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Citigroup

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FY2020 Annual Report · Citigroup
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2020 ANNUAL REPORT

Citi’s Value Proposition

A Mission of Enabling 
Growth and Progress

What You Can Expect From Us and  
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.

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.

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.

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.

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 4.

2020

$

30.0

$

$

44.3

0.1

74.3

11.0

4.72

4.73

$ 2,260

1,281

199

11.7%

13.3%

15.6%

7.0%

0.50%

5.7%

6.6%

$

$

$

$

2019

33.0

39.3

2.0

74.3

19.4

8.04

8.04

1,951

1,071

193

11.8%

13.3%

15.9%

6.2%

0.98%

10.3%

12.1%

2018

$

32.3

$

$

38.3

2.2

72.9

18.0

6.68

6.69

$

1,917

1,013

196

11.9%

13.4%

16.1%

6.4%

0.94%

9.4%

11.0%

$ 86.43

$

82.90

$ 75.05

73.67

2,082

73%

128

210

$

70.39

2,114

122%

169

200

$

63.79

2,368

109%

$

123

204

1

Dear Shareholders:
Never could I have imagined 
that my final year as CEO of 
Citi would be consumed by 
a once-in-a-century health 
crisis that would upend the 
global economy and the 
lives of everyone on our 
planet. It was a year filled 
with immense pain and 
uncertainty but also courage 
and purpose — and we can 
take heart that even as it 
did its worst, the global 
pandemic has brought out 
the best in us. 

Michael L. Corbat
Chief Executive Officer
October 2012 – February 2021

Letter to Shareholders

2020 was a year that tested Citi like never before. From the beginning, I was 
determined to see that Citi not merely manage through but emerge stronger 
from the pandemic — and that, in addition to serving as a source of strength 
for our clients, we seize the opportunity to help lead the relief and recovery 
and remind the world of the invaluable role that Citi plays as a global bank.

I’m proud to say we have done that, by every measure. Entering the 
pandemic on a solid footing from a capital and liquidity perspective gave 
us the resources we needed to support our colleagues, customers, clients 
and communities during the sharpest economic downturn since the Great 
Depression. That financial stability enabled us to do many things to catalyze 
the recovery without jeopardizing our own safety and soundness. 

From the onset of the pandemic, we acted swiftly. When shelter-at-home 
orders were issued last March by governments around the globe, we 
undertook a massive effort to keep our employees safe while serving our 
clients seamlessly. Within days, we had nearly 200,000 of our colleagues up 
and running at their kitchen tables and home offices. We offered childcare 
and in-home care options and enhanced health and education resources 
and provided special compensation to help ease the financial burden for 
75,000 colleagues.

We were one of the first banks in the U.S. to 
announce consumer assistance programs 
for our credit card and mortgage customers. 
Though Citi historically has not been a large 
lender to small businesses, by year end we 
funded loans totaling $3.8 billion as part of the 
U.S. Small Business Administration’s Paycheck 
Protection Program and donated $50 million 
in proceeds from the program to support 
community economic recovery efforts. 

For our globally minded clients who include 
multinational companies, emerging market 
leaders, governments, investors and ultra-
high net worth households, we have been 
helping them contend with volatile markets, 
reconfigure supply chains, and access short- 
and long-term liquidity.

2

And because we take seriously our 
responsibility to the communities we 
serve, we have supported front-line health 
workers and deployed other resources to 
those who desperately need help. Combined 
with donations from Citi colleagues, 
contributions to pandemic-related causes 
from our company and the Citi Foundation 
topped $100 million in 2020. 

Providing Strength in a Year  
of Upheaval
Despite the tumultuous impacts of the 
pandemic, we turned in solid financial results 
during 2020. In an operating environment 
more uncertain and challenging than any 
in recent memory, we kept revenues flat to 
the banner year of 2019. In 2020, we earned 
$11 billion of net income on revenues of 
$74 billion despite the roughly $10 billion 
increase we took in credit reserves as a 
result of the pandemic and the impact of 
current expected credit losses. 

Even after meeting the capital and liquidity 
needs of our clients, we closed out the 
year exceptionally well-capitalized, with 
a Common Equity Tier 1 ratio of 11.7%, 
exceeding our 10% regulatory minimum.  
We also increased our Tangible Book Value 
per Share to $73.67, up 5% from 2019.

Our Institutional Clients Group performed 
well, delivering 13% revenue growth, 
positive operating leverage and 22% 
operating margin growth for the year. 
Our Treasury and Trade Solutions 
business, although negatively affected 
by lower rates, experienced strong client 
engagement and digital adoption, including 
a 9% year-over-year increase in users of 
our CitiDirect BE® banking platform.

Our global expertise means that we 
continue to be the first call for many of 
the most significant financial transactions 
and activities. In September, our team led 
the initial public offering for the enterprise 
software company Snowflake, which 
returned 100% to investors while creating  
a new $65 billion market cap company.  
In November, we were selected to serve as 
the financial advisor to the international 
public health organization Gavi in its effort 
to equitably distribute 2 billion vaccine 
doses for COVID-19 by the end of 2021. 

Our Global Consumer Bank bore the impact of sharply decreased credit 
card spending, although we did see deposit growth in every region. In 
the U.S., our retail business benefited from exceptionally high mortgage 
refinancing as homeowners saw opportunities in this ultra-low-rate 
environment, and we experienced continued momentum in digital deposits. 
In Mexico, an ongoing slowdown in overall economic growth and industry 
volumes resulted in lower revenues. In Asia, card spending was down, 
but we saw strong performance in wealth management, with investment 
revenues at their highest level in a decade.

Jane Fraser
Chief Executive Officer
March 2021 –

“ Citi is an incredible institution with a 
proud history and a bright future. I am 
excited to join with my colleagues in 
writing the next chapter.”

3

We continued to combine our scale, 
digital capabilities and ecosystem to be 
where our customers need us to be. In 
the U.S., our largest consumer market, 
we expanded our lending partnership 
with American Airlines, announced 
private label and co-brand credit card 
agreements with two new partners, 
Meijer and Wayfair, and drove robust 
digital deposit sales. In Mexico, we 
worked with PepsiCo Alimentos Mexico 
and Amigo PAQ to enable mobile 
access to credit to more than 800,000 
shopkeepers through our Citibanamex 
digital apps. And in Asia, we expanded 
our partnership with Grab to offer 
personal loans through the ride-hailing 
company’s app.

Putting Citi on a  
Strong Footing
More than anything, 2020 
demonstrated the value of our 
diversified and durable business model. 
But for Citi, the story of 2020 actually 
began many years earlier. 

When I was appointed CEO in 2012, the 
firm was still in a tenuous position from 
the financial crisis several years before. 
At the time, I decided to accelerate a 
strategy that returned the firm back to 
basics. We streamlined our consumer 
business and embraced the shift to 
digital. We re-established Citi as a 
go-to bank for our institutional clients 
through our global network. 

Working through our legacy assets, 
we optimized our capital base and 
reduced our net deferred tax assets by 
more than half, generating $7 billion 
of regulatory capital in the process. 
Our financial performance improved 
steadily as we became a simpler, 
smaller, safer and stronger institution. 
We transitioned from restructuring the 
firm to investing in it and significantly 
improved our returns. 

Before the pandemic’s impact on the 
economy and our businesses took hold, 
we had made tremendous progress in 
closing the gap with our peers. From 
2012 to 2019:

• Citi’s Net Income increased from  

$7.5 billion to $19.4 billion.

2020 NET REVENUES1

• Citi’s Return on Assets increased 

$74.2 Billion

from 39 bps to 98 bps.

• Citi’s Efficiency Ratio improved  

from 72.0% to 56.5%.

• Citi’s Return on Tangible Common 

Equity increased from 5.0% to 12.1%, 
closing the gap with our peers. 

We dramatically increased the return 
of capital to common shareholders. 
From 2015 through 2019, we returned 
nearly $75 billion to our common 
shareholders while also reducing our 
share count by 30%. 

Showing how far Citi has come since 
the financial crisis, in 2020 — the year 
of a pandemic — we had $3.5 billion 
more in Net Income, an 11 bps higher 
Return on Assets and 160 bps higher 
Return on Tangible Common Equity 
than we had in 2012. That’s great 
progress but make no mistake: It was 
rooted in the hard work we put in 
during the years leading up to 2020. 
Prudent decisions we made in the wake 
of the last crisis have proved their full 
value in this one.

BY REGION

North America
50%

Europe, 
Middle East 
and Africa 
(EMEA)
17%

Latin America
12%

Asia2
21%

BY BUSINESS

Global 
Consumer 
Banking (GCB)
40%

ICG Banking
29%

ICG Markets and 
Securities Services
31%

ICG — Institutional Clients Group

1  Results exclude Corporate/Other revenues 

(of $0.1 billion) and are non-GAAP financial measures.

2 Asia GCB includes the results of operations of GCB 

activities in certain EMEA countries.

CITIGROUP — KEY CAPITAL METRICS

Common Equity Tier 1 Capital Ratio1

Supplementary Leverage Ratio1

TBV/Share2

12.6%

12.4%

11.9%

11.8%

11.7%

7.2%

6.7%

6.4%

6.2%

7.0%

$64.57

$60.16

$63.79

$70.39

$73.67

4Q’16

4Q’17

4Q’18

4Q’19

4Q’20

1  Citigroup’s Common Equity Tier 1 Capital Ratio and Supplementary Leverage Ratio for 2017 and 2016 
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 2020 Annual Report on Form 10-K.

4

Leading with Purpose
Amid a global health crisis that has 
created so much economic and social 
upheaval, Citi’s efforts to tackle long-
standing societal challenges have 
become even more important. 

We kicked off the year with the launch 
of the Citi Impact Fund in January. 
With $200 million to invest, it is the 
largest fund of its kind established 
by a bank with its own capital. In just 
its first year, the Citi Impact Fund has 
invested in 11 companies, the majority 
of which are founded by women, 
minorities — and in some cases both 
— that have the potential to make our 
cities and communities more equitable 
and sustainable.

The pandemic focused the spotlight 
on another intensifying global crisis 
— climate change. For more than two 
decades, Citi has led the industry’s 
drive toward sustainability. In 2020, 
we announced a new five-year goal to 
finance and facilitate $250 billion in 
environmental projects and activities, 
following on the heels of completing 
$100 billion in environmental 
transactions four years faster than  
the goal we had set.

encompasses $1 billion in strategic 
actions to help close the racial wealth 
gap and increase economic mobility in 
the U.S. The initiative underscores our 
determination to mobilize the full power 
of our business activities to attack 
the barriers that keep racially diverse 
communities from building wealth. 

Each of these efforts helps advance 
our ambition to be a leader on a broad 
range of societal issues and challenges. 
In each case, these efforts enjoy the full 
support of our franchise because this 
is about more than just “doing good.” 
It is a business imperative. By building 
a fairer, more inclusive and more 
sustainable economy, we all benefit — 
our company, our clients and customers, 
and the communities we serve.

Building on Our Success
Looking back at my time as CEO, I 
could not be more proud of what our 
firm has achieved. But I know there 
is always more to do. The pandemic 
will irrevocably change many things 
about banking, and we must embrace 
this opportunity to achieve a state of 
excellence in our risk and controls, our 
infrastructure and our ability to serve 
our clients.

2020 also brought a long overdue 
reckoning with systemic inequity 
and social injustice. In the aftermath 
of the murder of George Floyd, we 
launched Action for Racial Equity, which 

Consent orders issued in October 
by the Federal Reserve Board and 
the Office of the Comptroller of the 
Currency have created additional 
urgency and a framework for the 

firm’s transformation. Central to 
addressing regulators’ concerns 
is improving Citi’s risk and control 
environment, which will be essential  
to the new digital landscape. 

Now, after 38 years at Citi, I leave 
this institution with Jane Fraser’s 
hands at the helm, confident in the 
quality and comprehensiveness 
of the transformation she will be 
leading so Citi can continue its 
journey back to being the world’s 
leading bank. I leave Citi perhaps 
proudest of the fact that it is again 
an indisputably strong and stable 
institution — and an institution our 
colleagues are proud of which to be 
a part. And I know that Jane will take 
our great firm to new heights while 
maximizing returns and delivering 
the full benefits of our franchise to 
all our stakeholders. 

I will always be rooting for Citi.

Sincerely,

Michael L. Corbat
Chief Executive Officer, Citigroup Inc.

1  Tangible Book Value (TBV) is a non-GAAP financial measure. For the components of the TBV calculation, see “Capital Resources — Tangible Common 
Equity, Book Value per Share, Tangible Book Value per Share and Returns on Equity” in Citi’s 2020 Annual Report on Form 10-K included with this letter.

2  Return on Tangible Common Equity (ROTCE) is a non-GAAP financial measure. For the components of the ROTCE calculations, see “Capital Resources — 

Tangible Common Equity, Book Value per Share, Tangible Book Value per Share and Returns on Equity” in Citi’s 2020 Annual Report on Form 10-K included 
with this letter.

5

Global Consumer Banking

Citi’s Global Consumer Bank (GCB) is a global 
leader in banking and wealth management, the 
world’s largest credit card issuer and a partner 
of choice globally to the world’s most iconic 
brands and digital leaders. The Global Consumer 
Bank serves more than 110 million clients in the 
U.S., Mexico and Asia, spanning 19 markets.

In 2020, the Global Consumer Bank continued to execute a digital-first, 
client-led growth strategy while pivoting swiftly to provide value, service and 
support to clients and communities impacted by the COVID-19 pandemic.

The GCB’s model is distinct: digital-first capabilities complemented by a light 
physical footprint in leading urban markets. Our relationship banking model 
serves clients across the full spectrum of their needs as they borrow, pay, 
save, invest and protect and is supported by global assets and capabilities that 
are deployed locally. With a high-quality, highly digitally engaged customer 
base and one of the most dynamic partner ecosystems in the industry, the 
franchise is well positioned for where the world is headed.

In a rapidly changing landscape, the GCB intensified its focus on three 
strategic priorities to position the franchise for long-term growth: winning in 
wealth management; leading in consumer payments and lending; and driving 
scale through digitization and partnerships. With digital at the core of our 
strategy, GCB delivered double-digit growth in deposits, enhanced value 
propositions and provided an array of digital capabilities, garnering industry 
accolades for client experience. Citi was named Best Digital Bank in Asia 
(Euromoney), Best Digital Bank in Mexico (Global Finance) and Bank with the 
Most Desirable Mobile Banking Digital Money Management Features in the 
U.S. (Insider Intelligence).

At the onset of the COVID-19 pandemic, Citi responded quickly, enabling 
thousands of colleagues to work from home in a matter of weeks, with requisite 
training, technology and onboarding, while retaining servicing for customers. 

We launched assistance programs in 
markets worldwide, the first large bank 
to do so in the U.S., while also facilitating 
free cashing of U.S. government 
stimulus checks for non-customers. 
We continued to serve clients safely 
in branches, introducing new safety 
measures and cleaning protocols, as 
well as innovative ways to serve clients 
remotely, such as video banking in 
Asia and the U.S. As COVID-19 made 
mobile capabilities, high-touch digital 
services and the human touch critical, 
Citi introduced new and enhanced digital 
and mobile capabilities and evolved 
product benefits across our credit card 
portfolios to ensure value, utility and 
relevance to customers.

As of December 31, 2020, Citi 
had assisted more than 5 million 
customers and small businesses 
worldwide with a range of assistance 
measures, including fee waivers and 
deferral of credit card minimum 
payments. In the U.S., as part of 
the Small Business Administration’s 
Paycheck Protection Program (PPP), 
Citi funded more than $3 billion to 
U.S. small businesses, many in the 
areas hardest hit by COVID-19. Net 
profit earned through participation 
in the PPP was donated to the Citi 
Foundation to support community 
economic recovery efforts.

The GCB operates approximately 2,300 
branches and generated $1.1 billion 
in pretax earnings in 2020. At year 
end, the business had $345 billion in 
deposits, $282 billion in loans and $222 
billion in assets under management.

JANUARY

10

15

CitiDirect BE® ranked 
#1 globally in Greenwich 
Associates’ Digital Banking 
Benchmarking Study

Citi releases update on its 
global pay equity review, 
including progress on its 
raw pay gap analysis

17

Citi launches $150 million 
Impact Fund to make 
investments in double 
bottom-line startups 
with an emphasis on 
women and minority 
entrepreneurs

28

Citi Retail Services 
announces multi-year 
strategic agreement  
with Meijer

6

2020Credit Cards
Citi is a global leader in payments, with 
132 million accounts and $505 billion 
in annual purchase sales, and has 
unrivaled partnerships with premier 
brands across Citi Branded Cards and 
Citi Retail Services. At year-end 2020, 
card receivables were $153 billion.

Citi Branded Cards
Citi Branded Cards provides payment, 
credit and lending solutions to 
consumers and small businesses, with 
54 million accounts globally. In 2020, 
Citi Branded Cards generated annual 
purchase sales of $427 billion and 
ended the year with a loan portfolio  
of $107 billion.

In 2020, we continued to evolve our 
value propositions, expand co-brand 
partnerships and provide new digital 
capabilities to make purchases faster, 
convenient and more rewarding.

In the U.S., as part of a more 
integrated, multi-product relationship 
model, we expanded our lending 
partnership with American Airlines, our 
partner of more than three decades, to 
include the Citi Miles AheadTM Savings 
Account, a new deposit product 
exclusively for American Airlines co-
brand cardholders who reside within 
the U.S. but outside locations where 
Citi has a retail branch presence. The 
account provides the ability to earn 
more miles on everyday purchases, as 
well as relationship-based offers. 

During an unprecedented year marked 
by the pandemic, we actively engaged 
with cardholders to ensure we met their 
evolving needs. In the U.S., for example, 
we introduced relevant points offers on 
the Citi Prestige® Card and expanded 
the $250 travel credit to include 
supermarket and restaurant purchases 
through 2021. Similarly, we introduced 

Throughout the pandemic, Citibanamex colleagues continued to provide warm and professional 
service to clients in branches while following guidelines to ensure their well-being.

relevant accelerators to the Citi Premier 
Card, including increased rewards for 
supermarket and restaurant purchases, 
including takeout and curbside pickup. 
In addition, we introduced a temporary 
point-redemption option for U.S. 
cardholders by providing them with 
the choice to redeem cash rewards and 
ThankYou Points to pay the minimum 
due on their credit card.

We teamed up with World Central 
Kitchen, a nonprofit organization 
that uses the power of food to heal 
communities and strengthen economies 
in times of crisis and beyond, on a 
program to support hunger relief 
efforts during COVID-19 while further 
encouraging digital banking adoption 
among clients. In addition, we joined 
with Mastercard and a nonprofit 
organization called Start Small Think 
Big to help small businesses. As a 
long-time partner of Global Citizen, 
we supported its global broadcast and 
digital special, One World: Together at 
Home, in support of the World Health 
Organization and regional charities 
working to meet immediate COVID-19 
needs locally.

With physical cards rapidly digitizing, 
we continued to expand digital lending 
capabilities and point-of-sale solutions 
to give customers ease, convenience 
and choice in payments.

In the U.S., we introduced our 
proprietary Citi Flex Pay capabilities to 
American Airlines co-brand cardholders 
and on Amazon. Citi Flex Pay enables 
customers to finance purchases by 
converting eligible purchases into a 
fixed payment plan. Citi Flex Loan, a 
digital lending solution introduced in 
2019 that enables customers to convert 

29

Stonewall Top 100:  
Citi ranked #1 LGBT-
inclusive financial  
services employer

30

Citi introduces Citi  
Wealth Builder, an  
easy-to-use, low-cost 
digital investing platform 
with professionally 
managed portfolios

FEBRUARY

3

4

Citi Commercial Cards 
boosts digital servicing 
experience for clients with 
launch of an intelligent 
virtual agent capability

Citi named Best Global 
Bank for Liquidity 
Management by  
Global Finance

7

a portion of their credit line into a 
fixed rate personal loan, continued to 
perform well, with the average balance 
more than doubling.

In Asia, more than 60% of personal 
loans were made digitally through its Citi 
Quick Cash, Citi PayLite and Citi Flexibill 
solutions. A seamless, self-service 
mobile application journey, coupled 
with data-enabled real-time triggers, 
helped meet customers’ borrowing 
needs, with lending volumes in the 
mobile app up 67% despite a challenging 
environment. Innovation remains at the 

forefront of our business, with the recent 
expansion of our Grab partnership that 
allows customers to obtain personal 
loans on the Grab app via application 
programming interfaces (API).

In Mexico, Citibanamex is a leader 
in credit cards, with strong market 
share, compelling value propositions, 
including our reward programs 
(ThankYou® Rewards and Premia),  
and market-leading promotions such 
as Buen Fin, which included more than 
40,000 exclusive agreements with 
retailers and businesses.

Retail Services
Citi 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 78 
million customer accounts for iconic 
brands, including Best Buy, Exxon, Mobil, 
L.L.Bean, Macy’s, Sears, Shell, The Home 
Depot and Tractor Supply Company.

In 2020, Citi Retail Services announced 
private label and co-brand credit 
card agreements with two exciting 

A NEW WAY TO BANK NATIONWIDE ON GOOGLE PAY

Alongside the launch of the 
redesigned Google Pay in 
the U.S., then-Citi President 
and current CEO Jane Fraser 
shared a sneak preview of 
the Citi® PlexTM Account by 
Google Pay in 2021.

Today, customers want an integrated experience where their relationship  
with money operates at the same speed as the rest of their life. At Citi,  
we want to empower them with an account that provides smart — very smart — 
financial services built from the ground up with financial wellness and mobile 
functionality at its core.

The Citi Plex Account is a new digital checking and savings account built 
to make managing money simpler, smarter, safer and more rewarding, 
with financial wellness and mobile functionality at the core of the design. 
Consumers will open and manage these accounts through the Google Pay  
app on both Android and iOS.

“Just over a year ago, we set out on a journey with Google to create an 
experience that is 100% digital, and different, in banking,” said Anand Selva, 
CEO of the U.S. Consumer Bank and incoming CEO of the Global Consumer 
Bank. “The Citi Plex Account is designed to give customers an always-on, 
friction-free, personalized experience at their fingertips.”

The collaboration is the first of its kind 
in the U.S., bringing together Citi’s 
banking know-how with Google’s best-
in-class user experience and technology 
to drive a stream of new services and 
capabilities. It aligns seamlessly with our 
U.S. Consumer Bank strategy, giving us 
a platform to drive significant scale in 
our Retail Bank by unlocking the power 
of our respective ecosystems to deepen 
our existing relationships and serve a 
larger and new generation of customers.

The Citi Plex Account is Citi’s first-ever 
bundled checking and savings account 
solution. With extensive user experience 
and account management features 
powered by Google, the Citi Plex Account 
is designed to integrate seamlessly 
within Google Pay to deliver a richness 
of insights and capabilities to empower 
consumers with a simple, convenient and 
personal banking experience.

We are excited about the possibilities 
this collaboration creates for our clients 
and feel a tremendous sense of pride in 
helping to create a truly new and unique 
way to bank nationwide.

FEBRUARY

10

19

In J.D. Power study, 
Citibank ranked highest 
among 17 major U.S. banks 
for customer satisfaction 
with retail banking advice

Citi retains top spot in 
Greenwich Associates’ 
Global Fixed Income 
Dealer rankings for fifth 
consecutive year

27

Citi Asia Pacific wins 
Digital Bank of the Year 
from The Asset magazine

MARCH

2

U.S.: Citi tops Affordable 
Housing Lender Survey

8

2020new partners — Meijer and Wayfair. 
Meijer is a privately owned and family-
operated Midwestern retailer with 
more than 250 supercenters and 
grocery stores throughout the Midwest. 
Wayfair is one of the world’s largest 
online destinations for the home, 
offering millions of items across home 
furnishings, décor, home improvement, 
housewares and more. Today, Citi is the 
consumer credit card provider to half of 
the top 10 U.S. ecommerce companies.

In 2020, Citi Retail Services generated 
purchase sales of $78 billion and 
ended the year with a loan portfolio  
of $46 billion.

Retail Banking
With our high-tech, high-touch 
relationship model, Citibank serves as 
a trusted advisor to our retail, wealth 
management and small business clients 
at every stage of their financial journey. 

Through Citi’s Access Account, Basic 
Banking, Citi Priority, Citigold® and 
Citigold Private Client, we offer an 
array of products, services and digital 
capabilities to clients across the full 
spectrum of consumer banking  
needs worldwide.

In the U.S., Citi continued to digitize our 
retail bank model to drive national scale. 
Citi Accelerate Savings and Citi Elevate® 
Checking, digital high-yield savings 
and checking accounts for customers 
outside Citi’s branch footprint, helped 
drive robust digital deposit sales, while 
Citi’s Access Account, a checkless 
bank account with no or low monthly 
fees, no overdraft fees and access to 
Citi’s digital, retail and ATM channels, 
continued to be one of our fastest-
growing products.

ENABLING PROGRESS: CITI LAUNCHES CHOSEN NAME FEATURE  
ON BRANDED CREDIT CARDS

In October, Citi was 
proud to announce 
a new initiative 
offering transgender 
and non-binary 
people the ability 
to use their chosen 

name on eligible credit cards. The launch, in conjunction 
with Mastercard, provides eligible U.S. branded credit card 
customers with the option to use their self-identified chosen 
first name on credit cards.

With a recent survey by the National Center for Transgender Equality showing that 
one-third of transgender people reported suffering harassment or denial of service 
after showing ID with a name or gender marker that didn’t match their appearance, 
the initiative is a step toward helping customers feel recognized, accepted and 
empowered to be their true selves.

Today, eligible existing credit cardmembers are able to request new credit cards 
that display their chosen name. Further, customers are able to be serviced by their 
chosen name when they call into customer service and also across online and 
mobile access points.

The response has been tremendous to date, with thousands of customers updating 
their cards with their chosen first name and feedback from customers such as 
the following: “I wish that there had been something like this when I began my 
transition. This will remove one of the many worries that we all have had when we 
were introducing our true selves to the world.”

And this initiative really is an extension of the bank’s ongoing commitment to the 
LGBTQ+ community. Not only is Citi an active advocate for LGBTQ+ equality — most 
recently signing an amicus brief urging the Supreme Court to prohibit workplace 
discrimination on the basis of sexual orientation and gender identity in the U.S. 
and a letter to the Prime Minister advocating for trans equality in the U.K. — but 
we are committed to helping create an equitable and inclusive culture where we 
all recognize and respect how our identity affects our experiences. Also, for 16 
consecutive years, Citi has received a perfect score on the Human Rights Campaign 
Foundation’s Corporate Equality Index, a national survey that benchmarks 
corporate policies and practices for LGBTQ+ workplace equality.

6

Citi introduces fee  
waivers, hardship 
programs and small 
business support for  
U.S. customers impacted 
by COVID-19

19

30

Citi Foundation 
announces it will provide 
$15 million to support 
COVID-19-related relief 
efforts globally

Citi hires women-owned 
firms to lead distribution 
of $4 billion Citi bond 
issuance to commemorate 
Women’s History Month

APRIL

7

Citi expands assistance to 
U.S. customers impacted 
by COVID-19, broadening 
assistance measures 
to include credit card 
payment deferrals and 
additional fee waivers

9

Citi also gave consumers a sneak 
preview of the Citi Plex Account by 
Google Pay, a new digital checking 
and savings account launching on 
Google Pay in 2021, and announced 
Mastercard as our network partner for 
the account (see sidebar on page 8).

In the U.S., small business lending again 
exceeded $10 billion in addition to more 
than $3 billion administered through 
the Small Business Administration’s 
Paycheck Protection Program (see 
sidebar on page 11), while in Mortgage, 
the low rate environment drove strong 
origination and refinancing activity. In 
the U.S., Citibank, N.A. originated $24 
billion in new loans in 2020.

Throughout the pandemic, Citi worked 
tirelessly to ensure that customers and 
small businesses felt confident that as 
an essential service, we were available 
to help them navigate this challenging 
time. To educate customers on the ease 
and convenience of digital banking, 
Citi introduced education campaigns, 
highlighting tools and capabilities 
available for customers to self-service 
as they complied with stay-at-home 
orders. By providing customers with 
quick links to set up online access, 
shortcuts to key digital tools and how-
to videos on key features, we issued 
a steady stream of communications 
reinforcing the quick, easy nature of 
digital banking. These communications 
were incredibly well received by our 
customers, and we saw significant 
digital adoption and engagement 
among clients. Since the onset of 
COVID-19, the percentage of Retail Bank 
accounts opened digitally has risen to 
nearly 60% globally as has the use of 
mobile check deposits in the U.S.

In December, Citi opened its largest global wealth hub in Singapore. Designed to enhance a visitor’s 
connectivity to nature, the Citi Wealth Hub embodies biophilic design and is LEED certified.

In Wealth Management, we continued to enhance our capabilities and invest in our 
offerings and digital tools to meet a wider spectrum of customer needs. 

In the U.S., we launched Citi Wealth Builder, an easy-to-use, low-cost digital 
investment platform targeted to Citi Priority (emerging affluent) and Citigold® 
(affluent) clients, and introduced Citigold Private Client, a value proposition for 
clients with a minimum of $1 million in assets under management. Together, 
Citigold and Citigold Private Client clients enjoy 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.

In Asia, investment revenues were the highest in a decade, with record net new money 
driven by steadfast client engagement, remote advisory services and accelerated 
client adoption of digital platforms throughout the pandemic. We continued to 
enhance the client experience, opening our largest wealth hub globally in Singapore 
dedicated to Citigold and Citigold Private Client clients. With more than 30,000 
square feet across four floors, the Citi Wealth Hub has over 30 client advisory rooms 
for clients to engage with Relationship Managers, access a team of specialists, and 
enjoy facilities for customized lifestyle events and investment seminars.

In Mexico, Citibanamex is one of the leading 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 2020, in a first-of-its-kind partnership, Citibanamex teamed with PepsiCo 
Alimentos Mexico and Amigo PAQ to advance financial inclusion by enabling 
access to digital financial tools and lines of credit for shopkeepers to use the 
CoDi® electronic payment platform, offered by Banco de México, in the Transfer 
Citibanamex app. The partnership is poised to redefine the way in which collections 
and payments are made in Mexico for small and medium-sized companies, which 
represent about 50% of Mexico’s gross domestic product.

APRIL

14 

Citi announces virtual 
summer internship 
program and a full-time 
offer for most interns  
upon graduation

MAY

6

Global Finance names 
Citi as one of the Best 
Financial Innovation  
Labs in 2020

29

Citi releases first 
Environmental, Social 
and Governance report, 
building upon its Global 
Citizenship Report, which 
has been published 
annually since 2001

8

Citi launches Global 
Community Day 
Reimagined campaign to 
celebrate the 15th year  
of its annual flagship  
volunteer initiative

10

2020CITI SUPPORTS U.S. SMALL BUSINESSES THROUGH THE PANDEMIC

Through our participation 
in the Small Business 
Administration’s Paycheck 
Protection Program, one of 
the largest federal lending 
programs in history, we are 
proud to have served so  
many of our small business customers where and when  
they needed it most. 

As a smaller lender to small businesses due to our light branch footprint, our 
service model has been built on individual relationships, pairing our clients with 
dedicated support from a tight-knit team of experts. Yet as the pandemic drove 
small businesses across the country to close their doors almost overnight, we 
wanted to do our part. That meant dramatically scaling up our capabilities to 
ensure we were ready to support a government-led response. The effort involved 
thousands of colleagues, from every area of the business, working around the clock 
to design, build, test, launch, scale and serve to help small businesses that were 
struggling to stay afloat. And as the data shows, we helped make a difference.

In 2020, Citi funded more than $3 billion in PPP loans to more than 30,000 
businesses across the country that collectively employ more than 300,000 people. 
These loans, along with more than 4.5 million loans disbursed by thousands of our 
fellow lenders, have helped small businesses — the backbone of our economy — 
retain or rehire employees who may have lost their job in this crisis as economic 
activity slowed to contain the health crisis.

The makeup of Citi’s PPP loan portfolio demonstrates the great need that our small 
business services customers had for this critical lifeline. Roughly 86% of Citi loans 
in this Small Business Administration program went to small businesses in the 
services sector, such as healthcare and professional services. With eight out of 10 
U.S. jobs in services, the services sector is the lifeblood of the U.S. economy. 

Services enable all economic sectors — from healthcare to manufacturing to 
agriculture — to be more productive, reach more consumers, and, ultimately, 
contribute to a better livelihood for Americans through job creation, higher 
wages and greater opportunities.

Similarly, Citi’s PPP loans were 
concentrated in the markets where 
we have a branch footprint, including 
a high volume of loans in California, 
Florida, Illinois and New York, which 
were some of the states suffering 
most from the economic fallout. In 
fact, Citi’s top sectors served — again 
based on total number of employees 
at the businesses that received loans 
— mirrored the hardest-hit sectors in 
the states where we funded the most 
loans. The correlation between where 
we made loans and the hardest-hit 
sectors occurred across each state 
where we had a significant number  
of PPP loans.

At its core, banking is about people 
and our dedication to enabling them 
to grow. Behind the numbers and 
statistics, there are stories — many of 
them moving — about the small business 
owners struggling to navigate a health 
and economic crisis unlike any we have 
seen before. To tell them, we created a 
video series with stories that span the 
country, found on the Citi Blog under  
“A Moving Year in Moving Pictures:  
A Small Business Video Series.”

“When I reflect on the year,” said 
David Chubak, Head of U.S. Retail 
Banking, “our all-out effort to support 
the Small Business Administration’s 
PPP across the firm was one of the 
most meaningful highlights.”

11

13

20

JUNE

2

Citi announces inaugural 
U.S. dollar-denominated 
benchmark green bond 
issuance

Digital Onboarding for 
Citi’s Institutional Clients 
expanded to 37 countries 
in all regions

Citi announces 
partnership with minority-
owned depository 
institutions to purchase 
Paycheck Protection 
Program loans

Citi and leading 
international companies 
launch Restarting 
Together, an initiative 
to boost recovery after 
COVID-19 

11

Institutional Clients Group

The Institutional Clients Group strives to be 
the best banking partner for our clients by 
offering a broad spectrum of wholesale banking 
products and services, driven by our unique 
global footprint. Working together, we provide 
innovative solutions to corporations, financial 
institutions, public sector entities, investment 
managers and ultra-high net worth clients.

Our network-driven strategy allows us to service those 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 or region.

With a physical presence in 96 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, helping them to hire, grow and succeed.

Citi’s Institutional Clients Group is uniquely positioned to take advantage of 
important, evolving global trends, including environmental, social and corporate 
governance (ESG), fintech, wellness and mobility. Our unmatched global 
footprint and innovative product set allow us to 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, equity-related 
strategic financing, and merger and 
acquisition 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.

Following the market dislocation last 
spring, Citi was integral in reopening 
both the debt and equity markets, 
leading on several large transactions. 
In 2020, Citi led, as a bookrunning 
manager, over half of the record 
$1.7 trillion investment grade and 
$435 billion high-yield issuance 
volume. The issuance environment 
was very dynamic, with a rush to 
source liquidity during the first three 
months of the pandemic, turning to 
a more opportunistic and acquisition 
financing environment as the year 
progressed with markets steadily 
improving and ultimately rallying by 
year end. Citi was an early leader, 
providing significant balance sheet 
support for clients and guiding 
issuers that raised record amounts of 
liquidity from fixed income investors 
at the peak of the pandemic. As 
markets improved, Citi helped 
countless clients achieve record-low 
coupons. Citi served as a bookrunner 
on a number of landmark investment 
grade financings, including raising 
$25 billion in April for Boeing, $8.5 
billion in March and $9.5 billion in 
April for ExxonMobil, $4.1 billion 

JUNE

4

Citi launches Strategic 
Advisory Solutions Group, 
harnessing and scaling 
data insights across the 
Investment Bank

16

Citi ranked #2 on 3BL 
Media’s annual list of 100 
Best Corporate Citizens

25

Citi named Best  
Bank for High-Net- 
Worth Families by 
Kiplinger for fourth 
consecutive year

29

Citi and the Citi  
Foundation reach more 
than $100 million in 
commitments for  
COVID-19 community  
relief and economic 
recovery efforts

12

2020and €2.6 billion in September for 
Coca-Cola, and $8.9 billion secured 
financing in June for PG&E. Citi 
advised and executed on behalf of 
COVID-19-affected and opportunistic 
high-yield clients, including $8 billion 
in April for Ford, $4.7 billion in June 
for American Airlines, $2.0 billion 
in June for Occidental Petroleum 
and $2.8 billion in December for 
Community Health.

In equity capital markets, historic 
volatility drove waves of equity 
issuance. Citi served as underwriter on 
a number of successful initial public 
offerings (IPO) in 2020, including 
Snowflake’s $3.4 billion offering in 
September and Royalty Pharma’s  
$2.2 billion IPO in June. We saw record 
issuance particularly in the special 
purpose acquisition company (SPAC) 
space, with nearly $100 billion issued 
in 2020. Most notably among 2020 
SPACs was the $4.0 billion blank check 
company sponsored by Pershing Square 
Capital Management whereby Citi 
served as left lead on the transaction. 
In addition to being the largest SPAC 
raised globally, the transaction garnered 
significant praise for the use of minority 
broker-dealers as co-leads on the 
deal. Citi was left lead underwriter for 
both Dragoneer SPAC offerings for a 
combined total of $966 million and sole 
underwriter for the first ESG-linked 
SPAC in May. Citi was also selected as 
left lead for Shopify’s two secondary 
equity offerings, including its $1.5 billion 
follow-on offering in May, representing 
the largest internet overnight follow-on 
to date.

Citi’s Global Mergers & Acquisitions 
Group advised on landmark 
transactions signed and negotiated 
during the peak of the COVID-19 
crisis, demonstrating how our clients 
turn to us to provide trusted advice 
and to offer innovative strategic 
solutions. Citi advised Unilever on 
its transformational restructuring 
to create a simpler company with 
greater strategic flexibility and better 
positioning for future success. This 
transaction removes complexity and 
strengthens corporate governance by 
uniting its dual UK PLC and Dutch N.V. 
legal and listing structure resulting in 
a single parent company: Unilever PLC, 

which will have a market capitalization 
of approximately £110 billion. Citi was 
sole financial advisor to Telefónica on 
its joint venture with Liberty Global 
for its U.K. businesses (O2 and Virgin 
Media), valued at $38 billion. Citi 
served as a financial advisor to S&P 
Global on its announced merger with 
IHS Markit, an all-stock transaction 
implying an enterprise value for IHS 
Markit of $44 billion. This was one 
of the largest transactions of 2020, 
bringing together two world-class 
organizations with unique and highly 
complementary products and cutting-
edge innovation and technology.

Citi acted as sole global coordinator and bookrunner on UEP Penonomé II’s inaugural 
$262.7 million 144A/Reg S Green Notes offering in December, which refinanced initial 
construction financing for InterEnergy Group’s 215-megawatt UEP Penonomé II wind project 
and its 40-megawatt Tecnisol solar project in Panama. The financing represents the first 
international green bond by a renewables portfolio under a project finance structure in 
Latin America, as well as the first private sector green bond in Central America and the 
Caribbean. The Notes’ unique structure successfully monetized a five-year merchant 
tail post expiry of the power purchase agreements, thereby optimizing the projects’ 
capital structure and operational flexibility, supported by their priority of dispatch as 
non-conventional renewables. Combined, UEP Penonomé II and Tecnisol are the largest 
non-conventional renewable energy producers in Panama and one of the largest diversified 
clean power companies in Central America.

JULY

1

IFC, Citi create  
$800 million facility  
to boost trade finance  
in emerging markets

13

Citi announces alliance  
with BlackRock to  
enhance securities 
services for mutual clients; 
Citibanamex and BlackRock 
soon launch sustainable 
investment strategy

15

Citi named Euromoney’s 
Best Bank for Corporate 
Responsibility in  
North America

20

Citi earns the regional 
Euromoney Awards for 
Excellence in Africa,  
Asia Pacific, Latin America 
and North America

13

Citi Public Sector Group worked 
closely with governments and 
the public sector to find liquidity 
alternatives and advised on 
the issuance of social bonds to 
support countries in the emerging 
markets throughout the pandemic. 
In November, we announced our 
selection as financial advisor to 
Gavi, the Vaccine Alliance, for its 
COVAX Facility. In this capacity, a 
team consisting of more than two 
dozen senior bankers across multiple 
business units, spearheaded by the 
Public Sector Group, is providing 
Gavi with expert advice on structures 
to mitigate sovereign, credit and 
operational risk as the COVAX Facility 
seeks to facilitate pooled procurement 
and equitable distribution of safe and 
effective COVID-19 vaccines globally.

In addition, drawing on Citi’s global 
reach with physical presence in nearly 
100 countries and territories and the 
capability to serve nearly 60 additional 
countries, Citi’s Corporate Bank 
served as a critical partner to large 
multinationals in COVID-19-affected 
industries throughout 2020, providing 
new lines of credit and shoring up 
balance sheets for many blue chip 
corporations. In 2020, Citi syndicated 
500+ loans with volumes in excess of 
$895 billion. 

Commercial Bank
Citi Commercial Bank puts 200 
years of experience to work for mid-
sized, globally oriented companies 
by delivering actionable insights 
and ideas, comprehensive banking 
solutions and a truly global network. 

Citi closed a unique financing for 833 Bryant, a project designed to help confront the growing 
problem of homelessness. 833 Bryant Avenue will comprise 145 new permanent supportive 
affordable housing units in San Francisco to be built at a lower cost and on a faster delivery 
schedule than similar projects in the past. Citi played multiple roles in the effort: Low Income 
Housing Tax Credit investor; construction loan administrator; and Letter of Credit provider 
guaranteeing construction completion. In a departure from a typical 4% affordable housing 
project financing, we also structured and secured a rating for the tax-exempt private activity 
bonds that were publicly sold in the municipal bond market. The project is using modular 
construction, with units being built at Factory_OS in Vallejo, California, a new company 
in which Citi is an investor. Supportive services for the residents include intensive case 
management with ongoing, consistent tenant engagement that includes individualized health 
and wellness plans, eviction prevention, crisis intervention and on-site mental health services.

(Photo credit: David Baker Architects)

We provide high-quality financial advice, helping businesses prosper and grow in 
domestic markets, as well as internationally. Our distinctive approach puts the 
client at the center of everything we do. By understanding their industries and 
learning their business priorities, our Relationship Managers bring our clients 
insights designed to help them succeed. Whether providing capital to fund growth 
or refinancing debt, Citi Commercial Bank offers solutions that support the right 
capital structure to meet companies’ short- and long-term financing needs. With 
the full spectrum of Citi’s capabilities and access to our global network, we are able 
to deliver tailored solutions to meet our clients’ unique goals and objectives.

JULY

29

Citi announces new 2025 
Sustainable Progress 
Strategy, including a  
$250 Billion Environmental 
Finance Goal, to accelerate 
the low-carbon transition 
and reduce climate risk

29

Citi named as one of 
Fast Company’s Best 
Workplaces for Innovators 

AUGUST

20

Citi Asia Pacific leads in 
Global Finance’s 2020 
World’s Best Digital Bank 
Awards; Citibanamex 
named Mexico’s Best 
Digital Bank

SEPTEMBER

1

Global Finance names 
Citi Best Corporate/
Institutional Digital Bank 
in 14 Latin American 
countries

14

2020In the past year, Citi Commercial Bank 
enhanced our core client and internal 
applications and significantly improved 
our processes, reducing client friction 
and digitizing more of the client 
experience. We continue our digital 
transformation with the redesign and 
expansion of CitiBusiness® Online 
features and a new Gateway portal in 
the U.S. for account onboarding, Know 
Your Customer and product setup 
activities and continued to build a 
world-class experience by facilitating 
a fully digital onboarding journey 
through Gateway and CitiDirect BE® 
Digital Onboarding.

Citi Commercial Bank worked together 
with the Global Consumer Bank in 
the U.S. to support clients adversely 
affected by the COVID-19 pandemic by 
providing loans and participating in 
the PPP programs administered by the 
U.S. government. We also participated 
in a number of other government-
supported programs outside the U.S. 
and developed solutions to assist 
clients in need throughout the crisis.

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.

In 2020, Citi retained our ranking as the 
World’s Largest Fixed Income Dealer 
for the fifth straight year, according 

to Greenwich Associates’ Annual 
Benchmark Survey, which polled more 
than 3,500 fixed income investors 
around the world. Citi’s leading market 
position is driven by our strength in 
both Rates and Emerging Markets, 
ranked #1, respectively, along with the 
top spot in Municipal Bonds. In addition 
to the distinction of being overall 
share leader, Citi ranked #1 in Overall 
Quality, Sales Quality, Trading Quality 
and e-Trading market penetration. Citi 
was also named Largest Affordable 
Housing Lender in the country for the 
11th year in a row in Affordable Housing 
Finance magazine’s annual survey of 
affordable housing lenders. Partnering 
with developers, nonprofits and local 
governments, Citi has helped create or 
preserve nearly 488,000 affordable 
housing units over the past decade. 
In 2020, Citi Community Capital, the 
bank unit through which Citi works to 
finance all types of affordable housing 
and community development projects, 
reported more than $7 billion of  
lending to finance affordable rental 
housing projects. 

Citi Velocity®, Citi’s #1 ranked digital 
content platform for Institutional 
Clients, delivers electronic access 
to Citi’s capital markets services 
across equities, futures, FX, emerging 
markets, rates, credit, commodities, 
securitized products, municipals, 
securities services and research 
spanning thousands of content 
creators and apps. Nearly 100,000 
Institutional Clients spread over 
almost 150 countries use Citi Velocity 
on a regular basis across all asset 
classes. 2020 was the Citi Velocity 

platform’s strongest year since its 
2011 launch. In addition to pricing 
millions of derivative instruments 
and supporting half a billion data 
interactions, Citi Velocity made a big 
push into the audiovisual content 
and mobile space. We hosted 1,850 
webcasts that were attended by more 
than 100,000 clients, an increase of 
200% year-over-year. We produced 
over 3,100 videos and podcasts, 28% 
more than in prior years. The platform 
saw mobile growth soar 57%, while 
the number of unique client users 
grew 9%. While Citi Velocity was laser 
focused on being the best digital 
product for our clients, it was also used 
to offer clients and colleagues some 
respite from the year’s events. Citi 
Velocity streamed two concert series in 
2020, in partnership with the London 
Philharmonia, which became the most 
popular video content of the year.

In May 2020, Proxymity, a digital 
investor communications platform 
developed within Citi’s Institutional 
Clients Group, was spun off into 
a standalone entity that raised 
$20.5 million in a strategic round 
of investment led by Citi Ventures, 
with participation from a global 
industry consortium. Proxymity’s 
services include a digital, real-time 
and fully transparent proxy voting 
platform, providing post-meeting vote 
confirmation and giving investors up 
to nine additional days per meeting 
to research and vote. Proxymity 
also offers a shareholder disclosure 
platform that automates shareholder 
ID requests and eliminates the need 
for any manual handling. The idea for 

2

10

11

Citi becomes first 
American bank and first 
among world’s top five 
custodians to be awarded 
domestic fund custody 
license in China

CEO Michael Corbat 
announces plans to retire 
in February; Board of 
Directors selects Jane 
Fraser to succeed him  
as CEO

Citi Retail Services and 
Wayfair announce new 
strategic partnership with 
launch of private label and 
co-brand credit cards

17

Citi and Citi Foundation 
expand global job 
skills-building initiative 
Pathways to Progress to 
improve employability and 
economic opportunity for 
underserved communities

15

Proxymity was formulated in 2017 by 
two Markets and Securities Services 
colleagues as a way for issuers to 
better communicate with investors. 
As the idea for the platform evolved, 
D10X, an internal strategic growth 
model that enables employees to take 
new business ideas from concept to 
launch, helped Proxymity iterate and 
evaluate its vision to improve the proxy 
voting system. From there, the Citi 
Innovation Lab in Tel Aviv developed 
Proxymity into a market-ready 
offering in less than two years using 
a Lean team model and rapid, agile 
development. Citi is incredibly proud 
of what Proxymity has been able to 
achieve thus far and looks forward to 
continuing to support the platform as a 
member of the consortium.

In 2020, Citi entered into an alliance 
with BlackRock, through its Aladdin® 
business, to enhance the delivery of 
securities services to Citi’s clients 
who use the Aladdin end-to-end 
investment management platform. 
Connecting to Aladdin Provider, 
Citi will provide outsourced middle-
office services directly on a client’s 
instance of Aladdin for seamless 
integration with the front office, 
from trade confirmation to post-
settlement reconciliation. This 
agreement expands Citi’s relationship 
with BlackRock, to whom we provide 
custody, accounting and/or fiduciary 
services for certain BlackRock funds 
domiciled in Hong Kong, Mexico 
and Colombia. In addition to funds 
managed by BlackRock, Citi provides 
custody services to many asset 
managers on the Aladdin platform. 
Joining the Aladdin Provider network 

will allow Citi to optimize our operating model to support not only BlackRock’s 
asset management business but to provide an enhanced level of service to 
members of the broader Aladdin community.

Private Bank
The Private Bank is dedicated to helping the world’s wealthiest individuals, families 
and law firms protect and responsibly grow their wealth. 

From 50 locations worldwide, we serve more than 13,000 ultra-high net worth 
clients hailing from over 100 countries, including 25% of the world’s billionaires 
and more than 1,400 family offices. In 2020, total client business amounted to 
around $550 billion.

Our unique business model enables us to focus on fewer, larger and more 
sophisticated clients with 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. Citi Private Bank’s close partnership with Citi’s Institutional 
Clients Group means we can connect clients’ businesses to banking, capital markets 
and advisory services, as well as to Citi’s other institutional resources.

A growing number of our clients seek to align their investments with their personal 
values. Investing with Purpose is what we call our approach to sustainable and 
impactful investing. We help clients articulate their sustainability goals and 
objectives, provide them with comprehensive advice and offer in-house investment 
management that incorporates environmental, social and corporate governance 
principles. We also partner with third-party asset managers to deliver relevant 
themes and strategies.

In 2020, we transformed our flagship annual Family Office Leadership Program — 
often described by participants as “the Davos for family offices” — into a virtual 
summit. Sessions this year covered vital topics that include sustainable investing, 
advances in family healthcare practices, future of energy and the building of 
resilient families. Nearly 6,000 participants from 100+ countries took part in  
the program. 

We also launched the Direct Private Investments business to identify opportunities 
for family offices and private investment company clients to actively invest in 
direct private deals.

Treasury and Trade Solutions 
Treasury and Trade Solutions (TTS) 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 

SEPTEMBER

18

New Citi Impact Fund 
announces first four 
investments in double 
bottom-line companies

23

Citi launches Action for 
Racial Equity with more 
than $1 billion in strategic 
initiatives to help close 
racial wealth gap

23

29

At the 2020 GlobalCapital 
Derivatives Awards, Citi 
awarded House of the  
Year for Global Derivatives, 
Global FX Derivatives  
and Global Research & 
Strategy

With plans to double 
market share in 
Singapore’s wealth 
segment, Citi announces 
the opening of its largest 
wealth hub globally  
in Singapore 

16

2020way in delivering innovative and tailored 
solutions to clients. 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 digital 
capabilities, client advocacy, network 
management and service delivery 
across the entire organization.

Our digital transformation accelerated 
in 2020 with increased momentum in 
client engagement and digital adoption 
as evidenced by strong growth in 
CitiDirect BE® users, API volumes 
and digital account openings. Digital 
Onboarding is now live in 50 countries, 
and CitiDirect BE users were up 9% 
versus the prior year. Additionally, we 
delivered to the market 83 live APIs 
that collectively reached 1 billion API 
calls since inception.

Citi’s digital channels remain pivotal 
in helping clients with operational 
resiliency while continuing to operate 
in remote or continuity-of-business 
modes. Digital Onboarding enabled 
clients around the world to set up 
accounts using eSignatures and 
overcome major obstacles due to  
the pandemic.

With Instant Payments becoming a 
new norm, enabling our clients to 
disrupt their business model and shift 
toward a 24/7, always-on environment, 
we continue to invest in building a 
globally consistent Instant Payments 
proposition, having launched the 
capability in six additional markets in 
2020, taking our global presence to 26 
markets. Our global volumes have seen 
a growth of more than 70% year-over-

In 2020, as part of an effort to help to accelerate the global economic recovery, Citi joined 
CEMEX, Telefónica and 11 other companies and academic institutions to launch Restarting 
Together, a challenge that invited startups and small and medium-sized enterprises from across 
the world to find innovative projects to revamp our economies, enhance our cities and move 
society forward in response to the COVID-19 pandemic. The initiative was designed to contribute 
to a fast economic recovery and to create a more resilient society, as well as to reduce 
structural societal inequalities exacerbated by such crises.

More than 500 startups from 59 countries entered the challenge, and three winners were 
provided the opportunity to access mentoring and events, technology tools and acceleration 
services from the companies, including Citi, which supported the challenge. Restarting Together 
is an excellent representation of Citi’s ongoing commitment to our mission of enabling growth 
and economic progress, as we seek to find new ways to solve problems.

year and are rapidly approaching the 
million daily transaction mark. With 
an ambitious road map to continue to 
expand our footprint and capabilities, 
we are very well positioned for another 
exciting and successful year in 2021.

In October 2020, in support of U.S.-
based suppliers affected by COVID-19, 
we worked with the U.S. EXIM Bank 
to create facilities, including the 

guarantee of a $500 million facility 
by EXIM that allows Citi to finance 
accounts receivable from The Boeing 
Company to its U.S.-based suppliers. 
The agreement also includes the 
preliminary approval of a $327 million 
facility for the purchase of Boeing 
aircraft by Copa Airlines, exported 
from Renton, Washington.

29

Citi’s partnership with 
United Nations Development 
Programme strengthens 
across Asia, aiding the most 
vulnerable and marginalized 
communities across 
the region

OCTOBER

1

Citi hosts second 
symposium for students 
attending Historically 
Black Colleges and 
Universities 

6

Citi recognized as Best 
Corporate Bank by Global 
Finance magazine

14

Citi becomes the only 
U.S. bank named to The 
Wall Street Journal’s 
inaugural list of the 100 
Most Sustainably Managed 
Companies in the World

17

Environmental, Social  
and Governance

Through our business, we address some of 
society’s greatest challenges — an imperative 
stated in our mission and an idea that shapes 
our decisions every day. The need for action 
grew in urgency and scope in 2020 with 
the onset of the COVID-19 pandemic and a 
movement toward racial equity and systemic 
change in the U.S.

This section highlights our continued efforts as a bank, an employer and a 
philanthropist to address these societal issues and many others. Citi has the 
scale and capability 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. 

In the midst of the global pandemic, we launched our new 2025 Sustainable 
Progress Strategy to address another global crisis: climate change. Our 
new strategy, which had been in the works well before COVID-19 began its 
catastrophic spread, is aimed at driving the transition to a sustainable, low-
carbon future in an environmentally responsible way that serves society’s 
economic needs. COVID-19 became an accelerant for our work, illustrating 
the deep interconnections of systemic racism and societal, physical and 
environmental health.

Once a niche topic for investors, Environmental, Social and Governance (ESG) 
performance today is an essential part of our firm-wide strategy — deeply 
integrated into our business — and we continue to evolve our approach to 
managing ESG issues and opportunities.

Sustainable Growth and 
Climate Change 
The climate crisis is one of the most 
critical challenges facing our global 
society and economy. The science is 
irrefutable, and the world’s climate 
scientists agree that urgent action must 
be taken to address the current and 
potential impacts of climate change.

Since the onset of COVID-19, we 
have been continually reminded of 
the inextricable links between our 
health, economic success and the 
environment. Amid the pandemic, 
we launched our 2025 Sustainable 
Progress Strategy to accelerate 
our work in addressing the climate 
crisis, with the ambition to play a 
leading role in driving the transition 
to a low-carbon economy. As a global 
financial institution, we recognize the 
opportunity and obligation to drive 
capital to where it can have the most 
positive impact.

The core of our new five-year 
strategy consists of a commitment to 
finance and facilitate $250 billion in 
environmental projects and activities. 
This is an ambitious target that 
represents a commitment two-and-a-
half times larger than our prior goal, 
and which we aim to achieve in half 
the time. To support our $250 billion 
goal, we are financing activities in 
renewable energy, clean technology, 
water quality and conservation, 
sustainable transportation, green 
buildings and energy efficiency and 
have added circular economy and 
sustainable agriculture and land use as 
two additional areas under this goal. 

OCTOBER

14

Citi ranked #31 on Just 
Capital and Forbes’ annual 
list of America’s JUST  
100 companies

19

Citi launches True Name 
feature with Mastercard 
across the U.S., offering 
transgender and non-
binary people the ability to 
use their chosen first name 
on eligible credit cards

26

30

Citibanamex, PepsiCo 
and Amigo PAQ expand 
digital financial inclusion 
for underbanked retailers 
through CoDi®

Citi announces  
inaugural $2.5 billion 
affordable housing bond 
issuance, the largest-ever 
social bond

18

2020of goals focused on greenhouse gas 
emissions, energy, water and waste 
reduction targets and sustainable 
building solutions.

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

Financial Inclusion and 
Access to Capital 
The past year has brought to the 
forefront the long-standing social, 
economic and racial inequities that 
have faced our communities. As a 
financial institution with a long history 
of commitments to support resilient 
and inclusive communities, we 
challenged ourselves to look at how 
we can do things differently.

Since the onset of COVID-19, we have 
been adjusting our approach to meet 
the immediate needs and challenges 
posed by the health crisis while 
staying focused on our longer-term 
strategic initiatives of increasing 
affordable housing, boosting minority- 
and women-owned businesses, and 
expanding financial inclusion globally. 

By the end of 2020, Citi and Citi 
Foundation had committed more than 
$100 million in support of COVID-19-
related community relief and economic 
recovery efforts globally. Funding was 
provided to support our most affected 
communities around the world, from 
food donations and housing stability 
loans to personal protective equipment 
and COVID-19 screening efforts. Our 
efforts were complemented by more 
than $2 million in contributions from 
our colleagues, which was matched 
by Citi for an additional $2 million 

Citi continues to be a leader in project finance, financing a number of infrastructure and 
renewable energy transactions. Citi acted as a mandated lead arranger for a $704 million 
financing package to develop the Highlander Solar Facility* in Spotsylvania County, Virginia. 
The Highlander Solar Facility was developed by sPower, which merged with AES’ clean energy 
business in early 2021. When completed, it will be the largest solar project in the eastern U.S., 
totaling 485 megawatts of power with alternating current of renewable power. Highlander 
Solar is strategically located approximately 50 miles from northern Virginia’s Data Center 
Alley in the Dulles Technology Corridor, home to the world’s largest concentration of data 
centers. Renewable energy generated by the facility will help blue chip technology companies, 
including Microsoft and Apple, with the significant electric load requirements of their data 
centers while advancing their corporate sustainability and climate change goals.

*The Highlander Solar Facility is also known as Spotsylvania Solar Energy Center.

We will continue to focus on helping 
our clients across all sectors in their 
transition, no matter where they are in 
their sustainability journey, to shift to 
more sustainable business models and 
practices that will advance our progress 
toward a low-carbon economy.

Another key aspect of enabling this 
transition is measuring, managing 
and reducing the climate risk and 
impact of our client portfolio, which 
is a key pillar of our 2025 Sustainable 
Progress Strategy. Citi has been a 
leader in climate assessment and 
disclosure in alignment with the Task 
Force on Climate-related Financial 
Disclosures recommendations and 
released our second comprehensive 
report in December 2020 detailing our 

progress. In addition to embedding 
this work across Citi, we’re continuing 
to focus on industry collaboration 
to adopt new methodologies and 
analyze the climate risk associated 
with our client portfolio, such as the 
Paris Agreement Capital Transition 
Assessment and the Partnership for 
Carbon Accounting Financials. 

Our new strategy also builds on our 
20 years of experience measuring and 
reducing the environmental footprint 
of our own facilities and operations. 
As of the end of 2020, we achieved 
our goal of sourcing 100% renewable 
electricity to power our facilities 
globally, along with our third set of 
operational footprint goals. Looking 
ahead, we’ve launched our next set 

NOVEMBER

2

Citi selected as financial 
advisor to Gavi, the 
Vaccine Alliance’s  
multibillion dollar  
COVAX Facility

6

At the PWM/The Banker 
Awards, Citi named Best 
Private Bank for Customer 
Service, for Global Families 
and Family Offices, and for 
Business Continuity Plans 
(COVID-19)

9

Citi virtually hosts 10th 
annual Veterans on Wall 
Street Symposium 

18

Citi unveils sneak  
preview of Citi® PlexTM 
Account by Google Pay; 
selects Mastercard as 
network partner

19

through an employee donation program. Recognizing the disproportionate impact 
that COVID-19 has had on low-income communities and communities of color, Citi 
announced it would donate net profits from our participation in the U.S. Small 
Business Administration’s Paycheck Protection Program to the Citi Foundation.  
The Foundation deployed $25 million of these proceeds to Community 
Development Financial Institutions across the U.S. to support small businesses 
and economically vulnerable households impacted by the pandemic. In 2021, the 
Foundation announced an additional $25 million investment to support small 
businesses owned by people of color.

As calls for racial justice intensified across the U.S., Citi launched Action for Racial 
Equity — a firm-wide commitment that includes more than $1 billion in strategic 
initiatives to help close the racial wealth gap and increase economic mobility. This 
initiative was launched in tandem with the release of a new Citi Global Perspectives 
& Solutions report, which showed that if the U.S. had closed critical racial gaps  
for Black Americans in wages, housing, education and investment 20 years ago,  
$16 trillion could have been added to the U.S. economy. To help close these 
gaps, we are focusing on providing greater access to banking and credit in 
communities of color, increasing investment in Black-owned businesses, expanding 
homeownership among Black Americans and advancing anti-racist practices in the 
financial services industry. Action for Racial Equity represents an unprecedented 
effort to leverage Citi’s core business capabilities and the Citi Foundation’s 
philanthropic efforts to change the way we operate and drive systemic change.

As part of our racial equity efforts, 
we allocated an additional $50 million 
to the Citi Impact Fund to exclusively 
support Black entrepreneurs. Since 
launching in early 2020, the Impact 
Fund has made investments in 11 
companies — the majority of which 
were founded by women and/or people 
of color — that are addressing some of 
society’s biggest challenges.

Since 2007, Citi provided more than  
$1 billion in financial inclusion lending 
and supported nearly 4 million 
unbanked and underbanked small 
businesses in emerging markets, 
3.5 million of which are owned by 
female entrepreneurs. Last year, we 
completed two transactions under 
Scaling Enterprise, a partnership 
launched with the U.S. International 
Development Finance Corporation and 
the Ford Foundation in 2019, through 
which we provide early-stage financing 
to companies that expand access to 
products and services for low-income 
individuals in emerging markets. For 
example, Citi disbursed a working 
capital facility to support Gradian 
Health Systems, a medical technology 
company that provides critical 
equipment to underserved hospitals 
and clinics across Africa. 

Furthering the Citi Foundation’s 
commitment to address youth 
unemployment, a persistent global 
issue exacerbated by the economic 
impacts of COVID-19, the Foundation 
expanded its Pathways to Progress 
job skills-building initiative in 2020. 

NOVEMBER

19

Global Finance names 
Citi World’s Best Foreign 
Exchange Bank and 
recognizes Citi Latin 
America among inaugural 
Crisis Leadership program 
for its pandemic response

19

Citi Foundation provides 
$15 million in support 
to 30 Community 
Development Financial 
Institutions across  
the U.S.

DECEMBER

2

Citi named World’s Best 
Digital Bank 2020 by 
Global Finance magazine

3

Citi ranked ninth overall 
and first in the financial 
sector among Newsweek’s 
list of America’s Most 
Responsible Companies

20

2020Pathways to Progress aims to equip young people, particularly those from 
underserved communities, with the skills and resources they need to succeed in a 
rapidly changing economy. In addition, the expanded initiative includes a company-
wide commitment to provide 10,000 young adults with the opportunity to gain 
work experience at Citi and engage 10,000 Citi colleagues to volunteer their time 
and talent to serve as mentors, coaches and role models.

We have made it a priority to foster a culture of 
inclusion where the best people want to work, 
where people are promoted on their merits, where 
we value and demand respect for others, and where 
opportunities to develop are widely available to all.

Talent and Diversity 
Four years ago, Citi was the first bank to disclose our adjusted pay results, and the 
following year we became one of the first companies to disclose our unadjusted 
or “raw” pay gap for both women and U.S. minorities. Our commitment to that 
transparency continues today.

These disclosures hold us accountable for the progress we want to make in being 
a diverse and inclusive company. They also send an important signal to our 
colleagues, clients and partners about how we are continuously working to get this 
right. We looked at both numbers again this year and found that, on an adjusted 
basis, women globally are paid on average more than 99% of what men are paid at 
Citi and that there is no statistically significant difference in adjusted compensation 
for U.S. minorities and non-minorities. Following our review, we made appropriate 
pay adjustments as part of this year’s compensation cycle.

This year’s raw gap analysis showed that the median pay for women globally is 
better than 74% of the median for men, up from 73% last year and 71% in 2018 
and that the median pay for U.S. minorities is just under 94% of the median for 
non-minorities, which is similar to last year and up from 93% in 2018. Continuing 
to reduce our raw pay gap requires that we make progress on our representation 
goals — to increase representation at the Assistant Vice President (AVP) through 
Managing Director levels to at least 40% for women globally and 8% for Black 
employees in the U.S. by the end of 2021 — which we are committed to doing.

For our part, we’re continuing to 
innovate how we recruit and develop 
talent and use data more effectively 
to help us increase diversity at more 
senior levels at Citi. We recently 
launched a firm-wide exercise where 
our 200+ leaders with representation 
goals on their scorecards are using 
data to understand where they have 
representation gaps in their hiring, 
promotions and retention. Diverse 
slates have been a critical component 
of our work. In 2021, we expanded 
our slate practice from at least one 
to at least two women or minorities 
in our interviews for U.S. hires and at 
least two women in our interviews for 
global hires. 

We are expanding our group coaching 
program, Owning My Success, for top 
and emerging Black talent this year, 
extending the program from three to 
six months and offering it to all levels, 
including the Officer and AVP levels 
for the first time. In the first two years 
of the program, 150 Black colleagues 
have been a part of the program, 
participating in coaching and discussion 
on topics such as developing one’s 
personal brand, networking and taking 
career risks. As part of the program, 
participants’ managers engage in 
group coaching to help them support 
their Black direct reports and better 
understand their experiences.

Our philosophy is that every member 
of Citi’s team is responsible for this 
progress in making Citi an even more 
inclusive and equitable workplace.

3

Citi Markets and 
Securities Services 
donates $9.4 million  
to education-focused  
nonprofit organizations, 
part of annual e for 
education campaign

16

Citi Asia Pacific sets 
record for net new  
money in its Wealth 
Management business

17

Citi releases climate 
disclosure report showing 
progress in implementing 
the recommendations 
of the Task Force on 
Climate-related Financial 
Disclosures

21

Citi launches first lending 
API partnership with Grab, 
Southeast Asia’s leading 
super app

21

B:8.625"

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OUR ACTIONS SPEAK LOUDER 
THAN THESE WORDS.

Citi has a long-standing commitment to closing the racial wealth gap,  
and now with Action for Racial Equity, we have launched more than  
$1 billion in strategic initiatives to accelerate those efforts across our lines  

of business. These efforts will provide greater access to banking and credit  

in communities of color, increase investment in Black-owned businesses, expand 

homeownership among Black Americans and advance anti-racist practices in the 

financial services industry. That way communities of color can build a stronger 

economic presence and progress toward a future that we can all believe in. 

Learn more about Citi’s Action for Racial Equity at 

Citi.com/racialequity

S

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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, 2020 

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

52-1568099

(State or other jurisdiction of incorporation or organization)
388 Greenwich Street,  New York NY
(Address of principal executive offices)

(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 o				No x

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 o    No x

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 x    No o

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 x     No o

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 o    

Indicate by check mark whether the Registrant has filed a report on and attestation to its management’s assessment of the effectiveness of its internal control 
over financial reporting under Section 404(b) of the Sarbanes-Oxley Act (15 U.S.C. 7262(b)) by the registered public accounting firm that prepared or issued 
its audit report. ☒

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act). Yes ☐    No x

The aggregate market value of Citigroup Inc. common stock held by non-affiliates of Citigroup Inc. on June 30, 2020 was approximately $106.2 billion.

Number of shares of Citigroup Inc. common stock outstanding on January 31, 2021: 2,087,317,952 

Documents Incorporated by Reference: Portions of the registrant’s proxy statement for the annual meeting of stockholders scheduled to be held on April 27, 
2021 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

Part III

4–31, 123–128,
131, 162,
312–313

10.

Directors, Executive Officers 
and Corporate Governance

316–318*

**

***

****

*****

1A. Risk Factors

49–61

1B. Unresolved Staff Comments

Not Applicable

Properties

Not Applicable

2.

3.

Legal Proceedings—See 
Note 27 to the Consolidated 
Financial Statements

11.

Executive Compensation

12.

13.

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

Certain Relationships and 
Related Transactions and 
Director Independence

291–298

14.

Principal Accounting Fees 
and Services

Part IV

15.

Exhibits and Financial 
Statement Schedules

* 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 27, 2021, 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 “2020 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,” “Equity 
Compensation Plan Information,” and Delinquent Section 16(a) 
Reports 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.

4.

Mine Safety Disclosures

Not Applicable

Part II

5.

6.

7.

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

142–143, 168–170, 
314–315

Selected Financial Data

14–15

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

6–31, 66–122

7A. Quantitative and Qualitative 

Disclosures About Market 
Risk

66–122, 163–167, 
187–223, 230–282

8.

9.

Financial Statements and 
Supplementary Data

138–311

Changes in and 
Disagreements with 
Accountants on Accounting 
and Financial Disclosure

Not Applicable

9A. Controls and Procedures

129–130

9B. Other Information

Not Applicable

2

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CITIGROUP’S 2020 ANNUAL REPORT ON FORM 10-K 

OVERVIEW

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

Executive Summary

Citi's Consent Order Compliance

COVID-19 Pandemic Overview

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

CAPITAL RESOURCES

RISK FACTORS
HUMAN CAPITAL RESOURCES AND 
  MANAGEMENT

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

8

9

14

16
17
18
20
22
24
26
31

32

49

62

65

66

123

129

130

131

132

137

138

146

311

312

316

316

317

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, 2020, Citi had approximately 210,000 

full-time employees, compared to approximately 200,000 full-
time employees at December 31, 2019. For additional 
information, see “Human Capital Resources and 
Management” below.

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 2019 versus 2018 results of operations 

of GCB in North America, Latin America and Asia, ICG and 
Corporate/Other, see each respective business’s results of 
operations in Citi’s 2019 Annual Report on Form 10-K.

Certain reclassifications have been made to the prior 
periods’ financial statements and disclosures to conform to the 
current period’s presentation. 

Please see “COVID-19 Pandemic Overview” and 
 “Risk Factors” below for a discussion of the trends, 
uncertainties and material risks 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. 

5

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

EXECUTIVE SUMMARY 
As described further throughout this Executive Summary, 
during 2020, Citi demonstrated solid performance as well as 
financial strength and operational resilience, despite a 
significant deterioration in public health and economic 
conditions during the year due to the COVID-19 pandemic:

•

•

•

•

•

•

•

Citi’s earnings were substantially reduced by a higher 
allowance for credit loss (ACL) build (approximately $9.8 
billion) during the year under the CECL standard (see 
“Cost of Credit” below).
Despite the challenging environment, Citi’s revenues 
were largely unchanged from the prior year, as strong 
performance in fixed income markets, equity markets, 
investment banking and the private bank in Institutional 
Clients Group (ICG) offset the impact of lower interest 
rates across the Company, as well as the impact of lower 
customer activity in Global Consumer Banking (GCB), 
reflecting declines across all regions, and lower revenues 
in Corporate/Other.
Citi’s expenses reflected continued investments in its 
transformation, including infrastructure supporting its risk 
and control environment, as well as a $400 million civil 
money penalty in the third quarter of 2020 in connection 
with a consent order Citibank entered into with the Office 
of the Comptroller of the Currency (OCC) (for additional 
information on this consent order and the Citigroup 
consent order with the Federal Reserve Board, see “Citi’s 
Consent Order Compliance” below).
Citi had broad-based deposit growth across ICG and 
GCB, reflecting strong client engagement, as well as an 
elevated level of liquidity in the financial system, while 
loans declined reflecting lower levels of consumer and 
corporate activity.
Citi returned $7.2 billion of capital to its common 
shareholders in the form of dividends and common share 
repurchases.
The Federal Reserve Board authorized Citi to take certain 
capital actions during the first quarter of 2021, which 
allows Citi to return capital to common shareholders of up 
to $2.8 billion, including the previously announced 
common dividends of $0.51 per share in the quarter. Citi 
commenced share repurchases in February 2021.
Citi continued to support its colleagues, customers, clients 
and communities as well as the broader economy during 
this challenging time (see “COVID-19 Pandemic 
Overview” below), while maintaining a strong balance 
sheet.

The economic outlook for 2021 reflects continued 

challenges and uncertainties related to the pandemic, 
including, among others, the duration and severity of the 
public health crisis and associated economic impacts, which 
have created a more volatile operating environment that will 
continue to negatively impact Citi’s businesses and results. 

As a result of new information Citi received subsequent to 
December 31, 2020, Citi adjusted downward its fourth quarter 

6

of 2020 financial results from those previously reported on 
January 15, 2021 (and filed on a Form 8-K with the SEC on 
such date), due to a $390 million increase in operating 
expenses ($323 million after-tax) recorded within ICG, 
resulting from operational losses related to certain legal 
matters. For additional information on the impact to fourth 
quarter of 2020 financial results, see Note 30 to the 
Consolidated Financial Statements. Citi’s results of operations 
and financial condition for the full year 2020, as reported in 
this Annual Report on Form 10-K for the year ended 
December 31, 2020, reflect the impact of this adjustment. 
For a discussion of risks and uncertainties that will or 

could impact Citi’s businesses, results of operations and 
financial condition during 2021, see “COVID-19 Pandemic 
Overview,” “Risk Factors,” each respective business’s results 
of operations and “Managing Global Risk” below. 

2020 Results Summary

Citigroup
Citigroup reported net income of $11.0 billion, or $4.72 per 
share, compared to net income of $19.4 billion, or $8.04 per 
share, in the prior year. Net income declined 43%, driven by 
significantly higher credit costs and higher expenses, while 
revenues remained largely unchanged. Earnings per share 
decreased 41%, primarily driven by the decline in net income. 

Citigroup revenues of $74.3 billion were largely 
unchanged from the prior year, as higher revenues in ICG 
offset lower revenues in GCB and Corporate/Other.

Citigroup’s end-of-period loans decreased 3% from the 

prior year to $676 billion. Excluding the impact of foreign 
currency translation into U.S. dollars for reporting purposes 
(FX translation), Citigroup’s end-of-period loans declined 4%, 
driven by a 4% aggregate decline in GCB and ICG, reflecting 
lower spend activity in GCB as well as a higher level of 
repayments in both GCB and ICG. Citigroup’s end-of-period 
deposits increased 20% to $1.3 trillion. Excluding the impact 
of FX translation, Citigroup’s end-of-period deposits increased 
19%, primarily driven by 18% growth in GCB and 19% 
growth in ICG. (Citi’s results of operations excluding the 
impact of FX translation are non-GAAP financial measures. 
Citi believes the presentation of its results of operations and 
financial condition excluding the impact of FX translation 
provides a meaningful depiction of the underlying 
fundamentals of its businesses for investors, industry analysts 
and others.)

Expenses
Citigroup operating expenses of $43.2 billion increased 3% 
versus the prior year, primarily driven by investments in Citi’s 
transformation, including infrastructure supporting its risk and 
control environment, higher compensation, the civil money 
penalty, operational losses related to certain legal matters and 
pandemic-related expenses, partially offset by efficiency 
savings and reductions in marketing and other discretionary 
spending. Operating expenses in GCB declined 2%, while ICG 

expenses increased 6% and Corporate/Other expenses 
increased 16%.

Cost of Credit
Citi’s total provisions for credit losses and for benefits and 
claims of $17.5 billion increased significantly from $8.4 
billion in the prior year, reflecting ACL reserve increases 
across GCB, ICG and Corporate/Other. Citi’s ACL build of 
$9.8 billion was largely driven by builds during the first half 
of 2020. The reserve build in 2020 primarily reflected the 
impact of a deterioration in Citi’s macroeconomic outlook 
under the CECL standard and downgrades in the corporate 
loan portfolio, partially offset by lower loan volumes in GCB, 
all driven by the pandemic. The reserve build included an 
additional qualitative management adjustment to reflect the 
potential for a higher level of stress and a slower economic 
recovery. For further information on the drivers of Citi’s ACL 
build, see “Significant Accounting Policies and Significant 
Estimates—Allowance for Credit Losses” below. For 
information on the transition impact of the adoption of the 
CECL standard, see “COVID-19 Pandemic Overview” below.
Net credit losses of $7.6 billion declined 2% from the 

prior year. Consumer net credit losses of $6.6 billion 
decreased 10%, primarily reflecting lower loan volumes given 
lower spending activity and higher payment rates, as well as 
the benefits of consumer relief programs (see “COVID-19 
Pandemic Overview” below). Corporate net credit losses 
increased from $392 million to $1.0 billion, primarily driven 
by write-offs across various sectors, which were partially 
offset by the release of previously established ACL reserves. 
For additional information on Citi’s consumer and 

corporate credit costs and ACL, see each respective business’s 
results of operations and “Credit Risk” below.

Capital
Citigroup’s Common Equity Tier 1 Capital ratio was 11.7% as 
of December 31, 2020, based on the Basel III Advanced 
Approaches framework for determining risk-weighted assets, 
compared to 11.8% as of December 31, 2019, based on the 
Basel III Standardized Approach for determining risk-
weighted assets. The decline in the ratio primarily reflected an 
increase in risk-weighted assets and the return of capital to 
common shareholders, partially offset by net income and 
beneficial net movements in Accumulated other 
comprehensive income (AOCI). 

Citigroup’s Supplementary Leverage ratio was 7.0% as of 

December 31, 2020, compared to 6.2% as of December 31, 
2019. The increase was primarily driven by a decrease in Total 
Leverage Exposure, reflecting the benefit of temporary relief 
granted by the Federal Reserve Board. For additional 
information on Citi’s capital ratios and related components, 
see “Capital Resources” below.

Global Consumer Banking
GCB net income of $878 million declined 85% from the prior 
year. Excluding the impact of FX translation, net income 
declined 84%, reflecting lower revenues and higher cost of 
credit, partially offset by lower expenses. GCB operating 
expenses of $17.2 billion decreased 2%. Excluding the impact 
of FX translation, expenses decreased 1%, as lower volume-

7

related expenses, reductions in marketing and other 
discretionary spending and efficiency savings were partially 
offset by increases in pandemic-related expenses and higher 
repositioning costs. 

GCB revenues of $30.0 billion decreased 9%. Excluding 

the impact of FX translation, revenues decreased 8%, as strong 
deposit growth and momentum in wealth management were 
more than offset by lower card volumes and lower interest 
rates across all regions, reflecting the impact of the pandemic. 
North America GCB revenues of $19.1 billion decreased 
6%, with lower revenues across Citi-branded cards, Citi retail 
services and retail banking. Citi-branded cards revenues of 
$8.8 billion decreased 4%, reflecting lower purchase sales and 
higher payment rates driving lower average loans. Citi retail 
services revenues of $5.9 billion decreased 12%, reflecting 
lower average loans as well as higher partner payments. Retail 
banking revenues of $4.5 billion decreased 2%, as the benefit 
of stronger deposit volumes and an improvement in mortgage 
revenues were more than offset by lower deposit spreads.
North America GCB average deposits of $176 billion 
increased 15% year-over-year, average retail banking loans of 
$52 billion increased 8% year-over-year and assets under 
management of $80 billion increased 11%. Average Citi-
branded cards loans of $85 billion decreased 6% and Citi-
branded cards purchase sales of $338 billion decreased 8%, 
while average Citi retail services loans of $47 billion 
decreased 7% and Citi retail services purchase sales of $78 
billion decreased 11%. The decline in Citi-branded cards and
retail services loans and purchase sales were all driven by
reduced customer activity related to the pandemic. For 
additional information on the results of operations of North 
America GCB in 2020, 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 $10.8 billion declined 14% 
versus the prior year. Excluding the impact of FX translation, 
international GCB revenues declined 10%, largely reflecting 
the impact of the pandemic. On this basis, Latin America GCB 
revenues decreased 8%, driven by lower average loans and 
lower interest rates, partially offset by strong deposit growth. 
Asia GCB revenues decreased 11%, as lower card revenues 
and the impact of lower interest rates were partially offset by 
strong investment revenues and strong deposit growth. For 
additional information on the results of operations of Latin 
America GCB and Asia GCB in 2020, 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 $135 billion increased 
11%, average retail banking loans of $72 billion increased 3% 
and assets under management of $141 billion increased 8%. 
On this basis, international GCB average card loans of $22 
billion decreased 8% and card purchase sales of $88 billion 
decreased 16%, both driven by reduced customer activity 
related to the pandemic.

$2.5 billion increased significantly, as the wind-down of 
legacy assets was more than offset by investments in 
infrastructure, risk management and controls, the civil money 
penalty and incremental costs associated with the pandemic. 

Corporate/Other revenues of $54 million compared to 
$2.0 billion in the prior year, reflecting the impact of lower 
interest rates, episodic gains in the prior year, the wind-down 
of legacy assets and marks on securities. For additional 
information on the results of operations of Corporate/Other in 
2020, see “Corporate/Other” below.

CITI’S CONSENT ORDER COMPLIANCE
As previously disclosed, Citi is embarking on a multiyear 
transformation, with the target outcome to change Citi’s 
business and operating models such that they simultaneously 
strengthen risk and controls and improve Citi’s value to 
customers, clients and shareholders. 

One part of the broader transformation effort involves 

Citi’s compliance with the Federal Reserve Board and OCC 
consent orders issued with Citigroup and Citibank, 
respectively, in October 2020. The consent orders require that 
Citigroup and Citibank submit acceptable plans to the Federal 
Reserve Board and the OCC, on various timelines, relating 
principally to various aspects of risk management, 
compliance, data quality management and governance, and 
internal controls. The consent order with the OCC also 
required Citibank to pay a $400 million civil money penalty. 
As a part of its compliance actions, Citi has centralized its 
program management under the leadership of a Chief 
Administrative Officer organization and is making the 
strengthening of its risk and control environment a further 
strategic priority for the Company. The Citigroup and Citibank 
Boards of Directors each formed a Transformation Oversight 
Committee, an ad hoc committee of each Board, to provide 
oversight of management’s remediation efforts under the 
consent orders.

For additional information about the consent orders, see 
“Risk Factors—Compliance Risks” below and Citi’s Current 
Report on Form 8-K filed with the SEC on October 7, 2020. 

Institutional Clients Group
ICG net income of $11.7 billion decreased 9%, as revenue 
growth was more than offset by higher cost of credit and 
higher expenses. ICG operating expenses increased 6% to 
$23.5 billion, largely driven by investments in infrastructure 
and risk management and controls, higher compensation costs, 
operational losses related to certain legal matters and volume-
driven growth, partially offset by efficiency savings.

ICG revenues of $44.3 billion increased 13%, reflecting a 

29% increase in Markets and securities services revenues, 
partially offset by a 1% decline in Banking revenues. The 
decrease in Banking revenues included the impact of $51 
million of losses on loan hedges related to corporate lending 
and the private bank, compared to losses of $432 million 
related to corporate lending in the prior year.

Banking revenues of $21.2 billion (excluding the impact 

of losses on loan hedges) decreased 3%, as increases in 
investment banking and the private bank were more than 
offset by declines in treasury and trade solutions and corporate 
lending. Investment banking revenues of $5.8 billion increased 
11%, reflecting solid growth in capital markets, particularly in 
equity underwriting. Advisory revenues decreased 20% to 
$1.0 billion, while equity underwriting revenues increased 
64% to $1.6 billion and debt underwriting revenues increased 
7% to $3.2 billion.

Treasury and trade solutions revenues of $9.5 billion 
declined 7%, and 5% excluding the impact of FX translation, 
as strong client engagement and growth in deposits were more 
than offset by lower interest rates and reduced commercial 
card spend largely driven by the pandemic. Private bank 
revenues of $3.8 billion increased 9%. Excluding the impact 
of gains on loan hedges, private bank revenues of $3.7 billion, 
increased 8%, driven by increased capital markets activity and 
improved managed investments revenues, as well as higher 
lending and deposit volumes, partially offset by lower deposit 
spreads. Corporate lending revenues of $2.1 billion declined 
15%. Excluding the impact of losses on loan hedges, corporate 
lending revenues of $2.2 billion declined 25%, as higher 
average loan volumes were more than offset by lower spreads, 
higher hedging costs and an adjustment to the residual value of 
a lease financing asset.

Markets and securities services revenues of $23.1 billion 

increased 29%. Fixed income markets revenues of $17.3 
billion increased 34%, reflecting strength in rates and 
currencies, spread products and commodities. Equity markets 
revenues of $3.6 billion increased 25%, as solid performance 
in cash equities and derivatives was partially offset by lower 
revenues in prime finance. Securities services revenues of $2.5 
billion decreased 3%, and 1% excluding the impact of FX 
translation, as higher deposit volumes were more than offset 
by lower spreads. For additional information on the results of 
operations of ICG in 2020, see “Institutional Clients Group” 
below.

Corporate/Other
Corporate/Other net loss was $1.6 billion, compared to net 
income of $801 million in the prior year, reflecting lower 
revenues, increased expenses, higher cost of credit, driven by 
an ACL build on Citi’s residual legacy portfolio under the 
CECL standard, and lower tax benefits. Operating expenses of 

8

COVID-19 PANDEMIC OVERVIEW
In addition to the widespread public health implications, the 
COVID-19 pandemic has had an extraordinary impact on 
macroeconomic conditions in the U.S. and around the world. 
As discussed below and elsewhere throughout this Form 10-K, 
Citi’s businesses, results of operations and financial condition 
have been impacted by economic dislocations and trends 
caused by the pandemic. Citi had builds to its allowance for 
credit losses (ACL) of approximately $9.8 billion during 2020, 
bringing its total ACL to approximately $27.8 billion at 
December 31, 2020, with an allowance for credit losses on 
loans (ACLL) reserve ratio of 3.73% on funded loans. For 
additional information, see “Impact of CECL on Citi’s 
Allowance for Credit Losses” below.

Despite these impacts, Citi has maintained strong capital 

and liquidity positions with consistently strong business 
operations. At December 31, 2020, Citi had a Common Equity 
Tier 1 Capital ratio of 11.7%, a Supplementary Leverage ratio 
of 7.0% and a Liquidity Coverage ratio of 118%, each well 
above regulatory minimums, with approximately $972 billion 
of available liquidity resources (see “Capital Resources” and 
“Managing Global Risk—Liquidity Risk” below). 

Governments and central banks globally have taken a 
series of aggressive actions to support their economies and 
mitigate the systemic impacts of the pandemic, and Citi 
continues to proactively assess and utilize these measures 
where appropriate.

Citi’s COVID-19 Pandemic Response—Supporting 
Colleagues, Customers and Communities
The health and safety of Citi’s employees and their families, 
as well as Citi’s customers, clients and the communities it 
serves, are of the utmost importance. As the public health 
crisis has unfolded, Citi has continued to take proactive 
measures to support colleagues’ well-being while maintaining 
its ability to serve customers and clients.

Citi Colleagues
•

The majority of Citi colleagues—roughly 80%—around 
the world are working remotely, however this varies by 
country.
Citi is pursuing a slow and measured return in locations 
where local guidelines permit, beginning with only a 
small number of colleagues.
Citi’s response teams continue to consult with health 
experts and follow local government guidelines in 
determining the safest return to office for each location. 
Citi has reconfigured its sites and implemented new 
protocols to make work environments as safe as possible 
in offices, branches and ATMs. 
Citi continues to provide additional health and well-being 
resources for colleagues, plus enhanced flexibility and 
paid time off for those impacted by COVID-19.
The company continues to monitor the situation as it 
evolves and will review and update operations as needed.

•

•

•

•

•

Citi Communities
In addition to its business activities, including the consumer 
relief programs discussed below, Citi is supporting those 
immediately impacted by the pandemic through philanthropic 
efforts around the world. Citi and the Citi Foundation have 
committed more than $100 million to date in support of 
COVID-19-related community relief and economic recovery 
efforts globally. These contributions include over $4 million 
raised through an employee donation matching program to 
further global relief efforts. Additionally, Citi has donated $50 
million in proceeds from its participation in the U.S. Small 
Business Administration’s Paycheck Protection Program 
(PPP) to the Citi Foundation, which deployed those proceeds 
to support Community Development Financial Institutions 
(CDFIs) across the U.S. 

Citi Consumer Loan Relief Programs
As previously disclosed, Citi was one of the first banks in the 
U.S. to announce temporary assistance measures for 
pandemic-impacted consumer customers. In addition, Citi has 
offered a wide array of short- and medium-term relief 
programs to customers across regions and products as a result 
of the pandemic. The relief has primarily been in the form of 
payment deferrals and fee waivers. These consumer relief 
programs have mainly been provided to GCB customers, with 
a small portion reported within Corporate/Other. To date, Citi 
has provided assistance to approximately three million U.S. 
consumers and small businesses impacted by the pandemic. 

In the fourth quarter of 2020, Citi experienced a decline in 

enrollment of approximately 21% quarter-over-quarter in its 
formal COVID-19 assistance programs. As a result of the 
significant and steady decline in enrollment, Citi ended the 
programs as of December 31, 2020 for the majority of 
countries and products. Continued COVID-19 assistance 
programs through Citi’s subservicer include extended 
mortgage payment deferrals through 2021 and suspended 
foreclosures into the first quarter of 2021 for U.S. mortgages. 
Citi remains committed to discussing assistance options with 
customers that continue to experience financial hardship on a 
case-by-case basis.

The table below provides information on the number of 

loan modifications, the associated enrollment and outstanding 
balances as of December 31, 2020, for Citi’s pandemic-related 
relief programs, excluding troubled debt restructurings (for 
additional information, see “Troubled Debt Restructuring 
(TDR) Relief” below).

9

For the Three Months 
Ended December 31, 2020
Number of 
loans 
modified

Enrollment 
balance(1)

In millions of dollars, 
except number of loans 
modified
North America

For the Twelve Months 

Ended December 31, 2020 As of December 31, 2020
% of total 
Number of 
loan 
loans 
portfolio(4)
modified

Enrollment 
balance(2)

EOP 
balance(3)

Program details

Credit cards

270,655  $ 

843   

2,626,225  $ 

9,165  $ 

708 

 1  % Waivers on late fees and 

Residential first 
mortgages

1,022   

197   

9,279   

3,573   

1,256 

Home equity loans

264   

18   

5,230   

614   

254 

deferral of minimum payments 
for two to four payment cycles 
Extending existing payment 
deferral options through 2021 
and suspending foreclosures 
into the first quarter of 2021

Extending existing payment 
deferral options

 3 

 4 

Personal, small 
business and other

1,178   

11   

22,247   

315   

7 

 —  Waivers on fees including non-

Citi ATM fees and monthly 
service fees as well as 
minimum payment deferrals 
for up to six months

Total North America

273,119  $ 

1,069   

2,662,981  $ 

13,667  $ 

2,225 

 1 %

International

Asia
Credit cards

Residential first 
mortgages

Personal, small 
business and other

Latin America

Credit cards

Residential first 
mortgages

Personal, small 
business and other

153,684  $ 

366   

1,306,090  $ 

2,520  $ 

189 

 1  % Payment deferrals for one to 
six months, interest and fee 
waivers, and reductions in 
minimum due payments; 
balance conversion programs

1,537   

119   

46,275   

3,812   

583 

 2 

14,977   

85   

219,071   

1,740   

49 

 — 

—   

—   

—   

641,038   

1,263   

—   

26,251   

950   

— 

— 

 — 

 — 

—   

—   

184,966   

1,711   

— 

 — 

Payment deferrals for up to 12 
months, interest and fee 
waivers, and reductions in 
minimum due payments

Payment deferrals for up to 
three months for revolving 
products and overdrafts or up 
to 12 months for installment 
loans, interest and fee waivers, 
and reductions in minimum 
due payments

Minimum payment deferrals 
for up to six months

Installment payment deferral 
for up to six months to be 
recovered as a balloon 
payment at the end of the loan
Installment payment deferral 
for up to six months, 
temporary interest rate 
reductions

Total international

170,198  $ 

570   

2,423,691  $ 

11,996  $ 

821 

Total consumer

443,317  $ 

1,639   

5,086,672  $ 

25,663  $ 

3,046 

 1 %

 1 %

(1)  Enrollment balances represent the aggregate amounts enrolled during the fourth quarter of 2020.
(2)  Enrollment balances represent the aggregate amounts enrolled during the 12 months ended December 31, 2020.
(3)  Total outstanding balance on loans enrolled in consumer relief programs as of December 31, 2020. Reserves for these loans are calculated in accordance with the 

CECL standard.

(4)  The percentage denominator is the total end-of-period loans balance for the respective product and region as of December 31, 2020.

As set forth in the table above, during the fourth quarter 
of 2020, Citi modified approximately 0.4 million consumer 
loans, excluding TDRs, with associated enrollment balances of 
approximately $1.6 billion. For the year ended December 31, 
2020, Citi modified 5.1 million consumer loans, excluding 
TDRs, with associated enrollment balances of approximately 
$25.7 billion. As of December 31, 2020, Citi had 

approximately $3.0 billion of loan balances outstanding under 
the consumer loan relief programs, representing approximately 
1% of Citi’s total consumer loan balance. 

As of December 31, 2020, Citi had approximately $2.2 
billion of loan balances outstanding under the consumer relief 
programs in North America. 

10

 
 
 
 
 
 
 
 
 
 
 
 
 
Citi’s Management of COVID-19 Pandemic Risks
Citi has responded on multiple fronts to the challenges of the 
pandemic to support the ongoing needs of its customers and 
clients, while concurrently maintaining safety and soundness 
standards.

Citi’s dedicated continuity of business and crisis 

management groups are managing Citi’s protocols in response 
to the pandemic. These protocols provide for the safety and 
well-being of Citi’s staff, while continuing to maintain high 
levels of client servicing across all of the markets in which 
Citi operates. These protocols address the prioritization of 
critical processing; ability of staff and third parties to support 
these processes from remote work locations; deployment of 
new hardware to support technology needs; and ongoing 
monitoring to assess controls and service levels. Planning for 
Citi’s return-to-office strategy is ongoing.

Citi’s organizational response to the pandemic has been 
governed by Citi’s Executive Management Team, consisting 
of the Citigroup CEO and certain direct reports of the CEO, 
and driven through regional task forces that were deployed in 
Asia, EMEA, North America and Latin America. Led by 
regional CEOs and their management teams, these groups 
focused on, and continue to manage, the pandemic responses, 
implementation of continuity of business plans, locational and 
staffing strategies and responses to customer and client needs.
Throughout the crisis, Citi has also worked closely with 

U.S. authorities and host governments on implementing 
immediate policy responses and financial assistance structures 
to mitigate the systemic impacts of the pandemic. Citi also 
continues to engage closely with customers and clients, 
regulators and other relevant stakeholders to assure alignment 
on all pandemic-related matters.

Citi’s North America credit card programs had the largest 

number of loan modifications in 2020. As these credit card 
relief programs were introduced during the first half of 2020 
and offered a deferral of minimum payments for two to four 
payment cycles, nearly all of the customers had rolled off the 
programs by year-end, of whom approximately 86% have 
continued to make payments. 

For customers enrolled in mortgage forbearance programs 
in North America, Citi’s subservicer offered payment deferrals 
and suspended foreclosures, and by the end of 2020, 
approximately 63% of mortgage customers had rolled off the 
program, of whom approximately 72% have continued to 
make payments. As of December 31, 2020, Citi had 
approximately $1.3 billion of mortgage loan balances 
outstanding under the programs. 

As of December 31, 2020, Citi had approximately $0.8 

billion of loan balances outstanding under Asia consumer 
relief programs. In Asia, approximately 96% of customers had 
rolled off the consumer relief programs as of December 31, 
2020, of whom approximately 83% have continued to make 
payments. 

As of December 31, 2020, Citi had no loan balances 

outstanding under the Latin America consumer relief 
programs, as all the customers had rolled off the programs, of 
whom approximately 78% have continued to make payments. 

Citi Corporate Loan Relief Programs
Citi has modified the contractual terms of corporate loans to 
certain borrowers impacted by the pandemic, primarily 
commercial banking (small business) and private bank 
customers. These modifications consist primarily of deferrals 
in the payment of principal and/or interest that Citi has 
provided during 2020 in response to borrower requests, as 
well as those provided pursuant to government-mandated 
relief programs. 

The table below summarizes Citi’s outstanding active 
loan modifications, excluding TDRs as of December 31, 2020. 

In millions of dollars

Corporate loans

Private bank loans

Total corporate

December 31, 2020

Total credit 
exposure

Funded Unfunded

$ 

$ 

1,132  $ 

1,074  $ 

773   

762   

1,905  $ 

1,836  $ 

58 

11 

69 

11

 
Citi’s Allowance for Credit Losses (ACL)
The table below shows the impact of Citi’s adoption of the 
current expected credit loss (CECL) standard as of January 1, 
2020 and the ACL builds (releases) during 2020. For 
information on the drivers of Citi’s ACL release in the fourth 
quarter, see “Significant Accounting Policies and Significant 
Estimates—Allowance for Credit Losses” below. For 
additional information on Citi’s accounting policy on 
accounting for credit losses under CECL, see Note 1 to the 
Consolidated Financial Statements.

Balance 
Dec. 31, 
2019

CECL 
transition 
impact

Collection 
costs 
change(1)

Balance 
Jan. 1, 
2020

Allowance for credit losses (ACL)

Build (release)

1Q20

2Q20

3Q20

4Q20

2020

2020 
FX/
Other 

Balance 
Dec. 31, 
2020

ACLL/EOP 
loans Dec. 31, 
2020(2)

$ 

8,419  $ 

4,456  $ 

(407)  $  12,468  $ 2,412  $ 1,911  $ 

55  $ 

(79)  $ 4,299  $ 

38  $  16,805 

 10.98 %

1,200   

566   

(36)   

1,730   

399   

388   

(21)   

(114)   

652   

37   

2,419 

$ 

9,619  $ 

5,022  $ 

(443)  $  14,198  $ 2,811  $ 2,299  $ 

34  $  (193)  $ 4,951  $ 

75  $  19,224 

 6.81 %

2,886   

(721)   

—   

2,165    1,316    3,370   

106    (1,620)    3,172   

65   

5,402 

 1.42 

278   

(100)   

—   

178   

191   

160   

(128)   

(35)   

188   

(36)   

330 

$  12,783  $ 

4,201  $ 

(443)  $  16,541  $ 4,318  $ 5,829  $ 

12  $ (1,848) $ 8,311  $  104  $  24,956 

 3.73 %

1,456   

(194)   

—   

96   

—   

—   

1,262   

557   

113   

424   

352    1,446   

(53)   

2,655 

96   

2   

79   

(32)   

(38)   

11   

39   

146 

$  14,239  $ 

4,103  $ 

(443)  $  17,899  $ 4,877  $ 6,021  $  404  $ (1,534) $ 9,768  $ 

90  $  27,757 

In millions of 
dollars
Cards(1)
All other GCB

Global 
Consumer 
Banking

Institutional 
Clients Group
Corporate/
Other

Allowance for 
credit losses on 
loans (ACLL)

Allowance for 
credit losses on 
unfunded 
lending 
commitments

Other

Total 
allowance for 
credit losses 
(ACL)

(1)  See Note 1 to the Consolidated Financial Statements.
(2)  As of December 31, 2020, in North America GCB, Citi-branded cards ACLL/EOP loans was 10.0% and Citi retail services ACLL/EOP loans was 13.6%. 

Certain Key Government Actions in Support of the 
Economy

For additional information about Citi’s liquidity resources, see 
“Managing Global Risk—Liquidity Risk” below.

U.S. Government-Sponsored Liquidity Programs
During the first quarter of 2020, the Federal Reserve Board 
(FRB) introduced several liquidity facilities in response to the 
funding market volatility caused by the pandemic. Citi has 
participated in several of the U.S. government-sponsored 
liquidity programs, including the Money Market Mutual Fund 
Liquidity Facility (MMLF), the Primary Dealer Credit Facility 
(PDCF) and Discount Window (DW) in order to facilitate 
client activity and support the FRB actions to provide 
additional liquidity into the market. Citi has also participated 
in the Paycheck Protection Program Lending Facility 
(PPPLF), which was established to facilitate lending under the 
Small Business Administration’s (SBA’s) Paycheck Protection 
Program (see “Small Business Administration’s Paycheck 
Protection Program” below). The amounts Citi sourced from 
these facilities were not significant to Citi’s overall liquidity 
profile during 2020, which remains strong and highly liquid. 

U.S. Banking Agencies Regulatory Capital Relief 
In response to the pandemic, throughout 2020, the U.S. 
banking agencies issued several final rules and interim final 
rules revising the current regulatory capital standards, to 
provide banking organizations with additional flexibility to 
support consumers and businesses. Those rules applicable to 
Citi include:

•

Easing of capital distribution limits in the event of 
regulatory capital buffer breaches, which provides some 
flexibility to continue distributing capital under certain 
circumstances.

• Modification of the CECL transition provision to defer 

the January 1, 2020 capital impact to January 1, 2022 and 
to provide additional capital relief for ongoing increases 
in credit reserves. Citi’s reported Common Equity Tier 1 
Capital ratio at December 31, 2020, reflecting the 
modified CECL transition provision, was 39 basis points 

12

 
 
 
 
 
 
higher than Citi’s Common Equity Tier 1 Capital ratio, 
reflecting the full impact of CECL on regulatory capital. 
Excluding the modified CECL transition provision, 
Citigroup’s Common Equity Tier 1 Capital ratio would 
have been 11.34%, compared with a 10.0% effective 
minimum requirement.
Temporary Supplementary Leverage ratio (SLR) relief for 
bank holding companies, commencing in the second 
quarter of 2020, allowing Citigroup to temporarily expand 
its balance sheet by excluding U.S. Treasury securities 
and deposits with the FRB from the SLR denominator. 
Citigroup’s reported Supplementary Leverage ratio of 
7.00% benefited by 109 basis points during the fourth 
quarter of 2020 as a result of the temporary relief. 
Excluding the temporary relief, Citigroup’s 
Supplementary Leverage ratio would have been 5.91%, 
compared with a 5.0% effective minimum requirement.
Assigning a 0% risk weight to loans originated under the 
Paycheck Protection Program.

•

•

Pandemic and Other Impacts
In 2021, Citi expects overall revenues to decline from 2020, 
largely driven by normalization in the ICG markets 
businesses. In addition, GCB, ICG and Corporate/Other 
revenues will likely continue to be adversely impacted by the 
lower global interest rate environment, and GCB and ICG 
revenues will be affected by the challenges and uncertainties 
in the macroeconomic and market environment, including as a 
result of the continued severity and duration of the pandemic. 
Each GCB region is also expected to continue to experience 
the adverse impacts the pandemic has had on customer 
activity, while Latin America GCB is also likely to continue to 
experience an impact from macroeconomic weakness in 
Mexico. 

Citi also expects to incur higher expenses, as it continues 

to accelerate the transformation of its infrastructure, risk 
management and controls, including its efforts to improve the 
risk and control environment, as well as to comply with the 
consent orders (see “Citi’s Consent Order Compliance” 
above).

For additional information about regulatory capital relief 

Moreover, based on its existing portfolios as of December 

31, 2020, Citi expects to experience higher net credit losses, 
which will vary by business and region and be dependent on 
future macroeconomic conditions. Citi believes that these 
losses are adequately reserved for under the CECL standard at 
December 31, 2020. Citi expects international consumer losses 
to peak during the first half of 2021, while in the U.S., losses 
could begin to rise in 2021 but peak afterward. If Citi’s fourth 
quarter of 2020 macroeconomic forecast assumptions are 
realized, Citi would not expect additional reserve builds on its 
existing portfolios (for additional information, see “Significant 
Accounting Policies and Significant Estimates” below); 
however, the overall level of reserves remains dependent on 
the evolving economic and public health environments relative 
to this forecast, as well as new lending volumes. 

For additional information about material risks to Citi 
from the pandemic and other macroeconomic challenges and 
uncertainties, see “Risk Factors” below.

provided by the U.S. banking agencies, see “Capital 
Resources” below.

Troubled Debt Restructuring (TDR) Relief
Under U.S. GAAP, banks are required to assess modifications 
to a loan’s terms for potential classification as a TDR. A loan 
to a borrower experiencing financial difficulty is classified as 
a TDR when a lender grants a concession that it would 
otherwise not consider, such as a payment deferral or interest 
concession. 

In order to encourage banks to work with impacted 
borrowers, the Coronavirus Aid, Relief, and Economic 
Security Act (CARES Act) and U.S. banking agencies have 
provided relief from TDR accounting. The main benefits of 
TDR relief include a capital benefit in the form of reduced 
risk-weighted assets, as TDRs are more heavily risk-weighted 
for capital purposes; aging of the loans is frozen, i.e., they will 
continue to be reported in the same delinquency bucket they 
were in at the time of modification; and the loans are generally 
not reported as non-accrual during the modification period. 
The loans included in Citi’s pandemic-related consumer relief 
programs are included in Citi’s reserving process under the 
CECL standard. 

Small Business Administration’s Paycheck Protection 
Program
The Paycheck Protection Program (PPP) authorizes the 
origination of forgivable loans for small businesses to pay 
their employees during the pandemic. Loan terms are the same 
for all businesses. During the first round of PPP, which was 
launched in April 2020, Citi funded over 30,000 loans totaling 
$3.8 billion as of December 31, 2020, with approximately $3.4 
billion outstanding at December 31, 2020. The processing of 
loan forgiveness requests under PPP began during the third 
quarter of 2020 and Citi received approximately $314 million 
of funds from the SBA relating to forgiveness in the fourth 
quarter of 2020. Citi is currently participating in the relaunch 
of PPP and remains committed to supporting small businesses.

13

RESULTS OF OPERATIONS

SUMMARY OF SELECTED FINANCIAL DATA

Citigroup Inc. and Consolidated Subsidiaries

In millions of dollars, except per share amounts

2020

2019

2018

2017

2016

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

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

43,548  $ 

47,347  $ 

46,562  $ 

45,061  $ 

30,750   

26,939   

26,292   

27,383   

74,298  $ 

74,286  $ 

72,854  $ 

72,444  $ 

43,171   

17,495   

42,002   

8,383   

41,841   

7,568   

42,232   

7,451   

13,632  $ 

23,901  $ 

23,445  $ 

22,761  $ 

2,525   

4,430   

5,357   

29,388   

11,107  $ 

19,471  $ 

18,088  $ 

(6,627)  $ 

45,476 

25,321 

70,797 

42,338 

6,982 

21,477 

6,444 

15,033 

(20)   

(4)   

(8)   

(111)   

(58) 

11,087  $ 

19,467  $ 

18,080  $ 

(6,738)  $ 

14,975 

40   

66   

35   

60   

63 

11,047  $ 

19,401  $ 

18,045  $ 

(6,798)  $ 

14,912 

4.75  $ 

4.74   

4.73  $ 

4.72   

2.04   

8.08  $ 

8.08   

8.04  $ 

8.04   

1.92   

6.69  $ 

6.69   

6.69  $ 

6.68   

1.54   

(2.94)  $ 

(2.98)   

(2.94)  $ 

(2.98)   

0.96   

4,299  $ 

4,403  $ 

3,865  $ 

2,595  $ 

1,095   

2,925   

1,109   

17,875   

1,174   

14,545   

1,213   

14,538   

4.74 

4.72 

4.74 

4.72 

0.42 

1,214 

1,077 

9,451 

Table continues on the next page, including footnotes.

14

 
 
 
 
 
 
 
 
 
 
 
SUMMARY OF SELECTED FINANCIAL DATA
(Continued) 

Citigroup Inc. and Consolidated Subsidiaries

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

2020

2019

2018

2017

2016

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

$  2,260,090 

$  1,951,158 

$  1,917,383 

$  1,842,465 

$  1,792,077 

  1,280,671 

  1,070,590 

  1,013,170 

271,686 

179,962 

199,442 

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 

  2,226,256 

  1,978,805 

  1,920,242 

  1,875,438 

  1,808,728 

210 

200 

204 

209 

219 

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, net)
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)

 0.50 %

 0.98 %

 0.94 %

 (0.36) %

 0.82 %

 5.7 

 5.7 

 6.6 

 58.1 

 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 

 11.73 %

 11.79 %

 11.86 %

 12.36 %

 12.57 %

13.31 

15.61 

7.00 

 7.96 %

8.82 

 43 

 73 

86.43 

73.67 

$ 

13.33 

15.87 

6.20 

13.43 

16.14 

6.40 

 8.98 %

 9.27 %

9.90 

 24 

 122 

10.23 

 23 

 109 

14.06 

16.30 

6.68 

 9.85 %

10.90 

NM

NM

$ 

82.90 

$ 

75.05 

$ 

70.62 

$ 

70.39 

63.79 

60.16 

14.24 

16.24 

7.22 

 11.49 %

12.56 

 9 

 77 

74.26 

64.57 

(1)  2017 includes the one-time impact related to enactment of the Tax Cuts and Jobs Act (Tax Reform). 2020, 2019 and 2018 reflect the tax rate structure post Tax 

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

(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)  RoTCE and TBV are non-GAAP financial measures. 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 2016 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)  Citi’s reportable Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital as of December 31, 2020 were derived under the Basel III Advanced Approaches 
frameworks, whereas Citi’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the Basel III Standardized Approach 
and the reportable Total Capital ratio was the lower derived under the Basel III Advanced Approaches framework as of December 31, 2019 and 2018.

(6)  Dividends declared per common share as a percentage of net income per diluted share.
(7)  Total common dividends declared plus common share 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

15

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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(1)
Total

Institutional Clients Group

  North America

  EMEA

  Latin America

  Asia

Total

Corporate/Other

Income from continuing operations

Discontinued operations

Less: Net income attributable to noncontrolling interests

Citigroup’s net income

2020

2019

2018

% Change
2020 vs. 2019

% Change
2019 vs. 2018

$ 

$ 

$ 

$ 

$ 

$ 

$ 

59  $ 

277   

538   

874  $ 

3,224  $ 

901   

1,577   

5,702  $ 

3,461  $ 

3,511  $ 

3,327   

1,406   

3,604   

3,867   

2,111   

3,455   

3,087 

802 

1,420 

5,309 

3,675 

3,889 

2,013 

2,997 

11,798  $ 

12,944  $ 

12,574 

(1,565)   

825   

205 

11,107  $ 

19,471  $ 

18,088 

(20)  $ 

40   

(4)  $ 

66   

(8) 

35 

11,047  $ 

19,401  $ 

18,045 

 (98) %

 (69) 

 (66) 

 (85) %

 (1) %

 (14) 

 (33) 

 4 

 (9) %

NM

 (43) %

NM

 (39) %

 (43) %

 4 %

 12 

 11 

 7 %

 (4) %

 (1) 

 5 

 15 

 3 %

NM

 8 %

 50 %

 89 

 8 %

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

2020

2019

2018

% Change
2020 vs. 2019

% Change
2019 vs. 2018

$ 

19,148  $ 

20,398  $ 

19,829 

4,372   

6,471   

5,238   

7,335   

5,309 

7,201 

29,991  $ 

32,971  $ 

32,339 

17,185  $ 

13,459  $ 

12,814   

12,006   

4,838   

9,416   

44,253  $ 
54   

74,298  $ 

5,166   

8,670   

39,301  $ 
2,014   

74,286  $ 

13,522 

11,770 

4,954 

8,079 

38,325 
2,190 

72,854 

$ 

$ 

$ 

$ 

 (6) %

 (17) 

 (12) 

 (9) %

 3 %

 (1) 

 2 

 2 %

 28 %

 — %

 7 

 (6) 

 9 

 13 %
 (97) 

 — %

 2 

 4 

 7 

 3 %
 (8) 

 2 %

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

16

 
 
 
 
 
 
 
 
 
 
 
 
 
SEGMENT BALANCE SHEET(1)—DECEMBER 31, 2020

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

$ 

7,445  $ 

89,503  $ 

212,667  $ 

—  $ 

309,615 

201   

1,948   

1,310   

262,876   

39,716   

120,077   

294,258   

360,131   

136,105   

381,598   

99,348   

368,902   

253   

13,000   

309,944   

6,453   

43,334   

(488,979)   

—   

—   

—   

—   

—   

—   

294,712 

375,079 

447,359 

650,927 

182,398 

— 

433,573  $ 

1,729,845  $ 

96,672  $ 

—  $ 

2,260,090 

344,500  $ 

924,300  $ 

11,871  $ 

—  $ 

1,280,671 

685   

1,322   

—   

1,268   

21,422   

64,376   

198,828   

165,500   

25,507   

74,799   

74,573   

266,338   

12   

1,205   

4,007   

25,056   

14,472   

39,291   

—   

—   

—   

170,563   

—   

(370,005)   

433,573  $ 

1,729,845  $ 

95,914  $ 

(199,442)  $ 

—   

—   

758   

199,442   

433,573  $ 

1,729,845  $ 

96,672  $ 

—  $ 

199,525 

168,027 

29,514 

271,686 

110,467 

— 

2,059,890 

200,200 

2,260,090 

$ 

$ 

$ 

$ 

In millions of dollars

Assets

Cash and deposits with banks, net of 
allowance
Securities borrowed and purchased under 
agreements to resell, net of allowance

Trading account assets

Investments, net of allowance

Loans, net of unearned income and allowance 
for credit losses on loans 

Other assets, net of allowance
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 of allowance
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 are reflected 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.

17

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, in the U.S., 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 2,303 branches in 19 countries and jurisdictions as 
of December 31, 2020. At December 31, 2020, GCB had $434 billion in assets and $344.5 billion in retail banking deposits.

 GCB’s strategy is to leverage its global footprint and digital capabilities to develop multi-product relationships with customers—

both in and out of Citi’s branch footprint. To achieve this, GCB strives to optimize its clients’ experiences across lending, payments 
and wealth management through continued digitization, new partnerships and innovation.

In millions of dollars, except as otherwise noted

2020

2019

2018

% Change
2020 vs. 2019

% Change
2019 vs. 2018

 (7) %

 (20) 

 (9) %

 (2) %

 (10) %

NM

 (100) 

 44 

 48 %

 (85) %

 (88) 

 (85) %

NM

 (85) %

 7 %

 10 

 3 %

 (4) 

 2 %

 (1) %

 7 %

 (23) 

 100 

 (29) 

 5 %

 6 %

 3 

 7 %

 (14) 

 7 %

 5 %

 3 

 12 

 3 

 (6) %

 (11) 

 (9) %

 (60) %

 (97) 

 (85) %

 (1) %

 4 

 2 %

 — %

 12 

 7 %

Net interest revenue

Non-interest revenue

Total revenues, net of interest expense

Total operating expenses

Net credit losses on loans

Credit reserve build for loans

Provision for credit losses on unfunded lending commitments
Provisions for benefits and claims, HTM debt securities and 
other assets

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

Income from continuing operations before taxes

Income taxes

Income from continuing operations

Noncontrolling interests

Net income

Balance Sheet data and ratios 

EOP assets (in billions of dollars)

Average assets (in billions of dollars)

Return on average assets

Efficiency ratio

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

26,200 

$ 

28,205 

$ 

27,374 

3,791 

29,991 

17,203 

6,646 

4,951 

— 

105 

11,702 

1,086 

212 

874 

(4) 

$ 

$ 

$ 

$ 

$ 

$ 

4,766 

32,971 

17,628 

7,382 

439 

1 

73 

7,895 

7,448 

1,746 

$ 

$ 

$ 

$ 

$ 

5,702 

$ 

6 

4,965 

32,339 

17,786 

6,884 

568 

— 

103 

7,555 

6,998 

1,689 

5,309 

7 

878 

$ 

5,696 

$ 

5,302 

$ 

434 

426 

 0.21 %

 57 

$ 

407 

389 

 1.46 %

 53 

388 

378 

 1.40 %

 55 

269 

Average retail banking deposits (in billions of dollars)

$ 

311 

$ 

277 

$ 

Net credit losses as a percentage of average loans

 2.39 %

 2.60 %

 2.48 %

Revenue by business

Retail banking
Cards(1)
Total

Income from continuing operations by business

Retail banking
Cards(1)
Total

$ 

11,734 

$ 

12,549 

$ 

12,627 

18,257 

20,422 

19,712 

$ 

29,991 

$ 

32,971 

$ 

32,339 

$ 

$ 

744 

130 

874 

$ 

$ 

1,842 

$ 

3,860 

5,702 

$ 

1,851 

3,458 

5,309 

Table continues on the next page, including footnotes.

18

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 credit losses and PBC—as reported $ 

$ 

Impact of FX translation(2)

Total provisions for credit losses and PBC—ex-FX(3)
Net income—as reported

Impact of FX translation(2)

Net income—ex-FX(3)

$ 

$ 

$ 

29,991  $ 

32,971  $ 

32,339 

—   

29,991  $ 

17,203  $ 

—   

17,203  $ 

11,702  $ 

—   

11,702  $ 

878  $ 

—   

878  $ 

(509)   

32,462  $ 

17,628  $ 

(276)   

17,352  $ 

7,895  $ 

(124)   

7,771  $ 

5,696  $ 

(74)   

5,622  $ 

(664) 

31,675 

17,786 

(371) 

17,415 

7,555 

(161) 

7,394 

5,302 

(90) 

5,212 

 (9) %

 (8) %

 (2) %

 (1) %

 48 %

 51 %

 (85) %

 (84) %

 2 %

 2 %

 (1) %

 — %

 5 %

 5 %

 7 %

 8 %

Includes both Citi-branded cards and Citi retail services.

(1)
(2) Reflects the impact of FX translation into U.S. dollars at the 2020 average exchange rates for all periods presented.
(3) Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM  Not meaningful

19

 
 
 
 
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, 2020, 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, 2020, North America GCB had 
$52.7 billion in retail banking loans and $194.8 billion in retail banking deposits. In addition, North America GCB had $130.4 billion 
in outstanding card loan balances.

In millions of dollars, except as otherwise noted

2020

2019

2018

% Change
2020 vs. 2019

% Change
2019 vs. 2018

 (5) %

 (35) 

 (6) %

 (2) %

 (11) %

NM

 (100) 

 (11) 

 50 %

 (98) %

 (97) 

 (98) %

 — 

 (98) %

 5 %

 (36) 

 3 %

 (1) %

 10 %

 2 

 100 

 (14) 

 9 %

 3 %

 — 

 4 %

 — 

 4 %

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

Total operating expenses

Net credit losses on loans

Credit reserve build for loans

Provision for credit losses on unfunded lending commitments

Provisions for benefits and claims, HTM debt securities and 
other assets

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

Average assets (in billions of dollars)

Return on average assets

Efficiency ratio

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

18,802 

$ 

19,869 

$ 

19,006 

346 

19,148 

9,942 

4,990 

4,115 

— 

17 

9,122 

84 

25 

59 

— 

59 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

529 

20,398 

10,154 

5,583 

469 

1 

19 

6,072 

4,172 

948 

$ 

$ 

$ 

$ 

$ 

3,224 

$ 

— 

823 

19,829 

10,230 

5,085 

460 

— 

22 

5,567 

4,032 

945 

3,087 

— 

3,224 

$ 

3,087 

266 

$ 

232 

$ 

 0.02 %

 52 

 1.39 %

 50 

227 

 1.36 %

 52 

148 

 15 %

 2 %

 15 

 3 

Average retail banking deposits (in billions of dollars)

$ 

176 

$ 

153 

$ 

Net credit losses as a percentage of average loans

 2.72 %

 2.97 %

 2.78 %

Revenue by business

Retail banking

Citi-branded cards

Citi retail services

Total

Income (loss) from continuing operations by business

Retail banking

Citi-branded cards

Citi retail services

Total

$ 

4,457 

$ 

4,529 

$ 

8,758 

5,933 

9,165 

6,704 

4,600 

8,628 

6,601 

$ 

19,148 

$ 

20,398 

$ 

19,829 

$ 

(144) 

$ 

196 

$ 

21 

182 

1,742 

1,286 

$ 

59 

$ 

3,224 

$ 

312 

1,581 

1,194 

3,087 

 (2) %

 (4) 

 (12) 

 (6) %

NM

 (99) %

 (86) 

 (98) %

 (2) %

 6 

 2 

 3 %

 (37) %

 10 

 8 

 4 %

2018 includes an approximate $150 million gain on the Hilton portfolio sale. 

(1)
NM  Not meaningful

20

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 additional information about trends, uncertainties and 

risks related to North America GCB’s future results, see 
“COVID-19 Pandemic Overview” above and “Risk Factors” 
below.

2020 vs. 2019 
Net income decreased 98%, as significantly higher cost of 
credit and lower revenues were partially offset by lower 
expenses.

Revenues decreased 6%, reflecting lower revenues in Citi 
retail services, Citi-branded cards and retail banking, primarily 
due to the pandemic, including lower interest rates.

Retail banking revenues decreased 2%, as the benefit of 

stronger deposit volumes and an improvement in mortgage 
revenues were more than offset by lower deposit spreads, 
reflecting lower interest rates. 

Average deposits increased 15%, driven by a combination 

of factors, including government stimulus payments, a 
reduction in overall consumer spending related to the 
pandemic and strategic efforts to drive organic growth, 
including digital deposits which drove more than one-third of 
the year-over-year growth. 

Cards revenues decreased 7%. Citi-branded cards 
revenues decreased 4%, reflecting lower purchase sales and 
higher payment rates driving lower average loans. Average 
loans decreased 6% and purchase sales decreased 8%, both 
reflecting the impact of the pandemic on customer activity. 
Citi retail services revenues decreased 12%, primarily 
reflecting lower average loans and higher contractual partner 
payments. (For additional information on partner payments, 
see Note 5 to the Consolidated Financial Statements.) Average 
loans were down 7% and purchase sales declined 11%, both 
reflecting the impact of the pandemic on customer activity.
Expenses decreased 2%, as lower volume-related 
expenses, reductions in marketing and other discretionary 
expenses, as well as efficiency savings, more than offset 
higher pandemic-related expenses.

Provisions of $9.1 billion increased 50% from the prior 

year, driven by a higher allowance for credit losses (ACL) 
build, partially offset by lower net credit losses. Net credit 
losses decreased 11%, primarily driven by lower net credit 
losses in Citi retail services (down 16% to $2.2 billion) and 
Citi-branded cards (down 5% to $2.7 billion), primarily 
reflecting lower loan volumes as well as higher payment rates 
given high levels of liquidity, lower spending and the benefits 
of relief programs. 

The ACL build of $4.1 billion (compared to a build of

$470 million in the prior year under prior accounting
standards) was driven by builds during the first half of 2020. 
The builds reflected the impact of a deterioration in Citi’s 
macroeconomic outlook under the CECL standard, including 
an increase in the qualitative management adjustment to 
reflect the potential for a higher level of stress and a slower 
economic recovery, partially offset by lower loan volumes, 
both primarily driven by the pandemic. For additional 
information on Citi’s ACL, see “Significant Accounting 
Policies and Significant Estimates” below and Notes 1 and 15 
to the Consolidated Financial Statements.

21

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, 2020, Latin America GCB had 1,392 retail branches in Mexico, with $9.8 billion in retail banking loans and 

$25.8 billion in deposits. In addition, the business had $4.8 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 on loans
Credit reserve build (release) for loans
Provision for credit losses on unfunded lending commitments
Provisions for benefits and claims, HTM debt securities and 
other assets
Provisions for credit losses and for benefits and claims (PBC)
Income from continuing operations before taxes
Income taxes
Income from continuing operations
Noncontrolling interests
Net income
Balance Sheet data and ratios
Average assets (in billions of dollars)
Return on average assets
Efficiency ratio
Average deposits (in billions of dollars)
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 credit losses and PBC—as reported

Impact of FX translation(2)

Provisions for credit losses and PBC—ex-FX(3)
Net income—as reported

Impact of FX translation(2)

Net income—ex-FX(3)

$ 

$ 
$ 
$ 

$ 
$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 
$ 

$ 
$ 

$ 
$ 

$ 

2020

2019

2018

3,078 
1,294 
4,372 
2,730 
866 
316 
— 

87 
1,269 
373 
96 
277 
— 
277 

32 
 0.87 %
 62 
23 
 5.97 %

3,009 
1,363 
4,372 

153 
124 
277 

4,372 
— 
4,372 
2,730 
— 
2,730 
1,269 
— 
1,269 
277 
— 
277 

$ 

$ 
$ 
$ 

$ 
$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 
$ 

$ 
$ 

$ 
$ 

$ 

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

54 
1,125 
1,230 
329 
901 
— 
901 

35 
 2.57 %
 55 
23 
 6.45 %

3,585 
1,653 
5,238 

600 
301 
901 

5,238 
(473) 
4,765 
2,883 
(246) 
2,637 
1,125 
(115) 
1,010 
901 
(78) 
823 

$ 

$ 
$ 
$ 

$ 
$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 
$ 

$ 
$ 

$ 
$ 

$ 

3,681 
1,628 
5,309 
2,900 
1,131 
84 
— 

81 
1,296 
1,113 
311 
802 
— 
802 

33 
 2.43 %
 55 
23 
 6.50 %

3,744 
1,565 
5,309 

596 
206 
802 

5,309 
(511) 
4,798 
2,900 
(253) 
2,647 
1,296 
(136) 
1,160 
802 
(87) 
715 

% Change
2020 vs. 2019
 (15) %
 (19) 
 (17) %
 (5) %
 (22) %
NM

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

 — 

 61 
 13 %
 (70) %
 (71) 
 (69) %
 — 
 (69) %

 — 

 (33) 
 (13) %
 11 %
 6 
 12 %
 — 
 12 %

 (9) %

 6 %

 — 

 — 

 (16) %
 (18) 
 (17) %

 (75) %
 (59) 
 (69) %

 (17) %

 (8) %
 (5) %

 4 %
 13 %

 26 %
 (69) %

 (4) %
 6 
 (1) %

 1 %
 46 
 12 %

 (1) %

 (1) %
 (1) %

 — %
 (13) %

 (13) %
 12 %

 (66) %

 15 %

2018 includes an approximate $250 million gain on the sale of an asset management business. See Note 2 to the Consolidated Financial Statements.

(1)
(2) Reflects the impact of FX translation into U.S. dollars at the 2020 average exchange rates for all periods presented.
(3) Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM  Not meaningful

22

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.

2020 vs. 2019 
Net income decreased 66%, reflecting lower revenues, higher 
cost of credit and higher expenses.

Revenues decreased 8%, reflecting lower retail banking 
and cards revenues, largely due to the pandemic, including 
lower interest rates. Revenues also decreased due to the 
ongoing slowdown in overall economic growth and industry 
volumes in Mexico.

Retail banking revenues decreased 8%, driven by a 
decline in loan volumes and lower deposit spreads, partially 
offset by deposit growth and an increase in assets under 
management. Average deposits were up 10%, while average 
loans decreased 5%, reflecting the impact of the pandemic on 
customer activity, as well as the ongoing economic slowdown. 
Assets under management increased 12%, including the 
benefit of market movements.

Cards revenues decreased 10%, primarily driven by lower 

purchase sales (down 17%) and lower average loans (down 
8%), reflecting the impact of the pandemic on customer 
activity and the ongoing economic slowdown.

Expenses increased 4%, as efficiency savings were more 
than offset by repositioning costs, pandemic-related expenses, 
and ongoing investment spending.

Provisions of $1.3 billion increased 26% from the prior 

year, driven by a higher allowance for credit losses (ACL) 
build, partially offset by lower net credit losses. Net credit 
losses decreased 14%, primarily driven by lower average loans 
and the impact of consumer relief programs. 

The ACL build of $316 million (compared to a net 
reserve release of $35 million in the prior year under prior 
accounting standards) was driven by builds during the first 
half of 2020. The builds reflected the impact of a deterioration 
in Citi’s macroeconomic outlook under the CECL standard, 
including an increase in the qualitative management 
adjustment to reflect the potential for a higher level of stress 
and a slower economic recovery, partially offset by lower loan 
volumes, both primarily driven by the pandemic. For 
additional information on Citi’s ACL, see “Significant 
Accounting Policies and Significant Estimates” below and 
Notes 1 and 15 to the Consolidated Financial Statements.

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

For additional information about trends, uncertainties and 

risks related to Latin America GCB’s future results, see 
“COVID-19 Pandemic Overview” above and “Risk Factors” 
below.

23

ASIA GCB

Asia GCB provides traditional retail banking and Citi-branded card products to retail and small business customers. During 2020, Asia 
GCB’s most significant revenues in Asia were from Hong Kong, Singapore, South Korea, Taiwan, India, Australia, Thailand, the 
Philippines, China and Indonesia. Included within Asia GCB, traditional retail banking and Citi-branded card products are also 
provided to retail customers in certain EMEA countries, primarily the United Arab Emirates, Poland and Russia. 

At December 31, 2020, on a combined basis, the businesses had 224 retail branches, $66.5 billion in retail banking loans and 

$123.9 billion in deposits. In addition, the businesses had $17.9 billion in outstanding card loan balances. 

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

2020

2019

2018

% Change
2020 vs. 2019

% Change
2019 vs. 2018

Net interest revenue

Non-interest revenue

Total revenues, net of interest expense

Total operating expenses

Net credit losses on loans

Credit reserve build for loans

Provision for HTM debt securities and other assets

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

Average assets (in billions of dollars)

Return on average assets

Efficiency ratio

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

4,320 

$ 

4,697 

$ 

2,151 

6,471 

4,531 

790 

520 

1 

1,311 

629 

91 

$ 

$ 

$ 

$ 

$ 

2,638 

7,335 

4,591 

690 

8 

— 

698 

2,046 

469 

$ 

$ 

$ 

$ 

$ 

538 

$ 

1,577 

$ 

(4) 

6 

4,687 

2,514 

7,201 

4,656 

668 

24 

— 

692 

1,853 

433 

1,420 

7 

542 

$ 

1,571 

$ 

1,413 

 (8) %

 (18) 

 (12) %

 (1) %

 14 %

NM

 100 

 88 %

 (69) %

 (81) 

 (66) %

NM

 (65) %

 — %

 5 

 2 %

 (1) %

 3 %

 (67) 

 — 

 1 %

 10 %

 8 

 11 %

 (14) 

 11 %

129 

$ 

122 

$ 

 0.42 %

 70 

 1.29 %

 63 

119 

 1.19 %

 65 

98 

 6 %

 3 %

 12 

 3 

Average deposits (in billions of dollars)

$ 

113 

$ 

101 

$ 

Net credit losses as a percentage of average loans

 0.99 %

 0.88 %

 0.86 %

Revenue by business

Retail banking

Citi-branded cards

Total

Income (loss) 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)

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

4,268 

$ 

4,435 

$ 

2,203 

2,900 

6,471 

$ 

7,335 

$ 

735 

$ 

1,046 

$ 

(197) 

531 

4,283 

2,918 

7,201 

943 

477 

538 

$ 

1,577 

$ 

1,420 

 (4) %

 (24) 

 (12) %

 (30) %

NM

 (66) %

6,471 

$ 

7,335 

$ 

7,201 

 (12) %

— 

6,471 

4,531 

— 

4,531 

1,311 

— 

1,311 

542 

— 

$ 

$ 

$ 

$ 

$ 

$ 

(36) 

7,299 

4,591 

(30) 

4,561 

698 

(9) 

689 

1,571 

4 

$ 

$ 

$ 

$ 

$ 

$ 

(153) 

7,048 

4,656 

(118) 

4,538 

692 

(25) 

667 

1,413 

(3) 

 (11) %

 (1) %

 (1) %

 88 %

 90 %

 (65) %

 4 %

 (1) 

 2 %

 11 %

 11 

 11 %

 2 %

 4 %

 (1) %

 1 %

 1 %

 3 %

 11 %

542 

$ 

1,575 

$ 

1,410 

 (66) %

 12 %

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

24

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(2)  Reflects the impact of FX translation into U.S. dollars at the 2020 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.

2020 vs. 2019
Net income decreased 66%, as lower revenues and 
significantly higher cost of credit were partially offset by 
lower expenses.

Revenues decreased 11%, reflecting lower cards and retail 

banking revenues, largely due to the pandemic, including 
lower interest rates.

Retail banking revenues decreased 3%, as growth in 
deposits and higher fees on investments and foreign currency 
transactions due to higher volumes and volatility were more 
than offset by lower deposit spreads and lower insurance 
revenues. Average deposits increased 11% and average loans 
increased 5%. Assets under management increased 5% and 
investment sales increased 43%. Retail lending revenues 
increased 4%, largely reflecting growth in mortgages and 
personal loans, partially offset by spread compression in 
personal loans.

Cards revenues decreased 24%, primarily driven by lower 

purchase sales (down 16%) and lower average loans (down 
8%), reflecting the impact of the pandemic on customer 
activity, including from lower travel spend in the region given 
Citi’s skew to an affluent client base and a greater proportion 
of fee revenues coming from travel-related interchange and 
foreign transaction fees.

Expenses decreased 1%, as lower discretionary expenses 
and volume-related costs, as well as efficiency savings, were 
partially offset by ongoing investment spending.

Provisions of $1.3 billion increased 90%, driven by a 
higher allowance for credit losses (ACL) build as well as 
higher net credit losses. Net credit losses increased 16%, as 
pandemic lockdowns and the deterioration in the macro-
environment impacted credit performance. 

The ACL build of $520 million (compared to a build of 

$7 million in the prior year under prior accounting standards) 
was driven by builds during the first three quarters of 2020. 
The builds reflected the impact of a deterioration in Citi’s 
macroeconomic outlook under the CECL standard, including 
an increase in the qualitative management adjustment to 
reflect the potential for a higher level of stress and a slower 
economic recovery, partially offset by lower loan volumes, 
both primarily driven by the pandemic. For additional 
information on Citi’s ACL, see “Significant Accounting 
Policies and Significant Estimates” below and Notes 1 and 15 
to the Consolidated Financial Statements. 

For additional information on Asia GCB’s retail banking 

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

For additional information about trends, uncertainties and 

risks related to Asia GCB’s future results, see “COVID-19 
Pandemic Overview” above and “Risk Factors” below.

25

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 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 96 countries and jurisdictions. At December 31, 2020, ICG 
had $1.7 trillion in assets and $924 billion in deposits, while 
two of its businesses—securities services and issuer services
—managed $24.0 trillion and $20.3 trillion in assets under 
custody as of December 31, 2020 and 2019, respectively. For 
additional information on these operations, see 
“Administration and Other Fiduciary Fees” in Note 5 to the 
Consolidated Financial Statements.

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 
significantly impact client activity levels, bid/offer spreads and 
the fair value of product inventory. For example, a decrease in 

26

 
% Change
2020 vs. 2019

% Change
2019 vs. 2018

 (1) %

 (4) %

 4 

 13 

 55 

 (37) 

 21 %

 1 

 13 %

 6 %

NM

NM

NM

 100 %

NM

 (8) %

 (6) 

 (9) %

 25 

 (9) %

 20 %

 14 

 (2) 

 2 

 (2) 

 94 

 3 %

 3 

 3 %

 2 %

 89 %

NM

 (16) 

 — 

NM

 1 %

 (5) 

 3 %

NM

 3 %

 1 %

 3 

In millions of dollars, except as otherwise noted

2020

2019

2018

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 on loans

Credit reserve build (release) for loans

Provision for credit losses on unfunded lending commitments
Provisions for credit losses on HTM debt securities and other 
assets

Provisions for credit losses

Income from continuing operations before taxes

Income taxes

$ 

4,412 

$ 

4,462 

$ 

2,877 

5,009 

13,308 

1,149 

2,756 

4,440 

8,562 

1,829 

4,651 

2,806 

4,358 

8,742 

941 

$ 

26,755 

$ 

22,049 

$ 

21,498 

$ 

$ 

$ 

$ 

$ 

17,498 

44,253 

23,467 

987 

3,172 

1,435 

21 

5,615 

15,171 

3,373 

$ 

$ 

$ 

$ 

$ 

17,252 

39,301 

22,224 

394 

71 

98 

— 

563 

16,514 

3,570 

$ 

$ 

$ 

$ 

$ 

16,827 

38,325 

21,780 

208 

(109) 

116 

— 

215 

16,330 

3,756 

Income from continuing operations

$ 

11,798 

$ 

12,944 

$ 

12,574 

Noncontrolling interests

Net income

Balance Sheet data and ratios

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

50 

40 

17 

$ 

11,748 

$ 

12,904 

$ 

12,557 

$ 

1,730 

$ 

1,447 

$ 

1,706 

 0.69 %

 53 

1,493 

 0.86 %

 57 

1,438 

1,449 

 0.87 %

 57 

$ 

17,185 

$ 

13,459 

$ 

13,522 

 28 %

 — %

12,814 

4,838 

9,416 

12,006 

5,166 

8,670 

11,770 

4,954 

8,079 

$ 

44,253 

$ 

39,301 

$ 

38,325 

$ 

3,461 

$ 

3,511 

$ 

3,327 

1,406 

3,604 

3,867 

2,111 

3,455 

3,675 

3,889 

2,013 

2,997 

$ 

11,798 

$ 

12,944 

$ 

12,574 

$ 

201 

$ 

188 

$ 

174 

88 

39 

71 

87 

40 

73 

81 

42 

77 

399 

$ 

388 

$ 

374 

651 

273 

924 

$ 

$ 

536 

232 

768 

$ 

$ 

509 

218 

727 

$ 

$ 

$ 

 7 

 (6) 

 9 

 13 %

 (1) %

 (14) 

 (33) 

 4 

 (9) %

 7 %

 1 

 (3) 

 (3) 

 3 %

 21 %

 18 

 20 %

 2 

 4 

 7 

 3 %

 (4) %

 (1) 

 5 

 15 

 3 %

 8 %

 7 

 (5) 

 (5) 

 4 %

 5 %

 6 

 6 %

(1)  2019 includes an approximate $350 million gain on Citi’s investment in Tradeweb. 
NM  Not meaningful

27

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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—excluding gains (losses) on loan hedges(1)
Total Banking revenues (ex-gains (losses) on loan hedges)(1)
  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
Total Markets and securities services revenues, net 
of interest expense

Total revenues, net of interest expense

Commissions and fees
Principal transactions(3)
Other(2)
Total non-interest revenue 

Net interest revenue
Total fixed income markets(4)
Rates and currencies

Spread products/other fixed income

Total fixed income markets

Commissions and fees
Principal transactions(3)
Other

Total non-interest revenue 

Net interest revenue
Total equity markets(4)

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

2020

2019

2018

% Change
2020 vs. 2019

% Change
2019 vs. 2018

1,010  $ 

1,259  $ 

1,593   

3,184   

973   

2,984   

5,787  $ 

5,216  $ 

9,524   

2,184   

3,737   

10,293   

2,921   

3,460   

1,301 

991 

2,719 

5,011 

9,914 

2,913 

3,398 

21,232  $ 

21,890  $ 

21,236 

(51)  $ 

(432)  $ 

45 

21,181  $ 

17,256  $ 

21,458  $ 

12,884  $ 

21,281 

11,661 

3,427 

2,631 

(675) 

17,044 

38,325 

705 

7,134 

380 

8,219 

3,442 

2,908   

2,631   

(580)   

17,843  $ 

39,301  $ 

782  $ 

7,661   

1,117   

9,560  $ 

3,324   

3,624   

2,545   

(353)   

23,072  $ 

44,253  $ 

677  $ 

11,518   

579   

12,774  $ 

4,482   

17,256  $ 

12,145  $ 

5,111   

12,884  $ 

11,661 

9,225  $ 

3,659   

8,486 

3,175 

17,256  $ 

12,884  $ 

11,661 

1,245  $ 

1,121  $ 

1,281   

322   

775   

172   

2,848  $ 

2,068  $ 

776   

840   

3,624  $ 

2,908  $ 

1,267 

1,240 

110 

2,617 

810 

3,427 

 (20) %

 64 

 7 

 11 %

 (7) 

 (25) 

 8 

 (3) %

 88 %

 (1) %

 34 %

 25 

 (3) 

 39 

 29 %

 13 %

 (13) %

 50 

 (48) 

 34 %

 35 

 34 %

 32 %

 40 

 34 %

 11 %

 65 

 87 

 38 %

 (8) 

 25 %

 (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) %

(1)  Credit derivatives are used to economically hedge a portion of the private bank and 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 private bank and corporate lending revenues to reflect the cost of credit protection. Gains (losses) on 
loan hedges include $(74) million related to the corporate loan portfolio and $23 million related to the private bank for the year ended December 31, 2020. All of 
gains (losses) on loan hedges are related to the corporate loan portfolio for the years ended December 31, 2019 and 2018. 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. 
(3)  Excludes principal transactions revenues of ICG businesses other than Markets, primarily treasury and trade solutions and the private bank.
(4)  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

28

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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.

2020 vs. 2019
Net income decreased 9%, as higher revenues were more than 
offset by significantly higher credit costs and higher expenses.
Revenues increased 13%, driven by a 29% increase in 
Markets and securities services revenues, partially offset by a 
1% decrease in Banking revenues (including the impact of 
gains (losses) on loan hedges). Excluding the impact of gains 
(losses) on loan hedges, Banking revenues declined 3%, as 
growth in investment banking and the private bank was more 
than offset by a decrease in treasury and trade solutions and 
corporate lending. Excluding the pretax gain of approximately 
$350 million on Citi’s investment in Tradeweb in the prior 
year, Markets and securities services revenues increased 32%, 
primarily driven by growth in both fixed income markets and 
equity markets, partially offset by a decline in securities 
services.

Within Banking:

•

•

•

Investment banking revenues were up 11%, reflecting 
growth in overall market wallet as well as gains in wallet 
share. Advisory revenues decreased 20%, primarily 
reflecting a decline in the market wallet largely due to the 
pandemic and a decline in wallet share. Equity 
underwriting revenues increased 64%, reflecting growth 
in North America, EMEA and Asia, driven by continued 
strength in the market wallet, reflecting improved market 
liquidity and investor sentiment as well as wallet share 
gains. Debt underwriting revenues increased 7%, 
reflecting particular strength in North America, partially 
offset by Latin America, primarily driven by an increase 
in the second quarter of 2020, as the business assisted 
clients with sourcing liquidity. The increase in revenues 
was largely driven by a higher market wallet in 
investment grade debt underwriting, as well as an increase 
in overall wallet share.
Treasury and trade solutions revenues decreased 7%. 
Excluding the impact of FX translation, revenues 
decreased 5%, primarily driven by declines in EMEA and 
Asia. The decline in revenues was driven by both the cash 
and trade businesses. In the cash business, the decline in 
revenues reflected lower interest rates and a slowdown in 
commercial cards spend driven by the pandemic, partially 
offset by strong deposit volumes. Average deposit 
balances increased 23% (22% excluding the impact of FX 
translation), reflecting strong client engagement and solid 
growth across all regions. In trade, revenues were 
impacted by a decline in trade fees and trade loans, 
reflecting a slowdown in underlying trade flows related to 
the pandemic, partially offset by improved trade spreads.
Corporate lending revenues decreased 15%, including 
lower losses on loan hedges. Excluding the impact of 
losses on loan hedges, revenues decreased 25%, driven by 
lower loan spreads, an adjustment to the residual value of 
a lease financing asset and higher hedging costs, partially 
offset by higher average loan volumes. Average loans 
were up 4%, reflecting higher volumes as the business 

29

•

assisted clients with sourcing liquidity in the evolving 
environment, primarily in the first half of 2020. End-of-
period loans declined 9% in the current year, primarily 
reflecting repayments, as Citi’s clients accessed the 
capital markets, as well as lower loan demand in the 
second half of 2020, given more muted economic activity. 
Private bank revenues increased 9%. Excluding the 
impact of gains on loan hedges, revenues increased 8%, 
reflecting strength across all regions, driven by continued 
solid client engagement, in particular in capital markets, 
higher managed investments revenues and higher loan and 
deposit volumes, partially offset by lower deposit spreads 
due to the low interest rate environment.

Within Markets and securities services:

•

•

Fixed income markets revenues increased 34%. Excluding 
the Tradeweb gain in the prior year, revenues increased 
38%, reflecting strength across all regions, driven by 
strong client activity in rates and currencies, spread 
products and commodities, due to the impact of market 
conditions, including elevated volatility related to the 
pandemic primarily in the first half of the year, and 
developments related to vaccines and the U.S. elections in 
the second half of the year. Non-interest revenues 
increased, reflecting higher corporate and investor 
activity, given elevated volumes, spreads and volatility, 
primarily in the first half the year. Net interest revenues 
also increased, largely reflecting a change in the mix of 
trading positions in support of client activity, as well as 
lower funding costs. 

Rates and currencies revenues increased 32%, 

primarily driven by higher G10 rates and currencies 
revenues in North America and EMEA, as Citi helped 
corporate and investor clients reposition their portfolios in 
a volatile market environment driven by the pandemic 
largely in the first half of 2020. Spread products and other 
fixed income revenues increased 40%, reflecting strong 
client activity following robust primary issuance, 
particularly in flow trading, as well as a more favorable 
market making environment, as evidenced by spread 
tightening. Commodities revenues increased, reflecting a 
more favorable market making environment, as volatility 
remained elevated, particularly in gold and oil. 
Equity markets revenues increased 25%, driven by higher 
revenues in cash equities and derivatives, partially offset 
by a modest decline in prime finance revenues. Cash 
equities revenues increased driven by elevated levels of 
client activity. Equity derivatives revenues increased, 
reflecting strong client activity and continued market 
volatility, particularly in North America. The decline in 
prime finance revenues was largely due to lower 
financing spreads. Non-interest revenues increased, 
primarily driven by higher principal transactions and 
commissions and fee revenues, due to higher client 
activity and a more favorable trading environment due to 
volatility related to the pandemic and developments 

•

related to vaccines and U.S. elections, as well as a change 
in the mix of trading positions in support of client activity.
Securities services revenues decreased 3%. Excluding the 
impact of FX translation, revenues decreased 1%, as 
higher deposit volumes were more than offset by lower 
deposit spreads due to the low interest rate environment.

For additional information on trends in ICG’s deposits 

and trade loans, see “Managing Global Risk—Liquidity Risk
—Loans” and “—Deposits” below. 

Expenses increased 6%, reflecting investments in 

infrastructure, risk management and controls, higher 
compensation costs, operational losses related to certain legal 
matters and volume-driven growth, partially offset by 
efficiency savings. 

Provisions increased to $5.6 billion, driven by net credit 
losses of $987 million (compared to $394 million in the prior 
year), and an ACL build of $4.6 billion (compared to a modest 
build in the prior year under prior accounting standards). The 
increase in net credit losses was largely driven by write-offs 
across various sectors in both North America and EMEA, 
primarily reflecting energy and energy-related exposures. The 
net credit losses were partially offset by the release of 
previously established ACL reserves. 

The increase in the ACL build was driven by builds 
during the first half of 2020. The builds reflected the impact of 
a deterioration in Citi’s macroeconomic outlook under the 
CECL standard, driven by the impact of the pandemic across 
multiple sectors, as well as downgrades in the corporate 
portfolios. Sectors significantly impacted by the pandemic 
(including transportation; commercial real estate; energy and 
energy-related; and consumer retail) drove approximately half 
of the ACL reserve build during 2020. The reserve build also 
included an increase in the qualitative management adjustment 
to reflect the potential for a higher level of stress and a slower 
economic recovery. For additional information on Citi’s ACL 
accounting, see “Significant Accounting Policies and 
Significant Estimates” below and Notes 1 and 15 to the 
Consolidated Financial Statements.

As of December 31, 2020, reserves held on Citi’s balance 
sheet represented 1.4% of funded loans, compared to 0.7% as 
of December 31, 2019, including 4.4% of reserves held against 
the non-investment grade portion.

For additional information on ICG’s corporate credit 

portfolio, see “Managing Global Risk—Credit Risk—
Corporate Credit” below.

For additional information about trends, uncertainties and 

risks related to ICG’s future results, see “COVID-19 
Pandemic Overview” and “Risk Factors” above.

30

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, 2020, Corporate/Other had $96 
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 (recoveries) on loans

Credit reserve build (release) for loans
Provision (release) for credit losses on unfunded lending 
commitments
Provisions (releases) for benefits and claims, HTM debt 
securities and other assets
Provisions (releases) for credit losses and for benefits and 
claims

Income (loss) from continuing operations before taxes

Income taxes (benefits)

Income (loss) from continuing operations

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

Noncontrolling interests

Net income (loss)

NM Not meaningful

2020

2019

2018

% Change
2020 vs. 2019

% Change
2019 vs. 2018

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

(150)  $ 

204   

54  $ 

2,501  $ 

(22)  $ 

188   

11   

1   

178  $ 

(2,625)  $ 

(1,060)   

(1,565)  $ 

(20)   

(1,585)  $ 

(6)   

(1,579)  $ 

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) 

197 

11 

186 

NM

 65 %

 (97) %

 16 %

NM

NM

NM

 (20) %

NM

 (8) %

 (5) %

NM

 72 %

NM

 100 %

 100 

NM

NM

 (20) %

NM

NM

NM

NM

NM

 63 %

NM

NM

NM

 50 %

NM

 82 %

NM

Significant Estimates” below and Notes 1 and 15 to the 
Consolidated Financial Statements.

For additional information about trends, uncertainties and 

risks related to Corporate/Other’s future results, see 
“COVID-19 Pandemic Overview” above and “Risk Factors” 
below.

2020 vs. 2019 
Net loss was $1.6 billion, compared to net income of $801 
million in the prior year, largely driven by lower revenues, 
higher expenses, higher cost of credit and higher tax benefits 
in the prior year. The higher tax benefits in the prior year were 
primarily due to higher valuation allowance adjustments on 
Citi’s deferred tax assets. 

Revenues of $54 million decreased $2.0 billion, reflecting 

the impact of lower interest rates, episodic gains in the prior 
year, the wind-down of legacy assets and marks on securities.
Expenses increased 16%, as the wind-down of legacy 
assets was more than offset by investments in infrastructure, 
risk management and controls, the $400 million civil money 
penalty (for additional information, see “Executive Summary” 
and “Citi’s Consent Order Compliance” above) and 
incremental costs associated with the pandemic.

Provisions increased $253 million to $178 million, 
primarily driven by ACL builds of $199 million on legacy 
assets (versus a $67 million release in the prior year under 
prior accounting standards).

The ACL build was driven by builds during the first half 

of 2020 and primarily reflected the impact of a deterioration in 
Citi’s macroeconomic outlook under the CECL standard, 
primarily due to the pandemic. For additional information on 
Citi’s ACL, see “Significant Accounting Policies and 

31

 
 
 
 
 
 
 
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 and noncumulative perpetual 
preferred stock, 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 2020, Citi returned a total of $7.2 billion of capital 

to common shareholders in the form of share repurchases 
(approximately 41 million common shares) and dividends. On 
March 15, 2020, Citi announced it had joined other major U.S. 
banks in suspending share repurchases to support clients in 
light of the pandemic. Citi commenced share repurchases in 
February 2021. For additional information, see “Unregistered 
Sales of Equity Securities, Repurchases of Equity Securities 
and Dividends—Equity Security Repurchases” below.

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. 

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.

Under the U.S. Basel III rules, both Citi and Citibank, 

N.A. (Citibank) are 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. 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.

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. 

32

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. 

Temporary Supplementary Leverage Ratio Relief
In April 2020, the Federal Reserve Board issued an interim 
final rule that temporarily changes the calculation of the 
Supplementary Leverage ratio for bank holding companies, 
including Citigroup, by excluding U.S. Treasuries and 
deposits at Federal Reserve Banks from Total Leverage 
Exposure. Repo-style transactions on U.S. Treasuries are not 
in scope for this relief. The Supplementary Leverage ratio is a 
non-risk-sensitive measure, and the temporary exclusion 
allows banking organizations to expand their balance sheet, as 
appropriate, to continue to serve as financial intermediaries 
and to provide credit to households and businesses during the 
pandemic. 

Exposure. Accordingly, the calculation methodology of 
Citibank’s Supplementary Leverage ratio was unchanged.

Regulatory Capital Treatment—Modified Transition of the 
Current Expected Credit Losses Methodology
In September 2020, the U.S. banking agencies issued a final 
rule (substantially unchanged from a March 2020 interim final 
rule) that modifies the regulatory capital transition provision 
related to the current expected credit losses (CECL) 
methodology.

The final rule permits banks to delay for two years the 
“Day One” adverse regulatory capital effects resulting from 
adoption of the CECL methodology on January 1, 2020 until 
January 1, 2022, followed by a three-year transition to phase 
out the regulatory capital benefit provided by the delay.

In addition, for the ongoing impact of CECL, the agencies 

utilize a 25% scaling factor as an approximation of the 
increased reserve build under CECL compared to the previous 
incurred loss model and, therefore, allows banks to add back 
to Common Equity Tier 1 Capital an amount equal to 25% of 
the change in CECL-based allowances recognized through 
earnings in each quarter between January 1, 2020 and 
December 31, 2021. Beginning January 1, 2022, the 
cumulative 25% change in CECL-based allowances 
recognized through earnings between January 1, 2020 and 
December 31, 2021 will be phased in to regulatory capital at 
25% per year on January 1 of each year over the three-year 
transition period, along with the delayed “Day One” impact.

Citigroup and Citibank have elected the modified CECL 
transition provision provided by the rule beginning with the 
quarter ended March 31, 2020. Accordingly, the Day One 
regulatory capital effects resulting from adoption of the CECL 
methodology, as well as the ongoing adjustments for 25% of 
the change in CECL-based allowances recognized through 
earnings in each quarter between January 1, 2020 and 
December 31, 2021, will now commence phase-in on January 
1, 2022 and will be fully reflected in Citi’s regulatory capital 
as of January 1, 2025.

The interim final rule became effective for Citigroup’s 

For additional information on the U.S. banking agencies’ 

original regulatory capital transition provision related to the 
“Day One” adverse regulatory capital effects resulting from 
adoption of the CECL methodology, see “Capital Resources—
Regulatory Capital Treatment—Implementation and 
Transition of the Current Expected Credit Losses (CECL) 
Methodology” in Citi’s 2019 Annual Report on Form 10-K. 
Neither the September 2020 final rule nor the agencies’ prior 
guidance has any impact on U.S. GAAP accounting. 

Supplementary Leverage ratio, as well as for Citigroup’s 
leverage-based Total Loss Absorbing Capacity (TLAC) and 
Long-Term Debt (LTD) requirements, beginning with the 
quarter ended June 30, 2020, and will continue through March 
31, 2021. Citigroup’s reported Supplementary Leverage ratio 
of 7.0% benefited 109 basis points during the fourth quarter of 
2020 as a result of the temporary relief. Excluding the 
temporary relief, Citigroup’s Supplementary Leverage ratio 
would have been 5.9%, compared with a 5.0% effective 
minimum requirement.

In June 2020, the U.S. banking agencies issued an interim 

final rule permitting depository institutions, including 
Citibank, to elect to temporarily exclude U.S. Treasuries and 
deposits at Federal Reserve Banks from Total Leverage 
Exposure, subject to the condition that the depository 
institution receive approval from its primary federal banking 
regulator prior to paying dividends or making certain other 
capital distributions while the exclusion is in effect. Citibank 
did not elect to temporarily exclude U.S. Treasuries and 
deposits at Federal Reserve Banks from Total Leverage 

33

Regulatory Capital Buffers
Citi and Citibank are required to maintain several regulatory 
capital buffers above stated minimum capital requirements. 
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, share 
repurchases and discretionary executive bonuses), with the 
degree of such restrictions based upon the extent to which the 
buffers are breached. For additional information regarding 
limitations on capital distributions, see “Use of Regulatory 
Capital Buffers” below. 

Stress Capital Buffer
In March 2020, the Federal Reserve Board issued the final 
Stress Capital Buffer (SCB) rule, integrating the annual stress 
testing requirements with ongoing regulatory capital 
requirements. 

For Citigroup only, the SCB replaces the fixed 2.5% 

Capital Conservation Buffer under the Standardized 
Approach, and equals the peak-to-trough Common Equity Tier 
1 Capital ratio decline under the Supervisory Severely 
Adverse scenario used in the Comprehensive Capital Analysis 
and Review (CCAR) and Dodd-Frank Act Stress Testing 
(DFAST), plus four quarters of planned common stock 
dividends, subject to a floor of 2.5%. The fixed 2.5% Capital 
Conservation Buffer will continue to apply under the 
Advanced Approaches. SCB-based minimum capital 
requirements will generally be updated once per year as part of 
the CCAR process. For additional information regarding 
CCAR and DFAST, see “Stress Testing Component of Capital 
Planning” below.

In August 2020, the Federal Reserve Board finalized and 

announced Citi’s SCB requirement of 2.5%. Accordingly, 
effective October 1, 2020, Citigroup is required to maintain a 
10.0% effective minimum Common Equity Tier 1 Capital 
ratio under the Standardized Approach, which is unchanged 
from Citi’s previous effective minimum requirement Common 
Equity Tier 1 Capital ratio under the Standardized Approach 
inclusive of the 2.5% Capital Conservation Buffer. 

The Federal Reserve Board may, but is not required to, 

recalculate Citi’s SCB as a result of the capital plan 
resubmission, and has deferred such a decision through March 
31, 2021. For additional information on the capital plan 
resubmission, which the Federal Reserve Board required for 
each firm subject to its capital plan rule, see “Capital Plan 
Resubmission and Related Limitations on Capital 
Distributions” below. 

The SCB applies to Citigroup only. The regulatory capital 

framework applicable to Citibank, including the Capital 
Conservation Buffer, is unchanged by the SCB final rule.

Capital Conservation Buffer and Countercyclical Capital 
Buffer
Citigroup is subject to a fixed 2.5% Capital Conservation 
Buffer under the Advanced Approaches and, prior to the 
October 1, 2020 effective date of the SCB, under the 
Standardized Approach as well. Citibank is subject to the fixed 
2.5% Capital Conservation Buffer under both the Advanced 
Approaches and the Standardized Approach. 

Additionally, Advanced Approaches banking 
organizations, such as Citi and Citibank, are subject to a 
discretionary Countercyclical Capital Buffer. The Federal 
Reserve Board last voted to affirm the Countercyclical Capital 
Buffer amount at the current level of 0% in December 2020.

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 SCB, Capital Conservation Buffer and, if 
invoked, any Countercyclical Capital Buffer.

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. Under the second 
method (“method 2”), the substitutability category under the 
Basel Committee’s GSIB methodology 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, 2021 will be 
based on 2020 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, 2021 
would not become effective until January 1, 2023). 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, 2021 would become effective January 1, 2022).

34

The following table sets forth Citi’s effective GSIB 
surcharge as determined under method 1 and method 2 for 
2020 and 2019:

Method 1

Method 2

2020

2019

 2.0 %

 3.0 

 2.0 %

 3.0 

Citi’s GSIB surcharge effective for both 2020 and 2019 
was 3.0%, as derived under the higher method 2 result. Citi’s 
GSIB surcharge effective for 2021 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. Accordingly, Citi’s 
GSIB surcharge effective for 2022 will not exceed 3.0%. 
Citi’s GSIB surcharge effective for 2023 will likely be based 
on the lower of its method 2 scores for year-end 2020 and 
2021, and could increase to 3.5%.

Use of Regulatory Capital Buffers
In March 2020, the U.S. banking agencies issued a statement 
encouraging banking organizations to use their regulatory 
capital buffers as they respond to the challenges presented by 
the effects of the COVID-19 pandemic. 

Consistent with the statement, in October 2020, the U.S. 
banking agencies issued a final rule (substantially unchanged 
from two previous interim final rules in March 2020) that 
eases capital distribution limitations in the original U.S. Basel 
III rules, in an effort to reduce the impact of using regulatory 
capital buffers. The changes in the rule have the potential to 
prevent a complete and sudden cessation of capital 
distributions due to a breach of regulatory capital buffers, 
which include the SCB, Capital Conservation Buffer, GSIB 
surcharge, and any Countercyclical Capital Buffer (currently 
0%). 

The rule became effective in March 2020, and applies to 

risk-based capital ratios, the Supplementary Leverage ratio, 
and RWA-based or leverage-based external TLAC buffers. 
External Long-Term Debt requirements do not include any 
buffers and are, therefore, unaffected by the final rule. For 
additional information on Citi’s TLAC-related requirements, 
see “Total Loss-Absorbing Capacity (TLAC)” and “Risk 
Factors—Compliance, Conduct and Legal Risks” below.

More specifically, under the U.S. Basel III rules, banking 

organizations that fall below their regulatory capital buffers 
are subject to limitations on capital distributions and 
discretionary bonus payments to executive officers based on a 
percentage of “Eligible Retained Income” (ERI), with 
increasing restrictions based upon the severity of the breach. 
The original definition of ERI in the U.S. Basel III rules was 
equal to the bank’s net income for the four calendar quarters 
preceding the current calendar quarter, net of any distributions 
and tax effects not already reflected in net income. The final 
rule revises the definition of ERI to equal the greater of: (i) the 
bank’s net income for the four calendar quarters preceding the 
current calendar quarter, net of any distributions and tax 
effects not already reflected in net income, and (ii) the average 
of the bank’s net income for the four calendar quarters 
preceding the current calendar quarter.

35

As of December 31, 2020, Citi’s regulatory capital ratios 
exceeded effective regulatory minimum requirements. Citi is 
not subject to payout limitations as a result of Basel III 
requirements. For information related to capital distribution 
limitations that are currently in effect for large banks, see 
“Capital Plan Resubmission and Related Limitations on 
Capital Distributions” below.

The impact of the final rule on Citibank is limited, 
because the minimum requirements to be considered “well-
capitalized” under the Prompt Corrective Action (PCA) 
framework are unchanged.

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, 2020.

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 a qualitative evaluation of a firm’s abilities to 
determine its capital needs on a forward-looking basis. In 
conducting the qualitative assessment, the Federal Reserve 
Board evaluates firms’ capital planning practices, focusing on 
six areas of capital planning—namely, governance, risk 
management, internal controls, capital policies, incorporating 
stressful conditions and events, and estimating impact on 
capital positions. 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 share 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. 

 
Since firms are now required to maintain risk-based 
capital ratio minimum requirements that integrate stress test 
results, the Federal Reserve Board’s SCB final rule eliminated 
a number of previous CCAR requirements, including the once-
a-year quantitative objection, the pre-approval requirement 
from the Federal Reserve Board for making distributions in 
excess of planned capital actions, and the 30% dividend 
payout ratio as a criterion for heightened supervisory scrutiny.
All CCAR firms, including Citi, are 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.

Capital Plan Resubmission and Related Limitations on 
Capital Distributions
In June 2020, the Federal Reserve Board determined that 
changes in financial markets and macroeconomic outlooks 
related to the COVID-19 pandemic could have a material 
effect on the risk profile and financial condition of each firm 
subject to its capital plan rule and, therefore, required updated 
capital plans. Citigroup resubmitted its capital plan in 
November 2020.

In December 2020, the Federal Reserve Board announced
that it was modifying and extending for an additional quarter 
several measures that were previously announced for the third 
and fourth quarters of 2020 to ensure that large banks maintain 
a high level of capital resilience. Through the end of the first 
quarter of 2021, the Federal Reserve Board has authorized 
firms, including Citi, to pay common stock dividends and 
make share repurchases that, in the aggregate, do not exceed 
an amount equal to the average of the firm’s net income for 
the four preceding calendar quarters, unless otherwise 
specified by the Federal Reserve Board, provided that the firm 
does not exceed the amount of common stock dividends paid 
in the second quarter of 2020. Additionally, through the end of 
the first quarter of 2021, the Federal Reserve Board has 
authorized firms to make share repurchases relating to 
issuances of common stock related to employee stock 
ownership plans, and to redeem and make scheduled payments 
on Additional Tier 1 Capital and Tier 2 Capital instruments. 
These limitations on capital distributions may be extended or 
modified by the Federal Reserve Board.

On June 29, 2020, Citi announced its planned capital 
actions including common dividends. Citi is permitted to 
return capital to common shareholders of up $2.8 billion 
during the first quarter of 2021, including the previously 
announced common dividends of $0.51 per share in the 
quarter, consistent with the Federal Reserve Board’s income-
based formula for temporary limitations on common dividends 
and common share repurchases announced in December 2020. 
Citi commenced share repurchases in February 2021.

The Federal Reserve Board may, but is not required to, 

recalculate Citi’s SCB as a result of the capital plan 
resubmission, and has deferred such a decision up to March 
31, 2021.

36

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, 2020, September 30, 2020 and 
December 31, 2019:

Advanced Approaches

Standardized Approach

In millions of dollars, except ratios
Common Equity Tier 1 Capital(2)
Tier 1 Capital

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

   Operational Risk

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

Effective 
Minimum 

Requirement(1) Dec. 31, 2020 Sep. 30, 2020 Dec. 31, 2019 Dec. 31, 2020 Sep. 30, 2020 Dec. 31, 2019
137,798 
$  137,798 

$  142,158 

$  142,158 

$  147,274 

$  147,274 

$ 

167,053 

160,311 

155,805 

167,053 

160,311 

155,805 

195,959 

189,477 

181,337 

204,849 

198,120 

193,711 

  1,255,284 

  1,218,977 

  1,142,804 

  1,221,576 

  1,178,219 

1,168,848 

$  844,374 

$  821,024 

$  778,759 

$ 1,109,435 

$ 1,077,719 

$  1,110,100 

107,812 

303,098 

96,873 

301,080 

57,317 

306,728 

112,141 

100,500 

58,748 

— 

— 

— 

 10.0 %

 11.73 %

 11.66 %

 12.06 %

 12.06 %

 12.07 %

 11.79 %

 11.5 

 13.5 

 13.31 

 15.61 

 13.15 

 15.54 

 13.63 

 15.87 

 13.68 

 16.77 

 13.61 

 16.82 

 13.33 

 16.57 

In millions of dollars, except ratios
Quarterly Adjusted Average Total Assets(2)(4)
Total Leverage Exposure(2)(5)

Tier 1 Leverage ratio

Supplementary Leverage ratio

Effective 
Minimum 
Requirement

Dec. 31, 2020

Sept. 30, 2020

Dec. 31, 2019

$ 

2,265,615 

$ 

2,224,446 

$ 

4.0%

5.0

2,386,881 

2,349,620 

 7.37 %

 7.00 

 7.21 %

 6.82 

1,957,039 

2,513,702 

 7.96 %

 6.20 

(1) Beginning October 1, 2020, Citi’s effective minimum risk-based capital requirements include the 2.5% SCB and 3.0% GSIB surcharge under the Standardized 
Approach, and the 2.5% Capital Conservation Buffer and 3.0% GSIB surcharge under the Advanced Approaches (all of which must be composed of Common 
Equity Tier 1 Capital). For prior periods presented, Citi’s effective minimum risk-based capital requirements include the 2.5% Capital Conservation Buffer and the 
3.0% GSIB surcharge under both Approaches.

(2) Citi has elected to apply the modified transition provision related to the impact of the CECL accounting standard on regulatory capital, as provided by the U.S. 

banking agencies’ September 2020 final rule. Under the modified CECL transition provision, the changes in retained earnings (after-tax), deferred tax assets 
(DTAs) arising from temporary differences, and the ACL upon the January 1, 2020 CECL adoption date have been deferred and will phase in to regulatory capital 
at 25% per year commencing January 1, 2022. For the ongoing impact of CECL, Citigroup is allowed to adjust retained earnings and the ACL in an amount equal 
to 25% of the change in the ACL recognized through earnings (pretax) for each period between January 1, 2020 and December 31, 2021. The cumulative 
adjustments to retained earnings and the ACL between January 1, 2020 and December 31, 2021 will also phase in to regulatory capital at 25% per year 
commencing January 1, 2022, along with the deferred impacts related to the January 1, 2020 CECL adoption date. Corresponding adjustments to average on-
balance sheet assets are reflected in quarterly adjusted average total assets and Total Leverage Exposure. Additionally, the increase in DTAs arising from 
temporary differences upon the January 1, 2020 adoption date has been deducted from risk-weighted assets (RWA) and will phase in to RWA at 25% per year 
commencing January 1, 2022.

(3) Citi’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were derived under the Basel III Advanced Approaches framework as of December 31, 
2020 and September 30, 2020, and the Basel III Standardized Approach as of December 31, 2019, whereas Citi’s reportable Total Capital ratio was the lower 
derived under the Basel III Advanced Approaches framework for all periods presented.

(4) Tier 1 Leverage ratio denominator. Represents quarterly average total assets less amounts deducted from Tier 1 Capital. 
(5) Supplementary Leverage ratio denominator. Commencing with the second quarter of 2020, Citigroup’s Total Leverage Exposure temporarily excludes U.S. 

Treasuries and deposits at Federal Reserve Banks. For additional information, see “Temporary Supplementary Leverage Ratio Relief” above.

37

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Common Equity Tier 1 Capital Ratio 
Citi’s Common Equity Tier 1 Capital ratio was 11.7% at 
December 31, 2020 and September 30, 2020, both under the 
Basel III Advanced Approaches framework. Citi’s reportable 
Common Equity Tier 1 Capital ratio was 11.8% at December 
31, 2019 under the Basel III Standardized Approach. Citi’s 
Common Equity Tier 1 Capital ratio remained unchanged 
from September 30, 2020, as a net increase in risk-weighted 
assets and the return of $1.1 billion capital to common 

shareholders in the form of dividends were offset by quarter-
to-date net income of $4.3 billion. Citi’s Common Equity Tier 
1 Capital ratio decreased from year-end 2019, largely driven 
by a net increase in risk-weighted assets and the return of $7.2 
billion of capital to common shareholders in the form of share 
repurchases and dividends, partially offset by year-to-date net 
income of $11.0 billion, beneficial net movements in AOCI, 
and the relief of the modified CECL transition provision.

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:
Add: CECL transition and 25% provision deferral(2)
Less: Accumulated net unrealized gains (losses) on cash flow hedges, net of tax

December 31,
2020

December 31,
2019

$ 

180,118  $ 

175,414 

141   

5,348   

1,593   

154 

— 

123 

Less: Cumulative unrealized net gain (loss) related to changes in fair value of financial liabilities 
attributable to own creditworthiness, net of tax

(1,109)   

(679) 

Less: Intangible assets:
  Goodwill, net of related DTLs(3)
   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(4)
Total Common Equity Tier 1 Capital (Advanced Approaches and Standardized Approach)

Additional Tier 1 Capital
Qualifying noncumulative perpetual preferred stock(1)
Qualifying trust preferred securities(5)
Qualifying noncontrolling interests

Regulatory capital deductions:
Less: Permitted ownership interests in covered funds(6)
Less: Other

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

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

Tier 2 Capital

Qualifying subordinated debt
Qualifying trust preferred securities(7)
Qualifying noncontrolling interests
Excess of eligible credit reserves over expected credit losses(2)(8)
Regulatory capital deduction:

Less: Other

Total Tier 2 Capital (Advanced Approaches)

Total Capital (Tier 1 Capital + Tier 2 Capital) (Advanced Approaches)
Adjustment for eligible allowance for credit losses(2)(8)
Total Tier 2 Capital (Standardized Approach)

Total Capital (Tier 1 Capital + Tier 2 Capital) (Standardized Approach)

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

21,124   

4,166   

921   

11,638   

147,274  $ 

19,324  $ 

1,393   

35   

917   

56   

19,779  $ 

21,066 

4,087 

803 

12,370 

137,798 

17,828 

1,389 

42 

1,216 

36 

18,007 

167,053  $ 

155,805 

23,481  $ 

23,673 

331   

41   

5,084   

31   

28,906  $ 

195,959  $ 

8,890  $ 

37,796  $ 

326 

46 

1,523 

36 

25,532 

181,337 

12,374 

37,906 

204,849  $ 

193,711 

Footnotes continue on the following page.

38

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(1)

Issuance costs of $156 million and $152 million related to noncumulative perpetual preferred stock outstanding at December 31, 2020 and 2019, 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) Citi has elected to apply the modified transition provision related to the impact of the CECL accounting standard on regulatory capital, as provided by the U.S. 
banking agencies’ September 2020 final rule. Under the modified CECL transition provision, the changes in retained earnings (after-tax) and the ACL upon the 
January 1, 2020 CECL adoption date have been deferred and will phase in to regulatory capital at 25% per year commencing January 1, 2022. For the ongoing 
impact of CECL, Citigroup is allowed to adjust retained earnings and the ACL in an amount equal to 25% of the change in the ACL recognized through earnings 
(pretax) for each period between January 1, 2020 and December 31, 2021. The cumulative adjustments to retained earnings and the ACL between January 1, 2020 
and December 31, 2021 will also phase in to regulatory capital at 25% per year commencing January 1, 2022, along with the deferred impacts related to the 
January 1, 2020 CECL adoption date.
Includes goodwill “embedded” in the valuation of significant common stock investments in unconsolidated financial institutions. 

(3)
(4) Of Citi's $24.8 billion of net DTAs at December 31, 2020, $15.3 billion was includable in Common Equity Tier 1 Capital pursuant to the U.S. Basel III rules, 

while $9.5 billion was excluded. Excluded from Citi's Common Equity Tier 1 Capital as of December 31, 2020 was $11.6 billion of net DTAs arising from net 
operating loss, foreign tax credit and general business credit tax carry-forwards. The amount excluded was reduced by $2.1 billion of net DTLs primarily 
associated with goodwill and certain other intangible assets that are separately deducted from capital. DTAs arising from tax carry-forwards are required to be 
entirely deducted from Common Equity Tier 1 Capital under the U.S. Basel III rules. DTAs arising from temporary differences are required to be deducted from 
capital only if these DTAs exceed a 10% limitation under the U.S. Basel III rules. Citi’s DTAs do not currently exceed this limitation and, therefore, are not 
subject to deduction from Common Equity Tier 1 Capital, but are subject to risk weighting at 250%. 

(5) Represents Citigroup Capital XIII trust preferred securities, which are permanently grandfathered as Tier 1 Capital under the U.S. Basel III rules. 
(6) 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. The U.S. agencies issued a revised Volcker Rule 2.0 in November 2019 that 
removes permitted investments in third-party covered funds from capital deduction requirements, among other changes. Upon the removal of the capital 
deduction, permitted investments in third-party covered funds will be included in risk-weighted assets. Mandatory compliance with the revised Volcker Rule 2.0 is 
required by January 1, 2021, with early adoption permitted, in whole or in part, beginning January 1, 2020. Additionally, the U.S. agencies issued a revised 
Volcker Rule 2.1 in July 2020 that improves and streamlines several “covered funds” requirements, with an effective date of October 1, 2020. Citi continues to 
deduct from Tier 1 Capital all permitted ownership interests in covered funds for all periods presented. 

(7) 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.

(8) 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 ACL is eligible for inclusion in 
Tier 2 Capital up to 1.25% of credit risk-weighted assets, with any excess ACL being deducted in arriving at credit risk-weighted assets. The total amount of ACL 
that was eligible for inclusion in Tier 2 Capital, subject to limitation, under the Standardized Approach framework was $14.0 billion and $13.9 billion at 
December 31, 2020 and December 31, 2019 respectively. 

39

Citigroup Capital Rollforward 

In millions of dollars
Common Equity Tier 1 Capital, beginning of period
Net income
Common and preferred dividends declared
 Net change in treasury stock
Net increase 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 increase in excluded component of fair value hedges
Net increase in goodwill, net of related DTLs 
Net change in identifiable intangible assets other than MSRs, net of related DTLs
Net change in defined benefit pension plan net assets
 Net decrease in DTAs arising from net operating loss, foreign tax credit and 
 general business credit carry-forwards
Net change in CECL 25% provision deferral
Other
Net increase in Common Equity Tier 1 Capital
Common Equity Tier 1 Capital, end of period 
(Advanced Approaches and Standardized Approach)
Additional Tier 1 Capital, beginning of period
Net increase in qualifying perpetual preferred stock
Net change in qualifying trust preferred securities
Net decrease in permitted ownership interests in covered funds
Other
Net increase in Additional Tier 1 Capital

Tier 1 Capital, end of period 
(Advanced Approaches and Standardized Approach)
Tier 2 Capital, beginning of period (Advanced Approaches)
Net decrease in qualifying subordinated debt
Net increase 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)
Tier 2 Capital, beginning of period (Standardized Approach)
Net decrease in qualifying subordinated debt
Net increase 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)

$ 

$ 

$ 
$ 

$ 

$ 
$ 

$ 
$ 
$ 
$ 

$ 
$ 
$ 

Three months ended 
December 31, 2020

Twelve months ended
December 31, 2020

142,158  $ 
4,309   
(1,340)   
8   
87   
2,401   
(98)   
62   

62   
(16)   
(602)   
82   
28   

423   
(290)   
—   
5,116  $ 

147,274  $ 
18,153  $ 
1,495   
—   
158   
(27)   
1,626  $ 

167,053  $ 
29,113  $ 
(397)   
185   
5   
(207)  $ 
28,906  $ 
195,959  $ 
37,768  $ 
(397)   
420   
5   
28  $ 
37,796  $ 
204,849  $ 

137,798 
11,047 
(5,394) 
(2,469) 
10 
(250) 
3,585 
(55) 

(45) 
(15) 
(58) 
(79) 
(118) 

732 
2,463 
122 
9,476 

147,274 
18,007 
1,496 
4 
299 
(27) 
1,772 

167,053 
25,532 
(192) 
3,561 
5 
3,374 
28,906 
195,959 
37,877 
(192) 
106 
5 
(81) 
37,796 
204,849 

40

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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
Equity exposures
Over-the-counter (OTC) derivatives(4)
Derivatives CVA(5)
Other exposures(6)
Supervisory 6% multiplier
Net increase in Credit Risk-Weighted Assets
Changes in Market Risk-Weighted Assets
Risk levels(7)
Model and methodology updates(7)
Net increase in Market Risk-Weighted Assets 
Net change in Operational Risk-Weighted Assets(8)
Total Risk-Weighted Assets, end of period

Three months ended 
December 31, 2020

Twelve months ended
December 31, 2020

$ 

1,218,977  $ 

1,142,804 

(299)   

(1,690)   
1,277   
1,122   
874   

5,199   
7,138   

8,884   

845   
23,350  $ 

6,726  $ 
4,213   
10,939  $ 

2,018  $ 
1,255,284  $ 

(23,709) 

24,631 
15,618 
(1,089) 
924 

21,837 
17,713 

6,810 

2,880 
65,615 

31,744 
18,751 
50,495 

(3,630) 
1,255,284 

$ 

$ 

$ 

$ 
$ 

(1) Retail exposures decreased during the 12 months ended December 31, 2020, primarily driven by lower consumer activity in 2020 due to the pandemic.
(2) Wholesale exposures decreased during the three months ended December 31, 2020, primarily due to reductions in commercial loans partially offset by an increase 

in investment securities. Wholesale exposures increased during the 12 months ended December 31, 2020, primarily due to increases in investment securities and 
rating downgrades partially offset by annual model parameter updates reflecting Citi’s loss experiences.

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

transactions increased during the 12 months ended December 31, 2020, mainly driven by market volatility and volume increases.

(4) OTC derivatives increased during the three months ended December 31, 2020, primarily due to an increase in mark-to-market gains for bilateral derivatives. OTC 

derivatives increased during the 12 months ended December 31, 2020, primarily due to increases in mark-to-market gains and notional for bilateral derivatives. 

(5) Derivatives CVA increased during the three months ended December 31, 2020, primarily due to new trades with higher credit spreads and sensitivity. Derivatives 

CVA increased during the 12 months ended December 31, 2020, primarily due to widening credit spreads and market volatility.

(6) 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 and 12 months ended December 31, 2020, primarily due to increases in centrally cleared transactions and 
various other assets. 

(7) Market risk-weighted assets increased during the three months ended December 31, 2020 primarily due to changes in exposures impacting Stressed Value at Risk 
and Securitization charges. Market risk-weighted assets increased during the 12 months ended December 31, 2020 primarily driven by increases in market 
volatility due to the pandemic.

(8) Operational risk-weighted assets increased during the three months December 31, 2020, primarily due to changes in operational loss frequency. Operational risk-

weighted assets decreased during the 12 months ended December 31, 2020, primarily due to changes in operational loss severity and frequency.

41

 
 
 
 
 
 
 
 
 
 
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
Over-the-counter (OTC) derivatives(3)
Other exposures(4)
Off-balance sheet exposures(5)
Net change in Credit Risk-Weighted Assets

Changes in Market Risk-Weighted Assets
Risk levels(6)
Model and methodology updates(6)
Net increase in Market Risk-Weighted Assets 

Total Risk-Weighted Assets, end of period

Three months ended 
December 31, 2020

Twelve months ended
December 31, 2020

$ 

1,178,219  $ 

1,168,848 

11,075   

6,274   

1,184   

1,387   

4,518   

5,275   

2,003   

31,716  $ 

7,428  $ 

4,213   

11,641  $ 

(26,602) 

13,440 

1,119 

1,269 

16,331 

(1,582) 

(4,640) 

(665) 

34,642 

18,751 

53,393 

1,221,576  $ 

1,221,576 

$ 

$ 

$ 

$ 

(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 months ended December 31, 2020 primarily due to new accounts and holiday spending for qualifying revolving exposures (cards) partially offset 
by reductions in commercial loans. General credit risk exposures decreased during the 12 months ended December 31, 2020 primarily due to lesser spending for 
qualifying revolving (cards) exposures due to the pandemic. 

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

transactions increased during the three months and 12 months ended December 31, 2020, primarily due to increases in exposure and volume. 

(3) OTC derivatives increased during the three months ended December 31, 2020 primarily due to an increases in mark-to-market gains for bilateral derivatives. OTC 
derivatives increased during the 12 months ended December 31, 2020 primarily due to increases in mark-to-market gains and notional for bilateral derivatives.

(4) Other exposures include cleared transactions, unsettled transactions, and other assets. Other exposures increased during three months ended December 31, 2020 

primarily due to increases in other assets and centrally cleared transactions. Other exposures decreased during the 12 months ended December 31, 2020 primarily 
due to decreases in notional for centrally cleared derivatives and excess of credit reserves not included in Tier 2 capital eligible for RWA reduction.

(5) Off-balance sheet exposures increased during the three months ended December 31, 2020 primarily due to an increase in loan commitments. Off-balance sheet 

exposures decreased during the 12 months ended December 31, 2020 primarily due to a decrease in loan commitments.

(6) Market risk-weighted assets increased during the three months ended December 31, 2020 primarily due to changes in exposures impacting Stressed Value at Risk 
and Securitization charges. Market risk-weighted assets increased during the 12 months ended December 31, 2020 primarily driven by increases in market 
volatility due to the pandemic.

42

 
 
 
 
 
 
 
 
Supplementary Leverage Ratio
The following table sets forth Citi’s Supplementary Leverage 
ratio and related components as of December 31, 2020, 
September 30, 2020 and December 31, 2019:

In millions of dollars, except ratios

Tier 1 Capital

Total Leverage Exposure

On-balance sheet assets(1)(2)(3)
Certain off-balance sheet exposures:(4)
   Potential future exposure on derivative contracts
   Effective notional of sold credit derivatives, net(5)
   Counterparty credit risk for repo-style transactions(6)
   Unconditionally cancelable commitments
   Other off-balance sheet exposures

Total of certain off-balance sheet exposures

Less: Tier 1 Capital deductions
Total Leverage Exposure(3) 
Supplementary Leverage ratio

December 31, 2020

September 30, 2020 December 31, 2019

$ 

$ 

$ 

$ 

167,053 

$ 

160,311 

$ 

155,805 

1,864,374 

$ 

1,844,609 

$ 

1,996,617 

183,604 

32,640 

20,168 

71,163 
253,754 

176,424 

33,103 

18,095 

71,338 
244,934 

561,329 

$ 

543,894 

$ 

38,822 

38,883 

175,289 

38,481 

23,715 

70,870 
248,308 

556,663 

39,578 

2,386,881 

$ 

2,349,620 

$ 

2,513,702 

 7.00 %

 6.82 %

 6.20 %

(1) Represents the daily average of on-balance sheet assets for the quarter.
(2) Citi has elected to apply the modified transition provision related to the impact of the CECL accounting standard on regulatory capital, as provided by the U.S. 
banking agencies’ September 2020 final rule. Under the modified CECL transition provision, the changes in DTAs arising from temporary differences and the 
ACL upon the January 1, 2020 CECL adoption date have been deferred and will phase in to regulatory capital at 25% per year commencing January 1, 2022. For 
the ongoing impact of CECL, Citigroup is allowed to adjust the ACL in an amount equal to 25% of the change in the ACL recognized through earnings (pretax) 
for each period between January 1, 2020 and December 31, 2021. The cumulative adjustments to the ACL between January 1, 2020 and December 31, 2021 will 
also phase in to regulatory capital at 25% per year commencing January 1, 2022, along with the deferred impacts related to the January 1, 2020 CECL adoption 
date. Corresponding adjustments to average on-balance sheet assets are reflected in Total Leverage Exposure.

(3) Commencing with the second quarter of 2020, Citigroup’s Total Leverage Exposure temporarily excludes U.S. Treasuries and deposits at Federal Reserve Banks. 

For additional information, see “Temporary Supplementary Leverage Ratio Relief” above. 

(4) Represents the average of certain off-balance sheet exposures calculated as of the last day of each month in the quarter. 
(5) 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. 

(6) 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 7.0% at December 31, 2020, compared to 
6.8% at September 30, 2020 and 6.2% at December 31, 2019. 
The quarter-over-quarter increase was primarily driven by an 
increase in Tier 1 Capital resulting from net income and 
beneficial net movements in AOCI, partially offset by an 
increase in both average on-balance sheet assets and average 
off-balance sheet exposures. The year-over-year increase was 
primarily driven by a decrease in Total Leverage Exposure 
mainly attributable to the 109 basis point benefit resulting 
from the Federal Reserve Board’s temporary Supplementary 
Leverage ratio relief.

43

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 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, 2020, September 30, 2020 and 
December 31, 2019:

Advanced Approaches

Standardized Approach

In millions of dollars, except ratios
Common Equity Tier 1 Capital(2)
Tier 1 Capital

Total Capital (Tier 1 Capital + 
Tier 2 Capital)(2)(3)
Total Risk-Weighted Assets
   Credit Risk(2)
   Market Risk

   Operational Risk

Common Equity Tier 1 Capital 
ratio(4)(5)
Tier 1 Capital ratio(4)(5)
Total Capital ratio(4)(5)

Effective 
Minimum 

Requirement(1) Dec. 31, 2020 Sept. 30, 2020 Dec. 31, 2019 Dec. 31, 2020 Sept. 30, 2020 Dec. 31, 2019
$  130,720 

$  138,310 

$  138,310 

$  130,720 

$  142,884 

$  142,884 

  144,992 

140,397 

132,847 

  144,992 

140,397 

132,847 

  161,294 

156,697 

145,918 

  169,235 

164,459 

157,253 

  1,012,129 

  1,003,634 

938,735 

  1,030,081 

  1,010,583 

  1,022,607 

$  707,163 

$  706,187 

$  671,131 

$  969,416 

$  954,127 

$  993,010 

59,815 

  245,151 

55,853 

241,594 

29,167 

238,437 

60,665 

56,456 

29,597 

— 

— 

— 

 7.00 %

 14.12 %

 13.78 %

 13.93 %

 13.87 %

 13.69 %

 12.78 %

 8.50 

 10.50 

 14.33 

 15.94 

 13.99 

 15.61 

 14.15 

 15.54 

 14.08 

 16.43 

 13.89 

 16.27 

 12.99 

 15.38 

In millions of dollars, except ratios
Quarterly Adjusted Average Total Assets(2)(6)
Total Leverage Exposure(2)(7)
Tier 1 Leverage ratio(5)
Supplementary Leverage ratio(5)

Effective 
Minimum 
Requirement

Dec. 31, 2020

Sept. 30, 2020

Dec. 31, 2019

$ 

1,680,056 

$ 

1,646,280 

$ 

5.0%

6.0

2,167,969 

2,128,033 

 8.63 %

 6.69 

 8.53 %

 6.60 

1,459,780 

1,958,173 

 9.10 %

 6.78 

(1) Citibank’s effective minimum risk-based capital requirements are inclusive of the 2.5% Capital Conservation Buffer (all of which must be composed of Common 

Equity Tier 1 Capital).

(2) Citibank has elected to apply the modified transition provision related to the impact of the CECL accounting standard on regulatory capital, as provided by the 

U.S. banking agencies’ September 2020 final rule. Under the modified CECL transition provision, the changes in retained earnings (after-tax), deferred tax assets 
(DTAs) arising from temporary differences, and the ACL upon the January 1, 2020 CECL adoption date have been deferred and will phase in to regulatory capital 
at 25% per year commencing January 1, 2022. For the ongoing impact of CECL, Citibank is allowed to adjust retained earnings and the ACL in an amount equal 
to 25% of the change in the ACL recognized through earnings (pretax) for each period between January 1, 2020 and December 31, 2021. The cumulative 
adjustments to retained earnings and the ACL between January 1, 2020 and December 31, 2021 will also phase in to regulatory capital at 25% per year 
commencing January 1, 2022, along with the deferred impacts related to the January 1, 2020 CECL adoption date. Corresponding adjustments to average on-
balance sheet assets are reflected in quarterly adjusted average total assets and Total Leverage Exposure. Additionally, the increase in DTAs arising from 
temporary differences upon the January 1, 2020 adoption date has been deducted from risk-weighted assets (RWA) and will phase in to RWA at 25% per year 
commencing January 1, 2022.

(3) 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 ACL is eligible for inclusion in 
Tier 2 Capital up to 1.25% of credit risk-weighted assets, with any excess ACL being deducted in arriving at credit risk-weighted assets.

(4) Citibank’s reportable Total Capital ratio was derived under the Basel III Advanced Approaches framework as of December 31, 2020 and September 30, 2020, and 
the Basel III Standardized Approach as of December 31, 2019, whereas Citibank’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the 
lower derived under the Basel III Standardized Approach framework for all periods presented.

(5) 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.” 

(6) Tier 1 Leverage ratio denominator. Represents quarterly average total assets less amounts deducted from Tier 1 Capital.
(7) Supplementary Leverage ratio denominator. Citibank did not elect to temporarily exclude U.S. Treasuries and deposits at Federal Reserve Banks from Total 

Leverage Exposure. For additional information, see “Temporary Supplementary Leverage Ratio Relief” above.

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

December 31, 2020 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, 2020. 

44

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020. 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

Tier 1 Capital ratio

Total Capital ratio

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

0.8

0.8

1.0

1.0

Impact of
$1 billion
change in risk-
weighted assets

Impact of
$100 million
change in
Tier 1 Capital

Impact of
$1 billion
change in risk-
weighted assets

Impact of
$100 million
change in
Total Capital

Impact of
$1 billion
change in risk-
weighted assets

0.9

1.0

1.4

1.3

0.8

0.8

1.0

1.0

1.1

1.1

1.4

1.4

0.8

0.8

1.0

1.0

1.2

1.4

1.6

1.6

Tier 1 Leverage ratio

Supplementary Leverage ratio

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

0.3

0.5

Impact of
$100 million
change in
Tier 1 Capital

0.4

0.6

Impact of
$100 million
change in
Tier 1 Capital

Impact of
$1 billion
change in 
Total Leverage 
Exposure

0.4

0.5

0.3

0.3

In basis points
Citigroup

Advanced Approaches

Standardized Approach 

Citibank

Advanced Approaches

Standardized Approach 

In basis points

Citigroup

Citibank

Citigroup Broker-Dealer Subsidiaries
At December 31, 2020, 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 
$12.7 billion, which exceeded the minimum requirement by 
$9.2 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 $23.5 
billion at December 31, 2020, 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, 2020. 

45

Total Loss-Absorbing Capacity (TLAC) 
U.S. GSIBs, including Citi, are required to maintain minimum
levels of TLAC and eligible long-term debt (LTD), each set by
reference to the GSIB’s consolidated risk-weighted assets
(RWA) and total leverage exposure.

Minimum External TLAC Requirement
The minimum external 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 leverage-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 was 22.5% of 
RWA for 2020.

Minimum LTD Requirement
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.

The table below details Citi’s eligible external TLAC and
LTD amounts and ratios, and each effective minimum TLAC 
and LTD ratio requirement, as well as the surplus amount in 
dollars in excess of each requirement.

In billions of dollars, except ratios

Total eligible amount
% of Advanced Approaches risk-
weighted assets
Effective minimum requirement(1)(2)
Surplus amount
% of Total Leverage Exposure(3)
Effective minimum requirement

Surplus amount

December 31, 2020

External 
TLAC

LTD

$ 

311 

$ 

140 

 24.8 %

 11.1 %

 22.5 
29 

 13.0 %

 9.5 

85 

$ 

$ 

$ 

$ 

 9.0 
27 

 5.8 %

 4.5 

32 

(1)  External TLAC includes Method 1 GSIB surcharge of 2.0%.
(2)  LTD includes Method 2 GSIB surcharge of 3.0%.
(3)  Commencing with the second quarter of 2020, Citigroup’s Total 

Leverage Exposure temporarily excludes U.S. Treasuries and deposits at 
Federal Reserve Banks. 

As of December 31, 2020, Citi exceeded each of the
minimum TLAC and LTD requirements, resulting in a $27
billion surplus above its binding TLAC requirement of LTD as
a percentage of Advanced Approaches risk-weighted assets.
For additional discussion of the method 1 and method 2
GSIB capital surcharge methodologies, see “Regulatory 
Capital Buffers—GSIB Surcharge” above.

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

Capital Resources (Full Adoption of CECL, and Excluding Temporary Supplementary Leverage Ratio Relief for Citigroup)
The following tables set forth Citigroup’s and Citibank’s capital components and ratios reflecting the full impact of CECL, and 
excluding temporary Supplementary Leverage ratio relief for Citigroup, as of December 31, 2020:

Citigroup

Citibank

Effective 
Minimum 
Requirement

Advanced 
Approaches

Standardized 
Approach

Effective 
Minimum 
Requirement

Advanced 
Approaches

Standardized 
Approach

Common Equity Tier 1 Capital ratio

 10.0 %

 11.34 %

 11.65 %

 7.0 %

 13.67 %

 13.43 %

Tier 1 Capital ratio

Total Capital ratio

 11.5 

 13.5 

 12.92 

 15.23 

13.28 

16.38 

 8.5 

 10.5 

 13.88 

 15.50 

13.64 

16.00 

Tier 1 Leverage ratio
Supplementary Leverage ratio(1)

Effective 
Minimum 
Requirement

 4.0 %

 5.0 

Citigroup

7.15 %

5.73

Effective 
Minimum 
Requirement

 5.0 %

 6.0 

Citibank

8.36 %

6.47

(1) Citigroup’s Supplementary Leverage ratio, as presented in the table above, reflects the full impact of CECL as well as the inclusion of U.S. Treasuries and 

deposits at Federal Reserve Banks in Total Leverage Exposure. 

46

 
 
 
 
 
Regulatory Capital Standards Developments

U.S. Banking Agencies

TLAC Holdings
In January 2021, the U.S. banking agencies issued a final rule 
that creates a new regulatory capital deduction applicable to 
Advanced Approaches banking organizations for certain 
investments in covered debt instruments issued by GSIBs. The 
final rule is substantially consistent with an April 2019 
proposal, and is intended to reduce interconnectedness and 
systemic risk by creating an incentive for Advanced 
Approaches banking organizations to limit their exposure to 
GSIBs.

Under the U.S. Basel III rules, non-significant 
investments in the capital of unconsolidated financial 
institutions are subject to deduction from regulatory capital 
using the corresponding deduction approach if, in the 
aggregate, they exceed 10% of the banking organization’s 
Common Equity Tier 1 Capital. Non-significant investments 
in the capital of unconsolidated financial institutions that are 
not deducted from regulatory capital are risk weighted in the 
usual manner.

Under the final rule, an investment in a “covered debt 
instrument” will be treated as an investment in a Tier 2 Capital 
instrument and, therefore, will be subject to deduction from 
the Advanced Approaches banking organization’s own Tier 2 
Capital in accordance with the existing rules for non-
significant investments in unconsolidated financial 
institutions. Covered debt instruments 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 rule provides an exception from the approach 
described above for covered debt instruments held for market-
making activities for 30 days or less (or longer, for synthetic 
exposures only), if the aggregate amount of such debt 
instruments does not exceed 5% of the banking organization’s 
Common Equity Tier 1 Capital. 

Additionally, the final rule requires banking organizations 
to deduct from Tier 2 Capital investments in their own covered 
debt instruments.

The final rule will become effective for Citigroup and 
Citibank on April 1, 2021. Citi estimates that the final rule will 
not significantly impact Citigroup or Citibank’s regulatory 
capital upon adoption.

Standardized Approach for Counterparty Credit Risk
In January 2020, the U.S. banking agencies issued a final
rule to introduce the Standardized Approach for
Counterparty Credit Risk (SA-CCR) in the U.S. The
mandatory compliance date of the SA-CCR final rule is
January 1, 2022, and early adoption was originally
permitted beginning April 1, 2020. For additional
information on the SA-CCR final rule, see “Capital
Resources—Regulatory Capital Standards Developments”
in Citi’s 2019 Annual Report on Form 10-K.

In March 2020, the U.S. banking agencies issued an
interim final rule permitting banks to early adopt the SA-CCR 
final rule beginning with the quarter ended March 31,
2020.

Citi has not early adopted the SA-CCR final rule. Citi 

intends to implement SA-CCR upon the mandatory 
compliance date of January 1, 2022.

Basel Committee 

Deferral of Basel III Revisions
In April 2020, in light of the COVID-19 pandemic, the
Basel Committee on Banking Supervision (Basel
Committee) announced that the implementation date of the
Basel III post-crisis regulatory reforms finalized in
December 2017 has been deferred by one year to January 1,
2023. The reforms relate to the methodologies in deriving
credit and operational risk-weighted assets, the imposition
of a new aggregate output floor for risk-weighted assets,
and revisions to the leverage ratio framework. The Basel 
Committee also announced that the implementation date of
the revised market risk framework finalized in January
2019 has been deferred by one year to January 1, 2023.

The U.S. banking agencies may revise the U.S. Basel

III rules in the future, in response to the Basel Committee’s
Basel III post-crisis regulatory reforms and revised market
risk framework.

Targeted Revisions to the Credit Valuation Adjustment
Framework
In July 2020, the Basel Committee issued a standard with 
targeted revisions to the credit valuation adjustment (CVA) 
risk framework, which was previously finalized in December 
2017 and will become effective on January 1, 2023. The 
revisions 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 adjusted 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 the revisions adopted by the Basel Committee.

47

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 returns on average TCE are non-GAAP 
financial measures. Citi believes the presentation of TCE, 
TBV per share and returns on average TCE provides alternate 
measures of capital strength and performance for investors, 
industry analysts and others.

In millions of dollars or shares, except per share amounts

2020

2019

2018

2017

2016

Total Citigroup stockholders’ equity

$ 

199,442 

$ 

193,242 

$ 

196,220 

$ 

200,740 

$ 

225,120 

At December 31,

Less: Preferred stock

Common stockholders’ equity

Less:

  Goodwill

  Identifiable intangible assets (other than MSRs)

  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)

19,480 

17,980 

18,460 

19,253 

19,253 

$ 

179,962 

$ 

175,262 

$ 

177,760 

$ 

181,487 

$ 

205,867 

22,162 

4,411 

22,126 

4,327 

22,046 

4,636 

22,256 

4,588 

21,659 

5,114 

— 

— 

— 

32 

72 

$ 

153,389 

$ 

148,809 

$ 

151,078 

$ 

154,611 

$ 

179,022 

2,082.1 

86.43 

73.67 

2,114.1 

2,368.5 

2,569.9 

2,772.4 

$ 

82.90 

$ 

75.05 

$ 

70.62 

$ 

70.39 

63.79 

60.16 

74.26 

64.57 

In millions of dollars

2020

2019

2018

2017(1)

2016

Net income available to common shareholders

$ 

9,952 

$ 

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)

175,508 

149,892 

 5.7 %

 6.6 

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 

For the year ended December 31,

(1) Year ended December 31, 2017 excludes the one-time impact of Tax Reform. Citi believes the presentation of its 2017 RoTCE excluding the impact of Tax

Reform provides a meaningful depiction of the underlying performance of its business for investors, industry analysts and others. 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.

48

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RISK FACTORS

The following discussion sets forth what management 
currently believes could be the material 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
Rapidly Evolving Challenges and Uncertainties Related to 
the COVID-19 Pandemic Will Likely Continue to Have 
Negative Impacts on Citi’s Businesses and Results of 
Operations and Financial Condition. 
The COVID-19 pandemic has become global, affecting all of 
the countries and jurisdictions where Citi operates. The 
pandemic and responses to it have had, and will likely 
continue to have, severe impacts on global health and 
economic conditions. These impacts will continue to evolve 
by region, country or state, largely depending on the duration 
and severity of the public health consequences, including the 
duration and further spread of the coronavirus; the potential 
for new variants of the virus; timely development, production 
and distribution of effective vaccines; availability of 
therapeutics; public response; and government actions. The 
impacts to global economic conditions include, among others: 

•

•

•

•
•
•

the institution of social distancing and restrictions on 
businesses and the movement of the public in and among 
the U.S. and other countries;
closures, reduced activity and failures of many businesses, 
leading to loss of revenues and net losses; 
sharply reduced U.S. and global economic output, 
resulting in significant losses of employment and lower 
consumer spending, cards purchase sales and loan 
volumes; 
lower interest rates; 
disruption of global supply chains; and
significant disruption and volatility in financial markets. 

The pandemic has had, and will likely continue to have, 

negative impacts on Citi’s businesses and overall results of 
operations and financial condition, which could be material. 
The extent of the impact on Citi’s operations and financial 
performance, including its ability to execute its business 
strategies and initiatives, will continue to depend significantly 
on future developments in the U.S. and globally, which are 
uncertain and cannot be predicted, including the course of the 
virus, as well as any delay or weakness in the economic 
recovery or further economic downturn. 

Ongoing legislative and regulatory changes in the U.S. 

and globally to address the economic impact from the 
pandemic, such as consumer and corporate relief measures and 
continued lower interest rates, could further affect Citi’s 
businesses, operations and financial performance. Citi could 
also face challenges, including legal and reputational, and 
scrutiny in its implementation of and ongoing efforts to 

49

provide these relief measures. Such implementations and 
efforts have resulted in, and may continue to result in, 
litigation, including class actions, and regulatory and 
government actions and proceedings. Such actions may result 
in judgments, settlements, penalties and fines adverse to Citi. 
In addition, the different types of government actions could 
vary in scale and duration across jurisdictions and regions with 
varying degrees of effectiveness. 

The impact of the pandemic on Citi’s consumer and 
corporate borrowers will also vary by sector or industry, with 
some borrowers experiencing greater stress levels, which 
could lead to increased pressure on their results of operations 
and financial condition, increased borrowings or credit ratings 
downgrades, thus likely leading to higher credit costs for Citi. 
In addition, stress levels ultimately experienced by Citi’s 
borrowers may be different from and more intense than 
assumptions made in earlier estimates or models used by Citi, 
resulting in a further increase in Citi’s ACL or net credit 
losses, particularly as consumer and small business relief 
programs expire and the benefits of fiscal stimulus start to 
diminish. 

The pandemic may not be contained for an extended 
period of time. A prolonged health crisis could further reduce 
economic activity in the U.S. and other countries, resulting in 
additional declines in employment and business and consumer 
confidence. These factors could further negatively impact 
global economic activity and markets; cause a continued 
decline in the demand for Citi’s products and services and in 
its revenues; further increase Citi’s credit and other costs; and 
may result in impairment of long-lived assets or goodwill. 
These factors could also cause a continued increase in Citi’s 
balance sheet, risk-weighted assets and ACL, resulting in a 
decline in regulatory capital ratios or liquidity measures, as 
well as regulatory demands for higher capital levels and/or 
limitations or reductions in capital distributions (such as 
common share repurchases and dividends). Moreover, any 
disruption or failure of Citi’s performance of, or its ability to 
perform, key business functions, as a result of the continued 
spread of COVID-19 or otherwise, could adversely affect 
Citi’s operations. 

Any disruption to, breaches of or attacks on Citi’s 
information technology systems, including from cyber 
incidents, could have adverse effects on Citi’s businesses (see 
the operational processes and systems and cybersecurity risk 
factors below). These systems are supporting a substantial 
portion of Citi’s colleagues who have been affected by local 
pandemic restrictions and have been forced to work remotely. 
In addition, these systems interface with and depend on third-
party systems, and Citi could experience service denials or 
disruptions if demand for such systems were to exceed 
capacity or if a third-party system fails or experiences any 
interruptions. Citi has also taken measures to maintain the 
health and safety of its colleagues; however, these measures 
could result in increased expenses, and widespread illness 
could negatively affect staffing within certain functions, 
businesses or geographies. In addition, Citi’s ability to recruit, 
hire and onboard colleagues in key areas could be negatively 
impacted by global pandemic restrictions (see the qualified 
colleagues risk factor below). 

Further, it is unclear how the macroeconomic business 

environment or societal norms may be impacted after the 
pandemic. The post-pandemic environment may undergo 
unexpected developments or changes in financial markets, the 
fiscal, monetary, tax and regulatory environments and 
consumer customer and corporate client behavior. These 
developments and changes could have an adverse impact on 
Citi’s results of operations and financial condition. Ongoing 
business and regulatory uncertainties and changes may make 
Citi’s longer-term business, balance sheet and strategic and 
budget planning more difficult or costly. Citi and its 
management and businesses may also experience increased or 
different competitive and other challenges in this environment. 
To the extent that it is not able to adapt or compete effectively, 
Citi could experience loss of business and its results of 
operations and financial condition could suffer (see the 
competitive challenges risk factor below). 

For additional information about trends, uncertainties and 
risks related to the pandemic, as well as Citi’s management of 
pandemic-related risks, see “COVID-19 Pandemic Overview” 
above.

Citi’s Ability to Return Capital to Common Shareholders 
Consistent with Its Capital Planning Efforts and Targets 
Substantially Depends on Regulatory Capital Requirements, 
Including the Results of the CCAR Process and 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 capital requirements, including the Stress 
Capital Buffer (SCB), which is based upon the results of the 
CCAR process required by the Federal Reserve Board (FRB) 
as well as the supervisory stress tests required under the Dodd-
Frank Act (as described in more detail below). Citi’s ability to 
return capital also depends on its results of operations and 
financial condition, forecasts of macroeconomic conditions 
and effectiveness in managing its level of risk-weighted assets 
under both the Advanced Approaches and the Standardized 
Approach, Supplementary Leverage Ratio (SLR) and global 
systemically important bank holding company (GSIB) 
surcharge, which has been made more challenging due to the 
pandemic-related elevated levels of liquidity in the financial 
system (see macroeconomic challenges and uncertainties risk 
factor below). 

Citi’s ability to accurately predict, interpret or explain to 

stakeholders the results 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 limitations 
on Citi’s ability to return capital to common shareholders, as 
well as the CCAR process, supervisory stress test 
requirements and GSIB surcharge, see “Capital Resources—
Overview” and “Capital Resources—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 pre-provision net revenue 
(PPNR) and stress losses, and the addition of components 
deemed important by the FRB. 

Beginning January 1, 2022, Citi will be required to phase 
into regulatory capital at 25% per year the changes in retained 
earnings, deferred tax assets and ACL determined upon the 
January 1, 2020 CECL adoption date as well as subsequent 
changes in the ACL between January 1, 2020 and December 
31, 2021. The FRB has stated that it plans to maintain its 
current framework for calculating allowances on loans in the 
supervisory stress test for the 2021 supervisory stress test 
cycle, and to evaluate appropriate future enhancements to this 
framework as best practices for implementing the current 
expected credit losses (CECL) methodology are developed. 
The impacts on Citi’s capital adequacy of the FRB’s 
incorporation of CECL in its supervisory stress tests 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 adverse 
regulatory capital effects resulting from adoption of the CECL 
methodology, see “Capital Resources—Current Regulatory 
Capital Standards—Regulatory Capital Treatment—Modified 
Transition of the Current Expected Credit Losses (CECL) 
Methodology” above and Note 1 to the Consolidated Financial 
Statements. 

In addition, the FRB has integrated the annual stress 

testing requirements with ongoing regulatory capital 
requirements. For Citigroup, the SCB rule replaced the fixed 
2.5% Capital Conservation Buffer in Citi’s ongoing regulatory 
capital requirements for the Standardized Approach capital 
ratios. The SCB equals the maximum decline in Citi’s 
Common Equity Tier 1 Capital ratio under a severely adverse 
scenario over a nine-quarter CCAR measurement period, plus 
four quarters of planned common stock dividends, subject to a 
minimum requirement of 2.5%. Effective October 1, 2020, 
Citi’s SCB was 2.5%. The SCB is calculated by the FRB using 
its proprietary data and modeling of each firm’s results. 
Accordingly, Citi’s SCB may change annually, or possibly 
more frequently, based on the supervisory stress test results, 
thus potentially resulting in volatility in the calculation of the 
SCB. Similar to the Capital Conservation Buffer, a breach of 
the SCB would result in graduated limitations on capital 
distributions. For additional information on the SCB, 
including its calculation, see “Capital Resources—Regulatory 
Capital Buffers” 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 could 
increase the level of capital Citi is required or elects to hold, 

50

including as part of Citi’s management buffer, thus potentially 
impacting the extent to which Citi is able to return capital to 
shareholders. 

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, 
tax and other changes arising from the U.S. federal 
government and other governments, including as a result of 
the new U.S. presidential administration, regulatory leadership 
and Congress or in response to the pandemic; (ii) potential 
changes to various aspects of the regulatory capital framework 
and requirements applicable to Citi (see the capital return risk 
factor and “Capital Resources—Regulatory Capital Standards 
Developments” above); and (iii) the future legislative and 
regulatory framework resulting from the U.K.’s exit from the 
European Union (EU), including, among others, with respect 
to financial services (see “Managing Global Risk—Strategic 
Risk—U.K.’s Future Relationship with the EU” below). 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 strategic budget planning difficult, subject 
to change and potentially more costly. 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. For 
example, while the Basel III post-crisis regulatory reforms and 
revised market risk framework have been finalized at the 
international level, there remain significant uncertainties with 
respect to the integration of these revisions into the U.S. 
regulatory capital framework. 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 

51

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, as well as significant investments to 
transform its infrastructure, risk management and controls and 
further enhance safety and soundness (for additional 
information, see the legal and regulatory proceedings risk 
factor below). For example, Citi continues to make 
investments to enhance its digital capabilities across the 
franchise, including digital platforms and mobile and cloud-
based solutions. Citi also has been making investments across 
the firm, such as in the U.S. consumer franchise, Citi’s wealth 
management businesses and treasury and trade solutions, 
securities services and other businesses in ICG, including 
implementing new capabilities and partnerships. Further, Citi 
has been pursuing efficiency improvements through various 
technology and digital initiatives, organizational simplification 
and location strategies. 

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. Additionally, in connection 
with Citi’s CEO transition, Citi is undergoing an evaluation of 
its strategy, which may result in, among other things, 
additional investments as well as changes in or exits of 
businesses. There is no guarantee that these or other initiatives 
Citi may pursue will be as productive or effective as Citi 
expects, or at all. Additionally, such initiatives could result in 
losses, charges or other negative financial impacts. Citi’s 
investment and efficiency initiatives may continue to evolve as 
its business strategies, the market environment and regulatory 
expectations 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, including the negative impacts related to the 
pandemic, customer, client and competitor actions and 
ongoing regulatory changes, among others. 

Uncertainties Regarding the Transition Away from or 
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 continues to be widely used as a “benchmark” or 
“reference rate” across financial products and markets 

globally. Based on statements from U.S. and U.K. authorities, 
it is expected, however, that all non-U.S. dollar LIBOR tenors 
and some USD LIBOR tenors will cease after December 31, 
2021, while most U.S. dollar LIBOR tenors will continue to be 
quoted through June 2023. As a result of LIBOR’s wide use, 
there can be no assurance that market participants, including 
Citi, will be able to successfully modify all outstanding 
LIBOR-based securities or products or be sufficiently 
prepared for all of the uncertainties resulting from LIBOR’s 
discontinuance. In addition, following guidance provided by 
the Financial Stability Board, regulators have suggested 
reforming or replacing other benchmark rates with alternative 
reference rates. The transition away from and discontinuance 
of LIBOR or any other benchmark rate presents various 
uncertainties, risks and challenges to holders of LIBOR-based 
securities and products as well as 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 
benchmark rate, including any alternative benchmark rate. 
Despite ongoing actions by Citi to prepare for the 
transition away from LIBOR (see “Managing Global Risk—
Strategic Risk—LIBOR Transition Risk” below), Citi has 
continued to meet market demand by trading, holding or 
otherwise using 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 structured securities. The 
transition away from and discontinuation of LIBOR for these 
securities and products presents significant operational, legal, 
reputational or compliance, financial and other risks to Citi. 
For example, the LIBOR transition presents various 

challenges related to contractual mechanics of existing 
floating rate financial instruments and contracts that reference 
LIBOR and mature after discontinuance of the relevant 
LIBOR. Certain of these legacy 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. Further, Citi may not be able to amend 
certain instruments and contracts due to an inability to obtain 
sufficient required consent from counterparties or security 
holders. Even if the instruments and contracts provide for a 
transition to alternative benchmark rates, the new benchmark 
rates may, particularly in times of financial stress, 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, and may not 
ultimately be successful. 

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 further invest in and develop significant 
internal systems and infrastructure to transition to alternative 
benchmark rates to manage its businesses and support its 
clients. 

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, 2020, Citi’s net DTAs were $24.8 billion, 
net of a valuation allowance of $5.2 billion, of which $9.5 
billion was excluded from Citi’s Common Equity Tier 1 
Capital under the U.S. Basel III rules, primarily relating to net 
operating losses, foreign tax credit and general business credit 
carry-forwards (for additional information, see “Capital 
Resources—Components of Citigroup Capital” above). Of the 
net DTAs at December 31, 2020, $4.4 billion related to 
foreign tax credit carry-forwards (FTCs), net of a valuation 
allowance. The carry-forward utilization period for FTCs is 
ten years and represents the most time-sensitive component of 
Citi’s DTAs. The FTC carry-forwards at December 31, 2020 
expire over the period of 2021–2029. 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. Forecasts of future taxable earnings will 
depend upon various factors, including, among others, the 
continued impact of the pandemic and other macroeconomic 
conditions. In addition, any future increase in U.S. corporate 
tax rates could result in an increase in Citi’s DTA, which may 
subject more of Citi’s existing DTA to exclusion from 
regulatory capital while improving Citi’s ability to utilize its 
FTC carry-forwards. Citi’s overall ability to realize its DTAs 
will primarily be dependent upon its 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 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. In addition, Citi is subject to 

52

litigation or examinations with U.S. and non-U.S. tax 
authorities regarding non-income-based tax matters. Citi’s 
interpretations or 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 
requirement to pay additional taxes, penalties or interest, 
which could be material. For additional information on the 
litigation and examinations involving non-U.S. tax authorities, 
see Note 27 to the Consolidated Financial Statements.

Citi’s Presence in the Emerging Markets Subjects It to 
Various Risks as well as Increased Compliance and 
Regulatory Risks and Costs. 
During 2020, emerging markets revenues accounted for 
approximately 34% of Citi’s total revenues (Citi generally 
defines emerging markets as countries in Latin America, Asia 
(other than Japan, Australia and New Zealand), and central 
and Eastern Europe, the Middle East and Africa in EMEA). 
Although Citi continues to pursue its target client strategy, 
Citi’s presence in the emerging markets subjects it to various 
risks, such as limitations of hedges on foreign investments; 
foreign currency volatility, including devaluations, 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, and these risks can be exacerbated in 
the event of a deterioration in relationships between the U.S. 
and an emerging market country. For example, Citi operates in 
several countries that have, or have had in the past, strict 
capital and currency controls, such as Argentina, that limit its 
ability to convert local currency into U.S. dollars and/or 
transfer funds outside of those countries (for further 
information, see “Strategic Risk—Country Risk—Argentina” 
below). 

Moreover, if the economic situation in an emerging 
markets country where Citi operates were to deteriorate below 
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 (for further 
information, see “Strategic Risk—Country Risk—Argentina” 
below). 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 

53

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, even if the regulations require 
inconsistent results, in legal or regulatory proceedings, 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 across both businesses in 
North America GCB constituted an aggregate of 
approximately 10% of Citi’s revenues in 2020 (for additional 
information, see “Global Consumer Banking—North America 
GCB” above). 

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. The pandemic has exacerbated these trends
and generally resulted in a challenging operating environment
for retailers and merchants. 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. 

Citi’s co-branding and private label relationships could 
continue to be negatively impacted by, among other things, the 
general economic environment; declining sales and revenues, 
partner store closures, government imposed restrictions, 
reduced air and business travel, 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, whether 
due to the ongoing impact of the pandemic or otherwise (see 
the pandemic-related risk factor above). 

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 Citi 
to be resolved 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 
such 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, Retain and Motivate Highly 
Qualified Colleagues. 
Citi’s performance and the performance of its individual 
businesses largely depend on the talents and efforts of its 
diverse and highly qualified colleagues. Specifically, Citi’s 
continued ability to compete in each of its lines of business, to 
manage its businesses effectively and to execute its global 
strategy depends on its ability to attract new colleagues and to 
retain and motivate its existing colleagues. If Citi is unable to 
continue to attract, retain and motivate the most highly 
qualified colleagues, Citi’s performance, including its 
competitive position, the execution of its strategy and its 
results of operations could be negatively impacted. 

Citi’s ability to attract, retain and motivate colleagues 
depends on numerous factors, some of which are outside of its 

54

control. For example, the banking industry generally is subject 
to more comprehensive regulation of employee compensation 
than other industries, including deferral and clawback 
requirements for incentive compensation. Citi often competes 
for talent with entities that are not subject to similar regulatory 
requirements, including, among others, technology companies. 
Other factors that could impact Citi’s ability to attract, retain 
and motivate colleagues include its reputation, culture and the 
management and leadership of the Company and each of its 
lines of business, presence in a particular market or region and 
the professional opportunities it offers. For information on
Citi’s colleagues and workforce management, see “Human
Capital Resources and Management” below.

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, reach, 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, and have sought bank charters to provide these 
services. These firms attempt to use technology and mobile 
platforms to enhance the ability of companies and individuals 
to borrow, save and invest money. In addition, as discussed
above, it is unclear how the macroeconomic business
environment or societal norms may be impacted as a result of
the pandemic. Citi may experience increased or different
competitive and other challenges in a post-pandemic
environment. 

To the extent that Citi is not able to compete effectively 

with financial technology companies 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. 

Climate Change Could Have a Negative Impact on Citi’s 
Results of Operations and Financial Condition.
Citi operates globally, including in countries, states and 
regions where its businesses, and the activities of its consumer 
customers and corporate clients, could be negatively impacted 
by climate change. Climate change presents both immediate 
and long-term risks to Citi and its customers and clients, with 
the risks expected to increase over time. 

Climate risks can arise from physical risks (acute or 
chronic risks related to the physical effects of climate change) 
and transition risks (risks related to regulatory and legal, 

technological, market and reputational changes from a 
transition to a low-carbon economy). Physical risks could 
damage or destroy Citi’s or its customers’ and clients’ 
properties and other assets and disrupt their operations. For 
example, climate change may lead to more extreme weather 
events occurring more often which may result in physical 
damage and additional volatility within our trading and other 
businesses and potential counterparty exposures and other 
financial risks. Transition risks may result in changes in 
regulations or market preferences, which in turn could have 
negative impacts on asset values, results of operation or the 
reputation of Citi and its customers and clients. For example, 
Citi’s corporate credit portfolios include carbon-intensive 
industries like oil and gas and power that are exposed to 
climate risks, such as those risks related to the transition to a 
low-carbon economy, as well as low-carbon industries that 
may be subject to risks associated with new technologies. U.S. 
and non-U.S. banking regulators and others have increasingly 
viewed financial institutions as important in helping to address 
the risks related to climate change both directly and with 
respect to their customers. Ongoing legislative or regulatory 
uncertainties and changes regarding climate risk management 
and practices may result in higher regulatory, compliance, 
credit and reputational risks and costs. 

For information on Citi’s management of climate risk, see 

“Managing Global Risk—Strategic Risk—Climate Risk” 
below.

MARKET AND OTHER RISKS
Macroeconomic, Geopolitical and Other Challenges and 
Uncertainties Globally Could Have a Negative Impact on 
Citi’s Businesses and Results of Operations. 
In addition to the significant macroeconomic challenges posed 
by the pandemic (see the pandemic-related risk factor above), 
Citi has experienced, and could experience in the future, 
negative impacts to its businesses and results of operations as 
a result of other macroeconomic, geopolitical and other 
challenges, uncertainties and volatility. For example, 
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 global capital flows. 
Additional areas of uncertainty include, among others, 
geopolitical tensions and conflicts, protracted or widespread 
trade tensions, natural disasters, other pandemics and election 
outcomes. Moreover, 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.

In 2020, due to the pandemic, the FRB and other central 
banks took numerous actions to support the global economy, 
including by further reducing their benchmark interest rates 
and in certain instances providing additional liquidity to the 
financial system. Interest rates on loans Citi makes to 
customers and clients 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 

55

rates decline. By contrast, the interest rates at which Citi pays 
depositors are already low and unlikely to decline much 
further. Consequently, declining or continued low interest 
rates for loans and largely unchanged deposit rates would 
likely further 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 
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. 

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 across ICG and GCB and 
AOCI (which would in turn negatively impact Citi’s book and 
tangible book value). 

OPERATIONAL RISKS
A Failure in or Disruption of Citi’s Operational Processes or 
Systems Could Negatively Impact Citi’s Reputation, 
Customers, Clients, Businesses or Results of Operations and 
Financial Condition. 
Citi’s global operations rely heavily on the accurate, timely 
and secure processing, management, storage and transmission 
of confidential transactions, data and other information as well 
as the monitoring of a substantial amount of data and complex 
transactions in real time. For example, Citi obtains and stores 
an extensive amount of personal and client-specific 
information for its consumer and institutional customers and 
clients, and must accurately record and reflect their extensive 
account transactions. Citi’s operations must also comply with 
complex and evolving laws and regulations in the countries in 
which it operates. 

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 ever-increasing risk of operational loss, 
failure or disruption, including as a result of cyber or 
information security incidents. These risks have been 
exacerbated during the pandemic, when a substantial portion 
of Citi’s colleagues have worked remotely and customers and 
clients have increased their use of online banking and other 
platforms (for additional information, see the cybersecurity 
risk factor below and pandemic-related risk factor above). 
Although Citi has continued to upgrade its operational 

systems to automate processes and enhance efficiencies, 
operational incidents are unpredictable and can arise from 
numerous sources, not all of which are within Citi’s control, 
including, among others, human error, such as processing 
errors, fraud or malice on the part of employees or third 
parties, accidental system or technological failure, electrical or 
telecommunication outages, failures of or cyber incidents 
involving computer servers or infrastructure or other similar 
losses or damage to Citi’s property or assets. Irrespective of 
the sophistication of the technology utilized by Citi, there will 

always be some room for human error. In view of the large 
transactions in which Citi engages, such errors could result in 
significant loss. Operational incidents 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 follow procedures or 
processes, safeguard their systems or prevent system 
disruptions or cyber attacks. 

Incidents that impact information security and/or 

technology operations may cause disruptions and/or 
malfunctions within Citi’s businesses (e.g., 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. In addition, operational 
incidents could involve the failure or ineffectiveness of 
internal processes or controls. Given Citi’s global footprint 
and the high volume of transactions processed by Citi, certain 
failures, errors or actions may be repeated or compounded 
before they are discovered and rectified, which would further 
increase the consequences and costs. Operational incidents 
could result in financial losses as well as misappropriation, 
corruption or loss of confidential and other information or 
assets, which could significantly negatively impact Citi’s 
reputation, customers, clients, businesses or results of 
operations and financial condition. Cyber-related and other 
operational incidents can also result in legal and regulatory 
proceedings, fines and other costs (see the legal and regulatory 
proceedings risk factor below). 

For information on Citi’s management of operational risk, 

see “Managing Global Risk—Operational Risk” below. 

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 
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 

56

breaches impacting Citi customers. Furthermore, because 
financial institutions are becoming increasingly interconnected 
with central agents, exchanges and clearing houses, including 
as a result of derivatives reforms over the last few years, Citi 
has increased exposure to cyber attacks through third parties. 
While many of Citi’s agreements with 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 attempted and sometimes 
successful cyber attacks from external sources over the last 
several years, including (i) denial of service attacks, which 
attempt to interrupt service to clients and customers, (ii) 
hacking and malicious software installations, intended to gain 
unauthorized access to information systems or to disrupt those 
systems, (iii) data breaches due to unauthorized access to 
customer account data and (iv) malicious software attacks on 
client systems, in an attempt to gain unauthorized access to 
Citi systems or client data under the guise of normal client 
transactions. 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 become apparent for a substantial period of 
time following discovery of the incident. 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 processes and 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 and 
may not take into account reputational harm, the cost of which 
could be immeasurable. 

For additional information about Citi’s management of 

cybersecurity risk, see “Managing Global Risk—Operational 
Risk—Cybersecurity Risk” below. 

Changes to or the Application of 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, among other items, the estimate of the ACL; 
reserves related to litigation, regulatory and tax matters 
exposures; valuation of DTAs; and the fair values of certain 
assets and liabilities, such as goodwill or any other asset for 
impairment. 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, the CECL methodology, adopted as of 
January 1, 2020, requires that Citi provide reserves for a 
current estimate of lifetime expected credit losses for its loan 
portfolios and other financial assets, as applicable, at the time 
those assets are originated or acquired. This estimate is 
adjusted each period for changes in expected lifetime credit 
losses. Citi’s ACL estimate depends upon its CECL models 
and assumptions, forecasted macroeconomic conditions, 
including, among other things, the U.S. unemployment rate 
and the U.S. Real GDP, and the credit indicators, composition 
and other characteristics of Citi’s loan and other applicable 
portfolios. These model assumptions and forecasted 
macroeconomic conditions will change over time, whether due 
to the pandemic or otherwise, resulting in greater variability in 
Citi’s ACL compared to its provision for loan losses under the 
previous GAAP methodology, and, thus, impact its results of 
operations, as well as regulatory capital, including as the 
CECL phase-in begins as of January 1, 2022.

Moreover, 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 

57

translation and its foreign CTA components of AOCI, see 
Notes 1 and 19 to the Consolidated Financial Statements. 
For additional information on the key areas for which 
assumptions and estimates are used in preparing Citi’s 
financial statements, including those related to Citi’s ACL, 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 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. Changes to financial accounting or 
reporting standards or interpretations, whether promulgated or 
required 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. For additional information on Citi’s accounting 
policies, including the expected impacts on Citi’s results of 
operations and financial condition, see Note 1 to the 
Consolidated Financial Statements. 

If Citi’s Risk Management Processes, Strategies or Models 
Are Deficient or Ineffective, Citi May Incur Significant 
Losses and Its Regulatory Capital and Capital Ratios Could 
Be Negatively Impacted. 
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 the Company. 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. 

In addition, in October 2020, Citigroup and Citibank 

entered into consent orders with the FRB and OCC that 
require Citigroup and Citibank to submit acceptable plans 
relating principally to making improvements in various 
aspects of enterprise-wide risk management, compliance, data 
quality management and governance and internal controls (see 
“Citi’s Consent Order Compliance” above and the legal and 
regulatory proceedings risk factor below).

Citi’s risk management 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. 

CREDIT RISKS 
Credit Risk and Concentrations of Risk Can Increase the 
Potential for Citi to Incur Significant Losses. 
Credit risk primarily arises from Citi’s lending and other 
businesses in both GCB and ICG. Citi has credit exposures to 
consumer, corporate and public sector borrowers and other 
counterparties in the U.S. and various countries and 
jurisdictions globally, including end-of-period consumer loans 
of $289 billion and end-of-period corporate loans of $387 
billion at year-end 2020. 

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 pandemic-related, macroeconomic, 
geopolitical and other factors, among other things, can 
increase Citi’s credit risk and credit costs (for additional 
information, see the pandemic-related, 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, as applicable, such reserves are subject to 
judgments and estimates that could be incorrect or differ from 
actual future events. Under the CECL accounting standard, the 
ACL reflects expected losses, rather than incurred losses, 
which has resulted in and could lead to additional 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 
portfolios based on historical evidence showing that (i) credit 
card balances typically decrease during the first and second 
quarters, as borrowers use tax refunds to pay down balances; 
and (ii) balances increase during the third and fourth quarters 
each year as payments are no longer impacted by tax refunds 
and the holiday season approaches. However these seasonal 
trends could be affected in 2021 due to the impacts of
the pandemic, government stimulus and expiration of

consumer and small business relief programs. For additional 
information, see the incorrect assumptions or estimates and 
changes to financial accounting and reporting standards risk 
factors above. For additional information on Citi’s ACL, see 
“Significant Accounting Policies and Significant Estimates” 
below and Notes 1 and 15 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 Notes 14 and 15 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 2020, 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 large, 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, whether due to the 
pandemic or otherwise. Citi competes with other banks and 
financial institutions for deposits, which represent Citi’s most 
stable and lowest cost source of long-term funding. The 
competition for retail banking deposits has increased in recent 
years as a result of online banks and digital banking, among 
others. Furthermore, although Citi’s has had robust deposit 
growth since the onset of the pandemic, it remains unclear 
how “sticky” (likely to remain at Citi) those deposits may be, 
particularly in a less accommodating environment. 

58

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. 

Additionally, 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 
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 

59

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, Regulatory and 
Other Risks and Costs. 
Citi is continually required to interpret and implement 
extensive and frequently changing regulatory and legislative 
requirements in the U.S. and other jurisdictions where it does 
business, 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, 
infrastructure, data and 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, enforcement 
proceedings, penalties and fines (for additional information, 
see the legal and regulatory proceedings risk factor below). 

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. Additionally, the 
banking industry generally is being called upon to do more on 
the issues of social, economic and racial justice. This could 

result in additional regulatory requirements regarding banking 
services for underserved communities and individuals.

Increased and ongoing compliance requirements and 
uncertainties have resulted in higher compliance costs for Citi, 
in part due to an increase in risk, regulatory and compliance 
staff over the last several years despite a reduction in the 
overall employee population. 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, penalties and fines. 

Citi Is Subject to Extensive Legal and Regulatory 
Proceedings, Examinations, Investigations, Consent Orders 
and Related Compliance Efforts and Other Inquiries That 
Could Result in Significant Monetary Penalties, Supervisory 
or Enforcement Orders, Business Restrictions, Limitations 
on Dividends, Changes to Directors and/or Officers and 
Collateral Consequences Arising from Such Outcomes.
At any given time, Citi is a party to a significant number of 
legal and regulatory proceedings and is subject to numerous 
governmental and regulatory examinations, investigations, 
consent orders and related compliance efforts, and other 
inquiries. Citi can also be subject to enforcement proceedings 
not only because of violations of laws and regulations, but also 
due to failures, as determined by its regulators, to have 
adequate policies and procedures, or to remedy deficiencies on 
a timely basis. 

The recent FRB and OCC consent orders require 

Citigroup and Citibank to submit acceptable plans to the FRB 
and OCC, on various timelines, relating principally to making 
improvements in various aspects of enterprise-wide risk 
management, compliance, data quality management and 
governance and internal controls. The consent orders require 
preparation of acceptable gap analyses that identify the 
required improvements and related root causes, as well as 
targeted action plans and quarterly progress reports detailing 
the results and status of the improvements. These 
improvements will result in significant investments by Citi 
during 2021 and afterwards, as an essential part of Citi’s 
broader transformation efforts to enhance its infrastructure, 
governance, processes and risk and controls. Although there 
are no restrictions on Citi’s ability to serve its clients, the 
Citibank consent order requires prior approval of any 
significant new acquisition, including any portfolio or business 
acquisition, excluding ordinary course transactions. Moreover, 
the Citibank consent order provides that the OCC has the right 
to assess future civil monetary penalties or take other 
supervisory and/or enforcement actions, including where the 
OCC determines Citibank has not made sufficient and 
sustainable progress to address the required improvements. 
Such actions by the OCC could include imposing business 
restrictions, including possible limitations on the declaration 
or payment of dividends and changes in directors and/or senior 
executive officers. More generally the OCC and/or the Federal 
Reserve could take additional enforcement or other actions if 
the regulatory agency believes that Citi has not met regulatory 
expectations regarding compliance with the consent orders. 

For additional information regarding the consent orders, see 
“Citi’s Consent Order Compliance” above.

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. 

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, employees 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 general 
heightened scrutiny and expectations from regulators could 
lead to 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, employees 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. Furthermore, 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 for 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. 

60

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.

61

HUMAN CAPITAL RESOURCES AND 
MANAGEMENT

Attracting and retaining a highly qualified and motivated 
workforce is a strategic priority for Citi. Citi seeks to enhance 
the competitive strength of its workforce through the 
following efforts:

•

•

•

Continuous innovation in recruiting, training, 
compensation, promotion and engagement of colleagues
Actively seeking and listening to diverse perspectives at 
all levels of the organization 
Optimizing transparency concerning workforce goals, in 
order to promote accountability, credibility and 
effectiveness in achieving those goals 

Workforce Size and Distribution
As of December 31, 2020, Citi employed 210,153 colleagues in nearly 100 countries. The following table shows the geographic 
distribution of those colleagues by segment, region and gender:

Business segment

Global Consumer Banking

Institutional Clients Group

Corporate/Other

Total

North 
America

EMEA

Latin 
America

Asia

Total(1)

Female

Male

32,936   

16,905   

17,130   

66,971   

4,087   

16,457   

9,510   

30,054   

30,276   

7,166   

7,000   

31,849   

22,349   

14,488   

99,148 

62,877 

48,128 

44,442   

68,686   

210,153 

 58 %

 44 

 42 

 51 %

 42 %

 56 

 58 

 49 %

(1)  Part-time colleagues represented less than 1.5% of Citi’s global workforce.

Workforce Management
Citi devotes substantial resources to managing its workforce. 
Citigroup’s Board of Directors provides strategic oversight 
and direction to management regarding workforce policies and 
practices, and includes many members with experience in 
overseeing workforce issues. The chair of the Personnel and 
Compensation Committee of the Board was formerly the 
global head of human resources for PIMCO, a leading global 
asset management firm, and later served as its president, with 
oversight responsibility for human resources. In addition, the 
Personnel and Compensation Committee regularly reviews 
management’s achievements against human capital 
management goals, such as addressing representation of 
women and U.S. minorities in senior roles at Citi, as well as 
talent recruitment and development initiatives. 

Diversity
Citigroup’s Board is committed to ensuring that it and Citi’s 
Executive Management Team are composed of individuals 
whose backgrounds reflect the diversity represented by Citi’s 
employees, customers and stakeholders. 

Additionally, over the past several years, Citi has 

increased its efforts to diversify its workforce. In furtherance 
of that goal, Citi has focused on measuring and addressing pay 
equity within the organization:

•

In 2018, Citi was the first major U.S. financial institution 
to publicly release the results of a pay equity review 
comparing compensation of women to men and U.S. 

minorities to U.S. non-minorities. Since then, Citi has 
continued to be transparent about pay equity, also 
disclosing its unadjusted or “raw” pay gap for both 
women and U.S. minorities since 2019. 
Citi’s 2020 results found that, on an adjusted basis, 
women globally are paid on average more than 99% of 
what men are paid at Citi, and there was no statistically 
significant difference in adjusted compensation for U.S. 
minorities and non-minorities. Following the review, 
appropriate pay adjustments were made as part of Citi’s 
2020 compensation cycle. 
Citi’s 2020 raw gap analysis showed that the median pay 
for women globally is better than 74% of the median for 
men, up from 73% in 2019 and 71% in 2018, and that the 
median pay for U.S. minorities is just under 94% of the 
median for non-minorities, which is similar to 2019 and 
up from 93% in 2018. 
To continue closing the pay gap, Citi has set goals to 
increase representation at the assistant vice president 
through managing director levels to at least 40% for 
women globally and 8% for Black colleagues in the U.S. 
by the end of 2021.

Citi also has a goal to:

expand the use of diverse slates across the firm in 2021 to 
include not one, but at least two women or racial/ethnic 
minorities in Citi’s interviews for U.S. hires and at least 
two women in interviews for global hires; and

•

•

•

•

62

 
 
 
 
•

•

• 

•

•

•

increase the analyst and associate programs to 50% 
female colleagues globally and 30% Black and Hispanic/
Latino colleagues in the U.S.

In 2020, Citi also: 

expanded the standard for a diverse slate to include at 
least one woman globally and one woman and/or U.S. 
minority for U.S. hires at the assistant vice president, vice 
president and senior vice president levels, in addition to 
managing director and director level hires;
included a diverse slate of candidates, with at least one 
woman and/or U.S. minority, for 86% of roles that were 
posted globally with a qualified slate;
increased representation of underrepresented minorities in 
its full-time U.S. campus recruitment program from 18% 
in 2019 to 26% in 2020;
increased female representation in its full-time U.S. 
campus recruitment program from 45% in 2019 to 46% in 
2020; and
increased female representation in its summer internship 
program from 47% in 2019 to 52% in 2020 in the U.S. 
and from 48% in 2019 to 50% in 2020 globally, while 
Black and Hispanic/Latino representation in its summer 
class increased from 26% to 27% over the same 
timeframe. This was Citi’s most diverse intern class to 
date.

Workforce Development
Citi highly values a workplace environment where its 
colleagues can bring their whole selves to work and where 
diverse perspectives and ideas are embraced. Citi encourages 
career growth and development by offering broad and diverse 
opportunities to colleagues. Highlights of these opportunities 
include the following:

•

•

•

Citi provides a range of internal development and 
rotational programs to colleagues at all levels, including 
various training programs and events to assist high-
performing colleagues in building the skills needed to 
transition to manager and supervisory roles. 
Citi has a focus on internal talent development and aims 
to provide colleagues with career growth opportunities, 
with 33% of open positions filled internally. This 
emphasis is particularly important as Citi focuses on 
providing career paths for its diverse talent base as part of 
its efforts to increase diverse representation at more senior 
levels of the organization.
In order to assist colleagues in a rapidly changing world, 
Citi offers an online platform that delivers information on 
various topics of interest to colleagues, such as leadership, 
data analytics, artificial intelligence and cybersecurity, 
among others. 

For information about Citi’s reliance on a highly qualified 

and motivated workforce, see “Risk Factors” above. For 
additional information about Citi’s human capital management 
initiatives and goals, see Citi’s 2021 Annual Meeting Proxy 
Statement to be filed with the SEC in March 2021 as well as 
its 2019 Environmental, Social and Governance Report 
available at www.citigroup.com.

For information about Citi’s proactive measures to 

preserve the health and safety of its workforce during the 
pandemic, see “COVID-19 Pandemic Overview” above.

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64

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 Credit Losses on Loans (ACLL)
       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
  Erroneous Revlon-Related Payment
  Cybersecurity Risk

COMPLIANCE RISK

REPUTATION RISK

STRATEGIC RISK
   Overview
   U.K.’s Future Relationship with the EU
   LIBOR Transition Risk
   Climate 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.

65

MANAGING GLOBAL RISK

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. As discussed above, Citi is continuing 
its efforts to comply with the Federal Reserve Board and OCC 
consent orders, relating principally to various aspects of risk 
management, compliance, data quality management and 
governance, and internal controls, see “Citi’s Consent Order 
Compliance” and “Risk Factors—Compliance Risks” above.

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 colleagues 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 
colleagues’ 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 risk management practices that include a risk 
governance structure and the firm’s key policies, processes, 
personnel and control systems through which Citi identifies, 
measures, monitors, and controls risks such that the 
Company’s risk taking is consistent with its strategy and risk 
appetite. 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 colleagues 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, including its commitment to responsible finance. 
Citi’s risk mission is taking intelligent risk with shared 
responsibility, without forsaking individual accountability. 
Citi’s risk appetite framework sets boundaries for risk 
taking and consists of a set of risk appetite statements that 
articulate the aggregate level and types of risk that Citi is 
willing to accept in order to achieve its strategic objectives and 
business plan and includes governance processes through 
which the risk appetite is established, communicated and 
monitored, and its breaches are escalated and resolved. It is 
built on quantitative boundaries, which include goals, risk 

limits and thresholds, and on qualitative principles that guide 
behavior. Citi’s risk appetite framework is enterprise-wide and 
applicable across products, functions and geographies and 
comprehensively covers the major categories of risk facing the 
firm. 

Citi’s risks are generally categorized and summarized as 

follows:

•

•

•

Credit risk is the risk of loss resulting from the decline in 
credit quality (or downgrade risk) or failure of a borrower, 
counterparty, third party or issuer to honor its financial or 
contractual obligations.
Liquidity risk is the risk that the firm 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 firm. This risk may be exacerbated by the inability of 
the firm 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 or reduced net interest revenues 
resulting from changes in market variables, such as 
interest rates, exchange rates, equity and commodity 
prices 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, people and 
systems, or from external events. It includes legal risk, 
which is the risk of loss (including litigation costs, 
settlements and regulatory fines) resulting from the failure 
of the firm to comply with laws, regulations, prudent 
ethical standards and contractual obligations in any aspect 
of the firm’s business, but excludes strategic and 
reputation risks (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 non-conformance 
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 non-traditional. 
Reputation risk is the risk to current or projected financial 
conditions and resilience arising from negative public 
opinion. This risk may impair Citi’s competitiveness by 
affecting its ability to establish new relationships or 
services or continue servicing existing relationships.
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 conditions in a 
country (which may be 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 

66

obligations to Citi. Country risk includes sovereign 
defaults, banking crises, currency crises, currency 
convertibility and/or transferability restrictions or 
political developments.

Citi uses a lines of defense construct to manage its risks. 

The construct comprises units that create risks (first line of 
defense), those that independently assess risk (second line of 
defense), units that provide independent assurance (third line 
of defense) and units tasked with maintaining a strong control 
environment (control and support functions). The lines of 
defense, which include control and support functions, 
coordinate with each other in the risk management system in 
support of the common goal of identifying, measuring, 
monitoring and controlling risk-taking activities so they 
remain consistent with the firm’s strategy and risk appetite.

First Line of Defense: Front Line Units and Front Line 
Unit Activities
Citi’s first line of defense owns the risks inherent in or arising 
from their business and is responsible for identifying, 
assessing and controlling those risks so that they are within 
Citi’s risk appetite. 

Front line units are responsible and held accountable for 
managing the risks associated with their activities within the 
boundaries set by independent risk management. They are also 
responsible for designing and implementing effective internal 
controls and maintaining processes for managing their risk 
profile, including through risk mitigation, so that it remains 
consistent with Citi’s established risk appetite.

Front line unit activities are considered part of the first 

line of defense and are subject to the oversight and challenge 
of independent risk management, whether they are conducted 
by a front line unit or another line of defense designation. Note 
that front line units may also conduct control and support 
activities which are subject to the relevant firm-wide 
independent oversight processes specific to the risk category 
that they generate (e.g., operational risk, compliance risk, 
reputation risk).

The first line of defense is composed of Citi’s Business 
Management (Global Consumer Bank (GCB) and Institutional 
Clients Group (ICG)), Regional and Country Management, 
certain Corporate Functions (Enterprise Infrastructure, 
Operations and Technology (EIO&T) and Finance), as well as 
other front line unit activities.

Second Line of Defense: Independent risk management
Independent risk management units are independent of front 
line units. They are responsible for overseeing the risk-taking 
activities of the first line of defense and challenging the first 
line of defense in the execution of their risk management 
responsibilities. They are also responsible for independently 
identifying, measuring, monitoring and controlling aggregate 
risks and for setting standards for the management and 
oversight of risk. At Citi, the second line of defense is defined 
to include Independent Risk Management and Independent 
Compliance Risk Management (ICRM). Independent Risk 
Management and ICRM report to Citi’s Chief Risk Officer 
and Chief Compliance Officer (CCO), respectively, both of 
whom report directly to the Citigroup CEO and have 

67

unrestricted access to the Citigroup Board of Directors or its 
committees.

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

Independent Risk Management is organized to align to 

businesses, regions, types of risk and to firm-wide, cross-risk 
functions or processes. There are teams that report to an 
independent Chief Risk Officer (CRO) for Citi’s businesses 
(Business CROs, including Finance Chief Risk Officers) and 
regions / legal entities (Regional / Legal Entity CROs). In 
addition, there are risk-category-aligned teams that report to a 
Risk Category Head (e.g., Market Risk, Operational Risk, 
Model Risk) and foundational teams that report to a 
Foundational Risk Management Head (e.g., Risk Governance, 
Enterprise Concentration Risk Management, Global Risk 
Review). All of the above Risk Heads, together with the 
Business and Regional / Legal Entity CROs, report to the 
Citigroup CRO.

Independent Compliance Risk Management 
The Independent Compliance Risk Management organization 
is designed to oversee and 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, measures, monitors, 
controls and escalates compliance risk across the firm. 

Product Line, Function and Country ICRM provide 
compliance risk management advice and credible challenge on 
day-to-day matters and strategic decision-making for key 
initiatives. Additionally, Country ICRM provides advisory and 
challenge on regulatory and enterprise wide matters such as 
regulatory changes in a country. ICRM has program-level 
Enterprise Compliance units whose Heads are responsible for 
coordinating and managing their respective horizontal, 
enterprise-wide compliance programs, setting standards and 
establishing priorities for program-related compliance efforts.

Third Line of Defense: Internal Audit
Internal audit is independent of front line units and 
independent risk management units. Internal audit provides 
independent assurance to the Citigroup Board of Directors on 
the effectiveness of governance, risk management and internal 
controls. Internal audit reports to a chief audit executive (i.e., 
Citi’s Chief Auditor) who has unrestricted access to the Board 
or its audit committee to facilitate the ability to execute 
specific responsibilities pertaining to escalation of risks and 
issues. 

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.

The Citigroup Chief Auditor manages Internal Audit and 

maintains its independence from the front line units, 
Independent Risk Management, ICRM and control and 
support functions by reporting functionally to the Chairman of 
the Citigroup Audit Committee and administratively to the 
Citigroup CEO.

Control and Support Functions
Control and support functions do not meet the definition of 
front line unit, independent risk management or internal audit. 
While they do not report into the CRO or CCO, they are 
expected to design, implement and maintain an effective 
control environment with respect to the risks they generate, 
and also support safety and soundness. 

At Citi, the control and support functions are defined to 

include the following organizational units: Chief 
Administrative Office, Global Public Affairs, Human 
Resources, International Franchise Management, Legal 
(including Citi Security & Investigative Services) and the 
Office of the CBNA CEO.

Board and Executive Management
The Citigroup Board of Directors, both directly or through its 
committees, actively oversees Citi’s risk taking activities and 
holds management accountable for adhering to the risk 
governance framework. The primary responsibility of the 
Citigroup Board is to provide effective governance over Citi’s 
affairs for the benefit of its stakeholders. Directors have full 
and free access to management.

The standing committees of the Citigroup Board are the 
Risk Management Committee, Audit Committee, Personnel 
and Compensation Committee, Ethics, Conduct and Culture 
Committee and Nomination, Governance and Public Affairs 
Committee. 

The Board delegates authority to the Executive 

Management Team, which consists of the Citigroup CEO and
certain direct reports of the CEO, for directing and overseeing 
day-to-day management of the firm. The Executive 
Management Team is responsible for developing and 
implementing policies, procedures and processes that translate 
the Board’s goals, strategic objectives and risk appetite and 
limits into prudent standards for the safe and sound operation 
of the firm.

The Executive Management Team reports to the Board on 

the firm’s overall risk profile, including aggregate and 
emerging risks, and provides the Board with information about 
current and potential risk exposures and their potential impact 
on earnings, capital and strategic objectives.

Executive Management committees have been designed 

to cover all primary risks to which Citi is exposed. These 
Executive Management committees escalate to standing 
committees of the Board. The standing Executive 
Management committees are the Group Risk Management 
Committee, Group Strategic Risk Committee, Citigroup Asset 
& Liability Committee, Group Business, Risk and Control 
Committee and Group Reputation Risk Committee.

CREDIT RISK

Overview
Credit risk is the risk of loss resulting from the decline in 
credit quality of a client, customer or counterparty (or 
downgrade risk) 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 clearing and settlement 
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 clearing and settlement activities, 

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

To manage concentration of risk within credit risk, Citi 

has in place a 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 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 ACL process (see “Significant 
Accounting Policies and Significant Estimates—Allowance 
for Credit Losses” below and Notes 1 and 15 to the 

68

Consolidated Financial Statements), as well as through regular 
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. 

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 and/or industry scoring models 
for new customer approvals. 

As stated in “Global Consumer Banking” above, GCB’s 

strategy is to leverage its global footprint and digital 
capabilities to develop multiproduct relationships with
customers, both in and out of Citi’s branch footprint.

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’19

1Q’20

2Q’20

3Q’20

4Q’20

$ 

$ 

$ 

$ 

$ 

$ 

$ 

85.5 

$ 

83.6 

$ 

86.0 

$ 

87.5 

$ 

39.3 

36.6 

37.6 

38.3 

124.8 

$ 

120.2 

$ 

123.6 

$ 

125.8 

$ 

122.2 

$ 

110.2 

$ 

103.6 

$ 

102.2 

$ 

52.9 

175.1 

299.9 

$ 

$ 

48.9 

159.1 

279.3 

$ 

$ 

45.4 

149.0 

272.6 

$ 

$ 

44.4 

146.6 

272.4 

$ 

$ 

 66 %

 6 

 28 

 100 %

 67 %

 5 

 28 

 100 %

 66 %

 5 

 29 

 100 %

 66 %

 5 

 29 

 100 %

88.9 

40.1 

129.0 

106.7 

46.4 

153.1 

282.1 

 65 %

 5 

 30 

 100 %

9.6 

309.5 

$ 

$ 

9.1 

288.4 

$ 

$ 

8.5 

281.1 

$ 

$ 

7.6 

280.0 

$ 

$ 

6.7 

288.8 

(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 consumer loans, see 

“Liquidity Risk—Loans” below.

69

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

Global Consumer Banking

North America GCB

As shown in the chart above, GCB’s net credit loss rates 

decreased significantly year-over-year and quarter-over-
quarter as of the fourth quarter of 2020, primarily due to the 
impacts of the consumer relief programs Citi implemented 
since the beginning of the pandemic, combined with the 
benefit of reduced customer spending and significant 
government stimulus and assistance, as well as other banks’ 
consumer relief programs. 

The 90+ days past due delinquency rate increased quarter-

over-quarter, largely due to the expiration of the pandemic 
relief programs in certain countries. The 90+ days past due 
delinquency rate was largely unchanged year-over-year. 
As discussed above, loans modified under Citi’s 

consumer relief programs continue to be reported in the same 
delinquency bucket they were in at the time of modification 
and, thus, would not be reported as 90+ days past due or 
written off for the duration of the programs (which have 
various durations, and certain of which may be renewed by the 
customer). As a result of the significant and steady decline in
program enrollment, Citi ended its consumer relief programs
as of December 31, 2020 for the majority of countries and
products.

Citi expects to experience higher consumer net credit loss 

and 90+ days past due delinquency rates across regions, with 
sharper losses in Latin America GCB and Asia GCB starting in 
the near term. The losses will likely vary by business and 
region and be dependent on evolving macroeconomic and 
market conditions. These conditions include the severity and 
duration of the impact from the pandemic and the impacts of 
government stimulus programs, as well as the timing of 
expiration of consumer relief programs and when loans move 
into later delinquency buckets. Citi believes that these losses 
are adequately reserved for under the CECL standard at 
December 31, 2020. For additional information, see 
“COVID-19 Pandemic Overview—Pandemic and Other 
Impacts” above.

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 U.S. (for additional 
information on the U.S. retail bank, see “North America GCB” 
above).

As of December 31, 2020, approximately 71% 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 decreased significantly quarter-over-
quarter and year-over-year as of the fourth quarter of 2020, 
driven by the impacts of the consumer relief programs 
described above, unemployment benefits and government 
stimulus. 

The 90+ days past due delinquency rate increased quarter-

over-quarter, primarily due to seasonality in cards and the 
impact of customers rolling off the consumer relief programs. 

The 90+ days past due delinquency rate modestly 
decreased year-over-year, primarily driven by the impacts of 
the consumer relief programs described above, unemployment 
benefits and government stimulus.

Latin America GCB

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 
multiproduct relationships with customers.

70

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

Latin America GCB decreased significantly quarter-over-
quarter and year-over-year as of the fourth quarter of 2020, 
largely driven by the impact of the consumer relief programs 
described above. The 90+ days past due delinquency rate 
increased significantly quarter-over-quarter and year-over-
year, due to the adverse pandemic-related macroeconomic 
impacts, as well as the expiration of most consumer relief 
programs in Mexico by September 2020. 

Asia(1) GCB 

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

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

presented.

North America Citi-Branded Cards

Asia GCB operates in 17 countries and jurisdictions 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 and 90+ 

days past due delinquency rates in Asia GCB increased 
quarter-over-quarter and year-over-year as of the fourth 
quarter of 2020, driven by the adverse pandemic-related 
macroeconomic impacts in the region as well as the expiration 
of consumer relief programs, which generally have ended 
earlier than in Mexico and North America.

The performance of Asia GCB’s portfolios, with a 1.16% 

net credit loss rate, continues to reflect 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 improved 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 Notes 14 and 15 to the Consolidated Financial 
Statements.

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 
Citi-branded cards decreased quarter-over-quarter and year-
over-year as of the fourth quarter of 2020, driven by the 
impact of the consumer relief programs described above, 
unemployment benefits and government stimulus. The 90+ 
days past due delinquency rate decreased year-over-year for 
the same reasons, while it increased quarter-over-quarter as a 
result of seasonality and the impact of customers rolling off 
the consumer relief programs described above.

North America Citi Retail Services

71

Citi retail services partners directly with more than 20 

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

retailers and dealers to offer private label and co-branded 
cards. Citi retail services’ target market focuses 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 rate in Citi 

retail services decreased quarter-over-quarter and year-over-
year as of the fourth quarter of 2020, driven by the impact of 
the consumer relief programs described above, unemployment 
benefits and government stimulus. The 90+ days past due 
delinquency rate decreased year-over-year for the same 
reasons, while it increased quarter-over-quarter as a result of 
seasonality and the impact of customers rolling off the 
consumer relief programs.

days past due delinquency rates in Asia Citi-branded cards 
increased quarter-over-quarter and year-over-year as of the 
fourth quarter of 2020, driven by the adverse pandemic-related 
macroeconomic impacts as well as the expiration of the 
consumer relief programs described above.

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 14 
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.

Latin America Citi-Branded Cards

Citi-Branded Cards

FICO distribution(1)

Dec. 31, 
2020

Sept. 30, 
2020

Dec. 31, 
2019

  > 760

  680–760

  < 680

Total

 46 %

 43 %

 42 %

 39 

 15 

 41 

 16 

 40 

 18 

 100 %

 100 %

 100 %

Citi Retail Services

Latin America GCB issues proprietary and co-branded 

FICO distribution(1)

  > 760

  680–760

  < 680

Total

Dec. 31, 
2020

Sept. 30, 
2020

Dec. 31, 
2019

 27 %

 26 %

 25 %

 44 

 29 

 44 

 30 

 42 

 33 

 100 %

 100 %

 100 %

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

presentations. 

In 2020, FICO distributions improved in both Citi‑
branded cards and Citi retail services, primarily due to the 
impacts of the consumer relief programs and significant 
government stimulus and assistance, as well as lower credit 
utilization due to reduced customer spending. For additional 
information on FICO scores, see Note 14 to the Consolidated 
Financial Statements.

cards. 

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

Latin America Citi-branded cards decreased significantly 
quarter-over-quarter and year-over-year as of the fourth 
quarter of 2020, largely driven by the impact of the consumer 
relief programs described above, while the 90+ days past due 
delinquency rate increased due to the adverse pandemic-
related macroeconomic impact, as well as the expiration of the 
cards consumer relief program. 

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. 

72

Additional Consumer Credit Details

Consumer Loan Delinquencies Amounts and Ratios(1)

In millions of dollars, except EOP loan 
amounts in billions
Global Consumer Banking(4)(5)
Total

Ratio

Retail banking

Total

Ratio

North America

Ratio

Latin America

Ratio

Asia(6)

Ratio

Cards
Total

Ratio

Ratio

Latin America

Ratio

Asia(6)

Ratio

Corporate/Other—Consumer(7)

Total

Ratio
Total Citigroup
Ratio

EOP
loans(2)
December 
31,

90+ days past due(3)

30–89 days past due(3)

December 31,

December 31,

2020

2020

2019

2018

2020

2019

2018

$ 

$ 

282.1  $ 

2,507 

$ 

2,737 

$ 

2,550 

$ 

2,517 

$ 

3,001 

$ 

2,864 

 0.89 %

 0.91 %

 0.89 %

 0.89 %

 1.00 %

 1.00 %

129.0  $ 

52.7   

9.8   

66.5   

$ 

632 
 0.49 %
299 
 0.58 %
130 
 1.33 %
203 
 0.31 %

$ 

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

$ 

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

$ 

860 
 0.67 %
328 
 0.63 %
220 
 2.24 %
312 
 0.47 %

$ 

816 
 0.66 %
334 
 0.67 %
180 
 1.54 %
302 
 0.48 %

752 
 0.64 %
265 
 0.56 %
185 
 1.62 %
302 
 0.52 %

$ 

153.1  $ 

1,875 

$ 

2,299 

$ 

2,134 

$ 

1,657 

$ 

2,185 

$ 

2,112 

 1.22 %
686 
 0.82 %
644 
 1.39 %
233 
 4.85 %
312 
 1.74 %

313 
 5.13 %

 1.31 %
915 
 0.95 %

1,012 

 1.91 %
165 
 2.75 %
207 
 1.04 %

 1.26 %
812 
 0.88 %
952 
 1.81 %
171 
 3.00 %
199 
 1.03 %

 1.08 %
589 
 0.70 %
639 
 1.38 %
170 
 3.54 %
259 
 1.45 %

$ 

$ 

$ 

278 
 3.02 %

$ 

382 
 2.63 %

179 
 2.93 %

3,015 

$ 

2,932 

$ 

2,696 

$ 

$ 

 1.25 %
814 
 0.85 %
945 
 1.79 %
159 
 2.65 %
267 
 1.34 %

$ 

295 
 3.21 %

 1.25 %
755 
 0.82 %
932 
 1.77 %
170 
 2.98 %
255 
 1.32 %

362 
 2.50 %

3,296 

$ 

3,226 

 0.98 %

 0.98 %

 0.97 %

 0.94 %

 1.07 %

 1.07 %

4.8   

17.9   

$ 

6.7  $ 

288.8  $ 

2,820 

North America—Citi-branded

84.0   

Ratio

North America—Citi retail services

46.4   

(1) As discussed above, loans modified under Citi’s consumer relief programs continue to be reported in the same delinquency bucket they were in at the time of 

modification (which have various durations, and certain of which may be renewed by the customer).

(2) End-of-period (EOP) loans include interest and fees on credit cards.
(3) The ratios of 90+ days past due and 30–89 days past due are calculated based on EOP loans, net of unearned income.
(4) 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.

(5) 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 
$171 million ($0.7 billion), $135 million ($0.5 billion) and $211 million ($0.7 billion) at December 31, 2020, 2019 and 2018, respectively. The amounts excluded 
for loans 30–89 days past due (the 30—89 days past due EOP loans have the same adjustments as the 90+ days past due EOP loans) were $98 million, $72 million 
and $86 million at December 31, 2020, 2019 and 2018, respectively.

(6) Asia includes delinquencies and loans in certain EMEA countries for all periods presented.
(7) 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 $183 million ($0.5 billion), 
$172 million ($0.4 billion) and $367 million ($.8 billion) at December 31, 2020, 2019 and 2018, respectively. The amounts excluded for loans 30–89 days past 
due (the 30—89 days past due EOP loans have the same adjustments as the 90+ days past due EOP loans) were $73 million, $55 million and $122 million at 
December 31, 2020, 2019 and 2018, respectively.

73

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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(3)

Ratio

Cards
Total

Ratio

North America—Citi-branded

Ratio

North America—Citi retail services

Ratio

Latin America

Ratio

Asia(3)

Ratio

Corporate/Other—Consumer

Total

Ratio
Total Citigroup
Ratio

Average
loans(1)
2020

Net credit losses(2)
2019

2018

2020

$ 

7,382 
 2.60 %

6,884 
 2.48 %

$ 

$ 

277.6  $ 

6,646 

$ 

124.5  $ 

52.2   

9.8   

62.5   

$ 

 2.39 %

805 
 0.65 %
132 
 0.25 %
377 
 3.85 %
296 
 0.47 %

$ 

153.1  $ 

5,841 

$ 

 3.82 %

84.5   

2,708 

 3.20 %

46.5   

2,150 

4.7   

17.4   

 4.62 %
489 
 10.40 %
494 
 2.84 %

$ 

$ 

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 %

$ 

$ 

8.5  $ 

286.1  $ 

(21) 
 (0.25) %
6,625 

$ 
 2.32 %  

$ 

(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 %
6,908 
2.33  %

(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) Asia includes NCLs and average loans in certain EMEA countries for all periods presented.

74

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Loan Maturities and Fixed/Variable Pricing of
U.S. Consumer Mortgages

In millions of dollars at 
December 31, 2020
U.S. consumer 
mortgage loan 
portfolio
Residential first 
mortgages

Greater
than 1 
year
but within
5 years

Due
within
1 year

Greater
than 5
years

Total

$ 

3  $ 

109  $  47,666  $  47,778 

Home equity loans

116   

103   

6,909   

7,128 

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

$ 

119  $ 

212  $  54,575  $  54,906 

$ 

194  $  33,456 

18    21,119 

$ 

212  $  54,575 

75

 
 
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. Citi’s corporate credit
exposures also include exposures in the private bank,
excluding certain loans managed on a delinquency basis. 

Corporate Credit Portfolio
The following table details Citi’s corporate credit portfolio 
within ICG (excluding certain loans in the private bank, which 
are managed on a delinquency basis), and before consideration 
of collateral or hedges, by remaining tenor for the periods 
indicated:

December 31, 2020

September 30, 2020

December 31, 2019

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

$  177  $ 

142  $ 

25  $ 

344  $  175  $ 

145  $ 

24  $ 

344  $  184  $ 

142  $ 

25  $ 

351 

  158   

272   

11   

441    154   

264   

12   

430    161   

266   

17   

$  335  $ 

414  $ 

36  $ 

785  $  329  $ 

409  $ 

36  $ 

774  $  345  $ 

408  $ 

42  $ 

444 

795 

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 and Counterparty
Citi’s corporate credit portfolio is diverse across geography 
and counterparty. The following table shows the percentage of 
this portfolio by region (excluding the delinquency-managed 
private bank portfolio) based on Citi’s internal management 
geography:

December 31,
2020

September 30,
2020

December 31,
2019

North America

 56 %

 57 %

 57 %

EMEA

Asia

Latin America

Total

 25 

 13 

 6 

 25 

 12 

 6 

 24 

 12 

 7 

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.

The following table presents the corporate credit portfolio 

(excluding the delinquency-managed private bank portfolio) 
by facility risk rating as a percentage of the total corporate 
credit portfolio:

Total exposure

December 31,
2020

September 30,
2020

December 31,
2019

 100 %

 100 %

 100 %

AAA/AA/A

 49 %

 48 %

 50 %

BBB

BB/B

CCC or below

Total

 31 

 17 

 3 

 31 

 17 

 4 

 33 

 15 

 2 

 100 %

 100 %

 100 %

Note: Total exposure includes direct outstandings and unfunded lending 
commitments. 

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, regulatory environment and 

76

 
 
 
 
 
In addition to the obligor and facility risk ratings assigned 

to all exposures, Citi may classify exposures in the corporate 
credit portfolio. These classifications are consistent with Citi’s 
interpretation of the U.S. banking regulators’ definition of 
criticized exposures, which may categorize exposures as 
special mention, substandard, doubtful, or loss.

Risk ratings and classifications are reviewed regularly, 

and adjusted as appropriate. The credit review process 
incorporates quantitative and qualitative factors, including 
financial and non-financial disclosures or metrics, 
idiosyncratic events or changes to the competitive, regulatory 
or macroeconomic environment. This includes but is not 
limited to exposures in those sectors significantly impacted by 
the pandemic (including energy and energy-related, consumer 
retail, commercial real estate and transportation). 

Citigroup believes the corporate credit portfolio to be 

appropriately rated and classified as of December 31, 2020. 
During the year and since the onset of the COVID-19 
pandemic, Citigroup has taken action to adjust internal ratings 
and classifications of exposures as both the macroeconomic 
environment and obligor-specific factors have changed, 
particularly where additional stress has been seen. 

As obligor risk ratings are downgraded, the probability of 

default increases. Downgrades of obligor risk ratings tend to 
result in a higher provision for credit losses. In addition, 
downgrades may result in the purchase of additional credit 
derivatives or other risk mitigants to hedge the incremental 
credit risk, or may result in Citi seeking to reduce exposure to 
an obligor or an industry sector. Citi will continue to review 
exposures to ensure the appropriate probability of default is 
incorporated into all risk assessments.

For additional information on Citi’s corporate credit 

portfolio, see Note 14 to the Consolidated Financial 
Statements.

Portfolio Mix—Industry
Citi’s corporate credit portfolio is diversified by industry. The 
following table details the allocation of Citi’s total corporate 
credit portfolio by industry (excluding the delinquency-
managed private bank portfolio):

Total exposure

December 31,
2020

September 30,
2020

December 31,
2019

Transportation and 
industrials
Private bank
Consumer retail

Technology, media 
and telecom
Real estate

Power, chemicals, 
metals and mining

Banks and finance 
companies

Energy and 
commodities

Health

Public sector
Insurance

Asset managers 
and funds

Financial markets 
infrastructure

Securities firms

Other industries

Total

 19 %
 14 
 10 

 11 
 8 

 8 

 7 

 6 

 5 

 3 
 3 

 3 

 2 

 — 

 1 

 19 %
 14 
 11 

 10 
 8 

 8 

 7 

 7 

 4 

 3 
 3 

 3 

 2 

 — 

 1 

 19 %
 13 
 10 

 11 
 7 

 9 

 7 

 7 

 4 

 3 
 3 

 3 

 2 

 — 

 2 

 100 %

 100 %

 100 %

77

 
 
The following table details Citi’s corporate credit portfolio by industry as of December 31, 2020:

Total credit 
exposure

Funded(1) Unfunded(1)

Investment 
grade

Non-
criticized

Criticized 
performing

Criticized 
non-
performing
(2)

30 days or 
more past 
due and 
accruing(3)

Net charge-
offs 
(recoveries)
(4)

Credit 
derivative 
hedges(5)

Non-investment grade

Selected metrics

$  147,218  $ 

60,122  $ 

87,096  $  106,041  $ 

17,452  $ 

21,927  $ 

1,798  $ 

136  $ 

239  $ 

(8,110) 

In millions of dollars
Transportation and 
industrials

   Autos(6)

   Transportation

   Industrials

Private bank

Consumer retail

Technology, media 
and telecom

Real estate

Power, chemicals, 
metals and mining

  Power

  Chemicals

  Metals and mining

Banks and finance 
companies

Energy and 
commodities(7)

Health

Public sector

Insurance

Asset managers and 
funds

Financial markets 
infrastructure

Securities firms

Other industries

53,874 

27,693 

65,651 

109,397 

82,129 

82,657 

65,392 

63,926 

26,916 

22,356 

14,654 

25,310 

14,107 

20,705 

75,693 

34,809 

30,880 

43,285 

20,810 

6,379 

7,969 

6,462 

28,564 

13,586 

44,946 

43,059 

16,410 

46,572 

33,704 

104,244 

4,374 

2,993 

10,085 

2,395 

47,320 

60,741 

11,653 

51,777 

22,107 

43,116 

20,537 

14,387 

8,192 

61,296 

54,413 

47,923 

22,665 

16,665 

8,593 

15,924 

5,342 

11,554 

3,336 

3,804 

4,414 

6,167 

6,872 

8,888 

2,510 

9,418 

5,214 

5,453 

4,257 

761 

1,882 

1,614 

52,925 

29,856 

23,069 

43,831 

4,648 

4,387 

49,524 

35,504 

26,887 

26,576 

15,086 

8,658 

13,599 

1,925 

34,438 

26,846 

13,288 

24,651 

34,636 

29,164 

22,276 

25,864 

7,345 

4,354 

1,887 

575 

6,546 

1,749 

2,708 

136 

19,745 

4,491 

15,254 

18,528 

1,013 

191 

274 

1,418 

106 

248 

317 

223 

184 

192 

154 

5 

33 

59 

997 

237 

16 

1 

13 

— 

8 

8 

17 

111 

963 

146 

107 

334 

59 

14 

32 

13 

27 

70 

17 

45 

27 

41 

— 

— 

10 

45 

144 

50 

78 

64 

74 

18 

70 

57 

8 

5 

79 

285 

17 

9 

1 

(3,220) 

(1,166) 

(3,724) 

(1,080) 

(5,493) 

(7,237) 

(642) 

(5,341) 

(2,637) 

(2,102) 

(602) 

(765) 

(4,199) 

(1,964) 

(1,089) 

(2,682) 

(1)   

(84) 

— 

— 

43 

(9) 

(6) 

(138) 

12,610 

976 

9,307 

229 

430 

4,545 

12,381 

12,590 

546 

4,762 

573 

4,980 

20 

298 

— 

97 

2,702 

1,442 

183 

Total

$  784,773  $  344,418  $  440,355  $  627,100  $ 

87,162  $ 

66,035  $ 

4,476  $ 

1,982  $ 

976  $ 

(38,839) 

(1)  Excludes $42.6 billion and $4.4 billion of funded and unfunded exposure at December 31, 2020, respectively, primarily related to the delinquency-managed credit 

portfolio of the private bank.
Includes non-accrual loan exposures and criticized unfunded exposures.

(2) 
(3)  Excludes $162 million of past due loans primarily related to the delinquency-managed credit portfolio of the private bank.
(4)  Net charge-offs (recoveries) are for the year ended December 31, 2020 and exclude delinquency-managed private bank charge-offs of $10 million.
(5)  Represents the amount of purchased credit protection in the form of derivatives to economically hedge funded and unfunded exposures. Of the $38.8 billion of 

purchased credit protection, $36.8 billion represents the total notional of purchased credit derivatives on individual reference entities. The remaining $2.0 billion 
represents the first loss tranche of portfolios of purchased credit derivatives with a total notional of $16.1 billion, where the protection seller absorbs the first loss 
on the referenced loan portfolios.

(6)  Autos total credit exposure includes securitization financing facilities secured by auto loans and leases, extended mainly to the finance company subsidiaries of 
global auto manufacturers, bank subsidiaries and independent auto finance companies, of approximately $20.2 billion ($10.3 billion in funded, with more than 
99% rated investment grade) as of December 31, 2020.
In addition to this exposure, Citi has energy-related exposure within the public sector (e.g., energy-related state-owned entities) and the transportation and 
industrials sector (e.g., off-shore drilling entities) included in the table above. As of December 31, 2020, Citi’s total exposure to these energy-related entities was 
approximately $7.0 billion, of which approximately $3.8 billion consisted of direct outstanding funded loans.

(7) 

78

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exposure to Commercial Real Estate
As of December 31, 2020, ICG’s total corporate credit 
exposure to commercial real estate (CRE) was $58 billion, 
with $41 billion consisting of direct outstanding funded loans 
(mainly included in the real estate and private bank categories 
in the above table), or 6% of Citi’s total outstanding loans. In 
addition, as of December 31, 2020, more than 70% of ICG’s 
total corporate CRE exposure was to borrowers in the United 
States. Also as of December 31, 2020, approximately 77% of 
ICG’s total corporate CRE exposure was rated investment 
grade.

As of December 31, 2020, the ACLL was 1.8% of funded 

CRE exposure, including 5.1% of funded non-investment 
grade exposure.

Of the total CRE exposure:

•

•

•

•

$20 billion of the exposure ($13 billion of direct 
outstanding funded loans) relates to Community 
Reinvestment Act-related lending provided pursuant to 
Citi’s regulatory requirements to meet the credit needs of 
borrowers in low and moderate income neighborhoods.
$13 billion of the exposure ($12 billion of direct 
outstanding funded loans) relates to exposure secured by 
mortgages on underlying properties or in well-rated 
securitization exposures.
$13 billion of the exposure ($5 billion of direct 
outstanding funded loans) relates to unsecured loans to 
large REITs, with nearly 75% of the exposure rated 
investment grade.
$12 billion of the exposure ($11 billion of direct 
outstanding funded loans) relates to CRE exposure in the 
private bank, of which 100% is secured by mortgages. In 
addition, 45% of the exposure is also full recourse to the 
client. As of December 31, 2020, 77% of the exposure 
was rated investment grade.

79

The following table details Citi’s corporate credit portfolio by industry as of December 31, 2019:

Total credit 
exposure

Funded(1)

Unfunded(1)

Investment 
grade

Non-
criticized

Criticized 
performing

Criticized 
non-
performing(2)

30 days or 
more past 
due and 
accruing(3)

Net charge-
offs 
(recoveries)(4)

Credit 
derivative 
hedges(5)

Non-investment grade

Selected metrics

$  146,643  $ 

59,726  $ 

86,917  $  120,777  $  19,433  $ 

5,725  $ 

706  $ 

161  $ 

67  $ 

(7,134) 

48,604 

29,984 

68,055 

102,463 

81,338 

83,199 

55,518 

73,961 

34,349 

23,721 

15,891 

52,036 

53,317 

35,008 

27,194 

24,305 

24,763 

16,838 

1,151 

16,842 

21,564 

14,550 

23,612 

68,798 

36,117 

31,333 

38,058 

27,040 

43,570 

15,434 

23,021 

3,582 

4,886 

44,443 

54,186 

10,965 

33,665 

100,017 

2,244 

45,221 

62,993 

15,131 

51,866 

63,845 

15,846 

17,460 

49,461 

5,495 

24,377 

49,584 

58,670 

11,997 

26,666 

29,317 

14,569 

18,790 

8,349 

10,563 

19,465 

43,663 

35,889 

42,996 

26,218 

27,791 

12,968 

23,294 

22,647 

23,370 

4,051 

3,905 

4,041 

4,661 

5,780 

5,932 

1,637 

866 

17,821 

22,357 

2,276 

7,683 

9,152 

7,542 

32,571 

17,428 

8,790 

14,226 

1,658 

6,942 

22 

423 

9,718 

1,311 

1,652 

2,762 

171 

2,773 

3,305 

525 

2,963 

679 

1,014 

1,270 

3,345 

3,627 

1,180 

2,558 

69 

130 

— 

38 

16,816 

16,838 

— 

304 

801 

728 

7,214 

8,299 

7,383 

1,080 

140 

425 

141 

31 

441 

203 

37 

331 

302 

12 

17 

39 

914 

105 

33 

— 

— 

— 

8 

80 

8 

21 

132 

1,094 

209 

81 

97 

50 

37 

12 

1 

15 

51 

25 

107 

7 

1 

— 

— 

48 

5 

21 

41 

36 

38 

14 

(2,982) 

(725) 

(3,427) 

(1,080) 

(4,105) 

(6,181) 

(3)   

(573) 

24 

19 

1 

4 

12 

99 

14 

1 

1 

31 

— 

13 

42 

(4,763) 

(2,111) 

(2,079) 

(573) 

(755) 

(2,808) 

(1,588) 

(944) 

(2,218) 

(32) 

(2) 

— 

65 

In millions of dollars

Transportation and 
industrials

   Autos(6)

   Transportation

   Industrials

Private bank(1)

Consumer retail

Technology, media and 
telecom

Real estate

Power, chemicals, metals 
and mining

   Power

   Chemicals

   Metals and mining

Banks and finance 
companies

Energy and commodities(7)

Health

Public sector

Insurance

Asset managers and funds

Financial markets 
infrastructure

Securities firms

Other industries

Total

$  794,576  $  350,187  $ 

444,479  $  665,172  $  98,985  $ 

27,489  $ 

2,928  $ 

1,946  $ 

389  $  (32,118) 

(1)  Excludes $39.7 billion and $3.4 billion of funded and unfunded exposure at December 31, 2019, respectively, primarily related to the delinquency-managed credit 

portfolio of the private bank.
Includes non-accrual loan exposures and criticized unfunded exposures.

(2) 
(3)  Excludes $434 million of past due loans primarily related to the delinquency-managed credit portfolio of the private bank.
(4)  Net charge-offs (recoveries) are for the year ended December 31, 2019 and exclude delinquency-managed private bank charge-offs of $6 million.
(5)  Represents the amount of purchased credit protection in the form of derivatives to economically hedge funded and unfunded exposures. Of the $32.1 billion of 

purchased credit protection, $30.5 billion represents the total notional of purchased credit derivatives on individual reference entities. The remaining $1.6 billion 
represents the first loss tranche of portfolios of purchased credit derivatives with a total notional of $13.8 billion, where the protection seller absorbs the first loss 
on the referenced loan portfolios.

(6)  Autos total credit exposure includes securitization financing facilities secured by auto loans and leases, extended mainly to the finance company subsidiaries of 

(7) 

global auto manufacturers, bank subsidiaries and independent auto finance companies, of approximately $17.9 billion ($7.7 billion in funded, with more than 99% 
rated investment grade) at December 31, 2019.
In addition to this exposure, Citi has energy-related exposure within the public sector (e.g., energy-related state-owned entities) and the transportation and 
industrials sector (e.g., off-shore drilling entities) included in the table above. As of December 31, 2019, Citi’s total exposure to these energy-related entities was 
approximately $5.5 billion, of which approximately $3.2 billion consisted of direct outstanding funded loans. 

80

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020, September 30, 2020 and 

December 31, 2019, ICG (excluding the delinquency-managed 
private bank portfolio) had economic hedges on the corporate 
credit portfolio of $38.8 billion, $38.4 billion and 
$32.1 billion, respectively. Citigroup’s expected credit loss 
model used in the calculation of its ACL 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 ICG (excluding the delinquency-managed private 
bank portfolio) corporate credit portfolio exposures with the 
following risk rating distribution:

Rating of Hedged Exposure

December 31,
2020

September 30,
2020

December 31,
2019

AAA/AA/A

 30 %

 29 %

 36 %

BBB

BB/B

CCC or below

Total

 48 

 19 

 3 

 52 

 16 

 3 

 51 

 12 

 1 

 100 %

 100 %

 100 %

Loan Maturities and Fixed/Variable Pricing of Corporate
Loans 

Over 1
year
but
within
5 years

Due
within
1 year

Over 5
years

Total

$  27,175  $  16,073  $  14,483  $  57,731 

In millions of dollars at 
December 31, 2020

Corporate loans

In U.S. offices

Commercial and 
industrial loans

Financial institutions

  26,270    15,538    14,001    55,809 

Mortgage and real 
estate
Installment, revolving 
credit and other

  28,560    16,893    15,222    60,675 

  12,589   

7,446   

6,709    26,744 

Lease financing

317   

187   

169   

673 

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

  126,273    49,708   

9,431    185,412 

$ 221,184  $ 105,845  $  60,015  $ 387,044 

$  16,514  $  21,346 

  89,331    38,669 

$ 105,845  $  60,015 

(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.

81

 
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 and other
Lease financing

Total
In offices outside North America(1)

Commercial and industrial
Financial institutions
Mortgage and real estate(2)
Installment and other
Lease financing
Governments and official institutions

Total
Corporate loans, net of unearned income(4)
Total loans—net of unearned income
Allowance for credit losses on loans (ACLL)
Total loans—net of unearned income  
and ACLL
ACLL as a percentage of total loans—
net of unearned income(5)
ACLL for consumer loan losses as a percentage of 
total consumer loans—net of unearned income(5)
ACLL for corporate loan losses as a percentage of 
total corporate loans—net of unearned income(5)

2020

2019

December 31,
2018

2017

2016

$ 

$ 

$ 

$ 
$ 

$ 

$ 

$ 

$ 
$ 
$ 

47,778 
7,128 
130,385 
4,509 
189,800 

39,969 
22,692 
36,378 
99,039 
288,839 

57,731 
55,809 
60,675 
26,744 
673 
201,632 

104,072 
32,334 
11,371 
33,759 
65 
3,811 
185,412 
387,044 
675,883 
(24,956) 

$ 

$ 

$ 

$ 
$ 

$ 

$ 

$ 

$ 
$ 
$ 

47,008 
9,223 
149,163 
3,699 
209,093 

38,024 
25,909 
36,522 
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) 

$ 

$ 

$ 

$ 
$ 

$ 

$ 

$ 

$ 
$ 
$ 

47,412 
11,543 
144,542 
4,046 
207,543 

36,388 
24,951 
33,478 
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 

37,870 
25,727 
34,157 
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 

35,523 
23,055 
30,966 
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) 

$ 

650,927 

$ 

686,700 

$ 

671,881 

$ 

654,679 

$ 

612,309 

 3.73 %

 1.84 %

 1.81 %

 1.86 %

 1.94 %

 6.77 %

 3.20 %

 3.14 %

 3.08 %

 2.94 %

 1.42 %

 0.75 %

 0.74 %

 0.82 %

 1.01 %

(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 $749 million, $783 million, $742 million, $768 million and $803 million at December 31, 2020, 2019, 2018, 2017 

and 2016, respectively. Unearned income on consumer loans primarily represents unamortized origination fees and costs, premiums and discounts. 

(4) Corporate loans include private bank loans and are net of unearned income of $(844) million, $(814) million, $(855) million, $(794) million and $(730) million at 
December 31, 2020, 2019, 2018, 2017 and 2016, respectively. Unearned income on corporate loans primarily represents interest received in advance, but not yet 
earned, on loans originated on a discounted basis.

(5) Because loans carried at fair value do not have an ACLL, they are excluded from the ACLL ratio calculation.

82

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Details of Credit Loss Experience

In millions of dollars

2020

2019

2018

2017

2016

Allowance for credit losses on loans (ACLL) at beginning of year $ 

12,783 

$ 

12,315 

$ 

12,355 

$ 

12,060 

$ 

12,626 

Adjustments to opening balance:
     Financial instruments—credit losses (CECL)(1)
    Variable post-charge-off third-party collection costs(2)

4,201 

(443) 

— 

— 

— 

— 

— 

— 

— 

— 

Adjusted ACLL at beginning of year

$ 

16,541 

$ 

12,315 

$ 

12,355 

$ 

12,060 

$ 

12,626 

Provision for credit losses on loans (PCLL)
Consumer(2)
Corporate

Total

Gross credit losses on loans

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 on loans(2)
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 on loans (NCLs)

In U.S. offices

In offices outside the U.S. 

Total
Other—net(3)(4)(5)(6)(7)(8)
Allowance for credit losses on loans (ACLL) at end of year
ACLL as a percentage of EOP loans(9)
Allowance for credit losses on unfunded lending commitments 
(ACLUC)(10)(11)

$ 

11,765 

$ 

7,751 

$ 

7,258 

$ 

7,329 

$ 

6,207 

4,157 

467 

96 

174 

542 

$ 

15,922 

$ 

8,218 

$ 

7,354 

$ 

7,503 

$ 

6,749 

$ 

6,047 

2,144 

$ 

6,538 

$ 

5,971 

$ 

5,664 

$ 

2,316 

2,351 

2,377 

4,874 

2,594 

562 

409 

14 

12 

71 

4 

265 

196 

— 

3 

23 

— 

121 

208 

3 

7 

2 

2 

223 

401 

3 

1 

2 

2 

370 

334 

5 

5 

34 

6 

$ 

9,263 

$ 

9,341 

$ 

8,665 

$ 

8,673 

$ 

8,222 

$ 

1,106 

$ 

460 

$ 

975 

503 

$ 

912 

502 

$ 

892 

552 

972 

576 

43 

28 

— 

14 

— 

1 

28 

59 

— 

— 

8 

— 

47 

78 

— 

3 

6 

4 

31 

117 

1 

1 

2 

1 

31 

79 

1 

1 

1 

— 

1,652 

$ 

1,573 

$ 

1,552 

$ 

1,597 

$ 

1,661 

5,815 

$ 

5,132 

$ 

4,966 

$ 

5,545 

2,066 

7,611 

104 

24,956 

$ 

$ 

$ 

$ 

1,953 

7,768 

18 

12,783 

$ 

$ 

$ 

4,278 

2,283 

6,561 

1,981 

2,110 

7,113 

$ 

7,076 

$ 

(281)  $ 

(132)  $ 

(754) 

12,315 

$ 

12,355 

$ 

12,060 

$ 

$ 

$ 

$ 

$ 

 3.73 %

 1.84 %

 1.81 %

 1.86 %

 1.94 %

$ 

2,655 

$ 

1,456 

$ 

1,367 

$ 

1,258 

$ 

1,418 

83

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Total ACLL and ACLUC

Net consumer credit losses on loans

As a percentage of average consumer loans

Net corporate credit losses on loans

As a percentage of average corporate loans
ACLL by type at end of year(12)

Consumer

Corporate

Total

$ 

$ 

$ 

27,611 

6,625 

$ 

$ 

14,239 

7,376 

$ 

$ 

13,682 

6,908 

$ 

$ 

13,613 

6,597 

$ 

$ 

13,478 

5,920 

 2.32 %

 2.49 %

 2.33 %

 2.22 %

 2.00 %

986 

$ 

392 

$ 

205 

$ 

479 

$ 

641 

 0.25 %

 0.10 %

 0.05 %

 0.14 %

 0.20 %

$ 

19,554 

$ 

9,897 

$ 

9,504 

$ 

9,412 

$ 

5,402 

2,886 

2,811 

2,943 

8,842 

3,218 

$ 

24,956 

$ 

12,783 

$ 

12,315 

$ 

12,355 

$ 

12,060 

(1) On January 1, 2020, Citi adopted Accounting Standards Codification (ASC) 326, Financial Instruments—Credit Losses (CECL). The ASC introduces a new credit 
loss methodology requiring earlier recognition of credit losses while also providing additional disclosure about credit risk. On January 1, 2020, Citi recorded a 
$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 Consumer ACL due to longer estimated tenors than under 
the incurred loss methodology under prior U.S. GAAP, net of recoveries; and (ii) a $0.8 billion decrease to the Corporate ACL due to 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. See Note 
1 to the Consolidated Financial Statements for further discussion on the impact of Citi’s adoption of CECL.

(2) Citi had a change in accounting related to its variable post-charge-off third-party collection costs which was recorded as an adjustment to its January 1, 2020 

(3)

(4)

(5)

(6)

(7)

(8)

opening allowance for credit losses on loans of $443 million. See Note 1 to the Consolidated Financial Statements.
Includes all adjustments to the ACL, such as changes in the allowance from acquisitions, dispositions, securitizations, FX translation, purchase accounting 
adjustments, etc.
2020 includes reductions of approximately $4 million related to the transfer to HFS of various real estate loan portfolios. In addition, 2020 includes an increase of 
approximately $97 million related to FX translation.
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.
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.
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.
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.

(9) December 31, 2020, 2019, 2018, 2017 and 2016 exclude $6.9 billion, $4.1 billion, $3.2 billion, $4.4 billion and $3.5 billion, respectively, of loans which are 

carried at fair value.

(10) 2020 corporate ACLUC includes a non-provision transfer of $68 million, representing reserves on performance guarantees. The reserves on these contracts were 

reclassified out of the ACL on unfunded lending commitments and into other liabilities.

(11) Represents additional credit reserves recorded as Other liabilities on the Consolidated Balance Sheet.
(12) Beginning in 2020, under CECL, the ACLL represents management’s estimate of expected credit losses in the portfolio.and troubled debt restructurings. See 
“Significant Accounting Policies and Significant Estimates” and Note 1 to the Consolidated Financial Statements below. Attribution of the ACLL is made for 
analytical purposes only and the entire ACLL is available to absorb credit losses in the overall portfolio. Prior to 2020, the ACLL represented management’s 
estimate of probable losses inherent in the portfolio, as well as probable losses related to large individually evaluated impaired loans and TDRs. See “Superseded 
Accounting Principles” in Note 1 to the Consolidated Financial Statements.

84

 
 
 
 
 
Allowance for Credit Losses on Loans (ACLL)
The following tables detail information on Citi’s ACLL, loans and coverage ratios. The December 31, 2020 table reflects the impact 
from the January 1, 2020 CECL adoption and the impact from the pandemic. The December 31, 2019 table is presented under the 
previous accounting standard (see “Superseded Accounting Principles” in Note 1 to the Consolidated Financial Statements).

December 31, 2020

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

$ 

$ 

$ 

ACLL

EOP loans, net of
unearned income
130.4 
54.9 
4.5 
22.7 
76.3 
288.8 
387.1 
675.9 

14.7  $ 
0.7   
0.3   
2.1   
1.8   
19.6  $ 
5.4   
25.0  $ 

ACLL as a
percentage of EOP 
loans(1)

 11.3 %
 1.3 
 6.7 
 9.3 
 2.4 
 6.8 %
 1.4 
 3.7 %

(1) Loans carried at fair value do not have an ACLL and are excluded from the ACLL ratio calculation.
(2)

Includes both Citi-branded cards and Citi retail services. The $14.7 billion of loan loss reserves represented approximately 53 months of coincident net credit loss 
coverage. As of December 31, 2020, the North America Citi-branded cards ACLL as a percentage of EOP loans was 10.0% and the North America Citi retail 
services ACLL as a percentage of EOP loans was 13.6%.

(3) Of the $0.7 billion, approximately $0.3 billion was allocated to North America mortgages in Corporate/Other, including $0.5 billion and $0.2 billion determined 

in accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. Of the $54.9 billion in loans, approximately $53.0 billion and 
$1.9 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)

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

December 31, 2019

ACLL

EOP loans, net of
unearned income

ACLL as a
percentage of EOP 
loans(1)

$ 

$ 

$ 

7.0  $ 
0.3   
0.1   
1.4   
1.1   
9.9  $ 
2.9   
12.8  $ 

149.2 
56.2 
3.7 
25.9 
74.6 
309.6 
389.9 
699.5 

 4.7 %
 0.5 
 2.7 
 5.4 
 1.5 
 3.2 %
 0.7 
 1.8 %

(1) Loans carried at fair value do not have an ACLL and are excluded from the ACLL ratio calculation.
(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)

85

 
 
 
 
 
 
 
 
 
 
 
 
 
The following table details Citi’s corporate credit allowance for credit losses on loans (ACLL) by industry exposure: 

In millions of dollars, except percentages

Transportation and industrials

Private bank

Consumer retail

Technology, media and telecom

Real estate

Power, chemicals, metals and mining

Banks and finance companies

Energy and commodities

Health

Public sector

Insurance

Asset managers and funds

Financial markets infrastructure

Securities firms

Other industries

Total

December 31, 2020

Funded 
exposure(1)

ACLL(2)(3)

ACLL as a % of 
funded exposure

$ 

58,352  $ 

1,558 

 2.67 %

75,693   

34,621   

29,821   

42,711   

20,156   

29,570   

14,009   

8,575   

13,416   

1,925   

4,491   

229   

430   

3,579   

$ 

337,578  $ 

224 

563 

407 

718 

312 

219 

523 

144 

172 

7 

22 

— 

10 

122 

5,001 

 0.30 

 1.63 

 1.36 

 1.68 

 1.55 

 0.74 

 3.73 

 1.68 

 1.28 

 0.36 

 0.49 

 — 

 2.33 

 3.41 

 1.48 %

(1)  Funded exposure excludes $6,840 million of loans at fair value that are not subject to ACLL under the CECL standard.
(2)  As of December 31, 2020, the ACLL shown above reflects coverage of 0.5% of funded investment grade exposure and 4.4% of funded non-investment grade 

exposure.

(3)  Excludes $401 million of ACLL associated with approximately $43 billion of funded delinquency-managed private bank exposures at December 31, 2020. 

Including those reserves and exposures, the total ACLL is 1.42% of total funded exposure, including 0.5% of funded investment grade exposure and 4.4% of 
funded non-investment grade exposure.

86

 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 59%, 58% and 44% of Citi’s corporate 
non-accrual loans were performing at December 31, 2020, 
September 30, 2020 and December 31, 2019, 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.

87

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)
North America

EMEA

Latin America

Asia 

Total corporate non-accrual loans
Consumer non-accrual loans(1)
North America

Latin America
Asia(2)
Total consumer non-accrual loans

Total non-accrual loans

2020

2019

2018

2017

2016

December 31,

$ 

1,928  $ 

1,214  $ 

586  $ 

966  $ 

1,291 

661   

719   

219   

430   

473   

71   

375   

307   

243   

849   

348   

70   

904 

441 

220 

3,527  $ 

2,188  $ 

1,511  $ 

2,233  $ 

2,856 

1,059  $ 

774   

308   

2,141  $ 

5,668  $ 

905  $ 

632   

279   

1,816  $ 

4,004  $ 

1,138  $ 

1,468  $ 

1,854 

638   

250   

2,026  $ 

3,537  $ 

688   

243   

2,399  $ 

4,632  $ 

648 

221 

2,723 

5,579 

$ 

$ 

$ 

$ 

(1) For years prior to 2020, excludes purchased credit-deteriorated 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 and $187 million at December 31, 2016.

(2)  Asia includes balances in certain EMEA countries for all periods presented.

The changes in Citigroup’s non-accrual loans were as follows:

In millions of dollars

Corporate

Consumer

Total

Corporate

Consumer

Total

Year ended
December 31, 2020

Year ended
December 31, 2019

Non-accrual loans at beginning of year

$ 

Additions

Sales and transfers to HFS

Returned to performing

Paydowns/settlements

Charge-offs

Other

Ending balance

2,188  $ 

5,103   

(2)   

(157)   

(3,117)   

(446)   

(42)   

1,816  $ 

2,829   

(95)   

(389)   

(677)   

(1,132)   

(211)   

4,004  $ 

7,932   

(97)   

(546)   

(3,794)   

(1,578)   

(253)   

1,511  $ 

3,407   

(23)   

(68)   

(2,496)   

(268)   

125   

2,026  $ 

2,954   

(171)   

(431)   

(902)   

(1,444)   

(216)   

3,537 

6,361 

(194) 

(499) 

(3,398) 

(1,712) 

(91) 

$ 

3,527  $ 

2,141  $ 

5,668  $ 

2,188  $ 

1,816  $ 

4,004 

88

 
 
 
 
 
 
 
 
 
 
 
 
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
ACLL as a percentage of NAL(1)

2020

2019

2018

2017

2016

December 31,

$ 

$ 

$ 

$ 

$ 

$ 

19 

— 

7 

17 

43 

$ 

$ 

39 

1 

14 

7 

61 

$ 

$ 

64 

1 

12 

22 

99 

$ 

89 

2 

35 

18 

$ 

161 

— 

18 

7 

$ 

144 

$ 

186 

3,527 

$ 

2,188 

$ 

1,511 

$ 

2,233 

$ 

2,141 

5,668 

43 

5,711 

$ 

$ 

$ 

1,816 

4,004 

61 

4,065 

$ 

$ 

$ 

2,026 

3,537 

99 

3,636 

$ 

$ 

$ 

2,399 

4,632 

144 

4,776 

$ 

$ 

$ 

2,856 

2,723 

5,579 

186 

5,765 

 0.84 %

 0.57 %

 0.52 %

 0.69 %

 0.89 %

 0.25 

 440 

 0.21 

 319 

 0.19 

 348 

 0.26 

 267 

 0.32 

 216 

(1) The ACLL 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, prior to 2020, include purchased credit-deteriorated loans as these continue to accrue interest until charge-off.

89

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

2020
total

$ 

428  $ 

365  $ 

793 

177   

134   

311 

$ 

251  $ 

231  $ 

482 

(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.

Renegotiated Loans
The following table presents Citi’s loans modified in TDRs:

In millions of dollars
Corporate renegotiated loans(1)
In U.S. offices

Commercial and industrial(2)
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, 
2020

Dec. 31, 
2019

$ 

$ 

$ 

$ 
$ 

193  $ 
60   
—   
30   
283  $ 

132  $ 
32   
—   
3   
167  $ 
450  $ 

226 
57 
— 
4 
287 

200 
22 
— 
40 
262 
549 

$  1,904  $  1,956 
1,464 
1,449   
17 
33   
$  3,386  $  3,437 

$ 

361  $ 
533   
519   

305 
466 
400 
$  1,413  $  1,171 
$  4,799  $  4,608 

(1)

(2)

(3)

Includes $415 million and $472 million of non-accrual loans included in 
the non-accrual loans table above at December 31, 2020 and 2019, 
respectively. The remaining loans are accruing interest.
In addition to modifications reflected as TDRs at December 31, 2020 
and 2019, Citi also modified $47 million and $26 million, respectively, 
of commercial loans risk rated “Substandard Non-Performing” or worse 
(asset category defined by banking regulators) in offices outside the U.S. 
These modifications were not considered TDRs because they did not 
involve a concession or because they qualified for exemptions from 
TDR accounting provided by the CARES Act or Interagency Guidance.
Includes $873 million and $814 million of non-accrual loans included in 
the non-accrual loans table above at December 31, 2020 and 2019, 
respectively. The remaining loans are accruing interest.

90

 
 
 
 
 
 
 
 
 
 
 
 
 
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—Liquidity Risks” 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 sufficient 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 oversight provided by Independent 
Risk Management and various Asset & Liability Committees 
(ALCOs) at the Citigroup, region, country and business levels. 
Pursuant to this approach, Citi’s HQLA is managed with 
emphasis on asset-liability management and entity-level 
liquidity adequacy throughout Citi.

The Chief Risk Officer and Citi’s CFO co-chair 

Citigroup’s ALCO, which includes Citi’s Treasurer and other 
senior executives. ALCOs, among other things, set the 
strategy of the liquidity portfolio and monitor its performance. 
Significant changes to portfolio asset allocations need to be 
approved by the ALCOs.

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. 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.

91

 
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, 
2020

Citibank
Sept. 30, 
2020

Dec. 31, 
2019

Citi non-bank and other entities
Dec. 31, 
Sept. 30, 
Dec. 31, 
2019
2020
2020

Dec. 31, 
2020

Total
Sept. 30, 
2020

Dec. 31, 
2019

$ 

304.3  $ 

279.3  $ 

158.7  $ 

2.1  $ 

2.0  $ 

2.1  $ 

306.4  $ 

281.3  $ 

77.8   

31.8   

39.6   

1.2   

80.6   

34.6   

44.5   

1.5   

100.2   

56.9   

66.4   

2.4   

64.8   

6.5   

16.2   

0.5   

56.0   

5.8   

17.0   

0.7   

29.6   

4.4   

16.5   

0.5   

142.6   

136.6   

38.3   

55.8   

1.7   

40.4   

61.5   

2.2   

160.8 

129.8 

61.3 

82.9 

2.8 

Total HQLA (AVG)

$ 

454.7  $ 

440.5  $ 

384.6  $ 

90.1  $ 

81.5  $ 

53.1  $ 

544.8  $ 

522.0  $ 

437.6 

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 applicable under the U.S. LCR rule. 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 Japan, Mexico, 
Singapore, South Korea and Hong Kong.

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 quarter-over-quarter as of 
the fourth quarter of 2020, primarily reflecting an increase in 
average long-term non-bank debt. While deposit growth and a 
decline in loans increased liquidity at Citibank, a significant 
amount of this liquidity was assumed not to be transferable to 
other entities within Citigroup and therefore not included in 
Citi’s consolidated HQLA. 

As of December 31, 2020, Citigroup had $972 billion of 

available liquidity resources to support client and business 
needs, including end-of-period HQLA assets; additional 
unencumbered securities, including excess liquidity held at 
bank entities that is non-transferable to other entities within 
Citigroup; and available assets not already accounted for 
within Citi’s HQLA to support Federal Home Loan Bank 
(FHLB) and Federal Reserve Bank discount window 
borrowing capacity.

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

Dec. 31, 
2020

Sept. 30, 
2020

Dec. 31, 
2019

$ 544.8 

$ 522.0 

$ 437.6 

  460.7 

  442.6 

  382.0 

LCR
HQLA in excess of net outflows

 118 %  118 %

 115 %

$  84.1 

$  79.4 

$  55.6 

Note: The amounts are presented on an average basis.

As of December 31, 2020, Citi’s average LCR was 

unchanged sequentially, as Citi’s average HQLA and net 
outflows increased proportionately.

92

 
 
 
 
Long-Term Liquidity Measurement: Net Stable Funding 
Ratio (NSFR)
On October 20, 2020, the U.S. banking agencies adopted a 
final rule to assess the availability of a bank’s stable funding 
against a required level. The intended purpose of the final rule 
is to support the ability of financial institutions to provide 
financial intermediation to businesses and households across a 
range of market conditions and reduce the possibility of 
funding shocks compromising a financial institution’s liquidity 
position. 

In general, a bank’s available stable funding will include 

portions of equity, deposits and long-term debt, while its 
required stable funding will be based on the liquidity 
characteristics of its assets, derivatives and commitments. 
Standardized weightings will be required to be applied to the 
various asset and liabilities classes. The ratio of available 
stable funding to required stable funding will be required to be 
greater than 100%. 

The final rule becomes effective beginning July 1, 2021 
while public disclosure requirements to report the ratio will 
occur on a semi-annual basis beginning June 30, 2023. Citi 
expects to be in compliance with the final rule when the rule is 
effective.

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

Dec. 31, 
2020

Sept. 30, 
2020

Dec. 31, 
2019

$  179.4  $  179.1  $  192.7 

14.3   

82.4   

13.6   

79.7   

17.4 

80.9 

$  276.1  $  272.4  $  291.0 

$  146.2  $  166.1  $  154.2 

67.1   

67.1   

74.5 

113.3   

110.3   

106.6 

56.1   

53.1   

56.0 

$  382.7  $  396.6  $  391.3 

Total Corporate/Other

$ 

7.4  $ 

8.2  $ 

10.3 

Total Citigroup loans (AVG)

$  666.2  $  677.2  $  692.6 

Total Citigroup loans (EOP)

$  676.1  $  666.9  $  699.5 

(1)

Includes loans in certain EMEA countries for all periods presented.

As of the fourth quarter of 2020, end-of period loans 
declined 3% year-over-year and increased 1% quarter-over-
quarter. 

On an average basis, loans declined 4% year-over-year 

and 2% quarter-over-quarter. Excluding the impact of FX 
translation, average loans also declined 4% year-over-year and 
2% sequentially. On this basis, average GCB loans declined 
6% year-over-year, primarily reflecting the impact of lower 
consumer spending in Citi’s cards businesses and higher 
payments by customers given high levels of liquidity due to 
fiscal stimulus.

Excluding the impact of FX translation, average ICG 

loans declined 3% year-over-year. Treasury and trade 
solutions (TTS) loans declined 10% year-over-year, reflecting 
softness in underlying trade flows and the continued low level 
of spend in commercial cards driven by the impact of the 
pandemic. Average corporate lending loans declined 6%, 
reflecting net repayments as Citi continued to assist its clients 
in accessing the capital markets, as well as lower loan demand 
given more muted economic activity. Average private bank 
loans increased 6%, largely driven by secured lending to high-
net-worth clients, including residential real estate lending. 
Average Corporate/Other loans continued to decline 

(down 29%), 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(1)

North America

Latin America
Asia(2)

Total

Institutional Clients Group

Treasury and trade solutions 
(TTS) 

Dec. 31, 
2020

Sept. 30, 
2020

Dec. 31, 
2019

$  188.9  $  182.1  $  156.2 

24.3   

22.5   

23.0 

120.0   

115.2   

103.4 

$  333.2  $  319.8  $  282.6 

$  686.5  $  678.6  $  558.7 

Banking ex-TTS

163.2   

150.1   

140.7 

Markets and securities services

109.3   

107.9   

95.0 

Total
Corporate/Other

$  959.0  $  936.6  $  794.4 
12.5 
$ 

11.4  $ 

13.1  $ 

Total Citigroup deposits (AVG)

$ 1,305.3  $ 1,267.8  $ 1,089.5 

Total Citigroup deposits (EOP)

$ 1,280.7  $ 1,262.6  $ 1,070.6 

(1) Reflects deposits within retail banking.
(2)

Includes deposits in certain EMEA countries for all periods presented.

End-of-period deposits increased 20% year-over-year and 

1% sequentially. 

As of the fourth quarter of 2020, on an average basis, 
deposits increased 20% year-over-year and 3% sequentially. 
Excluding the impact of FX translation, average deposits grew 
19% from the prior-year period and 2% sequentially, 
reflecting continued client engagement as well as the elevated 
level of liquidity in the financial system. On this basis, average 
deposits in GCB increased 18%, with strong growth across all 
regions. 

Excluding the impact of FX translation, average deposits 

in ICG grew 20% year-over-year, primarily driven by 22% 

93

 
 
 
 
 
 
 
 
 
growth in TTS, as well as continued growth in the private 
bank and securities services.

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 multiyear 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 
8.6 years as of December 31, 2020, unchanged from 
September 30, 2020 and an increase 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 
complements benchmark debt issuance as a source of funding 
for Citi’s non-bank entities. Citi’s long-term debt at the bank 
includes bank notes, 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
Non-bank(1)
Benchmark debt:

Senior debt

Subordinated debt

Trust preferred

Customer-related debt
Local country and other(2)
Total non-bank

Bank

Dec. 31, 
2020

Sept. 30, 
2020

Dec. 31, 
2019

$  126.2  $  126.3  $  106.6 

27.1   

27.4   

1.7   

1.7   

65.2   

61.0   

6.7   

8.1   

25.5 

1.7 

53.8 

7.9 

$  226.9  $  224.5  $  195.5 

FHLB borrowings
Securitizations(3)
Citibank benchmark senior debt
Local country and other(2)
Total bank

$ 

10.9  $ 

14.7  $ 

16.6   

13.6   

3.7   

16.4   

14.2   

3.5   

5.5 

20.7 

23.1 

4.0 

$ 

44.8  $ 

48.8  $ 

53.3 

Total long-term debt

$  271.7  $  273.3  $  248.8 

Note: Amounts represent the current value of long-term debt on Citi’s 
Consolidated Balance Sheet that, for certain debt instruments, includes 
consideration of fair value, hedging impacts and unamortized discounts and 
premiums.
(1) Non-bank 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, 2020, non-bank included $56.4 billion of long-term debt 
issued by Citi’s broker-dealer and other subsidiaries, as well as certain 
Citigroup consolidated hedging activities.

(2) Local country and other includes debt issued by Citi’s affiliates in 
support of their local operations. Within non-bank, certain secured 
financing is also included. Within bank, borrowings under certain U.S. 
government-sponsored liquidity programs are also included. 
(3) Predominantly credit card securitizations, primarily backed by Citi-

branded credit card receivables.

As of the fourth quarter of 2020, Citi’s total long-term 
debt outstanding increased year-over-year, primarily driven by 
the issuance of unsecured benchmark senior debt and 
customer-related debt at the non-bank entities, as well as an 
increase in FHLB borrowings at the bank, partially offset by 
declines in unsecured benchmark senior debt and 
securitizations at the bank. Sequentially, long-term debt 
outstanding decreased, driven primarily by a decline in FHLB 
borrowings at the bank and local country and other debt at the 
non-bank, partially offset by higher customer-related debt at 
the non-bank.

As part of its liability management, Citi has considered, 

and may continue to consider, opportunities to redeem or 
repurchase its long-term debt pursuant to open market 
purchases, tender offers or other means. Such redemptions and 
repurchases help reduce Citi’s overall funding costs. During 
2020, Citi redeemed or repurchased $28.9 billion of its 
outstanding long-term debt. 

94

 
 
 
 
 
 
 
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

Non-bank

Benchmark debt:

Senior debt

Subordinated debt

Trust preferred

Customer-related debt

Local country and other

Total non-bank

Bank

FHLB borrowings

Securitizations

Citibank benchmark senior debt

Local country and other

Total bank

Total

2020

2019

2018

Maturities

Issuances

Maturities

Issuances

Maturities

Issuances

$ 

6.5  $ 

20.4  $ 

16.5  $ 

16.2  $ 

18.5  $ 

—   

—   

27.7   

2.4   

—   

—   

36.8   

1.4   

—   

—   

12.7   

1.1   

—   

—   

25.1   

5.4   

2.9   

—   

6.6   

1.2   

36.6  $ 

58.6  $ 

30.3  $ 

46.7  $ 

29.2  $ 

7.5  $ 

12.9  $ 

7.1  $ 

2.1  $ 

15.8  $ 

4.6   

9.8   

4.9   

26.8  $ 

63.4  $ 

0.3   

—   

4.6   

17.8  $ 

76.4  $ 

7.9   

4.8   

0.9   

20.7  $ 

51.0  $ 

0.1   

8.8   

1.4   

12.4  $ 

59.1  $ 

8.6   

2.3   

2.2   

28.9  $ 

58.1  $ 

$ 

$ 

$ 

$ 

14.8 

0.6 

— 

16.9 

2.3 

34.6 

7.9 

6.8 

8.5 

2.9 

26.1 

60.7 

The table below shows Citi’s aggregate long-term debt maturities (including repurchases and redemptions) in 2020, as well as its 
aggregate expected remaining long-term debt maturities by year as of December 31, 2020:

In billions of dollars

Non-bank

Benchmark debt:

Senior debt

Subordinated debt

Trust preferred 

Customer-related debt

Local country and other

Total non-bank

Bank

FHLB borrowings

Securitizations

Citibank benchmark senior debt

Local country and other

Total bank

Total long-term debt

2020

2021

2022

2023

2024

2025

Thereafter

Total

Maturities

$ 

6.5  $ 

14.7  $ 

11.5  $ 

13.0  $ 

11.3  $ 

7.7  $ 

67.9  $  126.2 

—   

—   

27.7   

2.4   

—   

—   

8.4   

1.6   

0.8   

—   

8.5   

1.3   

1.3   

—   

6.8   

2.2   

1.1   

—   

4.0   

—   

5.3   

—   

5.4   

—   

18.6   

1.7   

32.1   

1.6   

27.1 

1.7 

65.2 

6.7 

36.6  $ 

24.7  $ 

22.1  $ 

23.3  $ 

16.4  $ 

18.4  $ 

121.9  $  226.9 

7.5  $ 

5.7  $ 

5.3  $ 

—  $  —  $  —  $ 

—  $ 

4.6   

9.8   

4.9   

7.2   

5.1   

0.6   

2.1   

5.7   

1.5   

2.4   

—   

0.3   

1.1   

2.8   

0.7   

0.4   

—   

0.1   

3.3   

—   

0.5   

10.9 

16.6 

13.6 

3.7 

26.8  $ 

18.6  $ 

14.6  $ 

2.7  $ 

4.6  $ 

0.5  $ 

3.8  $ 

44.8 

63.4  $ 

43.3  $ 

36.7  $ 

26.0  $ 

21.0  $ 

18.9  $ 

125.7  $  271.7 

$ 

$ 

$ 

$ 

95

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
•

•

Citigroup will be obligated to continue to transfer 
Contributable Assets to Citicorp over time, subject 
to certain amounts retained by Citigroup to, among 
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. On July 1, 
2020, the FRB and FDIC provided information to the eight 
largest domestic banking organizations, including Citi, 
required to be included in the targeted resolution plans due on 
July 1, 2021.

Total Loss-Absorbing Capacity (TLAC)
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. 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. 

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 preferred “single point of entry” resolution 

plan strategy, 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 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 the Orderly 
Liquidation Authority under Title II of the Dodd-Frank Act, 
which provides the FDIC with the ability to resolve a firm 
when it is determined that bankruptcy would have serious 
adverse effects on financial stability in the U.S.

As previously disclosed, in response to feedback received 

from the Federal Reserve and FDIC, Citigroup took the 
following actions:

(i)

(ii)

(iii)

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;
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); 
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;

96

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, i.e., 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 $200 billion as of December 31, 2020 

increased 20% from the prior year and declined 4% from the 
prior quarter. Excluding the impact of FX translation, secured 
funding decreased 16% from the prior year and declined 7% 
sequentially, both driven by normal business activity. Average 
balances for secured funding were $227 billion for the quarter 
ended December 31, 2020.

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.

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, 2020.

Citi manages the risks in its secured funding by 

conducting daily stress tests to account for changes in 
capacity, tenor, 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 $30 billion as of the fourth 
quarter of 2020 decreased 34% year-over-year and 21% 
sequentially, primarily driven by a decline in FHLB advances 
(see Note 17 to the Consolidated Financial Statements for 
further information on Citigroup’s and its affiliates’ 
outstanding short-term borrowings).

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

2020

2019

2018

2020

2019

2018

Amounts outstanding at year end
Average outstanding during the year(3)(4)(5)
Maximum month-end outstanding
Weighted average interest rate during the year(3)(4)(5)(6)

$ 

199.5 

$ 

166.3 

$ 

177.8 

$ 

80.0 

$ 

216.8 

225.3 

190.2 

196.8 

172.1 

191.2 

102.4 

129.3 

$ 

93.7 

98.8 

112.3 

96.9 

108.4 

113.5 

 0.96 %

 3.29 %

 2.84 %

 0.62 %

 2.49 %

 2.04 %

(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)  Monthly or quarterly averages have been used by certain subsidiaries where daily averages are unavailable.
(6)  Average rates reflect prevailing local interest rates, including inflationary effects and monetary correction in certain countries.

97

 
 
 
 
 
 
 
 
 
 
 
 
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, 2020. 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, 
2020.

Ratings as of December 31, 2020

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, 2020, 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 $0.6 billion, unchanged from 
September 30, 2020. 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

Negative

Stable

Stable

Long-
term

Short-
term

A+

Aa3

A+

F1

P-1

A-1

Outlook

Negative

Stable

Stable

As of December 31, 2020, 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 due to 
derivative triggers by approximately $0.4 billion, unchanged 
from September 30, 2020. Other funding sources, such as 
secured financing transactions and other margin requirements, 
for which there are no explicit triggers, could also be 
adversely affected.

In total, as of December 31, 2020, 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 
$1.0 billion, unchanged from September 30, 2020 (see also 
Note 22 to the Consolidated Financial Statements). As detailed 
under “High-Quality Liquid Assets” above, Citigroup has 
various liquidity resources available to its bank and non-bank 
entities in part as a contingency for the potential events 
described above.

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 at 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.

98

 
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. Citibank has provided liquidity commitments to 
consolidated asset-backed commercial paper conduits, 
primarily in the form of asset purchase agreements. As of 
December 31, 2020, Citibank had liquidity commitments of 
approximately $10.0 billion to consolidated asset-backed 
commercial paper conduits, compared to $11.4 billion as of 
September 30, 2020 (for additional information, see 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.

99

these and other strategies to reduce its interest rate risks and 
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 and market risk management, 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, 
including various regional, legal entity and business Risk 
Management committees, Citi’s country and business Asset & 
Liability Committees and the Citigroup Risk Management and 
Asset & Liability Committees. 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 

100

 
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 negative impact to AOCI (after-tax)(2)
Estimated initial impact on Common Equity Tier 1 Capital ratio (bps)

Dec. 31, 2020

Sept. 30, 2020

Dec. 31, 2019

$ 

$ 

$ 

373 

683 

1,056 

$ 

$ 

65 

$ 

702 

767 

$ 

20 

606 

626 

 0.05 %

 0.04 %

 0.03 %

(5,645) 

$ 

(5,757)  $ 

(5,002) 

(34) 

(36) 

(31) 

(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 $(89) million for a 100 bps instantaneous increase in interest rates as of December 31, 2020.
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 increase 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 a parallel instantaneous 100 bps increase in 

interest rates, Citi expects that the negative impact to AOCI 
would be offset in shareholders’ equity through the expected 
recovery of the impact on AOCI through accretion of Citi’s 
investment portfolio over a period of time. As of 
December 31, 2020, Citi expects that the negative $5.6 billion 
impact to AOCI in such a scenario could potentially be offset 
over approximately 31 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. The 100 bps downward rate 
scenarios are impacted by the low level of interest rates in 
several countries and the assumption that market interest rates, 
as well as rates paid to depositors and charged to borrowers, 
do not fall below zero (i.e., the “flooring assumption”). The 
rate scenarios are also impacted by convexity related to 
mortgage products.

In addition, in the table below, 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.

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   

373  $ 

683   

1,056  $ 

100   

—   

348  $ 

489   

837  $ 

—   

100   

—   

(100)   

141  $ 

(113)  $ 

42   

(42)   

183  $ 

(155)  $ 

(100) 

(100) 

(217) 

(342) 

(559) 

(5,645)  $ 

(3,837)  $ 

(1,987)  $ 

1,391  $ 

2,472 

(34)   

(24)   

(12)   

7   

9 

$ 

$ 

$ 

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.

101

 
 
 
 
 
 
 
 
 
 
Changes in Foreign Exchange Rates—Impacts on AOCI 
and Capital
As of December 31, 2020, 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 $1.7 billion, or 1.0%, 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 
Singapore dollar.

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.

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.

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

Estimated impact to Common Equity Tier 1 Capital ratio (on a fully implemented basis) due 
to changes in FX translation, net of hedges (bps)

For the quarter ended

Dec. 31, 2020

Sept. 30, 2020

Dec. 31, 2019

 5.5 %

 2.6 %

$ 

1,829 

$ 

655 

$ 

 1.2 %

2 

 0.4 %

(1) 

 2.8 %

659 

 0.4 %

(3) 

(1)   FX spot rate change is a weighted average based on Citi’s quarterly average GAAP capital exposure to foreign countries.

102

 
 
 
Interest Revenue/Expense and Net Interest Margin (NIM)

2020

$ 58,285 

In millions of dollars, except as otherwise noted
Interest revenue(1)
Interest expense(2)
Net interest revenue, taxable equivalent basis $ 43,744 
Interest revenue—average rate(3)
Interest expense—average rate
Net interest margin(3)(4)
Interest rate benchmarks

  14,541 

 2.16 

 0.88 

 2.88 %

Two-year U.S. Treasury note—average rate

10-year U.S. Treasury note—average rate

 0.39 %

 0.89 

2019

  $  76,718 

    29,163 

  $  47,555 

2018

  $  71,082 

    24,266 

  $  46,816 

 4.27 %

 2.01 

 2.65 

 1.97 %

 2.14 

 4.08 %

 1.77 

 2.69 

 2.53 %

 2.91 

Change 
 2020 vs. 2019

Change 
 2019 vs. 2018

 (24) %

 (50) 

 (8) %

(139) 

bps  

(113) 

bps  

(49) 

bps  

 8 %

 20 

 2 %

19 

24 

bps

bps

(4)  bps

(158) 

bps  

(125) 

bps  

(56)  bps

(77)  bps

10-year vs. two-year spread

50 

bps  

17 

bps  

38 

bps

Note: All interest expense amounts include FDIC, as well as other similar deposit insurance assessments outside of the U.S. 
(1) Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rate of 21%) of 

(2)

$196 million, $208 million and $254 for 2020, 2019 and 2018, 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 above.
(4)  Citi’s net interest margin (NIM) is calculated by dividing net interest revenue by average interest-earning assets.

103

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Non-ICG Markets Net Interest Revenue 

In millions of dollars
Net interest revenue (NIR)—taxable equivalent basis(1) per above
ICG Markets NIR—taxable equivalent basis(1)
Non-ICG Markets NIR—taxable equivalent basis(1)

2020

2019

2018

$ 

$ 

43,744 

$ 

47,555 

$ 

5,454 

4,372 

38,290 

$ 

43,183 

$ 

46,816 

4,506 

42,310 

(1)  Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rate of 21%) of 

$196 million, $208 million and $254 million for 2020, 2019 and 2018, respectively. 

Citi’s net interest revenue (NIR) in the fourth quarter of 2020 
decreased 13% to $10.5 billion (also $10.5 billion on a taxable 
equivalent basis) versus the prior-year period. Excluding the 
impact of FX translation, NIR decreased year-over-year by 
approximately $1.3 billion. The decrease was primarily related 
to a decline of approximately $1.5 billion in non-ICG Markets 
NIR, partially offset by an approximate $130 million increase 
in ICG Markets (fixed income markets and equity markets) 
NIR. The decrease in non-ICG Markets NIR primarily 
reflected lower interest rates and lower loan balances across 
institutional and consumer businesses (for additional 
information, see “Liquidity Risk—Loans” above). Citi’s NIM 
was 2.00% on a taxable equivalent basis in the fourth quarter 
of 2020, a decrease of three basis points from the prior quarter, 
reflecting lower NIR and balance sheet expansion due to 
strong deposit growth. 

Citi’s NIR for the full year 2020 decreased 8% to $43.5 

billion ($43.7 billion on a taxable equivalent basis) versus the 
prior year. Excluding the impact of FX translation, NIR 
decreased 6%, or approximately $3.0 billion. The decrease 
was primarily related to a decline of $4.1 billion in non-ICG 
Markets NIR, partially offset by an increase of $1.1 billion in 
ICG Markets NIR. The decrease in non-ICG Markets NIR was 
primarily driven by lower interest rates, as well as lower loan 
balances. On a full-year basis, Citi’s NIM was 2.16% on a 
taxable equivalent basis, compared to 2.65% in 2019. 

Citi’s ICG Markets NIR and non-ICG Markets NIR are 
non-GAAP financial measures. Citi believes presentation of 
these measures provides a meaningful depiction of the 
underlying fundamentals of its lending, investing and deposit-
raising businesses.

104

 
 
 
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105

Additional Interest Rate Details

Average Balances and Interest Rates—Assets(1)(2)(3)

Taxable Equivalent Basis

In millions of dollars, except rates

2020

2019

2018

2020

2019

2018

2020

2019

2018

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

$ 

288,629  $ 

188,523  $ 

177,294  $ 

928  $  2,682  $  2,203 

 0.32 %  1.42 %

 1.24 %

$ 

149,076  $ 

146,030  $ 

149,879  $  1,202  $  4,752  $  3,818 

 0.81 %  3.25 %

 2.55 %

138,074   

119,550   

117,695   

1,081   

2,133   

1,674 

 0.78 

 1.78 

 1.42 

$ 

287,150  $ 

265,580  $ 

267,574  $  2,283  $  6,885  $  5,492 

 0.80 %  2.59 %

 2.05 %

$ 

144,130  $ 

109,064  $ 

94,065  $  3,624  $  4,099  $  3,706 

 2.51 %  3.76 %

 3.94 %

134,078   

131,217   

115,601   

2,509   

3,589   

2,615 

 1.87 

 2.74 

 2.26 

$ 

278,208  $ 

240,281  $ 

209,666  $  6,133  $  7,688  $  6,321 

 2.20 %  3.20 %

 3.01 %

$ 

265,833  $ 

221,895  $ 

228,686  $  3,860  $  5,162  $  5,331 

 1.45 %  2.33 %

 2.33 %

Exempt from U.S. income tax

14,084   

15,227   

17,199   

452   

577   

706 

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

139,400   

117,529   

104,033   

3,781   

4,222   

3,600 

$ 

419,317  $ 

354,651  $ 

349,918  $  8,093  $  9,961  $  9,637 

 1.93 %  2.81 %

 2.75 %

$ 

396,846  $ 

395,792  $ 

385,350  $  26,700  $  30,563  $  28,627 

 6.73 %  7.72 %

 7.43 %

288,379   

288,319   

285,505    13,569    17,266    17,129 

 4.71 

 5.99 

 6.00 

$ 

$ 

685,225  $ 

684,111  $ 

670,855  $  40,269  $  47,829  $  45,756 

 5.88 %  6.99 %

 6.82 %

67,531  $ 

64,322  $ 

67,269  $ 

579  $  1,673  $  1,673 

 0.86 %  2.60 %

 2.49 %

$  2,026,060  $  1,797,468  $  1,742,576  $  58,285  $  76,718  $  71,082 

 2.88 %  4.27 %

 4.08 %

$ 

200,196  $ 

181,341  $ 

177,654 

$  2,226,256  $  1,978,809  $  1,920,230 

 3.21 

 2.71 

 3.79 

 3.59 

 4.10 

 3.46 

(1) Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rate of 21%) of 

$196 million, $208 million and $254 million for 2020, 2019 and 2018, 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)

106

 
 
 
 
 
 
 
 
 
 
 
 
Average Balances and Interest Rates—Liabilities and Equity, and Net Interest Revenue(1)(2)(3)

Taxable Equivalent Basis

In millions of dollars, except rates

2020

2019

2018

2020

2019

2018

2020

2019

2018

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 and other 
interest-bearing liabilities(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

$ 

485,848  $ 

388,948  $ 

338,060  $  3,384  $  6,304  $  4,500 

 0.70 %  1.62 %

 1.33 %

541,301   

487,318   

453,793   

3,153   

6,329   

5,116 

 0.58 

 1.30 

 1.13 

$  1,027,149  $ 

876,266  $ 

791,853  $  6,537  $  12,633  $  9,616 

 0.64 %  1.44 %

 1.21 %

$ 

137,348  $ 

112,876  $ 

102,843  $  1,292  $  4,194  $  3,320 

 0.94 %  3.72 %

 3.23 %

79,426   

77,283   

69,264   

785   

2,069   

1,569 

 0.99 

 2.68 

 2.27 

$ 

216,774  $ 

190,159  $ 

172,107  $  2,077  $  6,263  $  4,889 

 0.96 %  3.29 %

 2.84 %

$ 

38,308  $ 

37,099  $ 

37,305  $ 

283  $ 

818  $ 

52,051   

51,817   

58,919   

345   

490   

612 

389 

 0.74 %  2.20 %

 1.64 %

 0.66 

 0.95 

 0.66 

$ 

90,359  $ 

88,916  $ 

96,224  $ 

628  $  1,308  $  1,001 

 0.70 %  1.47 %

 1.04 %

$ 

82,363  $ 

78,230  $ 

85,009  $ 

493  $  2,138  $  1,885 

 0.60 %  2.73 %

 2.22 %

20,053   

20,575   

23,402   

137   

327   

324 

 0.68 

 1.59 

 1.38 

$ 

102,416  $ 

98,805  $ 

108,411  $ 

630  $  2,465  $  2,209 

 0.62 %  2.49 %

 2.04 %

$ 

213,809  $ 

193,972  $ 

197,933  $  4,656  $  6,398  $  6,386 

 2.18 %  3.30 %

 3.23 %

3,918   

4,803   

4,895   

13   

96   

165 

 0.33 

 2.00 

 3.37 

$ 

217,727  $ 

198,775  $ 

202,828  $  4,669  $  6,494  $  6,551 

 2.14 %  3.27 %

 3.23 %

Total interest-bearing liabilities

$  1,654,425  $  1,452,921  $  1,371,423  $  14,541  $  29,163  $  24,266 

 0.88 %  2.01 %

 1.77 %

Demand deposits in U.S. offices

$ 

30,876  $ 

27,737  $ 

33,398 

Other non-interest-bearing 
liabilities(7)
Total liabilities

346,538   

301,813   

315,862 

$  2,031,839  $  1,782,471  $  1,720,683 

Citigroup stockholders’ equity

$ 

193,769  $ 

195,632  $ 

198,681 

Noncontrolling interests

648   

706   

866 

Total equity

$ 

194,417  $ 

196,338  $ 

199,547 

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

$  2,226,256  $  1,978,809  $  1,920,230 

$  1,187,061  $  1,017,021  $ 

992,543  $  26,661  $  28,466  $  28,157 

 2.25 %  2.80 %

 2.84 %

838,999   

780,447   

750,033    17,083    19,089    18,659 

 2.04 

 2.45 

 2.49 

$  2,026,060  $  1,797,468  $  1,742,576  $  43,744  $  47,555  $  46,816 

 2.16 %  2.65 %

 2.69 %

(1) Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rate of 21%) of 

$196 million, $208 million and $254 million	for 2020, 2019 and 2018, 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 composed 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-

bearing liabilities.

107

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(8)

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.

(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

2020 vs. 2019

Increase (decrease)
due to change in:

2019 vs. 2018

Increase (decrease)
due to change in:

Average
volume

Average
rate

Net
change

Average
volume

Average
rate

Net
change

$ 

$ 

$ 

976  $  (2,730)  $  (1,754)  $ 

146  $ 

333  $ 

479 

96  $  (3,647)  $  (3,551)  $ 

(100)  $  1,034  $ 

290   

(1,342)   

(1,052)   

27   

432   

934 

459 

386  $  (4,989)  $  (4,603)  $ 

(73)  $  1,466  $  1,393 

$  1,102  $  (1,577)  $ 

(475)  $ 

570  $ 

(177)  $ 

77   

(1,157)   

(1,080)   

382   

592   

393 

974 

$  1,179  $  (2,734)  $  (1,555)  $ 

952  $ 

415  $  1,367 

$ 

910  $  (2,337)  $  (1,427)  $ 

(213)  $ 

(85)  $ 

(298) 

703   

(1,144)   

(441)   

481   

141   

$  1,613  $  (3,481)  $  (1,868)  $ 

268  $ 

56  $ 

622 

324 

$ 

$ 

$ 

81  $  (3,944)  $  (3,863)  $ 

789  $  1,149  $  1,938 

4   

(3,701)   

(3,697)   

169   

(34)   

135 

85  $  (7,645)  $  (7,560)  $ 

958  $  1,115  $  2,073 

80  $  (1,173)  $  (1,093)  $ 

(75)  $ 

75  $ 

— 

$  4,319  $  (22,752)  $  (18,433)  $  2,176  $  3,460  $  5,636 

(1) The taxable equivalent adjustments related to the tax-exempt bond portfolio, based on the U.S. federal statutory tax rate of 21%, 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)

108

 
 
 
 
 
 
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 and other interest-bearing liabilities(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

2020 vs. 2019

Increase (decrease)
due to change in:

2019 vs. 2018

Increase (decrease)
due to change in:

Average
volume

Average
rate

Net
change

Average
volume

Average
rate

Net
change

$  1,298  $  (4,218)  $  (2,920)  $ 

738  $  1,066  $  1,804 

637   

(3,813)   

(3,176)   

397   

816   

1,213 

$  1,935  $  (8,031)  $  (6,096)  $  1,135  $  1,882  $  3,017 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

756  $  (3,658)  $  (2,902)  $ 

343  $ 

531  $ 

56   

(1,340)   

(1,284)   

194   

306   

874 

500 

812  $  (4,998)  $  (4,186)  $ 

537  $ 

837  $  1,374 

27  $ 

(562)  $ 

(535)  $ 

(3)  $ 

209  $ 

2   

(147)   

(145)   

(51)   

152   

29  $ 

(709)  $ 

(680)  $ 

(54)  $ 

361  $ 

206 

101 

307 

107  $  (1,752)  $  (1,645)  $ 

(159)  $ 

412  $ 

253 

(8)   

(182)   

(190)   

(42)   

45   

3 

99  $  (1,934)  $  (1,835)  $ 

(201)  $ 

457  $ 

256 

602  $  (2,344)  $  (1,742)  $ 

(129)  $ 

141  $ 

(15)   

(68)   

(83)   

(3)   

(66)   

587  $  (2,412)  $  (1,825)  $ 

(132)  $ 

75  $ 

12 

(69) 

(57) 

$  3,462  $ (18,084)  $ (14,622)  $  1,285  $  3,612  $  4,897 

$ 

857  $  (4,668)  $  (3,811)  $ 

891  $ 

(152)  $ 

739 

(1) The taxable equivalent adjustments related to the tax-exempt bond portfolio, based on the U.S. federal statutory tax rate of 21%, 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)

109

 
 
 
 
 
 
 
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 97.7% of the trading 
days in 2020.

Daily Trading-Related Revenue (Loss)(1)—Twelve Months Ended December 31, 2020
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.

110

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 
32% 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 increased from 2019 to 2020, mainly due to significant 
market volatility during the first half of 2020 across all asset 
classes, driven by macroeconomic challenges and 
uncertainties related to the COVID-19 pandemic. Citi’s 
average trading and credit portfolio VAR also increased in 
2020, primarily due to the higher market volatility, increased 
hedging activity and changes in portfolio composition.

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, 
2020

2020 
Average

December 31, 
2019

2019 
Average

$ 

$ 

$ 

$ 

$ 

$ 

$ 

72  $ 

66  $ 

70   

(51)   

86   

(48)   

91  $ 

104  $ 

40   

31   

17   

(85)   

94  $ 

(1)  $ 

95  $ 

29  $ 

123  $ 

26   

36   

22   

(82)   

106  $ 

(2)  $ 

108  $ 

49  $ 

155  $ 

32  $ 

44   

(27)   

49  $ 

22   

21   

13   

(52)   

53  $ 

3  $ 

50  $ 

30  $ 

83  $ 

35 

44 

(23) 

56 

23 

16 

24 

(62) 

57 

2 

55 

14 

71 

(1) Covariance adjustment (also known as diversification benefit) equals the difference between the total VAR and the sum of the VARs tied to each risk type. The 
benefit reflects the fact that the risks within individual 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 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.

111

 
 
 
 
 
 
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

2020

2019

Low

High

Low

High

$ 

$ 

$ 

28  $ 

36   

44  $ 

14   

13   

12   

47  $ 

58   

137  $ 

171   

223  $ 

40   

141   

64   

245  $ 

424   

25  $ 

36   

43  $ 

12   

7   

12   

38  $ 

54   

58 

55 

89 

34 

29 

75 

87 

103 

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, 2020

Total—all market risk factors, including 
general and specific risk

Average—during year

High—during year

Low—during year

$ 

$ 

97 

104 

236 

44 

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, product specific back-testing on portfolios is
periodically completed as part of the ongoing model 
performance monitoring process 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.

Material VAR model and assumption changes must be 

independently validated within Citi’s risk management 
organization. All model changes, including those for the VAR 
model, are validated by the 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 
composition of Risk Management VAR is discussed under 

112

“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 2020. As of December 
31, 2020, four back-testing exceptions were observed at the 
Citigroup level. These exceptions occurred in March and were 
due to losses across multiple businesses during the onset of the 
pandemic-related volatility.

The difference between the 65.26% of days with buy-and-
hold gains for Regulatory VAR back-testing and the 97.7% 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, 2020
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.

113

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.

114

OPERATIONAL RISK

Overview
Operational risk is the risk of loss resulting from inadequate or 
failed internal processes, people and systems or from external 
events. This includes legal risk, which is the risk of loss 
(including litigation costs, settlements, and regulatory fines) 
resulting from the failure of Citi to comply with laws, 
regulations, prudent ethical standards, and contractual 
obligations in any aspect of its businesses, but excludes 
strategic and reputation risks. Citi also recognizes the impact 
of operational risk on the reputation risk associated with Citi’s 
business activities. 

Operational risk is inherent in Citi’s global business 
activities, as well as related support functions, and can result 
in losses. Citi maintains a comprehensive firm-wide risk 
taxonomy to classify operational risks that it faces using 
standardized definitions across the firm’s Operational Risk 
Management Framework (see discussion below). This 
taxonomy also supports regulatory requirements and 
expectations inclusive of those related to U.S. Basel III capital 
requirements, CCAR process and heightened standards under 
U.S. banking requirements. 

Citi manages operational risk consistent with the overall 
framework described in “Managing Global Risk—Overview” 
above. Citi’s goal is to keep operational risk at appropriate 
levels relative to the characteristics of its businesses, the 
markets in which it operates, its capital and liquidity and the 
competitive, economic and regulatory environment. This 
includes effectively managing operational risk and 
maintaining or reducing operational risk exposures within 
Citi’s operational risk appetite.

To anticipate, mitigate and control operational risk, Citi’s 

Independent Operational Risk Management group has 
established a global-Operational Risk Management 
Framework with policies and practices for identification, 
measurement, monitoring, mitigating, and reporting 
operational risks and the overall operating effectiveness of the 
internal control environment. As part of this framework, Citi 
has defined its operational risk appetite and established a 
manager’s control assessment (MCA) process for self-
identification of significant operational risks, assessment of 
the performance of key controls and mitigation of residual risk 
above acceptable levels. 

Each major business segment must implement operational 

risk processes consistent with the requirements of this 
framework. This includes:

Understanding the operational risks they are exposed to;
designing controls to mitigate identified risks;
establishing key indicators;

•
•
•
• monitoring and reporting whether the operational risk 

•

•

•

exposures are in or out of their operational risk appetite;
having processes in place to bring operational risk 
exposures within acceptable levels; 
periodically estimate and aggregate the operational risks 
they are exposed to; and
ensuring that sufficient resources are available to 
actively improve the operational risk environment and 
mitigate emerging risks.

Citi considers operational risks that result from the 
introduction of new or changes to existing products, or result 
from significant changes in its organizational structures, 
systems, processes and personnel. 

Citi has a governance structure for the oversight of 

operational risk exposures through Business Risk and Controls 
Committees (BRCCs), which include a Citigroup BRCC as 
well as business, functions, regional and country BRCCs. 
BRCCs are chaired by the individuals in the first line of 
defense and provide escalation channels for senior 
management to review operational risk exposures including 
breaches of operational risk appetite, key indicators, 
operational risk events, and control issues. Membership 
includes senior business and functions leadership as well as 
members of the second line of defense.

Citi also has an Operational Risk Management Committee 
that provides senior management of the second line of defense 
risk organizations with a platform to assess Citi’s operational 
risk profile and to review that actions are taken to bring Citi’s 
operational risk exposures within operational risk appetite. 
Members include Citi’s Chief Risk Officer and Citi’s Head of 
Operational Risk Management 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, Independent Risk Management, including the 
Operational Risk Management group, works proactively with 
Citi’s businesses and functions to drive a strong and embedded 
operational risk management culture and framework across 
Citi. The Operational Risk Management group actively 
challenges business and functions implementation of the 
Operational Risk Management Framework requirements and 
the quality of operational risk management practices and 
outcomes.

Information about businesses’ key operational risks, 
historical operational risk losses and the control environment 
is reported by each major business segment and functional 
area. Citi’s operational risk profile and related information is 
summarized and reported to senior management, as well as to 
the Audit and Risk Committees of Citi’s Board of Directors by 
the Head of Operational Risk Management.
Operational risk is measured through 

Operational Risk Capital and Operational Risk Regulatory 
Capital for the Advanced Approaches under Basel III. 
Projected operational risk losses under stress scenarios are 
estimated as a required part of the Federal Reserve Board’s 
CCAR process. 

For additional information on Citi’s operational risks, see 

“Risk Factors—Operational Risk” above.

Erroneous Revlon-Related Payment
In August 2020, Citi, as administrative agent for a Revlon 
credit facility, in addition to making an interest payment, 
erroneously paid the lenders under the facility an aggregate of 
approximately $894 million, which is an amount equal to the 
principal balance of the loan at that time. Human error at Citi 
and at a third-party vendor, and limitations in Citi’s loan 

115

processing systems, were the main contributing factors. After 
a careful assessment of the incident, Citi immediately put in 
additional controls to prevent similar loan disbursement errors 
in the future, while also embarking on a major upgrade of the 
loan infrastructure and controls.

As of February 26, 2021, $389.8 million has been repaid 

to Citi. In August 2020, Citi commenced litigation against 
certain fund managers of lenders that have not returned the 
remaining $504.2 million of erroneously transferred funds, 
and obtained a temporary restraining order against the fund 
managers and those acting with them, freezing the funds from 
transfer or disbursement. On February 16, 2021, the court 
issued a judgment in favor of the defendants, which Citi 
intends to appeal. As a result of the court’s decision, Citi now 
has rights as a creditor related to the Revlon loan. For 
additional information, see Notes 27, 29 and 30 to the 
Consolidated Financial Statements.

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 protect against, 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 

116

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 and ICRM-T team collectively also monitor cyber 
legal and regulatory requirements, identify and define 
emerging risks, execute strategic cyber threat assessments, 
perform new products and initiative reviews, perform data 
management risk oversight and conduct 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, rules, 
or regulations, or from non-conformance with prescribed 
practices, internal policies and procedures or ethical standards. 
Compliance risk exposes Citi to fines, civil money penalties, 
payment of damages and the voiding of contracts. Compliance 
risk can result in diminished reputation, harm to the firm’s 
customers, limited business opportunities and lessened 
expansion potential. It encompasses the risk of noncompliance 
with all laws and regulations, as well as prudent ethical 
standards and some contractual obligations. It could also 
include exposure to litigation (known as legal risk) from all 
aspects of traditional and non-traditional banking.

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:

•

Drive and embed a culture of compliance and control 
throughout Citi;

• Maintain and oversee an integrated CRM Policy and 

Compliance Risk Framework 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; 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 Compliance Risk Framework, 
which is composed of the following integrated key activities, 
to holistically manage compliance risk:

• Management of Citi’s compliance with laws, rules and 
regulations by identifying and analyzing changes, 
assessing the impact, and implementing appropriate 
policies, processes and controls.
Developing and providing compliance training to ensure 
colleagues are aware of and understand the key laws, 
rules and regulations.

•

• Monitoring compliance risk appetite, which is articulated 
through qualitative compliance risk statements describing 
Citi’s appetite for certain types of risk and quantitative 
measures to monitor the Company’s compliance risk 
exposure.

• Monitoring and testing of compliance risks and controls 

•

in assessing conformance with laws, rules, regulations and 
internal policies.
Issue identification, escalation and remediation to drive 
accountability, including measurement and reporting of 
compliance risk metrics against established thresholds in 
support of the CRM Policy and Compliance Risk 
Appetite.

As discussed above, Citi is working to address the FRB 

and OCC consent orders, which include improvements to 
Citi’s Compliance Risk Framework and its Enterprise-wide 
application (for additional information regarding the consent 
orders, see “Citi’s Consent Order Compliance” above).

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 colleagues, customers, investors and 
regulators. 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 
Reputation Risk Committee or equivalent. 

The Reputation Risk Committees are part of the 

governance infrastructure that Citi has in place to review the 
reputation risk posed by business activities, sales practices, 
product design, or perceived conflicts of interest. These 
committees may also raise potential reputation risks for due 

consideration by the Reputation Risk Committee at the 
corporate level. The Citigroup Reputation Risk Committee
may escalate reputation risks to the Nomination, Governance
and Public Affairs Committee or other appropriate committee
of the Citigroup Board of Directors. The Reputation Risk 
Committees, which are composed of Citi’s most senior 
executives, govern the process by which material reputation 
risks are identified, monitored, reported, managed and 
escalated, and appropriate actions are taken in line with 
Company-wide strategic objectives, risk appetite thresholds 
and regulatory expectations, while promoting the culture of 
risk awareness and high standards of integrity and ethical 
behavior across the Company, consistent with Citi’s mission 
and value proposition. 

Further, the responsibility for maintaining Citi’s 

reputation is shared by all colleagues, who are guided by Citi’s 
Code of Conduct. Colleagues 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 reputation risk.

STRATEGIC RISK

Overview
Citi’s Executive Management Team, led by Citi’s CEO, 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 checkpoints 
where management’s progress is assessed and where decisions 
to refine the strategic direction of the Company are evaluated; 
Citi’s Executive Management Team 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 Board of Directors.

U.K.’s Future Relationship with the EU
As previously disclosed, the U.K. formally left the European 
Union (EU) on January 31, 2020. Subsequently, the U.K. and 
the EU entered into a Trade and Cooperation Agreement 
(TCA) that set out preferential arrangements in areas such as 
trade in goods and in services that became effective on 
January 1, 2021. While entering into the TCA avoided a “no 
deal” exit scenario, many questions remain as to the future 
relationship between the U.K. and the EU. For example, the 
TCA minimally covers financial services. The U.K. and the 
EU have committed under the TCA to negotiate further details 
regarding financial services, but there can be no assurance as 
to the successful completion or ultimate outcome of those 
negotiations. Citi planned extensively for the U.K. exit from 

117

the EU and successfully implemented its transition plans to 
date. However, future legislative and regulatory developments 
in the U.K. and the EU as a result of the exit may negatively 
impact Citi. For additional information, see “Risk Factors—
Strategic Risks” above.

LIBOR Transition Risk
The ICE Benchmark Administration concluded the 
consultation on its intent to cease publication of one week and 
two month USD LIBOR on December 31, 2021 and to extend 
the publication of all remaining USD LIBORs until June 30, 
2023 for legacy contracts. In addition, it is expected that all 
non USD LIBOR tenors will cease after December 31, 2021. 
Citi recognizes that a transition away from and discontinuance 
of LIBOR presents various 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 interest rate benchmark, see “Risk Factors—Strategic 
Risks” above). Accordingly, Citi has continued its efforts to 
identify and manage its LIBOR transition risks. Citi is also 
closely monitoring legislative, regulatory and other 
developments related to LIBOR transition matters and relief.

Citi has established a LIBOR governance and 

implementation program 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 & Liability 
Committee and reporting to the Risk Management Committee 
of Citigroup’s Board of Directors. As part of the program, Citi 
has continued to implement its 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 2020, 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 promote 
and advance development of alternative reference rates and 
seek to identify and address potential challenges from any 
transition to such rates. Citi also continued to engage with 
regulators, financial accounting bodies and others on LIBOR 
transition matters.

Moreover, Citi has continued to identify its LIBOR 
transition exposures, including financial instruments that do 
not contain contract provisions that adequately contemplate 
the discontinuance of reference rates and that would require 
additional negotiation with counterparties. Citi’s LIBOR 
transition efforts include, among other things, using alternative 
reference rates in certain newly issued financial instruments 
and products. Since 2019, Citi has issued preferred stock and 
benchmark debt referencing the Secured Overnight Financing 
Rate (SOFR) as well as updated the LIBOR determination 
method in its debt documentation with the ARRC 

118

recommended fallback language. In addition, in 2020, Citi 
transitioned the discounting of centrally cleared EUR and 
USD interest rate derivatives to the Euro Short-Term Rate 
(ESTR) and SOFR, respectively; announced the adoption of 
the newly published Interbank Offered Rate (IBOR) Fallbacks 
Protocol of the International Swaps and Derivatives 
Association (ISDA) for existing IBOR derivatives 
transactions; and increased Citi’s virtual client communication 
efforts, including outreach regarding these new industry-led 
protocols and solutions. Further, Citi has also been investing 
in its systems and infrastructure, as client activity moves away 
from LIBOR to alternative reference rates.

Climate Risk 
Climate change presents immediate and long-term risks to Citi 
and to its clients and customers, with the risks expected to 
increase over time. Climate risk refers to the risk of loss 
arising from climate change and is divided into physical risk 
and transition risk. Physical risk considers how chronic and 
acute climate change (e.g., increased storms, drought, fires, 
floods) can directly damage physical assets (e.g., real estate, 
crops) or otherwise impact their value or productivity. 
Transition risk considers how changes in policy, technology 
and market preference to address climate change (e.g., carbon 
price policies, power generation shifts from fossil fuels to 
renewable energy) can lead to changes in the value of assets, 
commodities and companies. 

Climate risk is an overarching risk that can act as a driver 
of other types of risk in the Citi risk taxonomy, such as credit 
risk from obligors exposed to high climate risk, reputational 
risk from increased stakeholder concerns about financing high 
carbon industries and operational risk from physical climate 
risks to Citi’s facilities.

Citi currently identifies climate risk as an “emerging risk” 
within its risk governance framework. Emerging risks are risks 
or thematic issues that are either new to the landscape, or in 
the case of climate risk, existing risks that are rapidly 
changing or evolving in an escalating fashion, which are 
difficult to assess due to limited data or other uncertainties. 
For additional information on climate risk, see “Risk Factors
—Strategic Risk” above.

With the increased importance and focus on climate risk, 

Citi has continued to expand its governance of climate risk and 
integrate climate considerations into the priorities of 
Citigroup’s Board of Directors and senior management. In 
particular, Citi has:

•
•

•

•

appointed a Chief Sustainability Officer;
appointed a Head of Climate Risk to partner with the 
Head of Environmental and Social Risk Management to 
deliver a Company-wide strategy concerning climate risk; 
formed a global, cross-functional senior-executive level 
Climate Risk Advisory Council to provide oversight of 
and guidance to Citi’s climate risk integration efforts; and
increased the frequency and depth of Board and senior-
level review of climate-related matters.

Citi manages and mitigates the credit and reputational 

risks from climate change through a number of internal 
initiatives, including Citi’s Environmental and Social Risk 

Management (ESRM) Policy. First established in 2003, the 
ESRM Policy is part of Citi’s broader credit risk management 
policy and is applicable to all Citi entities globally. The ESRM 
Policy provides the framework for how Citi identifies, 
mitigates and manages the potential environmental and social 
risks (including climate risks) associated with clients’ 
activities that could lead to credit or reputation risks to the 
Company. It guides how Citi evaluates lending, underwriting 
and advisory in environmentally sensitive and/or high-carbon 
sectors, and presents opportunities for Citi to engage clients on 
solutions to thematic risks. 

In project-related lending, Citi’s ESRM Policy 
incorporates the updates from the fourth iteration of the 
Equator Principles, which Citi helped shape, that expands 
climate risk requirements to include physical risk as well as 
transition risk. Citi’s ESRM Policy covers lending and 
underwriting with identified use of proceeds directed to 
physical assets and activities, as well as sector standards for 
corporate relationships in higher-risk sectors, including 
carbon-intensive sectors. In 2020, Citi updated its sector 
standards for thermal and coal mining, coal-fired power and 
Arctic oil and gas.

Citi has also made climate risk one of the three key pillars 

of its 2025 Sustainable Progress Strategy. Under this pillar, 
Citi intends to measure, manage and reduce the climate risk 
and impact of its client portfolios and enhance its Taskforce on 
Climate-Related Financial Disclosures (TCFD) 
implementation and disclosure through policy development, 
portfolio analysis and client engagement. In December 2020, 
Citi released its second report detailing its implementation of 
the TCFD recommendations: Finance for a Climate-Resilient 
Future II. In this report, Citi discusses its implementation of 
the TCFD recommendations, and Citi’s recent pilot testing of 
climate scenario analyses to assess climate-related impacts and 
risks in specific sectors, spanning both transition and physical 
climate risks. Climate data is still improving in terms of its 
accessibility and reliability, and the industry and Citi continue 
to develop better methodological approaches toward assessing 
climate change impacts. Nonetheless, Citi expects to integrate 
more quantitative analysis of climate risks into credit 
assessments in the future and to quantify the carbon emissions 
associated with its client portfolios. Citi will continue to 
disclose its progress in this area in its annual Environmental, 
Social, and Governance (ESG) Report and TCFD reporting. 
In addition, 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 
“Environmental, Social, and Governance.” For information on 
Citi’s ESG and Sustainability (including climate change) 
governance, see Citi’s 2020 Annual Meeting Proxy Statement 
available at www.citigroup.com. Click on “Investors” and then 
“Annual Reports & Proxy Statements.”

119

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, 2020. 
(Including the U.S., the total exposure as of December 31, 
2020 would represent approximately 96% 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 37% of corporate 
loans presented in the table below are to U.K. domiciled 
entities (42% for unfunded commitments), with the balance of 
the loans predominately to European domiciled counterparties. 
Approximately 80% of the total U.K. funded loans and 86% of 
the total U.K. unfunded commitments were investment grade 
as of December 31, 2020. 

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 
4Q20

Total 
as of 
3Q20

Total 
as of 
4Q19

Total as a 
% of Citi 
as of 
4Q20

$  43.3  $  —  $ 

2.0  $ 

52.0  $ 

17.0  $ 

(5.4)  $ 

5.0  $ 

1.3  $  115.2  $  108.5  $  105.8 

 6.6 %

In billions of 
dollars
United 
Kingdom

Mexico

  14.2    14.6   

Hong Kong

  18.2    13.2   

Singapore

  13.9    13.8   

Ireland

  13.0    —   

South Korea  

3.3    18.7   

India

Brazil

Germany

China

Japan

Australia

Canada

Taiwan

Poland

Jersey

United Arab 
Emirates

Malaysia

Thailand

Indonesia

Russia

6.6   

4.2   

  11.7    —   

0.7    —   

7.5   

3.6   

2.5    —   

4.9   

9.4   

2.2   

0.6   

5.5   

8.3   

3.5   

2.0   

6.8    —   

7.6   

1.4   

0.9   

1.3   

3.9   

2.9   

2.2   

0.7   

1.8   

0.8   

Luxembourg  

0.8    —   

Philippines
Czech 
Republic

0.8   

1.4   

0.8    —   

South Africa  

1.3    —   

0.3   

0.5   

0.2   

0.6   

0.1   

0.9   

—   

—   

0.6   

0.1   

—   

0.2   

0.2   

—   

—   

—   

0.1   

—   

—   

—   

—   

—   

—   

—   

Total as a % of Citi’s total exposure

Total as a % of Citi’s non-U.S. total exposure

9.6   

6.8   

6.4   

29.2   

2.6   

6.2   

2.8   

6.7   

3.1   

3.1   

7.0   

7.9   

1.3   

2.7   

6.9   

3.2   

0.8   

2.2   

1.3   

0.8   

—   

0.5   

0.7   

0.4   

3.1   

1.8   

2.1   

0.5   

1.5   

3.5   

4.2   

4.4   

1.6   

3.9   

1.6   

2.3   

0.6   

0.2   

(0.9)   

(0.7)   

(0.6)   

(0.1)   

(0.8)   

(0.4)   

(0.8)   

(4.0)   

(0.5)   

(1.9)   

(0.6)   

(0.9)   

(0.1)   

(0.1)   

—   

(0.3)   

0.5   

0.2   

0.1   

0.1   

0.3   

0.4   

0.1   

2.3   

0.3   

(0.3)   

—   

—   

(0.1)   

(0.1)   

(0.9)   

—   

—   

—   

19.0   

7.1   

8.0   

—   

9.7   

9.9   

4.3   

10.6   

5.7   

5.7   

1.5   

5.1   

0.4   

6.5   

—   

0.1   

1.7   

1.8   

1.7   

1.5   

4.5   

1.7   

0.4   

1.8   

4.6   

2.1   

2.0   

0.7   

0.7   

0.5   

4.0   

6.0   

0.2   

8.4   

64.5   

60.9   

49.0   

47.9   

45.8   

44.1   

43.9   

41.2   

35.8   

33.2   

31.4   

31.6   

26.2   

25.1   

24.4   

27.1   

21.8   

21.7   

21.8   

19.7   

(2.1)   

21.7   

21.2   

0.4   

1.1   

0.2   

17.8   

17.0   

17.3   

17.0   

15.0   

15.1   

—   

13.4   

13.3   

65.0 

49.0 

43.3 

39.9 

34.7 

30.0 

28.3 

21.8 

18.7 

17.0 

21.5 

15.2 

17.9 

13.4 

12.8 

—   

0.2   

0.1   

0.1   

0.1   

0.3   

—   

0.1   

(0.2)   

12.4   

11.9   

12.8 

8.3   

8.0   

6.0   

5.2   

5.1   

4.5   

4.3   

3.6   

8.4   

7.9   

6.0   

4.6   

6.7   

4.7   

3.8   

3.5   

8.4 

7.7 

5.9 

5.0 

4.6 

4.9 

4.3 

3.5 

 3.7 

 2.8 

 2.6 

 2.5 

 2.1 

 1.8 

 1.5 

 1.4 

 1.3 

 1.3 

 1.2 

 1.0 

 1.0 

 0.9 

 0.8 

 0.7 

 0.5 

 0.5 

 0.3 

 0.3 

 0.3 

 0.3 

 0.2 

 0.2 

 35.8 %

 91.5 %

(1) 

ICG loans reflect funded corporate loans and private bank loans, net of unearned income. As of December 31, 2020, private bank loans in the table above totaled 
$30.1 billion, concentrated in Hong Kong ($8.2 billion), the United Kingdom ($7.9 billion) and Singapore ($7 billion).

(2)  Other funded includes other direct exposures such as accounts receivable, loans HFS, other loans in Corporate/Other and investments accounted for under the 

equity method.

120

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(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 

inclusive of CVA. Includes margin loans.
(5) 
Investment securities include debt securities available-for-sale, recorded at fair market value, and debt securities held-to-maturity, recorded at historical cost.
(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
As previously disclosed, Citi operates in Argentina through its 
ICG businesses. As of December 31, 2020, Citi’s net 
investment in its Argentine operations was approximately $1.0 
billion. 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 August 2020, the Argentine government 
announced the successful restructuring of almost all of its 
foreign currency debt issued under foreign law, for which it 
had previously postponed principal and interest payments. 
However, during September 2020, the Argentine government 
tightened its existing capital and currency controls, which 
continue to restrict Citi’s ability to access U.S. dollars in 
Argentina and remit earnings from its Argentine operations. 
Citi’s net investment in its Argentine operations is likely
to increase as Citi generates net income in its Argentine
franchise and its earnings are unable to be remitted.

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 primarily executed outside of Argentina. 
As of December 31, 2020, the international NDF market had 
very limited liquidity, resulting in Citi’s being unable to 
economically hedge nearly all of its Argentine peso exposure. 
As a result, and to the extent that Citi does not execute NDF 
contracts for this unhedged exposure in the future, Citi would 
record devaluations on its net Argentine peso‑denominated 
assets in earnings, without any benefit from a change in the 
fair value of derivative positions used to economically hedge 
the exposure. 

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 allowances for 
credit losses 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, 
2020. However, 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” 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.

121

The tables below show each country whose total outstandings exceeded 0.75% of total Citigroup assets:

December 31, 2020
Cross-border claims on third parties and local country assets 
Short-term 
Other 
claims(2) 
(corporate 
(included in 
and households) 
(a))
(a)

Total 
outstanding(3) 
(sum of (a))

Trading 
assets(2) 
(included 
in (a))

Commitments
 and 
guarantees(4)

Public 
(a)

NBFIs(1) 
(a)

Credit 
derivatives 
purchased(5)

Credit 
derivatives 
sold(5)

Banks 
(a)

In billions of 
dollars
United 
Kingdom
Cayman 
Islands
Japan
Germany
Mexico
France
Singapore
South Korea  
Hong Kong
Australia
China 
India
Taiwan
Netherlands
Brazil
Italy
Switzerland
Canada

$  16.0  $  26.0  $ 

  11.0   

  —    —   
  32.9    35.5   
7.1    51.8   
3.9    31.5   
9.7   
2.5    25.6   
3.3    18.2   
1.5    13.8   
5.1    16.4   
4.5    16.3   
1.9    14.0   
7.8   
0.4   
7.8    10.4   
2.8    11.3   
2.5    19.1   
1.8    14.3   
6.3   
4.5   

55.9  $ 

17.5  $ 

14.2  $ 

75.1  $ 

115.4  $ 

25.8  $ 

76.2  $ 

75.3 

85.8   
12.1   
11.1   
9.5   
39.3   
10.7   
1.8   
3.9   
4.0   
3.3   
2.5   
2.0   
3.4   
1.6   
0.6   
1.4   
5.9   

12.7   
6.6   
9.6   
28.8   
9.5   
17.5   
24.9   
19.8   
13.0   
14.1   
12.9   
16.5   
4.8   
9.9   
1.9   
4.9   
4.5   

8.0   
16.2   
11.3   
6.0   
13.3   
2.8   
1.5   
7.2   
9.6   
9.7   
2.3   
5.1   
5.2   
5.2   
15.0   
2.6   
3.4   

70.1   
63.3   
58.6   
44.4   
58.7   
48.5   
35.6   
35.2   
31.6   
33.6   
22.1   
23.7   
18.2   
20.0   
16.1   
20.1   
15.1   

98.5   
87.1   
79.6   
73.7   
69.5   
56.3   
48.2   
39.0   
38.5   
38.2   
31.3   
26.7   
26.4   
25.6   
24.1   
22.4   
21.2   

11.9   
6.6   
14.1   
21.7   
68.2   
13.8   
14.7   
13.1   
13.0   
5.8   
11.3   
14.1   
10.4   
2.7   
2.7   
7.3   
14.5   

0.3   
16.1   
49.7   
7.3   
61.3   
1.9   
10.8   
2.1   
5.7   
10.5   
1.8   
—   
28.5   
6.0   
42.3   
18.0   
3.9   

0.2 
15.1 
48.1 
6.6 
56.4 
1.5 
10.7 
1.7 
5.2 
10.0 
1.6 
— 
27.4 
6.0 
41.3 
17.4 
4.0 

December 31, 2019
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)

$  —  $  —  $  95.5  $ 

10.1  $ 

5.3  $ 

75.0  $ 

105.6  $ 

9.9  $ 

—  $ 

— 

  13.3    25.2   
  32.7    33.3   
2.8    26.3   
6.8    29.8   
8.4   
7.5   
2.3    17.7   
2.0    16.8   
1.7    12.9   
0.6    10.2   
4.8   
8.7   
3.4    11.0   
3.3    13.3   
4.8   
2.9   
8.7   
6.8   
0.6   
6.8   
3.3    15.9   
1.2    14.6   
0.2

0.3

35.7   
8.4   
9.4   
7.7   
22.1   
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

20.0   
6.5   
35.0   
9.7   
7.5   
16.1   
21.6   
16.0   
19.9   
12.9   
12.7   
11.0   
5.0   
4.2   
14.3   
1.7   
4.6   
5.2

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

61.9   
58.0   
37.0   
33.6   
35.8   
38.0   
32.0   
23.1   
29.9   
20.6   
25.3   
20.7   
13.5   
15.5   
13.2   
14.9   
18.1   
12.9

94.2   
80.9   
73.5   
54.0   
45.5   
43.3   
42.1   
33.7   
33.7   
31.1   
30.2   
29.4   
24.2   
23.6   
23.3   
21.6   
21.5   
14.6

23.3   
4.7   
22.4   
13.1   
29.0   
12.0   
12.2   
10.8   
13.7   
11.8   
5.1   
3.2   
14.8   
11.0   
14.6   
2.5   
8.2   
5.3

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

In billions of 
dollars
Cayman 
Islands

United 
Kingdom
Japan
Mexico
Germany
France
Singapore
South Korea
India
Hong Kong
Australia
China
Brazil
Canada
Netherlands
Taiwan
Italy
Switzerland
Ireland

(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.

(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. 

122

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 or resale agreements) 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. 

123

Losses on available-for-sale securities whose fair values 
are less than the amortized cost, where Citi intends to sell the 
security or could more-likely-than-not be required to sell the 
security, are recognized in earnings. Where Citi does not 
intend to sell the security nor could more-likely-than-not be 
required to sell the security, the portion of the loss related to 
credit is recognized as an allowance for credit losses with a 
corresponding provision for credit losses and the remainder of 
the loss is recognized in other comprehensive income. Such 
losses are capped at the difference between the fair value and 
amortized cost of the security.

For equity securities carried at cost or under the 
measurement alternative, decreases in fair value below the 
carrying value are recognized as impairment in the 
Consolidated Statement of Income. Moreover, for certain 
equity method 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 (ACL)
Citi provides reserves for an estimate of current expected 
credit losses in the funded loan portfolio and for unfunded 
lending commitments, standby letters of credit and financial 
guarantees (excluding those that are performance guarantees), 
on the Consolidated Balance Sheet in Allowance for credit 
losses on loans (ACLL) and Other liabilities, respectively. In 
addition, Citi provides allowances for an estimate of current 
expected credit losses for other financial assets measured at 
amortized cost, including held-to-maturity securities, reverse 
repurchase agreements, securities borrowed, deposits with 
banks and other financial receivables carried at amortized cost 
(these allowances, together with the ACLL, are referred to as 
the ACL).

The ACL is composed of quantitative and qualitative 

components. For the quantitative component, Citi uses a 
forward-looking base macroeconomic forecast that is 
complemented by a qualitative management adjustment 
component. As further discussed below, this qualitative 
component reflects (i) economic uncertainty related to an 
alternative downside scenario, (ii) loss adjustments for 
concentration and collateral and (iii) specific adjustments 
based on the associated portfolio for estimating the ACL. 

Quantitative Component
Citi estimates expected credit losses for its quantitative 
component based on (i) its internal system of credit risk 
ratings, (ii) its comprehensive internal history and rating 
agency information regarding default rates and loss data, 
including internal data on the severity of losses in the event of 

default, and (iii) a reasonable and supportable forecast of 
future macroeconomic conditions.

For its consumer and corporate portfolios, Citi’s expected 
credit loss is determined primarily by utilizing models for the 
borrowers’ probability of default (PD), loss given default 
(LGD) and exposure at default (EAD). The loss likelihood and 
severity models used for estimating expected credit losses are 
sensitive to changes in macroeconomic variables that inform 
the forecasts. For corporate portfolios, the loss likelihood and 
loss severity models cover a wide range of geographic, 
industry, product and business segments that contribute to the 
portfolios.

In addition, Citi’s delinquency-managed portfolios 
containing smaller-balance homogeneous loans also primarily 
use PD, LGD and EAD models to determine expected credit 
losses and reserve balances based on leading credit indicators, 
including loan delinquencies and changes in portfolio size, as 
well as other current economic factors and credit trends, 
including housing prices, unemployment and gross domestic 
product (GDP). This methodology is applied separately for 
each product within each geographic region in which these 
portfolios exist, including the U.S., Mexico and Asia. 

This evaluation process is subject to numerous estimates 

and judgments. The frequency of default, risk ratings, loss 
recovery rates, size and diversity of individual large credits 
and 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. 
Changes in these estimates could have a direct impact on 
Citi’s credit costs and the allowance in any period.

Qualitative Management Adjustment Component
The qualitative management adjustment component considers, 
among other things, the uncertainty of forward-looking 
economic scenarios based on the likelihood and severity of a 
downside scenario, certain portfolio characteristics and 
concentrations, collateral coverage, model limitations, 
idiosyncratic events and other relevant criteria under banking 
supervisory guidance for the ACL. In the current 
macroeconomic environment, the qualitative management 
adjustment also reflects the uncertainty around the estimated 
impact of the pandemic on credit loss estimates.

4Q20 Combined Quantitative and Qualitative Components
In the fourth quarter of 2020, Citi (i) released $0.2 billion of 
the ACL for its consumer portfolios and (ii) released $1.3 
billion of the ACL for its corporate portfolios, primarily driven 
by an improvement in the base macroeconomic forecast.
In the fourth quarter, the qualitative management 
adjustment component incorporated an alternative downside 
scenario, reflecting more adverse economic conditions
and, subsequently a slower Real GDP recovery, at a 15% 
likelihood. This qualitative management adjustment 
component contributed to an increase in the ACL of 
approximately $0.7 billion resulting in a total qualitative 
management adjustment of $3.8 billion and an overall ACL 
balance of $27.8 billion at December 31, 2020.

The extent of the pandemic’s ultimate impact on Citi’s 

ACL will depend on, among other things, (i) how consumers 
respond to the government stimulus and assistance programs; 

124

(ii) the impact on unemployment; (iii) the timing and extent of 
the economic recovery; (iv) the severity and duration of the 
resurgence of COVID-19; (v) the rate of distribution and 
administration of vaccines; and (vi) the extent of any market 
volatility. Citi believes its analysis of the ACL reflects the 
forward view of the economic analysis as of December 31, 
2020, based on its November 5, 2020 base macroeconomic 
forecast. 

Macroeconomic Variables
Citi uses a multitude of variables in its base macroeconomic 
forecast as part of its calculation of both the quantitative and 
qualitative (including the downside scenario) components of 
the ACL, including both domestic and international variables 
for its global portfolios and exposures. Citi’s forecasts of the 
U.S. unemployment rate and U.S. Real GDP rate represent the 
key macroeconomic variables that most significantly affect its 
estimate of its consumer and corporate ACLs. 

The tables below show these macroeconomic variables 

used in determining Citi’s 1Q20, 2Q20, 3Q20 and 4Q20 
consumer and corporate ACLs, comparing Citi’s forecasted 
1Q21, 3Q21 and 1Q22 quarterly average U.S. unemployment 
rate and Citi’s forecasted 2020, 2021 and 2022 year-over-year 
U.S. Real GDP growth rate:

Quarterly average

U.S. unemployment

1Q21

3Q21

1Q22

Citi forecast at 1Q20

 6.9 %

 6.6 %

 6.3 %

13-quarter 
average(1)
 6.1 %

Citi forecast at 2Q20

Citi forecast at 3Q20

Citi forecast at 4Q20

 8.1 

 8.2 

 7.3 

 6.3 

 6.8 

 6.5 

 5.8 

 6.3 

 6.2 

 7.2 

 6.6 

 6.1 

(1)  Represents the average unemployment rate for the rolling, forward-

looking 13 quarters in forecast horizon.

U.S. Real GDP

Citi forecast at 1Q20

Citi forecast at 2Q20

Citi forecast at 3Q20

Citi forecast at 4Q20

Year-over-year growth rate(1)

Full year

2020

2021

2022

 (1.3) %

 1.5 %

 1.9 %

 (5.1) 

 (5.1) 

 (4.0) 

 5.5 

 3.3 

 3.7 

 3.3 

 2.8 

 2.7 

(1)  The year-over-year growth rate is the percentage change in the Real 

(inflation adjusted) GDP level.

Under the base macroeconomic forecast as of 4Q20, the 

U.S. unemployment rate and Real GDP growth rate are 
expected to continue to improve, as the U.S. moves past the 
peak of the pandemic-related health and economic crisis.

Consumer 
As discussed above, Citi’s total consumer ACL release 
(including Corporate/Other) of $0.2 billion in the fourth 
quarter of 2020 reduced the ACL balance to $19.6 billion, or 
6.77% of total consumer loans at December 31, 2020, and 
reflected the update of the base macroeconomic forecast for 
the fourth quarter, as well as changes in loan volumes. Citi’s 
consumer ACL is largely driven by the cards businesses, 

where the receivables have longer estimated tenors under the 
CECL lifetime expected credit loss methodology, net of 
recoveries, than under the previous incurred loss model. 

For cards, including Citi’s international businesses, the 
level of reserves relative to EOP loans decreased to 10.98% at 
December 31, 2020, compared to 11.42% at September 30, 
2020, primarily due to the update of the base macroeconomic 
forecast for the fourth quarter of 2020. For the remaining 
consumer exposures, the level of reserves relative to EOP 
loans decreased slightly to 2.0% at December 31, 2020, 
compared to 2.1% at September 30, 2020.

Corporate 
Citi’s corporate ACLL release of $1.6 billion in the fourth 
quarter of 2020 reduced the ACLL reserve balance to 
$5.4 billion, or 1.42% of total funded loans, and reflected the 
update of the macroeconomic forecast scenario for the fourth 
quarter, as well as fewer downgrades in the portfolio.

The ACLUC build of $0.4 billion in the fourth quarter of 

2020 increased the total corporate ACLUC reserve balance 
included in Other liabilities to $2.7 billion at December 31, 
2020. 

ACLL and Non-accrual Ratios
At December 31, 2020, the ratio of the ACLL to total funded 
loans was 3.73% (6.77% for consumer loans and 1.42% for 
corporate loans), compared to 4.00% at September 30, 2020 
(6.96% for consumer loans and 1.82% for corporate loans). 
Citi’s total non-accrual loans were $5.7 billion at 
December 31, 2020, up $394 million from September 30, 
2020. Consumer non-accrual loans increased $451 million to 
$2.1 billion at December 31, 2020, from $1.7 billion at 
September 30, 2020, while corporate non-accrual loans 
decreased $57 million to $3.5 billion at December 31, 2020, 
from $3.6 billion at September 30, 2020. In addition, the ratio 
of corporate non-accrual loans to total corporate loans was 
0.91%, and the ratio of consumer non-accrual loans to total 
consumer loans was 0.74%, at December 31, 2020.

Regulatory Capital Impact
Citi has elected to phase in the CECL impact for regulatory 
capital purposes. The transition provisions were recently 
modified to defer the phase-in. After two years with no impact 
on capital, the CECL transition impact will phase in over a 
three-year transition period with 25% of the impact (net of 
deferred taxes) recognized on the first day of each subsequent 
year, commencing January 1, 2022, and will be fully 
implemented on January 1, 2025. In addition, 25% of the build 
(pretax) made in 2020 and 2021 will be deferred and 
amortized over the same timeframe.

For a further description of the ACL and related accounts, 

see Notes 1 and 15 to the Consolidated Financial Statements.
For a discussion of the adoption of the 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 

125

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 2020, 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, 2020, 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 2019, Citigroup engaged an independent 
valuation specialist in 2020 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.

Under the market approach and in calculation of the 

terminal value under the income approach, the key 
assumptions are the selected price to earnings and price to 
tangible book value multiples. The selection of the multiples 
considers the operating performance and financial condition of 
the reporting units as compared with those of a group of 
selected publicly traded guideline companies. Among other 
factors, the level and expected growth in return on tangible 
equity relative to those of the guideline companies is 
considered. Since the guideline company prices used are on a 
minority interest basis, the selection of the multiples considers 
recent transactions prices, as well as data in comparable 
macroeconomic environments, which reflect control rights and 
privileges, in arriving at a multiple that reflects an appropriate 
control premium. 

For valuation under the income approach, the key 

assumptions used are the cash flows for the forecasted period, 
the terminal growth rate and the discount rate. The cash flows 
for the forecasted period are estimated based on management’s 
most recent projections available as of the testing date, given 

consideration to minimum equity capital requirement. The 
projections incorporate macroeconomic variables developed at 
the same time. The terminal growth rate is selected based on 
management’s long-term expectation for the businesses. The 
discount rate is based on the reporting unit’s estimated cost of 
equity capital computed under the capital asset pricing model 
and reflects the risk and uncertainty in the financial markets in 
the internally generated cash flow projections. 

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, 
2020. 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.

At July 1, 2020, the fair values of Citi’s reporting units as 

a percentage of their carrying values ranged from 
approximately 115% to 136%, resulting in no impairment. 
While the inherent risk related to uncertainty is embedded in 
the key assumptions used in the valuations, the current 
environment continues to evolve due to the challenge and 
uncertainties related to the pandemic. Further deterioration in 
macroeconomic and market conditions, including potential 
adverse effects to economic forecasts due to the severity and 
duration of the pandemic, as well as the responses of 
governments, customers and clients, could negatively 
influence the assumptions used in the valuations, in particular, 
the discount rates, exit multiples and growth rates used in net 
income projections. If the future were to differ from 
management’s best estimate of key assumptions (e.g., net 
interest revenue and loan volume), and associated cash flows 
were to decrease, Citi could potentially experience material 
goodwill impairment charges in the future.

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 
segments’ goodwill balances as of December 31, 2020.

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 that have not yet addressed the federal tax 
law changes choose to 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. Non-U.S. branches also continue to 
be subject to U.S. taxation. The impact of this on Citi’s 
earnings depends on the level of branch pretax income, the 
local branch tax rate and allocations of overall domestic loss 
(ODL) and expenses for U.S. tax purposes to branch earnings. 
Citi expects no residual U.S. tax on such earnings since it 
currently has sufficient branch tax carry-forwards. 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 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, 2020, Citi had net DTAs of $24.8 billion, 
unchanged from September 30, 2020. Citi’s net DTAs 
increased $1.7 billion from $23.1 billion at December 31, 
2019, primarily due to an increase in the ACL and adoption 
impact of the CECL standard, partially offset by gains in 
AOCI. Of Citi’s total net DTAs of $24.8 billion as of 
December 31, 2020, $9.5 billion, primarily related to tax 
carry-forwards, was excluded in calculating Citi’s regulatory 
capital. 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 quarter 
and year ended December 31, 2020, Citi did not have any such 
DTAs. Accordingly, the remaining $15.3 billion of net DTAs 
as of December 31, 2020 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 (VA) at December 31, 
2020 was $5.2 billion, a decrease of $1.3 billion from $6.5 
billion at December 31, 2019, primarily driven by usage of 
carry-forwards in the FTC branch basket. Citi’s VA of $5.2 
billion is composed of (i) $3.4 billion on its FTC carry-
forwards, (ii) $1.0 billion on its U.S. residual DTA related to 

126

 Although realization is not assured, Citi believes that the 

realization of its recognized net DTAs of $24.8 billion at 
December 31, 2020 is more-likely-than-not, based on 
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, 2020 (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 and Note 
9 to the Consolidated Financial Statements.

Tax Cuts and Jobs Act
On December 22, 2017, Tax Reform was signed 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.

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 
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. 

its non-U.S. branches, (iii) $0.6 billion on local non-U.S. 
DTAs and (iv) $0.2 billion on state net operating loss and 
capital loss carry-forwards.

As stated above with regard to the impact of non-U.S. 
branches on Citi’s earnings, the level of branch pretax income, 
the local branch tax rate and the allocations of ODL and 
expenses for U.S. tax purposes to the branch basket are also 
the main factors in determining the branch VA. Citi computed 
these factors for 2020. While the COVID-19 pandemic 
reduced branch earnings, the allocated ODL did not decline 
since a large portion of the pandemic losses will not be 
recognizable for U.S. taxable income until a future period. In 
addition, lower than forecasted U.S. interest rates resulted in a 
lower allocation of interest expense to non-U.S. branches. The 
combination of these factors drove the VA release of $0.5 
billion in Citi’s full-year effective tax rate. Citi also released 
$0.1 billion of branch basket VA in the fourth quarter, with 
respect to future years based upon Citi’s operating plan and 
estimates of future branch basket factors, as discussed above. 
Citi’s VA of $1.0 billion against FTC carry-forwards in 

its general basket declined $0.1 billion in 2020, primarily due 
to expired FTCs. In the general FTC basket, foreign source 
income, an important driver in the utilization of FTC carry-
forwards for the current year and future years in the carry-
forward period, has been reduced due to the compression in 
interest rate spreads. Overall U.S. taxable income, which 
impacts ODL usage and, correspondingly, the utilization of 
FTC carry-forwards is also lower because of the impacts of the 
pandemic. Accordingly, management has taken actions to 
increase future foreign source income and U.S. taxable 
income. These planning actions include geographic asset 
movements, deferral of future FTC recognition and 
capitalization of expenses for tax purposes, resulting in no tax 
provision change to Citi’s general basket VA in 2020. In light 
of the pandemic, Citi will continue to monitor its forecasts and 
mix of earnings, which could affect Citi’s VA against FTC 
carry-forwards. Citi continues to look for additional actions 
that are prudent and feasible, taking into account client, 
regulatory and operational considerations. See Note 9 to the 
Consolidated Financial Statements. 

Recognized FTCs comprised approximately $4.4 billion 

of Citi’s DTAs as of December 31, 2020, compared to 
approximately $6.3 billion as of December 31, 2019. The 
decrease was primarily due to current-year usage. The FTC 
carry-forward period represents the most time-sensitive 
component of Citi’s DTAs.

Citi had an overall domestic loss (ODL) of approximately 
$26 billion at December 31, 2020, 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.)

The majority of Citi’s U.S. federal net operating loss 
carry-forward and all of its New York State and City net 
operating loss carry-forwards are subject to a carry-forward 
period of 20 years. This provides enough time to fully utilize 
the net DTAs pertaining to these 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.

127

The table below details the fourth quarter of 2018 changes to Citi’s provisional impact from Tax Reform:

Provisional Impact of Tax Reform

In billions of dollars

Quasi-territorial tax system

Valuation allowance

Deemed repatriation

Total of provisional items

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 
Diluted earnings per share:
  Income from continuing operations
  Net income 

2018
as 
reported(1)
$  18,045 

2017
as reported
$  (6,798)  $ 

2017 one-time 
impact of 
Tax Reform

2017 
adjusted 
results(2)
$  15,796 

2018 increase (decrease) 
vs. 2017 ex-Tax Reform

$ Change

% Change

$ 

2,249 

 14 %

5.37 
5.33 

1.32 
1.35 

 25 
 25 

(22,594) 

(8.31) 
(8.31) 

6.69 
6.68 

(2.94) 
(2.98) 

  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.

128

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 
2020. Based on that evaluation, the CEO and CFO have 
concluded that at that date Citigroup’s disclosure controls and 
procedures were effective.

129

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.

Citi’s management assessed the effectiveness of 
Citigroup’s internal control over financial reporting as of 
December 31, 2020 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, 2020, 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, 2020 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, 2020 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, 2020.

130

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. 

131

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 
sheets of Citigroup Inc. and subsidiaries (the Company) as of 
December 31, 2020 and 2019, 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, 2020, 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, 2020, 
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, 2020 
and 2019, and the results of its operations and its cash flows 
for each of the years in the three-year period ended December 
31, 2020, 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, 2020 based on 
criteria established in Internal Control – Integrated Framework 
(2013) issued by the Committee of Sponsoring Organizations 
of the Treadway Commission.

Change in Accounting Principle
As discussed in Note 1 to the consolidated financial 
statements, the Company has changed its method of 
accounting for the recognition and measurement of credit 
losses as of January 1, 2020 due to the adoption of ASC Topic 
326, Financial Instruments - Credit Losses.

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.

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.

132

 
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 Level 3 assets and 
liabilities measured on a recurring basis
As described in Notes 1, 24 and 25 to the consolidated 
financial statements, the Company’s assets and liabilities 
recorded at fair value on a recurring basis were $918.1 
billion and $308.8. billion, respectively at December 31, 
2020. The Company estimated the fair value of Level 3 
assets and liabilities measured on a recurring basis ($16.1 
billion and $36.0 billion, respectively at December 31, 
2020) utilizing various valuation techniques with one or 
more significant inputs or significant value drivers being 
unobservable including, but not limited to, complex 
internal valuation models, alternative pricing procedures 
or comparables analysis and discounted cash flows.

We identified the assessment of the measurement of 
fair value for Level 3 assets and liabilities recorded at fair 
value on a recurring basis as a critical audit matter. A high 
degree of audit effort, including specialized skills and 
knowledge, and subjective and complex auditor judgment 
was involved in the assessment of the Level 3 fair values 
due to measurement uncertainty. Specifically, the 
assessment encompassed the evaluation of the fair value 
methodology, including methods, models and significant 
assumptions and inputs used to estimate fair value. 
Significant assumptions and inputs include interest rate, 
price, yield, credit spread, volatilities, correlations and 
forward prices. The assessment also included an 
evaluation of the conceptual soundness and performance 
of the valuation models.

The following are the primary procedures we 
performed to address this critical audit matter. We 
involved valuation professionals with specialized skills 
and knowledge who assisted in evaluating the design and 
testing the operating effectiveness of certain internal 
controls related to the Company’s Level 3 fair value 
measurements including controls over:

•

•
•

valuation methodologies, including significant inputs 
and assumptions
independent price verification
evaluating that significant model assumptions and 
inputs reflected those which a market participant 
would use to determine an exit price in the current 
market environment 

133

•

•

the valuation models used were mathematically 
accurate and appropriate to value the financial 
instruments
relevant information used within the Company’s 
models that was reasonably available was considered 
in the fair value determination.

We evaluated the Company’s methodology for 
compliance with U.S. generally accepted accounting 
principles. We involved valuation professionals with 
specialized skills and knowledge who assisted in 
developing an independent fair value estimate for a 
selection of certain Level 3 assets and liabilities recorded 
at fair value on a recurring basis based on independently 
developed valuation models and assumptions, as 
applicable, using market data sources we determined to be 
relevant and reliable and compared our independent 
expectation to the Company’s fair value measurements.

Assessment of the allowance for credit losses collectively 
evaluated for impairment
As discussed in Note 1 to the consolidated financial 
statements, the Company adopted ASU No. 2016-13, 
Financial Instruments – Credit Losses (ASC 326) as of 
January 1, 2020. As discussed in Notes 1 and 15 to the 
consolidated financial statements, the Company’s 
allowance for credit losses related to loans and unfunded 
lending commitments collectively evaluated for 
impairment (the collective ACLL) was $27.6 billion as of 
December 31, 2020. The expected credit losses for the 
quantitative component of the collective ACLL is the 
product of multiplying the probability of default (PD), 
loss given default (LGD), and exposure at default (EAD) 
for consumer and corporate loans. For consumer credit 
cards, the Company uses the payment rate approach over 
the life of the loan, which leverages payment rate curves, 
to determine the payments that should be applied to 
liquidate the end-of-period balance in the estimation of 
EAD. For unconditionally cancelable accounts, reserves 
are based on the expected life of the balance as of the 
evaluation date and do not include any undrawn 
commitments that are unconditionally cancelable. The 
Company’s models utilize a single forward-looking 
macroeconomic forecast and macroeconomic assumptions 
over reasonable and supportable forecast periods. 
Reasonable and supportable forecast periods vary by 
product. For consumer loan models, the Company uses a 
13-quarter reasonable and supportable period and reverts 
to historical loss experience thereafter. For corporate loan 
models, the Company uses a nine-quarter reasonable and 
supportable period followed by a three-quarter transition 
to historical loss experience. Additionally, for consumer 
loans, these models consider leading credit indicators 
including loan delinquencies, as well as economic factors. 
For corporate loans, these models consider the credit 
quality as measured by risk ratings and economic factors. 
The qualitative component considers idiosyncratic events 
and the uncertainty of forward-looking economic 
scenarios.

We identified the assessment of the collective ACLL 

as a critical audit matter. The assessment involved 
significant measurement uncertainty requiring complex 
auditor judgment, and specialized skills and knowledge as 
well as experience in the industry. This assessment 
encompassed the evaluation of the various components of 
the collective ACLL methodology, including the methods 
and models used to estimate the PD, LGD, and EAD and 
certain key assumptions and inputs for the Company’s 
quantitative and qualitative components. Key assumptions 
and inputs for consumer loans included loan 
delinquencies, certain credit indicators, reasonable and 
supportable forecast periods, expected life as well as 
economic factors, including unemployment rates, gross 
domestic product (GDP), and housing prices which are 
considered in the model. For corporate loans, key 
assumptions and inputs included risk ratings, reasonable 
and supportable forecasts, credit conversion factor for 
unfunded lending commitments, and economic factors, 
including GDP and unemployment rates considered in the 
model. Key assumptions and inputs for the qualitative 
component included the likelihood and severity of a 
downside scenario and consideration of uncertainties due 
to idiosyncratic events as a result of the COVID-19 
pandemic. The assessment also included an evaluation of 
the conceptual soundness and performance of the PD, 
LGD, and EAD models. In addition, auditor judgment 
was required to evaluate the sufficiency of audit evidence 
obtained.

The following are the primary procedures we 
performed to address this critical audit matter. We 
evaluated the design and tested the operating effectiveness 
of certain internal controls related to the Company’s 
measurement of the collective ACLL estimate, including 
controls over the:

•
•

•

approval of the collective ACLL methodologies 
determination of the key assumptions and inputs used 
to estimate the quantitative and qualitative 
components of the collective ACLL
performance monitoring of the PD, LGD, and EAD 
models.

We evaluated the Company’s process to develop the 

collective ACLL 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. In addition, we involved credit 
risk professionals with specialized skills and knowledge, 
who assisted in:

•

•

•

reviewing the Company’s collective ACLL 
methodologies and key assumptions for compliance 
with U.S. generally accepted accounting principles
evaluating judgments made by the Company relative 
to the development and performance monitoring 
testing of the PD, LGD, and EAD models by 
comparing them to relevant Company-specific 
metrics
assessing the conceptual soundness and performance 
testing of the PD, LGD, and EAD models by 

134

•

•

•

•

inspecting the model documentation to determine 
whether the models are suitable for their intended use
assessing the economic forecast scenarios through 
comparison to publicly available forecasts
evaluating the methodology used to develop certain 
economic forecast scenarios by comparing it to 
relevant industry practices
testing corporate loan risk ratings for a selection of 
borrowers by evaluating the financial performance of 
the borrower, sources of repayment, and any relevant 
guarantees or underlying collateral
evaluating the methodology used in determining the 
qualitative components and the effect of that 
component on the collective ACLL compared with 
relevant credit risk factors and consistency with 
credit trends.

We also assessed the sufficiency of the audit 
evidence obtained related to the collective ACLL by 
evaluating the:

•
•

•

cumulative results of the audit procedures
qualitative aspects of the Company’s accounting 
practices
potential bias in the accounting estimates.

Assessment of the realizability of deferred tax assets, 
specifically as it relates to general basket foreign tax 
credits
As discussed in Note 9 to the consolidated financial 
statements, the Company’s net deferred tax assets (DTA) 
were $31.0 billion as of December 31, 2020. This balance 
is net of a valuation allowance of $5.2 billion recorded by 
the Company. The estimation of the DTA for general 
basket foreign tax credits (FTCs) and related valuation 
allowance was $5.3 billion and $1.0 billion respectively. 
The Company evaluated the realization of the DTA for 
general basket FTCs to determine whether there was more 
than a 50% likelihood that the DTA for general basket 
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. In particular, the 
COVID-19 pandemic has negatively affected the 
economy and business activities in countries where the 
Company operates, which has impacted the Company’s 
future forecasts of taxable income as of December 31, 
2020.

We identified the assessment of the realizability of 

the DTA for general basket FTCs as a critical audit 
matter. Due to the significant measurement uncertainty 
associated with the realizability of the DTA for general 
basket FTCs, there was a high degree of subjectivity and 
judgment in evaluating global tax regulations and future 
taxable income. This assessment encompassed the 
evaluation of the Company’s estimations that are 
subjective and complex due to its global structure, 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 general basket FTCs before expiration of 
foreign tax credits.

The following are the primary procedures we 
performed to address this critical audit matter. We 
evaluated the design and tested the operating effectiveness 
of certain controls related to the Company’s DTA 
realizability process, including controls over the:

•

•

realizability of the Company’s deferred tax assets for 
general basket FTCs
appropriateness of 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 policy and methodology used by 
management in the valuation allowance determination. 
We involved income tax professionals with specialized 
skills and knowledge, who assisted in assessing:

•

•
•

certain 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
the prudence and feasibility of certain tax planning 
strategies.

We performed sensitivity analyses over the 
Company’s expectations of future taxable income and 
timing of tax credit expirations.

Evaluation of goodwill in the North American and Asia 
Global Consumer Banking reporting units
As discussed in Notes 1 and 16 to the consolidated 
financial statements, the goodwill balance as of December 
31, 2020 was $22.2 billion, of which $12.1 billion related 
to reporting units within the Global Consumer Banking 
segment and $10.1 billion related to reporting units within 
the Institutional Clients Group segment. The Company 
performs goodwill impairment testing on an annual basis 
and whenever events or changes in circumstances indicate 
that the carrying value of a reporting unit likely exceeds 
its fair value. This involves estimating the fair value of the 
reporting units using both discounted cash flow analyses 
and a market multiples approach. The COVID-19 
pandemic has negatively affected the economy and 
business activities in countries where the Company 
operates, which impacted the Company’s future forecasts 
used in the discounted cash flow analyses.

We identified the evaluation of the goodwill 

impairment analysis for the North America Global 
Consumer Banking and Asia Global Consumer Banking 
reporting units, two of the three reporting units within the 
Global Consumer Banking segment, as a critical audit 
matter. The estimated fair value of the North America and 
Asia Global Consumer Banking reporting units 
marginally exceeded their carrying values, indicating a 
higher risk due to measurement uncertainty that the 
goodwill may be impaired and, therefore, involved a high 
degree of subjective auditor judgment. Specifically, the 
assessment encompassed the evaluation of the key 
assumptions used in estimating the fair value of the North 
America and Asia Global Consumer Banking reporting 
units, which include the long-term growth rate, discount 
rate, exit multiple assumptions, certain forecasted 
macroeconomic assumptions used to inform the 
forecasted income by reporting unit, and certain 
assumptions used to forecast income by reporting unit 
including the forecast period, net interest revenue, and 
loan volume used in the discounted cash flow analyses.
The following are the primary procedures we 
performed to address this critical audit matter. We 
evaluated the design and tested the operating effectiveness 
of certain internal controls related to the Company’s 
determination of the estimated fair value of the North 
America Global Consumer Banking and Asia Global 
Consumer Banking reporting units, including controls 
related to management’s process for assessing the 
appropriateness of:

•

•

•

certain assumptions including the long-term growth 
rate, discount rate and exit multiple used in the 
discounted cash flow analyses
certain forecasted macroeconomic assumptions used 
to inform the forecasted income by reporting unit
certain assumptions used to forecast income by 
reporting unit including the forecast period, net 
interest revenue and loan volume.

135

We compared the Company’s historical revenue 
forecasts to actual results to assess the Company’s ability 
to accurately forecast. We evaluated the reasonableness of 
the Company’s forecasts by comparing to analyst reports.
In addition, we involved a valuation professional with 
specialized skills and knowledge, who assisted in:

•

•

•

•

•

•

developing an independent range of long-term growth 
rate assumptions by reviewing publicly available data 
for the United States and Asian markets and 
comparable industries and comparing it to the 
Company’s assumption
evaluating the discount rate by assessing the 
methodology used by management and developing an 
independent assumption for the discount rate
developing an independent range of the exit 
assumptions using publicly available data for 
comparable entities and comparing it to the 
Company’s assumption
developing an estimate of the fair value of North 
America and Asia Global Consumer Banking 
reporting units using the income approach and 
comparing the results to the Company’s fair value 
estimate
developing an independent range of control premium 
assumptions by comparing data from the 2008-2009 
financial crisis to the Company’s assumption
assessing the market capitalization reconciliation and 
the reasonableness of the implied control premium.

/s/ KPMG LLP
We have served as the Company’s auditor since 1969.

New York, New York 
February 26, 2021

136

FINANCIAL STATEMENTS AND NOTES TABLE OF CONTENTS

CONSOLIDATED FINANCIAL STATEMENTS

Consolidated Statement of Income—

For the Years Ended December 31, 2020, 2019 and 2018

138

Consolidated Statement of Comprehensive Income—

For the Years Ended December 31, 2020, 2019 and 2018

Consolidated Balance Sheet—December 31, 2020 and 2019
Consolidated Statement of Changes in Stockholders’ Equity

139

140

—For the Years Ended December 31, 2020, 2019 and 2018

142

Consolidated Statement of Cash Flows—

For the Years Ended December 31, 2020, 2019 and 2018

144

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

146

161

162

163

164

167

168

172

183

187

188

191

192

204

217

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—Subsequent Event

Note 30—Selected Quarterly Financial Data (Unaudited)

220

222

224

225

228

230

242

258

259

279

283

291

300

309

310

137

 
 
CONSOLIDATED FINANCIAL STATEMENTS
CONSOLIDATED STATEMENT OF INCOME                                                                   

 Citigroup Inc. and Subsidiaries

In millions of dollars, except per share amounts

2020

2019

2018

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

Impairment losses on investments:

Impairment losses on investments and other assets
Provision for credit losses on AFS debt securities(1)

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 credit losses on loans

Provision for credit losses on held-to-maturity (HTM) debt securities

Provision for credit losses on other assets

Policyholder benefits and claims

Provision for credit losses on 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 from continuing operations

Discontinued operations

Loss from discontinued operations

Provision (benefit) for income taxes

Loss from discontinued operations, net of taxes

Net income before attribution of noncontrolling interests

Noncontrolling interests

Citigroup’s net income
Basic earnings per share(2)
Income from continuing operations

Loss from discontinued operations, net of taxes

Net income 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

58,089  $ 

14,541   

43,548  $ 

11,385  $ 

13,885   

3,472   

1,756   

(165)   

(3)   

(168)  $ 

420  $ 

30,750  $ 

74,298  $ 

76,510  $ 

29,163   

47,347  $ 

11,746  $ 

8,892   

3,411   

1,474   

(32)   

—   

(32)  $ 

1,448  $ 

26,939  $ 

74,286  $ 

15,922  $ 

8,218  $ 

7   

7   

113   

1,446   

17,495  $ 

—   

—   

73   

92   

8,383  $ 

22,214  $ 

21,433  $ 

2,333   

7,383   

1,217   

10,024   

43,171  $ 

13,632  $ 

2,525   

11,107  $ 

(20)  $ 

—   

(20)  $ 

11,087  $ 

40   

11,047  $ 

4.75  $ 

(0.01)   

4.74  $ 

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  $ 

70,828 

24,266 

46,562 

11,857 

8,905 

3,580 

421 

(132) 

— 

(132) 

1,661 

26,292 

72,854 

7,354 

— 

— 

101 

113 

7,568 

21,154 

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)

2,085.8   

2,249.2   

2,493.3 

138

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED STATEMENT OF INCOME 
(Continued) 

In millions of dollars, except per share amounts
Diluted earnings per share(2)
Income from continuing operations

Income (loss) from discontinued operations, net of taxes

Net income 

Adjusted weighted average common shares outstanding 
(in millions)

Citigroup Inc. and Subsidiaries

Years ended December 31,

2020

2019

2018

$ 

$ 

4.73  $ 

(0.01)   

4.72  $ 

8.04  $ 

—   

8.04  $ 

6.69 

— 

6.68 

2,099.0   

2,265.3   

2,494.8 

In accordance with ASC 326.

(1)
(2)  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

Add: Citigroup’s other comprehensive income (loss)
Net change in unrealized gains and losses on debt securities, net of taxes(1)
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(2)
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)

Citigroup’s total comprehensive income

Add: Other comprehensive income (loss) attributable to noncontrolling interests

Add: Net income attributable to noncontrolling interests

Total comprehensive income

(1)  See Note 1 to the Consolidated Financial Statements.
(2) See Note 8 to the Consolidated Financial Statements.

Years ended December 31,

2020

2019

2018

11,047  $ 

19,401  $ 

18,045 

3,585  $ 

(475)   

1,470   

(55)   

(250)   

(15)   

4,260  $ 

15,307  $ 

26  $ 

40   

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 

15,373  $ 

20,319  $ 

15,538 

$ 

$ 

$ 

$ 

$ 

$ 

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

139

 
 
 
 
 
 
 
 
 
 
 
CONSOLIDATED BALANCE SHEET

In millions of dollars
Assets
Cash and due from banks (including segregated cash and other deposits)
Deposits with banks, net of allowance

Securities borrowed and purchased under agreements to resell (including $185,204 and $153,193 as of 

December 31, 2020 and 2019, respectively, at fair value), net of allowance

Brokerage receivables, net of allowance

Trading account assets (including $168,967 and $120,236 pledged to creditors at December 31, 2020 and 

2019, respectively)

Investments:

  Available-for-sale debt securities (including $5,921 and $8,721 pledged to creditors as of December 31, 

2020 and 2019, respectively), net of allowance
Held-to-maturity debt securities (including $547 and $1,923 pledged to creditors as of December 31, 

2020 and 2019, respectively), net of allowance

Equity securities (including $1,066 and $1,162 as of December 31, 2020 and 2019, respectively, at fair 

value)

Total investments
Loans:

Consumer (including $14 and $18 as of December 31, 2020 and 2019, respectively, at fair value)

Corporate (including $6,840 and $4,067 as of December 31, 2020 and 2019, respectively, at fair value)

Loans, net of unearned income

Allowance for credit losses on loans (ACLL)

Total loans, net
Goodwill

Citigroup Inc. and Subsidiaries

December 31,

2020

2019

26,349  $ 
283,266   

294,712   
44,806   

23,967 
169,952 

251,322 
39,857 

375,079   

276,140 

335,084   

280,265 

104,943   

80,775 

7,332   
447,359  $ 

288,839   

387,044   

675,883  $ 

(24,956)   
650,927  $ 
22,162   

7,523 
368,563 

309,548 

389,935 

699,483 

(12,783) 
686,700 
22,126 

$ 

$ 

$ 

$ 

Intangible assets (including MSRs of $336 and $495 as of December 31, 2020 and 2019, 
  respectively, at fair value)

Other assets (including $14,613 and $12,830 as of December 31, 2020 and 2019, respectively, 
  at fair value), net of allowance

Total assets

4,747   

4,822 

110,683   

107,709 

$ 

2,260,090  $ 

1,951,158 

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 credit losses on loans (ACLL)

Total loans, net
Other assets
Total assets of consolidated VIEs to be used to settle obligations of consolidated VIEs

Statement continues on the next page.

December 31,

2020

2019

$ 

$ 

$ 

$ 

281  $ 
8,104   
837   

37,561   
17,027   
54,588  $ 
(3,794)   
50,794  $ 
43   
60,059  $ 

108 
6,719 
1,295 

46,977 
16,175 
63,152 
(1,841) 
61,311 
73 
69,506 

140

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 $879 and $1,624 as of December 31, 2020 and 2019, 

respectively, at fair value)

Non-interest-bearing deposits in offices outside the U.S.

Interest-bearing deposits in offices outside the U.S. (including $1,079 and $695 as of December 31, 2020 

and 2019, respectively, at fair value)

Total deposits

Securities loaned and sold under agreements to repurchase (including $60,206 and $40,651 as of 

December 31, 2020 and 2019, respectively, at fair value)

Brokerage payables
Trading account liabilities

Short-term borrowings (including $4,683 and $4,946 as of December 31, 2020 and 2019, respectively, 
  at fair value)

Long-term debt (including $67,063 and $55,783 as of December 31, 2020 and 2019, respectively, 
  at fair value)

Other liabilities (including $6,835 and $6,343 as of December 31, 2020 and 2019, respectively, 
  at fair value), including allowance
Total liabilities
Stockholders’ equity

Preferred stock ($1.00 par value; authorized shares: 30 million), issued shares: 779,200 as of December 

31, 2020 and 719,200 as of December 31, 2019, at aggregate liquidation value

Common stock ($0.01 par value; authorized shares: 6 billion), issued shares: 3,099,763,661 as of 

December 31, 2020 and 3,099,602,856 as of December 31, 2019

Additional paid-in capital
Retained earnings

Treasury stock, at cost: 1,017,674,452 shares as of December 31, 2020 and 985,479,501 shares as of 
    December 31, 2019
Accumulated other comprehensive income (loss) (AOCI)
Total Citigroup stockholders’ equity
Noncontrolling interests
Total equity
Total liabilities and equity

$ 

$ 

$ 

$ 
$ 

       Citigroup Inc. and Subsidiaries

December 31,

2020

2019

$ 

126,942  $ 

98,811 

503,213   
100,543   

401,418 
85,692 

549,973   
1,280,671  $ 

484,669 
1,070,590 

$ 

199,525   
50,484   
168,027   

166,339 
48,601 
119,894 

29,514   

45,049 

271,686   

248,760 

59,983   
2,059,890  $ 

57,979 
1,757,212 

19,480  $ 

17,980 

31   
107,846   
168,272   

(64,129)   
(32,058)   
199,442  $ 
758   
200,200  $ 
2,260,090  $ 

31 
107,840 
165,369 

(61,660) 
(36,318) 
193,242 
704 
193,946 
1,951,158 

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,

2020

2019

$ 

$ 

9,278  $ 
20,405   

463   

10,031 
25,582 

917 

30,146  $ 

36,530 

141

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 year
Common stock and additional paid-in capital
Balance, beginning of year
Employee benefit plans
Preferred stock issuance costs
Other
Balance, end of year
Retained earnings
Balance, beginning of year
Adjustments to opening balance, net of taxes(1)
  Financial instruments—credit losses (CECL adoption)
  Variable post-charge-off  third-party collection costs
  Lease accounting, intra-entity transfers of assets
Adjusted balance, beginning of year
Citigroup’s net income
Common dividends(2)
Preferred dividends
Other
Balance, end of year
Treasury stock, at cost
Balance, beginning of year
Employee benefit plans(3)
Treasury stock acquired(4)
Balance, end of year
Citigroup’s accumulated other comprehensive income (loss)
Balance, beginning of year
Adjustment to opening balance, net of taxes(1)
Adjusted balance, beginning of year
Citigroup’s total other comprehensive income (loss)(3)
Balance, end of year
Total Citigroup common stockholders’ equity
Total Citigroup stockholders’ equity
Noncontrolling interests
Balance, beginning of year

Years ended December 31,

Amounts

2020

2019

2018

2020

Shares

2019

2018

$ 

$ 

17,980  $ 
3,000   
(1,500)   
19,480  $ 

18,460  $ 
1,500   
(1,980)   
17,980  $ 

19,253   
—   
(793)   
18,460   

719   
120   
(60)   
779   

738   
60   
(79)   
719   

770 
— 
(32) 
738 

$  107,871  $  107,953  $  108,039    3,099,603    3,099,567    3,099,523 
(94)   
44 
—   
— 
— 
8   
$  107,877  $  107,871  $  107,953    3,099,764    3,099,603    3,099,567 

(112)   
(4)   
34   

161   
—   
—   

36   
—   
—   

5   
(4)   
5   

$  165,369  $  151,347  $  138,425 

—   
—   
151   

(3,076)   
330   
—   

— 
— 
(84) 
$  162,623  $  151,498  $  138,341 
18,045 
(3,865) 
(1,174) 
— 
$  168,272  $  165,369  $  151,347 

11,047   
(4,299)   
(1,095)   
(4)   

19,401   
(4,403)   
(1,109)   
(18)   

(61,660)  $ 
456   
(2,925)   
(64,129)  $ 

(44,370)  $ 
585   
(17,875)   
(61,660)  $ 

(985,480)   
(30,309)   
8,546   
484   
(14,545)   
(40,740)   
(44,370)   (1,017,674)   

(731,100)   
9,872   
(264,252)   
(985,480)   

(529,615) 
10,557 
(212,042) 
(731,100) 

(36,318)  $ 
—   
(36,318)  $ 
4,260   
(32,058)  $ 

(37,170)  $ 
—   
(37,170)  $ 
852   
(36,318)  $ 

(34,668) 
(3) 
(34,671) 
(2,499) 
(37,170) 

$ 
$  179,962  $  175,262  $  177,760    2,082,090    2,114,123    2,368,467 
$  199,442  $  193,242  $  196,220 

$ 

$ 

$ 

$ 

$ 

704  $ 

854  $ 

932 

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

—   

(4)   
40   
(2)   

26   
(6)   

—   

(169)   
66   
(40)   

—   
(7)   

— 

(50) 
35 
(38) 

(43) 
18 

Net change in noncontrolling interests
Balance, end of year
Total equity

54  $ 
758  $ 

(78) 
$ 
$ 
854 
$  200,200  $  193,946  $  197,074 

(150)  $ 
704  $ 

142

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(1) See Note 1 to the Consolidated Financial Statements for additional details.
(2)  Common dividends declared were $0.51 per share in the first, second, third and fourth quarters of 2020; $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; and $0.32 in the first and second quarters of 2018 and $0.45 per share in the third and fourth quarters 
of 2018.
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.

(3) 

(4)  Primarily consists of open market purchases under Citi’s Board of Directors-approved common stock repurchase programs.

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

143

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 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

Provision for credit losses on loans and unfunded lending commitments

Realized gains from sales of investments

Impairment losses on investments and other assets

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

144

Years ended December 31,

2020

2019

2018

$ 

$ 

$ 

11,087  $ 

19,467  $ 

18,080 

40   

66   

35 

11,047  $ 

19,401  $ 

18,045 

(20)   

(4)   

(8) 

11,067  $ 

19,405  $ 

18,053 

—   

3,937   

(2,333)   

17,368   

(1,756)   

165   

—   

3,905   

(610)   

8,310   

(1,474)   

32   

(98,997)   

(20,124)   

48,133   

(24,411)   

(3,066)   

(20,377)   

1,202   

(1,012)   

558   

4,113   

(31,688)  $ 
(20,621)  $ 

(909)   

4,724   

1,737   

16,955   

(32,242)  $ 
(12,837)  $ 

(247) 

3,754 

(51) 

7,467 

(421) 

132 

(3,469) 

19,135 

6,163 

770 

(5,791) 

(984) 

(7,559) 

18,899 
36,952 

(43,390)  $ 

19,362  $ 

(38,206) 

14,249   

(22,466)   

(29,002) 

1,495   

2,878   

4,549 

(334,900)   

(274,491)   

(152,487) 

146,285   

137,173   

124,229   

119,051   

—   

—   

61,491 

83,604 

314 

(3,446)   

(5,336)   

(3,774) 

50   

259   

212 

116   
(95,312)  $ 

196   
(23,374)  $ 

181 
(73,118) 

(5,352)  $ 

(5,447)  $ 

(5,020) 

$ 
$ 

$ 

$ 

$ 

2,995   

(1,500)   

(2,925)   

(411)   

33,186   

76,458   

1,496   

(1,980)   

— 

(793) 

(17,571)   

(14,433) 

(364)   

(482) 

(11,429)   

59,134   

21,491 

60,655 

(58,132) 

53,348 
(12,106) 

(63,402)   

(51,029)   

210,081   
(15,535)   

57,420   
12,703   

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 due from banks

Change in cash, due from banks and deposits with banks

Cash, due from banks and deposits with banks at beginning of year

Cash, due from banks and deposits with banks at end of year

Cash and due from banks (including segregated cash and other deposits)

Deposits with banks, net of allowance

Cash, due from banks and deposits with banks at end of year

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(2)
Transfers to loans HFS (Other assets) from loans

Citigroup Inc. and Subsidiaries

Years ended December 31,

2020

2019

2018

233,595  $ 

42,933  $ 

44,528 

(1,966)  $ 

115,696  $ 

(908)  $ 

5,814  $ 

(773) 

7,589 

193,919   

188,105   

180,516 

309,615  $ 

193,919  $ 

188,105 

26,349  $ 

23,967  $ 

23,645 

283,266   

169,952   

164,460 

309,615  $ 

193,919  $ 

188,105 

4,797  $ 

4,888  $ 

13,298   

28,682   

4,313 

22,963 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

2,614  $ 

5,500  $ 

4,200 

(1) See Note 2 to the Consolidated Financial Statements for further information on significant disposals.
(2)  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, 2020 
and 2019.

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

145

 
 
 
 
 
 
 
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 disclosures to conform to the 
current period’s presentation.

For information on Citi’s recent revisions and 

reclassifications related to the accounting principle change for 
variable post-charge-off third-party collection costs, see below 
and Notes 15 and 30 to the Consolidated Financial Statements.

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 

146

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 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 include securities held in HTM or AFS, and equity 
securities accounted for under the Measurement Alternative or 
equity method. These securities are subject to evaluation for 
impairment as described in Note 15 to the Consolidated 
Financial Statements for HTM securities and in Note 13 for 
AFS, Measurement Alternative and equity method 
investments. 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 

147

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 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.

Where the conditions of ASC 210-20-45-11, Balance 

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 
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 

148

classified as non-accrual within 60 days of notification that the 
borrower has filed for bankruptcy, other than Federal Housing 
Administration (FHA)-insured loans. 

Loans that have been modified to grant a concession to 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 (other than for loan modifications 
made through the CARES Act relief provisions or banking 
agency guidance for pandemic-related issues) 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.

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 uncollectible. 
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.

Allowances for Credit Losses (ACL)
Commencing January 1, 2020, Citi adopted Accounting 
Standards Update (ASC) 326, Financial Instruments—Credit 
Losses, using the methodologies described below. For 
information about Citi’s accounting for loan losses prior to 
January 1, 2020, see “Superseded Accounting Principles” 
below.

The current expected credit losses (CECL) methodology 
is based on relevant information about past events, including 
historical experience, current conditions and reasonable and 
supportable (R&S) forecasts that affect the collectability of the 
reported financial asset balances. If the asset’s life extends 

149

beyond the R&S forecast period, then historical experience is 
considered over the remaining life of the assets in the ACL. 
The resulting ACL is adjusted in each subsequent reporting 
period through Provisions for credit losses in the Consolidated 
Statement of Income to reflect changes in history, current 
conditions and forecasts as well as changes in asset positions 
and portfolios. ASC 326 defines the ACL as a valuation 
account that is deducted from the amortized cost of a financial 
asset to present the net amount that management expects to 
collect on the financial asset over its expected life. All 
financial assets carried at amortized cost are in the scope of 
ASC 326, while assets measured at fair value are excluded. 
See Note 13 to the Consolidated Financial Statements for a 
discussion of impairment on available-for-sale (AFS) 
securities.

Increases and decreases to the allowances are recorded in 
Provisions for credit losses. The CECL methodology utilizes a 
lifetime expected credit loss (ECL) measurement objective for 
the recognition of credit losses for held-for-investment (HFI) 
loans, held-to-maturity (HTM) debt securities, receivables and 
other financial assets measured at amortized cost at the time 
the financial asset is originated or acquired. Within the life of 
a loan or other financial asset, the methodology generally 
results in the earlier recognition of the provision for credit 
losses and the related ACL than prior U.S. GAAP.

Estimation of ECLs requires Citi to make assumptions 
regarding the likelihood and severity of credit loss events and 
their impact on expected cash flows, which drive the 
probability of default (PD), loss given default (LGD) and 
exposure at default (EAD) models and, where Citi discounts 
the ECL, using discounting techniques for certain products. 
Where the asset’s life extends beyond the R&S forecast 
period, Citi considers historical experience over the remaining 
life of the assets in estimating the ACL. 

Citi uses a multitude of variables in its macroeconomic 
forecast as part of its calculation of both the qualitative and 
quantitative components of the ACL, including both domestic 
and international variables for its global portfolios and 
exposures. Citi’s forecasts of the U.S. unemployment rate and 
U.S. Real GDP growth rate represent the key macroeconomic 
variables that most significantly affect its estimate of its 
consumer and corporate ACLs. Under the quantitative base 
scenario, Citi’s 4Q’20 forecasts are for U.S. unemployment to 
continue to improve as the U.S. moves past the peak of the 
health and economic crisis. The downside scenario 
incorporates more adverse economic conditions and 
subsequently higher unemployment rates and slower GDP 
recovery.

The following are the main factors and interpretations that 

Citi considers when estimating the ACL under the CECL 
methodology: 

•

The most important reasons for the 2020 change in the 
ACL since the adoption of CECL on January 1, 2020 are 
the pandemic and the resulting economic recessions, 
which led to higher unemployment and lower GDP 
forecasts than were expected at the beginning of the year; 
the impact of government stimulus and relief programs; 
and portfolio changes and lower loan balances resulting 
from changed customer spending patterns.

•

•

•

•

•

CECL reserves are estimated over the contractual term of 
the financial asset, which is adjusted for expected 
prepayments. Expected extensions are generally not 
considered unless the option to extend the loan cannot be 
canceled unilaterally by Citi. Modifications are also not 
considered, unless Citi has a reasonable expectation that it 
will execute a troubled debt restructuring (TDR).
Credit enhancements that are not freestanding (such as 
those that are included in the original terms of the contract 
or those executed in conjunction with the lending 
transaction) are considered loss mitigants for purposes of 
CECL reserve estimation. 
For unconditionally cancelable accounts such as credit 
cards, reserves are based on the expected life of the 
balance as of the evaluation date (assuming no further 
charges) and do not include any undrawn commitments 
that are unconditionally cancelable. Reserves are included 
for undrawn commitments for accounts that are not 
unconditionally cancelable (such as letters of credit and 
corporate loan commitments, HELOCs, undrawn 
mortgage loan commitments and financial guarantees).
CECL models are designed to be economically sensitive. 
They utilize the macroeconomic forecasts provided by 
Citi’s economic forecasting team (EFT) that are approved 
by senior management. Analysis is performed and 
documented to determine the necessary qualitative 
management adjustment (QMA) to capture forward-
looking macroeconomic expectations and model 
uncertainty.
The portion of the forecast that reflects the EFT’s 
reasonable and supportable (R&S) period indicates the 
maximum length of time its models can produce a R&S 
macroeconomic forecast, after which mean reversion 
reflecting historical loss experience is used for the 
remaining life of the loan to estimate expected credit 
losses. For the loss forecast, businesses consume the 
macroeconomic forecast as determined to be appropriate 
and justifiable.

Citi’s ability to forecast credit losses over the reasonable 

and supportable (R&S) period is based on the ability to 
forecast economic activity over a reasonable and supportable 
time window.

The R&S period reflects the overall ability to have a 

reasonable and supportable forecast of credit loss based on 
economic forecasts.

•

•

The loss models consume all or a portion of the R&S 
economic forecast and then revert to historical loss 
experience. The R&S forecast period for consumer loans 
is 13 quarters and, in most cases, reverts to historically 
based loss experience either immediately or using a 
straight-line approach thereafter, while the R&S period 
for wholesale is nine quarters with an additional straight-
line  reversion period of three quarters for ECL 
parameters.
The ACL incorporates provisions for accrued interest on 
products that are not subject to a non-accrual and timely 
write-off policy (e.g., cards and Ready Credit, etc.).

•

•

•

The reserves for TDRs are calculated using the discounted 
cash flow method and consider appropriate 
macroeconomic forecast data for the exposure type. For 
TDR loans that are collateral dependent, the ACL is based 
on the fair value of the collateral.
Citi uses the most recent available information to inform 
its macroeconomic forecasts, allowing sufficient time for 
analysis of the results and corresponding approvals. Key 
variables are reviewed for significant changes through 
year end and changes to portfolio positions are reflected 
in the ACL.
Reserves are calculated at an appropriately granular level 
and on a pooled basis where financial assets share risk 
characteristics. At a minimum, reserves are calculated at a 
portfolio level (product and country). Where a financial 
asset does not share risk characteristics with any of the 
pools, it is evaluated for credit losses individually.

Quantitative and Qualitative Components of the ACL
The loss likelihood and severity models use both internal and 
external information and are sensitive to forecasts of different 
macroeconomic conditions. For the quantitative component, 
Citi uses a single forward-looking macroeconomic forecast, 
complemented by the qualitative component that reflects 
economic uncertainty due to a different possible more adverse 
scenario for estimating the ACL. Estimates of these ECLs are 
based upon (i) Citigroup’s internal system of credit risk 
ratings; (ii) historical default and loss data, including 
comprehensive internal history and rating agency information 
regarding default rates and internal data on the severity of 
losses in the event of default; and (iii) a R&S forecast of future 
macroeconomic conditions. ECL is determined primarily by 
utilizing models for the borrowers’ PD, LGD and EAD. 
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. 

Any adjustments needed to the modeled expected losses 

in the quantitative calculations are addressed through a 
qualitative adjustment. The qualitative adjustment considers, 
among other things: the uncertainty of forward-looking 
scenarios based on the likelihood and severity of a possible 
recession; the uncertainty of economic conditions related to an 
alternative downside scenario; certain portfolio characteristics 
and concentrations; collateral coverage; model limitations; 
idiosyncratic events; and other relevant criteria under banking 
supervisory guidance for loan loss reserves. The qualitative 
adjustment also reflects the estimated impact of the pandemic 
on the economic forecasts and the impact on credit loss 
estimates. The total ACL is composed of the quantitative and 
qualitative components.

Consumer Loans
For consumer loans, most portfolios including North America 
cards, mortgages and personal installment loans (PILs) are 
covered by the PD, LGD and EAD loss forecasting models. 

150

Some smaller international portfolios are covered by 
econometric models where the gross credit loss (GCL) rate is 
forecasted. The modeling of all retail products is performed by 
examining risk drivers for a given portfolio; these drivers 
relate to exposures with similar credit risk characteristics and 
consider past events, current conditions and R&S forecasts. 
Under the PD x LGD x EAD approach, GCLs and recoveries 
are captured on an undiscounted basis. Citi incorporates 
expected recoveries on loans into its reserve estimate, 
including expected recoveries on assets previously written off. 

CECL defines the exposure’s expected life as the 
remaining contractual maturity including any expected 
prepayments. Subsequent changes to the contractual terms that 
are the result of a re-underwriting are not included in the 
loan’s expected CECL life.

Citi does not establish reserves for the uncollectible 
accrued interest on non-revolving consumer products, such as 
mortgages and installment loans, which are subject to a non-
accrual and timely write-off policy. As such, only the principal 
balance is subject to the CECL reserve methodology and 
interest does not attract a further reserve. FAS 91-deferred 
origination costs and fees related to new account originations 
are amortized within a 12-month period, and an ACL is 
provided for components in the scope of the ASC.

Separate valuation allowances are determined for 
impaired smaller-balance homogeneous loans whose terms 
have been modified in a 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 ACL for 
TDRs is determined using a discounted cash flow (DCF) 
approach. When a DCF approach is used, the initial allowance 
for ECLs is calculated as the expected contractual cash flows 
discounted at the loan’s original effective interest rate. DCF 
techniques are applied only for consumer loans classified as 
TDR loan exposures.

For cards, Citi uses the payment rate approach, which 
leverages payment rate curves, to determine the payments that 
should be applied to liquidate the end-of-period balance 
(CECL balance) in the estimation of EAD. The payment rate 
approach uses customer payment behavior (payment rate) to 
establish the portion of the CECL balance that will be paid 
each month. These payment rates are defined as the percentage 
of principal payments received in the respective month divided 
by the prior month’s billed principal balance. The liquidation 
(CECL payment) amount for each forecast period is 
determined by multiplying the CECL balance by that period’s 
forecasted payment rate. The cumulative sum of these 
payments less the CECL balance produces the balance 
liquidation curve. Citi does not apply a non-accrual policy to 
credit card receivables; rather, they are subject to full charge-
off at 180 days past due. As such, the entire customer balance 
up until write-off, including accrued interest and fees, will be 
subject to the CECL reserve methodology. 

Corporate Loans and HTM Securities
Citi records allowances for credit losses on all financial assets 
carried at amortized cost that are in the scope of CECL, 

151

including corporate loans classified as HFI and HTM debt 
securities. Discounting techniques are applied for corporate 
loans classified as HFI and HTM securities and non-accrual/
TDR loan exposures. All cash flows are fully discounted to the 
reporting date. The ACL includes Citi’s estimate of all credit 
losses expected to be incurred over the estimated full 
contractual life of the financial asset. The contractual life of 
the financial asset does not include expected extensions, 
renewals or modifications, except for instances where the 
Company reasonably expects to extend the tenor of the 
financial asset pursuant to a future TDR Where Citi has an 
unconditional option to extend the contractual term, Citi does 
not consider the potential extension in determining the 
contractual term; however, where the borrower has the sole 
right to exercise the extension option without Citi’s approval, 
Citi does consider the potential extension in determining the 
contractual term. The decrease in credit losses under CECL at 
the date of adoption on January 1, 2020, compared with the 
prior incurred loss methodology, is largely due to more precise 
contractual maturities that result in shorter remaining tenors, 
the incorporation of recoveries and use of more specific 
historical loss data based on an increase in portfolio 
segmentation across industries and geographies.

The Company primarily bases its ACL on models that 
assess the likelihood and severity of credit events and their 
impact on cash flows under R&S forecasted economic 
scenarios. Allowances consider the probability of the 
borrower’s default, the loss the Company would incur upon 
default and the borrower’s exposure at default. Such models 
discount the present value of all future cash flows, using the 
asset’s effective interest rate (EIR). Citi applies a more 
simplified approach based on historical loss rates to certain 
exposures recorded in Other assets and certain loan exposures 
in the private bank.

The Company considers the risk of nonpayment to be zero 

for U.S. Treasuries and U.S. government-sponsored agency 
guaranteed mortgage-backed securities (MBS) and, as such, 
Citi does not have an ACL for these securities. For all other 
HTM debt securities, ECLs are estimated using PD models 
and discounting techniques, which incorporate assumptions 
regarding the likelihood and severity of credit losses. For 
structured securities, specific models use relevant assumptions 
for the underlying collateral type. A discounting approach is 
applied to HTM direct obligations of a single issuer, similar to 
that used for corporate HFI loans.

Other Financial Assets with Zero Expected Credit Losses
For certain financial assets, zero expected credit losses will be 
recognized where the expectation of nonpayment of the 
amortized cost basis is zero, based on there being no history of 
loss and the nature of the receivables.

Secured Financing Transactions
Most of Citi’s reverse repurchase agreements, securities 
borrowing arrangements and margin loans require that the 
borrower continually adjust the amount of the collateral 
securing Citi’s interest, primarily resulting from changes in the 
fair value of such collateral. In such arrangements, ACLs are 
recorded based only on the amount by which the asset’s 
amortized cost basis exceeds the fair value of the collateral. 
No ACLs are recorded where the fair value of the collateral is 

equal to or exceeds the asset’s amortized cost basis, as Citi 
does not expect to incur credit losses on such well-
collateralized exposures. For certain margin loans presented in 
Loans on the Consolidated Balance Sheet, credit losses are 
estimated using the same approach as corporate loans. 

acquisition of PCD assets and other assets and liabilities in a 
business combination are expensed as incurred. Subsequent 
accounting for acquired PCD assets is the same as the 
accounting for originated assets; changes in the allowance are 
recorded in Provisions for credit losses.

Accrued Interest
CECL permits entities to make an accounting policy election 
not to reserve for interest, if the entity has a policy in place 
that will result in timely reversal or write-off of interest. 
However, when a non-accrual or timely charge-off policy is 
not applied, an ACL is recognized on accrued interest. For 
HTM debt securities, Citi established a non-accrual policy that 
results in timely write-off of accrued interest. For corporate 
loans, where a timely charge-off policy is used, Citi has 
elected to recognize an ACL on accrued interest receivable. 
The LGD models for corporate loans include an adjustment 
for estimated accrued interest.

Reasonably Expected TDRs
For corporate loans, the reasonable expectation of TDR 
concept requires that the contractual life over which ECLs are 
estimated be extended when a TDR that results in a tenor 
extension is reasonably expected. Reasonably expected TDRs 
are included in the life of the asset. A discounting technique or 
collateral-dependent practical expedient is used for non-
accrual and TDR loan exposures that do not share risk 
characteristics with other loans and are individually assessed. 
Loans modified in accordance with the CARES Act and bank 
regulatory guidance are not classified as TDRs.

Purchased Credit Deteriorated (PCD) Assets 
ASC 326 requires entities that have acquired financial assets 
(such as loans and HTM securities) with an intent to hold, to 
evaluate whether those assets have experienced a more-than-
insignificant deterioration in credit quality since origination. 
These assets are subject to specialized accounting at initial 
recognition under CECL. Subsequent measurement of PCD 
assets will remain consistent with other purchased or 
originated assets, i.e., non-PCD assets. CECL introduces the 
notion of PCD assets, which replaces purchased credit 
impaired (PCI) accounting under prior U.S. GAAP.

CECL requires the estimation of credit losses to be 
performed on a pool basis unless a PCD asset does not share 
characteristics with any pool. If certain PCD assets do not 
meet the conditions for aggregation, those PCD assets should 
be accounted for separately. This determination must be made 
at the date the PCD asset is purchased. In estimating ECLs 
from day 2 onward, pools can potentially be reassembled 
based upon similar risk characteristics. When PCD assets are 
pooled, Citi determines the amount of the initial ACL at the 
pool level. The amount of the initial ACL for a PCD asset 
represents the portion of the total discount at acquisition that 
relates to credit and is recognized as a “gross-up” of the 
purchase price to arrive at the PCD asset’s (or pool’s) 
amortized cost. Any difference between the unpaid principal 
balance and the amortized cost is considered to be related to 
non-credit factors and results in a discount or premium, which 
is amortized to interest income over the life of the individual 
asset (or pool). Direct expenses incurred related to the 

Consumer
Citi does not purchase whole portfolios of PCD assets in its 
retail businesses. However, there may be a small portion of a 
purchased portfolio that is identified as PCD at the purchase 
date. Interest income recognition does not vary between PCD 
and non-PCD assets. A consumer financial asset is considered 
to be more-than-insignificantly credit deteriorated if it is more 
than 30 days past due at the purchase date.

Corporate
Citi generally classifies wholesale loans and debt securities 
classified HTM or AFS as PCD when both of the following 
criteria are met: (i) the purchase price discount is at least 10% 
of par and (ii) the purchase date is more than 90 days after the 
origination or issuance date. Citi classifies HTM beneficial 
interests rated AA- and lower obtained at origination from 
certain securitization transactions as PCD when there is a 
significant difference (i.e., 10% or greater) between 
contractual cash flows, adjusted for prepayments, and 
expected cash flows at the date of recognition.

Reserve Estimates and Policies
Management provides reserves for an estimate of lifetime 
ECLs in the funded loan portfolio on the Consolidated 
Balance Sheet in the form of an ACL. 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 risk management and finance 
representatives for each applicable business area. Applicable 
business areas include those having classifiably managed 
portfolios, where internal credit risk ratings are assigned 
(primarily ICG) and delinquency managed portfolios 
(primarily 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 credit 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 

152

ACL for TDRs, management considers a combination of 
historical re-default rates, the current 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 Provisions for credit 
losses.

Estimated credit losses in the delinquency-managed portfolios 
for performing exposures.
In addition, risk management and finance representatives 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 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, size and 
diversity of individual large credits and 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
Credit loss reserves are recognized on all off-balance sheet 
commitments that are not unconditionally cancelable. 
Corporate loan EAD models include an incremental usage 
factor (or credit conversion factor) to estimate ECLs on 
amounts undrawn at the reporting date. Off-balance sheet 
commitments include unfunded exposures, revolving facilities, 
securities underwriting commitments, letters of credit, 
HELOCs and financial guarantees, which excludes 
performance guarantees. 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 credit losses on 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 

153

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 

and upon the adoption of ASU No. 2017-04 on January 1, 
2020, 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 
quantitative 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 quantitative test. 

The quantitative test 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, an 
impairment loss is recognized in an amount equal to that 
excess, limited to the total amount of goodwill allocated to 
that reporting unit.

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 payables.

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 

154

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.

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.

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 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.

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.

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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 introduced a new credit 
loss methodology, the current expected credit losses (CECL) 
methodology, which requires earlier recognition of credit 
losses while also providing additional disclosure 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 ACL 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 ACL 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 ACL 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. 

156

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 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.

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. Citi calculates a judgmental management adjustment, 
which is an alternative, more adverse scenario that only 
considers downside risk.

Accounting for Variable Post-Charge-Off Third-Party 
Collection Costs
During the second quarter of 2020 Citi changed its accounting 
for variable post-charge-off third-party collection costs, 
whereby these costs were accounted for as an increase in 
expenses as incurred rather than a reduction in expected credit 
recoveries. Citi concluded that such a change in the method of 
accounting is preferable in Citi’s circumstances as it better 
reflects the nature of these collection costs. That is, these costs 
do not represent reduced payments from borrowers and are 
similar to Citi’s other executory third-party vendor contracts 
that are accounted for as operating expenses as incurred. As a 
result of this change, Citi had a consumer ACL release of 
$426 million in the second quarter of 2020 for its U.S. cards 
portfolios and $122 million in the third quarter of 2020 for its 
international portfolios.

In the fourth quarter of 2020, Citi revised the second 
quarter of 2020 accounting conclusion from a “change in 
accounting estimate effected by a change in accounting 
principle” to a “change in accounting principle,” which 
requires an adjustment to opening retained earnings rather than 
net income, with retrospective application to the earliest 
period presented. Citi considered the guidance in ASC Topic 
250, Accounting Changes and Error Corrections; ASC Topic 
270, Interim Reporting; ASC Topic 250-S99-1, Assessing 
Materiality; and ASC Topic 250-S99-23, Accounting Changes 
Not Retroactively Applied Due to Immateriality, Considering 
the Effects of Prior Year Misstatements when Quantifying 
Misstatements in Current Year Financial Statements. Citi 
believes that the effects of the revisions were not material to 
any previously reported quarterly or annual period. As a result, 
Citi’s full-year and quarterly results have been revised to 
reflect this change as if it were effective as of January 1, 2020 
(impacts to 2018 and 2019 were de minimis). Accordingly, 
Citi recorded an increase to its beginning retained earnings on 
January 1, 2020 of $330 million and a decrease of 
$443 million to its ACL. Further, Citi recorded a decrease of 
$18 million to its provisions for credit losses on loans in the 

first quarter of 2020 and an increase of $339 million and 
$122 million to its provisions for credit losses on loans in the 
second and third quarters of 2020, respectively. In addition, 
Citi`s operating expenses increased by $49 million and 
$45 million, with a corresponding decrease in net credit losses, 
in the first and second quarters of 2020, respectively. As a 
result of these changes, Citi’s net income for the year ended 
December 31, 2020 was $330 million lower, or $0.16 per 
share lower, than under the previous presentation as a change 
in accounting estimate.

Reference Rate Reform
In March 2020, the FASB issued ASU No. 2020-04, 
Reference Rate Reform (Topic 848): Facilitation of the Effects 
of Reference Rate Reform on Financial Reporting, which 
provides optional guidance to ease the potential burden in 
accounting for (or recognizing the effects of) reference rate 
reform on financial reporting. Specifically, the guidance 
permits an entity, when certain criteria are met, to consider 
amendments to contracts made to comply with reference rate 
reform to meet the definition of a modification under U.S. 
GAAP. It further allows hedge accounting to be maintained 
and permits a one-time transfer or sale of qualifying held-to-
maturity securities. The expedients and exceptions provided 
by the amendments are permitted to be adopted any time 
through December 31, 2022 and do not apply to contract 
modifications made and hedging relationships entered into or 
evaluated after December 31, 2022, except for certain optional 
expedients elected for certain hedging relationships existing as 
of December 31, 2022. The ASU was adopted by Citi as of 
June 30, 2020 with prospective application and did not impact 
financial results in 2020.

In January 2021, the FASB issued ASU No. 2021-01, 
Reference Rate Reform (Topic 848): Scope, which clarifies 
that the scope of the initial accounting relief issued by the 
FASB in March 2020 includes derivative instruments that do 
not reference a rate that is expected to be discontinued but that 
use an interest rate for margining, discounting, or contract 
price alignment that is modified as a result of reference rate 
reform (commonly referred to as the "discounting transition"). 
The amendments do not apply to contract modifications made 
after December 31, 2022, new hedging relationships entered 
into after December 31, 2022, and existing hedging 
relationships evaluated for effectiveness in periods after 
December 31, 2022, except for hedging relationships existing 
as of December 31, 2022, that apply certain optional 
expedients in which the accounting effects are recorded 
through the end of the hedging relationship. The ASU was 
adopted by Citi on a full retrospective basis upon issuance and 
did not impact financial results in 2020.

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 

157

accounting for finance leases, as well as lessor accounting, is 
largely unchanged. 

Effective January 1, 2019, Citi 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 Sheet related to its 
future lease payments as a lessee under operating leases. In 
addition, Citi 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. 

Citi 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. Citi 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 Citi 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 Citi’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 

158

(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. Citi 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, 2020 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 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 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 prepayable mortgage-backed 
securities and municipal bonds from held-to-maturity (HTM) 
into available-for-sale (AFS) securities classification as 

159

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. 

FUTURE ACCOUNTING CHANGES

Long-Duration Insurance Contracts
In August 2018, the FASB issued ASU No. 2018-12, 
Financial Services—Insurance: Targeted Improvements to the 
Accounting for Long-Duration Contracts, which changes the 
existing recognition, measurement, presentation and 
disclosures for long-duration contracts issued by an insurance 
entity. Specifically, the guidance (i) improves the timeliness of 
recognizing changes in the liability for future policy benefits 
and prescribes the rate used to discount future cash flows for 
long-duration insurance contracts, (ii) simplifies and improves 
the accounting for certain market-based options or guarantees 
associated with deposit (or account balance) contracts, (iii) 
simplifies the amortization of deferred acquisition costs and 
(iv) introduces additional quantitative and qualitative 
disclosures. Citi has certain insurance subsidiaries, primarily 
in the U.S. and Mexico, that issue long-duration insurance 
contracts that will be impacted by the requirements of ASU 
2018-12. 

The effective date of ASU No. 2018-12 was deferred for 
all insurance entities by ASU No. 2019-09, Finance Services
—Insurance: Effective Date (issued in October 2019) and by 
ASU No. 2020-11, Financial Services—Insurance: Effective 
Date and Early Application (issued November 2020). Citi 
plans to adopt the targeted improvements in ASU 2018-12 on 
January 1, 2023 and is currently evaluating the impact of the 
standard on its insurance subsidiaries. Citi does not expect a 
material impact to its results of operations as a result of 
adopting the standard. 

SUPERSEDED ACCOUNTING PRINCIPLES 

Accounting for Credit Losses
Prior to January 1, 2020, Citi applied the incurred loss method 
for the allowance for credit losses on loans and the other-than-
temporary impairment (OTTI) method for HTM securities as 
follows.

Allowance for Credit Losses 
The allowance for credit losses on loans represents 
management’s best estimate of probable credit losses inherent 
in the portfolio, including probable losses related to large 
individually evaluated impaired loans and troubled debt 
restructurings. Additions to the allowance are made through 
the Provision for credit losses on loans. 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.

Evaluating HTM Debt Securities for Other-Than-
Temporary Impairment (OTTI)
The Company conducts periodic reviews of all HTM debt 
securities with unrealized losses to evaluate whether the 
impairment is other-than-temporary. 

An unrealized loss exists when the current fair value of an 

individual debt security is lower than its adjusted amortized 
cost basis. 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. 

160

2.  DISCONTINUED OPERATIONS AND 
SIGNIFICANT DISPOSALS

Summary of Discontinued Operations
The Company’s results from Discontinued operations 
consisted of residual activities related to the sales of 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 table summarizes financial information for 

all Discontinued operations:

In millions of dollars

2020

2019

2018

Total revenues, net of interest expense

$  —  $  —  $  — 

Loss from discontinued operations

$ 

(20)  $  (31)  $ 

Benefit for income taxes

  —   

(27)   

(26) 

(18) 

Loss from discontinued operations, net 
of taxes

$ 

(20)  $ 

(4)  $ 

(8) 

Cash flows from Discontinued operations were not 

material for all periods presented.

Significant Disposals
There were no significant disposals during 2020 and 2019. 
The transaction described below was identified as a significant 
disposal in 2018. 

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:

In millions of dollars

Income before taxes

2020

2019

2018

$  —  $  —  $ 123 

161

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 legacy 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 allocates resources and 
measures financial performance 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 96 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, 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 following table presents certain information 

regarding the Company’s continuing operations by reportable 
segment:

Revenues,
net of interest expense(1)

Provision (benefits)
for income taxes

Income (loss) from
continuing operations(2)

Identifiable assets

In millions of dollars, except 
identifiable assets in billions

2020

2019

2018

2020

2019

2018

2020

2019

2018

2020

2019

Global Consumer Banking $  29,991  $  32,971  $  32,339  $ 

212  $  1,746  $  1,689  $ 

874  $  5,702  $  5,309  $ 

434  $ 

407 

Institutional Clients Group   44,253    39,301    38,325   

3,373   

3,570   

3,756    11,798    12,944    12,574   

1,730   

1,447 

Corporate/Other

54   

2,014   

2,190   

(1,060)   

(886)   

(88)   

(1,565)   

825   

205   

96   

97 

Total

$  74,298  $  74,286  $  72,854  $  2,525  $  4,430  $  5,357  $  11,107  $  19,471  $  18,088  $  2,260  $  1,951 

(1)   Includes total revenues, net of interest expense (excluding Corporate/Other), in North America of $36.3 billion, $33.9 billion and $33.4 billion; in EMEA of $12.8 
billion, $12.0 billion and $11.8 billion; in Latin America of $9.2 billion, $10.4 billion and $10.3 billion; and in Asia of $15.9 billion, $16.0 billion and $15.3 
billion in 2020, 2019 and 2018, respectively. These regional numbers exclude Corporate/Other, which largely operates within the U.S. 

(2)   Includes pretax provisions for credit losses and for benefits and claims in the GCB results of $11.7 billion, $7.9 billion and $7.6 billion; in the ICG results of $5.6 
billion, $0.6 billion and $0.2 billion; and in the Corporate/Other results of $0.2 billion, $(0.1) billion and $(0.2) billion in 2020, 2019 and 2018, respectively.

162

 
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-bearing assets

Total interest revenue

Interest expense
Deposits(2)
Securities loaned and sold under agreements to repurchase
Trading account liabilities(1)
Short-term borrowings and other interest-bearing liabilities

Long-term debt

Total interest expense

Net interest revenue

Provision for credit losses on loans

Net interest revenue after provision for credit losses on loans

2020

2019

2018

$ 

40,185  $ 

47,751  $ 

45,682 

928   

2,283   

7,989   

6,125   

579   

2,682   

6,872   

9,860   

7,672   

1,673   

2,203 

5,492 

9,494 

6,284 

1,673 

58,089  $ 

76,510  $ 

70,828 

6,537  $ 

2,077   

628   

630   

4,669   

14,541  $ 

43,548  $ 

15,922   

12,633  $ 

6,263   

1,308   

2,465   

6,494   

29,163  $ 

47,347  $ 

8,218   

27,626  $ 

39,129  $ 

9,616 

4,889 

1,001 

2,209 

6,551 

24,266 

46,562 

7,354 

39,208 

$ 

$ 

$ 

$ 

$ 

(1)

(2)

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 deposit insurance fees and charges of $1,203 million, $781 million and $1,182 million for 2020, 2019 and 2018, respectively.

163

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 $495 million, $485 million and $521 
million of revenue related to such variable consideration for 
the years ended December 31, 2020, 2019 and 2018, 
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. Citi’s credit 
card programs have certain partner sharing agreements that 
vary by partner. These partner sharing agreements are subject 
to contractually based performance thresholds that if met, 
would require Citi to make ongoing payments to the partner. 
The threshold is based on the profitability of a program and is 
generally calculated based on predefined program revenues 
less predefined program expenses. In most of Citi’s partner 
sharing agreements, program expenses include net credit 
losses and, to the extent that the increase in net credit losses 
reduces Citi’s liability for the partners’ share for a given 
program year, it would generally result in lower payments to 
partners in total for that year and vice versa. Further, in some 
instances, other partner payments are based on program sales 
and new account acquisitions.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 
$290 million, $322 million and $386 million of revenue 
related to such variable consideration for the years ended 
December 31, 2020, 2019 and 2018, 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.

164

 
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

$  4,483  $  —  $  —  $  4,483  $  3,767  $  —  $  —  $  3,767  $  3,568  $  —  $  —  $  3,568 

2020

2019

2018

Brokerage commissions
Credit card and bank card 
income

  1,986   

974   

—    2,960    1,771   

841   

—    2,612    1,977   

815   

—    2,792 

Interchange fees

703    7,301   

—    8,004    1,222    8,621   

—    9,843    1,077    8,112   

11    9,200 

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)

23   

626   

—   

649   

60   

718   

—   

778   

63   

627   

12   

702 

(380)    (8,293)   

—    (8,673)   

(691)    (8,883)   

—    (9,574)   

(504)    (8,253)   

(12)    (8,769) 

376   

—    1,334    1,048   

958   

886   

457   

11   

—   

82   

88   

—   

492   

125   

30   

118   

310   

—   

—   

—   

—   

25   

4   

974   

457   

503   

125   

137   

432   

824   

616   

12   

—   

78   

99   

470   

123   

—   

524   

186   

55   

261   

—    1,518    1,031   

572   

1    1,604 

—   

—   

—   

—   

21   

3   

947   

616   

536   

186   

154   

363   

733   

734   

14   

—   

100   

116   

83   

—   

565   

119   

91   

139   

4   

—   

11   

—   

37   

14   

820 

734 

590 

119 

228 

269 

$  9,327  $  2,029  $ 

29  $ 11,385  $  8,806  $  2,916  $ 

24  $ 11,746  $  8,909  $  2,870  $ 

78  $ 11,857 

(1)

Includes overdraft fees of $100 million, $127 million and $128 million for the years ended December 31, 2020, 2019 and 2018, 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 $(7,160) million, $(7,695) million and $(6,853) million not accounted for under ASC 606, Revenue from Contracts with 

Customers, for the years ended December 31, 2020, 2019 and 2018, 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.

165

 
 
 
 
 
 
 
 
 
 
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

2020

Corp/
Other

Total

ICG

GCB

2019

Corp/
Other

2018

Total

ICG

GCB

Corp/
Other

Total

Custody fees

Fiduciary fees

Guarantee fees

$ 1,590  $ 

29  $ 

38  $ 1,657  $ 1,453  $ 

16  $ 

73  $ 1,542  $ 1,497  $  133  $ 

65  $ 1,695 

668   

602   

4    1,274   

647   

621   

28    1,296    645    597   

43    1,285 

529   

7   

5    541   

558   

8   

7    573    584   

9   

7   

600 

Total administration and other 
fiduciary fees(1)

$ 2,787  $  638  $ 

47  $ 3,472  $ 2,658  $  645  $ 

108  $ 3,411  $ 2,726  $  739  $ 

115  $ 3,580 

(1)  Administration and other fiduciary fees includes $541 million, $573 million and $600 million for the years ended December 31, 2020, 2019 and 2018, 

respectively, that are not accounted for under ASC 606, Revenue from Contracts with Customers. These amounts include guarantee fees.

166

 
 
6.  PRINCIPAL TRANSACTIONS

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 and characterized below 
based on the primary risk managed by each trading desk. 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

2020

2019

2018

$ 

5,561  $ 

4,158   

1,343   

1,133   

1,690   

3,831  $ 

3,850   

808   

546   

(143)   

$ 

13,885  $ 

8,892  $ 

2,889 

3,772 

1,221 

668 

355 

8,905 

(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.

167

 
 
 
 
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 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 
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, 2019
Granted(1)
Canceled
Vested(2)
Unvested at December 31, 2020

  30,194,715  $ 

  12,361,412   

(606,918)   

  (13,722,917)   

  28,226,292  $ 

61.30 

76.68 

69.22 

58.45 

69.25 

(1) The weighted-average fair value of the shares granted during 2019 and 

2018 was $61.78 and $73.87, respectively.

(2) The weighted-average fair value of the shares vesting during 2020 was 

approximately $79.68 per share.

Total unrecognized compensation cost related to unvested 

stock awards was $580 million at December 31, 2020. The 
cost is expected to be recognized over a weighted-average 
period of 1.6 years. 

168

 
 
A summary of the performance share unit activity for 

2020 is presented below:

Performance share units
Outstanding, beginning of 
  year
Granted(1)
Canceled

Payments

Weighted-
average grant
date fair
value per unit

Units

  1,492,000  $ 

440,349   

—   

(598,546)   

71.69 

78.06 

— 

59.22 

79.39 

Outstanding, end of year

  1,333,803  $ 

(1)   Grant activity for 2020 includes additional units earned on the 2017 
grant. The weighted-average grant price for the 2020 grant alone was 
$83.45. The weighted-average grant date fair value per unit awarded in 
2019 and 2018 was $72.83 and $83.24, 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. 

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) every February from 2017 to 
2020, for performance in the year prior to the award date.

The PSUs granted each February from 2017 to 2020 were 

earned over the preceding 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

2020

2019

2018

Expected volatility

 22.26 %  25.33 %  24.93 %

Expected dividend yield

 2.82 

 2.67 

 1.75 

169

 
 
 
 
The following table presents information with respect to stock option activity under Citigroup’s stock option programs: 

2020

Weighted-
average
exercise
price

Options

Intrinsic
value
per share

Options

2019

Weighted-
average
exercise
price

Intrinsic
value
per share

Options

2018

Weighted-
average
exercise
price

Intrinsic
value
per share

Outstanding, beginning of 
year

Canceled

Expired

Exercised

166,650  $ 

47.42  $  32.47   

762,225  $  101.84  $  —   

1,138,813  $  161.96  $  — 

—   

—   

—   

—   

—   

—   

—   

—   

—   

(11,365)   

40.80   

(449,916)   

142.30   

—   

—   

—   

—   

(376,588)   

283.63   

(134,294)   

39.00   

23.50   

—   

—   

— 

— 

— 

Outstanding, end of year

166,650  $ 

47.42  $  14.24   

166,650  $ 

47.42  $  32.47   

762,225  $  101.84  $  — 

Exercisable, end of year

166,650 

166,650 

762,225 

The following table summarizes information about stock options outstanding under Citigroup’s stock option programs at 
December 31, 2020:

Range of exercise prices

$41.54–$60.00

Total at December 31, 2020

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 

0.4 years $ 

0.4 years $ 

47.42   

166,650  $ 

47.42   

166,650  $ 

47.42 

47.42 

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, 2020, approximately 34.0 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 2017 to 2020, and for 
the first quarter of 2021, 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 
vests, the shares delivered to the participant are freely 

170

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

2020

2019

2018

Charges for estimated awards to 
retirement-eligible colleagues

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

Total

$ 

748  $ 

683  $ 

669 

201   

355   

202 

95   

82   

75 

420   

404   

435 

627   

666   

640 

$  2,091  $  2,190  $  2,021 

(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 colleagues. 

171

 
 
 
 
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, 2020. 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

2020

2019

2018

2020

2019

2018

2020

2019

2018

2020

2019

2018

Benefits earned during the year

$  —  $ 

1  $ 

1  $  147  $  146  $  146  $  —  $  —  $  —  $ 

7  $ 

8  $ 

9 

Interest cost on benefit obligation

378   

469   

514   

246   

287   

292   

17   

24   

26   

93   

104   

102 

Expected return on assets

(824)   

(821)   

(844)   

(245)   

(281)   

(291)   

(17)   

(18)   

(14)   

(77)   

(84)   

(88) 

Amortization of unrecognized:

Prior service cost (benefit) 

Net actuarial loss 

Curtailment loss (gain)(1)
Settlement (gain) loss(1)
Total net (benefit) expense

2   

2   

2   

233   

200   

165   

  —   

1   

1   

  —    —    —   

5   

70   

(8)   

(1)   

(4)   

61   

(6)   

6   

(4)   

(2)    —    —   

53    —    —   

(1)   

(9)   

20   

(10)   

(10) 

23   

29 

(1)    —    —    —    —    —    — 

7    —    —    —    —    —    — 

$  (211)  $  (148)  $  (161)  $  214  $  209  $  202  $ 

(2)  $ 

6  $ 

11  $ 

34  $ 

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 2020 or 2019. 

The following table summarizes the Company’s actual 

contributions for the years ended December 31, 2020 and 
2019, as well as expected Company contributions for 2021. 
Expected contributions are subject to change, since 
contribution decisions are affected by various factors, such as 
market performance, tax considerations and regulatory 
requirements.

Pension plans(1)

Postretirement benefit plans(1)

In millions of dollars

Contributions made by the Company
Benefits paid directly by (reimbursements to) 
the Company

U.S. plans(2)
2020

2019

2021

Non-U.S. plans

U.S. plans

Non-U.S. plans

2021

2020

2019

2021

2020

2019

2021

2020

2019

$  —  $  —  $  425  $  97  $  115  $  111  $  —  $  —  $  —  $ 

3  $ 

4  $  221 

57   

56   

56   

58   

43   

39   

6   

(15)   

4   

5   

5   

4 

(1)  Amounts reported for 2021 are expected amounts.  
(2)   The U.S. pension plans include benefits paid directly by the Company for the nonqualified pension plans. 

172

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Funded Status and Accumulated Other Comprehensive Income (AOCI)
The following table summarizes the funded status and amounts recognized on the Consolidated Balance Sheet for the Company’s 
Significant Plans:

Pension plans

Postretirement benefit plans

U.S. plans

Non-U.S. plans

U.S. plans

Non-U.S. plans

In millions of dollars

2020

2019

2020

2019

2020

2019

2020

2019

Change in projected benefit obligation

Projected benefit obligation at beginning of year

$  13,453  $  12,655  $ 

8,105  $ 

7,149  $ 

692  $ 

662  $ 

1,384  $ 

1,159 

Benefits earned during the year

Interest cost on benefit obligation
Plan amendments(1)
Actuarial loss (gain)(2)
Benefits paid, net of participants’ contributions and 
government subsidy(3)
Settlement gain(4)
Curtailment loss (gain)(4)
Foreign exchange impact and other

—   

378   

—   

1   

469   

—   

950   

1,263   

(966)   

(936)   

—   

—   

—   

—   

1   

—   

147   

246   

(4)   

518   

(298)   

(110)   

(14)   

39   

146   

287   

—   

17   

7   

(104)   

861   

(18)   

—   

24   

—   

46   

(304)   

(84)   

(4)   

47   

(28)   

(40)   

—   

—   

—   

—   

—   

—   

7   

93   

—   

30   

(64)   

—   

—   

(60)   

8 

104 

— 

140 

(72) 

— 

— 

45 

Projected benefit obligation at year end

$  13,815  $  13,453  $ 

8,629  $ 

8,105  $ 

559  $ 

692  $ 

1,390  $ 

1,384 

Change in plan assets

Plan assets at fair value at beginning of year
Actual return on assets(2)
Company contributions (reimbursements)

Benefits paid, net of participants’ contributions and 
government subsidy(3)
Settlement gain(4)
Foreign exchange impact and other

$  12,717  $  11,490  $ 

7,556  $ 

6,699  $ 

345  $ 

345  $ 

1,127  $ 

1,036 

1,502   

1,682   

56   

481   

(966)   

(936)   

—   

—   

—   

—   

584   

158   

(298)   

(110)   

(59)   

781   

150   

(304)   

(84)   

314   

29   

(15)   

(28)   

—   

—   

36   

4   

(40)   

—   

—   

129   

9   

(64)   

—   

(55)   

138 

225 

(72) 

— 

(200) 

Plan assets at fair value at year end

$  13,309  $  12,717  $ 

7,831  $ 

7,556  $ 

331  $ 

345  $ 

1,146  $ 

1,127 

Funded status of the plans
Qualified plans(5)
Nonqualified plans(6)
Funded status of the plans at year end

Net amount recognized
Qualified plans

Benefit asset

Benefit liability

Qualified plans

Nonqualified plans

$ 

230  $ 

(23)  $ 

(798)  $ 

(549)  $ 

(228)  $ 

(347)  $ 

(244)  $ 

(257) 

(736)   

(713)   

—   

—   

—   

—   

—   

— 

$ 

(506)  $ 

(736)  $ 

(798)  $ 

(549)  $ 

(228)  $ 

(347)  $ 

(244)  $ 

(257) 

$ 

$ 

230  $ 

—  $ 

741  $ 

808  $ 

—  $ 

—  $ 

25  $ 

57 

—   

(23)   

(1,539)   

(1,357)   

(228)   

(347)   

(269)   

230  $ 

(23)  $ 

(798)  $ 

(549)  $ 

(228)  $ 

(347)  $ 

(244)  $ 

(736)   

(713)   

—   

—   

—   

—   

—   

(314) 

(257) 

— 

Net amount recognized on the balance sheet

$ 

(506)  $ 

(736)  $ 

(798)  $ 

(549)  $ 

(228)  $ 

(347)  $ 

(244)  $ 

(257) 

Amounts recognized in AOCI

Net transition obligation

Prior service (cost) benefit 

Net actuarial (loss) gain

Net amount recognized in equity (pretax) 

$ 

(7,142)  $ 

(7,104)  $ 

(1,851)  $ 

(1,734)  $ 

Accumulated benefit obligation at year end

$  13,812  $  13,447  $ 

8,116  $ 

7,618  $ 

24  $ 

(285)  $ 

692  $ 

1,390  $ 

1,384 

$ 

—  $ 

—  $ 

(10)   

(12)   

—  $ 

12   

1   

(7,132)   

(7,092)   

(1,863)   

(1,735)   

—  $ 

—  $ 

—  $ 

—  $ 

63   

(348)   

—   

24   

— 

76 

(416) 

(340) 

101   

56   

157  $ 

559  $ 

(1) U.S. postretirement benefit plan was amended in 2020 to move grandfathered Medicare-eligible retirees to the Medicare individual marketplace.
(2) During 2020 and 2019, the actuarial loss is primarily due to the decline in global discount rates offset by actual return on assets due to favorable asset returns.
(3) U.S. postretirement benefit plans were net of Employer Group Waiver Plan subsidy of $40 million and $22 million in 2020 and 2019, respectively.
(4) Curtailment and settlement (gains) losses relate to repositioning and divestiture activities.
(5) The U.S. qualified pension plan is fully funded under specified Employee Retirement Income Security Act (ERISA) funding rules as of January 1, 2021 and no 

minimum required funding is expected for 2021.
(6) The nonqualified plans of the Company are unfunded.

173

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 credit (cost)
Curtailment/settlement gain(3)
Foreign exchange impact and other

Change in deferred taxes, net

Change, net of tax
End of year balance, net of tax(1)(2)

2020

2019

2018

$ 

$ 

$ 

(6,809)  $ 

(1,464)   

1,076   

318   

108   

(8)   

(108)   

23   

(55)  $ 

(6,864)  $ 

(6,257)  $ 

(2,300)   

1,427   

274   

(7)   

1   

(66)   

119   

(552)  $ 

(6,809)  $ 

(6,183) 

1,288 

(1,732) 

214 

(7) 

7 

136 

20 

(74) 

(6,257) 

(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.

At December 31, 2020 and 2019, 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

2020

2019

2020

2019

2020

2019

2020

2019

Projected benefit obligation

$ 

736  $ 

13,453  $ 

4,849  $ 

4,445  $ 

736  $ 

13,453  $ 

4,723  $ 

Accumulated benefit obligation

734   

13,447   

Fair value of plan assets

—   

12,717   

4,400   

3,310   

4,041   

3,089   

734   

13,447   

—   

12,717   

4,329   

3,212   

2,748 

2,435 

1,429 

(1) As of December 31, 2020, only the nonqualified plans’ PBO and ABO exceeded plan assets; As of December 31, 2019, both the qualified and nonqualified plans’ 

PBO and ABO exceeded plan assets.

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. 

174

 
 
 
 
 
 
 
 
 
 
 
 
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

2020

2019

2.45%
2.35
2.20

3.25%
3.25
3.15

 -0.25 to 11.15 -0.10 to 11.30

3.14

3.65

0.80 to 8.55
7.42

0.90 to 9.10
7.76

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

1.20 to 11.25
3.10

1.50 to 11.50
3.17

5.80
5.80/1.50

6.70
6.70/3.00

0.00 to 11.50
3.39

0.00 to 11.50
3.95

5.95 to 8.00
7.99

6.20 to 8.00
7.99

(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.
(3)  For the year ended 2020 and 2019, the expected return on assets for the 

VEBA Trust was 1.50% and 3.00% respectively.

During the year

2020

2019

2018

Discount rate

U.S. plans 
Qualified 
pension

Nonqualified 
pension

Postretirement

3.25%/3.20%/  
2.60%/2.55%

4.25%/3.85%/  
3.45%/3.10%

3.60%/3.95%/         
4.25%/4.30%

3.25/3.25/  
2.55/2.50

3.15/3.20/ 
2.45/2.35

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

Non-U.S. pension plans(1)

Range(2)
Weighted 
average 

-0.10 to 11.30

-0.05 to 12.00

0.00 to 10.75

3.65

4.47

4.17

Non-U.S. postretirement plans(1)

Range
Weighted 
average 

0.90 to 9.75

1.75 to 10.75

1.75 to 10.10

7.76

9.05

8.10

Future compensation increase rate(3)
Non-U.S. pension plans(1)

Range
Weighted 
average 

1.50 to 11.50

1.30 to 13.67

1.17 to 13.67

3.17

3.16

3.08

Expected return on assets

U.S. plans

Qualified 
pension(4)
Postretirement(4)

6.70

6.70

6.80/6.70

6.70/3.00

6.70/3.00

6.80/6.70/3.00

Non-U.S. pension plans(1)

Range
Weighted 
average 

0.00 to 11.50

1.00 to 11.50

0.00 to 11.60

3.95

4.30

4.52

Non-U.S. postretirement plans(1)

Range
Weighted 
average 

6.20 to 8.00

8.00 to 9.20

8.00 to 9.80

7.99

8.01

8.01

(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 return on assets for the U.S. pension and postretirement 
plans was lowered from 6.70% to 5.80% effective January 1, 2021 to 
reflect the lower interest rate environment and a change in target asset 
allocation.

175

 
 
 
 
 
 
 
 
Sensitivities of Certain Key Assumptions
The following tables summarize the effect on pension 
expense: 

Discount rate

One-percentage-point increase

In millions of dollars

2020

2019

2018

U.S. plans

Non-U.S. plans

In millions of dollars

U.S. plans

Non-U.S. plans

$ 

$ 

34  $ 

(16)   

28  $ 

(19)   

25 

(22) 

One-percentage-point decrease

2020

2019

2018

(52)  $ 

25   

(44)  $ 

32   

(37) 

32 

The U.S. Qualified Pension Plan was frozen in 2008, and 

as a result, most service costs have been eliminated. The 
pension expense for the U.S. Qualified Pension Plan is 
therefore 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 return on assets

One-percentage-point increase

In millions of dollars

2020

2019

2018

U.S. plans

Non-U.S. plans

$ 

(123)  $ 

(123)  $ 

(66)   

(64)   

(126) 

(64) 

One-percentage-point decrease

In millions of dollars

2020

2019

2018

U.S. plans

Non-U.S. plans

$ 

123  $ 

66   

123  $ 

64   

126 

64 

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 Return on Assets
The Company determines its assumptions for the expected 
return on 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 return on assets 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 return on assets for the U.S. pension and 

postretirement plans Trust was 5.80% at December 31, 2020 
and 6.70% at December 31, 2019 and 2018. 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 return on assets 

used in determining the Company’s pension expense 
compared to the actual return on assets during 2020, 2019 and 
2018 for the U.S. pension and postretirement plans:

U.S. plans
(During the year)
Expected return on 
assets

U.S. pension and 
postretirement trust

VEBA trust
Actual return on 
assets(1)

U.S. pension and 
postretirement trust

VEBA trust

2020

2019

2018

6.70%

3.00

6.70%

6.80%/6.70%

3.00

3.00

12.84

2.11

15.20

-3.40

1.91 to 2.76

0.43 to 1.41

(1) Actual return on assets is presented net of fees.

176

 
 
 
 
 
 
 
 
 
Health Care Cost Trend Rate
Assumed health care cost trend rates were as follows:

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)

2020

2019

6.50%

6.75%

5.00

2027

5.00

2027

Following year

6.85%

6.85%

Ultimate rate to which cost increase is 
assumed to decline

Year in which the ultimate rate 
is reached

6.85

2021

6.85

2020

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.

At year end

U.S. plans

Non-U.S. plans

Weighted average interest 
crediting rate

2020

1.45%

1.60

2019

2.25%

1.61

2018

3.25%

1.68

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,

2021

0–26%

35–82

0–7

0–10

0–30

2020

2019

2020

2019

 16 %

 17 %

 16 %

 17 %

 59 

 4 

 3 

 18 

 58 

 4 

 3 

 18 

 59 

 4 

 3 

 18 

 58 

 4 

 3 

 18 

 100 %

 100 %

 100 %

 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 2020 and 2019.
(3) The VEBA Trust for postretirement benefits is primarily invested in cash equivalents and debt securities in 2020 and 2019 and is 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,

2021

0–100%

0–100

0–15

0–100

2020

0–100%

0–100

0–12

0–100

2019

0–100%

0–100

0–15

0–100

Weighted-average
at December 31,

2020

2019

 15 %

 13 %

 77 

 1 

 7 

 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. 

177

 
 
 
 
 
 
 
 
 
Asset category(1)
Equity securities

Debt securities

Other investments

Total

Non-U.S. postretirement plans

Target asset
allocation

Actual range
at December 31,

2021

0–38%

56–100

0–6

2020

0–38%

56–100

0–6

2019

0–31%

66–100

0–3

Weighted-average
at December 31,

2020

2019

 38 %

 56 

 6 

 100 %

 27 %

 71 

 2 

 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. 

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. 
Investments measured using the NAV per share practical 
expedient are excluded from Level 1, Level 2 and Level 3 in 
the tables below. 

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:

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, 2020

Level 1

Level 2

Level 3

Total

$ 

$ 

$ 

$ 

813  $ 

725   

447   

—   

1,275   

—   

8   

16   

3,284  $ 

72  $ 

(2)   

—  $ 

—   

—   

1,074   

4,429   

—   

6   

—   

5,509  $ 

1,035  $ 

(10)   

3,354  $ 

6,534  $ 

—  $ 

—   

—   

—   

—   

1   

—   

57   

58  $ 

—  $ 

—   

58  $ 

$ 

$ 

813 

725 

447 

1,074 

5,704 

1 

14 

73 

8,851 

1,107 

(12) 

9,946 

99 

3,595 

13,640 

(1) The investments of the U.S. pension and postretirement plans are commingled in one trust. At December 31, 2020, 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.

178

 
 
 
 
 
 
 
 
 
 
 
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, 2019

Level 1

Level 2

Level 3

Total

$ 

$ 

$ 

$ 

739  $ 

553   

280   

—   

1,534   

—   

10   

—   

3,116  $ 

93  $ 

(87)   

—  $ 

—   

—   

1,410   

4,046   

—   

7   

—   

5,463  $ 

1,080  $ 

(11)   

3,122  $ 

6,532  $ 

—  $ 

—   

—   

—   

—   

1   

—   

75   

76  $ 

—  $ 

—   

76  $ 

$ 

$ 

739 

553 

280 

1,410 

5,580 

1 

17 

75 

8,655 

1,173 

(98) 

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

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, 2020

Level 1

Level 2

Level 3

Total

16  $ 

670   

73   

—   

1,420   

2   

—   

1,005   

—   

3,186  $ 

3  $ 

(4,650)   

(1,461)  $ 

—  $ 

—   

—   

—   

—   

2   

5   

—   

312   

319  $ 

—  $ 

—   

319  $ 

$ 

$ 

21 

775 

3,210 

24 

8,125 

4 

5 

1,005 

312 

13,481 

132 

(4,650) 

8,963 

14 

8,977 

$ 

5  $ 

105   

3,137   

24   

6,705   

—   

—   

—   

—   

9,976  $ 

129  $ 

—   

10,105  $ 

$ 

$ 

$ 

179

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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  $ 

127   

3,223   

23   

4,307   

—   

—   

—   

1   

7,685  $ 

86  $ 

(3)   

7,768  $ 

$ 

$ 

$ 

12  $ 

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 

180

 
 
 
 
 
 
 
 
 
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, 2019

Realized (losses) Unrealized gains 

Purchases, 
sales and 
issuances

Transfers in and/
or out of Level 3

Ending Level 3 
fair value at 
Dec. 31, 2020

$ 

$ 

1  $ 

75   

76  $ 

—  $ 

(3)   

(3)  $ 

—  $ 

3   

3  $ 

—  $ 

(18)   

(18)  $ 

—  $ 

—   

—  $ 

1 

57 

58 

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 (losses)

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

Non-U.S. pension and postretirement benefit plans

Asset categories

Debt securities

Real estate

Annuity contracts

Other investments

Total investments

Beginning Level 3 
fair value at 
Dec. 31, 2019

Unrealized gains 

Purchases, sales and 
issuances

Transfers in and/
or out of Level 3

Ending Level 3 
fair value at 
Dec. 31, 2020

$ 

$ 

10  $ 

1   

5   

274   

290  $ 

—  $ 

1   

—   

23   

24  $ 

(10)  $ 

—   

—   

15   

5  $ 

—  $ 

—   

—   

—   

—  $ 

— 

2 

5 

312 

319 

 In millions of dollars

Non-U.S. pension and postretirement benefit plans

Asset categories

Debt securities

Real estate

Annuity contracts

Other investments

Total investments

Beginning Level 3 
fair value at 
Dec. 31, 2018

Unrealized (losses)

Purchases, sales and 
issuances

Transfers in and/
or out of Level 3

Ending Level 3 
fair value at 
Dec. 31, 2019

$ 

$ 

9  $ 

1   

10   

210   

230  $ 

1  $ 

—   

—   

7   

8  $ 

—  $ 

—   

(5)   

57   

52  $ 

—  $ 

—   

—   

—   

—  $ 

10 

1 

5 

274 

290 

181

 
 
 
 
 
 
 
 
 
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, publicly traded 
equity, hedge funds, 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

$ 

820  $ 

566  $ 

58  $ 

832   

847   

852   

857   

504   

507   

521   

527   

55   

52   

49   

45   

76 

80 

85 

90 

96 

In millions of dollars

2021

2022

2023

2024

2025

2026–2030

4,101   

2,698   

181   

550 

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.
The following table summarizes the funded status and 
amounts recognized in the Company’s Consolidated Balance 
Sheet: 

In millions of dollars

2020

2019

Funded status of the plan at year end

$ 

(40)  $ 

(38) 

Net amount recognized in AOCI (pretax)

$ 

(17)  $ 

(15) 

The following table summarizes the net expense (benefit) 

recognized in the Consolidated Statement of Income for the 
Company’s U.S. post employment plans:

In millions of dollars

2020

2019

2018

Net expense (benefit)

$ 

9  $ 

9  $ 

(18) 

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 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 2020 and 2019, 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:

U.S. plans

In millions of dollars

2020

2019

2018

Company contributions

$ 

414  $ 

404  $ 

396 

In millions of dollars

2020

2019

2018

Company contributions

$ 

304  $ 

281  $ 

283 

Non-U.S. plans

182

 
 
 
 
 
 
 
 
 
 
$  2,525  $  4,430  $  5,357 

  —   

(27)   

(18) 

(1)

2018 includes one-time Tax Reform benefits of $94 million for amounts 
that were considered provisional pursuant to SAB 118.

(2) See “Deferred Tax Assets” below for a description of the components.

9. INCOME TAXES

Income Tax Provision
Details of the Company’s income tax provision are presented 
below: 

In millions of dollars

2020

2019

2018

Current

Federal

Non-U.S.

State

$  305  $  365  $  834 

  4,113    4,352    4,290 

440   

323   

284 

Total current income taxes

$  4,858  $  5,040  $  5,408 

Deferred

Federal

Non-U.S.

State

$ (1,430)  $  (907)  $  (620) 

(690)   

10   

(213)   

287   

371 

198 

Total deferred income taxes

$ (2,333)  $  (610)  $ 

(51) 

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)

23   

(11)   

(263) 

  1,214   

648   

(346) 

(4)   

(16)   

455   

269   

(2) 

(8) 

(23)   

(119)   

(20) 

(141)   

(337)   

302 

(8)   

8   

(17) 

(911)   

46   

(305) 

Income taxes before noncontrolling 
interests

$  3,130  $  4,891  $  4,680 

(1)

(2)

Includes the tax on realized investment gains and impairment losses 
resulting in a provision (benefit) of $454 million and $(14) million in 
2020, $373 million and $(9) million in 2019 and $104 million and $(32) 
million in 2018, respectively.
2020 reflects the tax effect of ASU 2016-13 for current expected credit 
losses (CECL). 2019 reflects the tax effect of the accounting change for 
ASU 2016-02 for lease transactions. 2018 reflects the tax effect of the 
accounting change for ASU 2016-16 for intra-entity transfers of assets 
and the tax effect of the accounting change for ASU 2018-03, to report 
the net unrealized gains on former AFS equity securities. See Note 1 to 
the Consolidated Financial Statements.

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:

Federal statutory rate

 21.0 %  21.0 %  21.0 %

2020

2019

2018

State income taxes, net of federal 
benefit

Non-U.S. income tax rate differential
Effect of tax law changes(1)
Nondeductible FDIC premiums

Basis difference in affiliates

Tax advantaged investments
Valuation allowance releases(2)
Other, net

 1.3 

 3.5 

 — 

 1.3 

 (0.1) 

 (4.4) 

 (4.4) 

 0.3 

 1.9 

 1.3 

 1.8 

 5.3 

 (0.5) 

 (0.6) 

 0.4 

 (0.1) 

 (2.3) 

 (3.0) 

 (0.2) 

 0.7 

 (2.4) 

 (2.0) 

 — 

 (1.0) 

Effective income tax rate

 18.5 %  18.5 %  22.8 %

As set forth in the table above, Citi’s effective tax rate for 

2020 was 18.5%, the same as 2019.

Deferred Income Taxes
Deferred income taxes at December 31 related to the 
following:

In millions of dollars

Deferred tax assets

Credit loss deduction

2020

2019

$  6,791  $  3,809 

Deferred compensation and employee benefits

  2,510    2,224 

U.S. tax on non-U.S. earnings

Investment and loan basis differences

  1,195    1,030 

  1,486    2,727 

Tax credit and net operating loss carry-forwards

  17,416    19,711 

Fixed assets and leases

Other deferred tax assets

Gross deferred tax assets

Valuation allowance

  2,935    2,607 

  3,832    3,341 

$ 36,165  $ 35,449 

$  5,177  $  6,476 

Deferred tax assets after valuation allowance

$ 30,988  $ 28,973 

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

$ (2,526)  $ (2,640) 

(50)   

(201) 

(921)   

(974) 

(597)   

(587) 

  (2,054)    (1,477) 

$ (6,148)  $ (5,879) 

$ 24,840  $ 23,094 

183

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Unrecognized Tax Benefits
The following is a rollforward of the Company’s unrecognized 
tax benefits:

In millions of dollars

2020

2019

2018

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

$  721  $  607  $  1,013 

51   

50   

40 

217   

151   

46 

(74)   

(44)   

(174) 

(40)   

(21)   

(283) 

(13)   

(23)   

(23) 

(1)   

1   

(12) 

$  861  $  721  $  607 

In millions of dollars

The total amounts of unrecognized tax benefits at 

December 31, 2020, 2019 and 2018 that, if recognized, would 
affect Citi’s tax expense are $0.7 billion, $0.6 billion and $0.4 
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. 

2020

2019
Pretax Net of tax Pretax Net of tax Pretax Net of tax

2018

Total interest and penalties on the Consolidated Balance Sheet at January 1

$  100  $ 

82  $  103  $ 

85  $  121  $ 

101 

Total interest and penalties in the Consolidated Statement of Income
Total interest and penalties on the Consolidated Balance Sheet at December 31(1)

14   

118   

10   

(4)   

(4)   

6   

96   

100   

82   

103   

6 

85 

(1)

Includes $4 million, $3 million and $2 million for non-U.S. penalties in 2020, 2019 and 2018. Also includes $1 million, $1 million and $1 million for state 
penalties in 2020, 2019 and 2018.

As of December 31, 2020, 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.The potential range of 
amounts that could affect Citi’s effective tax rate is between 
$0 and $150 million.

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

2016

2009

2016

2016

2011

2014

2016

184

Non-U.S. Earnings
Non-U.S. pretax earnings approximated $13.8 billion in 2020, 
$16.7 billion in 2019 and $16.1 billion in 2018. 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, 2020, $11.0 billion of basis differences 
of non-U.S. entities was indefinitely invested. At the existing 
tax rates, additional taxes (net of U.S. FTCs) of $4.3 billion 
would have to be provided if such assertions were reversed.
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, 2020, the amount of the base year reserves 
totaled approximately $358 million (subject to a tax of $75 
million).

 
 
 
 
 
 
 
 
 
 The valuation allowance for U.S. residual DTA related to 

its non-U.S. branches increased from $0.8 billion to $1.0 
billion, primarily due to higher capitalized expenses. In 
addition, the non-U.S. local valuation allowance was reduced 
from $1.0 billion to $0.6 billion, primarily due to an expiration 
of NOL carry-forwards in a non-U.S. jurisdiction. The 
following table summarizes Citi’s DTAs:

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, 
2020

DTAs balance 
December 31, 
2019

$ 

$ 

$ 

$ 

$ 

$ 

$ 

3.0  $ 

4.4   

3.6   

7.9   

2.8 

6.3 

2.5 

6.2 

18.9  $ 

17.8 

1.5  $ 

0.1   

1.7   

3.3  $ 

0.6  $ 

2.0   

2.6  $ 

1.7 

0.2 

1.3 

3.2 

0.5 

1.6 

2.1 

24.8  $ 

23.1 

(1) All amounts are net of valuation allowances.
(2)

Included in the net U.S. federal DTAs of $18.9 billion as of December 
31, 2020 were deferred tax liabilities of $3.7 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. 

Deferred Tax Assets
As of December 31, 2020, Citi had a valuation allowance of 
$5.2 billion, composed of valuation allowances of $1.0 billion 
on its general basket FTC carry-forwards, $2.4 billion on its 
branch basket FTC carry-forwards, $1.0 billion on its U.S. 
residual DTA related to its non-U.S. branches, $0.6 billion on 
local non-U.S. DTAs and $0.2 billion on state net operating 
loss carry-forwards. The amount of Citi’s valuation 
allowances (VA) may change in future years. 

In 2020, Citi’s VA for carry-forward FTCs in its branch 

basket decreased by $1.0 billion and the related VA for the 
U.S. tax effect on non-U.S. branch temporary differences 
increased by $0.2 billion. Of this total branch-related change 
of $0.8 billion, $0.6 billion impacted the tax provision as 
discussed below. The remainder of the branch basket-related 
VA decrease of $0.2 billion was primarily due to carry-
forward expirations and changes in foreign exchange rates. 
The level of branch pretax income, the local branch tax rate 
and the allocations of Overall Domestic Loss (ODL) and 
expenses for U.S. tax purposes to the branch basket are the 
main factors in determining the branch VA. Citi computed 
these factors for 2020. While the COVID-19 pandemic 
reduced branch earnings, the allocated ODL was not 
diminished since a large portion of the pandemic losses will 
not be recognizable for U.S. taxable income until a future 
period. In addition, lower than forecasted U.S. interest rates 
resulted in a lower allocation of interest expense to non-U.S. 
branches. The combination of the factors enumerated are 
reflected in the VA release of $0.5 billion in Citi’s full-year 
effective tax rate. Citi also released branch basket VA of 
$0.1 billion in the fourth quarter, with respect to future years, 
based upon Citi’s Operating Plan and estimates of future 
branch basket factors, as outlined above.

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., 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 by $0.1 billion to 
$1.0 billion, primarily due to the expiration of carry-forwards 
in 2020. In the general FTC basket, foreign source income, an 
important driver in the utilization of FTC carry-forwards for 
the current year and future years, has been reduced due to the 
compression in interest rate spreads. The pandemic has 
otherwise reduced U.S. income, which impacts ODL usage 
and, correspondingly, the utilization of FTC carry-forwards. 
Accordingly, management identified actions, which became 
prudent due to the effects of the pandemic, to increase future 
foreign source income and U.S. taxable income. These 
planning actions include geographic asset movements, deferral 
of future FTC recognition and capitalization of expenses for 
tax purposes, resulting in no tax provision change to Citi’s 
general basket VA in 2020. In light of the pandemic, Citi will 
continue to monitor its forecasts and mix of earnings, which 
could affect Citi’s valuation allowance against FTC carry-
forwards. Citi continues to look for additional actions that are 
prudent and feasible, taking into account client, regulatory and 
operational considerations.

185

 
 
 
 
 
 
 
 
 
 
 
 
 
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 $24.8 billion at December 31, 2020 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).

The majority of Citi’s U.S. federal net operating loss 
carry-forward and all of its New York State and City net 
operating loss carry-forwards, are subject to a carry-forward 
period of 20 years. This provides enough time to fully utilize 
the DTAs pertaining to these 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 $26 billion as of December 31, 
2020 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 $4.4 billion 
($7.8 billion before valuation allowance) as of December 31, 
2020, compared to $6.3 billion as of December 31, 2019. 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)
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
2032
2033
2034
2035
2036
2037
2038
2039
2040
Total U.S. tax return general business 
credit carry-forwards
U.S. subsidiary separate federal NOL 
carry-forwards
2027
2028
2030
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, 2020

December 
31, 2019

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

—  $ 
—   
2.3   
0.4   
1.4   
1.2   

5.3  $ 

—  $ 
0.7   
1.0   
0.6   
0.2   

2.5  $ 

0.3  $ 
0.3   
0.2   
0.2   
0.2   
0.5   
0.5   
0.7   
0.7   

3.6  $ 

0.1  $ 
0.1   
0.3   
1.5   
2.0   
3.3   
2.1   
1.0   
3.9   

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 

14.3  $ 

13.5 

8.1  $ 

9.9 

8.7  $ 

10.0 

1.2  $ 

1.5 

186

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 

2020

2019

2018

Income from continuing operations before attribution of noncontrolling interests

$ 

11,107  $ 

19,471  $ 

18,088 

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

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

40   

66   

35 

$ 

11,067  $ 

19,405  $ 

18,053 

(20)   

(4)   

(8) 

$ 

11,047  $ 

19,401  $ 

18,045 

1,095   

1,109   

1,174 

$ 

9,952  $ 

18,292  $ 

16,871 

73   

121   

200 

$ 

9,879  $ 

18,171  $ 

16,671 

2,085.8   

2,249.2   

2,493.3 

$ 

$ 

$ 

4.75  $ 

8.08  $ 

(0.01)   

—   

4.74  $ 

8.08  $ 

6.69 

— 

6.69 

9,879  $ 

18,171  $ 

16,671 

30   

33   

— 

$ 

9,909  $ 

18,204  $ 

16,671 

Weighted-average common shares outstanding applicable to basic EPS (in millions)

$  2,085.8  $  2,249.2  $  2,493.3 

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

0.1   

13.1   

0.1   

16.0   

0.1 

1.4 

2,099.0   

2,265.3   

2,494.8 

$ 

$ 

4.73  $ 

8.04  $ 

(0.01)   

—   

4.72  $ 

8.04  $ 

6.69 

— 

6.68 

(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 2020, weighted-average options to purchase 0.1 million shares of common stock were outstanding but not included in the computation of earnings per 

share because the weighted-average exercise price of $56.25 per share was anti-dilutive. During 2019, no significant options to purchase shares of common stock 
were outstanding. During 2018, weighted-average options to purchase 0.5 million shares of common stock were outstanding but not included in the computation 
of earnings per share because the weighted-average exercise prices of $145.69 per share was anti-dilutive.

(4) Due to rounding, weighted-average common shares outstanding applicable to basic EPS and the effect of dilutive securities may not sum to weighted-average 

common shares outstanding applicable to diluted EPS.

187

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
$ 

181,194  $ 

155,164 

A substantial portion of the resale and repurchase 

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, net(1)
Allowance for credit losses on 
securities purchased and 
borrowed(2)
Total, net of allowance

December 31,

2020

2019

$ 

204,655  $ 

169,874 

90,067   

81,448 

$ 

294,722  $ 

251,322 

(10)   

— 

$ 

294,712  $ 

251,322 

Securities loaned and sold under agreements to 

repurchase, at their respective carrying values, consisted of 
the following:

In millions of dollars

Securities sold under agreements 
to repurchase

Deposits received for securities 
loaned
Total, net(1)

December 31,

2020

2019

18,331   

11,175 

$ 

199,525  $ 

166,339 

(1)   The above tables do not include securities-for-securities lending 

transactions of $6.8 billion and $6.3 billion at December 31, 2020 and 
2019, 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. 

(2)  See Note 15 to the Consolidated Financial Statements for further 

information.

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 

188

maintain contractual margin protection. For resale and 
repurchase agreements, when necessary, the Company posts 
additional collateral in order to maintain contractual margin 
protection. 

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.

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, 2020

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

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)

$ 

$ 

362,025  $ 

157,370  $ 

96,425   

6,358   

458,450  $ 

163,728  $ 

204,655  $ 

90,067   

294,722  $ 

159,232  $ 

45,423 

13,474   

76,593 

172,706  $ 

122,016 

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)

$ 

$ 

338,564  $ 

157,370  $ 

24,689   

6,358   

363,253  $ 

163,728  $ 

181,194  $ 

18,331   

199,525  $ 

95,563  $ 

85,631 

7,982   

10,349 

103,545  $ 

95,980 

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, 2019

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  $ 

35,724 

27,067   

54,381 

161,217  $ 

90,105 

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 

189

 
 
 
 
 
 
(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, 2020

Open and 
overnight

Up to 30 days

31–90 days

Greater than 
90 days

Total

160,754  $ 

98,226  $ 

41,679  $ 

37,905  $ 

338,564 

17,038   

3   

2,770   

4,878   

24,689 

177,792  $ 

98,229  $ 

44,449  $ 

42,783  $ 

363,253 

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 

$ 

$ 

$ 

$ 

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

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

In millions of dollars

State and municipal securities

Foreign government securities

Corporate bonds

Equity securities

Mortgage-backed securities

Asset-backed securities

Other

Total

U.S. Treasury and federal agency securities

$ 

100,781  $ 

Repurchase 
agreements

As of December 31, 2020
Securities lending 
agreements

Total

112,437  $ 

664   

130,017   

20,149   

21,497   

45,566   

3,307   

4,927   

—  $ 

2   

194   

78   

24,149   

—   

—   

266   

112,437 

666 

130,211 

20,227 

45,646 

45,566 

3,307 

5,193 

$ 

338,564  $ 

24,689  $ 

363,253 

Repurchase 
agreements

As of December 31, 2019
Securities lending 
agreements

Total

1,938   

95,880   

18,761   

12,010   

28,458   

4,873   

3,863   

27  $ 

5   

272   

249   

19,069   

—   

—   

152   

100,808 

1,943 

96,152 

19,010 

31,079 

28,458 

4,873 

4,015 

$ 

266,564  $ 

19,774  $ 

286,338 

190

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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
Receivables from customers

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)

December 31,

2020

2019

$ 

18,097  $ 

15,912 

26,709   

44,806  $ 

39,319  $ 

11,165   

50,484  $ 

23,945 

39,857 

37,613 

10,988 

48,601 

$ 

$ 

$ 

(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.

191

 
 
13.  INVESTMENTS 

The following table presents Citi’s investments by category:

In millions of dollars

Debt securities available-for-sale (AFS)
Debt securities held-to-maturity (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,

2020

2019

$ 

335,084  $ 

104,943   

280,265 

80,775 

515   

551   

962   

5,304   

$ 

447,359  $ 

458 

704 

700 

5,661 

368,563 

(1) Carried at adjusted amortized cost basis, net of any ACL.
(2) Unrealized gains and losses are recognized in earnings.
(3)

Impairment losses and adjustments to the carrying value as a result of observable price changes are recognized in earnings. See “Non-Marketable Equity 
Securities Not Carried at Fair Value” below.

(4) Represents shares issued by the Federal Reserve Bank, Federal Home Loan Banks and certain exchanges of which Citigroup is a member.

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 on investments

2020

2019

2018

$ 

$ 

7,554  $ 

9,269  $ 

8,704 

301   

134   

404   

187   

521 

269 

7,989  $ 

9,860  $ 

9,494 

The following table presents realized gains and losses on the sales of investments, which exclude impairment losses:

In millions of dollars

Gross realized investment gains

Gross realized investment losses

Net realized gains on sales of investments

2020

2019

2018

$ 

$ 

1,895  $ 

1,599  $ 

(139)   

(125)   

1,756  $ 

1,474  $ 

682 

(261) 

421 

192

 
 
 
 
 
 
 
 
Total U.S. Treasury and federal 
agency securities

State and municipal

Foreign government

Corporate
Asset-backed securities(1)
Other debt securities

The Company from time to time may sell certain debt 
securities that were classified as HTM. These sales are 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 impairment on the securities. In 2018, $61 million of 
HTM debt securities were sold and $8 million of HTM debt 
securities were reclassified to AFS in accordance with 
generally accepting accounting standards. There were no such 
activities during 2019 and 2020. 

Debt Securities Available-for-Sale
The amortized cost and fair value of AFS debt securities were as follows:

December 31, 2020

Amortized
cost

Gross
unrealized
gains

Gross
unrealized
losses

Allowance 
for credit 
losses

Fair
value

Amortized
cost

December 31, 2019

Gross
unrealized
gains

Gross
unrealized
losses

Fair
value

$ 

42,836  $ 

1,134  $ 

52  $ 

—  $  43,918  $ 

34,963  $ 

547  $ 

280  $  35,230 

568   

49   

3   

1   

—   

—   

—   

—   

571   

50   

789   

75   

3   

—   

—   

—   

792 

75 

$ 

43,453  $ 

1,138  $ 

52  $ 

—  $  44,539  $ 

35,827  $ 

550  $ 

280  $  36,097 

In millions of dollars

Debt securities AFS
Mortgage-backed securities(1)
U.S. government-sponsored 
agency guaranteed

Non-U.S. residential

Commercial

Total mortgage-backed 
securities

U.S. Treasury and federal 
agency securities

U.S. Treasury

Agency obligations

$  144,094  $ 

2,108  $ 

50   

1   

$  144,144  $ 

2,109  $ 

$ 

3,753  $ 

13  $ 

49  $ 

—   

49  $ 

47  $ 

—  $ 146,153  $  106,429  $ 

50  $ 

380  $ 106,099 

—   

51   

5,336   

3   

20   

5,319 

—  $ 146,204  $  111,765  $ 

—  $  3,719  $ 

5,024  $ 

53  $ 

43  $ 

400  $ 111,418 

89  $  4,978 

123,467   

1,623   

122   

—    124,968   

110,958   

586   

241    111,303 

10,444   

152   

277   

4,871   

5   

5   

91   

4   

—   

5    10,500   

11,266   

—   

—   

278   

524   

4,876   

4,729   

52   

—   

1   

101    11,217 

2   

522 

—   

4,730 

Total debt securities AFS

$  330,409  $ 

5,045  $ 

365  $ 

5  $ 335,084  $  280,093  $ 

1,285  $ 

1,113  $ 280,265 

(1) The Company invests in mortgage- and asset-backed securities, which are typically issued by VIEs through securitization transactions. 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, 2020, the amortized cost of fixed 
income securities exceeded their fair value by $365 million. 
Of the $365 million, $280 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, 70% 
were rated investment grade; and $85 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, 78% were rated investment grade. Of the $85 million, 
$61 million represents foreign government securities.

193

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020

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

U.S. government-sponsored agency guaranteed

$ 

3,588  $ 

30  $ 

298  $ 

22  $ 

3,886  $ 

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, 2019

Debt securities AFS

Mortgage-backed securities

State and municipal

Foreign government

Corporate

Asset-backed securities

Other debt securities

Total debt securities AFS

U.S. government-sponsored agency guaranteed

$ 

9,780  $ 

242  $ 

1,877  $ 

38  $  11,657  $ 

Non-U.S. residential

Commercial

Total mortgage-backed securities

U.S. Treasury and federal agency securities

U.S. Treasury

Agency obligations

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   

Total U.S. Treasury and federal agency securities

$  46,265  $ 

250  $  30,804  $ 

150  $  77,069  $ 

52 

— 

— 

52 

49 

— 

49 

47 

280 

— 

— 

280 

380 

20 

400 

89 

241 

101 

2 

— 

1   

7   

—   

—   

—   

4   

—   

—   

1   

11   

$ 

3,596  $ 

30  $ 

302  $ 

22  $ 

3,898  $ 

$  25,031  $ 

50   

$  25,081  $ 

$ 

3,214  $ 

29,344   

1,083   

194   

182   

49  $ 

—   

49  $ 

47  $ 

61   

90   

3   

—   

—  $ 

—   

—  $ 

24  $ 

—  $  25,031  $ 

—   

50   

—  $  25,081  $ 

—  $ 

3,238  $ 

3,502   

61   

32,846   

122 

24   

39   

—   

1   

1   

—   

1,107   

233   

182   

91 

4 

— 

$  62,694  $ 

280  $ 

3,891  $ 

85  $  66,585  $ 

365 

$ 

362  $ 

62  $ 

266  $ 

27  $ 

628  $ 

35,485   

149   

8,170   

92   

43,655   

2,916   

112   

1,307   

98   

1   

—   

123   

166   

—   

3   

1   

3,039   

278   

—   

1,307   

$  96,451  $ 

802  $  41,434  $ 

311  $  137,885  $ 

1,113 

194

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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,

2020

2019

Amortized
cost

Fair
value

Amortized
cost

Fair
value

$ 

27  $ 

27  $ 

20  $ 

567   

688   

571   

757   

573   

594   

20 

574 

626 

42,171   

43,184   

34,640   

34,877 

$ 

43,453  $ 

44,539  $ 

35,827  $ 

36,097 

$ 

34,834  $ 

34,951  $ 

40,757  $ 

40,688 

108,160   

110,091   

70,128   

69,850 

1,150   

1,162   

—   

—   

854   

26   

851 

29 

$  144,144  $  146,204  $  111,765  $  111,418 

$ 

427  $ 

428  $ 

932  $ 

189   

276   

198   

267   

714   

195   

2,861   

2,826   

3,183   

$ 

3,753  $ 

3,719  $ 

5,024  $ 

932 

723 

215 

3,108 

4,978 

$ 

48,133  $ 

48,258  $ 

42,611  $ 

42,666 

67,365   

68,586   

58,820   

59,071 

5,908   

2,061   

6,011   

2,113   

8,192   

1,335   

8,198 

1,368 

$  123,467  $  124,968  $  110,958  $  111,303 

$ 

6,661  $ 

6,665  $ 

7,306  $ 

7,814   

1,018   

99   

7,891   

1,034   

64   

8,279   

818   

116   

7,311 

8,275 

797 

86 

$ 

15,592  $ 

15,654  $ 

16,519  $ 

16,469 

$  330,409  $  335,084  $  280,093  $  280,265 

(1)

(2)
(3)

Includes mortgage-backed securities of U.S. government-sponsored agencies. The Company invests in mortgage- and asset-backed securities, which are typically 
issued by VIEs through securitization transactions.
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.

195

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Debt Securities Held-to-Maturity

The carrying value and fair value of debt securities HTM were as follows:

51,151 

1,126 

825 

53,102 

21,242 

9,929 

2,022 

21,495 

107,790 

47,663 

1,044 

583 

49,290 

9,531 

1,970 

21,432 

82,223 

In millions of dollars

December 31, 2020

Debt securities HTM
Mortgage-backed securities(2)

U.S. government-sponsored agency guaranteed

Non-U.S. residential

Commercial

Total mortgage-backed securities
U.S. Treasury securities(3)
State and municipal

Foreign government
Asset-backed securities(2)
Total debt securities HTM, net

December 31, 2019

Debt securities HTM
Mortgage-backed securities(2)(4)

Amortized cost, 
net(1)

Gross
unrealized
gains

Gross
unrealized
losses

Fair
value

$ 

$ 

$ 

49,004  $ 

2,162  $ 

1,124   

825   

50,953  $ 

21,293  $ 

9,185   

1,931   

21,581   

3   

1   

2,166  $ 

4  $ 

755   

91   

6   

15  $ 

1   

1   

17  $ 

55  $ 

11   

—   

92   

$ 

104,943  $ 

3,022  $ 

175  $ 

U.S. government-sponsored agency guaranteed

Non-U.S. residential

Commercial

Total mortgage-backed securities
State and municipal(5)
Foreign government
Asset-backed securities(2)
Total debt securities HTM

$ 

$ 

$ 

$ 

46,637  $ 

1,047  $ 

1,039   

582   

48,258  $ 

9,104  $ 

1,934   

21,479   

80,775  $ 

5   

1   

1,053  $ 

455  $ 

37   

12   

21  $ 

—   

—   

21  $ 

28  $ 

1   

59   

1,557  $ 

109  $ 

(1) Amortized cost is reported net of ACL of $86 million at December 31, 2020. There was no allowance as of December 31, 2019 due to CECL not being adopted 

until January 1, 2020.

(2) The Company invests in mortgage- and asset-backed securities. These securitizations are generally considered VIEs. The Company’s maximum exposure to loss 

(3)

(4)

(5)

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 August 2020, Citibank transferred $13.1 billion of investments in U.S. Treasury securities from AFS classification to HTM classification in accordance with 
ASC 320. At the time of transfer, the securities were in an unrealized gain position of $144 million. The gain amounts will remain in AOCI and will be amortized 
over the remaining life of the securities.
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.

196

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 at December 31, 2019:

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

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  $ 

109 

21 

28 

1 

59 

Note: Excluded from the gross unrecognized losses presented in the table above are $(582) million of net unrealized losses recorded in AOCI as of December 31, 2019, 
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.

197

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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(2)
Total

U.S. Treasury 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 HTM

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

December 31,

2020

2019

Amortized 
cost(1)

Fair value

Amortized 
cost

Fair value

81  $ 

463   

1,699   

48,710   

50,953  $ 

81  $ 

17  $ 

477   

1,873   

458   

1,662   

50,671   

46,121   

53,102  $ 

48,258  $ 

17 

463 

1,729 

47,081 

49,290 

—  $ 

—   

—   

—   

—  $ 

2  $ 

123   

597   

—  $ 

—  $ 

18,955   

2,338   

—   

19,127   

2,115   

—   

21,293  $ 

21,242  $ 

6  $ 

139   

818   

8,222   

9,185  $ 

361  $ 

1,570   

—   

—   

6  $ 

142   

869   

8,912   

8,382   

9,929  $ 

9,104  $ 

360  $ 

650  $ 

1,662   

1,284   

—   

—   

—   

—   

— 

— 

— 

— 

— 

26 

160 

590 

8,755 

9,531 

652 

1,318 

— 

— 

1,931  $ 

2,022  $ 

1,934  $ 

1,970 

—  $ 

—   

11,795   

9,786   

—  $ 

—   

—  $ 

—   

15,020   

8,545   

6,475   

12,934   

21,581  $ 

21,495  $ 

21,479  $ 

104,943  $ 

107,790  $ 

80,775  $ 

— 

— 

8,543 

12,889 

21,432 

82,223 

(1) Amortized cost is reported net of ACL of $86 million at December 31, 2020. There was no allowance as of December 31, 2019 due to CECL not being adopted 

until January 1, 2020.
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.

(2)
(3)

HTM Debt Securities Delinquency and Non-Accrual
Details
Citi did not have any HTM securities that were delinquent or
on non-accrual status at December 31, 2020.

There were no purchased credit-deteriorated HTM debt
securities held by the Company as of December 31, 2020.

198

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Evaluating Investments for Impairment

AFS Debt Securities

Overview—AFS Debt Securities
The Company conducts periodic reviews of all AFS debt 
securities with unrealized losses to evaluate whether the 
impairment resulted from expected credit losses or from other 
factors and to evaluate the Company’s intent to sell such 
securities.

An AFS debt security is impaired when the current fair 

value of an individual AFS debt security is less than its 
amortized cost basis.

The Company recognizes the entire difference between 
amortized cost basis and fair value in earnings for impaired 
AFS debt securities that Citi has an intent to sell or for which 
Citi believes it will more-likely-than-not be required to sell 
prior to recovery of the amortized cost basis. However, for 
those AFS 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 by recording an 
ACL. Any remaining fair value decline for such securities is 
recorded in AOCI. The Company does not consider the length 
of time that the fair value of a security is below its amortized 
cost when determining if a credit loss exists.

For AFS debt securities, credit losses exist where Citi 
does not expect to receive contractual principal and interest 
cash flows sufficient to recover the entire amortized cost basis 
of a security. The ACL is limited to the amount by which the 
AFS debt security’s amortized cost basis exceeds its fair value. 
The allowance is increased or decreased if credit conditions 
subsequently worsen or improve. Reversals of credit losses are 
recognized in earnings.

The Company’s review for impairment of AFS debt 

securities generally entails:

•
•

•

identification and evaluation of impaired investments;
consideration of evidential matter, including an evaluation 
of factors or triggers that could cause individual positions 
to qualify as credit impaired and those that would not 
support credit impairment; and
documentation of the results of these analyses, as required 
under business policies.

The sections below describe the Company’s process for 
identifying expected credit impairments for debt security types 
that have the most significant unrealized losses as of 
December 31, 2020.

Mortgage-Backed Securities
Citi records no allowances for credit losses on U.S. 
government-agency-guaranteed mortgage-backed securities, 
because the Company expects to incur no credit losses in the 
event of default due to a history of incurring no credit losses 
and due to the nature of the counterparties.

State and Municipal Securities
The process for estimating credit losses in Citigroup’s AFS 
state and municipal bonds is primarily based on a credit 
analysis that incorporates third-party credit ratings. Citi 
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 Aa2/
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 AFS state and municipal bonds with unrealized losses 

that Citi plans to sell, or would more-likely-than-not be 
required to sell, the full impairment is recognized in earnings. 
For AFS state and municipal bonds where Citi has no intent to 
sell and it is more-likely-than-not that the Company will not 
be required to sell, Citi records an allowance for expected 
credit losses for the amount it expects not to collect, capped at 
the difference between the bond’s amortized cost basis and 
fair value.

Equity Method Investments
Management assesses equity method investments that have 
fair values that are lower than their respective carrying values 
for other-than-temporary impairment (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.

199

Recognition and Measurement of Impairment
The following tables present total impairment 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 impairment 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 more-likely-than-not be required to sell or will be subject to an issuer call 
deemed probable of exercise

Total impairment 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 impairment 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 more-likely-than-not be required to sell or will be subject to an issuer call 
deemed probable of exercise

Total impairment losses recognized in earnings

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 impairment 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 more-likely-than-not be required to sell or will be subject to an issuer call deemed 
probable of exercise

Total impairment losses recognized in earnings

(1) For the year ended December 31, 2018, amounts represent AFS debt securities. 

Year ended
 December 31, 2020

AFS

Other
assets

Total

—  $ 

—   

—  $ 

109   

109  $ 

—  $ 

—   

—  $ 

—   

—  $ 

— 

— 

— 

109 

109 

Year ended
 December 31, 2019

AFS

HTM

Other
assets

Total

1  $ 
—   

—  $ 
—   

1  $ 
—   

1  $ 

—  $ 

1  $ 

20   

21  $ 

—   

—  $ 

1   

2  $ 

Year ended
December 31, 2018

AFS(1)

HTM

Other
assets

Total

—  $ 

—   

—  $ 

—   

—  $ 

—   

—  $ 

—  $ 

—  $ 

2 
— 

2 

21 

23 

— 

— 

— 

125   

125  $ 

—   

—  $ 

—   

—  $ 

125 

125 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

200

 
 
 
 
 
 
The following presents the credit-related impairments recognized in earnings for AFS securities held that the Company does not intend 
to sell nor will likely be required to sell at December 31, 2020:

Allowance for Credit Losses on AFS Debt Securities

In millions of dollars

Allowance for credit losses at beginning of year

Less: Write-offs

Recoveries of amounts written-off

Net credit losses (NCLs)

NCLs

Net reserve builds on securities that did not have previous reserves

Net reserve builds (releases) on securities that had previous reserves

Total provision for credit losses

Initial allowance on newly purchased credit-deteriorated securities during the year

Allowance for credit losses at end of year

Year ended December 31, 2020

Foreign 
government

Corporate

Total AFS

$ 

$ 

$ 

$ 

$ 

—  $ 

—   

—   

—  $ 

—  $ 

3   

(3)   

—  $ 

—   

—  $ 

—  $ 

—   

2   

2  $ 

(2)  $ 

5   

—   

3  $ 

—   

5  $ 

— 

— 

2 

2 

(2) 

8 

(3) 

3 

— 

5 

The following are 12-month rollforwards of the credit-related impairments recognized in earnings for AFS and HTM debt securities 
held that the Company does not intend to sell nor will likely be required to sell at December 31, 2019:

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 

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

(1)  Primarily consists of Prime securities.

201

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. 

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, 2020 and 2019:

In millions of dollars

Measurement alternative:

December 31, 
2020

December 31, 
2019

Carrying value

$ 

962  $ 

700 

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(1):
Impairment losses
Downward changes for 
observable prices
Upward changes for observable 
prices

$ 

Years ended December 31,

2020

2019

56  $ 

19   

144   

9 

16 

123 

(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, 2020

$ 

68 

53 
486 

A similar impairment analysis is performed for non-
marketable equity securities carried at cost. For the years 
ended December 31, 2020 and 2019, there was no impairment 
loss recognized in earnings for non-marketable equity 
securities carried at cost.

202

 
 
 
 
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, 
2020

December 31, 
2019

December 31, 
2020

December 31, 
2019

$ 

$ 

123  $ 
9   

20   
152  $ 

134  $ 
10   

26   
170  $ 

62  $ 
20   

—   
82  $ 

62 
18 

— 
80 

—
—

—

—
—

—

(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)

203

 
 
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) 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. 

204

The following tables provide Citi’s consumer loans by type:

Consumer Loans, Delinquencies and Non-Accrual Status at December 31, 2020

Total
current(1)(2)

30–89 days
past due(3)(4)

≥ 90 days
past due(3)(4)

Past due
government
guaranteed(5)

Total
loans

Non-
accrual 
loans for 
which there 
are no loan 
loss 
reserves

Non-
accrual 
loans for 
which 
there are 
loan loss 
reserves

Total
non-
accrual

90 days 
past due 
and accruing

$  46,471  $ 
6,829   
  127,827   
4,472   
$  185,599  $ 

$  39,557  $ 
21,718   
35,925   
$  97,200  $ 
$  282,799  $ 

402  $ 
78   
1,228   
27   
1,735  $ 

213  $ 
429   
319   
961  $ 
2,696  $ 

381  $ 
221   
1,330   
10   
1,942  $ 

199  $ 
545   
134   
878  $ 
2,820  $ 

524  $  47,778  $ 
—   
7,128   
—    130,385   
—   
4,509   
524  $ 189,800  $ 

—  $  39,969  $ 
—    22,692   
—    36,378   
—  $  99,039  $ 
524  $ 288,839  $ 

136  $ 
72   
—   
2   
210  $ 

645  $ 
509  $ 
379   
307   
—   
—   
33   
35   
849  $  1,059  $ 

486  $ 
486  $ 
—  $ 
384   
384   
—   
—   
212   
212   
—  $  1,082  $  1,082  $ 
210  $  1,931  $  2,141  $ 

332 
— 
1,330 
— 
1,662 

— 
376 
— 
376 
2,038 

In millions of dollars
In North America offices(6)

Residential first mortgages(7)
Home equity loans(8)(9)
Credit cards
Personal, small business and other

Total
In offices outside North America(6)
Residential first mortgages(7)
Credit cards
Personal, small business and other

Total
Total Citigroup(10)

Consumer Loans, Delinquencies and Non-Accrual Status at December 31, 2019

In millions of dollars
In North America offices(6)

Residential first mortgages(7)
Home equity loans(8)(9)
Credit cards

Total
current(1)(2)

30–89 days
past due(3)

≥ 90 days
past due(3)

Past due
government
guaranteed(5)

Total
loans

Total
non-
accrual

90 days 
past due 
and accruing

$  45,942  $ 

8,860   

411  $ 

174   

221  $ 

189   

434  $  47,008  $ 

479  $ 

—   

9,223   

405   

  145,477   

1,759   

1,927   

—    149,163   

288 

— 

1,927 

— 

—   

21   

Personal, small business and other

3,641   

44   

14   

—   

3,699   

Total
In offices outside North America(6)
Residential first mortgages(7)
Credit cards

Personal, small business and other

Total
Total Citigroup(10)

$  203,920  $ 

2,388  $ 

2,351  $ 

434  $ 209,093  $ 

905  $ 

2,215 

$  37,654  $ 

210  $ 

160  $ 

—  $  38,024  $ 

425  $ 

25,111   

36,118   

426   

272   

372   

132   

—    25,909   

—    36,522   

310   

176   

$  98,883  $ 

908  $ 

664  $ 

—  $ 100,455  $ 

911  $ 

— 

242 

— 

242 

$  302,803  $ 

3,296  $ 

3,015  $ 

434  $ 309,548  $  1,816  $ 

2,457 

Includes $14 million and $18 million at December 31, 2020 and 2019, 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) Loans modified under Citi’s consumer relief programs continue to be reported in the same delinquency bucket they were in at the time of modification, and thus 
almost all would not be reported as 30-89 or 90+ days past due for the duration of the programs (which have various durations, and certain of which may be 
renewed by the customer).

(5) Consists of residential first mortgages that are guaranteed by U.S. government-sponsored agencies that are 30–89 days past due of $0.2 billion and $0.1 billion and 

90 days or more past due of $0.4 billion and $0.3 billion at December 31, 2020 and 2019, respectively.

Includes approximately $0.1 billion and $0.1 billion at December 31, 2020 and 2019, respectively, of residential first mortgage loans in process of foreclosure.
Includes approximately $0.1 billion and $0.1 billion at December 31, 2020 and 2019, respectively, of home equity loans in process of foreclosure.

(6) North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America.
(7)
(8)
(9) Fixed-rate home equity loans and loans extended under home equity lines of credit, which are typically in junior lien positions.
(10) Consumer loans are net of unearned income of $749 million and $783 million at December 31, 2020 and 2019, respectively. Unearned income on consumer loans 

primarily represents unamortized origination fees and costs, premiums and discounts.

205

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Interest Income Recognized for Non-Accrual Consumer Loans

In millions of dollars
In North America offices(1)

Residential first mortgages

Home equity loans

Credit cards

Personal, small business and other

Total
In offices outside North America(1)

Residential first mortgages

Credit cards

Personal, small business and other

Total

Total Citigroup

Interest income

For the year ended 
December 31, 2020

$ 

$ 

$ 

$ 

$ 

15 

8 

— 

— 

23 

— 

— 

— 

— 

23 

(1) North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America.

During the years ended December 31, 2020 and 2019, the Company sold and/or reclassified to HFS $414 million and $2,857 million, 
respectively, of consumer loans.

206

 
 
 
 
 
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 Fair Isaac Corporation (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 by year of origination. 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)

December 31, 2020

In millions of dollars

Residential first mortgages

2020

2019

2018

2017

2016

Prior

Total residential first mortgages
Credit cards(2)
Home equity loans (pre-reset)

Home equity loans (post-reset)

Total home equity loans

Installment and other

2020

2019

2018

2017

2016

Prior

Personal, small business and other

Total

Less than
680

680 to 760

Greater
than 760

FICO not 
available

Total loans

$ 

187  $ 

3,741  $ 

9,052 

150

246

298

323

1,708

1,857

655

846

1,368

4,133

5,384

1,227

1,829

3,799

9,105

$ 

$ 

$ 

$ 

$ 

$ 

$ 

2,912  $ 

12,600  $ 

30,396  $ 

1,870  $ 

47,778 

26,227  $ 

52,778  $ 

49,767  $ 

1,041  $ 

129,813 

292  $ 

1,014  $ 

1,055   

1,569   

1,657 

1,524 

1,347  $ 

2,583  $ 

3,181  $ 

17  $ 

7,128 

23  $ 

79   

82   

26   

10   

214   

434  $ 

58  $ 

106   

80   

27   

9   

393   

673  $ 

95 

134 

84 

30 

8 

529 

880  $ 

2,522  $ 

4,509 

30,920  $ 

68,634  $ 

84,224  $ 

5,450  $ 

189,228 

(1) The FICO bands in the tables are consistent with general industry peer presentations.
(2) Excludes $572 million of balances related to Canada.

FICO score distribution in U.S. portfolio(1)

In millions of dollars
Residential first mortgages
Credit cards(2)
Home equity loans
Personal, small business and other
Total

Less than
680

680 to 760

December 31, 2019
Greater
than 760

FICO not 
available

Total loans

$ 

$ 

3,608  $ 
33,290   
1,901   
564   
39,363  $ 

13,264  $ 
59,536   
3,530   
907   
77,237  $ 

28,442  $ 
52,935   
3,732   
1,473   
86,582  $ 

1,694  $ 
2,773   
60   
755   
5,282  $ 

47,008 
148,534 
9,223 
3,699 
208,464 

(1) The FICO bands in the tables are consistent with general industry peer presentations. 
(2) Excludes $629 million of balances related to Canada.

207

 
 
 
 
 
 
 
 
 
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

December 31, 2020

In millions of dollars

Residential first mortgages

   2020

   2019

   2018

   2017

   2016

   Prior

Total residential first mortgages

Home equity loans (pre-reset)

Home equity loans (post-reset)

Total home equity loans

Total

Less than
 or equal 
to 80%

> 80% but less
than or equal 
to 100%

Greater
than
100%

LTV not 
available

Total

— 

2 

11 

4 

2 

16 

$ 

11,447  $ 

1,543  $ 

7,029   

1,617   

2,711   

5,423   

14,966   

43,193  $ 

2,876  $ 

3,782   

6,658  $ 

$ 

$ 

$ 

$ 

376   

507   

269   

84   

66   

50  $ 

290   

340  $ 

2,845  $ 

35  $ 

1,705  $ 

47,778 

16 

58 

74  $ 

109  $ 

56  $ 

7,128 

1,761  $ 

54,906 

49,851  $ 

3,185  $ 

LTV distribution in U.S. portfolio

December 31, 2019

In millions of dollars

Residential first mortgages

Home equity loans

Total

Less than 
or
equal to 
80%

> 80% but less
than or equal to
100%

Greater
than
100%

LTV not 
available

Total

$ 

41,993  $ 

3,313  $ 

8,101   

829   

$ 

50,094  $ 

4,142  $ 

98  $ 

237   

335  $ 

1,604  $ 

47,008 

56   

9,223 

1,660  $ 

56,231 

208

 
 
 
 
 
 
 
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

Personal, small business and other

Total

In millions of dollars

Mortgage and real estate

Residential first mortgages

Home equity loans

Credit cards

Personal, small business and other

Total

At and for the year ended December 31, 2020

Recorded
investment(1)(2)

Unpaid
principal 
balance

Related
specific 
allowance(3)

Average
carrying 
value(4)

Interest 
income
recognized(5)

$ 

1,787  $  1,962  $ 

157  $ 

1,661  $ 

478   

651   

1,982   

2,135   

552   

552   

60   

918   

210   

527   

1,926   

463   

$ 

4,799  $  5,300  $ 

1,345  $ 

4,577  $ 

68 

13 

106 

63 

250 

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   

824   

1,931   

2,288   

419   

455   

123   

771   

135   

637   

1,890   

683   

$ 

4,608  $  5,405  $ 

1,190  $ 

5,135  $ 

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.

(2) For December 31, 2020, $211 million of residential first mortgages and $147 million of home equity loans do not have a specific allowance. For December 31, 

2019, $405 million of residential first mortgages and $212 million of home equity loans do not have a specific allowance.
Included in the Allowance for credit losses on loans.

(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.

209

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Consumer Troubled Debt Restructurings(1)

In millions of dollars, except number of 
loans modified

Number of
loans modified

For the year ended December 31, 2020(1)

Post-
modification
recorded
investment(2)(3)

Deferred
principal(4)

Contingent
principal
forgiveness(5)

Principal
forgiveness(6)

Average
interest rate
reduction

North America

Residential first mortgages

Home equity loans

Credit cards

Personal, small business and other

Total(7)
International

Residential first mortgages

Credit cards

Personal, small business and other

Total(7)

1,225  $ 

296   

215,466   

2,452   

219,439  $ 

2,542  $ 

90,694   

41,079   

134,315  $ 

209  $ 

27   

1,038   

28   

1,302  $ 

141  $ 

401   

301   

843  $ 

—  $ 

—   

—   

—   

—  $ 

3  $ 

—   

—   

3  $ 

—  $ 

—   

—   

—   

—  $ 

—  $ 

—   

—   

—  $ 

— 

— 

— 

— 

— 

— 

12 

8 

20 

 — %

 1 

 17 

 5 

 2 %

 15 

 10 

In millions of dollars, except number of 
loans modified

Number of
loans modified

For the year ended December 31, 2019

Post-
modification
recorded
investment(2)(8)

Deferred
principal(4)

Contingent
principal
forgiveness(5)

Principal
forgiveness(6)

Average
interest rate
reduction

North America

Residential first mortgages

Home equity loans

Credit cards

Personal, small business and other

Total(7)
International

Residential first mortgages

Credit cards

Personal, small business and other

Total(7)

1,122  $ 

717   

268,778   

1,719   

272,336  $ 

2,448  $ 

72,325   

29,192   

103,965  $ 

172  $ 

79   

1,165   

15   

1,431  $ 

74  $ 

288   

204   

566  $ 

—  $ 

3   

—   

—   

3  $ 

—  $ 

—   

—   

—  $ 

—  $ 

—   

—   

—   

—  $ 

—  $ 

—   

—   

—  $ 

— 

— 

— 

— 

— 

— 

10 

6 

16 

 — %

 1 

 17 

 5 

 — %

 17 

 9 

(1) The above tables do not include loan modifications that meet the TDR relief criteria in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) or 

the interagency guidance.

(2) Post-modification balances include past-due amounts that are capitalized at the modification date.
(3) Post-modification balances in North America include $13 million of residential first mortgages and $2 million of home equity loans to borrowers who have gone 
through Chapter 7 bankruptcy in the year ended December 31, 2020. These amounts include $9 million of residential first mortgages and $2 million of home 
equity loans that were newly classified as TDRs during 2020, based on previously received OCC guidance.

(4) 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.

(5) Represents portion of contractual loan principal that is non-interest bearing and, depending upon borrower performance, eligible for forgiveness.
(6) Represents portion of contractual loan principal that was forgiven at the time of permanent modification.
(7)  The above tables reflect activity for restructured loans that were considered TDRs during the year.
(8)  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.

210

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

Purchased Credit-Deteriorated Assets

Year ended December 31, 2020

Years ended December 31,

2020

2019

$ 

$ 

$ 

$ 

71  $ 

14   

317   

4   

406  $ 

26  $ 

178   

78   

282  $ 

85 

15 

301 

4 

405 

13 

142 

74 

229 

Installment and 
other

In millions of dollars

Purchase price 
Allowance for credit 
losses at acquisition 
date

Discount or 
premium attributable 
to non-credit factors

Credit 
cards Mortgages(1)
$ 

4  $ 

49  $ 

4   

—   

  —   

—   

Par value (amortized 
cost basis)

$ 

8  $ 

49  $ 

(1) 

Includes loans sold to agencies that were bought back at par due to 
repurchase agreements.

— 

— 

— 

— 

211

 
 
 
 
 
 
 
 
 
 
 
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 $0.7 billion of lease 
financing receivables, as of December 31, 2020, 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, 2020 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 $0.3 billion as of 
December 31, 2020, while the amount covered by residual 
value guarantees is $0.2 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. 

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)

December 31,
2020

December 31,
2019

Commercial and industrial

$ 

57,731  $ 

Financial institutions
Mortgage and real estate(2)
Installment and other

Lease financing

Total

In offices outside 
North America(1)

55,809   

60,675   

26,744   

673   

55,929 

53,922 

53,371 

31,238 

1,290 

$ 

201,632  $ 

195,750 

Commercial and industrial

$ 

104,072  $ 

112,668 

Financial institutions
Mortgage and real estate(2)
Installment and other

Lease financing

Governments and official 
institutions

Total

Corporate loans, net of 
unearned income(3)

$ 

$ 

32,334   

11,371   

33,759   

65   

40,211 

9,780 

27,303 

95 

3,811   

4,128 

185,412  $ 

194,185 

387,044  $ 

389,935 

(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 ($844) million and ($814) 
million at December 31, 2020 and 2019, 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 
$2.2 billion and $2.6 billion of corporate loans during the 
years ended December 31, 2020 and 2019, respectively. The 
Company did not have significant purchases of corporate loans 
classified as held-for-investment for the years ended 
December 31, 2020 or 2019.

212

 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate Loan Delinquencies and Non-Accrual Details at December 31, 2020 

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)
$ 

≥ 90 days
past due and
accruing(1)

Total past due
and accruing

Total
non-accrual(2)

Total
current(3)

Total
loans(4)

400  $ 

109  $ 

509  $ 

2,795  $ 

153,036  $ 

156,340 

668   

450   

62   

112   

65   

247   

12   

19   

733   

697   

74   

131   

92   

505   

24   

111   

86,864   

70,836   

640   

63,157   

87,689 

72,038 

738 

63,399 

6,840 

$ 

1,692  $ 

452  $ 

2,144  $ 

3,527  $ 

374,533  $ 

387,044 

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  $ 

791   

534   

58   

190   

≥ 90 days
past due and
accruing(1)

Total past due
and accruing

Total
non-accrual(2)

Total
current(3)

Total
loans(4)

93  $ 

3   

4   

9   

22   

769  $ 

1,828  $ 

164,249  $ 

166,846 

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 

(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.

213

 
 
 
 
 
 
 
 
 
 
Corporate Loans Credit Quality Indicators 

Recorded investment in loans(1)

Term loans by year of origination

Totals as of

2019

2018

2017

2016

Prior

Revolving line 
of credit 
arrangements(2)

December 
31,
2020

December 
31,
2019

7,607  $ 

5,929  $ 

3,909  $ 

2,094  $ 

8,670  $ 

25,819  $ 

92,426  $ 

110,797 

2,964   

2,106   

782   

681   

2,030   

56,239   

75,362   

6,714   

5,174   

2,568   

1,212   

1,719   

1,557   

25,737   

3,566   

4,597   

952   

780   

5,290   

31,696   

57,755   

80,533 

27,571 

58,155 

$  66,625  $  20,851  $  17,806  $ 

8,211  $ 

4,767  $  17,709  $ 

115,311  $  251,280  $ 

277,056 

4,794  $ 

4,645  $ 

2,883  $ 

1,182  $ 

4,533  $ 

23,400  $ 

61,120  $ 

54,220 

700   

654   

274   

1,919   

2,058   

1,457   

918   

725   

370   

203   

—   

4   

3   

192   

143   

—   

3   

12   

—   

18   

29   

141   

697   

186   

57   

—   

8   

2   

197   

837   

657   

223   

—   

32   

65   

2,855   

12,234   

11,269 

551   

1,986   

9,401   

6,249   

3,811 

5,734 

1,717   

2,795   

1,828 

91   

427   

9   

92   

505   

135   

50 

188 

122 

13   

15   

$  30,674  $ 

8,541  $ 

8,289  $ 

5,174  $ 

2,273  $ 

6,544  $ 

31,036  $ 

92,531  $ 

77,222 

$ 

9,823  $ 

7,121  $ 

3,533  $ 

3,674  $ 

4,300  $ 

7,942  $ 

—  $ 

36,393  $ 

31,590 

6,840   

4,067 

$  107,122  $  36,513  $  29,628  $  17,059  $  11,340  $  32,195  $ 

146,347  $  387,044  $ 

389,935 

2020

6,793   

10,874   

In millions of dollars
Investment grade(3)
Commercial and industrial(4) $  38,398  $ 
Financial institutions(4)
10,560   
Mortgage and real estate
Other(5)
Total investment grade
Non-investment grade(3)
Accrual
Commercial and industrial(4) $  19,683  $ 
Financial institutions(4)
7,413   
Mortgage and real estate
Other(5)
Non-accrual
Commercial and industrial(4)
Financial institutions

1,882   

1,407   

260   

1   

Mortgage and real estate
Other(5)
Total non-investment 
grade

Non-rated private bank 
loans managed on a 
delinquency basis(3)(6)
Loans at fair value(7)
Corporate loans, net of 
unearned income

(1) Recorded investment in a loan includes net deferred loan fees and costs, unamortized premium or discount, less any direct write-downs.
(2) There were no significant revolving line of credit arrangements that converted to term loans during the year.
(3) Held-for-investment loans are accounted for on an amortized cost basis.
(4)
Includes certain short-term loans with less than one year in tenor.
(5) Other includes installment and other, lease financing and loans to government and official institutions. 
(6) Non-rated private bank loans mainly include mortgage and real estate loans to private banking clients. 
(7) Loans at fair value include loans to commercial and industrial, financial institutions, mortgage and real estate and other.

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.

214

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020

Recorded
investment(1)

Unpaid
principal balance

Related specific
allowance

Average
carrying value(2)

Interest income 
recognized(3)

Commercial and industrial

$ 

2,795  $ 

3,664  $ 

442  $ 

2,649  $ 

Financial institutions

Mortgage and real estate

Lease financing

Other

92   

505   

24   

111   

181   

803   

24   

235   

17   

38   

—   

18   

132   

413   

34   

174   

Total non-accrual corporate loans

$ 

3,527  $ 

4,907  $ 

515  $ 

3,402  $ 

14 

— 

— 

— 

21 

35 

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 with specific allowances

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

December 31, 2020

December 31, 2019

Recorded
investment(1)

Related specific
allowance

Recorded
investment(1)

Related specific
allowance

$ 

1,523  $ 

442  $ 

714  $ 

90   

246   

—   

68   

17   

38   

—   

18   

40   

48   

—   

7   

283 

2 

10 

— 

4 

299 

Total non-accrual corporate loans with specific allowances $ 

1,927  $ 

515  $ 

809  $ 

Non-accrual corporate loans without specific allowances

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other

$ 

1,272 

  $ 

1,114 

2 

259 

24 

43 

10 

140 

41 

74 

Total non-accrual corporate loans without specific 
allowances

$ 

1,600 

N/A $ 

1,379 

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 allowances.
(3)
N/A Not applicable

Interest income recognized for the year ended December 31, 2018 was $56 million.

215

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Corporate Troubled Debt Restructurings(1)

For the year ended December 31, 2020

In millions of dollars

Commercial and industrial

Mortgage and real estate

Other

Total

For the year ended December 31, 2019

In millions of dollars

Commercial and industrial

Mortgage and real estate

Other

Total

Carrying value of 
TDRs modified during 
the period

TDRs
involving changes
in the amount
and/or timing of
principal payments(2)

TDRs
involving changes
in the amount
and/or timing of
interest payments(3)

TDRs
involving changes
in the amount
and/or timing of
both principal and
interest payments

$ 

$ 

$ 

$ 

247  $ 

19   

19   

285  $ 

—  $ 

—   

6   

6  $ 

Carrying value of 
TDRs modified 
during the period

TDRs
involving changes
in the amount
and/or timing of
principal payments(2)

TDRs
involving changes
in the amount
and/or timing of
interest payments(3)

283  $ 

16   

6   

305  $ 

19  $ 

—   

6   

25  $ 

—  $ 

—   

—   

—  $ 

—  $ 

—   

—   

—  $ 

247 

19 

13 

279 

TDRs
involving changes
in the amount
and/or timing of
both principal and
interest payments

264 

16 

— 

280 

(1) The above tables do not include loan modifications that meet the TDR relief criteria in the CARES Act or the interagency guidance.
(2) 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 uncollectible 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.
(3) 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

Commercial and industrial

Financial institutions

Mortgage and real estate

Lease financing

Other
Total(1)

TDR balances at 
December 31, 2020

TDR loans that re-defaulted 
in 2020 within one year of 
modification

TDR balances at
December 31, 2019

TDR loans that re-defaulted 
in 2019 within one year of 
modification

$ 

$ 

325  $ 

—   

92   

—   

33   

450  $ 

—  $ 

—   

—   

—   

—   

—  $ 

426  $ 

—   

79   

—   

44   

549  $ 

35 

— 

— 

— 

— 

35 

(1) The above table reflects activity for loans outstanding that were considered TDRs as of the end of the reporting period.

216

 
 
 
 
 
 
 
 
15. ALLOWANCE FOR CREDIT LOSSES

In millions of dollars

2020

2019

2018

Allowance for credit losses on loans (ACLL) at beginning of year

$ 

12,783  $ 

12,315  $ 

12,355 

Adjustments to opening balance:
     Financial instruments—credit losses (CECL)(1)
   Variable post-charge-off third-party collection costs(1)

Adjusted ACLL at beginning of year

Gross credit losses on loans

Gross recoveries on loans

Net credit losses on loans (NCLs)

NCLs

Net reserve builds for loans

Net specific reserve builds (releases) for loans

Total provision for credit losses on loans (PCLL)
Initial allowance for credit losses on newly purchased credit-deteriorated assets during the 
period

Other, net (see table below)

ACLL at end of year
Allowance for credit losses on unfunded lending commitments (ACLUC) at beginning of 
year(2)
Adjustment to opening balance for CECL adoption(1)
Provision (release) for credit losses on unfunded lending commitments
Other, net(3)
ACLUC at end of year(2)
Total allowance for credit losses on loans, leases and unfunded lending commitments

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

Other

Other, net

$ 

$ 

$ 

$ 

4,201   

(443)   

16,541  $ 

(9,263)  $ 

1,652   

(7,611)  $ 

7,611  $ 

7,635   

676   

—   

—   

12,315  $ 

(9,341)  $ 

1,573   

(7,768)  $ 

7,768  $ 

364   

86   

$ 

15,922  $ 

8,218  $ 

4   

100   

—   

18   

— 

— 

12,355 

(8,665) 

1,552 

(7,113) 

7,113 

394 

(153) 

7,354 

— 

(281) 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

24,956  $ 

12,783  $ 

12,315 

1,456  $ 

1,367  $ 

1,258 

(194)   

1,446   

(53)   

—   

92   

(3)   

— 

113 

(4) 

2,655  $ 

1,456  $ 

27,611  $ 

14,239  $ 

1,367 

13,682 

2020

2019

2018

(4)  $ 

— 

(4)  $ 

97   

7   

100  $ 

(42)  $ 

— 

(42)  $ 

60   

—   

18  $ 

(91) 

(110) 

(201) 

(60) 

(20) 

(281) 

(1) See “Accounting Changes” in Note 1 to the Consolidated Financial Statements for additional details.
(2) Represents additional credit loss reserves for unfunded lending commitments and letters of credit recorded in Other liabilities on the Consolidated Balance Sheet.
(3)

2020 includes a non-provision transfer of $68 million, representing reserves on performance guarantees. The reserves on these contracts have been reclassified out 
of the allowance for credit losses on unfunded lending commitments and into Other liabilities on the Consolidated Balance Sheet beginning in 2020.

217

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 Allowance for Credit Losses on Loans and End-of-Period Loans at December 31, 2020

In millions of dollars

ACLL at beginning of year

Adjustments to opening balance:
     Financial instruments—credit losses (CECL)(1)
   Variable post-charge-off third-party collection costs(1)

Adjusted ACLL at beginning of year

Charge-offs

Recoveries

Replenishment of net charge-offs

Net reserve builds (releases)

Net specific reserve builds (releases)
Initial allowance for credit losses on newly purchased credit-deteriorated assets 
during the year

Other

Ending balance

Allowance for credit losses on loans

Collectively evaluated

Individually evaluated

Purchased credit deteriorated

Total allowance for credit losses on loans

Loans, net of unearned income

Collectively evaluated

Individually evaluated

Purchased credit deteriorated

Held at fair value

Corporate

Consumer

Total

$ 

2,886  $ 

9,897  $ 

12,783 

(721)   

—   

4,922   

(443)   

$ 

$ 

2,165  $ 

14,376  $ 

(1,072)  $ 

(8,191)  $ 

86   

986   

2,890   

282   

—   

65   

1,566   

6,625   

4,745   

394   

4   

35   

4,201 

(443) 

16,541 

(9,263) 

1,652 

7,611 

7,635 

676 

4 

100 

$ 

$ 

$ 

$ 

5,402  $ 

19,554  $ 

24,956 

4,887  $ 

18,207  $ 

515   

—   

1,345   

2   

23,094 

1,860 

2 

5,402  $ 

19,554  $ 

24,956 

376,677  $ 

283,885  $ 

660,562 

3,527   

—   

6,840   

4,799   

141   

14   

8,326 

141 

6,854 

Total loans, net of unearned income

$ 

387,044  $ 

288,839  $ 

675,883 

(1) See “Accounting Changes” in Note 1 to the Consolidated Financial Statements for additional details.

Allowance for Credit Losses on Loans and End-of-Period Loans at December 31, 2019 

In millions of dollars

ACLL 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 credit losses on loans

Collectively evaluated

Individually evaluated

Purchased credit deteriorated

Total allowance for credit losses on loans

Loans, net of unearned income

Collectively evaluated

Individually evaluated

Purchased credit deteriorated

Held at fair value

Total loans, net of unearned income

Corporate

Consumer

Total

$ 

2,811  $ 

9,504  $ 

(487)   

95   

392   

96   

(21)   

—   

(8,854)   

1,478   

7,376   

268   

107   

18   

12,315 

(9,341) 

1,573 

7,768 

364 

86 

18 

$ 

$ 

$ 

$ 

2,886  $ 

9,897  $ 

12,783 

2,587  $ 

299   

—   

8,706  $ 

1,190   

1   

11,293 

1,489 

1 

2,886  $ 

9,897  $ 

12,783 

383,828  $ 

304,794  $ 

688,622 

2,040   

—   

4,067   

4,608   

128   

18   

6,648 

128 

4,085 

$ 

389,935  $ 

309,548  $ 

699,483 

218

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Allowance for Credit Losses on Loans at December 31, 2018 

In millions of dollars

ACLL 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 Credit Losses on HTM Debt Securities

In millions of dollars

Allowance for credit losses on HTM debt securities at beginning 
of year

Adjustment to opening balance for CECL adoption

Net credit losses (NCLs)

NCLs

Net reserve builds (releases)

Net specific reserve builds (releases)

Total provision for credit losses on HTM debt securities

Other, net

Initial allowance for credit losses on newly purchased credit-
deteriorated securities during the year

Allowance for credit losses on HTM debt securities at end of year

$ 

Allowance for Credit Losses on Other Assets

Corporate

Consumer

Total

$ 

2,943  $ 

9,412  $ 

(343)   

138   

205   

42   

(151)   

(8,322)   

1,414   

6,908   

352   

(2)   

(23)  $ 

(258)  $ 

12,355 

(8,665) 

1,552 

7,113 

394 

(153) 

(281) 

$ 

$ 

2,811  $ 

9,504  $ 

12,315 

Year ended December 31, 2020

Mortgage-
backed

State and 
municipal

Foreign 
government

Asset-
backed

Total HTM

$ 

$ 

$ 

$ 

$ 

—  $ 

—   

—  $ 

—  $ 

(2)   

—   

(2)  $ 

5  $ 

—   

3  $ 

—  $ 

61   

—  $ 

—  $ 

10   

—   

10  $ 

3  $ 

—   

74  $ 

—  $ 

4   

—  $ 

—  $ 

(2)   

—   

(2)  $ 

4  $ 

—   

6  $ 

—  $ 

5   

—  $ 

—  $ 

1   

—   

1  $ 

(3)  $ 

—   

3  $ 

— 

70 

— 

— 

7 

— 

7 

9 

— 

86 

In millions of dollars

Year ended December 31, 2020

Cash and 
due from 
banks

Deposits 
with banks

Securities borrowed 
and purchased 
under agreements 
to resell

Brokerage 
receivables

All other 
assets(1)

Total

Allowance for credit losses at beginning of year

$ 

Adjustment to opening balance for CECL adoption  

Net credit losses (NCLs)

NCLs

Net reserve builds (releases)

Total provision for credit losses

Other, net

Allowance for credit losses on other assets at end 
of year

(1) Primarily accounts receivable.

$ 

$ 

$ 

$ 

$ 

—  $ 

6   

—  $ 

—  $ 

(6)   

(6)  $ 

—  $ 

—  $ 

14   

—  $ 

—  $ 

5   

5  $ 

1  $ 

—  $ 

2   

—  $ 

—  $ 

8   

8  $ 

—  $ 

—  $ 

1   

—  $ 

—  $ 

(1)   

(1)  $ 

—  $ 

—  $ 

3   

—  $ 

—  $ 

1   

1  $ 

21  $ 

—  $ 

20  $ 

10  $ 

—  $ 

25  $ 

— 

26 

— 

— 

7 

7 

22 

55 

For ACL on AFS debt securities, see Note 13 to the Consolidated Financial Statements. 

219

 
 
 
 
 
 
 
 
 
 
Global Consumer 
Banking

Institutional 
Clients Group

Corporate/
Other

Total

$ 

$ 

$ 

$ 

$ 

$ 

$ 

12,128  $ 

10,112  $ 

(41)  $ 

—   

(153)  $ 

—   

12,087  $ 

9,959  $ 

15  $ 

65  $ 

12,102  $ 

10,024  $ 

40  $ 

(4)  $ 

12,142  $ 

10,020  $ 

16  $ 

—  $ 

(16)   

—  $ 

—  $ 

—  $ 

—  $ 

—  $ 

22,256 

(194) 

(16) 

22,046 

80 

22,126 

36 

22,162 

16.  GOODWILL AND INTANGIBLE ASSETS

Goodwill

The changes in Goodwill by segment were as follows:

In millions of dollars

Balance at December 31, 2017

Foreign exchange translation
Divestitures(1)

Balance at December 31, 2018

Foreign exchange translation

Balance at December 31, 2019

Foreign exchange translation

Balance at December 31, 2020

(1)  Primarily related to the sale of consumer operations in Colombia in 2018.

The Company performed its annual goodwill impairment 

test as of July 1, 2020, at the level below each business 
segment (referred to as a reporting unit) which indicated that 
the fair values of the Company’s reporting units as a 
percentage of their carrying values ranged from approximately 
115% to 136%, resulting in no impairment. While the inherent 
risk related to uncertainty is embedded in the key assumptions 
used in the valuations, the economic environment and Citi’s 
outlook continues to evolve due to the challenges and 
uncertainties related to the impact of the COVID-19 
pandemic. Further deterioration in macroeconomic and market 
conditions, including potential adverse effects to economic 
forecasts due to the severity and duration of the pandemic, as 
well as the responses of governments, customers and clients, 
could negatively influence the assumptions used in the 
valuations, in particular, the discount rates, exit multiples and 
growth rates used in net income projections. If the future were 
to differ from management’s estimate of key assumptions 
(e.g., net interest revenue and loan volume), and associated 
cash flows were to decrease, Citi could potentially experience 
material goodwill impairment charges in the future.

For additional information regarding Citi’s goodwill 
impairment testing process, see the following Notes to the 
Consolidated Financial Statements: Note 1 for Citi’s 
Accounting Policy for goodwill, including the adoption of a 
new accounting standard regarding the subsequent 
measurement of goodwill, and Note 3 for a description of 
Citi’s Business Segments.

220

 
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, 2020

December 31, 2019

Gross
carrying
amount

Accumulated
amortization

Net
carrying
amount

Gross
carrying
amount

Accumulated
amortization

Net
carrying
amount

$ 

5,648  $ 

4,229  $  1,419  $ 

5,676  $ 

4,059  $  1,617 

3,929   

1,276   

2,653   

5,393   

3,069   

2,324 

45   

455   

32   

190   

72   

44   

314   

30   

—   

67   

1   

141   

2   

190   

5   

434   

424   

34   

228   

82   

433   

275   

31   

—   

77   

1 

149 

3 

228 

5 

$ 

10,371  $ 

5,960  $  4,411  $ 

12,271  $ 

7,944  $  4,327 

336   

—   

336   

495   

—   

495 

$ 

10,707  $ 

5,960  $  4,747  $ 

12,766  $ 

7,944  $  4,822 

(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, 2020.

(2) For additional information on Citi’s MSRs, see Note 21 to the Consolidated Financial Statements. 

Intangible assets amortization expense was $419 million, 

$564 million and $557 million for 2020, 2019 and 2018, 
respectively. Intangible assets amortization expense is 
estimated to be $364 million in 2021, $350 million in 2022, 
$351 million in 2023, $365 million in 2024 and $370 million 
in 2025. 

The changes in intangible assets were as follows:

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

Net carrying
amount at
December 31, 
2019

Acquisitions/
renewals/ 
divestitures

Amortization

Impairments

FX translation 
and other

Net carrying
amount at
December 31,
2020

$ 

$ 

$ 

1,617  $ 

2,324   

1   

149   

3   

228   

5   

11  $ 

509   

—   

—   

—   

—   

7   

(200)  $ 

(183)   

—   

(24)   

—   

—   

(12)   

4,327  $ 

527  $ 

(419)  $ 

495 

4,822 

(10)  $ 

1  $ 

—   

—   

—   

—   

(28)   

—   

(38)  $ 

3   

—   

16   

(1)   

(10)   

5   

14  $ 

$ 

1,419 

2,653 

1 

141 

2 

190 

5 

4,411 

336 

4,747 

(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, 2020 and 2019. During 2020, Citi renewed its contract with American Airlines.

(3) For additional information on Citi’s MSRs, including the rollforward from 2019 to 2020, see Note 21 to the Consolidated Financial Statements. 

221

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
17.  DEBT

Short-Term Borrowings

December 31,

2020

2019

In millions of dollars

Balance

Weighted 
average 
coupon

Balance

Weighted 
average 
coupon

Commercial paper
Bank(1)
Broker-dealer and 
other(2)
Total commercial 
paper
Other borrowings(3)
Total

$ 10,022 

$ 10,155 

  7,988 

  6,321 

$ 18,010 

 0.77 % $ 16,476 

 1.98 %

  11,504 

 0.48 

  28,573 

 1.94 

$ 29,514 

$ 45,049 

(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 Federal Home Loan Banks and other market 
participants. At December 31, 2020 and 2019, collateralized short-term 
advances from Federal Home Loan Banks were $4.0 billion and $17.6 
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

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

Balances at
December 31,

Weighted
average
coupon(1) Maturities

2020

2019

 2.82 % 2021-2098 $ 142,197  $ 123,292 
2022-2046   26,636    25,463 
 4.38 

 6.26 

2036-2067  

1,730   

1,722 

 1.64 

2021-2049   44,742    53,340 

 0.72 
 — 

 2.66  %

2021-2070   55,896    44,817 
2022-2046  

485   

126 

$ 271,686  $ 248,760 

$ 242,835  $ 221,449 

  27,121    25,589 

1,730   

1,722 

$ 271,686  $ 248,760 

(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, 2020 and 2019, collateralized long-term advances from 
Federal Home Loan Banks were $10.9 billion and $5.5 billion, 
respectively.

(5) Represents broker-dealer and other non-bank subsidiaries that are 

consolidated into Citigroup Inc., the parent holding company. Certain 
Citigroup consolidated hedging activities are also included in this line.

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, 2020, the Company’s 
overall weighted average interest rate for long-term debt, 
excluding structured notes accounted for at fair value, was 
2.66% on a contractual basis and 2.64% including the effects 
of derivative contracts.

222

 
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

2021

2022

2023

2024

2025

Thereafter

Total

$ 

15,605  $ 

13,159  $ 

14,805  $ 

12,329  $ 

13,733  $ 

100,933  $ 

170,564 

18,577   

14,608   

9,139   

8,978   

2,685   

8,557   

4,588   

4,089   

501   

3,782   

4,643   

20,975   

44,741 

56,381 

$ 

43,321  $ 

36,745  $ 

26,047  $ 

21,006  $ 

18,877  $ 

125,690  $ 

271,686 

The following table summarizes Citi’s outstanding trust preferred securities at December 31, 2020:

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   

2,246 

+ 637 bps  

1,000   

2,246  Oct. 30, 2040

Oct. 30, 2015

3 mo LIBOR 

Citigroup Capital XVIII

June 2007  

99,901   

137 

3 mo 
Sterling 
LIBOR + 
88.75 bps  

50   

137 

June 28, 2067

June 28, 2017

Total obligated

  $ 

2,577 

$ 

2,583 

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)

223

 
 
 
 
 
 
 
 
 
 
 
 
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 
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

Citigroup

Citibank

Stated
minimum

Well-
capitalized
minimum

December 31, 
2020

December 31, 
2019

Well-
capitalized
minimum

December 31, 
2020

December 31, 
2019

  $ 

147,274 

$ 

137,798 

  $ 

142,884 

$ 

130,720 

167,053 

155,805 

144,992 

132,847 

204,849 

193,711 

169,235 

157,253 

195,959 

181,337 

161,294 

145,918 

  1,221,576 

  1,168,848 

  1,030,081 

  1,022,607 

  1,255,284 

  1,142,804 

  1,012,129 

938,735 

    2,265,615 

  1,957,039 

  1,680,056 

  1,459,780 

  2,386,881 

  2,513,702 

  2,167,969 

  1,958,173 

 4.5 %

 6.0 

 8.0 

 4.0 

 3.0 

    N/A

 6.0 %

 10.0 

N/A

N/A

 11.73 %

 11.79 %

 6.5 %

 13.87 %

 12.78 %

 13.31 

 15.61 

 7.37 

 7.00 

 13.33 

 15.87 

 7.96 

 6.20 

 8.0 

 10.0 

 5.0 

 6.0 

 14.08 

 15.94 

 8.63 

 6.69 

 12.99 

 15.38 

 9.10 

 6.78 

(1) Tier 1 Leverage ratio denominator. 
(2) Supplementary Leverage ratio denominator. 
(3) Citigroup’s reportable Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios as of December 31, 2020 were the lower derived under the Basel III 
Advanced Approaches frameworks, whereas Citigroup’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the 
Basel III Standardized Approach and the reportable Total Capital ratio was the lower derived under the Basel III Advanced Approaches framework as of 
December 31, 2019. As of December 31, 2020 and 2019, Citibank’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived 
under the Basel III Standardized Approach, whereas the Total Capital ratios were the lower derived under the Basel III Advanced Approaches frameworks as of 
December 31, 2020 and the lower derived under the Standardized Approach as of December 31, 2019.

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, 2020 and 
2019.

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 $2.3 billion 
and $17.3 billion in dividends from Citibank during 2020 and 
2019, respectively.

224

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2017
Adjustment to opening balance, net 
  of taxes(6)
Adjusted balance, beginning of year
Other comprehensive income before
  reclassifications
Increase (decrease) due to amounts 
  reclassified from AOCI (7)
Change, net of taxes 
Balance, 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
Other comprehensive income before 
  reclassifications
Increase (decrease) due to amounts 
  reclassified from AOCI

Change, net of taxes 

Balance at December 31, 2020

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)

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

(1,158)  $ 

(921)  $ 

(698)  $ 

(6,183)  $ 

(25,708)  $ 

—  $ 

(34,668) 

(3)  $ 

—  $ 

—  $ 

—  $ 

—  $ 

(1,161)  $ 

(921)  $ 

(698)  $ 

(6,183)  $ 

(25,708)  $ 

—  $ 

—  $ 

(3) 

(34,671) 

(866)   

1,081   

(135)   

(240)   

(2,607)   

(57)   

(2,824) 

(223)   

32   

105   

166   

245   

(1,089)  $ 

1,113  $ 

(30)  $ 

(74)  $ 

(2,362)  $ 

(2,250)  $ 

192  $ 

(728)  $ 

(6,257)  $ 

(28,070)  $ 

—   

(57)  $ 

(57)  $ 

325 

(2,499) 

(37,170) 

3,065   

(1,151)   

549   

(758)   

(321)   

25   

1,409 

(1,080)   

15   

302   

206   

—   

1,985  $ 

(1,136)  $ 

851  $ 

(552)  $ 

(321)  $ 

(265)  $ 

(944)  $ 

123  $ 

(6,809)  $ 

(28,391)  $ 

—   

25  $ 

(32)  $ 

(557) 

852 

(36,318) 

4,837   

(490)   

2,027   

(287)   

(250)   

(15)   

5,822 

(1,252)   

15   

(557)   

232   

—   

3,585  $ 

(475)  $  1,470  $ 

(55)  $ 

(250)  $ 

3,320  $ 

(1,419)  $  1,593  $ 

(6,864)  $ 

(28,641)  $ 

—   

(15)  $ 

(47)  $ 

(1,562) 

4,260 

(32,058) 

(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 Mexican peso, Brazilian real, South Korean won and Euro against the U.S. dollar and changes in 
related tax effects and hedges for the year ended December 31, 2020. 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. 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.

(6) 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 

(7)

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.

225

 
 
 
 
 
 
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, 2017
Adjustment to opening balance(2)
Adjusted balance, beginning of year

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 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, 2019

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, 2020

Pretax

Tax effect(1)

After-tax

(41,228)  $ 

6,560  $ 

(34,668) 

(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)  $ 

4,799   

(616)   

1,925   

(78)   

(227)   

(23)   

1   

6,561  $ 

346   

(302)   

8   

20   

262   

17   

351  $ 

6,912  $ 

(648)   

337   

(269)   

119   

11   

(8)   

(458)  $ 

6,454  $ 

(1,214)   

141   

(455)   

23   

(23)   

8   

5,780  $ 

(36,992)  $ 

(1,520)  $ 

4,934  $ 

(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) 

3,585 

(475) 

1,470 

(55) 

(250) 

(15) 

4,260 

(32,058) 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

Includes the impact of ASU 2018-02, which transferred amounts from AOCI to Retained earnings. See Note 1 to the Consolidated Financial Statements.

(1) 
(2)  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.

226

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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)
Excluded component of fair value hedges, pretax

Tax effect

Excluded component of fair value hedges, after-tax

Foreign currency translation adjustment, pretax

Tax effect

Foreign currency translation adjustment, after-tax 

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,

2020

2019

2018

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

(1,756)  $ 

109   

(1,647)  $ 

395   

(1,252)  $ 

20  $ 

(5)   

15  $ 

(734)  $ 

4   

(730)  $ 

173   

(557)  $ 

(5)  $ 

322   

(8)   

309  $ 

(77)   

232  $ 

—  $ 

—   

—  $ 

—  $ 

—   

—  $ 

(2,048)  $ 

486   

(1,562)  $ 

(1,474)  $ 

23   

(1,451)  $ 

371   

(1,080)  $ 

20  $ 

(5)   

15  $ 

384  $ 

7   

391  $ 

(89)   

302  $ 

(12)  $ 

286   

1   

275  $ 

(69)   

206  $ 

—  $ 

—   

—  $ 

—  $ 

—   

—  $ 

(765)  $ 

208   

(557)  $ 

(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 

(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.

227

 
 
 
 
 
 
 
 
 
 
 
20.  PREFERRED STOCK

The following table summarizes the Company’s preferred stock outstanding:

Issuance date

Redeemable by issuer 
beginning

Dividend
rate

 Redemption
price per 
depositary
share/
preference 
share

Number
of 
depositary
shares

Carrying value
 in millions of dollars

December 31,
2020

December 31,
2019

October 29, 2012

January 30, 2023

 5.950 % $ 

1,000    1,500,000  $ 

1,500  $ 

December 13, 2012

February 15, 2023

April 30, 2013

May 15, 2023

September 19, 2013

September 30, 2023

October 31, 2013

November 15, 2023

April 30, 2014

May 15, 2024

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

January 23, 2020

January 30, 2025

December 10, 2020

December 10, 2025

 5.900 

 5.350 

 7.125 

 6.875 

 6.300 

 5.875 

 5.950 

 4.316 

 4.699 

 6.300 

 6.250 

 5.000 

 4.700 

 4.000 

1,000   

750,000   

1,000    1,250,000   

25    38,000,000   

25    59,800,000   

1,000    1,750,000   

1,000    1,500,000   

1,000    2,000,000   

1,000    1,250,000   

1,000    1,500,000   

25    41,400,000   

1,000    1,500,000   

1,000    1,500,000   

1,000    1,500,000   

1,000    1,500,000   

750   

1,250   

950   

1,495   

1,750   

—   

2,000   

1,250   

1,500   

1,035   

1,500   

1,500   

1,500   

1,500   

1,500 

750 

1,250 

950 

1,495 

1,750 

1,500 

2,000 

1,250 

1,500 

1,035 

1,500 

1,500 

— 

— 

$ 

19,480  $ 

17,980 

Series A(1)
Series B(2)
Series D(3)
Series J(4)
Series K(5)
Series M(6)
Series O(7)
Series P(8)
Series Q(9)
Series R(10)
Series S(11)
Series T(12)
Series U(13)
Series V(14)
Series W(15)

(1)

(2)

(3)

(4)

(5)

(6)

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, but excluding, 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, but excluding, 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, but excluding, 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, but excluding, 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, but excluding, 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. 
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, 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.

(7) The Series O preferred stock was redeemed in full on March 27, 2020.
(8)

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.
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.

(9)

(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 November 15, 2020, 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 1/1,000th 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.
(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 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.

(13) 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.

(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 January 30 and July 30 at a fixed rate until, but excluding, January 30, 2025, 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.

228

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(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 quarterly on March 10, June 10, September 10 and December 10 at a fixed rate until, but excluding, December 10, 2025, 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. 

During 2020, Citi distributed $1,095 million in dividends 
on its outstanding preferred stock. On January 21, 2021, Citi 
declared preferred dividends of approximately $292 million 
for the first quarter of 2021.

During the first quarter of 2021, Citi issued $2.3 billion of 
Series X preferred shares. In addition, Citi redeemed all of its 
Series S preferred shares for $1.035 billion, and $465 million 
of its Series R preferred shares. As of February 26, 2021, Citi 
estimates it will distribute preferred dividends of 
approximately $254 million, $293 million and $254 million in 
the second, third and fourth quarters of 2021, respectively, 
subject to such dividends being declared by the Citi Board of 
Directors. 

229

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. 

230

 
 
 
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, 2020

Maximum exposure to loss in significant unconsolidated VIEs(1)

Funded exposures(2)

Unfunded exposures

Total
involvement
with SPE
assets

Consolidated
VIE/SPE 
assets

Significant
unconsolidated
VIE assets(3)

Debt
investments

Equity
investments

Funding
commitments

Guarantees
and
derivatives

Total

$ 

32,420  $ 

32,420  $ 

—  $ 

—  $ 

—  $ 

—  $ 

—  $  — 

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(5)
Municipal securities tender 
option bond trusts (TOBs)

Municipal investments

Client intermediation

Investment funds

Other

Total

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(5)
Municipal securities tender 
option bond trusts (TOBs)

Municipal investments

Client intermediation

Investment funds

Other

Total

123,999   

46,132   

—   

939   

123,999   

45,193   

1,948   

2,550   

16,730   

16,730   

—   

—   

—   

—   

—   

—   

—   

2   

—   

—   

18,332   

222,274   

3,349   

20,335   

1,352   

488   

—   

—   

18,332   

4,273   

8,069   

214,205   

25,153   

1,587   

9,114   

835   

—   

910   

153   

—   

2,514   

—   

—   

20,335   

2,569   

4,056   

442   

335   

—   

88   

—   

—   

—   

—   

—   

1,611   

3,041   

—   

15   

—   

$ 

485,411  $ 

60,056  $ 

425,355  $ 

36,581  $ 

5,643  $ 

13,783  $ 

118  $  56,125 

As of December 31, 2019

Maximum exposure to loss in significant unconsolidated VIEs(1)

Funded exposures(2)

Unfunded exposures

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   

—   

117,374   

2,671   

1,187   

38,421   

876   

15,622   

15,622   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

17,395   

196,728   

6,950   

20,312   

1,455   

827   

352   

—   

17,395   

4,199   

6,139   

190,589   

23,756   

1,151   

9,524   

1,458   

—   

1,391   

174   

1   

5,492   

4   

—   

20,312   

2,636   

4,274   

64   

653   

351   

4   

5   

169   

—   

—   

—   

3,544   

3,034   

—   

16   

39   

61   

2,009 

1   

2,553 

—   

— 

—   

4,273 

—    35,854 

—   

1,611 

—   

9,666 

56   

—   

—   

144 

15 

— 

72   

2,743 

1   

877 

—   

— 

—   

4,199 

—    34,431 

—   

3,548 

—   

9,944 

—   

1   

—   

4 

22 

208 

$ 

460,157  $ 

69,506  $ 

390,651  $ 

34,320  $ 

5,425  $ 

16,157  $ 

74  $  55,976 

(1)  The definition of maximum exposure to loss is included in the text that follows this table.
(2) 
Included on Citigroup’s December 31, 2020 and 2019 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-

(5) 

securitizations” below for further discussion.
Included within this line are loans to third-party sponsored private equity funds, which represent $78 billion and $69 billion in unconsolidated VIE assets and 
$425 million and $711 million in maximum exposure to loss as of December 31, 2020 and 2019, respectively.

231

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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. As of December 31, 2020 and 2019, the 
Company’s maximum exposure to loss related to these 
deals was $57 billion and $52.5 billion, respectively (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 $5.22 billion and $6 billion at 
December 31, 2020 and 2019, 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.

232

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

Non-agency-sponsored mortgage securitizations

$ 

Asset-based financing

Municipal securities tender option bond trusts (TOBs)

Municipal investments

Investment funds

Other

December 31, 2020

December 31, 2019

Liquidity
facilities

Loan/equity
commitments

Liquidity
facilities

Loan/equity
commitments

—  $ 

—   

1,611   

—   

—   

—   

2  $ 

9,114   

—   

3,041   

15   

—   

—  $ 

—   

3,544   

—   

—   

—   

— 

9,524 

— 

3,034 

16 

39 

Total funding commitments

$ 

1,611  $ 

12,172  $ 

3,544  $ 

12,613 

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, 
2020

December 31, 
2019

$ 

$ 

—  $ 
2.0   
10.6   
29.3   
0.3   

42.2  $ 

— 
2.6 
9.9 
26.7 
0.5 

39.7 

233

 
 
 
 
 
 
 
 
 
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

2020

2019

2018

Proceeds from new securitizations

$ 

0.3  $  —  $ 

6.8 

Pay down of maturing notes

(4.3)   

(7.6)   

(8.3) 

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, 
2020

December 31, 
2019

$ 

$ 

15.7  $ 

7.9   

11.1   

34.7  $ 

19.7 

6.2 

17.8 

43.7 

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 2.9 
years as of December 31, 2020 and 3.1 years as of 
December 31, 2019.

In billions of dollars

Dec. 31, 
2020

Dec. 31, 
2019

Term notes issued to third parties
Term notes retained by Citigroup 

affiliates

Total Master Trust liabilities

$ 

$ 

13.9  $ 

2.7   

16.6  $ 

18.2 

4.3 

22.5 

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 1.1 years as of 
December 31, 2020 and 1.6 years as of December 31, 2019.

In billions of dollars

Dec. 31, 
2020

Dec. 31, 
2019

Term notes issued to third parties
Term notes retained by Citigroup 

affiliates

Total Omni Trust liabilities

$ 

$ 

1.8  $ 

5.2   

7.0  $ 

1.5 

1.9 

3.4 

234

 
 
 
 
 
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

2020

2019

2018

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

$ 

9.4  $ 

10.0   

0.1   

0.4   

11.3  $ 

11.4   

—   

—   

5.3  $ 

5.5   

0.1   

0.2   

15.6  $ 

15.5   

—   

—   

4.0  $ 

4.2   

0.1   

0.2   

5.6 

7.1 

— 

— 

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, 2020 were $88.4 million and $139.4 
million, respectively. 

Agency and non-agency securitization gains for the year 

ended December 31, 2019 were $16 million and $73.4 million, 
respectively, and $17 million and $36 million, respectively, 
for the year ended December 31, 2018.

2020
Non-agency-sponsored 
mortgages(1)

2019
Non-agency-sponsored 
mortgages(1)

In millions of dollars
Carrying value of retained interests(3) $ 

U.S. agency- 
sponsored 
mortgages

Senior 
interests(2)

Subordinated 
interests

U.S. agency- 
sponsored 
mortgages

Senior 
interests

Subordinated 
interests

315  $ 

1,210  $ 

145  $ 

491  $ 

748  $ 

102 

(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)  Senior interests in non-agency-sponsored mortgages include $112 million related to personal loan securitizations at December 31, 2020.
(3)  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.

235

 
 
 
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

December 31, 2020

Non-agency-sponsored mortgages(1)
Subordinated 
interests

Senior 
interests

 5.4 %

 25.8 %

   NM

 1.7 %

 3.4 %

 1.7 %

 3.0 %

 25.0 %

 0.5 %

4.8 years

3.8 years

2.3 years

U.S. agency- 
sponsored mortgages

December 31, 2019

Non-agency-sponsored mortgages(1)
Subordinated 
interests

Senior 
interests

 9.3 %

 12.9 %

   NM

 3.6 %

 10.5 %

 3.9 %

 4.6 %

 7.6 %

 2.8 %

6.6 years

3.0 years

11.4 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 in securitizations of mortgage receivables at period 
end 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

December 31, 2020

Non-agency-sponsored mortgages(1)
Subordinated 
interests

Senior 
interests

 5.9 %

 22.7 %

NM

 7.2 %

 5.3 %

 1.2 %

 4.3 %

 4.7 %

 1.4 %

4.5 years

5.3 years

4.7 years

U.S. agency- 
sponsored mortgages

December 31, 2019

Non-agency-sponsored mortgages(1)
Subordinated 
interests

Senior 
interests

 9.8 %

 10.1 %

   NM

 7.6 %

 3.6 %

 5.2 %

 4.2 %

 6.1 %

 2.7 %

6.6 years

5.9 years

29.3 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.

236

The sensitivity of the fair value to adverse changes of 10% and 20% in each of the key assumptions is 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, 2020

Non-agency-sponsored mortgages

U.S. agency- 
sponsored mortgages

Senior 
interests

Subordinated 
interests

$ 

(8)  $ 

(15)   

(21)   

(40)   

NM  

NM  

—  $ 

(1)   

—   

—   

—   

—   

December 31, 2019

Non-agency-sponsored mortgages

U.S. agency- 
sponsored mortgages

Senior 
interests

Subordinated 
interests

$ 

(18)  $ 

(35)   

(18)   

(35)   

NM  

NM  

—  $ 

(1)   

—   

—   

—   

—   

(1) 

(1) 

— 

— 

— 

— 

(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

2020

2019

2020

2019

2020

2019

Securitized assets

90 days past due

Liquidation losses

Securitized assets
Residential mortgages(1)
Commercial and other

Total

$ 

$ 

16.9  $ 

23.9   

40.8  $ 

11.7  $ 

19.0   

30.7  $ 

0.5  $ 

—   

0.5  $ 

0.4  $ 

—   

0.4  $ 

26.2  $ 

—   

26.2  $ 

49.0 

— 

49.0 

(1)   Securitized assets include $0.2 billion of personal loan securitizations as of December 31, 2020. 

237

 
 
 
 
 
 
 
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 
$336 million and $495 million at December 31, 2020 and 
2019, respectively. The MSRs correspond to principal loan 
balances of $53 billion and $58 billion as of December 31, 
2020 and 2019, 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

2020

2019

$ 

$ 

495  $ 
123   

(204)   
(78)   
—   
336  $ 

584 
70 

(84) 
(75) 
— 
495 

(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

2020

2019

2018

$ 

$ 

142  $ 
5 
— 
147  $ 

148  $ 
8
1
157  $ 

172 
4
8
184 

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, 2020 and 2019. These securities are 

backed by either residential or commercial mortgages and are 
often structured on behalf of clients. 

As of December 31, 2020 and December 31, 2019, Citi 

held no retained interests in private label re-securitization 
transactions structured by Citi. 

The Company also re-securitizes U.S. government-agency 

guaranteed mortgage-backed (agency) securities. During the 
years ended December 31, 2020 and 2019, Citi transferred 
agency securities with a fair value of approximately $42.8 
billion and $31.9 billion, respectively, to re-securitization 
entities. 

As of December 31, 2020, the fair value of Citi-retained 
interests in agency re-securitization transactions structured by 
Citi totaled approximately $1.6 billion (including $916 million 
related to re-securitization transactions executed in 2020) 
compared to $2.2 billion as of December 31, 2019 (including 
$1.3 billion related to re-securitization transactions executed in 
2019), 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, 2020 
and 2019 was approximately $83.6 billion and $73.5 billion, 
respectively.

As of December 31, 2020 and 2019, 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 

238

 
 
 
 
 
 
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, 
2020 and 2019, the commercial paper conduits administered 
by Citi had approximately $16.7 billion and $15.6 billion of 
purchased assets outstanding, respectively, and had 
incremental funding commitments with clients of 
approximately $17.1 billion and $16.3 billion, respectively.
Substantially all of the funding of the conduits is in the 

form of short-term commercial paper. At December 31, 2020 
and 2019, the weighted average remaining lives of the 
commercial paper issued by the conduits were approximately 
54 and 49 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% to 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 $1.5 billion as of December 31, 2020 and $1.4 
billion as of December 31, 2019. 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 
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 

239

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, 2020 and 2019, the Company owned $6.6 
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 billions of dollars

Principal securitized

2020

2019

2018

$ 

0.1  $  —  $  — 

Proceeds from new securitizations

0.1   

—   

— 

Cash flows received on retained 
interests and other net cash flows

—   

—   

0.1 

In millions of dollars

Carrying value of retained 
interests

Dec. 31, 
2020

Dec. 31, 
2019

Dec. 31, 
2018

$  1,611  $  1,404  $  3,142 

All of Citi’s retained interests were held-to-maturity 

securities as of December 31, 2020 and 2019.

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, 2020

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

In millions of dollars

Type
Commercial and other real 
estate

Corporate loans
Other (including investment 
funds, airlines and shipping)

34,570  $ 

12,022   

167,613   

$ 

214,205  $ 

7,758 

7,654 

20,442 

35,854 

December 31, 2019

Total 
unconsolidated 
VIE assets

Maximum 
exposure to 
unconsolidated 
VIEs

$ 

31,377  $ 

7,088   

152,124   

Total

$ 

190,589  $ 

7,489 

5,802 

21,140 

34,431 

240

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, 2020, Citi had no outstanding voluntary 
advances to customer TOB trusts.

For certain non-customer trusts, the Company also 

provides credit enhancement. At December 31, 2020 and 
2019, 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 
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 

 
 
 
 
 
 
 
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 colleagues to 
invest in private equity investments. The Company acts as 
investment manager for these funds and may provide 
colleagues with financing on both recourse and non-recourse 
bases for a portion of the colleagues’ investment 
commitments.

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, 2020 and 2019, liquidity agreements 
provided with respect to customer TOB trusts totaled $1.6 
billion and $3.5 billion, respectively, of which $0.8 billion and 
$1.6 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 $3.6 billion as of 
December 31, 2020 and $7.0 billion as of December 31, 2019. 
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 
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 

241

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-

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 

242

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 Hedging 
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.

243

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,
2020

December 31,
2019

December 31,
2020

December 31,
2019

334,351  $ 

318,089  $ 

17,724,147  $ 

17,063,272 

—   

—   

—   

—   

—   

—   

4,142,514   

1,573,483   

1,418,255   

3,636,658 

2,114,511 

1,857,770 

334,351  $ 

318,089  $ 

24,858,399  $ 

24,672,211 

65,709  $ 

37,080   

47   

53   

63,104  $ 

38,275   

80   

80   

6,567,304  $ 

3,945,391   

907,338   

900,626   

6,063,853 

3,979,188 

908,061 

959,149 

102,889  $ 

101,539  $ 

12,320,659  $ 

11,910,251 

—  $ 

—   

—   

—   

—  $ 

—  $ 

924   

—   

—   

924  $ 

—  $ 

—   

—  $ 

—  $ 

—   

—   

—   

274,098  $ 

67,025   

441,003   

328,202   

197,893 

66,705 

560,571 

422,393 

—  $ 

1,110,328  $ 

1,247,562 

—  $ 

1,195   

—   

—   

80,127  $ 

143,175   

71,376   

67,849   

1,195  $ 

362,527  $ 

69,445 

137,192 

91,587 

86,631 

384,855 

603,387 

703,926 

—  $ 

—   

—  $ 

543,607  $ 

612,770   

1,156,377  $ 

1,307,313 

438,164  $ 

420,823  $ 

39,808,290  $ 

39,522,192 

(1) Credit derivatives are arrangements designed to allow one party (protection purchaser) 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.

244

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020 and 2019. 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 certain 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 $280 billion 
and $180 billion as of December 31, 2020 and 2019, 
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.

245

Derivative Mark-to-Market (MTM) Receivables/Payables 

In millions of dollars at December 31, 2020

Derivatives instruments designated as ASC 815 hedges

Over-the-counter

Cleared

Interest rate contracts

Over-the-counter

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)

Derivatives classified
in Trading account assets/liabilities(1)(2)

Assets

Liabilities

1,781  $ 

74   

1,855  $ 

2,037  $ 

2,037  $ 

3,892  $ 

228,519  $ 

11,041   

46   

239,606  $ 

153,791  $ 

842   

—   

154,633  $ 

29,244  $ 

1   

21,274   

50,519  $ 

13,659  $ 

879   

14,538  $ 

7,826  $ 

1,963   

9,789  $ 

469,085  $ 

472,977  $ 

32,778  $ 

(364,879)   

(63,915)   

76,961  $ 

(1,567)  $ 

(7,408)   

67,986  $ 

161 

319 

480 

2,042 

2,042 

2,522 

209,330 

12,563 

38 

221,931 

152,784 

1,239 

1 

154,024 

41,036 

18 

22,515 

63,569 

17,076 

1,017 

18,093 

7,951 

2,178 

10,129 

467,746 

470,268 

8,196 

(364,879) 

(45,628) 

67,957 

(473) 

(13,087) 

54,397 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

(1) The derivatives fair values are also 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 $78,406 million and $72,111 million of gross cash collateral paid and received, respectively. Of the gross cash collateral paid, 

$45,628 million was used to offset trading derivative liabilities. Of the gross cash collateral received, $63,915 million was used to offset trading derivative assets.

(4) Represents the netting of balances with the same counterparty under enforceable netting agreements. Approximately $336 billion, $9 billion and $20 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.

(6) The net receivables/payables include approximately $6 billion of derivative asset and $8 billion of derivative liability fair values not subject to enforceable master 

netting agreements, respectively.

246

 
 
 
 
 
 
 
 
 
 
 
 
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 also 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 $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. Of the gross cash collateral received, $44,353 million was used to offset trading derivative assets.
(4) Represents the netting of 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 netting of cash 

collateral received and paid is 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.

247

 
 
 
 
 
 
 
 
 
 
 
 
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.

For the years ended December 31, 2020, 2019 and 2018, 

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

2020

2019

2018

Interest rate contracts

$ 

Foreign exchange

Total

$ 

63  $ 

(57)   

6  $ 

57  $ 

(29)   

28  $ 

(25) 

(197) 

(222) 

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 
ineffectiveness measured and recorded in current earnings. 
Hedge effectiveness assessment methodologies are performed 
in a similar manner for similar hedges, and are used 

248

 
 
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. 

Citigroup has 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 inventories. 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 it is 
generally reflected directly in earnings over the life of the 
hedge. Citi also excludes changes in forward rates from the 
assessment of hedge effectiveness and records it in Other 
comprehensive income. 

249

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

Gains (losses) on fair value hedges(1)
Year ended December 31,

2020

2019

2018

Other 
revenue

Net 
interest 
revenue

Other 
revenue

Net 
interest 
revenue

Other 
revenue

Net 
interest 
revenue

$ 

—  $ 

4,189  $ 

—  $ 

2,273  $ 

—  $ 

794 

1,442   

(164)   

—   

—   

337   

(33)   

—   

—   

(2,064)   

(123)   

— 

— 

$ 

1,278  $ 

4,189  $ 

304  $ 

2,273  $ 

(2,187)  $ 

794 

$ 

—  $ 

(4,537)  $ 

—  $ 

(2,085)  $ 

—  $ 

(747) 

(1,442)   

164   

—   

—   

(337)   

33   

—   

—   

2,064   

124   

— 

— 

$ 

(1,278)  $ 

(4,537)  $ 

(304)  $ 

(2,085)  $ 

2,188  $ 

(747) 

Interest rate hedges
Foreign exchange hedges(2)
Commodity hedges

$ 

—  $ 

(23)  $ 

—  $ 

3  $ 

—  $ 

(73)   

131   

—   

—   

(109)   

41   

—   

—   

(4)   

(19)   

Total net gain (loss) on the hedging derivatives excluded from 
assessment of the effectiveness of fair value hedges

$ 

58  $ 

(23)  $ 

(68)  $ 

3  $ 

(23)  $ 

(5) 

— 

— 

(5) 

(1) Gain (loss) amounts for interest rate risk hedges are included in Interest income/Interest expense. The accrued interest income on fair value hedges is recorded in 

Net interest revenue and is excluded from this table.

(2) 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. 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 $(23) million and $33 million for the years ended December 31, 2020 and 
2019, respectively.

250

 
 
 
 
 
 
 
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. This cumulative hedge 
basis adjustment becomes part of the carrying value of 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, 2020 and 2019, 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

Cumulative fair value hedging 
adjustment increasing 
(decreasing) the carrying 
amount

Active

De-designated

As of December 31, 2020
Debt securities
  AFS(1)(3)
Long-term debt

$ 

81,082  $ 

169,026   

As of December 31, 2019
Debt securities
  AFS(2)(3)
Long-term debt

$ 

94,659  $ 

157,387   

28  $ 

5,554   

(114)  $ 

2,334   

342 

4,989 

743 

3,445 

(1)  These amounts include a cumulative basis adjustment of $(18) million 
for active hedges and $62 million for de-designated hedges as of 
December 31, 2020 related to certain prepayable financial assets 
previously designated as the hedged item in a fair value hedge using the 
last-of-layer approach. The Company designated approximately 
$2,527 million as the hedged amount (from a closed portfolio of 
prepayable financial assets with a carrying value of $19 billion as of 
December 31, 2020) in a last-of-layer hedging relationship.

(2)  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.

(3)  Carrying amount represents the amortized cost.

251

 
 
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
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

2020

2019

2018

2,670  $ 

(15)   

2,655  $ 

746 

(17) 

729 

$ 

$ 

(361) 

5 

(356) 

Other 
revenue

Net interest 
revenue

Other 
revenue

Net interest 
revenue

Other 
revenue

Net interest 
revenue

—  $ 

(4)   

(4)  $ 

734  $ 

—   

734  $ 

—  $ 

(7)   

(7)  $ 

(384)  $ 

—   

(384)  $ 

—  $ 

(17)   

(17)  $ 

(301) 

— 

(301) 

$ 

1,925 

$ 

1,120 

$ 

(38) 

(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, 2020 is 
approximately $920 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.

252

 
 
 
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, was $(600) million, $(569) million and $1,147 million 
for the years ended December 31, 2020, 2019 and 2018, 
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.

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 December 31, 2020 and 2019, 
approximately 97% and 98%, respectively, 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 

253

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.

254

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, 2020

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

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

2,902  $ 

1,770   

109   

5,008   

9,789  $ 

9,254  $ 

535   

9,789  $ 

4,136  $ 

5,653   

9,789  $ 

914  $ 

6,022   

2,853   

9,789  $ 

3,187  $ 

1,215   

90   

5,637   

10,129  $ 

9,254  $ 

875   

10,129  $ 

4,037  $ 

6,092   

10,129  $ 

1,355  $ 

5,991   

2,783   

10,129  $ 

117,685  $ 

46,928   

5,740   

442,417   

612,770  $ 

599,633  $ 

13,137   

612,770  $ 

478,643  $ 

134,127   

612,770  $ 

134,080  $ 

421,682   

57,008   

612,770  $ 

120,739 

44,692 

2,217 

375,959 

543,607 

538,426 

5,181 

543,607 

418,147 

125,460 

543,607 

125,464 

374,376 

43,767 

543,607 

(1) The fair value amount receivable is composed of $3,514 million under protection purchased and $6,275 million under protection sold.
(2) The fair value amount payable is composed of $7,037 million under protection purchased and $3,092 million under protection sold.

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   

10,409  $ 

9,759  $ 

650   

10,409  $ 

4,579  $ 

5,830   

10,409  $ 

1,806  $ 

7,275   

1,328   

10,409  $ 

4,102  $ 

1,528   

76   

5,032   

10,738  $ 

9,791  $ 

947   

10,738  $ 

4,578  $ 

6,160   

10,738  $ 

2,181  $ 

7,265   

1,292   

10,738  $ 

172,461  $ 

54,843   

2,601   

474,021   

703,926  $ 

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.

255

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020 and 
2019 was $25 billion and $30 billion, respectively. The 
Company posted $22 billion and $28 billion as collateral for 
this exposure in the normal course of business as of 
December 31, 2020 and 2019, 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, 2020, the Company could be required to 
post an additional $0.8 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 $1 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 
transaction. These transactions generally do not result in a gain 

256

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 $2.0 billion and $5.8 billion as of December 31, 2020 
and 2019, respectively. 

At December 31, 2020, the fair value of these previously 

derecognized assets was $2.2 billion. The fair value of the 
total return swaps as of December 31, 2020 was $135 million 
recorded as gross derivative assets and $7 million recorded as 
gross derivative liabilities. At December 31, 2019, the fair 
value of these previously derecognized assets was $5.9 billion, 
and the fair value of the total return swaps was $117 million 
recorded as gross derivative assets and $43 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.

257

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, 2020, 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 $370.1 billion and 
$250.9 billion at December 31, 2020 and 2019, respectively. 
The German and Japanese 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 
Germany amounted to $51.8 billion and $29.8 billion at 
December 31, 2020 and 2019, respectively, and was composed 
of investment securities, loans and trading assets. The 
Company’s exposure to Japan amounted to $35.5 billion and 
$33.3 billion at December 31, 2020 and 2019, respectively, 
and was composed of investment securities, loans and trading 
assets.

The Company’s exposure to states and municipalities 
amounted to $24.4 billion and $31.4 billion at December 31, 
2020 and 2019, respectively, and was composed of trading 
assets, investment securities, derivatives and lending activities.

258

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 
from active markets 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 

259

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 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.
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. 

The FVA represents 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, 
2020 and 2019:

Credit and funding valuation 
adjustments
contra-liability (contra-asset)

December 31,
2020

December 31,
2019

$ 

(800)  $ 
(525)   
403   
67   

(705) 
(530) 
341 
72 

$ 

(855)  $ 

(822) 

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)

2020

2019

2018

(101)  $ 
(95)   
133   
(6)   

149  $ 
13   
(131)   
(63)   

(109) 
46 
178 
56 

(69)  $ 

(32)  $ 

171 

(616)  $ 

(1,473)  $ 

1,415 

(685)  $ 

(1,505)  $ 

1,586 

(1)  See Notes 1, 17 and 19 to the Consolidated Financial Statements.
(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 

260

 
 
 
 
 
 
 
 
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 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 collateralized debt obligation (CDO), that is not 
receiving any principal or interest and is not expected to 
receive any in the future.

When the Company’s principal exit market for a portfolio 

of loans is through securitization, the Company uses the 
securitization price as a key input into the fair value of the 
loan portfolio. The securitization price is determined from the 
assumed proceeds of a hypothetical securitization within the 
current market environment, with adjustments made to 
account for various costs associated with the process of 
securitization. Where such a price verification is possible, loan 
portfolios are typically classified as Level 2 in the fair value 
hierarchy.

For most of the subprime mortgage backed security 
(MBS) exposures, fair value is determined utilizing observable 
transactions where available, or other valuation techniques 
such as discounted cash flow analysis utilizing valuation 
assumptions derived from similar, more observable securities 
as market proxies. The valuation of certain asset-backed 
security (ABS) CDO positions are inferred through the net 
asset value of 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.

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 do not generally trade. 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 guideline public company analysis and comparable
transactions. 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.

261

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.

262

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, 
2020 and 2019. The Company may hedge positions that have 

been classified in the Level 3 category with other financial 
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:

Fair Value Levels

In millions of dollars at December 31, 2020

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

$ 

—  $ 

335,073  $ 

320  $ 

335,393  $ (150,189)  $  185,204 

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)

Total investments

—   
42,930 
—   
731 
1,029 
—   
—  $  44,690 
—  $  66,798 
—   
1,318 
83,389 
—   
20,822 
—   
66,479 
—   
—   
2,382 
12,240 
—   
—  $  298,118 

$ 
$ 

—   
—   
—   
—  $ 
64,529  $ 
—   
68,195   
1,607   
54,117   
—   
—   
$  188,448  $ 

$ 

$ 

42  $ 
2   
66   
—   
—   
110  $ 

42,903   
391   
893   
44,187  $ 
2,269  $ 
1,224   
15,143   
18,840   
12,289   
776   
11,295   
106,023  $ 

238,026  $ 
155,994   
48,362   
13,546   
8,634   
464,562  $ 

27   
340   
136   
503  $ 
—  $ 
94   
51   
375   
73   
1,606   
945   
3,647  $ 

3,393  $ 
674   
2,091   
992   
1,155   
8,305  $ 
$ 

42,930   
731   
1,029   
44,690  $ 
66,798  $ 
1,318   
83,389   
20,822   
66,479   
2,382   
12,240   
298,118  $ 

241,461 
156,670 
50,519 
14,538 
9,789 
472,977 
32,778 

$ 

110  $ 

464,562  $ 

8,305  $ 

$ (364,879) 
(63,915) 
505,755  $ (428,794)  $  76,961 

$ 

—  $ 
—   
—   
$ 
—  $ 
$  146,032  $ 
—   
77,056   
6,326   
287   
—   
—   
—   
$  229,701  $ 

43,888  $ 
571   
50   
44,509  $ 
172  $ 
2,885   
47,644   
4,114   
228   
277   
4,876   
50   
104,755  $ 

30  $ 
—   
—   
30  $ 
—  $ 
834   
268   
60   
—   
1   
—   
349   
1,542  $ 

43,918  $ 
571   
50   
44,539  $ 
146,204  $ 
3,719   
124,968   
10,500   
515   
278   
4,876   
399   
335,998  $ 

—  $  43,918 
571 
—   
—   
50 
—  $  44,539 
—  $  146,204 
—   
3,719 
—    124,968 
10,500 
—   
515 
—   
278 
—   
4,876 
—   
—   
399 
—  $  335,998 

Table continues on the next page.

263

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In millions of dollars at December 31, 2020

Level 1

Level 2

Level 3

Loans

Mortgage servicing rights

$ 

— 

— 

$ 

4,869 

$ 1,985 

— 

336 

336   

—   

6,854 

336 

Gross

inventory Netting(1)
6,854  $ 
$ 

—  $ 

Net
balance

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

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

$  6,230 

$ 

8,383 

$  — 

$ 

14,613  $ 

—  $  14,613 

$ 424,489 

$ 1,023,665 

$ 16,135 

$  1,497,067  $ (578,983)  $  918,084 

 29.0 %

 69.9 %

 1.1 %

$ 

— 

— 

$ 

1,752 

$  206 

$ 

1,958  $ 

—  $ 

1,958 

  156,644 

631 

157,275   

(97,069)   

60,206 

  85,353 

14,477 

— 

— 

214 

26 

100,044   

—    100,044 

26   

—   

26 

$  85,353 

$  14,477 

$  240 

$ 

100,070  $ 

—  $  100,070 

$  220,607 

$ 1,779 

$ 

222,411 

  155,441 

622 

156,066 

$ 

$ 

$ 

$ 

25 

3 

53 

— 

— 

81 

81 

— 

— 

58,212 

  5,304 

17,393 

700 

9,022 

  1,107 

$  460,675 

$ 9,512 

$  460,675 

$ 9,512 

$ 

4,464 

$  219 

41,853 

 25,210 

63,569 

18,093 

10,129 

470,268 

8,196 

$ (364,879) 

(45,628) 

478,464  $ (410,507)  $  67,957 

4,683  $ 

—  $ 

4,683 

67,063   

—   

67,063 

6,835  $ 

—  $ 

6,835 

816,348  $ (507,576)  $  308,772 

$ 

$ 

$ 

$ 

$ 

$ 

Total non-trading derivatives and other financial liabilities 
measured on a recurring basis

Total liabilities
Total as a percentage of gross liabilities(5)

$  6,762 

$ 

72 

$ 

1 

$  92,196 

$  679,937 

$ 36,019 

 11.4 %

 84.1 %

 4.5 %

(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 $78,406 million of gross cash collateral paid, of which $45,628 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 $72,111 million of gross cash collateral received, of which $63,915 million was used to offset trading derivative assets.

264

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Fair Value Levels

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

$ 

—  $  254,253  $ 

303  $  254,556  $  (101,363)  $ 153,193 

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

Equity securities

Asset-backed securities
Other trading assets(2)

—   

—   

—   

27,661   

573   

1,632   

10   

123   

61   

27,671   

696   

1,693   

—    27,671 

—   

696 

—   

1,693 

—  $ 

29,866  $ 

194  $ 

30,060  $ 

—  $  30,060 

26,159  $ 

3,736  $ 

—  $ 

29,895  $ 

—  $  29,895 

—   

2,573   

50,948   

20,326   

1,332   

17,246   

41,663   

9,878   

64   

52   

313   

100   

2,637   

71,326   

18,891   

51,641   

—   

74   

1,539   

1,177   

2,716   

11,412   

555   

12,041   

—   

2,637 

—    71,326 

—    18,891 

—    51,641 

—   

2,716 

—    12,041 

Total trading non-derivative assets

$  120,176  $ 

96,576  $  2,455  $  219,207  $ 

—  $ 219,207 

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

$ 

7  $  196,493  $  1,168  $  197,668 

1   

107,022   

83   

—   

—   

28,148   

13,498   

9,960   

547   

240   

714   

449   

107,570 

28,471 

14,212 

10,409 

$ 

91  $  355,121  $  3,118  $  358,330 

$ 

17,926 

$  (274,970) 

(44,353) 

91  $  355,121  $  3,118  $  376,256  $  (319,323)  $  56,933 

—  $ 

35,198  $ 

32  $ 

35,230  $ 

—  $  35,230 

—   

—   

793   

74   

—   

—   

793   

74   

—   

—   

793 

74 

—  $ 

36,065  $ 

32  $ 

36,097  $ 

—  $  36,097 

$ 

$ 

$ 

U.S. Treasury and federal agency securities

$  106,103  $ 

5,315  $ 

—  $  111,418  $ 

—  $ 111,418 

State and municipal

Foreign government

Corporate

Marketable equity securities

Asset-backed securities

Other debt securities
Non-marketable equity securities(4)

—   

4,355   

623   

4,978   

69,957   

41,196   

5,150   

6,076   

371   

500   

4,730   

87   

—   

—   

—   

96   

45   

—   

22   

—   

111,249   

11,271   

458   

522   

4,730   

534   

93   

441   

—   

4,978 

—    111,249 

—    11,271 

—   

—   

458 

522 

—   

4,730 

—   

534 

Total investments

$  181,297  $ 

98,701  $  1,259  $  281,257  $ 

—  $ 281,257 

Table continues on the next page. 

265

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In millions of dollars at December 31, 2019

Level 1

Level 2

Level 3

Gross
inventory

Netting(1)

Net
balance

Loans

Mortgage servicing rights

$ 

— 

— 

$ 

3,683 

$  402 

$ 

4,085  $ 

—  $  4,085 

— 

495 

495   

—   

495 

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

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

$  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 

$  215 

$ 

2,319  $ 

—  $  2,319 

  111,567 

757 

112,324   

(71,673)    40,651 

  60,429 

11,965 

48 

72,442   

—    72,442 

— 

24 

  — 

24   

—   

24 

$  60,429 

$  11,989 

$ 

48 

$ 

72,466  $ 

—  $  72,466 

$ 

$ 

$ 
$ 

8 
— 
144 
— 
— 
152 

$ 176,480 
  110,180 
28,506 
16,542 
10,233 
$ 341,941 

$  1,167 
552 
  1,836 
773 
505 
$  4,833 

$  177,655 
110,732 
30,486 
17,315 
10,738 
$  346,926 
14,391 
$ 

$ (274,970) 
(38,919) 

152 
— 
— 

$ 341,941 
4,933 
$ 
38,614 

$  4,833 
13 
$ 
  17,169 

$  361,317  $ (313,889)  $  47,428 
—  $  4,946 
$ 
—    55,783 

4,946  $ 
55,783   

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 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 $58,744 million of gross cash collateral received, of which $44,353 million was used to offset trading derivative assets.

266

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020 and 
2019. 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 
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:

Level 3 Fair Value Rollforward

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

Net realized/unrealized
gains (losses) included in(1)

Transfers

Dec. 31, 
2019

Principal

transactions Other(1)(2)

into
Level 3

out of
Level 3 Purchases

Issuances

Sales

Settlements

Dec. 31, 
2020

Unrealized
gains 
(losses)
still held(3)

0

$ 

303  $ 

23  $ 

—  $  —  $  —  $ 

194  $ 

—  $  —  $ 

(200)  $ 

320  $ 

43 

10 

123 

61 

(79)   

79 

— 

— 

— 

— 

21 

234 

162 

(11)   

(68)   

(35)   

392 

486 

174 

— 

— 

— 

(306)   

(514)   

(226)   

— 

— 

— 

27 

340 

136 

(1) 

(20) 

(14) 

$ 

194  $ 

—  $ 

—  $ 

417  $ 

(114)  $ 

1,052  $ 

—  $  (1,046)  $ 

—  $ 

503  $ 

(35) 

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)

64 

52 

313 

100 

1,177 

555 

—  $ 

—  $  —  $  —  $ 

—  $ 

—  $  —  $ 

—  $  —  $ 

2 

(35)   

246 

(16)   

(105)   

315 

— 

— 

— 

— 

— 

— 

33 

9 

(3)   

(1)   

211 

(136)   

43 

677 

471 

(2)   

(131)   

(343)   

62 

169 

770 

240 

1,406 

387 

— 

— 

— 

— 

— 

19 

(64)   

(143)   

— 

— 

94 

51 

(1,023)   

(6)   

375 

(292)   

(1,418)   

(440)   

— 

— 

73 

1,606 

(19)   

945 

— 

4 

(7) 

(37) 

(11) 

(248) 

(56) 

$  2,455  $ 

407  $ 

—  $  1,861  $ 

(730)  $ 

4,086  $ 

19  $  (4,426)  $ 

(25)  $  3,647  $ 

(390) 

Interest rate contracts

$ 

1  $ 

429  $ 

—  $  1,644  $ 

16  $ 

41  $ 

134  $ 

(34)  $ 

(617)  $  1,614  $ 

161 

Foreign exchange 
contracts

Equity contracts

Commodity contracts

Credit derivatives

Total trading derivatives, 
net(4)

(5)   

(1,596)   

(59)   

(56)   

105 

(536)   

(1)   

123 

— 

— 

— 

— 

(61)   

(519)   

48 

378 

99 

173 

(108)   

(334)   

74 

35 

101 

— 

— 

— 

— 

— 

(55)   

(886)   

(61)   

— 

(54)   

52 

130 

(89)   

(3,213)   

(3,868) 

321 

142 

292 

48 

407 

(136) 

$  (1,715)  $ 

120  $ 

—  $  1,336  $  —  $ 

251  $ 

134  $  (1,036)  $ 

(297)  $  (1,207)  $ 

(3,306) 

267

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In millions of dollars

Investments

Mortgage-backed 
securities

U.S. government-
sponsored agency 
guaranteed

Residential

Commercial

Total investment 
mortgage-backed 
securities

Net realized/unrealized
gains (losses) included in(1)

Transfers

Dec. 31, 
2019

Principal

transactions Other(1)(2)

into
Level 3

out of
Level 3 Purchases

Issuances

Sales

Settlements

Unrealized
gains 
(losses)
still held(3)

Dec. 31, 
2020

$ 

32  $ 

—  $ 

(5)  $ 

2  $  —  $ 

1  $ 

—  $  —  $ 

—  $ 

30  $ 

(104) 

— 

— 

— 

— 

76 

— 

— 

— 

— 

— 

— 

— 

— 

(76)   

— 

  — 

— 

— 

— 

— 

5 

— 

$ 

32  $ 

—  $ 

71  $ 

2  $  —  $ 

1  $ 

—  $ 

(76)  $ 

—  $ 

30  $ 

(99) 

U.S. Treasury and 
federal agency securities $  —  $ 

State and municipal

623 

Foreign government

Corporate

Marketable equity 
securities

Asset-backed securities

Other debt securities

Non-marketable equity 
securities

Total investments

Loans

96 

45 

— 

22 

— 

441 

$  1,259  $ 

$ 

402  $ 

Mortgage servicing rights

495 

— 

— 

— 

— 

— 

— 

— 

—  $ 

—  $ 

— 

—  $ 

—  $  —  $  —  $ 

—  $ 

—  $  —  $ 

—  $  —  $ 

(3)   

322 

(131)   

11 

6 

(1)   

(1)   

— 

(35)   

27 

49 

1 

— 

— 

— 

(64)   

(152)   

— 

— 

— 

(2)   

121 

381 

162 

— 

— 

— 

2 

— 

— 

— 

(98)   

(183)   

(50)   

— 

  — 

— 

(20)   

— 

  — 

— 

— 

— 

— 

— 

— 

834 

268 

60 

— 

1 

— 

3 

(3)   

(57)   

349 

— 

(20) 

(4) 

— 

— 

(4) 

— 

10 

48  $ 

401  $ 

(349)  $ 

1,143  $ 

451  $ 

(6)  $ 

667  $ 

—  $ 

3  $  (430)  $ 

(57)  $  1,542  $ 

(117) 

—  $  —  $ 

(5)  $  1,985  $ 

1,424 

Other financial assets 
measured on a recurring 
basis

Liabilities

1 

— 

— 

— 

— 

(204)   

— 

— 

— 

— 

123 

  — 

(78)   

336 

(180) 

— 

(1)   

— 

— 

— 

Interest-bearing deposits

$ 

215  $ 

—  $ 

11  $ 

278  $ 

(152)  $ 

—  $ 

34  $  —  $ 

(158)  $ 

206  $ 

(142) 

757 

5 

— 

— 

— 

— 

— 

  — 

(121)   

631 

(18) 

48 

— 

13 

(102)   

9 

78 

— 

— 

— 

271 

35 

220 

(17)   

— 

(6)   

Long-term debt

  17,169 

(1,489)   

— 

  6,553 

  (2,615)   

Other financial liabilities 
measured on a recurring 
basis

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

10 

— 

  — 

86 

  — 

(200)   

— 

(16)   

214 

26 

219 

(163) 

23 

(91) 

10,270 

  — 

(7,656)    25,210 

(1,679) 

3 

  — 

(2)   

1 

— 

(1) Net realized/unrealized gains (losses) are presented as increase (decrease) to Level 3 assets, and as (increase) decrease to Level 3 liabilities. Changes in fair value 

of available-for-sale debt securities are recorded in AOCI, unless related to credit 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 and 

DVA on fair value option liabilities), attributable to the change in fair value relating to assets and liabilities classified as Level 3 that are still held at December 31, 
2020.

(4) Total Level 3 trading derivative assets and liabilities have been netted in these tables for presentation purposes only.

268

Securities loaned and sold 
under agreements to 
repurchase

Trading account liabilities

Securities sold, not yet 
purchased

Other trading liabilities

Short-term borrowings

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Net realized/unrealized
gains (losses) included in(1)

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

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 

(72)   

(80)   

150 

(105)   

160 

227 

136 

(1)   

(287)   

— 

— 

(393)   

(211)   

— 

— 

— 

10 

123 

61 

$ 

501  $ 

29  $ 

—  $ 

290  $ 

(257)  $ 

523  $ 

(1)  $ 

(891)  $ 

—  $ 

194  $ 

U.S. Treasury and 
federal agency securities $ 

1  $ 

—  $  —  $  —  $ 

20  $ 

—  $ 

(11)  $ 

(1)  $  —  $ 

200 

31 

360 

153 

1,484 

818 

(9)  $ 

(2)   

28 

284 

(21)   

(65)   

(52)   

— 

— 

— 

— 

— 

— 

1 

12 

213 

13 

51 

97 

(19)   

(7)   

(86)   

(19)   

(127)   

(283)   

2 

88 

323 

117 

738 

598 

— 

— 

(118)   

(100)   

— 

— 

64 

52 

(29)   

(742)   

(10)   

313 

— 

— 

36 

(143)   

(904)   

(630)   

— 

— 

100 

1,177 

(29)   

555 

(257) 

$  3,548  $ 

192  $ 

—  $ 

677  $ 

(798)  $ 

2,409  $ 

6  $  (3,539)  $ 

(40)  $  2,455  $ 

(284) 

1 

10 

(4) 

7 

— 

(2) 

1 

(11) 

(51) 

29 

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)

Investments

Mortgage-backed 
securities

U.S. government-
sponsored agency 
guaranteed

Residential

Commercial

Total investment 
mortgage-backed 
securities

(6)   

(784)   

(18)   

61 

(73)   

(425)   

(121)   

(412)   

— 

— 

— 

— 

152 

(97)   

113 

— 

(114)   

20 

(5)   

(213)   

274 

(111)   

(147)   

(8)   

(182)   

(1,596)   

(15)   

(15)   

(114)   

204 

252 

— 

— 

— 

(133)   

14 

(9)   

191 

(59)   

(56)   

(134) 

(422) 

(33) 

(289) 

$ 

(901)  $ 

(915)  $ 

—  $ 

(319)  $ 

538  $ 

408  $ 

(102)  $ 

(242)  $ 

(182)  $  (1,715)  $ 

1,316 

$ 

32  $ 

—  $ 

—  $  —  $  —  $ 

—  $ 

—  $  —  $ 

—  $ 

32  $ 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

— 

(1) 

— 

— 

$ 

32  $ 

—  $ 

—  $  —  $  —  $ 

—  $ 

—  $  —  $ 

—  $ 

32  $ 

(1) 

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

708 

68 

156 

— 

187 

— 

586 

—  $ 

—  $  —  $  —  $ 

—  $ 

—  $  —  $ 

—  $  —  $ 

— 

— 

— 

— 

— 

— 

— 

86 

2 

(14)   

— 

(11)   

— 

14 

— 

3 

— 

122 

— 

(318)   

— 

(94)   

— 

(612)   

— 

(11)   

39 

(1)   

430 

145 

— 

— 

550 

— 

11 

— 

— 

— 

— 

— 

— 

— 

(297)   

(119)   

(6)   

— 

(214)   

— 

— 

— 

— 

— 

— 

— 

623 

96 

45 

— 

22 

— 

(151)   

(32)   

441 

Total investments

$  1,737  $ 

—  $ 

52  $ 

178  $  (1,025)  $ 

1,136  $ 

—  $ 

(787)  $ 

(32)  $  1,259  $ 

— 

82 

2 

— 

— 

13 

— 

16 

112 

Table continues on the next page.

269

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
In millions of dollars

Dec. 31, 
2018

Principal
transactions

Other(1)(2)

into
Level 3

out of
Level 3

Purchases

Issuances

Sales

Settlements

Net realized/unrealized
gains (losses) included in(1)

Transfers

Unrealized
gains
(losses)
still held(3)

Dec. 31, 
2019

Loans

$ 

277  $ 

—  $ 

192  $ 

148  $ 

(189)  $ 

16  $ 

—  $ 

(40)  $ 

(2)  $ 

402  $ 

(84)   

— 

— 

— 

70 

  — 

(75)   

495 

186 

(68) 

Mortgage servicing rights

584 

Other financial assets 
measured on a recurring 
basis

Liabilities

— 

— 

— 

96 

6 

(2)   

2 

32 

(21)   

(112)   

1 

18 

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

Long-term debt
Other financial liabilities 
measured on a recurring 
basis

983 

121 

— 

1 

4 

586 

— 

37 

122 

— 

32 

— 

— 

— 

68 

— 

13 

(443)   

— 

(42)   

  12,570 

(1,899)   

— 

  3,304 

  (4,411)   

— 

— 

4 

5 

— 

— 

19 

— 

— 

— 

— 

— 

(168)   

58 

757 

(26) 

— 

(12)   

— 

  — 

168 

  — 

(48)   

— 

(131)   

48 

— 

13 

3 

— 

(1) 

6,766 

  — 

(2,958)    17,169 

(1,411) 

4 

  — 

(5)   

— 

— 

(1) Net realized/unrealized gains (losses) are presented as increase (decrease) to Level 3 assets, and as (increase) decrease to Level 3 liabilities. Changes in fair value 

of available-for-sale debt securities are recorded in AOCI, unless related to credit 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 and 

DVA on fair value option liabilities), 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 derivative assets and liabilities have been netted in these tables for presentation purposes only.

The following were the significant Level 3 transfers for 

the period December 31, 2018 to December 31, 2019:

•

Transfers of Long-term debt of $3.3 billion from Level 2 
to Level 3, and of $4.4 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.

Level 3 Fair Value Rollforward 
The following were the significant Level 3 transfers for the 
period December 31, 2019 to December 31, 2020:

•

•

During the 12 months ended December 31, 2020, 
transfers of Interest rate contracts of $1.6 billion from 
Level 2 to Level 3 were due to interest rate option 
volatility becoming an unobservable and/or significant 
input relative to the overall valuation of inflation and 
other interest rate derivatives.
During the 12 months ended December 31, 2020, 
$6.6 billion of Long-term debt containing embedded 
derivatives was transferred from Level 2 to Level 3, as a 
result of interest rate option volatility, equity correlation 
and credit derivative inputs becoming unobservable and/
or significant input relative to the overall valuation of 
certain structured long-term debt products. In other 
instances, market changes resulted in unobservable 
volatility inputs becoming insignificant to the overall 
valuation of the instrument (e.g., when an option becomes 
deep-in or deep-out of the money). This has resulted in 
$2.6 billion of certain structured long-term debt products 
being transferred from Level 3 to Level 2 during the 12 
months ended December 31, 2020.

270

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 one or more 
unobservable inputs are used that are 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, 2020

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)

Equity contracts (gross)(7)

Commodity and other contracts 
(gross)

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

$ 

320  Model-based

Credit spread

344  Price-based
168  Yield analysis

1,566  Price-based

852  Model-based
36  Model-based
36  Price-based

863  Price-based

Interest rate
Price
Yield

Price
Credit spread
Price
WAL
Recovery
(in millions)
Price

744  Yield analysis

Yield

205  Comparables analysis Illiquidity discount

142  Price-based

PE ratio

Price

$ 

$ 

$ 

$ 
$ 

$ 

$ 

$ 

$ 
$ 

15 bps

 0.30 %
30 
 2.63 %

— 
35 bps
— 

1.48 years

5,733 
2 

 3.77 %

 10.00 %

13.60x

$ 

$ 

$ 

$ 
$ 

15 bps

 0.35 %
111 
 21.80 %

2,265 
375 bps

31,000 
1.48 years

5,733 
157 

 21.77 %

 45.00 %

28.00x

15 bps

 0.32 %
80 
 10.13 %

90 
226 bps
5,132 
1.48 years

5,733 
59 

 9.01 %

 25.29 %

22.83x

$ 

136 

$ 

2,041 

$ 

1,647 

EBITDA multiples
Adjustment factor
Appraised value
(in thousands)
Revenue multiple

$ 

3.30x
0.20x

287 
2.70x

36.70x
0.61x

15.10x
0.25x

$ 

39,745 

$ 

21,754 

28.00x

8.92x

5,143  Model-based

Inflation volatility

1,296  Model-based

7,330  Model-based

1,636  Model-based

 0.27 %

 0.11 %

 1.70 %
 100.00 %

 0.84 %

 0.11 %

 40.00 %

 (21.71) %

 5.00 %
 65.88 %

 (44.92) %

 0.16 %

 15.40 %

 2.36 %

 0.73 %

 12.63 %
 100.00 %

 84.09 %

 0.52 %

 60.00 %

 40.00 %

 91.43 %
 105.20 %

 95.91 %

 80.17 %

 262.00 %

 0.78 %

 0.52 %

 5.41 %
 100.00 %

 17.55 %

 0.46 %

 50.00 %

 38.09 %

 42.74 %
 91.82 %

 70.60 %

 23.72 %

 98.53 %

3.50 bps

352.35 bps

99.89 bps

IR normal volatility

FX volatility
Contingent event

Interest rate

IR normal volatility

IR-FX correlation

IR-IR correlation

Equity volatility
Forward price
Commodity 
correlation

Commodity volatility

Forward price

Credit spread

271

Credit derivatives (gross)

$ 

1,854  Model-based

 
 
 
 
 
 
 
 
 
 
 
As of December 31, 2020

Fair value(1)
 (in millions)

Methodology

408  Price-based

Input
Recovery rate

Credit correlation
Upfront points
Equity volatility
Yield
WAL

Low(2)(3)

High(2)(3)

 20.00 %

 60.00 %

 25.00 %
 — %
 24.65 %
 2.86 %
2.66 years

 80.00 %
 107.20 %
 83.09 %
 16.00 %
5.40 years

Weighted
average(4)

 41.60 %

 43.36 %
 48.10 %
 58.23 %
 6.32 %
4.46 years

1,804  Model-based
258  Cash flow
78  Model-based

206  Model-based

IR Normal volatility

 0.11 %

 0.73 %

 0.54 %

631  Model-based

Interest rate

 0.08 %

 1.86 %

 0.71 %

$ 

$ 

$ 

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 and other trading 
liabilities

$ 

178  Model-based

IR lognormal 
volatility

 52.06 %

 128.87 %

 89.82 %

62  Price-based

Price

$ 

— 

$ 

866 

$ 

80 

Interest rate

 10.03 %

 20.07 %

 13.70 %

Short-term borrowings and 
long-term debt

$ 

24,827  Model-based

IR Normal volatility

Forward price

 0.11 %

 15.40 %

 0.73 %

 262.00 %

 0.51 %

 92.48 %

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

$ 

$ 

$ 

$ 

$ 

$ 

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

$ 

$ 

$ 

$ 
$ 

$ 

$ 

Derivatives—gross(6)
Interest rate contracts (gross)

$ 

2,196  Model-based

Inflation volatility

Foreign exchange contracts 
(gross)

$ 

1,099  Model-based

Mean reversion

IR normal volatility

FX volatility
IR normal volatility

FX rate

Interest rate

272

15 bps

 1.59 %
36 

$ 

15 bps

 3.67 %
505 

$ 

15 bps

 2.72 %
97 

$ 

$ 

$ 
$ 

$ 

$ 

— 
35 bps
— 

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 %

$ 

$ 

$ 
$ 

$ 

$ 

1,238 
295 bps

38,500 
1.48 years

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 %

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 %

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Equity contracts (gross)(7)

$ 

2,076  Model-based

IR-IR correlation

IR-FX correlation
Equity volatility
Forward price

WAL

Recovery
(in millions)

 (51.00) %

 40.00 %
 3.16 %
 62.60 %

 40.00 %

 60.00 %
 52.80 %
 112.69 %

 32.00 %

 50.00 %
 28.43 %
 98.46 %

1.48 years

1.48 years

1.48 years

$ 

5,450 

$ 

5,450 

$ 

5,450 

Commodity and other contracts 
(gross)

$ 

1,487  Model-based

Forward price

 37.62 %

 362.57 %

 119.32 %

Credit derivatives (gross)

$ 

613  Model-based
341  Price-based

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

$ 

$ 

$ 

$ 

$ 

Commodity 
volatility

Commodity
correlation

Credit spread
Upfront points

Price

Credit 
correlation
Recovery rate
Credit spread
Equity volatility
Yield
WAL

 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

 1.00 %

 97.59 %

 20.00 %

 111.06 %

 48.57 %
 48.00 %
48 bps
 32.00 %
 9.49 %
6.61 years

 10.50 %

 102.96 %

378  Model-based

418  Cash flow
77  Model-based

215  Model-based

Mean reversion

Forward price

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 %

(1) The fair value amounts presented in these tables 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) 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 

273

 
 
 
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 prepayments and high 
delinquencies amplifies each input’s negative impact on a 
mortgage securities’ valuation. As prepayment speeds change, 
the weighted 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.

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 

274

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, 2020
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

$ 

3,375  $ 

478  $ 

2,897 

17   

1,015   

4   

679   

13 

336 

315   

312   

3 

$ 

4,722  $ 

1,473  $ 

3,249 

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

Total assets at fair value 
on a nonrecurring basis

$ 

4,579  $ 

3,249  $ 

1,330 

20   

344   

6   

93   

14 

251 

249   

249   

— 

$ 

5,192  $ 

3,597  $ 

1,595 

(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.

275

 
 
 
 
 
 
 
 
 
 
 
 
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, 2020

Loans HFS

Other real estate owned

Loans(5)

As of December 31, 2019

Loans HFS

Other real estate owned

Loans(5)

Fair value(1)
 (in millions)

Methodology

Input

Low(2)

$ 

$ 

$ 

2,683  Price-based

7  Price-based

4  Recovery analysis

147  Price-based
73  Recovery analysis

$ 

Price
79 
Appraised value(4) $  3,110,711 
51 
Price

$ 

Price
Recovery rate
Appraised value(4) $ 

2 
 0.99 %

$ 

$ 

$ 

High

100 

4,241,357 

51 

49 
 78.00 %

$ 

$ 

$ 

Weighted
average(3)

98 

3,586,975 

51 

23 
 13.37 %

34 

$  43,646,426 

$  17,762,950 

Fair value(1)
 (in millions)

Methodology

Input

Low(2)

High

Weighted
average(3)

$ 

$ 

$ 

1,320  Price-based

11  Price-based

Price
Appraised value(4)

$ 

86 

$ 2,297,358 

$ 

$ 

100 

8,394,102 

$ 

$ 

99 

5,615,884 

5  Recovery analysis
100  Recovery analysis

54  Cash flow
47  Price-based

66  Price-based

Recovery rate

 0.57 %

 100.00 %

Price

$ 

2 

$ 

54 

$ 

Cost of capital

 0.10 %

 100.00 %

 64.78 %

27 

 54.84 %

Price

$ 17,521,218  $  43,646,426 

$  30,583,822 

(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) 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.

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,
2020

(91) 

(1) 

(137) 

70 

(159) 

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 

(1) Represents loans held for investment whose carrying amount is based on 
the fair value of the underlying collateral less costs to sell, primarily real 
estate.

276

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020

Estimated fair value

Carrying
value

Estimated
fair value

Level 1

Level 2

Level 3

$ 

110.3  $ 

113.2  $ 

23.3  $ 

87.0  $ 

109.5   

643.3   

383.2   

109.5   

663.9   

—   

—   

109.5   

0.6   

663.3 

383.2   

291.5   

18.1   

73.6 

2.9 

— 

$ 

1,278.7  $ 

1,278.8  $ 

—  $  1,093.3  $ 

185.5 

139.3   

204.6   

102.4   

139.3   

221.2   

102.4   

—   

—   

—   

139.3   

197.8   

19.2   

— 

23.4 

83.2 

December 31, 2019

Estimated fair value

Carrying
value

Estimated
fair value

Level 1

Level 2

Level 3

$ 

86.4  $ 

98.1   

681.2   

262.4   

87.8  $ 

1.9  $ 

83.8  $ 

98.1   

677.7   

—   

—   

98.1   

4.7   

673.0 

262.4   

177.6   

16.3   

68.5 

2.1 

— 

$ 

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 

(1) The carrying value of loans is net of the Allowance for credit losses on loans of $25.0 billion for December 31, 2020 and $12.8 billion for December 31, 2019. In 

(2)
(3)

addition, the carrying values exclude $0.7 billion and $1.4 billion of lease finance receivables at December 31, 2020 and 2019, respectively.
Includes items measured at fair value on a nonrecurring basis.
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.

277

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
(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, 2020 and 
2019 were liabilities of $7.3 billion and $5.1 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.

278

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. 
Movements in DVA are reported as a component of 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(2)
Long-term debt(2)
Total liabilities

Changes in fair value—gains (losses) 
for the years ended December 31,

2020

2019

$ 

$ 

$ 

$ 

$ 

$ 

$ 

—  $ 
(136)   

—   

2,486   

1   

2,487  $ 

(204)  $ 

299   

95  $ 

2,446  $ 

(154)  $ 

(559)   

(1)   

802   

(2,700)   

(2,612)  $ 

6 
77 

— 

(222) 

— 

(222) 

(84) 

91 

7 

(132) 

(205) 

386 

27 

(78) 

(5,174) 

(5,044) 

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. 

279

 
 
 
 
 
 
 
 
 
 
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 $616 million and a loss of $1,473 million for the years 
ended December 31, 2020 and 2019, 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, 2020

December 31, 2019

Trading assets

Loans

Trading assets

Loans

Carrying amount reported on the Consolidated Balance Sheet

$ 

8,063  $ 

6,854  $ 

8,320  $ 

4,086 

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

(915)   

—   

(14)   

4   

410   

—   

315 

1 

—   

—   

—   

— 

In addition to the amounts reported above, $1,068 million 

and $1,062 million of unfunded commitments related to 
certain credit products selected for fair value accounting were 
outstanding as of December 31, 2020 and 2019, respectively.

280

 
 
 
 
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, 2020 and 2019 due to instrument-specific credit 
risk totaled to a loss of $(16) million and a gain of $95 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 $0.5 billion and 
$0.2 billion at December 31, 2020 and 2019, 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, 2020, there 
were approximately $7.4 billion and $6.3 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,
2020

December 31, 
2019

$ 

1,742  $ 

1,254 

91   

—   

—   

(31) 

1 

— 

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, 2020 and 2019 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.

281

 
 
 
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, 2020 December 31, 2019

$ 

$ 

16.0  $ 

1.2   

27.3   

1.4   

2.6   

48.5  $ 

22.6 

0.7 

23.7 

1.8 

0.9 

49.7 

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, 2020 December 31, 2019

$ 

67,063  $ 

(5,130)   

55,783 

(2,967) 

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, 2020 December 31, 2019

$ 

4,683  $ 

68   

4,946 

1,411 

282

 
 
 
 
 
 
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, 
2020

December 31,
2019

$ 

231,696  $ 

152,352 

239,699   

174,717   

236,033 

131,392 

$ 

646,112  $ 

519,777 

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 
Commodity 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, net of 
allowance

Total

December 31,
2020

December 31,
2019

$ 

$ 

3,774  $ 

3,758 

14,203   

17,977  $ 

26,493 

30,251 

In addition, included in Cash and due from banks and 
Deposits with banks at December 31, 2020 and 2019 were 
$9.4 billion and $8.5 billion, respectively, of cash segregated 
under federal and other brokerage regulations or deposited 
with clearing organizations.

In response to the COVID-19 pandemic, the Federal 

Reserve Bank and certain other central banks eased 
regulations related to minimum required cash deposited with 
central banks. This resulted in a decrease in Citigroup’s 
restricted cash amount at December 31, 2020.

Collateral
At December 31, 2020 and 2019, the approximate fair value of 
collateral received by Citi that may be resold or repledged, 
excluding the impact of allowable netting, was $671.6 billion 
and $569.8 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, 2020 and 2019, 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 lendings, pledges to clearing 
organizations, segregation requirements under securities laws 
and regulations, derivative transactions and bank loans.

In addition, at December 31, 2020 and 2019, Citi had 
pledged $470.7 billion and $388.9 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 may contain renewal 
and extension options and early termination features. 
However, these options do not impact the lease term unless the 
Company is reasonably certain that it will exercise the options. 
These leases have a weighted-average remaining lease term of 
approximately six years as of December 31, 2020 and 2019. 
The operating lease ROU asset was $2.8 billion and 
$3.1 billion, as of December 31, 2020 and 2019, respectively. 
The operating lease ROU liability was $3.1 billion and 
$3.3 billion, as of December 31, 2020 and 2019, respectively. 
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 $27 million and 
$56 million of sublease income, was $1,054 million and 
$1,084 million for the years ended December 31, 2020 and 
2019, respectively. During 2019, Citi purchased a previously 
leased property in London. The purchased property is included 
in Other assets on the Consolidated Balance Sheet at both 
December 31, 2020 and 2019.

The table below provides the Cash Flow Statement 

Supplemental Information:

In millions of dollars
Cash paid for amounts included 
in the measurement of lease 
liabilities
Right-of-use assets obtained in 
exchange for new operating 
lease liabilities(1)(2)

December 31,
2020

December 31,
2019

$ 

814  $ 

942 

447   

499 

(1)   Represents non-cash activity and, accordingly, is not reflected in the 

Consolidated Statement of Cash Flow.

(2)  Excludes the decrease in the right-of-use assets related to the purchase of 

a previously leased property.

283

 
 
 
 
 
Citi’s future lease payments are as follows:

In millions of dollars

2021

2022

2023

2024

2025

Thereafter

Total future lease payments

Less imputed interest (based on weighted-average 
discount rate of 3.6%)

Lease liability

$ 

$ 

$ 

$ 

791 

663 

518 

399 

307 

766 

3,444 

(356) 

3,088 

Operating lease expense was $1.0 billion for the year 

ended December 31, 2018.

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.

284

 
 
 
 
 
The following tables present information about Citi’s guarantees:

In billions of dollars at December 31, 2020

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, 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

Maximum potential amount of future payments

Expire within
1 year

Expire after
1 year

Total amount
outstanding

Carrying value
(in millions of dollars)

$ 

25.3  $ 

7.3   

20.0   

—   

112.2   

101.9   

0.2   

—   

$ 

266.9  $ 

68.4  $ 

6.0   

60.9   

1.2   

—   

—   

0.8   

37.3   

174.6  $ 

93.7  $ 

13.3   

80.9   

1.2   

112.2   

101.9   

1.0   

37.3   

441.5  $ 

1,407 

72 

671 

9 

— 

3 

7 

35 

2,204 

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  $ 

6.9   

35.2   

—   

87.8   

91.6   

0.2   

—   

$ 

253.6  $ 

61.4  $ 

5.5   

60.8   

1.2   

—   

—   

0.4   

33.7   

163.0  $ 

93.3  $ 

12.4   

96.0   

1.2   

87.8   

91.6   

0.6   

33.7   

581 

36 

474 

7 

— 

— 

23 

41 

416.6  $ 

1,162 

(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, 2020 and 2019, this maximum potential exposure was estimated to be $102 billion and $92 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 
guarantees include certain over-the-counter written put options 

285

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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, 2020 and 
2019, this maximum potential exposure was estimated to be 
$101.9 billion and $91.6 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, 2020 and 2019, 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 one 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.

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’s 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 $31 million and $37 million at December 31, 
2020 and 2019, 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 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 

286

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, 2020 and 2019, 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 

287

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, 2020 or 2019 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 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 to ensure 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, 

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 $16.6 billion and $13.3 billion as of 
December 31, 2020 and 2019, 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.

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, 2020 and 2019 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 this indemnification obligation, given GE’s 2018 LTC 
and other charges and the September 2019 AM Best credit 
ratings downgrade for the Genworth 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 
brokers, dealers and clearing organizations) or Cash and due 
from banks, respectively. 

288

Carrying Value—Guarantees and Indemnifications
At December 31, 2020 and 2019, the total carrying amounts of 
the liabilities related to the guarantees and indemnifications 
included in the tables above amounted to approximately $2.2 
billion and $1.2 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 
$51.6 billion and $46.7 billion at December 31, 2020 and 
2019, respectively. Securities and other marketable assets held 
as collateral amounted to $80.1 billion and $58.6 billion at 
December 31, 2020 and 2019, 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 $6.6 billion and 
$4.4 billion at December 31, 2020 and 2019, 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.

In billions of dollars at December 31, 2020

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, 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

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 on 
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.

Maximum potential amount of future payments

Investment
grade

Non-
investment
grade

Not
rated

Total

78.5  $ 

9.8   

14.6  $ 

3.0   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

24.9   

113.2  $ 

12.4   

30.0  $ 

0.6  $ 

0.5   

80.9   

1.2   

112.2   

101.9   

1.0   

—   

298.3  $ 

93.7 

13.3 

80.9 

1.2 

112.2 

101.9 

1.0 

37.3 

441.5 

Maximum potential amount of future payments

Investment
grade

Non-
investment
grade

Not
rated

Total

81.2  $ 

9.7   

11.6  $ 

2.3   

—   

—   

—   

—   

—   

—   

—   

—   

—   

—   

21.3   

112.2  $ 

12.4   

26.3  $ 

0.5  $ 

0.4   

96.0   

1.2   

87.8   

91.6   

0.6   

—   

93.3 

12.4 

96.0 

1.2 

87.8 

91.6 

0.6 

33.7 

278.1  $ 

416.6 

$ 

$ 

$ 

$ 

289

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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

U.S.

Outside of 
U.S.

December 31,
2020

December 31, 
2019

658  $ 
2,654   

8,326   
11,256   
606,768   
201,969   
5,177   
836,808  $ 

4,563  $ 
2,348   

1,300   
1,611   
103,631   
120,489   
538   
234,480  $ 

5,221  $ 
5,002   

4,533 
3,721 

9,626   
12,867   
710,399   
322,458   
5,715   

10,799 
12,981 
708,023 
324,359 
1,948 
1,071,288  $  1,066,364 

$ 

$ 

The majority of unused commitments are contingent upon 

Both secured-by-real-estate and unsecured commitments 

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. 

are included in this line, as well as 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, 2020 and 2019, 
Citigroup had approximately $71.8 billion and $34.0 billion in 
unsettled reverse repurchase and securities borrowing 
agreements, and $62.5 billion and $38.7 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.

290

 
 
 
 
 
 
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 applicable, the 
amount of damages or scope of any penalties or other relief 
sought as appropriate in each pending matter.

291

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 multiyear 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, 2020, Citigroup estimates that the 
reasonably possible unaccrued loss for these matters ranges up 
to approximately $1.4 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, regulatory and tax 
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 
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 

292

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 likely 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 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 Federal Court in New South Wales, Australia. 
Additional information concerning this action is publicly 
available in court filings under the docket number NSD 1316 - 
NSD 1324/2020.

Facilitation Trading Matters
Regulatory agencies in Asia Pacific countries and elsewhere 
are conducting investigations or making inquiries regarding 
Citigroup affiliates’ equity sales trading desks in connection 
with facilitation trades, which are securities transactions in 
which Citigroup trades fully or partially as principal. Citigroup 
is cooperating with these investigations and inquiries.

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.

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 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. On 
November 19, 2020, the court granted final 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.). 

Antitrust and Other Litigation: In 2018, a number of 

In 2019, an application, captioned MICHAEL 

institutional investors who opted out of the previously 
disclosed August 2018 final settlement filed an action against 
Citigroup, Citibank, Citigroup Global Markets Inc. (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. On July 28, 2020, plaintiffs 
filed a third 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 2018, a group of institutional investors issued a claim 
against Citigroup, Citibank and other defendants, captioned 
ALLIANZ GLOBAL INVESTORS GMBH AND OTHERS v. 
BARCLAYS BANK PLC AND OTHERS, in the High Court 
of Justice in London. Claimants allege that defendants 
manipulated, and colluded to manipulate, the foreign exchange 
market in violation of EU and U.K. competition laws. 
Additional information concerning this action is publicly 
available in court filings under the case number 
CL-2018-000840.

In 2015, a putative class of consumers and businesses in 

the U.S. 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 (later 
transferred to the United States District Court for the Southern 
District of New York). Subsequently, plaintiffs filed an 
amended class action complaint against 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.).

293

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 Citigroup, Citibank 
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 case number 1329/7/7/19.

In 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 Citigroup, Citibank 
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 case number 1336/7/7/19.

In 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.

In 2019, two motions for certification of class actions 

filed against Citigroup, Citibank 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. A hearing on 
Citibank’s motion to dismiss plaintiffs’ petition for 
certification is scheduled for April 12, 2021. Additional 
information concerning this action is publicly available in 
court filings under the docket number CA 29013-09-18.

Hong Kong Private Bank Litigation
In 2007, a claim was filed in the High Court of Hong Kong
claiming damages of over $51 million against Citibank. The
case, captioned PT ASURANSI TUGU PRATAMA
INDONESIA TBK v. CITIBANK N.A., was dismissed in
2018 by the Hong Kong Court of First Instance on grounds
that the claim was time-barred. Plaintiff has appealed the
court’s dismissal. Additional information concerning this
action is publicly available in court filings under the docket
number CACV 548/2018.

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 2018, plaintiffs entered into a settlement with 
Citigroup and Citibank, under which Citigroup and Citibank 
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 an 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, 

294

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 March 2020, the court granted 
defendants’ motion to dismiss the action for failure to state a 
claim, which plaintiffs appealed to the United States Court of 
Appeals for the Second Circuit. On December 28, 2020, DYJ 
Holdings, LLC filed a motion to intervene as a plaintiff, given 
that the existing plaintiffs intended to withdraw from the case, 
which defendants opposed and separately moved to dismiss 
for lack of subject matter jurisdiction. Additional information 
concerning this action is publicly available in court filings 
under the docket numbers 19 Civ. 439 (S.D.N.Y.) (Daniels, J.) 
and 20-1492 (2d Cir.).

On August 18, 2020, individual borrowers and consumers 

of loans and credit cards filed an action against Citigroup, 
Citibank, CGMI and other defendants, captioned 
MCCARTHY, ET AL. v. INTERCONTINENTAL 
EXCHANGE, INC., ET AL., in the United States District 
Court for the Northern District of California. Plaintiffs allege 
that defendants conspired to fix ICE LIBOR, assert claims 
under the Sherman Act and the Clayton Act, and seek 
declaratory relief, injunctive relief, and treble damages. On 
November 11, 2020, defendants filed a motion to transfer the 
case to the United States District Court for the Southern 
District of New York. Additional information concerning this 
action is publicly available in court filings under the docket 
number 20 Civ. 5832 (N.D. Cal.) (Donato, 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 
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. 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, including Citigroup and affiliates. 
In 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, later 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 actions 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 2019, and subsequently filed 
an 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 

295

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, which 
defendants later moved to dismiss. 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, Citibank, 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. In 2019, the 
Italian Supreme Court affirmed the decision in the full amount 
of $431 million. Citigroup has taken steps to enforce the 
judgment in Italian and Belgian courts. Additional information 
concerning these actions is publicly available in court filings 
under the docket numbers 27618/2014, 4133/2019, and 
22098/2019 (Italy), and 20/3617/A and 20/4007/A (Brussels). 
In 2015, Parmalat filed a claim in an Italian civil court in 

Milan claiming damages of €1.8 billion against Citigroup, 
Citibank, and related parties. The Milan court dismissed 
Parmalat’s claim on grounds that it was duplicative of 
Parmalat’s previously unsuccessful claims. In 2019, the Milan 
Court of Appeal rejected Parmalat’s appeal of the Milan 
court’s dismissal. 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 numbers 1009/2018 and 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. On November 5, 2020, Citibank 
joined the proceedings, seeking dismissal of the declaratory 
judgment application. Additional information concerning this 
action is publicly available in court filings under the docket 
number 8611/2020.

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 U.K. Financial 
Conduct Authority, and to defend claims filed in U.K. courts.

Revlon Credit Facility Litigation
On August 12, 2020, Citibank 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 UMB BANK, NATIONAL ASSOCIATION 
v. REVLON, INC., ET AL. Plaintiff alleged that, with respect 
to a 2016 credit agreement between Revlon and various 
lenders for which Citibank served as administrative and
collateral agent, the defendants deprived lenders of the 
collateral securing loans they made to Revlon under the credit 
agreement. On November 8, 2020, plaintiffs withdrew the case 

without prejudice. Additional information concerning this 
action is publicly available in court filings under the docket 
number 20-CV-6352 (S.D.N.Y.) (Schofield, J.).

Revlon-related Wire Transfer Litigation
On August 17, 18, and 20, 2020, Citibank filed actions in the 
United States District Court for the Southern District of New 
York, which have been consolidated under the caption IN RE 
CITIBANK AUGUST 11, 2020 WIRE TRANSFERS. The 
actions relate to a payment erroneously made by Citibank on 
August 11, 2020, in its capacity as administrative agent for a 
Revlon credit facility. The action seeks the return of the 
erroneously transferred funds from certain fund managers. 
Citibank has asserted claims for unjust enrichment, 
conversion, money had and received, and payment by mistake. 
The court issued temporary restraining orders related to the 
subject funds. A trial was held in December 2020. On 
February 16, 2021, the court issued a judgment in favor of the 
defendants. Additional information concerning this action is 
publicly available in court filings under the docket number 20-
CV-6539 (S.D.N.Y.) (Furman, J.).

Shareholder Derivative and Securities Litigation
Beginning on October 16, 2020, four derivative actions were 
filed in the United States District Court for the Southern 
District of New York, purportedly on behalf of Citigroup (as 
nominal defendant) against Citigroup’s current directors and 
certain former directors. On December 3, 2020, the actions 
were consolidated under the caption IN RE CITIGROUP INC. 
SHAREHOLDER DERIVATIVE LITIGATION. On 
December 24, 2020, plaintiffs filed a consolidated complaint 
asserting claims for breach of fiduciary duty, unjust 
enrichment, and contribution and indemnification in 
connection with defendants’ alleged failures to implement 
adequate internal controls. In addition, the consolidated 
complaint asserts derivative claims for violations of Sections 
10(b) and 14(a) of the Securities Exchange Act of 1934 in 
connection with statements in Citigroup’s 2019 and 2020 
annual meeting proxy statements. Additional information 
concerning this action is publicly available in court filings 
under the docket number 1:20-cv-09438 (S.D.N.Y.) (Nathan, 
J.). 

Beginning on December 4, 2020, two derivative actions 

were filed in the Supreme Court of the State of New York, 
purportedly on behalf of Citigroup (as nominal defendant) 
against Citigroup’s current directors, certain former directors, 
and certain current and former officers. The actions are 
captioned P. ALEXANDER ATAII v. CORBAT, ET AL. and 
ASHLEY IKEDA v. CORBAT, ET AL. The complaints assert 
claims for breach of fiduciary duty and unjust enrichment in 
connection with defendants’ alleged failures to implement 
adequate internal controls. Additional information concerning 
these actions is publicly available in court filings under the 
docket numbers 656759/2020 (N.Y. Sup. Ct.) and 
657086/2020 (N.Y. Sup. Ct.).

Beginning on October 30, 2020, three putative class 
action complaints were filed in the United States District 
Court for the Southern District of New York against Citigroup 
and certain of its current and former officers, asserting 
violations of Sections 10(b) and 20(a) of the Securities 

296

Exchange Act of 1934 in connection with defendants’ alleged 
misstatements concerning Citigroup’s internal controls. The 
actions are captioned CITY OF SUNRISE FIREFIGHTERS’ 
PENSION FUND v. CITIGROUP INC., ET AL., CITY OF 
STERLING HEIGHTS GENERAL EMPLOYEES’ 
RETIREMENT SYSTEM v. CITIGROUP INC., ET AL., and 
TIMOTHY LIM v. CITIGROUP INC., ET AL. Additional 
information concerning these actions is publicly available in 
court filings under the docket numbers 1:20-CV-9132 
(S.D.N.Y.) (Nathan, J.), 1:20-CV-09573 (S.D.N.Y.) (Nathan, 
J.), and 1:20-CV-10360 (S.D.N.Y.) (Nathan, J.). 

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 2017, a consolidated amended complaint was filed, 
alleging that defendants colluded to fix U.S. 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 U.S. 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, actions by putative classes of 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 
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 2019, the court granted 
defendants’ motion to dismiss certain defendants, including 
CGML. On June 1, 2020, plaintiffs appealed to the United 
States Court of Appeals for the Second Circuit from the 
district court’s grant of defendants’ remaining motion to 
dismiss the second amended consolidated complaint. 
Additional information concerning this action is publicly 
available in court filings under the docket numbers 16 Civ. 
3711 (S.D.N.Y.) (Ramos, J.) and 20-1759 (2d Cir.).

In 2017, purchasers of SSA bonds filed a proposed class 

action on behalf of direct and indirect purchasers of SSA 

bonds 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. The complaint alleges that defendants
manipulated, and colluded to manipulate, the SSA bonds 
market, asserts claims for breach of the Competition Act, 
breach of foreign law, civil conspiracy, unjust enrichment, 
waiver of tort, and breach of contract, and seeks compensatory 
and punitive damages, among other relief. Additional 
information concerning this action is publicly available in 
court filings under the docket number T-1871-17 (Fed. Ct.).

In 2019, the State of Louisiana filed an 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. The complaint alleges that defendants conspired to 
manipulate the market for bonds issued by U.S. government-
sponsored agencies. The complaint asserts a claim 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.). 

In 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. Additional 
information concerning this action is publicly available in 
court filings under the docket number 19 Civ. 725 (M.D. La.) 
(Dick, C.J.).

On April 1, 2020, the Louisiana Asset Management Pool 

filed a substantially similar action against CGMI and other 
defendants, captioned LOUISIANA ASSET MANAGEMENT 
POOL v. BANK OF AMERICA CORPORATION, ET AL., 
in the United States District Court for the Eastern District of 
Louisiana, which was subsequently transferred to the United 
States District Court for the Middle District of Louisiana. 
Additional information concerning this action is publicly 
available in court filings under the docket number 21 Civ. 
0003 (M.D. La.) (Dick, C.J.).

On September 21, 2020, the City of New Orleans and 

related entities filed a substantially similar action against 
CGMI and other defendants, captioned CITY OF NEW 
ORLEANS, ET AL. v. BANK OF AMERICA 
CORPORATION, ET AL., in the United States District Court 
for the Eastern District of Louisiana. Additional information 
concerning this action is publicly available in court filings 
under the docket number 20 Civ. 2570 (E.D. La.) (Vitter, 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. The complaint alleges that defendants colluded in the 
Mexican sovereign bond market. In September 2019, the court 
granted defendants’ motion to dismiss. In December 2019, 
plaintiffs filed an amended complaint against Citibanamex and 

297

other market makers in the Mexican sovereign bond market. 
Plaintiffs no longer assert any claims against Citigroup and 
any other U.S. 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 seeks treble damages, 
restitution and injunctive relief. On February 21, 2020, certain 
defendants, including Citibanamex, moved to dismiss the 
amended, which the court later granted. Additional 
information concerning this 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 non-U.S. tax authorities, including in the 
U.K., 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. 

In the adversary proceeding captioned KIRSCHNER v. 

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. 
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 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 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 2019, the Court of Appeals issued an amended 
decision again affirming the dismissal. In January 2020, the 
noteholders filed a petition for rehearing. On July 6, 2020, the 
noteholders filed a petition for a writ of certiorari in the United 
States Supreme Court. On October 5, 2020, the Supreme 

Court called for the views of the Acting Solicitor General on 
whether the petition should be granted.

CGMI was named as a defendant in a separate action, 
KIRSCHNER v. CGMI, in connection with its role as advisor 
to Tribune. In 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.), 
16-317 (U.S.), and 20-8 (U.S. Supreme Court).

Variable Rate Demand Obligation Litigation
In 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. On November 6, 2020, the court 
granted in part and denied in part defendants’ motion to 
dismiss the consolidated complaint. Additional information 
concerning this action 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 or other 
accruals.

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299

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, 2020, 2019 and 2018, Condensed 
Consolidating Balance Sheet as of December 31, 2020 and 
2019 and Condensed Consolidating Statement of Cash Flows 
for the years ended December 31, 2020, 2019 and 2018 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. 

300

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 revenue
Other revenue—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 from continuing operations before income taxes
Provision (benefit) for income taxes
Income from continuing operations
Income (loss) from discontinued operations, net of taxes

Net income before attribution of noncontrolling interests
Noncontrolling interests

Net income 
Comprehensive income 
Add: Other comprehensive income (loss) 
Total Citigroup comprehensive income

Add: Other comprehensive income attributable to noncontrolling 
interests
Add: Net income attributable to noncontrolling interests
Total comprehensive income

Year ended December 31, 2020

Citigroup 
parent 
company

Other Citigroup 
subsidiaries and 
eliminations

CGMHI

Consolidating 
adjustments

Citigroup 
consolidated

$ 

$ 
$ 

$ 
$ 
$ 

$ 

$ 
$ 

$ 

$ 

$ 

$ 

$ 
$ 

$ 

$ 

2,355  $ 
—   
4,162   
4,992   
502   
(1,332)  $ 
—  $ 
(36)   
(1,254)   
693   
(127)   
111   
(613)  $ 
410  $ 
—  $ 

(5)  $ 
191   
37   
15   
238  $ 
9,894  $ 

10,066  $ 
(981)   
11,047  $ 
—   

11,047  $ 
—   

11,047  $ 

—  $ 
5,364   
920   
1,989   
2,170   
2,125  $ 
6,216  $ 
290   
(4,252)   
9,064   
706   
23   
12,047  $ 
14,172  $ 
(1)  $ 

4,941  $ 
—   
2,393   
2,317   
9,651  $ 
—  $ 

4,522  $ 
1,249   
3,273  $ 
—   

3,273  $ 
—   

3,273  $ 

—  $ 
52,725   
(5,082)   
7,560   
(2,672)   
42,755  $ 
5,169  $ 
(254)   
19,391   
(9,757)   
4,901   
(134)   
19,316  $ 
62,071  $ 
17,496  $ 

17,278  $ 
(191)   
18,527   
(2,332)   
33,282  $ 
—  $ 

11,293  $ 
2,257   
9,036  $ 
(20)   

9,016  $ 
40   

8,976  $ 

(2,355)  $ 
—   
—   
—   
—   
—  $ 
—  $ 
—   
—   
—   
—   
—   
—  $ 
(2,355)  $ 
—  $ 

—  $ 
—   
—   
—   
—  $ 
(9,894)  $ 

(12,249)  $ 
—   
(12,249)  $ 
—   

(12,249)  $ 
—   

(12,249)  $ 

— 
58,089 
— 
14,541 
— 
43,548 
11,385 
— 
13,885 
— 
5,480 
— 
30,750 
74,298 
17,495 

22,214 
— 
20,957 
— 
43,171 
— 

13,632 
2,525 
11,107 
(20) 

11,087 
40 

11,047 

4,260  $ 
15,307  $ 

(223)  $ 
3,050  $ 

4,244  $ 
13,220  $ 

(4,021)  $ 
(16,270)  $ 

4,260 
15,307 

—  $ 
—   
15,307  $ 

—  $ 
—   
3,050  $ 

26  $ 
40   
13,286  $ 

—  $ 
—   
(16,270)  $ 

26 
40 
15,373 

301

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 revenue
Other revenue—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 from continuing operations before income taxes
Provision (benefit) for income taxes
Income from continuing operations
Income (loss) from discontinued operations, net of taxes

Net income (loss) before attribution of noncontrolling 
interests
Noncontrolling interests

Net income 
Comprehensive income 
Add: Other comprehensive income (loss) 
Total Citigroup comprehensive income

Add: Other comprehensive income attributable to noncontrolling 
interests
Add: Net income attributable to noncontrolling interests
Total comprehensive income

Year ended December 31, 2019

Citigroup 
parent 
company

Other Citigroup 
subsidiaries and 
eliminations

CGMHI

Consolidating 
adjustments

Citigroup 
consolidated

$ 

$ 
$ 

$ 
$ 
$ 

$ 

$ 
$ 
$ 

$ 

$ 

$ 

$ 
$ 

$ 

$ 

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  $ 

—  $ 
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  $ 

852  $ 
20,253  $ 

(651)  $ 
401  $ 

—  $ 
—   
20,253  $ 

—  $ 
—   
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 

302

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 revenue
Other revenue—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 from continuing operations before income taxes
Provision (benefit) for income taxes
Income from continuing operations
Income (loss) from discontinued operations, net of taxes

Net income before attribution of noncontrolling interests
Noncontrolling interests

Net income 
Comprehensive income 
Add: Other comprehensive income (loss) 
Total Citigroup comprehensive income

Add: Other comprehensive income attributable to noncontrolling 
interests
Add: Net income attributable to noncontrolling interests
Total comprehensive income

Year ended December 31, 2018

Citigroup 
parent 
company

Other Citigroup 
subsidiaries and 
eliminations

CGMHI

Consolidating 
adjustments

Citigroup 
consolidated

$ 

$ 
$ 

$ 
$ 
$ 

$ 

$ 
$ 

$ 

$ 

$ 

$ 

$ 
$ 

$ 

$ 

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  $ 

—  $ 
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  $ 

(22,854)  $ 
—   
—   
—   
—   
—  $ 
—  $ 
—   
—   
—   
—   
—   
—  $ 
(22,854)  $ 
—  $ 

—  $ 
—   
—   
—   
—  $ 
2,163  $ 

(20,691)  $ 
—   
(20,691)  $ 
—   

(20,691)  $ 
—   

(20,691)  $ 

— 
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 

3,500  $ 
23,727  $ 

(3,757)  $ 
(24,448)  $ 

(2,499) 
15,546 

(43)  $ 
35   
23,719  $ 

—  $ 
—   
(24,448)  $ 

(43) 
35 
15,538 

303

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Condensed Consolidating Balance Sheet

In millions of dollars
Assets
Cash and due from banks
Cash and due from banks—intercompany
Deposits with banks, net of allowance
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, net of allowance
Loans, net of unearned income
Loans, net of unearned income—intercompany
Allowance for credit losses on loans (ACLL)
Total loans, net
Advances to subsidiaries
Investments in subsidiaries
Other assets, net of allowance(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, including allowance
Other liabilities—intercompany
Stockholders’ equity
Total liabilities and equity

December 31, 2020

Citigroup 
parent 
company

CGMHI

Other 
Citigroup 
subsidiaries 
and 
eliminations

Consolidating 
adjustments

Citigroup 
consolidated

$ 

$ 
$ 

$ 

$ 

$ 

—  $ 
16   
—   
4,500   
—   

628  $ 
6,081   
5,224   
8,179   
238,718   

25,721  $ 
(6,097)   
278,042   
(12,679)   
55,994   

—   
307   
723   
1   
—   
—   
—   
—  $ 
152,383  $ 
213,267   
12,156   
2,781   
386,134  $ 

24,309   
222,278   
9,400   
374   
2,524   
—   
—   
2,524  $ 
—  $ 
—   
60,273   
51,489   
629,477  $ 

(24,309)   
152,494   
(10,123)   
446,984   
673,359   
—   
(24,956)   
648,403  $ 
(152,383)  $ 
—   
109,969   
(54,270)   
1,457,746  $ 

—  $ 
—   
—   
—   
—   

26,349 
— 
283,266 
— 
294,712 

—   
—   
—   
—   
—   
—   
—   
—  $ 
—  $ 
(213,267)   
—   
—   
(213,267)  $ 

— 
375,079 
— 
447,359 
675,883 
— 
(24,956) 
650,927 
— 
— 
182,398 
— 
2,260,090 

—  $ 
—   
—   

—  $ 
—   
184,786   

1,280,671  $ 
—   
14,739   

—  $ 
—   
—   

1,280,671 
— 
199,525 

—   
—   
397   
—   
—   
170,563   
—   
12,975   
2,692   
65   
199,442   
386,134  $ 

76,590   
113,100   
8,591   
12,323   
12,757   
47,732   
67,322   
—   
55,217   
15,378   
35,681   
629,477  $ 

(76,590)   
54,927   
(8,988)   
17,191   
(12,757)   
53,391   
(67,322)   
(12,975)   
52,558   
(15,443)   
178,344   
1,457,746  $ 

—   
—   
—   
—   
—   
—   
—   
—   
—   
—   
(213,267)   
(213,267)  $ 

— 
168,027 
— 
29,514 
— 
271,686 
— 
— 
110,467 
— 
200,200 
2,260,090 

(1) Other assets for Citigroup parent company at December 31, 2020 included $29.5 billion of placements to Citibank and its branches, of which $24.3 billion had a 

remaining term of less than 30 days. 

304

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Condensed Consolidating Balance Sheet

In millions of dollars
Assets
Cash and due from banks
Cash and due from banks—intercompany
Deposits with banks, net of allowance
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, net of allowance
Loans, net of unearned income
Loans, net of unearned income—intercompany
Allowance for credit losses on loans (ACLL)
Total loans, net
Advances to subsidiaries
Investments in subsidiaries
Other assets, net of allowance(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, including allowance
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  $ 

—  $ 
—   
—   
—   
—   

23,967 
— 
169,952 
— 
251,322 

—   
—   
—   
—   
—   
—   
—   
—  $ 
—  $ 
(202,116)   
—   
—   
(202,116)  $ 

— 
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. 

305

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 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 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 year

Cash and due from banks and deposits with banks at end of 
year

Cash and due from banks

Deposits with banks, net of allowance

Cash and due from banks and deposits with banks at end of 
year

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, 2020

Citigroup 
parent 
company

CGMHI

Other 
Citigroup 
subsidiaries 
and 
eliminations

Consolidating 
adjustments

Citigroup 
consolidated

5,002  $ 

(26,195)  $ 

572  $ 

—  $ 

(20,621) 

—  $ 
—   
—   
—   
—   

—  $ 
—   
—   
—   
—   

(334,900)  $ 
146,285   
124,229   
14,249   
1,495   

—   
(5,584)   
—   

(46,044)   
(6,917)   
(54)   

2,654   
12,501   
(3,226)   

—  $ 
—   
—   
—   
—   

—   
—   
—   

(334,900) 
146,285 
124,229 
14,249 
1,495 

(43,390) 
— 
(3,280) 

(5,584)  $ 

(53,015)  $ 

(36,713)  $ 

—  $ 

(95,312) 

(5,352)  $ 
2,995   
(1,500)   
(2,925)   
16,798   

(172)  $ 
—   
—   
—   
6,349   

172  $ 
—   
—   
—   
(10,091)   

—   
—   

—   
—   

3,960   
—   

(3,960)   
210,081   

79,322   
1,228   

(46,136)   
(16,763)   

(7,528)   
—   
(411)   

(7,806)   
—   
—   

15,334   
—   
—   

—  $ 
—   
—   
—   
—   

—   
—   

—   
—   

—   
—   
—   

(5,352) 
2,995 
(1,500) 
(2,925) 
13,056 

— 
210,081 

33,186 
(15,535) 

— 
— 
(411) 

2,077  $ 
—  $ 
1,495  $ 

82,881  $ 
—  $ 
3,671  $ 

148,637  $ 
(1,966)  $ 
110,530  $ 

—  $ 
—  $ 
—  $ 

233,595 
(1,966) 
115,696 

3,021   

16,441   

174,457   

—   

193,919 

4,516  $ 

20,112  $ 

284,987  $ 

16  $ 

6,709  $ 

19,624  $ 

4,500   

13,403   

265,363   

—  $ 

—  $ 

—   

309,615 

26,349 

283,266 

4,516  $ 

20,112  $ 

284,987  $ 

—  $ 

309,615 

(1,883)  $ 
2,681   

1,138  $ 
4,516   

5,542  $ 
6,101   

—  $ 
—   

4,797 
13,298 

—  $ 

—  $ 

2,614  $ 

—  $ 

2,614 

306

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
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 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 year
Cash and due from banks and deposits with banks at end of 
year

Cash and due from banks

Deposits with banks, net of allowance
Cash and due from banks and deposits with banks at end of 
year
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, 2019
Other 
Citigroup 
subsidiaries 
and 
eliminations

CGMHI

Consolidating 
adjustments

Citigroup 
consolidated

Citigroup 
parent 
company

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   

—   
—   

—   
—   

(968)   
—   
(364)   

—  $ 
—   
—   
—   
10,389   

(7,177)   
—   

5,115   
7,440   

5,843   
(74)   
(253)   

—  $ 
—   
—   
—   
(3,950)   

7,177   
57,420   

(16,544)   
5,263   

(4,875)   
74   
253   

(23,168)  $ 
—  $ 

21,283  $ 
—  $ 

44,818  $ 
(908)  $ 

1  $ 

764  $ 

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 

307

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Condensed Consolidating Statements of Cash Flows

In millions of dollars

Net cash provided by 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 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 (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 year

Cash and due from banks and deposits with banks at end of 
year

Cash and due from banks

Deposits with banks, net of allowance

Cash and due from banks and deposits with banks at end of 
year

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, 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   
(5,331)  $ 

(5,020)  $ 
(793)   
(14,433)   
(5,099)   

—   
—   

—   
32   

1,819   
—   
(482)   

(18)  $ 
3   
—   
—   
—   

—   

(34,018)   
(832)   
(59)   
(34,924)  $ 

—  $ 
—   
—   
10,278   

10,708   
—   

23,454   
88   

(19,111)   
(798)   
—   

(144,514)  $ 
53,854   
83,604   
(29,002)   
4,549   

314   

(4,188)   
6,398   
(3,878)   
(32,863)  $ 

—  $ 
—   
—   
(2,656)   

(10,708)   
53,348   

(1,963)   
(12,226)   

17,292   
798   
—   

(23,976)  $ 
—  $ 

24,619  $ 
—  $ 

43,885  $ 
(773)  $ 

(7,993)  $ 

2,982  $ 

12,600  $ 

—  $ 
—   
—   
—   
—   

—   

—   
—   
—   
—  $ 

—  $ 
—   
—   
—   

—   
—   

—   
—   

—   
—   
—   

—  $ 
—  $ 

—  $ 

(152,487) 
61,491 
83,604 
(29,002) 
4,549 

314 

(38,206) 
— 
(3,381) 
(73,118) 

(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 

308

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
29.  SUBSEQUENT EVENT

As a result of new information Citi received subsequent to 
December 31, 2020, Citi adjusted downward its 2020 
financial results (recognized in the fourth quarter of 2020) 
from those previously reported on January 15, 2021, due to a 
$390 million increase in operating expenses ($323 million 
after-tax) recorded within ICG, resulting from operational 
losses related to certain legal matters. Citi’s results of 
operations and financial condition for the full year 2020, as 
reported in this Annual Report on Form 10‑K for the year 
ended December 31, 2020, reflect the impact of this 
adjustment.

309

30.  SELECTED QUARTERLY FINANCIAL DATA (UNAUDITED)

2020

2019

In millions of dollars, except per share amounts

Revenues, net of interest expense

Operating expenses
Provisions (release) for credit losses and for benefits 
and claims

Income from continuing operations before income 
taxes
Income taxes(3)
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(4)
Basic

Fourth(1) Third(2) Second(2)
$  16,499  $  17,302  $  19,766  $  20,731  $  18,378  $  18,574  $  18,758  $  18,576 

First(2)

Second

Fourth

Third

First

  11,104    10,964    10,460    10,643   

10,454    10,464    10,500   

10,584 

(46)   

2,384   

8,197   

6,960   

2,222   

2,088   

2,093   

1,980 

$  5,441  $  3,954  $  1,109  $  3,128  $ 

5,702  $  6,022  $  6,165  $ 

6,012 

1,116   

777   

52   

580   

703   

1,079   

1,373   

1,275 

$  4,325  $  3,177  $  1,057  $  2,548  $ 

4,999  $  4,943  $  4,792  $ 

4,737 

6   

(7)   

(1)   

(18)   

(4)   

(15)   

17   

(2) 

$  4,331  $  3,170  $  1,056  $  2,530  $ 

4,995  $  4,928  $  4,809  $ 

4,735 

22   

24   

—   

(6)   

16   

15   

10   

25 

$  4,309  $  3,146  $  1,056  $  2,536  $ 

4,979  $  4,913  $  4,799  $ 

4,710 

Income from continuing operations

$ 

1.93  $ 

1.37  $ 

0.38  $ 

1.07  $ 

2.16  $ 

2.09  $ 

1.94  $ 

Net income

Diluted

1.93   

1.37   

0.38   

1.06   

2.16   

2.09   

1.95   

Income from continuing operations

Net income

1.92   

1.92   

1.36   

1.36   

0.38   

0.38   

1.06   

1.06   

2.15   

2.15   

2.08   

2.07   

1.94   

1.95   

1.88 

1.88 

1.87 

1.87 

This Note to the Consolidated Financial Statements is unaudited due to the Company’s individual quarterly results not being subject to an audit.
(1)   As a result of new information Citi received subsequent to December 31, 2020, Citi adjusted downward its fourth quarter of 2020 financial results from those 

(2) 

previously reported on January 15, 2021, due to a $390 million increase in operating expenses ($323 million after‑tax) recorded within ICG, resulting from 
operational losses related to certain legal matters. The downward adjustment lowered Citigroup’s fourth quarter net income from $4.6 billion to $4.3 billion and 
earnings per diluted share from $2.08 to $1.92.
In the fourth quarter of 2020, Citi revised the second quarter accounting conclusion for its variable post-charge-off third-party collection costs from a “change in 
accounting estimate effected by a change in accounting principle” to a “change in accounting principle,” which requires an adjustment to January 1, 2020 opening 
retained earnings, rather than net income. As a result, Citi’s full-year and quarterly results for 2020 have been revised to reflect this change as if it were effective 
as of January 1, 2020. Citi recorded an increase to its beginning retained earnings on January 1, 2020 of $330 million and a decrease of $443 million in its 
allowance for credit losses on loans, as well as a $113 million increase in other assets related to income taxes, and recorded a decrease of $18 million to its 
provisions for credit losses on loans in the first quarter and increases of $339 million and $122 million to its provisions for credit losses on loans in the second and 
third quarters, respectively. In addition, Citi’s operating expenses increased by $49 million and $45 million with a corresponding decrease in net credit losses, in 
the first and second quarters, respectively. See Note 1 to the Consolidated Financial Statements for additional information.

(3)  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.

(4)  Certain securities were excluded from the second quarter of 2020 diluted EPS calculation because they were anti-dilutive. Year-to-date EPS will not equal the sum 

of the individual quarters because the year-to-date EPS calculation is a separate calculation. In addition, 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

310

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
FINANCIAL DATA SUPPLEMENT

RATIOS 

Return on average assets

 0.50 %  0.98 %

 0.94 %

2020

2019

2018

Return on average common 
stockholders’ equity(1)
Return on average total 
stockholders’ equity(2)
Total average equity to average 
assets(3)
Dividend payout ratio(4)

 5.7 

 10.3 

 5.7 

 8.7 

 43 

 9.9 

 9.9 

 24 

 9.4 

 9.1 

 10.3 

 23 

(1)  Based on Citigroup’s net income less preferred stock dividends as a 

percentage of average common stockholders’ equity. 

(2)  Based on Citigroup’s net income as a percentage of average total 

Citigroup stockholders’ equity.

(3)  Based on average Citigroup stockholders’ equity as a percentage of 

average assets.

(4)  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

2020
Average 
balance

Average 
interest rate

2019
Average 
balance

Average 
interest rate

2018
Average 
balance

 0.10 % $ 

130,970 

 0.59 % $ 

52,699 

 1.35 % $ 

44,426 

 0.33 

 0.94 

311,342 

210,896 

 1.08 

 1.28 

293,209 

223,450 

 0.61 

 1.31 

287,665 

209,410 

 0.48 % $ 

653,208 

 1.11 % $ 

569,358 

 0.94 % $ 

541,501 

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, 2020

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

$ 

$ 

8,257  $ 

4,531   

7,478  $ 

2,535  $ 

13   

21   

6,434  $ 

4,499   

4,855  $ 

1,367  $ 

—   

—   

501 

708 

298 

39 

311

 
 
 
 
 
 
 
 
Financial Conduct Authority (FCA), and Citigroup Global 
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 and derivatives clearinghouses. In the U.S., CGMI 
is a member of the principal U.S. futures exchanges and 
clearinghouses, 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, and other Citi subsidiaries are 
registered with the CFTC as commodity pool operators. 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 colleagues and retain and motivate existing colleagues, 
while managing compensation and other costs. For additional 
information on competitive factors and uncertainties impacting 
Citi’s businesses, see “Risk Factors—Strategic Risks” above.

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 “Managing Global Risk—
Capital Resources” and “–Liquidity Risk” and “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. 

312

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 certain individuals or entities 
that are the subject of 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 no reportable activities for the first and third quarters 
of 2020 and reportable activities pursuant to Section 219 for 
the second quarter of 2020.

Citi had no reportable activities pursuant to Section 219 

for the fourth quarter of 2020.

313

 
information on these capital distribution limitations, see 
“Capital Resources—Capital Plan Resubmission and Related 
Limitations on Capital Distributions” 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. 

UNREGISTERED SALES OF EQUITY SECURITIES, 
REPURCHASES OF EQUITY SECURITIES AND 
DIVIDENDS

Unregistered Sales of Equity Securities
None.

Equity Security Repurchases As previously announced, on 
March 15, 2020, Citi joined other major U.S. banks in 
suspending share repurchases in light of the COVID-19 
pandemic. In addition, based on measures announced by the 
Federal Reserve Board throughout 2020, share repurchases 
were prohibited through the end of the fourth quarter of 2020. 
Accordingly, Citi did not have any share repurchases in the 
fourth quarter of 2020, other than permitted repurchases 
relating to issuances of common stock related to employee 
stock ownership plans. During the fourth quarter, pursuant to 
Citigroup’s Board of Directors’ authorization, Citi 
repurchased 50,588 shares (at an average price of $54.59) of 
common stock, added to treasury stock, related to activity on 
employee stock programs where shares were withheld to 
satisfy the employee tax requirements. 

Based on measures announced by the Federal Reserve 
Board in December 2020, share repurchases will be permitted 
during the first quarter of 2021, subject to limitations based on 
net income for the four preceding calendar quarters, in 
addition to the previously announced common dividends paid 
during the first quarter of 2021. These limitations on capital 
distributions may be extended by the Federal Reserve Board. 
Under these modified limitations on capital distributions, Citi 
is authorized to return capital to common shareholders of up to 
$2.8 billion, during the first quarter of 2021, including the 
previously announced common dividends of $0.51 per share in 
the quarter. Citi commenced share repurchases in February 
2021. For additional information on these capital distribution 
limitations, see “Capital Resources—Capital Plan 
Resubmission and Related Limitations on Capital 
Distributions” above.

Dividends
Consistent with the regulatory capital framework, Citi paid 
common dividends of $0.51 per share for the fourth quarter of 
2020 and the first quarter of 2021, and intends to maintain its 
planned capital actions, which include common dividends of 
$0.51 per share through the second and third quarter of 2021 
(the remaining quarters of the 2020 CCAR cycle), subject to 
approval of Citi’s Board of Directors and the latest financial 
and macroeconomic conditions.

In addition to Board of Directors’ approval, Citi’s ability 
to pay common stock dividends substantially depends on 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—
Stress Testing Component of Capital Planning” and “Risk 
Factors—Strategic Risks” above. 

Through the end of the first quarter of 2021, dividends 
continue to be capped and tied to a formula based on recent 
income. These limitations on capital distributions may be 
extended by the Federal Reserve Board. For additional 

314

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, 2020. The graph and 
table assume that $100 was invested on December 31, 2015 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-2015
31-Dec-2016
31-Dec-2017
31-Dec-2018
31-Dec-2019
31-Dec-2020

Citigroup

100.0   
115.9   
147.2   
105.3   
166.1   
133.5   

S&P 500 
Index
100.0   
112.0   
136.4   
130.4   
171.5   
203.0   

S&P 
Financials 
Index
100.0 
122.8 
150.0 
130.5 
172.4 
169.5 

Note: Citi’s common stock is listed on the NYSE under the 
ticker symbol “C” and held by 63,632 common stockholders 
of record as of January 31, 2021.

315

CitigroupS&P 500 IndexS&P Financials Index20152016201720182019202075100125150175200225 
 
 
 
 
 
 
CORPORATE INFORMATION 

EXECUTIVE OFFICERS
Citigroup’s executive officers as of February 26, 2021 are:

Name

Age Position and office held

Peter Babej
Michael L. Corbat*

57 CEO, Asia Pacific
60 Chief Executive Officer, Citigroup Inc. 

and Citibank, N.A.

Jane Fraser*

53 President

David Livingstone

57 CEO, Europe, Middle East and Africa

Mark A. L. Mason

51 Chief Financial Officer

Mary McNiff
Johnbull Okpara

50 Chief Compliance Officer
49 Controller and Chief Accounting 

Officer

Karen Peetz

65 Chief Administrative Officer

Anand Selvakesari   

53 CEO, Global Consumer Banking

Edward Skyler

47 Head of Global Public Affairs

Ernesto Torres Cantú

56 CEO, Latin America

Zdenek Turek

56 Chief Risk Officer

Sara Wechter
Rohan Weerasinghe

40 Head of Human Resources
70 General Counsel and Corporate 

Secretary

Mike Whitaker

57 Head of Operations and Technology

Paco Ybarra

59 CEO, Institutional Clients Group

* Ms. Fraser will succeed Mr. Corbat as Citigroup’s CEO effective 
immediately following the filing of Citi’s 2020 Annual Report on Form 10-K.

Each executive officer has held his or her current executive 
officer position with Citigroup for at least five years, except 
that:

• 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 GCB from October 2019 to December 2020. Before 
that, 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;

• Mr. Mason joined Citi in 2001 and assumed his current 

position in February 2019. Previously, he served as CFO 

316

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 June 2020. Previously, she served as CEO of 
Citibank, N.A. from April 2019 to June 2020 and Chief 
Auditor of Citi from February 2017 to April 2019. Prior 
to taking on that role, Ms. McNiff served as Chief 
Administrative Officer of Latin America & Mexico and 
interim Chief Auditor. She also led the Global 
Transformation initiative within Internal Audit;
• Mr. Okpara joined Citi in his current position in 

November 2020. Previously he served as Managing 
Director, Global Head of Financial Planning and Analysis 
and CFO, Infrastructure Groups at Morgan Stanley since 
2016. Prior to that, Mr. Okpara was Managing Vice 
President, Finance and Deputy Controller at Capital One 
Financial Corporation;

• Ms. Peetz joined Citi in her current position in June 2020. 
Previously, she served on the Board of Directors of Wells 
Fargo from 2017 to 2019. Ms. Peetz spent nearly 20 years 
at BNY Mellon, where she managed several business 
units and ultimately served as President for five years 
until her departure in 2016. Prior to that, she worked at 
JPMorgan Chase, where she held a variety of 
management positions during her tenure;

• Mr. Selvakesari joined Citi in 1991 and assumed his 

current position in January 2021. Previously, he served as 
Head of the U.S. Consumer Bank since October 2018 and 
he held various other roles at Citi prior to that, including 
Head of Consumer Banking for Asia Pacific from 2015 to 
2018, as well as a number of regional and country roles, 
including Head of Consumer Banking for ASEAN and 
India, leading the consumer banking businesses in 
Singapore, Malaysia, Indonesia, Philippines, Thailand and 
Vietnam, as well as India; 

• 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;

• Mr. Turek joined Citi in 1991 and assumed his current 

position in December 2020. Previously, he served as CRO 
for EMEA since February 2020 and held various other 
roles at Citi, including CEO of Citibank Europe as well as 
leading significant franchises across Citi, including in 
Russia, South Africa and Hungary; 

• 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 Citigroup’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 Citigroup’s Board of 
Directors. 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. and Citibank, N.A.

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
Chair
Citibank, N.A.

John C. Dugan
Chair
Citigroup Inc.

Jane Fraser
President of Citigroup Inc. 

Duncan P. Hennes
Co-Founder and Partner
Atrevida Partners, LLC

Peter Blair Henry
Dean Emeritus and W. R. 
Berkley Professor of Economics 
and Finance
New York University
Stern School of Business

S. Leslie Ireland
Former Assistant Secretary for 
Intelligence and Analysis
U.S. Department of the Treasury

Lew W. (Jay) Jacobs, IV
Former President and Managing 
Director
Pacific Investment Management 
Company LLC (PIMCO)

Renée J. James
Founder, Chairman and CEO
Ampere Computing

Gary M. Reiner
Operating Partner
General Atlantic LLC

Diana L. Taylor
Former Superintendent of Banks
State of New York

James S. Turley
Former Chairman and CEO
Ernst & Young

Deborah C. Wright
Former Chairman
Carver Bancorp, Inc.

Alexander Wynaendts
Former Chief Executive Officer 
and Chairman of the  Executive 
Board
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

317

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 26th day of 
February, 2021.

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
Jane Fraser
Duncan P. Hennes
Peter Blair Henry
S. Leslie Ireland

Lew W. (Jay) Jacobs, IV
Renée J. James
Gary M. Reiner
Diana L. Taylor
James S. Turley
Deborah C. Wright
Alexander Wynaendts
Ernesto Zedillo Ponce de Leon

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 26th day of February, 2021.

Citigroup’s Principal Executive Officer and a Director:

/s/ Mark A. L. Mason

Mark A. L. Mason

/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/ Johnbull E. Okpara

Johnbull E. Okpara

318

EXHIBIT INDEX

Description of Exhibit

Restated Certificate of Incorporation of Citigroup, as amended, as in effect on the date hereof.

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 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 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 August 1, 2017 
(File No. 001-09924).

Fourth Supplemental Indenture dated as of June 27, 2019, between Citigroup and The Bank of New York Mellon, 
as trustee, incorporated by reference to Exhibit 4.2 to the Company’s Current Report on Form 8-K filed on June 28, 
2019 (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 JP Morgan 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 February 4, 
2013 (File 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 August 31, 2004 (File 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 
(File 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 March 1, 
2017 (File No. 333-216372).

Fourth Supplemental Indenture, dated as of June 27, 2019, between Citigroup 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 
June 28, 2019 (File No. 001-09924).

Exhibit
Number

3.01+

3.02

4.01

4.02

4.03

4.04

4.05

4.06

4.07

4.08

4.09

4.10

319

 
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

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 December 8, 1992 (File 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 December 8, 1992 (File No. 03355542).

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 December 8, 1992 (File 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 (File 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 (File 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 
December 11, 2008 (File 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 December 21, 2012 (File 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 
May 20, 2016 (File 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 March 13, 2006 (File 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 December 21, 2012 (File 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 July 23, 2004 (File 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 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 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 March 9, 2016 (File No. 001-09924). 

320

4.25

4.26

4.27

4.28

First Supplemental Indenture, dated as of March 1, 2017, between Citigroup Global Markets Holdings Inc., the 
Company and the Bank of New York Mellon, as trustee, incorporated by reference to Exhibit 4.24 to the 
Company’s Registration Statement on Form S-3 filed March 1, 2017 (File No. 333-216372).

Second Supplemental Indenture, dated as of April 13, 2020, between Citigroup Global Markets Holdings Inc., the 
Company 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 April 13, 2020 (File No. 001-09924).

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 July 2, 2004 (File No. 333-117615).

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 May 9, 2011 (File No. 001-09924).

4.29+

Description of Citigroup’s Securities Registered Pursuant to Section 12 of the Securities Exchange Act of 1934.

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*

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 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 April 30, 2018 (File No. 001-09924).

Citigroup 2019 Stock Incentive Plan (as amended and restated effective April 21, 2020), incorporated by reference 
to Exhibit 10.1 to the Company’s Current Report on Form 8-K filed 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).

Citigroup Inc. DCAP Agreement, incorporated by reference to Exhibit 10.04 to the Company’s Quarterly Report 
on Form 10-Q for the quarterly period ended March 31, 2020 (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).

10.08.1*

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).

321

10.08.2*

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).

10.09*

10.10*

10.11*

10.12*

10.13*

10.14*

10.15*

10.16.1*

10.16.2*

10.16.3*

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 October 6, 2006 
(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).

The Retirement Plan for Specified Non-United States International Staff of Citibank, N.A. and Participating 
Companies As Amended and Restated Effective January 1, 2000 (with amendments through December 31, 2008), 
incorporated by reference to Exhibit 10.02 to the Company’s Quarterly Report on Form 10-Q for the quarterly 
period ended March 31, 2020 (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 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), incorporated by reference to Exhibit 10.14 to the Company’s Annual Report on 
Form 10-K for the fiscal year ended December 31, 2019 (File No. 001-09924) (the “Company’s 2019 10-K”). 

Agreement between Stephen Bird and Citibank, N.A. (dated November 8, 2019), incorporated by reference to 
Exhibit 10.15 to the Company’s 2019 form 10-K (File No. 001-09924).

Letter Agreement, dated April 22, 2020, between Paco Ybarra and Citigroup Global Markets Limited, incorporated 
by reference to Exhibit 10.03 to the Company’s Quarterly Report on Form 10-Q for the quarterly period ended 
March 31, 2020 (File No. 001-09924).

Amendment to Letter Agreement, dated April 22, 2020, between Paco Ybarra and Citigroup Global Markets 
Limited (dated June 19, 2020), incorporated by reference to Exhibit 10.01 to the Company’s Quarterly Report on 
Form 10-Q for the quarterly period ended June 30, 2020 (File No. 001-09924).

Amendment to Letter Agreement, dated April 22, 2020, between Paco Ybarra and Citigroup Global Markets 
Limited (dated June 29, 2020), incorporated by reference to Exhibit 10.02 to the Company’s Quarterly Report on 
Form 10-Q for the quarterly period ended June 30, 2020 (File No. 001-09924).

18.01+

Preferability Letter of KPMG LLP, Independent Registered Public Accounting Firm.

21.01+

Subsidiaries of Citigroup.

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.

322

31.02+

Certification of principal financial officer pursuant to Section 302 of the Sarbanes-Oxley Act of 2002.

32.01+

99.01+

101.01+

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, 
2020, filed on February 26, 2021 , 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.

104

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 
2020 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.

323

Stockholder Information

Citigroup common stock is listed on the NYSE under the 
ticker symbol “C.” Citigroup preferred stock Series J and K 
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 14, 2020.

As of January 31, 2021, Citigroup had approximately 63,632 
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 505005 
Louisville, KY 40233-5005 
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 2020 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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