions of dollars at
December 31, 2019
U.S. consumer
mortgage loan
portfolio

Residential first
mortgages
Home equity loans
Total
Fixed/variable
pricing of U.S.
consumer mortgage
loans with maturities
due after one year
Loans at fixed interest
rates
Loans at floating or
adjustable interest
rates
Total

68

CORPORATE CREDIT
Consistent with its overall strategy, Citi’s corporate clients are 
typically large, multinational corporations that value the depth 
and breadth of Citi’s global network. Citi aims to establish 
relationships with these clients that, consistent with client 
needs, encompass multiple products, including cash 
management and trade services, foreign exchange, lending, 
capital markets and M&A advisory. As of the fourth quarter of 
2019, Citi’s commercial banking businesses previously 
reported as part of GCB in North America, Latin America and 
Asia, including approximately $28 billion in end-of-period 
loans, are now reported in ICG for all periods presented. 

Corporate Credit Portfolio
The following table presents Citi’s corporate credit portfolio 
within ICG (excluding private bank), before consideration of 
collateral or hedges, by remaining tenor for the periods 
indicated:

December 31, 2019

September 30, 2019

December 31, 2018

Greater
than 
1 year
but 
within
5 years

Due
within
1 year

Greater
than
5 years

Total
exposure

Due
within
1 year

Greater
than
1 year
but
within
5 years

Greater
than
5 years

Total
exposure

Due
within
1 year

Greater
than 
1 year
but 
within
5 years

Greater
than
5 years

Total
exposure

$ 141 $

117 $

23 $

281 $ 150 $

115 $

24 $

289 $ 144 $

119 $

23 $

286

145

249

17

411

133

250

16

399

111

253

18

$ 286 $

366 $

40 $

692 $ 283 $

365 $

40 $

688 $ 255 $

372 $

41 $

382

668

In billions of dollars

Direct outstandings 
(on-balance sheet)(1)
Unfunded lending 
commitments 
(off-balance sheet)(2)
Total exposure

(1) 
(2) 

Includes drawn loans, overdrafts, bankers’ acceptances and leases. 
Includes unused commitments to lend, letters of credit and financial guarantees.

Portfolio Mix—Geography, Counterparty and Industry
Citi’s corporate credit portfolio is diverse by geography and 
counterparty. The following table shows the regional 
percentages of this portfolio based on Citi’s internal 
management geography:

North America

EMEA

Asia

Latin America

Total

December 31,
2019

September 30,
2019

December 31,
2018

55%

26

12

7

100%

55%

26

12

7

100%

54%

26

12

8

100%

The maintenance of accurate and consistent risk ratings 
across the corporate credit portfolio facilitates the comparison 
of credit exposure across all lines of business, geographic 
regions and products. Counterparty risk ratings reflect an 
estimated probability of default for a counterparty and are 
derived by leveraging validated statistical models, scorecard 
models and external agency ratings (under defined 
circumstances), in combination with consideration of factors 
specific to the obligor or market, such as management 
experience, competitive position and regulatory environment 

69

and commodity prices. Facility risk ratings are assigned that 
reflect the probability of default of the obligor and factors that 
affect the loss given default of the facility, such as support or 
collateral. Internal obligor ratings that generally correspond to 
BBB and above are considered investment grade, while those 
below are considered non-investment grade.

Citigroup has also incorporated environmental factors 

such as climate risk assessment and reporting criteria for 
certain obligors, as necessary. Factors evaluated include 
consideration of climate risk to an obligor’s business and 
physical assets and, when relevant, consideration of cost-
effective options to reduce greenhouse gas emissions.

The following table presents the corporate credit portfolio 

by facility risk rating as a percentage of the total corporate 
credit portfolio:

Total exposure

December 31,
2019

September 30,
2019

December 31,
2018

AAA/AA/A

BBB

BB/B

CCC or below

Total

46%

36

16

2

46%

36

16

2

47%

35

17

1

100%

100%

100%

 
 
 
Note: Total exposure includes direct outstandings and unfunded lending 
commitments. 

Rating of Hedged Exposure

AAA/AA/A

BBB

BB/B

CCC or below

Total

December 31,
2019

September 30,
2019

December 31,
2018

32%

51

15

2

34%

48

17

1

35%

50

14

1

100%

100%

100%

The credit protection was economically hedging 
underlying corporate credit portfolio exposures with the 
following industry distribution:

Industry of Hedged Exposure

Transportation and
industrial

Technology,
media and telecom

Consumer retail
and health

Power, chemicals,
metals and mining

Energy and
commodities

Insurance and
special purpose
entities

Banks/broker-
dealers/finance
companies

Public sector

Real estate

Other industries

Total

December 31,
2019

September 30,
2019

December 31,
2018

24%

23%

23%

19

18

15

9

7

3

3

2

—

100%

19

16

14

9

5

5

4

4

1

17

16

15

11

6

4

3

4

1

100%

100%

Citi’s corporate credit portfolio is also diversified by 

industry. The following table shows the allocation of Citi’s 
total corporate credit portfolio by industry:

Total exposure

December 31,
2019

September 30,
2019

December 31,
2018

21%

21%

22%

17

12

11

8

8

8

4

4

4

3

17

12

10

8

8

8

4

4

4

4

17

13

10

8

8

8

5

4

4

1

100%

100%

100%

Transportation and 
 industrial

Consumer retail  
and health

Technology, media  
and telecom

Power, chemicals, 
metals and mining
Banks/broker-
dealers/finance
companies
Real estate

Energy and
commodities

Public sector

Insurance and
special purpose
entities

Hedge funds

Other industries

Total

For additional information on Citi’s corporate credit 

portfolio, see Note 14 to the Consolidated Financial 
Statements. 

Credit Risk Mitigation
As part of its overall risk management activities, Citigroup 
uses credit derivatives and other risk mitigants to hedge 
portions of the credit risk in its corporate credit portfolio, in 
addition to outright asset sales. Citi may enter into partial-term 
hedges as well as full-term hedges. In advance of the 
expiration of partial-term hedges, Citi will determine, among 
other factors, the economic feasibility of hedging the 
remaining life of the instrument. The results of the mark-to-
market and any realized gains or losses on credit derivatives 
are reflected primarily in Principal transactions in the 
Consolidated Statement of Income.

At December 31, 2019, September 30, 2019 and 

December 31, 2018, Citigroup had economic hedges in place 
on the corporate credit portfolio of $35.2 billion, $29.5 billion 
and $30.2 billion, respectively. Citigroup’s expected loss 
model used in the calculation of its loan loss reserve does not 
include the favorable impact of credit derivatives and other 
mitigants that are marked to market. In addition, the reported 
amounts of direct outstandings and unfunded lending 
commitments in the tables above do not reflect the impact of 
these hedging transactions. The credit protection was 
economically hedging underlying corporate credit portfolio 
exposures with the following risk rating distribution:

70

 
 
Loan Maturities and Fixed/Variable Pricing of Corporate
Loans

Over 1
year
but
within
5 years

Due
within
1 year

Over 5
years

Total

$ 20,679 $ 21,623 $ 13,627 $ 55,929

In millions of dollars at
December 31, 2019

Corporate loans

In U.S. offices

Commercial and
industrial loans

Financial institutions

19,938

20,846

13,138

53,922

Mortgage and real
estate
Installment,
revolving credit and
other

Lease financing

In offices outside
the U.S.

Total corporate
loans

Fixed/variable
pricing of corporate
loans with
maturities due after
one year(1)
Loans at fixed
interest rates
Loans at floating or
adjustable interest
rates

Total

19,735

20,633

13,003

53,371

11,550

12,077

7,611

31,238

477

499

314

1,290

124,384

59,295

10,506

194,185

$ 196,763 $ 134,973 $ 58,199 $ 389,935

$ 22,432 $ 20,676

112,541

37,523

$ 134,973 $ 58,199

(1)  Based on contractual terms. Repricing characteristics may effectively
be modified from time to time using derivative contracts. See Note 22
to the Consolidated Financial Statements.

71

 
 
ADDITIONAL CONSUMER AND CORPORATE CREDIT DETAILS

Loans Outstanding

In millions of dollars
Consumer loans
In North America offices(1)

Residential first mortgages(2)
Home equity loans(2)
Credit cards
Personal, small business and other

Total
In offices outside North America(1)
Residential first mortgages(2)
Credit cards
Personal, small business and other

Total
Consumer loans, net of unearned income(3)
Corporate loans
In North America offices(1)
Commercial and industrial
Financial institutions
Mortgage and real estate(2)
Installment, revolving credit and other
Lease financing

Total
In offices outside North America(1)

Commercial and industrial
Financial institutions
Mortgage and real estate(2)
Installment, revolving credit and other
Lease financing
Governments and official institutions

Total
Corporate loans, net of unearned income(4)
Total loans—net of unearned income
Allowance for loan losses—on drawn exposures
Total loans—net of unearned income 
  and allowance for credit losses
Allowance for loan losses as a percentage of total loans—  
  net of unearned income(5)
Allowance for consumer loan losses as a percentage of 
  total consumer loans—net of unearned income(5)
Allowance for corporate loan losses as a percentage of 
  total corporate loans—net of unearned income(5)

2019

2018

December 31,
2017

2016

2015

$

$

$

$
$

$

$

$

$
$
$

$

47,008
9,223
149,163
3,699
209,093

37,686
25,909
36,860
100,455
309,548

55,929
53,922
53,371
31,238
1,290
195,750

112,668
40,211
9,780
27,303
95
4,128
194,185
389,935
699,483
(12,783)

686,700

$

$

$

$
$

$

$

$

$
$
$

$

47,412
11,543
144,542
4,046
207,543

35,972
24,951
33,894
94,817
302,360

60,861
48,447
50,124
32,425
1,429
193,286

114,029
36,837
7,376
25,685
103
4,520
188,550
381,836
684,196
(12,315)

$

$

$

$
$

$

$

$

$
$
$

49,375
14,827
139,718
4,140
208,060

37,419
25,727
34,608
97,754
305,814

60,219
39,128
44,683
31,932
1,470
177,432

113,178
35,273
7,309
22,638
190
5,200
183,788
361,220
667,034
(12,355)

$

$

$

$
$

$

$

$

$
$
$

53,131
19,454
133,297
5,290
211,172

35,336
23,055
31,153
89,544
300,716

57,886
35,517
38,691
31,194
1,518
164,806

100,532
26,886
5,363
19,965
251
5,850
158,847
323,653
624,369
(12,060)

$

$

$

$
$

$

$

$

$
$
$

56,872
22,745
113,352
5,396
198,365

40,139
26,617
35,980
102,736
301,101

53,611
36,425
32,623
30,426
1,780
154,865

99,442
28,704
5,106
23,185
303
4,911
161,651
316,516
617,617
(12,626)

671,881

$

654,679

$

612,309

$

604,991

1.84%

3.20%

0.75%

1.81%

3.14%

0.74%

1.86%

3.08%

0.82%

1.94%

2.94%

1.01%

2.06%

3.08%

1.08%

(1)  North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America. The classification of corporate loans between 

offices in North America and outside North America is based on the domicile of the booking unit. The difference between the domicile of the booking unit and the 
domicile of the managing unit is not material.

(2)  Loans secured primarily by real estate.
(3)  Consumer loans are net of unearned income of $783 million, $742 million, $768 million, $803 million and $850 million at December 31, 2019, 2018, 2017, 2016 

and 2015, respectively. Unearned income on consumer loans primarily represents unamortized origination fees and costs, premiums and discounts. 

(4)  Corporate loans are net of unearned income of $(814) million, $(855) million, $(794) million, $(730) million and $(686) million at December 31, 2019, 2018, 

2017, 2016 and 2015, respectively. Unearned income on corporate loans primarily represents interest received in advance, but not yet earned, on loans originated 
on a discounted basis.

(5)  All periods exclude loans that are carried at fair value.

72

Details of Credit Loss Experience

In millions of dollars

Allowance for loan losses at beginning of period

Provision for loan losses

Consumer

Corporate

Total

Gross credit losses

Consumer

In U.S. offices

In offices outside the U.S. 

Corporate

Commercial and industrial, and other

In U.S. offices

In offices outside the U.S. 

Loans to financial institutions

In U.S. offices

In offices outside the U.S. 

Mortgage and real estate

In U.S. offices

In offices outside the U.S.

Total
Credit recoveries(1)
Consumer

In U.S. offices

In offices outside the U.S. 

Corporate

Commercial and industrial, and other

In U.S. offices

In offices outside the U.S. 

Loans to financial institutions

In U.S. offices

In offices outside the U.S. 

Mortgage and real estate

In U.S. offices

In offices outside the U.S. 

Total

Net credit losses

In U.S. offices

In offices outside the U.S. 

Total
Other—net(2)(3)(4)(5)(6)(7)(8)
Allowance for loan losses at end of period
Allowance for loan losses as a percentage of total loans(9)
Allowance for unfunded lending commitments(8)(10)

Total allowance for loan losses and unfunded lending
commitments

Net consumer credit losses

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

2019

12,315

7,751

467

8,218

6,538

2,316

265

196

—

3

23

—

2018

12,355

7,258

96

7,354

$

$

$

2017

12,060

7,329

174

7,503

$

$

$

2016

12,626

6,207

542

6,749

$

$

$

5,971

$

5,664

$

4,874

$

2,351

2,377

2,594

121

208

3

7

2

2

223

401

3

1

2

2

370

334

5

5

34

6

2015

15,994

6,073

1,035

7,108

5,439

3,077

173

297

—

4

8

43

9,341

$

8,665

$

8,673

$

8,222

$

9,041

$

975

503

$

912

502

$

892

552

$

972

576

954

642

47

78

—

3

6

4

31

117

1

1

2

1

31

79

1

1

1

—

1,552

5,132

1,981

7,113

$

$

$

1,597

4,966

2,110

7,076

$

$

$

1,661

4,278

2,283

6,561

$

$

$

(281) $

(132) $

(754) $

12,315

1.81%

1,367

13,682

6,908

$

$

$

$

12,355

1.86%

1,258

13,613

6,597

$

$

$

$

12,060

1.94%

1,418

13,478

5,920

$

$

$

$

43

84

7

2

7

—

1,739

4,609

2,693

7,302

(3,174)

12,626

2.06%

1,402

14,028

6,920

28

59

—

—

8

—

$

$

$

$

$

$

$

$

1,573

5,815

1,953

7,768

18

12,783

1.84%

1,456

14,239

7,376

73

As a percentage of average consumer loans

Net corporate credit losses

As a percentage of average corporate loans
Allowance by type at end of period(11)

Consumer

Corporate

Total Citigroup

2.49%

392

$

0.10%

2.33%

205

$

0.05%

2.22%

479

$

0.14%

2.00%

641

$

0.20%

2.19%

382

0.12%

9,897

2,886

12,783

$

$

9,504

2,811

12,315

$

$

9,412

2,943

12,355

$

$

8,842

3,218

12,060

$

$

9,273

3,353

12,626

$

$

$

(1)  Recoveries have been reduced by certain collection costs that are incurred only if collection efforts are successful.
(2) 

Includes all adjustments to the allowance for credit losses, such as changes in the allowance from acquisitions, dispositions, securitizations, FX translation, 
purchase accounting adjustments, etc.

(3)  2019 includes reductions of approximately $42 million related to the transfer to HFS of various real estate loan portfolios. In addition, 2019 includes an increase 

of approximately $60 million related to FX translation.

(4)  2018 includes reductions of approximately $201 million related to the sale or transfer to HFS of various loan portfolios, which include approximately $91 million 

related to the transfer of various real estate loan portfolios to HFS. In addition, 2018 includes a reduction of approximately $60 million related to FX translation.
(5)  2017 includes reductions of approximately $261 million related to the sale or transfer to HFS of various loan portfolios, which include approximately $106 million 

related to the transfer of various real estate loan portfolios to HFS. In addition, 2017 includes an increase of approximately $115 million related to FX translation.

(6)  2016 includes reductions of approximately $574 million related to the sale or transfer to HFS of various loan portfolios, which include approximately $106 million 

related to the transfer of various real estate loan portfolios to HFS. In addition, 2016 includes a reduction of approximately $199 million related to FX translation.
(7)  2015 includes reductions of approximately $2.4 billion related to the sale or transfer to HFS of various loan portfolios, which include approximately $1.5 billion 
related to the transfer of various real estate loan portfolios to HFS. In addition, 2015 includes a reduction of approximately $474 million related to FX translation.

(8)  2015 includes a reclassification of $271 million of Allowance for loan losses to allowance for unfunded lending commitments, included in the Other line item. 

This reclassification reflects the re-attribution of $271 million in the allowance for credit losses between the funded and unfunded portions of the corporate credit 
portfolios and does not reflect a change in the underlying credit performance of these portfolios.

(9)  December 31, 2019, 2018, 2017, 2016 and 2015 exclude $4.1 billion, $3.2 billion, $4.4 billion, $3.5 billion and $5.0 billion, respectively, of loans which are 

carried at fair value.

(10)  Represents additional credit reserves recorded as Other liabilities on the Consolidated Balance Sheet.
(11)  Allowance for loan losses represents management’s best estimate of probable losses inherent in the portfolio, as well as probable losses related to large 

individually evaluated impaired loans and troubled debt restructurings. See “Significant Accounting Policies and Significant Estimates” and Note 1 to the 
Consolidated Financial Statements below. Attribution of the allowance is made for analytical purposes only and the entire allowance is available to absorb 
probable credit losses inherent in the overall portfolio.

74

Allowance for Loan Losses
The following tables detail information on Citi’s allowance for loan losses, loans and coverage ratios:

December 31, 2019

(1)  Allowance as a percentage of loans excludes loans that are carried at fair value.
(2) 

Includes both Citi-branded cards and Citi retail services. The $7.0 billion of loan loss reserves represented approximately 15 months of coincident net credit loss 
coverage.

(3)  Of the $0.3 billion, nearly all was allocated to North America mortgages in Corporate/Other, including $0.1 billion and $0.2 billion determined in accordance with 
ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. Of the $56.2 billion in loans, approximately $54.2 billion and $2.0 billion of the 
loans were evaluated in accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. For additional information, see Note 15 to 
the Consolidated Financial Statements.
Includes mortgages and other retail loans.

(4) 

December 31, 2018

Allowance for
loan losses

Loans, net of
unearned income
149.2
56.2
3.7
25.9
74.6
309.6
389.9
699.5

7.0 $
0.3
0.1
0.7
1.8
9.9 $
2.9
12.8 $

Allowance as a
percentage of loans(1)

4.7%
0.5
2.7
2.7
2.4
3.2%
0.7
1.8%

Allowance for
loan losses

Loans, net of
unearned income
144.5
59.0
4.0
25.0
69.9
302.4
381.8
684.2

6.6 $
0.4
0.1
0.7
1.7
9.5 $
2.8
12.3 $

Allowance as a
percentage of loans(1)

4.6%
0.7
2.5
2.8
2.4
3.1%
0.7
1.8%

$

$

$

$

$

$

In billions of dollars
North America cards(2)
North America mortgages(3)
North America other
International cards
International other(4)
Total consumer
Total corporate
Total Citigroup

In billions of dollars
North America cards(2)
North America mortgages(3)
North America other
International cards
International other(4)
Total consumer
Total corporate
Total Citigroup

(1)  Allowance as a percentage of loans excludes loans that are carried at fair value.
(2) 

Includes both Citi-branded cards and Citi retail services. The $6.6 billion of loan loss reserves represented approximately 16 months of coincident net credit loss 
coverage.

(3)  Of the $0.4 billion, nearly all was allocated to North America mortgages in Corporate/Other, including approximately $0.1 billion and $0.3 billion determined in 
accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. Of the $59.0 billion in loans, approximately $56.3 billion and $2.5 
billion were evaluated in accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. For additional information, see Note 15 to 
the Consolidated Financial Statements.
Includes mortgages and other retail loans.

(4) 

75

 
 
 Non-Accrual Loans and Assets and Renegotiated Loans
There is a certain amount of overlap among non-accrual loans 
and assets and renegotiated loans. The following summary 
provides a general description of each category.

Non-Accrual Loans and Assets:

•  Corporate and consumer (including commercial banking) 
non-accrual status is based on the determination that 
payment of interest or principal is doubtful.

•  A corporate loan may be classified as non-accrual and still 

be performing under the terms of the loan structure. Non-
accrual loans may still be current on interest payments. 
Approximately 44%, 41% and 48% of Citi’s corporate 
non-accrual loans were performing at December 31, 2019, 
September 30, 2019 and December 31, 2018, respectively.
•  Consumer non-accrual status is generally based on aging, 

i.e., the borrower has fallen behind on payments.
•  Consumer mortgage loans, other than Federal Housing 

Administration (FHA) insured loans, are classified as 
non-accrual within 60 days of notification that the 
borrower has filed for bankruptcy. In addition, home 
equity loans are classified as non-accrual if the related 
residential first mortgage loan is 90 days or more past 
due.

•  North America Citi-branded cards and Citi retail services 
are not included because, under industry standards, credit 
card loans accrue interest until such loans are charged off, 
which typically occurs at 180 days of contractual 
delinquency.

Renegotiated Loans:

• 

• 

Includes both corporate and consumer loans whose terms 
have been modified in a troubled debt restructuring 
(TDR).
Includes both accrual and non-accrual TDRs.

76

Non-Accrual Loans
The table below summarizes Citigroup’s non-accrual loans as 
of the periods indicated. Non-accrual loans may still be 
current on interest payments. In situations where Citi 
reasonably expects that only a portion of the principal owed 

will ultimately be collected, all payments received are 
reflected as a reduction of principal and not as interest income. 
For all other non-accrual loans, cash interest receipts are 
generally recorded as revenue.

In millions of dollars
Corporate non-accrual loans(1)(2)
North America

EMEA

Latin America

Asia

Total corporate non-accrual loans
Consumer non-accrual loans(1)(3)
North America

Latin America
Asia(4)
Total consumer non-accrual loans

Total non-accrual loans

2019

2018

2017

2016

2015

December 31,

$

$

$

$

$

1,214 $

586 $

966 $

1,291 $

1,005

430

473

71

375

307

243

849

348

70

904

441

220

347

421

191

2,188 $

1,511 $

2,233 $

2,856 $

1,964

905 $

1,138 $

1,468 $

1,854 $

632

279

1,816 $

4,004 $

638

250

2,026 $

3,537 $

688

243

2,399 $

4,632 $

648

221

2,723 $

5,579 $

2,328

756

206

3,290

5,254

(1)  Excludes purchased distressed loans, as they are generally accreting interest. The carrying value of these loans was $128 million at December 31, 2019, $128 

million at December 31, 2018, $167 million at December 31, 2017, $187 million at December 31, 2016 and $250 million at December 31, 2015.

(2)  The 2016 increase in corporate non-accrual loans was primarily related to Citi’s North America and EMEA energy and energy-related corporate credit exposure.
(3)  The 2015 decline in consumer non-accrual loans includes the impact related to the transfer of approximately $8 billion of mortgage loans to Loans HFS (included 

within Other assets). 

(4)  Asia includes balances in certain EMEA countries for all periods presented.

The changes in Citigroup’s non-accrual loans were as follows:

Year ended

December 31, 2019

Year ended

December 31, 2018

In millions of dollars

Corporate

Consumer

Total

Corporate

Consumer

Total

Non-accrual loans at beginning of period

$

1,511 $

2,026 $

3,537 $

2,233 $

2,399 $

Additions

Sales and transfers to HFS

Returned to performing

Paydowns/settlements

Charge-offs

Other

Ending balance

3,407

(23)

(68)

(2,496)

(268)

125

2,954

(171)

(431)

(902)

(1,444)

(216)

6,361

(194)

(499)

(3,398)

(1,712)

(91)

2,108

(119)

(127)

(2,282)

(196)

(106)

3,148

(268)

(629)

(1,052)

(1,634)

62

$

2,188 $

1,816 $

4,004 $

1,511 $

2,026 $

4,632

5,256

(387)

(756)

(3,334)

(1,830)

(44)

3,537

77

Non-Accrual Assets
The table below summarizes Citigroup’s other real estate owned (OREO) assets. OREO is recorded on the Consolidated Balance 
Sheet within Other assets. This represents the carrying value of all real estate property acquired by foreclosure or other legal 
proceedings when Citi has taken possession of the collateral:

In millions of dollars

OREO

North America

EMEA

Latin America

Asia

Total OREO

Non-accrual assets

Corporate non-accrual loans

Consumer non-accrual loans

Non-accrual loans (NAL)

OREO

Non-accrual assets (NAA)

NAL as a percentage of total loans

NAA as a percentage of total assets
Allowance for loan losses as a percentage of NAL(1)

2019

2018

2017

2016

2015

December 31,

$

$

$

$

$

$

$

$

$

$

$

$

39

1

14

7

61

2,188

1,816

4,004

61

4,065

0.57%

0.21

319

$

$

$

$

$

$

64

1

12

22

99

1,511

2,026

3,537

99

3,636

0.52%

0.19

348

$

$

$

$

$

$

89

2

35

18

144

2,233

2,399

4,632

144

4,776

0.69%

0.26

267

161

$

—

18

7

186

2,856

2,723

5,579

186

5,765

0.89%

0.32

216

$

$

$

$

$

166

1

38

4

209

1,964

3,290

5,254

209

5,463

0.85%

0.32

240

(1)  The allowance for loan losses includes the allowance for Citi’s credit card portfolios and purchased distressed loans, while the non-accrual loans exclude credit 

card balances (with the exception of certain international portfolios) and purchased distressed loans as these continue to accrue interest until charge-off.

78

Renegotiated Loans
The following table presents Citi’s loans modified in TDRs:

Forgone Interest Revenue on Loans(1)  

In millions of dollars

Interest revenue that 
would have been 
accrued at original 
contractual rates(2)
Amount recognized as 
interest revenue(2)
Forgone interest
revenue

$

$

In U.S.
offices

In non-
U.S.
offices

2019
total

488 $

421 $

130

112

358 $

309 $

909

242

667

(1)   Relates to corporate non-accrual loans, renegotiated loans and consumer 

(2) 

loans on which accrual of interest has been suspended. 
Interest revenue in offices outside the U.S. may reflect prevailing local 
interest rates, including the effects of inflation and monetary correction 
in certain countries.

In millions of dollars
Corporate renegotiated loans(1)
In U.S. offices

Commercial and industrial
Mortgage and real estate
Financial institutions
Other

Total
In offices outside the U.S.

Commercial and industrial(2)
Mortgage and real estate
Financial institutions
Other

Total
Total corporate renegotiated loans
Consumer renegotiated loans(3)
In U.S. offices

Mortgage and real estate
Cards
Installment and other

Total
In offices outside the U.S.
Mortgage and real estate
Cards
Installment and other

Total
Total consumer renegotiated loans

Dec. 31,
2019

Dec. 31,
2018

$

$

$

$
$

$

$

$

$
$

226 $
57
—
4
287 $

200 $
22
—
40
262 $
549 $

188
111
16
2
317

226
12
9
—
247
564

1,956 $ 2,520
1,464
1,338
17
13
3,437 $ 3,871

305 $
466
400

299
480
387
1,171 $ 1,166
4,608 $ 5,037

(1) 

(2) 

(3) 

Includes $472 million and $466 million of non-accrual loans included in 
the non-accrual loans table above at December 31, 2019 and 2018, 
respectively. The remaining loans are accruing interest.
In addition to modifications reflected as TDRs at December 31, 2019 
and 2018, Citi also modified $26 million and $2 million in offices 
outside the U.S., respectively, of commercial loans risk rated 
“Substandard Non-Performing” or worse (asset category defined by 
banking regulators). These modifications were not considered TDRs 
because the modifications did not involve a concession.
Includes $814 million and $933 million of non-accrual loans included in 
the non-accrual loans table above at December 31, 2019 and 2018, 
respectively. The remaining loans are accruing interest.

79

 
 
LIQUIDITY RISK

Overview
Adequate and diverse sources of funding and liquidity are 
essential to Citi’s businesses. Funding and liquidity risks arise 
from several factors, many of which are mostly or entirely 
outside Citi’s control, such as disruptions in the financial 
markets, changes in key funding sources, credit spreads, 
changes in Citi’s credit ratings and macroeconomic, 
geopolitical and other conditions. For additional information, 
see “Risk Factors” above.

Citi’s funding and liquidity management objectives are 
aimed at (i) funding its existing asset base, (ii) growing its 
core businesses, (iii) maintaining sufficient liquidity, 
structured appropriately, so that Citi can operate under a 
variety of adverse circumstances, including potential 
Company-specific and/or market liquidity events in varying 
durations and severity, and (iv) satisfying regulatory 
requirements, including, among other things, those related to 
resolution planning (for additional information, see 
“Resolution Plan” and “Total Loss-Absorbing Capacity 
(TLAC)” below). Citigroup’s primary liquidity objectives are 
established by entity, and in aggregate, across two major 
categories:

•  Citibank (including Citibank Europe plc, Citibank 

Singapore Ltd. and Citibank (Hong Kong) Ltd.); and
•  Citi’s non-bank and other entities, including the parent 
holding company (Citigroup Inc.), Citi’s primary 
intermediate holding company (Citicorp LLC), Citi’s 
broker-dealer subsidiaries (including Citigroup Global 
Markets Inc., Citigroup Global Markets Ltd. and 
Citigroup Global Markets Japan Inc.) and other bank and 
non-bank subsidiaries that are consolidated into Citigroup 
(including Citibanamex).

At an aggregate Citigroup level, Citi’s goal is to maintain 
sufficient funding in amount and tenor to fully fund customer 
assets and to provide an appropriate amount of cash and high-
quality liquid assets (as discussed below), even in times of 
stress, in order to meet its payment obligations as they come 
due. The liquidity risk management framework provides that 
in addition to the aggregate requirements, certain entities be 
self-sufficient or net providers of liquidity, including in 
conditions established under their designated stress tests.

Citi’s primary sources of funding include (i) deposits via 

Citi’s bank subsidiaries, which are Citi’s most stable and 
lowest cost source of long-term funding, (ii) long-term debt 
(primarily senior and subordinated debt) primarily issued at 
the parent and certain bank subsidiaries, and (iii) stockholders’ 
equity. These sources may be supplemented by short-term 
borrowings, primarily in the form of secured funding 
transactions.

As referenced above, Citi’s funding and liquidity 

framework ensures that the tenor of these funding sources is of 
sufficient term in relation to the tenor of its asset base. The 
goal of Citi’s asset/liability management is to ensure that there 
is excess liquidity and tenor in the liability structure relative to 
the liquidity profile of the assets. This reduces the risk that 
liabilities will become due before assets mature or are 
monetized. This excess liquidity is held primarily in the form 
of high-quality liquid assets (HQLA), as set forth in the table 
below. 

Citi’s liquidity is managed via a centralized treasury 

model by Treasury, in conjunction with regional and in-
country treasurers with independent oversight provided by 
Independent Risk Management. Pursuant to this approach, 
Citi’s HQLA are managed with emphasis on asset-liability 
management and entity-level liquidity adequacy throughout 
Citi.

The Chief Risk Officer and Citi’s CFO co-chair Citi’s 

Asset Liability Management Committee (ALCO), which 
includes Citi’s Treasurer and other senior executives. ALCO, 
among other things, sets the strategy of the liquidity portfolio 
and monitors its performance. Significant changes to portfolio 
asset allocations need to be approved by ALCO.

Liquidity Monitoring and Measurement

Stress Testing 
Liquidity stress testing is performed for each of Citi’s major 
entities, operating subsidiaries and/or countries. Stress testing 
and scenario analyses are intended to quantify the potential 
impact of an adverse liquidity event on the balance sheet and 
liquidity position, and to identify viable funding alternatives 
that can be utilized. These scenarios include assumptions 
about significant changes in key funding sources, market 
triggers (such as credit ratings), potential uses of funding and 
macroeconomic, geopolitical and other conditions. These 
conditions include expected and stressed market conditions as 
well as Company-specific events.

Liquidity stress tests are performed to ascertain potential 
mismatches between liquidity sources and uses over a variety 
of time horizons and over different stressed conditions. 
Liquidity limits are set accordingly. To monitor the liquidity of 
an entity, these stress tests and potential mismatches are 
calculated with varying frequencies, with several tests 
performed daily.

Given the range of potential stresses, Citi maintains 

contingency funding plans on a consolidated basis and for 
individual entities. These plans specify a wide range of readily 
available actions for a variety of adverse market conditions or 
idiosyncratic stresses.

80

 
High-Quality Liquid Assets (HQLA)

In billions of dollars

Available cash

U.S. sovereign

U.S. agency/agency MBS
Foreign government debt(1)
Other investment grade

Dec. 31,
2019

Citibank
Sept. 30,
2019

Dec. 31,
2018

Citi non-bank and other entities
Dec. 31,
Dec. 31,
Sept. 30,
2019
2018
2019

Dec. 31,
2019

Total
Sept. 30,
2019

Dec. 31,
2018

$

158.7 $

123.7 $

97.1 $

2.1 $

31.8 $

27.6 $

160.8 $

155.5 $

100.2

56.9

66.4

2.4

94.3

55.5

65.9

2.9

103.2

60.0

76.8

1.5

29.6

4.4

16.5

0.5

32.4

4.6

10.9

0.7

24.0

5.8

6.3

1.4

129.8

126.7

61.3

82.9

2.8

60.1

76.8

3.6

124.7

127.2

65.8

83.1

2.9

Total HQLA (AVG)

$

384.6 $

342.3 $

338.6 $

53.1 $

80.4 $

65.1 $

437.6 $

422.7 $

403.7

Note: The amounts set forth in the table above are presented on an average basis. For securities, the amounts represent the liquidity value that potentially could be 
realized and, therefore, exclude any securities that are encumbered and incorporate any haircuts that would be required for securities financing transactions. The table 
above incorporates various restrictions that could limit the transferability of liquidity between legal entities, including Section 23A of the Federal Reserve Act.
(1)   Foreign government debt includes securities issued or guaranteed by foreign sovereigns, agencies and multilateral development banks. Foreign government debt 
securities are held largely to support local liquidity requirements and Citi’s local franchises and principally include government bonds from Mexico, Hong Kong, 
South Korea, Singapore, India and Brazil. 

The table above includes average amounts of HQLA held at 
Citigroup’s operating entities that are eligible for inclusion in 
the calculation of Citigroup’s consolidated Liquidity Coverage 
Ratio (LCR), pursuant to the U.S. LCR rules. These amounts 
include the HQLA needed to meet the minimum requirements 
at these entities and any amounts in excess of these minimums 
that are assumed to be transferable to other entities within 
Citigroup. Citigroup’s HQLA increased sequentially, reflecting 
deposit growth and the issuance of long-term debt.

Citi’s HQLA as set forth above does not include Citi’s 
available borrowing capacity from the Federal Home Loan 
Banks (FHLBs) of which Citi is a member, which was 
approximately $35 billion as of December 31, 2019 (compared 
to $40 billion as of September 30, 2019 and $29 billion as of 
December 31, 2018) and maintained by eligible collateral 
pledged to such banks. The HQLA also does not include Citi’s 
borrowing capacity at the U.S. Federal Reserve Bank discount 
window or other central banks, which would be in addition to 
the resources noted above.

Short-Term Liquidity Measurement: Liquidity Coverage 
Ratio (LCR)
In addition to internal 30-day liquidity stress testing performed 
for Citi’s major entities, operating subsidiaries and countries, 
Citi also monitors its liquidity by reference to the LCR.

Generally, the LCR is designed to ensure that banks 
maintain an adequate level of HQLA to meet liquidity needs 
under an acute 30-day stress scenario. The LCR is calculated 
by dividing HQLA by estimated net outflows over a stressed 
30-day period, with the net outflows determined by applying 
prescribed outflow factors to various categories of liabilities, 
such as deposits, unsecured and secured wholesale 
borrowings, unused lending commitments and derivatives-
related exposures, partially offset by inflows from assets 
maturing within 30 days. Banks are required to calculate an 
add-on to address potential maturity mismatches between 
contractual cash outflows and inflows within the 30-day 
period in determining the total amount of net outflows. The 
minimum LCR requirement is 100%.

 The table below details the components of Citi’s LCR 

calculation and HQLA in excess of net outflows for the 
periods indicated:

In billions of dollars

HQLA

Net outflows

LCR

Dec. 31,
2019

Sept. 30,
2019

Dec. 31,
2018

$ 437.6

$ 422.7

$ 403.7

382.0

373.4

334.8

115%

113%

121%

HQLA in excess of net outflows

$ 55.6

$

49.3

$

68.9

Note: The amounts are presented on an average basis.

Citi’s average LCR increased sequentially, reflecting the 

issuance of long-term debt. 

81

 
Long-Term Liquidity Measurement: Net Stable Funding 
Ratio (NSFR)
In 2016, the Federal Reserve Board, the FDIC and the OCC 
issued a proposed rule to implement the Basel III NSFR 
requirement. 

  The U.S.-proposed NSFR is largely consistent with the 
Basel Committee’s final NSFR rules. In general, the NSFR 
assesses the availability of a bank’s stable funding against a 
required level. A bank’s available stable funding would 
include portions of equity, deposits and long-term debt, while 
its required stable funding would be based on the liquidity 
characteristics and encumbrance period of its assets, 
derivatives and commitments. Prescribed factors would be 
required to be applied to the various categories of asset and 
liabilities classes. The ratio of available stable funding to 
required stable funding would be required to be greater than 
100%.

While Citi believes that it is compliant with the proposed 

U.S. NSFR rules as of December 31, 2019, it will need to 
evaluate a final version of the rules. Citi expects that the 
NSFR final rules implementation period will be 
communicated along with the final version of the rules.

Loans
As part of its funding and liquidity objectives, Citi seeks to 
fund its existing asset base appropriately as well as maintain 
sufficient liquidity to grow its GCB and ICG businesses, 
including its loan portfolio. Citi maintains a diversified 
portfolio of loans to its consumer and institutional clients. The 
table below details the average loans, by business and/or 
segment, and the total end-of-period loans for each of the 
periods indicated:

In billions of dollars

Global Consumer Banking

North America

Latin America
Asia(1)

Total

Institutional Clients Group

Corporate lending
Treasury and trade solutions
(TTS)

Private bank

Markets and securities services 
and other

Total

Total Corporate/Other

Total Citigroup loans (AVG)

Total Citigroup loans (EOP)

Dec. 31,
2019

Sept. 30,
2019

Dec. 31,
2018

$

192.7 $

188.8 $

186.8

17.4

80.9

17.0

78.3

16.9

76.7

$

291.0 $

284.1 $

280.4

$

154.2 $

160.9 $

158.2

74.5

106.6

72.5

104.0

77.0

94.7

56.0

52.3

49.2

$

$

$

$

391.3 $

389.7 $

379.1

10.3 $

11.2 $

16.0

692.6 $

685.0 $

675.5

699.5 $

691.7 $

684.2

(1) 

Includes loans in certain EMEA countries for all periods presented.

End-of period loans increased 2% year-over-year and 1% 
quarter-over-quarter. On an average basis, loans increased 3% 
year-over-year and 1% quarter-over-quarter.

82

Excluding the impact of FX translation, average loans 

increased 3% year-over-year, driven by 4% aggregate across 
GCB and ICG. Within GCB, average loans grew 4%, driven 
by continued growth in North America GCB and Asia GCB. 
Average loans in Latin America GCB were largely unchanged 
year-over-year, reflecting lower overall industry volumes.

Average ICG loans increased 3% year-over-year. Treasury 

and trade solutions (TTS) loans declined 3% year-over-year, 
as Citi continued to utilize its distribution capabilities in order 
to optimize its balance sheet while supporting its clients. 
Corporate lending loans declined 2%, reflecting the episodic 
nature of clients’ funding needs, as well as an active quarter in 
debt capital markets originations. Private bank loans increased 
13%, reflecting growth across regions, driven by both new 
clients and the deepening of relationships with existing clients. 
Markets and securities services loans increased 14%, 
primarily driven by residential and commercial real estate 
warehouse lending.

Average Corporate/Other loans continued to decline 

(down 34%), driven by the wind-down of legacy assets. 

Deposits
The table below details the average deposits, by business and/
or segment, and the total end-of-period deposits for each of the 
periods indicated:

In billions of dollars

Global Consumer Banking

North America

Latin America
Asia(1)

Total

Institutional Clients Group

Treasury and trade solutions
(TTS)

Banking ex-TTS

Markets and securities services

Total
Total Corporate/Other

Dec. 31,
2019

Sept. 30,
2019

Dec. 31,
2018

$

156.2 $

153.6 $

146.5

23.0

103.4

22.5

100.7

22.3

97.7

$

282.6 $

276.8 $

266.5

$

558.7 $

541.0 $

510.9

140.7

95.0

137.0

95.7

$
$

794.4 $
12.5 $

773.7 $
15.8 $

128.3

86.7

725.9
13.3

Total Citigroup deposits (AVG)

$ 1,089.5 $ 1,066.3 $ 1,005.7

Total Citigroup deposits (EOP)

$ 1,070.6 $ 1,087.8 $ 1,013.2

(1) 

Includes deposits in certain EMEA countries for all periods presented.

End-of-period deposits increased 6% year-over-year and 

declined 2% quarter-over-quarter. On an average basis, 
deposits increased 8% year-over-year and 2% quarter-over-
quarter.

Excluding the impact of FX translation, average deposits 
increased 9% year-over-year. In GCB, deposits increased 6%, 
driven by continued growth in Asia GCB and North America 
GCB. In North America GCB, deposit growth accelerated to 
7%, with contributions from both traditional and digital 
channels. 

In ICG, deposits increased 10%, primarily driven by high-

quality deposit growth in TTS.

Long-Term Debt 
Long-term debt (generally defined as debt with original 
maturities of one year or more) represents the most significant 
component of Citi’s funding for the Citigroup parent company 
and Citi’s non-bank subsidiaries and is a supplementary source 
of funding for the bank entities. 

Long-term debt is an important funding source due in part 

to its multi-year contractual maturity structure. The weighted-
average maturity of unsecured long-term debt issued by 
Citigroup and its affiliates (including Citibank) with a 
remaining life greater than one year was approximately 
8.4 years as of December 31, 2019, unchanged from 
September 30, 2019 and a slight decline from the prior year. 
The weighted-average maturity is calculated based on the 
contractual maturity of each security. For securities that are 
redeemable prior to maturity at the option of the holder, the 
weighted-average maturity is calculated based on the earliest 
date an option becomes exercisable.

Citi’s long-term debt outstanding at the Citigroup parent 

company includes benchmark senior and subordinated debt 
and what Citi refers to as customer-related debt, consisting of 
structured notes, such as equity- and credit-linked notes, as 
well as non-structured notes. Citi’s issuance of customer-
related debt is generally driven by customer demand and 
supplements benchmark debt issuance as a source of funding 
for Citi’s non-bank entities. Citi’s long-term debt at the bank 
includes benchmark senior debt, FHLB advances and 
securitizations. 

Long-Term Debt Outstanding
The following table sets forth Citi’s end-of-period total long-
term debt outstanding for each of the dates indicated:

In billions of dollars
Parent and other(1)
Benchmark debt:
Senior debt
Subordinated debt
Trust preferred
Customer-related debt
Local country and other(2)
Total parent and other
Bank
FHLB borrowings
Securitizations(3)
Citibank benchmark senior debt
Local country and other(2)
Total bank
Total long-term debt

Dec. 31,
2019

Sept. 30,
2019

Dec. 31,
2018

$ 106.6 $ 104.3 $ 104.6
24.5
1.7
37.1
2.9
$ 195.5 $ 187.3 $ 170.8

25.9
1.7
50.1
5.3

25.5
1.7
53.8
7.9

$

5.5 $
20.7
23.1
4.0
53.3 $

10.5
28.4
18.8
3.5
$
61.2
$ 248.8 $ 242.2 $ 232.0

5.5 $
22.8
23.1
3.5
54.9 $

Note: Amounts represent the current value of long-term debt on Citi’s 
Consolidated Balance Sheet which, for certain debt instruments, includes 
consideration of fair value, hedging impacts and unamortized discounts and 
premiums.
(1)  Parent and other includes long-term debt issued to third parties by the 
parent holding company (Citigroup) and Citi’s non-bank subsidiaries 
(including broker-dealer subsidiaries) that are consolidated into 
Citigroup. As of December 31, 2019, parent and other included $46.9 
billion of long-term debt issued by Citi’s broker-dealer subsidiaries.

(2)  Local country and other includes debt issued by Citi’s affiliates in 

support of their local operations. Within parent and other, certain secured 
financing is also included.

(3)  Predominantly credit card securitizations, primarily backed by Citi-

branded credit card receivables.

Citi’s total long-term debt outstanding increased both 
year-over-year and quarter-over-quarter, largely driven by an 
increase in customer-related debt at the non-bank entities. 
Year-over-year, this growth was partially offset by a decline in 
securitizations at the bank. 

As part of its liability management, Citi has considered, 
and may continue to consider, opportunities to repurchase its 
long-term debt pursuant to open market purchases, tender 
offers or other means. Such repurchases help reduce Citi’s 
overall funding costs. During 2019, Citi repurchased $13.1 
billion of its outstanding long-term debt, including early 
redemptions of FHLB advances, but excluding the exercise of 
call options on $4.0 billion of securities with a remaining life 
of three months or less. 

83

Long-Term Debt Issuances and Maturities
The table below details Citi’s long-term debt issuances and maturities (including repurchases and redemptions) during the periods 
presented:

In billions of dollars

Parent and other

Benchmark debt:

Senior debt

Subordinated debt

Customer-related debt

Local country and other

Total parent and other

Bank

FHLB borrowings

Securitizations

Citibank benchmark senior debt

Local country and other

Total bank

Total

2019

2018

2017

Maturities

Issuances

Maturities

Issuances

Maturities

Issuances

$

$

$

$

$

16.5 $

16.2 $

18.5 $

14.8 $

14.1 $

—

12.7

1.1

—

25.1

5.4

2.9

6.6

1.2

0.6

16.9

2.3

1.6

7.6

1.2

30.3 $

46.7 $

29.2 $

34.6 $

24.5 $

7.1 $

2.1 $

15.8 $

7.9 $

7.8 $

7.9

4.8

0.9

0.1

8.8

1.4

8.6

2.3

2.2

6.8

8.5

2.9

5.3

—

3.4

20.7 $

51.0 $

12.4 $

59.1 $

28.9 $

58.1 $

26.1 $

60.7 $

16.5 $

41.0 $

21.6

1.3

12.3

0.1

35.3

5.5

12.2

12.6

2.4

32.7

68.0

The table below shows Citi’s aggregate long-term debt maturities (including repurchases and redemptions) in 2019, as well as its 
aggregate expected annual long-term debt maturities as of December 31, 2019:

In billions of dollars

Parent and other

Benchmark debt:

Senior debt

Subordinated debt

Trust preferred

Customer-related debt

Local country and other

Total parent and other

Bank

FHLB borrowings

Securitizations

Citibank benchmark senior debt

Local country and other

Total bank

Total long-term debt

2019

2020

2021

2022

2023

2024

Thereafter

Total

Maturities

$

16.5 $

6.4 $

14.2 $

11.3 $

12.5 $

7.0 $

55.2 $

106.6

—

—

12.7

1.1

—

—

9.2

1.0

—

—

6.3

3.6

0.7

—

5.1

1.5

1.2

—

3.7

0.1

0.9

—

3.6

0.1

22.7

1.7

25.9

1.6

25.5

1.7

53.8

7.9

30.3 $

16.6 $

24.1 $

18.6 $

17.5 $

11.6 $

107.1 $

195.5

7.1 $

5.5 $

— $

— $

— $

— $

— $

7.9

4.8

0.9

4.6

8.7

1.9

7.3

6.1

0.6

2.3

5.6

0.6

2.6

—

—

1.1

2.7

0.6

2.8

—

0.3

20.7 $

20.7 $

14.0 $

8.5 $

2.6 $

4.4 $

3.1 $

5.5

20.7

23.1

4.0

53.3

51.0 $

37.3 $

38.1 $

27.1 $

20.1 $

16.0 $

110.2 $

248.8

$

$

$

$

84

 
 
Resolution Plan
Citi is required under Title I of the Dodd-Frank Wall Street 
Reform and Consumer Protection Act of 2010 (Dodd-Frank 
Act) and the rules promulgated by the FDIC and FRB to 
periodically submit a plan for Citi’s rapid and orderly 
resolution under the U.S. Bankruptcy Code in the event of 
material financial distress or failure. For additional 
information on Citi’s resolution plan submissions, see “Risk 
Factors—Strategic Risks” above. Citigroup’s preferred 
resolution strategy is “single point of entry” under the U.S. 
Bankruptcy Code. 

Under Citi’s resolution plan, only Citigroup, the parent 

holding company, would enter into bankruptcy, while 
Citigroup’s material legal entities (as defined in the public 
section of its 2019 resolution plan, which can be found on the 
FRB’s and FDIC’s websites) would remain operational and 
outside of any resolution or insolvency proceedings. 
Citigroup’s resolution plan has been designed to minimize the 
risk of systemic impact to the U.S. and global financial 
systems, while maximizing the value of the bankruptcy estate 
for the benefit of Citigroup’s creditors, including its unsecured 
long-term debt holders. In addition, in line with the Federal 
Reserve’s final total loss-absorbing capacity (TLAC) rule, 
Citigroup believes it has developed the resolution plan so that 
Citigroup’s shareholders and unsecured creditors—including 
its unsecured long-term debt holders—bear any losses 
resulting from Citigroup’s bankruptcy. Accordingly, any value 
realized by holders of its unsecured long-term debt may not be 
sufficient to repay the amounts owed to such debt holders in 
the event of a bankruptcy or other resolution proceeding of 
Citigroup.

The FDIC has also indicated that it was developing a 
single point of entry strategy to implement its resolution 
authority under Title II of the Dodd-Frank Act.

As previously disclosed, in response to feedback received 

from the Federal Reserve and FDIC, Citigroup took the 
following actions:

(i)  Citicorp LLC (Citicorp), an existing wholly owned 
subsidiary of Citigroup, was established as an 
intermediate holding company (an IHC) for certain of 
Citigroup’s operating material legal entities;

(ii)  Citigroup executed an inter-affiliate agreement with 
Citicorp, Citigroup’s operating material legal entities 
and certain other affiliated entities pursuant to which 
Citicorp is required to provide liquidity and capital 
support to Citigroup’s operating material legal entities 
in the event Citigroup were to enter bankruptcy 
proceedings (Citi Support Agreement); 
(iii) pursuant to the Citi Support Agreement:

•  Citigroup made an initial contribution of assets, 
including certain high-quality liquid assets and 
inter-affiliate loans (Contributable Assets), to 
Citicorp, and Citicorp became the business as usual 
funding vehicle for Citigroup’s operating material 
legal entities;

•  Citigroup will be obligated to continue to transfer 
Contributable Assets to Citicorp over time, subject 
to certain amounts retained by Citigroup to, among 

85

• 

other things, meet Citigroup’s near-term cash 
needs; 
in the event of a Citigroup bankruptcy, Citigroup 
will be required to contribute most of its remaining 
assets to Citicorp; and

(iv)  the obligations of both Citigroup and Citicorp under the 
Citi Support Agreement, as well as the Contributable 
Assets, are secured pursuant to a security agreement.

The Citi Support Agreement provides two mechanisms, 
besides Citicorp’s issuing of dividends to Citigroup, pursuant 
to which Citicorp will be required to transfer cash to Citigroup 
during business as usual so that Citigroup can fund its debt 
service as well as other operating needs: (i) one or more 
funding notes issued by Citicorp to Citigroup and (ii) a 
committed line of credit under which Citicorp may make loans 
to Citigroup. 

On December 17, 2019, the FRB and FDIC issued 
feedback on the resolution plans filed on July 1, 2019 by the 
eight U.S. GSIBs, including Citi. The FRB and FDIC 
identified one shortcoming, but no deficiencies, in Citi’s 
resolution plan relating to governance mechanisms. Citi is 
required to submit a plan to address the shortcoming by March 
31, 2020, which the FRB and FDIC will take into account in 
determining the scope of Citi’s targeted resolution plan due on 
July 1, 2021.

Total Loss-Absorbing Capacity (TLAC)
In 2016, the Federal Reserve Board imposed minimum 
external TLAC and long-term debt (LTD) requirements on 
U.S. global systemically important bank holding companies 
(GSIBs), including Citi, effective as of January 1, 2019. As a 
result, U.S. GSIBs are required to maintain minimum levels of 
TLAC and eligible LTD, each set by reference to the GSIB’s 
consolidated risk-weighted assets (RWA) and total leverage 
exposure, as described further below. The intended purpose of 
the requirements is to facilitate the orderly resolution of U.S. 
GSIBs under the U.S. Bankruptcy Code and Title II of the 
Dodd-Frank Act. For additional information, including Citi’s 
TLAC and LTD amounts and ratios, see “Capital Resources— 
Current Regulatory Capital Standards” and “Risk Factors—
Compliance Risks” above. 

Minimum TLAC Requirements
The minimum TLAC requirement is the greater of (i) 18% of 
the GSIB’s RWA plus the then-applicable RWA-based TLAC 
buffer (see below) and (ii) 7.5% of the GSIB’s total leverage 
exposure plus a leveraged-based TLAC buffer of 2% (i.e., 
9.5%). 

The RWA-based TLAC buffer equals the 2.5% capital 

conservation buffer, plus any applicable countercyclical 
capital buffer (currently 0%), plus the GSIB’s capital 
surcharge as determined under method 1 of the GSIB 
surcharge rule (2.0% for Citi for 2020). Accordingly, Citi’s 
total current minimum TLAC requirement is 22.5% of RWA 
for 2020.

As of December 31, 2019, Citi exceeded each of the 
minimum TLAC requirements, with ratios of 11.5% of TLAC 

The remainder of the secured funding activity in the 
broker-dealer subsidiaries serves to fund securities inventory 
held in the context of market making and customer activities. 
To maintain reliable funding under a wide range of market 
conditions, including under periods of stress, Citi manages 
these activities by taking into consideration the quality of the 
underlying collateral and establishing minimum required 
funding tenors. The weighted average maturity of Citi’s 
secured funding of less liquid securities inventory was greater 
than 110 days as of December 31, 2019.

Citi manages the risks in its secured funding by 

conducting daily stress tests to account for changes in 
capacity, tenors, haircut, collateral profile and client actions. 
In addition, Citi maintains counterparty diversification by 
establishing concentration triggers and assessing counterparty 
reliability and stability under stress. Citi generally sources 
secured funding from more than 150 counterparties.

Short-Term Borrowings
Citi’s short-term borrowings of $45 billion increased 39% 
year-over-year and 28% sequentially, primarily driven by an 
increase in FHLB advances as well as commercial paper 
issued out of the broker-dealer entities (see Note 17 to the 
Consolidated Financial Statements for further information on 
Citigroup’s and its affiliates’ outstanding short-term 
borrowings).

as a percentage of Total Leverage Exposure and 24.7% of 
TLAC as a percentage of Standardized Approach RWA.

Minimum Eligible LTD Requirements
The minimum LTD requirement is the greater of (i) 6% of the 
GSIB’s RWA plus its capital surcharge as determined under 
method 2 of the GSIB surcharge rule (3.0% for Citi for 2020), 
for a total current requirement of 9% of RWA for Citi, and (ii) 
4.5% of the GSIB’s total leverage exposure. 

As of December 31, 2019, Citi exceeded each of the 
minimum LTD requirements, with ratios of 10.9% of LTD as a 
percentage of Standardized Approach RWA and 5.1% of LTD 
as a percentage of Total Leverage Exposure.

For additional discussion of the method 1 and method 2 
GSIB capital surcharge methodologies, see “Capital Resources
—Current Regulatory Capital Standards” above. 

Secured Funding Transactions and Short-Term 
Borrowings
Citi supplements its primary sources of funding with short-
term financings that generally include (i) secured funding 
transactions consisting of securities loaned or sold under 
agreements to repurchase, or repos, and (ii) to a lesser extent, 
short-term borrowings consisting of commercial paper and 
borrowings from the FHLB and other market participants. 

Secured Funding Transactions
Secured funding is primarily accessed through Citi’s broker-
dealer subsidiaries to fund efficiently both (i) secured lending 
activity and (ii) a portion of the securities inventory held in the 
context of market making and customer activities. Citi also 
executes a smaller portion of its secured funding transactions 
through its bank entities, which are typically collateralized by 
government debt securities. Generally, daily changes in the 
level of Citi’s secured funding are primarily due to 
fluctuations in secured lending activity in the matched book 
(as described below) and securities inventory. 

Secured funding of $166 billion as of December 31, 2019 

decreased 6% from the prior year and 15% from the prior 
quarter. Excluding the impact of FX translation, secured 
funding decreased 7% from the prior year and 17% from the 
prior quarter, both driven by normal business activity. Average 
balances for secured funding were $188 billion for the quarter 
ended December 31, 2019.

The portion of secured funding in the broker-dealer 
subsidiaries that funds secured lending is commonly referred 
to as “matched book” activity. The majority of this activity is 
secured by high-quality liquid securities such as U.S. Treasury 
securities, U.S. agency securities and foreign government debt 
securities. Other secured funding is secured by less liquid 
securities, including equity securities, corporate bonds and 
asset-backed securities, the tenor of which is generally equal 
to or longer than the tenor of the corresponding matched book 
assets.

86

Overall Short-Term Borrowings 
The following table contains the year-end, average and maximum month-end amounts for the following respective short-term 
borrowings categories at the end of each of the three prior years:

Securities sold under
agreements to repurchase

Other borrowings(1)(2)

In billions of dollars

2019

2018

2017

2019

2018

2017

Amounts outstanding at year end
Average outstanding during the year(3)(4)
Maximum month-end outstanding
Weighted average interest rate during the year(3)(4)(5)

$

166.3

190.2

196.8

$

177.8

$

156.3

$

172.1

191.2

157.7

163.0

93.7

98.8

105.8

$

96.9

$

108.4

113.5

105.8

97.7

112.3

3.29%

2.84%

1.69%

2.49%

2.04%

1.08%

(1)  Original maturities of less than one year.
(2)  Other borrowings include commercial paper, brokerage payables and borrowings from the FHLB and other market participants. See “Average Balances and 

Interest Rates” below.
Interest rates and amounts include the effects of risk management activities associated with the respective liability categories.

(3) 
(4)  Average volumes of securities sold under agreements to repurchase are reported net pursuant to ASC 210-20-45; average rates exclude the impact of ASC 

210-20-45.

(5)  Average rates reflect prevailing local interest rates, including inflationary effects and monetary correction in certain countries.

87

Credit Ratings
Citigroup’s funding and liquidity, funding capacity, ability to 
access capital markets and other sources of funds, the cost of 
these funds and its ability to maintain certain deposits are 
partially dependent on its credit ratings. 

The table below shows the ratings for Citigroup and 
Citibank as of December 31, 2019. While not included in the 
table below, the long-term and short-term ratings of Citigroup 
Global Markets Holding Inc. (CGMHI) were BBB+/A-2 at 
Standard & Poor’s and A/F1 at Fitch as of December 31, 2019.

Ratings as of December 31, 2019

Fitch Ratings (Fitch)

Moody’s Investors Service (Moody’s)

Standard & Poor’s (S&P)

Potential Impacts of Ratings Downgrades
Ratings downgrades by Moody’s, Fitch or S&P could 
negatively impact Citigroup’s and/or Citibank’s funding and 
liquidity due to reduced funding capacity, including derivative 
triggers, which could take the form of cash obligations and 
collateral requirements.

The following information is provided for the purpose of 

analyzing the potential funding and liquidity impact to 
Citigroup and Citibank of a hypothetical, simultaneous 
ratings downgrade across all three major rating agencies. This 
analysis is subject to certain estimates, estimation 
methodologies, judgments and uncertainties. Uncertainties 
include potential ratings limitations that certain entities may 
have with respect to permissible counterparties, as well as 
general subjective counterparty behavior. For example, certain 
corporate customers and markets counterparties could re-
evaluate their business relationships with Citi and limit 
transactions in certain contracts or market instruments with 
Citi. Changes in counterparty behavior could impact Citi’s 
funding and liquidity, as well as the results of operations of 
certain of its businesses. The actual impact to Citigroup or 
Citibank is unpredictable and may differ materially from the 
potential funding and liquidity impacts described below. For 
additional information on the impact of credit rating changes 
on Citi and its applicable subsidiaries, see “Risk Factors—
Liquidity Risks” above.

 Citigroup Inc. and Citibank—Potential Derivative Triggers
As of December 31, 2019, Citi estimates that a hypothetical 
one-notch downgrade of the senior debt/long-term rating of 
Citigroup Inc. across all three major rating agencies could 
impact Citigroup’s funding and liquidity due to derivative 
triggers by approximately $0.5 billion, compared to 
$0.3 billion as of September 30, 2019. Other funding sources, 
such as secured financing transactions and other margin 
requirements, for which there are no explicit triggers, could 
also be adversely affected.

Citigroup Inc.

Citibank, N.A.

Senior
debt

Commercial
paper

A

A3

BBB+

F1

P-2

A-2

Outlook

Stable

Stable

Stable

Long-
term

Short-
term

A+

Aa3

A+

F1

P-1

A-1

Outlook

Stable

Stable

Stable

As of December 31, 2019, Citi estimates that a 
hypothetical one-notch downgrade of the senior debt/long-
term rating of Citibank across all three major rating agencies 
could impact Citibank’s funding and liquidity by 
approximately $0.3 billion, compared to $0.7 billion as of 
September 30, 2019.

In total, as of December 31, 2019, Citi estimates that a 
one-notch downgrade of Citigroup and Citibank across all 
three major rating agencies could result in increased aggregate 
cash obligations and collateral requirements of approximately 
$0.8 billion, compared to $1.0 billion as of September 30, 
2019 (see also Note 22 to the Consolidated Financial 
Statements). As detailed under “High-Quality Liquid Assets” 
above, the liquidity resources that are eligible for inclusion in 
the calculation of Citi’s consolidated HQLA were 
approximately $385 billion for Citibank and $53 billion for 
Citi’s non-bank and other entities, for a total of approximately 
$438 billion as of December 31, 2019. These liquidity 
resources are available in part as a contingency for the 
potential events described above.

88

 
In addition, a broad range of mitigating actions are 
currently included in Citigroup’s and Citibank’s contingency 
funding plans. For Citigroup, these mitigating factors include, 
but are not limited to, accessing surplus funding capacity from 
existing clients, tailoring levels of secured lending and 
adjusting the size of select trading books and collateralized 
borrowings from certain Citibank subsidiaries. Mitigating 
actions available to Citibank include, but are not limited to, 
selling or financing highly liquid government securities, 
tailoring levels of secured lending, adjusting the size of select 
trading assets, reducing loan originations and renewals, raising 
additional deposits or borrowing from the FHLB or central 
banks. Citi believes these mitigating actions could 
substantially reduce the funding and liquidity risk, if any, of 
the potential downgrades described above.

Citibank—Additional Potential Impacts
In addition to the above derivative triggers, Citi believes that a 
potential downgrade of Citibank’s senior debt/long-term rating 
across any of the three major rating agencies could also have 
an adverse impact on the commercial paper/short-term rating 
of Citibank. As of December 31, 2019, Citibank had liquidity 
commitments of approximately $10.2 billion to consolidated 
asset-backed commercial paper conduits, compared to $10.0 
billion as of September 30, 2019 (as referenced in Note 21 to 
the Consolidated Financial Statements).

In addition to the above-referenced liquidity resources of 

certain Citibank entities, Citibank could reduce the funding 
and liquidity risk, if any, of the potential downgrades 
described above through mitigating actions, including 
repricing or reducing certain commitments to commercial 
paper conduits. In the event of the potential downgrades 
described above, Citi believes that certain corporate customers 
could re-evaluate their deposit relationships with Citibank. 
This re-evaluation could result in clients adjusting their 
discretionary deposit levels or changing their depository 
institution, which could potentially reduce certain deposit 
levels at Citibank. However, Citi could choose to adjust 
pricing, offer alternative deposit products to its existing 
customers or seek to attract deposits from new customers, in 
addition to the mitigating actions referenced above.

89

implements such strategies when it believes those actions are 
prudent. 

Citi manages interest rate risk as a consolidated 

Company-wide position. Citi’s client-facing businesses create 
interest rate-sensitive positions, including loans and deposits, 
as part of their ongoing activities. Citi Treasury aggregates 
these risk positions and manages them centrally. Operating 
within established limits, Citi Treasury makes positioning 
decisions and uses tools, such as Citi’s investment securities 
portfolio, company-issued debt and interest rate derivatives, to 
target the desired risk profile. Changes in Citi’s interest rate 
risk position reflect the accumulated changes in all non-
trading assets and liabilities, with potentially large and 
offsetting impacts, as well as in Citi Treasury’s positioning 
decisions.

Citigroup employs additional measurements, including 
stress testing the impact of non-linear interest rate movements 
on the value of the balance sheet, and the analysis of portfolio 
duration and volatility, particularly as they relate to mortgage 
loans and mortgage-backed securities and the potential impact 
of the change in the spread between different market indices.

Interest Rate Risk of Investment Portfolios—Impact 
on AOCI
Citi also measures the potential impacts of changes in interest 
rates on the value of its AOCI, which can in turn impact Citi’s 
common equity and tangible common equity. This will impact 
Citi’s Common Equity Tier 1 and other regulatory capital 
ratios. Citi’s goal is to benefit from an increase in the market 
level of interest rates, while limiting the impact of changes in 
AOCI on its regulatory capital position.

AOCI at risk is managed as part of the Company-wide 
interest rate risk position. AOCI at risk considers potential 
changes in AOCI (and the corresponding impact on the 
Common Equity Tier 1 Capital ratio) relative to Citi’s capital 
generation capacity.

MARKET RISK

Overview
Market risk is the potential for losses arising from changes in 
the value of Citi’s assets and liabilities resulting from changes 
in market variables such as interest rates, foreign exchange 
rates, equity prices, commodity prices and credit spreads, as 
well as their implied volatilities. Market risk emanates from 
both Citi’s trading and non-trading portfolios. For additional 
information on market risk, see “Risk Factors” above.

Each business is required to establish, with approval from 
Citi’s market risk management, a market risk limit framework 
for identified risk factors that clearly defines approved risk 
profiles and is within the parameters of Citi’s overall risk 
appetite. These limits are monitored by the Risk organization, 
Citi’s country and business Asset and Liability Committees 
and the Citigroup Asset and Liability Committee. In all cases, 
the businesses are ultimately responsible for the market risks 
taken and for remaining within their defined limits.

Market Risk of Non-Trading Portfolios 
Market risk from non-trading portfolios stems from the 
potential impact of changes in interest rates and foreign 
exchange rates on Citi’s net interest revenues, the changes in 
Accumulated other comprehensive income (loss) (AOCI) from 
its debt securities portfolios and capital invested in foreign 
currencies. 

Net Interest Revenue at Risk
Net interest revenue, for interest rate exposure purposes, is the 
difference between the yield earned on the non-trading 
portfolio assets (including customer loans) and the rate paid on 
the liabilities (including customer deposits or company 
borrowings). Net interest revenue is affected by changes in the 
level of interest rates, as well as the amounts and mix of assets 
and liabilities, and the timing of contractual and assumed 
repricing of assets and liabilities to reflect market rates.

 Citi’s principal measure of risk to net interest revenue is 

interest rate exposure (IRE). IRE measures the change in 
expected net interest revenue in each currency resulting solely 
from unanticipated changes in forward interest rates. 

Citi’s estimated IRE incorporates various assumptions 

including prepayment rates on loans, customer behavior and 
the impact of pricing decisions. For example, in rising interest 
rate scenarios, portions of the deposit portfolio may be 
assumed to experience rate increases that are less than the 
change in market interest rates. In declining interest rate 
scenarios, it is assumed that mortgage portfolios experience 
higher prepayment rates. Citi’s estimated IRE below assumes 
that its businesses and/or Citi Treasury make no additional 
changes in balances or positioning in response to the 
unanticipated rate changes.

In order to manage changes in interest rates effectively, 

Citi may modify pricing on new customer loans and deposits, 
purchase fixed-rate securities, issue debt that is either fixed or 
floating or enter into derivative transactions that have the 
opposite risk exposures. Citi regularly assesses the viability of 
these and other strategies to reduce its interest rate risks and 

90

 
The following table sets forth the estimated impact to Citi’s net interest revenue, AOCI and the Common Equity Tier 1 Capital ratio 
(on a fully implemented basis), each assuming an unanticipated parallel instantaneous 100 basis point (bps) increase in interest rates: 

In millions of dollars, except as otherwise noted

Estimated annualized impact to net interest revenue
U.S. dollar(1)
All other currencies

Total

As a percentage of average interest-earning assets

Estimated initial impact to AOCI (after-tax)(2)
Estimated initial impact on Common Equity Tier 1 Capital ratio (bps)

Dec. 31, 2019

Sept. 30, 2019

Dec. 31, 2018

$

$

$

20

606

626

$

$

292

605

897

$

$

0.03%

0.05%

(5,002)

$

(4,055) $

(31)

(24)

758

661

1,419

0.08%

(3,920)

(28)

(1)  Certain trading-oriented businesses within Citi have accrual-accounted positions that are excluded from the estimated impact to net interest revenue in the table, 
since these exposures are managed economically in combination with mark-to-market positions. The U.S. dollar interest rate exposure associated with these 
businesses was $(240) million for a 100 bps instantaneous increase in interest rates as of December 31, 2019.
Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension liability adjustments.

(2) 

The year-over-year decrease in the estimated impact to net 

interest revenue primarily reflected changes in Citi’s balance 
sheet composition and Citi Treasury positioning. The year-
over-year changes in the estimated impact to AOCI and the 
Common Equity Tier 1 Capital ratio primarily reflected the 
impact of the composition of Citi Treasury’s investment and 
derivatives portfolio.

In the event of an unanticipated parallel instantaneous 100 

bps increase in interest rates, Citi expects that the negative 
impact to AOCI would be offset in shareholders’ equity 
through the combination of expected incremental net interest 

revenue and the expected recovery of the impact on AOCI 
through accretion of Citi’s investment portfolio over a period 
of time. As of December 31, 2019, Citi expects that the 
negative $5.0 billion impact to AOCI in such a scenario could 
potentially be offset over approximately 37 months.

The following table sets forth the estimated impact to 
Citi’s net interest revenue, AOCI and the Common Equity 
Tier 1 Capital ratio (on a fully implemented basis) under five 
different changes in interest rate scenarios for the U.S. dollar 
and Citi’s other currencies: 

In millions of dollars, except as otherwise noted

Scenario 1

Scenario 2

Scenario 3

Scenario 4

Scenario 5

Overnight rate change (bps)

10-year rate change (bps)

Estimated annualized impact to net interest revenue 

U.S. dollar

All other currencies

Total
Estimated initial impact to AOCI (after-tax)(1)
Estimated initial impact to Common Equity Tier 1 Capital ratio (bps)

$

$

$

100

100

20 $

606

626 $

100

—

92 $

558

650 $

(5,002) $

(3,230) $

(1,944) $

(31)

(20)

(13)

—

100

—

(100)

39 $

34

73 $

(93) $

(34)

(127) $

1,570 $

9

(100)

(100)

(363)

(411)

(774)

4,389

26

Note: Each scenario assumes that the rate change will occur instantaneously. Changes in interest rates for maturities between the overnight rate and the 10-year rate are 
interpolated. 
(1) 

Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension liability adjustments.

As shown in the table above, the magnitude of the impact 

to Citi’s net interest revenue and AOCI is greater under 
scenario 2 as compared to scenario 3. This is because the 
combination of changes to Citi’s investment portfolio, 
partially offset by changes related to Citi’s pension liabilities, 
results in a net position that is more sensitive to rates at 
shorter- and intermediate-term maturities.

91

Changes in Foreign Exchange Rates—Impacts on AOCI 
and Capital
As of December 31, 2019, Citi estimates that an unanticipated 
parallel instantaneous 5% appreciation of the U.S. dollar 
against all of the other currencies in which Citi has invested 
capital could reduce Citi’s tangible common equity (TCE) by 
approximately $1.5 billion, or 1%, as a result of changes to 
Citi’s foreign currency translation adjustment in AOCI, net of 
hedges. This impact would be primarily due to changes in the 
value of the Mexican peso, Euro, Australian dollar and Indian 
rupee.

This impact is also before any mitigating actions Citi may 

take, including ongoing management of its foreign currency 
translation exposure. Specifically, as currency movements 
change the value of Citi’s net investments in foreign currency-
denominated capital, these movements also change the value 
of Citi’s risk-weighted assets denominated in those currencies. 
This, coupled with Citi’s foreign currency hedging strategies, 
such as foreign currency borrowings, foreign currency 
forwards and other currency hedging instruments, lessens the 
impact of foreign currency movements on Citi’s Common 
Equity Tier 1 Capital ratio. Changes in these hedging 
strategies, as well as hedging costs, divestitures and tax 
impacts, can further affect the actual impact of changes in 
foreign exchange rates on Citi’s capital as compared to an 
unanticipated parallel shock, as described above.

In millions of dollars, except as otherwise noted
Change in FX spot rate(1)
Change in TCE due to FX translation, net of hedges

As a percentage of TCE

The effect of Citi’s ongoing management strategies with 

respect to changes in foreign exchange rates and the impact of 
these changes on Citi’s TCE and Common Equity Tier 1 
Capital ratio are shown in the table below. For additional 
information on the changes in AOCI, see Note 19 to the 
Consolidated Financial Statements.

For the quarter ended

Dec. 31, 2019

Sept. 30, 2019

Dec. 31, 2018

2.8%

(3.0)%

$

659

$

(1,192)

$

0.4%

(0.8)%

(1.6)%

(491)

(0.3)%

Estimated impact to Common Equity Tier 1 Capital ratio (on a fully implemented basis) due 
  to changes in FX translation, net of hedges (bps)

(3)

(1)

(1)

(1)   FX spot rate change is a weighted average based on Citi’s quarterly average GAAP capital exposure to foreign countries.

92

Interest Revenue/Expense and Net Interest Margin (NIM)

In millions of dollars, except as otherwise noted
Interest revenue(1)
Interest expense(2)
Net interest revenue, taxable equivalent basis
Interest revenue—average rate(3)
Interest expense—average rate
Net interest margin(3)(4)
Interest rate benchmarks

Two-year U.S. Treasury note—average rate

10-year U.S. Treasury note—average rate

2019

2018

2017

$ 76,718

  $ 71,082

  $ 62,075

29,163

24,266

16,518

$ 47,555

  $ 46,816

  $ 45,557

4.27%

2.01

2.65

1.97%

2.14

4.08%

1.77

2.69

2.53%

2.91

3.71%

1.28

2.73

1.40%

2.33

10-year vs. two-year spread

17

bps

38

bps

93

bps

Change 
 2019 vs. 2018

Change 
 2018 vs. 2017

8%

20

2%

19

24

bps

bps

(4) bps

(56) bps

(77) bps

15%

47

3%

37

49

bps

bps

(4) bps

113

58

bps

bps

Note: All interest expense amounts include FDIC, as well as other similar deposit insurance assessments outside of the U.S. As of the fourth quarter of 2018, Citi’s 
FDIC surcharge was eliminated (approximately $130 million per quarter). 
(1)  Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rates of 21% in 

(2) 

2019 and 2018 and 35% in 2017) of $208 million, $254 million and $496 million for 2019, 2018 and 2017, respectively. 
Interest expense associated with certain hybrid financial instruments, which are classified as Long-term debt and accounted for at fair value, is reported together
with any changes in fair value as part of Principal transactions in the Consolidated Statement of Income and is therefore not reflected in Interest expense in the 
table above.

(3)  The average rate on interest revenue and net interest margin reflects the taxable equivalent gross-up adjustment. See footnote 1 on “Average Balances and Interest 

Rates—Assets” below.

(4)  Citi’s net interest margin (NIM) is calculated by dividing net interest revenue by average interest-earning assets.

93

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net Interest Revenue Excluding ICG Markets

In millions of dollars
Net interest revenue—taxable equivalent basis(1) per above
ICG Markets net interest revenue—taxable equivalent basis(1)
Net interest revenue excluding ICG Markets—taxable equivalent basis(1)

$

$

2019

2018

2017

47,555

4,372

43,183

$

$

46,816

4,506

42,310

$

$

45,557

5,741

39,816

(1)  Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rates of 21% in 

2019 and 2018 and 35% in 2017) of $208 million, $254 million and $496 million for 2019, 2018 and 2017, respectively. 

Citi’s net interest revenue in the fourth quarter of 2019 
increased 1% to $12.0 billion (also $12.0 billion on a taxable 
equivalent basis) versus the prior-year period. Excluding the 
impact of FX translation, net interest revenue also increased 
1%, or approximately $70 million, as growth in ICG Markets 
(fixed income markets and equity markets) net interest 
revenue of 21%, or $210 million, was partially offset by a 1% 
decline, or $150 million, in net interest revenue ex-markets. 
The increase in markets net interest revenue was driven by 
ongoing changes in the composition and mix of the business’s 
revenues between net interest revenue and non-interest 
revenue. The decline in net interest revenue ex-markets was 
primarily due to the impact of lower interest rates, partially 
offset by growth in the non-markets franchise. Citi’s NIM was 
2.63% on a taxable equivalent basis in the fourth quarter of 
2019, an increase of 7 basis points (bps) from the prior 
quarter, primarily driven by the higher markets net interest 
revenue, partially offset by the impact of lower interest rates.

Citi’s net interest revenue for the full year 2019 increased 

2% to $47.3 billion ($47.6 billion on a taxable equivalent 
basis) versus the prior year. Excluding the impact of FX 
translation, Citi’s net interest revenue increased 3%, or 
approximately $1.4 billion, mainly reflecting strength in Citi-
branded cards in North America GCB and treasury and trade 
solutions, including the impact of volume growth as well as 
interest rates. On a full-year basis, Citi’s NIM was 2.65% on a 
taxable equivalent basis, compared to 2.69% in 2018. Citi’s 
markets and non-markets net interest revenues are non-GAAP 
financial measures. Citi reviews non-markets net interest 
revenue to assess the performance of its lending, investing and 
deposit-raising activities. Citi believes disclosure of this 
metric assists in providing a meaningful depiction of the 
underlying fundamentals of its non-markets businesses.

94

 
Additional Interest Rate Details

Average Balances and Interest Rates—Assets(1)(2)(3)

Taxable Equivalent Basis

In millions of dollars, except rates

2019

2018

2017

2019

2018

2017

2019

2018

2017

Average volume

Interest revenue

% Average rate

Assets
Deposits with banks(4)
Securities borrowed and 
purchased under agreements to 
resell(5)
In U.S. offices
In offices outside the U.S.(4)
Total
Trading account assets(6)(7)
In U.S. offices
In offices outside the U.S.(4)
Total

Investments

In U.S. offices

Taxable

Exempt from U.S. income tax

In offices outside the U.S.(4)
Total
Loans (net of unearned income)(8)
In U.S. offices
In offices outside the U.S.(4)
Total
Other interest-earning assets(9)
Total interest-earning assets
Non-interest-earning assets(6)
Total assets

$

188,523 $

177,294 $

169,385 $

2,682 $

2,203 $

1,635

1.42% 1.24%

0.97%

$

$

$

$

146,030 $

149,879 $

141,308 $

4,752 $

3,818 $

1,922

3.25% 2.55%

1.36%

119,550

117,695

106,606

2,133

1,674

1,327

1.78

1.42

1.24

265,580 $

267,574 $

247,914 $

6,885 $

5,492 $

3,249

2.59% 2.05%

1.31%

109,064 $

94,065 $

99,755 $

4,099 $

3,706 $

3,531

3.76% 3.94%

3.54%

131,217

115,601

104,197

3,589

2,615

2,117

2.74

2.26

2.03

240,281 $

209,666 $

203,952 $

7,688 $

6,321 $

5,648

3.20% 3.01%

2.77%

$

221,895 $

228,686 $

226,227 $

5,162 $

5,331 $

4,450

2.33% 2.33%

1.97%

15,227

117,529

17,199

104,033

18,152

106,040

577

4,222

706

3,600

775

3,309

3.79

3.59

4.10

3.46

4.27

3.12

354,651 $

349,918 $

350,419 $

9,961 $

9,637 $

8,534

2.81% 2.75%

2.44%

395,792 $

385,350 $

371,711 $ 30,563 $ 28,627 $ 25,944

7.72% 7.43%

6.98%

288,319

285,505

267,774

17,266

17,129

15,904

5.99

6.00

684,111 $

670,855 $

639,485 $ 47,829 $ 45,756 $ 41,848

6.99% 6.82%

64,322 $

67,269 $

60,626 $

1,673 $

1,673 $

1,161

2.60% 2.49%

$ 1,797,468 $ 1,742,576 $ 1,671,781 $ 76,718 $ 71,082 $ 62,075

4.27% 4.08%

$

181,341 $

177,654 $

203,657

$ 1,978,809 $ 1,920,230 $ 1,875,438

5.94

6.54%

1.92%

3.71%

$

$

$

$

(1)  Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rates of 21% in 

2019 and 2018 and 35% in 2017) of $208 million, $254 million and $496 million for 2019, 2018 and 2017, respectively.
Interest rates and amounts include the effects of risk management activities associated with the respective asset categories.

(2) 
(3)  Monthly or quarterly averages have been used by certain subsidiaries where daily averages are unavailable.
(4)  Average rates reflect prevailing local interest rates, including inflationary effects and monetary corrections in certain countries.
(5)  Average volumes of securities borrowed or purchased under agreements to resell are reported net pursuant to ASC 210-20-45. However, Interest revenue excludes 

the impact of ASC 210-20-45.

(6)  The fair value carrying amounts of derivative contracts are reported net, pursuant to ASC 815-10-45, in Non-interest-earning assets and Other non-interest-

bearing liabilities.
Interest expense on Trading account liabilities of ICG is reported as a reduction of Interest revenue. Interest revenue and Interest expense on cash collateral 
positions are reported in interest on Trading account assets and Trading account liabilities, respectively.
Includes cash-basis loans.
Includes brokerage receivables.

(7) 

(8) 
(9) 

95

 
 
 
 
 
 
 
Average Balances and Interest Rates—Liabilities and Equity, and Net Interest Revenue(1)(2)(3)

Taxable Equivalent Basis

In millions of dollars, except rates

2019

2018

2017

2019

2018

2017

2019

2018

2017

Average volume

Interest expense

% Average rate

Liabilities

Deposits
In U.S. offices(4)
In offices outside the U.S.(5)
Total

Securities loaned and sold under 
agreements to repurchase(6)
In U.S. offices
In offices outside the U.S.(5)
Total
Trading account liabilities(7)(8)
In U.S. offices
In offices outside the U.S.(5)
Total
Short-term borrowings(9)
In U.S. offices
In offices outside the U.S.(5)
Total
Long-term debt(10)
In U.S. offices
In offices outside the U.S.(5)
Total

$

$

$

$

$

$

$

$

$

$

388,948 $

338,060 $

313,094 $

6,304 $

4,500 $

2,530

1.62% 1.33%

0.81%

487,318

453,793

436,949

6,329

5,116

4,057

1.30

1.13

0.93

876,266 $

791,853 $

750,043 $ 12,633 $

9,616 $

6,587

1.44% 1.21%

0.88%

112,876 $

102,843 $

96,258 $

4,194 $

3,320 $

1,574

3.72% 3.23%

1.64%

77,283

69,264

61,434

2,069

1,569

1,087

2.68

2.27

1.77

190,159 $

172,107 $

157,692 $

6,263 $

4,889 $

2,661

3.29% 2.84%

1.69%

37,099 $

37,305 $

33,399 $

818 $

612 $

51,817

58,919

57,149

490

389

88,916 $

96,224 $

90,548 $

1,308 $

1,001 $

78,230 $

85,009 $

74,825 $

2,138 $

1,885 $

20,575

23,402

22,837

327

324

380

258

638

684

375

2.20% 1.64%

1.14%

0.95

0.66

0.45

1.47% 1.04%

0.70%

2.73% 2.22%

0.91%

1.59

1.38

1.64

98,805 $

108,411 $

97,662 $

2,465 $

2,209 $

1,059

2.49% 2.04%

1.08%

193,972 $

197,933 $

192,079 $

6,398 $

6,386 $

5,382

3.30% 3.23%

2.80%

4,803

4,895

4,615

96

165

191

2.00

3.37

198,775 $

202,828 $

196,694 $

6,494 $

6,551 $

5,573

3.27% 3.23%

4.14

2.83%

1.28%

Total interest-bearing liabilities

$ 1,452,921 $ 1,371,423 $ 1,292,639 $ 29,163 $ 24,266 $ 16,518

2.01% 1.77%

Demand deposits in U.S. offices

$

27,737 $

33,398 $

37,824

Other non-interest-bearing 
liabilities(7)
Total liabilities

Citigroup stockholders’ equity

Noncontrolling interests

Total equity

Total liabilities and stockholders’
equity
Net interest revenue as a 
percentage of average interest-
earning assets(11)
In U.S. offices
In offices outside the U.S.(6)
Total

301,813

315,862

316,129

$ 1,782,471 $ 1,720,683 $ 1,646,592

$

$

195,632 $

198,681 $

227,849

706

866

997

196,338 $

199,547 $

228,846

$ 1,978,809 $ 1,920,230 $ 1,875,438

$ 1,017,021 $

992,543 $

970,439 $ 28,466 $ 28,157 $ 27,551

2.80% 2.84%

2.84%

780,447

750,033

701,342

19,089

18,659

18,006

2.45

2.49

2.57

$ 1,797,468 $ 1,742,576 $ 1,671,781 $ 47,555 $ 46,816 $ 45,557

2.65% 2.69%

2.73%

(1)  Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rates of 21% in 

2019 and 2018 and 35% in 2017) of $208 million, $254 million and $496 million for 2019, 2018 and 2017, respectively.
Interest rates and amounts include the effects of risk management activities associated with the respective liability categories.

(2) 
(3)  Monthly or quarterly averages have been used by certain subsidiaries where daily averages are unavailable.
(4)  Consists of other time deposits and savings deposits. Savings deposits are made up of insured money market accounts, NOW accounts and other savings deposits. 

The interest expense on savings deposits includes FDIC deposit insurance assessments.

(5)  Average rates reflect prevailing local interest rates, including inflationary effects and monetary corrections in certain countries.
(6)  Average volumes of securities sold under agreements to repurchase are reported net pursuant to ASC 210-20-45. However, Interest expense excludes the impact of 

ASC 210-20-45.

(7)  The fair value carrying amounts of derivative contracts are reported net, pursuant to ASC 815-10-45, in Non-interest-earning assets and Other non-interest-

(8) 

bearing liabilities.
Interest expense on Trading account liabilities of ICG is reported as a reduction of Interest revenue. Interest revenue and Interest expense on cash collateral 
positions are reported in interest on Trading account assets and Trading account liabilities, respectively.

96

 
 
 
 
 
 
 
 
 
 
Includes Brokerage payables.

(9) 
(10)  Excludes hybrid financial instruments and beneficial interests in consolidated VIEs that are classified as Long-term debt, as the changes in fair value for these 

obligations are recorded in Principal transactions.

(11)  Includes allocations for capital and funding costs based on the location of the asset.

Analysis of Changes in Interest Revenue(1)(2)(3)

In millions of dollars
Deposits with banks(3)

Securities borrowed and purchased under agreements to resell

In U.S. offices
In offices outside the U.S.(3)
Total
Trading account assets(4)
In U.S. offices
In offices outside the U.S.(3)
Total
Investments(1)
In U.S. offices
In offices outside the U.S.(3)
Total
Loans (net of unearned income)(5)
In U.S. offices
In offices outside the U.S.(3)
Total
Other interest-earning assets(6)
Total interest revenue

2019 vs. 2018

Increase (decrease)
due to change in:

2018 vs. 2017

Increase (decrease)
due to change in:

Average
volume

Average
rate

Net
change

Average
volume

Average
rate

Net
change

$

$

$

$

$

$

$

$

$

$

$

146 $

333 $

479 $

79 $

489 $

568

(100) $

1,034 $

934 $

123 $

1,773 $

1,896

27

432

459

146

201

347

(73) $

1,466 $

1,393 $

269 $

1,974 $

2,243

570 $

(177) $

393 $

(209) $

384 $

382

592

974

245

253

952 $

415 $

1,367 $

36 $

637 $

(213) $

(85) $

(298) $

32 $

780 $

481

141

622

(64)

355

175

498

673

812

291

268 $

56 $

324 $

(32) $

1,135 $

1,103

789 $

1,149 $

1,938 $

974 $

1,709 $

2,683

169

(34)

135

1,062

163

1,225

958 $

1,115 $

2,073 $

2,036 $

1,872 $

3,908

(75) $

75 $

— $

137 $

375 $

512

2,176 $

3,460 $

5,636 $

2,525 $

6,482 $

9,007

(1)  The taxable equivalent adjustments related to the tax-exempt bond portfolio, based on the U.S. federal statutory tax rates of 21% in 2019 and 2018 and 35% in 

2017, are included in this presentation.

(2)  Rate/volume variance is allocated based on the percentage relationship of changes in volume and changes in rate to the total net change.
(3)  Changes in average rates reflect changes in prevailing local interest rates, including inflationary effects and monetary corrections in certain countries.
(4) 

Interest expense on Trading account liabilities of ICG is reported as a reduction of Interest revenue. Interest revenue and Interest expense on cash collateral 
positions are reported in interest on Trading account assets and Trading account liabilities, respectively.
Includes cash-basis loans.
Includes Brokerage receivables.

(5) 
(6) 

97

 
 
Analysis of Changes in Interest Expense and Net Interest Revenue(1)(2)(3)

In millions of dollars

Deposits

In U.S. offices
In offices outside the U.S.(3)
Total

Securities loaned and sold under agreements to repurchase

In U.S. offices
In offices outside the U.S.(3)
Total
Trading account liabilities(4)
In U.S. offices
In offices outside the U.S.(3)
Total
Short-term borrowings(5)
In U.S. offices
In offices outside the U.S.(3)
Total

Long-term debt

In U.S. offices
In offices outside the U.S.(3)
Total

Total interest expense

Net interest revenue

2019 vs. 2018

Increase (decrease)
due to change in:

2018 vs. 2017

Increase (decrease)
due to change in:

Average
volume

Average
rate

Net
change

Average
volume

Average
rate

Net
change

$

$

$

$

$

$

$

$

$

$

$

$

738 $

1,066 $

1,804 $

216 $

1,754 $

1,970

397

816

1,213

162

897

1,059

1,135 $

1,882 $

3,017 $

378 $

2,651 $

3,029

343 $

531 $

874 $

115 $

1,631 $

1,746

194

306

500

151

331

482

537 $

837 $

1,374 $

266 $

1,962 $

2,228

(3) $

209 $

206 $

49 $

183 $

(51)

152

101

8

123

(54) $

361 $

307 $

57 $

306 $

232

131

363

(159) $

412 $

253 $

105 $

1,096 $

1,201

(42)

45

3

9

(60)

(51)

(201) $

457 $

256 $

114 $

1,036 $

1,150

(129) $

141 $

12 $

168 $

836 $

1,004

(3)

(66)

(69)

11

(37)

(132) $

75 $

(57) $

179 $

799 $

(26)

978

1,285 $

3,612 $

4,897 $

994 $

6,754 $

7,748

891 $

(152) $

739 $

1,531 $

(272) $

1,259

(1)  The taxable equivalent adjustments related to the tax-exempt bond portfolio, based on the U.S. federal statutory tax rates of 21% in 2019 and 2018 and 35% in 

2017, are included in this presentation.

(2)  Rate/volume variance is allocated based on the percentage relationship of changes in volume and changes in rate to the total net change.
(3)  Changes in average rates reflect changes in prevailing local interest rates, including inflationary effects and monetary corrections in certain countries.
(4) 

Interest expense on Trading account liabilities of ICG is reported as a reduction of Interest revenue. Interest revenue and Interest expense on cash collateral 
positions are reported in interest on Trading account assets and Trading account liabilities, respectively.
Includes Brokerage payables.

(5) 

98

 
 
Market Risk of Trading Portfolios
Trading portfolios include positions resulting from market-
making activities, hedges of certain available-for-sale (AFS) 
debt securities, the CVA relating to derivative counterparties 
and all associated hedges, fair value option loans and hedges 
of the loan portfolio within capital markets origination within 
ICG.

The market risk of Citi’s trading portfolios is monitored 
using a combination of quantitative and qualitative measures, 
including, but not limited to:

• 
• 
• 

factor sensitivities; 
value at risk (VAR); and 
stress testing.

Each trading portfolio across Citi’s businesses has its own 
market risk limit framework encompassing these measures and 
other controls, including trading mandates, new product 

approval, permitted product lists and pre-trade approval for 
larger, more complex and less liquid transactions.

The following chart of total daily trading-related revenue 
(loss) captures trading volatility and shows the number of days 
in which revenues for Citi’s trading businesses fell within 
particular ranges. Trading-related revenue includes trading, net 
interest and other revenue associated with Citi’s trading 
businesses. It excludes DVA, FVA and CVA adjustments 
incurred due to changes in the credit quality of counterparties, 
as well as any associated hedges of that CVA. In addition, it 
excludes fees and other revenue associated with capital 
markets origination activities. Trading-related revenues are 
driven by both customer flows and the changes in valuation of 
the trading inventory. As shown in the chart below, positive 
trading-related revenue was achieved for 100% of the trading 
days in 2019.

Daily Trading-Related Revenue (Loss)(1)— Twelve Months ended December 31, 2019
In millions of dollars

(1)  Reflects the effects of asymmetrical accounting for economic hedges of certain AFS debt securities. Specifically, the change in the fair value of hedging 

derivatives is included in trading-related revenue, while the offsetting change in the fair value of hedged AFS debt securities is included in AOCI and not reflected 
above.

99

Factor Sensitivities
Factor sensitivities are expressed as the change in the value of 
a position for a defined change in a market risk factor, such as 
a change in the value of a U.S. Treasury bill for a one-basis-
point change in interest rates. Citi’s market risk management, 
within the Risk organization, works to ensure that factor 
sensitivities are calculated, monitored and limited for all 
material risks taken in the trading portfolios.

Value at Risk (VAR)
VAR estimates, at a 99% confidence level, the potential 
decline in the value of a position or a portfolio under normal 
market conditions assuming a one-day holding period. VAR 
statistics, which are based on historical data, can be materially 
different across firms due to differences in portfolio 
composition, differences in VAR methodologies and 
differences in model parameters. As a result, Citi believes 
VAR statistics can be used more effectively as indicators of 
trends in risk-taking within a firm, rather than as a basis for 
inferring differences in risk-taking across firms.

Citi uses a single, independently approved Monte Carlo 

simulation VAR model (see “VAR Model Review and 
Validation” below), which has been designed to capture 
material risk sensitivities (such as first- and second-order 
sensitivities of positions to changes in market prices) of 
various asset classes/risk types (such as interest rate, credit 

spread, foreign exchange, equity and commodity risks). Citi’s 
VAR includes positions that are measured at fair value; it does 
not include investment securities classified as AFS or HTM. 
For information on these securities, see Note 13 to the 
Consolidated Financial Statements.

Citi believes its VAR model is conservatively calibrated 

to incorporate fat-tail scaling and the greater of short-term 
(approximately the most recent month) and long-term (three 
years) market volatility. The Monte Carlo simulation involves 
approximately 450,000 market factors, making use of 
approximately 350,000 time series, with sensitivities updated 
daily, volatility parameters updated intra-monthly and 
correlation parameters updated monthly. The conservative 
features of the VAR calibration contribute an approximate 
26% add-on to what would be a VAR estimated under the 
assumption of stable and perfectly, normally distributed 
markets. 

As set forth in the table below, Citi’s average trading VAR 

decreased from 2018 to 2019, mainly due to changes in 
interest rates in the ICG Markets businesses. The average 
trading and credit portfolio VAR also declined, although the 
decrease in average trading VAR was partially offset by 
additional hedging related to lending activities in 2019.

Year-end and Average Trading VAR and Trading and Credit Portfolio VAR 

In millions of dollars

Interest rate

Credit spread
Covariance adjustment(1)
Fully diversified interest rate and credit spread(2)
Foreign exchange

Equity

Commodity
Covariance adjustment(1)
Total trading VAR—all market risk factors, including general and specific risk 
(excluding credit portfolios)(2)
Specific risk-only component(3)
Total trading VAR—general market risk factors only (excluding credit portfolios)
Incremental impact of the credit portfolio(4)
Total trading and credit portfolio VAR

December 31,
2019

2019
Average

December 31,
2018

2018
Average

$

$

$

$

$

$

$

32 $

35 $

44

(27)

44

(23)

49 $

56 $

22

21

13

(52)

53 $

3 $

50 $

30 $

83 $

23

16

24

(62)

57 $

2 $

55 $

14 $

71 $

48 $

55

(23)

80 $

18

25

23

60

47

(24)

83

25

22

19

(66)

(67)

80 $

4 $

76 $

18 $

98 $

82

4

78

10

92

(1)  Covariance adjustment (also known as diversification benefit) equals the difference between the total VAR and the sum of the VARs tied to each individual risk 
type. The benefit reflects the fact that the risks within each and across risk types are not perfectly correlated and, consequently, the total VAR on a given day will 
be lower than the sum of the VARs relating to each individual risk type. The determination of the primary drivers of changes to the covariance adjustment is made 
by an examination of the impact of both model parameter and position changes. 

(2)  The total trading VAR includes mark-to-market and certain fair value option trading positions in ICG, with the exception of hedges to the loan portfolio, fair value 

option loans and all CVA exposures. Available-for-sale and accrual exposures are not included.

(3)   The specific risk-only component represents the level of equity and fixed income issuer-specific risk embedded in VAR. 
(4)   The credit portfolio is composed of mark-to-market positions associated with non-trading business units including Citi Treasury, the CVA relating to derivative 
counterparties and all associated CVA hedges. FVA and DVA are not included. The credit portfolio also includes hedges to the loan portfolio, fair value option 
loans and hedges to the leveraged finance pipeline within capital markets origination in ICG.

100

The table below provides the range of market factor VARs associated with Citi’s total trading VAR, inclusive of specific risk:

In millions of dollars

Interest rate

Credit spread

Fully diversified interest rate and credit spread

Foreign exchange

Equity

Commodity

Total trading

Total trading and credit portfolio

2019

2018

Low

High

Low

High

$

$

$

25 $

36

43 $

12

7

12

38 $

54

58 $

55

89 $

34

29

75

87 $

103

34 $

38

59 $

13

15

13

56 $

66

89

64

118

44

33

27

120

124

Note: No covariance adjustment can be inferred from the above table as the high and low for each market factor will be from different close-of-business dates.

The following table provides the VAR for ICG, excluding 
the CVA relating to derivative counterparties, hedges of CVA, 
fair value option loans and hedges to the loan portfolio:

In millions of dollars

Dec. 31, 2019

Total—all market risk factors, including
general and specific risk

Average—during year

High—during year

Low—during year

$

$

53

57

86

38

VAR Model Review and Validation
Generally, Citi’s VAR review and model validation process 
entails reviewing the model framework, major assumptions 
and implementation of the mathematical algorithm. In 
addition, as part of the model validation process, product 
specific back-testing on portfolios is periodically completed 
and reviewed with Citi’s U.S. banking regulators. 
Furthermore, Regulatory VAR back-testing (as described 
below) is performed against buy-and-hold profit and loss on a 
monthly basis for multiple sub-portfolios across the 
organization (trading desk level, ICG business segment and 
Citigroup) and the results are shared with U.S. banking 
regulators.

Significant VAR model and assumption changes must be 

independently validated within Citi’s risk management 
organization. This validation process includes a review by 
model validation group within Citi’s Model Risk 
Management. In the event of significant model changes, 
parallel model runs are undertaken prior to implementation. In 
addition, significant model and assumption changes are 
subject to the periodic reviews and approval by Citi’s U.S. 
banking regulators.

Citi uses the same independently validated VAR model 
for both Regulatory VAR and Risk Management VAR (i.e., 
total trading and total trading and credit portfolios VARs) and, 
as such, the model review and validation process for both 
purposes is as described above.

Regulatory VAR, which is calculated in accordance with 
Basel III, differs from Risk Management VAR due to the fact 
that certain positions included in Risk Management VAR are 
not eligible for market risk treatment in Regulatory VAR. The 

101

composition of Risk Management VAR is discussed under 
“Value at Risk” above. The applicability of the VAR model for 
positions eligible for market risk treatment under U.S. 
regulatory capital rules is periodically reviewed and approved 
by Citi’s U.S. banking regulators.

In accordance with Basel III, Regulatory VAR includes all 

trading book-covered positions and all foreign exchange and 
commodity exposures. Pursuant to Basel III, Regulatory VAR 
excludes positions that fail to meet the intent and ability to 
trade requirements and are therefore classified as non-trading 
book and categories of exposures that are specifically 
excluded as covered positions. Regulatory VAR excludes CVA 
on derivative instruments and DVA on Citi’s own fair value 
option liabilities. CVA hedges are excluded from Regulatory 
VAR and included in credit risk-weighted assets as computed 
under the Advanced Approaches for determining risk-
weighted assets.

Regulatory VAR Back-Testing
In accordance with Basel III, Citi is required to perform back-
testing to evaluate the effectiveness of its Regulatory VAR 
model. Regulatory VAR back-testing is the process in which 
the daily one-day VAR, at a 99% confidence interval, is 
compared to the buy-and-hold profit and loss (i.e., the profit 
and loss impact if the portfolio is held constant at the end of 
the day and re-priced the following day). Buy-and-hold profit 
and loss represents the daily mark-to-market profit and loss 
attributable to price movements in covered positions from the 
close of the previous business day. Buy-and-hold profit and 
loss excludes realized trading revenue, net interest, fees and 
commissions, intra-day trading profit and loss and changes in 
reserves.

Based on a 99% confidence level, Citi would expect two 

to three days in any one year when buy-and-hold losses 
exceed the Regulatory VAR. Given the conservative 
calibration of Citi’s VAR model (as a result of taking the 
greater of short- and long-term volatilities and fat-tail scaling 
of volatilities), Citi would expect fewer exceptions under 
normal and stable market conditions. Periods of unstable 
market conditions could increase the number of back-testing 
exceptions.

The following graph shows the daily buy-and-hold profit 
and loss associated with Citi’s covered positions compared to 
Citi’s one-day Regulatory VAR during 2019. As of 
December 31, 2019, there were no back-testing exceptions 
observed for Citi’s Regulatory VAR for the prior 12 months.
The difference between the 54.8% of days with buy-and-
hold gains for Regulatory VAR back-testing and the 100% of 
days with trading, net interest and other revenue associated 
with Citi’s trading businesses, shown in the histogram of daily 
trading-related revenue below, reflects, among other things, 
that a significant portion of Citi’s trading-related revenue is 
not generated from daily price movements on these positions 
and exposures, as well as differences in the portfolio 
composition of Regulatory VAR and Risk Management VAR.

Regulatory Trading VAR and Associated Buy-and-Hold Profit and Loss(1)—12 Months ended December 31, 2019
In millions of dollars

(1)   Buy-and-hold profit and loss, as defined by the banking regulators under Basel III, represents the daily mark-to-market revenue movement attributable to the 
trading position from the close of the previous business day. Buy-and-hold profit and loss excludes realized trading revenue and net interest intra-day trading 
profit and loss on new and terminated trades, as well as changes in reserves. Therefore, it is not comparable to the trading-related revenue presented in the chart of 
daily trading-related revenue above.

102

Stress Testing
Citi performs market risk stress testing on a regular basis to 
estimate the impact of extreme market movements. It is 
performed on individual positions and trading portfolios, as 
well as in aggregate, inclusive of multiple trading portfolios. 
Citi’s market risk management, after consultations with the 
businesses, develops both systemic and specific stress 
scenarios, reviews the output of periodic stress testing 
exercises and uses the information to assess the ongoing 
appropriateness of exposure levels and limits. Citi uses two 
complementary approaches to market risk stress testing across 
all major risk factors (i.e., equity, foreign exchange, 
commodity, interest rate and credit spreads): top-down 
systemic stresses and bottom-up business-specific stresses. 
Systemic stresses are designed to quantify the potential impact 
of extreme market movements on an institution-wide basis, 
and are constructed using both historical periods of market 
stress and projections of adverse economic scenarios. 
Business-specific stresses are designed to probe the risks of 
particular portfolios and market segments, especially those 
risks that are not fully captured in VAR and systemic stresses.
The systemic stress scenarios and business-specific stress 
scenarios at Citi are used in several reports reviewed by senior 
management and also to calculate internal risk capital for 
trading market risk. In general, changes in market values are 
defined over a one-year horizon. For the most liquid positions 
and market factors, changes in market values are defined over 
a shorter two-month horizon. The limited set of positions and 
market factors whose market value changes are defined over a 
two-month horizon are those that in management’s judgment 
have historically remained very liquid during financial crises, 
even as the trading liquidity of most other positions and 
market factors materially declined.

103

OPERATIONAL RISK

Overview
Operational risk is the risk of loss resulting from inadequate or 
failed internal processes, systems or human factors, or from 
external events. It includes risk of failing to comply with 
applicable laws and regulations, but excludes strategic risk. 
Operational risk includes the reputation and franchise risk 
associated with business practices or market conduct in which 
Citi is involved, as well as compliance, conduct and legal 
risks.

Operational risk is inherent in Citi’s global business 
activities, as well as related support functions, and can result 
in losses arising from events associated with the following, 
among others:

• 
• 
• 
• 
• 

fraud, theft and unauthorized activity;
employment practices and workplace environment;
clients, products and business practices;
physical assets and infrastructure; and
execution, delivery and process management.

Citi manages operational risk consistent with the overall 
framework described in “Managing Global Risk—Overview” 
above. The Company’s goal is to keep operational risk at 
appropriate levels relative to the characteristics of Citi’s 
businesses, the markets in which it operates, its capital and 
liquidity and the competitive, economic and regulatory 
environment.

To anticipate, mitigate and control operational risk, Citi 

has established policies and a global framework for assessing, 
monitoring and communicating operational risks and the 
overall operating effectiveness of the internal control 
environment across Citigroup. As part of this framework, Citi 
has defined its operational risk appetite and has established a 
manager’s control assessment (MCA) process (a process 
through which managers at Citi identify, monitor, measure, 
report on and manage risks and the related controls) to help 
managers self-assess significant operational risks and key 
controls and identify and address weaknesses in the design 
and/or operating effectiveness of internal controls that mitigate 
significant operational risks.

Each major business segment must implement an 
operational risk process consistent with the requirements of 
this framework. The process for operational risk management 
includes the following steps:

• 
• 
• 
• 

• 
• 

identify and assess key operational risks;
design controls to mitigate identified risks;
establish key risk indicators;
implement a process for early problem recognition and 
timely escalation;
produce comprehensive operational risk reporting; and
ensure that sufficient resources are available to actively 
improve the operational risk environment and mitigate 
emerging risks.

As new products and business activities are developed, 

processes are designed, modified or sourced through 
alternative means and operational risks are considered.

104

An Operational Risk Management Committee has been 

established to provide oversight for operational risk across 
Citigroup and to provide a forum to assess Citi’s operational 
risk profile and ensure actions are taken so that Citi’s 
operational risk exposure is actively managed consistent with 
Citi’s risk appetite. The Committee seeks to ensure that these 
actions address the root causes that persistently lead to 
operational risk losses and create lasting solutions to 
minimize these losses. Members include Citi’s Chief Risk 
Officer and Citi’s Head of Operational Risk and senior 
members of their organizations. These members cover 
multiple dimensions of risk management and include business 
and regional Chief Risk Officers and senior operational risk 
managers.

In addition, risk management, including Operational 
Risk Management, works proactively with the businesses 
and other independent control functions to embed a strong 
operational risk management culture and framework across 
Citi. Operational Risk Management engages with the 
businesses to ensure effective implementation of the 
Operational Risk Management framework by focusing on (i) 
identification, analysis and assessment of operational risks, 
(ii) effective challenge of key control issues and operational 
risks and (iii) anticipation and mitigation of operational risk 
events.

Information about the businesses’ operational risk, 

historical operational risk losses and the control 
environment is reported by each major business segment and 
functional area. The information is summarized and reported 
to senior management, as well as to the Audit and Risk 
Committees of Citi’s Board of Directors.

Operational risk is measured and assessed through 
Operational Risk Capital and Operational Risk Regulatory 
Capital for the Advanced Approaches under Basel III. 
Projected operational risk losses under stress scenarios are 
also required as part of the Federal Reserve Board’s CCAR 
process. 

For additional information on Citi’s operational risks, see 

“Risk Factors—Operational Risk” above.

Cybersecurity Risk
Cybersecurity risk is the business risk associated with the 
threat posed by a cyber attack, cyber breach or the failure to 
protect Citi’s most vital business information assets or 
operations, resulting in a financial or reputational loss (for 
additional information, see the operational systems and 
cybersecurity risk factors in “Risk Factors—Operational 
Risks” above). With an evolving threat landscape, ever-
increasing sophistication of cybersecurity attacks and use of 
new technologies to conduct financial transactions, Citi and its 
clients, customers and third parties are and will continue to be 
at risk for cyber attacks and information security incidents. 
Citi recognizes the significance of these risks and, therefore, 
employs an intelligence-led strategy to prevent, detect, 
respond to and recover from cyber attacks. Further, Citi 
actively participates in financial industry, government and 
cross-sector knowledge-sharing groups to enhance individual 
and collective cyber resilience. 

Citi’s technology and cybersecurity risk management 
program is built on three lines of defense. Citi’s first line of 
defense under the Office of the Chief Information Security 
Officer provides frontline business, operational and technical 
controls and capabilities to protect against cybersecurity risks, 
and to respond to cyber incidents and data breaches. Citi 
manages these threats through state-of-the-art Fusion Centers, 
which serve as central command for monitoring and 
coordinating responses to cyber threats. The enterprise 
information security team is responsible for infrastructure 
defense and security controls, performing vulnerability 
assessments and third-party information security assessments, 
employee awareness and training programs and security 
incident management, in each case working in coordination 
with a network of information security officers who are 
embedded within the businesses and functions on a global 
basis. 

Citi’s Operational Risk Management-Technology and 

Cyber (ORM-T/C) and Independent Compliance Risk 
Management-Technology and Information Security (ICRM-T) 
groups serve as the second line of defense, and actively 
evaluate, anticipate and challenge Citi’s risk mitigation 
practices and capabilities. Internal audit serves as the third line 
of defense and independently provides assurance on how 
effectively the organization as a whole manages cybersecurity 
risk. Citi also has multiple senior committees such as the 
Information Security Risk Committee (ISRC), which governs 
enterprise-level risk tolerance inclusive of cybersecurity risk.

Citi seeks to proactively identify and remediate 

technology and cybersecurity risks before they materialize as 
incidents that negatively affect business operations. 
Accordingly, the ORM-T/C team independently challenges 
and monitors capabilities in accordance with Citi’s defined 
Technology and Cyber Risk Appetite statements. To address 
evolving cybersecurity risks and corresponding regulations, 
ORM-T/C also monitors cyber legal and regulatory 
requirements, identifies and defines emerging risks, executes 
strategic cyber threat assessments, performs new products and 
initiative reviews, performs data management risk oversight 
and conducts cyber risk assurance reviews (inclusive of third-
party assessments). In addition, ORM-T/C employs tools and 
oversees and challenges metrics that are both tailored to 
cybersecurity and technology and aligned with Citi’s overall 
operational risk management framework to effectively track, 
identify and manage risk.

COMPLIANCE RISK
Compliance risk is the risk to current or projected financial 
condition and resilience arising from violations of laws or 
regulations, or from nonconformance with prescribed 
practices, internal policies and procedures or ethical standards. 
This risk exposes a bank to fines, civil money penalties, 
payment of damages and the voiding of contracts. Compliance 
risk is not limited to risk from failure to comply with 
consumer protection laws; it encompasses the risk of 
noncompliance with all laws and regulations, as well as 
prudent ethical standards and contractual obligations. It also 
includes the exposure to litigation (known as legal risk) from 
all aspects of banking, traditional and nontraditional. 

105

Compliance risk spans all risk types in Citi’s risk 

governance framework and the risk categories outlined in the 
Governance, Risk, Compliance (GRC) taxonomy. Citi seeks to 
operate with integrity, maintain strong ethical standards and 
adhere to applicable policies and regulatory and legal 
requirements. Citi must maintain and execute a proactive 
Compliance Risk Management (CRM) Policy that is designed 
to manage compliance risk effectively across Citi, with a view 
to fundamentally strengthen the compliance risk management 
culture across the lines of defense, taking into account Citi’s 
risk governance framework and regulatory requirements. 
Independent Compliance Risk Management’s (ICRM) primary 
objectives are to:

•  Maintain and oversee an integrated CRM Policy that 

facilitates enterprise-wide compliance with local, national 
or cross-border laws, rules or regulations, Citi’s internal 
policies, standards and procedures and relevant standards 
of conduct;

•  Assess compliance risks and issues across product lines, 
functions and geographies, supported by globally 
consistent systems and compliance risk management 
processes;

•  Drive and embed a culture of compliance and control 

• 

throughout Citi; and
Provide compliance risk data aggregation and reporting 
capabilities.

To anticipate, control and mitigate compliance risk, Citi has 
established the CRM Policy to achieve standardization and 
centralization of methodologies and processes, and to enable 
more consistent and comprehensive execution of compliance 
risk management. 

Citi has a commitment, as well as an obligation, to 
identify, assess and mitigate compliance risks associated with 
its businesses and functions. ICRM is responsible for 
oversight of Citi’s CRM Policy, while all businesses and 
global control functions are responsible for managing their 
compliance risks and operating within the Compliance Risk 
Appetite. 

Citi carries out its objectives and fulfills its 

responsibilities through the integrated CRM Policy, which is 
based upon four components: (i) governance and organization; 
(ii) compliance risk requirements; (iii) processes and 
activities; and (iv) resources and capabilities. To achieve this, 
Citi follows these CRM Policy process steps:

• 

Identifying regulatory changes and performing the impact 
assessment, as well as capturing and monitoring 
adherence to existing regulatory requirements. 
•  Establishing, maintaining and adhering to policies, 
standards and procedures for the management of 
compliance risk, in accordance with policy governance 
requirements. 

•  Developing and providing training to support the effective 
execution of roles and responsibilities related to the 
identification, control, reporting and escalation of matters 
related to compliance risks.
Self-assessment (e.g., Managers Control Assessment) of 
compliance risk.

• 

• 

• 

ICRM is responsible for independently assessing the 
management of compliance risks.
Independently testing and monitoring that Citi is 
operating within the Compliance Risk Appetite. 
Identifying instances of non-conformance with laws, 
regulations, rules and breaches of internal policies. 
•  Escalating through the appropriate channels, which may 
include governance forums, the results of monitoring, 
testing, reporting or other oversight activities that may 
represent a violation of law, regulation, policy or other 
significant compliance risk and take reasonable action to 
see that the matter is appropriately identified, tracked and 
resolved, including through the issuance of corrective 
action plans against the first line of defense.

REPUTATION RISK
Citi’s reputation is a vital asset in building trust with its 
stakeholders and Citi is diligent in communicating its 
corporate values to its employees, customers and investors.  
To support this, Citi has defined a reputation risk appetite 
approach. Under this approach, each major business segment 
has implemented a risk appetite statement and related key 
indicators to monitor and address weaknesses that may result 
in significant reputation risks. The approach requires that each 
business segment or region escalates significant reputation 
risks that require review or mitigation through its business 
practice committee or equivalent.

The business practices committees are part of the 
governance infrastructure that Citi has in place to properly 
review business activities, sales practices, product design, 
perceived conflicts of interest and other potential franchise or 
reputation risks. These committees may also raise potential 
franchise, reputation or systemic risks for due consideration by 
the business practices committee at the corporate level. All of 
these committees, which are composed of Citi’s most senior 
executives, provide the guidance necessary for Citi’s business 
practices to meet the highest standards of professionalism, 
integrity and ethical behavior consistent with Citi’s mission 
and value proposition.

Further, the responsibility for maintaining Citi’s 

reputation is shared by all employees, who are guided by Citi’s 
code of conduct. Employees are expected to exercise sound 
judgment and common sense in decisions and actions. They 
are also expected to promptly and appropriately escalate all 
issues that present potential franchise, reputation and/or 
systemic risk. 

STRATEGIC RISK

Overview
Citi executive management, with Citi’s CEO at the lead, is 
responsible for the development and execution of Citi’s 
strategy. This strategy is translated into forward-looking plans 
that are then cascaded across the organization. Strategic risk is 
monitored through a range of practices: regular Citigroup 
Board of Director meetings provide strategic external 
checkpoints where management’s progress against executing 
the plans is assessed and where decisions to refine the 
strategic direction of the Company are evaluated; Citi’s 

106

executive management assesses progress against executing the 
defined plans; CEO reviews, which include a risk assessment 
of the plans, occur across products, regions and functions to 
focus on progress against executing the plans; products, 
regions and functions have internal reviews to assess 
performance at lower levels across the organization; and 
specific forums exist to focus on key areas that drive strategic 
risk such as balance sheet management, the introduction of 
new or modified products and services and country 
management, among others. In addition to these day-to-day 
practices, significant strategic actions, such as mergers, 
acquisitions or capital expenditures, are reviewed and 
approved by, or notified to, the Citigroup and Citibank Boards 
of Directors, as appropriate.

Exit of U.K. from EU
As a result of a 2016 U.K. referendum, Citi has reorganized 
certain U.K. and EU operations and implemented contingency 
plans to address the U.K.’s official exit from the EU, which 
occurred as of January 31, 2020. In addition, Citi has 
established a formal program with senior-level sponsorship 
and governance to deliver a coordinated response to the U.K.’s 
exit. 

Until negotiations between the U.K. and the EU are 
finalized and any exit agreement is ratified, Citi continues to 
plan for a “hard” exit scenario. Citi’s strategy focuses on 
providing continuity of services to its U.K. and EU clients 
with minimal disruption. Consequently, Citi has migrated 
certain business activities to alternative legal entities and 
branches with appropriate regulatory permissions to carry out 
such activity, and has established required capabilities in the 
U.K. and EU. Citi’s plans for a U.K. exit from the EU have 
primarily covered:

• 

• 

• 

• 

the enhancement of Citi’s European bank in Ireland, 
supported by its substantial European branch network to 
ensure business continuity for its EU clients;
the conversion of Citi’s banking subsidiary in Germany 
into Citi’s EU investment firm to support broker-dealer 
activities with EU clients;
the establishment of a new U.K. consumer bank to focus 
on servicing consumer business clients in the U.K.; and
the amendments to existing U.K. legal entities or 
branches, where required, to ensure continuity of services 
to U.K. and non-EU clients. 

Citi has worked closely with clients, regulators and other 

relevant stakeholders in the execution of its plans to prepare 
for the U.K.’s exit from the EU. In addition, Citi continues to 
monitor macroeconomic scenarios and market events and has 
been undertaking stress testing to assess potential impacts on 
its businesses. For additional information, see “Risk Factors—
Strategic Risks” above. 

LIBOR Transition Risk
Citi recognizes that a transition away from and discontinuance 
of LIBOR presents risks and challenges that could 
significantly impact financial markets and market participants, 
including Citi (for information about Citi’s risks from a 
transition away from and discontinuation of LIBOR or any 

other benchmark, see “Risk Factors—Strategic Risks” above). 
Accordingly, Citi has continued its efforts to identify and 
manage its LIBOR transition risks. 

Citi’s LIBOR governance and implementation program 
remains focused on identifying and addressing the LIBOR 
transition impacts to Citi’s clients, operational capabilities and 
legal and financial contracts, among others. The program 
operates globally across Citi’s businesses and functions and 
includes active involvement of senior management, oversight 
by Citi’s Asset and Liability Committee and reporting to the 
Risk Management Committee of Citigroup’s Board of 
Directors. As part of the program, Citi has developed LIBOR 
transition action plans and associated roadmaps under the 
following key workstreams: program management; transition 
strategy and risk management; customer management, 
including internal communications and training, legal/contract 
management and product management; financial exposures 
and risk management; regulatory and industry engagement; 
operations and technology; and finance, risk, tax and treasury. 
During 2019, Citi continued to participate in a number of 

working groups formed by global regulators, including the 
Alternative Reference Rates Committee (ARRC) convened by 
the Federal Reserve Board. These working groups continue to 
promote and advance development of alternative reference 
rates and to identify and address potential challenges from any 
transition to such rates. Citi also continues to engage with and 
monitor developments involving regulators, financial 
accounting bodies and others on LIBOR transition matters and 
relief.

Moreover, Citi has been investing in its systems and 
infrastructure, as client activity moves away from LIBOR to 
alternative reference rates. Citi also has continued to identify 
its LIBOR transition exposures, including existing financial 
instruments that do not contain contract provisions that 
adequately contemplate the discontinuance of reference rates 
and that would require additional negotiation with 
counterparties. In addition, Citi has begun to mitigate its 
LIBOR transition exposures by, among other things, using 
alternative reference rates in certain newly issued financial 
instruments and products. For example, since early 2019, Citi 
has issued both preferred stock and benchmark debt 
referencing the Secured Overnight Financing Rate (SOFR) 
and updated the LIBOR determination method in its debt 
documentation with the ARRC recommended fallback 
language. Citi has also been conducting LIBOR transition-
related training for employees.

107

Country Risk

Top 25 Country Exposures 
The following table presents Citi’s top 25 exposures by
country (excluding the U.S.) as of December 31, 2019. The 
total exposure as of December 31, 2019 to the top 25 countries 
disclosed below, in combination with the U.S., would 
represent approximately 95% of Citi’s exposure to all 
countries. For purposes of the table, loan amounts are reflected 
in the country where the loan is booked, which is generally 
based on the domicile of the borrower. For example, a loan to 
a Chinese subsidiary of a Switzerland-based corporation will 
generally be categorized as a loan in China. In addition, Citi 
has developed regional booking centers in certain countries, 

most significantly in the United Kingdom (U.K.) and Ireland, 
in order to more efficiently serve its corporate customers. As 
an example, with respect to the U.K., only 33% of corporate
loans presented in the table below are to U.K. domiciled
entities (35% for unfunded commitments), with the balance of
the loans predominately to European domiciled counterparties.
Approximately 85% of the total U.K. funded loans and 89% of
the total U.K. unfunded commitments were investment grade
as of December 31, 2019. Trading account assets and 
investment securities are generally categorized based on the 
domicile of the issuer of the security of the underlying 
reference entity. For additional information on the assets 
included in the table, see the footnotes to the table below.

ICG 
loans(1)

GCB
loans

Other 

funded(2) Unfunded(3)

Net MTM 
on 
derivatives
/repos(4)

Total
hedges
(on loans
and
CVA)

Investment 
securities(5)

Trading 
account 
assets(6)

Total 
as of 
4Q19

Total 
as of 
3Q19

Total 
as of 
4Q18

Total as a
% of Citi
as of
4Q19

$ 41.8 $ — $

1.9 $

50.0 $

12.3 $

(5.2) $

7.3 $

(2.3) $ 105.8 $ 116.6 $

111.6

6.5%

17.8

20.5

14.5

12.1

3.1

6.5

12.7

0.5

4.7

7.6

5.9

2.7

2.4

4.1

8.0

8.1

1.9

0.9

2.4

1.9

0.7

—

0.8

—

17.6

12.9

13.3

—

16.5

4.8

—

—

9.8

3.3

8.0

—

0.6

2.0

—

1.5

4.2

2.9

0.9

1.0

1.6

—

—

—

0.3

0.9

0.1

0.5

0.1

0.9

—

0.1

0.1

0.6

0.1

0.1

0.1

0.1

0.1

0.1

0.2

—

—

—

0.1

—

—

—

8.9

7.2

5.0

26.4

2.4

5.9

3.1

6.0

6.2

2.9

1.9

2.5

6.8

2.4

5.1

2.9

1.0

1.8

1.4

0.7

0.5

—

0.7

—

0.8

1.4

0.7

0.5

1.0

1.5

5.6

3.9

1.6

0.8

0.4

2.4

1.7

0.2

—

0.2

0.2

—

0.1

0.2

—

0.7

2.7

0.1

(0.8)

(0.7)

(0.4)

—

(0.4)

(0.6)

(0.9)

(3.9)

(0.4)

(0.5)

(0.1)

(1.7)

(0.7)

(0.1)

(0.4)

(0.1)

(0.1)

—

(0.1)

(0.1)

—

(0.3)

—

(0.6)

16.0

6.2

8.2

—

8.9

10.1

4.1

9.2

1.5

5.0

0.9

5.8

3.9

3.8

—

0.1

1.0

1.7

1.1

1.1

1.9

3.7

—

3.0

4.4

0.6

1.9

0.4

3.1

0.9

3.7

6.0

(2.0)

(1.0)

0.8

5.2

0.4

0.9

—

—

—

0.4

0.1

0.2

0.1

0.5

0.1

1.0

65.0

49.0

43.3

39.9

34.7

30.0

28.3

21.8

21.5

18.7

17.9

17.0

15.2

13.4

12.8

67.3

52.5

41.3

34.8

31.2

29.6

25.7

18.0

20.8

18.6

17.2

18.3

15.9

13.6

13.6

12.8

11.6

8.4

7.7

5.9

5.0

4.9

4.6

4.3

3.5

9.1

7.8

5.9

5.0

4.6

3.1

3.8

3.8

59.6

48.1

40.7

33.7

33.8

30.2

26.0

17.4

23.5

18.0

17.4

17.6

16.0

13.2

10.4

9.6

10.0

7.4

6.3

4.6

5.3

4.9

3.0

2.5

4.0

3.0

2.6

2.4

2.1

1.8

1.7

1.3

1.3

1.1

1.1

1.0

0.9

0.8

0.8

0.8

0.5

0.5

0.4

0.3

0.3

0.3

0.3

0.2

36.0%

89.7%

Total as a % of Citi’s Total Exposure

Total as a % of Citi’s non-U.S. Total Exposure

(1) 

ICG loans reflect funded corporate loans and private bank loans, net of unearned income. As of December 31, 2019, private bank loans in the table above totaled 
$30 billion, concentrated in Hong Kong ($9.3 billion), Singapore ($7.6 billion) and the U.K. ($7.2 billion).  

(2)  Other funded includes other direct exposure such as accounts receivable, loans HFS, other loans in Corporate/Other and investments accounted for under the 

equity method. 

108

In billions of
U.S. dollars
United
Kingdom

Mexico

Hong Kong

Singapore

Ireland

South Korea

India

Brazil

Germany

Australia

China

Taiwan

Japan

Canada

Poland

Jersey

United Arab
Emirates

Malaysia

Thailand

Indonesia

Russia

Philippines

Luxembourg
Czech
Republic

Cayman
Islands

 
 
 
 
 
 
 
 
 
 
 
 
 
(3)  Unfunded exposure includes unfunded corporate lending commitments, letters of credit and other contingencies. 
(4)  Net mark-to-market counterparty risk on OTC derivatives and securities lending/borrowing transactions (repos). Exposures are shown net of collateral and 

(5) 

inclusive of CVA. Includes margin loans. 
Investment securities include securities available-for-sale, recorded at fair market value, and securities held-to-maturity, recorded at historical cost. Investment 
securities are reflected in the country that holds, not issues, the investments. 

(6)  Trading account assets are shown on a net basis and include issuer risk on cash products and derivative exposure where the underlying reference entity/issuer is 

located in that country.

Argentina
Citi operates in Argentina through its ICG businesses. As of 
December 31, 2019, Citi’s net investment in its Argentine 
operations was approximately $730 million. Citi uses the U.S. 
dollar as the functional currency for its operations in Argentina 
because the Argentine economy is considered highly 
inflationary under U.S. GAAP. 

During 2019, the Argentine peso depreciated 59% against 

the U.S. dollar, and the U.S. rating agencies downgraded 
Argentina’s sovereign debt rating given renewed concerns of a 
debt default. In addition, the government of Argentina re-
profiled certain short-term debt obligations, and also 
implemented new capital and currency controls during the 
third quarter of 2019. Prior to the implementation of these new 
capital controls, Citi had already remitted all available 
earnings from its Argentine operations that could be remitted 
during the 2019 calendar year; the new controls may restrict 
Citi’s ability to access U.S. dollars in Argentina and remit 
earnings from its Argentine operations in the future. 

Citi economically hedges the foreign currency risk in its 
net Argentine peso-denominated assets to the extent possible 
and prudent using non-deliverable forward (NDF) derivative 
instruments that are executed outside of Argentina. As of 
December 31, 2019, the international NDF market had very 
limited liquidity, resulting in Citi being unable to 
economically hedge a significant portion of its Argentine peso 
exposure. To the extent that Citi is unable to execute 
additional NDF contracts in the future, devaluations on Citi’s 
net Argentine peso-denominated assets would be recorded in 
earnings, without any benefit from a change in the fair value 
of derivative positions used to economically hedge the 
exposure. 

In addition, Citi continually evaluates its economic 
exposure to its Argentine counterparties and reserves for 
changes in credit risk and sovereign risk associated with its 
Argentine assets. Citi believes it has established appropriate 
loan loss reserves on its Argentine loans, and appropriate fair 
value adjustments on Argentine assets and liabilities measured 
at fair value, for such risks under U.S. GAAP as of December 
31, 2019. However, given the recent events in Argentina, U.S. 
regulatory agencies may require Citi to record additional 
reserves in the future, increasing ICG’s cost of credit, based on 
the perceived country risk associated with its Argentine 
exposures. For additional information on emerging markets 
risks, see “Risk Factors—Strategic Risks” above.

FFIEC—Cross-Border Claims on Third Parties and Local 
Country Assets
Citi’s cross-border disclosures are based on the country 
exposure bank regulatory reporting guidelines of the Federal 
Financial Institutions Examination Council (FFIEC). The 
following summarizes some of the FFIEC key reporting 
guidelines:

•  Amounts are based on the domicile of the ultimate 

obligor, counterparty, collateral (only including qualifying 
liquid collateral), issuer or guarantor, as applicable (e.g., a 
security recorded by a Citi U.S. entity but issued by the 
U.K. government is considered U.K. exposure; a loan 
recorded by a Citi Mexico entity to a customer domiciled 
in Mexico where the underlying collateral is held in 
Germany is considered German exposure). 

•  Amounts do not consider the benefit of collateral received 

for secured financing transactions (i.e., repurchase 
agreements, reverse repurchase agreements and securities 
loaned and borrowed) and are reported based on notional 
amounts. 

•  Netting of derivative receivables and payables, reported at 
fair value, is permitted, but only under a legally binding 
netting agreement with the same specific counterparty, 
and does not include the benefit of margin received or 
hedges.

•  Credit default swaps (CDS) are included based on the 
gross notional amount sold and purchased and do not 
include any offsetting CDS on the same underlying entity. 

•  Loans are reported without the benefit of hedges.

Given the requirements noted above, Citi’s FFIEC cross-
border exposures and total outstandings tend to fluctuate, in 
some cases significantly, from period to period. As an 
example, because total outstandings under FFIEC guidelines 
do not include the benefit of margin or hedges, market 
volatility in interest rates, foreign exchange rates and credit 
spreads may cause significant fluctuations in the level of total 
outstandings, all else being equal.

109

 
 
 
 
 
 
 
 
 
 
 
The tables below show each country whose total outstandings exceeded 0.75% of total Citigroup assets:

December 31, 2019
Cross-border claims on third parties and local country assets
Short-term 
Other 
claims(2) 
(corporate 
(included 
and households) 
in (a))
(a)

Total 
outstanding(3) 
(sum of (a))

Trading 
assets(2) 
(included 
in (a))

Commitments
 and 
guarantees(4)

Credit 
derivatives 
purchased(5)

Credit 
derivatives 
sold(5)

Banks
(a)

Public
(a)

NBFIs(1) 
(a)

$ — $ — $

96.8 $

10.3 $

5.3 $

75.9 $

107.1 $

10.0 $

— $

13.3
32.7
2.8
6.8
8.4
2.3
2.0
1.7
0.6
4.8
3.4
3.3
2.9
6.8
0.6
3.3
1.2
0.2

24.4
33.3
26.3
29.8
6.8
17.7
16.0
12.9
10.2
8.7
11.0
13.3
4.7
8.5
6.8
15.9
14.5
0.3

34.8
7.8
9.4
7.7
22.2
7.2
1.7
3.1
3.0
4.7
3.1
1.8
11.5
3.9
1.6
0.7
1.1
8.9

20.6
6.5
35.2
9.7
7.5
16.1
21.7
16.3
20.0
12.9
12.7
11.0
5.0
4.6
14.3
1.7
4.6
5.4

12.9
13.1
5.5
9.3
9.6
2.8
2.6
2.7
4.1
7.9
3.9
6.1
3.1
4.6
2.9
12.8
2.2
4.2

61.3
57.4
37.0
33.6
35.3
36.1
31.4
23.4
27.9
20.6
25.3
20.8
13.5
15.7
13.2
14.9
18.1
12.9

93.1
80.3
73.7
54.0
44.9
43.3
41.4
34.0
33.8
31.1
30.2
29.4
24.1
23.8
23.3
21.6
21.4
14.8

23.2
4.7
22.4
13.1
29.0
12.0
12.0
10.8
13.7
11.8
5.1
3.2
14.7
11.0
14.6
2.5
8.2
5.4

71.6
18.7
8.9
48.0
56.0
2.0
13.9
2.3
2.2
7.4
12.8
8.1
4.3
26.9
0.1
44.5
17.8
1.6

—

71.6
17.1
8.8
46.4
54.3
1.9
13.0
2.0
2.0
7.3
11.6
8.2
5.1
26.5
0.1
44.0
17.3
1.8

December 31, 2018
Cross-border claims on third parties and local country assets 

Banks
(a)

Public
(a)

NBFIs(1) 
(a)

Other 
(corporate 
and households) 
(a)

Trading 
assets(2) 
(included 
in (a))

Short-term 
claims(2) 
(included 
in (a))

Total 
outstanding(3) 
(sum of (a))

Commitments
 and 
guarantees(4)

Credit 
derivatives 
purchased(5)

Credit 
derivatives 
sold(5)

$ 14.6 $ 23.5 $

35.7 $

22.4 $

12.3 $

67.8 $

96.2 $

25.1 $

74.3 $

76.4

—
31.4
3.1
6.3
12.4
1.5
2.3
3.3
0.9
5.0
3.1
3.8
0.7
6.8
3.2
1.4
3.4

—
28.8
24.5
45.6
8.5
17.8
22.5
12.7
11.2
11.3
7.8
10.4
7.4
9.0
4.0
13.9
11.0

81.6
8.4
7.4
7.2
30.7
3.0
4.4
3.3
3.2
3.0
4.8
1.4
3.2
3.2
9.9
1.1
0.8

9.2
7.8
34.7
7.6
5.6
22.6
13.4
15.3
16.9
12.3
13.4
10.9
12.6
4.7
5.2
3.6
1.6

5.4
13.6
6.0
6.6
9.1
1.8
1.7
4.3
3.9
4.5
7.1
5.0
1.6
3.7
2.8
1.6
7.9

62.5
40.7
29.1
49.8
49.5
33.2
32.3
22.5
27.5
20.6
14.4
16.8
18.7
14.7
15.5
5.1
10.5

90.8
76.4
69.7
66.7
57.2
44.9
42.6
34.6
32.2
31.6
29.1
26.5
23.9
23.7
22.3
20.0
16.8

5.0
4.0
20.2
10.7
30.7
12.1
11.4
9.7
14.6
4.2
12.1
2.6
13.0
8.6
13.8
6.0
2.5

—
19.9
7.3
51.3
59.9
12.2
1.9
2.5
2.2
15.6
10.6
8.4
0.1
28.4
5.3
19.7
51.3

—
18.3
7.6
50.2
58.5
12.2
1.9
2.0
2.2
14.6
10.5
8.1
0.1
28.3
6.2
19.6
51.5

In billions of
U.S. dollars
Cayman
Islands
United
Kingdom
Japan
Mexico
Germany
France
Singapore
South Korea
India
Hong Kong
Australia
China
Brazil
Canada
Netherlands
Taiwan
Italy
Switzerland
Ireland

In billions of
U.S. dollars
United
Kingdom

Cayman
Islands
Japan
Mexico
Germany
France
South Korea
Singapore
India
Hong Kong
China
Australia
Brazil
Taiwan
Netherlands
Canada
Switzerland
Italy

(1)  Non-bank financial institutions.
(2) 
(3)  Total outstanding includes cross-border claims on third parties, as well as local country assets. Cross-border claims on third parties include cross-border loans, 

Included in total outstanding.

securities, deposits with banks and other monetary assets, as well as net revaluation gains on foreign exchange and derivative products.

110

(4)  Commitments (not included in total outstanding) include legally binding cross-border letters of credit and other commitments and contingencies as defined by the 
FFIEC guidelines. The FFIEC definition of commitments includes commitments to local residents to be funded with local currency liabilities originated within the 
country.

(5)  Credit default swaps (CDS) are not included in total outstanding. 

111

SIGNIFICANT ACCOUNTING POLICIES AND SIGNIFICANT ESTIMATES

This section contains a summary of Citi’s most significant 
accounting policies. Note 1 to the Consolidated Financial 
Statements contains a summary of all of Citigroup’s 
significant accounting policies. These policies, as well as 
estimates made by management, are integral to the 
presentation of Citi’s results of operations and financial 
condition. While all of these policies require a certain level 
of management judgment and estimates, this section 
highlights and discusses the significant accounting policies 
that require management to make highly difficult, complex 
or subjective judgments and estimates at times regarding 
matters that are inherently uncertain and susceptible to 
change (see also “Risk Factors—Operational Risks” above). 
Management has discussed each of these significant 
accounting policies, the related estimates and its judgments 
with the Audit Committee of the Citigroup Board of 
Directors. 

Valuations of Financial Instruments
Citigroup holds debt and equity securities, derivatives, 
retained interests in securitizations, investments in private 
equity and other financial instruments. Substantially all of 
these assets and liabilities are reflected at fair value on Citi’s 
Consolidated Balance Sheet.

Citi purchases securities under agreements to resell 

(reverse repos) and sells securities under agreements 
to repurchase (repos), a majority of which are carried at 
fair value. In addition, certain loans, short-term borrowings, 
long-term debt and deposits, as well as certain securities 
borrowed and loaned positions that are collateralized with 
cash, are carried at fair value. Citigroup holds its 
investments, trading assets and liabilities, and resale and 
repurchase agreements on the Consolidated Balance Sheet to 
meet customer needs and to manage liquidity needs, interest 
rate risks and private equity investing.

When available, Citi generally uses quoted market 
prices to determine fair value and classifies such items 
within Level 1 of the fair value hierarchy established under 
ASC 820-10, Fair Value Measurement. If quoted market 
prices are not available, fair value is based upon internally 
developed valuation models that use, where possible, current 
market-based or independently sourced market parameters, 
such as interest rates, currency rates and option volatilities. 
Such models are often based on a discounted cash flow 
analysis. In addition, items valued using such internally 
generated valuation techniques are classified according to 
the lowest level input or value driver that is significant to the 
valuation. Thus, an item may be classified under the fair 
value hierarchy as Level 3 even though there may be some 
significant inputs that are readily observable.

Citi is required to exercise subjective judgments relating 

to the applicability and functionality of internal valuation 
models, the significance of inputs or value drivers to the 
valuation of an instrument and the degree of illiquidity and 
subsequent lack of observability in certain markets. These 
judgments have the potential to impact the Company’s 
financial performance for instruments where the changes in 

fair value are recognized in either the Consolidated 
Statement of Income or in AOCI. 

Moreover, for certain investments, decreases in fair 

value are only recognized in earnings in the Consolidated 
Statement of Income if such decreases are judged to be an 
other-than-temporary impairment (OTTI). Adjudicating the 
temporary nature of fair value impairments is also inherently 
judgmental. 

 The fair value of financial instruments incorporates the 

effects of Citi’s own credit risk and the market view of 
counterparty credit risk, the quantification of which is also 
complex and judgmental. For additional information on 
Citi’s fair value analysis, see Notes 1, 6, 24 and 25 to the 
Consolidated Financial Statements.

Allowance for Credit Losses
Management provides reserves for an estimate of probable 
losses inherent in the funded loan portfolio and in unfunded 
loan commitments and standby letters of credit on the 
Consolidated Balance Sheet in the Allowance for loan losses 
and in Other liabilities, respectively. 

Estimates of these probable losses are based upon (i) 
Citigroup’s internal system of credit-risk ratings that are 
analogous to the risk ratings of the major credit rating 
agencies and (ii) historical default and loss data, including 
rating agency information regarding default rates from 1983 
to 2017 and internal data dating to the early 1970s on 
severity of losses in the event of default. Adjustments may 
be made to this data, including (i) statistically calculated 
estimates to cover the historical fluctuation of the default 
rates over the credit cycle, the historical variability of loss 
severity among defaulted loans and the degree to which 
there are large obligor concentrations in the global portfolio 
and (ii) adjustments made for specifically known items, such 
as current environmental factors and credit trends.
In addition, representatives from both the risk 
management and finance staffs who cover business areas 
with delinquency-managed portfolios containing smaller 
balance homogeneous loans present their recommended 
reserve balances based upon leading credit indicators, 
including loan delinquencies and changes in portfolio size, 
as well as economic trends, including housing prices, 
unemployment and GDP. This methodology is applied 
separately for each individual product within each 
geographic region in which these portfolios exist.

This evaluation process is subject to numerous estimates 

and judgments. The frequency of default, risk ratings, loss 
recovery rates, the size and diversity of individual large 
credits and the ability of borrowers with foreign currency 
obligations to obtain the foreign currency necessary for 
orderly debt servicing, among other things, are all taken into 
account during this review. Changes in these estimates could 
have a direct impact on Citi’s credit costs and the allowance 
in any period. 

For a further description of the loan loss reserve and 

related accounts, see Notes 1 and 15 to the Consolidated 
Financial Statements.

112

For a discussion of the recently adopted CECL 
accounting pronouncement, see Note 1 to the Consolidated 
Financial Statements. 

Goodwill 
Citi tests goodwill for impairment annually on July 1 (the 
annual test) and through interim assessments between annual 
tests if an event occurs or circumstances change that would 
more-likely-than-not reduce the fair value of a reporting unit 
below its carrying amount, such as a significant adverse 
change in the business climate, a decision to sell or dispose 
of all or a significant portion of a reporting unit or a 
significant decline in Citi’s stock price. During 2019, the 
annual test was performed, which resulted in no goodwill 
impairment as described in Note 16 to the Consolidated 
Financial Statements. 

As of December 31, 2019, Citigroup’s activities are 

conducted through the Global Consumer Banking and 
Institutional Clients Group business segments and 
Corporate/Other. Goodwill impairment testing is performed 
at the level below the business segment (referred to as a 
reporting unit). 

Citi utilizes allocated equity as a proxy for the carrying 

value of its reporting units for purposes of goodwill 
impairment testing. The allocated equity in the reporting 
units is determined based on the capital the business would 
require if it were operating as a standalone entity, 
incorporating sufficient capital to be in compliance with both 
current and expected regulatory capital requirements, 
including capital for specifically identified goodwill and 
intangible assets. The capital allocated to the businesses is 
incorporated into the annual budget process, which is 
approved by Citi’s Board of Directors. 

 Goodwill impairment testing involves management 
judgment, requiring an assessment of whether the carrying 
value of the reporting unit can be supported by the fair value 
of the reporting unit using widely accepted valuation 
techniques, such as the market approach (earnings multiples 
and/or transaction multiples) and/or the income approach 
(discounted cash flow (DCF) method). In applying these 
methodologies, Citi utilizes a number of factors, including 
actual operating results, future business plans, economic 
projections and market data.

 Similar to 2018, Citigroup engaged an independent 
valuation specialist in 2019 to assist in Citi’s valuation for all 
the reporting units with goodwill balances, employing both 
the market approach and the DCF method. The resulting fair 
values were relatively consistent and appropriate weighting 
was given to outputs from both methods.

The DCF method utilized at the time of each 
impairment test used discount rates that Citi believes 
adequately reflected the risk and uncertainty in the financial 
markets in the internally generated cash flow projections. 
The DCF method employs a capital asset pricing model in 
estimating the discount rate. 

Since none of the Company’s reporting units are 

publicly traded, individual reporting unit fair value 
determinations cannot be directly correlated to Citigroup’s 
common stock price. The sum of the fair values of the 

reporting units exceeded the overall market capitalization of 
Citi as of July 1, 2019. However, Citi believes that it is not 
meaningful to reconcile the sum of the fair values of the 
Company’s reporting units to its market capitalization due to 
several factors. The market capitalization of Citigroup 
reflects the execution risk in a transaction involving 
Citigroup due to its size. However, the individual reporting 
units’ fair values are not subject to the same level of 
execution risk nor a business model that is perceived to be as 
complex. In addition, the market capitalization of Citigroup 
does not include consideration of the individual reporting 
unit’s control premium.

See Notes 1 and 16 to the Consolidated Financial 

Statements for additional information on goodwill, including 
the changes in the goodwill balance year-over-year and the 
reporting units’ goodwill balances as of December 31, 2019.

Income Taxes

Overview
Citi is subject to the income tax laws of the U.S., its states 
and local municipalities and the non-U.S. jurisdictions in 
which Citi operates. These tax laws are complex and are 
subject to differing interpretations by the taxpayer and the 
relevant governmental taxing authorities. Disputes over 
interpretations of the tax laws may be subject to review and 
adjudication by the court systems of the various tax 
jurisdictions or may be settled with the taxing authority upon 
audit.

In establishing a provision for income tax expense, Citi 

must make judgments and interpretations about the 
application of these inherently complex tax laws. Citi must 
also make estimates about when in the future certain items 
will affect taxable income in the various tax jurisdictions, 
both domestic and foreign. Deferred taxes are recorded for 
the future consequences of events that have been recognized 
in the financial statements or tax returns, based upon enacted 
tax laws and rates. Deferred tax assets (DTAs) are 
recognized subject to management’s judgment that 
realization is more-likely-than-not. For example, if it is 
more-likely-than-not that a carry-forward would expire 
unused, Citi would set up a valuation allowance against that 
DTA. Citi has established valuation allowances as described 
below.

As a result of the Tax Cuts and Jobs Act (Tax Reform), 
beginning in 2018, Citi is taxed on income generated by its 
U.S. operations at a federal tax rate of 21%. The effect on 
Citi’s state tax rate is dependent upon how and when the 
individual states choose to or automatically adopt the various 
new provisions of the U.S. Internal Revenue Code.

Citi’s non-U.S. branches and subsidiaries are subject to 
tax at their local tax rates. While non-U.S. branches continue 
to be subject to U.S. taxation, Citi expects no material 
residual U.S. tax on such earnings since its overall non-U.S. 
branch tax rate is in excess of 21%. With respect to non-U.S. 
subsidiaries, dividends from these subsidiaries will be 
excluded from U.S. taxation. While the majority of Citi’s 
non-U.S. subsidiary earnings are classified as Global 
Intangible Low Taxed Income (GILTI), Citi similarly 

113

expects no material residual U.S. tax on such earnings based 
on its non-U.S. subsidiaries’ local tax rates, which exceed, 
on average, the GILTI tax rate. Finally, Citi does not expect 
the Base Erosion Anti-Abuse Tax (BEAT) to affect its tax 
provision.

Deferred Tax Assets and Valuation Allowances
At December 31, 2019, Citi had net DTAs of $23.1 billion. 
In the fourth quarter of 2019, Citi’s DTAs increased by $0.6 
billion, driven primarily by the release of a portion of the 
valuation allowance related to Citi’s general basket FTC 
carry-forwards and losses in AOCI. On a full-year basis, 
Citi’s DTAs increased $0.2 billion from $22.9 billion at 
December 31, 2018, primarily due to the releases of a 
portion of the valuation allowance related to Citi’s general 
basket FTC carry-forwards, partially offset by gains in 
AOCI. 

Of Citi’s total net DTAs of $23.1 billion as of December 

31, 2019, $10.7 billion, primarily related to tax carry-
forwards, was excluded in calculating Citi’s regulatory 
capital. The amount excluded from Citi’s regulatory capital 
decreased $0.9 billion in the full year 2019, adjusting for the 
impact of the valuation allowance releases. Net DTAs arising 
from temporary differences are deducted from regulatory 
capital if in excess of the 10%/15% limitations (see “Capital 
Resources” above). For the year ended December 31, 2019, 
Citi did not have any such DTAs. Accordingly, the remaining 
$12.4 billion of net DTAs as of December 31, 2019 was not 
deducted in calculating regulatory capital pursuant to Basel 
III standards, and was appropriately risk weighted under 
those rules.

Citi’s total valuation allowance at December 31, 2019 

was $6.5 billion, a decrease of $2.8 billion from $9.3 billion 
at December 31, 2018. The decrease was primarily driven by 
carry-forward expirations in the FTC branch basket and in a 
non-U.S. NOL, FTC general basket valuation allowance 
releases and a reduction in the net U.S. residual DTA related 
to non-U.S. branches. Citi’s valuation allowance of $6.5 
billion is composed of $4.6 billion on its FTC carry-
forwards, $0.8 billion on its U.S. residual DTA related to its 
non-U.S. branches, $1.0 billion on local non-U.S. DTAs and 
$0.1 billion on state net operating loss and capital loss carry-
forwards.

Citi’s valuation allowance of $3.5 billion against FTC 
carry-forwards relating to its non-U.S. branches decreased 
by $0.9 billion in 2019, primarily due to the expiration of the 
2009 FTC carry-forward. Citi expects that the absolute 
amount of its valuation allowance may change in future 
years as it generates additional FTCs relating to the higher 
overall local tax rate of its non-U.S. branches, reduced by 
the expiration of FTC carry-forwards. 

Citi’s valuation allowance of $1.1 billion against FTC 

carry-forwards in its general basket decreased by $0.5 
billion, primarily due to actions taken to increase foreign 
source income in the U.S. and the updated forecast of 
foreign source income for the FTC carry-forward period. In 
the fourth quarter of 2019, Citi committed to a plan to move 
a financing business involving non-U.S. clients and its 
associated funding to the U.S. The incremental foreign 

source income generated by this action over time will more-
likely-than-not enable usage of FTC carry-forwards of $0.2 
billion. See Note 9 to the Consolidated Financial Statements. 
As stated above, with respect to the portion of the valuation 
allowance established on Citi’s FTC carry-forwards that are 
available for use in the general basket, changes in the 
amount of earnings from sources outside the U.S. could alter 
the amount of valuation allowance that is eventually needed 
against such FTCs. Citi continues to look for other actions 
that may improve foreign source income in the U.S. tax 
return and thus affect the valuation allowance. These actions 
can include the relocation of certain businesses to the U.S., 
each of which can raise client, regulatory or operational 
challenges. No other actions were deemed prudent and 
feasible as of December 31, 2019.

Recognized FTCs comprised approximately $6.3 billion 

of Citi’s DTAs as of December 31, 2019, compared to 
approximately $6.8 billion as of December 31, 2018. The 
decrease in FTCs year-over-year was primarily due to 
current-year usage, partially offset by the valuation 
allowance release. The FTC carry-forward period represents 
the most time-sensitive component of Citi’s DTAs.
Citi has an overall domestic loss (ODL) of 

approximately $39 billion at December 31, 2019, which 
allows Citi to elect a percentage between 50% and 100% of 
future years’ domestic source income to be reclassified as 
foreign source income. (See Note 9 to the Consolidated 
Financial Statements for a description of the ODL).

Citi believes the U.S. federal and New York State and 

City net operating loss carry-forward period of 20 years 
provides enough time to fully utilize the net DTAs pertaining 
to the existing net operating loss carry-forwards. This is due 
to Citi’s forecast of sufficient U.S. taxable income and the 
continued taxation of Citi’s non-U.S. income by New York 
State and City. Although realization is not assured, Citi 
believes that the realization of its recognized net DTAs of 
$23.1 billion at December 31, 2019 is more-likely-than-not, 
based upon management’s expectations as to future taxable 
income in the jurisdictions in which the DTAs arise, as well 
as available tax planning strategies (as defined in ASC Topic 
740, Income Taxes). Citi has concluded that it has the 
necessary positive evidence to support the realization of its 
net DTAs after taking its valuation allowances into 
consideration.

For additional information on Citi’s income taxes, 
including its income tax provision, tax assets and liabilities 
and a tabular summary of Citi’s net DTAs balance as of 
December 31, 2019 (including the FTCs and applicable 
expiration dates of the FTCs), see Note 9 to the Consolidated 
Financial Statements. For information on Citi’s ability to use 
its DTAs, see “Risk Factors—Strategic Risks” above.

Tax Cuts and Jobs Act
On December 22, 2017, the President signed Tax Reform 
into law, reflecting changes to U.S. corporate taxation, 
including a lower statutory tax rate of 21%, a quasi-
territorial regime and a deemed repatriation of all 
accumulated earnings and profits of foreign subsidiaries. The 
new law was generally effective January 1, 2018.

114

Citi recorded a one-time, non-cash charge to continuing 

operations of $22.6 billion in the fourth quarter of 2017, 
composed of (i) a $12.4 billion remeasurement due to the 
reduction of the U.S. corporate tax rate and the change to a 
“quasi-territorial tax system,” (ii) a $7.9 billion valuation 
allowance against Citi’s FTC carry-forwards and its U.S. 
residual DTAs related to its non-U.S. branches and (iii) a 
$2.3 billion reduction in Citi’s FTC carry-forwards related to 
the deemed repatriation of undistributed earnings of non-
U.S. subsidiaries. Of this one-time charge, $16.4 billion was 

Provisional Impact of Tax Reform

In billions of dollars

Quasi-territorial tax system

Valuation allowance

Deemed repatriation

Total of provisional items

considered provisional pursuant to Staff Accounting Bulletin 
(SAB) 118.

Citi completed its accounting for Tax Reform under 

SAB 118 during the fourth quarter of 2018 and recorded a 
one-time, non-cash tax benefit of $94 million in Corporate/
Other, related to amounts that were considered provisional 
pursuant to SAB 118. 

The table below details the fourth quarter of 2018 
changes to Citi’s provisional impact from Tax Reform:

Provisional amounts 
included in the 
2017 Form 10-K

SAB 118 impact to fourth 
quarter of 2018 
tax provision

$

$

6.2 $

7.9

2.3

16.4 $

0.2

(1.2)

0.9

(0.1)

2017 Impact of Tax Reform
The table below discloses the as-reported GAAP results for 2018 and 2017, as well as the 2017 adjusted results excluding the one-
time 2017 impact of Tax Reform. The table below does not reflect any adjustment to 2018 results.

In millions of dollars, except per share amounts and
as otherwise noted
Net income (loss)
Diluted earnings per share:
  Income (loss) from continuing operations
  Net income (loss)

2018
as 
reported(1)
18,045
$

2017
as 
reported
$ (6,798)

2017 one-time 
impact of 
Tax Reform

$

(22,594)

$

2017 
adjusted 
results(2)
15,796

2018 increase (decrease) 
vs. 2017 ex-Tax Reform

$ Change

% Change

$

2,249

14%

6.69
6.68

(2.94)
(2.98)

(8.31)
(8.31)

5.37
5.33

1.32
1.35

25
25

  Effective tax rate

22.8% 129.1 %

(9,930) bps

29.8%

(700) bps

Performance and other metrics:
  Return on average assets
  Return on average common stockholders’ 
  equity 
  Return on average total stockholders’ equity
  Return on average tangible common equity
  Dividend payout ratio
  Total payout ratio

0.94%

(0.36)%

(120) bps

0.84%

10

bps

9.4
9.1
11.0
23.1
109.1

(3.9)
(3.0)
(4.6)
(32.2)
(213.9)

(1,090)
(1,000)
(1,270)
(5,020)
(33,140)

7.0
7.0
8.1
18.0
117.5

240
210
290
510
840

(1)  2018 includes the one-time benefit of $94 million, due to the finalization of the provisional component of the impact based on Citi’s analysis as well as 

additional guidance received from the U.S. Treasury Department related to Tax Reform, which impacted the tax line within Corporate/Other. 

(2)  2017 excludes the one-time impact of Tax Reform.

Litigation Accruals
See the discussion in Note 27 to the Consolidated Financial 
Statements for information regarding Citi’s policies on 
establishing accruals for litigation and regulatory 
contingencies.

115

DISCLOSURE CONTROLS AND 
PROCEDURES
Citi’s disclosure controls and procedures are designed to 
ensure that information required to be disclosed under the 
Securities Exchange Act of 1934, as amended, is recorded, 
processed, summarized and reported within the time periods 
specified in the SEC’s rules and forms, including without 
limitation that information required to be disclosed by Citi in 
its SEC filings is accumulated and communicated to 
management, including the Chief Executive Officer (CEO) 
and Chief Financial Officer (CFO), as appropriate, to allow for 
timely decisions regarding required disclosure.

Citi’s Disclosure Committee assists the CEO and CFO in 

their responsibilities to design, establish, maintain and 
evaluate the effectiveness of Citi’s disclosure controls and 
procedures. The Disclosure Committee is responsible for, 
among other things, the oversight, maintenance and 
implementation of the disclosure controls and procedures, 
subject to the supervision and oversight of the CEO and CFO.
Citi’s management, with the participation of its CEO and 
CFO, has evaluated the effectiveness of Citigroup’s disclosure 
controls and procedures (as defined in Rule 13a-15(e) under 
the Securities Exchange Act of 1934) as of December 31, 
2019. Based on that evaluation, the CEO and CFO have 
concluded that at that date Citigroup’s disclosure controls and 
procedures were effective.

116

MANAGEMENT’S ANNUAL REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING

Citi’s management is responsible for establishing and 
maintaining adequate internal control over financial reporting. 
Citi’s internal control over financial reporting is designed to 
provide reasonable assurance regarding the reliability of its 
financial reporting and the preparation of financial statements 
for external reporting purposes in accordance with U.S. 
generally accepted accounting principles. Citi’s internal 
control over financial reporting includes those policies and 
procedures that (i) pertain to the maintenance of records that 
in reasonable detail accurately and fairly reflect the 
transactions and dispositions of Citi’s assets, (ii) provide 
reasonable assurance that transactions are recorded as 
necessary to permit preparation of financial statements in 
accordance with generally accepted accounting principles and 
that Citi’s receipts and expenditures are made only in 
accordance with authorizations of Citi’s management and 
directors and (iii) provide reasonable assurance regarding 
prevention or timely detection of unauthorized acquisition, use 
or disposition of Citi’s assets that could have a material effect 
on its financial statements.

Because of its inherent limitations, internal control over 

financial reporting may not prevent or detect all 
misstatements. Also, projections of any evaluation of 
effectiveness to future periods are subject to the risk that 
controls may become inadequate because of changes in 
conditions or that the degree of compliance with the policies 
or procedures may deteriorate. In addition, given Citi’s large 
size, complex operations and global footprint, lapses or 
deficiencies in internal controls may occur from time to time.

Citi’s management assessed the effectiveness of 
Citigroup’s internal control over financial reporting as of 
December 31, 2019 based on the criteria set forth by the 
Committee of Sponsoring Organizations of the Treadway 
Commission (COSO) in Internal Control—Integrated 
Framework (2013). Based on this assessment, management 
believes that, as of December 31, 2019, Citi’s internal control 
over financial reporting was effective. In addition, there were 
no changes in Citi’s internal control over financial reporting 
during the fiscal quarter ended December 31, 2019 that 
materially affected, or are reasonably likely to materially 
affect, Citi’s internal control over financial reporting.

The effectiveness of Citi’s internal control over financial 

reporting as of December 31, 2019 has been audited by 
KPMG LLP, Citi’s independent registered public accounting 
firm, as stated in their report below, which expressed an 
unqualified opinion on the effectiveness of Citi’s internal 
control over financial reporting as of December 31, 2019.

117

FORWARD-LOOKING STATEMENTS 

Certain statements in this Form 10-K, including but not 
limited to statements included within the Management’s 
Discussion and Analysis of Financial Condition and Results of 
Operations, are “forward-looking statements” within the 
meaning of the rules and regulations of the SEC. In addition, 
Citigroup also may make forward-looking statements in its 
other documents filed or furnished with the SEC, and its 
management may make forward-looking statements orally to 
analysts, investors, representatives of the media and others.

Generally, forward-looking statements are not based on 

historical facts but instead represent Citigroup’s and its 
management’s beliefs regarding future events. 

Such statements may be identified by words such as 
believe, expect, anticipate, intend, estimate, may increase, may 
fluctuate, target and illustrative, and similar expressions or 
future or conditional verbs such as will, should, would and 
could. Such statements are based on management’s current 
expectations and are subject to risks, uncertainties and changes 
in circumstances. Actual results and capital and other financial 
conditions may differ materially from those included in these 
statements due to a variety of factors, including without 
limitation (i) the precautionary statements included within 
each individual business’s discussion and analysis of its results 
of operations and (ii) the factors listed and described under 
“Risk Factors” above.

Any forward-looking statements made by or on behalf of 

Citigroup speak only as to the date they are made, and Citi 
does not undertake to update forward-looking statements to 
reflect the impact of circumstances or events that arise after 
the forward-looking statements were made. 

118

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Stockholders and Board of Directors
Citigroup Inc.:

Opinions on the Consolidated Financial Statements and 
Internal Control Over Financial Reporting 
We have audited the accompanying consolidated balance sheet 
of Citigroup Inc. and subsidiaries (the Company) as of 
December 31, 2019 and 2018, the related consolidated 
statements of income, comprehensive income, changes in 
stockholders’ equity and cash flows for each of the years in the 
three-year period ended December 31, 2019, and the related 
notes (collectively, the consolidated financial statements). We 
also have audited the Company’s internal control over 
financial reporting as of December 31, 2019, based on criteria 
established in Internal Control—Integrated Framework (2013) 
issued by the Committee of Sponsoring Organizations of the 
Treadway Commission. 

In our opinion, the consolidated financial statements 

referred to above present fairly, in all material respects, the 
financial position of the Company as of December 31, 2019 
and 2018, and the results of its operations and its cash flows 
for each of the years in the three-year period ended 
December 31, 2019, in conformity with U.S. generally 
accepted accounting principles. Also in our opinion, the 
Company maintained, in all material respects, effective 
internal control over financial reporting as of December 31, 
2019 based on criteria established in Internal Control— 
Integrated Framework (2013) issued by the Committee of 
Sponsoring Organizations of the Treadway Commission.

Basis for Opinions 
The Company’s management is responsible for these 
consolidated financial statements, for maintaining effective 
internal control over financial reporting and for its assessment 
of the effectiveness of internal control over financial reporting, 
included in the accompanying management’s annual report on 
internal control over financial reporting. Our responsibility is 
to express an opinion on the Company’s consolidated financial 
statements and an opinion on the Company’s internal control 
over financial reporting based on our audits. We are a public 
accounting firm registered with the Public Company 
Accounting Oversight Board (United States) (PCAOB) and 
are required to be independent with respect to the Company in 
accordance with the U.S. federal securities laws and the 
applicable rules and regulations of the Securities and 
Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards 

of the PCAOB. Those standards require that we plan and 
perform the audits to obtain reasonable assurance about 
whether the consolidated financial statements are free of 
material misstatement, whether due to error or fraud, and 
whether effective internal control over financial reporting was 
maintained in all material respects. 

119

Our audits of the consolidated financial statements 
included performing procedures to assess the risks of material 
misstatement of the consolidated financial statements, whether 
due to error or fraud, and performing procedures that respond 
to those risks. Such procedures included examining, on a test 
basis, evidence regarding the amounts and disclosures in the 
consolidated financial statements. Our audits also included 
evaluating the accounting principles used and significant 
estimates made by management, as well as evaluating the 
overall presentation of the consolidated financial statements. 
Our audit of internal control over financial reporting included 
obtaining an understanding of internal control over financial 
reporting, assessing the risk that a material weakness exists 
and testing and evaluating the design and operating 
effectiveness of internal control based on the assessed risk. 
Our audits also included performing such other procedures as 
we considered necessary in the circumstances. We believe that 
our audits provide a reasonable basis for our opinions.

Definition and Limitations of Internal Control Over Financial 
Reporting 
A company’s internal control over financial reporting is a 
process designed to provide reasonable assurance regarding 
the reliability of financial reporting and the preparation of 
financial statements for external purposes in accordance with 
generally accepted accounting principles. A company’s 
internal control over financial reporting includes those policies 
and procedures that (1) pertain to the maintenance of records 
that, in reasonable detail, accurately and fairly reflect the 
transactions and dispositions of the assets of the company; 
(2) provide reasonable assurance that transactions are recorded 
as necessary to permit preparation of financial statements in 
accordance with generally accepted accounting principles, and 
that receipts and expenditures of the company are being made 
only in accordance with authorizations of management and 
directors of the company; and (3) provide reasonable 
assurance regarding prevention or timely detection of 
unauthorized acquisition, use or disposition of the company’s 
assets that could have a material effect on the financial 
statements.

Because of its inherent limitations, internal control over 
financial reporting may not prevent or detect misstatements. 
Also, projections of any evaluation of effectiveness to future 
periods are subject to the risk that controls may become 
inadequate because of changes in conditions, or that the 
degree of compliance with the policies or procedures may 
deteriorate.

 
Critical Audit Matters 
The critical audit matters communicated below are matters 
arising from the current period audit of the consolidated 
financial statements that were communicated or required to be 
communicated to the audit committee and that: (1) relate to 
accounts or disclosures that are material to the consolidated 
financial statements and (2) involved our especially 
challenging, subjective, or complex judgments. The 
communication of critical audit matters does not alter in any 
way our opinion on the consolidated financial statements, 
taken as a whole, and we are not, by communicating the 
critical audit matters below, providing separate opinions on the 
critical audit matters or on the accounts or disclosures to 
which they relate.

Assessment of the fair value of hard-to-price financial 
instruments
As described in Notes 1, 6, 24 and 25 to the consolidated 
financial statements, the Company’s financial assets and 
liabilities recorded at fair value on a recurring basis were 
$1,148.7 billion and $615.5 billion, respectively at 
December 31, 2019. Financial instruments which are 
measured at fair value using valuation techniques, 
inclusive of complex internal valuation models or 
alternative pricing procedures with significant 
unobservable inputs, represent all Level 3 assets and 
liabilities ($8.0 billion and $23.0 billion, respectively) and 
certain Level 2 assets and liabilities (collectively, hard-to-
price financial instruments). The Company estimated the 
fair value of hard-to-price financial instruments utilizing 
various valuation techniques including, but not limited to, 
internal valuation models, price-based or comparables 
analysis and discounted cash flows. 

We identified the assessment of the fair value for 
hard-to-price financial instruments as a critical audit 
matter, as the assessment involved complex auditor 
judgment. In particular, there was a high level of 
subjectivity in the evaluation of the key assumptions and 
estimates utilized for prices and/or inputs that are not 
readily observable in the current market and complex 
internally developed valuation techniques and/or models 
were used. This assessment encompassed the evaluation 
of the fair value estimate methodologies, including the 
Company’s key assumptions and inputs such as interest 
rate, price, yield, credit spread, volatilities, correlations 
and forward prices. This also included an evaluation of 
the underlying models for mathematical accuracy and 
assessing if the models are appropriate to value the 
financial instruments. 

The following are the primary procedures we 
performed to address this critical audit matter. We tested 
internal controls over hard-to-price financial instruments, 
including pricing methodologies and valuation 
techniques, and key inputs and assumptions to determine 
the fair value. We tested the Company’s process to 
develop the fair value estimate. This included performing 
an assessment of the key policies and methodologies used 
in the fair value determination. We involved valuation 
professionals with industry knowledge and experience 

120

who assisted in challenging the models’ significant prices, 
inputs and assumptions that are not readily observable and 
which are used in the fair value determination, by testing 
the reliability of the process used by the Company to 
determine fair value and evaluating that:

• 

• 

• 

the key assumptions and/or inputs reflected those 
which a market participant would use to 
determine an exit price in the current market 
environment; 
the valuation models used were mathematically 
accurate and appropriate to value the financial 
instruments; and 
relevant information that was reasonably 
available was considered in the fair value 
determination.

We involved valuation professionals with industry 
knowledge and experience who assisted in developing an 
independent fair value estimate for certain financial 
instruments based on independently developed valuation 
models and/or assumptions and comparing to the 
Company’s fair value measurements.

Assessment of the allowance for loan losses collectively 
evaluated for impairment
As discussed in Notes 1 and 15 to the consolidated 
financial statements, the Company’s allowance for loan 
losses related to loans collectively evaluated for 
impairment (ALL) was $11.3 billion as of December 31, 
2019. The Company estimated this ALL for consumer 
loans utilizing a migration analysis, in which historical 
delinquency and credit loss experience is applied to the 
current aging of the portfolio, together with analyses that 
reflect economic conditions. For corporate loans, the ALL 
was determined using a statistical model considering the 
portfolio’s size, remaining tenor and credit quality as 
measured by internal risk ratings assigned to individual 
credit facilities, which reflect probability of default and 
loss given default. The statistical model and migration 
analysis were each supplemented by qualitative 
assessments.

We identified the assessment of the ALL as a critical 

audit matter, as the assessment involved significant 
measurement uncertainty requiring complex auditor 
judgment, and knowledge and experience in the industry. 
This assessment encompassed the evaluation of the 
various components of the ALL methodology, including 
certain key assumptions and inputs for the Company’s 
quantitative and qualitative assessments. Key assumptions 
and inputs for consumer loans included historical credit 
losses, delinquency status and the manner in which they 
are applied within a migration analysis. For corporate 
loans, key assumptions and inputs included internal risk 
ratings, probability of default and loss given default 
considered in the statistical model. 

The following are the primary procedures we 
performed to address this critical audit matter. We tested 
certain internal controls over (1) the approval of the ALL 
methodologies and (2) the determination of the key 

assumptions and inputs used to estimate the quantitative 
and qualitative assessments. We evaluated the Company’s 
process to develop the ALL estimate by testing certain 
sources of data, factors and assumptions that the 
Company used and considered the relevance and 
reliability of such data, factors and assumptions. We 
assessed the methodologies used to develop the resulting 
qualitative assessments and the effect of those 
assessments on the ALL compared with credit trends. We 
involved credit risk professionals with industry 
knowledge and experience who assisted in: 

• 

• 

• 

reviewing the Company’s ALL methodologies 
and key assumptions for compliance with U.S. 
generally accepted accounting principles; 
testing the key assumptions and inputs in the 
consumer loans migration analysis and corporate 
loans statistical model; and 
evaluating the qualitative assessments of the 
ALL.

We tested corporate loan internal risk ratings for a 
selection of credit facilities by (1) involving credit risk 
professionals with industry knowledge and risk rating 
experience to assist in evaluating the appropriateness of 
the internal risk ratings and (2) testing the historical 
accuracy of internal risk ratings compared to prior 
periods. 

Assessment of the realizability of deferred tax assets, 
specifically as it relates to foreign tax credits
As discussed in Notes 1 and 9 to the consolidated 
financial statements, the Company’s net deferred tax 
assets (DTA) were $23.1 billion as of December 31, 2019. 
This balance is net of a valuation allowance of $6.5 
billion recorded by the Company. The estimation of the 
DTA for foreign tax credits (FTCs) and related valuation 
allowance was $10.9 billion and $4.6 billion respectively. 
The Company evaluated the realization of the DTA for 
FTCs to determine whether there was more than a 50% 
likelihood that the DTA for FTCs would be realized, 
based primarily on the Company’s expectations of future 
taxable income in each relevant jurisdiction, available tax 
planning strategies and timing of tax credit expirations. 
We identified the assessment of the realizability of 

the DTA for FTCs as a critical audit matter, as the 

assessment involved complex auditor judgment and 
knowledge of global tax regulations. This assessment 
encompassed the evaluation of the Company’s estimations 
that are complex due to its global structure and subjective, 
given the Company’s assumptions used to determine that 
sufficient taxable income will be generated or tax 
planning strategies implemented to support the realization 
of the DTA for FTCs before expiration of foreign tax 
credits. 

The following are the primary procedures we 
performed to address this critical audit matter. We tested 
certain internal controls over the Company’s analysis of 
the realizability of the DTA for FTCs, including future 
taxable income and tax planning strategies. We tested the 
Company’s process to develop the valuation allowance 
estimate. This included performing an assessment of the 
key policies and methodologies used in the valuation 
allowance determination. We involved income tax 
professionals with FTC knowledge and experience, 
including resources from our national office, who assisted 
in assessing: 

• 

• 
• 

the assumptions used to determine the 
Company’s future taxable income, including the 
interpretation of the various tax laws and 
regulations and the source and character of future 
taxable income; 
the timing of tax credit expirations; and 
the prudence and feasibility of tax planning 
strategies.

We performed sensitivity analyses over the Company’s 
expectations of future taxable income and timing of tax 
credit expirations.

/s/ KPMG LLP

We have served as the Company’s auditor since 1969.

New York, New York 
February 21, 2020

121

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122

FINANCIAL STATEMENTS AND NOTES TABLE OF CONTENTS

CONSOLIDATED FINANCIAL STATEMENTS

Consolidated Statement of Income—

For the Years Ended December 31, 2019, 2018 and 2017

124

Consolidated Statement of Comprehensive Income—

For the Years Ended December 31, 2019, 2018 and 2017

Consolidated Balance Sheet—December 31, 2019 and 2018
Consolidated Statement of Changes in Stockholders’ Equity

—For the Years Ended December 31, 2019, 2018 and 2017

125

126

128

Consolidated Statement of Cash Flows—

For the Years Ended December 31, 2019, 2018 and 2017

130

NOTES TO CONSOLIDATED FINANCIAL

STATEMENTS

Note 1—Summary of Significant Accounting Policies

Note 2—Discontinued Operations and Significant Disposals

Note 3—Business Segments

Note 4—Interest Revenue and Expense

Note 5—Commissions and Fees; Administration and Other 
                  Fiduciary Fees

Note 6—Principal Transactions

Note 7—Incentive Plans

Note 8—Retirement Benefits

Note 9—Income Taxes
Note 10—Earnings per Share

Note 11—Securities Borrowed, Loaned and
                   Subject to Repurchase Agreements

Note 12—Brokerage Receivables and Brokerage Payables
Note 13—Investments

Note 14—Loans

Note 15—Allowance for Credit Losses

132

145

146

147

148

151

152

156

168

172

173

176

177

190

201

Note 16—Goodwill and Intangible Assets

Note 17—Debt

Note 18—Regulatory Capital

Note 19—Changes in Accumulated Other Comprehensive
                   Income (Loss) (AOCI)

Note 20—Preferred Stock

Note 21—Securitizations and Variable Interest Entities

Note 22—Derivatives

Note 23—Concentrations of Credit Risk

Note 24—Fair Value Measurement

Note 25—Fair Value Elections

Note 26—Pledged Assets, Collateral, Guarantees and 
                   Commitments
Note 27—Contingencies

Note 28—Condensed Consolidating Financial Statements
Note 29—Selected Quarterly Financial Data (Unaudited)

204

206

208

209

212

214

226

242

243

264

268

276

283

292

123

 
 
CONSOLIDATED FINANCIAL STATEMENTS

CONSOLIDATED STATEMENT OF INCOME                                                                   

     Citigroup Inc. and Subsidiaries

In millions of dollars, except per share amounts

2019

2018

2017

Years ended December 31,

Revenues

Interest revenue

Interest expense

Net interest revenue

Commissions and fees

Principal transactions

Administration and other fiduciary fees

Realized gains on sales of investments, net

Net impairment losses recognized in earnings

Other revenue

Total non-interest revenues

Total revenues, net of interest expense

Provisions for credit losses and for benefits and claims

Provision for loan losses

Policyholder benefits and claims

Provision (release) for unfunded lending commitments

Total provisions for credit losses and for benefits and claims

Operating expenses

Compensation and benefits

Premises and equipment

Technology/communication

Advertising and marketing

Other operating

Total operating expenses

Income from continuing operations before income taxes

Provision for income taxes

Income (loss) from continuing operations

Discontinued operations

Loss from discontinued operations

Provision (benefit) for income taxes

Loss from discontinued operations, net of taxes
Net income (loss) before attribution of noncontrolling
interests
Noncontrolling interests

Citigroup’s net income (loss)

Basic earnings per share(1)
Income (loss) from continuing operations

Loss from discontinued operations, net of taxes

Net income (loss)

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

76,510 $

29,163

47,347 $

11,746 $

8,892

3,411

1,474

(32) $

1,448 $

26,939 $

74,286 $

8,218 $

73

92

8,383 $

70,828 $

24,266

46,562 $

11,857 $

8,905

3,580

421

(132) $

1,661 $

26,292 $

72,854 $

7,354 $

101

113

7,568 $

21,433 $

21,154 $

2,328

7,077

1,516

9,648

42,002 $

23,901 $

4,430

19,471 $

(31) $

(27)

(4) $

19,467 $

66

19,401 $

8.08 $

—

8.08 $

2,324

7,193

1,545

9,625

41,841 $

23,445 $

5,357

18,088 $

(26) $

(18)

(8) $

18,080 $

35

18,045 $

6.69 $

—

6.69 $

Weighted average common shares outstanding (in millions)

2,249.2

2,493.3

61,579

16,518

45,061

12,707

8,940

3,584

778

(63)

1,437

27,383

72,444

7,503

109

(161)

7,451

21,181

2,453

6,909

1,608

10,081

42,232

22,761

29,388

(6,627)

(104)

7

(111)

(6,738)

60

(6,798)

(2.94)

(0.04)

(2.98)

2,698.5

124

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF INCOME
(Continued)

In millions of dollars, except per share amounts
Diluted earnings per share(1)
Income (loss) from continuing operations

Income (loss) from discontinued operations, net of taxes

Net income (loss)

Adjusted weighted average common shares outstanding 
  (in millions)

Citigroup Inc. and Subsidiaries

Years ended December 31,

2019

2018

2017

$

$

8.04 $

—

8.04 $

6.69 $

—

6.68 $

(2.94)

(0.04)

(2.98)

2,265.3

2,494.8

2,698.5

(1)  Due to rounding, earnings per share on continuing operations and discontinued operations may not sum to earnings per share on net income. 

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME

Citigroup Inc. and Subsidiaries

In millions of dollars

Citigroup’s net income (loss)

Add: Citigroup’s other comprehensive income (loss)
Net change in unrealized gains and losses on debt securities, net of taxes(1)(2)
Net change in debt valuation adjustment (DVA), net of taxes(1)
Net change in cash flow hedges, net of taxes
Benefit plans liability adjustment, net of taxes(3)
Net change in foreign currency translation adjustment, net of taxes and hedges
Net change in excluded component of fair value hedges, net of taxes
Citigroup’s total other comprehensive income (loss)(4)
Citigroup’s total comprehensive income (loss)

Add: Other comprehensive income (loss) attributable to noncontrolling interests

Add: Net income attributable to noncontrolling interests

Total comprehensive income (loss)

Years ended December 31,

2019

2018

2017

19,401 $

18,045 $

(6,798)

1,985 $

(1,136)

851

(552)

(321)

25

852 $

20,253 $

— $

66

(1,089) $

1,113

(30)

(74)

(2,362)

(57)

(2,499) $

15,546 $

(43) $

35

(863)

(569)

(138)

(1,019)

(202)

—

(2,791)

(9,589)

114

60

20,319 $

15,538 $

(9,415)

$

$

$

$

$

$

(1)    See Note 1 to the Consolidated Financial Statements.
(2)  For the years ended December 31, 2019 and 2018, amounts represent the net change in unrealized gains and losses on available-for-sale (AFS) debt securities. 

Effective January 1, 2018, the AFS category was eliminated for equity securities under ASU 2016-01.

(3)    See Note 8 to the Consolidated Financial Statements.
(4) 

Includes the impact of ASU 2018-02, adopted in 2017. See Note 1 to the Consolidated Financial Statements.

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

125

 
 
 
Citigroup Inc. and Subsidiaries

December 31,

2019

2018

CONSOLIDATED BALANCE SHEET

In millions of dollars
Assets
Cash and due from banks (including segregated cash and other deposits)
Deposits with banks

Securities borrowed and purchased under agreements to resell (including $153,193 and $147,701 as of

December 31, 2019 and 2018, respectively, at fair value)

Brokerage receivables

Trading account assets (including $120,236 and $112,932 pledged to creditors at December 31, 2019 and

2018, respectively)

Investments:
  Available-for-sale debt securities (including $8,721 and $9,284 pledged to creditors as of December 31,

2019 and 2018, respectively)
Held-to-maturity debt securities (including $1,923 and $971 pledged to creditors as of December 31,

2019 and 2018, respectively)

Equity securities (including $1,162 and $1,109 as of December 31, 2019 and 2018, respectively, at fair

value)

Total investments
Loans:

Consumer (including $18 and $20 as of December 31, 2019 and 2018, respectively, at fair value)

Corporate (including $4,067 and $3,203 as of December 31, 2019 and 2018, respectively, at fair value)

Loans, net of unearned income

Allowance for loan losses

Total loans, net
Goodwill

Intangible assets (including MSRs of $495 and $584 as of December 31, 2019 and 2018, 
  respectively, at fair value)

Other assets (including $12,830 and $20,788 as of December 31, 2019 and 2018, respectively, 
  at fair value)

$

$

$

$

23,967 $
169,952

251,322
39,857

276,140

280,265

80,775

7,523
368,563 $

309,548

389,935

699,483 $

(12,783)
686,700 $
22,126

4,822

107,709

Total assets

$

1,951,158 $

23,645
164,460

270,684
35,450

256,117

288,038

63,357

7,212
358,607

302,360

381,836

684,196

(12,315)
671,881
22,046

5,220

109,273

1,917,383

The following table presents certain assets of consolidated variable interest entities (VIEs), which are included on the 

Consolidated Balance Sheet above. The assets in the table below include those assets that can only be used to settle obligations of 
consolidated VIEs, presented on the following page, and are in excess of those obligations. In addition, the assets in the table below 
include third-party assets of consolidated VIEs only and exclude intercompany balances that eliminate in consolidation.

In millions of dollars
Assets of consolidated VIEs to be used to settle obligations of consolidated VIEs
Cash and due from banks
Trading account assets
Investments
Loans, net of unearned income

Consumer
Corporate

Loans, net of unearned income
Allowance for loan losses

Total loans, net
Other assets
Total assets of consolidated VIEs to be used to settle obligations of consolidated VIEs

December 31,

2019

2018

$

$

$

$

108 $

6,719
1,295

46,977
16,175
63,152 $
(1,841)
61,311 $
73
69,506 $

270
917
1,796

49,403
19,259
68,662
(1,852)
66,810
151
69,944

Statement continues on the next page.

126

 
 
 
 
 
 
 
CONSOLIDATED BALANCE SHEET 
(Continued)

In millions of dollars, except shares and per share amounts
Liabilities
Non-interest-bearing deposits in U.S. offices

Interest-bearing deposits in U.S. offices (including $1,624 and $717 as of December 31, 2019 and 2018,

respectively, at fair value)

Non-interest-bearing deposits in offices outside the U.S.

Interest-bearing deposits in offices outside the U.S. (including $695 and $758 as of December 31, 2019

and 2018, respectively, at fair value)

Total deposits
Securities loaned and sold under agreements to repurchase (including $40,651 and $44,510 as of

December 31, 2019 and 2018, respectively, at fair value)

Brokerage payables
Trading account liabilities

Short-term borrowings (including $4,946 and $4,483 as of December 31, 2019 and 2018, respectively, 
  at fair value)

Long-term debt (including $55,783 and $38,229 as of December 31, 2019 and 2018, respectively, 
  at fair value)

Other liabilities (including $6,343 and $15,906 as of December 31, 2019 and 2018, respectively, 
  at fair value)
Total liabilities
Stockholders’ equity
Preferred stock ($1.00 par value; authorized shares: 30 million), issued shares: 719,200 as of December 

31, 2019 and 738,400 as of December 31, 2018, at aggregate liquidation value

Common stock ($0.01 par value; authorized shares: 6 billion), issued shares: 3,099,602,856 as of 

December 31, 2019 and 3,099,567,177 as of December 31, 2018

Additional paid-in capital
Retained earnings
Treasury stock, at cost: 985,479,501 shares as of December 31, 2019 and 731,099,833 shares as of 
    December 31, 2018
Accumulated other comprehensive income (loss) (AOCI)
Total Citigroup stockholders’ equity
Noncontrolling interest
Total equity
Total liabilities and equity

       Citigroup Inc. and Subsidiaries

December 31,

2019

2018

98,811 $

105,836

401,418
85,692

484,669
1,070,590 $

166,339
48,601
119,894

45,049

361,573
80,648

465,113
1,013,170

177,768
64,571
144,305

32,346

248,760

231,999

57,979
1,757,212 $

56,150
1,720,309

17,980 $

18,460

31
107,840
165,369

(61,660)
(36,318)
193,242 $
704
193,946 $
1,951,158 $

31
107,922
151,347

(44,370)
(37,170)
196,220
854
197,074
1,917,383

$

$

$

$

$

$
$

The following table presents certain liabilities of consolidated VIEs, which are included on the Consolidated Balance Sheet 
above. The liabilities in the table below include third-party liabilities of consolidated VIEs only and exclude intercompany balances 
that eliminate in consolidation. The liabilities also exclude amounts where creditors or beneficial interest holders have recourse to the 
general credit of Citigroup.

In millions of dollars

Liabilities of consolidated VIEs for which creditors or beneficial interest holders do not have

recourse to the general credit of Citigroup

Short-term borrowings
Long-term debt

Other liabilities

Total liabilities of consolidated VIEs for which creditors or beneficial interest holders do not have

recourse to the general credit of Citigroup

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

December 31,

2019

2018

$

$

10,031 $
25,582

917

36,530 $

13,134
28,514

697

42,345

127

 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF CHANGES IN STOCKHOLDERS’ EQUITY

Citigroup Inc. and Subsidiaries

In millions of dollars, except shares in thousands
Preferred stock at aggregate liquidation value
Balance, beginning of year
Issuance of new preferred stock
Redemption of preferred stock
Balance, end of period
Common stock and additional paid-in capital
Balance, beginning of year
Employee benefit plans
Preferred stock issuance expense
Other
Balance, end of period
Retained earnings
Balance, beginning of year
Adjustment to opening balance, net of taxes(1)
Adjusted balance, beginning of period
Citigroup’s net income (loss)
Common dividends(2)
Preferred dividends
Impact of Tax Reform related to AOCI reclassification(3)
Other(4)
Balance, end of period
Treasury stock, at cost
Balance, beginning of year
Employee benefit plans(5)
Treasury stock acquired(6)
Balance, end of period

Citigroup’s accumulated other comprehensive income (loss)

Balance, beginning of year
Adjustment to opening balance, net of taxes(1)
Adjusted balance, beginning of period
Citigroup’s total other comprehensive income (loss)(3)
Balance, end of period
Total Citigroup common stockholders’ equity
Total Citigroup stockholders’ equity

Noncontrolling interests

Balance, beginning of year

Transactions between noncontrolling-interest shareholders and

the related consolidated subsidiary

Transactions between Citigroup and the noncontrolling-interest

shareholders

Net income attributable to noncontrolling-interest shareholders
Distributions paid to noncontrolling-interest shareholders

Other comprehensive income (loss) attributable to 
   noncontrolling-interest shareholders

Other

Net change in noncontrolling interests

Balance, end of period

Total equity

Years ended December 31,

Amounts

2019

2018

2017

2019

Shares

2018

2017

$

$

18,460 $
1,500
(1,980)
17,980 $

19,253 $
—
(793)
18,460 $

19,253
—
—
19,253

738
60
(79)
719

770
—
(32)
738

770
—
—
770

$ 107,953 $ 108,039 $ 108,073
(27)
—
(7)
$ 107,871 $ 107,953 $ 108,039

(112)
(4)
34

(94)
—
8

3,099,567
36
—
—
3,099,603

3,099,523
44
—
—
3,099,567

3,099,482
41
—
—
3,099,523

151

(84)

$ 151,347 $ 138,425 $ 146,477
(660)
$ 151,498 $ 138,341 $ 145,817
(6,798)
(2,595)
(1,213)
3,304
(90)
$ 165,369 $ 151,347 $ 138,425

19,401
(4,403)
(1,109)
—
(18)

18,045
(3,865)
(1,174)
—
—

$

$

$

$

(44,370) $
585
(17,875)
(61,660) $

(30,309) $
484
(14,545)
(44,370) $

(16,302)
531
(14,538)
(30,309)

(731,100)
9,872
(264,252)
(985,480)

(529,615)
10,557
(212,042)
(731,100)

(327,090)
11,651
(214,176)
(529,615)

(37,170) $

(34,668) $

(32,381)

—

(3)

504

(37,170) $

(34,671) $

(31,877)

852

(2,499)

(2,791)

2,114,123

2,368,467

2,569,908

(37,170) $

(36,318) $

(34,668)
$
$ 175,262 $ 177,760 $ 181,487
$ 193,242 $ 196,220 $ 200,740

$

854 $

932 $

1,023

—

(169)

66
(40)

—

(7)

—

(50)

35
(38)

(43)

18

$

$

(150) $

704 $

(78) $

854 $

(28)

(121)

60
(44)

114

(72)

(91)

932

$ 193,946 $ 197,074 $ 201,672

128

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(1)  See Note 1 to the Consolidated Financial Statements for additional details.
(2)  Common dividends declared were $0.45 per share in the first and second quarters of 2019 and $0.51 per share in the third and fourth quarters of 2019; $0.32 per 
share in the first and second quarters of 2018 and $0.45 per share in the third and fourth quarters of 2018; and $0.16 in the first and second quarters of 2017 and 
$0.32 per share in the third and fourth quarters of 2017.
Includes the impact of ASU 2018-02, which transferred those amounts from AOCI to 2017 Retained earnings. See Notes 1 and 19 to the Consolidated Financial 
Statements.

(3) 

(4)  2017 includes the impact of ASU No. 2016-09, Compensation—Stock Compensation (Topic 718): Improvements to Employee Share-Based Payment Accounting. 

(5) 

See Note 1 to the Consolidated Financial Statements.
Includes treasury stock related to (i) certain activity on employee stock option program exercises where the employee delivers existing shares to cover the option 
exercise, or (ii) under Citi’s employee restricted or deferred stock programs where shares are withheld to satisfy tax requirements.

(6)  Primarily consists of open market purchases under Citi’s Board of Directors-approved common stock repurchase program.

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

129

CONSOLIDATED STATEMENT OF CASH FLOWS

Citigroup Inc. and Subsidiaries

In millions of dollars

Cash flows from operating activities of continuing operations

Net income before attribution of noncontrolling interests

Net income attributable to noncontrolling interests

Citigroup’s net income

Loss from discontinued operations, net of taxes

Income (loss) from continuing operations—excluding noncontrolling interests

Adjustments to reconcile net income to net cash provided by (used in) operating activities

of continuing operations
Net gains on significant disposals(1)
Depreciation and amortization
Deferred income taxes(2)
Provision for loan losses

Realized gains from sales of investments

Net impairment losses on investments

Change in trading account assets

Change in trading account liabilities

Change in brokerage receivables net of brokerage payables

Change in loans HFS

Change in other assets

Change in other liabilities

Other, net

Total adjustments

Net cash provided by (used in) operating activities of continuing operations

Cash flows from investing activities of continuing operations

   Change in securities borrowed and purchased under agreements to resell

   Change in loans

   Proceeds from sales and securitizations of loans

   Purchases of investments

   Proceeds from sales of investments

   Proceeds from maturities of investments
   Proceeds from significant disposals(1)
   Capital expenditures on premises and equipment and capitalized software
   Proceeds from sales of premises and equipment, subsidiaries and affiliates 
      and repossessed assets

   Other, net

Net cash used in investing activities of continuing operations

Cash flows from financing activities of continuing operations

   Dividends paid

   Issuance of preferred stock

   Redemption of preferred stock

   Treasury stock acquired

   Stock tendered for payment of withholding taxes

   Change in securities loaned and sold under agreements to repurchase

   Issuance of long-term debt

   Payments and redemptions of long-term debt

   Change in deposits

   Change in short-term borrowings

130

$

$

$

$

$

$

$

$

Years ended December 31,

2019

2018

2017

19,467 $

18,080 $

(6,738)

66

35

19,401 $

18,045 $

(4)

(8)

19,405 $

18,053 $

—

3,905

(610)

8,218

(1,474)

32

(20,124)

(24,411)

(20,377)

(909)

4,724

1,829

16,955

(32,242) $

(12,837) $

(247)

3,754

(51)

7,354

(421)

132

(3,469)

19,135

6,163

770

(5,791)

(871)

(7,559)

18,899 $

36,952 $

60

(6,798)

(111)

(6,687)

(602)

3,659

24,877

7,503

(778)

91

(7,038)

(15,375)

(5,307)

247

(3,364)

(3,044)

(2,956)

(2,087)

(8,774)

19,362 $

(38,206) $

4,335

(22,466)

(29,002)

(58,062)

2,878

4,549

8,365

(274,491)

(152,487)

(185,740)

137,173

119,051

—

(5,336)

259

196

61,491

83,604

314

(3,774)

212

181

107,368

84,369

3,411

(3,361)

377

187

(23,374) $

(73,118) $

(38,751)

(5,447) $

(5,020) $

(3,797)

1,496

(1,980)

—

(793)

—

—

(17,571)

(14,433)

(14,541)

(364)

(11,429)

59,134

(51,029)

57,420

12,703

(482)

21,491

60,655

(58,132)

53,348

(12,106)

(405)

14,456

67,960

(40,986)

30,416

13,751

 
 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF CASH FLOWS 
(Continued)

In millions of dollars

Net cash provided by financing activities of continuing operations

Effect of exchange rate changes on cash and cash equivalents

Change in cash, due from banks and deposits with banks
Cash, due from banks and deposits with banks at beginning of period(3)
Cash, due from banks and deposits with banks at end of period(3)
Cash and due from banks

Deposits with banks

Cash, due from banks and deposits with banks at end of period

Supplemental disclosure of cash flow information for continuing operations

Cash paid during the year for income taxes

Cash paid during the year for interest
Non-cash investing activities(4)
Transfers to loans HFS (Other assets) from loans

Citigroup Inc. and Subsidiaries

Years ended December 31,

2019

2018

2017

42,933 $

44,528 $

66,854

(908) $

5,814 $

(773) $

7,589 $

188,105

180,516

193,919 $

188,105 $

23,967 $

23,645 $

169,952

164,460

193,919 $

188,105 $

693

20,022

160,494

180,516

23,775

156,741

180,516

4,888 $

4,313 $

28,682

22,963

2,083

15,675

5,500 $

4,200 $

5,900

$

$

$

$

$

$

$

$

(1)  See Note 2 to the Consolidated Financial Statements for further information on significant disposals.
(2) 

Includes the full impact of the $22.6 billion non-cash charge related to the Tax Cuts and Jobs Act (Tax Reform) in 2017. See Notes 1 and 9 to the 
Consolidated Financial Statements for further information. 
Includes the impact of ASU 2016-18, Restricted Cash. See Notes 1 and 26 to the Consolidated Financial Statements.

(3) 
(4)  Operating and finance lease right-of-use assets and lease liabilities represent non-cash investing and financing activities, respectively, and are not included in 
the non-cash investing activities presented here. See Note 26 to the Consolidated Financial Statements for more information and balances as of December 31, 
2019.

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

131

 
 
 
 
 
 
 
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

1. SUMMARY OF SIGNIFICANT ACCOUNTING 
POLICIES 

Throughout these Notes, “Citigroup,” “Citi” and the 
“Company” refer to Citigroup Inc. and its consolidated 
subsidiaries.

Certain reclassifications have been made to the prior 
periods’ financial statements and Notes to conform to the 
current period’s presentation.

Principles of Consolidation
The Consolidated Financial Statements include the accounts 
of Citigroup and its subsidiaries prepared in accordance with 
U.S. generally accepted accounting principles (GAAP). The 
Company consolidates subsidiaries in which it holds, 
directly or indirectly, more than 50% of the voting rights or 
where it exercises control. Entities where the Company 
holds 20% to 50% of the voting rights and/or has the ability 
to exercise significant influence, other than investments of 
designated venture capital subsidiaries or investments 
accounted for at fair value under the fair value option, are 
accounted for under the equity method, and the pro rata 
share of their income (loss) is included in Other revenue. 
Income from investments in less-than-20%-owned 
companies is recognized when dividends are received. As 
discussed in more detail in Note 21 to the Consolidated 
Financial Statements, Citigroup also consolidates entities 
deemed to be variable interest entities when Citigroup is 
determined to be the primary beneficiary. Gains and losses 
on the disposition of branches, subsidiaries, affiliates, 
buildings and other investments are included in Other 
revenue.

Citibank
Citibank, N.A. (Citibank) is a commercial bank and wholly 
owned subsidiary of Citigroup. Citibank’s principal offerings 
include consumer finance, mortgage lending and retail 
banking (including commercial banking) products and 
services; investment banking, cash management and trade 
finance; and private banking products and services.

Variable Interest Entities (VIEs)
An entity is a variable interest entity (VIE) if it meets either 
of the criteria outlined in Accounting Standards Codification 
(ASC) Topic 810, Consolidation, which are (i) the entity has 
equity that is insufficient to permit the entity to finance its 
activities without additional subordinated financial support 
from other parties, or (ii) the entity has equity investors that 
cannot make significant decisions about the entity’s 
operations or that do not absorb their proportionate share of 
the entity’s expected losses or expected returns.

The Company consolidates a VIE when it has both the 
power to direct the activities that most significantly impact 
the VIE’s economic performance and a right to receive 
benefits or the obligation to absorb losses of the entity that 
could be potentially significant to the VIE (that is, Citi is the 
primary beneficiary). In addition to variable interests held in 

consolidated VIEs, the Company has variable interests in 
other VIEs that are not consolidated because the Company is 
not the primary beneficiary.

All unconsolidated VIEs are monitored by the Company 

to assess whether any events have occurred to cause its 
primary beneficiary status to change. 

All entities not deemed to be VIEs with which the 
Company has involvement are evaluated for consolidation 
under other subtopics of ASC 810. See Note 21 to the 
Consolidated Financial Statements for more detailed 
information.

Foreign Currency Translation
Assets and liabilities of Citi’s foreign operations are 
translated from their respective functional currencies into 
U.S. dollars using period-end spot foreign exchange rates. 
The effects of those translation adjustments are reported in 
Accumulated other comprehensive income (loss), a 
component of stockholders’ equity, net of any related hedge 
and tax effects, until realized upon sale or substantial 
liquidation of the foreign operation, at which point such 
amounts related to the foreign entity are reclassified into 
earnings. Revenues and expenses of Citi’s foreign operations 
are translated monthly from their respective functional 
currencies into U.S. dollars at amounts that approximate 
weighted average exchange rates.

For transactions that are denominated in a currency 
other than the functional currency, including transactions 
denominated in the local currencies of foreign operations 
that use the U.S. dollar as their functional currency, the 
effects of changes in exchange rates are primarily included 
in Principal transactions, along with the related effects of 
any economic hedges. Instruments used to hedge foreign 
currency exposures include foreign currency forward, option 
and swap contracts and, in certain instances, designated 
issues of non-U.S. dollar debt. Foreign operations in 
countries with highly inflationary economies designate the 
U.S. dollar as their functional currency, with the effects of 
changes in exchange rates primarily included in Other 
revenue.

Investment Securities
Investments include debt and equity securities. Debt 
securities include bonds, notes and redeemable preferred 
stocks, as well as certain loan-backed and structured 
securities that are subject to prepayment risk. Equity 
securities include common and nonredeemable preferred 
stock.

Debt Securities

•  Debt securities classified as “held-to-maturity” are 

securities that the Company has both the ability and the 
intent to hold until maturity and are carried at amortized 
cost. Interest income on such securities is included in 
Interest revenue.

•  Debt securities classified as “available-for-sale” are 

carried at fair value with changes in fair value reported 

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in Accumulated other comprehensive income (loss), a 
component of stockholders’ equity, net of applicable 
income taxes and hedges. Interest income on such 
securities is included in Interest revenue.

Equity Securities

•  Marketable equity securities are measured at fair value 
with changes in fair value recognized in earnings. 
•  Non-marketable equity securities are measured at fair 

value with changes in fair value recognized in earnings 
unless (i) the measurement alternative is elected or (ii) 
the investment represents Federal Reserve Bank and 
Federal Home Loan Bank stock or certain exchange 
seats that continue to be carried at cost. Non-marketable 
equity securities under the measurement alternative are 
carried at cost plus or minus changes resulting from 
observed prices for orderly transactions for the identical 
or a similar investment of the same issuer.

•  Certain investments that would otherwise have been 

accounted for using the equity method are carried at fair 
value with changes in fair value recognized in earnings, 
since the Company elected to apply fair value 
accounting.

For investments in debt securities classified as HTM or 

AFS, the accrual of interest income is suspended for 
investments that are in default or for which it is likely that 
future interest payments will not be made as scheduled. 
Debt securities not measured at fair value through 
earnings, such as securities held in HTM or AFS, and equity 
securities under the measurement alternative, are subject to 
evaluation for impairment as described in Note 13 to the 
Consolidated Financial Statements. Realized gains and 
losses on sales of investments are included in earnings, 
primarily on a specific identification basis.

The Company uses a number of valuation techniques for 

investments carried at fair value, which are described in 
Note 24 to the Consolidated Financial Statements. 

Trading Account Assets and Liabilities
Trading account assets include debt and marketable equity 
securities, derivatives in a receivable position, residual 
interests in securitizations and physical commodities 
inventory. In addition, as described in Note 25 to the 
Consolidated Financial Statements, certain assets that 
Citigroup has elected to carry at fair value under the fair 
value option, such as loans and purchased guarantees, are 
also included in Trading account assets.

Trading account liabilities include securities sold, not 

yet purchased (short positions) and derivatives in a net 
payable position, as well as certain liabilities that Citigroup 
has elected to carry at fair value (as described in Note 25 to 
the Consolidated Financial Statements).

Other than physical commodities inventory, all trading 

account assets and liabilities are carried at fair value. 
Revenues generated from trading assets and trading 
liabilities are generally reported in Principal transactions 
and include realized gains and losses as well as unrealized 

gains and losses resulting from changes in the fair value of 
such instruments. Interest income on trading assets is 
recorded in Interest revenue reduced by interest expense on 
trading liabilities.

Physical commodities inventory is carried at the lower 

of cost or market with related losses reported in Principal 
transactions. Realized gains and losses on sales of 
commodities inventory are included in Principal 
transactions. Investments in unallocated precious metals 
accounts (gold, silver, platinum and palladium) are 
accounted for as hybrid instruments containing a debt host 
contract and an embedded non-financial derivative 
instrument indexed to the price of the relevant precious 
metal. The embedded derivative instrument is separated 
from the debt host contract and accounted for at fair value. 
The debt host contract is carried at fair value under the fair 
value option, as described in Note 25 to the Consolidated 
Financial Statements.

Derivatives used for trading purposes include interest 

rate, currency, equity, credit and commodity swap 
agreements, options, caps and floors, warrants, and financial 
and commodity futures and forward contracts. Derivative 
asset and liability positions are presented net by counterparty 
on the Consolidated Balance Sheet when a valid master 
netting agreement exists and the other conditions set out in 
ASC Topic 210-20, Balance Sheet—Offsetting, are met. See 
Note 22 to the Consolidated Financial Statements.

The Company uses a number of techniques to determine 

the fair value of trading assets and liabilities, which are 
described in Note 24 to the Consolidated Financial 
Statements.

Securities Borrowed and Securities Loaned
Securities borrowing and lending transactions do not 
constitute a sale of the underlying securities for accounting 
purposes and are treated as collateralized financing 
transactions. Such transactions are recorded at the amount of 
proceeds advanced or received plus accrued interest. As 
described in Note 25 to the Consolidated Financial 
Statements, the Company has elected to apply fair value 
accounting to a number of securities borrowing and lending 
transactions. Fees paid or received for all securities lending 
and borrowing transactions are recorded in Interest expense 
or Interest revenue at the contractually specified rate.

The Company monitors the fair value of securities 

borrowed or loaned on a daily basis and obtains or posts 
additional collateral in order to maintain contractual margin 
protection.

As described in Note 24 to the Consolidated Financial 

Statements, the Company uses a discounted cash flow 
technique to determine the fair value of securities lending 
and borrowing transactions.

Repurchase and Resale Agreements
Securities sold under agreements to repurchase (repos) and 
securities purchased under agreements to resell (reverse 
repos) do not constitute a sale (or purchase) of the 
underlying securities for accounting purposes and are treated 
as collateralized financing transactions. As described in Note 

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25 to the Consolidated Financial Statements, the Company 
has elected to apply fair value accounting to certain of such 
transactions, with changes in fair value reported in earnings. 
Any transactions for which fair value accounting has not 
been elected are recorded at the amount of cash advanced or 
received plus accrued interest. Irrespective of whether the 
Company has elected fair value accounting, interest paid or 
received on all repo and reverse repo transactions is recorded 
in Interest expense or Interest revenue at the contractually 
specified rate.

are 90 days contractually past due. For credit cards and other 
unsecured revolving loans, however, Citi generally accrues 
interest until payments are 180 days past due. As a result of 
OCC guidance, home equity loans in regulated bank entities 
are classified as non-accrual if the related residential first 
mortgage is 90 days or more past due. Also as a result of 
OCC guidance, mortgage loans in regulated bank entities are 
classified as non-accrual within 60 days of notification that 
the borrower has filed for bankruptcy, other than Federal 
Housing Administration (FHA)-insured loans. 

Where the conditions of ASC 210-20-45-11, Balance 

Loans that have been modified to grant a concession to 

Sheet—Offsetting: Repurchase and Reverse Repurchase 
Agreements, are met, repos and reverse repos are presented 
net on the Consolidated Balance Sheet.

The Company’s policy is to take possession of securities 

purchased under reverse repurchase agreements. The 
Company monitors the fair value of securities subject to 
repurchase or resale on a daily basis and obtains or posts 
additional collateral in order to maintain contractual margin 
protection.

As described in Note 24 to the Consolidated Financial 

Statements, the Company uses a discounted cash flow 
technique to determine the fair value of repo and reverse 
repo transactions.

Loans
Loans are reported at their outstanding principal balances net 
of any unearned income and unamortized deferred fees and 
costs, except for credit card receivable balances, which 
include accrued interest and fees. Loan origination fees and 
certain direct origination costs are generally deferred and 
recognized as adjustments to income over the lives of the 
related loans.

As described in Note 25 to the Consolidated Financial 

Statements, Citi has elected fair value accounting for certain 
loans. Such loans are carried at fair value with changes in 
fair value reported in earnings. Interest income on such loans 
is recorded in Interest revenue at the contractually specified 
rate.

Loans that are held-for-investment are classified as 
Loans, net of unearned income on the Consolidated Balance 
Sheet, and the related cash flows are included within the 
cash flows from investing activities category in the 
Consolidated Statement of Cash Flows on the line Change in 
loans. However, when the initial intent for holding a loan 
has changed from held-for-investment to held-for-sale 
(HFS), the loan is reclassified to HFS, but the related cash 
flows continue to be reported in cash flows from investing 
activities in the Consolidated Statement of Cash Flows on 
the line Proceeds from sales and securitizations of loans.

Consumer Loans
Consumer loans represent loans and leases managed 
primarily by the Global Consumer Banking (GCB) 
businesses and Corporate/Other.

Consumer Non-accrual and Re-aging Policies
As a general rule, interest accrual ceases for installment and 
real estate (both open- and closed-end) loans when payments 

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a borrower in financial difficulty may not be accruing 
interest at the time of the modification. The policy for 
returning such modified loans to accrual status varies by 
product and/or region. In most cases, a minimum number of 
payments (ranging from one to six) is required, while in 
other cases the loan is never returned to accrual status. For 
regulated bank entities, such modified loans are returned to 
accrual status if a credit evaluation at the time of, or 
subsequent to, the modification indicates the borrower is 
able to meet the restructured terms, and the borrower is 
current and has demonstrated a reasonable period of 
sustained payment performance (minimum six months of 
consecutive payments).

For U.S. consumer loans, generally one of the 
conditions to qualify for modification is that a minimum 
number of payments (typically ranging from one to three) 
must be made. Upon modification, the loan is re-aged to 
current status. However, re-aging practices for certain open-
ended consumer loans, such as credit cards, are governed by 
Federal Financial Institutions Examination Council (FFIEC) 
guidelines. For open-ended consumer loans subject to FFIEC 
guidelines, one of the conditions for the loan to be re-aged to 
current status is that at least three consecutive minimum 
monthly payments, or the equivalent amount, must be 
received. In addition, under FFIEC guidelines, the number of 
times that such a loan can be re-aged is subject to limitations 
(generally once in 12 months and twice in five years). 
Furthermore, FHA and Department of Veterans Affairs (VA) 
loans may only be modified under those respective agencies’ 
guidelines, and payments are not always required in order to 
re-age a modified loan to current.

Consumer Charge-Off Policies
Citi’s charge-off policies follow the general guidelines 
below:

•  Unsecured installment loans are charged off at 120 days 

contractually past due.

•  Unsecured revolving loans and credit card loans are 
charged off at 180 days contractually past due.

•  Loans secured with non-real estate collateral are written 
down to the estimated value of the collateral, less costs 
to sell, at 120 days contractually past due.

•  Real estate-secured loans are written down to the 

estimated value of the property, less costs to sell, at 180 
days contractually past due.

•  Real estate-secured loans are charged off no later than 
180 days contractually past due if a decision has been 
made not to foreclose on the loans.

•  Unsecured loans in bankruptcy are charged off within 

60 days of notification of filing by the bankruptcy court 
or in accordance with Citi’s charge-off policy, 
whichever occurs earlier.

•  Real estate-secured loans in bankruptcy, other than 

FHA-insured loans, are written down to the estimated 
value of the property, less costs to sell, within 60 days of 
notification that the borrower has filed for bankruptcy or 
in accordance with Citi’s charge-off policy, whichever is 
earlier.

•  Commercial banking loans are written down to the 

extent that principal is judged to be uncollectable.

Corporate Loans
Corporate loans represent loans and leases managed by 
Institutional Clients Group (ICG). Corporate loans are 
identified as impaired and placed on a cash (non-accrual) 
basis when it is determined, based on actual experience and 
a forward-looking assessment of the collectability of the loan 
in full, that the payment of interest or principal is doubtful or 
when interest or principal is 90 days past due, except when 
the loan is well collateralized and in the process of 
collection. Any interest accrued on impaired corporate loans 
and leases is reversed at 90 days past due and charged 
against current earnings, and interest is thereafter included in 
earnings only to the extent actually received in cash. When 
there is doubt regarding the ultimate collectability of 
principal, all cash receipts are thereafter applied to reduce 
the recorded investment in the loan.

Impaired corporate loans and leases are written down to 

the extent that principal is deemed to be uncollectable. 
Impaired collateral-dependent loans and leases, where 
repayment is expected to be provided solely by the sale of 
the underlying collateral and there are no other available and 
reliable sources of repayment, are written down to the lower 
of carrying value or collateral value. Cash-basis loans are 
returned to accrual status when all contractual principal and 
interest amounts are reasonably assured of repayment and 
there is a sustained period of repayment performance in 
accordance with the contractual terms.

Loans Held-for-Sale
Corporate and consumer loans that have been identified for 
sale are classified as loans HFS and included in Other assets. 
The practice of Citi’s U.S. prime mortgage business has been 
to sell substantially all of its conforming loans. As such, U.S. 
prime mortgage conforming loans are classified as HFS and 
the fair value option is elected at origination, with changes in 
fair value recorded in Other revenue. With the exception of 
those loans for which the fair value option has been elected, 
HFS loans are accounted for at the lower of cost or market 
value, with any write-downs or subsequent recoveries 
charged to Other revenue. The related cash flows are 
classified in the Consolidated Statement of Cash Flows in 
the cash flows from operating activities category on the line 
Change in loans held-for-sale.

Allowance for Loan Losses
Allowance for loan losses represents management’s best 
estimate of probable losses inherent in the portfolio, 
including probable losses related to large individually 
evaluated impaired loans and troubled debt restructurings. 
Attribution of the allowance is made for analytical purposes 
only, and the entire allowance is available to absorb probable 
loan losses inherent in the overall portfolio. Additions to the 
allowance are made through the Provision for loan losses. 
Loan losses are deducted from the allowance and subsequent 
recoveries are added. Assets received in exchange for loan 
claims in a restructuring are initially recorded at fair value, 
with any gain or loss reflected as a recovery or charge-off in 
the provision.

Consumer Loans
For consumer loans, each portfolio of non-modified smaller-
balance homogeneous loans is independently evaluated for 
impairment by product type (e.g., residential mortgage, 
credit card, etc.) in accordance with ASC 450, 
Contingencies. The allowance for loan losses attributed to 
these loans is established via a process that estimates the 
probable losses inherent in the specific portfolio. This 
process includes migration analysis, in which historical 
delinquency and credit loss experience is applied to the 
current aging of the portfolio, together with analyses that 
reflect current and anticipated economic conditions, 
including changes in housing prices and unemployment 
trends. Citi’s allowance for loan losses under ASC 450 only 
considers contractual principal amounts due, except for 
credit card loans, where estimated loss amounts related to 
accrued interest receivable are also included.

Management also considers overall portfolio indicators, 
including historical credit losses; delinquent, non-performing 
and classified loans; trends in volumes and terms of loans; 
an evaluation of overall credit quality; the credit process, 
including lending policies and procedures; and economic, 
geographical, product and other environmental factors.
Separate valuation allowances are determined for 
impaired smaller-balance homogeneous loans whose terms 
have been modified in a troubled debt restructuring (TDR). 
Long-term modification programs, and short-term (less than 
12 months) modifications that provide concessions (such as 
interest rate reductions) to borrowers in financial difficulty, 
are reported as TDRs. In addition, loan modifications that 
involve a trial period are reported as TDRs at the start of the 
trial period. The allowance for loan losses for TDRs is 
determined in accordance with ASC 310-10-35, Receivables
—Subsequent Measurement, considering all available 
evidence, including, as appropriate, the present value of the 
expected future cash flows discounted at the loan’s original 
contractual effective rate, the secondary market value of the 
loan and the fair value of collateral less disposal costs. These 
expected cash flows incorporate modification program 
default rate assumptions. The original contractual effective 
rate for credit card loans is the pre-modification rate, which 
may include interest rate increases under the original 
contractual agreement with the borrower.

135

Corporate Loans
In the corporate portfolios, the Allowance for loan losses 
includes an asset-specific component and a statistically 
based component. The asset-specific component is 
calculated under ASC 310-10-35 for larger-balance, non-
homogeneous loans that are considered impaired. An asset-
specific allowance is established when the discounted cash 
flows, collateral value (less disposal costs) or observable 
market price of the impaired loan are lower than its carrying 
value. This allowance considers the borrower’s overall 
financial condition, resources and payment record, the 
prospects for support from any financially responsible 
guarantors (discussed further below) and, if appropriate, the 
realizable value of any collateral. The asset-specific 
component of the allowance for smaller-balance impaired 
loans is calculated on a pool basis considering historical loss 
experience.

The allowance for the remainder of the loan portfolio is 
determined under ASC 450 using a statistical methodology, 
supplemented by management judgment. The statistical 
analysis considers the portfolio’s size, remaining tenor and 
credit quality as measured by internal risk ratings assigned to 
individual credit facilities, which reflect probability of 
default and loss given default. The statistical analysis 
considers historical default rates and historical loss severity 
in the event of default, including historical average levels 
and historical variability. The result is an estimated range for 
inherent losses. The best estimate within the range is then 
determined by management’s quantitative and qualitative 
assessment of current conditions, including general 
economic conditions, specific industry and geographic 
trends and internal factors including portfolio 
concentrations, trends in internal credit quality indicators 
and current and past underwriting standards.

For both the asset-specific and the statistically based 

components of the Allowance for loan losses, management 
may incorporate guarantor support. The financial 
wherewithal of the guarantor is evaluated, as applicable, 
based on net worth, cash flow statements and personal or 
company financial statements, which are updated and 
reviewed at least annually. Citi seeks performance on 
guarantee arrangements in the normal course of business. 
Seeking performance entails obtaining satisfactory 
cooperation from the guarantor or borrower in the specific 
situation. This regular cooperation is indicative of pursuit 
and successful enforcement of the guarantee; the exposure is 
reduced without the expense and burden of pursuing a legal 
remedy. A guarantor’s reputation and willingness to work 
with Citigroup are evaluated based on the historical 
experience with the guarantor and knowledge of the 
marketplace. In the rare event that the guarantor is unwilling 
or unable to perform or facilitate borrower cooperation, Citi 
pursues a legal remedy; however, enforcing a guarantee via 
legal action against the guarantor is not the primary means of 
resolving a troubled loan situation and rarely occurs. If Citi 
does not pursue a legal remedy, it is because Citi does not 
believe that the guarantor has the financial wherewithal to 
perform regardless of legal action or because there are legal 
limitations on simultaneously pursuing guarantors and 

foreclosure. A guarantor’s reputation does not impact Citi’s 
decision or ability to seek performance under the guarantee.
In cases where a guarantee is a factor in the assessment 

of loan losses, it is included via adjustment to the loan’s 
internal risk rating, which in turn is the basis for the 
adjustment to the statistically based component of the 
Allowance for loan losses. To date, it is only in rare 
circumstances that an impaired commercial loan or 
commercial real estate loan is carried at a value in excess of 
the appraised value due to a guarantee.

When Citi’s monitoring of the loan indicates that the 

guarantor’s wherewithal to pay is uncertain or has 
deteriorated, there is either no change in the risk rating, 
because the guarantor’s credit support was never initially 
factored in, or the risk rating is adjusted to reflect that 
uncertainty or deterioration. Accordingly, a guarantor’s 
ultimate failure to perform or a lack of legal enforcement of 
the guarantee does not materially impact the allowance for 
loan losses, as there is typically no further significant 
adjustment of the loan’s risk rating at that time. Where Citi is 
not seeking performance under the guarantee contract, it 
provides for loan losses as if the loans were non-performing 
and not guaranteed.

Reserve Estimates and Policies
Management provides reserves for an estimate of probable 
losses inherent in the funded loan portfolio on the 
Consolidated Balance Sheet in the form of an allowance for 
loan losses. These reserves are established in accordance 
with Citigroup’s credit reserve policies, as approved by the 
Audit Committee of the Citigroup Board of Directors. Citi’s 
Chief Risk Officer and Chief Financial Officer review the 
adequacy of the credit loss reserves each quarter with 
representatives from the risk management and finance staffs 
for each applicable business area. Applicable business areas 
include those having classifiably managed portfolios, where 
internal credit-risk ratings are assigned (primarily ICG and 
GCB) or modified consumer loans, where concessions were 
granted due to the borrowers’ financial difficulties.

The aforementioned representatives for these business 
areas present recommended reserve balances for their funded 
and unfunded lending portfolios along with supporting 
quantitative and qualitative data discussed below:

Estimated probable losses for non-performing, non-
homogeneous exposures within a business line’s classifiably 
managed portfolio and impaired smaller-balance 
homogeneous loans whose terms have been modified due to 
the borrowers’ financial difficulties, where it was determined 
that a concession was granted to the borrower. 
Consideration may be given to the following, as appropriate, 
when determining this estimate: (i) the present value of 
expected future cash flows discounted at the loan’s original 
effective rate, (ii) the borrower’s overall financial condition, 
resources and payment record and (iii) the prospects for 
support from financially responsible guarantors or the 
realizable value of any collateral. In the determination of the 
allowance for loan losses for TDRs, management considers a 
combination of historical re-default rates, the current 

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economic environment and the nature of the modification 
program when forecasting expected cash flows. When 
impairment is measured based on the present value of 
expected future cash flows, the entire change in present 
value is recorded in Provision for loan losses.

Statistically calculated losses inherent in the classifiably 
managed portfolio for performing and de minimis non-
performing exposures. The calculation is based on (i) Citi’s 
internal system of credit-risk ratings, which are analogous to 
the risk ratings of the major rating agencies, and (ii) 
historical default and loss data, including rating agency 
information regarding default rates from 1983 to 2017 and 
internal data dating to the early 1970s on severity of losses 
in the event of default. Adjustments may be made to this 
data. Such adjustments include (i) statistically calculated 
estimates to cover the historical fluctuation of the default 
rates over the credit cycle, the historical variability of loss 
severity among defaulted loans and the degree to which 
there are large obligor concentrations in the global portfolio 
and (ii) adjustments made for specific known items, such as 
current environmental factors and credit trends.

In addition, representatives from each of the risk 
management and finance staffs who cover business areas 
with delinquency-managed portfolios containing smaller-
balance homogeneous loans present their recommended 
reserve balances based on leading credit indicators, 
including loan delinquencies and changes in portfolio size as 
well as economic trends, including current and future 
housing prices, unemployment, length of time in foreclosure, 
costs to sell and GDP. This methodology is applied 
separately for each individual product within each 
geographic region in which these portfolios exist.

This evaluation process is subject to numerous estimates 

and judgments. The frequency of default, risk ratings, loss 
recovery rates, the size and diversity of individual large 
credits and the ability of borrowers with foreign currency 
obligations to obtain the foreign currency necessary for 
orderly debt servicing, among other things, are all taken into 
account during this review. Changes in these estimates could 
have a direct impact on the credit costs in any period and 
could result in a change in the allowance.

Allowance for Unfunded Lending Commitments
A similar approach to the allowance for loan losses is used 
for calculating a reserve for the expected losses related to 
unfunded lending commitments and standby letters of credit. 
This reserve is classified on the Consolidated Balance Sheet 
in Other liabilities. Changes to the allowance for unfunded 
lending commitments are recorded in Provision for unfunded 
lending commitments.

Mortgage Servicing Rights (MSRs)
Mortgage servicing rights (MSRs) are recognized as 
intangible assets when purchased or when the Company sells 
or securitizes loans acquired through purchase or origination 
and retains the right to service the loans. Mortgage servicing 
rights are accounted for at fair value, with changes in value 
recorded in Other revenue in the Company’s Consolidated 
Statement of Income.

For additional information on the Company’s MSRs, see 

Notes 16 and 21 to the Consolidated Financial Statements.

Goodwill
Goodwill represents the excess of acquisition cost over the 
fair value of net tangible and intangible assets acquired in a 
business combination. Goodwill is subject to annual 
impairment testing and interim assessments between annual 
tests if an event occurs or circumstances change that would 
more-likely-than-not reduce the fair value of a reporting unit 
below its carrying amount. 

Under ASC Topic 350, Intangibles—Goodwill and 
Other, the Company has an option to assess qualitative 
factors to determine if it is necessary to perform the goodwill 
impairment test. If, after assessing the totality of events or 
circumstances, the Company determines that it is not more-
likely-than-not that the fair value of a reporting unit is less 
than its carrying amount, no further testing is necessary. If, 
however, the Company determines that it is more-likely-
than-not that the fair value of a reporting unit is less than its 
carrying amount, then the Company must perform the first 
step of the two-step goodwill impairment test. 

The Company has an unconditional option to bypass the 
qualitative assessment for any reporting unit in any reporting 
period and proceed directly to the first step of the goodwill 
impairment test. 

The first step requires a comparison of the fair value of 
the individual reporting unit to its carrying value, including 
goodwill. If the fair value of the reporting unit is in excess of 
the carrying value, the related goodwill is considered not 
impaired and no further analysis is necessary. If the carrying 
value of the reporting unit exceeds the fair value, this is an 
indication of potential impairment and the second step of 
testing is performed to measure the amount of impairment, if 
any, for that reporting unit.

If required, the second step involves calculating the 

implied fair value of goodwill for each of the affected 
reporting units. The implied fair value of goodwill is 
determined in the same manner as the amount of goodwill 
recognized in a business combination, which is the excess of 
the fair value of the reporting unit determined in step one 
over the fair value of the net assets and identifiable 
intangibles as if the reporting unit were being acquired. If 
the amount of the goodwill allocated to the reporting unit 
exceeds the implied fair value of the goodwill in the pro 
forma purchase price allocation, an impairment charge is 
recorded for the excess. A recognized impairment charge 
cannot exceed the amount of goodwill allocated to a 
reporting unit and cannot subsequently be reversed even if 
the fair value of the reporting unit recovers.

137

 
Upon any business disposition, goodwill is allocated to, 

and derecognized with, the disposed business based on the 
ratio of the fair value of the disposed business to the fair 
value of the reporting unit.

Additional information on Citi’s goodwill impairment 

testing can be found in Note 16 to the Consolidated 
Financial Statements.

Intangible Assets
Intangible assets—including core deposit intangibles, 
present value of future profits, purchased credit card 
relationships, credit card contract related intangibles, other 
customer relationships and other intangible assets, but 
excluding MSRs—are amortized over their estimated useful 
lives. Intangible assets that are deemed to have indefinite 
useful lives, primarily trade names, are not amortized and 
are subject to annual impairment tests. An impairment exists 
if the carrying value of the indefinite-lived intangible asset 
exceeds its fair value. For other intangible assets subject to 
amortization, an impairment is recognized if the carrying 
amount is not recoverable and exceeds the fair value of the 
intangible asset.

Other Assets and Other Liabilities
Other assets include, among other items, loans HFS, 
deferred tax assets, equity method investments, interest and 
fees receivable, lease right-of-use assets, premises and 
equipment (including purchased and developed software), 
repossessed assets and other receivables. Other liabilities 
include, among other items, accrued expenses and other 
payables, lease liabilities, deferred tax liabilities and reserves 
for legal claims, taxes, unfunded lending commitments, 
repositioning reserves and other matters.

Other Real Estate Owned and Repossessed Assets
Real estate or other assets received through foreclosure or 
repossession are generally reported in Other assets, net of a 
valuation allowance for selling costs and subsequent 
declines in fair value.

Securitizations
There are two key accounting determinations that must be 
made relating to securitizations. Citi first makes a 
determination as to whether the securitization entity must be 
consolidated. Second, it determines whether the transfer of 
financial assets to the entity is considered a sale under 
GAAP. If the securitization entity is a VIE, the Company 
consolidates the VIE if it is the primary beneficiary (as 
discussed in “Variable Interest Entities” above). For all other 
securitization entities determined not to be VIEs in which 
Citigroup participates, consolidation is based on which party 
has voting control of the entity, giving consideration to 
removal and liquidation rights in certain partnership 
structures. Only securitization entities controlled by 
Citigroup are consolidated.

Interests in the securitized and sold assets may be 
retained in the form of subordinated or senior interest-only 
strips, subordinated tranches, spread accounts and servicing 
rights. In credit card securitizations, the Company retains a 

seller’s interest in the credit card receivables transferred to 
the trusts, which is not in securitized form. In the case of 
consolidated securitization entities, including the credit card 
trusts, these retained interests are not reported on Citi’s 
Consolidated Balance Sheet. The securitized loans remain on
the balance sheet. Substantially all of the consumer loans 
sold or securitized through non-consolidated trusts by 
Citigroup are U.S. prime residential mortgage loans. 
Retained interests in non-consolidated mortgage 
securitization trusts are classified as Trading account assets, 
except for MSRs, which are included in Intangible assets on 
Citigroup’s Consolidated Balance Sheet.

Debt
Short-term borrowings and Long-term debt are accounted for 
at amortized cost, except where the Company has elected to 
report the debt instruments, including certain structured 
notes at fair value, or the debt is in a fair value hedging 
relationship.

Transfers of Financial Assets
For a transfer of financial assets to be considered a sale: (i) 
the assets must be legally isolated from the Company, even 
in bankruptcy or other receivership, (ii) the purchaser must 
have the right to pledge or sell the assets transferred (or, if 
the purchaser is an entity whose sole purpose is to engage in 
securitization and asset-backed financing activities through 
the issuance of beneficial interests and that entity is 
constrained from pledging the assets it receives, each 
beneficial interest holder must have the right to sell or 
pledge their beneficial interests) and (iii) the Company may 
not have an option or obligation to reacquire the assets.
If these sale requirements are met, the assets are 
removed from the Company’s Consolidated Balance Sheet. 
If the conditions for sale are not met, the transfer is 
considered to be a secured borrowing, the assets remain on 
the Consolidated Balance Sheet and the sale proceeds are 
recognized as the Company’s liability. A legal opinion on a 
sale generally is obtained for complex transactions or where 
the Company has continuing involvement with assets 
transferred or with the securitization entity. For a transfer to 
be eligible for sale accounting, that opinion must state that 
the asset transfer would be considered a sale and that the 
assets transferred would not be consolidated with the 
Company’s other assets in the event of the Company’s 
insolvency.

For a transfer of a portion of a financial asset to be 
considered a sale, the portion transferred must meet the 
definition of a participating interest. A participating interest 
must represent a pro rata ownership in an entire financial 
asset; all cash flows must be divided proportionately, with 
the same priority of payment; no participating interest in the 
transferred asset may be subordinated to the interest of 
another participating interest holder; and no party may have 
the right to pledge or exchange the entire financial asset 
unless all participating interest holders agree. Otherwise, the 
transfer is accounted for as a secured borrowing.

See Note 21 to the Consolidated Financial Statements 

for further discussion.

138

Risk Management Activities—Derivatives Used for 
Hedging Purposes
The Company manages its exposures to market movements 
outside of its trading activities by modifying the asset and 
liability mix, either directly or through the use of derivative 
financial products, including interest rate swaps, futures, 
forwards and purchased options, as well as foreign-exchange 
contracts. These end-user derivatives are carried at fair value 
in Trading account assets and Trading account liabilities.

 See Note 22 to the Consolidated Financial Statements 

for a further discussion of the Company’s hedging and 
derivative activities.

Instrument-specific Credit Risk
Citi presents separately in AOCI the portion of the total 
change in the fair value of a liability resulting from a change 
in the instrument-specific credit risk, when the entity has 
elected to measure the liability at fair value in accordance 
with the fair value option for financial instruments. 
Accordingly, the change in fair value of liabilities for which 
the fair value option was elected, related to changes in 
Citigroup’s own credit spreads, is presented in AOCI.

Employee Benefits Expense
Employee benefits expense includes current service costs of 
pension and other postretirement benefit plans (which are 
accrued on a current basis), contributions and unrestricted 
awards under other employee plans, the amortization of 
restricted stock awards and costs of other employee benefits. 
For its most significant pension and postretirement benefit 
plans (Significant Plans), Citigroup measures and discloses 
plan obligations, plan assets and periodic plan expense 
quarterly, instead of annually. The effect of remeasuring the 
Significant Plan obligations and assets by updating plan 
actuarial assumptions on a quarterly basis is reflected in 
Accumulated other comprehensive income (loss) and 
periodic plan expense. All other plans (All Other Plans) are 
remeasured annually. See Note 8 to the Consolidated 
Financial Statements.

Stock-Based Compensation
The Company recognizes compensation expense related to 
stock and option awards over the requisite service period, 
generally based on the instruments’ grant-date fair value, 
reduced by actual forfeitures as they occur. Compensation 
cost related to awards granted to employees who meet 
certain age plus years-of-service requirements (retirement-
eligible employees) is accrued in the year prior to the grant 
date, in the same manner as the accrual for cash incentive 
compensation. Certain stock awards with performance 
conditions or certain clawback provisions are subject to 
variable accounting, pursuant to which the associated 
compensation expense fluctuates with changes in Citigroup’s 
common stock price. See Note 7 to the Consolidated 
Financial Statements.

Income Taxes
The Company is subject to the income tax laws of the U.S. 
and its states and municipalities, as well as the non-U.S. 
jurisdictions in which it operates. These tax laws are 
complex and may be subject to different interpretations by 
the taxpayer and the relevant governmental taxing 
authorities. In establishing a provision for income tax 
expense, the Company must make judgments and 
interpretations about these tax laws. The Company must also 
make estimates about when in the future certain items will 
affect taxable income in the various tax jurisdictions, both 
domestic and foreign.

Disputes over interpretations of the tax laws may be 

subject to review and adjudication by the court systems of 
the various tax jurisdictions, or may be settled with the 
taxing authority upon examination or audit. The Company 
treats interest and penalties on income taxes as a component 
of Income tax expense.

Deferred taxes are recorded for the future consequences 

of events that have been recognized in financial statements 
or tax returns, based upon enacted tax laws and rates. 
Deferred tax assets are recognized subject to management’s 
judgment about whether realization is more-likely-than-not. 
ASC 740, Income Taxes, sets out a consistent framework to 
determine the appropriate level of tax reserves to maintain 
for uncertain tax positions. This interpretation uses a two-
step approach wherein a tax benefit is recognized if a 
position is more-likely-than-not to be sustained. The amount 
of the benefit is then measured to be the highest tax benefit 
that is more than 50% likely to be realized. ASC 740 also 
sets out disclosure requirements to enhance transparency of 
an entity’s tax reserves.

See Note 9 to the Consolidated Financial Statements for 

a further description of the Company’s tax provision and 
related income tax assets and liabilities.

Commissions, Underwriting and Principal Transactions
Commissions and fees revenues are recognized in income 
when earned. Underwriting revenues are recognized in 
income typically at the closing of the transaction. Principal 
transactions revenues are recognized in income on a trade-
date basis. See Note 5 to the Consolidated Financial 
Statements for a description of the Company’s revenue 
recognition policies for Commissions and fees, and Note 6 to 
the Consolidated Financial Statements for details of 
Principal transactions revenue.

Earnings per Share
Earnings per share (EPS) is computed after deducting 
preferred stock dividends. The Company has granted 
restricted and deferred share awards with dividend rights that 
are considered to be participating securities, which are akin 
to a second class of common stock. Accordingly, a portion of 
Citigroup’s earnings is allocated to those participating 
securities in the EPS calculation.

Basic earnings per share is computed by dividing 

income available to common stockholders after the 
allocation of dividends and undistributed earnings to the 
participating securities by the weighted average number of 

139

common shares outstanding for the period. Diluted earnings 
per share reflects the potential dilution that could occur if 
securities or other contracts to issue common stock were 
exercised. It is computed after giving consideration to the 
weighted average dilutive effect of the Company’s stock 
options and warrants and convertible securities and after the 
allocation of earnings to the participating securities. Anti-
dilutive options and warrants are disregarded in the EPS 
calculations. 

Use of Estimates
Management must make estimates and assumptions that 
affect the Consolidated Financial Statements and the related 
Notes to the Consolidated Financial Statements. Such 
estimates are used in connection with certain fair value 
measurements. See Note 24 to the Consolidated Financial 
Statements for further discussions on estimates used in the 
determination of fair value. Moreover, estimates are 
significant in determining the amounts of other-than-
temporary impairments, impairments of goodwill and other 
intangible assets, provisions for probable losses that may 
arise from credit-related exposures and probable and 
estimable losses related to litigation and regulatory 
proceedings, and income taxes. While management makes 
its best judgment, actual amounts or results could differ from 
those estimates. 

Cash Flows
Cash equivalents are defined as those amounts included in 
Cash and due from banks and predominately all of Deposits 
with banks. Cash flows from risk management activities are 
classified in the same category as the related assets and 
liabilities.

Related Party Transactions
The Company has related party transactions with certain of 
its subsidiaries and affiliates. These transactions, which are 
primarily short-term in nature, include cash accounts, 
collateralized financing transactions, margin accounts, 
derivative transactions, charges for operational support and 
the borrowing and lending of funds, and are entered into in 
the ordinary course of business.

ACCOUNTING CHANGES

Lease Accounting
In February 2016, the FASB issued ASU No. 2016-02, 
Leases (Topic 842), which increases the transparency and 
comparability of accounting for lease transactions. The ASU 
requires lessees to recognize liabilities for operating leases 
and corresponding right-of-use (ROU) assets on the balance 
sheet. The ASU also requires quantitative and qualitative 
disclosures regarding key information about leasing 
arrangements. Lessee accounting for finance leases, as well 
as lessor accounting, are largely unchanged. 

Effective January 1, 2019, the Company prospectively 

adopted the provisions of the ASU. At adoption, Citi 
recognized a lease liability and a corresponding ROU asset 
of approximately $4.4 billion on the Consolidated Balance 

140

Sheet related to its future lease payments as a lessee under 
operating leases. In addition, the Company recorded a $151 
million increase in Retained earnings for the cumulative 
effect of recognizing previously deferred gains on sale/
leaseback transactions. Adoption of the ASU did not have a 
material impact on the Consolidated Statement of Income. 
See Notes 14 and 26 for additional details. 

The Company has elected not to separate lease and non-

lease components in its lease contracts and accounts for 
them as a single lease component. Citi has also elected not to 
record an ROU asset for short-term leases that have a term 
of 12 months or less and do not contain purchase options 
that Citi is reasonably certain to exercise. The cost of short-
term leases is recognized in the Consolidated Statement of 
Income on a straight-line basis over the lease term. In 
addition, Citi applies the portfolio approach to account for 
certain equipment leases with nearly identical contractual 
terms. 

Lessee accounting
Operating lease ROU assets and lease liabilities are included 
in Other assets and Other liabilities, respectively, on the 
Consolidated Balance Sheet. Finance lease assets and 
liabilities are included in Other assets and Long-term debt, 
respectively, on the Consolidated Balance Sheet. The 
Company uses its incremental borrowing rate, factoring in 
the lease term, to determine the lease liability, which is 
measured at the present value of future lease payments. The 
ROU asset is initially measured at the amount of the lease 
liability plus any prepaid rent and remaining initial direct 
costs, less any remaining lease incentives and accrued rent. 
The ROU asset is subject to impairment, during the lease 
term, in a manner consistent with the impairment of long-
lived assets. The lease terms include periods covered by 
options to extend or terminate the lease depending on 
whether Citi is reasonably certain to exercise such options.

Lessor accounting
Lessor accounting is largely unchanged under the ASU. Citi 
acts as a lessor for power, railcar, shipping and aircraft 
assets, where the Company has executed operating, direct 
financing and leveraged leasing arrangements. In a direct 
financing or a leveraged lease, Citi derecognizes the leased 
asset and records a lease financing receivable at lease 
commencement in Loans. Upon lease termination, Citi may 
obtain control of the asset, which is then recorded in Other 
assets on the Consolidated Balance Sheet and any remaining 
receivable for the asset’s residual value is derecognized. 
Under the ASU, leveraged lease accounting is grandfathered 
and may continue to be applied until the leveraged lease is 
terminated or modified. Upon modification, the lease must 
be classified as an operating, direct finance or sales-type 
lease in accordance with the ASU. 

Separately, as part of managing its real estate footprint, 

Citi subleases excess real estate space via operating lease 
arrangements. 

SEC Staff Accounting Bulletin 118
On December 22, 2017, the SEC issued Staff Accounting 
Bulletin (SAB) 118, which set forth the accounting for the 
changes in tax law caused by the enactment of the Tax Cuts 
and Jobs Act (Tax Reform). SAB 118 provided guidance 
where the accounting under ASC 740 was incomplete for 
certain income tax effects of Tax Reform, at the time of the 
issuance of an entity’s financial statements for the period in 
which Tax Reform was enacted (provisional items). Citi 
disclosed several provisional items recorded as part of its 
$22.6 billion fourth quarter 2017 charge related to Tax 
Reform.

Citi completed its accounting for Tax Reform under 

SAB 118 during the fourth quarter of 2018 and recorded a 
one-time, non-cash tax benefit of $94 million in Corporate/
Other related to amounts that were considered provisional 
pursuant to SAB 118. The adjustments for the provisional 
amounts consisted of a $1.2 billion benefit relating to a 
reduction of the valuation allowance against Citi’s FTC 
carry-forwards and its U.S. residual DTAs related to its non-
U.S. branches, offset by additional charges of $0.2 billion 
related to the impact of a change to a “quasi-territorial tax 
system” and $0.9 billion related to the impact of deemed 
repatriation of undistributed earnings of non-U.S. 
subsidiaries.

Also, Citi has made a policy election to account for 

taxes on Global Intangible Low Taxed Income (GILTI) as 
incurred.

Revenue Recognition
In May 2014, the FASB issued ASU No. 2014-09, Revenue 
from Contracts with Customers (Revenue Recognition), 
which outlines a single comprehensive model for entities to 
use in accounting for revenue arising from contracts with 
customers. The core principle of the revenue model is that an 
entity recognizes revenue to depict the transfer of promised 
goods or services to customers in an amount that reflects the 
consideration to which the entity expects to be entitled, in 
exchange for those goods or services. The ASU defines the 
promised good or service as the performance obligation 
under the contract.

While the guidance replaces most existing revenue 
recognition guidance in GAAP, the ASU is not applicable to 
financial instruments and, therefore, does not impact a 
majority of the Company’s revenues, including net interest 
income, loan fees, gains on sales and mark-to-market 
accounting.

In accordance with the new revenue recognition 
standard, Citi has identified the specific performance 
obligation (promised services) associated with the contract 
with the customer and has determined when that specific 
performance obligation has been satisfied, which may be at a 
point in time or over time depending on how the 
performance obligation is defined. The contracts with 
customers also contain the transaction price, which consists 
of fixed consideration and/or consideration that may vary 
(variable consideration), and is defined as the amount of 
consideration an entity expects to be entitled to when or as 
the performance obligation is satisfied, excluding amounts 

collected on behalf of third parties (including transaction 
taxes). The amounts recognized at the point in time the 
performance obligation is satisfied may differ from the 
ultimate transaction price associated with that performance 
obligation when a portion of it is based on variable 
consideration. For example, some consideration is based on 
the client’s month-end balance or market values, which are 
unknown at the time the contract is executed. The remaining 
transaction price amount, if any, will be recognized as the 
variable consideration becomes determinable. In certain 
transactions, the performance obligation is considered 
satisfied at a point in time in the future. In this instance, Citi 
defers revenue on the balance sheet that will only be 
recognized upon completion of the performance obligation. 
The new revenue recognition standard further clarified 
the guidance related to reporting revenue gross as principal 
versus net as an agent. In many cases, Citi outsources a 
component of its performance obligations to third parties. 
The Company has determined that it acts as principal in the 
majority of these transactions and therefore presents the 
amounts paid to these third parties gross within operating 
expenses.

The Company has retrospectively adopted this standard 
as of January 1, 2018 and as a result was required to report 
amounts paid to third parties where Citi is principal to the 
contract within Operating expenses. The adoption resulted in 
an increase in both revenue and expenses of approximately 
$1 billion for each of the years ended December 31, 2019 
and 2018 with similar amounts for prior years. Prior to 
adoption, these expense amounts were reported as contra 
revenue primarily within Commissions and fees and 
Administration and other fiduciary fees revenues. 
Accordingly, prior periods have been reclassified to conform 
to the new presentation.

See Note 5 to the Consolidated Financial Statements for 
a description of the Company’s revenue recognition policies 
for Commissions and fees and Administration and other 
fiduciary fees.

Income Tax Impact of Intra-Entity Transfers of Assets
In October 2016, the FASB issued ASU No. 2016-16, 
Income Taxes—Intra-Entity Transfers of Assets Other Than 
Inventory, which requires an entity to recognize the income 
tax consequences of an intra-entity transfer of an asset other 
than inventory when the transfer occurs. The ASU was 
effective January 1, 2018 and was adopted as of that date. 
The impact of this standard was an increase of DTAs by 
approximately $300 million, a decrease of Retained earnings 
by approximately $80 million and a decrease of prepaid tax 
assets by approximately $380 million.  

Clarifying the Definition of a Business
In January 2017, the FASB issued ASU No. 2017-01, 
Business Combinations (Topic 805): Clarifying the 
Definition of a Business. The definition of a business directly 
and indirectly affects many areas of accounting (e.g., 
acquisitions, disposals, goodwill and consolidation). The 
ASU narrows the definition of a business by introducing a 
quantitative screen as the first step, such that if substantially 

141

all of the fair value of the gross assets acquired is 
concentrated in a single identifiable asset or a group of 
similar identifiable assets, then the set of transferred assets 
and activities is not a business. If the set is not clarified from 
the quantitative screen, the entity then evaluates whether the 
set meets the requirement that a business include, at a 
minimum, an input and a substantive process that together 
significantly contribute to the ability to create outputs.

Citi adopted the ASU upon its effective date on January 
1, 2018, prospectively. The ongoing impact of the ASU will 
depend upon the acquisition and disposal activities of Citi. If 
fewer transactions qualify as a business, there could be less 
initial recognition of Goodwill, but also less goodwill 
allocated to disposals. There was no impact during 2018 
from the adoption of this ASU.

Changes in Accounting for Pension and Postretirement 
(Benefit) Expense
In March 2017, the FASB issued ASU No. 2017-07, 
Compensation—Retirement Benefits (Topic 715): Improving 
the Presentation of Net Periodic Pension Cost and Net 
Periodic Postretirement Benefit Cost, which changes the 
income statement presentation of net benefit expense and 
requires restating the Company’s financial statements for 
each of the earlier periods presented in Citi’s annual and 
interim financial statements. The change in presentation was 
effective for annual and interim periods starting January 1, 
2018. The ASU requires that only the service cost 
component of net benefit expense be included in 
Compensation and benefits on the income statement. The 
other components of net benefit expense are required to be 
presented outside of Compensation and benefits and are 
presented in Other operating expenses. Since both of these 
income statement line items are part of Operating expenses, 
total Operating expenses and Net income will not 
change. This change in presentation did not have a material 
effect on Compensation and benefits and Other operating 
expenses and was applied prospectively. The components of 
the net benefit expense are disclosed in Note 8 to the 
Consolidated Financial Statements.

 The standard also changes the components of net 

benefit expense that are eligible for capitalization when 
employee costs are capitalized in connection with various 
activities, such as internally developed software, 
construction-in-progress and loan origination costs. 
Prospectively from January 1, 2018, only the service cost 
component of net benefit expense may be capitalized.  
Existing capitalized balances are not affected. This change in 
amounts eligible for capitalization does not have a material 
effect on the Company’s Consolidated Financial Statements 
and related disclosures.

Hedging
In August 2017, the FASB issued ASU No. 2017-12, 
Targeted Improvements to Accounting for Hedging Activities, 
which better aligns an entity’s risk management activities 
and financial reporting for hedging relationships through 
changes to the designation and measurement guidance for 
qualifying hedging relationships and the presentation of 

142

hedge results. The ASU requires the change in the fair value 
of the hedging instrument to be presented in the same 
income statement line as the hedged item and also requires 
expanded disclosures. Citi adopted this standard on January 
1, 2018 and transferred approximately $4 billion of pre-
payable mortgage-backed securities and municipal bonds 
from held-to-maturity (HTM) into available-for-sale (AFS) 
securities classification as permitted as a one-time transfer 
upon adoption of the standard, as these assets were deemed 
to be eligible to be hedged under the last-of-layer hedge 
strategy. The impact to opening Retained earnings was 
immaterial. See Note 19 to the Consolidated Financial 
Statements for more information. 

Statement of Cash Flows
In November 2016, the FASB issued ASU No. 2016-18, 
Restricted Cash, which requires that companies present cash, 
cash equivalents and amounts generally described as 
restricted cash or restricted cash equivalents (restricted cash) 
when reconciling beginning-of-period and end-of-period 
totals on the Consolidated Statement of Cash Flows. In 
connection with the adoption of the ASU, Citigroup also 
changed its definition of cash and cash equivalents to 
include all of Cash and due from banks and predominately 
all of Deposits with banks. The Company has retrospectively 
adopted this ASU as of January 1, 2018 and as a result Net 
cash provided by investing activities of continuing 
operations on the Consolidated Statement of Cash Flows for 
the year ended December 31, 2017 increased by $19.3 
billion.

Reclassification of Certain Tax Effects from Accumulated 
Other Comprehensive Income 
On February 14, 2018, the FASB issued ASU No. 2018-02, 
Reclassification of Certain Tax Effects from Accumulated 
Other Comprehensive Income. The ASU allows a 
reclassification from AOCI to Retained earnings for the 
deferred taxes previously recorded in AOCI that exceed the 
current federal tax rate of 21%, resulting from the newly 
enacted corporate tax rate in Tax Reform, and other stranded 
tax amounts related to the application of Tax Reform that 
Citi elects to reclassify. The ASU allows adjustments to 
reclassification amounts in subsequent periods as a result of 
changes to the amounts recorded under SAB 118. Citi 
elected to early adopt the ASU effective December 31, 2017, 
which applied only to the period in which the effects related 
to the one-time Tax Reform charge were recognized. In 
addition to the reclassification of deferred taxes recorded in 
AOCI that exceed the current federal tax rate, Citi also 
reclassified amounts recorded in AOCI related to the effects 
of the shift to a territorial system related to the application of 
Tax Reform using the portfolio method.

The effect of adopting the ASU resulted in an increase 
of $3.3 billion to Retained earnings at December 31, 2017 
due to the reclassification of AOCI to Retained earnings. 

Premium Amortization on Purchased Callable 
Debt Securities
In March 2017, the FASB issued ASU No. 2017-08, 
Receivables—Nonrefundable Fees and Other Costs 
(Subtopic 310-20): Premium Amortization on Purchased 
Callable Debt Securities, which amends the amortization 
period for certain purchased callable debt securities held at a 
premium. The ASU requires entities to amortize premiums 
on debt securities by the first call date when the securities 
have fixed and determinable call dates and prices. The scope 
of the ASU includes all accounting premiums, such as 
purchase premiums and cumulative fair value hedge 
adjustments. The ASU does not change the accounting for 
discounts, which continue to be recognized over the 
contractual life of a security.

Citi early adopted the ASU in the second quarter of 
2017, with an effective date of January 1, 2017. Adoption of 
the ASU is on a modified retrospective basis through a 
cumulative effect adjustment to Retained earnings as of the 
beginning of the year of adoption. Adoption of the ASU 
primarily affected Citi’s AFS and HTM portfolios of callable 
state and municipal debt securities. The ASU adoption 
resulted in a net reduction to total stockholders’ equity of 
$156 million (after-tax), effective as of January 1, 2017. This 
amount is composed of a reduction of approximately $660 
million to Retained earnings for the incremental 
amortization of purchase premiums and cumulative hedge 
adjustments generated under fair value hedges of these 
callable debt securities, offset by an increase to AOCI of 
$504 million related to the cumulative fair value hedge 
adjustments reclassified to Retained earnings for AFS debt 
securities.

Fair Value Measurement
In August 2018, the FASB issued ASU No. 2018-13, Fair 
Value Measurement (Topic 820): Disclosure Framework—
Changes to the Disclosure Requirements for Fair Value 
Measurement. The amendments modify certain disclosure 
requirements for fair value measurements and were effective 
January 1, 2020, with early adoption permitted. The 
Company early adopted this ASU as of December 31, 2019 
in its entirety, with no material impact on the Company.

FUTURE ACCOUNTING CHANGES

Accounting for Financial Instruments—Credit Losses

Overview
In June 2016, the Financial Accounting Standards Board 
(FASB) issued ASU No. 2016-13, Financial Instruments—
Credit Losses (Topic 326). The ASU introduces a new credit 
loss methodology, the Current Expected Credit Losses 
(CECL) methodology, which requires earlier recognition of 
credit losses while also providing additional transparency 
about credit risk. Citi adopted the ASU as of January 1, 
2020, which, as discussed below, resulted in an increase in 
Citi’s Allowance for credit losses and a decrease to opening 
Retained earnings, net of deferred income taxes, at January 
1, 2020.

The CECL methodology utilizes a lifetime “expected 

credit loss” measurement objective for the recognition of 
credit losses for loans, held-to-maturity debt securities, 
receivables and other financial assets measured at amortized 
cost at the time the financial asset is originated or acquired. 
The allowance for credit losses is adjusted each period for 
changes in expected lifetime credit losses. The CECL 
methodology represents a significant change from prior U.S. 
GAAP and replaced the prior multiple existing impairment 
methods, which generally required that a loss be incurred 
before it was recognized. Within the life cycle of a loan or 
other financial asset, the methodology generally results in 
the earlier recognition of the provision for credit losses and 
the related allowance for credit losses than prior U.S. GAAP. 
For available-for-sale debt securities where fair value is less 
than cost, that Citi intends to hold or more-likely-than-not 
will not be required to sell, credit-related impairment, if any, 
is recognized through an allowance for credit losses and 
adjusted each period for changes in credit risk. 

January 1, 2020 CECL Transition (Day 1) Impact
The CECL methodology’s impact on expected credit losses, 
among other things, reflects Citi’s view of the current state 
of the economy, forecasted macroeconomic conditions and 
Citi’s portfolios. At the January 1, 2020 date of adoption, 
based on forecasts of macroeconomic conditions and 
exposures at that time, the aggregate impact to Citi was an 
approximate $4.1 billion, or an approximate 29%, pretax 
increase in the Allowance for credit losses, along with a $3.1 
billion after-tax decrease in Retained earnings and a deferred 
tax asset increase of $1.0 billion. This transition impact 
reflects (i) a $4.9 billion build to the Allowance for credit 
losses for Citi’s consumer exposures, primarily driven by the 
impact on credit card receivables of longer estimated tenors 
under the CECL lifetime expected credit loss methodology 
(loss coverage of approximately 23 months) compared to 
shorter estimated tenors under the probable loss 
methodology under prior U.S. GAAP (loss coverage of 
approximately 14 months), net of recoveries; and (ii) a 
release of $0.8 billion of reserves primarily related to Citi’s 
corporate net loan loss exposures, largely due to more 
precise contractual maturities that result in shorter remaining 
tenors, incorporation of recoveries and use of more specific 
historical loss data based on an increase in portfolio 
segmentation across industries and geographies.

Under the CECL methodology, the Allowance for credit 

losses consists of quantitative and qualitative components. 
Citi’s quantitative component of the Allowance for credit 
losses is model based and utilizes a single forward-looking 
macroeconomic forecast, complemented by the qualitative 
component described below, in estimating expected credit 
losses and discounts inputs for the corporate classifiably 
managed portfolios. Reasonable and supportable forecast 
periods vary by product. For example, Citi’s consumer cards 
models use a 13-quarter reasonable and supportable period 
and revert to historical loss experience thereafter, while its 
corporate loan models use a nine-quarter reasonable and 
supportable period followed by a three-quarter graduated 
transition to historical loss experience. 

143

Citi’s qualitative component of the Allowance for credit 

losses considers (i) the uncertainty of forward-looking 
scenarios based on the likelihood and severity of a possible 
recession as another possible scenario; (ii) certain portfolio 
characteristics, such as portfolio concentration and collateral 
coverage; and (iii) model limitations as well as idiosyncratic 
events. 

Subsequent Measurement of Goodwill 
In January 2017, the FASB issued ASU No. 2017-04, 
Intangibles—Goodwill and Other (Topic 350): Simplifying 
the Test for Goodwill Impairment. The ASU simplifies the 
subsequent measurement of goodwill impairment by 
eliminating the requirement to calculate the implied fair 
value of goodwill (i.e., the current step 2 of the goodwill 
impairment test) to measure a goodwill impairment charge. 
Under the ASU, the impairment test is the comparison of the 
fair value of a reporting unit with its carrying amount (the 
current step 1), with the impairment charge being the deficit 
in fair value but not exceeding the total amount of goodwill 
allocated to that reporting unit. The simplified one-step 
impairment test applies to all reporting units (including those 
with zero or negative carrying amounts). 

The ASU was adopted by Citi as of January 1, 2020 
with prospective application. The impact of the ASU will 
depend upon the performance of Citi’s reporting units and 
the market conditions impacting the fair value of each 
reporting unit going forward.

144

2. DISCONTINUED OPERATIONS AND SIGNIFICANT DISPOSALS

Summary of Discontinued Operations
The Company’s Discontinued operations consisted of residual 
activities related to the sales of the Brazil Credit Card business 
in 2013, the Egg Banking plc Credit Card business in 2011, 
and the German Retail Banking business in 2008. All 
Discontinued operations results are recorded within 
Corporate/Other.

The following summarizes financial information for all 

Discontinued operations:

In millions of dollars

2019

2018

2017

Total revenues, net of interest expense

$ — $ — $ —

Loss from discontinued operations

$

(31) $ (26) $ (104)

Provision (benefit) for income taxes

(27)

(18)

7

Loss from discontinued operations, net
of taxes

$

(4) $

(8) $ (111)

Cash flows from Discontinued operations were not 

material for all periods presented.

Significant Disposals
There were no significant disposals during 2019. The 
transactions described below were identified as significant 
disposals during 2018 and 2017. 

Sale of Mexico Asset Management Business
On September 21, 2018, Citi completed the sale of its Mexico 
asset management business, which was part of Latin America 
GCB. As part of the sale, Citi derecognized total assets of 
$137 million and total liabilities of $41 million. The 
transaction resulted in a pretax gain on sale of approximately 
$250 million (approximately $150 million after-tax) recorded 
in Other revenue in 2018. Further, Citi and the buyer entered 
into a 10-year services framework agreement, with Citi acting 
as the distributor in exchange for an ongoing fee. 

Income before taxes for the divested business, excluding 

the pretax gain on sale, was as follows:

Exit of U.S. Mortgage Service Operations
Citigroup executed agreements during the first quarter of 2017 
to effectively exit its direct U.S. mortgage servicing 
operations, which included the sale of mortgage servicing 
rights and execution of a subservicing agreement for the 
remaining Citi-owned loans and certain other mortgage 
servicing rights. As part of this transaction, Citi also 
transferred certain employees.

This transaction, which was part of Corporate/Other, 

resulted in a pretax loss of $331 million ($207 million after-
tax) recorded in Other revenue during 2017. The loss on sale 
did not include certain other costs and charges related to the 
disposed operation recorded primarily in Operating expenses 
during 2017, resulting in a total pretax loss of $382 million. As 
part of the sale, Citi derecognized a total of $1,162 million of 
servicing-related assets, including $1,046 million of Mortgage 
servicing rights, related to approximately 750,000 Fannie Mae 
and Freddie Mac held loans with outstanding balances of 
approximately $93 billion. 

Excluding the loss on sale and the additional charges, 

income before taxes for the disposed operation was 
immaterial.

Sale of CitiFinancial Canada Consumer Finance Business
On March 31, 2017, Citi completed the sale of CitiFinancial 
Canada (CitiFinancial), which was part of Corporate/Other 
and included 220 retail branches and approximately 1,400 
employees. As part of the sale, Citi derecognized Total assets 
of approximately $1.9 billion, including $1.7 billion consumer 
loans (net of allowance), and Total liabilities of approximately 
$1.5 billion related to intercompany borrowings, which were 
settled at closing of the transaction. The sale of CitiFinancial 
generated a pretax gain on sale of approximately $350 million 
recorded in Other revenue ($178 million after-tax) during 
2017.

Income before taxes for the divested business, excluding 

the pretax gain on sale, was as follows:

In millions of dollars

Income before taxes

2019

2018

2017

$ — $ 123 $ 164

In millions of dollars

Income before taxes

2019

2018 2017

$ — $ — $ 41

Sale of Fixed Income Analytics and Index Business
On August 31, 2017, Citi completed the sale of a fixed income 
analytics business and a fixed income index business that were 
part of Markets and securities services within Institutional 
Clients Group (ICG). As part of the sale, Citi derecognized 
Total assets of $112 million, including goodwill of $72 
million, while the derecognized liabilities were $18 million. 
The transaction resulted in a pretax gain on sale of 
approximately $580 million ($355 million after-tax) recorded 
in Other revenue in ICG during 2017. 

Income before taxes for the divested businesses, 

excluding the pretax gain on sale, was immaterial.

145

3. BUSINESS SEGMENTS

Citigroup’s activities are conducted through the following 
business segments: Global Consumer Banking (GCB) 
and Institutional Clients Group (ICG). In addition, Corporate/
Other includes activities not assigned to a specific business 
segment, as well as certain North America loan portfolios, 
discontinued operations and other legacy assets.

The business segments are determined based on products 

and services provided or type of customers served, of which 
those identified as non-core are recorded in Corporate/Other 
and are reflective of how management currently evaluates 
financial information to make business decisions.

GCB includes a global, full-service consumer franchise 
delivering a wide array of banking, credit card lending and 
investment services through a network of local branches, 
offices and electronic delivery systems and consists of three 
GCB businesses: North America, Latin America and Asia 
(including consumer banking activities in certain EMEA 
countries).

ICG consists of Banking and Markets and securities 
services and provides corporate, institutional, public sector 
and high-net-worth clients in 98 countries and jurisdictions 
with a broad range of banking and financial products and 
services.

Corporate/Other includes certain unallocated costs of 
global functions, other corporate expenses and net treasury 
results, unallocated corporate expenses, offsets to certain line-
item reclassifications and eliminations, the results of certain 

North America legacy loan portfolios, discontinued operations 
and unallocated taxes.

The accounting policies of these reportable segments are 

the same as those disclosed in Note 1 to the Consolidated 
Financial Statements. 

The prior-period balances reflect reclassifications to 
conform the presentation for all periods to the current period’s 
presentation. During 2019, financial data was reclassified to 
reflect:

•  Citi’s commercial banking businesses previously reported 
as part of GCB in North America, Latin America and 
Asia, including approximately $28 billion in end-of-
period loans and approximately $37 billion in end-of-
period deposits, are reported in ICG for all periods 
presented;
the re-attribution of certain costs between Corporate/
Other and GCB and ICG; and
certain other immaterial reclassifications.

• 

• 

Citi’s consolidated Net income (loss) reported in its 2018 

Annual Report on Form 10-K remains unchanged for all 
periods presented as a result of the changes and 
reclassifications discussed above.

The following table presents certain information 
regarding the Company’s continuing operations by segment:

Revenues,
net of interest expense(1)

Provision (benefits)
for income taxes(2)

Income (loss) from
continuing operations(2)(3)

Identifiable assets

In millions of dollars, except
identifiable assets in billions

2019

2018

2017

2019

2018

2017

2019

2018

2017

2019

2018

Global Consumer Banking $ 32,971 $ 32,339 $ 31,445 $
Institutional Clients
Group

39,301

37,822

38,325

1,746 $ 1,689 $

3,067 $

5,702 $ 5,309 $

3,542 $

407 $

388

3,570

3,756

7,241

12,944

12,574

9,375

1,447

1,438

Corporate/Other

2,014

2,190

3,177

(886)

(88)

19,080

825

205

(19,544)

97

91

Total

$ 74,286 $ 72,854 $ 72,444 $

4,430 $ 5,357 $ 29,388 $ 19,471 $ 18,088 $ (6,627) $

1,951 $

1,917

(1)   Includes total revenues, net of interest expense (excluding Corporate/Other), in North America of $33.9 billion, $33.4 billion and $34.1 billion; in EMEA of $12.0 
billion, $11.8 billion and $10.9 billion; in Latin America of $10.4 billion, $10.3 billion and $9.6 billion; and in Asia of $16.0 billion, $15.3 billion and $14.6 
billion in 2019, 2018 and 2017, respectively. These regional numbers exclude Corporate/Other, which largely operates within the U.S. 

(2)  Corporate/Other, GCB and ICG 2017 results include the one-time impact of Tax Reform. 
(3)   Includes pretax provisions for credit losses and for benefits and claims in the GCB results of $7.9 billion, $7.6 billion and $7.6 billion; in the ICG results of $563 

million, $215 million and $19 million; and in the Corporate/Other results of $(75) million, $(202) million and $(175) million in 2019, 2018 and 2017, 
respectively.

146

4.  INTEREST REVENUE AND EXPENSE

Interest revenue and Interest expense consisted of the following:

In millions of dollars

Interest revenue

Loan interest, including fees

Deposits with banks

Securities borrowed and purchased under agreements to resell

Investments, including dividends
Trading account assets(1)
Other interest

Total interest revenue

Interest expense
Deposits(2)
Securities loaned and sold under agreements to repurchase
Trading account liabilities(1)
Short-term borrowings

Long-term debt

Total interest expense

Net interest revenue

Provision for loan losses

Net interest revenue after provision for loan losses

2019

2018

2017

$

47,751 $

45,682 $

41,736

2,682

6,872

9,860

7,672

1,673

2,203

5,492

9,494

6,284

1,673

1,635

3,249

8,295

5,501

1,163

76,510 $

70,828 $

61,579

12,633 $

9,616 $

6,263

1,308

2,465

6,494

29,163 $

47,347 $

8,218

4,889

1,001

2,209

6,551

24,266 $

46,562 $

7,354

39,129 $

39,208 $

6,587

2,661

638

1,059

5,573

16,518

45,061

7,503

37,558

$

$

$

$

$

(1) 
(2) 

Interest expense on Trading account liabilities is reported as a reduction of interest revenue from Trading account assets.
Includes deposit insurance fees and charges of $781 million, $1,182 million and $1,249 million for 2019, 2018 and 2017, respectively.

147

 
 
 
 
 
 
5.   COMMISSIONS AND FEES; ADMINISTRATION 
AND OTHER FIDUCIARY FEES

Commissions and Fees
The primary components of Commissions and fees revenue are 
investment banking fees, brokerage commissions, credit card 
and bank card income and deposit-related fees. 

Investment banking fees are substantially composed of 
underwriting and advisory revenues. Such fees are recognized 
at the point in time when Citigroup’s performance under the 
terms of a contractual arrangement is completed, which is 
typically at the closing of a transaction. Reimbursed expenses 
related to these transactions are recorded as revenue and are 
included within investment banking fees. In certain instances 
for advisory contracts, Citi will receive amounts in advance of 
the deal’s closing. In these instances, the amounts received 
will be recognized as a liability and not recognized in revenue 
until the transaction closes. For the periods presented, the 
contract liability amount was negligible. 

Out-of-pocket expenses associated with underwriting 
activity are deferred and recognized at the time the related 
revenue is recognized, while out-of-pocket expenses 
associated with advisory arrangements are expensed as 
incurred. In general, expenses incurred related to investment 
banking transactions, whether consummated or not, are 
recorded in Other operating expenses. The Company has 
determined that it acts as principal in the majority of these 
transactions and therefore presents expenses gross within 
Other operating expenses.

Brokerage commissions primarily include commissions 

and fees from the following: executing transactions for clients 
on exchanges and over-the-counter markets; sales of mutual 
funds and other annuity products; and assisting clients in 
clearing transactions, providing brokerage services and other 
such activities. Brokerage commissions are recognized in 
Commissions and fees at the point in time the associated 
service is fulfilled, generally on the trade execution date. 
Gains or losses, if any, on these transactions are included in 
Principal transactions (see Note 6 to the Consolidated 
Financial Statements). Sales of certain investment products 
include a portion of variable consideration associated with the 
underlying product. In these instances, a portion of the 
revenue associated with the sale of the product is not 
recognized until the variable consideration becomes fixed. The 
Company recognized $485 million, $521 million and $416 
million of revenue related to such variable consideration for 
the years ended December 31, 2019, 2018 and 2017, 
respectively. These amounts primarily relate to performance 
obligations satisfied in prior periods.

Credit card and bank card income is primarily composed 
of interchange fees, which are earned by card issuers based on
purchase sales, and certain card fees, including annual fees.
Costs related to customer reward programs and certain
payments to partners (primarily based on program sales,
profitability and customer acquisitions) are recorded as a
reduction of credit card and bank card income. Interchange
revenues are recognized as earned on a daily basis when Citi's
performance obligation to transmit funds to the payment
networks has been satisfied. Annual card fees, net of
origination costs, are deferred and amortized on a straight-line
basis over a 12-month period. Costs related to card reward
programs are recognized when the rewards are earned by the
cardholders. Payments to partners are recognized when
incurred.

Deposit-related fees consist of service charges on deposit
accounts and fees earned from performing cash management
activities and other deposit account services. Such fees are
recognized in the period in which the related service is
provided.

Transactional service fees primarily consist of fees
charged for processing services such as cash management,
global payments, clearing, international funds transfer and
other trade services. Such fees are recognized as/when the
associated service is satisfied, which normally occurs at the
point in time the service is requested by the customer and
provided by Citi.

Insurance distribution revenue consists of commissions
earned from third-party insurance companies for marketing
and selling insurance policies on behalf of such entities. Such
commissions are recognized in Commissions and fees at the
point in time the associated service is fulfilled, generally when
the insurance policy is sold to the policyholder. Sales of
certain insurance products include a portion of variable
consideration associated with the underlying product. In these
instances, a portion of the revenue associated with the sale of
the policy is not recognized until the variable consideration
becomes determinable. The Company recognized $322 
million, $386 million and $440 million of revenue related to 
such variable consideration for the years ended December 31, 
2019, 2018 and 2017, respectively. These amounts primarily 
relate to performance obligations satisfied in prior periods.
Insurance premiums consist of premium income from

insurance policies that Citi has underwritten and sold to
policyholders.

148

 
 
The following table presents Commissions and fees revenue:

In millions of dollars

ICG

GCB

Corp/
Other

Total

ICG

GCB

Corp/
Other

Total

ICG

GCB

Corp/
Other

Total

Investment banking

$ 3,767 $ — $ — $ 3,767 $ 3,568 $ — $ — $ 3,568 $ 3,817 $ — $ — $ 3,817

2019

2018

2017

Brokerage commissions
Credit card and bank card 
  income

1,771

841

— 2,612

1,977

815

— 2,792

1,889

826

3

2,718

     Interchange fees

1,222

8,621

— 9,843

1,077

8,112

60

718

—

778

63

627

11

12

9,200

702

953

53

7,523

693

99

48

8,575

794

     Card-related loan fees
     Card rewards and partner 
       payments
Deposit-related fees(1)
Transactional service fees
Corporate finance(2)
Insurance distribution 
  revenue

Insurance premiums

Loan servicing

Other
Total commissions and 
  fees(3)

(691)

(8,883)

— (9,574)

(504)

(8,253)

(12)

(8,769)

(426)

(7,242)

(57)

(7,725)

1,048

824

616

12

—

78

99

470

123

—

524

186

55

261

— 1,518

1,031

—

—

—

—

21

3

947

616

536

186

154

363

733

734

14

—

100

116

572

83

—

565

119

91

139

1

4

—

11

—

37

14

1,604

1,031

820

734

590

119

228

269

751

766

12

—

117

30

642

78

—

562

122

71

90

14

49

—

68

—

95

30

1,687

878

766

642

122

283

150

$ 8,806 $ 2,916 $

24 $11,746 $ 8,909 $ 2,870 $

78 $11,857 $ 8,993 $ 3,365 $

349 $12,707

(1) 

Includes overdraft fees of $127 million, $128 million and $135 million for the years ended December 31, 2019, 2018 and 2017, respectively. Overdraft fees are 
accounted for under ASC 310.

(2)  Consists primarily of fees earned from structuring and underwriting loan syndications or related financing activity. This activity is accounted for under ASC 310.
(3)  Commissions and fees includes $(7,695) million, $(6,853) million and $(5,627) million not accounted for under ASC 606, Revenue from Contracts with 

Customers, for the years ended December 31, 2019, 2018 and 2017, respectively. Amounts reported in Commissions and fees accounted for under other guidance 
primarily include card-related loan fees, card reward programs and certain partner payments, corporate finance fees, insurance premiums and loan servicing fees.

149

Administration and Other Fiduciary Fees
Administration and other fiduciary fees revenue is primarily 
composed of custody fees and fiduciary fees.

The custody product is composed of numerous services 
related to the administration, safekeeping and reporting for 
both U.S. and non-U.S. denominated securities. The services 
offered to clients include trade settlement, safekeeping, 
income collection, corporate action notification, record-
keeping and reporting, tax reporting and cash management. 
These services are provided for a wide range of securities, 
including but not limited to equities, municipal and corporate 
bonds, mortgage- and asset-backed securities, money market 
instruments, U.S. Treasuries and agencies, derivative 
instruments, mutual funds, alternative investments and 
precious metals. Custody fees are recognized as or when the 
associated promised service is satisfied, which normally 
occurs at the point in time the service is requested by the 
customer and provided by Citi.

Fiduciary fees consist of trust services and investment 
management services. As an escrow agent, Citi receives, safe-

keeps, services and manages clients’ escrowed assets, such as 
cash, securities, property (including intellectual property), 
contracts or other collateral. Citi performs its escrow agent 
duties by safekeeping the funds during the specified time 
period agreed upon by all parties and therefore earns its 
revenue evenly during the contract duration. 

Investment management services consist of managing 

assets on behalf of Citi’s retail and institutional clients. 
Revenue from these services primarily consists of asset-based 
fees for advisory accounts, which are based on the market 
value of the client’s assets and recognized monthly, when the 
market value is fixed. In some instances, the Company 
contracts with third-party advisors and with third-party 
custodians. The Company has determined that it acts as 
principal in the majority of these transactions and therefore 
presents the amounts paid to third parties gross within Other 
operating expenses.

The following table presents Administration and other 

fiduciary fees revenue:

In millions of dollars

ICG GCB

2019

Corp/
Other

Total

ICG

GCB

2018

Corp/
Other

2017

Total

ICG

GCB

Corp/
Other

Total

Custody fees

Fiduciary fees

Guarantee fees

Total administration 
  and other fiduciary fees(1)

$ 1,453 $

16 $

73 $1,542 $ 1,497 $ 133 $

65 $1,695 $1,508 $ 164 $

56 $ 1,728

647

558

621

8

28

7

1,296

573

645

584

597

9

43

7

1,285

600

593

584

575

5

91

8

1,259

597

$ 2,658 $ 645 $

108 $3,411 $ 2,726 $ 739 $

115 $3,580 $2,685 $ 744 $

155 $ 3,584

(1)  Administration and other fiduciary fees includes $573 million, $600 million and $597 million for the years ended December 31, 2019, 2018 and 2017, 

respectively, that are not accounted for under ASC 606, Revenue from Contracts with Customers. These amounts include guarantee fees.

150

6.  PRINCIPAL TRANSACTIONS

Citi’s Principal transactions revenue consists of realized and 
unrealized gains and losses from trading activities. Trading 
activities include revenues from fixed income, equities, credit 
and commodities products and foreign exchange transactions 
that are managed on a portfolio basis characterized by primary 
risk. Not included in the table below is the impact of net 
interest revenue related to trading activities, which is an 
integral part of trading activities’ profitability. See Note 4 to 
the Consolidated Financial Statements for information about 

net interest revenue related to trading activities. Principal 
transactions include CVA (credit valuation adjustments) and 
FVA (funding valuation adjustments) on over-the-counter 
derivatives, and gains (losses) on certain economic hedges on 
loans in ICG. These adjustments are discussed further in Note 
24 to the Consolidated Financial Statements. 

In certain transactions, Citi incurs fees and presents these 
fees paid to third parties in operating expenses. The following 
table presents Principal transactions revenue:

In millions of dollars
Interest rate risks(1)
Foreign exchange risks(2)
Equity risks(3)
Commodity and other risks(4)
Credit products and risks(5)
Total

2019

2018

2017

$

$

5,990 $

1,650

872

516

(136)

5,178 $

1,398

1,336

669

324

8,892 $

8,905 $

5,304

2,435

525

425

251

8,940

(1) 

(2) 
(3) 

Includes revenues from government securities and corporate debt, municipal securities, mortgage securities and other debt instruments. Also includes spot and 
forward trading of currencies and exchange-traded and over-the-counter (OTC) currency options, options on fixed income securities, interest rate swaps, currency 
swaps, swap options, caps and floors, financial futures, OTC options and forward contracts on fixed income securities.
Includes revenues from foreign exchange spot, forward, option and swap contracts, as well as foreign currency translation (FX translation) gains and losses.
Includes revenues from common, preferred and convertible preferred stock, convertible corporate debt, equity-linked notes and exchange-traded and OTC equity 
options and warrants.

(4)  Primarily includes revenues from crude oil, refined oil products, natural gas and other commodities trades.
(5) 

Includes revenues from structured credit products.

151

scheduled to vest will be reduced based on the amount of any 
pretax loss in the participant’s business in the calendar year 
preceding the scheduled vesting date. A minimum reduction of 
20% applies for the first dollar of loss for CAP and deferred 
cash stock unit awards. 

In addition, deferred cash awards are subject to a 
discretionary performance-based vesting condition under 
which an amount otherwise scheduled to vest may be reduced 
in the event of a “material adverse outcome” for which a 
participant has “significant responsibility.” These awards are 
also subject to an additional clawback provision pursuant to 
which unvested awards may be canceled if the employee 
engaged in misconduct or exercised materially imprudent 
judgment, or failed to supervise or escalate the behavior of 
other employees who did. 

Sign-on and Long-Term Retention Awards
Stock awards and deferred cash awards may be made at 
various times during the year as sign-on awards to induce new 
hires to join Citi or to high-potential employees as long-term 
retention awards.

Vesting periods and other terms and conditions pertaining 

to these awards tend to vary by grant. Generally, recipients 
must remain employed through the vesting dates to vest in the 
awards, except in cases of death, disability or involuntary 
termination other than for gross misconduct. These awards do 
not usually provide for post employment vesting by 
retirement-eligible participants. 

Outstanding (Unvested) Stock Awards
A summary of the status of unvested stock awards granted as 
discretionary annual incentive or sign-on and long-term 
retention awards is presented below:

Unvested stock awards

Shares

Weighted-
average grant
date fair
value per 
share

Unvested at December 31, 2018
Granted(1)
Canceled
Vested(2)
Unvested at December 31, 2019

31,728,596 $

14,920,917

(1,104,448)

(15,350,350)

30,194,715 $

57.30

61.78

60.45

53.58

61.30

(1)  The weighted-average fair value of the shares granted during 2018 and 

2017 was $73.87 and $59.12, respectively.

(2)  The weighted-average fair value of the shares vesting during 2019 was 

approximately $63.38 per share.

Total unrecognized compensation cost related to unvested 

stock awards was $538 million at December 31, 2019. The 
cost is expected to be recognized over a weighted-average 
period of 1.6 years. 

7.  INCENTIVE PLANS

Discretionary Annual Incentive Awards
Citigroup grants immediate cash bonus payments and various 
forms of immediate and deferred awards as part of its 
discretionary annual incentive award program involving a 
large segment of Citigroup’s employees worldwide. Most of 
the shares of common stock issued by Citigroup as part of its 
equity compensation programs are issued to settle the vesting 
of the stock components of these awards. 

Discretionary annual incentive awards are generally 
awarded in the first quarter of the year based on the previous 
year’s performance. Awards valued at less than U.S. $100,000 
(or the local currency equivalent) are generally paid entirely in 
the form of an immediate cash bonus. Pursuant to Citigroup 
policy and/or regulatory requirements, certain employees and 
officers are subject to mandatory deferrals of incentive pay 
and generally receive 25%–60% of their awards in a 
combination of restricted or deferred stock, deferred cash 
stock units or deferred cash. Discretionary annual incentive 
awards to many employees in the EU are subject to deferral 
requirements regardless of the total award value, with at least 
50% of the immediate incentive delivered in the form of a 
stock payment award subject to a restriction on sale or transfer 
(generally, for 12 months). 

Deferred annual incentive awards may be delivered in the 
form of one or more award types: a restricted or deferred stock 
award under Citi’s Capital Accumulation Program (CAP), or a 
deferred cash stock unit award and/or a deferred cash award 
under Citi’s Deferred Cash Award Plan. The applicable mix of 
awards may vary based on the employee’s minimum deferral 
requirement and the country of employment. 

Subject to certain exceptions (principally, for retirement-

eligible employees), continuous employment within Citigroup 
is required to vest in CAP, deferred cash stock unit and 
deferred cash awards. Post employment vesting by retirement-
eligible employees and participants who meet other conditions 
is generally conditioned upon their refraining from 
competition with Citigroup during the remaining vesting 
period, unless the employment relationship has been 
terminated by Citigroup under certain conditions.

Generally, the deferred awards vest in equal annual 

installments over three- or four-year periods. Vested CAP 
awards are delivered in shares of common stock. Deferred 
cash awards are payable in cash and, except as prohibited by 
applicable regulatory guidance, earn a fixed notional rate of 
interest that is paid only if and when the underlying principal 
award amount vests. Deferred cash stock unit awards are 
payable in cash at the vesting value of the underlying stock. 
Generally, in the EU, vested CAP shares are subject to a 
restriction on sale or transfer after vesting, and vested deferred 
cash awards and deferred cash stock units are subject to hold 
back (generally, for 6 or 12 months based on the award type).
Unvested CAP, deferred cash stock units and deferred 

cash awards are subject to one or more clawback provisions 
that apply in certain circumstances, including gross 
misconduct. CAP and deferred cash stock unit awards, made 
to certain employees, are subject to a formulaic performance-
based vesting condition pursuant to which amounts otherwise 

152

 
A summary of the performance share unit activity for 

2019 is presented below:

Performance share units
Outstanding, beginning of 
  period
Granted(1)
Canceled

Payments

Weighted-
average grant
date fair
value per unit

Units

1,768,362 $

560,031

(194,782)

(641,611)

51.88

72.83

42.24

27.03

71.69

Outstanding, end of period

1,492,000 $

(1)   The weighted-average grant date fair value per unit awarded in 2018 and 

2017 was $83.24 and $59.22, respectively.

PSUs granted in 2017 were equitably adjusted after the 
enactment of Tax Reform, as required under the terms of those 
awards. The adjustments were intended to reproduce the 
expected value of the awards immediately prior to the passage 
of Tax Reform. The PSUs granted in 2016 were not impacted 
by Tax Reform. 

Stock Option Programs
All outstanding stock options are fully vested, with the related 
expense recognized as a charge to income in prior periods.

Performance Share Units
Certain executive officers were awarded a target number of 
performance share units (PSUs) each February from 2016 to 
2019, for performance in the year prior to the award date.

The PSUs granted in February 2016 were earned over a 
three-year performance period based on Citigroup’s relative 
total shareholder return as compared to peers.

The PSUs granted in February 2017, 2018 and 2019 are 

earned over a three-year performance period, based half on 
return on tangible common equity performance in the last year 
of the three-year performance period and the remaining half 
on cumulative earnings per share over the three-year 
performance period. 

For all award years, if the total shareholder return is 
negative over the three-year performance period, executives 
may earn no more than 100% of the target PSUs, regardless of 
the extent to which Citigroup outperforms peer firms. The 
number of PSUs ultimately earned could vary from zero, if 
performance goals are not met, to as much as 150% of target, 
if performance goals are meaningfully exceeded.

For all award years, the value of each PSU is equal to the 

value of one share of Citi common stock. Dividend 
equivalents will be accrued and paid on the number of earned 
PSUs after the end of the performance period.

PSUs are subject to variable accounting, pursuant to 
which the associated value of the award will fluctuate with 
changes in Citigroup’s stock price and the attainment of the 
specified performance goals for each award, until the award is 
settled solely in cash after the end of the performance period. 
The value of the award, subject to the performance goals, is 
estimated using a simulation model that incorporates multiple 
valuation assumptions, including the probability of achieving 
the specified performance goals of each award. The risk-free 
rate used in the model is based on the applicable U.S. Treasury 
yield curve. Other significant assumptions for the awards are 
as follows:

Valuation assumptions

2019

2018

2017

Expected volatility

25.33% 24.93% 25.79%

Expected dividend yield

2.67

1.75

1.30

153

 
The following table presents information with respect to stock option activity under Citigroup’s stock option programs: 

2019

Weighted-
average
exercise
price

Options

Intrinsic
value
per share

Options

2018

Weighted-
average
exercise
price

Intrinsic
value
per share

Options

2017

Weighted-
average
exercise
price

Intrinsic
value
per share

Outstanding, beginning of
period

Canceled

Expired

Exercised

762,225 $

101.84 $

(11,365)

(449,916)

(134,294)

40.80

142.30

39.00

—

—

—

1,138,813 $ 161.96 $

—

—

(376,588)

283.63

23.50

—

—

Outstanding, end of period

166,650 $

47.42 $

32.47

762,225 $ 101.84 $

—

—

—

—

—

1,527,396 $ 131.78 $

—

—

—

—

—

—

—

(388,583)

43.35

15.67

1,138,813 $ 161.96 $

—

Exercisable, end of period

166,650

762,225

1,138,813

The following table summarizes information about stock options outstanding under Citigroup’s stock option programs at 
December 31, 2019:

Range of exercise prices

$41.54–$60.00

Total at December 31, 2019

Options outstanding

Options exercisable

Number
outstanding

Weighted-average
contractual life
remaining

Weighted-average
exercise price

Number
exercisable

Weighted-average
exercise price

166,650

166,650

1.4 years $

1.4 years $

47.42

47.42

166,650 $

166,650 $

47.42

47.42

vests, the shares delivered to the participant are freely 
transferable, unless they are subject to a restriction on sale or 
transfer for a specified period. 

All equity awards granted since April 19, 2005 have been 
made pursuant to stockholder-approved stock incentive plans 
that are administered by the Personnel and Compensation 
Committee of the Citigroup Board of Directors, which is 
composed entirely of independent non-employee directors.

At December 31, 2019, approximately 29.7 million shares 
of Citigroup common stock were authorized and available for 
grant under Citigroup’s 2019 Stock Incentive Plan, the only 
plan from which equity awards are currently granted.

The 2019 Stock Incentive Plan and predecessor plans 
permit the use of treasury stock or newly issued shares in 
connection with awards granted under the plans. Treasury 
shares were used to settle vestings from 2016 to 2019, and for 
the first quarter of 2020, except where local laws favor newly 
issued shares. The use of treasury stock or newly issued shares 
to settle stock awards does not affect the compensation 
expense recorded in the Consolidated Statement of Income for 
equity awards.

Other Variable Incentive Compensation
Citigroup has various incentive plans globally that are used to 
motivate and reward performance primarily in the areas of 
sales, operational excellence and customer satisfaction. 
Participation in these plans is generally limited to employees 
who are not eligible for discretionary annual incentive awards. 
Other forms of variable compensation include monthly 
commissions paid to financial advisors and mortgage loan 
officers.

Summary
Except for awards subject to variable accounting, the total 
expense recognized for stock awards represents the grant date 
fair value of such awards, which is generally recognized as a 
charge to income ratably over the vesting period, other than 
for awards to retirement-eligible employees and immediately 
vested awards. Whenever awards are made or are expected to 
be made to retirement-eligible employees, the charge to 
income is accelerated based on when the applicable conditions 
to retirement eligibility were or will be met. If the employee is 
retirement eligible on the grant date, or the award is vested at 
the grant date, the entire expense is recognized in the year 
prior to grant. 

Recipients of Citigroup stock awards generally do not 
have any stockholder rights until shares are delivered upon 
vesting or exercise, or after the expiration of applicable 
required holding periods. Recipients of restricted or deferred 
stock awards and deferred cash stock unit awards, however, 
may, except as prohibited by applicable regulatory guidance, 
be entitled to receive or accrue dividends or dividend-
equivalent payments during the vesting period. Recipients of 
restricted stock awards generally are entitled to vote the shares 
in their award during the vesting period. Once a stock award 

154

 
 
 
 
 
 
 
 
 
Incentive Compensation Cost
The following table shows components of compensation 
expense, relating to certain of the incentive compensation 
programs described above:

In millions of dollars

2019

2018

2017

Charges for estimated awards to
retirement-eligible employees

Amortization of deferred cash
awards, deferred cash stock units and
performance stock units

Immediately vested stock award 
expense(1)
Amortization of restricted and 
deferred stock awards(2)
Other variable incentive
compensation

$

683 $

669 $

659

355

202

354

82

404

666

75

435

640

70

474

694

Total

$ 2,190 $ 2,021 $ 2,251

(1)  Represents expense for immediately vested stock awards that generally 
were stock payments in lieu of cash compensation. The expense is 
generally accrued as cash incentive compensation in the year prior to 
grant.

(2)  All periods include amortization expense for all unvested awards to non-

retirement-eligible employees. 

155

8. RETIREMENT BENEFITS

Pension and Postretirement Plans
The Company has several non-contributory defined benefit 
pension plans covering certain U.S. employees and has various 
defined benefit pension and termination indemnity plans 
covering employees outside the U.S. 

The U.S. qualified defined benefit plan was frozen 

effective January 1, 2008 for most employees. Accordingly, no 
additional compensation-based contributions have been 
credited to the cash balance portion of the plan for existing plan 
participants after 2007. However, certain employees covered 
under the prior final pay plan formula continue to accrue 
benefits. The Company also offers postretirement health care 
and life insurance benefits to certain eligible U.S. retired 
employees, as well as to certain eligible employees outside the 
U.S.

The Company also sponsors a number of non-contributory, 

nonqualified pension plans. These plans, which are unfunded, 
provide supplemental defined pension benefits to certain U.S. 

employees. With the exception of certain employees covered 
under the prior final pay plan formula, the benefits under these 
plans were frozen in prior years.

The plan obligations, plan assets and periodic plan expense 
for the Company’s most significant pension and postretirement 
benefit plans (Significant Plans) are measured and disclosed 
quarterly, instead of annually. The Significant Plans captured 
approximately 90% of the Company’s global pension and 
postretirement plan obligations as of December 31, 2019. All 
other plans (All Other Plans) are measured annually with a 
December 31 measurement date. 

Net (Benefit) Expense
The following table summarizes the components of net 
(benefit) expense recognized in the Consolidated Statement of 
Income for the Company’s pension and postretirement plans for 
Significant Plans and All Other Plans:

Pension plans

Postretirement benefit plans

U.S. plans

Non-U.S. plans

U.S. plans

Non-U.S. plans

In millions of dollars

2019

2018

2017

2019

2018

2017

2019

2018

2017

2019

2018

2017

Benefits earned during the year

$

1 $

1 $

3 $

146 $

146 $

153 $ — $ — $ — $

8 $

9 $

9

Interest cost on benefit obligation

469

514

533

287

292

295

Expected return on plan assets

(821)

(844)

(865)

(281)

(291)

(299)

24

(18)

26

(14)

26

(6)

104

(84)

102

(88)

101

(89)

Amortization of unrecognized:

Prior service cost (benefit)

Net actuarial loss

Curtailment loss (gain)(1)
Settlement loss(1)

2

200

1

—

2

165

1

—

2

173

6

—

(4)

61

(6)

6

(4)

53

(1)

7

(3)

61

—

12

—

—

—

—

—

(1)

—

—

—

—

—

—

(10)

(10)

(10)

23

—

—

29

—

—

35

—

—

46

Total net (benefit) expense

$ (148) $ (161) $ (148) $

209 $

202 $

219 $

6 $

11 $

20 $

41 $

42 $

(1)  Curtailment and settlement relate to repositioning and divestiture actions.

Contributions
The Company’s funding practice for U.S. and non-U.S. pension 
and postretirement plans is generally to fund to minimum 
funding requirements in accordance with applicable local laws 
and regulations. The Company may increase its contributions 
above the minimum required contribution, if appropriate. In 
addition, management has the ability to change its funding 
practices. For the U.S. pension plans, there were no required 
minimum cash contributions for 2019 or 2018. 

The following table summarizes the actual Company 
contributions for the years ended December 31, 2019 and 2018, 
as well as estimated expected Company contributions for 2020. 
Expected contributions are subject to change, since contribution 
decisions are affected by various factors, such as market 
performance, tax considerations and regulatory requirements.

In millions of dollars

U.S. plans(2)
2019

2020

Pension plans(1)

Non-U.S. plans

Postretirement benefit plans(1)
U.S. plans

Non-U.S. plans

2018

2020

2019

2018

2020

2019

2018

2020

2019

2018

Contributions made by the Company

$ — $ 425 $ — $ 111 $ 111 $ 140 $ — $ — $ 145 $

4 $ 221 $

Benefits paid directly by the Company

58

56

55

53

39

42

6

4

5

6

4

3

6

(1)  Amounts reported for 2020 are expected amounts.  
(2)   The U.S. pension plans include benefits paid directly by the Company for the nonqualified pension plans. 

156

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Funded Status and Accumulated Other Comprehensive Income (AOCI)
The following table summarizes the funded status and amounts recognized in the Consolidated Balance Sheet for the Company’s 
pension and postretirement plans:

Pension plans

Postretirement benefit plans

U.S. plans

Non-U.S. plans

U.S. plans

Non-U.S. plans

In millions of dollars

2019

2018

2019

2018

2019

2018

2019

2018

Change in projected benefit obligation

Projected benefit obligation at beginning of year

$ 12,655 $ 14,040 $

7,149 $

7,433 $

662 $

699 $

1,159 $

1,261

Benefits earned during the year

Interest cost on benefit obligation

Plan amendments
Actuarial loss (gain)( 1)
Benefits paid, net of participants’ contributions and 
government subsidy(2)
Settlement gain(3)
Curtailment loss (gain)(3)
Foreign exchange impact and other

1

469

—

1

514

—

1,263

(1,056)

(936)

(845)

—

1

—

1

—

146

287

7

861

(304)

(84)

(4)

47

146

292

7

(99)

(293)

(121)

(1)

(215)

—

24

—

46

—

26

—

(1)

8

104

—

140

(40)

(62)

(72)

—

—

—

—

—

—

—

—

45

9

102

—

(123)

(68)

—

—

(22)

Projected benefit obligation at year end

$ 13,453 $ 12,655 $

8,105 $

7,149 $

692 $

662 $

1,384 $

1,159

Change in plan assets

Plan assets at fair value at beginning of year
Actual return on plan assets(1)
Company contributions

Benefits paid, net of participants’ contributions and 
government subsidy(2)
Settlement gain(3)
Foreign exchange impact and other

$ 11,490 $ 12,725 $

6,699 $

7,128 $

345 $

262 $

1,036 $

1,119

1,682

481

(445)

55

(936)

(845)

—

—

—

—

781

150

(304)

(84)

314

(11)

182

(293)

(121)

(186)

36

4

(40)

—

—

(5)

150

(62)

—

—

138

225

(72)

—

(200)

(26)

9

(68)

—

2

Plan assets at fair value at year end

$ 12,717 $ 11,490 $

7,556 $

6,699 $

345 $

345 $

1,127 $

1,036

Funded status of the plans
Qualified plans(4)
Nonqualified plans(5)
Funded status of the plans at year end

Net amount recognized
Qualified plans
Benefit asset

Benefit liability

Qualified plans

Nonqualified plans

Net amount recognized on the balance sheet

Amounts recognized in AOCI

Net transition obligation

Prior service (cost) benefit

Net actuarial (loss) gain

$

$

$

$

$

$

(23) $

(483) $

(549) $

(450) $

(347) $

(317) $

(257) $

(123)

(713)

(682)

—

—

—

—

—

—

(736) $ (1,165) $

(549) $

(450) $

(347) $

(317) $

(257) $

(123)

— $

— $

808 $

806 $

— $

— $

57 $

(23)

(483)

(1,357)

(1,256)

(347)

(317)

(314)

(23) $

(483) $

(549) $

(450) $

(347) $

(317) $

(257) $

(713)

(682)

—

—

—

—

—

175

(298)

(123)

—

(736) $ (1,165) $

(549) $

(450) $

(347) $

(317) $

(257) $

(123)

Net amount recognized in equity (pretax)
Accumulated benefit obligation at year end

$ (7,104) $ (6,905) $ (1,734) $ (1,409) $

$ 13,447 $ 12,646 $

7,618 $

6,720 $

— $

— $

— $

(1) $

— $

— $

— $

(12)

(13)

1

12

(7,092)

(6,892)

(1,735)

(1,420)

—

24

24 $

692 $

—

53

76

(416)

53 $

(340) $

—

83

(340)

(257)

662 $

1,384 $

1,159

(1)  During 2019, the actuarial loss is primarily due to the decline in global discount rates and actual return on plan assets due to favorable asset returns.
(2)  U.S. postretirement benefit plans were net of Employer Group Waiver Plan subsidy of $22 million and $15 million in 2019 and 2018, respectively.
(3)  Curtailment and settlement (gains) losses relate to repositioning and divestiture activities.
(4)  The U.S. qualified pension plan is fully funded under specified Employee Retirement Income Security Act (ERISA) funding rules as of January 1, 2020 and no 

minimum required funding is expected for 2020.
(5)  The nonqualified plans of the Company are unfunded.

157

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table shows the change in AOCI related to the Company’s pension, postretirement and post employment plans:

In millions of dollars
Beginning of year balance, net of tax(1)(2)
Actuarial assumptions changes and plan experience

Net asset gain (loss) due to difference between actual and expected returns

Net amortization

Prior service (cost) credit
Curtailment/settlement gain(3)
Foreign exchange impact and other
Impact of Tax Reform(4)
Change in deferred taxes, net

Change, net of tax
End of year balance, net of tax(1)(2)

2019

2018

2017

$

$

$

(6,257) $

(2,300)

1,427

274

(7)

1

(66)

—

119

(6,183) $

1,288

(1,732)

214

(7)

7

136

—

20

(552) $

(6,809) $

(74) $

(6,257) $

(5,164)

(760)

625

229

(4)

17

(93)

(1,020)

(13)

(1,019)

(6,183)

(1)  See Note 19 to the Consolidated Financial Statements for further discussion of net AOCI balance.
(2) 
Includes net-of-tax amounts for certain profit-sharing plans outside the U.S.
(3)  Curtailment and settlement relate to repositioning and divestiture activities.
(4) 

In the fourth quarter of 2017, Citi adopted ASU 2018-02, which transferred these amounts from AOCI to Retained earnings. See Note 1 to the Consolidated Financial 
Statements.

At December 31, 2019 and 2018, the aggregate projected benefit obligation (PBO), the aggregate accumulated benefit obligation 
(ABO) and the aggregate fair value of plan assets are presented for all defined benefit pension plans with a PBO in excess of plan assets 
and for all defined benefit pension plans with an ABO in excess of plan assets as follows:

PBO exceeds fair value of plan assets
U.S. plans(1)

Non-U.S. plans

ABO exceeds fair value of plan assets
U.S. plans(1)

Non-U.S. plans

In millions of dollars

2019

2018

2019

2018

2019

2018

2019

2018

Projected benefit obligation

$

13,453 $

12,655 $

4,445 $

3,904 $

13,453 $

12,655 $

2,748 $

Accumulated benefit obligation

Fair value of plan assets

13,447

12,717

12,646

11,490

4,041

3,089

3,528

2,648

13,447

12,717

12,646

11,490

2,435

1,429

3,718

3,387

2,478

(1)  At December 31, 2019 and 2018, for both the U.S. qualified plan and nonqualified plans, the aggregate PBO and the aggregate ABO exceeded plan assets. 

158

 
 
(3) 

In 2019 and 2018, the expected rate of return for the VEBA Trust was 
3.00%.

During the year

Discount rate

U.S. plans

Qualified pension

Nonqualified
pension

Postretirement

2019

2018

2017

4.25%/3.85%/
3.45%/3.10%

3.60%/3.95%/
4.25%/4.30%

4.10%/4.05%/
3.80%/3.75%

4.25/3.90/
3.50/3.10

4.20/3.80/
3.35/3.00

3.60/3.95/
4.25/4.30

3.50/3.90/
4.20/4.20

4.00/3.95/
3.75/3.65

3.90/3.85/
3.60/3.55

Non-U.S. pension plans(1)

Range(2)
Weighted average

4.47
Non-U.S. postretirement plans(1)

-0.05 to 12.00

0.00 to 10.75

0.25 to 72.50

4.17

4.40

Range

1.75 to 10.75

1.75 to 10.10

1.75 to 11.05

Weighted average

9.05

8.10

8.27

Future compensation increase rate(3)
Non-U.S. pension plans(1)

Range

1.30 to 13.67

1.17 to 13.67

1.25 to 70.00

Weighted average

3.16

3.08

3.21

Expected return on assets

U.S. plans

Qualified pension(4)

6.70

6.80/6.70

Postretirement(4)(5)

6.70/3.00

6.80/6.70/3.00

Non-U.S. pension plans(1)

6.80

6.80

Range

1.00 to 11.50

0.00 to 11.60

1.00 to 11.50

Weighted average

4.30
Non-U.S. postretirement plans(1)

4.52

4.55

Range

8.00 to 9.20

8.00 to 9.80

8.00 to 10.30

Weighted average

8.01

8.01

8.02

(1)  Reflects rates utilized to determine the quarterly expense for Significant 

non-U.S. pension and postretirement plans.

(2)  Due to substantial downward movement in yields, there were negative 
discount rates for plans with relatively short duration in major markets, 
such as the Eurozone and Switzerland.

(3)  Not material for U.S. plans.
(4)  The expected rate of return for the U.S. pension and postretirement plans 
was lowered from 6.80% to 6.70% effective in the second quarter of 2018 
to reflect a change in target asset allocation.
In 2017, the VEBA Trust was funded with an expected rate of return on 
assets of 3.00%.

(5) 

Plan Assumptions 
The Company utilizes a number of assumptions to determine 
plan obligations and expenses. Changes in one or a 
combination of these assumptions will have an impact on the 
Company’s pension and postretirement PBO, funded status and 
(benefit) expense. Changes in the plans’ funded status resulting 
from changes in the PBO and fair value of plan assets will have 
a corresponding impact on Accumulated other comprehensive 
income (loss). 

The actuarial assumptions at the respective years ended 
December 31 in the table below are used to measure the year-
end PBO and the net periodic (benefit) expense for the 
subsequent year (period). Since Citi’s Significant Plans are 
measured on a quarterly basis, the year-end rates for those plans 
are used to calculate the net periodic (benefit) expense for the 
subsequent year’s first quarter. 

As a result of the quarterly measurement process, the net 
periodic (benefit) expense for the Significant Plans is calculated 
at each respective quarter end based on the preceding quarter-
end rates (as shown below for the U.S. and non-U.S. pension 
and postretirement plans). The actuarial assumptions for All 
Other Plans are measured annually. 

Certain assumptions used in determining pension and 
postretirement benefit obligations and net benefit expense for 
the Company’s plans are shown in the following table:

At year end
Discount rate
U.S. plans

Qualified pension
Nonqualified pension
Postretirement

Non-U.S. pension plans

Range(1)
Weighted average

Non-U.S. postretirement plans

Range
Weighted average

2019

2018

3.25%
3.25
3.15

4.25%
4.25
4.20

-0.10 to 11.30 0.25 to 12.00

3.65

4.47

0.90 to 9.10
7.76

1.75 to 10.75
9.05

Future compensation increase rate(2)
Non-U.S. pension plans

Range
Weighted average

Expected return on assets
U.S. plans

Qualified pension
Postretirement(3)

Non-U.S. pension plans

Range
Weighted average

Non-U.S. postretirement plans

Range
Weighted average

1.50 to 11.50
3.17

1.30 to 13.67
3.16

6.70
6.70/3.00

6.70
6.70/3.00

0.00 to 11.50
3.95

1.00 to 11.50
4.30

6.20 to 8.00
7.99

8.00 to 9.20
8.01

(1)  Due to substantial downward movement in yields, there were negative 
discount rates for plans with relatively short duration in major markets, 
such as the Eurozone and Switzerland.

(2)  Not material for U.S. plans.

159

 
 
 
 
 
 
 
 
Discount Rate
The discount rates for the U.S. pension and postretirement 
plans were selected by reference to a Citigroup-specific 
analysis using each plan’s specific cash flows and compared 
with high-quality corporate bond indices for reasonableness. 
The discount rates for the non-U.S. pension and postretirement 
plans are selected by reference to high-quality corporate bond 
rates in countries that have developed corporate bond markets. 
However, where developed corporate bond markets do not 
exist, the discount rates are selected by reference to local 
government bond rates with a premium added to reflect the 
additional risk for corporate bonds in certain countries.
Effective December 31, 2019, the established rounding 
convention is to the nearest 5 bps for all countries.

Expected Rate of Return
The Company determines its assumptions for the expected rate 
of return on plan assets for its U.S. pension and postretirement 
plans using a “building block” approach, which focuses on 
ranges of anticipated rates of return for each asset class. A 
weighted average range of nominal rates is then determined 
based on target allocations to each asset class. Market 
performance over a number of earlier years is evaluated 
covering a wide range of economic conditions to determine 
whether there are sound reasons for projecting any past trends.
The Company considers the expected rate of return to be a 

long-term assessment of return expectations and does not 
anticipate changing this assumption unless there are significant 
changes in investment strategy or economic conditions. This 
contrasts with the selection of the discount rate and certain 
other assumptions, which are reconsidered annually (or 
quarterly for the Significant Plans) in accordance with GAAP.
The expected rate of return for the U.S. pension and 
postretirement plans was 6.70% at December 31, 2019 and 
2018 and 6.80% at December 31, 2017. The expected return on 
assets reflects the expected annual appreciation of the plan 
assets and reduces the Company’s annual pension expense. The 
expected return on assets is deducted from the sum of service 
cost, interest cost and other components of pension expense to 
arrive at the net pension (benefit) expense. 

The following table shows the expected rates of return 
used in determining the Company’s pension expense compared 
to the actual rate of return on plan assets during 2019, 2018 and 
2017 for the U.S. pension and postretirement plans:

 U.S. plans

2019

2018

2017

Expected rate of return
U.S. pension and
postretirement trust
VEBA trust(1)
Actual rate of return(2)
U.S. pension and
postretirement trust
VEBA trust(1)

6.70%

3.00

6.80%/6.70% 6.80%

3.00

3.00

15.20

-3.40

10.90

1.91 to 2.76

0.43 to 1.41

—

(1) 

In December 2017, the VEBA Trust was funded for postretirement 
benefits with an expected rate of return on assets of 3.00%.

(2)  Actual rates of return are presented net of fees.

For the non-U.S. pension plans, pension expense for 2019 
was reduced by the expected return of $281 million, compared 
with the actual return of $781 million. Pension expense for 
2018 and 2017 was reduced by expected returns of $291 
million and $299 million, respectively. 

Mortality Tables
At December 31, 2019, the Company adopted the Private 
Retirement Plans (PRI-2012) mortality table and the Mortality 
Projection 2019 (MP-2019) projection table for the U.S. plans.

 U.S. plans

Mortality

Pension

2019(1)

2018(2)

PRI-2012/MP-2019 RP-2014/MP-2018

Postretirement

PRI-2012/MP-2019 RP-2014/MP-2018

(1)  The PRI-2012 table is the white-collar PRI-2012 table. The MP-2019 

projection scale is projected from 2012, with convergence to 0.75% 
ultimate rate of annual improvement by 2035.

(2)  The RP-2014 table is the white-collar RP-2014 table. The MP-2018 
projection scale is projected from 2006, with convergence to 0.75%  
ultimate rate of annual improvement by 2034.

160

 
 
Sensitivities of Certain Key Assumptions
The following tables summarize the effect on pension expense: 

 Health Care Cost Trend Rate
Assumed health care cost trend rates were as follows:

Discount rate

One-percentage-point increase

In millions of dollars

2019

2018

2017

U.S. plans

Non-U.S. plans

In millions of dollars

U.S. plans

Non-U.S. plans

$

$

28 $

(19)

25 $

(22)

29

(27)

One-percentage-point decrease

2019

2018

2017

(44) $

32

(37) $

32

(44)

41

The U.S. Qualified Pension Plan was frozen in 2008, and as a 
result, most service cost has been eliminated. The pension 
expense for the U.S. Qualified Pension Plan is driven primarily 
by interest cost rather than by service cost. An increase in the 
discount rate generally increases pension expense.

For Non-U.S. Pension Plans that are not frozen (in 
countries such as Mexico, the U.K. and South Korea), there is 
more service cost. The pension expense for the Non-U.S. Plans 
is driven by both service cost and interest cost. An increase in 
the discount rate generally decreases pension expense due to 
the greater impact on service cost compared to interest cost.

Since the U.S. Qualified Pension Plan was frozen, most of 

the prospective service cost has been eliminated and the gain/
loss amortization period was changed to the life expectancy for 
inactive participants. As a result, pension expense for the U.S. 
Qualified Pension Plan is driven more by interest costs than 
service costs, and an increase in the discount rate would 
increase pension expense, while a decrease in the discount rate 
would decrease pension expense.

The following tables summarize the effect on pension 

expense:

Expected rate of return

One-percentage-point increase

In millions of dollars

2019

2018

2017

U.S. plans

Non-U.S. plans

$

(123) $

(126) $

(64)

(64)

(127)

(64)

One-percentage-point decrease

In millions of dollars

2019

2018

2017

U.S. plans

Non-U.S. plans

$

123 $

126 $

64

64

127

64

Health care cost increase rate for 
  U.S. plans

Following year
Ultimate rate to which cost increase is 
  assumed to decline
Year in which the ultimate rate is 
  reached

Health care cost increase rate for 
  Non-U.S. plans (weighted average)

2019

2018

6.75%

7.00%

5.00

2027

5.00

2027

Following year

6.85%

6.90%

Ultimate rate to which cost increase is   
  assumed to decline

Year in which the ultimate rate 
  is reached

6.85

2020

6.90

2019

Interest Crediting Rate
The Company has cash balance plans and other plans with 
promised interest crediting rates. For these plans, the interest 
crediting rates are set in line with plan rules or country 
legislation and do not change with market conditions.

Weighted average interest
crediting rate
2018

2019

2017

2.25%

1.61

3.25%

1.68

2.60%

1.74

At year end

U.S. plans

Non-U.S. plans

161

 
 
 
 
 
 
 
 
 
Plan Assets
Citigroup’s pension and postretirement plans’ asset allocations for the U.S. plans and the target allocations by asset category based on 
asset fair values, are as follows:

Asset category(1)
Equity securities(2)
Debt securities(3)

Real estate

Private equity
Other investments
Total

Target asset
allocation

U.S. pension assets
at December 31,

U.S. postretirement assets
at December 31,

2020

0–26%

35–82

0–7

0–10
0–30

2019

2018

2019

2018

17%

58

4

3
18
100%

15%

57

5

3
20
100%

17%

58

4

3
18
100%

15%

57

5

3
20
100%

(1)  Asset allocations for the U.S. plans are set by investment strategy, not by investment product. For example, private equities with an underlying investment in real 

estate are classified in the real estate asset category, not private equity.

(2)  Equity securities in the U.S. pension and postretirement plans do not include any Citigroup common stock at the end of 2019 and 2018.
(3)  The VEBA Trust for postretirement benefits are primarily invested in cash equivalents and debt securities in 2019 and 2018, respectively, and are not reflected in the 

table above.

Third-party investment managers and advisors provide 
their services to Citigroup’s U.S. pension and postretirement 
plans. Assets are rebalanced as the Company’s Pension Plan 
Investment Committee deems appropriate. Citigroup’s 
investment strategy, with respect to its assets, is to maintain a 
globally diversified investment portfolio across several asset 
classes that, when combined with Citigroup’s contributions to 

the plans, will maintain the plans’ ability to meet all required 
benefit obligations.

Citigroup’s pension and postretirement plans’ weighted-
average asset allocations for the non-U.S. plans and the actual 
ranges, and the weighted-average target allocations by asset 
category based on asset fair values, are as follows:

Asset category(1)

Equity securities

Debt securities

Real estate

Other investments

Total

Non-U.S. pension plans

Target asset
allocation

Actual range
at December 31,

2020

0–100%

0–100

0–15

0–100

2019

0–100%

0–100

0–15

0–100

2018

0–66%

0–100

0–12

0–100

Weighted-average
at December 31,

2019

2018

13%

80

1

6

13%

80

1

6

100%

100%

(1)  Similar to the U.S. plans, asset allocations for certain non-U.S. plans are set by investment strategy, not by investment product. 

Asset category(1)

Equity securities

Debt securities

Other investments

Total

Target asset
allocation
2020

0–38%

56–100

0–6

Non-U.S. postretirement plans

Actual range
at December 31,

2019

0–31%

66–100

0–3

2018

0–35%

62–100

0–3

Weighted-average
at December 31,

2019

2018

27%

71

2

100%

35%

62

3

100%

(1)  Similar to the U.S. plans, asset allocations for certain non-U.S. plans are set by investment strategy, not by investment product. 

162

 
 
 
 
 
 
Fair Value Disclosure
For information on fair value measurements, including 
descriptions of Levels 1, 2 and 3 of the fair value hierarchy and 
the valuation methodology utilized by the Company, see Notes 
1 and 24 to the Consolidated Financial Statements. ASU 
2015-07 removed the requirement to categorize within the fair 
value hierarchy investments for which fair value is measured 
using the NAV per share practical expedient.

In millions of dollars

Asset categories
U.S. equities

Non-U.S. equities

Mutual funds and other registered investment companies

Commingled funds

Debt securities

Annuity contracts

Derivatives

Other investments

Total investments

Cash and short-term investments

Other investment liabilities

Net investments at fair value

Other investment receivables redeemed at NAV

Securities valued at NAV

Total net assets

Certain investments may transfer between the fair value 

hierarchy classifications during the year due to changes in 
valuation methodology and pricing sources. 

Plan assets by detailed asset categories and the fair value 

hierarchy are as follows:

U.S. pension and postretirement benefit plans(1)

Fair value measurement at December 31, 2019

Level 1

Level 2

Level 3

Total

$

739 $

553

280

—

1,534

—

10

—

3,116 $

93 $

(87)

3,122 $

$

$

$

— $

—

—

1,410

4,046

—

245

—

5,701 $

1,080 $

(249)

6,532 $

— $

—

—

—

—

1

—

75

76 $

— $

—

76 $

$

$

739

553

280

1,410

5,580

1

255

75

8,893

1,173

(336)

9,730

22

3,310

13,062

(1)  The investments of the U.S. pension and postretirement plans are commingled in one trust. At December 31, 2019, the allocable interests of the U.S. pension and 

postretirement plans were 98.0% and 2.0%, respectively. The investments of the VEBA Trust for postretirement benefits are reflected in the above table.

In millions of dollars

Asset categories
U.S. equities

Non-U.S. equities

Mutual funds and other registered investment companies

Commingled funds

Debt securities

Annuity contracts

Derivatives

Other investments

Total investments

Cash and short-term investments

Other investment liabilities

Net investments at fair value

Other investment receivables redeemed at NAV

Securities valued at NAV 

Total net assets

U.S. pension and postretirement benefit plans(1)

Fair value measurement at December 31, 2018

Level 1

Level 2

Level 3

Total

$

625 $

481

215

—

1,346

—

16

—

2,683 $

93 $

(100)

2,676 $

$

$

$

— $

—

—

1,344

3,443

—

252

—

5,039 $

897 $

(254)

5,682 $

— $

—

—

—

—

1

—

127

128 $

— $

—

128 $

$

$

625

481

215

1,344

4,789

1

268

127

7,850

990

(354)

8,486

80

3,269

11,835

(1)  The investments of the U.S. pension and postretirement plans are commingled in one trust. At December 31, 2018, the allocable interests of the U.S. pension and 

postretirement plans were 98.0% and 2.0%, respectively. The investments of the VEBA Trust for postretirement benefits are reflected in the above table.

163

In millions of dollars

Asset categories

U.S. equities

Non-U.S. equities

Mutual funds and other registered investment companies

Commingled funds

Debt securities

Real estate

Annuity contracts

Derivatives

Other investments

Total investments

Cash and short-term investments

Other investment liabilities

Net investments at fair value

Securities valued at NAV 

Total net assets

In millions of dollars

Asset categories

U.S. equities

Non-U.S. equities
Mutual funds and other registered investment companies

Commingled funds

Debt securities

Real estate

Annuity contracts

Derivatives

Other investments

Total investments

Cash and short-term investments

Other investment liabilities

Net investments at fair value

Securities valued at NAV 

Total net assets

Non-U.S. pension and postretirement benefit plans

Fair value measurement at December 31, 2019

Level 1

Level 2

Level 3

Total

$

4 $

12 $

— $

127

3,223

23

4,307

—

—

—

1

7,685 $

86 $

(3)

7,768 $

262

63

—

1,615

3

—

1,590

—

3,545 $

3 $

(2,938)

610 $

—

—

—

10

1

5

—

274

290 $

— $

—

290 $

$

$

16

389

3,286

23

5,932

4

5

1,590

275

11,520

89

(2,941)

8,668

15

8,683

Non-U.S. pension and postretirement benefit plans

Fair value measurement at December 31, 2018

Level 1

Level 2

Level 3

Total

4 $

9 $

— $

100

2,887

21

5,145

—

—

—

1

8,158 $

91 $

(1)

8,248 $

100

63

—

1,500

3

1

156

—

1,832 $

3 $

(2,589)

(754) $

—

—

—

9

1

10

—

210

230 $

— $

—

230 $

$

$

13

200

2,950

21

6,654

4

11

156

211

10,220

94

(2,590)

7,724

11

7,735

$

$

$

$

$

$

$

164

 
Level 3 Rollforward
The reconciliations of the beginning and ending balances during the year for Level 3 assets are as follows:

In millions of dollars

U.S. pension and postretirement benefit plans

Asset categories

Annuity contracts

Other investments

Total investments

Beginning Level 
3 fair value at 
Dec. 31, 2018

Realized (losses) Unrealized gains

Purchases,
sales and
issuances

Transfers in and/
or out of Level 3

Ending Level 3
fair value at Dec.
31, 2019

$

$

1 $

127

128 $

— $

(7)

(7) $

— $

12

12 $

— $

(57)

(57) $

— $

—

— $

1

75

76

In millions of dollars

U.S. pension and postretirement benefit plans

Asset categories

Annuity contracts

Other investments

Total investments

Beginning Level 3 
fair value at 
Dec. 31, 2017

Realized (losses)

Unrealized
(losses)

Purchases,
sales and
issuances

Transfers in and/
or out of Level 3

Ending Level 3
fair value at Dec.
31, 2018

$

$

1 $

148

149 $

— $

(2)

(2) $

— $

(18)

(18) $

— $

(1)

(1) $

— $

—

— $

1

127

128

 In millions of dollars

Non-U.S. pension and postretirement benefit plans

Beginning Level 3 
fair value at 
Dec. 31, 2018

Unrealized gains

Purchases, sales and
issuances

Transfers in and/
or out of Level 3

Ending Level 3 fair
value at Dec. 31,
2019

Asset categories

Debt securities

Real estate

Annuity contracts

Other investments

Total investments

$

$

9 $

1

10

210

230 $

1 $

—

—

7

8 $

— $

—

(5)

57

52 $

 In millions of dollars

Non-U.S. pension and postretirement benefit plans

Asset categories

Non-U.S. equities

Debt securities

Real estate

Annuity contracts

Other investments

Total investments

Beginning Level 3
fair value at
Dec. 31, 2017

Unrealized (losses)

Purchases, sales and
issuances

Transfers in and/
or out of Level 3

$

$

1 $

7

1

9

214

232 $

— $

(1)

—

(1)

(3)

(5) $

— $

3

—

1

(1)

3 $

165

— $

—

—

—

— $

(1) $

—

—

1

—

— $

10

1

5

274

290

Ending Level 3 fair 
value at 
Dec. 31, 2018

—

9

1

10

210

230

 
 
 
Investment Strategy
The Company’s global pension and postretirement funds’ 
investment strategy is to invest in a prudent manner for the 
exclusive purpose of providing benefits to participants. The 
investment strategies are targeted to produce a total return that, 
when combined with the Company’s contributions to the funds, 
will maintain the funds’ ability to meet all required benefit 
obligations. Risk is controlled through diversification of asset 
types and investments in domestic and international equities, 
fixed income securities and cash and short-term investments. 
The target asset allocation in most locations outside the U.S. is 
primarily in equity and debt securities. These allocations may 
vary by geographic region and country depending on the nature 
of applicable obligations and various other regional 
considerations. The wide variation in the actual range of plan 
asset allocations for the funded non-U.S. plans is a result of 
differing local statutory requirements and economic conditions. 
For example, in certain countries local law requires that all 
pension plan assets must be invested in fixed income 
investments, government funds or local-country securities.

Significant Concentrations of Risk in Plan Assets
The assets of the Company’s pension plans are diversified to 
limit the impact of any individual investment. The U.S. 
qualified pension plan is diversified across multiple asset 
classes, with publicly traded fixed income, hedge funds, 
publicly traded equity and real estate representing the most 
significant asset allocations. Investments in these four asset 
classes are further diversified across funds, managers, 
strategies, vintages, sectors and geographies, depending on the 
specific characteristics of each asset class. The pension assets 
for the Company’s non-U.S. Significant Plans are primarily 
invested in publicly traded fixed income and publicly traded 
equity securities.

Oversight and Risk Management Practices
The framework for the Company’s pension oversight process 
includes monitoring of retirement plans by plan fiduciaries and/
or management at the global, regional or country level, as 
appropriate. Independent Risk Management contributes to the 
risk oversight and monitoring for the Company’s U.S. qualified 
pension plan and non-U.S. Significant Pension Plans. Although 
the specific components of the oversight process are tailored to 
the requirements of each region, country and plan, the 
following elements are common to the Company’s monitoring 
and risk management process:

• 

• 
• 

• 

• 

periodic asset/liability management studies and strategic 
asset allocation reviews;
periodic monitoring of funding levels and funding ratios;
periodic monitoring of compliance with asset allocation 
guidelines;
periodic monitoring of asset class and/or investment 
manager performance against benchmarks; and
periodic risk capital analysis and stress testing.

Estimated Future Benefit Payments 
The Company expects to pay the following estimated benefit 
payments in future years:

Pension plans
Non-
U.S. plans

U.S.
plans

Postretirement
benefit plans

U.S.
plans

Non-
U.S. plans

$

821 $

476 $

64 $

840

851

866

873

434

464

480

495

63

61

59

57

75

80

85

91

97

In millions of dollars

2020

2021

2022

2023

2024

2025–2029

4,282

2,651

244

567

166

 
 
 
Defined Contribution Plans
The Company sponsors defined contribution plans in the U.S. 
and in certain non-U.S. locations, all of which are administered 
in accordance with local laws. The most significant defined 
contribution plan is the Citi Retirement Savings Plan (formerly 
known as the Citigroup 401(k) Plan) sponsored by the 
Company in the U.S.

Under the Citi Retirement Savings Plan, eligible U.S. 
employees received matching contributions of up to 6% of their 
eligible compensation for 2019 and 2018, subject to statutory 
limits. In addition, for eligible employees whose eligible 
compensation is $100,000 or less, a fixed contribution of up to 
2% of eligible compensation is provided. All Company 
contributions are invested according to participants’ individual 
elections. The following tables summarize the Company 
contributions for the defined contribution plans:

In millions of dollars

2019

2018

2017

Company contributions

$

404 $

396 $

383

U.S. plans

In millions of dollars

2019

2018

2017

Company contributions

$

281 $

283 $

270

Non-U.S. plans

Post Employment Plans
The Company sponsors U.S. post employment plans that 
provide income continuation and health and welfare benefits to 
certain eligible U.S. employees on long-term disability.

As of December 31, 2019 and 2018, the plans’ funded 
status recognized in the Company’s Consolidated Balance 
Sheet was $(38) million and $(32) million, respectively. The 
pretax amounts recognized in AOCI as of December 31, 2019 
and 2018 were $(15) million and $(15) million, respectively. 
The following table summarizes the components of net 

expense recognized in the Consolidated Statement of Income 
for the Company’s U.S. post employment plans:

In millions of dollars
Service-related expense

Interest cost on benefit
obligation

Expected return on plan
assets
Amortization of
unrecognized:

   Prior service cost

   Net actuarial loss

Total service-related
(benefit) expense

Non-service-related expense
(benefit)

Total net expense (benefit)

Net expense
2018

2019

2017

$

2 $

2 $

(1)

(1)

—

2

3 $

6 $

9 $

(23)

2

(20) $

2 $

(18) $

$

$

$

2

—

(31)

2

(27)

30

3

The following table summarizes certain assumptions used 
in determining the post employment benefit obligations and net 
benefit expense for the Company’s U.S. post employment 
plans: 

Discount rate

Expected return on assets

Health care cost increase rate

Following year

Ultimate rate to which cost increase is
assumed to decline

Year in which the ultimate rate is reached

2019

2018

2.90% 3.95%

3.00

3.00

6.75

7.00

5.00

2027

5.00

2027

167

 
 
 
 
 
 
 
 
9. INCOME TAXES

Income Tax Provision
Details of the Company’s income tax provision are presented 
below: 

In millions of dollars

2019

2018

2017

Tax Rate
The reconciliation of the federal statutory income tax rate to 
the Company’s effective income tax rate applicable to income 
from continuing operations (before noncontrolling interests 
and the cumulative effect of accounting changes) for each of 
the periods indicated is as follows:

Current

Federal

Non-U.S.

State

$

365 $

834 $

332

4,352

4,290

3,910

323

284

269

Total current income taxes

$ 5,040 $ 5,408 $ 4,511

Deferred

Federal

Non-U.S.

State

$ (907) $ (620) $24,902

10

287

371

198

(377)

352

Total deferred income taxes

$ (610) $

(51) $24,877

Federal statutory rate

State income taxes, net of federal
benefit
Non-U.S. income tax rate differential
Effect of tax law changes(1)
Basis difference in affiliates
Tax advantaged investments
Valuation allowance releases(2)
Other, net
Effective income tax rate

2018

2019
21.0% 21.0% 35.0%

2017

1.8
1.1
1.9
1.3
5.3
(1.6)
(0.5)
(0.6)
99.7
(0.1)
(2.4)
(2.1)
(2.3)
(2.0)
(2.2)
(3.0)
—
—
0.2
(0.8)
(0.3)
18.5% 22.8% 129.1%

$ 4,430 $ 5,357 $29,388

(27)

(18)

7

(1)  2018 includes one-time Tax Reform benefits of $94 million for amounts 
that were considered provisional pursuant to SAB 118. 2017 includes the 
one-time $22,594 million charge for Tax Reform.

(2)  See the Deferred Tax Assets section below for a description of the 

components.

Provision for income tax on 
continuing operations before 
noncontrolling interests(1)
Provision (benefit) for income taxes
on discontinued operations

Income tax expense (benefit) reported
in stockholders’ equity related to:

FX translation

Investment securities

Employee stock plans

Cash flow hedges

Benefit plans

FVO DVA

Excluded fair value hedges
Retained earnings(2)

(11)

648

(16)

269

(119)

(337)

8

46

(263)

(346)

(2)

(8)

(20)

302

(17)

188

(149)

(4)

(12)

13

(250)

—

(305)

(295)

Income taxes before noncontrolling
interests

$ 4,891 $ 4,680 $28,886

(1) 

Includes the tax on realized investment gains and other-than-temporary-
impairment losses resulting in a provision (benefit) of $373 million and 
$(9) million in 2019, $104 million and $(32) million in 2018 and $272 
million and $(22) million in 2017, respectively.

(2)  2019 reflects the tax effect of the accounting change for ASU 2016-02. 
2018 reflects the tax effect of the accounting change for ASU 2016-16 
and the tax effect of the accounting change for ASU 2018-03, to report 
the net unrealized gains on former AFS equity securities. 2017 reflects 
the tax effect of the accounting change for ASU 2017-08. See Note 1 to 
the Consolidated Financial Statements.  

As set forth in the table above, Citi’s effective tax rate for 
2019 was 18.5%. The rate is lower than the 22.8% reported in 
2018, primarily due to the general basket FTC valuation 
allowance release.

Deferred Income Taxes
Deferred income taxes at December 31 related to the 
following:

In millions of dollars
Deferred tax assets
Credit loss deduction
Deferred compensation and employee benefits
Repositioning and settlement reserves
U.S. tax on non-U.S. earnings
Investment and loan basis differences
Tax credit and net operating loss carry-forwards
Fixed assets and leases
Other deferred tax assets
Gross deferred tax assets
Valuation allowance
Deferred tax assets after valuation allowance
Deferred tax liabilities
Intangibles and leases
Debt issuances
Non-U.S. withholding taxes
Interest-related items
Other deferred tax liabilities
Gross deferred tax liabilities
Net deferred tax assets

2019

2018

2,224
345
1,030
2,727
19,711
2,607
2,996

$ 3,809 $ 3,419
1,975
428
2,080
4,891
20,759
1,006
2,385
$35,449 $36,943
$ 6,476 $ 9,258
$28,973 $27,685

(201)
(974)
(587)
(1,477)

$ (2,640) $ (1,284)
(530)
(1,040)
(594)
(1,334)
$ (5,879) $ (4,782)
$23,094 $22,903

168

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Unrecognized Tax Benefits
The following is a rollforward of the Company’s unrecognized 
tax benefits:

In millions of dollars

2019

2018

2017

Total unrecognized tax benefits at
January 1

Net amount of increases for current
year’s tax positions

Gross amount of increases for prior
years’ tax positions

Gross amount of decreases for prior
years’ tax positions

Amounts of decreases relating to
settlements

Reductions due to lapse of statutes of
limitation

Foreign exchange, acquisitions and
dispositions

Total unrecognized tax benefits at
December 31

$

607 $ 1,013 $ 1,092

50

151

40

46

43

324

(44)

(174)

(246)

(21)

(283)

(199)

(23)

(23)

(11)

1

(12)

10

$

721 $

607 $ 1,013

In millions of dollars

The total amounts of unrecognized tax benefits at 

December 31, 2019, 2018 and 2017 that, if recognized, would 
affect Citi’s tax expense are $0.6 billion, $0.4 billion and $0.8 
billion, respectively. The remaining uncertain tax positions 
have offsetting amounts in other jurisdictions or are temporary 
differences.

Interest and penalties (not included in “unrecognized tax 

benefits” above) are a component of Provision for income 
taxes. 

2019

2018
Pretax Net of tax Pretax Net of tax Pretax Net of tax

2017

Total interest and penalties on the Consolidated Balance Sheet at January 1

$

103 $

85 $ 121 $

101 $ 260 $

Total interest and penalties in the Consolidated Statement of Income
Total interest and penalties on the Consolidated Balance Sheet at December 31(1)

(4)

100

(4)

82

6

103

6

85

5

121

164

21

101

(1) 

Includes $3 million, $2 million and $3 million for non-U.S. penalties in 2019, 2018 and 2017. Also includes $1 million, $1 million and $3 million for state 
penalties in 2019, 2018 and 2017.

As of December 31, 2019, Citi was under audit by the 
Internal Revenue Service and other major taxing jurisdictions 
around the world. It is thus reasonably possible that significant 
changes in the gross balance of unrecognized tax benefits may 
occur within the next 12 months, although Citi does not expect 
such audits to result in amounts that would cause a significant 
change to its effective tax rate.

The following are the major tax jurisdictions in which the 

Company and its affiliates operate and the earliest tax year 
subject to examination:

Jurisdiction
United States
Mexico
New York State and City
United Kingdom
India
Singapore
Hong Kong
Ireland

Tax year
2016
2014
2009
2015
2016
2011
2013
2015

169

Non-U.S. Earnings
Non-U.S. pretax earnings approximated $16.7 billion in 2019, 
$16.1 billion in 2018 and $13.7 billion in 2017. As a U.S. 
corporation, Citigroup and its U.S. subsidiaries are currently 
subject to U.S. taxation on all non-U.S. pretax earnings of 
non-U.S. branches. Beginning in 2018, there is a separate 
foreign tax credit (FTC) basket for branches. Also, dividends 
from a non-U.S. subsidiary or affiliate are effectively exempt 
from U.S. taxation. The Company provides income taxes on 
the book over tax basis differences of non-U.S. subsidiaries 
except to the extent that such differences are indefinitely 
reinvested outside the U.S.

At December 31, 2019, $10.9 billion of basis differences 

of non-U.S. entities was indefinitely invested compared to 
$15.5 billion at December 31, 2018. At the existing tax rates, 
additional taxes (net of U.S. FTCs) of $4.1 billion would have 
to be provided if such assertions were reversed. The decrease 
of $4.6 billion in basis differences from the prior year end was 
primarily due to a tax election to treat a contiguous country 
affiliate as a branch rather than a subsidiary.

Income taxes are not provided for the Company’s 
“savings bank base year bad debt reserves” that arose before 
1988, because under current U.S. tax rules, such taxes will 
become payable only to the extent that such amounts are 
distributed in excess of limits prescribed by federal law. At 
December 31, 2019, the amount of the base year reserves 

 
In billions of dollars

Jurisdiction/component(1)
U.S. federal(2)
Net operating losses (NOLs)(3)
Foreign tax credits (FTCs)

General business credits (GBCs)

Future tax deductions and credits

Total U.S. federal

State and local

New York NOLs

Other state NOLs

Future tax deductions

Total state and local

Non-U.S.

NOLs

Future tax deductions

Total non-U.S.

Total

DTAs balance
December 31,
2019

DTAs balance
December 31,
2018

$

$

$

$

$

$

$

2.8 $

6.3

2.5

6.2

17.8 $

1.7 $

0.2

1.3

3.2 $

0.5 $

1.6

2.1 $

23.1 $

2.6

6.8

1.0

6.7

17.1

2.0

0.2

1.4

3.6

0.6

1.6

2.2

22.9

(1)  All amounts are net of valuation allowances.
(2) 

Included in the net U.S. federal DTAs of $17.8 billion as of December 
31, 2019 were deferred tax liabilities of $3.4 billion that will reverse in 
the relevant carry-forward period and may be used to support the DTAs.

(3)  Consists of non-consolidated tax return NOL carry-forwards that are 

eventually expected to be utilized in Citigroup’s consolidated tax return. 

totaled approximately $358 million (subject to a tax of $75 
million).

Deferred Tax Assets
As of December 31, 2019, Citi had a valuation allowance of 
$6.5 billion, composed of valuation allowances of $4.6 billion 
on its FTC carry-forwards, $0.8 billion on its U.S. residual 
DTA related to its non-U.S. branches, $1.0 billion on local 
non-U.S. DTAs and $0.1 billion on state net operating loss 
carry-forwards. The valuation allowance against FTCs results 
from the impact of the lower tax rate and the new separate 
FTC basket for non-U.S. branches. The absolute amount of 
Citi’s post-Tax Reform-related valuation allowances may 
change in future years. First, the separate FTC basket for non-
U.S. branches may result in additional DTAs (for FTCs) 
requiring a valuation allowance, given that the local tax rate 
for these branches exceeds on average the U.S. tax rate of 
21%, offset by expirations of carry-forwards. The valuation 
allowance for the branch basket FTCs was reduced from $4.4 
billion to $3.5 billion, primarily as a result of the expiration of 
the 2009 FTC carry-forward.

Second, in Citi’s general basket for FTCs, changes in the 

forecasted amount of income in U.S. locations derived from 
sources outside the U.S., as well as actions that Citi may be 
able to take to enhance such income, in addition to tax 
examination changes from prior years, could alter the amount 
of valuation allowance that is needed against such FTCs. The 
valuation allowance for the general basket decreased from 
$1.6 billion to $1.1 billion. The decrease consists of the 
following items. Citi committed to a plan to move a financing 
business involving non-U.S. clients and its associated  funding 
to the U.S. The incremental foreign source income generated 
by this action over time will more-likely-than-not enable 
usage of FTC carry-forwards of $0.2 billion. In addition, Citi 
committed to a plan as part of the Company’s liquidity 
management program, to increase its ownership of certain 
types of non-U.S. securities and to hold such securities in its 
U.S. operations. The incremental foreign source income 
generated by this action will more-likely-than-not enable the 
usage of FTC carry-forwards of another $0.2 billion. The 
remainder of the decrease in the valuation allowance in the 
general basket was the result of other increases in foreign 
source income of $0.3 billion (of which $0.2 billion is 
considered discrete and $0.1 billion is related to changes in 
2019 foreign source income), partially offset by an increase of 
$0.2 billion relating to prior years’ tax return adjustments that 
increased FTCs and the corresponding valuation allowance. 
The valuation allowance for U.S. residual DTA related to its 
non-U.S. branches decreased from $1.7 billion to $0.8 billion 
primarily due to a tax election to convert a contiguous country 
subsidiary into a branch, which resulted in $0.9 billion of U.S. 
DTLs offsetting non-U.S local DTAs. In addition, the non-
U.S. local valuation allowance was reduced from $1.5 billion 
to $1.0 billion, primarily due to an expiration of NOL carry-
forwards in a non-U.S. jurisdiction. The following table 
summarizes Citi’s DTAs:

170

 
 
 
 
 
 
 
The time remaining for utilization of the FTC component 
has shortened, given the passage of time. Although realization 
is not assured, Citi believes that the realization of the 
recognized net DTAs of $23.1 billion at December 31, 2019 is 
more-likely-than-not, based upon expectations as to future 
taxable income in the jurisdictions in which the DTAs arise 
and consideration of available tax planning strategies (as 
defined in ASC 740, Income Taxes).

Citi believes the U.S. federal and New York State and 
City NOL carry-forward period of 20 years provides enough 
time to fully utilize the DTAs pertaining to the existing NOL 
carry-forwards. This is due to Citi’s forecast of sufficient U.S. 
taxable income and the fact that New York State and City 
continue to tax Citi’s non-U.S. income.

With respect to the FTCs component of the DTAs, the 

carry-forward period is 10 years. Utilization of FTCs in any 
year is generally limited to 21% of foreign source taxable 
income in that year. However, overall domestic losses that Citi 
has incurred of approximately $39 billion as of December 31, 
2019 are allowed to be reclassified as foreign source income 
to the extent of 50%–100% (at taxpayer’s election) of 
domestic source income produced in subsequent years. Such 
resulting foreign source income would substantially cover the 
FTC carry-forwards after valuation allowance. As noted in the 
tables above, Citi’s FTC carry-forwards were $6.3 billion 
($10.9 billion before valuation allowance) as of December 31, 
2019, compared to $6.8 billion as of December 31, 2018. Citi 
believes that it will generate sufficient U.S. taxable income 
within the 10-year carry-forward period to be able to utilize 
the net FTCs after the valuation allowance, after considering 
any FTCs produced in the tax return for such period, which 
must be used prior to any carry-forward utilization. 

The following table summarizes the amounts of tax carry-

forwards and their expiration dates: 

In billions of dollars

Year of expiration

U.S. tax return general basket foreign 
tax credit carry-forwards(1)
2020
2021
2022
2023
2025
2027
Total U.S. tax return general basket
foreign tax credit carry-forwards

U.S. tax return branch basket foreign 
tax credit carry-forwards(1)
2019
2020
2021
2022
2028
2029
Total U.S. tax return branch basket
foreign tax credit carry-forwards
U.S. tax return general business credit
carry-forwards
2033
2034
2035
2036
2037
2038
2039
Total U.S. tax return general business
credit carry-forwards
U.S. subsidiary separate federal NOL
carry-forwards
2027
2028
2030
2032
2033
2034
2035
2036
2037
Unlimited carry-forward period
Total U.S. subsidiary separate federal 
NOL carry-forwards(2)
New York State NOL carry-forwards(2)
2034
New York City NOL carry-forwards(2)
2034
Non-U.S. NOL carry-forwards(1)
Various

(1)  Before valuation allowance.
(2)  Pretax.

December
31, 2019

December
31, 2018

$

$

$

$

$

$

$

$

$

$

$

0.9 $
1.1
2.4
0.4
1.4
1.2

7.4 $

— $
0.7
0.6
1.0
0.9
0.3

3.5 $

0.3 $
0.2
0.2
0.1
0.5
0.5
0.7

2.5 $

0.1 $
0.1
0.3
—
1.6
2.0
3.3
2.1
1.0
3.0

2.0
1.1
2.4
0.4
1.4
1.1

8.4

0.9
0.6
0.7
0.9
1.3
—

4.4

—
—
—
0.1
0.4
0.5
—

1.0

0.2
0.1
0.3
0.1
1.6
2.1
3.3
2.1
1.0
1.7

13.5 $

12.5

9.9 $

11.7

10.0 $

11.5

1.5 $

2.0

171

 
 
 
 
 
 
 
 
 
 
 
 
10.     EARNINGS PER SHARE

The following table reconciles the income and share data used in the basic and diluted earnings per share (EPS) computations:

In millions of dollars, except per share amounts

Earnings per common share

Income from continuing operations before attribution of noncontrolling interests

Less: Noncontrolling interests from continuing operations

Net income from continuing operations (for EPS purposes)

Loss from discontinued operations, net of taxes

Citigroup's net income
Less: Preferred dividends(1)
Net income available to common shareholders

Less: Dividends and undistributed earnings allocated to employee restricted and deferred shares 
  with rights to dividends, applicable to basic EPS

Net income allocated to common shareholders for basic EPS

Weighted-average common shares outstanding applicable to basic EPS (in millions)
Basic earnings per share(2)
Income from continuing operations

Discontinued operations

Net income per share—basic

Diluted earnings per share

Net income allocated to common shareholders for basic EPS

Add back: Dividends allocated to employee restricted and deferred shares with rights to dividends 
  that are forfeitable

Net income allocated to common shareholders for diluted EPS

Weighted-average common shares outstanding applicable to basic EPS (in millions)

Effect of dilutive securities
   Options(3)
   Other employee plans
Adjusted weighted-average common shares outstanding applicable to diluted EPS (in millions)(4)
Diluted earnings per share(2)
Income from continuing operations

Discontinued operations

Net income per share—diluted

2019

2018

2017

$

$

$

$

19,471 $

18,088 $

(6,627)

66

35

60

19,405 $

18,053 $

(6,687)

(4)

(8)

(111)

19,401 $

18,045 $

(6,798)

1,109

1,174

1,213

18,292 $

16,871 $

(8,011)

121

200

37

$

18,171 $

16,671 $

(8,048)

2,249.2

2,493.3

2,698.5

$

$

$

$

$

$

$

8.08 $

6.69 $

—

—

8.08 $

6.69 $

(2.94)

(0.04)

(2.98)

18,171 $

16,671 $

(8,048)

33

—

—

18,204 $

16,671 $

(8,048)

2,249.2 $

2,493.3 $

2,698.5

0.1

16.0

0.1

1.4

—

—

2,265.3

2,494.8

2,698.5

8.04 $

6.69 $

—

—

8.04 $

6.68 $

(2.94)

(0.04)

(2.98)

(1)  See Note 20 to the Consolidated Financial Statements for the potential future impact of preferred stock dividends.
(2)  Due to rounding, earnings per share on continuing operations and discontinued operations may not sum to earnings per share on net income.
(3)  During 2019, no significant options to purchase shares of common stock were outstanding. During 2018 and 2017, weighted-average options to purchase 0.5 

million and 0.8 million shares of common stock, respectively, were outstanding but not included in the computation of earnings per share because the weighted-
average exercise prices of $145.69 and $204.80 per share, respectively, were anti-dilutive.

(4)  Due to rounding, common shares outstanding applicable to basic EPS and the effect of dilutive securities may not sum to common shares outstanding applicable to 

diluted EPS.

172

   
 
   
  
11. SECURITIES BORROWED, LOANED AND 
SUBJECT TO REPURCHASE AGREEMENTS

Securities borrowed and purchased under agreements to 
resell, at their respective carrying values, consisted of the 
following:

In millions of dollars

Securities purchased under
agreements to resell

Deposits paid for securities
borrowed
Total(1)

December 31, December 31,

2019

2018

$

$

169,874 $

159,364

81,448

251,322 $

111,320

270,684

Securities loaned and sold under agreements to 

repurchase, at their respective carrying values, consisted of the 
following:

December 31, December 31,

In millions of dollars

2019

2018

Securities sold under agreements
to repurchase

Deposits received for securities
loaned
Total(1)

$

$

155,164 $

166,090

11,175

11,678

166,339 $

177,768

(1)   The above tables do not include securities-for-securities lending 

transactions of $6.3 billion and $15.9 billion at December 31, 2019 and 
2018, respectively, where the Company acts as lender and receives 
securities that can be sold or pledged as collateral. In these transactions, 
the Company recognizes the securities received at fair value within 
Other assets and the obligation to return those securities as a liability 
within Brokerage payables. 

The resale and repurchase agreements represent 
collateralized financing transactions. Citi executes these 
transactions primarily through its broker-dealer subsidiaries to 
facilitate customer matched-book activity and to efficiently 
fund a portion of Citi’s trading inventory. Transactions 
executed by Citi’s bank subsidiaries primarily facilitate 
customer financing activity.

To maintain reliable funding under a wide range of market 

conditions, including under periods of stress, Citi manages 
these activities by taking into consideration the quality of the 
underlying collateral and stipulating financing tenor. Citi 
manages the risks in its collateralized financing transactions 
by conducting daily stress tests to account for changes in 
capacity, tenors, haircut, collateral profile and client actions. 
In addition, Citi maintains counterparty diversification by 
establishing concentration triggers and assessing counterparty 
reliability and stability under stress.

It is the Company’s policy to take possession of the 
underlying collateral, monitor its market value relative to the 
amounts due under the agreements and, when necessary, 
require prompt transfer of additional collateral in order to 
maintain contractual margin protection. For resale and 
repurchase agreements, when necessary, the Company posts 
additional collateral in order to maintain contractual margin 
protection. 

173

Collateral typically consists of government and 

government-agency securities, corporate and municipal bonds, 
equities and mortgage- and other asset-backed securities.
The resale and repurchase agreements are generally 
documented under industry standard agreements that allow the 
prompt close-out of all transactions (including the liquidation 
of securities held) and the offsetting of obligations to return 
cash or securities by the non-defaulting party, following a 
payment default or other type of default under the relevant 
master agreement. Events of default generally include 
(i) failure to deliver cash or securities as required under the 
transaction, (ii) failure to provide or return cash or securities 
as used for margining purposes, (iii) breach of representation, 
(iv) cross-default to another transaction entered into among 
the parties, or, in some cases, their affiliates and (v) a 
repudiation of obligations under the agreement. The 
counterparty that receives the securities in these transactions is 
generally unrestricted in its use of the securities, with the 
exception of transactions executed on a tri-party basis, where 
the collateral is maintained by a custodian and operational 
limitations may restrict its use of the securities.

A substantial portion of the resale and repurchase 

agreements is recorded at fair value, as described in Notes 24 
and 25 to the Consolidated Financial Statements. The 
remaining portion is carried at the amount of cash initially 
advanced or received, plus accrued interest, as specified in the 
respective agreements.

The securities borrowing and lending agreements also 
represent collateralized financing transactions similar to the 
resale and repurchase agreements. Collateral typically consists 
of government and government-agency securities and 
corporate debt and equity securities.

Similar to the resale and repurchase agreements, securities 

borrowing and lending agreements are generally documented 
under industry standard agreements that allow the prompt 
close-out of all transactions (including the liquidation of 
securities held) and the offsetting of obligations to return cash 
or securities by the non-defaulting party, following a payment 
default or other default by the other party under the relevant 
master agreement. Events of default and rights to use 
securities under the securities borrowing and lending 
agreements are similar to the resale and repurchase 
agreements referenced above.

A substantial portion of securities borrowing and lending 

agreements is recorded at the amount of cash advanced or 
received. The remaining portion is recorded at fair value as the 
Company elected the fair value option for certain securities 
borrowed and loaned portfolios, as described in Note 25 to the 
Consolidated Financial Statements. With respect to securities 
loaned, the Company receives cash collateral in an amount 
generally in excess of the market value of the securities 
loaned. The Company monitors the market value of securities 
borrowed and securities loaned on a daily basis and obtains or 
posts additional collateral in order to maintain contractual 
margin protection.

The enforceability of offsetting rights incorporated in the 

master netting agreements for resale and repurchase 
agreements, and securities borrowing and lending agreements, 
is evidenced to the extent that (i) a supportive legal opinion 

has been obtained from counsel of recognized standing that 
provides the requisite level of certainty regarding the 
enforceability of these agreements and (ii) the exercise of 
rights by the non-defaulting party to terminate and close out 
transactions on a net basis under these agreements will not be 
stayed or avoided under applicable law upon an event of 
default including bankruptcy, insolvency or similar 
proceeding.

A legal opinion may not have been sought or obtained for 

certain jurisdictions where local law is silent or sufficiently 
ambiguous to determine the enforceability of offsetting rights 
or where adverse case law or conflicting regulation may cast 
doubt on the enforceability of such rights. In some 
jurisdictions and for some counterparty types, the insolvency 
law for a particular counterparty type may be nonexistent or 

unclear as overlapping regimes may exist. For example, this 
may be the case for certain sovereigns, municipalities, central 
banks and U.S. pension plans.

The following tables present the gross and net resale and 
repurchase agreements and securities borrowing and lending 
agreements and the related offsetting amounts permitted under 
ASC 210-20-45. The tables also include amounts related to 
financial instruments that are not permitted to be offset under 
ASC 210-20-45, but would be eligible for offsetting to the 
extent that an event of default has occurred and a legal opinion 
supporting enforceability of the offsetting rights has been 
obtained. Remaining exposures continue to be secured by 
financial collateral, but the Company may not have sought or 
been able to obtain a legal opinion evidencing enforceability 
of the offsetting right.

As of December 31, 2019

In millions of dollars

Securities purchased under agreements to
resell

Deposits paid for securities borrowed

Total

Gross amounts
of recognized
assets

Gross amounts
offset on the
Consolidated
Balance Sheet(1)

Net amounts of
assets included on
the Consolidated
Balance Sheet

Amounts
not offset on the
Consolidated Balance
Sheet but eligible for
offsetting upon
counterparty default(2)

Net
amounts(3)

$

$

281,274 $

111,400 $

90,047

8,599

371,321 $

119,999 $

169,874 $

81,448

251,322 $

134,150 $

27,067

161,217 $

35,724

54,381

90,105

In millions of dollars

Securities sold under agreements to
repurchase

Deposits received for securities loaned

Total

Gross amounts
of recognized
liabilities

Gross amounts
offset on the
Consolidated
Balance Sheet(1)

Net amounts of
liabilities included on
the Consolidated
Balance Sheet

Amounts
not offset on the
Consolidated Balance
Sheet but eligible for
offsetting upon
counterparty default(2)

Net
amounts(3)

$

$

266,564 $

111,400 $

19,774

8,599

286,338 $

119,999 $

155,164 $

11,175

166,339 $

91,034 $

64,130

3,138

8,037

94,172 $

72,167

In millions of dollars

Securities purchased under agreements to
resell

Deposits paid for securities borrowed

Total

In millions of dollars

Securities sold under agreements to
repurchase

Deposits received for securities loaned

Total

As of December 31, 2018

Gross amounts
of recognized
assets

Gross amounts
offset on the
Consolidated
Balance Sheet(1)

Net amounts of
assets included on
the Consolidated
Balance Sheet

Amounts
not offset on the
Consolidated Balance
Sheet but eligible for
offsetting upon
counterparty default(2)

Net
amounts(3)

$

$

246,788 $

111,320

358,108 $

87,424 $

—

87,424 $

159,364 $

111,320

270,684 $

124,557 $

35,766

34,807

75,554

160,323 $

110,361

Gross amounts
of recognized
liabilities

Gross amounts
offset on the
Consolidated
Balance Sheet(1)

Net amounts of
liabilities included on
the Consolidated
Balance Sheet

Amounts
not offset on the
Consolidated Balance
Sheet but eligible for
offsetting upon
counterparty default(2)

Net
amounts(3)

$

$

253,514 $

87,424 $

11,678

—

265,192 $

87,424 $

166,090 $

11,678

177,768 $

82,823 $

83,267

3,415

8,263

86,238 $

91,530

174

 
 
(1) 
(2) 

Includes financial instruments subject to enforceable master netting agreements that are permitted to be offset under ASC 210-20-45.
Includes financial instruments subject to enforceable master netting agreements that are not permitted to be offset under ASC 210-20-45, but would be eligible for 
offsetting to the extent that an event of default has occurred and a legal opinion supporting enforceability of the offsetting right has been obtained.

(3)  Remaining exposures continue to be secured by financial collateral, but the Company may not have sought or been able to obtain a legal opinion evidencing 

enforceability of the offsetting right.

The following tables present the gross amounts of liabilities associated with repurchase agreements and securities lending agreements 
by remaining contractual maturity:

In millions of dollars

Securities sold under agreements to repurchase

Deposits received for securities loaned

Total

In millions of dollars

Securities sold under agreements to repurchase

Deposits received for securities loaned

Total

As of December 31, 2019

Open and
overnight

Up to 30 days

31–90 days

Greater than
90 days

Total

108,534 $

82,749 $

35,108 $

40,173 $

266,564

15,758

208

1,789

2,019

19,774

124,292 $

82,957 $

36,897 $

42,192 $

286,338

As of December 31, 2018

Open and
overnight

Up to 30 days

31–90 days

Greater than
90 days

Total

108,405 $

70,850 $

29,898 $

44,361 $

253,514

6,296

774

2,626

1,982

11,678

114,701 $

71,624 $

32,524 $

46,343 $

265,192

$

$

$

$

The following tables present the gross amounts of liabilities associated with repurchase agreements and securities lending agreements 
by class of underlying collateral:

In millions of dollars

Repurchase
agreements

As of December 31, 2019
Securities lending
agreements

Total

U.S. Treasury and federal agency securities

$

100,781 $

27 $

100,808

State and municipal securities

Foreign government securities

Corporate bonds

Equity securities

Mortgage-backed securities

Asset-backed securities

Other

Total

In millions of dollars

U.S. Treasury and federal agency securities

State and municipal securities

Foreign government securities

Corporate bonds

Equity securities

Mortgage-backed securities

Asset-backed securities

Other

Total

$

$

1,938

95,880

18,761

12,010

28,458

4,873

3,863

5

272

249

19,069

—

—

152

1,943

96,152

19,010

31,079

28,458

4,873

4,015

266,564 $

19,774 $

286,338

Repurchase
agreements

As of December 31, 2018
Securities lending
agreements

Total

86,785 $

41 $

2,605

99,131

21,719

12,920

19,421

6,207

4,726

—

179

749

10,664

—

—

45

86,826

2,605

99,310

22,468

23,584

19,421

6,207

4,771

$

253,514 $

11,678 $

265,192

175

12. BROKERAGE RECEIVABLES AND BROKERAGE
PAYABLES

The Company has receivables and payables for financial 
instruments sold to and purchased from brokers, dealers and 
customers, which arise in the ordinary course of business. 
Citi is exposed to risk of loss from the inability of brokers, 
dealers or customers to pay for purchases or to deliver the 
financial instruments sold, in which case Citi would have to 
sell or purchase the financial instruments at prevailing 
market prices. Credit risk is reduced to the extent that an 
exchange or clearing organization acts as a counterparty to 
the transaction and replaces the broker, dealer or customer in 
question.

Citi seeks to protect itself from the risks associated with 

customer activities by requiring customers to maintain 
margin collateral in compliance with regulatory and internal 
guidelines. Margin levels are monitored daily, and customers 
deposit additional collateral as required. Where customers 
cannot meet collateral requirements, Citi may liquidate 
sufficient underlying financial instruments to bring the 
customer into compliance with the required margin level.

Exposure to credit risk is impacted by market volatility, 

which may impair the ability of clients to satisfy their 
obligations to Citi. Credit limits are established and closely 
monitored for customers and for brokers and dealers 
engaged in forwards, futures and other transactions deemed 
to be credit sensitive. 

Brokerage receivables and Brokerage payables 

consisted of the following:

In millions of dollars

December 31,

2019

2018

Receivables from customers

$

15,912 $

14,415

Receivables from brokers,
dealers and clearing
organizations
Total brokerage receivables(1) $
Payables to customers
$

Payables to brokers, dealers
and clearing organizations
Total brokerage payables(1)

23,945

39,857 $

37,613 $

10,988

$

48,601 $

21,035

35,450

40,273

24,298

64,571

(1)   Includes brokerage receivables and payables recorded by Citi broker-

dealer entities that are accounted for in accordance with the AICPA 
Accounting Guide for Brokers and Dealers in Securities as codified in 
ASC 940-320.

176

13.   INVESTMENTS

The following table presents Citi’s investments by category:

In millions of dollars

Debt securities AFS
Debt securities HTM(1)
Marketable equity securities carried at fair value(2)
Non-marketable equity securities carried at fair value(2)
Non-marketable equity securities measured using the measurement alternative(3)
Non-marketable equity securities carried at cost(4)
Total investments

December 31,

2019

2018

$

280,265 $

80,775

458

704

700

5,661

$

368,563 $

288,038

63,357

220

889

538

5,565

358,607

(1)  Carried at adjusted amortized cost basis, net of any credit-related impairment.
(2)  Unrealized gains and losses are recognized in earnings.
(3) 
(4)  Primarily consists of shares issued by the Federal Reserve Bank, Federal Home Loan Banks and certain exchanges of which Citigroup is a member.

Impairment losses and adjustments to the carrying value as a result of observable price changes are recognized in earnings.

The following table presents interest and dividend income on investments:

In millions of dollars

Taxable interest

Interest exempt from U.S. federal income tax

Dividend income

Total interest and dividend income

2019

2018

2017

$

$

9,269 $

8,704 $

404

187

521

269

7,538

535

222

9,860 $

9,494 $

8,295

The following table presents realized gains and losses on the sales of investments, which exclude OTTI losses:

In millions of dollars

Gross realized investment gains

Gross realized investment losses

Net realized gains on sale of investments

2019

2018

2017

$

$

1,599 $

(125)

1,474 $

682 $

(261)

421 $

1,039

(261)

778

177

The Company from time to time may sell certain debt 
securities that were classified as HTM. These sales were in 
response to significant deterioration in the creditworthiness of 
the issuers or securities or because the Company has collected 
a substantial portion (at least 85%) of the principal 
outstanding at acquisition of the security. In addition, certain 
other debt securities were reclassified to AFS investments in 

response to significant credit deterioration. Because the 
Company generally intends to sell these reclassified debt 
securities, Citi recorded OTTI on the securities. The following 
table presents, for the periods indicated, the carrying value of 
HTM debt securities sold and reclassified to AFS, as well as 
the related gain (loss) or the OTTI losses recorded on these 
securities: 

In millions of dollars

Carrying value of HTM debt securities sold

Net realized gain (loss) on sale of HTM debt securities

Carrying value of debt securities reclassified to AFS

OTTI losses on debt securities reclassified to AFS

2019

2018

2017

$

— $

61 $

—

—

—

—

8

—

81

13

74

—

Debt Securities Available-for-Sale
The amortized cost and fair value of AFS debt securities were as follows:

2019

2018

Amortized
cost

Gross
unrealized
gains

Gross
unrealized
losses

Fair
value

Amortized
cost

Gross
unrealized
gains

Gross
unrealized
losses

Fair
value

In millions of dollars

Debt securities AFS
Mortgage-backed securities(1)

U.S. government agency guaranteed

$

34,963 $

547 $

280 $ 35,230 $

43,504 $

241 $

725 $ 43,020

Non-U.S. residential

Commercial

789

75

3

—

—

—

792

75

1,310

174

4

1

2

2

1,312

173

Total mortgage-backed securities

$

35,827 $

550 $

280 $ 36,097 $

44,988 $

246 $

729 $ 44,505

U.S. Treasury and federal agency
securities

U.S. Treasury

Agency obligations

Total U.S. Treasury and federal agency
securities

State and municipal

Foreign government

Corporate
Asset-backed securities(1)
Other debt securities

$

106,429 $

50 $

380 $ 106,099 $ 109,376 $

33 $

1,339 $ 108,070

5,336

3

20

5,319

9,283

1

132

9,152

$

$

111,765 $

5,024 $

53 $

43 $

400 $ 111,418 $ 118,659 $

89 $

4,978 $

9,372 $

34 $

96 $

1,471 $ 117,222

262 $

9,206

110,958

11,266

524

4,729

586

52

—

1

241

101

2

—

111,303

100,872

11,217

11,714

522

4,730

845

3,973

415

42

2

—

596

157

4

1

100,691

11,599

843

3,972

Total debt securities AFS

$

280,093 $

1,285 $

1,113 $ 280,265 $ 290,423 $

835 $

3,220 $ 288,038

(1)  The Company invests in mortgage- and asset-backed securities. These securitization entities are generally considered VIEs. The Company’s maximum exposure 
to loss from these VIEs is equal to the carrying amount of the securities, which is reflected in the table above. For mortgage- and asset-backed securitizations in 
which the Company has other involvement, see Note 21 to the Consolidated Financial Statements.

At December 31, 2019, the amortized cost of fixed 
income securities exceeded their fair value by $1,113 million. 
Of the $1,113 million, $802 million represented unrealized 
losses on fixed income investments that have been in a gross-
unrealized-loss position for less than a year and, of these, 
93% were rated investment grade; and $311 million 
represented unrealized losses on fixed income investments 
that have been in a gross-unrealized-loss position for a year or 
more and, of these, 92% were rated investment grade. Of the 
$311 million mentioned above, $132 million represents U.S. 
Treasury securities.

178

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table shows the fair value of AFS debt securities that have been in an unrealized loss position:

In millions of dollars

December 31, 2019

Debt securities AFS

Mortgage-backed securities

U.S. government agency guaranteed

Non-U.S. residential

Commercial

Total mortgage-backed securities

U.S. Treasury and federal agency securities

U.S. Treasury

Agency obligations

Total U.S. Treasury and federal agency securities

State and municipal

Foreign government

Corporate

Asset-backed securities

Other debt securities

Total debt securities AFS

December 31, 2018
Debt securities AFS

Mortgage-backed securities

Less than 12 months

12 months or longer

Total

Fair
value

Gross
unrealized
losses

Fair
value

Gross
unrealized
losses

Fair
value

Gross
unrealized
losses

$

9,780 $

242 $

1,877 $

38 $

11,657 $

$

$

$

$

208

16

—

—

1

27

—

—

209

43

10,004 $

242 $

1,905 $

38 $

11,909 $

45,484 $

248 $

26,907 $

132 $

72,391 $

781

2

3,897

18

4,678

46,265 $

250 $

30,804 $

150 $

77,069 $

362 $

62 $

266 $

27 $

628 $

35,485

2,916

112

1,307

149

8,170

98

1

—

123

166

—

92

3

1

—

43,655

3,039

278

1,307

280

—

—

280

380

20

400

89

241

101

2

—

$

96,451 $

802 $

41,434 $

311 $ 137,885 $

1,113

U.S. government agency guaranteed

$

11,160 $

286 $

13,143 $

439 $

24,303 $

725

Non-U.S. residential

Commercial

Total mortgage-backed securities

U.S. Treasury and federal agency securities

U.S. Treasury

Agency obligations

Total U.S. Treasury and federal agency securities

State and municipal

Foreign government

Corporate

Asset-backed securities

Other debt securities

Total debt securities AFS

$

$

$

$

284

79

2

1

2

82

—

1

286

161

2

2

11,523 $

289 $

13,227 $

440 $

24,750 $

729

8,389 $

42 $

77,883 $

1,297 $

86,272 $

1,339

277

8,666 $

1,614 $

40,655

4,547

441

1,790

2

8,660

130

8,937

132

44 $

86,543 $

1,427 $

95,209 $

1,471

34 $

1,303 $

228 $

2,917 $

265

115

4

1

15,053

2,077

55

—

331

55,708

42

—

—

6,624

496

1,790

262

596

157

4

1

$

69,236 $

752 $ 118,258 $

2,468 $ 187,494 $

3,220

179

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table presents the amortized cost and fair value of AFS debt securities by contractual maturity dates:

In millions of dollars
Mortgage-backed securities(1)
Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(2)
Total

U.S. Treasury and federal agency securities

Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(2)
Total

State and municipal

Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(2)
Total

Foreign government

Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(2)
Total
All other(3)
Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(2)
Total

Total debt securities AFS

December 31,

2019

2018

Amortized
cost

Fair
value

Amortized
cost

Fair
value

$

$

$

20 $

20 $

14 $

573

594

574

626

662

2,779

34,640

34,877

41,533

35,827 $

36,097 $

44,988 $

40,757 $

40,688 $

41,941 $

70,128

69,850

76,139

854

26

851

29

489

90

14

661

2,828

41,002

44,505

41,867

74,800

462

93

$

111,765 $

111,418 $

118,659 $

117,222

$

$

$

932 $

932 $

2,586 $

714

195

3,183

723

215

3,108

1,676

585

4,525

5,024 $

4,978 $

9,372 $

42,611 $

42,666 $

39,078 $

58,820

59,071

8,192

1,335

8,198

1,368

50,125

10,153

1,516

2,586

1,675

602

4,343

9,206

39,028

49,962

10,149

1,552

$

110,958 $

111,303 $

100,872 $

100,691

$

7,306 $

7,311 $

6,166 $

8,279

818

116

8,275

797

86

8,459

1,474

433

6,166

8,416

1,427

405

$

$

16,519 $

16,469 $

16,532 $

16,414

280,093 $

280,265 $

290,423 $

288,038

(1) 
(2) 

(3) 

Includes mortgage-backed securities of U.S. government-sponsored agencies.
Investments with no stated maturities are included as contractual maturities of greater than 10 years. Actual maturities may differ due to call or prepayment 
rights.
Includes corporate, asset-backed and other debt securities.

180

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Debt Securities Held-to-Maturity

The carrying value and fair value of debt securities HTM were as follows:

In millions of dollars

December 31, 2019

Debt securities HTM
Mortgage-backed securities(1)(2)

U.S. government agency guaranteed

Non-U.S. residential

Commercial

Total mortgage-backed securities
State and municipal(3)
Foreign government
Asset-backed securities(1)
Total debt securities HTM

December 31, 2018

Debt securities HTM
Mortgage-backed securities(1)(4)

U.S. government agency guaranteed

Non-U.S. residential

Commercial

Total mortgage-backed securities

State and municipal

Foreign government
Asset-backed securities(1)
Total debt securities HTM

Carrying
value

Gross
unrealized
gains

Gross
unrealized
losses

Fair
value

$

$

$

$

$

$

$

$

46,637 $

1,047 $

1,039

582

48,258 $

9,104 $

1,934

21,479

5

1

1,053 $

455 $

37

12

21 $

—

—

21 $

28 $

1

59

80,775 $

1,557 $

109 $

34,239 $

1,339

368

35,946 $

7,628 $

1,027

18,756

63,357 $

199 $

12

—

211 $

167 $

—

8

386 $

578 $

1

—

579 $

138 $

24

112

853 $

47,663

1,044

583

49,290

9,531

1,970

21,432

82,223

33,860

1,350

368

35,578

7,657

1,003

18,652

62,890

(2) 

(1)  The Company invests in mortgage- and asset-backed securities. These securitization entities are generally considered VIEs. The Company’s maximum exposure 
to loss from these VIEs is equal to the carrying amount of the securities, which is reflected in the table above. For mortgage- and asset-backed securitizations in 
which the Company has other involvement, see Note 21 to the Consolidated Financial Statements.
In March 2019, Citibank transferred $5 billion of agency residential mortgage-backed securities (RMBS) from AFS classification to HTM classification in 
accordance with ASC 320. At the time of transfer, the securities were in an unrealized loss position of $56 million. The loss amounts will remain in AOCI and be 
amortized over the remaining life of the securities.
In December 2019, Citibank transferred $173 million of state and municipal bonds from AFS classification to HTM classification in accordance with ASC 320. 
At the time of transfer, the bonds were in an unrealized gain position of $5 million. The gain amounts will remain in AOCI and be amortized over the remaining 
life of the securities.
In November 2018, Citibank transferred $10 billion of agency residential mortgage-backed securities (RMBS) and commercial mortgage-backed securities 
(CMBS) from AFS classification to HTM classification in accordance with ASC 320. At the time of transfer, the securities were in an unrealized loss position of 
$598 million. This amount will remain in AOCI and be amortized over the remaining life of the securities.

(4) 

(3) 

181

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The Company has the positive intent and ability to hold 
these securities to maturity or, where applicable, to exercise 
any issuer call options, absent any unforeseen significant 
changes in circumstances, including deterioration in credit or 
changes in regulatory capital requirements.

The net unrealized losses classified in AOCI for HTM 

securities primarily relate to debt securities previously 
classified as AFS that were transferred to HTM, and include 
any cumulative fair value hedge adjustments. The net 
unrealized loss amount also includes any non-credit-related 
changes in fair value of HTM debt securities that have 
suffered credit impairment recorded in earnings. The AOCI 
balance related to HTM debt securities is amortized as an 
adjustment of yield, in a manner consistent with the accretion 
of any difference between the carrying value at the transfer 
date and par value of the same debt securities. 

The table below shows the fair value of debt securities HTM that have been in an unrecognized loss position:

In millions of dollars

December 31, 2019

Debt securities HTM

Less than 12 months

12 months or longer

Total

Fair
value

Gross
unrecognized
losses

Fair
value

Gross
unrecognized
losses

Fair
value

Gross
unrecognized
losses

Mortgage-backed securities

$

3,590 $

10 $

1,116 $

11 $

4,706 $

State and municipal

Foreign government

Asset-backed securities

Total debt securities HTM

December 31, 2018

Debt securities HTM

Mortgage-backed securities

State and municipal

Foreign government

Asset-backed securities

Total debt securities HTM

34

1,970

7,972

1

1

11

1,125

—

765

27

—

48

1,159

1,970

8,737

$

13,566 $

23 $

3,006 $

86 $

16,572 $

$

2,822 $

20 $

18,086 $

559 $

20,908 $

981

1,003

13,008

34

24

112

1,242

—

—

104

—

—

2,223

1,003

13,008

$

17,814 $

190 $

19,328 $

663 $

37,142 $

21

28

1

59

109

579

138

24

112

853

Note: Excluded from the gross unrecognized losses presented in the above table are $(582) million and $(653) million of net unrealized losses recorded in AOCI as of 
December 31, 2019 and 2018, respectively, primarily related to the difference between the amortized cost and carrying value of HTM debt securities that were 
reclassified from AFS. Substantially all of these net unrecognized losses relate to securities that have been in a loss position for 12 months or longer at December 31, 
2019 and 2018.

182

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table presents the carrying value and fair value of HTM debt securities by contractual maturity dates:

In millions of dollars

Mortgage-backed securities

Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(1)
Total

State and municipal

Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(1)
Total

Foreign government

Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(1)
Total
All other(2)
Due within 1 year

After 1 but within 5 years

After 5 but within 10 years
After 10 years(1)
Total

Total debt securities HTM

December 31,

2019

2018

Carrying value

Fair value

Carrying value

Fair value

$

$

$

$

$

$

$

$

$

17 $

17 $

3 $

458

1,662

46,121

463

1,729

47,081

539

997

34,407

48,258 $

49,290 $

35,946 $

2 $

123

597

8,382

9,104 $

650 $

1,284

—

—

26 $

160

590

8,755

9,531 $

652 $

1,318

—

—

37 $

168

540

6,883

7,628 $

60 $

967

—

—

3

540

1,011

34,024

35,578

37

174

544

6,902

7,657

36

967

—

—

1,934 $

1,970 $

1,027 $

1,003

— $

—

8,545

12,934

21,479 $

80,775 $

— $

—

8,543

12,889

21,432 $

82,223 $

— $

—

2,535

16,221

18,756 $

63,357 $

—

—

2,539

16,113

18,652

62,890

(1) 

(2) 

Investments with no stated maturities are included as contractual maturities of greater than 10 years. Actual maturities may differ due to call or prepayment 
rights.
Includes corporate and asset-backed securities.

183

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluating Investments for Other-Than-Temporary 
Impairment (OTTI)

Debt Securities
Overview
The Company conducts periodic reviews of all debt securities 
with unrealized losses to evaluate whether the impairment is 
other-than-temporary. This review applies to all debt 
securities that are not measured at fair value through earnings. 
Effective January 1, 2018, the AFS category was eliminated 
for equity securities and, therefore, other-than-temporary 
impairment (OTTI) review is not required for those securities. 
An unrealized loss exists when the current fair value of 

an individual debt security is lower than its adjusted 
amortized cost basis. Unrealized losses that are determined to 
be temporary in nature are recorded, net of tax, in AOCI for 
AFS debt securities. Temporary losses related to HTM debt 
securities generally are not recorded, as these investments are 
carried at adjusted amortized cost basis. However, for HTM 
debt securities with credit-related impairment, the credit loss 
is recognized in earnings as OTTI, and any difference 
between the cost basis adjusted for the OTTI and fair value is 
recognized in AOCI and amortized as an adjustment of yield 
over the remaining contractual life of the security. For debt 
securities transferred to HTM from Trading account assets, 
amortized cost is defined as the fair value of the securities at 
the date of transfer, plus any accretion income and less any 
impairment recognized in earnings subsequent to transfer. For 
debt securities transferred to HTM from AFS, amortized cost 
is defined as the original purchase cost, adjusted for the 
cumulative accretion or amortization of any purchase discount 
or premium, plus or minus any cumulative fair value hedge 
adjustments, net of accretion or amortization, and less any 
impairment recognized in earnings.

Regardless of the classification of debt securities as AFS 

or HTM, the Company assesses each position with an 
unrealized loss for OTTI. Factors considered in determining 
whether a loss is temporary include:

• 

• 
• 

• 

• 

the length of time and the extent to which fair value has 
been below cost;
the severity of the impairment;
the cause of the impairment and the financial condition 
and near-term prospects of the issuer;
activity in the market of the issuer that may indicate 
adverse credit conditions; and
the Company’s ability and intent to hold the investment 
for a period of time sufficient to allow for any anticipated 
recovery.

The Company’s review for impairment generally entails:

• 
• 

• 

identification and evaluation of impaired investments;
analysis of individual positions that have fair values 
lower than amortized cost, including consideration of the 
length of time the position has been in an unrealized loss 
position and the expected recovery period;
consideration of evidential matter, including an 
evaluation of factors or triggers that could cause 
individual positions to qualify as having other-than-

184

temporary impairment and those that would not support 
other-than-temporary impairment; and
documentation of the results of these analyses, as 
required under business policies.

• 

The entire difference between amortized cost basis and 
fair value is recognized in earnings as OTTI for impaired debt 
securities that the Company has an intent to sell or for which 
the Company believes it will more-likely-than-not be required 
to sell prior to recovery of the amortized cost basis. However, 
for those debt securities that the Company does not intend to 
sell and is not likely to be required to sell, only the credit-
related impairment is recognized in earnings and any non-
credit-related impairment is recorded in AOCI.

For debt securities, credit impairment exists where 
management does not expect to receive contractual principal 
and interest cash flows sufficient to recover the entire 
amortized cost basis of a security.

The sections below describe the Company’s process for 
identifying credit-related impairments for debt security types 
that have the most significant unrealized losses as of 
December 31, 2019. 

Mortgage-Backed Securities
For U.S. mortgage-backed securities, credit impairment is 
assessed using a cash flow model that estimates the principal 
and interest cash flows on the underlying mortgages using the 
security-specific collateral and transaction structure. The 
model distributes the estimated cash flows to the various 
tranches of securities, considering the transaction structure 
and any subordination and credit enhancements that exist in 
that structure. The cash flow model incorporates actual cash 
flows on the mortgage-backed securities through the current 
period and then estimates the remaining cash flows using a 
number of assumptions, including default rates, prepayment 
rates, recovery rates (on foreclosed properties) and loss 
severity rates (on non-agency mortgage-backed securities).

Management develops specific assumptions using 

market data, internal estimates and estimates published by 
rating agencies and other third-party sources. Default rates are 
projected by considering current underlying mortgage loan 
performance, generally assuming the default of (i) 10% of 
current loans, (ii) 25% of 30–59 day delinquent loans, 
(iii) 70% of 60–90 day delinquent loans and (iv) 100% of 91+ 
day delinquent loans. These estimates are extrapolated along a 
default timing curve to estimate the total lifetime pool default 
rate. Other assumptions contemplate the actual collateral 
attributes, including geographic concentrations, rating actions 
and current market prices.

Cash flow projections are developed using different stress 

test scenarios. Management evaluates the results of those 
stress tests (including the severity of any cash shortfall 
indicated and the likelihood of the stress scenarios actually 
occurring based on the underlying pool’s characteristics and 
performance) to assess whether management expects to 
recover the amortized cost basis of the security. If cash flow 
projections indicate that the Company does not expect to 
recover its amortized cost basis, the Company recognizes the 
estimated credit loss in earnings.

State and Municipal Securities
The process for identifying credit impairments in Citigroup’s 
AFS and HTM state and municipal bonds is primarily based 
on a credit analysis that incorporates third-party credit ratings.  
Citigroup monitors the bond issuers and any insurers 
providing default protection in the form of financial guarantee 
insurance. The average external credit rating, ignoring any 
insurance, is Aa3/AA-.  In the event of an external rating 
downgrade or other indicator of credit impairment (i.e., based 
on instrument-specific estimates of cash flows or probability 
of issuer default), the subject bond is specifically reviewed for 
adverse changes in the amount or timing of expected 
contractual principal and interest payments. 

For state and municipal bonds with unrealized losses that 

Citigroup plans to sell, or would be more-likely-than-not 
required to sell, the full impairment is recognized in earnings.

Equity Method Investments
Management assesses equity method investments that have 
fair values that are lower than their respective carrying values 
for OTTI. Fair value is measured as price multiplied by 
quantity if the investee has publicly listed securities. If the 
investee is not publicly listed, other methods are used (see 
Note 24 to the Consolidated Financial Statements).

For impaired equity method investments that Citi plans to 

sell prior to recovery of value or would more-likely-than-not 
be required to sell, with no expectation that the fair value will 
recover prior to the expected sale date, the full impairment is 
recognized in earnings as OTTI regardless of severity and 
duration. The measurement of the OTTI does not include 
partial projected recoveries subsequent to the balance sheet 
date.

For impaired equity method investments that 

management does not plan to sell and is not more-likely-than-
not to be required to sell prior to recovery of value, the 
evaluation of whether an impairment is other-than-temporary 
is based on (i) whether and when an equity method 
investment will recover in value and (ii) whether the investor 
has the intent and ability to hold that investment for a period 
of time sufficient to recover the value. The determination of 
whether the impairment is considered other-than-temporary 
considers the following indicators:

• 

• 

• 

the cause of the impairment and the financial condition 
and near-term prospects of the issuer, including any 
specific events that may influence the operations of the 
issuer;
the intent and ability to hold the investment for a period 
of time sufficient to allow for any anticipated recovery in 
market value; and
the length of time and extent to which fair value has been 
less than the carrying value.

185

Recognition and Measurement of OTTI
The following tables present total OTTI on Investments recognized in earnings:

In millions of dollars

Impairment losses related to debt securities that the Company does not intend to sell nor
will likely be required to sell:

Total OTTI losses recognized during the period

Less: portion of impairment loss recognized in AOCI (before taxes)

Net impairment losses recognized in earnings for debt securities that the Company does
not intend to sell nor will likely be required to sell
Impairment losses recognized in earnings for debt securities that the Company intends to
sell, would be more-likely-than-not required to sell or will be subject to an issuer call
deemed probable of exercise

Total OTTI losses recognized in earnings

In millions of dollars

Impairment losses related to debt securities that the Company does not intend to sell nor
will likely be required to sell:

Total OTTI losses recognized during the period
Less: portion of impairment loss recognized in AOCI (before taxes)

Net impairment losses recognized in earnings for debt securities that the Company does
not intend to sell nor will likely be required to sell

Impairment losses recognized in earnings for debt securities that the Company intends to
sell, would be more-likely-than-not required to sell or will be subject to an issuer call
deemed probable of exercise

Total OTTI losses recognized in earnings

(1)  For the year ended December 31, 2018, amounts represent AFS debt securities. 

In millions of dollars

Impairment losses related to securities that the Company does not intend to sell nor will
likely be required to sell:

Total OTTI losses recognized during the period

Less: portion of impairment loss recognized in AOCI (before taxes)

Net impairment losses recognized in earnings for securities that the Company does not
intend to sell nor will likely be required to sell

Impairment losses recognized in earnings for securities that the Company intends to sell,
would be more-likely-than-not required to sell or will be subject to an issuer call deemed
probable of exercise

Total OTTI losses recognized in earnings

(1) 

Includes OTTI on non-marketable equity securities.

Year ended 
  December 31, 2019

AFS

HTM

Other
assets

Total

1 $

—

1 $

20

21 $

— $

—

— $

—

— $

1 $

—

1 $

1

2 $

2

—

2

21

23

Year ended 
  December 31, 2018

AFS(1)

HTM

Other
assets

Total

— $
—

— $

125

125 $

— $
—

— $

—

— $

— $
—

— $

—

— $

—
—

—

125

125

Year ended
December 31, 2017

AFS(1)

HTM

Other
assets

Total

2 $

—

2 $

59

61 $

— $

—

— $

2

2 $

— $

—

— $

—

— $

2

—

2

61

63

$

$

$

$

$

$

$

$

$

186

The following are 12-month rollforwards of the credit-related impairments recognized in earnings for AFS and HTM debt securities 
that the Company does not intend to sell nor likely will be required to sell:

Cumulative OTTI credit losses recognized in earnings on debt securities still held

Credit
impairments
recognized in
earnings on
securities not
previously
impaired

Credit
impairments
recognized in
earnings on
securities 
that have 
been previously
impaired 

Dec. 31, 2018
balance

Changes due to
credit-impaired
securities sold,
transferred or
matured(1)

Dec. 31, 2019
balance

$

$

$

1 $

— $

— $

—

4

—

5 $

3

3 $

—

—

1

1 $

—

— $

4

—

—

4 $

—

— $

— $

—

—

—

— $

—

— $

1

4

4

1

10

3

3

Cumulative OTTI credit losses recognized in earnings on debt securities still held

Credit
impairments
recognized in
earnings on
securities not
previously
impaired

Credit
impairments
recognized in
earnings on
securities 
that have
been previously
impaired

Dec. 31, 2017
balance

Changes due to
credit-impaired
securities sold,
transferred or
matured(3)

Dec. 31, 2018
balance

$

$

$

$

38 $
4
4
2

48 $

54 $

3

57 $

— $
—
—
—

— $

— $

—

— $

— $
—
—
—

— $

— $

—

— $

(37) $
(4)
—
(2)

(43) $

(54) $

—

(54) $

1
—
4
—

5

—

3

3

In millions of dollars

AFS debt securities
Mortgage-backed securities(1)
State and municipal

Corporate

All other debt securities

Total OTTI credit losses recognized for AFS debt
securities

HTM debt securities

State and municipal

Total OTTI credit losses recognized for HTM
debt securities

In millions of dollars
AFS debt securities
Mortgage-backed securities(1)
State and municipal
Corporate
All other debt securities

Total OTTI credit losses recognized for AFS debt
securities
HTM debt securities
Mortgage-backed securities(2)
State and municipal 

Total OTTI credit losses recognized for HTM debt
securities

(1)  Primarily consists of Prime securities.
(2)  Primarily consists of Alt-A securities.
(3) 

Includes $18 million in cumulative OTTI reclassified from HTM to AFS due to the transfer of the related debt securities from HTM to AFS. Citi adopted ASU 
2017-12, Targeted Improvements to Accounting for Hedging Activities, on January 1, 2018 and transferred approximately $4 billion of HTM debt securities into 
AFS classification as permitted as a one-time transfer under the standard.

187

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Non-Marketable Equity Securities Not Carried at 
Fair Value
Non-marketable equity securities are required to be measured 
at fair value with changes in fair value recognized in earnings 
unless (i) the measurement alternative is elected or (ii) the 
investment represents Federal Reserve Bank and Federal 
Home Loan Bank stock or certain exchange seats that 
continue to be carried at cost. See Note 1 to the Consolidated 
Financial Statements for additional details.

The election to measure a non-marketable equity security 

using the measurement alternative is made on an instrument-
by-instrument basis. Under the measurement alternative, an 
equity security is carried at cost plus or minus changes 
resulting from observable prices in orderly transactions for 
the identical or a similar investment of the same issuer. The 
carrying value of the equity security is adjusted to fair value 
on the date of an observed transaction. Fair value may differ 
from the observed transaction price due to a number of 
factors, including marketability adjustments and differences 
in rights and obligations when the observed transaction is not 
for the identical investment held by Citi.

Equity securities under the measurement alternative are 

also assessed for impairment. On a quarterly basis, 
management qualitatively assesses whether each equity 
security under the measurement alternative is impaired. 
Impairment indicators that are considered include, but are not 
limited to, the following:

• 

• 

• 

• 

• 

a significant deterioration in the earnings performance, 
credit rating, asset quality or business prospects of the 
investee;
a significant adverse change in the regulatory, economic 
or technological environment of the investee;
a significant adverse change in the general market 
condition of either the geographical area or the industry 
in which the investee operates;
a bona fide offer to purchase, an offer by the investee to 
sell or a completed auction process for the same or 
similar investment for an amount less than the carrying 
amount of that investment; and
factors that raise significant concerns about the investee’s 
ability to continue as a going concern, such as negative 
cash flows from operations, working capital deficiencies 
or noncompliance with statutory capital requirements or 
debt covenants.

When the qualitative assessment indicates that 
impairment exists, the investment is written down to fair 
value, with the full difference between the fair value of the 
investment and its carrying amount recognized in earnings.
Below is the carrying value of non-marketable equity 
securities measured using the measurement alternative at 
December 31, 2019 and 2018:

In millions of dollars

Measurement alternative:

December 31,
2019

December 31,
2018

Carrying value

$

700 $

538

Below are amounts recognized in earnings and life-to-
date amounts for non-marketable equity securities measured 
using the measurement alternative:

In millions of dollars

Measurement alternative:
Impairment losses(1)
Downward changes for 
observable prices(1)

Upward changes for 
observable prices(1)

Years Ended December 31,

2019

2018

$

9 $

16

123

7

18

219

(1)   See Note 24 to the Consolidated Financial Statements for additional 
information on these nonrecurring fair value measurements. 

In millions of dollars

Measurement alternative:

Impairment losses

Downward changes for observable prices
Upward changes for observable prices

Life-to-date amounts
on securities still held
December 31, 2019

$

16

34
342

A similar impairment analysis is performed for non-
marketable equity securities carried at cost. For the years 
ended December 31, 2019 and 2018, there was no impairment 
loss recognized in earnings for non-marketable equity 
securities carried at cost.

188

Investments in Alternative Investment Funds That 
Calculate Net Asset Value
The Company holds investments in certain alternative 
investment funds that calculate net asset value (NAV), or its 
equivalent, including private equity funds, funds of funds and 
real estate funds, as provided by third-party asset managers. 
Investments in such funds are generally classified as non-
marketable equity securities carried at fair value. The fair 
values of these investments are estimated using the NAV of 
the Company’s ownership interest in the funds. Some of these 
investments are in “covered funds” for purposes of the 

Volcker Rule, which prohibits certain proprietary investment 
activities and limits the ownership of, and relationships with, 
covered funds. On April 21, 2017, Citi’s request for extension 
of the permitted holding period under the Volcker Rule for 
certain of its investments in illiquid funds was approved, 
allowing the Company to hold such investments until the 
earlier of five years from the July 21, 2017 expiration date of 
the general conformance period, or the date such investments 
mature or are otherwise conformed with the Volcker Rule.

Fair value

Unfunded
commitments

Redemption frequency
(if currently eligible)
monthly, quarterly, annually

Redemption 
notice
period

In millions of dollars
Private equity funds(1)(2)
Real estate funds(2)(3)
Mutual/collective 
  investment funds
Total

December 31,
2019

December 31,
2018

December 31,
2019

December 31,
2018

$

$

134 $
10

26
170 $

168 $
14

25
207 $

62 $
18

—
80 $

62
19

—
81

—
—

—

—
—

—

(1)  Private equity funds include funds that invest in infrastructure, emerging markets and venture capital.
(2)  With respect to the Company’s investments in private equity funds and real estate funds, distributions from each fund will be received as the underlying assets 
held by these funds are liquidated. It is estimated that the underlying assets of these funds will be liquidated over a period of several years as market conditions 
allow. Private equity and real estate funds do not allow redemption of investments by their investors. Investors are permitted to sell or transfer their investments, 
subject to the approval of the general partner or investment manager of these funds, which generally may not be unreasonably withheld.
Includes several real estate funds that invest primarily in commercial real estate in the U.S., Europe and Asia.

(3) 

189

loans are modified under those respective agencies’ guidelines 
and payments are not always required in order to re-age a 
modified loan to current.

14.   LOANS

Citigroup loans are reported in two categories: consumer and 
corporate. These categories are classified primarily according 
to the segment and subsegment that manage the loans.

Consumer Loans
Consumer loans represent loans and leases managed primarily 
by GCB and Corporate/Other. 

Citigroup has established a risk management process to 
monitor, evaluate and manage the principal risks associated 
with its consumer loan portfolio. Credit quality indicators that 
are actively monitored include delinquency status, consumer 
credit scores under Fair Isaac Corporation (FICO) and loan to 
value (LTV) ratios, each as discussed in more detail below.
Included in the loan table above are lending products 
whose terms may give rise to greater credit issues. Credit 
cards with below-market introductory interest rates and 
interest-only loans are examples of such products. These 
products are closely managed using credit techniques that are 
intended to mitigate their higher inherent risk.

Delinquency Status
Delinquency status is monitored and considered a key 
indicator of credit quality of consumer loans. Principally, the 
U.S. residential first mortgage loans use the Mortgage Bankers 
Association (MBA) method of reporting delinquencies, which 
considers a loan delinquent if a monthly payment has not been 
received by the end of the day immediately preceding the 
loan’s next due date. All other loans use a method of reporting 
delinquencies that considers a loan delinquent if a monthly 
payment has not been received by the close of business on the 
loan’s next due date.

As a general policy, residential first mortgages, home 
equity loans and installment loans are classified as non-accrual 
when loan payments are 90 days contractually past due. Credit 
cards and unsecured revolving loans generally accrue interest 
until payments are 180 days past due. Home equity loans in 
regulated bank entities are classified as non-accrual if the 
related residential first mortgage is 90 days or more past due. 
Mortgage loans, other than Federal Housing Administration 
(FHA)-insured loans, are classified as non-accrual within 60 
days of notification that the borrower has filed for bankruptcy. 
The policy for re-aging modified U.S. consumer loans to 

current status varies by product. Generally, one of the 
conditions to qualify for these modifications is that a 
minimum number of payments (typically ranging from one to 
three) be made. Upon modification, the loan is re-aged to 
current status. However, re-aging practices for certain open-
ended consumer loans, such as credit cards, are governed by 
Federal Financial Institutions Examination Council (FFIEC) 
guidelines. For open-ended consumer loans subject to FFIEC 
guidelines, one of the conditions for a loan to be re-aged to 
current status is that at least three consecutive minimum 
monthly payments, or the equivalent amount, must be 
received. In addition, under FFIEC guidelines, the number of 
times that such a loan can be re-aged is subject to limitations 
(generally once in 12 months and twice in five years). 
Furthermore, FHA and Department of Veterans Affairs (VA) 

190

The following table provides Citi’s consumer loans by type:

Consumer Loan Delinquencies and Non-Accrual Details at December 31, 2019

288

—

1,927

—

2,215

—

242

—

242

549

—

1,764

—

2,313

—

235

—

235

Total
current(1)(2)

30–89 days
past due(3)

 90 days
past due(3)

Past due
government
guaranteed(4)

Total
loans(2)

Total
non-
accrual

90 days past due
and accruing

$

45,942 $

411 $

221 $

434 $

47,008 $

479 $

8,860

145,477

3,641

174

1,759

44

189

1,927

14

—

9,223

— 149,163

—

3,699

405

—

21

203,920 $

2,388 $

2,351 $

434 $ 209,093 $

905 $

37,316 $

210 $

160 $

— $

37,686 $

421 $

25,111

36,456

426

272

372

132

—

—

25,909

36,860

310

180

98,883 $

908 $

664 $

— $ 100,455 $

911 $

302,803 $

3,296 $

3,015 $

434 $ 309,548 $

1,816 $

2,457

In millions of dollars
In North America offices(5)

Residential first mortgages(6)
Home equity loans(7)(8)
Credit cards

Personal, small business and other

Total
In offices outside North America(5)
Residential first mortgages(6)
Credit cards
Personal, small business and other

Total
Total Citigroup(9)

In millions of dollars
In North America offices(5)

Residential first mortgages(6)
Home equity loans(7)(8)
Credit cards

Personal, small business and other

Total
In offices outside North America(5)
Residential first mortgages(6)
Credit cards

Personal, small business and other

Total
Total Citigroup (9)

$

$

$

$

$

$

$

$

Consumer Loan Delinquencies and Non-Accrual Details at December 31, 2018

Total
current(1)(2)

30–89 days
past due(3)

 90 days
past due(3)

Past due
government
guaranteed(4)

Total
loans(2)

Total
non-accrual

90 days past due
and accruing

$

45,953 $

420 $

253 $

786 $ 47,412 $

583 $

11,135

141,091

3,983

161

1,687

46

247

1,764

17

—

11,543

— 144,542

—

4,046

527

—

28

202,162 $

2,314 $

2,281 $

786 $ 207,543 $

1,138 $

35,624 $

203 $

145 $

— $ 35,972 $

383 $

24,156

33,474

425

284

370

136

—

—

24,951

33,894

312

193

93,254 $

912 $

651 $

— $ 94,817 $

888 $

295,416 $

3,226 $

2,932 $

786 $ 302,360 $

2,026 $

2,548

Includes $18 million and $20 million at December 31, 2019 and 2018, respectively, of residential first mortgages recorded at fair value.

(1)  Loans less than 30 days past due are presented as current.
(2) 
(3)  Excludes loans guaranteed by U.S. government-sponsored agencies.
(4)  Consists of residential first mortgages that are guaranteed by U.S. government-sponsored agencies that are 30–89 days past due of $0.1 billion and $0.2 billion and 

90 days or more past due of $0.3 billion and $0.6 billion at December 31, 2019 and 2018, respectively.

Includes approximately $0.1 billion and $0.1 billion at December 31, 2019 and 2018, respectively, of residential first mortgage loans in process of foreclosure.
Includes approximately $0.1 billion and $0.1 billion at December 31, 2019 and 2018, respectively, of home equity loans in process of foreclosure.

(5)  North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America.
(6) 
(7) 
(8)  Fixed-rate home equity loans and loans extended under home equity lines of credit, which are typically in junior lien positions.
(9)  Consumer loans are net of unearned income of $783 million and $742 million at December 31, 2019 and 2018, respectively. Unearned income on consumer loans 

primarily represents unamortized origination fees and costs, premiums and discounts.

During the years ended December 31, 2019 and 2018, the 
Company sold and/or reclassified to HFS $2.9 billion and $3.2 
billion, respectively, of consumer loans. 

191

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Loan to Value (LTV) Ratios
LTV ratios (loan balance divided by appraised value) are 
calculated at origination and updated by applying market price 
data.

The following tables provide details on the LTV ratios for 

Citi’s U.S. consumer mortgage portfolios. LTV ratios are 
updated monthly using the most recent Core Logic Home 
Price Index data available for substantially all of the portfolio 
applied at the Metropolitan Statistical Area level, if available, 
or the state level if not. The remainder of the portfolio is 
updated in a similar manner using the Federal Housing 
Finance Agency indices.

LTV distribution in 
U.S. portfolio(1)(2)

In millions of dollars

Residential first
mortgages

Home equity loans

Total

LTV distribution in 
U.S. portfolio(1)(2)

In millions of dollars

Residential first
mortgages

Home equity loans

Total

December 31, 2019

Less than 
or
equal to 
80%

> 80% but less
than or equal 
to
100%

Greater
than
100%

$

$

41,705 $

3,302 $

7,934

819

49,639 $

4,121 $

98

235

333

December 31, 2018

Less than 
or
equal to 
80%

> 80% but less
than or equal to
100%

Greater
than
100%

$

$

42,379 $

9,465

51,844 $

2,474 $

1,287

3,761 $

197

390

587

(1)  Excludes loans guaranteed by U.S. government-sponsored agencies, 

loans subject to LTSCs with U.S. government-sponsored agencies and 
loans recorded at fair value.

(2)  Excludes balances where LTV was not available. Such amounts are not 

material.

Consumer Credit Scores (FICO)
In the U.S., independent credit agencies rate an individual’s 
risk for assuming debt based on the individual’s credit history 
and assign every consumer a FICO credit score. These scores 
are continually updated by the agencies based upon an 
individual’s credit actions (e.g., taking out a loan or missed or 
late payments).

The following tables provide details on the FICO scores 

for Citi’s U.S. consumer loan portfolio based on end-of-period 
receivables. FICO scores are updated monthly for 
substantially all of the portfolio or, otherwise, on a quarterly 
basis for the remaining portfolio.

FICO score 
distribution in 
U.S. portfolio(1)(2)(3)

In millions of dollars

Residential first
mortgages

Home equity loans

Credit cards
Personal, small 
business and other

December 31, 2019

Less than
680

680 to 760

Greater
than 760

$

3,602 $

13,178 $

1,881

33,290

3,475

59,536

28,235

3,630

52,935

564

907

1,473

Total

$

39,337 $

77,096 $

86,273

FICO score 
distribution in 
U.S. portfolio(1)(2)(3)

In millions of dollars

Residential first
mortgages

Home equity loans

Credit cards
Personal, small 
business and other

December 31, 2018

Less than
680

680 to 760

Greater
than 760

$

4,530 $

13,848 $

2,438

32,686

4,296

58,722

625

1,097

26,546

4,471

51,299

1,121

83,437

Total

$

40,279 $

77,963 $

(1)  The FICO bands in the tables are consistent with general industry peer 

presentations. 

(2)  Excludes loans guaranteed by U.S. government-sponsored agencies, 
loans subject to long-term standby commitments (LTSC) with 
U.S. government-sponsored agencies and loans recorded at fair value.

(3)  Excludes balances where FICO was not available. Such amounts are not 

material.

192

Impaired Consumer Loans
A loan is considered impaired when Citi believes it is probable 
that all amounts due according to the original contractual 
terms of the loan will not be collected. Impaired consumer 
loans include non-accrual loans, as well as smaller-balance 
homogeneous loans whose terms have been modified due to 
the borrower’s financial difficulties and where Citi has granted 
a concession to the borrower. These modifications may 

include interest rate reductions and/or principal forgiveness. 
Impaired consumer loans exclude smaller-balance 
homogeneous loans that have not been modified and are 
carried on a non-accrual basis. 

The following tables present information about impaired 
consumer loans and interest income recognized on impaired 
consumer loans:

In millions of dollars

Mortgage and real estate

Residential first mortgages

Home equity loans

Credit cards

Installment and other

Personal, small business and other

Total

At and for the year ended December 31, 2019

Recorded
investment(1)(2)

Unpaid
principal 
balance

Related
specific 
allowance(3)

Average
carrying 
value(4)

Interest 
income
recognized(5)

$

$

1,666 $

1,838 $

161 $

1,925 $

592

1,931

824

2,288

703

738

123

771

135

637

1,890

754

4,892 $

5,688 $

1,190 $

5,206 $

60

9

103

55

227

(1)  Recorded investment in a loan includes net deferred loan fees and costs, unamortized premium or discount and direct write-downs and includes accrued interest 

only on credit card loans.

Included in the Allowance for loan losses.

(2)    $405 million of residential first mortgages, and $212 million of home equity loans do not have a specific allowance.
(3) 
(4)  Average carrying value represents the average recorded investment ending balance for the last four quarters and does not include the related specific allowance.
(5) 

Includes amounts recognized on both an accrual and cash basis.

In millions of dollars

Mortgage and real estate

Residential first mortgages

Home equity loans

Credit cards

Installment and other

Personal, small business and other

Total

At and for the year ended December 31, 2018

Recorded
investment(1)(2)

Unpaid
principal 
balance

Related
specific 
allowance(3)

Average
carrying 
value(4)

Interest 
income
recognized(5)(6)

$

$

2,130 $

2,329 $

178 $

2,483 $

684

1,818

946

1,842

452

666

122

677

139

698

1,815

500

5,084 $

5,783 $

1,116 $

5,496 $

81

12

105

22

220

(1)  Recorded investment in a loan includes net deferred loan fees and costs, unamortized premium or discount and direct write-downs and includes accrued interest 

only on credit card loans.

Included in the Allowance for loan losses.

(2)  $484 million of residential first mortgages and $263 million of home equity loans do not have a specific allowance.
(3) 
(4)  Average carrying value represents the average recorded investment ending balance for the last four quarters and does not include the related specific allowance.
(5) 
(6) 

Includes amounts recognized on both an accrual and cash basis.
Interest income recognized for the year ended December 31, 2017 was $342 million. 

193

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consumer Troubled Debt Restructurings

In millions of dollars, except number of
loans modified

Number of
loans modified

North America

For the year ended December 31, 2019

Post-
modification
recorded
investment(1)(2)

Deferred
principal(3)

Contingent
principal
forgiveness(4)

Principal
forgiveness(5)

Average
interest rate
reduction

Residential first mortgages

1,122 $

172 $

— $

— $

Home equity loans

Credit cards

Personal, small business and other

Total(6)
International

717

268,778

1,719

79

1,165

15

272,336 $

1,431 $

Residential first mortgages

Credit cards

Personal, small business and other

Total(6)

2,448 $

72,325

29,192

103,965 $

74 $

288

204

566 $

3

—

—

3 $

— $

—

—

— $

—

—

—

— $

— $

—

—

— $

—

—

—

—

—

—

10

6

16

—%

1

17

5

—%

17

9

In millions of dollars, except number of
loans modified

Number of
loans modified

North America

For the year ended December 31, 2018

Post-
modification
recorded
investment(1)(7)

Deferred
principal(3)

Contingent
principal
forgiveness(4)

Principal
forgiveness(5)

Average
interest rate
reduction

Residential first mortgages

2,019 $

300 $

2 $

— $

Home equity loans

Credit cards

   Personal, small business and other
Total(6)
International

Residential first mortgages

Credit cards
Personal, small business and other

Total(6)

1,381

243,253

1,349

130

978

12

248,002 $

1,420 $

2,572 $

77,823

30,849

111,244 $

85 $

323

216

624 $

5

—

—

7 $

— $

—

—

— $

—

—

—

— $

— $

—

—

— $

—

—

—

—

—

—

9

7

16

—%

1

18

4

—%

16

9

(1)  Post-modification balances include past due amounts that are capitalized at the modification date.
(2)  Post-modification balances in North America include $19 million of residential first mortgages and $7 million of home equity loans to borrowers who have gone 

through Chapter 7 bankruptcy in the year ended December 31, 2019. These amounts include $11 million of residential first mortgages and $6 million of home 
equity loans that were newly classified as TDRs during 2019, based on previously received OCC guidance.

(3)  Represents portion of contractual loan principal that is non-interest bearing but still due from the borrower. Such deferred principal is charged off at the time of 

permanent modification to the extent that the related loan balance exceeds the underlying collateral value.

(4)  Represents portion of contractual loan principal that is non-interest bearing and, depending upon borrower performance, eligible for forgiveness.
(5)  Represents portion of contractual loan principal that was forgiven at the time of permanent modification.
(6)  The above tables reflect activity for restructured loans that were considered TDRs during the year.
(7)  Post-modification balances in North America include $38 million of residential first mortgages and $12 million of home equity loans to borrowers who have gone 

through Chapter 7 bankruptcy in the year ended December 31, 2018. These amounts include $27 million of residential first mortgages and $10 million of home 
equity loans that were newly classified as TDRs during 2018, based on previously received OCC guidance.

194

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The following table presents consumer TDRs that defaulted for which the payment default occurred within one year of a 

permanent modification. Default is defined as 60 days past due.

In millions of dollars

North America

Residential first mortgages

Home equity loans

Credit cards
Personal, small business and other

Total

International

Residential first mortgages

Credit cards
Personal, small business and other

Total

Years ended December 31,

2019

2018

$

$

$

$

85 $

15

301

4

405 $

13 $

142

74

229 $

136

23

241

4

404

9

198

80

287

195

 
 
 
 
Corporate Loans
Corporate loans represent loans and leases managed by ICG. 
The following table presents information by corporate loan 
type:

In millions of dollars
In North America offices(1)
Commercial and industrial

Financial institutions
Mortgage and real estate(2)
Installment, revolving credit
and other

Lease financing

Total

In offices outside 
North America(1)

Commercial and industrial

Financial institutions
Mortgage and real estate(2)
Installment, revolving credit
and other

Lease financing

Governments and official
institutions

Total

Corporate loans, net of 
unearned income(3)

December 31,
2019

December 31,
2018

$

55,929 $

53,922

53,371

31,238

1,290

60,861

48,447

50,124

32,425

1,429

$

$

$

$

195,750 $

193,286

112,668 $

114,029

40,211

9,780

27,303

95

36,837

7,376

25,685

103

4,128

194,185 $

4,520

188,550

389,935 $

381,836

(1)  North America includes the U.S., Canada and Puerto Rico. Mexico is 
included in offices outside North America. The classification between 
offices in North America and outside North America is based on the 
domicile of the booking unit. The difference between the domicile of 
the booking unit and the domicile of the managing unit is not material.

(2)  Loans secured primarily by real estate.
(3)  Corporate loans are net of unearned income of ($814) million and 
($855) million at December 31, 2019 and 2018, respectively. 
Unearned income on corporate loans primarily represents interest 
received in advance, but not yet earned, on loans originated on a 
discounted basis.

The Company sold and/or reclassified to held-for-sale 
$2.6 billion and $1.0 billion of corporate loans during the 
years ended December 31, 2019 and 2018, respectively. The 
Company did not have significant purchases of corporate 

loans classified as held-for-investment for the years ended 
December 31, 2019 or 2018.
Lease financing
Citi is a lessor in the power, railcars, shipping and aircraft 
sectors, where the Company has executed operating, direct 
financing and leveraged leases. Citi’s $1.4 billion of lease 
financing receivables, as of December 31, 2019, is composed 
of approximately equal balances of direct financing lease 
receivables and net investments in leveraged leases. Citi uses 
the interest rate implicit in the lease to determine the present 
value of its lease financing receivables. Interest income on 
direct financing and leveraged leases during the year ended 
December 31, 2019 was not material.

The Company’s leases have an average remaining 
maturity of approximately three and a half years. In certain 
cases, Citi obtains residual value insurance from third parties 
and/or the lessee to manage the risk associated with the 
residual value of the leased assets. The receivable related to 
the residual value of the leased assets is $0.9 billion as of 
December 31, 2019, while the amount covered by residual 
value guarantees is $0.3 billion.

 The Company’s operating leases, where Citi is a lessor, 
are not significant to the Consolidated Financial Statements.

Delinquency Status
Citi generally does not manage corporate loans on a 
delinquency basis. Corporate loans are identified as impaired 
and placed on a cash (non-accrual) basis when it is 
determined, based on actual experience and a forward-
looking assessment of the collectability of the loan in full, 
that the payment of interest or principal is doubtful or when 
interest or principal is 90 days past due, except when the 
loan is well collateralized and in the process of collection. 
Any interest accrued on impaired corporate loans and leases 
is reversed at 90 days and charged against current earnings, 
and interest is thereafter included in earnings only to the 
extent actually received in cash. When there is doubt 
regarding the ultimate collectability of principal, all cash 
receipts are thereafter applied to reduce the recorded 
investment in the loan. While corporate loans are generally 
managed based on their internally assigned risk rating (see 
further discussion below), the following tables present 
delinquency information by corporate loan type. 

196

 
 
 
 
Corporate Loan Delinquencies and Non-Accrual Details at December 31, 2019 

In millions of dollars

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

Loans at fair value

Total

30–89 days
past due
and accruing(1)
$

676 $

 90 days
past due and
accruing(1)

Total past due
and accruing

Total
non-accrual(2)

Total
current(3)

Total
loans(4)

93 $

769 $

1,828 $

164,249 $

166,846

791

534

58

190

3

4

9

22

794

538

67

212

50

188

41

81

91,008

62,425

1,277

62,341

91,852

63,151

1,385

62,634

4,067

$

2,249 $

131 $

2,380 $

2,188 $

381,300 $

389,935

Corporate Loan Delinquencies and Non-Accrual Details at December 31, 2018

In millions of dollars

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

Loans at fair value

Total

30–89 days
past due
and accruing(1)
$

403 $

 90 days
past due and
accruing(1)

Total past due
and accruing

Total
non-accrual(2)

Total
current(3)

Total
loans(4)

111 $

514 $

1,119 $

173,257 $

174,890

87

128

5

151

7

5

10

52

94

133

15

203

102

215

—

75

85,088

57,152

1,517

59,149

85,284

57,500

1,532

59,427

3,203

$

774 $

185 $

959 $

1,511 $

376,163 $

381,836

(1)  Corporate loans that are 90 days past due are generally classified as non-accrual. Corporate loans are considered past due when principal or interest is 

contractually due but unpaid.

(2)  Non-accrual loans generally include those loans that are 90 days or more past due or those loans for which Citi believes, based on actual experience and a 

forward-looking assessment of the collectability of the loan in full, that the payment of interest or principal is doubtful.

(3)  Loans less than 30 days past due are presented as current.
(4)  Total loans include loans at fair value, which are not included in the various delinquency columns. 

Citigroup has a risk management process to monitor, 
evaluate and manage the principal risks associated with its 
corporate loan portfolio. As part of its risk management 
process, Citi assigns numeric risk ratings to its corporate 
loan facilities based on quantitative and qualitative 
assessments of the obligor and facility. These risk ratings are 
reviewed at least annually or more often if material events 
related to the obligor or facility warrant. Factors considered 
in assigning the risk ratings include financial condition of the 
obligor, qualitative assessment of management and strategy, 
amount and sources of repayment, amount and type of 
collateral and guarantee arrangements, amount and type of 
any contingencies associated with the obligor and the 
obligor’s industry and geography.

The obligor risk ratings are defined by ranges of default 
probabilities. The facility risk ratings are defined by ranges 
of loss norms, which are the product of the probability of 
default and the loss given default. The investment grade 
rating categories are similar to the category BBB-/Baa3 and 
above as defined by S&P and Moody’s. Loans classified 
according to the bank regulatory definitions as special 
mention, substandard and doubtful will have risk ratings 
within the non-investment-grade categories.

197

Impaired collateral-dependent loans and leases, where 
repayment is expected to be provided solely by the sale of 
the underlying collateral and there are no other available and 
reliable sources of repayment, are written down to the lower 
of carrying value or collateral value, less cost to sell. Cash-
basis loans are returned to an accrual status when all 
contractual principal and interest amounts are reasonably 
assured of repayment and there is a sustained period of 
repayment performance, generally six months, in accordance 
with the contractual terms of the loan.

Corporate Loans Credit Quality Indicators 

In millions of dollars
Investment grade(2)
Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

Total investment grade
Non-investment grade(2)
Accrual

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

Non-accrual

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

Recorded investment in loans(1)
December 31,
December 31,
2018
2019

$

110,797 $

113,925

$

$

80,533

27,571

816

57,339

73,533

26,799

1,035

58,916

277,056 $

274,208

54,220 $

11,269

3,811

528

5,206

1,828

50

188

41

81

53,942

10,866

4,200

497

5,753

1,119

102

215

—

75

Total non-investment grade

$

77,222 $

76,769

Non-rated private bank 
loans managed on a 
delinquency basis(2)
Loans at fair value

Corporate loans, net of
unearned income

$

$

31,590 $

4,067

27,656

3,203

389,935 $

381,836

(1)  Recorded investment in a loan includes net deferred loan fees and 

costs, unamortized premium or discount, less any direct write-downs.

(2)  Held-for-investment loans are accounted for on an amortized cost 

basis.

198

 
 
 
 
 
 
 
 
 
Non-Accrual Corporate Loans
The following tables present non-accrual loan information by corporate loan type and interest income recognized on non-accrual 
corporate loans:

In millions of dollars

Non-accrual corporate loans

At and for the year ended December 31, 2019

Recorded
investment(1)

Unpaid
principal balance

Related specific
allowance

Average
carrying value(2)

Interest income 
recognized(3)

Commercial and industrial

$

1,828 $

1,942 $

283 $

1,449 $

Financial institutions

Mortgage and real estate

Lease financing

Other

50

188

41

81

120

362

41

202

2

10

—

4

63

192

8

76

Total non-accrual corporate loans

$

2,188 $

2,667 $

299 $

1,788 $

33

—

—

—

9

42

In millions of dollars

Non-accrual corporate loans

At and for the year ended December 31, 2018

Recorded
investment(1)

Unpaid
principal balance

Related specific
allowance

Average
carrying value(2)

Interest income 
recognized(3)

Commercial and industrial

$

1,119 $

1,270 $

245 $

1,299 $

Financial institutions

Mortgage and real estate

Lease financing

Other

102

215

—

75

123

323

28

165

35

39

—

6

99

233

21

83

Total non-accrual corporate loans

$

1,511 $

1,909 $

325 $

1,735 $

49

—

1

—

6

56

In millions of dollars

Non-accrual corporate loans with specific allowance

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

Total non-accrual corporate loans with specific
allowance
Non-accrual corporate loans without specific allowance

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

Total non-accrual corporate loans without specific
allowance

$

$

$

$

December 31, 2019

December 31, 2018

Recorded
investment(1)

Related specific
allowance

Recorded
investment(1)

Related specific
allowance

714 $

283 $

801 $

40

48

—

7

2

10

—

4

76

100

—

24

809 $

299 $

1,001 $

1,114

10

140

41

74

1,379

  $

N/A $

318

26

115

—

51

510

245

35

39

—

6

325

N/A

(1)  Recorded investment in a loan includes net deferred loan fees and costs, unamortized premium or discount, less any direct write-downs.
(2)  Average carrying value represents the average recorded investment balance and does not include related specific allowance.
(3) 
N/A Not applicable

Interest income recognized for the year ended December 31, 2017 was $35 million.

199

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
— $

—

—

— $

8 $

—

8 $

264

16

—

280

TDRs
involving changes
in the amount
and/or timing of
both principal and
interest payments

146

57

203

Corporate Troubled Debt Restructurings

For the year ended December 31, 2019:

Carrying value of
TDRs modified during
the period

TDRs
involving changes
in the amount
and/or timing of
principal payments(1)

TDRs
involving changes
in the amount
and/or timing of
interest payments(2)

TDRs
involving changes
in the amount
and/or timing of
both principal and
interest payments

In millions of dollars

Commercial and industrial

Mortgage and real estate

Other

Total

$

$

283 $

16

6

305 $

19 $

—

6

25 $

For the year ended December 31, 2018:

In millions of dollars

Commercial and industrial

Mortgage and real estate

Total

Carrying value of
TDRs modified
during the period

TDRs
involving changes
in the amount
and/or timing of
principal payments(1)

TDRs
involving changes
in the amount
and/or timing of
interest payments(2)

$

$

159 $

60

219 $

5 $

3

8 $

(1)  TDRs involving changes in the amount or timing of principal payments may involve principal forgiveness or deferral of periodic and/or final principal 

payments. Because forgiveness of principal is rare for corporate loans, modifications typically have little to no impact on the loans’ projected cash flows and 
thus little to no impact on the allowance established for the loans. Charge-offs for amounts deemed uncollectable may be recorded at the time of the 
restructuring or may have already been recorded in prior periods such that no charge-off is required at the time of the modification.

(2)  TDRs involving changes in the amount or timing of interest payments may involve a below-market interest rate.

The following table presents total corporate loans modified in a TDR as well as those TDRs that defaulted and for which the 
payment default occurred within one year of a permanent modification. Default is defined as 60 days past due, except for 
classifiably managed commercial banking loans, where default is defined as 90 days past due.

In millions of dollars

TDR balances at
December 31, 2019

TDR loans in payment
default during the year
ended December 31, 2019

TDR balances at
December 31, 2018

TDR loans in payment default
during the year ended
December 31, 2018

Commercial and industrial

$

603 $

35 $

568 $

Financial institutions

Mortgage and real estate

Lease financing

Other
Total(1)

—

79

—

44

—

—

—

—

25

123

—

2

$

726 $

35 $

718 $

(1)  The above table reflects activity for loans outstanding that were considered TDRs as of the end of the reporting period.

111

—

—

—

—

111

200

15. ALLOWANCE FOR CREDIT LOSSES

In millions of dollars

Allowance for loan losses at beginning of period

Gross credit losses
Gross recoveries(1)

Net credit losses (NCLs)

NCLs

Net reserve builds (releases)

Net specific reserve builds (releases)

Total provision for loan losses

Other, net (see table below)

Allowance for loan losses at end of period

Allowance for credit losses on unfunded lending commitments at beginning of period

Provision (release) for unfunded lending commitments

Other, net
Allowance for credit losses on unfunded lending commitments at end of period(2)
Total allowance for loans, leases and unfunded lending commitments

2019

2018

2017

$

$

$

$

$

$

$

$

12,315 $

12,355 $

(9,341)

1,573

(7,768) $

7,768 $

364

86

8,218 $

18

12,783 $

1,367 $

92

(3)

1,456 $

14,239 $

(8,665)

1,552

(7,113) $

7,113 $

394

(153)

7,354 $

(281)

12,315 $

1,258 $

113

(4)

1,367 $

13,682 $

12,060

(8,673)

1,597

(7,076)

7,076

544

(117)

7,503

(132)

12,355

1,418

(161)

1

1,258

13,613

(1)  Recoveries have been reduced by certain collection costs that are incurred only if collection efforts are successful.
(2)  Represents additional credit loss reserves for unfunded lending commitments and letters of credit recorded in Other liabilities on the Consolidated Balance Sheet.

Other, net details

In millions of dollars

Sales or transfers of various consumer loan portfolios to HFS

Transfer of real estate loan portfolios

Transfer of other loan portfolios

Sales or transfers of various consumer loan portfolios to HFS

FX translation, primarily consumer

Other

Other, net

2019

2018

2017

$

$

$

(42) $

—

(42) $

60

—

(91) $

(110)

(201) $

(60)

(20)

18 $

(281) $

(106)

(155)

(261)

115

14

(132)

201

 
 Allowance for Credit Losses and End-of-Period Loans at December 31, 2019

In millions of dollars

Allowance for loan losses at beginning of year

Charge-offs

Recoveries

Replenishment of net charge-offs

Net reserve builds (releases)

Net specific reserve builds (releases)

Other

Ending balance

Allowance for loan losses

Collectively evaluated in accordance with ASC 450

Individually evaluated in accordance with ASC 310-10-35

Purchased credit impaired in accordance with ASC 310-30

Total allowance for loan losses

Loans, net of unearned income

Collectively evaluated in accordance with ASC 450

Individually evaluated in accordance with ASC 310-10-35

Purchased credit impaired in accordance with ASC 310-30

Held at fair value

Total loans, net of unearned income

Allowance for Credit Losses and End-of-Period Loans at December 31, 2018 

In millions of dollars

Allowance for loan losses at beginning of year

Charge-offs

Recoveries

Replenishment of net charge-offs

Net reserve builds (releases)

Net specific reserve builds (releases)

Other

Ending balance

Allowance for loan losses

Collectively evaluated in accordance with ASC 450

Individually evaluated in accordance with ASC 310-10-35

Purchased credit impaired in accordance with ASC 310-30

Total allowance for loan losses

Loans, net of unearned income

Collectively evaluated in accordance with ASC 450

Individually evaluated in accordance with ASC 310-10-35

Purchased credit impaired in accordance with ASC 310-30

Held at fair value

Total loans, net of unearned income

202

$

$

$

$

$

Corporate

Consumer

Total

2,811 $

(487)

9,504 $

(8,854)

12,315

(9,341)

95

392

96

(21)

—

1,478

7,376

268

107

18

1,573

7,768

364

86

18

2,886 $

9,897 $

12,783

2,587 $

8,706 $

299

—

1,190

1

11,293

1,489

1

2,886 $

9,897 $

12,783

383,828 $

304,510 $

688,338

2,040

—

4,067

4,892

128

18

6,932

128

4,085

$

389,935 $

309,548 $

699,483

$

$

$

$

$

Corporate

Consumer

Total

2,943 $

(343)

9,412 $

(8,322)

138

205

42

(151)

(23)

1,414

6,908

352

(2)

(258)

12,355

(8,665)

1,552

7,113

394

(153)

(281)

2,811 $

9,504 $

12,315

2,486 $

8,386 $

325

—

1,116

2

10,872

1,441

2

2,811 $

9,504 $

12,315

377,186 $

297,128 $

674,314

1,447

—

3,203

5,084

128

20

6,531

128

3,223

$

381,836 $

302,360 $

684,196

 
 
 
 
 
 
Allowance for Credit Losses at December 31, 2017 

In millions of dollars

Allowance for loan losses at beginning of year

Charge-offs

Recoveries

Replenishment of net charge-offs

Net reserve builds (releases)

Net specific reserve builds (releases)

Other

Ending balance

Corporate

Consumer

Total

$

3,218 $

(632)

153

479

(274)

(31)

30

8,842 $

(8,041)

1,444

6,597

818

(86)

(162)

12,060

(8,673)

1,597

7,076

544

(117)

(132)

$

2,943 $

9,412 $

12,355

203

16.   GOODWILL AND INTANGIBLE ASSETS

Goodwill

The changes in Goodwill by segment were as follows:

In millions of dollars
Balance at December 31, 2016(1)

Foreign exchange translation
Divestitures(2)
Impairment of  goodwill(3)

Balance at December 31, 2017

Foreign exchange translation
Divestitures(4)

Balance at December 31, 2018

Foreign exchange translation

Balance at December 31, 2019

Global
Consumer
Banking

Institutional
Clients Group

Corporate/
Other

Total

$

$

$

$

$

$

$

11,874 $

286 $

(32)

—

9,741 $

443 $

(72)

—

12,128 $

10,112 $

(41) $

—

12,087 $

15 $

(153) $

—

9,959 $

65 $

12,102 $

10,024 $

44 $

— $

—

(28)

16 $

— $

(16)

— $

— $

— $

21,659

729

(104)

(28)

22,256

(194)

(16)

22,046

80

22,126

(1)  December 31, 2016 has been revised to reflect intersegment goodwill allocations that resulted from the 2019 reorganization of the Citi commercial banking 

business from GCB to ICG. See Note 3 to the Consolidated Financial Statements.

(2)    Primarily related to the sale of a fixed income analytics business and a fixed income index business completed in 2017 and agreement to sell a Mexico asset 

management business as of December 31, 2017. See Note 2 to the Consolidated Financial Statements.

(3)  Related to the transfer of the mortgage servicing business from North America GCB to Corporate/Other effective January 1, 2017.
(4)  Primarily related to the sale of consumer operations in Colombia in 2018.

Goodwill impairment testing is performed at the level 

below each business segment (referred to as a reporting 
unit). See Note 3 for further information on business 
segments.

The Company performed its annual goodwill 
impairment test as of July 1, 2019. The fair values of the 
Company’s reporting units exceeded their carrying values 
by approximately 33% to 134% and no reporting unit is at 
risk of impairment. 

Effective in the fourth quarter of 2019, the Citi 

commercial banking business, previously included in North 
America GCB, Latin America GCB and Asia GCB, was 
reorganized and is now part of ICG. Goodwill was allocated 
to the transferred business based on relative fair value to the 
legacy reporting units. An interim goodwill impairment test 
was performed under both the legacy and current reporting 
unit structures, which resulted in no impairment. No 
additional triggering events were identified and no goodwill 
was impaired during the year.

204

 
Intangible Assets
The components of intangible assets were as follows:

In millions of dollars

Purchased credit card relationships
Credit card contract-related intangibles(1)
Core deposit intangibles

Other customer relationships

Present value of future profits

Indefinite-lived intangible assets

Other

Intangible assets (excluding MSRs)
Mortgage servicing rights (MSRs)(2)
Total intangible assets

December 31, 2019

December 31, 2018

Gross
carrying
amount

Accumulated
amortization

Net
carrying
amount

Gross
carrying
amount

Accumulated
amortization

Net
carrying
amount

$

5,676 $

4,059 $

1,617 $

5,733 $

3,936 $ 1,797

5,393

3,069

2,324

5,225

2,791

2,434

434

424

34

228

82

433

275

31

—

77

1

149

3

228

5

419

470

32

218

84

415

299

29

—

75

4

171

3

218

9

$

$

12,271 $

7,944 $

4,327 $

12,181 $

7,545 $ 4,636

495

—

495

584

—

584

12,766 $

7,944 $

4,822 $

12,765 $

7,545 $ 5,220

(1)  Primarily reflects contract-related intangibles associated with the American Airlines, The Home Depot, Costco and AT&T credit card program agreements, 

which represented 96% of the aggregate net carrying amount as of December 31, 2019.

(2)  For additional information on Citi’s MSRs, see Note 21 to the Consolidated Financial Statements. 

Intangible assets amortization expense was $564 million, 
$557 million and $603 million for 2019, 2018 and 2017, 
respectively. Intangible assets amortization expense is 
estimated to be $424 million in 2020, $399 million in 2021, 
$1,025 million in 2022, $226 million in 2023 and $219 
million in 2024.

The changes in intangible assets were as follows:

Net carrying
amount at

Net carrying
amount at

December 31,
2019

FX
translation
and other

In millions of dollars
Purchased credit card relationships(1)
Credit card contract-related intangibles(2)
Core deposit intangibles

Other customer relationships

Present value of future profits

Indefinite-lived intangible assets

Other

Intangible assets (excluding MSRs)
Mortgage servicing rights (MSRs)(3)
Total intangible assets

December 31,
2018

Acquisitions/
divestitures

Amortization

Impairments

$

$

$

1,797 $

2,434

4

171

3

218

9

9 $

(189) $

— $

73

—

—

—

4

6

(336)

(4)

(24)

—

—

(11)

—

—

—

—

—

—

— $

153

1

2

—

6

1

4,636 $

92 $

(564) $

— $

163 $

584

5,220

$

1,617

2,324

1

149

3

228

5

4,327

495

4,822

(1)  Reflects intangibles for the value of cardholder relationships, which are discrete from partner contract-related intangibles and include credit card accounts 

primarily in the Costco, Macy’s and Sears portfolios. 

(2)  Primarily reflects contract-related intangibles associated with the American Airlines, The Home Depot, Costco and AT&T credit card program agreements, 

which represent 96% of the aggregate net carrying amount at December 31, 2019 and 2018.

(3)  For additional information on Citi’s MSRs, including the rollforward from 2018 to 2019, see Note 21 to the Consolidated Financial Statements. 

205

 
17.   DEBT

Short-Term Borrowings

December 31,

2019

2018

In millions of dollars

Balance

Commercial paper
Bank(1)
Broker-dealer and 
other(2)
Total commercial
paper
Other borrowings(3)
Total

$10,155

6,321

$16,476

28,573

$45,049

Weighted
average
coupon

Weighted
average
coupon

Balance

$13,238

—

1.98% $13,238

2.57

19,108

$32,346

1.95%

2.99

(1)  Represents Citibank entities as well as other bank entities.
(2)  Represents broker-dealer and other non-bank subsidiaries that are 
consolidated into Citigroup Inc., the parent holding company.
Includes borrowings from the Federal Home Loan Banks and other 
market participants. At December 31, 2019 and 2018, collateralized 
short-term advances from the Federal Home Loan Banks were $17.6 
billion and $9.5 billion, respectively.

(3) 

Borrowings under bank lines of credit may be at interest 

rates based on LIBOR, CD rates, the prime rate or bids 
submitted by the banks. Citigroup pays commitment fees for 
its lines of credit.

Some of Citigroup’s non-bank subsidiaries have credit 
facilities with Citigroup’s subsidiary depository institutions, 
including Citibank. Borrowings under these facilities are 
secured in accordance with Section 23A of the Federal 
Reserve Act.

Citigroup Global Markets Holdings Inc. (CGMHI) has 
borrowing agreements consisting of facilities that CGMHI 
has been advised are available, but where no contractual 
lending obligation exists. These arrangements are reviewed 
on an ongoing basis to ensure flexibility in meeting 
CGMHI’s short-term requirements.

Long-Term Debt

Balances at
December 31,

Weighted
average
coupon(1) Maturities

2019

2018

3.11% 2020-2098 $ 123,292 $ 117,511

5.59

2022-2046

25,463

24,545

8.15

2036-2067

1,722

1,711

2.51

2020-2038

53,340

61,237

2.43

2020-2098

44,817

26,947

2.37

2022-2046

126

48

3.28%

$ 248,760 $ 231,999

$ 221,449 $ 205,695

25,589

24,593

1,722

1,711

$ 248,760 $ 231,999

In millions of
dollars
Citigroup Inc.(2)
Senior debt

Subordinated 
debt(3)
Trust preferred 
    securities
Bank(4)
Senior debt
Broker-dealer(5)
Senior debt
Subordinated 
debt(3)
Total

Senior debt

Subordinated 
debt(3)
Trust preferred 
    securities

Total

(1)  The weighted average coupon excludes structured notes accounted for 

at fair value.

(2)  Represents the parent holding company.
(3) 

Includes notes that are subordinated within certain countries, regions 
or subsidiaries.

(4)  Represents Citibank entities as well as other bank entities. At 

December 31, 2019 and 2018, collateralized long-term advances from 
the Federal Home Loan Banks were $5.5 billion and $10.5 billion, 
respectively.

(5)  Represents broker-dealer and other non-bank subsidiaries that are 
consolidated into Citigroup Inc., the parent holding company.

The Company issues both fixed- and variable-rate debt 

in a range of currencies. It uses derivative contracts, 
primarily interest rate swaps, to effectively convert a portion 
of its fixed-rate debt to variable-rate debt. The maturity 
structure of the derivatives generally corresponds to the 
maturity structure of the debt being hedged. In addition, the 
Company uses other derivative contracts to manage the 
foreign exchange impact of certain debt issuances. At 
December 31, 2019, the Company’s overall weighted 
average interest rate for long-term debt, excluding structured 
notes accounted for at fair value, was 3.28% on a contractual 
basis and 3.54% including the effects of derivative contracts.

206

Aggregate annual maturities of long-term debt obligations (based on final maturity dates) including trust preferred securities are as 
follows:

In millions of dollars

Citigroup Inc.

Bank

Broker-dealer

Total

2020

2021

2022

2023

2024

Thereafter

Total

$

$

7,033 $

15,208 $

13,061 $

14,202 $

8,247 $

92,726 $

150,477

20,654

9,570

14,023

8,852

8,471

5,558

2,634

3,292

4,417

3,359

3,141

14,312

53,340

44,943

37,257 $

38,083 $

27,090 $

20,128 $

16,023 $

110,179 $

248,760

The following table summarizes Citi’s outstanding trust preferred securities at December 31, 2019:

Trust

Issuance
date

Securities
issued

Liquidation
value(1)

Coupon
rate(2)

 In millions of dollars, except securities and share amounts

Junior subordinated debentures owned by trust

Common
shares
issued
to parent

Amount

Maturity

Redeemable
by issuer
beginning

Citigroup Capital III

Dec. 1996

194,053 $

194

7.625%

6,003 $

200

Dec. 1, 2036

Not redeemable

Citigroup Capital XIII

Sept. 2010 89,840,000

Citigroup Capital XVIII

June 2007

99,901

Total obligated

  $

3 mo LIBOR
+ 637 bps
3 mo LIBOR
+ 88.75 bps

2,246

132

2,572

1,000

2,246

Oct. 30, 2040

Oct. 30, 2015

50

132

June 28, 2067

June 28, 2017

$

2,578

Note: Distributions on the trust preferred securities and interest on the subordinated debentures are payable semiannually for Citigroup Capital III and Citigroup 
Capital XVIII and quarterly for Citigroup Capital XIII.
(1)  Represents the notional value received by outside investors from the trusts at the time of issuance. This differs from Citi’s balance sheet carrying value due 

primarily to unamortized discount and issuance costs.
In each case, the coupon rate on the subordinated debentures is the same as that on the trust preferred securities. 

(2) 

207

 
 
 
 
 
 
 
 
 
 
18. REGULATORY CAPITAL 

Citigroup is subject to risk-based capital and leverage 
standards issued by the Federal Reserve Board, which 
constitute the U.S. Basel III rules. Citi’s U.S.-insured 
depository institution subsidiaries, including Citibank, are 
subject to similar standards issued by their respective primary 
federal bank regulatory agencies. These standards are used to 
evaluate capital adequacy and include the required minimums 

shown in the following table. The regulatory agencies are 
required by law to take specific, prompt corrective actions 
with respect to institutions that do not meet minimum capital 
standards.

 The following table sets forth for Citigroup and Citibank 
the regulatory capital tiers, total risk-weighted assets, quarterly 
adjusted average total assets, Total Leverage Exposure, risk-
based capital ratios and leverage ratios:

In millions of dollars, except ratios

Common Equity Tier 1 Capital

Tier 1 Capital
Total Capital (Tier 1 Capital + Tier 2 
Capital)—Standardized Approach
Total Capital (Tier 1 Capital + Tier 2 
Capital)—Advanced Approaches

Total risk-weighted assets—
Standardized Approach

Total risk-weighted assets—Advanced
Approaches
Quarterly adjusted average total assets(1)
Total Leverage Exposure(2)
Common Equity Tier 1 Capital ratio(3)
Tier 1 Capital ratio(3)
Total Capital ratio(3)
Tier 1 Leverage ratio

Supplementary Leverage ratio

Stated
minimum

Well-
capitalized
minimum

Citigroup

Citibank

December 31,
2019

December 31,
2018

  $

137,798

$

155,805

139,252

158,122

Well-
capitalized
minimum

December 31,
2019

December 31,
2018

  $

130,791

$

132,918

129,091

131,215

193,682

195,440

157,324

155,154

181,337

183,144

145,989

144,358

1,166,523

1,174,448

1,019,916

1,032,809

1,135,553

1,957,039

2,507,891

1,131,933

1,896,959

2,465,641

932,432

1,459,851

1,951,701

926,229

1,398,875

1,914,663

4.5%

    N/A

11.81%

11.86%

6.5%

12.82%

12.50%

6.0

8.0

4.0

3.0

6.0%

10.0

N/A

N/A

13.36

15.97

7.96

6.21

13.46

16.18

8.34

6.41

8.0

10.0

5.0

6.0

13.03

15.43

9.10

6.81

12.70

15.02

9.38

6.85

(1)  Tier 1 Leverage ratio denominator. 
(2)  Supplementary Leverage ratio denominator. 
(3)  As of December 31, 2019 and 2018, Citigroup’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the Basel III 
Standardized Approach, whereas the reportable Total Capital ratios were the lower derived under the Basel III Advanced Approaches framework. As of 
December 31, 2019 and 2018, Citibank’s reportable Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios were the lower derived under the Basel 
III Standardized Approach.

N/A  Not applicable

As indicated in the table above, Citigroup and Citibank 

were “well capitalized” under the current federal bank 
regulatory agency definitions as of December 31, 2019 and 
2018.

Banking Subsidiaries—Constraints on Dividends
There are various legal limitations on the ability of Citigroup’s 
subsidiary depository institutions to extend credit, pay 
dividends or otherwise supply funds to Citigroup and its non-
bank subsidiaries. The approval of the Office of the 
Comptroller of the Currency is required if total dividends 
declared in any calendar year were to exceed amounts 
specified by the agency’s regulations. 

In determining the dividends, each subsidiary depository 

institution must also consider its effect on applicable risk-
based capital and leverage ratio requirements, as well as 
policy statements of the federal bank regulatory agencies that 
indicate that banking organizations should generally pay 
dividends out of current operating earnings. Citigroup 
received $17.3 billion and $8.3 billion in dividends from 
Citibank during 2019 and 2018, respectively.

208

 
 
 
 
 
 
19.   CHANGES IN ACCUMULATED OTHER COMPREHENSIVE INCOME (LOSS) (AOCI)

Changes in each component of Citigroup’s Accumulated other comprehensive income (loss) were as follows:

In millions of dollars

Balance, December 31, 2016

Adjustment to opening balance, net 
  of taxes(6)
Adjusted balance, beginning of period
Impact of Tax Reform(7)
Other comprehensive income before     
  reclassifications
Increase (decrease) due to amounts 
  reclassified from AOCI 
Change, net of taxes 
Balance, December 31, 2017

Adjustment to opening balance, net 
  of taxes(8)
Adjusted balance, beginning of period

Other comprehensive income before
reclassifications

Increase (decrease) due to amounts 
reclassified from AOCI(9)
Change, net of taxes 
Balance at December 31, 2018

Other comprehensive income before 
  reclassifications

Increase (decrease) due to amounts 
  reclassified from AOCI

Change, net of taxes

Balance at December 31, 2019

Net
unrealized
gains
(losses)
on
investment
securities

Debt 
valuation 
adjustment 
(DVA)(1)

Cash 
flow 
hedges(2)

Benefit 
plans(3)

Foreign
currency
translation
adjustment 
(CTA), net 
of hedges(4)

Excluded 
component 
of fair 
value 
hedges(5)

Accumulated
other
comprehensive
income (loss)

$

$

$

$

$

$

$

$

$

$

$

$

(799) $

(352) $

(560) $

(5,164) $

(25,506) $

— $

(32,381)

504 $

(295) $

(223) $

— $

— $

— $

— $

(352) $

(139) $

(560) $

(5,164) $

(25,506) $

(113) $

(1,020) $

(1,809) $

(186)

(426)

(111)

(158)

1,607

(454)

(863) $

(4)

86

159

—

(569) $

(138) $

(1,019) $

(202) $

(1,158) $

(921) $

(698) $

(6,183) $

(25,708) $

(3) $

— $

— $

— $

— $

(1,161) $

(921) $

(698) $

(6,183) $

(25,708) $

— $

— $

— $

—

—

— $

— $

— $

— $

504

(31,877)

(3,304)

726

(213)

(2,791)

(34,668)

(3)

(34,671)

(866)

1,081

(135)

(240)

(2,607)

(57)

(2,824)

(223)

(1,089) $

(2,250) $

32

105

166

245

1,113 $

(30) $

(74) $

(2,362) $

192 $

(728) $

(6,257) $

(28,070) $

3,065

(1,151)

(1,080)

15

549

302

(758)

(647)

206

326

1,985 $

(1,136) $

851 $

(552) $

(321) $

(265) $

(944) $

123 $

(6,809) $

(28,391) $

—

(57) $

(57) $

25

—

25 $

(32) $

325

(2,499)

(37,170)

1,083

(231)

852

(36,318)

(1)  Changes in DVA are reflected as a component of AOCI, pursuant to the adoption of ASU 2016-01 relating to the presentation of DVA on fair value option 

liabilities. 

(2)  Primarily driven by Citi’s pay fixed/receive floating interest rate swap programs that hedge the floating rates on liabilities. 
(3)  Primarily reflects adjustments based on the quarterly actuarial valuations of the Company’s significant pension and postretirement plans, annual actuarial 

valuations of all other plans and amortization of amounts previously recognized in other comprehensive income. 

(4)  Primarily reflects the movements in (by order of impact) the Indian rupee, Brazilian real, Chilean peso, and Euro against the U.S. dollar and changes in related 
tax effects and hedges for the year ended December 31, 2019. Primarily reflects the movements in (by order of impact) the Brazilian real, Indian rupee, 
Mexican peso, and Australian dollar against the U.S. dollar and changes in related tax effects and hedges for the year ended December 31, 2018. Primarily 
reflects the movements in (by order of impact) the Euro, Mexican peso, Polish zloty and South Korean won against the U.S. dollar and changes in related tax 
effects and hedges for the year ended December 31, 2017. Amounts recorded in the CTA component of AOCI remain in AOCI until the sale or substantial 
liquidation of the foreign entity, at which point such amounts related to the foreign entity are reclassified into earnings.

(5)  Beginning in the first quarter of 2018, changes in the excluded component of fair value hedges are reflected as a component of AOCI, pursuant to the early 

adoption of ASU 2017-12, Targeted Improvements to Accounting for Hedging Activities. See Note 1 of the Consolidated Financial Statements for further 
information regarding this change.
In the second quarter of 2017, Citi early adopted ASU 2017-08. Upon adoption, a cumulative effect adjustment was recorded to reduce Retained earnings, 
effective January 1, 2017, for the incremental amortization of cumulative fair value hedge adjustments on callable state and municipal debt securities. See 
Note 1 to the Consolidated Financial Statements.
In the fourth quarter of 2017, Citi adopted ASU 2018-02, which transferred these amounts from AOCI to Retained earnings. See Note 1 to the Consolidated 
Financial Statements.

(6) 

(7) 

(8)  Citi adopted ASU 2016-01 and ASU 2018-03 on January 1, 2018. Upon adoption, a cumulative effect adjustment was recorded from AOCI to Retained 
earnings for net unrealized gains on former AFS equity securities. For additional information, see Note 1 to the Consolidated Financial Statements.
Includes the impact of the release of foreign currency translation adjustment, net of hedges, upon meeting the accounting trigger for substantial liquidation of 
Citi’s Japan Consumer Finance business during the fourth quarter of 2018. See Note 1 to the Consolidated Financial Statements.

(9) 

209

The pretax and after-tax changes in each component of Accumulated other comprehensive income (loss) were as follows:

In millions of dollars
Balance, December 31, 2016
Adjustment to opening balance(2)
Adjusted balance, beginning of period
Change in net unrealized gains (losses) on investment securities
Debt valuation adjustment (DVA)
Cash flow hedges
Benefit plans
Foreign currency translation adjustment
Change
Balance, December 31, 2017
Adjustment to opening balance(3)
Adjusted balance, beginning of period
Change in net unrealized gains (losses) on investment securities
Debt valuation adjustment (DVA)
Cash flow hedges
Benefit plans
Foreign currency translation adjustment
Excluded component of fair value hedges
Change
Balance, December 31, 2018
Change in net unrealized gains (losses) on AFS debt securities
Debt valuation adjustment (DVA)
Cash flow hedges
Benefit plans
Foreign currency translation adjustment
Excluded component of fair value hedges
Change
Balance, December 31, 2019

Pretax

Tax effect(1)

After-tax

$

$

$
$

$

$
$

$
$

(42,035) $
803
(41,232) $
(1,088)
(680)
(37)
14
1,795

4 $
(41,228) $

(4)

(41,232) $
(1,435)
1,415
(38)
(94)
(2,624)
(74)
(2,850) $
(44,082) $
2,633
(1,473)
1,120
(671)
(332)
33
1,310 $
(42,772) $

9,654 $
(299)
9,355 $
225
111
(101)
(1,033)
(1,997)
(2,795) $
6,560 $
1
6,561 $
346
(302)
8
20
262
17
351 $
6,912 $
(648)
337
(269)
119
11
(8)
(458) $
6,454 $

(32,381)
504
(31,877)
(863)
(569)
(138)
(1,019)
(202)
(2,791)
(34,668)
(3)
(34,671)
(1,089)
1,113
(30)
(74)
(2,362)
(57)
(2,499)
(37,170)
1,985
(1,136)
851
(552)
(321)
25
852
(36,318)

(1) 
(2) 

Includes the impact of ASU 2018-02, which transferred amounts from AOCI to Retained earnings. See Note 1 to the Consolidated Financial Statements.
In the second quarter of 2017, Citi early adopted ASU 2017-08. Upon adoption, a cumulative effect adjustment was recorded to reduce Retained earnings, 
effective January 1, 2017, for the incremental amortization of cumulative fair value hedge adjustments on callable state and municipal debt securities. See 
Note 1 to the Consolidated Financial Statements.

(3)  Citi adopted ASU 2016-01 and ASU 2018-03 on January 1, 2018. Upon adoption, a cumulative effect adjustment was recorded from AOCI to Retained 
earnings for net unrealized gains on former AFS equity securities. For additional information, see Note 1 to the Consolidated Financial Statements.

210

The Company recognized pretax gains (losses) related to amounts in AOCI reclassified to the Consolidated Statement of Income as 
follows:

In millions of dollars

Realized (gains) losses on sales of investments

Gross impairment losses

Subtotal, pretax

Tax effect

Net realized (gains) losses on investments, after-tax(1)
Realized DVA (gains) losses on fair value option liabilities, pretax

Tax effect

Net realized DVA, after-tax

Interest rate contracts

Foreign exchange contracts

Subtotal, pretax

Tax effect

Amortization of cash flow hedges, after-tax(2)
Amortization of unrecognized

Prior service cost (benefit)

Net actuarial loss

Curtailment/settlement impact(3)

Subtotal, pretax

Tax effect

Amortization of benefit plans, after-tax(3)
Foreign currency translation adjustment

Tax effect

Foreign currency translation adjustment

Total amounts reclassified out of AOCI, pretax

Total tax effect

Total amounts reclassified out of AOCI, after-tax

Increase (decrease) in AOCI due to amounts reclassified to 
Consolidated Statement of Income

Year ended December 31,

2019

2018

2017

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

(1,474) $

23

(1,451) $

371

(1,080) $

20 $

(5)

15 $

384 $

7

391 $

(89)

302 $

(12) $

286

1

275 $

(69)

206 $

— $

326

326 $

(765) $

534

(231) $

(421) $

125

(296) $

73

(223) $

41 $

(9)

32 $

301 $

17

318 $

(213)

105 $

(34) $

248

6

220 $

(54)

166 $

34 $

211

245 $

317 $

8

325 $

(778)

63

(715)

261

(454)

(7)

3

(4)

126

10

136

(50)

86

(42)

271

17

246

(87)

159

—

—

—

(340)

127

(213)

(1)  The pretax amount is reclassified to Realized gains (losses) on sales of investments, net and Gross impairment losses in the Consolidated Statement of 

Income. See Note 13 to the Consolidated Financial Statements for additional details.

(2)  See Note 22 to the Consolidated Financial Statements for additional details.
(3)  See Note 8 to the Consolidated Financial Statements for additional details.

211

20.   PREFERRED STOCK

The following table summarizes the Company’s preferred stock outstanding:

Series A(1)
Series B(2)
Series D(3)
Series J(4)
Series K(5)
Series L(6)
Series M(7)
Series N(8)
Series O(9)
Series P(10)
Series Q(11)
Series R(12)
Series S(13)
Series T(14)
Series U(15)

Issuance date

Redeemable by issuer
beginning

Dividend
rate

October 29, 2012

January 30, 2023

5.950% $

December 13, 2012

February 15, 2023

April 30, 2013

May 15, 2023

September 19, 2013

September 30, 2023

October 31, 2013

November 15, 2023

February 12, 2014

February 12, 2019

April 30, 2014

May 15, 2024

October 29, 2014

November 15, 2019

March 20, 2015

March 27, 2020

April 24, 2015

May 15, 2025

August 12, 2015

August 15, 2020

November 13, 2015

November 15, 2020

February 2, 2016

February 12, 2021

April 25, 2016

August 15, 2026

September 12, 2019

September 12, 2024

5.900

5.350

7.125

6.875

6.875

6.300

5.800

5.875

5.950

5.950

6.125

6.300

6.250

5.000

 Redemption
price per
depositary
share/
preference
share

1,000

1,000

1,000

25

25

25

1,000

1,000

1,000

1,000

1,000

1,000

Number
of
depositary
shares
1,500,000 $

750,000

1,250,000

38,000,000

59,800,000

19,200,000

1,750,000

1,500,000

1,500,000

2,000,000

1,250,000

1,500,000

25

41,400,000

1,000

1,000

1,500,000

1,500,000

Carrying value
 in millions of dollars

December 31,
2019

December 31,
2018

1,500 $

750

1,250

950

1,495

—

1,750

—

1,500

2,000

1,250

1,500

1,035

1,500

1,500

1,500

750

1,250

950

1,495

480

1,750

1,500

1,500

2,000

1,250

1,500

1,035

1,500

—

$

17,980 $

18,460

(1) 

(2) 

(3) 

(4) 

(5) 

Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable semiannually on January 30 and July 30 at a fixed rate until January 30, 2023, thereafter payable quarterly on January 30, April 30, July 30 and 
October 30 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable semiannually on February 15 and August 15 at a fixed rate until February 15, 2023, thereafter payable quarterly on February 15, May 15, August 15 and 
November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors. 
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable semiannually on May 15 and November 15 at a fixed rate until May 15, 2023, thereafter payable quarterly on February 15, May 15, August 15 and 
November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
Issued as depositary shares, each representing a 1/1,000th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable quarterly on March 30, June 30, September 30 and December 30 at a fixed rate until September 30, 2023, thereafter payable quarterly on the same dates at 
a floating rate, in each case when, as and if declared by the Citi Board of Directors. 
Issued as depositary shares, each representing a 1/1,000th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable quarterly on February 15, May 15, August 15 and November 15 at a fixed rate until November 15, 2023, thereafter payable quarterly on the same dates at 
a floating rate, in each case when, as and if declared by the Citi Board of Directors. 

(6)  The Series L preferred stock was redeemed in full on February 12, 2019.
(7) 

Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable semiannually on May 15 and November 15 at a fixed rate until May 15, 2024, thereafter payable quarterly on February 15, May 15, August 15 and 
November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

(8)  The Series N preferred stock was redeemed in full on November 15, 2019.
(9) 

Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable semiannually on March 27 and September 27 at a fixed rate until, but excluding, March 27, 2020, and thereafter payable quarterly on March 27, June 27, 
September 27 and December 27 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

(10)  Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable semiannually on May 15 and November 15 at a fixed rate until, but excluding, May 15, 2025, and thereafter payable quarterly on February 15, May 15, 
August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

(11)  Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable semiannually on February 15 and August 15 at a fixed rate until, but excluding, August 15, 2020, and thereafter payable quarterly on February 15, May 
15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

(12)  Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 

payable semiannually on May 15 and November 15 at a fixed rate until, but excluding, November 15, 2020, and thereafter payable quarterly on February 15, May 
15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

(13)  Issued as depositary shares, each representing a 1/1,000th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable quarterly on February 12, May 12, August 12 and November 12 at a fixed rate, in each case when, as and if declared by the Citi Board of Directors.
(14)  Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 
payable semiannually on February 15 and August 15 at a fixed rate until, but excluding, August 15, 2026, thereafter payable quarterly on February 15, May 15, 
August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

212

 
 
 
 
 
 
(15)  Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are 

payable semiannually on March 12 and September 12 at a fixed rate until, but excluding, September 12, 2024, thereafter payable quarterly on March 12, June 12, 
September 12 and December 12 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

During 2019, Citi distributed $1,109 million in dividends 
on its outstanding preferred stock. On January 15, 2020, Citi 
declared preferred dividends of approximately $291 million 
for the first quarter of 2020. During the first quarter of 2020, 
Citi issued 1.5 million Series V preferred shares for $1.5 
billion. Semi-annual dividends on Series V, assuming such 
dividends are declared by the Citi Board of Directors, will be 
distributed beginning in the third quarter of 2020. As of 
February 21, 2020, Citi estimates it will distribute preferred 
dividends of approximately $253 million, $328 million and 
$253 million in the second, third and fourth quarters of 2020, 
respectively. 

213

21. SECURITIZATIONS AND VARIABLE INTEREST 
ENTITIES

Uses of Special Purpose Entities
A special purpose entity (SPE) is an entity designed to fulfill a 
specific limited need of the company that organized it. The 
principal uses of SPEs by Citi are to obtain liquidity and 
favorable capital treatment by securitizing certain financial 
assets, to assist clients in securitizing their financial assets and 
to create investment products for clients. SPEs may be 
organized in various legal forms, including trusts, partnerships 
or corporations. In a securitization, through the SPE’s issuance 
of debt and equity instruments, certificates, commercial paper 
or other notes of indebtedness, the company transferring assets 
to the SPE converts all (or a portion) of those assets into cash 
before they would have been realized in the normal course of 
business. These issuances are recorded on the balance sheet of 
the SPE, which may or may not be consolidated onto the 
balance sheet of the company that organized the SPE.

Investors usually have recourse only to the assets in the 
SPE, but may also benefit from other credit enhancements, 
such as a collateral account, a line of credit or a liquidity 
facility, such as a liquidity put option or asset purchase 
agreement. Because of these enhancements, the SPE issuances 
typically obtain a more favorable credit rating than the 
transferor could obtain for its own debt issuances. This results 
in less expensive financing costs than unsecured debt. The 
SPE may also enter into derivative contracts in order to 
convert the yield or currency of the underlying assets to match 
the needs of the SPE investors or to limit or change the credit 
risk of the SPE. Citigroup may be the provider of certain 
credit enhancements as well as the counterparty to any related 
derivative contracts.

Most of Citigroup’s SPEs are variable interest entities 

(VIEs), as described below.

Variable Interest Entities
VIEs are entities that have either a total equity investment that 
is insufficient to permit the entity to finance its activities 
without additional subordinated financial support or whose 
equity investors lack the characteristics of a controlling 
financial interest (i.e., ability to make significant decisions 
through voting rights or similar rights and a right to receive 
the expected residual returns of the entity or an obligation to 
absorb the expected losses of the entity). Investors that finance 
the VIE through debt or equity interests or other counterparties 
providing other forms of support, such as guarantees, certain 
fee arrangements or certain types of derivative contracts, are 
variable interest holders in the entity.

The variable interest holder, if any, that has a controlling 

financial interest in a VIE is deemed to be the primary 
beneficiary and must consolidate the VIE. Citigroup would be 
deemed to have a controlling financial interest and be the 
primary beneficiary if it has both of the following 
characteristics:

• 

• 

power to direct the activities of the VIE that most 
significantly impact the entity’s economic performance; 
and
an obligation to absorb losses of the entity that could 
potentially be significant to the VIE, or a right to receive 
benefits from the entity that could potentially be 
significant to the VIE. 

The Company must evaluate each VIE to understand the 
purpose and design of the entity, the role the Company had in 
the entity’s design and its involvement in the VIE’s ongoing 
activities. The Company then must evaluate which activities 
most significantly impact the economic performance of the 
VIE and who has the power to direct such activities.

For those VIEs where the Company determines that it has 
the power to direct the activities that most significantly impact 
the VIE’s economic performance, the Company must then 
evaluate its economic interests, if any, and determine whether 
it could absorb losses or receive benefits that could potentially 
be significant to the VIE. When evaluating whether the 
Company has an obligation to absorb losses that could 
potentially be significant, it considers the maximum exposure 
to such loss without consideration of probability. Such 
obligations could be in various forms, including, but not 
limited to, debt and equity investments, guarantees, liquidity 
agreements and certain derivative contracts.

In various other transactions, the Company may (i) act as 

a derivative counterparty (for example, interest rate swap, 
cross-currency swap or purchaser of credit protection under a 
credit default swap or total return swap where the Company 
pays the total return on certain assets to the SPE), (ii) act as 
underwriter or placement agent, (iii) provide administrative, 
trustee or other services or (iv) make a market in debt 
securities or other instruments issued by VIEs. The Company 
generally considers such involvement, by itself, not to be 
variable interests and thus not an indicator of power or 
potentially significant benefits or losses. 

214

 
 
 
Citigroup’s involvement with consolidated and unconsolidated VIEs with which the Company holds significant variable interests 

or has continuing involvement through servicing a majority of the assets in a VIE is presented below:

As of December 31, 2019

Maximum exposure to loss in significant unconsolidated VIEs(1)

Funded exposures(2)

Unfunded exposures

In millions of dollars
Credit card securitizations
Mortgage securitizations(4)
U.S. agency-sponsored
Non-agency-sponsored

Citi-administered asset-

backed commercial paper
conduits

Collateralized loan

obligations (CLOs)
Asset-based financing
Municipal securities tender

option bond trusts (TOBs)

Municipal investments
Client intermediation
Investment funds
Other
Total

Total
involvement
with SPE
assets

Consolidated
VIE/SPE 
assets

Significant
unconsolidated
VIE assets(3)

Debt
investments

Equity
investments

Funding
commitments

Guarantees
and
derivatives

Total

$

43,534 $

43,534 $

— $

— $

— $

— $

— $

—

117,374
39,608

—
1,187

117,374
38,421

2,671
876

15,622

15,622

—

—

17,395
196,728

6,950
20,312
1,455
827
352
460,157 $

$

—
6,139

1,458
—
1,391
174
1

69,506 $

17,395
190,589

4,199
23,756

5,492
20,312
64
653
351
390,651 $

4
2,636
4
5
169
34,320 $

—
—

—

—
1,151

—
4,274
—
—
—
5,425 $

—
—

—

—
9,524

3,544
3,034
—
16
39
16,157 $

72
1

—

2,743
877

—

—
4,199
— 34,431

3,548
—
9,944
—
4
—
22
1
208
—
74 $ 55,976

As of December 31, 2018

Maximum exposure to loss in significant unconsolidated VIEs(1)
Funded exposures(2)

Unfunded exposures

In millions of dollars
Credit card securitizations
Mortgage securitizations(4)
U.S. agency-sponsored
Non-agency-sponsored

Citi-administered asset-

backed commercial paper
conduits

Collateralized loan

obligations (CLOs)
Asset-based financing
Municipal securities tender

option bond trusts (TOBs)

Municipal investments
Client intermediation
Investment funds
Other
Total

Total
involvement
with SPE
assets

Consolidated
VIE/SPE 
assets

Significant
unconsolidated
VIE assets(3)

Debt
investments

Equity
investments

Funding
commitments

Guarantees
and
derivatives

Total

$

46,232 $

46,232 $

— $

— $

— $

— $

— $

—

116,563
30,886

—
1,498

116,563
29,388

3,038
431

18,750

18,750

—

—

21,837
99,433

7,998
18,044
858
1,272
63

—
628

1,776
3
614
440
3

21,837
98,805

6,222
18,041
244
832
60

$

361,936 $

69,944 $

291,992 $

5,891
21,640

9
2,813
172
12
37
34,043 $

—
—

—

—
715

—
3,922
—
—
—
4,637 $

—
—

—

—
9,757

4,262
2,738
—
1
23
16,781 $

60
1

—

3,098
432

—

5,900
9
— 32,112

4,271
—
9,473
—
174
2
14
1
—
60
73 $ 55,534

(1)  The definition of maximum exposure to loss is included in the text that follows this table.
(2) 
Included on Citigroup’s December 31, 2019 and 2018 Consolidated Balance Sheet.
(3)  A significant unconsolidated VIE is an entity in which the Company has any variable interest or continuing involvement considered to be significant, regardless of 

the likelihood of loss.

(4)  Citigroup mortgage securitizations also include agency and non-agency (private label) re-securitization activities. These SPEs are not consolidated. See “Re-

securitizations” below for further discussion.

215

The asset balances for consolidated VIEs represent the 
carrying amounts of the assets consolidated by the Company. 
The carrying amount may represent the amortized cost or the 
current fair value of the assets depending on the legal form of 
the asset (e.g., loan or security) and the Company’s standard 
accounting policies for the asset type and line of business.

The asset balances for unconsolidated VIEs in which the 

Company has significant involvement represent the most 
current information available to the Company. In most cases, 
the asset balances represent an amortized cost basis without 
regard to impairments, unless fair value information is readily 
available to the Company.

The maximum funded exposure represents the balance 
sheet carrying amount of the Company’s investment in the 
VIE. It reflects the initial amount of cash invested in the VIE, 
adjusted for any accrued interest and cash principal payments 
received. The carrying amount may also be adjusted for 
increases or declines in fair value or any impairment in value 
recognized in earnings. The maximum exposure of unfunded 
positions represents the remaining undrawn committed 
amount, including liquidity and credit facilities provided by 
the Company or the notional amount of a derivative 
instrument considered to be a variable interest. In certain 
transactions, the Company has entered into derivative 
instruments or other arrangements that are not considered 
variable interests in the VIE (e.g., interest rate swaps, cross-
currency swaps or where the Company is the purchaser of 
credit protection under a credit default swap or total return 
swap where the Company pays the total return on certain 
assets to the SPE). Receivables under such arrangements are 
not included in the maximum exposure amounts.

The previous tables do not include:

• 

• 

• 

• 

• 

• 

• 

certain venture capital investments made by some of the 
Company’s private equity subsidiaries, as the Company 
accounts for these investments in accordance with the 
Investment Company Audit Guide (codified in ASC 946);
certain investment funds for which the Company provides 
investment management services and personal estate 
trusts for which the Company provides administrative, 
trustee and/or investment management services;
certain third-party sponsored private equity funds to 
which the Company provides secured credit facilities. The 
Company has no decision-making power and does not 
consolidate these funds, some of which may meet the 
definition of a VIE. The Company’s maximum exposure 
to loss is generally limited to a loan or lending-related 
commitment (for more information on these positions, see 
Notes 14 and 26 to the Consolidated Financial 
Statements);
certain VIEs structured by third parties in which the 
Company holds securities in inventory, as these 
investments are made on arm’s-length terms; 
certain positions in mortgage- and asset-backed securities 
held by the Company, which are classified as Trading 
account assets or Investments, in which the Company has 
no other involvement with the related securitization entity 
deemed to be significant (for more information on these 
positions, see Notes 13 and 24 to the Consolidated 
Financial Statements); 
certain representations and warranties exposures in legacy 
ICG-sponsored mortgage- and asset-backed 
securitizations in which the Company has no variable 
interest or continuing involvement as servicer. The 
outstanding balance of mortgage loans securitized during 
2005 to 2008 in which the Company has no variable 
interest or continuing involvement as servicer was 
approximately $6 billion and $7 billion at December 31, 
2019 and 2018, respectively;
certain representations and warranties exposures in 
Citigroup residential mortgage securitizations in which 
the original mortgage loan balances are no longer 
outstanding; and

•  VIEs such as trust preferred securities trusts used in 

connection with the Company’s funding activities. The 
Company does not have a variable interest in these trusts.

216

Funding Commitments for Significant Unconsolidated VIEs—Liquidity Facilities and Loan Commitments
The following table presents the notional amount of liquidity facilities and loan commitments that are classified as funding 
commitments in the VIE tables above:

In millions of dollars

Asset-based financing

Municipal securities tender option bond trusts (TOBs)

Municipal investments

Investment funds

Other

Total funding commitments

December 31, 2019

December 31, 2018

Liquidity
facilities

Loan/equity
commitments

Liquidity
facilities

Loan/equity
commitments

$

$

— $

3,544

—

—

—

9,524 $

—

3,034

16

39

— $

4,262

—

—

—

9,757

—

2,738

1

23

3,544 $

12,613 $

4,262 $

12,519

Consolidated VIEs
The Company engages in on-balance sheet securitizations, 
which are securitizations that do not qualify for sales 
treatment; thus, the assets remain on Citi’s Consolidated 
Balance Sheet, and any proceeds received are recognized as 
secured liabilities. The consolidated VIEs represent more than 
a hundred separate entities with which the Company is 
involved. In general, the third-party investors in the 
obligations of consolidated VIEs have legal recourse only to 
the assets of the respective VIEs and do not have such 
recourse to the Company, except where Citi has provided a 
guarantee to the investors or is the counterparty to certain 

derivative transactions involving the VIE. Thus, Citigroup’s 
maximum legal exposure to loss related to consolidated VIEs 
is significantly less than the carrying value of the consolidated 
VIE assets due to outstanding third-party financing. 
Intercompany assets and liabilities are excluded from Citi’s 
Consolidated Balance Sheet. All VIE assets are restricted from 
being sold or pledged as collateral. The cash flows from these 
assets are the only source used to pay down the associated 
liabilities, which are non-recourse to Citi’s general assets. See 
the Consolidated Balance Sheet for more information about 
these Consolidated VIE assets and liabilities. 

Significant Interests in Unconsolidated VIEs—Balance Sheet Classification
The following table presents the carrying amounts and classification of significant variable interests in unconsolidated VIEs:

In billions of dollars
Cash
Trading account assets
Investments
Total loans, net of allowance
Other

Total assets

December 31,
2019

December 31,
2018

$

$

— $
2.6
9.9
26.7
0.5

39.7 $

—
3.0
10.7
24.5
0.5

38.7

217

Credit Card Securitizations
The Company securitizes credit card receivables through trusts 
established to purchase the receivables. Citigroup transfers 
receivables into the trusts on a non-recourse basis. Credit card 
securitizations are revolving securitizations: as customers pay 
their credit card balances, the cash proceeds are used to 
purchase new receivables and replenish the receivables in the 
trust.

Substantially all of the Company’s credit card 

securitization activity is through two trusts—Citibank Credit 
Card Master Trust (Master Trust) and Citibank Omni Master 
Trust (Omni Trust), with the substantial majority through the 
Master Trust. These trusts are consolidated entities because, as 

servicer, Citigroup has the power to direct the activities that 
most significantly impact the economic performance of the 
trusts. Citigroup holds a seller’s interest and certain securities 
issued by the trusts, which could result in exposure to 
potentially significant losses or benefits from the trusts. 
Accordingly, the transferred credit card receivables remain on 
Citi’s Consolidated Balance Sheet with no gain or loss 
recognized. The debt issued by the trusts to third parties is 
included on Citi’s Consolidated Balance Sheet. 

Citi utilizes securitizations as one of the sources of 

funding for its business in North America. The following table 
reflects amounts related to the Company’s securitized credit 
card receivables:

In billions of dollars
Ownership interests in principal amount of trust credit card receivables
   Sold to investors via trust-issued securities
   Retained by Citigroup as trust-issued securities
   Retained by Citigroup via non-certificated interests
Total

The following table summarizes selected cash flow 
information related to Citigroup’s credit card securitizations:

In billions of dollars
Proceeds from new securitizations
Pay down of maturing notes

2019

2018

2017

$ — $

(7.6)

6.8 $
(8.3)

11.1
(5.0)

Managed Loans
After securitization of credit card receivables, the Company 
continues to maintain credit card customer account 
relationships and provides servicing for receivables transferred 
to the trusts. As a result, the Company considers the 
securitized credit card receivables to be part of the business it 
manages. As Citigroup consolidates the credit card trusts, all 
managed securitized card receivables are on-balance sheet.

Funding, Liquidity Facilities and Subordinated Interests
As noted above, Citigroup securitizes credit card receivables 
through two securitization trusts—Master Trust and Omni 
Trust. The liabilities of the trusts are included on the 
Consolidated Balance Sheet, excluding those retained by 
Citigroup.

December 31,
2019

December 31,
2018

$

$

19.7 $
6.2
17.8
43.7 $

27.3
7.6
11.3
46.2

Master Trust Liabilities (at Par Value)
The Master Trust issues fixed- and floating-rate term notes. 
Some of the term notes may be issued to multi-seller 
commercial paper conduits. The weighted average maturity of 
the third-party term notes issued by the Master Trust was 3.1 
years as of December 31, 2019 and 3.0 years as of 
December 31, 2018.

In billions of dollars
Term notes issued to third parties
Term notes retained by Citigroup

affiliates

Total Master Trust liabilities

Dec. 31,
2019

Dec. 31,
2018

$

$

18.2 $

4.3
22.5 $

25.8

5.7
31.5

Omni Trust Liabilities (at Par Value)
The Omni Trust issues fixed- and floating-rate term notes, 
some of which are purchased by multi-seller commercial 
paper conduits. The weighted average maturity of the third-
party term notes issued by the Omni Trust was 1.6 years as of 
December 31, 2019 and 2.7 years as of December 31, 2018.

In billions of dollars
Term notes issued to third parties
Term notes retained by Citigroup

affiliates

Total Omni Trust liabilities

$

$

Dec. 31,
2019

Dec. 31,
2018

1.5 $

1.9
3.4 $

1.5

1.9
3.4

218

 
Mortgage Securitizations
Citigroup provides a wide range of mortgage loan products to 
a diverse customer base. Once originated, the Company often 
securitizes these loans through the use of VIEs. These VIEs 
are funded through the issuance of trust certificates backed 
solely by the transferred assets. These certificates have the 
same life as the transferred assets. In addition to providing a 
source of liquidity and less expensive funding, securitizing 
these assets also reduces Citi’s credit exposure to the 
borrowers. These mortgage loan securitizations are primarily 
non-recourse, thereby effectively transferring the risk of future 
credit losses to the purchasers of the securities issued by the 
trust.

Citi’s U.S. consumer mortgage business generally retains 
the servicing rights and in certain instances retains investment 
securities, interest-only strips and residual interests in future 
cash flows from the trusts and also provides servicing for a 
limited number of ICG securitizations. Citi’s ICG business 
may hold investment securities pursuant to credit risk 
retention rules or in connection with secondary market-making 
activities. 

The Company securitizes mortgage loans generally 
through either a U.S. government-sponsored agency, such as 
Ginnie Mae, Fannie Mae or Freddie Mac (U.S. agency-
sponsored mortgages), or private label (non-agency-sponsored 

mortgages) securitization. Citi is not the primary beneficiary 
of its U.S. agency-sponsored mortgage securitization entities 
because Citigroup does not have the power to direct the 
activities of the VIEs that most significantly impact the 
entities’ economic performance. Therefore, Citi does not 
consolidate these U.S. agency-sponsored mortgage 
securitization entities. Substantially all of the consumer loans 
sold or securitized through non-consolidated trusts by 
Citigroup are U.S. prime residential mortgage loans. Retained 
interests in non-consolidated agency-sponsored mortgage 
securitization trusts are classified as Trading account assets, 
except for MSRs, which are included in Other assets on 
Citigroup’s Consolidated Balance Sheet.

Citigroup does not consolidate certain non-agency-
sponsored mortgage securitization entities because Citi is 
either not the servicer with the power to direct the significant 
activities of the entity or Citi is the servicer, but the servicing 
relationship is deemed to be a fiduciary relationship; therefore, 
Citi is not deemed to be the primary beneficiary of the entity.

In certain instances, the Company has (i) the power to 
direct the activities and (ii) the obligation to either absorb 
losses or the right to receive benefits that could be potentially 
significant to its non-agency-sponsored mortgage 
securitization entities and, therefore, is the primary beneficiary 
and, thus, consolidates the VIE.

The following tables summarize selected cash flow information and retained interests related to Citigroup mortgage securitizations:

In billions of dollars

Principal securitized
Proceeds from new securitizations(1)
Contractual servicing fees received
Purchases of previously transferred financial assets

2019

2018

2017

U.S. agency-
sponsored
mortgages

Non-agency-
sponsored
mortgages

U.S. agency-
sponsored
mortgages

Non-agency-
sponsored
mortgages

U.S. agency-
sponsored
mortgages

Non-agency-
sponsored
mortgages

$

5.3 $

5.5

0.1

0.2

18.9 $

18.9

—

—

4.0 $

5.6 $

7.8 $

4.2

0.1

0.2

7.1

—

—

8.1

0.2

0.4

7.3

7.3

—

—

Note: Excludes re-securitization transactions.
(1)  The proceeds from new securitizations in 2019 include $0.2 billion related to personal loan securitizations.

For non-consolidated mortgage securitization entities 
where the transfer of loans to the VIE meets the conditions for 
sale accounting, Citi recognizes a gain or loss based on the 
difference between the carrying value of the transferred assets 
and the proceeds received (generally cash but may be 
beneficial interests or servicing rights).

Agency and non-agency securitization gains for the year 
ended December 31, 2019 were $16 million and $99 million, 
respectively. 

Agency and non-agency securitization gains for the year 
ended December 31, 2018 were $17 million and $36 million, 
respectively, and $28 million and $70 million, respectively, for 
the year ended December 31, 2017.

2019
Non-agency-sponsored 
mortgages(1)

2018
Non-agency-sponsored 
mortgages(1)

U.S. agency-
sponsored
mortgages

Senior
interests

Subordinated 
interests(3)

U.S. agency-
sponsored
mortgages

Senior
interests

Subordinated
interests

$

491 $

748 $

102 $

564 $

300 $

51

In millions of dollars

Carrying value of retained 

interests(2)

(1)  Disclosure of non-agency-sponsored mortgages as senior and subordinated interests is indicative of the interests’ position in the capital structure of the 

securitization.

(2)  Retained interests consist of Level 2 or Level 3 assets depending on the observability of significant inputs. See Note 24 to the Consolidated Financial Statements 

for more information about fair value measurements.

(3)  Senior interests in non-agency-sponsored mortgages include $150 million related to personal loan securitizations at December 31, 2019.

219

Key assumptions used in measuring the fair value of retained interests at the date of sale or securitization of mortgage receivables 
were as follows:

Weighted average discount rate
Weighted average constant prepayment rate
Weighted average anticipated net credit losses(2)
Weighted average life

Weighted average discount rate
Weighted average constant prepayment rate
Weighted average anticipated net credit losses(2)
Weighted average life

U.S. agency- 
sponsored mortgages
9.3%
12.9%

   NM
6.6 years

December 31, 2019

Non-agency-sponsored mortgages(1)
Subordinated 
interests

Senior 
interests

3.6%
10.5%

3.9%
3 years

4.6%
7.6%

2.8%
11.4 years

U.S. agency-
sponsored mortgages

December 31, 2018

Non-agency-sponsored mortgages(1)
Subordinated
interests

Senior
interests

9.6%
5.8%

   NM
7.5 years

2.8%
8.0%

4.4%
5.5 years

4.4%
9.1%

3.4%
6.7 years

(1)  Disclosure of non-agency-sponsored mortgages as senior and subordinated interests is indicative of the interests’ position in the capital structure of the 

securitization.

(2)  Anticipated net credit losses represent estimated loss severity associated with defaulted mortgage loans underlying the mortgage securitizations disclosed above. 
Anticipated net credit losses, in this instance, do not represent total credit losses incurred to date, nor do they represent credit losses expected on retained interests 
in mortgage securitizations.

NM  Anticipated net credit losses are not meaningful due to U.S. agency guarantees.

The interests retained by the Company range from highly rated and/or senior in the capital structure to unrated and/or residual 
interests. Key assumptions used in measuring the fair value of retained interests at period end or securitization of mortgage receivables 
were as follows:

Weighted average discount rate
Weighted average constant prepayment rate
Weighted average anticipated net credit losses(2)
Weighted average life

Weighted average discount rate
Weighted average constant prepayment rate
Weighted average anticipated net credit losses(2)
Weighted average life

U.S. agency- 
sponsored mortgages
9.8%
10.1%
NM
6.6 years

December 31, 2019

Non-agency-sponsored mortgages(1)
Subordinated 
interests

Senior 
interests

7.6%
3.6%
5.2%
5.9 years

4.2%
6.1%
2.7%
29.3 years

U.S. agency- 
sponsored mortgages

December 31, 2018

Non-agency-sponsored mortgages(1)
Subordinated 
interests

Senior 
interests

7.8%
9.1%
   NM
6.4 years

9.3%
8.0%
40.0%
6.6 years

—
—
—
—

(1)  Disclosure of non-agency-sponsored mortgages as senior and subordinated interests is indicative of the interests’ position in the capital structure of the 

securitization.

(2)  Anticipated net credit losses represent estimated loss severity associated with defaulted mortgage loans underlying the mortgage securitizations disclosed above. 
Anticipated net credit losses, in this instance, do not represent total credit losses incurred to date, nor do they represent credit losses expected on retained interests 
in mortgage securitizations.

NM  Anticipated net credit losses are not meaningful due to U.S. agency guarantees.

220

The sensitivity of the fair value to adverse changes of 10% and 20% in each of the key assumptions are presented in the tables 

below. The negative effect of each change is calculated independently, holding all other assumptions constant. Because the key 
assumptions may not be independent, the net effect of simultaneous adverse changes in the key assumptions may be less than the sum 
of the individual effects shown below.

In millions of dollars
Discount rate
   Adverse change of 10%
   Adverse change of 20%
Constant prepayment rate
   Adverse change of 10%
   Adverse change of 20%
Anticipated net credit losses
   Adverse change of 10%
   Adverse change of 20%

In millions of dollars
Discount rate
   Adverse change of 10%
   Adverse change of 20%
Constant prepayment rate
   Adverse change of 10%
   Adverse change of 20%
Anticipated net credit losses
   Adverse change of 10%
   Adverse change of 20%

December 31, 2019

Non-agency-sponsored mortgages

U.S. agency- 
sponsored mortgages

Senior 
interests

Subordinated 
interests

$

(18) $
(35)

(18)
(35)

NM
NM

— $
(1)

—
—

—
—

December 31, 2018

Non-agency-sponsored mortgages

U.S. agency- 
sponsored mortgages

Senior 
interests

Subordinated 
interests

$

(16) $
(32)

(21)
(41)

NM
NM

— $
—

—
—

—
—

(1)
(1)

—
—

—
—

—
—

—
—

—
—

NM  Anticipated net credit losses are not meaningful due to U.S. agency guarantees.

The following table includes information about loan delinquencies and liquidation losses for assets held in non-consolidated, non-

agency-sponsored securitization entities:

In billions of dollars, except liquidation losses in millions
Securitized assets
Residential mortgages
Commercial and other
Total

Securitized assets

90 days past due

Liquidation losses

2019

2018

2019

2018

2019

2018

$

$

11.7 $
22.3
34.0 $

5.2 $
13.1
18.3 $

0.4 $
—
0.4 $

0.4 $
—
0.4 $

49.0 $
—
49.0 $

54.0
—
54.0

221

Mortgage Servicing Rights (MSRs)
In connection with the securitization of mortgage loans, Citi’s 
U.S. consumer mortgage business generally retains the 
servicing rights, which entitle the Company to a future stream 
of cash flows based on the outstanding principal balances of 
the loans and the contractual servicing fee. Failure to service 
the loans in accordance with contractual requirements may 
lead to a termination of the servicing rights and the loss of 
future servicing fees.

These transactions create intangible assets referred to as 

MSRs, which are recorded at fair value on Citi’s Consolidated 
Balance Sheet. The fair value of Citi’s capitalized MSRs was 
$495 million and $584 million at December 31, 2019 and 
2018, respectively. The MSRs correspond to principal loan 
balances of $58 billion and $62 billion as of December 31, 
2019 and 2018, respectively. 

The following table summarizes the changes in 

capitalized MSRs:

In millions of dollars
Balance, beginning of year
Originations
Changes in fair value of MSRs due to
changes in inputs and assumptions

Other changes(1)
Sale of MSRs
Balance, as of December 31

2019

2018

$

$

584 $
70

(84)
(75)
—
495 $

558
58

54
(68)
(18)
584

(1)  Represents changes due to customer payments and passage of time.

The fair value of the MSRs is primarily affected by 
changes in prepayments of mortgages that result from shifts in 
mortgage interest rates. Specifically, higher interest rates tend 
to lead to declining prepayments, which causes the fair value 
of the MSRs to increase. In managing this risk, Citigroup 
economically hedges a significant portion of the value of its 
MSRs through the use of interest rate derivative contracts, 
forward purchase and sale commitments of mortgage-backed 
securities and purchased securities, all classified as Trading 
account assets. 

The Company receives fees during the course of servicing 

previously securitized mortgages. The amounts of these fees 
were as follows:

In millions of dollars
Servicing fees
Late fees
Ancillary fees
Total MSR fees

2019

2018

2017

$

$

148 $
8
1
157 $

172 $
4
8
184 $

276
10
13
299

In the Consolidated Statement of Income these fees are 

primarily classified as Commissions and fees, and changes in 
MSR fair values are classified as Other revenue.

Re-securitizations
The Company engages in re-securitization transactions in 
which debt securities are transferred to a VIE in exchange for 
new beneficial interests. Citi did not transfer non-agency 
(private label) securities to re-securitization entities during the 
years ended December 31, 2019 and 2018. These securities are 

222

backed by either residential or commercial mortgages and are 
often structured on behalf of clients. 

As of December 31, 2019, Citi held no retained interests 

in private label re-securitization transactions structured by 
Citi. As of December 31, 2018, the fair value of Citi-retained 
interests in private label re-securitization transactions 
structured by Citi totaled approximately $16 million (all 
related to re-securitization transactions executed prior to 
2016). Of this amount, all was related to subordinated 
beneficial interests. The original par value of private label re-
securitization transactions in which Citi held a retained 
interest as of December 31, 2018 was approximately $271 
million.

The Company also re-securitizes U.S. government-agency 

guaranteed mortgage-backed (agency) securities. During the 
years ended December 31, 2019 and 2018, Citi transferred 
agency securities with a fair value of approximately $31.9 
billion and $26.3 billion, respectively, to re-securitization 
entities. 

As of December 31, 2019, the fair value of Citi-retained 
interests in agency re-securitization transactions structured by 
Citi totaled approximately $2.2 billion (including $1.3 billion 
related to re-securitization transactions executed in 2019) 
compared to $2.5 billion as of December 31, 2018 (including 
$1.4 billion related to re-securitization transactions executed 
in 2018), which is recorded in Trading account assets. The 
original fair value of agency re-securitization transactions in 
which Citi holds a retained interest as of December 31, 2019 
and 2018 was approximately $73.5 billion and $70.9 billion, 
respectively.

As of December 31, 2019 and 2018, the Company did not 

consolidate any private label or agency re-securitization 
entities.

Citi-Administered Asset-Backed Commercial Paper Conduits
The Company is active in the asset-backed commercial paper 
conduit business as administrator of several multi-seller 
commercial paper conduits and also as a service provider to 
single-seller and other commercial paper conduits sponsored 
by third parties.

Citi’s multi-seller commercial paper conduits are designed 
to provide the Company’s clients access to low-cost funding in 
the commercial paper markets. The conduits purchase assets 
from or provide financing facilities to clients and are funded 
by issuing commercial paper to third-party investors. The 
conduits generally do not purchase assets originated by Citi. 
The funding of the conduits is facilitated by the liquidity 
support and credit enhancements provided by the Company.
As administrator to Citi’s conduits, the Company is 
generally responsible for selecting and structuring assets 
purchased or financed by the conduits, making decisions 
regarding the funding of the conduits, including determining 
the tenor and other features of the commercial paper issued, 
monitoring the quality and performance of the conduits’ assets 
and facilitating the operations and cash flows of the conduits. 
In return, the Company earns structuring fees from customers 
for individual transactions and earns an administration fee 
from the conduit, which is equal to the income from the client 
program and liquidity fees of the conduit after payment of 
conduit expenses. This administration fee is fairly stable, since 

most risks and rewards of the underlying assets are passed 
back to the clients. Once the asset pricing is negotiated, most 
ongoing income, costs and fees are relatively stable as a 
percentage of the conduit’s size.

The conduits administered by Citi do not generally invest 
in liquid securities that are formally rated by third parties. The 
assets are privately negotiated and structured transactions that 
are generally designed to be held by the conduit, rather than 
actively traded and sold. The yield earned by the conduit on 
each asset is generally tied to the rate on the commercial paper 
issued by the conduit, thus passing interest rate risk to the 
client. Each asset purchased by the conduit is structured with 
transaction-specific credit enhancement features provided by 
the third-party client seller, including over-collateralization, 
cash and excess spread collateral accounts, direct recourse or 
third-party guarantees. These credit enhancements are sized 
with the objective of approximating a credit rating of A or 
above, based on Citi’s internal risk ratings. At December 31, 
2019 and 2018, the commercial paper conduits administered 
by Citi had approximately $15.6 billion and $18.8 billion of 
purchased assets outstanding, respectively, and had 
incremental funding commitments with clients of 
approximately $16.3 billion and $14.0 billion, respectively.
Substantially all of the funding of the conduits is in the 

form of short-term commercial paper. At December 31, 2019 
and 2018, the weighted average remaining lives of the 
commercial paper issued by the conduits were approximately 
49 and 53 days, respectively. 

The primary credit enhancement provided to the conduit 

investors is in the form of transaction-specific credit 
enhancements described above. In addition to the transaction-
specific credit enhancements, the conduits, other than the 
government guaranteed loan conduit, have obtained a letter of 
credit from the Company, which is equal to at least 8%–10% 
of the conduit’s assets with a minimum of $200 million. The 
letters of credit provided by the Company to the conduits total 
approximately $1.4 billion as of December 31, 2019 and $1.7 
billion as of December 31, 2018. The net result across multi-
seller conduits administered by the Company is that, in the 
event that defaulted assets exceed the transaction-specific 
credit enhancements described above, any losses in each 
conduit are allocated first to the Company and then to the 
commercial paper investors.

Citigroup also provides the conduits with two forms of 
liquidity agreements that are used to provide funding to the 
conduits in the event of a market disruption, among other 
events. Each asset of the conduits is supported by a 
transaction-specific liquidity facility in the form of an asset 
purchase agreement (APA). Under the APA, the Company has 
generally agreed to purchase non-defaulted eligible 
receivables from the conduit at par. The APA is not designed 
to provide credit support to the conduit, as it generally does 
not permit the purchase of defaulted or impaired assets. Any 
funding under the APA will likely subject the underlying 
conduit clients to increased interest costs. In addition, the 
Company provides the conduits with program-wide liquidity 
in the form of short-term lending commitments. Under these 
commitments, the Company has agreed to lend to the conduits 
in the event of a short-term disruption in the commercial paper 
market, subject to specified conditions. The Company receives 

223

fees for providing both types of liquidity agreements and 
considers these fees to be on fair market terms.

Finally, Citi is one of several named dealers in the 
commercial paper issued by the conduits and earns a market-
based fee for providing such services. Along with third-party 
dealers, the Company makes a market in the commercial paper 
and may from time to time fund commercial paper pending 
sale to a third party. On specific dates with less liquidity in the 
market, the Company may hold in inventory commercial paper 
issued by conduits administered by the Company, as well as 
conduits administered by third parties. Separately, in the 
normal course of business, Citi purchases commercial paper, 
including commercial paper issued by Citigroup's conduits. At 
December 31, 2019 and 2018, the Company owned $5.5 
billion and $5.5 billion, respectively, of the commercial paper 
issued by its administered conduits. The Company's 
investments were not driven by market illiquidity and the 
Company is not obligated under any agreement to purchase 
the commercial paper issued by the conduits.

The asset-backed commercial paper conduits are 
consolidated by Citi. The Company has determined that, 
through its roles as administrator and liquidity provider, it has 
the power to direct the activities that most significantly impact 
the entities’ economic performance. These powers include its 
ability to structure and approve the assets purchased by the 
conduits, its ongoing surveillance and credit mitigation 
activities, its ability to sell or repurchase assets out of the 
conduits and its liability management. In addition, as a result 
of all the Company’s involvement described above, it was 
concluded that Citi has an economic interest that could 
potentially be significant. However, the assets and liabilities of 
the conduits are separate and apart from those of Citigroup. 
No assets of any conduit are available to satisfy the creditors 
of Citigroup or any of its other subsidiaries.

Collateralized Loan Obligations (CLOs)
A collateralized loan obligation (CLO) is a VIE that purchases 
a portfolio of assets consisting primarily of non-investment 
grade corporate loans. CLOs issue multiple tranches of debt 
and equity to investors to fund the asset purchases and pay 
upfront expenses associated with forming the CLO. A third-
party asset manager is contracted by the CLO to purchase the 
underlying assets from the open market and monitor the credit 
risk associated with those assets. Over the term of a CLO, the 
asset manager directs purchases and sales of assets in a 
manner consistent with the CLO’s asset management 
agreement and indenture. In general, the CLO asset manager 
will have the power to direct the activities of the entity that 
most significantly impact the economic performance of the 
CLO. Investors in a CLO, through their ownership of debt 
and/or equity in it, can also direct certain activities of the 
CLO, including removing its asset manager under limited 
circumstances, optionally redeeming the notes, voting on 
amendments to the CLO’s operating documents and other 
activities. A CLO has a finite life, typically 12 years.

Citi serves as a structuring and placement agent with 
respect to the CLOs. Typically, the debt and equity of the 
CLOs are sold to third-party investors. On occasion, certain 
Citi entities may purchase some portion of a CLO’s liabilities 
for investment purposes. In addition, Citi may purchase, 

typically in the secondary market, certain securities issued by 
the CLOs to support its market making activities.

The Company generally does not have the power to direct 

the activities that most significantly impact the economic 
performance of the CLOs, as this power is generally held by a 
third-party asset manager of the CLO. As such, those CLOs 
are not consolidated.

The following tables summarize selected cash flow 
information and retained interests related to Citigroup CLOs:

In millions of dollars

Principal securitized

2019

2018

2017

$

— $

— $

Proceeds from new securitizations

Cash flows received on retained

interests and other net cash flows

—

72

—

127

133

133

107

In millions of dollars

Carrying value of retained

interests

Dec. 31,
2019

Dec. 31,
2018

Dec. 31,
2017

$

1,404 $

3,142 $

4,079

All of Citi’s retained interests were held-to-maturity 

securities as of December 31, 2019 and 2018.

Asset-Based Financing
The Company provides loans and other forms of financing to 
VIEs that hold assets. Those loans are subject to the same 
credit approvals as all other loans originated or purchased by 
the Company. Financings in the form of debt securities or 
derivatives are, in most circumstances, reported in Trading 
account assets and accounted for at fair value through 
earnings. The Company generally does not have the power to 
direct the activities that most significantly impact these VIEs’ 
economic performance; thus, it does not consolidate them.

The primary types of Citi’s asset-based financings, total 

assets of the unconsolidated VIEs with significant 
involvement and Citi’s maximum exposure to loss are shown 
below. For Citi to realize the maximum loss, the VIE 
(borrower) would have to default with no recovery from the 
assets held by the VIE.

December 31, 2019

Total 
unconsolidated 
VIE assets

Maximum 
exposure to 
unconsolidated 
VIEs

In millions of dollars
Type

Commercial and other real

estate

Corporate loans

Other (including investment

funds, airlines and shipping)

Total

$

$

31,377 $
7,088

152,124
190,589 $

7,489
5,802

21,140
34,431

In millions of dollars
Type
Commercial and other real

estate

Corporate loans
Other (including investment 

funds, airlines and shipping)

Total

December 31, 2018

Total 
unconsolidated 
VIE assets

Maximum 
exposure to 
unconsolidated 
VIEs

$

$

23,918 $
6,973

67,914
98,805 $

6,928
5,744

19,440
32,112

Municipal Securities Tender Option Bond (TOB) Trusts
Municipal TOB trusts may hold fixed- or floating-rate, taxable 
or tax-exempt securities issued by state and local governments 
and municipalities. TOB trusts are typically structured as 
single-issuer entities whose assets are purchased from either 
the Company or from other investors in the municipal 
securities market. TOB trusts finance the purchase of their 
municipal assets by issuing two classes of certificates: long-
dated, floating rate certificates (“Floaters”) that are putable 
pursuant to a liquidity facility and residual interest certificates 
(“Residuals”). The Floaters are purchased by third-party 
investors, typically tax-exempt money market funds. The 
Residuals are purchased by the original owner of the 
municipal securities that are being financed.

From Citigroup’s perspective, there are two types of TOB 

trusts: customer and non-customer. Customer TOB trusts are 
those trusts utilized by customers of the Company to finance 
their securities, generally municipal securities. The Residuals 
issued by these trusts are purchased by the customer being 
financed. Non-customer TOB trusts are generally used by the 
Company to finance its own municipal securities investments; 
the Residuals issued by non-customer TOB trusts are 
purchased by the Company.

With respect to both customer and non-customer TOB 
trusts, Citi may provide remarketing agent services. If Floaters 
are optionally tendered and the Company, in its role as 
remarketing agent, is unable to find a new investor to purchase 
the optionally tendered Floaters within a specified period of 
time, Citigroup may, but is not obligated to, purchase the 
tendered Floaters into its own inventory. The level of the 
Company’s inventory of such Floaters fluctuates. 

For certain customer TOB trusts, Citi may also serve as a 

voluntary advance provider. In this capacity, the Company 
may, but is not obligated to, make loan advances to customer 
TOB trusts to purchase optionally tendered Floaters that have 
not otherwise been successfully remarketed to new investors. 
Such loans are secured by pledged Floaters. As of 
December 31, 2019, Citi had no outstanding voluntary 
advances to customer TOB trusts.

For certain non-customer trusts, the Company also 

provides credit enhancement. At December 31, 2019 and 
2018, none of the municipal bonds owned by non-customer 
TOB trusts were subject to a credit guarantee provided by the 
Company.

Citigroup also provides liquidity services to many 
customer and non-customer trusts. If a trust is unwound early 
due to an event other than a credit event on the underlying 

224

 
 
 
municipal bonds, the underlying municipal bonds are sold out 
of the trust and bond sale proceeds are used to redeem the 
outstanding trust certificates. If this results in a shortfall 
between the bond sale proceeds and the redemption price of 
the tendered Floaters, the Company, pursuant to the liquidity 
agreement, would be obligated to make a payment to the trust 
to satisfy that shortfall. For certain customer TOB trusts, 
Citigroup has also executed a reimbursement agreement with 
the holder of the Residual, pursuant to which the Residual 
holder is obligated to reimburse the Company for any payment 
the Company makes under the liquidity arrangement. These 
reimbursement agreements may be subject to daily margining 
based on changes in the market value of the underlying 
municipal bonds. In cases where a third party provides 
liquidity to a non-customer TOB trust, a similar 
reimbursement arrangement may be executed, whereby the 
Company (or a consolidated subsidiary of the Company), as 
Residual holder, would absorb any losses incurred by the 
liquidity provider.

For certain other non-customer TOB trusts, Citi serves as 

tender option provider. The tender option provider 
arrangement allows Floater holders to put their interests 
directly to the Company at any time, subject to the requisite 
notice period requirements, at a price of par.

At December 31, 2019 and 2018, liquidity agreements 
provided with respect to customer TOB trusts totaled $3.5 
billion and $4.3 billion, respectively, of which $1.6 billion and 
$2.3 billion, respectively, were offset by reimbursement 
agreements. For the remaining exposure related to TOB 
transactions, where the residual owned by the customer was at 
least 25% of the bond value at the inception of the transaction, 
no reimbursement agreement was executed. 

Citi considers both customer and non-customer TOB 
trusts to be VIEs. Customer TOB trusts are not consolidated 
by the Company, as the power to direct the activities that most 
significantly impact the trust’s economic performance rests 
with the customer Residual holder, which may unilaterally 
cause the sale of the trust’s bonds.

Non-customer TOB trusts generally are consolidated 
because the Company holds the Residual interest and thus has 
the unilateral power to cause the sale of the trust’s bonds.

The Company also provides other liquidity agreements or 

letters of credit to customer-sponsored municipal investment 
funds, which are not variable interest entities, and 
municipality-related issuers that totaled $7.0 billion as of 
December 31, 2019 and $6.1 billion as of December 31, 2018. 
These liquidity agreements and letters of credit are offset by 
reimbursement agreements with various term-out provisions.

Municipal Investments
Municipal investment transactions include debt and equity 
interests in partnerships that finance the construction and 
rehabilitation of low-income housing, facilitate lending in new 
or underserved markets or finance the construction or 
operation of renewable municipal energy facilities. Citi 
generally invests in these partnerships as a limited partner and 
earns a return primarily through the receipt of tax credits and 
grants earned from the investments made by the partnership. 
The Company may also provide construction loans or 
permanent loans for the development or operation of real 

225

estate properties held by partnerships. These entities are 
generally considered VIEs. The power to direct the activities 
of these entities is typically held by the general partner. 
Accordingly, these entities are not consolidated by Citigroup.

Client Intermediation
Client intermediation transactions represent a range of 
transactions designed to provide investors with specified 
returns based on the returns of an underlying security, 
referenced asset or index. These transactions include credit-
linked notes and equity-linked notes. In these transactions, the 
VIE typically obtains exposure to the underlying security, 
referenced asset or index through a derivative instrument, such 
as a total-return swap or a credit-default swap. In turn, the VIE 
issues notes to investors that pay a return based on the 
specified underlying security, referenced asset or index. The 
VIE invests the proceeds in a financial asset or a guaranteed 
insurance contract that serves as collateral for the derivative 
contract over the term of the transaction. The Company’s 
involvement in these transactions includes being the 
counterparty to the VIE’s derivative instruments and investing 
in a portion of the notes issued by the VIE. In certain 
transactions, the investor’s maximum risk of loss is limited 
and the Company absorbs risk of loss above a specified level. 
Citi does not have the power to direct the activities of the VIEs 
that most significantly impact their economic performance and 
thus it does not consolidate them.

Citi’s maximum risk of loss in these transactions is 
defined as the amount invested in notes issued by the VIE and 
the notional amount of any risk of loss absorbed by Citi 
through a separate instrument issued by the VIE. The 
derivative instrument held by the Company may generate a 
receivable from the VIE (for example, where the Company 
purchases credit protection from the VIE in connection with 
the VIE’s issuance of a credit-linked note), which is 
collateralized by the assets owned by the VIE. These 
derivative instruments are not considered variable interests 
and any associated receivables are not included in the 
calculation of maximum exposure to the VIE.

Investment Funds
The Company is the investment manager for certain 
investment funds and retirement funds that invest in various 
asset classes including private equity, hedge funds, real estate, 
fixed income and infrastructure. Citigroup earns a 
management fee, which is a percentage of capital under 
management, and may earn performance fees. In addition, for 
some of these funds the Company has an ownership interest in 
the investment funds. Citi has also established a number of 
investment funds as opportunities for qualified employees to 
invest in private equity investments. The Company acts as 
investment manager for these funds and may provide 
employees with financing on both recourse and non-recourse 
bases for a portion of the employees’ investment 
commitments.

22.   DERIVATIVES

In the ordinary course of business, Citigroup enters into 
various types of derivative transactions, which include: 

•  Futures and forward contracts, which are commitments to 

• 

buy or sell at a future date a financial instrument, 
commodity or currency at a contracted price that may be 
settled in cash or through delivery of an item readily 
convertible to cash.
Swap contracts, which are commitments to settle in cash 
at a future date or dates that may range from a few days to 
a number of years, based on differentials between 
specified indices or financial instruments, as applied to a 
notional principal amount.

•  Option contracts, which give the purchaser, for a 

premium, the right, but not the obligation, to buy or sell 
within a specified time a financial instrument, commodity 
or currency at a contracted price that may also be settled 
in cash, based on differentials between specified indices 
or prices.

Swaps, forwards and some option contracts are over-the-
counter (OTC) derivatives that are bilaterally negotiated with 
counterparties and settled with those counterparties, except for 
swap contracts that are novated and "cleared" through central 
counterparties (CCPs). Futures contracts and other option 
contracts are standardized contracts that are traded on an 
exchange with a CCP as the counterparty from the inception of 
the transaction. Citigroup enters into derivative contracts 
relating to interest rate, foreign currency, commodity and other 
market/credit risks for the following reasons:

• 

• 

 Trading Purposes: Citigroup trades derivatives as an 
active market maker. Citigroup offers its customers 
derivatives in connection with their risk management 
actions to transfer, modify or reduce their interest rate, 
foreign exchange and other market/credit risks or for their 
own trading purposes. Citigroup also manages its 
derivative risk positions through offsetting trade activities, 
controls focused on price verification and daily reporting 
of positions to senior managers.
 Hedging: Citigroup uses derivatives in connection with 
its own risk management activities to hedge certain risks 
or reposition the risk profile of the Company. Hedging 
may be accomplished by applying hedge accounting in 
accordance with ASC 815, Derivatives and Hedging, or 
by an economic hedge. For example, Citigroup issues 
fixed-rate long-term debt and then enters into a receive-
fixed, pay-variable-rate interest rate swap with the same 
tenor and notional amount to synthetically convert the 
interest payments to a net variable-rate basis. This 
strategy is the most common form of an interest rate 
hedge, as it minimizes net interest cost in certain yield 
curve environments. Derivatives are also used to manage 
market risks inherent in specific groups of on-balance 
sheet assets and liabilities, including AFS securities, 
commodities and borrowings, as well as other interest-
sensitive assets and liabilities. In addition, foreign 
exchange contracts are used to hedge non-U.S.-dollar-

226

denominated debt, foreign currency-denominated AFS 
securities and net investment exposures. 

Derivatives may expose Citigroup to market, credit or 

liquidity risks in excess of the amounts recorded on the 
Consolidated Balance Sheet. Market risk on a derivative 
product is the exposure created by potential fluctuations in 
interest rates, market prices, foreign exchange rates and other 
factors and is a function of the type of product, the volume of 
transactions, the tenor and terms of the agreement and the 
underlying volatility. Credit risk is the exposure to loss in the 
event of nonperformance by the other party to satisfy a 
derivative liability where the value of any collateral held by 
Citi is not adequate to cover such losses. The recognition in 
earnings of unrealized gains on derivative transactions is 
subject to management’s assessment of the probability of 
counterparty default. Liquidity risk is the potential exposure 
that arises when the size of a derivative position may affect the 
ability to monetize the position in a reasonable period of time 
and at a reasonable cost in periods of high volatility and 
financial stress. 

Derivative transactions are customarily documented under 

industry standard master netting agreements, which provide 
that following an event of default, the non-defaulting party 
may promptly terminate all transactions between the parties 
and determine the net amount due to be paid to, or by, the 
defaulting party. Events of default include (i) failure to make a 
payment on a derivative transaction that remains uncured 
following applicable notice and grace periods, (ii) breach of 
agreement that remains uncured after applicable notice and 
grace periods, (iii) breach of a representation, (iv) cross 
default, either to third-party debt or to other derivative 
transactions entered into between the parties, or, in some 
cases, their affiliates, (v) the occurrence of a merger or 
consolidation that results in a party’s becoming a materially 
weaker credit and (vi) the cessation or repudiation of any 
applicable guarantee or other credit support document. 
Obligations under master netting agreements are often secured 
by collateral posted under an industry standard credit support 
annex to the master netting agreement. An event of default 
may also occur under a credit support annex if a party fails to 
make a collateral delivery that remains uncured following 
applicable notice and grace periods. 

The netting and collateral rights incorporated in the 

master netting agreements are considered to be legally 
enforceable if a supportive legal opinion has been obtained 
from counsel of recognized standing that provides (i) the 
requisite level of certainty regarding enforceability and (ii) 
that the exercise of rights by the non-defaulting party to 
terminate and close-out transactions on a net basis under these 
agreements will not be stayed or avoided under applicable law 
upon an event of default, including bankruptcy, insolvency or 
similar proceeding. 

A legal opinion may not be sought for certain jurisdictions 

where local law is silent or unclear as to the enforceability of 
such rights or where adverse case law or conflicting regulation 
may cast doubt on the enforceability of such rights. In some 
jurisdictions and for some counterparty types, the insolvency 
law may not provide the requisite level of certainty. For 

example, this may be the case for certain sovereigns, 
municipalities, central banks and U.S. pension plans. 

Exposure to credit risk on derivatives is affected by 

market volatility, which may impair the ability of 
counterparties to satisfy their obligations to the Company. 
Credit limits are established and closely monitored for 
customers engaged in derivatives transactions. Citi considers 
the level of legal certainty regarding enforceability of its 
offsetting rights under master netting agreements and credit 
support annexes to be an important factor in its risk 
management process. Specifically, Citi generally transacts 
much lower volumes of derivatives under master netting 
agreements where Citi does not have the requisite level of 
legal certainty regarding enforceability, because such 
derivatives consume greater amounts of single counterparty 
credit limits than those executed under enforceable master 
netting agreements. 

Cash collateral and security collateral in the form of G10 

government debt securities are often posted by a party to a 
master netting agreement to secure the net open exposure of 
the other party; the receiving party is free to commingle/
rehypothecate such collateral in the ordinary course of its 
business. Nonstandard collateral such as corporate bonds, 
municipal bonds, U.S. agency securities and/or MBS may also 
be pledged as collateral for derivative transactions. Security 
collateral posted to open and maintain a master netting 
agreement with a counterparty, in the form of cash and/or 
securities, may from time to time be segregated in an account 
at a third-party custodian pursuant to a tri-party account 
control agreement.

As of January 1, 2018, Citigroup early adopted ASU 
2017-12, Targeted Improvements to Accounting for Hedge 
Activities. This standard primarily impacts Citi’s accounting 
for derivatives designated as cash flow hedges and fair value 
hedges. Refer to the respective sections below for details.

227

Information pertaining to Citigroup’s derivative activities, 

based on notional amounts, is presented in the table below. 
Derivative notional amounts are reference amounts from 
which contractual payments are derived and do not represent a 
complete measure of Citi’s exposure to derivative transactions. 
Citi’s derivative exposure arises primarily from market 
fluctuations (i.e., market risk), counterparty failure (i.e., credit 
risk) and/or periods of high volatility or financial stress (i.e., 
liquidity risk), as well as any market valuation adjustments 
that may be required on the transactions. Moreover, notional
amounts do not reflect the netting of offsetting trades. For 
example, if Citi enters into a receive-fixed interest rate swap 
with $100 million notional, and offsets this risk with an

Derivative Notionals

identical but opposite pay-fixed position with a different
counterparty, $200 million in derivative notionals is reported, 
although these offsetting positions may result in de minimis 
overall market risk. 

In addition, aggregate derivative notional amounts can 

fluctuate from period to period in the normal course of 
business based on Citi’s market share, levels of client activity 
and other factors. All derivatives are recorded in Trading 
account assets/Trading account liabilities on the Consolidated 
Balance Sheet.

In millions of dollars

Interest rate contracts

Swaps

Futures and forwards

Written options

Purchased options

Total interest rate contracts

Foreign exchange contracts

Swaps

Futures, forwards and spot

Written options

Purchased options

Total foreign exchange contracts

Equity contracts

Swaps

Futures and forwards

Written options

Purchased options

Total equity contracts

Commodity and other contracts

Swaps

Futures and forwards

Written options

Purchased options

Total commodity and other contracts
Credit derivatives(1)
Protection sold

Protection purchased

Total credit derivatives

Total derivative notionals

$

$

$

$

$

$

$

$

$

$

$

Hedging instruments under
ASC 815

Trading derivative instruments

December 31,
2019

December 31,
2018

December 31,
2019

December 31,
2018

318,089 $

273,636 $

17,063,272 $

18,138,686

—

—

—

—

—

—

3,636,658

2,114,511

1,857,770

4,632,257

3,018,469

2,532,479

318,089 $

273,636 $

24,672,211 $

28,321,891

63,104 $

38,275

80

80

57,153 $

6,063,853 $

41,410

1,726

2,104

3,979,188

908,061

959,149

6,738,158

5,115,504

1,566,717

1,543,516

101,539 $

102,393 $

11,910,251 $

14,963,895

— $

—

—

—

— $

— $

1,195

—

—

— $

197,893 $

—

—

—

66,705

560,571

422,393

217,580

52,053

454,675

341,018

— $

1,247,562 $

1,065,326

— $

69,445 $

802

—

—

137,192

91,587

86,631

1,195 $

802 $

384,855 $

— $

—

— $

— $

—

— $

603,387 $

703,926

1,307,313 $

420,823 $

376,831 $

39,522,192 $

79,133

146,647

62,629

61,298

349,707

724,939

795,649

1,520,588

46,221,407

(1)  Credit derivatives are arrangements designed to allow one party (protection buyer) to transfer the credit risk of a “reference asset” to another party (protection 

seller). These arrangements allow a protection seller to assume the credit risk associated with the reference asset without directly purchasing that asset. The 
Company enters into credit derivative positions for purposes such as risk management, yield enhancement, reduction of credit concentrations and diversification 
of overall risk.

228

 
 
 
 
 
The following tables present the gross and net fair values 

of the Company’s derivative transactions and the related 
offsetting amounts as of December 31, 2019 and 2018. Gross 
positive fair values are offset against gross negative fair values 
by counterparty, pursuant to enforceable master netting 
agreements. Under ASC 815-10-45, payables and receivables 
in respect of cash collateral received from or paid to a given 
counterparty pursuant to a credit support annex are included in 
the offsetting amount, if a legal opinion supporting the 
enforceability of netting and collateral rights has been 
obtained. GAAP does not permit similar offsetting for security 
collateral. 

In addition, the following tables reflect rule changes 
adopted by clearing organizations that require or allow entities 
to treat derivative assets, liabilities and the related variation 
margin as settlement of the related derivative fair values for 
legal and accounting purposes, as opposed to presenting gross 
derivative assets and liabilities that are subject to collateral, 
whereby the counterparties would also record a related 
collateral payable or receivable. As a result, the tables reflect a 
reduction of approximately $180 billion and $100 billion as of 
December 31, 2019 and 2018, respectively, of derivative 
assets and derivative liabilities that previously would have 
been reported on a gross basis, but are now legally settled and 
not subject to collateral. The tables also present amounts that 
are not permitted to be offset, such as security collateral or 
cash collateral posted at third-party custodians, but which 
would be eligible for offsetting to the extent that an event of 
default has occurred and a legal opinion supporting 
enforceability of the netting and collateral rights has been 
obtained.

229

Derivative Mark-to-Market (MTM) Receivables/Payables

In millions of dollars at December 31, 2019

Derivatives instruments designated as ASC 815 hedges

Derivatives classified
in Trading account assets/liabilities(1)(2)
Liabilities

Assets

Over-the-counter

Cleared

Interest rate contracts

Over-the-counter

Cleared

Foreign exchange contracts

Total derivatives instruments designated as ASC 815 hedges

Derivatives instruments not designated as ASC 815 hedges

Over-the-counter

Cleared

Exchange traded

Interest rate contracts

Over-the-counter

Cleared

Exchange traded

Foreign exchange contracts

Over-the-counter

Exchange traded

Equity contracts

Over-the-counter

Exchange traded

Commodity and other contracts

Over-the-counter

Cleared

Credit derivatives

Total derivatives instruments not designated as ASC 815 hedges

Total derivatives
Cash collateral paid/received(3)
Less: Netting agreements(4)
Less: Netting cash collateral received/paid(5)
Net receivables/payables included on the Consolidated Balance Sheet(6)
Additional amounts subject to an enforceable master netting agreement, but not offset

on the Consolidated Balance Sheet

Less: Cash collateral received/paid

Less: Non-cash collateral received/paid
Total net receivables/payables(6)

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

1,682 $

41

1,723 $

1,304 $

—

1,304 $

3,027 $

189,892 $

5,896

157

195,945 $

105,401 $

862

3

106,266 $

21,311 $

7,160

28,471 $

13,582 $

630

14,212 $

8,896 $

1,513

10,409 $

355,303 $

358,330 $

17,926 $

(274,970)

(44,353)

56,933 $

(861) $

(13,143)

42,929 $

143

111

254

908

2

910

1,164

169,749

7,472

180

177,401

108,807

1,015

—

109,822

22,411

8,075

30,486

16,773

542

17,315

8,975

1,763

10,738

345,762

346,926

14,391

(274,970)

(38,919)

47,428

(128)

(7,308)

39,992

(1)  The derivatives fair values are presented in Note 24 to the Consolidated Financial Statements. 
(2)  Over-the-counter (OTC) derivatives are derivatives executed and settled bilaterally with counterparties without the use of an organized exchange or central 

clearing house. Cleared derivatives include derivatives executed bilaterally with a counterparty in the OTC market, but then novated to a central clearing house, 
whereby the central clearing house becomes the counterparty to both of the original counterparties. Exchange-traded derivatives include derivatives executed 
directly on an organized exchange that provides pre-trade price transparency.

(3)  Reflects the net amount of the $56,845 million and $58,744 million of gross cash collateral paid and received, respectively. Of the gross cash collateral paid, 

$38,919 million was used to offset trading derivative liabilities and, of the gross cash collateral received, $44,353 million was used to offset trading derivative 
assets.

(4)  Represents the netting of derivative receivable and payable balances with the same counterparty under enforceable netting agreements. Approximately $262 
billion, $6 billion and $7 billion of the netting against trading account asset/liability balances is attributable to each of the OTC, cleared and exchange-traded 
derivatives, respectively.

(5)  Represents the netting of cash collateral paid and received by counterparties under enforceable credit support agreements. Substantially all cash collateral received 

and paid is netted against OTC derivative assets and liabilities, respectively.

(6)  The net receivables/payables include approximately $7 billion of derivative asset and $6 billion of derivative liability fair values not subject to enforceable master 

netting agreements, respectively.

230

In millions of dollars at December 31, 2018

Derivatives instruments designated as ASC 815 hedges

Derivatives classified
in Trading account assets/liabilities(1)(2)
Liabilities

Assets

Over-the-counter

Cleared

Interest rate contracts

Over-the-counter

Cleared

Foreign exchange contracts

Total derivatives instruments designated as ASC 815 hedges

Derivatives instruments not designated as ASC 815 hedges

Over-the-counter

Cleared

Exchange traded

Interest rate contracts

Over-the-counter

Cleared

Exchange traded

Foreign exchange contracts

Over-the-counter

Cleared

Exchange traded

Equity contracts

Over-the-counter

Exchange traded

Commodity and other contracts

Over-the-counter

Cleared

Credit derivatives

Total derivatives instruments not designated as ASC 815 hedges

Total derivatives
Cash collateral paid/received(3)
Less: Netting agreements(4)
Less: Netting cash collateral received/paid(5)
Net receivables/payables included on the Consolidated Balance Sheet(6)
Additional amounts subject to an enforceable master netting agreement, but not offset

on the Consolidated Balance Sheet

Less: Cash collateral received/paid

Less: Non-cash collateral received/paid
Total net receivables/payables(6)

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

1,631 $

238

1,869 $

1,402 $

—

1,402 $

3,271 $

161,183 $

8,489

91

169,763 $

159,099 $

1,900

53

161,052 $

18,253 $

17

11,623

29,893 $

16,661 $

894

17,555 $

6,967 $

3,798

10,765 $

389,028 $

392,299 $

11,518 $

(311,089)

(38,608)

54,120 $

(767) $

(13,509)

39,844 $

172

53

225

736

4

740

965

146,909

7,594

99

154,602

156,904

1,671

40

158,615

21,527

32

12,249

33,808

19,894

795

20,689

6,155

4,196

10,351

378,065

379,030

13,906

(311,089)

(29,911)

51,936

(164)

(13,354)

38,418

(1)  The derivatives fair values are presented in Note 24 to the Consolidated Financial Statements.
(2)  Over-the-counter (OTC) derivatives include derivatives executed and settled bilaterally with counterparties without the use of an organized exchange or central 
clearing house. Cleared derivatives include derivatives executed bilaterally with a counterparty in the OTC market, but then novated to a central clearing house, 
whereby the central clearing house becomes the counterparty to both of the original counterparties. Exchange-traded derivatives include derivatives executed 
directly on an organized exchange that provides pre-trade price transparency.

(3)  Reflects the net amount of the $41,429 million and $52,514 million of gross cash collateral paid and received, respectively. Of the gross cash collateral paid, 

$29,911 million was used to offset trading derivative liabilities and, of the gross cash collateral received, $38,608 million was used to offset trading derivative 
assets.

(4)  Represents the netting of balances with the same counterparty under enforceable netting agreements. Approximately $296 billion, $4 billion and $11 billion of the 

netting against trading account asset/liability balances is attributable to each of the OTC, cleared and exchange-traded derivatives, respectively.

(5)  Represents the netting of cash collateral paid and received by counterparties under enforceable credit support agreements. Substantially all netting of cash 

collateral received and paid is against OTC derivative assets and liabilities, respectively.

231

(6)  The net receivables/payables include approximately $5 billion of derivative asset and $7 billion of derivative liability fair values not subject to enforceable master 

ineffectiveness measured and recorded in current earnings. 
Hedge effectiveness assessment methodologies are performed 
in a similar manner for similar hedges, and are used 
consistently throughout the hedging relationships. The 
assessment of effectiveness may exclude changes in the value 
of the hedged item that are unrelated to the risks being hedged 
and the changes in fair value of the derivative associated with 
time value. Prior to January 1, 2018, these excluded items 
were recognized in current earnings for the hedging derivative, 
while changes in the value of a hedged item that were not 
related to the hedged risk were not recorded. Upon adoption of 
ASC 2017-12, Citi excludes changes in the cross-currency 
basis associated with cross-currency swaps from the 
assessment of hedge effectiveness and records it in Other 
comprehensive income.

Discontinued Hedge Accounting
A hedging instrument must be highly effective in 
accomplishing the hedge objective of offsetting either changes 
in the fair value or cash flows of the hedged item for the risk 
being hedged. Management may voluntarily de-designate an 
accounting hedge at any time, but if a hedging relationship is 
not highly effective, it no longer qualifies for hedge 
accounting and must be de-designated. Subsequent changes in 
the fair value of the derivative are recognized in Other revenue 
or Principal transactions, similar to trading derivatives, with 
no offset recorded related to the hedged item.

For fair value hedges, any changes in the fair value of the 
hedged item remain as part of the basis of the asset or liability 
and are ultimately realized as an element of the yield on the 
item. For cash flow hedges, changes in fair value of the end-
user derivative remain in Accumulated other comprehensive 
income (loss) (AOCI) and are included in the earnings of 
future periods when the forecasted hedged cash flows impact 
earnings. However, if it becomes probable that some or all of 
the hedged forecasted transactions will not occur, any amounts 
that remain in AOCI related to these transactions must be 
immediately reflected in Other revenue.

The foregoing criteria are applied on a decentralized 

basis, consistent with the level at which market risk is 
managed, but are subject to various limits and controls. The 
underlying asset, liability or forecasted transaction may be an 
individual item or a portfolio of similar items.

netting agreements, respectively.

For the years ended December 31, 2019, 2018 and 2017, 

the amounts recognized in Principal transactions in the 
Consolidated Statement of Income include certain derivatives 
not designated in a qualifying hedging relationship. Citigroup 
presents this disclosure by business classification, showing 
derivative gains and losses related to its trading activities 
together with gains and losses related to non-derivative 
instruments within the same trading portfolios, as this 
represents how these portfolios are risk managed. See Note 6 
to the Consolidated Financial Statements for further 
information.

The amounts recognized in Other revenue in the 

Consolidated Statement of Income related to derivatives not 
designated in a qualifying hedging relationship are shown 
below. The table below does not include any offsetting gains 
(losses) on the economically hedged items to the extent that 
such amounts are also recorded in Other revenue.

Gains (losses) included in
Other revenue

Year ended December 31,

In millions of dollars

2019

2018

2017

Interest rate contracts $

Foreign exchange

Total

$

57 $

(29)

28 $

(25) $

(197)

(222) $

(73)

2,062

1,989

Accounting for Derivative Hedging
Citigroup accounts for its hedging activities in accordance 
with ASC 815, Derivatives and Hedging. As a general rule, 
hedge accounting is permitted where the Company is exposed 
to a particular risk, such as interest rate or foreign exchange 
risk, that causes changes in the fair value of an asset or 
liability or variability in the expected future cash flows of an 
existing asset, liability or a forecasted transaction that may 
affect earnings.

Derivative contracts hedging the risks associated with 
changes in fair value are referred to as fair value hedges, while 
contracts hedging the variability of expected future cash flows 
are cash flow hedges. Hedges that utilize derivatives or debt 
instruments to manage the foreign exchange risk associated 
with equity investments in non-U.S.-dollar-functional-
currency foreign subsidiaries (net investment in a foreign 
operation) are net investment hedges.

To qualify as an accounting hedge under the hedge 
accounting rules (versus an economic hedge where hedge 
accounting is not applied), a hedging relationship must be 
highly effective in offsetting the risk designated as being 
hedged. The hedging relationship must be formally 
documented at inception, detailing the particular risk 
management objective and strategy for the hedge. This 
includes the item and risk(s) being hedged, the hedging 
instrument being used and how effectiveness will be assessed. 
The effectiveness of these hedging relationships is evaluated at 
hedge inception and on an ongoing basis both on a 
retrospective and prospective basis, typically using 
quantitative measures of correlation, with hedge 

232

 
Fair Value Hedges

Hedging of Benchmark Interest Rate Risk
Citigroup’s fair value hedges are primarily hedges of fixed-
rate long-term debt or assets, such as available-for-sale debt 
securities or loans.

For qualifying fair value hedges of interest rate risk, the 
changes in the fair value of the derivative and the change in 
the fair value of the hedged item attributable to the hedged risk 
are presented within Interest revenue or Interest expense based 
on whether the hedged item is an asset or a liability. 

In the first quarter of 2019, Citigroup executed a last-of-

layer hedge, which permits an entity to hedge the interest rate 
risk of a stated portion of a closed portfolio of prepayable 
financial assets that are expected to remain outstanding for the 
designated tenor of the hedge. In accordance with ASC 815, 
an entity may exclude prepayment risk when measuring the 
change in fair value of the hedged item attributable to interest 
rate risk under the last-of-layer approach. Similar to other fair 
value hedges, where the hedged item is an asset, the fair value 
of the hedged item attributable to interest rate risk will be 
presented in Interest revenue along with the change in the fair 
value of the hedging instrument.

Hedging of Foreign Exchange Risk
Citigroup hedges the change in fair value attributable to 
foreign exchange rate movements in available-for-sale debt 
securities and long-term debt that are denominated in 
currencies other than the functional currency of the entity 
holding the securities or issuing the debt. The hedging 
instrument is generally a forward foreign exchange contract or 
a cross-currency swap contract. Citigroup considers the 
premium associated with forward contracts (i.e., the 
differential between the spot and contractual forward rates) as 
the cost of hedging; this amount is excluded from the 
assessment of hedge effectiveness and is generally reflected 
directly in earnings over the life of the hedge. Citi also 
excludes changes in cross-currency basis associated with 
cross-currency swaps from the assessment of hedge 
effectiveness and records it in Other comprehensive income.

Hedging of Commodity Price Risk 
Citigroup hedges the change in fair value attributable to spot 
price movements in physical commodities inventory. The 
hedging instrument is a futures contract to sell the underlying 
commodity. In this hedge, the change in the value of the 
hedged inventory is reflected in earnings, which offsets the 
change in the fair value of the futures contract that is also 
reflected in earnings. Although the change in the fair value of 
the hedging instrument recorded in earnings includes changes 
in forward rates, Citigroup excludes the differential between 
the spot and the contractual forward rates under the futures 
contract from the assessment of hedge effectiveness and 
reflects it directly in earnings over the life of the hedge. 

233

The following table summarizes the gains (losses) on the Company’s fair value hedges:

In millions of dollars
Gain (loss) on the hedging derivatives included in
assessment of the effectiveness of fair value hedges
Interest rate hedges

Foreign exchange hedges

Commodity hedges

Total gain (loss) on the hedging derivatives included in
assessment of the effectiveness of fair value hedges

Gain (loss) on the hedged item in designated and
qualifying fair value hedges

Interest rate hedges

Foreign exchange hedges

Commodity hedges

Total gain (loss) on the hedged item in designated and
qualifying fair value hedges
Net gain (loss) on the hedging derivatives excluded from
assessment of the effectiveness of fair value hedges

Interest rate hedges
Foreign exchange hedges(3)
Commodity hedges

Total net gain (loss) on the hedging derivatives excluded
from assessment of the effectiveness of fair value hedges

Gains (losses) on fair value hedges(1)

Year Ended December 31,

2019

2018

Other revenue

Net interest
revenue

Other 
revenue

Net interest
revenue

2017(2)
Other 
revenue

$

$

$

$

$

$

— $

2,273 $

— $

794 $

337

(33)

—

—

(2,064)

(123)

—

—

(891)

(824)

(17)

304 $

2,273 $

(2,187) $

794 $

(1,732)

— $

(2,085) $

— $

(747) $

(337)

33

—

—

2,064

124

—

—

853

969

18

(304) $

(2,085) $

2,188 $

(747) $

1,840

— $

(109)

41

(68) $

3 $

—

—

3 $

— $

(4)

(19)

(23) $

(5) $

—

—

(5) $

(7)

96

1

90

(1)  Beginning January 1, 2018, gain (loss) amounts for interest rate risk hedges are included in Interest income/Interest expense, while the remaining amounts 

including the amounts for interest rate hedges prior to January 1, 2018 are included in Other revenue or Principal transactions on the Consolidated Statement of 
Income. The accrued interest income on fair value hedges both prior to and after January 1, 2018 is recorded in Net interest revenue and is excluded from this 
table.

(2)  Hedge ineffectiveness recognized in earnings on designated and qualifying fair value hedges for the year ended December 31, 2017 was $(31) million for interest 

rate hedges and $49 million for foreign exchange hedges, for a total of $18 million. 

(3)  Amounts relate to the premium associated with forward contracts (differential between spot and contractual forward rates) that are excluded from the assessment 

of hedge effectiveness and are generally reflected directly in earnings. After January 1, 2018, amounts related to cross-currency basis, which are recognized in 
AOCI, are not reflected in the table above. The amount of cross-currency basis that was included in AOCI was $33 million and $(74) million for the years ended 
December 31, 2019 and 2018, respectively.

234

 
Cumulative Basis Adjustment
Upon electing to apply ASC 815 fair value hedge accounting, 
the carrying value of the hedged item is adjusted to reflect the 
cumulative changes in the hedged risk. The hedge basis 
adjustment, whether from an active or de-designated hedge 
relationship, remains with the hedged item until the hedged 
item is derecognized from the balance sheet. The table below 
presents the carrying amount of Citi’s hedged assets and 
liabilities under qualifying fair value hedges at December 31, 
2019 and 2018, along with the cumulative hedge basis 
adjustments included in the carrying value of those hedged 
assets and liabilities, that would reverse through earnings in 
future periods. 

In millions of dollars

Balance sheet
line item in
which hedged
item is
recorded

Carrying
amount of
hedged asset/
liability

As of December 31, 2019

Cumulative fair value hedging
adjustment increasing
(decreasing) the carrying
amount

Active

De-designated

Debt securities
  AFS(1)(2)
Long-term   
  debt

$

94,659 $

(114) $

157,387

2,334

As of December 31, 2018

Debt securities
  AFS(2)
Long-term   
  debt

$

$

81,632 $

(196) $

149,054 $

1,211 $

743

3,445

295

869

(1)  These amounts include a cumulative basis adjustment of $(8) million for 

active hedges and $157 million for de-designated hedges as of 
December 31, 2019 related to certain prepayable financial assets 
designated as the hedged item in a fair value hedge using the last-of-
layer approach. The Company designated approximately $605 million as 
the hedged amount (from a closed portfolio of prepayable financial 
assets with a carrying value of $20 billion as of December 31, 2019) in a 
last-of-layer hedging relationship, which commenced in the first quarter 
of 2019.

(2)  Carrying amount represents the amortized cost.

235

Cash Flow Hedges
Citigroup hedges the variability of forecasted cash flows due 
to changes in contractually specified interest rates associated 
with floating-rate assets/liabilities and other forecasted 
transactions. Variable cash flows from those liabilities are 
synthetically converted to fixed-rate cash flows by entering 
into receive-variable, pay-fixed interest rate swaps and 
receive-variable, pay-fixed forward-starting interest rate 
swaps. Variable cash flows associated with certain assets are 
synthetically converted to fixed-rate cash flows by entering 
into receive-fixed, pay-variable interest rate swaps. These cash 
flow hedging relationships use either regression analysis or 
dollar-offset ratio analysis to assess whether the hedging 
relationships are highly effective at inception and on an 
ongoing basis. Prior to the adoption of ASU 2017-12, 
Citigroup designated the risk being hedged as the risk of 
overall variability in the hedged cash flows for certain items.

With the adoption of ASU 2017-12, Citigroup hedges the 
variability from changes in a contractually specified rate and 
recognizes the entire change in fair value of the cash flow 
hedging instruments in AOCI. Prior to the adoption of ASU 
2017-12, to the extent that these derivatives were not fully 
effective, changes in their fair values in excess of changes in 
the value of the hedged transactions were immediately 
included in Other revenue. With the adoption of ASU 
2017-12, such amounts are no longer required to be 
immediately recognized in income, but instead the full change 
in the value of the hedging instrument is required to be 
recognized in AOCI, and then recognized in earnings in the 
same period that the cash flows impact earnings. The pretax 
change in AOCI from cash flow hedges is presented below:

In millions of dollars

2019

2018

2017

Amount of gain (loss) recognized in AOCI on derivatives

Interest rate contracts

Foreign exchange contracts

Total gain (loss) recognized in AOCI

Amount of gain (loss) reclassified from AOCI to earnings(1)
Interest rate contracts

Foreign exchange contracts

Total gain (loss) reclassified from AOCI into earnings

Net pretax change in cash flow hedges included within AOCI

$

$

$

$

746 $

(17)

729 $

(361) $

5

(356) $

(165)

(8)

(173)

Other
revenue

Net Interest
revenue

Other 
revenue

Net interest 
revenue

Other 
revenue

— $

(7)

(7) $

$

(384) $

—

(384) $

1,120

— $

(17)

(17) $

$

(301) $

—

(301) $

(38) $

(126)

(10)

(136)

(37)

(1)  All amounts reclassified into earnings for interest rate contracts are included in Interest income/Interest expense (Net interest revenue). For all other hedges, the 

amounts reclassified to earnings are included primarily in Other revenue and Net interest revenue in the Consolidated Statement of Income. 

For cash flow hedges, the entire change in the fair value 

of the hedging derivative is recognized in AOCI and then 
reclassified to earnings in the same period that the forecasted 
hedged cash flows impact earnings. The net gain (loss) 
associated with cash flow hedges expected to be reclassified 
from AOCI within 12 months of December 31, 2019 is 
approximately $84 million. The maximum length of time over 
which forecasted cash flows are hedged is 10 years.

The after-tax impact of cash flow hedges on AOCI is 
shown in Note 19 to the Consolidated Financial Statements.

236

Net Investment Hedges
Consistent with ASC 830-20, Foreign Currency Matters—
Foreign Currency Transactions, ASC 815 allows the hedging 
of the foreign currency risk of a net investment in a foreign 
operation. Citigroup uses foreign currency forwards, cross-
currency swaps, options and foreign currency-denominated 
debt instruments to manage the foreign exchange risk 
associated with Citigroup’s equity investments in several non-
U.S.-dollar-functional-currency foreign subsidiaries. Citigroup 
records the change in the carrying amount of these 
investments in Foreign currency translation adjustment within 
AOCI. Simultaneously, the effective portion of the hedge of 
this exposure is also recorded in Foreign currency translation 
adjustment and any ineffective portion is immediately 
recorded in earnings.

For derivatives designated as net investment hedges, 
Citigroup follows the forward-rate method outlined in ASC 
815-35-35. According to that method, all changes in fair value, 
including changes related to the forward-rate component of 
the foreign currency forward contracts and the time value of 
foreign currency options, are recorded in Foreign currency 
translation adjustment within AOCI.

For foreign currency-denominated debt instruments that 

are designated as hedges of net investments, the translation 
gain or loss that is recorded in Foreign currency translation 
adjustment is based on the spot exchange rate between the 
functional currency of the respective subsidiary and the U.S. 
dollar, which is the functional currency of Citigroup. To the 
extent that the notional amount of the hedging instrument 
exactly matches the hedged net investment, and the underlying 
exchange rate of the derivative hedging instrument relates to 
the exchange rate between the functional currency of the net 
investment and Citigroup’s functional currency (or, in the case 
of a non-derivative debt instrument, such instrument is 
denominated in the functional currency of the net investment), 
no ineffectiveness is recorded in earnings.

The pretax gain (loss) recorded in Foreign currency 
translation adjustment within AOCI, related to net investment 
hedges, is $(556) million, $1,207 million and $2,528 million 
for the years ended December 31, 2019, 2018 and 2017, 
respectively.

Economic Hedges
Citigroup often uses economic hedges when hedge accounting 
would be too complex or operationally burdensome. End-user 
derivatives that are economic hedges are carried at fair value, 
with changes in value included in either Principal transactions 
or Other revenue. 

For asset/liability management hedging, fixed-rate long-

term debt is recorded at amortized cost under GAAP.

For other hedges that either do not meet the ASC 815 
hedging criteria or for which management decides not to apply 
ASC 815 hedge accounting, the derivative is recorded at fair 
value on the balance sheet with the associated changes in fair 
value recorded in earnings, while the debt continues to be 
carried at amortized cost. Therefore, current earnings are 
affected by the interest rate shifts and other factors that cause a 
change in the swap’s value, but for which no offsetting change 
in value is recorded on the debt.

237

Citigroup may alternatively elect to account for the debt 
at fair value under the fair value option. Once the irrevocable 
election is made upon issuance of the debt, the full change in 
fair value of the debt is reported in earnings. The changes in 
fair value of the related interest rate swap are also reflected in 
earnings, which provides a natural offset to the debt’s fair 
value change. To the extent that the two amounts differ 
because the full change in the fair value of the debt includes 
risks not offset by the interest rate swap, the difference is 
automatically captured in current earnings.

Additional economic hedges include hedges of the credit 
risk component of commercial loans and loan commitments. 
Citigroup periodically evaluates its hedging strategies in other 
areas and may designate either an accounting hedge or an 
economic hedge after considering the relative costs and 
benefits. Economic hedges are also employed when the 
hedged item itself is marked to market through current 
earnings, such as hedges of commitments to originate one- to 
four-family mortgage loans to be HFS and MSRs.

Credit Derivatives
Citi is a market maker and trades a range of credit derivatives. 
Through these contracts, Citi either purchases or writes 
protection on either a single name or a portfolio of reference 
credits. Citi also uses credit derivatives to help mitigate credit 
risk in its corporate and consumer loan portfolios and other 
cash positions and to facilitate client transactions. 

Citi monitors its counterparty credit risk in credit 

derivative contracts. As of both December 31, 2019 and 2018, 
approximately 98% of the gross receivables are from 
counterparties with which Citi maintains collateral 
agreements. A majority of Citi’s top 15 counterparties (by 
receivable balance owed to Citi) are central clearing houses, 
banks, financial institutions or other dealers. Contracts with 
these counterparties do not include ratings-based termination 
events. However, counterparty ratings downgrades may have 
an incremental effect by lowering the threshold at which Citi 
may call for additional collateral. 

The range of credit derivatives entered into includes credit 

default swaps, total return swaps, credit options and credit-
linked notes. 

A credit default swap is a contract in which, for a fee, a 
protection seller agrees to reimburse a protection buyer for any 
losses that occur due to a predefined credit event on a 
reference entity. These credit events are defined by the terms 
of the derivative contract and the reference credit and are 
generally limited to the market standard of failure to pay on 
indebtedness and bankruptcy of the reference credit and, in a 
more limited range of transactions, debt restructuring. Credit 
derivative transactions that reference emerging market entities 
also typically include additional credit events to cover the 
acceleration of indebtedness and the risk of repudiation or a 
payment moratorium. In certain transactions, protection may 
be provided on a portfolio of reference entities or asset-backed 
securities. If there is no credit event, as defined by the specific 
derivative contract, then the protection seller makes no 
payments to the protection buyer and receives only the 
contractually specified fee. However, if a credit event occurs 
as defined in the specific derivative contract sold, the 

protection seller will be required to make a payment to the 
protection buyer. Under certain contracts, the seller of 
protection may not be required to make a payment until a 
specified amount of losses has occurred with respect to the 
portfolio and/or may only be required to pay for losses up to a 
specified amount.

A total return swap typically transfers the total economic 

performance of a reference asset, which includes all associated 
cash flows, as well as capital appreciation or depreciation. The 
protection buyer receives a floating rate of interest and any 
depreciation on the reference asset from the protection seller 
and, in return, the protection seller receives the cash flows 
associated with the reference asset plus any appreciation. 
Thus, according to the total return swap agreement, the 
protection seller will be obligated to make a payment any time 
the floating interest rate payment plus any depreciation of the 
reference asset exceeds the cash flows associated with the 
underlying asset. A total return swap may terminate upon a 
default of the reference asset or a credit event with respect to 
the reference entity, subject to the provisions of the related 
total return swap agreement between the protection seller and 
the protection buyer.

A credit option is a credit derivative that allows investors 

to trade or hedge changes in the credit quality of a reference 
entity. For example, in a credit spread option, the option writer 
assumes the obligation to purchase or sell credit protection on 
the reference entity at a specified “strike” spread level. The 
option purchaser buys the right to sell credit default protection 
on the reference entity to, or purchase it from, the option 
writer at the strike spread level. The payments on credit spread 
options depend either on a particular credit spread or the price 
of the underlying credit-sensitive asset or other reference 
entity. The options usually terminate if a credit event occurs 
with respect to the underlying reference entity. 

A credit-linked note is a form of credit derivative 

structured as a debt security with an embedded credit default 
swap. The purchaser of the note effectively provides credit 
protection to the issuer by agreeing to receive a return that 
could be negatively affected by credit events on the underlying 
reference credit. If the reference entity defaults, the note may 
be cash settled or physically settled by delivery of a debt 
security of the reference entity. Thus, the maximum amount of 
the note purchaser’s exposure is the amount paid for the 
credit-linked note.

238

The following tables summarize the key characteristics of Citi’s credit derivatives portfolio by counterparty and derivative form:

In millions of dollars at December 31, 2019

Receivable(1)

Payable(2)

Protection
purchased

Protection
sold

Fair values

Notionals

By industry of counterparty

Banks

Broker-dealers

Non-financial

Insurance and other financial institutions

Total by industry of counterparty

By instrument

Credit default swaps and options

Total return swaps and other

Total by instrument

By rating of reference entity

Investment grade

Non-investment grade

Total by rating of reference entity

By maturity

Within 1 year

From 1 to 5 years

After 5 years

Total by maturity

$

$

$

$

$

$

$

$

4,017 $

1,724

92

4,576

4,102 $

172,461 $

1,528

76

5,032

54,843

2,601

474,021

10,409 $

10,738 $

703,926 $

9,759 $

650

10,409 $

4,579 $

5,830

10,409 $

1,806 $

7,275

1,328

10,409 $

9,791 $

947

10,738 $

4,578 $

6,160

10,738 $

2,181 $

7,265

1,292

10,738 $

685,643 $

18,283

703,926 $

560,806 $

143,120

703,926 $

231,135 $

414,237

58,554

703,926 $

169,546

53,846

1,968

378,027

603,387

593,850

9,537

603,387

470,778

132,609

603,387

176,188

379,915

47,284

603,387

(1)  The fair value amount receivable is composed of $3,415 million under protection purchased and $6,994 million under protection sold.
(2)  The fair value amount payable is composed of $7,793 million under protection purchased and $2,945 million under protection sold.

In millions of dollars at December 31, 2018

Receivable(1)

Payable(2)

Protection
purchased

Protection
sold

Fair values

Notionals

By industry of counterparty

Banks

Broker-dealers

Non-financial

Insurance and other financial institutions

Total by industry of counterparty

By instrument

Credit default swaps and options

Total return swaps and other

Total by instrument

By rating of reference entity

Investment grade

Non-investment grade

Total by rating of reference entity

By maturity

Within 1 year

From 1 to 5 years

After 5 years

Total by maturity

$

$

$

$

$

$

$

$

4,785 $

1,706

64

4,210

4,432 $

214,842 $

1,612

87

4,220

62,904

2,687

515,216

10,765 $

10,351 $

795,649 $

10,030 $

735

10,765 $

4,725 $

6,040

10,765 $

2,037 $

6,720

2,008

10,765 $

9,755 $

596

10,351 $

4,544 $

5,807

10,351 $

2,063 $

6,414

1,874

10,351 $

771,865 $

23,784

795,649 $

637,790 $

157,859

795,649 $

251,994 $

493,096

50,559

795,649 $

218,273

63,014

1,192

442,460

724,939

712,623

12,316

724,939

568,849

156,090

724,939

225,597

456,409

42,933

724,939

(1)  The fair value amount receivable is composed of $5,126 million under protection purchased and $5,639 million under protection sold. 
(2)  The fair value amount payable is composed of $5,882 million under protection purchased and $4,469 million under protection sold.

239

 
 
Fair values included in the above tables are prior to 
application of any netting agreements and cash collateral. For 
notional amounts, Citi generally has a mismatch between the 
total notional amounts of protection purchased and sold, and it 
may hold the reference assets directly rather than entering into 
offsetting credit derivative contracts as and when desired. The 
open risk exposures from credit derivative contracts are 
largely matched after certain cash positions in reference assets 
are considered and after notional amounts are adjusted, either 
to a duration-based equivalent basis or to reflect the level of 
subordination in tranched structures. The ratings of the credit 
derivatives portfolio presented in the tables and used to 
evaluate payment/performance risk are based on the assigned 
internal or external ratings of the reference asset or entity. 
Where external ratings are used, investment-grade ratings are 
considered to be “Baa/BBB” and above, while anything below 
is considered non-investment grade. Citi’s internal ratings are 
in line with the related external rating system. 

Citigroup evaluates the payment/performance risk of the 

credit derivatives for which it stands as a protection seller 
based on the credit rating assigned to the underlying reference 
credit. Credit derivatives written on an underlying non-
investment grade reference credit represent greater payment 
risk to the Company. The non-investment grade category in 
the table above also includes credit derivatives where the 
underlying reference entity has been downgraded subsequent 
to the inception of the derivative. 

The maximum potential amount of future payments under 

credit derivative contracts presented in the table above is 
based on the notional value of the derivatives. The Company 
believes that the notional amount for credit protection sold is 
not representative of the actual loss exposure based on 
historical experience. This amount has not been reduced by the 
value of the reference assets and the related cash flows. In 
accordance with most credit derivative contracts, should a 
credit event occur, the Company usually is liable for the 
difference between the protection sold and the value of the 
reference assets. Furthermore, the notional amount for credit 
protection sold has not been reduced for any cash collateral 
paid to a given counterparty, as such payments would be 
calculated after netting all derivative exposures, including any 
credit derivatives with that counterparty in accordance with a 
related master netting agreement. Due to such netting 
processes, determining the amount of collateral that 
corresponds to credit derivative exposures alone is not 
possible. The Company actively monitors open credit-risk 
exposures and manages this exposure by using a variety of 
strategies, including purchased credit derivatives, cash 
collateral or direct holdings of the referenced assets. This risk 
mitigation activity is not captured in the table above.

Credit Risk-Related Contingent Features in Derivatives
Certain derivative instruments contain provisions that require 
the Company to either post additional collateral or 
immediately settle any outstanding liability balances upon the 
occurrence of a specified event related to the credit risk of the 
Company. These events, which are defined by the existing 
derivative contracts, are primarily downgrades in the credit 
ratings of the Company and its affiliates. 

The fair value (excluding CVA) of all derivative 
instruments with credit risk-related contingent features that 
were in a net liability position at both December 31, 2019 and 
2018 was $30 billion and $33 billion, respectively. The 
Company posted $28 billion and $33 billion as collateral for 
this exposure in the normal course of business as of 
December 31, 2019 and 2018, respectively.

A downgrade could trigger additional collateral or cash 

settlement requirements for the Company and certain 
affiliates. In the event that Citigroup and Citibank were 
downgraded a single notch by all three major rating agencies 
as of December 31, 2019, the Company could be required to 
post an additional $0.6 billion as either collateral or settlement 
of the derivative transactions. In addition, the Company could 
be required to segregate with third-party custodians collateral 
previously received from existing derivative counterparties in 
the amount of $0.2 billion upon the single notch downgrade, 
resulting in aggregate cash obligations and collateral 
requirements of approximately $0.8 billion.

Derivatives Accompanied by Financial Asset Transfers
The Company executes total return swaps that provide it with 
synthetic exposure to substantially all of the economic return 
of the securities or other financial assets referenced in the 
contract. In certain cases, the derivative transaction is 
accompanied by the Company’s transfer of the referenced 
financial asset to the derivative counterparty, most typically in 
response to the derivative counterparty’s desire to hedge, in 
whole or in part, its synthetic exposure under the derivative 
contract by holding the referenced asset in funded form. In 
certain jurisdictions these transactions qualify as sales, 
resulting in derecognition of the securities transferred (see 
Note 1 to the Consolidated Financial Statements for further 
discussion of the related sale conditions for transfers of 
financial assets). For a significant portion of the transactions, 
the Company has also executed another total return swap 
where the Company passes on substantially all of the 
economic return of the referenced securities to a different third 
party seeking the exposure. In those cases, the Company is not 
exposed, on a net basis, to changes in the economic return of 
the referenced securities.

These transactions generally involve the transfer of the 
Company’s liquid government bonds, convertible bonds or 
publicly traded corporate equity securities from the trading 
portfolio and are executed with third-party financial 
institutions. The accompanying derivatives are typically total 
return swaps. The derivatives are cash settled and subject to 
ongoing margin requirements.

When the conditions for sale accounting are met, the 
Company reports the transfer of the referenced financial asset 
as a sale and separately reports the accompanying derivative 

240

transaction. These transactions generally do not result in a gain 
or loss on the sale of the security, because the transferred 
security was held at fair value in the Company’s trading 
portfolio. For transfers of financial assets accounted for as a 
sale by the Company and for which the Company has retained 
substantially all of the economic exposure to the transferred 
asset through a total return swap executed with the same 
counterparty in contemplation of the initial sale (and still 
outstanding), both the asset amounts derecognized and the 
gross cash proceeds received as of the date of derecognition 
were $5.8 billion and $4.6 billion as of December 31, 2019 
and 2018, respectively. 

At December 31, 2019, the fair value of these previously 

derecognized assets was $5.9 billion. The fair value of the 
total return swaps as of December 31, 2019 was $117 million 
recorded as gross derivative assets and $43 million recorded as 
gross derivative liabilities. At December 31, 2018, the fair 
value of these previously derecognized assets was $4.5 billion, 
and the fair value of the total return swaps was $55 million 
recorded as gross derivative assets and $40 million recorded as 
gross derivative liabilities. 

The balances for the total return swaps are on a gross 

basis, before the application of counterparty and cash 
collateral netting, and are included primarily as equity 
derivatives in the tabular disclosures in this Note.

241

23. CONCENTRATIONS OF CREDIT RISK 

Concentrations of credit risk exist when changes in economic, 
industry or geographic factors similarly affect groups of 
counterparties whose aggregate credit exposure is material in 
relation to Citigroup’s total credit exposure. Although 
Citigroup’s portfolio of financial instruments is broadly 
diversified along industry, product and geographic lines, 
material transactions are completed with other financial 
institutions, particularly in the securities trading, derivatives 
and foreign exchange businesses.

In connection with the Company’s efforts to maintain a 
diversified portfolio, the Company limits its exposure to any 
one geographic region, country or individual creditor and 
monitors this exposure on a continuous basis. At 
December 31, 2019, Citigroup’s most significant 
concentration of credit risk was with the U.S. government and 
its agencies. The Company’s exposure, which primarily results 
from trading assets and investments issued by the U.S. 
government and its agencies, amounted to $250.9 billion and 
$250.0 billion at December 31, 2019 and 2018, respectively. 
The Japanese and German governments and their agencies, 
which are rated investment grade by both Moody’s and S&P, 
were the next largest exposures. The Company’s exposure to 
Japan amounted to $33.3 billion and $28.8 billion at 
December 31, 2019 and 2018, respectively, and was composed 
of investment securities, loans and trading assets. The 
Company’s exposure to Germany amounted to $29.8 billion 
and $45.6 billion at December 31, 2019 and 2018, 
respectively, and was composed of investment securities, loans 
and trading assets.

The Company’s exposure to states and municipalities 
amounted to $23.8 billion and $27.9 billion at December 31, 
2019 and 2018, respectively, and was composed of trading 
assets, investment securities, derivatives and lending activities.

242

24.   FAIR VALUE MEASUREMENT

ASC 820-10, Fair Value Measurement, defines fair value, 
establishes a consistent framework for measuring fair value 
and requires disclosures about fair value measurements. Fair 
value is defined as the price that would be received to sell an 
asset or paid to transfer a liability in an orderly transaction 
between market participants at the measurement date, and 
therefore represents an exit price. Among other things, the 
standard requires the Company to maximize the use of 
observable inputs and minimize the use of unobservable 
inputs when measuring fair value.

Under ASC 820-10, the probability of default of a 
counterparty is factored into the valuation of derivative and 
other positions as well as the impact of Citigroup’s own 
credit risk on derivatives and other liabilities measured at 
fair value.

Fair Value Hierarchy
ASC 820-10 specifies a hierarchy of inputs based on whether 
the inputs are observable or unobservable. Observable inputs 
are developed using market data and reflect market 
participant assumptions, while unobservable inputs reflect 
the Company’s market assumptions. These two types of 
inputs have created the following fair value hierarchy:

•  Level 1: Quoted prices for identical instruments in 

active markets.

•  Level 2: Quoted prices for similar instruments in active 

markets, quoted prices for identical or similar 
instruments in markets that are not active and model-
derived valuations in which all significant inputs and 
significant value drivers are observable in active 
markets.

•  Level 3: Valuations derived from valuation techniques 
in which one or more significant inputs or significant 
value drivers are unobservable.

As required under the fair value hierarchy, the Company 

considers relevant and observable market inputs in its 
valuations where possible. The frequency of transactions, the 
size of the bid-ask spread and the amount of adjustment 
necessary when comparing similar transactions are all 
factors in determining the relevance of observed prices in 
those markets.

Determination of Fair Value
For assets and liabilities carried at fair value, the Company 
measures fair value using the procedures set out below, 
irrespective of whether the assets and liabilities are measured 
at fair value as a result of an election or whether they are 
required to be measured at fair value.

When available, the Company uses quoted market prices 

to determine fair value and classifies such items as Level 1. 
In some specific cases where a market price is available, the 
Company will make use of acceptable practical expedients 
(such as matrix pricing) to calculate fair value, in which case 
the items are classified as Level 2.

The Company may also apply a price-based 

methodology, which utilizes, where available, quoted prices 
or other market information obtained from recent trading 
activity in positions with the same or similar characteristics 
to the position being valued. The frequency and size of 
transactions are among the factors that are driven by the 
liquidity of markets and determine the relevance of observed 
prices in those markets. If relevant and observable prices are 
available, those valuations may be classified as Level 2. 
When that is not the case, and there are one or more 
significant unobservable “price” inputs, then those 
valuations will be classified as Level 3. Furthermore, when 
less liquidity exists for a security or loan, a quoted price is 
stale, a significant adjustment to the price of a similar 
security is necessary to reflect differences in the terms of the 
actual security or loan being valued, or prices from 
independent sources are insufficient to corroborate the 
valuation, the “price” inputs are considered unobservable 
and the fair value measurements are classified as Level 3.
If quoted market prices are not available, fair value is 
based upon internally developed valuation techniques that 
use, where possible, current market-based parameters, such 
as interest rates, currency rates and option volatilities. Items 
valued using such internally generated valuation techniques 
are classified according to the lowest level input or value 
driver that is significant to the valuation. Thus, an item may 
be classified as Level 3 even though there may be some 
significant inputs that are readily observable.

Fair value estimates from internal valuation techniques 

are verified, where possible, to prices obtained from 
independent vendors or brokers. Vendors’ and brokers’ 
valuations may be based on a variety of inputs ranging from 
observed prices to proprietary valuation models, and the 
Company assesses the quality and relevance of this 
information in determining the estimate of fair value. The 
following section describes the valuation methodologies 
used by the Company to measure various financial 
instruments at fair value, including an indication of the level 
in the fair value hierarchy in which each instrument is 
generally classified. Where appropriate, the description 
includes details of the valuation models, the key inputs to 
those models and any significant assumptions.

Market Valuation Adjustments
Generally, the unit of account for a financial instrument is 
the individual financial instrument. The Company applies 
market valuation adjustments that are consistent with the 
unit of account, which does not include adjustment due to 
the size of the Company’s position, except as follows. ASC 
820-10 permits an exception, through an accounting policy 
election, to measure the fair value of a portfolio of financial 
assets and financial liabilities on the basis of the net open 
risk position when certain criteria are met. Citi has elected to 
measure certain portfolios of financial instruments that meet 
those criteria, such as derivatives, on the basis of the net 
open risk position. The Company applies market valuation 
adjustments, including adjustments to account for the size of 
the net open risk position, consistent with market participant 
assumptions.

243

Valuation adjustments are applied to items classified as 
Level 2 or Level 3 in the fair value hierarchy to ensure that 
the fair value reflects the price at which the net open risk 
position could be exited. These valuation adjustments are 
based on the bid/offer spread for an instrument in the market. 
When Citi has elected to measure certain portfolios of 
financial investments, such as derivatives, on the basis of the 
net open risk position, the valuation adjustment may take 
into account the size of the position.

Credit valuation adjustments (CVA) and funding 
valuation adjustments (FVA) are applied to the relevant 
population of over-the-counter (OTC) derivative instruments 
where adjustments to reflect counterparty credit risk, own 
credit risk and term funding risk are required to estimate fair 
value. This principally includes derivatives with a base 
valuation (e.g., discounted using overnight indexed swap 
(OIS)) requiring adjustment for these effects, such as 
uncollateralized interest rate swaps. The CVA represents a 
portfolio-level adjustment to reflect the risk premium 
associated with the counterparty’s (assets) or Citi’s 
(liabilities) non-performance risk. 

FVA reflect a market funding risk premium inherent in 
the uncollateralized portion of a derivative portfolio and in 
certain collateralized derivative portfolios that do not include 
standard credit support annexes (CSAs), such as where the 
CSA does not permit the reuse of collateral received. Citi’s 
FVA methodology leverages the existing CVA methodology 
to estimate a funding exposure profile. The calculation of 
this exposure profile considers collateral agreements in 
which the terms do not permit the Company to reuse the 
collateral received, including where counterparties post 
collateral to third-party custodians.

Citi’s CVA and FVA methodology consists of two steps: 

• 

• 

First, the exposure profile for each counterparty is 
determined using the terms of all individual derivative 
positions and a Monte Carlo simulation or other 
quantitative analysis to generate a series of expected 
cash flows at future points in time. The calculation of 
this exposure profile considers the effect of credit risk 
mitigants and sources of funding, including pledged 
cash or other collateral and any legal right of offset that 
exists with a counterparty through arrangements such as 
netting agreements. Individual derivative contracts that 
are subject to an enforceable master netting agreement 
with a counterparty are aggregated as a netting set for 
this purpose, since it is those aggregate net cash flows 
that are subject to nonperformance risk. This process 
identifies specific, point-in-time future cash flows that 
are subject to nonperformance risk and unsecured 
funding, rather than using the current recognized net 
asset or liability as a basis to measure the CVA and 
FVA. 
Second, for CVA, market-based views of default 
probabilities derived from observed credit spreads in the 
credit default swap (CDS) market are applied to the 
expected future cash flows determined in step one. Citi’s 
own-credit CVA is determined using Citi-specific CDS 
spreads for the relevant tenor. Generally, counterparty 

CVA is determined using CDS spread indices for each 
credit rating and tenor. For certain identified netting sets 
where individual analysis is practicable (e.g., exposures 
to counterparties with liquid CDSs), counterparty-
specific CDS spreads are used. For FVA, a term 
structure of future liquidity spreads is applied to the 
expected future funding requirement.

The CVA and FVA are designed to incorporate a market 
view of the credit and funding risk, respectively, inherent in 
the derivative portfolio. However, most unsecured derivative 
instruments are negotiated bilateral contracts and are not 
commonly transferred to third parties. Derivative 
instruments are normally settled contractually or, if 
terminated early, are terminated at a value negotiated 
bilaterally between the counterparties. Thus, the CVA and 
FVA may not be realized upon a settlement or termination in 
the normal course of business. In addition, all or a portion of 
these adjustments may be reversed or otherwise adjusted in 
future periods in the event of changes in the credit or funding 
risk associated with the derivative instruments.

The table below summarizes the CVA and FVA applied 
to the fair value of derivative instruments at December 31, 
2019 and 2018:

Credit and funding valuation 
adjustments
contra-liability (contra-asset)
December 31,
December 31,
2018
2019

$

$

(705) $
(530)
341
72

(1,085)
(544)
482
135

(822) $

(1,012)

In millions of dollars
Counterparty CVA
Asset FVA
Citigroup (own-credit) CVA
Liability FVA

Total CVA—derivative 
instruments(1)

(1)   FVA is included with CVA for presentation purposes.

The table below summarizes pretax gains (losses) 
related to changes in CVA on derivative instruments, net of 
hedges, FVA on derivatives and debt valuation adjustments 
(DVA) on Citi’s own fair value option (FVO) liabilities for 
the years indicated:

In millions of dollars
Counterparty CVA
Asset FVA
Own-credit CVA
Liability FVA

Total CVA—derivative
instruments

DVA related to own FVO 
liabilities(1)
Total CVA and DVA(2)

Credit/funding/debt valuation
adjustments gain (loss)

2019

2018

2017

149 $
13
(131)
(63)

(109) $
46
178
56

276
90
(153)
(15)

(32) $

171 $

198

(1,473) $

1,415 $

(1,505) $

1,586 $

(680)

(482)

$

$

$

$

(1)  See Notes 1, 17 and 19 to the Consolidated Financial Statements.

244

 
 
observable securitization prices for certain directly 
comparable portfolios of loans have not been readily 
available. Therefore, such portfolios of loans are generally 
classified as Level 3 of the fair value hierarchy. However, for 
other loan securitization markets, such as commercial real 
estate loans, price verification of the hypothetical 
securitizations has been possible, since these markets have 
remained active. Accordingly, this loan portfolio is classified 
as Level 2 of the fair value hierarchy.

For most of the lending and structured direct subprime 

exposures, fair value is determined utilizing observable 
transactions where available, other market data for similar 
assets in markets that are not active and other internal 
valuation techniques. The valuation of certain asset-backed 
security (ABS) CDO positions utilizes prices based on the 
underlying assets of the ABS CDO. 

Trading Account Assets and Liabilities—Derivatives
Exchange-traded derivatives, measured at fair value using 
quoted (i.e., exchange) prices in active markets, where 
available, are classified as Level 1 of the fair value 
hierarchy.

Derivatives without a quoted price in an active market 
and derivatives executed over the counter are valued using 
internal valuation techniques. These derivative instruments 
are classified as either Level 2 or Level 3 depending on the 
observability of the significant inputs to the model.

The valuation techniques depend on the type of 

derivative and the nature of the underlying instrument. The 
principal techniques used to value these instruments are 
discounted cash flows and internal models, such as 
derivative pricing models (e.g., Black-Scholes and Monte 
Carlo simulations). 

The key inputs depend upon the type of derivative and 
the nature of the underlying instrument and include interest 
rate yield curves, foreign exchange rates, volatilities and 
correlation. The Company typically uses OIS curves as fair 
value measurement inputs for the valuation of certain 
derivatives.

(2)  FVA is included with CVA for presentation purposes.

Securities Purchased Under Agreements to Resell and 
Securities Sold Under Agreements to Repurchase
No quoted prices exist for these instruments, so fair value is 
determined using a discounted cash flow technique. Cash 
flows are estimated based on the terms of the contract, taking 
into account any embedded derivative or other features. 
These cash flows are discounted using interest rates 
appropriate to the maturity of the instrument as well as the 
nature of the underlying collateral. Generally, when such 
instruments are recorded at fair value, they are classified 
within Level 2 of the fair value hierarchy, as the inputs used 
in the valuation are readily observable. However, certain 
long-dated positions are classified within Level 3 of the fair 
value hierarchy.

Trading Account Assets and Liabilities—Trading Securities 
and Trading Loans
When available, the Company uses quoted market prices in 
active markets to determine the fair value of trading 
securities; such items are classified as Level 1 of the fair 
value hierarchy. Examples include government securities and 
exchange-traded equity securities.

For bonds and secondary market loans traded over the 

counter, the Company generally determines fair value 
utilizing valuation techniques, including discounted cash 
flows, price-based and internal models. Fair value estimates 
from these internal valuation techniques are verified, where 
possible, to prices obtained from independent sources, 
including third-party vendors. Vendors compile prices from 
various sources and may apply matrix pricing for similar 
bonds or loans where no price is observable. A price-based 
methodology utilizes, where available, quoted prices or other 
market information obtained from recent trading activity of 
assets with similar characteristics to the bond or loan being 
valued. The yields used in discounted cash flow models are 
derived from the same price information. Trading securities 
and loans priced using such methods are generally classified 
as Level 2. However, when less liquidity exists for a security 
or loan, a quoted price is stale, a significant adjustment to the 
price of a similar security or loan is necessary to reflect 
differences in the terms of the actual security or loan being 
valued, or prices from independent sources are insufficient to 
corroborate valuation, a loan or security is generally 
classified as Level 3. The price input used in a price-based 
methodology may be zero for a security, such as a subprime 
CDO, that is not receiving any principal or interest and is 
currently written down to zero.

When the Company’s principal market for a portfolio of 

loans is the securitization market, the Company uses the 
securitization price to determine the fair value of the 
portfolio. The securitization price is determined from the 
assumed proceeds of a hypothetical securitization in the 
current market, adjusted for transformation costs (i.e., direct 
costs other than transaction costs) and securitization 
uncertainties such as market conditions and liquidity. As a 
result of the severe reduction in the level of activity in 
certain securitization markets since the second half of 2007, 

245

Investments
The investments category includes available-for-sale debt 
and marketable equity securities whose fair values are 
generally determined by utilizing similar procedures 
described for trading securities above or, in some cases, 
using vendor pricing as the primary source.

Also included in investments are nonpublic investments 
in private equity and real estate entities. Determining the fair 
value of nonpublic securities involves a significant degree of 
management judgment, as no quoted prices exist and such 
securities are generally thinly traded. In addition, there may 
be transfer restrictions on private equity securities. The 
Company’s process for determining the fair value of such 
securities utilizes commonly accepted valuation techniques, 
including comparables analysis. In determining the fair value 
of nonpublic securities, the Company also considers events 
such as a proposed sale of the investee company, initial 
public offerings, equity issuances or other observable 
transactions. Private equity securities are generally classified 
as Level 3 of the fair value hierarchy.

In addition, the Company holds investments in certain 
alternative investment funds that calculate NAV per share, 
including hedge funds, private equity funds and real estate 
funds. Investments in funds are generally classified as non-
marketable equity securities carried at fair value. The fair 
values of these investments are estimated using the NAV per 
share of the Company’s ownership interest in the funds 
where it is not probable that the investment will be realized 
at a price other than the NAV. Consistent with the provisions 
of ASU 2015-07, these investments have not been 
categorized within the fair value hierarchy and are not 
included in the tables below. See Note 13 to the 
Consolidated Financial Statements for additional 
information.

Short-Term Borrowings and Long-Term Debt
Where fair value accounting has been elected, the fair value 
of non-structured liabilities is determined by utilizing 
internal models using the appropriate discount rate for the 
applicable maturity. Such instruments are generally 
classified as Level 2 of the fair value hierarchy when all 
significant inputs are readily observable.

The Company determines the fair value of hybrid 
financial instruments, including structured liabilities, using 
the appropriate derivative valuation methodology (described 
above in “Trading Account Assets and Liabilities—
Derivatives”) given the nature of the embedded risk profile. 
Such instruments are classified as Level 2 or Level 3 
depending on the observability of significant inputs to the 
model.

246

Items Measured at Fair Value on a Recurring Basis
The following tables present for each of the fair value 
hierarchy levels the Company’s assets and liabilities that are 
measured at fair value on a recurring basis at December 31, 
2019 and 2018. The Company may hedge positions that have 
been classified in the Level 3 category with other financial 

Fair Value Levels

instruments (hedging instruments) that may be classified as 
Level 3, but also with financial instruments classified as 
Level 1 or Level 2 of the fair value hierarchy. The effects of 
these hedges are presented gross in the following tables:

In millions of dollars at December 31, 2019

Level 1

Level 2

Level 3

Gross

inventory Netting(1)

Net
balance

Assets

Securities borrowed and purchased under agreements to resell
Trading non-derivative assets

$

— $

254,253 $

303 $

254,556 $ (101,363) $ 153,193

Trading mortgage-backed securities

U.S. government-sponsored agency guaranteed
Residential
Commercial

Total trading mortgage-backed securities

U.S. Treasury and federal agency securities
State and municipal
Foreign government
Corporate
Equity securities
Asset-backed securities
Other trading assets(2)

Total trading non-derivative assets
Trading derivatives

Interest rate contracts
Foreign exchange contracts
Equity contracts
Commodity contracts
Credit derivatives
Total trading derivatives
Cash collateral paid(3)
Netting agreements
Netting of cash collateral received

Total trading derivatives
Investments

Mortgage-backed securities

U.S. government-sponsored agency guaranteed
Residential
Commercial

Total investment mortgage-backed securities
  U.S. Treasury and federal agency securities

State and municipal
Foreign government
Corporate
Marketable equity securities
Asset-backed securities
Other debt securities
Non-marketable equity securities(4)

$
$

$

$

$

$

$

$
$

27,671
—
696
—
—
1,693
— $ 30,060
— $ 29,895
2,637
—
71,326
—
18,891
—
51,641
—
2,716
—
—
12,041
— $ 219,207

—
—
—
— $
26,159 $
—
50,948
1,332
41,663
—
74

120,176 $

27,661
573
1,632
29,866 $
3,736 $
2,573
20,326
17,246
9,878
1,539
11,412
96,576 $

7 $
1
83
—
—
91 $

196,493 $
107,022
28,148
13,498
9,960
355,121 $

10
123
61
194 $
— $
64
52
313
100
1,177
555
2,455 $

1,168 $
547
240
714
449
3,118 $
$

27,671
696
1,693
30,060 $
29,895 $
2,637
71,326
18,891
51,641
2,716
12,041
219,207 $

197,668
107,570
28,471
14,212
10,409
358,330
17,926

91 $

355,121 $

3,118 $

$ (274,970)
(44,353)
376,256 $ (319,323) $ 56,933

— $
—
—
— $
106,103 $

—
69,957
5,150
87
—
—
—

35,198 $
793
74
36,065 $
5,315 $
4,355
41,196
6,076
371
500
4,730
93
98,701 $

32 $
—
—
32 $
— $
623
96
45
—
22
—
441
1,259 $

35,230 $
793
74
36,097 $
111,418 $
4,978
111,249
11,271
458
522
4,730
534
281,257 $

— $ 35,230
793
—
—
74
— $ 36,097
— $ 111,418
—
4,978
— 111,249
11,271
—
458
—
522
—
4,730
—
—
534
— $ 281,257

Total investments

$

181,297 $

Table continues on the next page.

247

 
 
 
 
 
 
In millions of dollars at December 31, 2019

Loans

Mortgage servicing rights

Non-trading derivatives and other financial assets measured on
a recurring basis

Total assets
Total as a percentage of gross assets(5)
Liabilities

Interest-bearing deposits

Securities loaned and sold under agreements to repurchase

—

111,567

Trading account liabilities

Securities sold, not yet purchased

Other trading liabilities

Total trading liabilities

Trading derivatives

Interest rate contracts

Foreign exchange contracts

Equity contracts

Commodity contracts

Credit derivatives

Total trading derivatives

Cash collateral received(6)
Netting agreements

Netting of cash collateral paid

Total trading derivatives

Short-term borrowings

Long-term debt

Level 1

Level 2

Level 3

$

— $

3,683

$

—

—

402

495

Gross

inventory Netting(1)

Net
balance

$

4,085

$

— $

4,085

495

—

495

$

5,628

$

7,201

$

1

$

12,830

$

— $ 12,830

$ 307,192

$ 815,535

$ 8,033

$1,148,686

$ (420,686) $ 728,000

27.2%

72.1%

0.7%

$

— $

2,104

$

60,429

11,965

—

24

$ 60,429

$

11,989

$

215

757

48

—

48

$

2,319

$

— $

2,319

112,324

(71,673)

40,651

72,442

24

—

—

72,442

24

$

72,466

$

— $ 72,466

$

8

—

144

—

—

$ 176,480

$ 1,167

$ 177,655

110,180

28,506

16,542

10,233

552

1,836

773

505

110,732

30,486

17,315

10,738

$

152

$ 341,941

$ 4,833

$ 346,926

$

14,391

$ (274,970)

(38,919)

$

$

152

$ 341,941

$ 4,833

$ 361,317

$ (313,889) $ 47,428

— $

4,933

$

13

$

4,946

$

— $

4,946

—

38,614

17,169

55,783

—

55,783

Total non-trading derivatives and other financial liabilities
measured on a recurring basis

Total liabilities
Total as a percentage of gross liabilities(5)

$

6,280

$

63

$ — $

6,343

$

— $

6,343

$ 66,861

$ 511,211

$ 23,035

$ 615,498

$ (385,562) $ 229,936

11.1%

85.0%

3.8%

(1)  Represents netting of (i) the amounts due under securities purchased under agreements to resell and the amounts owed under securities sold under agreements to 

(2) 

repurchase and (ii) derivative exposures covered by a qualifying master netting agreement and cash collateral offsetting.
Includes positions related to investments in unallocated precious metals, as discussed in Note 25 to the Consolidated Financial Statements. Also includes physical 
commodities accounted for at the lower of cost or fair value and unfunded credit products.

(3)  Reflects the net amount of $56,845 million of gross cash collateral paid, of which $38,919 million was used to offset trading derivative liabilities.
(4)  Amounts exclude $0.2 billion of investments measured at net asset value (NAV) in accordance with ASU No. 2015-07, Fair Value Measurement (Topic 820): 

Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent). 

(5)  Because the amount of the cash collateral paid/received has not been allocated to the Level 1, 2 and 3 subtotals, these percentages are calculated based on total 

assets and liabilities measured at fair value on a recurring basis, excluding the cash collateral paid/received on derivatives.

(6)  Reflects the net amount of $58,744 million of gross cash collateral received, of which $44,353 million was used to offset trading derivative assets.

248

Fair Value Levels

In millions of dollars at December 31, 2018

Level 1

Level 2

Level 3

Gross
inventory

Netting(1)

Net
balance

Assets

Securities borrowed and purchased under agreements to resell

$

— $

214,570 $

115 $

214,685 $

(66,984) $147,701

Trading non-derivative assets

Trading mortgage-backed securities

U.S. government-sponsored agency guaranteed

Residential

Commercial

—

—

—

24,090

709

1,323

156

268

77

24,246

977

1,400

Total trading mortgage-backed securities

U.S. Treasury and federal agency securities

$

$

— $

26,122 $

501 $

26,623 $

26,439 $

4,802 $

1 $

31,242 $

State and municipal

Foreign government

Corporate

Equity securities

Asset-backed securities
Other trading assets(2)

—

43,309

1,026

36,342

—

3

3,782

21,179

14,510

7,308

1,429

12,198

200

31

360

153

1,484

818

3,982

64,519

15,896

43,803

2,913

13,019

Total trading non-derivative assets

$

107,119 $

91,330 $

3,548 $

201,997 $

— 24,246

—

—

977

1,400

— $ 26,623

— $ 31,242

—

3,982

— 64,519

— 15,896

— 43,803

—

2,913

— 13,019

— $201,997

Trading derivatives

Interest rate contracts

Foreign exchange contracts

Equity contracts

Commodity contracts

Credit derivatives

Total trading derivatives
Cash collateral paid(3)
Netting agreements

Netting of cash collateral received

Total trading derivatives

Investments

Mortgage-backed securities

U.S. government-sponsored agency guaranteed

Residential

Commercial

Total investment mortgage-backed securities

U.S. Treasury and federal agency securities

State and municipal

Foreign government

Corporate

Marketable equity securities

Asset-backed securities

Other debt securities
Non-marketable equity securities(4)

Total investments

$

101 $

169,860 $

1,671 $

171,632

$

$

$

$

$

—

647

—

—

162,108

28,903

16,788

9,839

346

343

767

926

162,454

29,893

17,555

10,765

748 $

387,498 $

4,053 $

392,299

$

11,518

748 $

387,498 $

4,053 $

403,817 $ (349,697) $ 54,120

$ (311,089)

(38,608)

— $

42,988 $

32 $

43,020 $

— $ 43,020

—

—

1,313

172

—

—

1,313

172

— $

44,473 $

107,577 $

9,645 $

32 $

— $

44,505 $

117,222 $

—

58,252

4,410

206

—

—

—

8,498

42,371

7,033

14

656

3,972

96

708

68

156

—

187

—

586

9,206

100,691

11,599

220

843

3,972

682

—

—

1,313

172

— $ 44,505

— $117,222

—

9,206

— 100,691

— 11,599

—

—

—

—

220

843

3,972

682

$

170,445 $

116,758 $

1,737 $

288,940 $

— $288,940

Table continues on the next page. 

249

 
 
 
 
 
 
In millions of dollars at December 31, 2018

Loans

Mortgage servicing rights

Level 1

Level 2

Level 3

$

— $

2,946

$

—

—

277

584

Gross
inventory

$

3,223

Net
balance

Netting(1)
$

— $ 3,223

584

—

584

Securities loaned and sold under agreements to repurchase

—

110,511

Non-trading derivatives and other financial assets measured on a
recurring basis

Total assets
Total as a percentage of gross assets(5)
Liabilities

Interest-bearing deposits

Trading account liabilities

Securities sold, not yet purchased

Other trading liabilities

Total trading liabilities

Trading account derivatives
Interest rate contracts
Foreign exchange contracts
Equity contracts
Commodity contracts
Credit derivatives
Total trading derivatives

Cash collateral received(6)
Netting agreements
Netting of cash collateral paid

Total trading derivatives
Short-term borrowings
Long-term debt

Non-trading derivatives and other financial liabilities measured
on a recurring basis

Total liabilities
Total as a percentage of gross liabilities(5)

$

15,839

$

4,949

$

— $

20,788

$

— $ 20,788

$ 294,151

$ 818,051

$ 10,314

$1,134,034

$ (416,681) $717,353

26.2%

72.9%

0.9%

$

— $

980

$

78,872

—

11,364

1,547

495

983

586

—

$

1,475

$

— $ 1,475

111,494

(66,984)

44,510

90,822

1,547

— 90,822

—

1,547

$

$

$

$
$

$

$

78,872

$

12,911

$

586

$

92,369

$

— $ 92,369

71
—
351
—
—
422

$ 152,931
159,003
32,330
19,904
9,486
$ 373,654

$ 1,825
352
1,127
785
865
$ 4,954

$ 154,827
159,355
33,808
20,689
10,351
$ 379,030
13,906
$

$ (311,089)
(29,911)

422
— $
—

$ 373,654
4,446
25,659

$ 4,954
37
$
12,570

$ 392,936
4,483
$
38,229

$ (341,000) $ 51,936
— $ 4,483
$
— 38,229

15,839

$

67

$

— $

15,906

$

— $ 15,906

95,133

$ 528,228

$ 19,625

$ 656,892

$ (407,984) $248,908

14.8%

82.1%

3.1%

(1)  Represents netting of (i) the amounts due under securities purchased under agreements to resell and the amounts owed under securities sold under agreements to 

(2) 

repurchase and (ii) derivative exposures covered by a qualifying master netting agreement and cash collateral offsetting.
Includes positions related to investments in unallocated precious metals, as discussed in Note 25 to the Consolidated Financial Statements. Also includes physical 
commodities accounted for at the lower of cost or fair value and unfunded credit products.

(3)  Reflects the net amount of $41,429 million of gross cash collateral paid, of which $29,911 million was used to offset trading derivative liabilities.
(4)  Amounts exclude $0.2 billion of investments measured at net asset value (NAV) in accordance with ASU 2015-07, Fair Value Measurement (Topic 820): 

Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent). 

(5)  Because the amount of the cash collateral paid/received has not been allocated to the Level 1, 2 and 3 subtotals, these percentages are calculated based on total 

assets and liabilities measured at fair value on a recurring basis, excluding the cash collateral paid/received on derivatives.

(6)  Reflects the net amount of $52,514 million of gross cash collateral received, of which $38,608 million was used to offset trading derivative assets.

250

Changes in Level 3 Fair Value Category
The following tables present the changes in the Level 3 fair 
value category for the years ended December 31, 2019 and 
2018. The gains and losses presented below include changes in 
the fair value related to both observable and unobservable 
inputs.

The Company often hedges positions with offsetting 
positions that are classified in a different level. For example, 
the gains and losses for assets and liabilities in the Level 3 

Level 3 Fair Value Rollforward

category presented in the tables below do not reflect the effect 
of offsetting losses and gains on hedging instruments that may 
be classified in the Level 1 and Level 2 categories. In addition, 
the Company hedges items classified in the Level 3 category 
with instruments also classified in Level 3 of the fair value 
hierarchy. The hedged items and related hedges are presented 
gross in the following tables:

Net realized/unrealized
gains/losses included in

Transfers

Dec. 31,
2018

Principal

transactions Other(1)(2)

into
Level 3

out of
Level 3 Purchases

Issuances

Sales

Settlements

Unrealized
gains/
losses
still held(3)

Dec. 31,
2019

$

115 $

(5) $

— $

191 $

(4) $

195 $

— $

— $

(189) $

303 $

3

In millions of dollars

Assets

Securities borrowed and
purchased under
agreements to resell

Trading non-derivative
assets

Trading mortgage-
backed securities

U.S. government-
sponsored agency
guaranteed

Residential

Commercial

Total trading mortgage-
backed securities

U.S. Treasury and
federal agency securities $

State and municipal

Foreign government

Corporate

Marketable equity
securities

Asset-backed securities

Other trading assets

Total trading non-
derivative assets
Trading derivatives, net(4)

156

268

77

—

15

14

—

—

—

54

86

150

(72)

(80)

(105)

160

227

136

(1)

—

—

(287)

(393)

(211)

—

—

—

10

123

61

$

501 $

29 $

— $

290 $

(257) $

523 $

(1) $

(891) $

— $

194 $

1 $

(9) $

— $

— $

— $

20 $

— $

(11) $

(1) $

— $

200

31

360

153

1,484

818

(2)

28

284

(21)

(65)

(52)

—

—

—

—

—

—

1

12

213

13

51

97

(19)

(7)

(86)

(19)

(127)

(283)

2

88

323

117

738

598

—

—

(29)

—

—

36

(118)

(100)

(742)

(143)

(904)

(630)

—

—

(10)

—

—

(29)

64

52

313

100

1,177

555

1

10

(4)

7

—

(2)

1

(11)

(51)

29

(257)

$

3,548 $

192 $

— $

677 $

(798) $

2,409 $

6 $ (3,539) $

(40) $

2,455 $

(284)

Interest rate contracts

$

(154) $

116 $

— $

(129) $

172 $

154 $

45 $

(1) $

(202) $

1 $

2,194

Foreign exchange
contracts

Equity contracts

Commodity contracts

Credit derivatives

Total trading derivatives, 
net(4)

(6)

(784)

(18)

61

(73)

(425)

(121)

(412)

—

—

—

—

152

(213)

(15)

(114)

(97)

274

(15)

204

113

(111)

252

—

—

(147)

—

—

(114)

(8)

(133)

14

20

(5)

(182)

(1,596)

(9)

191

(59)

(56)

(134)

(422)

(33)

(289)

$

(901) $

(915) $

— $

(319) $

538 $

408 $

(102) $

(242) $

(182) $ (1,715) $

1,316

Table continues on the next page.

251

 
 
 
 
 
 
 
Net realized/unrealized
gains/losses included in

Transfers

Dec. 31,
2018

Principal

transactions Other(1)(2)

into
Level 3

out of
Level 3 Purchases

Issuances

Sales

Settlements

Unrealized
gains/
losses
still held(3)

Dec. 31,
2019

$

32 $

— $

— $

— $

— $

— $

— $ — $

— $

32 $

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

—

$

$

32 $

— $

708

68

156

—

187

—

586

$

$

1,737 $

277 $

584

— $

— $

— $

— $

— $

— $ — $

— $

32 $

— $

— $

— $

— $

— $

— $ — $

— $

— $

—

—

—

—

—

—

—

— $

— $

—

86

2

(14)

—

(11)

—

(11)

14

—

3

—

122

—

39

(318)

—

(94)

—

(612)

—

(1)

430

145

—

—

550

—

11

— (297)

— (119)

—

—

(6)

—

— (214)

—

—

—

—

—

—

—

—

623

96

45

—

22

—

— (151)

(32)

441

52 $

178 $ (1,025) $

1,136 $

— $ (787) $

(32) $

1,259 $

192 $

148 $

(189) $

(84)

—

—

16 $

—

— $

(40) $

(2) $

402 $

70

—

(75)

495

(1)

—

—

(1)

—

82

2

—

—

13

—

16

112

186

(68)

—

—

96

6

(2)

2

32

(21)

(112)

1

18

In millions of dollars

Investments

Mortgage-backed
securities

U.S. government-
sponsored agency
guaranteed

Residential

Commercial

Total investment
mortgage-backed
securities

U.S. Treasury and
federal agency securities

State and municipal

Foreign government

Corporate

Marketable equity
securities

Asset-backed securities

Other debt securities

Non-marketable equity
securities

Total investments

Loans

Mortgage servicing rights

Other financial assets
measured on a recurring
basis

Liabilities

Interest-bearing deposits

$

495 $

— $

(16) $

10 $

(783) $

— $

843 $ — $

(366) $

215 $

(25)

Securities loaned and sold
under agreements to
repurchase

Trading account liabilities

Securities sold, not yet
purchased

Other trading liabilities

Short-term borrowings

983

586

—

37

121

122

—

32

Long-term debt

12,570

(2,140)

Other financial liabilities
measured on a recurring
basis

—

—

—

—

—

—

—

4

1

68

—

13

4

(443)

—

(42)

3,892

(5,188)

5

—

—

19

—

—

23

—

— (168)

58

757

(26)

—

—

168

8,262

(12)

—

—

(5)

(48)

—

(131)

48

—

13

3

—

(1)

(4,525)

17,169

(3,300)

4

—

(5)

—

—

(1)  Changes in fair value of available-for-sale investments are recorded in AOCI, unless related to other-than-temporary impairment, while gains and losses from sales 

are recorded in Realized gains (losses) from sales of investments in the Consolidated Statement of Income.

(2)  Unrealized gains (losses) on MSRs are recorded in Other revenue in the Consolidated Statement of Income.
(3)  Represents the amount of total gains or losses for the period, included in earnings (and AOCI for changes in fair value of available-for-sale investments), 

attributable to the change in fair value relating to assets and liabilities classified as Level 3 that are still held at December 31, 2019.

(4)  Total Level 3 trading derivative assets and liabilities have been netted in these tables for presentation purposes only.

252

 
 
 
 
 
 
 
Net realized/unrealized
gains (losses) included in

Transfers

Dec. 31,
2017

Principal
transactions Other(1)(2)

into
Level 3

out of
Level 3

Purchases

Issuances

Sales

Settlements

Unrealized
gains
(losses)
still held(3)

Dec. 31,
2018

$

16 $

17 $

— $

50 $

— $

95 $

— $

16 $

(79) $

115 $

9

U.S. Treasury and
federal agency securities $

In millions of dollars

Assets

Securities borrowed and
purchased under
agreements to resell

Trading non-derivative
assets

Trading mortgage-
backed securities

U.S. government-
sponsored agency
guaranteed

Residential

Commercial

Total trading mortgage-
backed securities

State and municipal

Foreign government

Corporate

Marketable equity
securities
Asset-backed securities

Other trading assets

Total trading non-
derivative assets
Trading derivatives, net(4)

Foreign exchange
contracts

Equity contracts

Commodity contracts

Credit derivatives

Total trading derivatives, 
net(4)

Investments

Mortgage-backed
securities

U.S. government-
sponsored agency
guaranteed

Residential

Commercial

Total investment
mortgage-backed
securities

163

164

57

5

112

(7)

—

—

—

92

124

24

(107)

(133)

(49)

281

154

110

—

—

—

(278)

(153)

(58)

—

—

—

156

268

77

$

384 $

110 $

— $

240 $

(289) $

545 $

— $

(489) $

— $

501 $

— $

— $

— $

6 $

(4) $

1 $

— $

— $

(2) $

1 $

274

16

275

120

1,590

615

22

(2)

(72)

2

28

276

—

—

—

—

—

—

—

5

138

25

77

197

(96)

(13)

(122)

(62)

(90)

(82)

45

75

596

290

1,238

598

—

—

(45)

(50)

(40)

(415)

—

(222)

— (1,359)

8

(777)

—

—

—

—

—

(17)

200

31

360

153

1,484

818

$

3,274 $

364 $

— $

688 $

(758) $

3,388 $

(32) $ (3,357) $

(19) $

3,548 $

153

Interest rate contracts

$

(422) $

414 $

— $

(6) $

(193) $

8 $

17 $

(32) $

60 $

(154) $

336

130

(2,027)

(1,861)

(799)

(99)

479

(505)

261

—

—

—

—

(29)

(131)

(32)

(7)

77

1,114

2,180

391

11

25

62

2

—

(44)

—

—

(89)

(17)

(19)

1

(7)

(6)

(183)

(784)

157

212

(18)

61

(72)

52

(171)

87

$ (4,979) $

550 $

— $

(205) $ 3,569 $

108 $

(27) $

(156) $

239 $

(901) $

232

$

24 $

— $

10 $

— $

— $

— $

— $

(2) $

— $

32 $

—

3

—

—

—

2

—

1

—

(1)

—

—

—

—

—

(5)

—

—

—

—

$

27 $

— $

12 $

1 $

(1) $

— $

— $

(7) $

— $

32 $

U.S. Treasury and
federal agency securities $

State and municipal

Foreign government

Corporate

Marketable equity
securities
Asset-backed securities

Other debt securities

Non-marketable equity
securities

— $

— $

— $

— $

— $

— $

— $

— $

— $

— $

737

92

71

2

827

—

681

—

—

—

—

—

—

—

(20)

(3)

(1)

1

(21)

—

—

3

61

—

10

—

(95)

193

(18)

(4)

(66)

—

(524)

—

—

211

141

101

—

63

—

91

—

—

—

—

—

—

—

(202)

(161)

(10)

(2)

(168)

—

(234)

—

—

—

(1)

—

—

(50)

708

68

156

—

187

—

586

Total investments

$

2,437 $

— $

(127) $

268 $

(613) $

607 $

— $

(784) $

(51) $

1,737 $

Table continues on the next page.

253

186

4

—

190

—

9

(28)

(32)

(56)

(21)

91

14

—

—

14

—

(29)

4

—

—

—

—

55

44

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In millions of dollars

Dec. 31,
2017

Principal
transactions

Other(1)(2)

into
Level 3

out of
Level 3

Purchases

Issuances

Sales

Settlements

Net realized/unrealized
gains (losses) included in

Transfers

Unrealized
gains
(losses)
still held(3)

Dec. 31,
2018

Loans

$

550 $

— $

(319) $

— $

13 $

140 $

— $ (103) $

(4) $

277 $

Mortgage servicing rights

558

Other financial assets
measured on a recurring
basis

Liabilities

16

—

—

54

51

—

—

—

(11)

—

4

58

(18)

(68)

584

12

(12)

(60)

—

236

59

63

Interest-bearing deposits

$

286 $

— $

14 $

13 $

(1) $

— $

215 $ — $

(4) $

495 $

(355)

Securities loaned and sold
under agreements to
repurchase

Trading account liabilities

Securities sold, not yet
purchased
Other trading liabilities

Short-term borrowings

726

(8)

22

5

18

(454)

5

53

(182)

—

—

—

—

—

1

—

187

—

72

(172)

—

(46)

2,850

(3,514)

Long-term debt

13,082

Other financial liabilities
measured on a recurring
basis

8

—

(2)

1

(10)

—

7

—

—

36

—

243

(31)

36

983

24

226

—

86

(39)

—

—

(99)

—

(40)

586

—

37

(238)

—

25

(18)

(45)

(3)

12,570

(2,871)

2

—

(3)

—

(8)

(1)  Changes in fair value of available-for-sale debt securities are recorded in AOCI, unless related to other-than-temporary impairment, while gains and losses from 

sales are recorded in Realized gains (losses) from sales of investments in the Consolidated Statement of Income.

(2)  Unrealized gains (losses) on MSRs are recorded in Other revenue in the Consolidated Statement of Income.
(3)  Represents the amount of total gains or losses for the period, included in earnings (and AOCI for changes in fair value of available-for-sale debt securities), 

attributable to the change in fair value relating to assets and liabilities classified as Level 3 that are still held at December 31, 2018.

(4)  Total Level 3 derivative assets and liabilities have been netted in these tables for presentation purposes only.

Level 3 Fair Value Rollforward 
The following were the significant Level 3 transfers for the 
period December 31, 2018 to December 31, 2019:

•  Transfers of Long-Term Debt of $3.9 billion from Level 2 
to Level 3, and of $5.2 billion from Level 3 to Level 2, 
mainly related to structured debt, reflecting changes in the 
significance of unobservable inputs as well as certain 
underlying market inputs becoming less or more 
observable.

The following were the significant Level 3 transfers for the 
period December 31, 2017 to December 31, 2018:

•  Transfers of Equity Contract Derivatives of $1.1 billion 
from Level 3 to Level 2, related to equity derivatives 
where the unobservable components were deemed 
insignificant.

•  Transfers of Commodity Contract Derivatives of $2.2 
billion from Level 3 to Level 2, related to commodity 
derivatives where the unobservable component of the 
derivatives were deemed insignificant.

•  Transfers of Long-term debt of $2.9 billion from Level 2 

to Level 3, and of $3.5 billion from Level 3 to Level 2, 
mainly related to structured debt, reflecting changes in the 
significance of unobservable inputs as well as certain 
underlying market inputs becoming less or more 
observable.

254

 
 
 
 
 
 
 
Valuation Techniques and Inputs for Level 3 Fair 
Value Measurements
The Company’s Level 3 inventory consists of both cash
instruments and derivatives of varying complexity. The
valuation methodologies used to measure the fair value of
these positions include discounted cash flow analysis, internal
models and comparative analysis. A position is classified
within Level 3 of the fair value hierarchy when at least one
input is unobservable and is considered significant to its
valuation. The specific reason an input is deemed
unobservable varies; for example, at least one significant
input to the pricing model is not observable in the market, at

least one significant input has been adjusted to make it more
representative of the position being valued or the price quote
available does not reflect sufficient trading activities.

The following tables present the valuation techniques 

covering the majority of Level 3 inventory and the most 
significant unobservable inputs used in Level 3 fair value 
measurements. Differences between this table and amounts 
presented in the Level 3 Fair Value Rollforward table 
represent individually immaterial items that have been 
measured using a variety of valuation techniques other than 
those listed.

Fair value(1)
 (in millions)

Methodology

Input

Low(2)(3)

High(2)(3)

Weighted
average(4)

As of December 31, 2019

Assets
Securities borrowed and

purchased under agreements
to resell

Mortgage-backed securities

State and municipal, foreign

government, corporate and
other debt securities

Marketable equity securities(5)

Asset-backed securities

Non-marketable equities

\

Derivatives—gross(6)
Interest rate contracts (gross)

Foreign exchange contracts
(gross)

$

$

$

$

$

$

$

$

$

303 Model-based

Credit spread

196 Price-based
22 Model-based

880 Model-based
677 Price-based
70 Price-based
30 Model-based

812 Price-based

Interest rate
Price

Price
Credit spread
Price
WAL

Recovery
(in millions)
Price

368 Yield analysis

Yield

316 Comparables analysis EBITDA multiples

97 Price-based

Appraised value
(in thousands)

Price
PE ratio
Price to book ratio
Discount to price

$

$

$

$
$

$

$

2,196 Model-based

Inflation volatility

1,099 Model-based

Mean reversion

IR normal volatility

FX volatility
IR normal volatility

FX rate

Interest rate

IR-IR correlation

IR-FX correlation
Equity volatility
Forward price

WAL

Recovery
(in millions)

255

15 bps

1.59 %
36

$

15 bps

3.67%
505

$

15 bps

2.72 %
97

$

$

$
$

$

$

— $

35 bps

— $

1.48 years

1,238
295 bps
38,500
1.48 years

$
$

$

$

5,450
4

0.61 %

7.00x

397

3
14.70x
1.50x
— %

0.21 %

1.00 %

0.09 %

1.27 %
0.27 %

37.39 %

2.72 %

(51.00)%

40.00 %
3.16 %
62.60 %

5,450
103

23.38%

17.95x

33,246

2,019
28.70x
3.00x
10.00%

2.74%

20.00%

0.66%

12.16%
0.66%

586.84%

56.14%

40.00%

60.00%
52.80%
112.69%

90
209 bps
2,979
1.48 years

5,450
60

8.88 %

10.34x

8,446

1,020
20.54x
1.88x
2.32 %

0.79 %

10.50 %

0.53 %

9.17 %
0.58 %

80.64 %

13.11 %

32.00 %

50.00 %
28.43 %
98.46 %

1.48 years

1.48 years

1.48 years

$

5,450

$

5,450

$

5,450

Equity contracts (gross)(7)

$

2,076 Model-based

 
 
 
 
 
 
As of December 31, 2019
Commodity and other contracts
(gross)

Fair value(1)
 (in millions)

Methodology

Input

Low(2)(3)

High(2)(3)

Weighted
average(4)

$

1,487 Model-based

Forward price

37.62 %

362.57%

119.32 %

Credit derivatives (gross)

Loans and leases

Mortgage servicing rights

Liabilities
Interest-bearing deposits

Securities loaned and sold under
agreements to repurchase

Trading account liabilities
Securities sold, not yet
purchased

Short-term borrowings and

long-term debt

$

$

$

$

$

$

$

613 Model-based
341 Price-based

378 Model-based

418 Cash flow
77 Model-based

215 Model-based

Commodity 
volatility

Commodity
correlation

Credit spread
Upfront points

Price

Credit
correlation
Recovery rate
Credit spread
Equity volatility
Yield
WAL

Mean reversion

Forward price

5.25 %

93.63%

23.55 %

(39.65)%

8 bps
2.59 %

87.81%

283 bps
99.94%

41.80 %

80 bps
59.41 %

$

12

$

100

$

87

25.00 %
20.00 %
9 bps
32.00 %
1.78 %
4.07 years

87.00%
65.00%
52 bps
32.00%
12.00%
8.13 years

48.57 %
48.00 %
48 bps
32.00 %
9.49 %
6.61 years

1.00 %

97.59 %

20.00%

111.06%

10.50 %

102.96 %

757 Model-based

Interest rate

1.59 %

2.38%

1.95 %

46 Price-based

Price

$

— $

866

$

96

17,182 Model-based

Mean reversion

IR normal volatility

Forward price

Equity-IR
Correlation

1.00 %

0.09 %

20.00%

0.66%

37.62 %

362.57%

10.50 %

0.46 %

97.52 %

15.00 %

44.00%

32.66 %

Fair value(1)
 (in millions)

Methodology

Input

Low(2)(3)

High(2)(3)

Weighted
average(4)

As of December 31, 2018

Assets

Securities borrowed and

purchased under agreements to
resell

Mortgage-backed securities

State and municipal, foreign
government, corporate and
other debt securities

Marketable equity securities(5)

Asset-backed securities

Non-marketable equities

$

$

$

$

$

$

115 Model-based

Interest rate

313 Price-based

198 Yield analysis

Price

Yield

1,212 Price-based

Price

938 Model-based

Credit spread

108 Price-based

45 Model-based

1,608 Price-based

Comparables
analysis

293

Price

WAL

Price

Discount to price

255 Price-based

EBITDA multiples

Net operating income
multiple

2.52 %

11

$

2.27 %

7.43 %

110

$

8.70 %

5.08 %

90

3.74 %

— $

104

35 bps

446 bps

— $

20,255

1.47 years

1.47 years

3

$

101

$

$

$

91

238 bps

1,248

1.47 years

66

$

$

$

$

— %

5.00x

100.00 %

34.00x

24.70x

24.70x

0.66 %

9.73x

24.70x

420

7.06x

Derivatives—gross(6)

256

Price

$

2

$

1,074

$

Revenue multiple

2.25x

16.50x

 
 
 
 
 
 
Fair value(1)
 (in millions)

Methodology

Input

Low(2)(3)

High(2)(3)

Weighted
average(4)

As of December 31, 2018

Interest rate contracts (gross)

Foreign exchange  contracts
(gross)

$

$

3,467 Model-based

Mean reversion

Inflation volatility

IR normal volatility

Foreign exchange (FX)

626 Model-based

volatility

73 Cash flow

IR-IR correlation

IR-FX correlation

Credit spread

IR basis

Yield

Equity contracts (gross)(7)

$

1,467 Model-based

Equity volatility

Forward price

Equity-Equity
correlation

Equity-FX correlation

1.00 %

0.22 %

0.16 %

3.15 %

(51.00)%

40.00 %

39 bps

(0.65)%

6.98 %

3.00 %

64.66 %

(81.39)%

(86.27)%

20.00 %

2.65 %

0.86 %

17.35 %

40.00 %

60.00 %

676 bps

0.11 %

7.48 %

78.39 %

144.45 %

100.00 %

70.00 %

10.50 %

0.77 %

0.56 %

11.37 %

32.69 %

50.00 %

423 bps

(0.17)%

7.23 %

37.53 %

98.55 %

35.49 %

(1.20)%

59.86 %

92.11 %

85.00 %

99.04 %

1,127 bps

65.00 %

5.00 %

7.41 %

2 bps

5.00 %

$

$

17

$

98

$

138 bps

0.30 %

255 bps

0.47 %

56

$

110

$

4.60 %

12.00 %

20.34 %

40.71 %

41.06 %

58.95 %

87 bps

46.40 %

81

147 bps

0.32 %

92

7.79 %

3.55 years

7.45 years

6.39 years

WAL

1.47 years

1.47 years

1.47 years

1,552 Model-based

Forward price

Commodity volatility

15.30 %

8.92 %

Commodity correlation

(51.90)%

585.07 %

145.08 %

1,089 Model-based

Credit correlation

701 Price-based

Upfront points

Credit spread

Recovery rate

Price

248 Model-based

Credit spread

29 Price-based

501 Cash flow

84 Model-based

Yield

Price

Yield

WAL

495 Model-based

Mean reversion

Forward price

Equity volatility

1.00 %

64.66 %

3.00 %

20.00 %

144.45 %

78.39 %

10.50 %

98.55 %

43.49 %

983 Model-based

Interest rate

2.52 %

3.21 %

2.87 %

Securities sold, not yet purchased $

509 Model-based

Forward price

77 Price-based

Equity volatility

Equity-Equity
correlation

Equity-FX correlation

Commodity volatility

Commodity correlation

Equity-IR correlation

Short-term borrowings and long-

term debt

$

12,289 Model-based

Mean reversion

Forward price

Equity volatility

15.30 %

3.00 %

(81.39)%

(86.27)%

8.92 %

(51.90)%

(40.00)%

1.00 %

64.66 %

3.00 %

585.07 %

78.39 %

100.00 %

70.00 %

59.86 %

92.11 %

70.37 %

20.00 %

144.45 %

78.39 %

105.69 %

43.49 %

34.04 %

(1.20)%

20.34 %

40.71 %

30.80 %

10.50 %

98.58 %

43.24 %

(1)  The fair value amounts presented in these tables represent the primary valuation technique or techniques for each class of assets or liabilities.

257

Commodity and other contracts
(gross)

Credit derivatives (gross)

Loans and leases

Mortgage servicing rights

Liabilities

Interest-bearing deposits

Securities loaned and sold under
agreements to repurchase

Trading account liabilities

$

$

$

$

$

$

(2)  Some inputs are shown as zero due to rounding.
(3)  When the low and high inputs are the same, there is either a constant input applied to all positions, or the methodology involving the input applies to only one 

large position.

(4)  Weighted averages are calculated based on the fair values of the instruments.
(5)  For equity securities, the price inputs are expressed on an absolute basis, not as a percentage of the notional amount.
(6)  Both trading and nontrading account derivatives—assets and liabilities—are presented on a gross absolute value basis.
(7) 

Includes hybrid products.

Uncertainty of Fair Value Measurements Relating to 
Unobservable Inputs
Valuation uncertainty arises when there is insufficient or 
disperse market data to allow a precise determination of the 
exit value of a fair-valued position or portfolio in today’s 
market. This is especially prevalent in Level 3 fair value 
instruments, where uncertainty exists in valuation inputs that 
may be both unobservable and significant to the instrument’s 
(or portfolio’s) overall fair value measurement. The 
uncertainties associated with key unobservable inputs on the 
Level 3 fair value measurements may not be independent of 
one another. In addition, the amount and direction of the 
uncertainty on a fair value measurement for a given change in 
an unobservable input depends on the nature of the instrument 
as well as whether the Company holds the instrument as an 
asset or a liability. For certain instruments, the pricing, 
hedging and risk management are sensitive to the correlation 
between various inputs rather than on the analysis and 
aggregation of the individual inputs.

The following section describes some of the most 
significant unobservable inputs used by the Company in 
Level 3 fair value measurements.

Correlation
Correlation is a measure of the extent to which two or more 
variables change in relation to each other. A variety of 
correlation-related assumptions are required for a wide range 
of instruments, including equity and credit baskets, foreign 
exchange options, CDOs backed by loans or bonds, 
mortgages, subprime mortgages and many other instruments. 
For almost all of these instruments, correlations are not 
directly observable in the market and must be calculated using 
alternative sources, including historical information. 
Estimating correlation can be especially difficult where it may 
vary over time, and calculating correlation information from 
market data requires significant assumptions regarding the 
informational efficiency of the market (e.g., swaption 
markets). Uncertainty therefore exists when an estimate of the 
appropriate level of correlation as an input into some fair 
value measurements is required.

Changes in correlation levels can have a substantial 

impact, favorable or unfavorable, on the value of an 
instrument, depending on its nature. A change in the default 
correlation of the fair value of the underlying bonds 
comprising a CDO structure would affect the fair value of the 
senior tranche. For example, an increase in the default 
correlation of the underlying bonds would reduce the fair 
value of the senior tranche, because highly correlated 
instruments produce greater losses in the event of default and 
a portion of these losses would become attributable to the 
senior tranche. That same change in default correlation would 

have a different impact on junior tranches of the same 
structure.

Volatility
Volatility represents the speed and severity of market price 
changes and is a key factor in pricing options. Volatility 
generally depends on the tenor of the underlying instrument 
and the strike price or level defined in the contract. Volatilities 
for certain combinations of tenor and strike are not observable 
and need to be estimated using alternative methods, such as 
using comparable instruments, historical analysis or other 
sources of market information. This leads to uncertainty 
around the final fair value measurement of instruments with 
unobservable volatilities. 

The general relationship between changes in the value of 
a portfolio to changes in volatility also depends on changes in 
interest rates and the level of the underlying index. Generally, 
long option positions (assets) benefit from increases in 
volatility, whereas short option positions (liabilities) will 
suffer losses. Some instruments are more sensitive to changes 
in volatility than others. For example, an at-the-money option 
would experience a greater percentage change in its fair value 
than a deep-in-the-money option. In addition, the fair value of 
an option with more than one underlying security (e.g., an 
option on a basket of bonds) depends on the volatility of the 
individual underlying securities as well as their correlations.

Yield
In some circumstances, the yield of an instrument is not 
observable in the market and must be estimated from historical 
data or from yields of similar securities. This estimated yield 
may need to be adjusted to capture the characteristics of the 
security being valued. In other situations, the estimated yield 
may not represent sufficient market liquidity and must be 
adjusted as well. Whenever the amount of the adjustment is 
significant to the value of the security, the fair value 
measurement is classified as Level 3.

Adjusted yield is generally used to discount the projected 
future principal and interest cash flows on instruments, such as 
asset-backed securities. Adjusted yield is impacted by changes 
in the interest rate environment and relevant credit spreads. 

Prepayment
Voluntary unscheduled payments (prepayments) change the 
future cash flows for the investor and thereby change the fair 
value of the security. The effect of prepayments is more 
pronounced for residential mortgage-backed securities. An 
increase in prepayments—in speed or magnitude—generally 
creates losses for the holder of these securities. Prepayment is 
generally negatively correlated with delinquency and interest 
rate. A combination of low prepayment and high delinquencies 
amplifies each input’s negative impact on mortgage securities’ 
valuation. As prepayment speeds change, the weighted 

258

average life of the security changes, which impacts the 
valuation either positively or negatively, depending upon the 
nature of the security and the direction of the change in the 
weighted average life.

Recovery
Recovery is the proportion of the total outstanding balance of 
a bond or loan that is expected to be collected in a liquidation 
scenario. For many credit securities (such as asset-backed 
securities), there is no directly observable market input for 
recovery, but indications of recovery levels are available from 
pricing services. The assumed recovery of a security may 
differ from its actual recovery that will be observable in the 
future. The recovery rate impacts the valuation of credit 
securities. Generally, an increase in the recovery rate 
assumption increases the fair value of the security. An increase 
in loss severity, the inverse of the recovery rate, reduces the 
amount of principal available for distribution and, as a result, 
decreases the fair value of the security.

Credit Spread
Credit spread is a component of the security representing its 
credit quality. Credit spread reflects the market perception of 
changes in prepayment, delinquency and recovery rates, 
therefore capturing the impact of other variables on the fair 
value. Changes in credit spread affect the fair value of 
securities differently depending on the characteristics and 
maturity profile of the security. For example, credit spread is a 
more significant driver of the fair value measurement of a high 
yield bond as compared to an investment grade bond. 
Generally, the credit spread for an investment grade bond is 
also more observable and less volatile than its high yield 
counterpart.

259

Where the fair value of the related collateral is based on 
an unadjusted appraised value, the loan is generally classified 
as Level 2. Where significant adjustments are made to the 
appraised value, the loan is classified as Level 3. In addition, 
for corporate loans, appraisals of the collateral are often based 
on sales of similar assets; however, because the prices of 
similar assets require significant adjustments to reflect the 
unique features of the underlying collateral, these fair value 
measurements are generally classified as Level 3.

The fair value of non-marketable equity securities under 
the measurement alternative is based on observed transaction 
prices for the identical or similar investment of the same 
issuer, or an internal valuation technique in the case of an 
impairment. Where significant adjustments are made to the 
observed transaction price or when an internal valuation 
technique is used, the security is classified as Level 3. Fair 
value may differ from the observed transaction price due to a 
number of factors, including marketability adjustments and 
differences in rights and obligations when the observed 
transaction is not for the identical investment held by Citi.

Items Measured at Fair Value on a Nonrecurring Basis
Certain assets and liabilities are measured at fair value on a 
nonrecurring basis and, therefore, are not included in the 
tables above. These include assets measured at cost that have 
been written down to fair value during the periods as a result 
of an impairment. These also include non-marketable equity 
securities that have been measured using the measurement 
alternative and are either (i) written down to fair value during 
the periods as a result of an impairment or (ii) adjusted upward 
or downward to fair value as a result of a transaction observed 
during the periods for the identical or similar investment of the 
same issuer. In addition, these assets include loans held-for-
sale and other real estate owned that are measured at the lower 
of cost or market value.

The following tables present the carrying amounts of all 
assets that were still held for which a nonrecurring fair value 
measurement was recorded:

In millions of dollars

Fair value

Level 2

Level 3

December 31, 2019
Loans HFS(1)
Other real estate owned
Loans(2)
Non-marketable equity
securities measured
using the measurement
alternative

$

4,579 $

3,249 $

1,330

20

344

6

93

14

251

249

249

—

Total assets at fair value
on a nonrecurring basis $

5,192 $

3,597 $

1,595

In millions of dollars

Fair value

Level 2

Level 3

December 31, 2018
Loans HFS(1)
Other real estate owned
Loans(2)
Non-marketable equity
securities measured
using the measurement
alternative
Total assets at fair value
on a nonrecurring basis

$

5,055 $

3,261 $

1,794

78

390

62

139

16

251

261

192

69

$

5,784 $

3,654 $

2,130

(1)  Net of fair value amounts on the unfunded portion of loans HFS 

recognized as Other liabilities on the Consolidated Balance Sheet. 
(2)  Represents impaired loans held for investment whose carrying amount is 
based on the fair value of the underlying collateral less costs to sell, 
primarily real estate.

The fair value of loans HFS is determined where possible 
using quoted secondary-market prices. If no such quoted price 
exists, the fair value of a loan is determined using quoted 
prices for a similar asset or assets, adjusted for the specific 
attributes of that loan. Fair value for the other real estate 
owned is based on appraisals. For loans whose carrying 
amount is based on the fair value of the underlying collateral, 
the fair values depend on the type of collateral. Fair value of 
the collateral is typically estimated based on quoted market 
prices if available, appraisals or other internal valuation 
techniques.

260

 
 
 
 
 
 
Valuation Techniques and Inputs for Level 3 Nonrecurring Fair Value Measurements 
The following tables present the valuation techniques covering the majority of Level 3 nonrecurring fair value measurements and the 
most significant unobservable inputs used in those measurements:

As of December 31, 2019

Loans HFS

Other real estate owned

Loans(6)

Fair value(1)
 (in millions)

Methodology

Input

$

$

$

$

1,320 Price-based

11 Price-based

5 Recovery analysis

Price
$
Appraised value(4) $

100 Recovery analysis

Recovery rate

54 Cash flow

47 Price-based

29 Price-based

Price

$

Cost of capital
Appraised value(4) $

As of December 31, 2018

Loans HFS

Other real estate owned

Loans(6)

Fair value(1)
 (in millions)

Methodology

Input

$

$

$

1,729 Price-based

15 Price-based

2 Recovery analysis

Price
Appraised value(4)
Discount to price

Price

251 Recovery analysis

Recovery rate

Price

Non-marketable equity
securities measured using
the measurement alternative $

66 Price-based

Price

$

$

$

Low(2)

86

2,297,358

0.57%

2

0.10%

17,521,218

Low(2)

$

81

$ 8,394,102

13.00%

56

30.60%

3

High

100

8,394,102

100.00%

54

100.00%

43,646,426

High

100

8,394,102

13.00%

83

100.00%

85

Weighted
average(3)

99

5,615,884

64.78%

27

54.84%

30,583,822

Weighted
average(3)

98

8,394,102

13.00%

58

50.51%

28

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

$

46

$

1,514

$

570

(1)  The fair value amounts presented in this table represent the primary valuation technique or techniques for each class of assets or liabilities.
(2)  Some inputs are shown as zero due to rounding.
(3)  Weighted averages are calculated based on the fair values of the instruments.
(4)  Appraised values are disclosed in whole dollars.
(5) 
(6)  Represents impaired loans held for investment whose carrying amounts are based on the fair value of the underlying collateral, primarily real estate secured loans.

Includes estimated costs to sell.

Nonrecurring Fair Value Changes
The following tables present total nonrecurring fair value 
measurements for the period, included in earnings, attributable 
to the change in fair value relating to assets that were still 
held:

In millions of dollars

Loans HFS

$

Other real estate owned
Loans(1)
Non-marketable equity securities measured
using the measurement alternative

Total nonrecurring fair value gains (losses)

$

Year ended
December 31,

2019

—

(1)

(56)

99

42

In millions of dollars

Loans HFS

$

Other real estate owned
Loans(1)
Non-marketable equity securities measured
using the measurement alternative

Total nonrecurring fair value gains (losses)

$

Year ended
December 31,

2018

(13)

(2)

(22)

194

157

(1)  Represents loans held for investment whose carrying amount is based on 

the fair value of the underlying collateral, primarily real estate.

261

Estimated Fair Value of Financial Instruments Not 
Carried at Fair Value
The following tables present the carrying value and fair value 
of Citigroup’s financial instruments that are not carried at fair 
value. The tables below therefore exclude items measured at 
fair value on a recurring basis presented in the tables above.

The disclosure also excludes leases, affiliate investments, 

pension and benefit obligations, certain insurance contracts 
and tax-related items. Also, as required, the disclosure 
excludes the effect of taxes, any premium or discount that 
could result from offering for sale at one time the entire 
holdings of a particular instrument, excess fair value 
associated with deposits with no fixed maturity and other 
expenses that would be incurred in a market transaction. In 
addition, the tables exclude the values of non-financial assets 
and liabilities, as well as a wide range of franchise, 
relationship and intangible values, which are integral to a full 
assessment of Citigroup’s financial position and the value of 
its net assets. 

Fair values vary from period to period based on changes 

in a wide range of factors, including interest rates, credit 
quality and market perceptions of value, and as existing assets 
and liabilities run off and new transactions are entered into. 

In billions of dollars
Assets

Investments

Securities borrowed and purchased under agreements to resell
Loans(1)(2)
Other financial assets(2)(3)
Liabilities

Deposits

Securities loaned and sold under agreements to repurchase
Long-term debt(4)
Other financial liabilities(5)

In billions of dollars
Assets

Investments

Securities borrowed and purchased under agreements to resell
Loans(1)(2)
Other financial assets(2)(3)
Liabilities

Deposits

Securities loaned and sold under agreements to repurchase
Long-term debt(4)
Other financial liabilities(5)

December 31, 2019

Estimated fair value

Carrying
value

Estimated
fair value

Level 1

Level 2

Level 3

$

86.4 $

87.8 $

1.9 $

83.8 $

98.1

681.2

262.4

98.1

677.7

262.4

—

—

177.6

98.1

4.7

16.3

2.1

—

673.0

68.5

$

1,068.3 $

1,066.7 $

— $

875.5 $

191.2

125.7

193.0

110.2

125.7

203.8

110.2

—

—

—

125.7

187.3

37.5

—

16.5

72.7

December 31, 2018

Estimated fair value

Carrying
value

Estimated
fair value

Level 1

Level 2

Level 3

$

68.9 $

68.5 $

1.0 $

65.4 $

123.0

667.1

249.7

123.0

666.9

250.1

—

—

172.3

121.6

5.6

15.8

2.1

1.4

661.3

62.0

$

1,011.7 $

1,009.5 $

— $

847.1 $

162.4

133.3

193.8

103.8

133.3

193.7

103.8

—

—

—

133.3

178.4

17.2

—

15.3

86.6

(1)  The carrying value of loans is net of the Allowance for loan losses of $12.8 billion for December 31, 2019 and $12.3 billion for December 31, 2018. In addition, 

the carrying values exclude $1.4 billion and $1.6 billion of lease finance receivables at December 31, 2019 and 2018, respectively.
Includes items measured at fair value on a nonrecurring basis.

(2) 

262

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(3) 

Includes cash and due from banks, deposits with banks, brokerage receivables, reinsurance recoverables and other financial instruments included in Other assets 
on the Consolidated Balance Sheet, for all of which the carrying value is a reasonable estimate of fair value.

(4)  The carrying value includes long-term debt balances under qualifying fair value hedges.
(5) 

Includes brokerage payables, separate and variable accounts, short-term borrowings (carried at cost) and other financial instruments included in Other liabilities 
on the Consolidated Balance Sheet, for all of which the carrying value is a reasonable estimate of fair value.

The estimated fair values of the Company’s corporate 
unfunded lending commitments at December 31, 2019 and 
2018 were liabilities of $5.1 billion and $7.8 billion, 
respectively, substantially all of which are classified as 
Level 3. The Company does not estimate the fair values of 
consumer unfunded lending commitments, which are 
generally cancelable by providing notice to the borrower.

263

25.   FAIR VALUE ELECTIONS

The Company may elect to report most financial instruments 
and certain other items at fair value on an instrument-by-
instrument basis with changes in fair value reported in 
earnings, other than DVA (see below). The election is made 
upon the initial recognition of an eligible financial asset, 
financial liability or firm commitment or when certain 
specified reconsideration events occur. The fair value election 
may not otherwise be revoked once an election is made. The 

changes in fair value are recorded in current earnings, other 
than DVA, which is reported in AOCI. Additional discussion 
regarding the applicable areas in which fair value elections 
were made is presented in Note 24 to the Consolidated 
Financial Statements.

The Company has elected fair value accounting for its 

mortgage servicing rights (MSRs). See Note 21 to the 
Consolidated Financial Statements for further discussions 
regarding the accounting and reporting of MSRs.

The following table presents the changes in fair value of those items for which the fair value option has been elected:

In millions of dollars

Assets

Securities borrowed and purchased under agreements to resell

Trading account assets

Investments

Loans

Certain corporate loans 
Certain consumer loans

Total loans

Other assets

MSRs
Certain mortgage loans HFS(1)

Total other assets

Total assets

Liabilities

Interest-bearing deposits
Securities loaned and sold under agreements to repurchase 

Trading account liabilities

Short-term borrowings
Long-term debt(2)
Total liabilities

Changes in fair value for the years 
ended 
December 31,

2019

2018

$

$

$

$

$

$

$

6 $
77

—

(222)

—

(222) $

(84) $

91

7 $

(132) $

(205) $

386

27

(78)

(5,174)

(5,044) $

(6)
(337)
—

(116)
—

(116)

54

38

92

(367)

20

(118)

(13)

150

3,048

3,087

Includes gains (losses) associated with interest rate lock commitments for those loans that have been originated and elected under the fair value option.

(1) 
(2)   Includes DVA that is included in AOCI. See Notes 19 and 24 to the Consolidated Financial Statements. 

264

 
Own Debt Valuation Adjustments (DVA)
Own debt valuation adjustments are recognized on Citi’s 
liabilities for which the fair value option has been elected 
using Citi’s credit spreads observed in the bond market. 
Changes in fair value of fair value option liabilities related to 
changes in Citigroup’s own credit spreads (DVA) are reflected 
as a component of AOCI. See Note 1 to the Consolidated 
Financial Statements for additional information. 

Among other variables, the fair value of liabilities for 
which the fair value option has been elected (other than non-
recourse debt and similar liabilities) is impacted by the 
narrowing or widening of the Company’s credit spreads. 
The estimated changes in the fair value of these non-
derivative liabilities due to such changes in the Company’s 
own credit spread (or instrument-specific credit risk) were a 
loss of $1,473 million and a gain of $1,415 million for the 
years ended December 31, 2019 and 2018, respectively. 
Changes in fair value resulting from changes in instrument-
specific credit risk were estimated by incorporating the 
Company’s current credit spreads observable in the bond 
market into the relevant valuation technique used to value 
each liability as described above.

The Fair Value Option for Financial Assets and Financial 
Liabilities

Selected Portfolios of Securities Purchased Under 
Agreements to Resell, Securities Borrowed, Securities Sold 
Under Agreements to Repurchase, Securities Loaned and 
Certain Non-Collateralized Short-Term Borrowings
The Company elected the fair value option for certain 
portfolios of fixed income securities purchased under 
agreements to resell and fixed income securities sold under 
agreements to repurchase, securities borrowed, securities 
loaned and certain uncollateralized short-term borrowings held 
primarily by broker-dealer entities in the United States, the 
United Kingdom and Japan. In each case, the election was 
made because the related interest rate risk is managed on a 
portfolio basis, primarily with offsetting derivative 
instruments that are accounted for at fair value through 
earnings. 

Changes in fair value for transactions in these portfolios 

are recorded in Principal transactions. The related interest 
revenue and interest expense are measured based on the 
contractual rates specified in the transactions and are reported 
as Interest revenue and Interest expense in the Consolidated 
Statement of Income.

Certain Loans and Other Credit Products
Citigroup has also elected the fair value option for certain 
other originated and purchased loans, including certain 
unfunded loan products, such as guarantees and letters of 
credit, executed by Citigroup’s lending and trading businesses. 
None of these credit products are highly leveraged financing 
commitments. Significant groups of transactions include loans 
and unfunded loan products that are expected to be either sold 
or securitized in the near term, or transactions where the 
economic risks are hedged with derivative instruments, such 
as purchased credit default swaps or total return swaps where 
the Company pays the total return on the underlying loans to a 
third party. Citigroup has elected the fair value option to 
mitigate accounting mismatches in cases where hedge 
accounting is complex and to achieve operational 
simplifications. Fair value was not elected for most lending 
transactions across the Company.

The following table provides information about certain credit products carried at fair value:

In millions of dollars

December 31, 2019

December 31, 2018

Trading assets

Loans

Trading assets

Loans

Carrying amount reported on the Consolidated Balance Sheet

$

8,320 $

4,086 $

10,108 $

3,224

Aggregate unpaid principal balance in excess of (less than) fair value

Balance of non-accrual loans or loans more than 90 days past due

Aggregate unpaid principal balance in excess of (less than) fair value for non-accrual 
loans or loans more than 90 days past due

410

—

—

315

1

—

435

—

—

741

1

—

In addition to the amounts reported above, $1,062 million 

and $1,137 million of unfunded commitments related to 
certain credit products selected for fair value accounting were 
outstanding as of December 31, 2019 and 2018, respectively.

265

 
Certain Investments in Private Equity and Real Estate 
Ventures 
Citigroup invests in private equity and real estate ventures for 
the purpose of earning investment returns and for capital 
appreciation. The Company has elected the fair value option 
for certain of these ventures, because such investments are 
considered similar to many private equity or hedge fund 
activities in Citi’s investment companies, which are reported at 
fair value. The fair value option brings consistency in the 
accounting and evaluation of these investments. All 
investments (debt and equity) in such private equity and real 
estate entities are accounted for at fair value. These 
investments are classified as Investments on Citigroup’s 
Consolidated Balance Sheet.

Changes in the fair values of these investments are 
classified in Other revenue in the Company’s Consolidated 
Statement of Income.

Certain Mortgage Loans Held-for-Sale (HFS)
Citigroup has elected the fair value option for certain 
purchased and originated prime fixed-rate and conforming 
adjustable-rate first mortgage loans HFS. These loans are 
intended for sale or securitization and are hedged with 
derivative instruments. The Company has elected the fair 
value option to mitigate accounting mismatches in cases 
where hedge accounting is complex and to achieve operational 
simplifications.

Changes in the fair value of funded and unfunded credit 

products are classified in Principal transactions in Citi’s 
Consolidated Statement of Income. Related interest revenue is 
measured based on the contractual interest rates and reported 
as Interest revenue on Trading account assets or loan interest 
depending on the balance sheet classifications of the credit 
products. The changes in fair value for the years ended 
December 31, 2019 and 2018 due to instrument-specific credit 
risk totaled to a gain of $95 million and a loss of $27 million, 
respectively.

Certain Investments in Unallocated Precious Metals
Citigroup invests in unallocated precious metals accounts 
(gold, silver, platinum and palladium) as part of its commodity 
and foreign currency trading activities or to economically 
hedge certain exposures from issuing structured liabilities. 
Under ASC 815, the investment is bifurcated into a debt host 
contract and a commodity forward derivative instrument. 
Citigroup elects the fair value option for the debt host contract, 
and reports the debt host contract within Trading account 
assets on the Company’s Consolidated Balance Sheet. The 
total carrying amount of debt host contracts across unallocated 
precious metals accounts was approximately $0.2 billion and 
$0.4 billion at December 31, 2019 and 2018, respectively. The 
amounts are expected to fluctuate based on trading activity in 
future periods.

As part of its commodity and foreign currency trading 
activities, Citi trades unallocated precious metals investments 
and executes forward purchase and forward sale derivative 
contracts with trading counterparties. When Citi sells an 
unallocated precious metals investment, Citi’s receivable from 
its depository bank is repaid and Citi derecognizes its 
investment in the unallocated precious metal. The forward 
purchase or sale contract with the trading counterparty 
indexed to unallocated precious metals is accounted for as a 
derivative, at fair value through earnings. As of December 31, 
2019, there were approximately $7.4 billion and $6.8 billion in 
notional amounts of such forward purchase and forward sale 
derivative contracts outstanding, respectively.

The following table provides information about certain mortgage loans HFS carried at fair value:

In millions of dollars

Carrying amount reported on the Consolidated Balance Sheet

Aggregate fair value in excess of (less than) unpaid principal balance

Balance of non-accrual loans or loans more than 90 days past due

Aggregate unpaid principal balance in excess of fair value for non-accrual loans or loans more than 90 days
past due

December 31,
2019

December 31,
2018

$

1,254 $

(31)

1

—

556

21

—

—

The changes in the fair values of these mortgage loans are 

reported in Other revenue in the Company’s Consolidated 
Statement of Income. There was no net change in fair value 
during the years ended December 31, 2019 and 2018 due to 
instrument-specific credit risk. Related interest income 
continues to be measured based on the contractual interest 
rates and reported as Interest revenue in the Consolidated 
Statement of Income.

266

Certain Structured Liabilities
The Company has elected the fair value option for certain 
structured liabilities whose performance is linked to structured 
interest rates, inflation, currency, equity, referenced credit or 
commodity risks. The Company elected the fair value option 
because these exposures are considered to be trading-related 
positions and, therefore, are managed on a fair value basis. 
These positions will continue to be classified as debt, deposits 
or derivatives (Trading account liabilities) on the Company’s 
Consolidated Balance Sheet according to their legal form.

The following table provides information about the carrying value of structured notes, disaggregated by type of embedded derivative 
instrument:

In billions of dollars

Interest rate linked

Foreign exchange linked

Equity linked

Commodity linked

Credit linked

Total

December 31, 2019 December 31, 2018

$

$

22.9 $

0.9

21.7

1.8

2.4

49.7 $

17.3

0.5

14.8

1.2

1.9

35.7

The portion of the changes in fair value attributable to 
changes in Citigroup’s own credit spreads (DVA) is reflected 
as a component of AOCI while all other changes in fair value 
are reported in Principal transactions. Changes in the fair 
value of these structured liabilities include accrued interest, 
which is also included in the change in fair value reported in 
Principal transactions.

Certain Non-Structured Liabilities
The Company has elected the fair value option for certain non-
structured liabilities with fixed and floating interest rates. The 
Company has elected the fair value option where the interest 
rate risk of such liabilities may be economically hedged with 

derivative contracts or the proceeds are used to purchase 
financial assets that will also be accounted for at fair value 
through earnings. The elections have been made to mitigate 
accounting mismatches and to achieve operational 
simplifications. These positions are reported in Short-term 
borrowings and Long-term debt on the Company’s 
Consolidated Balance Sheet. The portion of the changes in fair 
value attributable to changes in Citigroup’s own credit spreads 
(DVA) is reflected as a component of AOCI while all other 
changes in fair value are reported in Principal transactions.

Interest expense on non-structured liabilities is measured 
based on the contractual interest rates and reported as Interest 
expense in the Consolidated Statement of Income.

The following table provides information about long-term debt carried at fair value:

In millions of dollars

Carrying amount reported on the Consolidated Balance Sheet

Aggregate unpaid principal balance in excess of (less than) fair value

December 31, 2019 December 31, 2018

$

55,783 $

(2,967)

38,229

3,814

The following table provides information about short-term borrowings carried at fair value:

In millions of dollars

Carrying amount reported on the Consolidated Balance Sheet

Aggregate unpaid principal balance in excess of (less than) fair value

December 31, 2019 December 31, 2018

$

4,946 $

1,411

4,483

861

267

26.   PLEDGED ASSETS, COLLATERAL, 
GUARANTEES AND COMMITMENTS

Pledged Assets
In connection with Citi’s financing and trading activities, 
Citi has pledged assets to collateralize its obligations under 
repurchase agreements, secured financing agreements, 
secured liabilities of consolidated VIEs and other 
borrowings. The approximate carrying values of the 
significant components of pledged assets recognized on 
Citi’s Consolidated Balance Sheet included the following:

In millions of dollars

Investment securities

Loans

Trading account assets

Total

December 31,
2019

December 31,
2018

$

$

152,352 $

236,033

132,332

520,717 $

148,756

227,840

120,292

496,888

Restricted Cash
Citigroup defines restricted cash (as cash subject to 
withdrawal restrictions) to include cash deposited with 
central banks that must be maintained to meet minimum 
regulatory requirements, and cash set aside for the benefit of 
customers or for other purposes such as compensating 
balance arrangements or debt retirement. Restricted cash 
includes minimum reserve requirements with the Federal 
Reserve Bank and certain other central banks and cash 
segregated to satisfy rules regarding the protection of 
customer assets as required by Citigroup broker-dealers’ 
primary regulators, including the United States Securities 
and Exchange Commission (SEC), the Commodities Futures 
Trading Commission and the United Kingdom’s Prudential 
Regulation Authority.

Restricted cash is included on the Consolidated Balance 

Sheet within the following balance sheet lines:

In millions of dollars

Cash and due from banks

Deposits with banks

Total

December 31,
2019

December 31,
2018

$

$

3,758 $

26,493

30,251 $

4,000

27,208

31,208

In addition, included in Cash and due from banks and 
Deposits with banks at December 31, 2019 and 2018 were 
$8.5 billion and $8.3 billion, respectively, of cash segregated 
under federal and other brokerage regulations or deposited 
with clearing organizations.

Collateral
At December 31, 2019 and 2018, the approximate fair value 
of collateral received by Citi that may be resold or 
repledged, excluding the impact of allowable netting, was 
$569.8 billion and $526.0 billion, respectively. This 
collateral was received in connection with resale agreements, 
securities borrowings and loans, securities for securities 
lending transactions, derivative transactions and margined 
broker loans.

At December 31, 2019 and 2018, a substantial portion 
of the collateral received by Citi had been sold or repledged 
in connection with repurchase agreements, securities sold, 
not yet purchased, securities borrowings and loans, pledges 
to clearing organizations, segregation requirements under 
securities laws and regulations, derivative transactions and 
bank loans.

In addition, at December 31, 2019 and 2018, Citi had 
pledged $389.8 billion and $373.7 billion, respectively, of 
collateral that may not be sold or repledged by the secured 
parties.

Leases
The Company’s operating leases, where Citi is a lessee, 
include real estate, such as office space and branches, and 
various types of equipment. These leases have a weighted-
average remaining lease term of approximately six years as 
of December 31, 2019. The operating lease ROU asset and 
lease liability were $3.1 billion and $3.3 billion, respectively, 
as of December 31, 2019. The Company recognizes fixed 
lease costs on a straight-line basis throughout the lease term 
in the Consolidated Statement of Income. In addition, 
variable lease costs are recognized in the period in which the 
obligation for those payments is incurred. The total operating 
lease expense (principally for offices, branches and 
equipment), net of $56 million of sublease income, was 
$1,084 million for the year ended December 31, 2019. The 
decrease in the lease liability (and related operating lease 
financial information) from January 1, 2019 is primarily 
related to the purchase of a previously leased property in 
London during the second quarter of 2019. See Note 1 for 
additional lease liability details and balances at January 1, 
2019. The purchased property is included in Other assets on 
the Consolidated Balance Sheet at December 31, 2019.

While Citi has certain finance leases as a lessee, such 

leases are not material to the Company's Consolidated 
Financial Statements.

Citi’s lease arrangements that have not yet commenced 

as of December 31, 2019 and the Company’s short-term 
lease, variable lease and finance lease costs, for the year 
ended December 31, 2019, are not material to the 
Consolidated Financial Statements. 

268

Citi’s cash outflows related to operating leases were 
$942 million for the year ended December 31, 2019, while 
the future lease payments are as follows:

In millions of dollars

2020

2021

2022

2023

2024

Thereafter

Total future lease payments
Less imputed interest (based on weighted-average
discount rate of 3.6%)
Lease liability

$

$

$

$

801

695

572

425

314

935

3,742

(402)

3,340

The minimum annual rent commitments under non-

cancelable leases, net of sublease income, as of 
December 31, 2018 prior to the adoption of ASU 2016-02, 
were as follows:

In millions of dollars

2019

2020

2021

2022

2023

Thereafter

Total lease commitments

$

$

925

748

657

525

394

1,890

5,139

Operating lease expenses were $1.0 billion and $1.1 
billion for the years ended December 31, 2018 and 2017, 
respectively.

Guarantees
Citi provides a variety of guarantees and indemnifications to 
its customers to enhance their credit standing and enable 
them to complete a wide variety of business transactions. For
certain contracts meeting the definition of a guarantee, the 
guarantor must recognize, at inception, a liability for the fair 
value of the obligation undertaken in issuing the guarantee.
In addition, the guarantor must disclose the maximum 
potential amount of future payments that the guarantor could 
be required to make under the guarantee, if there were a total 
default by the guaranteed parties. The determination of the 
maximum potential future payments is based on the notional 
amount of the guarantees without consideration of possible 
recoveries under recourse provisions or from collateral held 
or pledged. As such, Citi believes such amounts bear no 
relationship to the anticipated losses, if any, on these 
guarantees.

269

The following tables present information about Citi’s guarantees:

In billions of dollars at December 31, 2019

Financial standby letters of credit

Performance guarantees

Derivative instruments considered to be guarantees

Loans sold with recourse
Securities lending indemnifications(1)
Credit card merchant processing(1)(2)
Credit card arrangements with partners

Custody indemnifications and other

Total

In billions of dollars at December 31, 2018

Financial standby letters of credit

Performance guarantees

Derivative instruments considered to be guarantees

Loans sold with recourse
Securities lending indemnifications(1)
Credit card merchant processing(1)(2)
Credit card arrangements with partners

Custody indemnifications and other

Total

Maximum potential amount of future
payments

Expire within
1 year

Expire after
1 year

Total amount
outstanding

Carrying value
(in millions of dollars)

$

31.9 $

62.4 $

94.3 $

6.9

37.5

—

87.8

91.6

0.2

—

5.5

60.1

1.2

—

—

0.4

33.7

12.4

97.6

1.2

87.8

91.6

0.6

33.7

$

255.9 $

163.3 $

419.2 $

140

21

289

7

—

—

23

41

521

Maximum potential amount of future payments

Expire within
1 year

Expire after
1 year

Total amount
outstanding

Carrying value
(in millions of dollars)

$

32.1 $

67.5 $

99.6 $

7.7

23.5

—

98.3

94.7

0.3

—

4.2

87.4

1.2

—

—

0.8

35.4

11.9

110.9

1.2

98.3

94.7

1.1

35.4

$

256.6 $

196.5 $

453.1 $

131

29

567

9

—

—

162

41

939

(1)  The carrying values of securities lending indemnifications and credit card merchant processing were not material for either period presented, as the probability 

of potential liabilities arising from these guarantees is minimal.

(2)  At December 31, 2019 and 2018, this maximum potential exposure was estimated to be $92 billion and $95 billion, respectively. However, Citi believes that 

the maximum exposure is not representative of the actual potential loss exposure based on its historical experience. This contingent liability is unlikely to 
arise, as most products and services are delivered when purchased and amounts are refunded when items are returned to merchants.

Financial Standby Letters of Credit
Citi issues standby letters of credit, which substitute its own 
credit for that of the borrower. If a letter of credit is drawn 
down, the borrower is obligated to repay Citi. Standby letters 
of credit protect a third party from defaults on contractual 
obligations. Financial standby letters of credit include 
(i) guarantees of payment of insurance premiums and 
reinsurance risks that support industrial revenue bond 
underwriting, (ii) settlement of payment obligations to 
clearing houses, including futures and over-the-counter 
derivatives clearing (see further discussion below), 
(iii) support options and purchases of securities in lieu of 
escrow deposit accounts and (iv) letters of credit that 
backstop loans, credit facilities, promissory notes and trade 
acceptances.

Performance Guarantees
Performance guarantees and letters of credit are issued to 
guarantee a customer’s tender bid on a construction or 
systems-installation project or to guarantee completion of 
such projects in accordance with contract terms. They are 
also issued to support a customer’s obligation to supply 
specified products, commodities or maintenance or warranty 
services to a third party.

Derivative Instruments Considered to Be Guarantees
Derivatives are financial instruments whose cash flows are 
based on a notional amount and an underlying instrument, 
reference credit or index, where there is little or no initial 
investment, and whose terms require or permit net 
settlement. For a discussion of Citi’s derivatives activities, 
see Note 22 to the Consolidated Financial Statements.

Derivative instruments considered to be guarantees 
include only those instruments that require Citi to make 
payments to the counterparty based on changes in an 
underlying instrument that is related to an asset, a liability or 
an equity security held by the guaranteed party. More 
specifically, derivative instruments considered to be 

270

 
 
 
 
Citi has the right to offset any payments with cash flows 
otherwise due to the merchant. To further mitigate this risk, 
Citi may delay settlement, require a merchant to make an 
escrow deposit, include event triggers to provide Citi with 
more financial and operational control in the event of the 
financial deterioration of the merchant or require various 
credit enhancements (including letters of credit and bank 
guarantees). In the unlikely event that a private label 
merchant is unable to deliver products, services or a refund 
to its private label cardholders, Citi is contingently liable to 
credit or refund cardholders.

With regard to (ii) above, Citi has a potential liability for 

bank card transactions where Citi provides the transaction 
processing services as well as those where a third party 
provides the services and Citi acts as a secondary guarantor, 
should that processor fail to perform.

Citi’s maximum potential contingent liability related to 

both bank card and private label merchant processing 
services is estimated to be the total volume of credit card 
transactions that meet the requirements to be valid charge-
back transactions at any given time. At December 31, 2019 
and 2018, this maximum potential exposure was estimated to 
be $91.6 billion and $94.7 billion, respectively.

However, Citi believes that the maximum exposure is 
not representative of the actual potential loss exposure based 
on its historical experience. This contingent liability is 
unlikely to arise, as most products and services are delivered 
when purchased and amounts are refunded when items are 
returned to merchants. Citi assesses the probability and 
amount of its contingent liability related to merchant 
processing based on the financial strength of the primary 
guarantor, the extent and nature of unresolved charge-backs 
and its historical loss experience. At December 31, 2019 and 
2018, the losses incurred and the carrying amounts of Citi’s 
contingent obligations related to merchant processing 
activities were immaterial.

Credit Card Arrangements with Partners
Citi, in certain of its credit card partner arrangements, 
provides guarantees to the partner regarding the volume of 
certain customer originations during the term of the 
agreement. To the extent that such origination targets are not 
met, the guarantees serve to compensate the partner for 
certain payments that otherwise would have been generated 
in connection with such originations.

Custody Indemnifications
Custody indemnifications are issued to guarantee that 
custody clients will be made whole in the event that a third-
party subcustodian or depository institution fails to safeguard 
clients’ assets.

guarantees include certain over-the-counter written put 
options where the counterparty is not a bank, hedge fund or 
broker-dealer (such counterparties are considered to be 
dealers in these markets and may, therefore, not hold the 
underlying instruments). Credit derivatives sold by Citi are 
excluded from the tables above as they are disclosed 
separately in Note 22 to the Consolidated Financial 
Statements. In instances where Citi’s maximum potential 
future payment is unlimited, the notional amount of the 
contract is disclosed.

Loans Sold with Recourse
Loans sold with recourse represent Citi’s obligations to 
reimburse the buyers for loan losses under certain 
circumstances. Recourse refers to the clause in a sales 
agreement under which a seller/lender will fully reimburse 
the buyer/investor for any losses resulting from the 
purchased loans. This may be accomplished by the seller 
taking back any loans that become delinquent.

In addition to the amounts shown in the tables above, 

Citi has recorded a repurchase reserve for its potential 
repurchases or make-whole liability regarding residential 
mortgage representation and warranty claims related to its 
whole loan sales to U.S. government-sponsored agencies 
and, to a lesser extent, private investors. The repurchase 
reserve was approximately $37 million and $49 million at 
December 31, 2019 and 2018, respectively, and these 
amounts are included in Other liabilities on the Consolidated 
Balance Sheet.

Securities Lending Indemnifications
Owners of securities frequently lend those securities for a fee 
to other parties who may sell them short or deliver them to 
another party to satisfy some other obligation. Banks may 
administer such securities lending programs for their clients. 
Securities lending indemnifications are issued by the bank to 
guarantee that a securities lending customer will be made 
whole in the event that the security borrower does not return 
the security subject to the lending agreement and collateral 
held is insufficient to cover the market value of the security.

Credit Card Merchant Processing
Credit card merchant processing guarantees represent the 
Company’s indirect obligations in connection with 
(i) providing transaction processing services to various 
merchants with respect to its private label cards and 
(ii) potential liability for bank card transaction processing 
services. The nature of the liability in either case arises as a 
result of a billing dispute between a merchant and a 
cardholder that is ultimately resolved in the cardholder’s 
favor. The merchant is liable to refund the amount to the 
cardholder. In general, if the credit card processing company 
is unable to collect this amount from the merchant, the credit 
card processing company bears the loss for the amount of the 
credit or refund paid to the cardholder.

With regard to (i) above, Citi has the primary contingent 

liability with respect to its portfolio of private label 
merchants. The risk of loss is mitigated as the cash flows 
between Citi and the merchant are settled on a net basis, and 

271

Other Guarantees and Indemnifications

Credit Card Protection Programs
Citi, through its credit card businesses, provides various
cardholder protection programs on several of its card
products, including programs that provide insurance
coverage for rental cars, coverage for certain losses
associated with purchased products, price protection for
certain purchases and protection for lost luggage. These
guarantees are not included in the table, since the total
outstanding amount of the guarantees and Citi’s maximum
exposure to loss cannot be quantified. The protection is
limited to certain types of purchases and losses, and it is not
possible to quantify the purchases that would qualify for
these benefits at any given time. Citi assesses the probability
and amount of its potential liability related to these programs
based on the extent and nature of its historical loss 
experience. At December 31, 2019 and 2018, the actual and 
estimated losses incurred and the carrying value of Citi’s 
obligations related to these programs were immaterial.

Other Representation and Warranty Indemnifications
In the normal course of business, Citi provides standard 
representations and warranties to counterparties in contracts 
in connection with numerous transactions and also provides 
indemnifications, including indemnifications that protect the 
counterparties to the contracts in the event that additional 
taxes are owed, due either to a change in the tax law or an 
adverse interpretation of the tax law. Counterparties to these 
transactions provide Citi with comparable indemnifications. 
While such representations, warranties and indemnifications 
are essential components of many contractual relationships, 
they do not represent the underlying business purpose for the 
transactions. The indemnification clauses are often standard 
contractual terms related to Citi’s own performance under 
the terms of a contract and are entered into in the normal 
course of business based on an assessment that the risk of 
loss is remote. Often these clauses are intended to ensure that 
terms of a contract are met at inception. No compensation is 
received for these standard representations and warranties, 
and it is not possible to determine their fair value because 
they rarely, if ever, result in a payment. In many cases, there 
are no stated or notional amounts included in the 
indemnification clauses, and the contingencies potentially 
triggering the obligation to indemnify have not occurred and 
are not expected to occur. As a result, these indemnifications 
are not included in the tables above.

Value-Transfer Networks (Including Exchanges and 
Clearing Houses) (VTNs)
Citi is a member of, or shareholder in, hundreds of value-
transfer networks (VTNs) (payment, clearing and settlement 
systems as well as exchanges) around the world. As a 
condition of membership, many of these VTNs require that 
members stand ready to pay a pro rata share of the losses 
incurred by the organization due to another member’s default 
on its obligations. Citi’s potential obligations may be limited 
to its membership interests in the VTNs, contributions to the 
VTN’s funds, or, in certain narrow cases, to the full pro rata 

share. The maximum exposure is difficult to estimate as this 
would require an assessment of claims that have not yet 
occurred; however, Citi believes the risk of loss is remote 
given historical experience with the VTNs. Accordingly, 
Citi’s participation in VTNs is not reported in the guarantees 
tables above, and there are no amounts reflected on the 
Consolidated Balance Sheet as of December 31, 2019 or 
2018 for potential obligations that could arise from Citi’s 
involvement with VTN associations.

Long-Term Care Insurance Indemnification
In 2000, Travelers Life & Annuity (Travelers), then a 
subsidiary of Citi, entered into a reinsurance agreement to 
transfer the risks and rewards of its long-term care (LTC) 
business to GE Life (now Genworth Financial Inc., or 
Genworth), then a subsidiary of the General Electric 
Company (GE). As part of this transaction, the reinsurance 
obligations were provided by two regulated insurance 
subsidiaries of GE Life, which funded two collateral trusts 
with securities. Presently, as discussed below, the trusts are 
referred to as the Genworth Trusts. 

As part of GE’s spin-off of Genworth in 2004, GE 
retained the risks and rewards associated with the 2000 
Travelers reinsurance agreement by providing a reinsurance 
contract to Genworth through GE’s Union Fidelity Life 
Insurance Company (UFLIC) subsidiary that covers the 
Travelers LTC policies. In addition, GE provided a capital 
maintenance agreement in favor of UFLIC that is designed 
to assure that UFLIC will have the funds to pay its 
reinsurance obligations. As a result of these reinsurance 
agreements and the spin-off of Genworth, Genworth has 
reinsurance protection from UFLIC (supported by GE) and 
has reinsurance obligations in connection with the Travelers 
LTC policies. As noted below, the Genworth reinsurance 
obligations now benefit Brighthouse Financial, Inc. 
(Brighthouse). While neither Brighthouse nor Citi are direct 
beneficiaries of the capital maintenance agreement between 
GE and UFLIC, Brighthouse and Citi benefit indirectly from 
the existence of the capital maintenance agreement, which 
helps assure that UFLIC will continue to have funds 
necessary to pay its reinsurance obligations to Genworth.

In connection with Citi’s 2005 sale of Travelers to 
MetLife Inc. (MetLife), Citi provided an indemnification to 
MetLife for losses (including policyholder claims) relating to 
the LTC business for the entire term of the Travelers LTC 
policies, which, as noted above, are reinsured by subsidiaries 
of Genworth. In 2017, MetLife spun off its retail insurance 
business to Brighthouse. As a result, the Travelers LTC 
policies now reside with Brighthouse. The original 
reinsurance agreement between Travelers (now Brighthouse) 
and Genworth remains in place and Brighthouse is the sole 
beneficiary of the Genworth Trusts. The fair value of the 
Genworth Trusts was approximately $8.6 billion as of 
December 31, 2019, compared to approximately $7.5 billion 
at December 31, 2018. The Genworth Trusts are designed to 
provide collateral to Brighthouse in an amount equal to the 
statutory liabilities of Brighthouse in respect of the Travelers 
LTC policies. The assets in the Genworth Trusts are 
evaluated and adjusted periodically by Genworth to ensure 

272

brokers, dealers and clearing organizations) or Cash and due 
from banks, respectively. 

However, for exchange-traded and OTC-cleared 
derivatives contracts where Citi does not obtain benefits 
from or control the client cash balances, the client cash 
initial margin collected from clients and remitted to the CCP 
or depository institutions is not reflected on Citi’s 
Consolidated Balance Sheet. These conditions are met when 
Citi has contractually agreed with the client that (i) Citi will 
pass through to the client all interest paid by the CCP or 
depository institutions on the cash initial margin, (ii) Citi 
will not utilize its right as a clearing member to transform 
cash margin into other assets, (iii) Citi does not guarantee 
and is not liable to the client for the performance of the CCP 
or the depository institution and (iv) the client cash balances 
are legally isolated from Citi’s bankruptcy estate. The total 
amount of cash initial margin collected and remitted in this 
manner was approximately $13.3 billion and $13.8 billion as 
of December 31, 2019 and 2018, respectively.

Variation margin due from clients to the respective CCP, 

or from the CCP to clients, reflects changes in the value of 
the client’s derivative contracts for each trading day. As a 
clearing member, Citi is exposed to the risk of non-
performance by clients (e.g., failure of a client to post 
variation margin to the CCP for negative changes in the 
value of the client’s derivative contracts). In the event of 
non-performance by a client, Citi would move to close out 
the client’s positions. The CCP would typically utilize initial 
margin posted by the client and held by the CCP, with any 
remaining shortfalls required to be paid by Citi as clearing 
member. Citi generally holds incremental cash or securities 
margin posted by the client, which would typically be 
expected to be sufficient to mitigate Citi’s credit risk in the 
event that the client fails to perform.

 As required by ASC 860-30-25-5, securities collateral 

posted by clients is not recognized on Citi’s Consolidated 
Balance Sheet.

that the fair value of the assets continues to provide 
collateral in an amount equal to these estimated statutory 
liabilities, as the liabilities change over time.

If both (i) Genworth fails to perform under the original 

Travelers/GE Life reinsurance agreement for any reason, 
including its insolvency or the failure of UFLIC to perform 
under its reinsurance contract or GE to perform under the 
capital maintenance agreement, and (ii) the assets of the two 
Genworth Trusts are insufficient or unavailable, then Citi, 
through its LTC reinsurance indemnification, must reimburse 
Brighthouse for any losses incurred in connection with the 
LTC policies. Since both events would have to occur before 
Citi would become responsible for any payment to 
Brighthouse pursuant to its indemnification obligation, and 
the likelihood of such events occurring is currently not 
probable, there is no liability reflected on the Consolidated 
Balance Sheet as of December 31, 2019 and 2018 related to 
this indemnification. However, if both events become 
reasonably possible (meaning more than remote but less than 
probable), Citi will be required to estimate and disclose a 
reasonably possible loss or range of loss to the extent that 
such an estimate could be made. In addition, if both events 
become probable, Citi will be required to accrue for such 
liability in accordance with applicable accounting principles. 

Citi continues to closely monitor its potential exposure 

under the Brighthouse indemnification obligation, given 
GE’s 2018 LTC and other charges and the September 2019 
AM Best credit ratings downgrade for the two Genworth 
insurance subsidiaries.

Separately, Genworth announced that it had agreed to be 
purchased by China Oceanwide Holdings Co., Ltd, subject to 
a series of conditions and regulatory approvals. Citi is 
monitoring these developments.

Futures and Over-the-Counter Derivatives Clearing
Citi provides clearing services on central clearing parties 
(CCPs) for clients that need to clear exchange-traded and 
over-the-counter (OTC) derivatives contracts with CCPs. 
Based on all relevant facts and circumstances, Citi has 
concluded that it acts as an agent for accounting purposes in 
its role as clearing member for these client transactions. As 
such, Citi does not reflect the underlying exchange-traded or 
OTC derivatives contracts in its Consolidated Financial 
Statements. See Note 22 for a discussion of Citi’s derivatives 
activities that are reflected in its Consolidated Financial 
Statements.

As a clearing member, Citi collects and remits cash and 

securities collateral (margin) between its clients and the 
respective CCP. In certain circumstances, Citi collects a 
higher amount of cash (or securities) from its clients than it 
needs to remit to the CCPs. This excess cash is then held at 
depository institutions such as banks or carry brokers.

There are two types of margin: initial and variation. 
Where Citi obtains benefits from or controls cash initial 
margin (e.g., retains an interest spread), cash initial margin 
collected from clients and remitted to the CCP or depository 
institutions is reflected within Brokerage payables (payables 
to customers) and Brokerage receivables (receivables from 

273

Carrying Value—Guarantees and Indemnifications
At December 31, 2019 and 2018, the total carrying amounts 
of the liabilities related to the guarantees and 
indemnifications included in the tables above amounted to 
approximately $0.5 billion and $0.9 billion, respectively. The 
carrying value of financial and performance guarantees is 
included in Other liabilities. For loans sold with recourse, 
the carrying value of the liability is included in Other 
liabilities.

Collateral
Cash collateral available to Citi to reimburse losses realized 
under these guarantees and indemnifications amounted to 
$46.7 billion and $38.0 billion at December 31, 2019 and 
2018, respectively. Securities and other marketable assets 
held as collateral amounted to $45.8 billion and $54.7 billion 
at December 31, 2019 and 2018, respectively. The majority 
of collateral is held to reimburse losses realized under 
securities lending indemnifications. In addition, letters of 
credit in favor of Citi held as collateral amounted to $4.4 
billion and $4.1 billion at December 31, 2019 and 2018, 
respectively. Other property may also be available to Citi to 
cover losses under certain guarantees and indemnifications; 
however, the value of such property has not been 
determined.

Performance Risk
Citi evaluates the performance risk of its guarantees based 
on the assigned referenced counterparty internal or external 
ratings. Where external ratings are used, investment-grade 
ratings are considered to be Baa/BBB and above, while 
anything below is considered non-investment grade. Citi’s 
internal ratings are in line with the related external rating 
system. On certain underlying referenced assets or entities, 
ratings are not available. Such referenced assets are included 
in the “not rated” category. The maximum potential amount 
of the future payments related to the outstanding guarantees 
is determined to be the notional amount of these contracts, 
which is the par amount of the assets guaranteed.

Presented in the tables below are the maximum potential 

amounts of future payments that are classified based upon 
internal and external credit ratings. The determination of the 
maximum potential future payments is based on the notional 
amount of the guarantees without consideration of possible 
recoveries under recourse provisions or from collateral held 
or pledged. As such, Citi believes such amounts bear no 
relationship to the anticipated losses, if any, on these 
guarantees.

In billions of dollars at December 31, 2019

Financial standby letters of credit

Performance guarantees

Derivative instruments deemed to be guarantees

Loans sold with recourse

Securities lending indemnifications

Credit card merchant processing

Credit card arrangements with partners

Custody indemnifications and other

Total

In billions of dollars at December 31, 2018

Financial standby letters of credit

Performance guarantees

Derivative instruments deemed to be guarantees

Loans sold with recourse

Securities lending indemnifications

Credit card merchant processing
Credit card arrangements with partners

Custody indemnifications and other

Total

Maximum potential amount of future payments

Investment
grade

Non-
investment
grade

Not
rated

Total

$

66.4 $

12.5 $

15.4 $

294.6 $

419.2

Maximum potential amount of future payments

Investment
grade

Non-
investment
grade

Not
rated

Total

71.3 $

11.9 $

16.4 $

9.7

—

—

—

—

—

2.3

—

—

—

—

—

21.3

97.4 $

12.4

27.2 $

9.2

—

—

—

—

—

2.1

—

—

—

—

—

22.2

102.7 $

13.2

27.2 $

0.4

97.6

1.2

87.8

91.6

0.6

—

0.6

110.9

1.2

98.3

94.7

1.1

—

94.3

12.4

97.6

1.2

87.8

91.6

0.6

33.7

99.6

11.9

110.9

1.2

98.3

94.7

1.1

35.4

323.2 $

453.1

$

$

$

274

 
 
Credit Commitments and Lines of Credit
The table below summarizes Citigroup’s credit commitments:

In millions of dollars
Commercial and similar letters of credit
One- to four-family residential mortgages

Revolving open-end loans secured by one- to four-family residential
properties
Commercial real estate, construction and land development
Credit card lines
Commercial and other consumer loan commitments
Other commitments and contingencies
Total

The majority of unused commitments are contingent 

upon customers maintaining specific credit standards. 
Commercial commitments generally have floating interest 
rates and fixed expiration dates and may require payment of 
fees. Such fees (net of certain direct costs) are deferred and, 
upon exercise of the commitment, amortized over the life of 
the loan or, if exercise is deemed remote, amortized over the 
commitment period. 

Commercial and Similar Letters of Credit
A commercial letter of credit is an instrument by which 
Citigroup substitutes its credit for that of a customer to 
enable the customer to finance the purchase of goods or to 
incur other commitments. Citigroup issues a letter on behalf 
of its client to a supplier and agrees to pay the supplier upon 
presentation of documentary evidence that the supplier has 
performed in accordance with the terms of the letter of 
credit. When a letter of credit is drawn, the customer is then 
required to reimburse Citigroup. 

One- to Four-Family Residential Mortgages
A one- to four-family residential mortgage commitment is a 
written confirmation from Citigroup to a seller of a property 
that the bank will advance the specified sums enabling the 
buyer to complete the purchase. 

Revolving Open-End Loans Secured by One- to Four-
Family Residential Properties
Revolving open-end loans secured by one- to four-family 
residential properties are essentially home equity lines of 
credit. A home equity line of credit is a loan secured by a 
primary residence or second home to the extent of the excess 
of fair market value over the debt outstanding for the first 
mortgage. 

Commercial Real Estate, Construction and Land 
Development
Commercial real estate, construction and land development 
include unused portions of commitments to extend credit for 
the purpose of financing commercial and multifamily 
residential properties as well as land development projects. 

 Both secured-by-real-estate and unsecured 
commitments are included in this line, as well as 

U.S.

Outside of 
U.S.

December 31,
2019

December 31,
2018

746 $

2,088

3,787 $
1,633

4,533 $
3,721

5,461
2,671

9,511
10,623
609,866
212,569
1,852
847,255 $

1,288
2,358
98,157
111,790
96

219,109 $

10,799
12,981
708,023
324,359
1,948
1,066,364 $

11,374
11,293
696,007
300,115
3,321
1,030,242

$

$

undistributed loan proceeds, where there is an obligation to 
advance for construction progress payments. However, this 
line only includes those extensions of credit that, once 
funded, will be classified as Total loans, net on the 
Consolidated Balance Sheet. 

Credit Card Lines
Citigroup provides credit to customers by issuing credit 
cards. The credit card lines are cancelable by providing 
notice to the cardholder or without such notice as permitted 
by local law. 

Commercial and Other Consumer Loan Commitments
Commercial and other consumer loan commitments include 
overdraft and liquidity facilities as well as commercial 
commitments to make or purchase loans, purchase third-
party receivables, provide note issuance or revolving 
underwriting facilities and invest in the form of equity. 

Other Commitments and Contingencies
Other commitments and contingencies include all other 
transactions related to commitments and contingencies not 
reported on the lines above.

Unsettled Reverse Repurchase and Securities Borrowing 
Agreements and Unsettled Repurchase and Securities 
Lending Agreements
In addition, in the normal course of business, Citigroup 
enters into reverse repurchase and securities borrowing 
agreements, as well as repurchase and securities lending 
agreements, which settle at a future date. At December 31, 
2019 and 2018, Citigroup had approximately $34.0 billion 
and $36.1 billion in unsettled reverse repurchase and 
securities borrowing agreements, respectively, and $38.7 
billion and $30.7 billion in unsettled repurchase and 
securities lending agreements, respectively. For a further 
discussion of securities purchased under agreements to resell 
and securities borrowed, and securities sold under 
agreements to repurchase and securities loaned, including 
the Company’s policy for offsetting repurchase and reverse 
repurchase agreements, see Note 11 to the Consolidated 
Financial Statements.

275

27.   CONTINGENCIES

Accounting and Disclosure Framework
ASC 450 governs the disclosure and recognition of loss 
contingencies, including potential losses from litigation, 
regulatory, tax and other matters. ASC 450 defines a “loss 
contingency” as “an existing condition, situation, or set of 
circumstances involving uncertainty as to possible loss to an 
entity that will ultimately be resolved when one or more 
future events occur or fail to occur.” It imposes different 
requirements for the recognition and disclosure of loss 
contingencies based on the likelihood of occurrence of the 
contingent future event or events. It distinguishes among 
degrees of likelihood using the following three terms: 
“probable,” meaning that “the future event or events are 
likely to occur”; “remote,” meaning that “the chance of the 
future event or events occurring is slight”; and “reasonably 
possible,” meaning that “the chance of the future event or 
events occurring is more than remote but less than likely.” 
These three terms are used below as defined in ASC 450.
Accruals. ASC 450 requires accrual for a loss 
contingency when it is “probable that one or more future 
events will occur confirming the fact of loss” and “the amount 
of the loss can be reasonably estimated.” In accordance with 
ASC 450, Citigroup establishes accruals for contingencies, 
including the litigation, regulatory and tax matters disclosed 
herein, when Citigroup believes it is probable that a loss has 
been incurred and the amount of the loss can be reasonably 
estimated. When the reasonable estimate of the loss is within a 
range of amounts, the minimum amount of the range is 
accrued, unless some higher amount within the range is a 
better estimate than any other amount within the range. Once 
established, accruals are adjusted from time to time, as 
appropriate, in light of additional information. The amount of 
loss ultimately incurred in relation to those matters may be 
substantially higher or lower than the amounts accrued for 
those matters.

Disclosure. ASC 450 requires disclosure of a loss 

contingency if “there is at least a reasonable possibility that a 
loss or an additional loss may have been incurred” and there is 
no accrual for the loss because the conditions described above 
are not met or an exposure to loss exists in excess of the 
amount accrued. In accordance with ASC 450, if Citigroup has 
not accrued for a matter because Citigroup believes that a loss 
is reasonably possible but not probable, or that a loss is 
probable but not reasonably estimable, and the reasonably 
possible loss is material, it discloses the loss contingency. In 
addition, Citigroup discloses matters for which it has accrued 
if it believes a reasonably possible exposure to material loss 
exists in excess of the amount accrued. In accordance with 
ASC 450, Citigroup’s disclosure includes an estimate of the 
reasonably possible loss or range of loss for those matters as to 
which an estimate can be made. ASC 450 does not require 
disclosure of an estimate of the reasonably possible loss or 
range of loss where an estimate cannot be made. Neither 
accrual nor disclosure is required for losses that are deemed 
remote.

Litigation, Regulatory and Other Contingencies
Overview. In addition to the matters described below, in the 
ordinary course of business, Citigroup, its affiliates and 
subsidiaries, and current and former officers, directors and 
employees (for purposes of this section, sometimes 
collectively referred to as Citigroup and Related Parties) 
routinely are named as defendants in, or as parties to, various 
legal actions and proceedings. Certain of these actions and 
proceedings assert claims or seek relief in connection with 
alleged violations of consumer protection, fair lending, 
securities, banking, antifraud, antitrust, anti-money 
laundering, employment and other statutory and common 
laws. Certain of these actual or threatened legal actions and 
proceedings include claims for substantial or indeterminate 
compensatory or punitive damages, or for injunctive relief, 
and in some instances seek recovery on a class-wide basis.

In the ordinary course of business, Citigroup and Related 

Parties also are subject to governmental and regulatory 
examinations, information-gathering requests, investigations 
and proceedings (both formal and informal), certain of which 
may result in adverse judgments, settlements, fines, penalties, 
restitution, disgorgement, injunctions or other relief. In 
addition, certain affiliates and subsidiaries of Citigroup are 
banks, registered broker-dealers, futures commission 
merchants, investment advisors or other regulated entities and, 
in those capacities, are subject to regulation by various U.S., 
state and foreign securities, banking, commodity futures, 
consumer protection and other regulators. In connection with 
formal and informal inquiries by these regulators, Citigroup 
and such affiliates and subsidiaries receive numerous requests, 
subpoenas and orders seeking documents, testimony and other 
information in connection with various aspects of their 
regulated activities. From time to time Citigroup and Related 
Parties also receive grand jury subpoenas and other requests 
for information or assistance, formal or informal, from federal 
or state law enforcement agencies including, among others, 
various United States Attorneys’ Offices, the Asset Forfeiture 
and Money Laundering Section and other divisions of the 
Department of Justice, the Financial Crimes Enforcement 
Network of the United States Department of the Treasury, and 
the Federal Bureau of Investigation relating to Citigroup and 
its customers.

Because of the global scope of Citigroup’s operations, 
and its presence in countries around the world, Citigroup and 
Related Parties are subject to litigation and governmental and 
regulatory examinations, information-gathering requests, 
investigations and proceedings (both formal and informal) in 
multiple jurisdictions with legal, regulatory and tax regimes 
that may differ substantially, and present substantially 
different risks, from those Citigroup and Related Parties are 
subject to in the United States. In some instances, Citigroup 
and Related Parties may be involved in proceedings involving 
the same subject matter in multiple jurisdictions, which may 
result in overlapping, cumulative or inconsistent outcomes.
Citigroup seeks to resolve all litigation, regulatory, tax 
and other matters in the manner management believes is in 
the best interests of Citigroup and its shareholders, and 
contests liability, allegations of wrongdoing and, where 

276

applicable, the amount of damages or scope of any penalties 
or other relief sought as appropriate in each pending matter.

Inherent Uncertainty of the Matters Disclosed. Certain of 

the matters disclosed below involve claims for substantial or 
indeterminate damages. The claims asserted in these matters 
typically are broad, often spanning a multi-year period and 
sometimes a wide range of business activities, and the 
plaintiffs’ or claimants’ alleged damages frequently are not 
quantified or factually supported in the complaint or statement 
of claim. Other matters relate to regulatory investigations or 
proceedings, as to which there may be no objective basis for 
quantifying the range of potential fine, penalty or other 
remedy. As a result, Citigroup is often unable to estimate the 
loss in such matters, even if it believes that a loss is probable 
or reasonably possible, until developments in the case, 
proceeding or investigation have yielded additional 
information sufficient to support a quantitative assessment of 
the range of reasonably possible loss. Such developments may 
include, among other things, discovery from adverse parties or 
third parties, rulings by the court on key issues, analysis by 
retained experts and engagement in settlement negotiations. 
Depending on a range of factors, such as the complexity of the 
facts, the novelty of the legal theories, the pace of discovery, 
the court’s scheduling order, the timing of court decisions and 
the adverse party’s, regulator’s or other authority’s willingness 
to negotiate in good faith toward a resolution, it may be 
months or years after the filing of a case or commencement of 
a proceeding or an investigation before an estimate of the 
range of reasonably possible loss can be made.

Matters as to Which an Estimate Can Be Made. For some 

of the matters disclosed below, Citigroup is currently able to 
estimate a reasonably possible loss or range of loss in excess 
of amounts accrued (if any). For some of the matters included 
within this estimation, an accrual has been made because a 
loss is believed to be both probable and reasonably estimable, 
but an exposure to loss exists in excess of the amount accrued. 
In these cases, the estimate reflects the reasonably possible 
range of loss in excess of the accrued amount. For other 
matters included within this estimation, no accrual has been 
made because a loss, although estimable, is believed to be 
reasonably possible, but not probable; in these cases, the 
estimate reflects the reasonably possible loss or range of loss. 
As of December 31, 2019, Citigroup estimates that the 
reasonably possible unaccrued loss for these matters ranges up 
to approximately $1.3 billion in the aggregate.

These estimates are based on currently available 

information. As available information changes, the matters for 
which Citigroup is able to estimate will change, and the 
estimates themselves will change. In addition, while many 
estimates presented in financial statements and other financial 
disclosures involve significant judgment and may be subject 
to significant uncertainty, estimates of the range of reasonably 
possible loss arising from litigation and regulatory 
proceedings are subject to particular uncertainties. For 
example, at the time of making an estimate, (i) Citigroup may 
have only preliminary, incomplete, or inaccurate information 
about the facts underlying the claim, (ii) its assumptions about 
the future rulings of the court, other tribunal or authority on 
significant issues, or the behavior and incentives of adverse 

277

parties, regulators or other authorities, may prove to be wrong 
and (iii) the outcomes it is attempting to predict are often not 
amenable to the use of statistical or other quantitative 
analytical tools. In addition, from time to time an outcome 
may occur that Citigroup had not accounted for in its estimate 
because it had deemed such an outcome to be remote. For all 
of these reasons, the amount of loss in excess of accruals 
ultimately incurred for the matters as to which an estimate has 
been made could be substantially higher or lower than the 
range of loss included in the estimate.

Matters as to Which an Estimate Cannot Be Made. For 

other matters disclosed below, Citigroup is not currently able 
to estimate the reasonably possible loss or range of loss. Many 
of these matters remain in very preliminary stages (even in 
some cases where a substantial period of time has passed 
since the commencement of the matter), with few or no 
substantive legal decisions by the court, tribunal or other 
authority defining the scope of the claims, the class (if any) or 
the potentially available damages or other exposure, and fact 
discovery is still in progress or has not yet begun. In many of 
these matters, Citigroup has not yet answered the complaint or 
statement of claim or asserted its defenses, nor has it engaged 
in any negotiations with the adverse party (whether a 
regulator, taxing authority or a private party). For all these 
reasons, Citigroup cannot at this time estimate the reasonably 
possible loss or range of loss, if any, for these matters.

Opinion of Management as to Eventual Outcome. Subject 
to the foregoing, it is the opinion of Citigroup’s management, 
based on current knowledge and after taking into account its 
current legal or other accruals, that the eventual outcome of all 
matters described in this Note would not be likely to have a 
material adverse effect on the consolidated financial condition 
of Citigroup. Nonetheless, given the substantial or 
indeterminate amounts sought in certain of these matters, and 
the inherent unpredictability of such matters, an adverse 
outcome in certain of these matters could, from time to time, 
have a material adverse effect on Citigroup’s consolidated 
results of operations or cash flows in particular quarterly or 
annual periods.

ANZ Underwriting Matter
In June 2018, the Australian Commonwealth Director of 
Public Prosecutions (CDPP) filed charges against Citigroup 
Global Markets Australia Pty Limited (CGMA) for alleged 
criminal cartel offenses following a referral by the Australian 
Competition and Consumer Commission. CDPP alleges that 
the cartel conduct took place following an institutional share 
placement by Australia and New Zealand Banking Group 
Limited (ANZ) in August 2015, where CGMA acted as joint 
underwriter and lead manager with other banks. CDPP also 
charged other banks and individuals, including current and 
former Citi employees. Separately, the Australian Securities 
and Investments Commission is conducting an investigation, 
and CGMA is cooperating with the investigation. Charges 
relating to CGMA are captioned R v. CITIGROUP GLOBAL 
MARKETS AUSTRALIA PTY LIMITED. The matter is 
before the Downing Centre Local Court in Sydney, 
Australia. Additional information concerning this action is 

publicly available in court filings under the docket number 
2018/00175168.

Foreign Exchange Matters
Regulatory Actions: Government and regulatory agencies in 
the U.S. and in other jurisdictions are conducting 
investigations or making inquiries regarding Citigroup’s 
foreign exchange business. Citigroup is cooperating with these 
and related investigations and inquiries.

Antitrust and Other Litigation: In 2018, a number of 

institutional investors who opted out of the previously 
disclosed August 2018 final settlement filed an action against 
Citigroup, Citibank, CGMI and other defendants, captioned 
ALLIANZ GLOBAL INVESTORS, ET AL. v. BANK OF 
AMERICA CORP., ET AL., in the United States District Court 
for the Southern District of New York. Plaintiffs allege that 
defendants manipulated, and colluded to manipulate, the 
foreign exchange markets. Plaintiffs assert claims under the 
Sherman Act and unjust enrichment claims, and seek 
consequential and punitive damages and other forms of relief. 
In July 2019, defendants moved to dismiss plaintiffs’ second 
amended complaint. Additional information concerning this 
action is publicly available in court filings under the docket 
number 18 Civ. 10364 (S.D.N.Y.) (Schofield, J.).

In December 2018, a group of institutional investors 

issued a claim against Citibank, Citigroup and other 
defendants, captioned ALLIANZ GLOBAL INVESTORS 
GMBH AND OTHERS v. BARCLAYS BANK PLC AND 
OTHERS, in the High Court in London. Claimants allege that 
defendants manipulated, and colluded to manipulate, the 
foreign exchange market in violation of EU and U.K. 
competition laws. In July 2019, defendants responded to 
plaintiffs’ claims, and in September 2019, claimants filed their 
reply. Additional information concerning this action is 
publicly available in court filings under the docket number 
CL-2018-000840.

In 2015, a putative class of consumers and businesses in 

the United States who directly purchased supracompetitive 
foreign currency at benchmark exchange rates filed an action 
against Citigroup and other defendants, captioned NYPL v. 
JPMORGAN CHASE & CO., ET AL., in the United States 
District Court for the Northern District of California. 
Subsequently, plaintiffs filed a third amended class action 
complaint, naming Citigroup, Citibank and Citicorp as 
defendants. Plaintiffs allege that they suffered losses as a 
result of defendants’ alleged manipulation of, and collusion 
with respect to, the foreign exchange market. Plaintiffs assert 
claims under federal and California antitrust and consumer 
protection laws, and seek compensatory damages, treble 
damages and declaratory and injunctive relief. Additional 
information concerning this action is publicly available in 
court filings under the docket numbers 15 Civ. 2290 (N.D. 
Cal.) (Chhabria, J.) and 15 Civ. 9300 (S.D.N.Y.) (Schofield, 
J.).

In 2017, putative classes of indirect purchasers of certain 

foreign exchange instruments filed an action against 
Citigroup, Citibank, Citicorp, CGMI and other defendants, 
captioned CONTANT, ET AL. v. BANK OF AMERICA 
CORP., ET AL., in the United States District Court for the 

278

Southern District of New York. Plaintiffs allege that 
defendants engaged in a conspiracy to fix currency prices. 
Plaintiffs assert claims under the Sherman Act and various 
state antitrust laws, and seek compensatory damages and 
treble damages. In July 2019, the court granted preliminary 
approval of a settlement between plaintiffs and Citigroup, 
Citibank, Citicorp and CGMI. Additional information 
concerning this action is publicly available in court filings 
under the docket number 17 Civ. 3139 (S.D.N.Y.) (Schofield, 
J.). 

On May 27, 2019, a putative class action was filed against 

Citibank and other defendants, captioned J WISBEY & 
ASSOCIATES PTY LTD v. UBS AG & ORS, in the Federal 
Court of Australia. Plaintiffs allege that defendants 
manipulated the foreign exchange markets. Plaintiffs assert 
claims under antitrust laws, and seek compensatory damages 
and declaratory and injunctive relief. Additional information 
concerning this action is publicly available in court filings 
under the docket number VID567/2019.

On July 29, 2019, an application, captioned MICHAEL 
O’HIGGINS FX CLASS REPRESENTATIVE LIMITED v. 
BARCLAYS BANK PLC AND OTHERS, was made to the 
U.K.’s Competition Appeal Tribunal requesting permission to 
commence collective proceedings against Citibank, Citigroup 
and other defendants. The application seeks compensatory 
damages for losses alleged to have arisen from the actions at 
issue in the European Commission’s foreign exchange spot 
trading infringement decision (European Commission 
Decision of May 16, 2019 in Case AT.40135-FOREX (Three 
Way Banana Split) C(2019) 3631 final). Additional 
information concerning this action is publicly available in 
court filings under the docket number 1329/7/7/19.

On December 20, 2019, an application, captioned 

PHILLIP EVANS v. BARCLAYS BANK PLC AND 
OTHERS, was made to the U.K.’s Competition Appeal 
Tribunal requesting permission to commence collective 
proceedings against Citibank, Citigroup and other defendants. 
The application seeks compensatory damages similar to those 
in the Michael O’Higgins FX Class Representative Limited 
application. Additional information concerning this action is 
publicly available in court filings under the docket number 
1336/7/7/19.

In September 2019, two motions for certification of class 

actions filed against Citibank, Citigroup and Citicorp and 
other defendants were consolidated, under the caption 
GERTLER, ET AL. v. DEUTSCHE BANK AG, in the Tel 
Aviv Central District Court in Israel. Plaintiffs allege that 
defendants manipulated the foreign exchange markets. The 
amended motion for certification has not yet been served on 
Citigroup or Citicorp. Additional information concerning this 
action is publicly available in court filings under the docket 
number CA 29013-09-18.

Interbank Offered Rates-Related Litigation and Other 
Matters
Antitrust and Other Litigation: In 2016, a putative class action 
was filed against Citibank, Citigroup and other defendants, 
now captioned FUND LIQUIDATION HOLDINGS LLC, AS 
ASSIGNOR AND SUCCESSOR-IN-INTEREST TO 

FRONTPOINT ASIAN EVENT DRIVEN FUND L.P., ET 
AL. v. CITIBANK, N.A., ET AL., in the United States District 
Court for the Southern District of New York. Plaintiffs allege 
that defendants manipulated the Singapore Interbank Offered 
Rate and Singapore Swap Offer Rate. Plaintiffs assert claims 
under the Sherman Act, the Clayton Act, the RICO Act and 
state law. In May 2018, plaintiffs entered into a settlement 
with Citibank and Citigroup, under which Citibank and 
Citigroup agreed to pay approximately $10 million. In July 
2019, the court found that it lacked subject-matter jurisdiction 
over the non-settling defendants and dismissed the case. The 
court also found that it lacked jurisdiction to approve the 
settlement and denied plaintiffs’ motion for preliminary 
approval of the settlement. In August 2019, plaintiffs filed a 
notice of appeal with the United States Court of Appeals for 
the Second Circuit. Additional information concerning this 
action is publicly available in court filings under the docket 
numbers 16 Civ. 5263 (S.D.N.Y.) (Hellerstein, J.) and 19-2719 
(2d Cir.).

In 2016, Banque Delubac filed an action against 
Citigroup, Citigroup Global Markets Limited (CGML) and 
Citigroup Europe Plc, captioned SCS BANQUE DELUBAC 
& CIE v. CITIGROUP INC., ET AL., in the Commercial 
Court of Aubenas in France. Plaintiff alleges that defendants 
suppressed LIBOR submissions between 2005 and 2012 and 
that Banque Delubac’s EURIBOR-linked lending activity was 
negatively impacted as a result. Plaintiff asserts a claim under 
tort law, and seeks compensatory damages and consequential 
damages. In November 2018, the Commercial Court of 
Aubenas referred the case to the Commercial Court of 
Marseille. In March 2019, the Court of Appeal of Nîmes held 
that neither the Commercial Court of Aubenas nor any other 
court of France has territorial jurisdiction over Banque 
Delubac’s claims. In May 2019, plaintiff filed an appeal before 
the Cour de cassation of France challenging the Court of 
Appeal of Nîmes’s decision. Additional information 
concerning this action is publicly available in court filings 
under docket numbers RG no. 2018F02750 in the Commercial 
Court of Marseille and 19-16.931 in the Cour de cassation.
In May 2019, three putative class actions filed against 

Citigroup, Citibank, CGMI and other defendants were 
consolidated, under the caption IN RE ICE LIBOR 
ANTITRUST LITIGATION, in the United States District 
Court of the Southern District of New York. In July 2019, 
Plaintiffs filed a consolidated amended complaint. Plaintiffs 
allege that defendants suppressed ICE LIBOR. Plaintiffs assert 
claims under the Sherman Act, the Clayton Act and unjust 
enrichment, and seek compensatory damages, disgorgement 
and treble damages. In August 2019, defendants moved to 
dismiss the action. Additional information concerning this 
action is publicly available in court filings under the docket 
number 19 Civ. 439 (S.D.N.Y.) (Daniels, J.).

Interchange Fee Litigation
Beginning in 2005, several putative class actions were filed 
against Citigroup, Citibank and Citicorp, together with Visa, 
MasterCard and other banks and their affiliates, in various 
federal district courts and consolidated with other related 
individual cases in a multi-district litigation proceeding in the 

279

United States District Court for the Eastern District of New 
York. This proceeding is captioned IN RE PAYMENT CARD 
INTERCHANGE FEE AND MERCHANT DISCOUNT 
ANTITRUST LITIGATION.

The plaintiffs, merchants that accept Visa and 
MasterCard branded payment cards as well as various 
membership associations that claim to represent certain groups 
of merchants, allege, among other things, that defendants have 
engaged in conspiracies to set the price of interchange and 
merchant discount fees on credit and debit card transactions 
and to restrain trade unreasonably through various Visa and 
MasterCard rules governing merchant conduct, all in violation 
of Section 1 of the Sherman Act and certain California 
statutes. Plaintiffs further alleged violations of Section 2 of the 
Sherman Act. Supplemental complaints also were filed against 
defendants in the putative class actions alleging that Visa’s and 
MasterCard’s respective initial public offerings were 
anticompetitive and violated Section 7 of the Clayton Act, and 
that MasterCard’s initial public offering constituted a 
fraudulent conveyance.

In 2014, the district court entered a final judgment 
approving the terms of a class settlement providing for, among 
other things, cash payment to the class of $6.05 billion; a 
rebate to merchants participating in the damages class 
settlement of 10 bps on interchange collected for a period of 
eight months by the Visa and MasterCard networks; and 
changes to certain network rules. Various objectors appealed 
from the final class settlement approval order to the United 
States Court of Appeals for the Second Circuit.

In 2016, the Court of Appeals reversed the district court’s 

approval of the class settlement and remanded for further 
proceedings. The district court thereafter appointed separate 
interim counsel for a putative class seeking damages and a 
putative class seeking injunctive relief. Amended or new 
complaints on behalf of the putative classes and various 
individual merchants were subsequently filed, including a 
further amended complaint on behalf of a putative damages 
class and a new complaint on behalf of a putative injunctive 
class, both of which named Citigroup and Related Parties. In 
addition, numerous merchants have filed amended or new 
complaints against Visa, MasterCard, and in some instances 
one or more issuing banks. Three of these suits—7-ELEVEN, 
INC., ET AL. v. VISA INC., ET AL.; ROUNDY’S 
SUPERMARKETS, INC. v. VISA INC. ET AL.; and LUBY’S 
FUDDRUCKERS RESTAURANTS, LLC, v. VISA INC., ET 
AL—brought on behalf of numerous individual merchants, 
name Citigroup and affiliates as defendants.

On December 13, 2019, the district court granted the 

damages class plaintiffs’ motion for final approval of a new 
settlement with the defendants. The settlement involves the 
damages class only and does not settle the claims of the 
injunctive relief class or any actions brought on a non-class 
basis by individual merchants. The settlement provides for a 
cash payment to the damages class of $6.24 billion, though 
that amount has been reduced by $700 million based on the 
transaction volume of class members that opted-out from the 
settlement. Several merchants and merchant groups have 
appealed the final approval order. Additional information 
concerning these consolidated actions is publicly available in 

court filings under the docket number MDL 05-1720 
(E.D.N.Y.) (Brodie, J.).

Interest Rate and Credit Default Swap Matters
Regulatory Actions: The Commodity Futures Trading 
Commission (CFTC) is conducting an investigation into 
alleged anticompetitive conduct in the trading and clearing of 
interest rate swaps (IRS) by investment banks. Citigroup is 
cooperating with the investigation.

Antitrust and Other Litigation: Beginning in 2015, 
Citigroup, Citibank, CGMI, CGML, and numerous other 
parties were named as defendants in a number of industry-
wide putative class actions related to IRS trading. These 
actions have been consolidated in the United States District 
Court for the Southern District of New York under the caption 
IN RE INTEREST RATE SWAPS ANTITRUST 
LITIGATION. The complaints allege that defendants colluded 
to prevent the development of exchange-like trading for IRS 
and assert federal and state antitrust claims and claims for 
unjust enrichment. Also consolidated under the same caption 
are individual actions filed by swap execution facilities, 
asserting federal and state antitrust claims, as well as claims 
for unjust enrichment and tortious interference with business 
relations. Plaintiffs in all of these actions seek treble damages, 
fees, costs, and injunctive relief. Lead plaintiffs in the class 
action moved for class certification in February 2019, and 
subsequently filed a fourth amended complaint. Additional 
information concerning these actions is publicly available in 
court filings under the docket numbers 18-CV-5361 (S.D.N.Y.) 
(Oetken, J.) and 16-MD-2704 (S.D.N.Y.) (Oetken, J.).  
In 2017, Citigroup, Citibank, CGMI, CGML and 

numerous other parties were named as defendants in an action 
filed in the United States District Court for the Southern 
District of New York under the caption TERA GROUP, INC., 
ET AL. v. CITIGROUP, INC., ET AL. The complaint alleges 
that defendants colluded to prevent the development of 
exchange-like trading for credit default swaps and asserts 
federal and state antitrust claims and state law tort claims. In 
January 2020, plaintiffs filed an amended complaint. 
Additional information concerning this action is publicly 
available in court filings under the docket number 17-CV-4302 
(S.D.N.Y.) (Sullivan, J.).

Parmalat Litigation
In 2004, an Italian commissioner appointed to oversee the 
administration of various Parmalat companies filed a 
complaint against Citigroup and Related Parties alleging that 
the defendants facilitated a number of frauds by Parmalat 
insiders. In 2008, a jury rendered a verdict in Citigroup’s favor 
and awarded Citi $431 million. Citigroup has taken steps to 
enforce the judgment in Italian court. In April 2019, the Italian 
Supreme Court affirmed the decision in the full amount of 
$431 million. Additional information concerning this action is 
publicly available in court filings under the docket numbers 
27618/2014 and 10540/2019. 

In 2015, Parmalat filed a claim in an Italian civil court in 
Milan claiming damages of €1.8 billion  against Citigroup and 
Related Parties. The Milan court dismissed Parmalat’s claim 
on grounds that it was duplicative of Parmalat’s previously 

280

unsuccessful claims. In May 2019, the Milan Court of Appeal 
rejected Parmalat’s appeal against the decision of the Milan 
court. In June 2019, Parmalat filed a further appeal with the 
Italian Supreme Court. Additional information concerning this 
action is publicly available in court filings under the docket 
number 20598/2019. 

On January 29, 2020, Parmalat, its three directors and its 

sole shareholder, Sofil S.a.s., as co-plaintiffs, filed a claim 
before the Italian civil court in Milan seeking a declaratory 
judgment that they do not owe compensatory damages of €990 
million to Citibank.

Payment Protection Insurance
Regulators and courts in the U.K. have scrutinized the selling 
of payment protection insurance (PPI) by financial institutions 
for several years. Citibank continues to review customer 
claims relating to the sale of PPI in the U.K., to grant redress 
in accordance with the requirements of the Financial Conduct 
Authority and to defend claims filed in U.K. courts.   

Sovereign Securities Matters
Regulatory Actions: Government and regulatory agencies in 
the U.S. and in other jurisdictions are conducting 
investigations or making inquiries regarding Citigroup’s sales 
and trading activities in connection with sovereign and other 
government-related securities. Citigroup is cooperating with 
these investigations and inquiries.

Antitrust and Other Litigation: In 2015, putative class 

actions filed against CGMI and other defendants were 
consolidated, under the caption IN RE TREASURY 
SECURITIES AUCTION ANTITRUST LITIGATION, in the 
United States District Court for the Southern District of New 
York. In December 2017, a consolidated amended complaint 
was filed, alleging that defendants colluded to fix Treasury 
auction bids by sharing competitively sensitive information 
ahead of the auctions, and that defendants colluded to boycott 
and prevent the emergence of an anonymous, all-to-all 
electronic trading platform in the Treasuries secondary market. 
The complaint asserts claims under antitrust laws, and seeks 
damages, including treble damages where authorized by 
statute, and injunctive relief. In February 2018, defendants 
moved to dismiss the complaint. Additional information 
concerning this action is publicly available in court filings 
under the docket number 15-MD-2673 (S.D.N.Y.) (Gardephe, 
J.).

In 2016 and 2017, class actions by direct purchasers of 
supranational, sub-sovereign and agency (SSA) bonds filed 
against Citigroup, Citibank, CGMI, CGML and other 
defendants were consolidated, under the caption IN RE SSA 
BONDS ANTITRUST LITIGATION, in the United States 
District Court for the Southern District of New York. In 
November 2018, a second amended consolidated complaint 
was filed, alleging that defendants, as market makers and 
traders of SSA bonds, colluded to fix the price at which they 
bought and sold SSA bonds in the secondary market. The 
complaint asserts claims under the antitrust laws and unjust 
enrichment, and seeks damages, including treble damages 
where authorized by statute, and disgorgement. In September 
2019, the court granted defendants’ motion to dismiss certain 

defendants, including CGML. Additional information 
concerning this action is publicly available in court filings 
under the docket number 16 Civ. 3711 (S.D.N.Y.) (Ramos, J.).
On February 7, 2019, a putative class action, captioned 
STACHON v. BANK OF AMERICA N.A., ET AL., was filed 
against Citigroup, Citibank, CGMI, CGML and other 
defendants, captioned STACHON v. BANK OF AMERICA 
N.A., ET AL., in the United States District Court for the 
Southern District of New York. Plaintiffs assert claims under 
New York antitrust laws based on the same conduct alleged in 
IN RE SSA BONDS ANTITRUST LITIGATION and seek 
treble damages and injunctive relief. The action is currently 
stayed pending a decision on the remaining motion to dismiss 
in IN RE SSA BONDS ANTITRUST LITIGATION. 
Additional information concerning this action is publicly 
available in court filings under the docket number 19 Civ. 
01205 (S.D.N.Y.) (Swain, J.).

In 2017, a class action related to the SSA bond market 
was filed in the Ontario Court of Justice in Canada, against 
Citigroup, Citibank, CGMI, CGML, Citibank Canada, 
Citigroup Global Markets Canada, Inc. and other defendants, 
asserting plaintiff claims under breach of contract, breach of 
the competition act, breach of foreign law, unjust enrichment 
and civil conspiracy. Plaintiffs seek compensatory and 
punitive damages and declaratory relief. Additional 
information concerning this action is publicly available in 
court filings under the docket number CV-17-586082-00CP 
(Ont. S.C.J.).

In 2017, purchasers of SSA bonds filed a similar action 
against Citigroup, Citibank, CGMI, CGML, Citibank Canada, 
Citigroup Global Markets Canada, Inc. and other defendants, 
captioned JOSEPH MANCINELLI, ET AL. v. BANK OF 
AMERICA CORPORATION, ET AL., in the Federal Court in 
Canada. In October 2019, plaintiffs filed an amended claim. 
Plaintiffs allege that defendants manipulated, and colluded to 
manipulate, the SSA bonds market. Plaintiffs assert claims 
under breach of the competition law, breach of foreign law, 
civil conspiracy, unjust enrichment, waiver of tort and breach 
of contract. Additional information concerning this action is 
publicly available in court filings under the docket number 
T-1871-17 (Fed. Ct.).

On September 10, 2019, plaintiffs filed a third 

consolidated amended complaint against CGMI and other 
defendants, under the caption IN RE GSE BONDS 
ANTITRUST LITIGATION, in the United States District 
Court for the Southern District of New York. Plaintiffs allege 
that defendants conspired to manipulate the market for bonds 
issued by U.S. government-sponsored agencies. Plaintiffs 
assert a claim under the Sherman Act, and seek treble damages 
and injunctive relief. In December 2019, plaintiffs moved for 
preliminary approval of a settlement with CGMI and 11 other 
defendants. Additional information concerning this action is 
publicly available in court filings under the docket number 19 
Civ. 1704 (S.D.N.Y.) (Rakoff, J.).

manipulate the market for bonds issued by U.S. government-
sponsored agencies. Plaintiff asserts a claim against 
defendants for a violation of the Sherman Act, and seeks treble 
damages and injunctive relief. Additional information 
concerning this action is publicly available in court filings 
under the docket number 19 Civ. 638 (M.D. La.) (Dick, C.J.). 

On October 21, 2019, the City of Baton Rouge and related 
plaintiffs filed a substantially similar action against CGMI and 
other defendants, captioned CITY OF BATON ROUGE, ET 
AL. v. BANK OF AMERICA, N.A., ET AL., in the United 
States District Court for the Middle District of Louisiana. 
Plaintiffs allege that defendants conspired to manipulate the 
market for U.S. government-sponsored agencies bonds. 
Plaintiffs assert a claim under the Sherman Act, and seek 
treble damages and injunctive relief. Additional information 
concerning this action is publicly available in court filings 
under the docket number 19 Civ. 725 (M.D. La.) (Dick, C.J.).

In 2018, a putative class action was filed against 

Citigroup, CGMI, Citigroup Financial Products Inc., Citigroup 
Global Markets Holdings Inc., Citibanamex, Grupo Banamex 
and other banks, captioned IN RE MEXICAN 
GOVERNMENT BONDS ANTITRUST LITIGATION, in the 
United States District Court for the Southern District of New 
York. Plaintiffs allege that defendants colluded in the Mexican 
sovereign bond market. In September 2019, the court granted 
defendants’ motion to dismiss. Subsequently, plaintiffs filed an 
amended complaint against Citibanamex and other market 
makers in the Mexican sovereign bond market. Plaintiffs no 
longer assert any claims against Citigroup and any other Citi 
affiliates. The amended complaint alleges a conspiracy to fix 
prices in the Mexican sovereign bond market from January 1, 
2006 to April 19, 2017, and asserts antitrust and unjust 
enrichment claims, and seek treble damages, restitution and 
injunctive relief. Additional information concerning this 
consolidated action is publicly available in court filings under 
the docket number 18 Civ. 2830 (S.D.N.Y.) (Oetken, J.). 

Transaction Tax Matters
Citigroup and Citibank are engaged in litigation or 
examinations with tax authorities in India and Germany 
concerning the payment of transaction taxes and other non-
income tax matters.

Tribune Company Bankruptcy
Certain Citigroup affiliates (along with numerous other 
parties) have been named as defendants in adversary 
proceedings related to the Chapter 11 cases of Tribune 
Company (Tribune) filed in the United States Bankruptcy 
Court for the District of Delaware, asserting claims arising out 
of the approximately $11 billion leveraged buyout of Tribune 
in 2007. The actions were consolidated as IN RE TRIBUNE 
COMPANY FRAUDULENT CONVEYANCE LITIGATION 
and transferred to the United States District Court for the 
Southern District of New York. 

On September 23, 2019, the State of Louisiana filed an 

In the adversary proceeding captioned KIRSCHNER v. 

action against CGMI and other defendants, captioned STATE 
OF LOUISIANA v. BANK OF AMERICA, N.A., ET AL., in 
the United States District Court for the Middle District of 
Louisiana. Plaintiff alleges that defendants conspired to 

FITZSIMONS, ET AL., the litigation trustee, as successor 
plaintiff to the unsecured creditors committee, seeks to avoid 
and recover as actual fraudulent transfers the transfers of 
Tribune stock that occurred as a part of the leveraged buyout. 

281

Several Citigroup affiliates, along with numerous other 
parties, were named as shareholder defendants and were 
alleged to have tendered Tribune stock to Tribune as a part of 
the buyout. In 2017, the United States District Court for the 
Southern District of New York dismissed the actual fraudulent 
transfer claim against the shareholder defendants, including 
the Citigroup affiliates. In July 2019, the litigation trustee filed 
an appeal to the United States Court of Appeals for the Second 
Circuit. 

Several Citigroup affiliates, along with numerous other 
parties, are named as defendants in certain actions brought by 
Tribune noteholders, which seek to recover the transfers of 
Tribune stock that occurred as a part of the leveraged buyout, 
as state-law constructive fraudulent conveyances. The 
noteholders’ claims were previously dismissed and the 
dismissal was affirmed on appeal. In May 2018, the United 
States Court of Appeals for the Second Circuit withdrew its 
2016 transfer of jurisdiction to the district court to reconsider 
its decision in light of a recent United States Supreme Court 
decision. In December 2019, the Court of Appeals issued an 
amended decision again affirming the dismissal. In January 
2020, the noteholders filed a petition for rehearing. 

Citigroup Global Markets Inc. (CGMI) was named as a 

defendant in a separate action in connection with its role as 
advisor to Tribune. In January 2019, the court dismissed the 
action, which the litigation trustee has appealed to the United 
States Court of Appeals for the Second Circuit. 

Additional information concerning these actions is 
publicly available in court filings under the docket numbers 
08-13141 (Bankr. D. Del.) (Carey, J.), 11 MD 02296 
(S.D.N.Y.) (Cote, J.), 12 MC 2296 (S.D.N.Y.) (Cote, J.), 
13-3992 (2d Cir.), 19-0449 (2d Cir.), 19-3049 (2d Cir.) and 
16-317 (U.S.).

Variable Rate Demand Obligation Litigation
On May 31, 2019, plaintiffs in the consolidated actions CITY 
OF PHILADELPHIA v. BANK OF AMERICA CORP., ET 
AL. and MAYOR AND CITY COUNCIL OF BALTIMORE v. 
BANK OF AMERICA CORP., ET AL. filed a consolidated 
complaint naming as defendants Citigroup, Citibank, CGMI, 
CGML and numerous other industry participants. The 
consolidated complaint asserts violations of the Sherman Act, 
as well as claims for breach of contract, breach of fiduciary 
duty, and unjust enrichment, and seeks damages and injunctive 
relief based on allegations that defendants served as 
remarketing agents for municipal bonds called variable rate 
demand obligations (VRDOs) and colluded to set artificially 
high VRDO interest rates. In July 2019, defendants filed a 
motion to dismiss the consolidated complaint. Additional 
information concerning these actions is publicly available in 
court filings under the docket numbers 19-CV-1608 (S.D.N.Y.) 
(Furman, J.) and 19-CV-2667 (S.D.N.Y.) (Furman, J.).

Settlement Payments
Payments required in settlement agreements described above 
have been made or are covered by existing litigation accruals.

282

28.   CONDENSED CONSOLIDATING FINANCIAL 
STATEMENTS

Citigroup amended its Registration Statement on Form S-3 on 
file with the SEC (File No. 33-192302) to add its wholly 
owned subsidiary, Citigroup Global Markets Holdings Inc. 
(CGMHI), as a co-registrant. Any securities issued by CGMHI 
under the Form S-3 will be fully and unconditionally 
guaranteed by Citigroup. 

The following are the Condensed Consolidating 
Statements of Income and Comprehensive Income for the 
years ended December 31, 2019, 2018 and 2017, Condensed 
Consolidating Balance Sheet as of December 31, 2019 and 
2018 and Condensed Consolidating Statement of Cash Flows 
for the years ended December 31, 2019, 2018 and 2017 for 
Citigroup Inc., the parent holding company (Citigroup parent 
company), CGMHI, other Citigroup subsidiaries and 
eliminations and total consolidating adjustments. “Other 
Citigroup subsidiaries and eliminations” includes all other 
subsidiaries of Citigroup, intercompany eliminations and 
income (loss) from discontinued operations. “Consolidating 
adjustments” includes Citigroup parent company elimination 
of distributed and undistributed income of subsidiaries and 
investment in subsidiaries.

These Condensed Consolidating Financial Statements 
have been prepared and presented in accordance with SEC 
Regulation S-X Rule 3-10, “Financial Statements of 
Guarantors and Issuers of Guaranteed Securities Registered or 
Being Registered.” 

These Condensed Consolidating Financial Statements 
schedules are presented for purposes of additional analysis, 
but should be considered in relation to the Consolidated 
Financial Statements of Citigroup taken as a whole. 

283

Condensed Consolidating Statements of Income and Comprehensive Income

In millions of dollars
Revenues
Dividends from subsidiaries
Interest revenue
Interest revenue—intercompany
Interest expense
Interest expense—intercompany
Net interest revenue
Commissions and fees
Commissions and fees—intercompany
Principal transactions
Principal transactions—intercompany
Other income
Other income—intercompany
Total non-interest revenues
Total revenues, net of interest expense
Provisions for credit losses and for benefits and claims
Operating expenses
Compensation and benefits
Compensation and benefits—intercompany
Other operating
Other operating—intercompany
Total operating expenses
Equity in undistributed income of subsidiaries

Income (loss) from continuing operations before income
taxes
Provision (benefit) for income taxes
Income (loss) from continuing operations
Income (loss) from discontinued operations, net of taxes

Net income before attribution of noncontrolling interests
Noncontrolling interests

Net income (loss)
Comprehensive income
Add: Other comprehensive income (loss)
Total Citigroup comprehensive income (loss)

Add: Other comprehensive income attributable to
noncontrolling interests
Add: Net income attributable to noncontrolling interests
Total comprehensive income (loss)

$

$
$

$
$
$

$

$
$

$

$

$

$

$
$

$

$

Year ended December 31, 2019

Citigroup
parent
company

Other Citigroup
subsidiaries and
eliminations

CGMHI

Consolidating
adjustments

Citigroup
consolidated

— $

10,661
1,942
7,010
4,243
1,350 $
5,265 $
354
277
2,464
832
102
9,294 $
10,644 $
— $

4,680 $
—
2,326
2,410
9,416 $
— $

1,228 $
176
1,052 $
—

1,052 $
—

1,052 $

(651) $
401 $

— $
—
401 $

— $

65,849
(7,033)
17,204
(5,281)
46,893 $
6,481 $
(333)
11,152
(3,716)
4,702
(47)
18,239 $
65,132 $
8,383 $

16,721 $
(134)
18,259
(2,430)
32,416 $
— $

24,333 $
5,588
18,745 $

(4)

18,741 $
66

18,675 $

1,600 $
20,275 $

— $
66
20,341 $

(23,347) $
—
—
—
—
— $
— $
—
—
—
—
—
— $
(23,347) $
— $

— $
—
—
—
— $
3,620 $

(19,727) $
—
(19,727) $
—

(19,727) $
—

(19,727) $

(949) $
(20,676) $

— $
—
(20,676) $

—
76,510
—
29,163
—
47,347
11,746
—
8,892
—
6,301
—
26,939
74,286
8,383

21,433
—
20,569
—
42,002
—

23,901
4,430
19,471
(4)

19,467
66

19,401

852
20,253

—
66
20,319

23,347 $
—
5,091
4,949
1,038
(896) $
— $
(21)
(2,537)
1,252
767
(55)
(594) $
21,857 $
— $

32 $
134
(16)
20
170 $
(3,620) $

18,067 $
(1,334)
19,401 $
—

19,401 $
—

19,401 $

852 $
20,253 $

— $
—
20,253 $

284

Condensed Consolidating Statements of Income and Comprehensive Income

In millions of dollars
Revenues
Dividends from subsidiaries
Interest revenue
Interest revenue—intercompany
Interest expense
Interest expense—intercompany
Net interest revenue
Commissions and fees
Commissions and fees—intercompany
Principal transactions
Principal transactions—intercompany
Other income
Other income—intercompany
Total non-interest revenues
Total revenues, net of interest expense
Provisions for credit losses and for benefits and claims
Operating expenses
Compensation and benefits
Compensation and benefits—intercompany
Other operating
Other operating—intercompany
Total operating expenses
Equity in undistributed income of subsidiaries

Income (loss) from continuing operations before income
taxes
Provision (benefit) for income taxes
Income (loss) from continuing operations
Income (loss) from discontinued operations, net of taxes

Net income (loss) before attribution of noncontrolling
interests
Noncontrolling interests

Net income (loss)
Comprehensive income
Add: Other comprehensive income (loss)
Total Citigroup comprehensive income (loss)
Add: Other comprehensive income attributable to
noncontrolling interests

Add: Net income attributable to noncontrolling interests
Total comprehensive income (loss)

$

$
$

$
$
$

$

$
$

$

$

$

$

$
$

$

$

Year ended December 31, 2018

Citigroup
parent
company

Other Citigroup
subsidiaries and
eliminations

CGMHI

Consolidating
adjustments

Citigroup
consolidated

— $

8,732
1,659
5,430
3,539
1,422 $
5,146 $
237
1,599
1,328
710
143
9,163 $
10,585 $
(22) $

4,484 $
—
2,224
2,312
9,020 $
— $

1,587 $
1,123

464 $
—

464 $
—

464 $
$
257 $
721 $

— $
—
721 $

— $

62,029
(6,592)
14,053
(4,737)
46,121 $
6,711 $
(235)
8,616
(399)
3,447
(36)
18,104 $
64,225 $
7,590 $

16,666 $
(115)
18,655
(2,361)
32,845 $
— $

23,790 $
3,520
20,270 $

(8)

20,262 $
35

20,227 $
—
3,500 $
23,727 $

(43) $
35
23,719 $

(22,854) $
—
—
—
—
— $
— $
—
—
—
—
—
— $
(22,854) $
— $

— $
—
—
—
— $
2,163 $

(20,691) $
—
(20,691) $
—

(20,691) $
—

(20,691) $

(3,757) $
(24,448) $

— $
—
(24,448) $

—
70,828
—
24,266
—
46,562
11,857
—
8,905
—
5,530
—
26,292
72,854
7,568

21,154
—
20,687
—
41,841
—

23,445
5,357
18,088
(8)

18,080
35

18,045

(2,499)
15,546

(43)
35
15,538

22,854 $
67
4,933
4,783
1,198
(981) $
— $
(2)
(1,310)
(929)
1,373
(107)
(975) $
20,898 $
— $

4 $

115
(192)
49
(24) $
(2,163) $

18,759 $
714
18,045 $
—

18,045 $
—

18,045 $

(2,499) $
15,546 $

— $
—
15,546 $

285

Condensed Consolidating Statements of Income and Comprehensive Income

In millions of dollars
Revenues
Dividends from subsidiaries
Interest revenue
Interest revenue—intercompany
Interest expense
Interest expense—intercompany
Net interest revenue
Commissions and fees
Commissions and fees—intercompany
Principal transactions
Principal transactions—intercompany
Other income
Other income—intercompany
Total non-interest revenues
Total revenues, net of interest expense
Provisions for credit losses and for benefits and claims
Operating expenses
Compensation and benefits
Compensation and benefits—intercompany
Other operating
Other operating—intercompany
Total operating expenses
Equity in undistributed income of subsidiaries

Income (loss) from continuing operations before income
taxes
Provision (benefit) for income taxes
Income (loss) from continuing operations
Income (loss) from discontinued operations, net of taxes

Net income before attribution of noncontrolling interests
Noncontrolling interests

Net income (loss)
Comprehensive income
Add: Other comprehensive income (loss)
Total Citigroup comprehensive income (loss)
Add: Other comprehensive income attributable to
noncontrolling interests

Add: Net income attributable to noncontrolling interests
Total comprehensive income (loss)

$

$
$

$
$
$

$

$
$

$

$

$

$

$
$

$

$

Year ended December 31, 2017

Citigroup
parent
company

Other Citigroup
subsidiaries and
eliminations

CGMHI

Consolidating
adjustments

Citigroup
consolidated

— $

5,279
1,178
2,340
2,297
1,820 $
5,366 $
182
1,183
1,200
867
170
8,968 $
10,788 $
— $

4,403 $
—
2,184
2,231
8,818 $
— $

1,970 $
873
1,097 $
—

1,097 $
(1)

1,098 $
$
(117) $
981 $

— $
(1)
980 $

— $

56,299
(5,150)
9,412
(3,126)
44,863 $
7,341 $
(180)
6,103
(2,134)
7,450
(175)
18,405 $
63,268 $
7,451 $

16,885 $
(120)
19,185
(2,196)
33,754 $
— $

22,063 $
19,578
2,485 $
(111)

2,374 $
61

2,313 $
—
(4,160) $
(1,847) $

114 $
61
(1,672) $

(22,499) $
—
—
—
—
— $
— $
—
—
—
—
—
— $
(22,499) $
— $

— $
—
—
—
— $
19,088 $

(3,411) $
—
(3,411) $
—

(3,411) $
—

(3,411) $

4,277 $
866 $

— $
—
866 $

—
61,579
—
16,518
—
45,061
12,707
—
8,940
—
5,736
—
27,383
72,444
7,451

21,181
—
21,051
—
42,232
—

22,761
29,388
(6,627)
(111)

(6,738)
60

(6,798)

(2,791)
(9,589)

114
60
(9,415)

22,499 $

1
3,972
4,766
829
(1,622) $
— $
(2)
1,654
934
(2,581)
5
10 $
20,887 $
— $

(107) $
120
(318)
(35)
(340) $
(19,088) $

2,139 $
8,937
(6,798) $
—

(6,798) $
—

(6,798) $

(2,791) $
(9,589) $

— $
—
(9,589) $

286

Condensed Consolidating Balance Sheet

In millions of dollars
Assets
Cash and due from banks
Cash and due from banks—intercompany
Deposits with banks
Deposits with banks—intercompany
Securities borrowed and purchased under resale agreements

Securities borrowed and purchased under resale agreements—
intercompany
Trading account assets
Trading account assets—intercompany
Investments
Loans, net of unearned income
Loans, net of unearned income—intercompany
Allowance for loan losses
Total loans, net
Advances to subsidiaries
Investments in subsidiaries
Other assets(1)
Other assets—intercompany
Total assets
Liabilities and equity
Deposits
Deposits—intercompany
Securities loaned and sold under repurchase agreements
Securities loaned and sold under repurchase agreements—
intercompany
Trading account liabilities
Trading account liabilities—intercompany
Short-term borrowings
Short-term borrowings—intercompany
Long-term debt
Long-term debt—intercompany
Advances from subsidiaries
Other liabilities
Other liabilities—intercompany
Stockholders’ equity
Total liabilities and equity

December 31, 2019

Citigroup
parent
company

CGMHI

Other
Citigroup
subsidiaries
and
eliminations

Consolidating
adjustments

Citigroup
consolidated

$

$
$

$

$

$

— $
21
—
3,000
—

—
286
426
1
—
—
—
— $
144,587 $
202,116
12,377
2,799
365,613 $

586 $

5,095
4,050
6,710
195,537

21,446
152,115
5,858
541
2,497
—
—
2,497 $
— $
—
54,784
45,588
494,807 $

23,381 $
(5,116)
165,902
(9,710)
55,785

(21,446)
123,739
(6,284)
368,021
696,986
—
(12,783)
684,203 $
(144,587) $

—
107,353
(48,387)
1,292,854 $

— $
—
—
—
—

—
—
—
—
—
—
—
— $
— $

(202,116)
—
—

(202,116) $

23,967
—
169,952
—
251,322

—
276,140
—
368,563
699,483
—
(12,783)
686,700
—
—
174,514
—
1,951,158

— $
—
—

— $
—
145,473

1,070,590 $

—
20,866

— $
—
—

1,070,590
—
166,339

—
1
379
66
—
150,477
—
20,503
937
8
193,242
365,613 $

36,581
80,100
5,109
11,096
17,129
39,578
66,791
—
51,777
8,414
32,759
494,807 $

(36,581)
39,793
(5,488)
33,887
(17,129)
58,705
(66,791)
(20,503)
53,866
(8,422)
170,061
1,292,854 $

—
—
—
—
—
—
—
—
—
—
(202,116)
(202,116) $

—
119,894
—
45,049
—
248,760
—
—
106,580
—
193,946
1,951,158

(1)  Other assets for Citigroup parent company at December 31, 2019 included $35.1 billion of placements to Citibank and its branches, of which $24.9 billion had a 

remaining term of less than 30 days. 

287

Condensed Consolidating Balance Sheet

In millions of dollars
Assets
Cash and due from banks
Cash and due from banks—intercompany
Deposits with banks
Deposits with banks—intercompany
Securities borrowed and purchased under resale agreements

Securities borrowed and purchased under resale agreements—
intercompany
Trading account assets
Trading account assets—intercompany
Investments
Loans, net of unearned income
Loans, net of unearned income—intercompany
Allowance for loan losses
Total loans, net
Advances to subsidiaries
Investments in subsidiaries
Other assets(1)
Other assets—intercompany
Total assets
Liabilities and equity
Deposits
Deposits—intercompany
Securities loaned and sold under repurchase agreements
Securities loaned and sold under repurchase agreements—
intercompany
Trading account liabilities
Trading account liabilities—intercompany
Short-term borrowings
Short-term borrowings—intercompany
Long-term debt
Long-term debt—intercompany
Advances from subsidiaries
Other liabilities
Other liabilities—intercompany
Stockholders’ equity
Total liabilities and equity

December 31, 2018

Citigroup
parent
company

CGMHI

Other
Citigroup
subsidiaries
and
eliminations

Consolidating
adjustments

Citigroup
consolidated

$

$
$

$

$

$

1 $
19
—
3,000
—

—
302
627
7
—
—
—
— $
143,119 $
205,337
9,861
3,037
365,310 $

— $
—
—

—
1
410
207
—
143,767
—
21,471
3,011
223
196,220
365,310 $

689 $

3,545
4,915
6,528
212,720

20,074
146,233
1,728
224
1,292
—
—
1,292 $
— $
—
59,734
44,255
501,937 $

— $
—
155,830

21,109
95,571
1,398
3,656
11,343
25,986
73,884
—
66,732
13,763
32,665
501,937 $

22,955 $
(3,564)
159,545
(9,528)
57,964

(20,074)
109,582
(2,355)
358,376
682,904
—
(12,315)
670,589 $
(143,119) $

—
102,394
(47,292)
1,255,473 $

1,013,170 $

—
21,938

(21,109)
48,733
(1,808)
28,483
(11,343)
62,246
(73,884)
(21,471)
50,978
(13,986)
173,526
1,255,473 $

— $
—
—
—
—

—
—
—
—
—
—
—
— $
— $

(205,337)
—
—

(205,337) $

23,645
—
164,460
—
270,684

—
256,117
—
358,607
684,196
—
(12,315)
671,881
—
—
171,989
—
1,917,383

— $
—
—

1,013,170
—
177,768

—
—
—
—
—
—
—
—
—
—
(205,337)
(205,337) $

—
144,305
—
32,346
—
231,999
—
—
120,721
—
197,074
1,917,383

(1)  Other assets for Citigroup parent company at December 31, 2018 included $34.7 billion of placements to Citibank and its branches, of which $22.4 billion had a 

remaining term of less than 30 days. 

288

Condensed Consolidating Statement of Cash Flows

In millions of dollars

Net cash provided by (used in) operating activities of

continuing operations

Cash flows from investing activities of continuing operations
Purchases of investments
Proceeds from sales of investments
Proceeds from maturities of investments
Change in loans
Proceeds from sales and securitizations of loans
Change in securities borrowed and purchased under agreements
to resell
Changes in investments and advances—intercompany
Other investing activities

Net cash provided by (used in) investing activities of
continuing operations
Cash flows from financing activities of continuing operations
Dividends paid
Issuance of preferred stock
Redemption of preferred stock
Treasury stock acquired
Proceeds (repayments) from issuance of long-term debt, net

Proceeds (repayments) from issuance of long-term debt—
intercompany, net
Change in deposits
Change in securities loaned and sold under agreements to
repurchase
Change in short-term borrowings

Net change in short-term borrowings and other advances—
intercompany
Capital contributions from (to) parent
Other financing activities

Net cash provided by (used in) financing activities of
continuing operations
Effect of exchange rate changes on cash and due from banks
Change in cash and due from banks and deposits with banks

Cash and due from banks and deposits with banks at
beginning of period

Cash and due from banks and deposits with banks at end of
period

Cash and due from banks

Deposits with banks

Cash and due from banks and deposits with banks at end of
period

Supplemental disclosure of cash flow information for
continuing operations
Cash paid during the year for income taxes
Cash paid during the year for interest
Non-cash investing activities
Transfers to loans HFS from loans

$

$

$

$

$
$
$

$

$

$

$

$

Year ended December 31, 2019

Citigroup
parent
company

CGMHI

Other
Citigroup
subsidiaries
and
eliminations

Consolidating
adjustments

Citigroup
consolidated

25,011 $

(35,396) $

(2,452) $

— $

(12,837)

— $
5
—
—
—

— $
—
—
—
—

(274,491) $
137,168
119,051
(22,466)
2,878

—
(1,847)
—

15,811
(870)
(64)

3,551
2,717
(4,817)

— $
—
—
—
—

—
—
—

(274,491)
137,173
119,051
(22,466)
2,878

19,362
—
(4,881)

(1,842) $

14,877 $

(36,409) $

— $

(23,374)

(5,447) $
1,496
(1,980)
(17,571)
1,666

— $
—
—
—
10,389

— $
—
—
—
(3,950)

—
—

—
—

(968)
—
(364)

(7,177)
—

5,115
7,440

5,843
(74)
(253)

7,177
57,420

(16,544)
5,263

(4,875)
74
253

(23,168) $
— $
1 $

21,283 $
— $
764 $

44,818 $
(908) $
5,049 $

— $
—
—
—
—

—
—

—
—

—
—
—

— $
— $
— $

(5,447)
1,496
(1,980)
(17,571)
8,105

—
57,420

(11,429)
12,703

—
—
(364)

42,933
(908)
5,814

3,020

15,677

169,408

—

188,105

3,021 $

16,441 $

174,457 $

21 $

5,681 $

18,265 $

3,000

10,760

156,192

— $

— $

—

193,919

23,967

169,952

3,021 $

16,441 $

174,457 $

— $

193,919

(393) $
3,820

418 $

12,664

4,863 $
12,198

— $
—

4,888
28,682

— $

— $

5,500 $

— $

5,500

289

Condensed Consolidating Statement of Cash Flows

In millions of dollars

Net cash provided by (used in) operating activities of

continuing operations

Cash flows from investing activities of continuing operations
Purchases of investments
Proceeds from sales of investments
Proceeds from maturities of investments
Change in loans
Proceeds from sales and securitizations of loans
Proceeds from significant disposals
Change in securities borrowed and purchased under agreements to
resell
Changes in investments and advances—intercompany
Other investing activities

Net cash provided by (used in) investing activities of
continuing operations
Cash flows from financing activities of continuing operations
Dividends paid
Redemption of preferred stock
Treasury stock acquired
Proceeds from issuance of long-term debt, net

Proceeds (repayments) from issuance of long-term debt—
intercompany, net
Change in deposits
Change in securities loaned and sold under agreements to
repurchase
Change in short-term borrowings

Net change in short-term borrowings and other advances—
intercompany
Capital contributions from parent
Other financing activities

Net cash provided by (used in) financing activities of
continuing operations
Effect of exchange rate changes on cash and due from banks

Change in cash and due from banks and deposits with banks

Cash and due from banks and deposits with banks at
beginning of period

Cash and due from banks and deposits with banks at end of
period

Cash and due from banks

Deposits with banks

Cash and due from banks and deposits with banks at end of
period

Supplemental disclosure of cash flow information for
continuing operations

Cash paid (received) during the year for income taxes
Cash paid during the year for interest
Non-cash investing activities
Transfers to loans HFS from loans

$

$

$

$

$
$

$

$

$

$

$

$

Year ended December 31, 2018

Citigroup
parent
company

CGMHI

Other
Citigroup
subsidiaries
and
eliminations

Consolidating
adjustments

Citigroup
consolidated

21,314 $

13,287 $

2,351 $

— $

36,952

(7,955) $
7,634
—
—
—
—

—
(5,566)
556

(18) $
3
—
—
—
—

(144,514) $
53,854
83,604
(29,002)
4,549
314

(34,018)
(832)
(59)

(4,188)
6,398
(3,878)

— $
—
—
—
—
—

—
—
—

(152,487)
61,491
83,604
(29,002)
4,549
314

(38,206)
—
(3,381)

(5,331) $

(34,924) $

(32,863) $

— $

(73,118)

(5,020) $
(793)
(14,433)
(5,099)

— $
—
—
10,278

— $
—
—
(2,656)

—
—

—
32

1,819
—
(482)

10,708
—

23,454
88

(19,111)
(798)
—

(10,708)
53,348

(1,963)
(12,226)

17,292
798
—

(23,976) $
— $

(7,993) $

24,619 $
— $

2,982 $

43,885 $
(773) $

12,600 $

— $
—
—
—

—
—

—
—

—
—
—

— $
— $

— $

(5,020)
(793)
(14,433)
2,523

—
53,348

21,491
(12,106)

—
—
(482)

44,528
(773)

7,589

11,013

12,695

156,808

—

180,516

3,020 $

15,677 $

169,408 $

20 $

4,234 $

19,391 $

3,000

11,443

150,017

— $

— $

—

188,105

23,645

164,460

3,020 $

15,677 $

169,408 $

— $

188,105

(783) $
3,854

458 $

8,671

4,638 $
10,438

— $
—

4,313
22,963

— $

— $

4,200 $

— $

4,200

290

Condensed Consolidating Statements of Cash Flows

In millions of dollars

Net cash provided by (used in) operating activities of

continuing operations

Cash flows from investing activities of continuing operations
Purchases of investments
Proceeds from sales of investments
Proceeds from maturities of investments
Change in loans
Proceeds from sales and securitizations of loans

Proceeds from significant disposals
Change in securities borrowed and purchased under agreements to
resell
Changes in investments and advances—intercompany
Other investing activities

Net cash provided by (used in) investing activities of
continuing operations
Cash flows from financing activities of continuing operations
Dividends paid
Issuance of preferred stock
Treasury stock acquired
Proceeds (repayments) from issuance of long-term debt, net

Proceeds (repayments) from issuance of long-term debt—
intercompany, net
Change in deposits
Change in securities loaned and sold under agreements to
repurchase
Change in short-term borrowings

Net change in short-term borrowings and other advances—
intercompany
Capital contributions from parent
Other financing activities

Net cash provided by financing activities of continuing
operations
Effect of exchange rate changes on cash and due from banks

Change in cash and due from banks and deposits with banks

Cash and due from banks and deposits with banks at
beginning of period

Cash and due from banks and deposits with banks at end of
period

Cash and due from banks

Deposits with banks

Cash and due from banks and deposits with banks at end of
period

Supplemental disclosure of cash flow information for
continuing operations
Cash paid during the year for income taxes
Cash paid during the year for interest
Non-cash investing activities

Transfers to loans held-for-sale from loans

$

$

$

$

$
$

$

$

$

$

$

$

Year ended December 31, 2017

Citigroup
parent
company

CGMHI

Other
Citigroup
subsidiaries
and
eliminations

Consolidating
adjustments

Citigroup
consolidated

25,270 $

(33,365) $

(679) $

— $

(8,774)

— $
132
—
—
—

—

—
(899)
—

(14) $
18
—
—
—

—

9,731
9,755
(24)

(185,726) $
107,218
84,369
(58,062)
8,365

3,411

(5,396)
(8,856)
(2,773)

— $
—
—
—
—

—

—
—
—

(185,740)
107,368
84,369
(58,062)
8,365

3,411

4,335
—
(2,797)

(767) $

19,466 $

(57,450) $

— $

(38,751)

(3,797) $
—
(14,541)
6,544

— $
—
—
4,909

— $
—
—
15,521

—
—

—
49

(22,152)
—
(405)

(2,031)
—

5,748
2,212

(8,615)
(748)
—

2,031
30,416

8,708
11,490

30,767
748
—

(34,302) $
— $

1,475 $
— $

(9,799) $

(12,424) $

99,681 $
693 $

42,245 $

— $
—
—
—

—
—

—
—

—
—
—

— $
— $

— $

(3,797)
—
(14,541)
26,974

—
30,416

14,456
13,751

—
—
(405)

66,854
693

20,022

20,812

25,119

114,563

—

160,494

11,013 $

12,695 $

156,808 $

13 $

4,128 $

19,634 $

11,000

8,567

137,174

— $

— $

—

180,516

23,775

156,741

11,013 $

12,695 $

156,808 $

— $

180,516

(3,730) $
4,151

678 $

4,513

5,135 $
7,011

— $
—

2,083
15,675

— $

— $

5,900 $

— $

5,900

291

29.  SELECTED QUARTERLY FINANCIAL DATA (UNAUDITED)

In millions of dollars, except per share amounts

Fourth

Third

Second

First

Fourth

Third

Second

First

Revenues, net of interest expense

$ 18,378 $ 18,574 $ 18,758 $ 18,576 $ 17,124 $ 18,389 $ 18,469 $ 18,872

Operating expenses

10,454

10,464

10,500

10,584

Provisions for credit losses and for benefits and claims

2,222

2,088

2,093

1,980

9,893

1,925

10,311

10,712

1,974

1,812

10,925

1,857

2019

2018

Income from continuing operations before income
taxes
Income taxes(1)
Income from continuing operations

Income (loss) from discontinued operations, net of
taxes

Net income before attribution of noncontrolling
interests

Noncontrolling interests

Citigroup’s net income
Earnings per share(2)
Basic

$

5,702 $

6,022 $

6,165 $

6,012 $

5,306 $

6,104 $

5,945 $

703

1,079

1,373

1,275

1,001

1,471

1,444

$

4,999 $

4,943 $

4,792 $

4,737 $

4,305 $

4,633 $

4,501 $

6,090

1,441

4,649

(4)

(15)

17

(2)

(8)

(8)

15

(7)

$

4,995 $

4,928 $

4,809 $

4,735 $

4,297 $

4,625 $

4,516 $

4,642

16

15

10

25

(16)

3

26

22

$

4,979 $

4,913 $

4,799 $

4,710 $

4,313 $

4,622 $

4,490 $

4,620

Income from continuing operations

$

2.16 $

2.09 $

1.94 $

1.88 $

1.65 $

1.74 $

1.62 $

Net income

Diluted

2.16

2.09

1.95

1.88

1.65

1.73

1.63

Income from continuing operations

Net income

2.15

2.15

2.08

2.07

1.94

1.95

1.87

1.87

1.65

1.64

1.74

1.73

1.62

1.63

1.68

1.68

1.68

1.68

This Note to the Consolidated Financial Statements is unaudited due to the Company’s individual quarterly results not being subject to an audit.
(1)  The fourth quarter of 2019 includes discrete tax items of roughly $540 million including an approximate $430 million benefit of a reduction in Citi’s valuation 

allowance related to its DTAs. The third quarter of 2019 includes discrete tax items of roughly $230 million, including an approximate $180 million benefit of a 
reduction in Citi’s valuation allowance related to its DTAs.

(2)  Due to averaging of shares, quarterly earnings per share may not sum to the totals reported for the full year.

End of Consolidated Financial Statements and Notes to Consolidated Financial Statements

292

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
FINANCIAL DATA SUPPLEMENT

RATIOS 

Citigroup’s net income to average 

assets(1)

0.98% 0.94%

0.84%

2019

2018

2017

Return on average common 
stockholders’ equity(1)(2)

Return on average total 

stockholders’ equity(1)(3)

Total average equity to average 

assets(4)

Dividend payout ratio(1)(5)

10.3

9.9

9.9

23.9

9.4

9.1

10.3

23.1

7.0

7.0

12.1

18.0

(1)  2017 excludes the one-time impact of Tax Reform. See “Significant 

Accounting Policies and Estimates—Income Taxes” above.

(2)   Based on Citigroup’s net income less preferred stock dividends as a 

percentage of average common stockholders’ equity. 

(3)  Based on Citigroup’s net income as a percentage of average total 

Citigroup stockholders’ equity.

(4)  Based on average Citigroup stockholders’ equity as a percentage of 

average assets.

(5)  Dividends declared per common share as a percentage of net income per 

diluted share.

AVERAGE DEPOSIT LIABILITIES IN OFFICES OUTSIDE THE U.S.(1)

In millions of dollars at year end, except ratios
Banks
Other demand deposits
Other time and savings deposits(2)
Total

Average
interest rate

2019
Average
balance

Average
interest rate

2018
Average
balance

Average
interest rate

2017
Average
balance

1.71% $
1.05
1.05
1.11% $

52,235
300,101
217,944
570,280

1.35% $
0.61
1.31
0.94% $

44,426
287,665
209,410
541,501

0.49% $
0.52
1.23
0.78% $

36,063
293,389
191,363
520,815

Interest rates and amounts include the effects of risk management activities and also reflect the impact of the local interest rates prevailing in certain countries.

(1) 
(2)  Primarily consists of certificates of deposit and other time deposits in denominations of $100,000 or more. 

MATURITY PROFILE OF TIME DEPOSITS IN U.S. OFFICES

In millions of dollars at December 31, 2019

Under 3
months

Over 3 to 6
months

Over 6 to 12
months

Over 12
months

Over $100,000

Certificates of deposit

Other time deposits

Over $250,000

Certificates of deposit

Other time deposits

$

$

15,866 $

8,152 $

9,008 $

3,924

29

38

14,026 $

5,008 $

4,953 $

3,923

29

2

694

1,556

539

11

293

SUPERVISION, REGULATION AND OTHER

SUPERVISION AND REGULATION
Citi is subject to regulation under U.S. federal and state laws, 
as well as applicable laws in the other jurisdictions in which it 
does business.

General
Citigroup is a registered bank holding company and financial 
holding company and is regulated and supervised by the 
Federal Reserve Board. Citigroup’s nationally chartered 
subsidiary banks, including Citibank, are regulated and 
supervised by the Office of the Comptroller of the Currency 
(OCC). The Federal Deposit Insurance Corporation (FDIC) 
also has examination authority for banking subsidiaries whose 
deposits it insures. Overseas branches of Citibank are 
regulated and supervised by the Federal Reserve Board and 
OCC and overseas subsidiary banks by the Federal Reserve 
Board. These overseas branches and subsidiary banks are also 
regulated and supervised by regulatory authorities in the host 
countries. In addition, the Consumer Financial Protection 
Bureau (CFPB) regulates consumer financial products and 
services. Citi is also subject to laws and regulations 
concerning the collection, use, sharing and disposition of 
certain customer, employee and other personal and 
confidential information, including those imposed by the 
Gramm-Leach-Bliley Act, the Fair Credit Reporting Act and 
the EU General Data Protection Regulation. For more 
information on U.S. and foreign regulation affecting or 
potentially affecting Citi, see “Risk Factors” above.

Other Bank and Bank Holding Company Regulation
Citi, including its banking subsidiaries, is subject to regulatory 
limitations, including requirements for banks to maintain 
reserves against deposits, requirements as to liquidity, risk-
based capital and leverage (see “Capital Resources” above and 
Note 18 to the Consolidated Financial Statements), restrictions 
on the types and amounts of loans that may be made and the 
interest that may be charged, and limitations on investments 
that can be made and services that can be offered. The Federal 
Reserve Board may also expect Citi to commit resources to its 
subsidiary banks in certain circumstances. Citi is also subject 
to anti-money laundering and financial transparency laws, 
including standards for verifying client identification at 
account opening and obligations to monitor client transactions 
and report suspicious activities.

Securities and Commodities Regulation
Citi conducts securities underwriting, brokerage and dealing 
activities in the U.S. through Citigroup Global Markets Inc. 
(CGMI), its primary broker-dealer, and other broker-dealer 
subsidiaries, which are subject to regulations of the U.S. 
Securities and Exchange Commission (SEC), the Financial 
Industry Regulatory Authority and certain exchanges. Citi 
conducts similar securities activities outside the U.S., subject 
to local requirements, through various subsidiaries and 
affiliates, principally Citigroup Global Markets Limited in 
London (CGML), which is regulated principally by the U.K. 
Financial Conduct Authority (FCA), and Citigroup Global 

294

Markets Japan Inc. in Tokyo, which is regulated principally by 
the Financial Services Agency of Japan.

Citi also has subsidiaries that are members of futures 

exchanges. In the U.S., CGMI is a member of the principal 
U.S. futures exchanges, and Citi has subsidiaries that are 
registered as futures commission merchants and commodity 
pool operators with the Commodity Futures Trading 
Commission (CFTC). Citibank, CGMI, Citigroup Energy Inc., 
Citigroup Global Markets Europe AG and CGML are also 
registered as swap dealers with the CFTC. CGMI is also 
subject to SEC and CFTC rules that specify uniform minimum 
net capital requirements. Compliance with these rules could 
limit those operations of CGMI that require the intensive use 
of capital and also limits the ability of broker-dealers to 
transfer large amounts of capital to parent companies and 
other affiliates. See “Capital Resources” and Note 18 to the 
Consolidated Financial Statements for a further discussion of 
capital considerations of Citi’s non-banking subsidiaries.

Transactions with Affiliates
Transactions between Citi’s U.S. subsidiary depository 
institutions and their non-bank affiliates are regulated by the 
Federal Reserve Board, and are generally required to be on 
arm’s-length terms. See “Managing Global Risk—Liquidity 
Risk” above.

COMPETITION
The financial services industry is highly competitive. Citi’s 
competitors include a variety of financial services and 
advisory companies. Citi competes for clients and capital 
(including deposits and funding in the short- and long-term 
debt markets) with some of these competitors globally and 
with others on a regional or product basis. Citi’s competitive 
position depends on many factors, including, among others, 
the value of Citi’s brand name, reputation, the types of clients 
and geographies served; the quality, range, performance, 
innovation and pricing of products and services; the 
effectiveness of and access to distribution channels, 
technology advances, customer service and convenience; the 
effectiveness of transaction execution, interest rates and 
lending limits; and regulatory constraints. Citi’s ability to 
compete effectively also depends upon its ability to attract 
new employees and retain and motivate existing employees, 
while managing compensation and other costs. For additional 
information on competitive factors and uncertainties 
impacting Citi’s businesses, see “Risk Factors—Operational 
Risks” above.

CLIMATE CHANGE
Climate change presents immediate and long-term risks to Citi 
and to its clients and customers, with the risks potentially 
increasing over time. Climate risk can arise from physical 
risks (risks related to the physical effects of climate change) 
and transition risks (risks related to regulatory, legal, 
technological and market changes from a transition to a low-
carbon economy). 

Citi’s Environmental and Social Risk Management Policy 

incorporates climate risk assessment for credit underwriting 
purposes and reporting criteria for certain corporate obligors 

DISCLOSURE PURSUANT TO SECTION 219 OF THE 
IRAN THREAT REDUCTION AND SYRIA HUMAN 
RIGHTS ACT
Pursuant to Section 219 of the Iran Threat Reduction and Syria 
Human Rights Act of 2012 (Section 219), which added 
Section 13(r) to the Securities Exchange Act of 1934, as 
amended, Citi is required to disclose in its annual or quarterly 
reports, as applicable, whether it or any of its affiliates 
knowingly engaged in certain activities, transactions or 
dealings relating to Iran or with individuals or entities that are 
subject to sanctions under U.S. law. Disclosure is generally 
required even where the activities, transactions or dealings 
were conducted in compliance with applicable law. Citi, in its 
related quarterly reports on Form 10-Q, previously disclosed 
reportable activities pursuant to Section 219 for the first, 
second and third quarters of 2019.

Citi had no reportable activities pursuant to Section 219 

for the fourth quarter of 2019.

and transactions. Factors evaluated include consideration of 
climate risk to an obligor’s business and physical assets and, 
when relevant, consideration of cost-effective options to 
reduce greenhouse gas (GHG) emissions. Citi engages clients 
to support their low-carbon transition, including through Citi’s 
growing environmental finance offerings.

To manage the risks of climate change to Citi’s own 
operations and facilities, Citi assesses its exposure to climate 
hazards to inform business continuity and resilience planning. 
In addition, Citi has developed programs for its properties to 
achieve long-term energy efficiency objectives and reduce its 
GHG emissions to lessen its impact on climate change.  

Citi has adopted the Taskforce on Climate-related 
Financial Disclosures (TCFD) recommendations and 
published its first TCFD report, Finance for a Climate 
Resilient Future, in 2018. As detailed in that report, Citi 
participated in the United Nations Environment Finance 
Initiative Banking Sector TCFD Project in 2017–2018 and 
piloted climate scenario analyses on Citi’s North America oil 
and gas exploration and production and U.S. power portfolios, 
to understand their exposure to climate risk under select 
scenarios. Citi continues to participate in financial industry 
collaborations to develop and pilot new methodologies and 
approaches for measuring and assessing the potential financial 
risks of climate change. Citi is also closely monitoring 
regulatory developments on climate risk and sustainable 
finance, and actively engaging with regulators on these topics.
For information on Citi’s environmental and social 

policies and priorities, see Citi’s website at 
www.citigroup.com. Click on “About Us” and then 
“Corporate Governance” and “Citizenship Report” or 
“Environmental and Social Information.” For information on 
Citi’s citizenship and sustainability governance, see Citi’s 
2019 Annual Meeting Proxy Statement available at 
www.citigroup.com. Click on “Investors” and then “Annual 
Reports & Proxy Statements.”

295

 
UNREGISTERED SALES OF EQUITY SECURITIES, REPURCHASES OF EQUITY SECURITIES AND DIVIDENDS

Unregistered Sales of Equity Securities
None.

Equity Security Repurchases
The following table summarizes Citi’s common stock repurchases during the three months ended December 31, 2019:

In millions, except per share amounts

October 2019

Open market repurchases(1)
Employee transactions(2)

November 2019

Open market repurchases(1)
Employee transactions(2)

December 2019

Open market repurchases(1)
Employee transactions(2)

Total shares
purchased

Average
price paid
per share

Approximate dollar
value of shares that
may yet be purchased
under the plan or
programs

21.6 $

69.77 $

—

—

21.0

—

26.6

—

74.80

—

77.03

—

10,473

N/A

8,902

N/A

6,855

N/A

6,855

Total for 4Q19 and remaining program balance as of December 31, 2019

69.2 $

74.09 $

(1)  Represents repurchases under the $17.1 billion 2019 common stock repurchase program (2019 Repurchase Program) that was approved by Citigroup’s Board of 

Directors and announced on June 27, 2019. The 2019 Repurchase Program was part of the planned capital actions included by Citi as part of the 2019 
Comprehensive Capital Analysis and Review (CCAR). Shares repurchased under the 2019 Repurchase Program were added to treasury stock. The 2019 
Repurchase Program expires on June 30, 2020. 

(2)  Consisted of shares added to treasury stock related to (i) certain activity on employee stock option program exercises where the employee delivers existing shares 

to cover the option exercise, or (ii) under Citi’s employee restricted share rewards where shares are withheld to satisfy tax requirements.

N/A   Not applicable

Dividends
In addition to Board of Directors’ approval, Citi’s ability to 
pay common stock dividends substantially depends on 
regulatory approval, including an annual regulatory review of 
the results of the CCAR process required by the Federal 
Reserve Board and the supervisory stress tests required under 
the Dodd-Frank Act. For additional information regarding 
Citi’s capital planning and stress testing, see “Capital 
Resources—Current Regulatory Capital Standards—Stress 
Testing Component of Capital Planning” and “Risk Factors—
Strategic Risks” above. Any dividend on Citi’s outstanding 
common stock would also need to be made in compliance with 
Citi’s obligations on its outstanding preferred stock.

For information on the ability of Citigroup’s subsidiary 
depository institutions to pay dividends, see Note 18 to the 
Consolidated Financial Statements.

296

 
 
 
 
 
 
 
 
PERFORMANCE GRAPH

Comparison of Five-Year Cumulative Total Return
The following graph and table compare the cumulative total 
return on Citi’s common stock with the cumulative total return 
of the S&P 500 Index and the S&P Financials Index over the 
five-year period through December 31, 2019. The graph and 
table assume that $100 was invested on December 31, 2014 in 
Citi’s common stock, the S&P 500 Index and the S&P 
Financials Index, and that all dividends were reinvested.

Comparison of Five-Year Cumulative Total Return
For the years ended

DATE
31-Dec-2014
31-Dec-2015
31-Dec-2016
31-Dec-2017
31-Dec-2018
31-Dec-2019

Citigroup
100.0
95.9
111.2
141.2
101.0
159.4

S&P 500
Index
100.0
101.4
113.5
138.3
132.2
173.9

S&P
Financials
Index
100.0
98.5
120.9
147.7
128.5
169.8

Note: Citi’s common stock is listed on the NYSE under the 
ticker symbol “C” and held by 66,990 common stockholders 
of record as of January 31, 2020.

297

CORPORATE INFORMATION 

•  Mr. Mason joined Citi in 2001 and assumed his current 

EXECUTIVE OFFICERS
Citigroup’s executive officers as of February 21, 2020 are:

Name
Raja J. Akram

Age Position and office held
47 Controller and Chief Accounting

Peter Babej
Michael L. Corbat
Jane Fraser

Officer

56 CEO, Asia Pacific

59 Chief Executive Officer
52 President; CEO, Global Consumer

Banking

Bradford Hu

56 Chief Risk Officer

David Livingstone
Mark A. L. Mason
Mary McNiff
Ernesto Torres
Cantú

56 CEO, Europe, Middle East and Africa
50 Chief Financial Officer
49 CEO, Citibank, N.A.
55 CEO, Latin America

Sara Wechter
Rohan Weerasinghe

39 Head of Human Resources
69 General Counsel and Corporate

Secretary

Mike Whitaker

56 Head of Operations and Technology

Paco Ybarra

58 CEO, Institutional Clients Group

Each executive officer has held senior executive or 
management positions with Citigroup for at least five years, 
except that:

•  Mr. Akram joined Citi in 2006 and assumed his current 
position in November 2017. Previously, he served as 
Deputy Controller since April 2017. He held a number of 
other roles in Citi Finance, including Lead Finance 
Officer for Treasury and Trade Solutions, Brazil Country 
Controller, Brazil Country Finance Officer and Head of 
the Corporate Accounting Policy team supporting M&A 
activities; 

•  Mr. Babej joined Citi in 2010 and assumed his current 

position in October 2019. Previously, he served as ICG’s 
Global Head of the Financial Institutions Group (FIG) 
from January 2017 to October 2019 and Global Co-Head 
of FIG from 2010 to January 2017. Prior to joining Citi, 
Mr. Babej served as Co-Head, Financial Institutions— 
Americas at Deutsche Bank, among other roles;  
•  Ms. Fraser joined Citi in 2004 and assumed her current 

position in October 2019. Previously, she served as CEO 
of Citi Latin America from June 2015 to October 2019. 
She held a number of other roles across the organization, 
including CEO of U.S. Consumer and Commercial 
Banking and CitiMortgage, CEO of Citi’s Global Private 
Bank and Global Head of Strategy and M&A; 
•  Mr. Livingstone joined Citi in 2016 and assumed his 

current position in March 2019. Previously, he served as 
Citi Country Officer for Australia and New Zealand since 
June 2016. Prior to joining Citi, he had a nine-year career 
at Credit Suisse, where he was Vice Chairman of the 
Investment Banking and Capital Markets Division for the 
EMEA region, Head of M&A and CEO of Credit Suisse 
Australia; 

298

position in February 2019. Previously, he served as CFO 
of ICG since September 2014. He held a number of other 
senior operational, strategic and financial executive roles 
across the organization, including CEO of Citi Private 
Bank, CEO of Citi Holdings and CFO and Head of 
Strategy and M&A for Citi’s Global Wealth Management 
Division; 

•  Ms. McNiff joined Citi in 2012 and assumed her current 

position in April 2019. Previously, she served as Chief 
Auditor since February 2017. She held a number of other 
roles across the organization, including Chief Auditor of 
GCB, Chief Administrative Officer for Citi Latin America 
& Mexico and interim Chief Auditor, ICG. She also 
previously led the Global Transformation initiative within 
Internal Audit;

•  Mr. Torres Cantú joined Citi in 1989 and assumed his 

current position in October 2019. Previously, he served as 
CEO of Citibanamex since October 2014. He served as 
CEO of GCB in Mexico from 2006 to 2011 and CEO of 
Crédito Familiar from 2003 to 2006. In addition, he 
previously held roles in Citibanamex, including Regional 
Director and Divisional Director; 

•  Ms. Wechter joined Citi in 2004 and assumed her current 
position in July 2018. Previously, she served as Citi's 
Head of Talent and Diversity as well as Chief of Staff to 
Citi CEO Michael Corbat. She served as Chief of Staff to 
both Michael O'Neill and Richard Parsons during their 
terms as Chairman of Citi's Board of Directors. In 
addition, she held roles in Citi's ICG, including Corporate 
M&A and Strategy and Investment Banking; 

•  Mr. Whitaker joined Citi in 2009 and assumed his current 
position in November 2018. Previously, he served as 
Head of Operations & Technology for ICG since 
September 2014 and held various other roles at Citi, 
including Head of Securities & Banking Operations & 
Technology, Head of ICG Technology and Regional Chief 
Information Officer; and

•  Mr. Ybarra joined Citi in 1987 and assumed his current 

position in May 2019. Previously, he served as ICG’s 
Global Head of Markets and Securities Services since 
November 2013. In addition, he has held a number of 
other roles across ICG, including Deputy Head of ICG, 
Global Head of Markets and Co-Head of Global Fixed 
Income.

Code of Conduct, Code of Ethics
Citi has a Code of Conduct that maintains its commitment to 
the highest standards of conduct. The Code of Conduct is 
supplemented by a Code of Ethics for Financial Professionals 
(including accounting, controllers, financial reporting 
operations, financial planning and analysis, treasury, tax, 
strategy and M&A, investor relations and regional/product 
finance professionals and administrative staff) that applies 
worldwide. The Code of Ethics for Financial Professionals 
applies to Citi’s principal executive officer, principal financial 
officer and principal accounting officer. Amendments and 
waivers, if any, to the Code of Ethics for Financial 

Professionals will be disclosed on Citi’s website, 
www.citigroup.com.

Both the Code of Conduct and the Code of Ethics for 

Financial Professionals can be found on the Citi website by 
clicking on “About Us,” and then “Corporate Governance.” 
Citi’s Corporate Governance Guidelines can also be found 
there, as well as the charters for the Audit Committee, the 
Ethics and Culture Committee, the Nomination, Governance 
and Public Affairs Committee, the Operations and Technology 
Committee, the Personnel and Compensation Committee and 
the Risk Management Committee of the Board. These 
materials are also available by writing to Citigroup Inc., 
Corporate Governance, 388 Greenwich Street, 17th Floor, 
New York, New York 10013.

CITIGROUP BOARD OF DIRECTORS

Michael L. Corbat
Chief Executive Officer
Citigroup Inc.

Duncan P. Hennes
Co-Founder and Partner
Atrevida Partners, LLC

Ellen M. Costello
Former President and CEO 
BMO Financial Corporation and 
Former U.S. Country Head
BMO Financial Group

Grace E. Dailey
Former Senior Deputy Comptroller 
for Bank Supervision Policy and 
Chief National Bank Examiner
Office of the Comptroller of the 
Currency (OCC)

Barbara Desoer
Former Chief Executive Officer 
Citibank, N.A.

John C. Dugan
Chair
Citigroup Inc.

Peter Blair Henry
Dean Emeritus and W. R. 
Berkley Professor of Economics 
and Finance
New York University
Stern School of Business

Renée J. James
Chairman and CEO
Ampere Computing and 
Operating Executive
The Carlyle Group

Eugene (Gene) M. McQuade
Former Chief Executive Officer 
Citibank, N.A. and
Former Vice Chairman
Citigroup Inc.

S. Leslie Ireland
Former Assistant Secretary for 
Intelligence and Analysis
U.S. Department of the Treasury

Gary M. Reiner
Operating Partner
General Atlantic LLC

Lew W. (Jay) Jacobs, IV
Former President and Managing 
Director
Pacific Investment Management 
Company LLC (PIMCO)

Diana L. Taylor
Former Superintendent of Banks
State of New York

299

James S. Turley
Former Chairman and CEO
Ernst & Young

Deborah C. Wright
Former Chairman 
Carver Bancorp, Inc.

Alexander Wynaendts
Chief Executive Officer and 
Chairman of the Management 
and Executive Boards 
Aegon N.V.

Ernesto Zedillo Ponce de Leon
Director, Center for the
Study of Globalization and
Professor in the Field
of International
Economics and Politics
Yale University

Signatures
Pursuant to the requirements of Section 13 or 15(d) of the 
Securities Exchange Act of 1934, the registrant has duly 
caused this report to be signed on its behalf by the 
undersigned, thereunto duly authorized, on the 21st day of 
February, 2020.

Citigroup Inc.
(Registrant)

/s/ Mark A. L. Mason

Mark A. L. Mason
Chief Financial Officer

The Directors of Citigroup listed below executed a power of 
attorney appointing Mark A. L. Mason their attorney-in-fact, 
empowering him to sign this report on their behalf.

Ellen M. Costello
Grace E. Dailey
Barbara Desoer
John C. Dugan
Duncan P. Hennes
Peter Blair Henry
S. Leslie Ireland
Lew W. (Jay) Jacobs, IV Ernesto Zedillo Ponce de Leon

Renée J. James
Eugene M. McQuade
Gary M. Reiner
Diana L. Taylor
James S. Turley
Deborah C. Wright
Alexander Wynaendts

Pursuant to the requirements of the Securities Exchange Act of 
1934, this report has been signed below by the following 
persons on behalf of the registrant and in the capacities 
indicated on the 21st day of February, 2020.

/s/ Mark A. L. Mason

Mark A. L. Mason

Citigroup’s Principal Executive Officer and a Director:

/s/ Michael L. Corbat

Michael L. Corbat

Citigroup’s Principal Financial Officer:

/s/ Mark A. L. Mason

Mark A. L. Mason

Citigroup’s Principal Accounting Officer:

/s/ Raja J. Akram

Raja J. Akram

300

Exhibit
Number

EXHIBIT INDEX

Description of Exhibit

3.01+

Restated Certificate of Incorporation of Citigroup, as amended, as in effect on the date hereof.

3.02

4.01

4.02

4.03

4.04

4.05

4.06

4.07

4.08

4.09

4.10

By-Laws of Citigroup, as amended, as in effect on the date hereof, incorporated by reference to the Company’s 
Current Report on Form 8-K filed on December 18, 2019 (File No. 001-09924).

Form of Senior Indenture between Citigroup and The Bank of New York Mellon, as trustee, incorporated by 
reference to Exhibit 4.8 to the Company’s Registration Statement on Form S-3 filed on November 13, 2013 (File 
No. 333-192302).

First Supplemental Indenture, dated as of February 1, 2016, between Citigroup and The Bank of New York Mellon, 
as trustee, incorporated by reference to Exhibit 4.01 to the Company’s Current Report on Form 8-K filed on 
February 1, 2016 (File No. 001-9924).

Second Supplemental Indenture, dated as of December 29, 2016, between Citigroup and The Bank of New York 
Mellon, as trustee, incorporated by reference to Exhibit 4.01 to the Company’s Current Report on Form 8-K filed 
on December 29, 2016 (File No. 001-9924).

Third Supplemental Indenture dated as of June 26, 2017 among Citigroup Global Markets Holdings Inc., the 
Company and The Bank of New York Mellon, as trustee, to Indenture dated as of November 13, 2013, 
incorporated by reference to Exhibit 4.01 to the Company’s Quarterly Report on Form 10-Q filed on August 1, 
2017 (File No. 001-09924).

Subordinated Debt Indenture, dated as of April 12, 2001, between the Company and The Bank of New York 
Mellon, as successor to JPMorgan Chase Bank (formerly Bank One Trust Company, N.A.), as trustee, incorporated 
by reference to Exhibit 4.1 to the Company’s Registration Statement on Form S-3 filed on February 4, 2013 (No. 
333-186425).

First Supplemental Indenture, dated as of August 2, 2004, between the Company and J.P. Morgan Trust Company, 
N.A. (formerly Bank One Trust Company, N.A.), as trustee, incorporated by reference to Exhibit 4.13 to the 
Company’s Registration Statement on Form S-3/A filed on August 31, 2004 (No. 333-117615).

Second Supplemental Indenture, dated as of May 18, 2016, between Citigroup and The Bank of New York Mellon, 
as successor to J.P. Morgan Trust Company, N.A. (formerly Bank One Trust Company, N.A.), as trustee, 
incorporated by reference to Exhibit 4.2 to the Company’s Current Report on Form 8-K filed on May 20, 2016 
(No. 001-9924).

Third Supplemental Indenture, dated as of March 1, 2017, between Citigroup and The Bank of New York Mellon, 
as successor to J.P. Morgan Trust Company, N.A. (formerly Bank One Trust Company, N.A.), as trustee, 
incorporated by reference to Exhibit 4.11 to the Company’s Registration Statement on Form S-3 filed on March 1, 
2017 (No. 333-216372).

Indenture, dated as of March 15, 1987, between Primerica Corporation, a New Jersey corporation, and The Bank of
New York, as trustee, incorporated by reference to Exhibit 4.01 to the Company’s Registration Statement on Form
S-3 filed on December 8, 1992 (No. 03355542).

First Supplemental Indenture, dated as of December 15, 1988, among Primerica Corporation, Primerica Holdings,
Inc. and The Bank of New York, as trustee, incorporated by reference to Exhibit 4.02 to the Company’s
Registration Statement on Form S-3 filed on December 8, 1992 (No. 03355542).

301

 
4.11

4.12

4.13

4.14

4.15

4.16

4.17

4.18

4.19

4.20

4.21

4.22

4.23

4.24

Second Supplemental Indenture, dated as of January 31, 1991, between Primerica Holdings, Inc. and The Bank of
New York, as trustee, incorporated by reference to Exhibit 4.03 to the Company’s Registration Statement on Form
S-3 filed on December 8, 1992 (No. 03355542).

Third Supplemental Indenture, dated as of December 9, 1992, among Primerica Holdings, Inc., Primerica
Corporation and The Bank of New York, as trustee, incorporated by reference to Exhibit 5 to the Company’s Form
8-A dated December 21, 1992, with respect to its 7 3/4% Notes Due June 15, 1999 (No. 001-09924).

Fourth Supplemental Indenture, dated as of November 2, 1998, between the Company and The Bank of New York, 
as trustee, incorporated by reference to Exhibit 4.01 to the Company’s Quarterly Report on Form 10-Q for the 
quarter ended September 30, 1998 (No. 001-09924).

Fifth Supplemental Indenture, dated as of December 9, 2008, between the Company and The Bank of New York 
Mellon, as trustee, incorporated by reference to Exhibit 4.04 to the Company’s Current Report on Form 8-K filed 
on December 11, 2008 (No. 001-09924).

Sixth Supplemental Indenture, dated as of December 20, 2012, between the Company and The Bank of New York 
Mellon, as trustee, providing for the issuance of debt securities, incorporated by reference to Exhibit 4.5 to the 
Company’s Current Report on Form 8-K filed on December 21, 2012 (No. 001-09924).

Seventh Supplemental Indenture, dated as of May 18, 2016, between Citigroup Inc. and The Bank of New York 
Mellon, as trustee, incorporated by reference to Exhibit 4.1 to the Company’s Current Report on Form 8-K filed on 
May 20, 2016 (No. 001-9924).

Senior Debt Indenture, dated as of June 1, 2005, among Citigroup Funding Inc., the Company and The Bank of 
New York Mellon, as successor trustee to JPMorgan Chase Bank, N.A., incorporated by reference to Exhibit 4(b) 
to the Company’s Registration Statement on Form S-3 filed on March 13, 2006 (No. 333-132370-01).

Second Supplemental Indenture, dated as of December 20, 2012, among Citigroup Funding Inc., the Company and 
The Bank of New York Mellon, as successor trustee to JPMorgan Chase Bank, N.A., incorporated by reference to 
Exhibit 4.2 to the Company’s Current Report on Form 8-K filed on December 21, 2012 (No. 001-09924).

Indenture, dated as of July 23, 2004, between the Company and The Bank of New York Mellon, as successor 
trustee to JPMorgan Chase Bank, as trustee, incorporated by reference to Exhibit 4.28 to the Company’s 
Registration Statement on Form S-3 filed on July 23, 2004 (No. 333-117615).

Form of Indenture, between the Company and The Bank of New York Mellon, as successor trustee to JPMorgan 
Chase Bank, incorporated by reference to Exhibit 4.01 to the Company’s Post-Effective Amendment No. 2 to the 
Registration Statement on Form S-3 filed on May 4, 2007 (File No. 333-135163).

Form of Indenture, between the Company and The Bank of New York Mellon, as successor trustee to JPMorgan 
Chase Bank (formerly known as The Chase Manhattan Bank), incorporated by reference to Exhibit 4.11 to the 
Travelers Group Inc. Registration Statement on Form S-3 filed on September 20, 1996 (File No. 333-12439).

Senior Debt Indenture, dated as of March 8, 2016, between Citigroup Global Markets Holdings Inc., the Company 
and The Bank of New York Mellon, as trustee, incorporated by reference to Exhibit 4.1 to the Company’s Current 
Report on Form 8-K filed on March 9, 2016 (File No. 1-9924). 

Form of Capital Securities Guarantee Agreement between the Company, as Guarantor, and The Bank of New York 
Mellon, as Guarantee Trustee, incorporated by reference to Exhibit 4.32 to the Company’s Registration Statement 
on Form S-3 filed on July 2, 2004 (File No. 333-117615).

Amended and Restated Declaration of Trust for Citigroup Capital XIII, incorporated by reference to Exhibit 4.02 
to the Company’s Current Report on Form 8-K filed on September 30, 2010 (File No. 1-9924).

302

4.25

4.26

4.27

4.28+

10.01*

10.02.1*

10.02.2*

10.02.3*

10.03*

10.04.1*

10.04.2*

10.05*

10.06*

10.07.1*

10.07.2*

10.08*

Form of Amended and Restated Declaration of Trust for Citigroup Capital XVIII, incorporated by reference to 
Exhibit 4.07 to the Registrant’s Post-Effective Amendment No. 2 to the Registration Statement on Form S-3 
(No. 333-135163).

Form of Amended and Restated Declaration of Trust for Citigroup Capital III (previously known as Travelers
Capital III), incorporated by reference to Exhibit 4.8 to Travelers Group Inc.’s Registration Statement on Form S-3
(File No. 333-12439).

Specimen Physical Common Stock Certificate of Citigroup, incorporated by reference to Exhibit 4.1 to the 
Company’s Current Report on Form 8-K filed on May 9, 2011 (File No. 001-09924).

Description of Citigroup’s Securities Registered Pursuant to Section 12 of the Securities Exchange Act of 1934.

Citi Discretionary Incentive and Retention Award Plan (as Amended and Restated Effective as of January 1, 2015), 
incorporated by reference to Exhibit 10.01 to the Company’s Annual Report on Form 10-K for the fiscal year 
ended December 31, 2014 (File No. 001-09924) (the “Company’s 2014 10-K”).

Citigroup 2009 Stock Incentive Plan (as amended and restated effective April 24, 2013), incorporated by reference 
to Exhibit 10.1 to the Company’s Current Report on Form 8-K filed on April 26, 2013 (File No. 001-09924).

Citigroup 2014 Stock Incentive Plan (as amended and restated effective April 24, 2018), incorporated by reference 
to Exhibit 10.1 to the Company’s Current Report on Form 8-K filed on April 30, 2018 (File No. 001-09924).

Citigroup 2019 Stock Incentive Plan, incorporated by reference to Exhibit 10.1 to the Company’s Current Report 
on Form 8-K filed on April 17, 2019 (File No. 001-09924). 

Citigroup Inc. Deferred Cash Award Plan (as Amended and Restated Effective as of January 1, 2015), incorporated 
by reference to Exhibit 10.03 to the Company’s 2014 10-K.

Form of Citigroup Inc. CAP/DCAP Agreement, incorporated by reference to Exhibit 10.01 to the Company’s 
Quarterly Report on Form 10-Q for the quarterly period ended September 30, 2015 (File No. 001-09924).

Form of Citigroup Inc. CAP/DCAP Agreement (for awards granted on February 14, 2019 and in future years), 
incorporated by reference to Exhibit 10.02 to the Company’s Quarterly Report on Form 10-Q for the quarterly 
period ended March 31, 2019 (File No. 001-09924).

Form of Citigroup Inc. CAP Agreement, incorporated by reference to Exhibit 10.01 to the Company’s Quarterly 
Report on Form 10-Q for the quarterly period ended September 30, 2019 (File No. 001-09924).

The Amended and Restated 2011 Citigroup Executive Performance Plan (as amended and restated as of January 1, 
2016, and as further amended on February 16, 2017), incorporated by reference to Exhibit 10.2 to the Company’s 
Current Report on Form 10-Q filed for the quarterly period ended March 31, 2017  (File No. 001-09924).

Form of Citigroup Inc. Performance Share Unit Award Agreement (awards dated February 16, 2017 and in future 
years), incorporated by reference to Exhibit 10.01 to the Company’s Quarterly Report on Form 10-Q for the 
quarterly period ended March 31, 2017 (File No. 001-09924).

Form of Citigroup Inc. Performance Share Unit Award Agreement (awards dated February 14, 2019 and in future 
years), incorporated by reference to Exhibit 10.01 to the Company’s Quarterly Report on Form 10-Q for the 
quarterly period ended March 31, 2019 (File No. 001-09924).

Citigroup Management Committee Termination Notice and Non-Solicitation Policy, effective October 2, 2006, 
incorporated by reference to Exhibit 10.1 to the Company’s Current Report on Form 8-K filed on October 6, 2006 
(File No. 001-09924).

10.09.1*

Citicorp Deferred Compensation Plan, effective October 1995, incorporated by reference to Exhibit 10 to 
Citicorp’s Registration Statement on Form S-8 filed on February 15, 1996 (File No. 333-00983).

303

10.09.2*

10.09.3*

10.09.4*

10.10.1*

10.10.2*

10.10.3*

10.10.4*

10.10.5*

10.10.6*

10.10.7*

10.11*

10.12*

10.13*

10.14+*

Amendment to the Citicorp Deferred Compensation Plan, incorporated by reference to Exhibit 10.18.2 to the 
Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 1999 (File No. 001-09924) (the 
“Company’s 1999 10-K”).

Amendment to the Citicorp Deferred Compensation Plan, effective as of September 28, 2001, incorporated by 
reference to Exhibit 10.17.3 to the Company’s Annual Report on Form 10-K for the fiscal year ended December 
31, 2001 (File No. 001-09924).

Amendment to the Citicorp Deferred Compensation Plan, effective November 22, 2009, incorporated by reference 
to Exhibit 10.01.5 to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2009 
(File No. 001-09924) (the “Company’s 2009 10-K”).

Supplemental ERISA Compensation Plan of Citibank, N.A. and Affiliates, as amended and restated (the “Citibank 
Supplemental ERISA Plan”), incorporated by reference to Exhibit 10.(G) to Citicorp’s Annual Report on Form 10-
K for the fiscal year ended December 31, 1997 (File No. 001-05378).

Amendment to the Citibank Supplemental ERISA Plan, effective January 1, 2000, incorporated by reference to 
Exhibit 10.21.2 to the Company’s 1999 10-K.

Resolution Amending the Citibank Supplemental ERISA Plan, incorporated by reference to Exhibit 10.04.1 to the 
Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2005 (File No. 001-09924).

Amendment to the Citibank Supplemental ERISA Plan, effective January 1, 2009, incorporated by reference to 
Exhibit 10.01.4 to the Company’s 2009 10-K.

Amendment to the Citibank Supplemental ERISA Plan, effective November 22, 2009, incorporated by reference to 
Exhibit 10.01.5 to the Company’s 2009 10-K.

Amendment to the Citibank Supplemental ERISA Plan, effective December 31, 2012, incorporated by reference to 
Exhibit 10.01.6 to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2012 (File 
No. 001-09924).

Amendment to the Citibank Supplemental ERISA Plan, effective December 31, 2018, incorporated by reference to 
Exhibit 10.09.7 to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2018 (File 
No. 001-09924).

Citigroup Inc. Omnibus Non-Qualified Plan Amendment, effective as of June 2, 2014, incorporated by reference to 
Exhibit 10.01 to the Company’s Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2014 (File 
No. 001-09924).

Letter Agreement, dated December 21, 2011, between Citigroup Inc. and Michael Corbat, incorporated by 
reference to Exhibit 10.1 to the Company’s Current Report on Form 8-K filed on December 22, 2011 (File No. 
001-09924).

Citigroup Inc. Non-Employee Directors Compensation Plan (effective as of January 1, 2008), incorporated by 
reference to Exhibit 10.01 to the Company’s Quarterly Report on Form 10-Q for the quarterly period ended 
September 30, 2007 (File No. 001-09924).

Citigroup Inc. Off-Cycle Award Agreement for Deferred Stock Award and Deferred Cash Award granted to Jane 
Fraser (dated November 25, 2019).

10.15+*

Agreement between Stephen Bird and Citibank, N.A. (dated November 8, 2019).

21.01+

Subsidiaries of Citigroup.

304

23.01+

Consent of KPMG LLP, Independent Registered Public Accounting Firm.

24.01+

Powers of Attorney.

31.01+

Certification of principal executive officer pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

31.02+

Certification of principal financial officer pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

32.01+

99.01+

101.01+

104

Certification pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 
2002.

List of Securities Registered Pursuant to Section 12(b) of the Securities Exchange Act of 1934, formatted in inline 
XBRL.

Financial statements from the Annual Report on Form 10-K of Citigroup for the fiscal year ended December 31, 
2019, filed on February 21, 2020, formatted in inline XBRL: (i) the Consolidated Statement of Income, (ii) the 
Consolidated Balance Sheet, (iii) the Consolidated Statement of Changes in Equity, (iv) the Consolidated 
Statement of Cash Flows and (v) the Notes to Consolidated Financial Statements.

The cover page of this Current Report on Form 10-K, formatted in inline XBRL.

The total amount of securities authorized pursuant to any instrument defining rights of holders of long-term debt of the Company does 
not exceed 10% of the total assets of the Company and its consolidated subsidiaries. The Company will furnish copies of any such 
instrument to the SEC upon request.

Copies of any of the exhibits referred to above will be furnished at a cost of $0.25 per page (although no charge will be made for the 
2019 Annual Report on Form 10-K) to security holders who make written request to Citigroup Inc., Corporate Governance, 388 
Greenwich Street, New York, NY 10013.

* Denotes a management contract or compensatory plan or arrangement.
+ Filed herewith.

305

Stockholder Information

Citigroup common stock is listed on the NYSE under the 
ticker symbol “C.” Citigroup preferred stock Series J, K and S 
are also listed on the NYSE.

Because Citigroup’s common stock is listed on the NYSE, 
the Chief Executive Officer is required to make an annual 
certification to the NYSE stating that he was not aware of 
any violation by Citigroup of the corporate governance listing 
standards of the NYSE. The annual certification to that effect 
was made to the NYSE on May 13, 2019.

As of January 31, 2020, Citigroup had approximately 66,990 
common stockholders of record. This figure does not 
represent the actual number of beneficial owners of common 
stock because shares are frequently held in “street name” 
by securities dealers and others for the benefit of individual 
owners who may vote the shares.

Transfer Agent
Stockholder address changes and inquiries regarding stock 
transfers, dividend replacement, 1099-DIV reporting and 
lost securities for common and preferred stock should be 
directed to:

Computershare 
P.O. Box 505004 
Louisville, KY 40233-5004 
Telephone No. 781 575 4555 
Toll-free No. 888 250 3985 
E-mail address: shareholder@computershare.com 
Web address: www.computershare.com/investor

Exchange Agent
Holders of Golden State Bancorp, Associates First Capital 
Corporation or Citicorp common stock should arrange to 
exchange their certificates by contacting:

Computershare 
P.O. Box 505004 
Louisville, KY 40233-5004 
Telephone No. 781 575 4555 
Toll-free No. 888 250 3985 
E-mail address: shareholder@computershare.com 
Web address: www.computershare.com/investor

On May 9, 2011, Citi effected a 1-for-10 reverse stock split. 
All Citi common stock certificates issued prior to that date 
must be exchanged for new certificates by contacting 
Computershare at the address noted above.

Citi’s 2019 Form 10-K filed with the SEC, as well as other 
annual and quarterly reports, are available from Citi 
Document Services toll free at 877 936 2737 (outside the 
United States at 716 730 8055), by e-mailing a request to 
docserve@citi.com or by writing to:

Citi Document Services 
540 Crosspoint Parkway 
Getzville, NY 14068

Stockholder Inquiries
Information about Citi, including quarterly earnings 
releases and filings with the U.S. Securities and Exchange 
Commission, can be accessed via Citi’s website at  
www.citigroup.com. Stockholder inquiries can also be 
directed by e-mail to shareholderrelations@citi.com.

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The cover and editorial section of this annual report are printed on McCoy, manufactured by Sappi North America with 10% recycled content  
and FSC® Chain of Custody Certified. 100% of the electricity used to manufacture McCoy is Green-e® certified renewable energy.

The financial section of this annual report is printed on FSC® certified Accent Opaque from International Paper. 

Citi, Citi and Arc Design and other marks used herein are service marks of Citigroup Inc. or its affiliates, used and registered throughout the world.

Cover photo: U.S. wind and solar project owned by NextEra Energy Partners, LP and KKR. Financed by Citi.

 
 
 
 
www.citigroup.com

© 2020 Citigroup Inc.
1921382  CIT24028  03/20

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