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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, 20192021


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.Inc.
(Exact name of registrant as specified in its charter)
Delaware52-1568099
(State or other jurisdiction of incorporation or organization)(I.R.S. Employer Identification No.)
388 Greenwich Street,New YorkNY10013
(Address of principal executive offices)

(Zip code)
(212(212) 559-1000
(Registrant'sRegistrant’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 oNo 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, a smaller reporting company, or an emerging growth company. See the definitions of "large“large accelerated filer," "accelerated” “accelerated filer," "smaller” “smaller reporting company"company” and “emerging growth company” in Rule 12b-2 of the Exchange Act.
Large accelerated filerAccelerated filerNon-accelerated filerSmaller 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, 20192021 was approximately $158.0$143.2 billion.
Number of shares of Citigroup Inc. common stock outstanding on January 31, 2020: 2,106,486,7932022: 1,980,894,613
Documents Incorporated by Reference: Portions of the registrant’s proxy statement for the annual meeting of stockholders scheduled to be held on April 21, 202026, 2022 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 NumberPage
Part I
1.Business4–27, 112–115,28, 124–130,
118, 146,133, 161,
294–295316–317
1A.Risk Factors46–5545–61
1B.Unresolved Staff CommentsNot Applicable
2.PropertiesNot Applicable
3.Legal Proceedings—See Note 27 to the Consolidated Financial Statements276–282296–303
4.Mine Safety DisclosuresNot Applicable
Part II
5.Market for Registrant’s Common Equity, Related Stockholder Matters and Issuer Purchases of Equity Securities128–129, 152–154, 296–297142–143, 167–169, 318–319
6.Selected Financial Data[Reserved]10–11
7.Management’s Discussion and Analysis of Financial Condition and Results of Operations6–29, 58–1117–28, 66–123
7A.Quantitative and Qualitative Disclosures About Market Risk58–111, 147–151, 172–207, 214–26766–123, 162–166, 187–227, 234–288
8.Financial Statements and Supplementary Data124–293138–315
9.Changes in and Disagreements with Accountants on Accounting and Financial DisclosureNot Applicable
9A.Controls and Procedures116–117131–132
9B.Other InformationNot Applicable
9C.Disclosure Regarding Foreign Jurisdictions that Prevent InspectionsNot Applicable
Part III
Part III
10.
10.Directors, Executive Officers and Corporate Governance298–300*320–322*
11.Executive Compensation**
12.Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters***
13.Certain Relationships and Related Transactions, and Director Independence****
14.Principal AccountingAccountant Fees and Services*****
Part IV
15.ExhibitsExhibit 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 21, 2020,26, 2022, to be filed with the SEC (the Proxy Statement), incorporated herein by reference.
**See “Compensation Discussion and Analysis,” “The Personnel and Compensation Committee Report,” and “2019“2021 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”Ownership,” and “Equity Compensation Plan Information” in the Proxy Statement, incorporated herein by reference.
****See “Corporate Governance—Director Independence,” “—Certain Transactions and Relationships, Compensation Committee Interlocks and Insider Participation” and “—Indebtedness” in the Proxy Statement, incorporated herein by reference.
*****See “Proposal 2: Ratification of Selection of Independent Registered Public Accounting Firm”Accountants” in the Proxy Statement, incorporated herein by reference.

2


CITIGROUP’S 20192021 ANNUAL REPORT ON FORM 10-K

OVERVIEW
  Citigroup Segments
MANAGEMENT'S5
  Strategic Refresh
MANAGEMENT’S DISCUSSION AND

ANALYSIS OF FINANCIAL CONDITION AND

RESULTS OF OPERATIONS
Executive Summary
Citi’s Consent Order Compliance
Summary of Selected Financial Data
SEGMENT AND BUSINESS—INCOME (LOSS)

AND REVENUES
SEGMENT BALANCE SHEET
Institutional Clients Group
Global Consumer Banking
North America GCB
Latin America GCB
Asia GCB
Institutional Clients GroupCorporate/Other
Corporate/OtherCAPITAL RESOURCES
RISK FACTORS
SUSTAINABILITY AND OTHER ESG MATTERS
OFF-BALANCE SHEETHUMAN CAPITAL RESOURCES AND
  ARRANGEMENTSMANAGEMENT
CONTRACTUAL OBLIGATIONS
CAPITAL RESOURCES
RISK FACTORS
Managing Global Risk Table of Contents
MANAGING GLOBAL RISK
SIGNIFICANT ACCOUNTING POLICIES AND

SIGNIFICANT ESTIMATES
DISCLOSURE CONTROLS AND

PROCEDURES
MANAGEMENT’S ANNUAL REPORT ON

INTERNAL CONTROL OVER FINANCIAL

REPORTING
FORWARD-LOOKING STATEMENTS
REPORT OF INDEPENDENT REGISTERED

PUBLIC ACCOUNTING FIRM
FINANCIAL STATEMENTS AND NOTES

TABLE OF CONTENTS
CONSOLIDATED FINANCIAL STATEMENTS
NOTES TO CONSOLIDATED FINANCIAL

STATEMENTS
FINANCIAL DATA SUPPLEMENT
SUPERVISION, REGULATION AND OTHER
CORPORATE INFORMATION
Executive Officers
Citigroup Board of Directors
GLOSSARY OF TERMS AND ACRONYMS








3


OVERVIEW

Citigroup’s history dates back to the founding of the City
Bank of New York in 1812.
Citigroup is a global diversified financial services holding company whose businesses provide consumers, corporations, governments and institutions with a broad, yet focused, range of financial products and services, including consumer banking and credit, corporate and investment banking, securities brokerage, trade and securities services and wealth management. Citi has approximately 200 million customer accounts and does business in more than 160 countries and jurisdictions.
At December 31, 2019,2021, Citi had approximately 200,000223,400 full-time employees, compared to approximately 204,000210,000 full-time employees at December 31, 2018.
Citigroup currently operates, for management reporting purposes, via two primary business segments: Global Consumer Banking (GCB)2020. For additional information, see “Human Capital Resources 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.Management” below.
Throughout this report, “Citigroup,” “Citi” and “the Company” refer to Citigroup Inc. and its consolidated subsidiaries.
For a list of terms and acronyms used in this Annual Report on Form 10-K and other Citigroup presentations, see “Glossary of Terms and Acronyms” at the end of this report.

Additional Information
Additional information about Citigroup is available on Citi’s website at www.citigroup.com.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.www.sec.gov.
For a discussion of 20182020 versus 20172019 results of operations ofICG, GCB in North America, Latin America and Asia, ICGand Corporate/Other, see each respective business’s results of operationoperations in Citi’s 20182020 Annual Report on Form 10-K.
Certain reclassifications including a realignment of certain businesses, have been made to the prior periods’ financial statements and disclosures to conform to the current period’s presentation. For additional information on certain recent reclassifications, see Note 3 to the Consolidated Financial Statements.




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














































4



As described above,of December 31, 2021, Citigroup iswas managed pursuant to two business segments: Global Consumer Banking and operating segments—Institutional Clients Group, and Global Consumer Banking—with the remaining operations in Corporate/Other.Other. (For information on Citi’s planned revision to its reporting structure effective for the first quarter of 2022, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” below.)
For a further description of the operating segments and the products and services they provide, see “Management’s Discussion and Analysis of Financial Condition and Results of Operations” and Note 3 to the Consolidated Financial Statements.
Citigroup Operating Segments
Institutional
Clients Group
(ICG)
Global
Consumer Banking
(GCB)
Banking
Investment banking
Treasury and trade solutions
Corporate lending
Private bank
Markets and securities services
Fixed income markets
Equity markets
Securities services
North America
Latin America(1)
Asia(2)
Consisting of:
Retail banking and wealth management, including
Residential real estate
Small business banking
Branded cards in all regions
Retail services in North America

Corporate/Other
Corporate Treasury
Operations and technology
Global staff functions and other corporate expenses
Legacy non-core assets:
Consumer loans
Certain portfolios of securities, loans and other assets
Discontinued operations

citisegments123119.jpg
The following are the four regions in which Citigroup operates. The regional results are fully reflected in the segment and Corporate/Otherresults above.
citiregionsq4a04.jpg

(1)
Latin America GCBCitigroup Regions consists of Citi’s consumer banking businessin Mexico.(3)
(2)
Asia GCB includes the results of operations of GCB activities in certain EMEA countries for all periods presented.
(3)North
America
Europe,
Middle East
and Africa
North (EMEA)
Latin
America
includes the U.S., Canada and Puerto Rico, Latin America includes Mexico and
Asia includes Japan.
Note:
(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


Strategic Refresh—Market Exits and Planned Revision to Reporting Structure
As part of its strategic refresh, Citi is making management reporting changes to align with its vision and strategy, including to assist Citi in decisions about resources and capital allocation and to assess business performance. In the first quarter of 2022, Citi will revise its financial reporting structure to align with these management reporting changes to enable investors and others to better understand the performance of Citi’s businesses (see the table below for additional information on the revised financial reporting structure):

First, Citi is creating a Personal Banking and Wealth Management segment. It will consist of two distinct reporting units: U.S. Personal Banking businesses and a Global Wealth Management business, which will include the private bank.
Second, with respect to Institutional Clients Group (ICG), Citi will begin reporting under three reporting units: Services, Banking and Markets. Services will include treasury and trade solutions and securities services, reflecting the importance of these businesses to Citi’s future.
Finally, Citi is creating Legacy Franchises, a segment that will consist of all the businesses Citi intends to exit (see below), including its remaining Legacy Holdings assets.


In conjunction with the strategic refresh, in 2021 Citi announced that it will focus its consumer banking franchises in Asia and EMEA on four wealth centers: Singapore, Hong Kong, the United Arab Emirates (UAE) and London. As a result, Citi is pursuing exits of its consumer franchises in the remaining 13 markets across these two regions.
In 2021 and early 2022, Citi announced sale agreements for or exit of a majority of the fourth quarter of 2019, Citi’s13 markets (for additional information, see “Executive Summary” and “Asia GCB” below). ICG will continue to serve clients, including its commercial banking clients, in all of these markets.
In addition, in January 2022, Citi announced that it intends to exit the consumer, small business and middle-market banking operations of Citibanamex. The businesses previouslyin the intended exit include the Mexico consumer and small business banking operations, reported as part of Citi’s GCB segment, as well as the Mexico middle-market banking business, reported in Citi’s North AmericaICG, segment. These operations represent the entirety of the Latin America GCB unit. Citi and Asia, including approximately $28 billionwill continue to operate a locally licensed banking business in end-of-period loans and approximately $37 billion in end-of-period deposits, are reported inMexico through its global ICG(for all periods presented.    additional information, see “Executive Summary” and “Latin America GCB” below).

For additional information regarding the exit markets, see Note 2 to the Consolidated Financial Statements. For information regarding risks related to the exit markets, see “Risk Factors” below.

The following table summarizes both Citi’s reporting structure during 2021 and its planned 2022 financial reporting structure:

c-20211231_g1.jpg
Corporate/OtherCorporate/Other


6


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

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

Citi had solid underlying revenue growth in every region in Global Consumer Banking (GCB), excluding the impact of foreign currency translation into U.S. dollars for reporting purposes (FX translation), as well as pretax gains on sale in 2018 of approximately $150 million on the Hilton portfolio in North America GCB and approximately $250 million on an asset management business in Latin America GCB.
Citi had balanced performance across the Institutional Clients Group (ICG), with solid results in fixed income markets, treasury and trade solutions, investment banking and the private bank, while equity markets revenues were negatively impacted by a challenging environment.
Citi demonstrated strong expense discipline, resultingcontinued progress across the franchise during 2021:

Citi’s earnings increased significantly versus the prior year, largely reflecting an allowance for credit loss (ACL) release of approximately $8.8 billion as a result of continued improvement in expenses that were largely unchangedboth the macroeconomic environment and portfolio credit quality.
Citi’s revenues declined 5% from the prior year, year. Excluding a pretax loss of approximately $0.7 billion (approximately $0.6 billion after-tax) related to Citi’s agreement to sell its Australia consumer banking business in Asia Global Consumer Banking (GCB) (see “Citigroup” below), Citi’s revenues declined 4%, as strength in investment banking, equity markets, the private bank and securities services in Institutional Clients Group (ICG) was more than offset by normalization in market activity in fixed income markets within ICG,as well as positive operating leverage, even as the impact of lower deposit spreads and card loans across GCB.
Citi’s expenses included pretax costs of approximately $1.2 billion ($1.1 billion after-tax) primarily related to charges incurred from the voluntary early retirement program (VERP) in connection with the wind-down of the Korea consumer banking business (for additional information, see “Asia GCB” below).
Citi continued to invest in its transformation, including infrastructure supporting its risk and control environment, and make investments in the franchise. Citi’s positive operating leveragebusiness-led investments.
Citi had broad-based deposit growth across ICG and GCB (up 3% and 5%, respectively), reflecting continued credit discipline resulted in an improvement in pretax earnings.
Citi reported broad-based loan and deposit growthengagement across both corporate and consumer clients.
GCB and ICG.
Citi returned $22.3approximately $11.8 billion of capital to its common shareholders in the form of $4.2 billion in dividends and $7.6 billion in common stockshare repurchases, and dividends; Citi repurchasedtotaling approximately 264105 million common shares, contributing to a 9% reduction in average outstanding common shares from the prior year.
Despite continued progress in capital returns to shareholders, Citi’s keywhile maintaining robust regulatory capital metrics remained strong.ratios.

In addition to the sale announcements related to Asia GCB, Citi also announced it intends to exit the consumer, small business and middle-market banking operations of Citibanamex in Mexico. Citi’s planned divestitures of its consumer businesses across Mexico, Asia and EMEA are aligned with the repositioning of its consumer operations to focus on global wealth centers, as well as payments and lending and a targeted retail presence in the U.S. (For additional information on the exit markets and Citi’s revised reporting structure effective for the first quarter of 2022, see “Strategic Refresh—Market Exits and Revised Reporting Strategy” above and “Latin America GCB” and “Asia GCB” below.)
While global
Although economic growth hasand employment rates have continued andto recover from pandemic-related lows, particularly in the underlyingU.S., various macroeconomic environment remains largely positive, economic forecasts for 2020 have been lowered and various economic, political and other riskschallenges and uncertainties couldrelated to, among other things, the duration and
severity of the pandemic-related public health crisis, disruptions of global supply chains, inflationary pressures, increasing interest rates and geopolitical tensions involving Eastern Europe, will continue to create a more volatile operating environment and impactuncertainty around Citi’s businesses and future results.
For a discussion of trends, uncertainties and risks and uncertainties that will or could impact Citi’s businesses, results of operations and financial condition during 2020,2022, see “2021 Results Summary,” “Risk Factors,” each respective business’s results of operations “Risk Factors” and “Managing Global Risk” below. Despite these risks and uncertainties, Citi intends to continue to build on the progress made during 2019 with a focus on further optimizing its performance to benefit shareholders, while remaining flexible and adapting to market and economic conditions as they develop.

20192021 Results Summary

Citigroup
Citigroup reported net income of $19.4$22.0 billion, or $8.04$10.14 per share, compared to net income of $18.0$11.0 billion, or $6.68$4.72 per share, in the prior year. NetThe increase in net income increased 8%, primarilywas driven by a lower effective tax rate and higher revenues,cost of credit, partially offset by higher cost of credit, while expenses were largely unchanged.and lower revenues. Citigroup’s effective tax rate was 20%, up modestly from 19% in the prior year. Earnings per share increased 20%,significantly, primarily driven by higher net income and the 9% reduction in average shares outstanding due to the common stock repurchases. Results in 2019 included a net tax benefit of approximately $0.35 per share related to discrete tax items, including an approximate $0.6 billion benefit from reductions in Citi’s valuation allowance related to its deferred tax assets, primarily recorded in Corporate/Other (see “Significant Accounting Policies and Significant Estimates—Income Taxes” below).income.
Citigroup revenues of $74.3$71.9 billion increased 2%, or 4% excludingdecreased 5% from the impact of FX translation andprior year. Excluding the gainsAustralia loss on sale, Citigroup revenues decreased 4%, primarily driven by lower revenues in the prior year (see “Executive Summary” above), reflecting higher revenues acrossboth ICG and GCB and ICG, partially offset by lowerhigher revenues in Corporate/Other.
As discussed above, Citi’s 2021 results include the impacts of divestitures of Citi’s consumer banking businesses in Asia. Reported revenues include the Australia loss on sale (approximately $0.7 billion pretax, $0.6 billion after-tax), primarily reflecting the impact of a currency translation adjustment (CTA) loss (net of hedges) already reflected in the Accumulated other comprehensive income (AOCI) component of equity. Upon closing, the CTA balance will be removed from the AOCI component of equity, resulting in a neutral impact to Citi’s Common Equity Tier 1 Capital.
Reported expenses include the impact of the Korea VERP of approximately $1.1 billion (approximately $0.8 billion after-tax) and contract modification costs related to the Asia divestitures of approximately $119 million (approximately $98 million after-tax). (As used throughout this Form 10-K, Citi’s results of operations and financial condition excluding the impact of the Australia loss on sale, Korea VERP and other Asia divestiture-related costs are non-GAAP financial measures. Citi believes the presentation of its results of operations and financial condition excluding the divestiture-related impacts described above provides a meaningful depiction of the underlying fundamentals of its broader results and Asia GCB businesses’ results for investors, industry analysts and others.)
Citigroup’s end-of-period loans increased 2%decreased 1% from the prior year to $699$668 billion. Excluding the impact of FXforeign currency translation Citigroupinto U.S. dollars for reporting purposes (FX translation), Citigroup’s end-of-period loans also grew 2%,were largely unchanged, as 3% aggregate growth in GCB andICG was partially offset by the continued wind-down of legacy assetslower loans inGCB and Corporate/Other. Citigroup’s end-of-period deposits
7


increased 6%3% to $1.1$1.3 trillion. Excluding the impact of FX translation, Citigroup’s end-of-period deposits also grew 6%increased 4%, primarily driven by 7%reflecting growth in both GCB and 6% growth in ICG, excluding the impact of FX translation. (Citi’s. (As used throughout this Form 10-K, Citi’s results of operations excluding the gains on sale as well as the impact of FX translation are non-GAAP financial measures. Citi believes the presentation of its results of operations and financial condition excluding the impact of FX translation and gains on sale provides a meaningful depiction for investors of the underlying fundamentals of its businesses.businesses for investors, industry analysts and others.)

Expenses
Citigroup operating expenses of $42.0$48.2 billion were largely unchanged, as efficiency savings andincreased 9% versus the wind-downprior year. Excluding the impact of legacy assets offset volume-driven growth and continuedthe Asia divestitures, expenses of $47.0 billion increased 6%, primarily reflecting investments in the franchise. OperatingCiti’s transformation, including infrastructure supporting its risk and control environment, business-led investments and revenue- and transaction-related expenses, partially offset by productivity savings. Citi expects expenses in GCB 2022 to continue to be impacted by its transformation-related and Corporate/Other were down 1% and 5%, respectively, while ICG operating expenses increased 2%.business-led investments.

Cost of Credit
Citi’s total provisions for credit losses and for benefits and claims were a benefit of $8.4$3.8 billion, increased 11%.compared to a cost of $17.5 billion in the prior year primarily related to the pandemic. The increasedecreased cost of credit was primarily driven by highera net credit lossesACL reserve release of $8.8 billion (versus a build of $9.8 billion in both Citi-branded cards and Citi retail services in North America GCB,the prior year) as well as lower net credit losses. Citi’s net ACL release primarily reflected improvement in Citi’s macroeconomic outlook and portfolio credit quality. Citi could experience higher overall costcredit costs in 2022, as the level of credit in ICG.ACL releases from 2021 are unlikely to continue, and Citi expects to build ACL reserves for new lending volumes.
For further information on the drivers of Citi’s ACL, see “Significant Accounting Policies and Significant Estimates—Citi’s Allowance for Credit Losses (ACL)” below.
Net credit losses of $7.8$4.9 billion increased 9%.declined 36% from the prior year. Consumer net credit losses of $7.4$4.5 billion increased 7%decreased 32%, primarily reflecting volume growthlower loan volumes and seasoningimproved delinquencies in the North Americacards portfolios. Corporate net credit losses increased to $392

of $395 million from $205 milliondecreased 60%, primarily reflecting improvements in the prior year, reflecting a normalization inportfolio credit trends.quality.
For additional information on Citi’s consumer and corporate credit costs and allowance for loan losses,ACL, see each respective business’s results of operations and “Credit Risk” below.

Capital
Citigroup’s Common Equity Tier 1 (CET1) Capital ratio was 11.8%12.2% as of December 31, 2019, compared to 11.9% as of December 31, 2018,2021, based on the Basel III Standardized Approach framework for determining risk-weighted assets, compared to 11.5% as of December 31, 2020, based on the Basel III Advanced Approaches for determining risk-weighted assets. The declineincrease in the ratio primarily reflected the return of capitalactions to common shareholders, partially offset by net incomereduce risk-weighted assets (RWA) and a reductiontemporary pause in risk-weighted assets. common share repurchases in the fourth quarter of 2021, in preparation for the implementation of the Standardized Approach for Counterparty Credit Risk (SA-CCR) on January 1, 2022. Citi resumed common share repurchases in January 2022.
Citigroup’s Supplementary Leverage ratio was 5.7% as of December 31, 2019 was 6.2%,2021, compared to 6.4%7.0% as of December 31, 2018.2020. The decrease was primarily driven by the expiration of temporary relief granted by the Federal Reserve Board (FRB) as of the end of the first quarter of 2021. For additional information on SA-CCR and Citi’s capital ratios, and related components, see “Capital Resources” below.

Global Consumer Banking
GCB net income of $5.7 billion increased 7%. Excluding the impact of FX translation, net income increased 8%, driven by higher revenues, partially offset by higher cost of credit. GCB operating expenses of $17.6 billion decreased 1%. Excluding the impact of FX translation, expenses were largely unchanged, as efficiency savings offset continued investments in the franchise and volume-driven growth.
GCB revenues of $33.0 billion increased 2%. Excluding the impact of FX translation and the gains on sale in both North America GCB and Latin America GCB in the prior year, revenues increased 4%, driven by growth in all three regions. North America GCB revenues of $20.4 billion increased 3%, and 4% excluding the gain on sale in the prior year, primarily driven by growth in Citi-branded cards and Citi retail services, partially offset by lower retail banking revenues. In North America GCB,Citi-branded cards revenues of $9.2 billion increased 6%, and 8% excluding the gain on sale in the prior year, primarily reflecting volume growth and spread expansion. Citi retail servicesrevenues of $6.7 billion increased 2%, primarily driven by organic loan growth and the full-year benefit of the L.L.Bean acquisition. Retail banking revenues of $4.5 billion decreased 2%, as the benefit of stronger deposit volumes was more than offset by lower deposit spreads.
North America GCB average deposits of $153 billion increased 3%, average retail banking loans of $49 billion increased 3% and assets under management of $72 billion grew 20% (including the benefit of market movements). Average Citi-branded card loans of $90 billion increased 3%, while Citi-branded card purchase sales of $368 billion increased 7%. Average Citi retail services loans of $50 billion increased 3%, while Citi retail services purchase sales of $88 billion increased 2%. For additional information on the results of operations of North America GCB in 2019, see “Global Consumer Banking—North America GCB” below.
International GCB revenues (consisting of Latin America GCB and Asia GCB (which includes the results of operations in certain EMEA countries)), of $12.6 billion increased 1%.
Excluding the impact of FX translation and the gain on sale in Latin America GCB in the prior year, international GCB revenues increased 4%. On this basis, Latin America GCB revenues increased 4%, primarily driven by an increase in cards revenues and improved deposit spreads. Asia GCB revenues increased 4%, primarily reflecting higher deposit, investment and cards revenues. For additional information on the results of operations of Latin America GCB and Asia GCB in 2019, including the impact of FX translation,see “Global Consumer Banking—Latin America GCB” and “Global Consumer Banking—Asia GCB” below.
Year-over-year, excluding the impact of FX translation, international GCB average deposits of $124 billion increased 5%, average retail banking loans of $71 billion increased 4%, assets under management of $104 billion increased 16%(including the benefit of market movements), average card loans of $25 billion increased 3% and card purchase sales of $108 billion increased 6%.

Institutional Clients Group
ICG net income of $12.9$15.7 billion increased 3%36%, primarily driven by higher revenues and areflecting lower effective tax rate,cost of credit, partially offset by higher expenses and cost of credit.lower revenues. ICG operating expenses increased 2%8% to $22.2$26.5 billion, primarily driven by higher compensation costs,reflecting continued investments in Citi’s transformation, business-led investments and volume-driven growth,revenue- and transaction-related expenses, partially offset by efficiencyproductivity savings.
ICG revenues of $39.3$43.9 billion increaseddecreased 3%, reflectingas a 1%7% increase in Bankingrevenues and a 5% increasewas more than offset by an 11% decline in Markets and securities services revenues. The increase in Banking revenues included the impact of $432$144 million of losses on loan hedges withinrelated to corporate lending and the private bank, compared to gainslosses of $45$51 million in the prior year.
Banking revenues of $21.9$23.3 billion (excluding the impact of gains (losses)losses on loan hedges within corporate lending)hedges) increased 3%7%, driven by solid growthas higher revenues in treasury and trade solutions, investment banking and the private bank. Investment banking revenues of $5.2 billion increased 4%, as strength in debt underwriting wasbank were partially offset by lower revenues in bothtreasury and trade solutions and corporate lending. Investment banking revenues of $7.5 billion increased 30%, reflecting growth across products, particularly in advisory and equity underwriting and advisory.underwriting. Advisory revenues decreased 3%increased 78% to $1.3$1.8 billion, equity underwriting revenues decreased 2%increased 53% to $973 million$2.4 billion and debt underwriting revenues increased 10%3% to $3.0$3.3 billion.
Treasury and trade solutions revenues of $10.3$9.4 billion increaseddeclined 4%, and 6% excluding the impact of FX translation, reflecting strong client engagement and volumeas higher fee revenues, including a recovery in commercial card revenues, as well as growth partiallyin trade were more than offset by the impact of lower interest rates.deposit spreads. Private bank revenues of $3.5 billion increased 2%, driven by higher lending and deposit volumes as well as higher investment activity, partially offset by spread compression. Corporate lending revenues declined 16% to $2.5 billion.5%. Excluding the impact of gains (losses)on loan hedges, private bank revenues of $4.0 billion increased 6%, driven by higher loan volumes and spreads, as well as higher managed investments and deposits, partially offset by lower deposit spreads. Corporate lending revenues decreased 3%. Excluding the impact of losses on loan hedges, corporate lending revenues were largely unchanged,of $2.3 billion decreased 1%, as growth in the commercial loan portfoliolower cost of funds was more than offset by lower volumes in the rest of the portfolio.loan volumes.
Markets and securities services revenues of $17.8$20.8 billion increased 5%, including a pretax gain of approximately $350 million on Citi’s investment in Tradeweb in the second quarter of 2019, recorded in fixed income markets.decreased 11%. Fixed income markets revenues of $12.9$13.7 billion increased 10%decreased 22%, reflecting

growth a normalization in market activity across rates and currencies as well as spread products, including the Tradeweb gain.products. Equity markets revenues of $2.9$4.5 billion decreased 15%increased 25%, primarily driven by lower revenuesgrowth across cash equities, derivativesall products, reflecting solid client activity and prime finance.favorable market conditions. Securities services revenues of $2.6$2.7 billion were largely unchanged, but increased 4% excluding the impact of FX translation, reflecting6%, as strong fee revenues, driven by higher net interest revenue due to higher depositssettlement volumes and higher interest rates, particularly in emerging markets, as well as higher client volumes.assets under custody, were partially offset by lower deposit spreads. For additional information on the results of operations of ICG in 2019,2021, see ��Institutional Clients Group” below.
8


Global Consumer Banking
GCB net income was $6.1 billion, compared to net income of $667 million in the prior year, reflecting lower cost of credit, partially offset by lower revenues and higher expenses. GCB operating expenses of $20.0 billion increased 12%. Excluding the impact of FX translation and the Asia divestitures, expenses increased 5%, reflecting continued investments in Citi’s transformation, as well as business-led investments and volume-related expenses, partially offset by productivity savings.
GCB revenues of $27.3 billion decreased 10% from the prior year. Excluding the impact of FX translation and the Australia loss on sale, revenues decreased 9%, as continued solid deposit growth and growth in assets under management were more than offset by lower card loans and lower deposit spreads. For additional information on GCB’s results of operations, including the impact of FX translation, see “Global Consumer Banking” below.
North America GCB revenues of $17.5 billion decreased 9%, with lower revenues across branded cards, retail services and retail banking. Branded cards revenues of $8.2 billion decreased 7%, reflecting continued higher payment rates. Retail servicesrevenues of $5.1 billion decreased 15%, reflecting continued higher payment rates and lower average loans as well as higher partner payments. Retail banking revenues of $4.2 billion decreased 7%, as the benefit of stronger deposit volumes was more than offset by lower deposit spreads and lower mortgage revenues.
North America GCB average deposits of $206 billion increased 17% year-over-year and average retail banking loans of $50 billion decreased 4% year-over-year, while assets under management of $87 billion increased 8%. Average branded cards loans of $81 billion decreased 4% and average retail services loans decreased 7%, reflecting higher payment rates. Branded cards spend volume of $411 billion increased 21% and retail services spend volume of $92 billion increased 18%, reflecting a recovery in sales activity from the pandemic-driven low levels in the prior year. For additional information on the results of operations of North America GCB in 2021, 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 $9.8 billion declined 11% versus the prior year. Excluding the impact of FX translation and the Australia loss on sale, international GCB revenues declined 7%. Excluding the impact of FX translation, Latin America GCB revenues decreased 9%, driven by lower average loans and lower deposit spreads. Excluding the impact of FX translation and the Australia loss on sale, Asia GCB revenues decreased 6%, reflecting lower spreads, partially offset by higher investment revenues. For additional information on the results of operations of Latin America GCB and Asia GCB in 2021, including the impacts of FX translation,see “Global Consumer Banking—Latin America GCB” and “Global Consumer Banking—Asia GCB” below. For additional information on Citi’s consumer banking business in Australia, see “Global Consumer Banking—Asia GCB” below.
Year-over-year, excluding the impact of FX translation, international GCB average deposits of $146 billion increased 5%, average retail banking loans of $72 billion decreased 3% and assets under management of $145 billion increased 5%. On this basis, international GCB average card loans of $20 billion decreased 13%, while credit card spend volumes of $100 billion increased 9%, reflecting a continued recovery in credit card spend activity from the pandemic-related low levels in the prior year.

Corporate/Other
Corporate/Other net income was $801$215 million, compared to $186 milliona net loss of $1.1 billion in the prior year, primarily reflecting higher revenues, lower expenses, lower cost of credit, and the benefitrelease of discretea foreign tax items.credit (FTC) valuation allowance. Operating expenses of $2.2$1.6 billion decreased 5%14%, asreflecting the continued wind-downabsence of legacy assets more than offset higher infrastructure costs. Corporate/Other revenues of $2.0 billion decreased 8%, primarily driven by the continuedprior year’s civil money penalty and the wind-down of legacy assets, partially offset by gains on investments.increases related to Citi’s transformation.
Corporate/Other revenues of $667 million compared to $71 million in the prior year, primarily driven by higher net revenue from the investment portfolio. For additional information on the results of operations of Corporate/Other in 2019,2021, see “Corporate/Other” below.

CITI’S CONSENT ORDER COMPLIANCE
Citi has embarked 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.
This includes efforts to effectively implement the October 2020 FRB and Office of the Comptroller of the Currency (OCC) consent orders issued to Citigroup and Citibank, respectively. In the second quarter of 2021, Citi made an initial submission to the OCC, and submitted its plans to address the consent orders to both regulators during the third quarter of 2021. Citi continues to work constructively with the regulators, and will continue to reflect their feedback in its project plans and execution efforts.
As discussed above, Citi’s efforts include continued investments in its transformation, including the remediation of its consent orders. Citi's CEO has made the strengthening of Citi's risk and control environment a strategic priority and has
established a Chief Administrative Officer organization to centralize program management. In addition, 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.











9


























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RESULTS OF OPERATIONS
SUMMARY OF SELECTED FINANCIAL DATA—PAGE 1DATA

Citigroup Inc. and Consolidated Subsidiaries
In millions of dollars, except per share amounts20212020201920182017
Net interest income(1)
$42,494 $44,751 $48,128 $46,562 $45,061 
Non-interest revenue29,390 30,750 26,939 27,474 28,632 
Revenues, net of interest expense$71,884 $75,501 $75,067 $74,036 $73,693 
Operating expenses(1)
48,193 44,374 42,783 43,023 43,481 
Provisions for credit losses and for benefits and claims(3,778)17,495 8,383 7,568 7,451 
Income from continuing operations before income taxes$27,469 $13,632 $23,901 $23,445 $22,761 
Income taxes(2)
5,451 2,525 4,430 5,357 29,388 
Income (loss) from continuing operations$22,018 $11,107 $19,471 $18,088 $(6,627)
Income (loss) from discontinued operations, net of taxes7 (20)(4)(8)(111)
Net income (loss) before attribution of noncontrolling interests$22,025 $11,087 $19,467 $18,080 $(6,738)
Net income attributable to noncontrolling interests
73 40 66 35 60 
Citigroup’s net income (loss)(2)
$21,952 $11,047 $19,401 $18,045 $(6,798)
Earnings per share
Basic
Income (loss) from continuing operations$10.21 $4.75 $8.08 $6.69 $(2.94)
Net income (loss)10.21 4.74 8.08 6.69 (2.98)
Diluted
Income (loss) from continuing operations$10.14 $4.73 $8.04 $6.69 $(2.94)
Net income (loss)
10.14 4.72 8.04 6.68 (2.98)
Dividends declared per common share2.04 2.04 1.92 1.54 0.96 
Common dividends$4,196 $4,299 $4,403 $3,865 $2,595 
Preferred dividends1,040 1,095 1,109 1,174 1,213 
Common share repurchases7,600 2,925 17,875 14,545 14,538 
In millions of dollars, except per share amounts20192018201720162015
Net interest revenue$47,347
$46,562
$45,061
$45,476
$47,093
Non-interest revenue26,939
26,292
27,383
25,321
30,184
Revenues, net of interest expense$74,286
$72,854
$72,444
$70,797
$77,277
Operating expenses42,002
41,841
42,232
42,338
44,538
Provisions for credit losses and for benefits and claims8,383
7,568
7,451
6,982
7,913
Income from continuing operations before income taxes$23,901
$23,445
$22,761
$21,477
$24,826
Income taxes(1)
4,430
5,357
29,388
6,444
7,440
Income (loss) from continuing operations$19,471
$18,088
$(6,627)$15,033
$17,386
Income (loss) from discontinued operations, net of taxes(4)(8)(111)(58)(54)
Net income (loss) before attribution of noncontrolling interests$19,467
$18,080
$(6,738)$14,975
$17,332
Net income attributable to noncontrolling interests
66
35
60
63
90
Citigroup’s net income (loss)(1)
$19,401
$18,045
$(6,798)$14,912
$17,242
Earnings per share     
Basic     
Income (loss) from continuing operations$8.08
$6.69
$(2.94)$4.74
$5.43
Net income (loss)8.08
6.69
(2.98)4.72
5.41
Diluted     
Income (loss) from continuing operations$8.04
$6.69
$(2.94)$4.74
$5.42
Net income (loss)
8.04
6.68
(2.98)4.72
5.40
Dividends declared per common share1.92
1.54
0.96
0.42
0.16
Common dividends$4,403
$3,865
$2,595
$1,214
$484
Preferred dividends1,109
1,174
1,213
1,077
769
Common share repurchases17,875
14,545
14,538
9,451
5,452

Table continues on the next page, including footnotes.

10


SUMMARY OF SELECTED FINANCIAL DATA—PAGE 2DATA
(Continued)
Citigroup Inc. and Consolidated Subsidiaries
In millions of dollars, except per share amounts, ratios and direct staff20212020201920182017
At December 31:
Total assets$2,291,413 $2,260,090 $1,951,158 $1,917,383 $1,842,465 
Total deposits1,317,230 1,280,671 1,070,590 1,013,170 959,822 
Long-term debt254,374 271,686 248,760 231,999 236,709 
Citigroup common stockholders’ equity(2)
182,977 179,962 175,262 177,760 181,487 
Total Citigroup stockholders’ equity(2)
201,972 199,442 193,242 196,220 200,740 
Average assets2,347,709 2,226,454 1,978,805 1,920,242 1,875,438 
Direct staff (in thousands)
223 210 200 204 209 
Performance metrics
Return on average assets0.94 %0.50 %0.98 %0.94 %(0.36)%
Return on average common stockholders’ equity(2)(3)
11.5 5.7 10.3 9.4 (3.9)
Return on average total stockholders’ equity(2)(3)
10.9 5.7 9.9 9.1 (3.0)
Return on tangible common equity (RoTCE)(2)(4)
13.4 6.6 12.1 11.0 8.1 
Efficiency ratio (total operating expenses/total revenues, net)67.0 58.8 57.0 58.1 59.0 
Basel III ratios(2)(5)
Common Equity Tier 1 Capital(6)
12.25 %11.51 %11.79 %11.86 %12.36 %
Tier 1 Capital(6)
13.91 13.06 13.33 13.43 14.06 
Total Capital(6)
16.04 15.33 15.87 16.14 16.30 
Supplementary Leverage ratio5.73 6.99 6.20 6.40 6.68 
Citigroup common stockholders’ equity to assets(2)
7.99 %7.96 %8.98 %9.27 %9.85 %
Total Citigroup stockholders’ equity to assets(2)
8.81 8.82 9.90 10.23 10.90 
Dividend payout ratio(7)
20 43 24 23 NM
Total payout ratio(8)
56 73 122 109 NM
Book value per common share(2)
$92.21 $86.43 $82.90 $75.05 $70.62 
Tangible book value (TBV) per share(2)(4)
79.16 73.67 70.39 63.79 60.16 

(1)    Revenue previously referred to as net interest revenue is now referred to as net interest income. During the fourth quarter of 2021, Citi reclassified deposit insurance expenses from Interest expense to Other operating expenses for all periods presented. Amounts reclassified for each year were $1,207 million for 2021, $1,203 million for 2020, $781 million for 2019, $1,182 million for 2018 and $1,249 million for 2017. See Note 1 to the Consolidated Financial Statements.
(2)    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.
(3)    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.
(4)    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.
(5)    Citi’s risk-based capital and leverage ratios for 2017 are non-GAAP financial measures, which reflect full implementation of regulatory capital adjustments and deductions prior to the effective date of January 1, 2018.
(6)    Citi’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were 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, 2021 and December 31, 2019 to 2017. Citi’s reportable Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios were the lower derived under the Basel III Advanced Approaches framework as of December 31, 2020.
(7)    Dividends declared per common share as a percentage of net income per diluted share.
(8)    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


11
  
In millions of dollars, except per share amounts, ratios and direct staff20192018201720162015
At December 31:     
Total assets$1,951,158
$1,917,383
$1,842,465
$1,792,077
$1,731,210
Total deposits1,070,590
1,013,170
959,822
929,406
907,887
Long-term debt248,760
231,999
236,709
206,178
201,275
Citigroup common stockholders’ equity(1)
175,262
177,760
181,487
205,867
205,139
Total Citigroup stockholders’ equity(1)
193,242
196,220
200,740
225,120
221,857
Average assets1,978,805
1,920,242
1,875,438
1,808,728
1,823,875
Direct staff (in thousands)
200
204
209
219
231
Performance metrics     
Return on average assets0.98%0.94%(0.36)%0.82%0.95%
Return on average common stockholders’ equity(1)(2)
10.3
9.4
(3.9)6.6
8.1
Return on average total stockholders’ equity(1)(2)
9.9
9.1
(3.0)6.5
7.9
Return on tangible common equity (RoTCE)(1)(3)
12.1
11.0
8.1
7.6
9.3
Efficiency ratio (total operating expenses/total revenues)56.5
57.4
58.3
59.8
57.6
Basel III ratios(1)(4)
     
Common Equity Tier 1 Capital(5)
11.81%11.86%12.36 %12.57%12.07%
Tier 1 Capital(5)
13.36
13.46
14.06
14.24
13.49
Total Capital(5)
15.97
16.18
16.30
16.24
15.30
Supplementary Leverage ratio6.21
6.41
6.68
7.22
7.08
Citigroup common stockholders’ equity to assets(1)
8.98%9.27%9.85 %11.49%11.85%
Total Citigroup stockholders’ equity to assets(1)
9.90
10.23
10.90
12.56
12.82
Dividend payout ratio(6)
23.9
23.1
         NM
8.9
3.0
Total payout ratio(7)
121.8
109.1
         NM
77.1
36.0
Book value per common share(1)
$82.90
$75.05
$70.62
$74.26
$69.46
Tangible book value (TBV) per share(1)(3)
70.39
63.79
60.16
64.57
60.61
(1)2017 includes the one-time impact related to enactment of the Tax Cuts and Jobs Act (Tax Reform). 2019 and 2018 reflect the tax rate structure post Tax Reform. For additional information, see “Significant Accounting Policies and Significant Estimates—Income Taxes” below. RoTCE for 2017 excludes the one-time impact from Tax Reform.
(2)The return on average common stockholders’ equity is calculated using net income less preferred stock dividends divided by average common stockholders’ equity. The return on average total Citigroup stockholders’ equity is calculated using net income divided by average Citigroup stockholders’ equity.
(3)For information on RoTCE and TBV, see “Capital Resources—Tangible Common Equity, Book Value Per Share, Tangible Book Value Per Share and Returns on Equity” below.
(4)Citi’s risk-based capital and leverage ratios for 2017 and prior years are non-GAAP financial measures, which reflect full implementation of regulatory capital adjustments and deductions prior to the effective date of January 1, 2018.
(5)As of December 31, 2019, 2018, and 2017, Citi’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the Basel III Standardized Approach, whereas the reportable Total Capital ratio was the lower derived under the Basel III Advanced Approaches framework. For all prior periods presented, Citi’s Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios were the lower derived under the Basel III Advanced Approaches framework.
(6)Dividends declared per common share as a percentage of net income per diluted share.
(7)
Total common dividends declared plus common stock repurchases as a percentage of net income available to common shareholders (Net income, less preferred dividends). See “Consolidated Statement of Changes in Stockholders’ Equity,” Note 10 to the Consolidated Financial Statements and “Equity Security Repurchases” below for the component details.

NMNot meaningful



SEGMENT AND BUSINESS—INCOME (LOSS) AND REVENUES

CITIGROUP INCOME

In millions of dollars20192018
2017(1)
% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
In millions of dollars202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Income (loss) from continuing operations  Income (loss) from continuing operations
Global Consumer Banking  
North America$3,224
$3,087
$1,829
4 %69 %
Latin America901
802
516
12
55
Asia(2)
1,577
1,420
1,197
11
19
Total$5,702
$5,309
$3,542
7 %50 %
Institutional Clients Group  Institutional Clients Group
North America$3,511
$3,675
$2,494
(4)%47 %North America$5,781 $3,310 $3,407 75 %(3)%
EMEA3,867
3,889
2,828
(1)38
EMEA4,347 3,280 3,836 33 (14)
Latin America2,111
2,013
1,637
5
23
Latin America2,429 1,390 2,101 75 (34)
Asia3,455
2,997
2,416
15
24
Asia(2)
3,206 3,573 3,432 (10)
TotalTotal$15,763 $11,553 $12,776 36 %(10)%
Global Consumer BankingGlobal Consumer Banking
North AmericaNorth America$5,934 $(46)$3,157 NMNM
Latin AmericaLatin America798 241 885 NM(73)%
Asia(1)
Asia(1)
(686)468 1,537 NM(70)
Total$12,944
$12,574
$9,375
3 %34 %Total$6,046 $663 $5,579 NM(88)%
Corporate/Other825
205
(19,544)NM
NM
Corporate/Other209 (1,109)1,116 NMNM
Income (loss) from continuing operations$19,471
$18,088
$(6,627)8 %NM
Income from continuing operationsIncome from continuing operations$22,018 $11,107 $19,471 98 %(43)%
Discontinued operations$(4)$(8)$(111)50 %93 %Discontinued operations$7 $(20)$(4)NMNM
Less: net income attributable to noncontrolling interests66
35
60
89
(42)
Citigroup’s net income (loss)$19,401
$18,045
$(6,798)8 %NM
Less: Net income attributable to noncontrolling interestsLess: Net income attributable to noncontrolling interests73 40 66 83 %(39)%
Citigroup’s net incomeCitigroup’s net income$21,952 $11,047 $19,401 99 %(43)%

(1)
2017 includes the one-time impact related to enactment of Tax Reform. For additional information, see “Significant Accounting Policies and SignificantEstimates—Income Taxes” below.
(1)    Asia GCB includes the results of operations of GCB activities in certain EMEA countries.
(2)
Asia GCB includes the results of operations of GCB activities in certain EMEA countries for all periods presented.
NM Not meaningful

CITIGROUP REVENUES
CITIGROUP REVENUES
In millions of dollars202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Institutional Clients Group
North America$16,748 $17,476 $13,603 (4)%28 %
EMEA13,094 13,041 12,157  
Latin America4,946 4,981 5,275 (1)(6)
Asia9,099 9,590 8,789 (5)
Total$43,887 $45,088 $39,824 (3)%13 %
Global Consumer Banking
North America$17,481 $19,284 $20,460 (9)%(6)%
Latin America4,250 4,466 5,334 (5)(16)
Asia(1)
5,599 6,592 7,427 (15)(11)
Total$27,330 $30,342 $33,221 (10)%(9)%
Corporate/Other667 71 2,022 NM(96)
Total Citigroup net revenues$71,884 $75,501 $75,067 (5)%%

(1)    Asia GCB includes the results of operations of GCB activities in certain EMEA countries.
NM Not meaningful

12
In millions of dollars201920182017% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
Global Consumer Banking     
  North America$20,398
$19,829
$19,570
3 %1 %
  Latin America5,238
5,309
4,794
(1)11
  Asia(1)
7,335
7,201
7,081
2
2
Total$32,971
$32,339
$31,445
2 %3 %
Institutional Clients Group     
  North America$13,459
$13,522
$14,578
 %(7)%
  EMEA12,006
11,770
10,878
2
8
  Latin America5,166
4,954
4,814
4
3
  Asia8,670
8,079
7,552
7
7
Total$39,301
$38,325
$37,822
3 %1 %
Corporate/Other2,014
2,190
3,177
(8)(31)
Total Citigroup net revenues$74,286
$72,854
$72,444
2 %1 %
(1)
Asia GCB includes the results of operations of GCB activities in certain EMEA countries for all periods presented.




SEGMENT BALANCE SHEET(1)—DECEMBER 31, 20192021
In millions of dollarsInstitutional
Clients
Group
Global
Consumer
Banking
Corporate/Other
and
consolidating
eliminations(2)
Citigroup
parent
company-
issued
long-term
debt and
stockholders’
equity(3)
Total
Citigroup
consolidated
Assets     
Cash and deposits with banks, net of allowance$90,714 $7,953 $163,366 $ $262,033 
Securities borrowed and purchased under agreements to resell, net of allowance326,937 118 233  327,288 
Trading account assets318,495 1,186 12,264  331,945 
Investments, net of allowance132,357 1,218 379,247  512,822 
Loans, net of unearned income and allowance for credit losses on loans393,681 253,721 3,910  651,312 
Other assets, net of allowance112,901 51,480 41,632  206,013 
Net inter-segment liquid assets(4)
386,448 116,728 (503,176)  
Total assets$1,761,533 $432,404 $97,476 $ $2,291,413 
Liabilities and equity    
Total deposits$949,522 $361,808 $5,900 $ $1,317,230 
Securities loaned and sold under agreements to repurchase188,784 2,498 3  191,285 
Trading account liabilities160,353 763 413  161,529 
Short-term borrowings27,309 109 555  27,973 
Long-term debt(3)
89,720 482 (773)164,945 254,374 
Other liabilities, net of allowance88,443 32,325 15,582  136,350 
Net inter-segment funding (lending)(3)
257,402 34,419 75,096 (366,917) 
Total liabilities$1,761,533 $432,404 $96,776 $(201,972)$2,088,741 
Total stockholders’ equity(5)
  700 201,972 202,672 
Total liabilities and equity$1,761,533 $432,404 $97,476 $ $2,291,413 

(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.

13
In millions of dollars
Global
Consumer
Banking
Institutional
Clients
Group
Corporate/Other
and
consolidating
eliminations(2)
Citigroup
parent
company-
issued
long-term
debt and
stockholders’
equity(3)
Total
Citigroup
consolidated
Assets     
Cash and deposits with banks$7,076
$69,363
$117,480
$
$193,919
Securities borrowed and purchased under agreements to resell87
250,968
267

251,322
Trading account assets1,168
265,260
9,712

276,140
Investments1,150
126,481
240,932

368,563
Loans, net of unearned income and allowance for loan losses290,270
387,036
9,394

686,700
Other assets39,071
94,648
40,795

174,514
Net inter-segment liquid assets(4)
68,077
253,463
(321,540)

Total assets$406,899
$1,447,219
$97,040
$
$1,951,158
Liabilities and equity    
Total deposits$291,049
$767,666
$11,875
$
$1,070,590
Securities loaned and sold under agreements to repurchase2,229
164,096
14

166,339
Trading account liabilities549
118,788
557

119,894
Short-term borrowings417
27,082
17,550

45,049
Long-term debt(3)
1,472
64,758
32,053
150,477
248,760
Other liabilities20,847
71,215
14,518

106,580
Net inter-segment funding (lending)(3)
90,336
233,614
19,769
(343,719)
Total liabilities$406,899
$1,447,219
$96,336
$(193,242)$1,757,212
Total stockholders’ equity(5)


704
193,242
193,946
Total liabilities and equity$406,899
$1,447,219
$97,040
$
$1,951,158


INSTITUTIONAL CLIENTS GROUP
As of December 31, 2021, Institutional Clients Group (ICG) included Banking and Markets and securities services (for additional information on these businesses, see “Citigroup Segments” above). ICG provided 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 transacted with clients in both cash instruments and derivatives, including fixed income, foreign currency, equity and commodity products.
For information on Citi’s planned revision to its reporting structure, including the reporting of the private bank as part of a new reporting segment, Personal Banking and Wealth Management, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
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 income.
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 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.
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 95 countries and jurisdictions. At December 31, 2021, ICG had $1.8 trillion in assets and $950 billion in deposits. Securities services and issuer services managed $24.0 trillion in assets under custody and administration at December 31, 2021, of which Citi provides both custody and administrative services to certain clients related to $1.9 trillion of such assets. Managed assets under trust were $3.8 trillion at December 31, 2021. For additional information on these operations, see “Administration and Other Fiduciary Fees” in Note 5 to the Consolidated Financial Statements.
14


(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.
In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Commissions and fees$4,750 $4,412 $4,462 8 %(1)%
Administration and other fiduciary fees3,351 2,877 2,756 16 
Investment banking6,741 5,009 4,440 35 13 
Principal transactions10,064 13,308 8,562 (24)55 
Other(1)
1,384 1,149 1,829 20 (37)
Total non-interest revenue$26,290 $26,755 $22,049 (2)%21 %
Net interest income (including dividends)17,597 18,333 17,775 (4)
Total revenues, net of interest expense$43,887 $45,088 $39,824 (3)%13 %
Total operating expenses(2)
$26,513 $24,617 $22,961 8 %%
Net credit losses on loans$396 $987 $394 (60)%NM
Credit reserve build (release) for loans(2,533)3,172 71 NMNM
Provision for credit losses on unfunded lending commitments(777)1,435 98 NMNM
Provisions for credit losses on HTM debt securities and other assets1 21 — (95)100 %
Provisions for credit losses$(2,913)$5,615 $563 NMNM
Income from continuing operations before taxes$20,287 $14,856 $16,300 37 %(9)%
Income taxes4,524 3,303 3,524 37 (6)
Income from continuing operations$15,763 $11,553 $12,776 36 %(10)%
Noncontrolling interests83 50 40 66 25 
Net income$15,680 $11,503 $12,736 36 %(10)%
Balance Sheet data and ratios
EOP assets (in billions of dollars)
$1,762 $1,730 $1,447 2 %20 %
Average assets (in billions of dollars)
1,812 1,706 1,493 6 14 
Return on average assets0.87 %0.67 %0.85 %
Efficiency ratio60 55 58 
Revenues by region
North America$16,748 $17,476 $13,603 (4)%28 %
EMEA13,094 13,041 12,157  
Latin America4,946 4,981 5,275 (1)(6)
Asia9,099 9,590 8,789 (5)
Total$43,887 $45,088 $39,824 (3)%13 %
Income from continuing operations by region 
North America$5,781 $3,310 $3,407 75 %(3)%
EMEA4,347 3,280 3,836 33 (14)
Latin America2,429 1,390 2,101 75 (34)
Asia3,206 3,573 3,432 (10)
Total$15,763 $11,553 $12,776 36 %(10)%
Average loans by region (in billions of dollars)
 
North America$202 $201 $188  %%
EMEA89 88 87 1 
Latin America32 39 40 (18)(3)
Asia73 71 73 3 (3)
Total$396 $399 $388 (1)%%
EOP deposits by business (in billions of dollars)
Treasury and trade solutions$636 $651 $536 (2)%21 %
All other ICG businesses
314 273 232 15 18 
Total$950 $924 $768 3 %20 %

(1)    2019 includes an approximate $350 million gain on Citi’s investment in Tradeweb.
(2)    2020 includes an approximate $390 million operational loss related to certain legal matters.
NM Not meaningful

15


ICG Revenue Details

In millions of dollars202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Investment banking revenue details
Advisory$1,796 $1,010 $1,259 78 %(20)%
Equity underwriting2,434 1,593 973 53 64 
Debt underwriting3,283 3,184 2,984 3 
Total investment banking$7,513 $5,787 $5,216 30 %11 %
Treasury and trade solutions9,444 9,824 10,513 (4)(7)
Corporate lending—excluding gains (losses) on loan hedges(1)
2,291 2,310 2,985 (1)(23)
Private bank—excluding gains (losses) on loan hedges(1)
4,005 3,794 3,487 6 
Total Banking revenues (ex-gains (losses) on loan hedges)(1)
$23,253 $21,715 $22,201 7 %(2)%
  Losses on loan hedges(1)
$(144)$(51)$(432)NM88 %
Total Banking revenues (including gains (losses) on loan hedges), net of interest expense
$23,109 $21,664 $21,769 7 %— %
Fixed income markets(2)
$13,720 $17,588 $13,074 (22)%35 %
Equity markets4,545 3,624 2,908 25 25 
Securities services2,720 2,562 2,642 6 (3)
Other(207)(352)(569)41 38 
Total Markets and securities services revenues, net
of interest expense
$20,778 $23,424 $18,055 (11)%30 %
Total revenues, net of interest expense$43,887 $45,088 $39,824 (3)%13 %
Commissions and fees$793 $677 $782 17 %(13)%
Principal transactions(3)
7,692 11,518 7,661 (33)50 
Other(2)
831 579 1,117 44 (48)
Total non-interest revenue$9,316 $12,774 $9,560 (27)%34 %
Net interest income4,404 4,814 3,514 (9)37 
Total fixed income markets(4)
$13,720 $17,588 $13,074 (22)%35 %
Rates and currencies$8,903 $12,162 $9,242 (27)%32 %
Spread products/other fixed income4,817 5,426 3,832 (11)42 
Total fixed income markets$13,720 $17,588 $13,074 (22)%35 %
Commissions and fees$1,231 $1,245 $1,121 (1)%11 %
Principal transactions(3)
1,986 1,281 775 55 65 
Other191 322 172 (41)87 
Total non-interest revenue$3,408 $2,848 $2,068 20 %38 %
Net interest income1,137 776 840 47 (8)
Total equity markets(4)
$4,545 $3,624 $2,908 25 %25 %

(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 $(131) million and $(74) million related to the corporate loan portfolio and $(13) million and $23 million related to the private bank for the years ended December 31, 2021 and 2020, respectively. All of gains (losses) on loan hedges are related to the corporate loan portfolio for the year ended December 31, 2019. 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 income 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
16


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.

2021 vs. 2020
Net income of $15.7 billion increased 36% versus the prior year, primarily driven by lower cost of credit, partially offset by higher expenses and lower revenues.
Revenues decreased 3%, reflecting lower Markets and securities services revenues, partially offset by higher Banking revenues. Banking revenues were up 7% (both including and excluding the impact of losses on loan hedges), driven by higher revenues in investment banking and the private bank, partially offset by lower revenues in treasury and trade solutions and corporate lending. Markets and securities services revenues were down 11%, primarily reflecting a normalization in fixed income markets revenues, partially offset by growth in equity markets and securities services.
Citi expects that revenues in its markets and investment banking businesses will continue to reflect the overall market environment during 2022.

Within Banking:

Investment banking revenues were up 30%, reflecting growth in the overall market wallet. Advisory revenues increased 78%, reflecting strength in North America and EMEA, driven by growth in the market wallet as well as wallet share gains. Equity underwriting revenues increased 53%, reflecting strength in North America and EMEA, driven by growth in the market wallet, as well as wallet share gains. Debt underwriting revenues increased 3%, reflecting strength in EMEA, as growth in the market wallet was partially offset by a decline in wallet share.
Treasury and trade solutions revenues decreased 4% (both including and excluding the impact of FX translation), reflecting a decline in revenues in the cash business, partially offset by an increase in trade revenues. Cash revenues decreased, driven by the ongoing impact of lower deposit spreads. The decrease was partially offset by strong growth in fee revenues reflecting solid client engagement and growth in transaction volumes, including growth in USD clearing, commercial cards and cross-border solutions. The increase in trade revenues was driven by improved trade spreads and growth in loans, reflecting an increase in trade flows and originations, primarily in Asia and EMEA. Average trade loans increased 5% (both including and excluding the impact of FX translation).
Corporate lending revenues decreased 3%, including the impact of losses on loan hedges. Excluding the impact of losses on loan hedges, revenues decreased 1%, as lower cost of funds was more than offset by lower loan volumes, reflecting muted demand given strong client liquidity positions. Average loans decreased 20% during the current year.
Private bank revenues increased 5%. Excluding the impact of gains (losses) on loan hedges, revenues increased 6%, driven by strong performance in North America and EMEA. The higher revenues reflected continued momentum with new and existing clients,
resulting in higher loan volumes and spreads, higher managed investments revenues and higher deposit volumes. The increase in revenues was partially offset by lower deposit spreads due to the ongoing low interest rate environment and lower capital markets revenue.

Within Markets and securities services:

Fixed income markets revenues decreased 22%, reflecting lower revenues across all regions, largely driven by a comparison to a strong prior year, as well as a normalization in market activity, particularly in rates and currencies, and spread products. Non-interest revenues decreased, reflecting lower investor client activity across rates and currencies and spread products. Net interest income also decreased, largely reflecting a change in the mix of trading positions.
Rates and currencies revenues decreased 27%, driven by the normalization in market activity, and a comparison to a strong prior year that included elevated levels of volatility related to the pandemic. Spread products and other fixed income revenues decreased 11%, driven by a comparison to a strong prior year and the normalization in market activity, particularly in flow trading and structured products, reflecting lower volatility and spreads, partially offset by strong securitization activity.
Equity markets revenues increased 25%, driven by growth across all products. Equity derivatives revenues increased reflecting higher client activity, particularly in EMEA and North America. Prime finance revenues increased due to favorable market conditions as well as growth in client balances. Cash equities revenues increased modestly, reflecting higher client activity. Non-interest revenues increased, primarily due to higher principal transactions revenues, reflecting higher client activity.
Securities services revenues increased 6%. Excluding the impact of FX translation, revenues increased 7%, as an increase in fee revenues with both new and existing clients, driven by growth in assets under custody and settlement volumes, was partially offset by lower deposit spreads.

Expenses were up 8%, primarily driven by continued investments in Citi’s transformation, business-led investments and higher incentive compensation, as well as transactional related expenses, partially offset by productivity savings.
Provisions reflected a benefit of $2.9 billion compared to costs of $5.6 billion in the prior year, driven by an ACL release and lower net credit losses.
Net credit losses declined to $396 million from $987 million in the prior year, driven by improvements in portfolio credit quality.
The ACL release was $3.3 billion compared to a build of $4.6 billion in the prior year. The release was primarily driven by improvements in portfolio credit quality as well as Citi’s improved macroeconomic outlook. For additional information
17


on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on trends in ICG’s deposits and loans, see “Managing Global Risk—Liquidity Risk—Loans” and “—Deposits” below.
For additional information on ICG’scorporate 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 “Managing Global Risk—Other Risks—Country Risk—Argentina” and “Risk Factors” below.



18














































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19


(3)Total stockholders’ equity and the majority of long-term debt of Citigroup reside on the Citigroup parent company balance sheet. Citigroup allocates stockholders’ equity and long-term debt to its businesses through inter-segment allocations as shown above.
(4)Represents the attribution of Citigroup’s liquid assets (primarily consisting of cash, marketable equity securities and available-for-sale debt securities) to the various businesses based on Liquidity Coverage Ratio (LCR) assumptions.
(5)
Corporate/Other equity represents noncontrolling interests.


GLOBAL CONSUMER BANKING

As of December 31, 2021, Global Consumer Banking (GCB) consistsconsisted of consumer banking businesses in North America, Latin America (consisting of Citi’s consumer banking business in Mexico) and Asia. GCB providesprovided traditional banking services to retail customers through retail banking, Citi-brandedbranded cards and, Citiin the U.S., retail services (for additional information on these businesses,consumer market exits related to Latin America GCB and Asia GCB as well as Citi’s planned revision to its reporting structure, see “Citigroup Segments”“Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above).
GCB is focused on its priority’s markets in the U.S., Mexico and Asia with 2,348had a combined 2,154 branches in 19 countries and jurisdictions as of December 31, 2019.2021. At December 31, 2019,2021, GCB had approximately $407$267 billion in assetsloans and $291$362 billion in deposits.retail banking deposits (excluding approximately $10 billion of loans and $8 billion of deposits reclassified to held-for-sale as a result of Citi’s agreements to sell its consumer banking businesses in Australia and the Philippines).
GCB’s overall strategy is to leverage Citi’s global footprint and be the pre-eminent bank for the affluent and emerging affluent consumers in large urban centers. In credit cards and in certain retail markets, Citi serves customers in a somewhat broader set of segments and geographies.

In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$24,238 $26,551 $28,455 (9)%(7)%
Non-interest revenue3,092 3,791 4,766 (18)(20)
Total revenues, net of interest expense$27,330 $30,342 $33,221 (10)%(9)%
Total operating expenses$20,035 $17,834 $18,039 12 %(1)%
Net credit losses on loans$4,582 $6,646 $7,382 (31)%(10)%
Credit reserve build (release) for loans(5,174)4,951 439 NMNM
Provision for credit losses on unfunded lending commitments —  100 
Provisions for benefits and claims, and other assets96 105 73 (9)44 
Provisions for credit losses and for benefits and claims (PBC)$(496)$11,702 $7,895 NM48 %
Income from continuing operations before taxes$7,791 $806 $7,287 NM(89)%
Income taxes1,745 143 1,708 NM(92)
Income from continuing operations$6,046 $663 $5,579 NM(88)%
Noncontrolling interests(11)(4)NMNM
Net income$6,057 $667 $5,573 NM(88)%
Balance Sheet data and ratios
EOP assets (in billions of dollars)
$432 $434 $407  %%
Average assets (in billions of dollars)
440 426 389 3 10 
Return on average assets1.38 %0.16 %1.43 %
Efficiency ratio73 59 54 
Average retail banking deposits (in billions of dollars)
$352 $311 $277 13 12 
Net credit losses as a percentage of average loans1.72 %2.39 %2.60 %
Revenue by business
Retail banking$10,776 $11,996 $12,758 (10)%(6)%
Cards(1)
16,554 18,346 20,463 (10)(10)
Total$27,330 $30,342 $33,221 (10)%(9)%
Income from continuing operations by business
Retail banking$(830)$557 $1,741 NM(68)%
Cards(1)
6,876 106 3,838 NM(97)
Total$6,046 $663 $5,579 NM(88)%
In millions of dollars, except as otherwise noted201920182017% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
Net interest revenue$28,205
$27,374
$26,277
3 %4 %
Non-interest revenue4,766
4,965
5,168
(4)(4)
Total revenues, net of interest expense$32,971
$32,339
$31,445
2 %3 %
Total operating expenses$17,628
$17,786
$17,229
(1)%3 %
Net credit losses$7,382
$6,884
$6,462
7 %7 %
Credit reserve build439
568
1,029
(23)(45)
Provision for unfunded lending commitments1


100

Provision for benefits and claims73
103
116
(29)(11)
Provisions for credit losses and for benefits and claims
  (LLR & PBC)
$7,895
$7,555
$7,607
5 %(1)%
Income from continuing operations before taxes$7,448
$6,998
$6,609
6 %6 %
Income taxes1,746
1,689
3,067
3
(45)
Income from continuing operations$5,702
$5,309
$3,542
7 %50 %
Noncontrolling interests6
7
9
(14)(22)
Net income$5,696
$5,302
$3,533
7 %50 %
Balance Sheet data and ratios (in billions of dollars)
     
Total EOP assets$407
$388
$389
5 % %
Average assets389
378
380
3
(1)
Return on average assets1.46%1.40%0.93%  
Efficiency ratio53
55
55
  
Average deposits$277
$269
$267
3
1
Net credit losses as a percentage of average loans2.60%2.48%2.39%  
Revenue by business     
Retail banking$12,549
$12,627
$12,089
(1)%4 %
Cards(1)
20,422
19,712
19,356
4
2
Total$32,971
$32,339
$31,445
2 %3 %
Income from continuing operations by business     
Retail banking$1,842
$1,851
$1,320
 %40 %
Cards(1)
3,860
3,458
2,222
12
56
Total$5,702
$5,309
$3,542
7 %50 %

Table continues on the next page, including footnotes.


20


Foreign currency (FX) translation impact  Foreign currency (FX) translation impact
Total revenue—as reported$32,971
$32,339
$31,445
2 %3 %Total revenue—as reported$27,330 $30,342 $33,221 (10)%(9)%
Impact of FX translation(2)

(146)(270) 
Impact of FX translation(2)
 323 (157)
Total revenues—ex-FX(3)
$32,971
$32,193
$31,175
2 %3 %
Total revenues—ex-FX(3)
$27,330 $30,665 $33,064 (11)%(7)%
Total operating expenses—as reported$17,628
$17,786
$17,229
(1)%3 %Total operating expenses—as reported$20,035 $17,834 $18,039 12 %(1)%
Impact of FX translation(2)

(100)(154) 
Impact of FX translation(2)
 212 (80)
Total operating expenses—ex-FX(3)
$17,628
$17,686
$17,075
 %4 %
Total operating expenses—ex-FX(3)
$20,035 $18,046 $17,959 11 %— %
Total provisions for LLR & PBC—as reported$7,895
$7,555
$7,607
5 %(1)%
Total provisions for credit losses and PBC—as reportedTotal provisions for credit losses and PBC—as reported$(496)$11,702 $7,895 NM48 %
Impact of FX translation(2)

(24)(53) 
Impact of FX translation(2)
 87 (51)
Total provisions for LLR & PBC—ex-FX(3)
$7,895
$7,531
$7,554
5 % %
Total provisions for credit losses and PBC—ex-FX(3)
Total provisions for credit losses and PBC—ex-FX(3)
$(496)$11,789 $7,844 NM50 %
Net income—as reported$5,696
$5,302
$3,533
7 %50 %Net income—as reported$6,057 $667 $5,573 NM(88)%
Impact of FX translation(2)

(16)(42) 
Impact of FX translation(2)
 12 (11)
Net income—ex-FX(3)
$5,696
$5,286
$3,491
8 %51 %
Net income—ex-FX(3)
$6,057 $679 $5,562 NM(88)%
(1)Includes both Citi-branded cards and Citi retail services.
(2)

(1)Includes both branded cards and retail services.
(2)Reflects the impact of FX translation into U.S. dollars at the 2019 average exchange rates for all periods presented.
(3)Presentation of this metric excluding FX translation is a non-GAAP financial measure.
Note: For information on the impact of Citi’s January 1, 2020 adoptionFX translation into U.S. dollars at the 2021 average exchange rates for all periods presented.
(3)Presentation of the new accounting standard on credit losses (CECL), see “Risk Factors—Operational Risks” below and Note 1 to the Consolidated Financial Statements.this metric excluding FX translation is a non-GAAP financial measure.
NM Not meaningful




21


NORTH AMERICA GCB

As of December 31, 2021, North America GCB providesprovided traditional retail banking and Citi-brandedbranded 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 includesincluded its proprietary portfolio (including the Citi Double(Double Cash, Thank YouCustom Cash, ThankYou and Value cards) and co-branded cards (including, among others, American Airlines and Costco) within Citi-brandedbranded cards, as well as its co-brand and private label relationships (including, among others, Sears, The Home Depot, Sears, Best Buy and Macy’s) within Citi retail services. For information on Citi’s planned revision to its reporting structure, including the reporting of North America GCB’s consumer banking businesses as part of a new reporting segment, Personal Banking and Wealth Management, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
At December 31, 2019,2021, North America GCB had 687658 retail bank branches concentrated in the six key metropolitan areas of New York, Chicago, Miami, Washington, D.C., Los Angeles and San Francisco. Also, as of December 31, 2019,2021, North America GCB had approximately $50.3$48.1 billion in retail banking loans and $160.5$219.3 billion in retail banking deposits. In addition, North America GCB had approximately $149.2$133.9 billion in outstanding card loan balances.

In millions of dollars, except as otherwise noted201920182017% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest revenue$19,869
$19,006
$18,298
5 %4 %
Non-interest revenue(1)
529
823
1,272
(36)(35)
Net interest incomeNet interest income$17,393 $18,938 $19,931 (8)%(5)%
Non-interest revenueNon-interest revenue88 346 529 (75)(35)
Total revenues, net of interest expense$20,398
$19,829
$19,570
3 %1 %Total revenues, net of interest expense$17,481 $19,284 $20,460 (9)%(6)%
Total operating expenses$10,154
$10,230
$9,867
(1)%4 %Total operating expenses$10,832 $10,237 $10,305 6 %(1)%
Net credit losses$5,583
$5,085
$4,737
10 %7 %
Credit reserve build469
460
926
2
(50)
Provision for unfunded lending commitments1


100

Provision for benefits and claims19
22
33
(14)(33)
Net credit losses on loansNet credit losses on loans$2,937 $4,990 $5,583 (41)%(11)%
Credit reserve build for loansCredit reserve build for loans(3,974)4,115 469 NMNM
Provision for credit losses on unfunded lending commitmentsProvision for credit losses on unfunded lending commitments —  100 
Provisions for benefits and claims, and other assetsProvisions for benefits and claims, and other assets19 17 19 12 (11)
Provisions for credit losses and for benefits and claims$6,072
$5,567
$5,696
9 %(2)%Provisions for credit losses and for benefits and claims$(1,018)$9,122 $6,072 NM50 %
Income from continuing operations before taxes$4,172
$4,032
$4,007
3 %1 %Income from continuing operations before taxes$7,667 $(75)$4,083 NMNM
Income taxes948
945
2,178

(57)Income taxes1,733 (29)926 NMNM
Income from continuing operations$3,224
$3,087
$1,829
4 %69 %Income from continuing operations$5,934 $(46)$3,157 NMNM
Noncontrolling interests

(1)
100
Noncontrolling interests — —  %— %
Net income$3,224
$3,087
$1,830
4 %69 %Net income$5,934 $(46)$3,157 NMNM
Balance Sheet data and ratios (in billions of dollars)
  
 
 
Average assets$232
$227
$232
2 %(2)%
Balance Sheet data and ratiosBalance Sheet data and ratios 
Average assets (in billions of dollars)
Average assets (in billions of dollars)
$266 $266 $232  %15 %
Return on average assets1.39%1.36%0.79% Return on average assets2.23 %(0.02)%1.36 %
Efficiency ratio50
52
50
 Efficiency ratio62 53 50 
Average deposits$152.8
$148.0
$151.0
3
(2)
Average retail banking deposits (in billions of dollars)
Average retail banking deposits (in billions of dollars)
$206 $176 $153 17 15 
Net credit losses as a percentage of average loans2.97%2.78%2.67% Net credit losses as a percentage of average loans1.69 %2.72 %2.97 %
Revenue by business  
 
 Revenue by business 
Retail banking$4,529
$4,600
$4,565
(2)%1 %Retail banking$4,211 $4,519 $4,558 (7)%(1)%
Citi-branded cards9,165
8,628
8,578
6
1
Citi retail services6,704
6,601
6,427
2
3
Branded cardsBranded cards8,189 8,800 9,184 (7)(4)
Retail servicesRetail services5,081 5,965 6,718 (15)(11)
Total$20,398
$19,829
$19,570
3 %1 %Total$17,481 $19,284 $20,460 (9)%(6)%
Income from continuing operations by business  
 
 
Income (loss) from continuing operations by businessIncome (loss) from continuing operations by business 
Retail banking$196
$312
$251
(37)%24 %Retail banking$(453)$(232)$145 (95)%NM
Citi-branded cards1,742
1,581
1,009
10
57
Citi retail services1,286
1,194
569
8
NM
Branded cardsBranded cards3,903 12 1,734 NM(99)%
Retail servicesRetail services2,484 174 1,278 NM(86)
Total$3,224
$3,087
$1,829
4 %69 %Total$5,934 $(46)$3,157 NMNM

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





22

2019
2021 vs. 20182020
Net income increased 4%, as higher revenues andwas $5.9 billion, compared to a net loss of $46 million in the prior year, reflecting significantly lower expenses werecost of credit, partially offset by lower revenues and higher cost of credit.expenses.
Revenues increased 3%. Excluding the impact of the $150 million gain on the Hilton portfolio sale in the prior year, revenues increased 4%decreased 9%, reflecting higherlower revenues in Citi-brandedretail banking, branded cards and Citi retail services, partially offset by lower retail banking revenues.services.
Retail banking revenues decreased 2%7%, as the benefit of strongerstrong deposit volumesgrowth and growth in assets under management (increase of 8%, reflecting favorable market conditions and strong client engagement) was more than offset by lower deposit spreads.spreads, as well as lower mortgage revenues. Average deposits increased 3%. Assets under management increased 20%17%, including the benefitdriven by higher levels of market movements. Citi expects that retail banking revenues will likely be impacted by the lower interest rate environment in the near term.consumer liquidity due to government stimulus, as well as continued strategic efforts to drive organic growth.
Cards revenues increased 4% (5% excluding the Hilton gain)decreased 10%. In Citi-brandedBranded cards revenues increased 6% (8% excluding the Hilton gain)decreased 7%, primarily driven by continued higher payment rates, reflecting increased customer liquidity from government stimulus and relief programs, partially offset by higher spending-related revenues. Credit card spend volume growth and spread expansion. Average loans increased 3% and purchase21%, reflecting a continued recovery in sales increased 7%.activity from the pandemic-driven low levels in the prior year.
Citi retailRetail services revenues increased 2%decreased 15%, primarily driven by organic loan growthlower average loans (down 7%), reflecting higher payment rates from the increased customer liquidity from government stimulus and relief programs, as well as higher partner payments, reflecting higher income sharing as a result of lower net credit losses. For additional information on partner payments, see Note 5 to the full-year benefit ofConsolidated Financial Statements. Credit card spend volume increased 18%, reflecting a continued recovery in sales activity from the L.L.Bean portfolio acquisition. Average loans increased 3% and purchase sales increased 2%.pandemic-driven low levels in the prior year.
Expenses decreased 1%increased 6%, primarily driven by continued investments in Citi’s transformation, as efficiency savings more than offset ongoingwell as business-led investments and higher volume-related expenses.expenses, partially offset by productivity savings.
Provisions increased 9%,reflected a benefit of $1.0 billion, compared to costs of $9.1 billion in the prior year, primarily driven by highera net ACL release compared to a net ACL build in the prior year, as well as lower net credit losses. Net credit losses increased 10%decreased 41%, driven by higherconsisting of lower net credit losses in Citi-brandedboth branded cards (up 10%(down 39% to $2.9$1.7 billion) and Citi retail services (up 9%(down 46% to $2.6$1.2 billion). The increase in net credit losses reflected volume growth, primarily driven by lower loan volumes and seasoning in both cards portfolios. improved delinquencies, primarily as a result of the higher payment rates.
The net loan loss reserveACL release was $4.0 billion, compared to a net build increased 2%,of $4.1 billion in the prior year, reflecting volume growthimprovement in portfolio credit quality and seasoningthe continued improvement in both cards portfolios.the macroeconomic outlook. For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on North America GCB’s retail banking, and its Citi-brandedbranded cards and Citi retail services portfolios, see “Credit Risk—Consumer Credit” below.
For information on the impact of Citi’s January 1, 2020 adoption of the new accounting standard on credit losses (CECL), see “Risk Factors—Operational Risks” below and Note 1 to the Consolidated Financial Statements.
As previously disclosed, Sears has continued to close stores since it exited bankruptcy. Although Citi retail services will continue to be impacted from reduced new account acquisitions and lower purchase sales, Citi does not currently expect an immediate or ongoing material impact on its consolidated results. For additional information on the potential impact from a deterioration in or failureabout trends, uncertainties and risks related to maintain Citi’s co-brandingNorth America GCB’s future results, see “Executive Summary” above and private label credit card relationships, see “Risk Factors—Strategic Risks” below.







23


LATIN AMERICA GCB

As of December 31, 2021, Latin America GCB providesprovided traditional retail banking and Citi-brandedbranded card products to retailconsumer and small business customers in Mexico through Citibanamex, oneCitibanamex.
As discussed above, Citi intends to exit its consumer, small business and middle-market banking operations in Mexico. For additional information, see Citi’s Current Report on Form 8-K filed with the SEC on January 11, 2022. For information on Citi’s planned revision to its reporting structure, including the reporting of Mexico’s largest banks.the Mexico consumer, small business and middle-market banking operations as part of a new reporting segment, Legacy Franchises, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
At December 31, 2019,2021, Latin America GCB had 1,4191,276 retail branches in Mexico, with approximately $11.7$8.6 billion in retail banking loans and $23.8$24.8 billion in deposits. In addition, the business had approximately $6.0$4.7 billion in outstanding card loan balances.

In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$2,874 $3,172 $3,735 (9)%(15)%
Non-interest revenue1,376 1,294 1,599 6 (19)
Total revenues, net of interest expense$4,250 $4,466 $5,334 (5)%(16)%
Total operating expenses$2,949 $2,871 $3,001 3 %(4)%
Net credit losses on loans$920 $866 $1,109 6 %(22)%
Credit reserve build (release) for loans(825)316 (38)NMNM
Provision for credit losses on unfunded lending commitments — —  — 
Provisions for benefits and claims, and other assets80 87 54 (8)61 
Provisions for credit losses and for benefits and claims (PBC)$175 $1,269 $1,125 (86)%13 %
Income from continuing operations before taxes$1,126 $326 $1,208 NM(73)%
Income taxes328 85 323 NM(74)
Income from continuing operations$798 $241 $885 NM(73)%
Noncontrolling interests — —  %— 
Net income$798 $241 $885 NM(73)%
Balance Sheet data and ratios  
Average assets (in billions of dollars)
$35 $32 $35 9 %(9)%
Return on average assets2.28 %0.75 %2.53 %
Efficiency ratio69 64 56 
Average deposits (in billions of dollars)
$24 $23 $23 4 — 
Net credit losses as a percentage of average loans6.87 %5.97 %6.45 %
Revenue by business
Retail banking$3,119 $3,103 $3,681 1 %(16)%
Branded cards1,131 1,363 1,653 (17)(18)
Total$4,250 $4,466 $5,334 (5)%(16)%
Income from continuing operations by business  
Retail banking$435 $120 $586 NM(80)%
Branded cards363 121 299 NM(60)
Total$798 $241 $885 NM(73)%
FX translation impact  
Total revenues—as reported$4,250 $4,466 $5,334 (5)%(16)%
Impact of FX translation(1)
 211 (246)
Total revenues—ex-FX(2)
$4,250 $4,677 $5,088 (9)%(8)%
Total operating expenses—as reported$2,949 $2,871 $3,001 3 %(4)%
Impact of FX translation(1)
 129 (132)
Total operating expenses—ex-FX(2)
$2,949 $3,000 $2,869 (2)%%
Provisions for credit losses and PBC—as reported$175 $1,269 $1,125 (86)%13 %
Impact of FX translation(1)
 66 (58)
Provisions for credit losses and PBC—ex-FX(2)
$175 $1,335 $1,067 (87)%25 %
Net income—as reported$798 $241 $885 NM(73)%
Impact of FX translation(1)
 (37)
Net income—ex-FX(2)
$798 $250 $848 NM(71)%

(1)Reflects the impact of FX translation into U.S. dollars at the 2021 average exchange rates for all periods presented.
24


In millions of dollars, except as otherwise noted201920182017% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
Net interest revenue$3,639
$3,681
$3,491
(1)%5 %
Non-interest revenue(1)
1,599
1,628
1,303
(2)25
Total revenues, net of interest expense$5,238
$5,309
$4,794
(1)%11 %
Total operating expenses$2,883
$2,900
$2,721
(1)%7 %
Net credit losses$1,109
$1,131
$1,083
(2)%4 %
Credit reserve build(38)84
113
NM
(26)
Provision for unfunded lending commitments




Provision for benefits and claims54
81
83
(33)(2)
Provisions for credit losses and for benefits and claims (LLR & PBC)$1,125
$1,296
$1,279
(13)%1 %
Income from continuing operations before taxes$1,230
$1,113
$794
11 %40 %
Income taxes329
311
278
6
12
Income from continuing operations$901
$802
$516
12 %55 %
Noncontrolling interests

5

(100)
Net income$901
$802
$511
12 %57 %
Balance Sheet data and ratios (in billions of dollars)
  
 
  
Average assets$35
$33
$35
6 %(6)%
Return on average assets2.57%2.43%1.46%  
Efficiency ratio55
55
57
  
Average deposits$22.8
$22.7
$21.8

4
Net credit losses as a percentage of average loans6.45%6.50%6.08%  
Revenue by business     
Retail banking$3,585
$3,744
$3,324
(4)%13 %
Citi-branded cards1,653
1,565
1,470
6
6
Total$5,238
$5,309
$4,794
(1)%11 %
Income from continuing operations by business  
 
  
Retail banking$600
$596
$332
1 %80 %
Citi-branded cards301
206
184
46
12
Total$901
$802
$516
12 %55 %
FX translation impact  
 
  
Total revenues—as reported(1)
$5,238
$5,309
$4,794
(1)%11 %
Impact of FX translation(2)

(23)(117)  
Total revenues—ex-FX(3)
$5,238
$5,286
$4,677
(1)%13 %
Total operating expenses—as reported$2,883
$2,900
$2,721
(1)%7 %
Impact of FX translation(2)

(13)(59)  
Total operating expenses—ex-FX(3)
$2,883
$2,887
$2,662
 %8 %
Provisions for LLR & PBC—as reported$1,125
$1,296
$1,279
(13)%1 %
Impact of FX translation(2)

(6)(32)  
Provisions for LLR & PBC—ex-FX(3)
$1,125
$1,290
$1,247
(13)%3 %
Net income—as reported$901
$802
$511
12 %57 %
Impact of FX translation(2)

(3)(19)  
Net income—ex-FX(3)
$901
$799
$492
13 %62 %
(2)Presentation of this metric excluding FX translation is a non-GAAP financial measure.
(1)2018 includes an approximate $250 million gain on the sale of an asset management business. See Note 2 to the Consolidated Financial Statements.
(2)Reflects the impact of FX translation into U.S. dollars at the 2019 average exchange rates for all periods presented.
(3)Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM Not meaningful



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.

20192021 vs. 20182020
Net incomeincreased 13%, primarily was $798 million, compared to $250 million in the prior year, reflecting significantly lower cost of credit and modestly lower expenses, partially offset by lower revenues.
Revenues decreased 1%, including a gain on sale (approximately $250 million) of an asset management business in the prior year. Excluding the gain on sale, revenues increased 4%9%, reflecting higher revenues in bothlower cards and retail banking and cards.revenues, largely due to the continued impact of the pandemic.
Retail banking revenues decreased 4%. Excluding the gain on sale, retail banking revenues increased 3%, as improvedprimarily driven by lower loan volumes and deposit spreads, were partially offset by growth in assets under management. Average loans decreased 13%, reflecting the impact of the pandemic on customer activity. Assets under management increased 8%, reflecting favorable market conditions, as well as strong client engagement.
Cards revenues decreased 21%, primarily driven by lower average loans (down 3%11%), reflecting higher payment rates. Credit card spend volume increased 16%, reflecting a continued recovery in sales activity from the ongoing slowdownpandemic-driven low levels in overall economic growth and industry volumes in Mexico. Assets under management increased 13%, including the benefit of market movements, while average deposits were
largely unchanged, as clients transferred money to investments. Cards revenues increased 6%, primarily driven by continued volume growth, reflecting higher purchase sales (up 7%) and average loans (up 3%), as well as higher rates.prior year.
Expenses were largely unchanged,decreased 2%, as efficiencyproductivity savings more than offset ongoing investment spending and volume-driven growth.continued investments in Citi’s transformation.
Provisions of $174 million decreased 13%87%, primarily driven by a modest net loan loss reserveACL release (comparedcompared to a net loan loss reserveACL build in the prior year) and loweryear, partially offset by higher net credit losses reflectingresulting from pandemic-related charge-offs.
The net ACL release was $826 million, compared to a build of $329 million in the prior year. The release reflected an improvement in portfolio credit quality, as well as continued improvement in the macroeconomic outlook and lower volumes in retail banking.loan volumes. For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on Latin America GCB’s retail banking and its Citi-brandedbranded cards portfolios, see “Credit Risk—Consumer Credit” below.
For additional information on the impact of Citi’s January 1, 2020 adoption of the new accounting standard on credit losses (CECL),about trends, uncertainties and risks related to Latin America GCB’s future results, see “Executive Summary” above and “Risk Factors—OperationalStrategic Risks” below and Note 1 to the Consolidated Financial Statements.below.



















25


ASIA GCBINSTITUTIONAL CLIENTS GROUP
Asia GCBAs of December 31, 2021, Institutional Clients Group (ICG) provides traditional retailincluded Banking and Markets and securities services (for additional information on these businesses, see “Citigroup Segments” above). ICG provided 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 Citi-branded card productsadvisory services, private banking, cash management, trade finance and securities services. ICG transacted with clients in both cash instruments and derivatives, including fixed income, foreign currency, equity and commodity products.
For information on Citi’s planned revision to retailits reporting structure, including the reporting of the private bank as part of a new reporting segment, Personal Banking and small business customers. During 2019, Wealth ManagementAsia GCB, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
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 income.
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 market liquidity may increase bid/offer spreads, decrease client activity levels and widen credit spreads on product inventory positions.
ICG’s most significantmanagement of the Markets businesses involves daily monitoring and evaluation of the above factors at the trading desk as well as the country 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 Asia were from Hong Kong, Singapore, South Korea, Australia, India, Taiwan, Thailand, Philippines, Indonesia and Malaysia. Included within Asia GCB, traditional retail banking and Citi-branded card products are also provided to retail customers inanticipation of client demand) or the results of certain EMEA countries, primarily Poland, Russia and the United Arab Emirates.economic hedging activities.
ICG’s international presence is supported by trading floors in approximately 80 countries and a proprietary network in 95 countries and jurisdictions. At December 31, 2019, on a combined basis, the businesses2021, ICG had 242 retail branches, approximately $62.8 billion$1.8 trillion in retail banking loansassets and $106.7$950 billion in deposits. In addition,Securities services and issuer services managed $24.0 trillion in assets under custody and administration at December 31, 2021, of which Citi provides both custody and administrative services to certain clients related to $1.9 trillion of such assets. Managed assets under trust were $3.8 trillion at December 31, 2021. For additional information on these operations, see “Administration and Other Fiduciary Fees” in Note 5 to the businesses had approximately $19.9 billionConsolidated Financial Statements.
14


In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Commissions and fees$4,750 $4,412 $4,462 8 %(1)%
Administration and other fiduciary fees3,351 2,877 2,756 16 
Investment banking6,741 5,009 4,440 35 13 
Principal transactions10,064 13,308 8,562 (24)55 
Other(1)
1,384 1,149 1,829 20 (37)
Total non-interest revenue$26,290 $26,755 $22,049 (2)%21 %
Net interest income (including dividends)17,597 18,333 17,775 (4)
Total revenues, net of interest expense$43,887 $45,088 $39,824 (3)%13 %
Total operating expenses(2)
$26,513 $24,617 $22,961 8 %%
Net credit losses on loans$396 $987 $394 (60)%NM
Credit reserve build (release) for loans(2,533)3,172 71 NMNM
Provision for credit losses on unfunded lending commitments(777)1,435 98 NMNM
Provisions for credit losses on HTM debt securities and other assets1 21 — (95)100 %
Provisions for credit losses$(2,913)$5,615 $563 NMNM
Income from continuing operations before taxes$20,287 $14,856 $16,300 37 %(9)%
Income taxes4,524 3,303 3,524 37 (6)
Income from continuing operations$15,763 $11,553 $12,776 36 %(10)%
Noncontrolling interests83 50 40 66 25 
Net income$15,680 $11,503 $12,736 36 %(10)%
Balance Sheet data and ratios
EOP assets (in billions of dollars)
$1,762 $1,730 $1,447 2 %20 %
Average assets (in billions of dollars)
1,812 1,706 1,493 6 14 
Return on average assets0.87 %0.67 %0.85 %
Efficiency ratio60 55 58 
Revenues by region
North America$16,748 $17,476 $13,603 (4)%28 %
EMEA13,094 13,041 12,157  
Latin America4,946 4,981 5,275 (1)(6)
Asia9,099 9,590 8,789 (5)
Total$43,887 $45,088 $39,824 (3)%13 %
Income from continuing operations by region 
North America$5,781 $3,310 $3,407 75 %(3)%
EMEA4,347 3,280 3,836 33 (14)
Latin America2,429 1,390 2,101 75 (34)
Asia3,206 3,573 3,432 (10)
Total$15,763 $11,553 $12,776 36 %(10)%
Average loans by region (in billions of dollars)
 
North America$202 $201 $188  %%
EMEA89 88 87 1 
Latin America32 39 40 (18)(3)
Asia73 71 73 3 (3)
Total$396 $399 $388 (1)%%
EOP deposits by business (in billions of dollars)
Treasury and trade solutions$636 $651 $536 (2)%21 %
All other ICG businesses
314 273 232 15 18 
Total$950 $924 $768 3 %20 %

(1)    2019 includes an approximate $350 million gain on Citi’s investment in outstanding card loan balances.Tradeweb.

(2)    2020 includes an approximate $390 million operational loss related to certain legal matters.
In millions of dollars, except as otherwise noted(1)
201920182017% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
Net interest revenue$4,697
$4,687
$4,488
 %4 %
Non-interest revenue2,638
2,514
2,593
5
(3)
Total revenues, net of interest expense$7,335
$7,201
$7,081
2 %2 %
Total operating expenses$4,591
$4,656
$4,641
(1)% %
Net credit losses$690
$668
$642
3 %4 %
Credit reserve build (release)8
24
(10)(67)NM
Provision (release) for unfunded lending commitments




Provisions for credit losses$698
$692
$632
1 %9 %
Income from continuing operations before taxes$2,046
$1,853
$1,808
10 %2 %
Income taxes469
433
611
8
(29)
Income from continuing operations$1,577
$1,420
$1,197
11 %19 %
Noncontrolling interests6
7
5
(14)40
Net income$1,571
$1,413
$1,192
11 %19 %
Balance Sheet data and ratios (in billions of dollars)
  
 
  
Average assets$122
$119
$114
3 %4 %
Return on average assets1.29%1.19%1.05%  
Efficiency ratio63
65
66
  
Average deposits$101.1
$98.0
$94.6
3
4
Net credit losses as a percentage of average loans0.88%0.86%0.85%  
Revenue by business     
Retail banking$4,435
$4,283
$4,200
4 %2 %
Citi-branded cards2,900
2,918
2,881
(1)1
Total$7,335
$7,201
$7,081
2 %2 %
Income from continuing operations by business     
Retail banking$1,046
$943
$737
11 %28 %
Citi-branded cards531
477
460
11
4
Total$1,577
$1,420
$1,197
11 %19 %
FX translation impact     
Total revenues—as reported$7,335
$7,201
$7,081
2 %2 %
Impact of FX translation(2)

(123)(153)  
Total revenues—ex-FX(3)
$7,335
$7,078
$6,928
4 %2 %
Total operating expenses—as reported$4,591
$4,656
$4,641
(1)% %
Impact of FX translation(2)

(87)(95)  
Total operating expenses—ex-FX(3)
$4,591
$4,569
$4,546
 %1 %
Provisions for credit losses—as reported$698
$692
$632
1 %9 %
Impact of FX translation(2)

(18)(21)  
Provisions for credit losses—ex-FX(3)
$698
$674
$611
4 %10 %
Net income—as reported$1,571
$1,413
$1,192
11 %19 %
Impact of FX translation(2)

(13)(23)  
Net income—ex-FX(3)
$1,571
$1,400
$1,169
12 %20 %

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

15


ICG Revenue Details

In millions of dollars202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Investment banking revenue details
Advisory$1,796 $1,010 $1,259 78 %(20)%
Equity underwriting2,434 1,593 973 53 64 
Debt underwriting3,283 3,184 2,984 3 
Total investment banking$7,513 $5,787 $5,216 30 %11 %
Treasury and trade solutions9,444 9,824 10,513 (4)(7)
Corporate lending—excluding gains (losses) on loan hedges(1)
2,291 2,310 2,985 (1)(23)
Private bank—excluding gains (losses) on loan hedges(1)
4,005 3,794 3,487 6 
Total Banking revenues (ex-gains (losses) on loan hedges)(1)
$23,253 $21,715 $22,201 7 %(2)%
  Losses on loan hedges(1)
$(144)$(51)$(432)NM88 %
Total Banking revenues (including gains (losses) on loan hedges), net of interest expense
$23,109 $21,664 $21,769 7 %— %
Fixed income markets(2)
$13,720 $17,588 $13,074 (22)%35 %
Equity markets4,545 3,624 2,908 25 25 
Securities services2,720 2,562 2,642 6 (3)
Other(207)(352)(569)41 38 
Total Markets and securities services revenues, net
of interest expense
$20,778 $23,424 $18,055 (11)%30 %
Total revenues, net of interest expense$43,887 $45,088 $39,824 (3)%13 %
Commissions and fees$793 $677 $782 17 %(13)%
Principal transactions(3)
7,692 11,518 7,661 (33)50 
Other(2)
831 579 1,117 44 (48)
Total non-interest revenue$9,316 $12,774 $9,560 (27)%34 %
Net interest income4,404 4,814 3,514 (9)37 
Total fixed income markets(4)
$13,720 $17,588 $13,074 (22)%35 %
Rates and currencies$8,903 $12,162 $9,242 (27)%32 %
Spread products/other fixed income4,817 5,426 3,832 (11)42 
Total fixed income markets$13,720 $17,588 $13,074 (22)%35 %
Commissions and fees$1,231 $1,245 $1,121 (1)%11 %
Principal transactions(3)
1,986 1,281 775 55 65 
Other191 322 172 (41)87 
Total non-interest revenue$3,408 $2,848 $2,068 20 %38 %
Net interest income1,137 776 840 47 (8)
Total equity markets(4)
$4,545 $3,624 $2,908 25 %25 %

(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 $(131) million and $(74) million related to the corporate loan portfolio and $(13) million and $23 million related to the private bank for the years ended December 31, 2021 and 2020, respectively. All of gains (losses) on loan hedges are related to the corporate loan portfolio for the year ended December 31, 2019. 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 income 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
16


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.

2021 vs. 2020
Net income of $15.7 billion increased 36% versus the prior year, primarily driven by lower cost of credit, partially offset by higher expenses and lower revenues.
Revenues decreased 3%, reflecting lower Markets and securities services revenues, partially offset by higher Banking revenues. Banking revenues were up 7% (both including and excluding the impact of losses on loan hedges), driven by higher revenues in investment banking and the private bank, partially offset by lower revenues in treasury and trade solutions and corporate lending. Markets and securities services revenues were down 11%, primarily reflecting a normalization in fixed income markets revenues, partially offset by growth in equity markets and securities services.
Citi expects that revenues in its markets and investment banking businesses will continue to reflect the overall market environment during 2022.

Within Banking:

Investment banking revenues were up 30%, reflecting growth in the overall market wallet. Advisory revenues increased 78%, reflecting strength in North America and EMEA, driven by growth in the market wallet as well as wallet share gains. Equity underwriting revenues increased 53%, reflecting strength in North America and EMEA, driven by growth in the market wallet, as well as wallet share gains. Debt underwriting revenues increased 3%, reflecting strength in EMEA, as growth in the market wallet was partially offset by a decline in wallet share.
Treasury and trade solutions revenues decreased 4% (both including and excluding the impact of FX translation), reflecting a decline in revenues in the cash business, partially offset by an increase in trade revenues. Cash revenues decreased, driven by the ongoing impact of lower deposit spreads. The decrease was partially offset by strong growth in fee revenues reflecting solid client engagement and growth in transaction volumes, including growth in USD clearing, commercial cards and cross-border solutions. The increase in trade revenues was driven by improved trade spreads and growth in loans, reflecting an increase in trade flows and originations, primarily in Asiaand EMEA. Average trade loans increased 5% (both including and excluding the impact of FX translation).
Corporate lending revenues decreased 3%, including the impact of losses on loan hedges. Excluding the impact of losses on loan hedges, revenues decreased 1%, as lower cost of funds was more than offset by lower loan volumes, reflecting muted demand given strong client liquidity positions. Average loans decreased 20% during the current year.
Private bank revenues increased 5%. Excluding the impact of gains (losses) on loan hedges, revenues increased 6%, driven by strong performance in North America and EMEA. The higher revenues reflected continued momentum with new and existing clients,
resulting in higher loan volumes and spreads, higher managed investments revenues and higher deposit volumes. The increase in revenues was partially offset by lower deposit spreads due to the ongoing low interest rate environment and lower capital markets revenue.

Within Markets and securities services:

Fixed income markets revenues decreased 22%, reflecting lower revenues across all regions, largely driven by a comparison to a strong prior year, as well as a normalization in market activity, particularly in rates and currencies, and spread products. Non-interest revenues decreased, reflecting lower investor client activity across rates and currencies and spread products. Net interest income also decreased, largely reflecting a change in the mix of trading positions.
Rates and currencies revenues decreased 27%, driven by the normalization in market activity, and a comparison to a strong prior year that included elevated levels of volatility related to the pandemic. Spread products and other fixed income revenues decreased 11%, driven by a comparison to a strong prior year and the normalization in market activity, particularly in flow trading and structured products, reflecting lower volatility and spreads, partially offset by strong securitization activity.
Equity markets revenues increased 25%, driven by growth across all products. Equity derivatives revenues increased reflecting higher client activity, particularly in EMEA and North America. Prime finance revenues increased due to favorable market conditions as well as growth in client balances. Cash equities revenues increased modestly, reflecting higher client activity. Non-interest revenues increased, primarily due to higher principal transactions revenues, reflecting higher client activity.
Securities services revenues increased 6%. Excluding the impact of FX translation, revenues increased 7%, as an increase in fee revenues with both new and existing clients, driven by growth in assets under custody and settlement volumes, was partially offset by lower deposit spreads.

Expenses were up 8%, primarily driven by continued investments in Citi’s transformation, business-led investments and higher incentive compensation, as well as transactional related expenses, partially offset by productivity savings.
Provisions reflected a benefit of $2.9 billion compared to costs of $5.6 billion in the prior year, driven by an ACL release and lower net credit losses.
Net credit losses declined to $396 million from $987 million in the prior year, driven by improvements in portfolio credit quality.
The ACL release was $3.3 billion compared to a build of $4.6 billion in the prior year. The release was primarily driven by improvements in portfolio credit quality as well as Citi’s improved macroeconomic outlook. For additional information
17


on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on trends in ICG’s deposits and loans, see “Managing Global Risk—Liquidity Risk—Loans” and “—Deposits” below.
For additional information on ICG’scorporate 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 “Managing Global Risk—Other Risks—Country Risk—Argentina” and “Risk Factors” below.



18














































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19


GLOBAL CONSUMER BANKING

As of December 31, 2021, Global Consumer Banking (GCB) consisted of consumer banking businesses in North America, Latin America (consisting of Citi’s consumer banking business in Mexico) and Asia. GCB provided traditional banking services to retail customers through retail banking, branded cards and, in the U.S., retail services (for information on consumer market exits related to Latin America GCB and Asia GCB as well as Citi’s planned revision to its reporting structure, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above).
GCB’s markets in the U.S., Mexico and Asia had a combined 2,154 branches in 19 countries and jurisdictions as of December 31, 2021. At December 31, 2021, GCB had $267 billion in loans and $362 billion in retail banking deposits (excluding approximately $10 billion of loans and $8 billion of deposits reclassified to held-for-sale as a result of Citi’s agreements to sell its consumer banking businesses in Australia and the Philippines).

In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$24,238 $26,551 $28,455 (9)%(7)%
Non-interest revenue3,092 3,791 4,766 (18)(20)
Total revenues, net of interest expense$27,330 $30,342 $33,221 (10)%(9)%
Total operating expenses$20,035 $17,834 $18,039 12 %(1)%
Net credit losses on loans$4,582 $6,646 $7,382 (31)%(10)%
Credit reserve build (release) for loans(5,174)4,951 439 NMNM
Provision for credit losses on unfunded lending commitments —  100 
Provisions for benefits and claims, and other assets96 105 73 (9)44 
Provisions for credit losses and for benefits and claims (PBC)$(496)$11,702 $7,895 NM48 %
Income from continuing operations before taxes$7,791 $806 $7,287 NM(89)%
Income taxes1,745 143 1,708 NM(92)
Income from continuing operations$6,046 $663 $5,579 NM(88)%
Noncontrolling interests(11)(4)NMNM
Net income$6,057 $667 $5,573 NM(88)%
Balance Sheet data and ratios
EOP assets (in billions of dollars)
$432 $434 $407  %%
Average assets (in billions of dollars)
440 426 389 3 10 
Return on average assets1.38 %0.16 %1.43 %
Efficiency ratio73 59 54 
Average retail banking deposits (in billions of dollars)
$352 $311 $277 13 12 
Net credit losses as a percentage of average loans1.72 %2.39 %2.60 %
Revenue by business
Retail banking$10,776 $11,996 $12,758 (10)%(6)%
Cards(1)
16,554 18,346 20,463 (10)(10)
Total$27,330 $30,342 $33,221 (10)%(9)%
Income from continuing operations by business
Retail banking$(830)$557 $1,741 NM(68)%
Cards(1)
6,876 106 3,838 NM(97)
Total$6,046 $663 $5,579 NM(88)%

Table continues on the next page, including footnotes.
20


Foreign currency (FX) translation impact
Total revenue—as reported$27,330 $30,342 $33,221 (10)%(9)%
Impact of FX translation(2)
 323 (157)
Total revenues—ex-FX(3)
$27,330 $30,665 $33,064 (11)%(7)%
Total operating expenses—as reported$20,035 $17,834 $18,039 12 %(1)%
Impact of FX translation(2)
 212 (80)
Total operating expenses—ex-FX(3)
$20,035 $18,046 $17,959 11 %— %
Total provisions for credit losses and PBC—as reported$(496)$11,702 $7,895 NM48 %
Impact of FX translation(2)
 87 (51)
Total provisions for credit losses and PBC—ex-FX(3)
$(496)$11,789 $7,844 NM50 %
Net income—as reported$6,057 $667 $5,573 NM(88)%
Impact of FX translation(2)
 12 (11)
Net income—ex-FX(3)
$6,057 $679 $5,562 NM(88)%

(1)Includes both branded cards and retail services.
(2)Reflects the impact of FX translation into U.S. dollars at the 2021 average exchange rates for all periods presented.
(3)Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM Not meaningful




21


NORTH AMERICA GCB

As of December 31, 2021, North America GCB provided traditional retail banking and branded and retail services card products to retail and small business customers in the U.S. North America GCB’s U.S. cards product portfolio included its proprietary portfolio (Double Cash, Custom Cash, ThankYou and Value cards) and co-branded cards (including, among others, American Airlines and Costco) within branded cards, as well as its co-brand and private label relationships (including, among others, The Home Depot, Sears, Best Buy and Macy’s) within retail services. For information on Citi’s planned revision to its reporting structure, including the reporting of North America GCB’s consumer banking businesses as part of a new reporting segment, Personal Banking and Wealth Management, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
At December 31, 2021, North America GCB had 658 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, 2021, North America GCB had $48.1 billion in retail banking loans and $219.3 billion in retail banking deposits. In addition, North America GCB had $133.9 billion in outstanding card loan balances.

In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$17,393 $18,938 $19,931 (8)%(5)%
Non-interest revenue88 346 529 (75)(35)
Total revenues, net of interest expense$17,481 $19,284 $20,460 (9)%(6)%
Total operating expenses$10,832 $10,237 $10,305 6 %(1)%
Net credit losses on loans$2,937 $4,990 $5,583 (41)%(11)%
Credit reserve build for loans(3,974)4,115 469 NMNM
Provision for credit losses on unfunded lending commitments —  100 
Provisions for benefits and claims, and other assets19 17 19 12 (11)
Provisions for credit losses and for benefits and claims$(1,018)$9,122 $6,072 NM50 %
Income from continuing operations before taxes$7,667 $(75)$4,083 NMNM
Income taxes1,733 (29)926 NMNM
Income from continuing operations$5,934 $(46)$3,157 NMNM
Noncontrolling interests — —  %— %
Net income$5,934 $(46)$3,157 NMNM
Balance Sheet data and ratios  
Average assets (in billions of dollars)
$266 $266 $232  %15 %
Return on average assets2.23 %(0.02)%1.36 %
Efficiency ratio62 53 50 
Average retail banking deposits (in billions of dollars)
$206 $176 $153 17 15 
Net credit losses as a percentage of average loans1.69 %2.72 %2.97 %
Revenue by business  
Retail banking$4,211 $4,519 $4,558 (7)%(1)%
Branded cards8,189 8,800 9,184 (7)(4)
Retail services5,081 5,965 6,718 (15)(11)
Total$17,481 $19,284 $20,460 (9)%(6)%
Income (loss) from continuing operations by business  
Retail banking$(453)$(232)$145 (95)%NM
Branded cards3,903 12 1,734 NM(99)%
Retail services2,484 174 1,278 NM(86)
Total$5,934 $(46)$3,157 NMNM

NM Not meaningful




22


2021 vs. 2020
Net income was $5.9 billion, compared to a net loss of $46 million in the prior year, reflecting significantly lower cost of credit, partially offset by lower revenues and higher expenses.
Revenues decreased 9%, reflecting lower revenues in retail banking, branded cards and retail services.
Retail banking revenues decreased 7%, as the benefit of strong deposit growth and growth in assets under management (increase of 8%, reflecting favorable market conditions and strong client engagement) was more than offset by lower deposit spreads, as well as lower mortgage revenues. Average deposits increased 17%, driven by higher levels of consumer liquidity due to government stimulus, as well as continued strategic efforts to drive organic growth.
Cards revenues decreased 10%. Branded cards revenues decreased 7%, primarily driven by continued higher payment rates, reflecting increased customer liquidity from government stimulus and relief programs, partially offset by higher spending-related revenues. Credit card spend volume increased 21%, reflecting a continued recovery in sales activity from the pandemic-driven low levels in the prior year.
Retail services revenues decreased 15%, primarily driven by lower average loans (down 7%), reflecting higher payment rates from the increased customer liquidity from government stimulus and relief programs, as well as higher partner payments, reflecting higher income sharing as a result of lower net credit losses. For additional information on partner payments, see Note 5 to the Consolidated Financial Statements. Credit card spend volume increased 18%, reflecting a continued recovery in sales activity from the pandemic-driven low levels in the prior year.
Expenses increased 6%, primarily driven by continued investments in Citi’s transformation, as well as business-led investments and higher volume-related expenses, partially offset by productivity savings.
Provisions reflected a benefit of $1.0 billion, compared to costs of $9.1 billion in the prior year, primarily driven by a net ACL release compared to a net ACL build in the prior year, as well as lower net credit losses. Net credit losses decreased 41%, consisting of lower net credit losses in both branded cards (down 39% to $1.7 billion) and retail services (down 46% to $1.2 billion), primarily driven by lower loan volumes and improved delinquencies, primarily as a result of the higher payment rates.
The net ACL release was $4.0 billion, compared to a net build of $4.1 billion in the prior year, reflecting improvement in portfolio credit quality and the continued improvement in the macroeconomic outlook. For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on North America GCB’s retail banking, and its branded cards and 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 “Executive Summary” above and “Risk Factors—Strategic Risks” below.





23


LATIN AMERICA GCB

As of December 31, 2021, Latin America GCB provided traditional retail banking and branded card products to consumer and small business customers in Mexico through Citibanamex.
As discussed above, Citi intends to exit its consumer, small business and middle-market banking operations in Mexico. For additional information, see Citi’s Current Report on Form 8-K filed with the SEC on January 11, 2022. For information on Citi’s planned revision to its reporting structure, including the reporting of the Mexico consumer, small business and middle-market banking operations as part of a new reporting segment, Legacy Franchises, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
At December 31, 2021, Latin America GCB had 1,276 retail branches in Mexico, with $8.6 billion in retail banking loans and $24.8 billion in deposits. In addition, the business had $4.7 billion in outstanding card loan balances.

In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$2,874 $3,172 $3,735 (9)%(15)%
Non-interest revenue1,376 1,294 1,599 6 (19)
Total revenues, net of interest expense$4,250 $4,466 $5,334 (5)%(16)%
Total operating expenses$2,949 $2,871 $3,001 3 %(4)%
Net credit losses on loans$920 $866 $1,109 6 %(22)%
Credit reserve build (release) for loans(825)316 (38)NMNM
Provision for credit losses on unfunded lending commitments — —  — 
Provisions for benefits and claims, and other assets80 87 54 (8)61 
Provisions for credit losses and for benefits and claims (PBC)$175 $1,269 $1,125 (86)%13 %
Income from continuing operations before taxes$1,126 $326 $1,208 NM(73)%
Income taxes328 85 323 NM(74)
Income from continuing operations$798 $241 $885 NM(73)%
Noncontrolling interests — —  %— 
Net income$798 $241 $885 NM(73)%
Balance Sheet data and ratios  
Average assets (in billions of dollars)
$35 $32 $35 9 %(9)%
Return on average assets2.28 %0.75 %2.53 %
Efficiency ratio69 64 56 
Average deposits (in billions of dollars)
$24 $23 $23 4 — 
Net credit losses as a percentage of average loans6.87 %5.97 %6.45 %
Revenue by business
Retail banking$3,119 $3,103 $3,681 1 %(16)%
Branded cards1,131 1,363 1,653 (17)(18)
Total$4,250 $4,466 $5,334 (5)%(16)%
Income from continuing operations by business  
Retail banking$435 $120 $586 NM(80)%
Branded cards363 121 299 NM(60)
Total$798 $241 $885 NM(73)%
FX translation impact  
Total revenues—as reported$4,250 $4,466 $5,334 (5)%(16)%
Impact of FX translation(1)
 211 (246)
Total revenues—ex-FX(2)
$4,250 $4,677 $5,088 (9)%(8)%
Total operating expenses—as reported$2,949 $2,871 $3,001 3 %(4)%
Impact of FX translation(1)
 129 (132)
Total operating expenses—ex-FX(2)
$2,949 $3,000 $2,869 (2)%%
Provisions for credit losses and PBC—as reported$175 $1,269 $1,125 (86)%13 %
Impact of FX translation(1)
 66 (58)
Provisions for credit losses and PBC—ex-FX(2)
$175 $1,335 $1,067 (87)%25 %
Net income—as reported$798 $241 $885 NM(73)%
Impact of FX translation(1)
 (37)
Net income—ex-FX(2)
$798 $250 $848 NM(71)%

(1)Reflects the impact of FX translation into U.S. dollars at the 2021 average exchange rates for all periods presented.
24


(2)Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM Not meaningful

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

2019
2021 vs. 20182020
Net income increased 12%, primarily driven by higher revenues,was $798 million, compared to $250 million in the prior year, reflecting significantly lower cost of credit and modestly lower expenses, partially offset by modestly higher cost of credit.lower revenues.
Revenues increaseddecreased 9%, reflecting lower cards and retail banking revenues, largely due to the continued impact of the pandemic.
Retail banking revenues decreased 4%, primarily driven by lower loan volumes and deposit spreads, partially offset by growth in retail banking.assets under management. Average loans decreased 13%, reflecting the impact of the pandemic on customer activity. Assets under management increased 8%, reflecting favorable market conditions, as well as strong client engagement.
Retail bankingCards revenues increased 5%decreased 21%, primarily driven by higher investment revenues due to improved market sentiment and higher deposit revenues. Investment sales increased 8%, assets under management grew 17%, including the benefit of market movements, average deposits increased 6% andlower average loans (down 11%), reflecting higher payment rates. Credit card spend volume increased 5%. Retail lending revenues declined 1%16%, reflecting a continued recovery in sales activity from the pandemic-driven low levels in the prior year.
Expenses decreased 2%, as continued growth in personal loans wasproductivity savings more than offset by lower mortgage revenues due to spread compression.
Cards revenues increased 1%, including a modest episodic gaincontinued investments in the current year, as continued growth in average loans (up 3%) and purchase sales (up 6%) was largely offset by spread compression.
Expenses were largely unchanged, as efficiency savings were offset by ongoing investment spending and volume-driven growth.Citi’s transformation.
Provisions increased 4%of $174 million decreased 87%, asprimarily driven by a net ACL release compared to a net ACL build in the prior year, partially offset by higher net credit losses reflecting volume growth and seasoning were partially offset byresulting from pandemic-related charge-offs.
The net ACL release was $826 million, compared to a lower net loan loss reserve build of $329 million in the currentprior year. OverallThe release reflected an improvement in portfolio credit quality, remained stableas well as continued improvement in the region.macroeconomic outlook and lower loan volumes. For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on AsiaLatin America GCB’s retail banking portfolios and its Citi-brandedbranded cards portfolio,portfolios, see “Credit Risk—Consumer Credit” below.
For additional information on the impact of Citi’s January 1, 2020 adoption of the new accounting standard on credit losses (CECL),about trends, uncertainties and risks related to Latin America GCB’s future results, see “Executive Summary” above and “Risk Factors—OperationalStrategic Risks” below and Note 1 to the Consolidated Financial Statements.below.











25


INSTITUTIONAL CLIENTS GROUP
As of December 31, 2021, Institutional Clients Group (ICG) includesincluded Banking and Markets and securities services (for additional information on these businesses, see “Citigroup Segments” above). ICG providesprovided 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 transactstransacted with clients in both cash instruments and derivatives, including fixed income, foreign currency, equity and commodity products.
For information on Citi’s planned revision to its reporting structure, including the reporting of the private bank as part of a new reporting segment, Personal Banking and Wealth Management, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
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 revenueincome.
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 market liquidity may increase bid/offer spreads, decrease client activity levels and widen credit spreads on product inventory positions.
ICG’s management of the Markets businesses involves daily monitoring and evaluation of the above factors at the trading desk as well as the country level. ICG does not separately track the impact on total Markets revenues of the volume of transactions, bid/offer spreads, fair value changes of product inventory positions and economic hedges because, as noted above, these components are interrelated and are not deemed useful or necessary individually to manage the Markets businesses at an aggregatelevel.
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 9895 countries and jurisdictions. At December 31, 2019,2021, ICG had approximately $1.4$1.8 trillion in assets and $768$950 billion in deposits, while two of its businesses—securitiesdeposits. Securities services and issuer services—services managed approximately $20.3 trillion and $17.5$24.0 trillion in assets under custody as ofand administration at December 31, 20192021, of which Citi provides both custody and 2018, respectively.administrative services to certain clients related to $1.9 trillion of such assets. Managed assets under trust were $3.8 trillion at December 31, 2021. For additional information on these operations, see “Administration and Other Fiduciary Fees” in Note 5 to the Consolidated Financial Statements.

14


In millions of dollars, except as otherwise noted201920182017% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Commissions and fees$4,462
$4,651
$4,456
(4)%4 %Commissions and fees$4,750 $4,412 $4,462 8 %(1)%
Administration and other fiduciary fees2,756
2,806
2,721
(2)3
Administration and other fiduciary fees3,351 2,877 2,756 16 
Investment banking4,440
4,358
4,666
2
(7)Investment banking6,741 5,009 4,440 35 13 
Principal transactions8,562
8,742
7,527
(2)16
Principal transactions10,064 13,308 8,562 (24)55 
Other(1)
1,829
941
1,711
94
(45)
Other(1)
1,384 1,149 1,829 20 (37)
Total non-interest revenue$22,049
$21,498
$21,081
3 %2 %Total non-interest revenue$26,290 $26,755 $22,049 (2)%21 %
Net interest revenue (including dividends)17,252
16,827
16,741
3
1
Net interest income (including dividends)Net interest income (including dividends)17,597 18,333 17,775 (4)
Total revenues, net of interest expense$39,301
$38,325
$37,822
3 %1 %Total revenues, net of interest expense$43,887 $45,088 $39,824 (3)%13 %
Total operating expenses$22,224
$21,780
$21,187
2 %3 %
Net credit losses$394
$208
$465
89 %(55)%
Credit reserve build (release)71
(109)(285)NM
62
Provision (release) for unfunded lending commitments98
116
(161)(16)NM
Total operating expenses(2)
Total operating expenses(2)
$26,513 $24,617 $22,961 8 %%
Net credit losses on loansNet credit losses on loans$396 $987 $394 (60)%NM
Credit reserve build (release) for loansCredit reserve build (release) for loans(2,533)3,172 71 NMNM
Provision for credit losses on unfunded lending commitmentsProvision for credit losses on unfunded lending commitments(777)1,435 98 NMNM
Provisions for credit losses on HTM debt securities and other assetsProvisions for credit losses on HTM debt securities and other assets1 21 — (95)100 %
Provisions for credit losses$563
$215
$19
NM
NM
Provisions for credit losses$(2,913)$5,615 $563 NMNM
Income from continuing operations before taxes$16,514
$16,330
$16,616
1 %(2)%Income from continuing operations before taxes$20,287 $14,856 $16,300 37 %(9)%
Income taxes3,570
3,756
7,241
(5)(48)Income taxes4,524 3,303 3,524 37 (6)
Income from continuing operations$12,944
$12,574
$9,375
3 %34 %Income from continuing operations$15,763 $11,553 $12,776 36 %(10)%
Noncontrolling interests40
17
57
NM
(70)Noncontrolling interests83 50 40 66 25 
Net income$12,904
$12,557
$9,318
3 %35 %Net income$15,680 $11,503 $12,736 36 %(10)%
Balance Sheet data and ratiosBalance Sheet data and ratios
EOP assets (in billions of dollars)
$1,447
$1,438
$1,375
1 %5 %
EOP assets (in billions of dollars)
$1,762 $1,730 $1,447 2 %20 %
Average assets (in billions of dollars)
1,493
1,449
1,395
3
4
Average assets (in billions of dollars)
1,812 1,706 1,493 6 14 
Return on average assets0.86%0.87%0.67% Return on average assets0.87 %0.67 %0.85 %
Efficiency ratio57
57
56
 Efficiency ratio60 55 58 
Revenues by region  Revenues by region
North America$13,459
$13,522
$14,578
 %(7)%North America$16,748 $17,476 $13,603 (4)%28 %
EMEA12,006
11,770
10,878
2
8
EMEA13,094 13,041 12,157  
Latin America5,166
4,954
4,814
4
3
Latin America4,946 4,981 5,275 (1)(6)
Asia8,670
8,079
7,552
7
7
Asia9,099 9,590 8,789 (5)
Total$39,301
$38,325
$37,822
3 %1 %Total$43,887 $45,088 $39,824 (3)%13 %
Income from continuing operations by region  
  Income from continuing operations by region 
North America$3,511
$3,675
$2,494
(4)%47 %North America$5,781 $3,310 $3,407 75 %(3)%
EMEA3,867
3,889
2,828
(1)38
EMEA4,347 3,280 3,836 33 (14)
Latin America2,111
2,013
1,637
5
23
Latin America2,429 1,390 2,101 75 (34)
Asia3,455
2,997
2,416
15
24
Asia3,206 3,573 3,432 (10)
Total$12,944
$12,574
$9,375
3 %34 %Total$15,763 $11,553 $12,776 36 %(10)%
Average loans by region (in billions of dollars)
  
  
Average loans by region (in billions of dollars)
 
North America$188
$174
$159
8 %9 %North America$202 $201 $188  %%
EMEA87
81
69
7
17
EMEA89 88 87 1 
Latin America40
42
42
(5)
Latin America32 39 40 (18)(3)
Asia73
77
72
(5)7
Asia73 71 73 3 (3)
Total$388
$374
$342
4 %9 %Total$396 $399 $388 (1)%%
EOP deposits by business (in billions of dollars)
  
EOP deposits by business (in billions of dollars)
Treasury and trade solutions$536
$509
$469
5 %9 %Treasury and trade solutions$636 $651 $536 (2)%21 %
All other ICG businesses
232
218
208
6
5
All other ICG businesses
314 273 232 15 18 
Total$768
$727
$677
6 %7 %Total$950 $924 $768 3 %20 %

(1)2019 includes an approximate $350 million gain on Citi's investment in Tradeweb in the second quarter. 2017 includes the approximate $580 million gain on the sale of a fixed income analytics business.
(1)    2019 includes an approximate $350 million gain on Citi’s investment in Tradeweb.
(2)    2020 includes an approximate $390 million operational loss related to certain legal matters.
NM Not meaningful


15



ICG Revenue Details

In millions of dollars201920182017% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
In millions of dollars202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Investment banking revenue details
  
Investment banking revenue details
Advisory$1,259
$1,301
$1,123
(3)%16 %Advisory$1,796 $1,010 $1,259 78 %(20)%
Equity underwriting973
991
1,121
(2)(12)Equity underwriting2,434 1,593 973 53 64 
Debt underwriting2,984
2,719
3,126
10
(13)Debt underwriting3,283 3,184 2,984 3 
Total investment banking$5,216
$5,011
$5,370
4 %(7)%Total investment banking$7,513 $5,787 $5,216 30 %11 %
Treasury and trade solutions10,293
9,914
9,279
4
7
Treasury and trade solutions9,444 9,824 10,513 (4)(7)
Corporate lending—excluding gains (losses) on loan hedges(1)
2,921
2,913
2,623

11
Corporate lending—excluding gains (losses) on loan hedges(1)
2,291 2,310 2,985 (1)(23)
Private bank3,458
3,398
3,108
2
9
Total Banking revenues (ex-gains (losses) on
loan hedges)
$21,888
$21,236
$20,380
3 %4 %
Corporate lending—gains (losses) on loan hedges(1)
$(432)$45
$(133)NM
NM
Private bank—excluding gains (losses) on loan hedges(1)
Private bank—excluding gains (losses) on loan hedges(1)
4,005 3,794 3,487 6 
Total Banking revenues (ex-gains (losses) on loan hedges)(1)
Total Banking revenues (ex-gains (losses) on loan hedges)(1)
$23,253 $21,715 $22,201 7 %(2)%
Losses on loan hedges(1)
Losses on loan hedges(1)
$(144)$(51)$(432)NM88 %
Total Banking revenues (including gains (losses) on loan hedges), net of interest expense
$21,456
$21,281
$20,247
1 %5 %
Total Banking revenues (including gains (losses) on loan hedges), net of interest expense
$23,109 $21,664 $21,769 7 %— %
Fixed income markets(2)
$12,884
$11,661
$12,369
10 %(6)%
Fixed income markets(2)
$13,720 $17,588 $13,074 (22)%35 %
Equity markets2,908
3,427
2,879
(15)19
Equity markets4,545 3,624 2,908 25 25 
Securities services2,631
2,631
2,366

11
Securities services2,720 2,562 2,642 6 (3)
Other(3)
(578)(675)(39)14
NM
OtherOther(207)(352)(569)41 38 
Total Markets and securities services revenues, net
of interest expense
$17,845
$17,044
$17,575
5 %(3)%
Total Markets and securities services revenues, net
of interest expense
$20,778 $23,424 $18,055 (11)%30 %
Total revenues, net of interest expense$39,301
$38,325
$37,822
3 %1 %Total revenues, net of interest expense$43,887 $45,088 $39,824 (3)%13 %
Commissions and fees$782
$705
$628
11 %12 %Commissions and fees$793 $677 $782 17 %(13)%
Principal transactions(4)
7,661
7,134
7,001
7
2
Principal transactions(3)
Principal transactions(3)
7,692 11,518 7,661 (33)50 
Other(2)
1,117
380
619
NM
(39)
Other(2)
831 579 1,117 44 (48)
Total non-interest revenue$9,560
$8,219
$8,248
16 % %Total non-interest revenue$9,316 $12,774 $9,560 (27)%34 %
Net interest revenue3,324
3,442
4,121
(3)(16)
Total fixed income markets(5)
$12,884
$11,661
$12,369
10 %(6)%
Net interest incomeNet interest income4,404 4,814 3,514 (9)37 
Total fixed income markets(4)
Total fixed income markets(4)
$13,720 $17,588 $13,074 (22)%35 %
Rates and currencies$9,225
$8,486
$8,901
9 %(5)%Rates and currencies$8,903 $12,162 $9,242 (27)%32 %
Spread products/other fixed income3,659
3,175
3,468
15
(8)Spread products/other fixed income4,817 5,426 3,832 (11)42 
Total fixed income markets$12,884
$11,661
$12,369
10 %(6)%Total fixed income markets$13,720 $17,588 $13,074 (22)%35 %
Commissions and fees$1,121
$1,267
$1,282
(12)%(1)%Commissions and fees$1,231 $1,245 $1,121 (1)%11 %
Principal transactions(4)
775
1,240
494
(38)NM
Principal transactions(3)
Principal transactions(3)
1,986 1,281 775 55 65 
Other172
110
(21)56
NM
Other191 322 172 (41)87 
Total non-interest revenue$2,068
$2,617
$1,755
(21)%49 %Total non-interest revenue$3,408 $2,848 $2,068 20 %38 %
Net interest revenue840
810
1,124
4
(28)
Total equity markets(5)
$2,908
$3,427
$2,879
(15)%19 %
Net interest incomeNet interest income1,137 776 840 47 (8)
Total equity markets(4)
Total equity markets(4)
$4,545 $3,624 $2,908 25 %25 %

(1)
(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 corporate lending revenues to reflect the cost of credit protection. Citigroup’s results of operations excluding the impact of gains (losses) on loan hedges are non-GAAP financial measures.
(2)2019 includes an approximate $350 million gain on Citi's investment in Tradeweb in the second quarter.
(3)2017 includes the approximate $580 million gain on the sale of a fixed 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 $(131) million and $(74) million related to the corporate loan portfolio and $(13) million and $23 million related to the private bank for the years ended December 31, 2021 and 2020, respectively. All of gains (losses) on loan hedges are related to the corporate loan portfolio for the year ended December 31, 2019. 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 income analytics business.
(4)
Excludes principal transactions revenues of ICG businesses other than Markets, primarily treasury and trade solutions and the private bank.
(5)
Citi assesses its Markets business performance on a total revenue basis, as offsets may occur across revenue line items. For example, securities that generate Net interest revenue may be risk managed by derivatives that are recorded in Principal transactions revenue. For a description of the composition of these revenue line items, see Notes 4, 5 and 6 to the Consolidated Financial Statements.
NM Not meaningful

16



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.


20192021 vs. 20182020
Net income of $15.7 billion increased 3%,36% versus the prior year, primarily driven primarily by higher revenues and a lower effective tax rate,cost of credit, partially offset by higher expenses and higher cost of credit.lower revenues.
Revenues increaseddecreased 3%, reflecting higher Banking revenues (increase of 1% including the gains (losses) on loan hedges) and higherlower Markets and securities services revenues, (increase of 5%). Excluding the impact of the gains (losses) on loan hedges,partially offset by higher Banking revenues. Banking revenues were up 3%7% (both including and excluding the impact of losses on loan hedges), driven by higher revenues in treasury and trade solutions, investment banking and the private bank, aspartially offset by lower revenues in treasury and trade solutions and corporate lending was largely unchanged.lending. Markets and securities servicesrevenues were up 5%down 11%, includingprimarily reflecting a gain in the second quarter of 2019 from Citi’s investment in Tradeweb, as higher revenuesnormalization in fixed income markets revenues, partially offset by growth in equity markets and securities services.
Citi expects that revenues in its markets and investment banking businesses will continue to reflect the overall market environment during 2022.

Within Banking:

Investment banking revenues were up 30%, reflecting growth in the overall market wallet. Advisory revenues increased 78%, reflecting strength in North America and EMEA, driven by growth in the market wallet as well as wallet share gains. Equity underwriting revenues increased 53%, reflecting strength in North America and EMEA, driven by growth in the market wallet, as well as wallet share gains. Debt underwriting revenues increased 3%, reflecting strength in EMEA, as growth in the market wallet was partially offset by a decline in wallet share.
Treasury and trade solutions revenues decreased 4% (both including and excluding the impact of FX translation), reflecting a decline in revenues in the cash business, partially offset by an increase in trade revenues. Cash revenues decreased, driven by the ongoing impact of lower deposit spreads. The decrease was partially offset by strong growth in fee revenues reflecting solid client engagement and growth in transaction volumes, including growth in USD clearing, commercial cards and cross-border solutions. The increase in trade revenues was driven by improved trade spreads and growth in loans, reflecting an increase in trade flows and originations, primarily in Asia and EMEA. Average trade loans increased 5% (both including and excluding the impact of FX translation).
Corporate lending revenues decreased 3%, including the impact of losses on loan hedges. Excluding the impact of losses on loan hedges, revenues decreased 1%, as lower cost of funds was more than offset by lower loan volumes, reflecting muted demand given strong client liquidity positions. Average loans decreased 20% during the current year.
Private bank revenues increased 5%. Excluding the impact of gains (losses) on loan hedges, revenues increased 6%, driven by strong performance in North America and EMEA. The higher revenues reflected continued momentum with new and existing clients,
resulting in higher loan volumes and spreads, higher managed investments revenues and higher deposit volumes. The increase in revenues was partially offset by lower equity markets revenues.
Citi expects that ICG’s revenues will likely be impacted bydeposit spreads due to the lowerongoing low interest rate environment in the near term.

and lower capital markets revenue.
Within
Banking:

Investment banking revenues increased 4%, reflecting gains in wallet share despite a decline in the overall market wallet. Debt underwriting increased 10%, reflecting gains in wallet share, primarily in investment grade underwriting, across North America, EMEA and Asia. Equity underwriting revenues decreased 2%, reflecting a decline in market wallet, particularly in Asia and EMEA,partially offset by gains in wallet share. Advisory revenues decreased 3%, largely due to a comparison to a strong prior year as well as a decline in market wallet, partially offset by gains in wallet share.
Treasury and trade solutions revenues increased 4%. Excluding the impact of FX translation, revenues increased 6%, reflecting strength in all regions, driven by growth across both net interest and fee income. Revenues increased in the cash business, primarily driven by strong client engagement and solid growth in deposit and transaction volumes, partially offset by spread compression in the second half of 2019 due to the impact of lower interest rates. Revenue growth in the trade business was driven by improved spreads, due to growth in structured loans as well as the ability to continue to utilize distribution capabilities to optimize the balance sheet and drive returns, while supporting clients. Average deposits increased 10%, reflecting growth across regions. Average trade loans declined 3%, driven by North America, EMEA and Asia (for additional information, see “Liquidity Risk—Loans” below).
Corporate lending revenues decreased 16%. Excluding the impact of gains (losses) on loan hedges, revenues were largely unchanged versus the prior year, as growth in the commercial loan portfolio was offset by lower
volumes in the rest of the portfolio.

Private bank revenues increased 2%, driven primarily by North America and Asia, partially offset by Latin America. The increase in revenues reflected strong client activity, driving higher lending and deposit volumes, as well as higher capital markets revenues, partially offset by lower deposit spreads.

Within Markets and securities services:

Fixed income markets revenues increased 10%, including the Tradeweb gain, reflecting higher revenues across all regions. Non-interest revenues increased due to higher corporate and investor client activity as well as improved market activity, particularly in rates and spread products. The increase in non-interest revenues was partially offset by a decline in net interest revenues, reflecting a change in the mix of trading positions in support of client activity as well as higher funding costs, given the higher interest rate environment in the first half of the year.
Fixed income markets revenues decreased 22%, reflecting lower revenues across all regions, largely driven by a comparison to a strong prior year, as well as a normalization in market activity, particularly in rates and currencies, and spread products. Non-interest revenues decreased, reflecting lower investor client activity across rates and currencies and spread products. Net interest income also decreased, largely reflecting a change in the mix of trading positions.
Rates and currencies revenues increased 9%decreased 27%, primarily driven by higher G10 ratesthe normalization in market activity, and currencies revenues in North America, Asia and EMEA, reflecting a more favorable operating environment incomparison to a strong prior year that included elevated levels of volatility related to the second half of 2019, with higher corporate and investor client activity. Local markets rates and currencies revenues increased modestly despite declining currency volatility.
pandemic. Spread products and other fixed income revenues decreased 11%, driven by a comparison to a strong prior year and the normalization in market activity, particularly in flow trading and structured products, reflecting lower volatility and spreads, partially offset by strong securitization activity.
Equity markets revenues increased 15%25%, including the Tradeweb gain,driven by growth across all products. Equity derivatives revenues increased reflecting higher revenuesclient activity, particularly in bothEMEA and North America. Prime finance revenues increased due to favorable market conditions as well as growth in client balances. Cash equities revenues increased modestly, reflecting higher client activity. Non-interest revenues increased, primarily due to higher principal transactions revenues, reflecting higher client activity.
Securities services revenues increased 6%. Excluding the impact of FX translation, revenues increased 7%, as an increase in fee revenues with both new and existing clients, driven by growth in assets under custody and settlement volumes, was partially offset by lower deposit spreads.

Expenses were up 8%, primarily driven by continued investments in Citi’s transformation, business-led investments and higher incentive compensation, as well as transactional related expenses, partially offset by productivity savings.
Provisions reflected a benefit of $2.9 billion compared to costs of $5.6 billion in the prior year, driven by an ACL release and lower net credit losses.
Net credit losses declined to $396 million from $987 million in the prior year, driven by improvements in portfolio credit quality.
The ACL release was $3.3 billion compared to a build of $4.6 billion in the prior year. The release was primarily driven by improvements in portfolio credit quality as well as Citi’s improved macroeconomic outlook. For additional information
17


on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on trends in ICG’s deposits and loans, see “Managing Global Risk—Liquidity Risk—Loans” and “—Deposits” below.
For additional information on ICG’scorporate 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 “Managing Global Risk—Other Risks—Country Risk—Argentina” and “Risk Factors” below.



18














































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19


GLOBAL CONSUMER BANKING

As of December 31, 2021, Global Consumer Banking (GCB) consisted of consumer banking businesses in North America, Latin America (consisting of Citi’s consumer banking business in Mexico) and Asia. GCB provided traditional banking services to retail customers through retail banking, branded cards and, in the U.S., retail services (for information on consumer market exits related to Latin America GCB and Asia GCB as well as Citi’s planned revision to its reporting structure, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above).
GCB’s markets in the U.S., Mexico and Asia had a combined 2,154 branches in 19 countries and jurisdictions as of December 31, 2021. At December 31, 2021, GCB had $267 billion in loans and $362 billion in retail banking deposits (excluding approximately $10 billion of loans and $8 billion of deposits reclassified to held-for-sale as a result of Citi’s agreements to sell its consumer banking businesses in Australia and the Philippines).

In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$24,238 $26,551 $28,455 (9)%(7)%
Non-interest revenue3,092 3,791 4,766 (18)(20)
Total revenues, net of interest expense$27,330 $30,342 $33,221 (10)%(9)%
Total operating expenses$20,035 $17,834 $18,039 12 %(1)%
Net credit losses on loans$4,582 $6,646 $7,382 (31)%(10)%
Credit reserve build (release) for loans(5,174)4,951 439 NMNM
Provision for credit losses on unfunded lending commitments —  100 
Provisions for benefits and claims, and other assets96 105 73 (9)44 
Provisions for credit losses and for benefits and claims (PBC)$(496)$11,702 $7,895 NM48 %
Income from continuing operations before taxes$7,791 $806 $7,287 NM(89)%
Income taxes1,745 143 1,708 NM(92)
Income from continuing operations$6,046 $663 $5,579 NM(88)%
Noncontrolling interests(11)(4)NMNM
Net income$6,057 $667 $5,573 NM(88)%
Balance Sheet data and ratios
EOP assets (in billions of dollars)
$432 $434 $407  %%
Average assets (in billions of dollars)
440 426 389 3 10 
Return on average assets1.38 %0.16 %1.43 %
Efficiency ratio73 59 54 
Average retail banking deposits (in billions of dollars)
$352 $311 $277 13 12 
Net credit losses as a percentage of average loans1.72 %2.39 %2.60 %
Revenue by business
Retail banking$10,776 $11,996 $12,758 (10)%(6)%
Cards(1)
16,554 18,346 20,463 (10)(10)
Total$27,330 $30,342 $33,221 (10)%(9)%
Income from continuing operations by business
Retail banking$(830)$557 $1,741 NM(68)%
Cards(1)
6,876 106 3,838 NM(97)
Total$6,046 $663 $5,579 NM(88)%

Table continues on the next page, including footnotes.
20


Foreign currency (FX) translation impact
Total revenue—as reported$27,330 $30,342 $33,221 (10)%(9)%
Impact of FX translation(2)
 323 (157)
Total revenues—ex-FX(3)
$27,330 $30,665 $33,064 (11)%(7)%
Total operating expenses—as reported$20,035 $17,834 $18,039 12 %(1)%
Impact of FX translation(2)
 212 (80)
Total operating expenses—ex-FX(3)
$20,035 $18,046 $17,959 11 %— %
Total provisions for credit losses and PBC—as reported$(496)$11,702 $7,895 NM48 %
Impact of FX translation(2)
 87 (51)
Total provisions for credit losses and PBC—ex-FX(3)
$(496)$11,789 $7,844 NM50 %
Net income—as reported$6,057 $667 $5,573 NM(88)%
Impact of FX translation(2)
 12 (11)
Net income—ex-FX(3)
$6,057 $679 $5,562 NM(88)%

(1)Includes both branded cards and retail services.
(2)Reflects the impact of FX translation into U.S. dollars at the 2021 average exchange rates for all periods presented.
(3)Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM Not meaningful




21


NORTH AMERICA GCB

As of December 31, 2021, North America GCB provided traditional retail banking and branded and retail services card products to retail and small business customers in the U.S. North America GCB’s U.S. cards product portfolio included its proprietary portfolio (Double Cash, Custom Cash, ThankYou and Value cards) and co-branded cards (including, among others, American Airlines and Costco) within branded cards, as well as its co-brand and private label relationships (including, among others, The Home Depot, Sears, Best Buy and Macy’s) within retail services. For information on Citi’s planned revision to its reporting structure, including the reporting of North America GCB’s consumer banking businesses as part of a new reporting segment, Personal Banking and Wealth Management, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
At December 31, 2021, North America GCB had 658 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, 2021, North America GCB had $48.1 billion in retail banking loans and $219.3 billion in retail banking deposits. In addition, North America GCB had $133.9 billion in outstanding card loan balances.

In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$17,393 $18,938 $19,931 (8)%(5)%
Non-interest revenue88 346 529 (75)(35)
Total revenues, net of interest expense$17,481 $19,284 $20,460 (9)%(6)%
Total operating expenses$10,832 $10,237 $10,305 6 %(1)%
Net credit losses on loans$2,937 $4,990 $5,583 (41)%(11)%
Credit reserve build for loans(3,974)4,115 469 NMNM
Provision for credit losses on unfunded lending commitments —  100 
Provisions for benefits and claims, and other assets19 17 19 12 (11)
Provisions for credit losses and for benefits and claims$(1,018)$9,122 $6,072 NM50 %
Income from continuing operations before taxes$7,667 $(75)$4,083 NMNM
Income taxes1,733 (29)926 NMNM
Income from continuing operations$5,934 $(46)$3,157 NMNM
Noncontrolling interests — —  %— %
Net income$5,934 $(46)$3,157 NMNM
Balance Sheet data and ratios  
Average assets (in billions of dollars)
$266 $266 $232  %15 %
Return on average assets2.23 %(0.02)%1.36 %
Efficiency ratio62 53 50 
Average retail banking deposits (in billions of dollars)
$206 $176 $153 17 15 
Net credit losses as a percentage of average loans1.69 %2.72 %2.97 %
Revenue by business  
Retail banking$4,211 $4,519 $4,558 (7)%(1)%
Branded cards8,189 8,800 9,184 (7)(4)
Retail services5,081 5,965 6,718 (15)(11)
Total$17,481 $19,284 $20,460 (9)%(6)%
Income (loss) from continuing operations by business  
Retail banking$(453)$(232)$145 (95)%NM
Branded cards3,903 12 1,734 NM(99)%
Retail services2,484 174 1,278 NM(86)
Total$5,934 $(46)$3,157 NMNM

NM Not meaningful




22


2021 vs. 2020
Net income was $5.9 billion, compared to a net loss of $46 million in the prior year, reflecting significantly lower cost of credit, partially offset by lower revenues and higher expenses.
Revenues decreased 9%, reflecting lower revenues in retail banking, branded cards and retail services.
Retail banking revenues decreased 7%, as the benefit of strong deposit growth and growth in assets under management (increase of 8%, reflecting favorable market conditions and strong client engagement) was more than offset by lower deposit spreads, as well as lower mortgage revenues. Average deposits increased 17%, driven by higher levels of consumer liquidity due to government stimulus, as well as continued strategic efforts to drive organic growth.
Cards revenues decreased 10%. Branded cards revenues decreased 7%, primarily driven by continued higher payment rates, reflecting increased customer liquidity from government stimulus and relief programs, partially offset by higher spending-related revenues. Credit card spend volume increased 21%, reflecting a continued recovery in sales activity from the pandemic-driven low levels in the prior year.
Retail services revenues decreased 15%, primarily driven by lower average loans (down 7%), reflecting higher payment rates from the increased customer liquidity from government stimulus and relief programs, as well as higher partner payments, reflecting higher income sharing as a result of lower net credit losses. For additional information on partner payments, see Note 5 to the Consolidated Financial Statements. Credit card spend volume increased 18%, reflecting a continued recovery in sales activity from the pandemic-driven low levels in the prior year.
Expenses increased 6%, primarily driven by continued investments in Citi’s transformation, as well as business-led investments and higher volume-related expenses, partially offset by productivity savings.
Provisions reflected a benefit of $1.0 billion, compared to costs of $9.1 billion in the prior year, primarily driven by a net ACL release compared to a net ACL build in the prior year, as well as lower net credit losses. Net credit losses decreased 41%, consisting of lower net credit losses in both branded cards (down 39% to $1.7 billion) and retail services (down 46% to $1.2 billion), primarily driven by lower loan volumes and improved delinquencies, primarily as a result of the higher payment rates.
The net ACL release was $4.0 billion, compared to a net build of $4.1 billion in the prior year, reflecting improvement in portfolio credit quality and the continued improvement in the macroeconomic outlook. For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on North America GCB’s retail banking, and its branded cards and 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 “Executive Summary” above and “Risk Factors—Strategic Risks” below.





23


LATIN AMERICA GCB

As of December 31, 2021, Latin America GCB provided traditional retail banking and branded card products to consumer and small business customers in Mexico through Citibanamex.
As discussed above, Citi intends to exit its consumer, small business and middle-market banking operations in Mexico. For additional information, see Citi’s Current Report on Form 8-K filed with the SEC on January 11, 2022. For information on Citi’s planned revision to its reporting structure, including the reporting of the Mexico consumer, small business and middle-market banking operations as part of a new reporting segment, Legacy Franchises, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
At December 31, 2021, Latin America GCB had 1,276 retail branches in Mexico, with $8.6 billion in retail banking loans and $24.8 billion in deposits. In addition, the business had $4.7 billion in outstanding card loan balances.

In millions of dollars, except as otherwise noted202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$2,874 $3,172 $3,735 (9)%(15)%
Non-interest revenue1,376 1,294 1,599 6 (19)
Total revenues, net of interest expense$4,250 $4,466 $5,334 (5)%(16)%
Total operating expenses$2,949 $2,871 $3,001 3 %(4)%
Net credit losses on loans$920 $866 $1,109 6 %(22)%
Credit reserve build (release) for loans(825)316 (38)NMNM
Provision for credit losses on unfunded lending commitments — —  — 
Provisions for benefits and claims, and other assets80 87 54 (8)61 
Provisions for credit losses and for benefits and claims (PBC)$175 $1,269 $1,125 (86)%13 %
Income from continuing operations before taxes$1,126 $326 $1,208 NM(73)%
Income taxes328 85 323 NM(74)
Income from continuing operations$798 $241 $885 NM(73)%
Noncontrolling interests — —  %— 
Net income$798 $241 $885 NM(73)%
Balance Sheet data and ratios  
Average assets (in billions of dollars)
$35 $32 $35 9 %(9)%
Return on average assets2.28 %0.75 %2.53 %
Efficiency ratio69 64 56 
Average deposits (in billions of dollars)
$24 $23 $23 4 — 
Net credit losses as a percentage of average loans6.87 %5.97 %6.45 %
Revenue by business
Retail banking$3,119 $3,103 $3,681 1 %(16)%
Branded cards1,131 1,363 1,653 (17)(18)
Total$4,250 $4,466 $5,334 (5)%(16)%
Income from continuing operations by business  
Retail banking$435 $120 $586 NM(80)%
Branded cards363 121 299 NM(60)
Total$798 $241 $885 NM(73)%
FX translation impact  
Total revenues—as reported$4,250 $4,466 $5,334 (5)%(16)%
Impact of FX translation(1)
 211 (246)
Total revenues—ex-FX(2)
$4,250 $4,677 $5,088 (9)%(8)%
Total operating expenses—as reported$2,949 $2,871 $3,001 3 %(4)%
Impact of FX translation(1)
 129 (132)
Total operating expenses—ex-FX(2)
$2,949 $3,000 $2,869 (2)%%
Provisions for credit losses and PBC—as reported$175 $1,269 $1,125 (86)%13 %
Impact of FX translation(1)
 66 (58)
Provisions for credit losses and PBC—ex-FX(2)
$175 $1,335 $1,067 (87)%25 %
Net income—as reported$798 $241 $885 NM(73)%
Impact of FX translation(1)
 (37)
Net income—ex-FX(2)
$798 $250 $848 NM(71)%

(1)Reflects the impact of FX translation into U.S. dollars at the 2021 average exchange rates for all periods presented.
24


(2)Presentation of this metric excluding FX translation is a non-GAAP financial measure.
NM Not meaningful

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.

2021 vs. 2020
Net income was $798 million, compared to $250 million in the prior year, reflecting significantly lower cost of credit and modestly lower expenses, partially offset by lower revenues.
Revenues decreased 9%, reflecting lower cards and retail banking revenues, largely due to the continued impact of the pandemic.
Retail banking revenues decreased 4%, primarily driven by lower loan volumes and deposit spreads, partially offset by growth in assets under management. Average loans decreased 13%, reflecting the impact of the pandemic on customer activity. Assets under management increased 8%, reflecting favorable market conditions, as well as strong client engagement.
Cards revenues decreased 21%, primarily driven by lower average loans (down 11%), reflecting higher payment rates. Credit card spend volume increased 16%, reflecting a continued recovery in sales activity from the pandemic-driven low levels in the prior year.
Expenses decreased 2%, as productivity savings more than offset continued investments in Citi’s transformation.
Provisions of $174 million decreased 87%, primarily driven by a net ACL release compared to a net ACL build in the prior year, partially offset by higher net credit losses resulting from pandemic-related charge-offs.
The net ACL release was $826 million, compared to a build of $329 million in the prior year. The release reflected an improvement in portfolio credit quality, as well as continued improvement in the macroeconomic outlook and lower loan volumes. For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on LatinAmerica GCB’s retail banking and its 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 “Executive Summary” above and “Risk Factors—Strategic Risks” below.

25


ASIA GCB

As of December 31, 2021, Asia GCB provided traditional retail banking and branded card products to retail and small business customers. Included within Asia GCB were traditional retail banking and branded card products provided to retail customers in certain EMEA countries, primarily the UAE, Poland and Russia.
As discussed above, Citi is pursuing exits of its consumer franchises in 13 markets across Asia and EMEA. The increase and will focus its consumer banking franchise in revenues was driven by higher client activity as well as an improved trading environment, particularlythe two regions on four wealth centers: Singapore, Hong Kong, the UAE and London. In 2021, Citi entered into agreements to sell its consumer banking businesses in flow tradingAustralia and financing products. This increase in revenues was partially offset by lower structured products revenues, reflectingthe Philippines, and made a challenging trading environment.
Equity markets revenues decreased 15%, driven by lower revenues across cash equities, equity derivatives and prime finance, particularly in North America and Asia. Cash equities revenues decreased largely due to lower client volumes. Despite strong corporate and investor client activity, equity derivatives revenues decreased due to the impact of a less favorable trading environment, given lower market volatility, as well as a comparison to a strong prior year. The decline in prime finance revenues was primarily driven by lower client activity and lower financing balances. Non-interest revenues decreased, primarily driven by lower principal transaction and commissions and fee revenues, due to lower client activity and a less favorable trading environment, as well as a change in the mix of trading positions in support of client activity.
Securities services revenues were largely unchanged versus the prior year. Excluding the impact of FX translation, revenues increased 4%, reflecting higher revenues in Asia and Latin America. The increase in revenues was driven by higher net interest revenue due to higher deposit volumes and higher interest rates,

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

Expenses increased 2%, as higher compensation, volume-related expensesdecision to wind down and continued investments were partially offset by efficiency savings and a benefit from FX translation.close its Korea consumer banking business (for additional information, see Note 2 to the Consolidated Financial Statements).
Provisions increased $348 million, driven by an increaseIn addition, in net credit losses of $186 million,January 2022, Citi entered into agreements to sell its consumer banking businesses in Indonesia, Malaysia, Taiwan, Thailand and an increase in the net loan loss reserve build of $162 million. Both the increase in net credit losses and the higher loan loss reserve build largely reflected a normalization of credit trends.
Vietnam. For information on Citi’s planned revision to its reporting structure, including the impactreporting of the 13 exit markets as part of a new reporting segment, Legacy Franchises, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.
At December 31, 2021, on a combined basis, the businesses had 220 retail branches, $58.9 billion in retail banking loans and $117.7 billion in deposits. In addition, the businesses had $13.1 billion in outstanding card loan balances. These amounts exclude approximately $10 billion of loans ($7 billion of retail banking loans and $3 billion of credit card loan balances) and $8 billion of deposits reclassified to held-for-sale (HFS) as a result of Citi’s January 1, 2020 adoption ofagreements to sell its consumer banking businesses in Australia and the new accounting standard on credit losses (CECL),Philippines. Australia and the Philippines are the only consumer businesses reclassified as HFS at December 31, 2021. For additional information, see “Risk Factors—Operational Risks” below and Note 12 to the Consolidated Financial Statements.


In millions of dollars, except as otherwise noted(1)
202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest income$3,971 $4,441 $4,789 (11)%(7)%
Non-interest revenue1,628 2,151 2,638 (24)(18)
Total revenues, net of interest expense$5,599 $6,592 $7,427 (15)%(11)%
Total operating expenses$6,254 $4,726 $4,733 32 %— %
Net credit losses on loans$725 $790 $690 (8)%14 %
Credit reserve build for loans(375)520 NMNM
Provisions for other assets(3)— NM— 
Provisions for credit losses$347 $1,311 $698 (74)%88 %
Income (loss) from continuing operations before taxes$(1,002)$555 $1,996 NM(72)%
Income taxes (benefits)(316)87 459 NM(81)
Income (loss) from continuing operations$(686)$468 $1,537 NM(70)%
Noncontrolling interests(11)(4)NMNM
Net income (loss)$(675)$472 $1,531 NM(69)%
Balance Sheet data and ratios  
Average assets (in billions of dollars)
$139 $129 $122 8 %%
Return on average assets(0.49)%0.37 %1.25 %
Efficiency ratio112 72 64 
Average deposits (in billions of dollars)
$122 $113 $101 8 12 
Net credit losses as a percentage of average loans0.92 %0.99 %0.88 %
Revenue by business
Retail banking$3,446 $4,374 $4,519 (21)%(3)%
Branded cards2,153 2,218 2,908 (3)(24)
Total$5,599 $6,592 $7,427 (15)%(11)%
Income (loss) from continuing operations by business
Retail banking$(812)$669 $1,010 NM(34)%
Branded cards126 (201)527 NMNM
Total$(686)$468 $1,537 NM(70)%
FX translation impact
Total revenues—as reported$5,599 $6,592 $7,427 (15)%(11)%
Impact of FX translation(2)
 112 89 
Total revenues—ex-FX(3)
$5,599 $6,704 $7,516 (16)%(11)%
26


Total operating expenses—as reported$6,254 $4,726 $4,733 32 %— %
Impact of FX translation(2)
 83 52 
Total operating expenses—ex-FX(3)
$6,254 $4,809 $4,785 30 %%
Provisions for credit losses—as reported$347 $1,311 $698 (74)%88 %
Impact of FX translation(2)
 21 
Provisions for credit losses—ex-FX(3)
$347 $1,332 $705 (74)%89 %
Net income (loss)—as reported$(675)$472 $1,531 NM(69)%
Impact of FX translation(2)
 26 
Net income (loss)—ex-FX(3)
$(675)$475 $1,557 NM(69)%

(1)    Asia GCB includes the results of operations of GCB activities in certain EMEA countries for all periods presented.
(2)    Reflects the impact of FX translation into U.S. dollars at the 2021 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.

2021 vs. 2020
Net loss was $675 million, compared to net income of $475 million in the prior year. The net loss included the following items related to the 13 exit markets: (i) approximately $1.1 billion (approximately $0.8 billion after-tax) related to charges incurred from the voluntary early retirement program (VERP) in connection with the wind-down of the Korea consumer banking business; (ii) an approximate $0.7 billion pretax loss ($0.6 billion after-tax) related to the agreement to sell the Australia consumer banking business, largely reflecting the impact of a CTA loss (net of hedges); and (iii) contract modification costs related to the Asia divestitures of $119 million ($98 million after-tax).     
Excluding the above items, net income was $807 million compared to net income of $475 million in the prior year, reflecting significantly lower cost of credit, partially offset by higher expenses and lower revenues.
Revenues decreased 16%, including the Australia loss on sale. Excluding the Australia loss on sale, revenues declined 6%, reflecting lower retail banking and cards revenues, largely due to the continued impact of the pandemic, including lower interest rates.
Retail banking revenues decreased 22%, including the Australia loss on sale. Excluding the Australia loss on sale, revenues decreased 7%, as growth in both investment revenues and deposits was more than offset by lower deposit spreads due to lower interest rates and lower FX and insurance revenues. Assets under management increased 3%, reflecting the impact of improved market conditions, as well as client engagement. Average deposits increased 6% and average loans decreased 2%. The decline in retail banking revenues was also impacted by a 3% decrease in retail lending revenues, reflecting a decline in personal loans driven by spread compression.
Cards revenues decreased 5%, as lower average loans (down 14%, including the reclassification to held-for-sale related to Australia and the Philippines and higher payment rates) were partially offset by higher spending-related revenues (credit card spend volume up 8%), reflecting a continued recovery in sales activity from the pandemic-driven low levels in the prior year.
Expenses increased 30%, including approximately $1.2 billion of costs related to the Asia divestitures. Excluding the costs related to the Asia divestitures, expenses increased 6%, primarily driven by continued investments in Citi’s transformation, as well as business-led investments, partially offset by productivity savings.
Provisions decreased 74%, primarily driven by a net ACL release compared to a net ACL build in the prior year, as well as lower net credit losses. Net credit losses decreased 10%, primarily reflecting lower cards loan volumes and improved delinquencies.
The net ACL release was $376 million, compared to a build of $528 million in the prior year. The release reflected an improvement in portfolio credit quality. For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information on Asia GCB’s retail banking portfolios and its 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 “Executive Summary” above and “Risk Factors—Strategic Risks” and “Significant Accounting Policies and Significant Estimates” below.


27


CORPORATE/OTHER

Activities not assigned to the operating segments (ICG and GCB) are included in Corporate/Other. As of December 31, 2021, Corporate/Other includesincluded certain unallocated costs of global staff functions (including certain finance, risk, human resources, legal and compliance), other corporate expenses and unallocated global operations and technology expenses and income taxes, as well as results of Corporate Treasury, certain North America legacy consumer loan portfolios, discontinued operations and other legacy assets. For information on Citi’s planned revision to its reporting structure, including the reporting of the North America legacy consumer loan portfolios, discontinued operations and other legacy assets and discontinued operations (for additional information onas part of a new reporting segment, Corporate/OtherLegacy Franchises, see “Citigroup Segments” above).“Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above. At December 31, 2019,2021, Corporate/Other had $97 billion in assets.

In millions of dollars201920182017% Change 
 2019 vs. 2018
% Change 
 2018 vs. 2017
In millions of dollars202120202019% Change
2021 vs. 2020
% Change
2020 vs. 2019
Net interest revenue$1,890
$2,361
$2,043
(20)%16 %
Net interest incomeNet interest income$659 $(133)$1,898 NMNM
Non-interest revenue124
(171)1,134
NM
NM
Non-interest revenue8 204 124 (96)%65 %
Total revenues, net of interest expense$2,014
$2,190
$3,177
(8)%(31)%Total revenues, net of interest expense$667 $71 $2,022 NM(96)%
Total operating expenses$2,150
$2,275
$3,816
(5)%(40)%Total operating expenses$1,645 $1,923 $1,783 (14)%%
Net credit losses$(8)$21
$149
NM
(86)%
Credit reserve build (release)(60)(218)(317)72 %31
Provision (release) for unfunded lending commitments(7)(3)
NM

Provision for benefits and claims
(2)(7)100
71
Provisions (benefits) for credit losses and for benefits and claims$(75)$(202)$(175)63 %(15)%
Net credit losses (recoveries) on loansNet credit losses (recoveries) on loans$(83)$(22)$(8)NMNM
Credit reserve build (release) for loansCredit reserve build (release) for loans(291)188 (60)NMNM
Provision (release) for credit losses on unfunded lending commitmentsProvision (release) for credit losses on unfunded lending commitments(11)11 (7)NMNM
Provisions (releases) for benefits and claims, HTM debt securities and other assetsProvisions (releases) for benefits and claims, HTM debt securities and other assets16 — 100 %— %
Provisions (releases) for credit losses and for benefits and claimsProvisions (releases) for credit losses and for benefits and claims$(369)$178 $(75)NMNM
Income (loss) from continuing operations before taxes$(61)$117
$(464)NM
NM
Income (loss) from continuing operations before taxes$(609)$(2,030)$314 70 %NM
Income taxes (benefits)(886)(88)19,080
NM
(100)%Income taxes (benefits)(818)(921)(802)11 (15)%
Income (loss) from continuing operations$825
$205
$(19,544)NM
NM
Income (loss) from continuing operations$209 $(1,109)$1,116 NMNM
Income (loss) from discontinued operations, net of taxes(4)(8)(111)50 %93 %
(Loss) from discontinued operations, net of taxes(Loss) from discontinued operations, net of taxes7 (20)(4)NMNM
Net income (loss) before attribution of noncontrolling interests$821
$197
$(19,655)NM
NM
Net income (loss) before attribution of noncontrolling interests$216 $(1,129)$1,112 NMNM
Noncontrolling interests20
11
(6)82 %NM
Noncontrolling interests1 (6)20 NMNM
Net income (loss)$801
$186
$(19,649)NM
NM
Net income (loss)$215 $(1,123)$1,092 NMNM

NM Not meaningful


20192021 vs. 20182020
Net income was $801$215 million, compared to a net incomeloss of $186$1.1 billion in the prior year, reflecting higher revenues, lower expenses and lower cost of credit.
Revenues of $667 million compared to $71 million in the prior year. Net income was largelyyear, primarily driven by an income tax benefithigher net revenue from the investment portfolio.
Expenses decreased 14%, reflecting the absence of $886 million, compared to an income tax benefit of $88 milliona civil money penalty in the prior year. The increase inyear and the income tax benefit primarily reflected the reduction in the valuation allowance related to Citi’s deferred tax assets and a pretax loss in the current year (see “Significant Accounting Policies and Significant Estimates—Income Taxes” below). The pretax loss was largely driven by lower revenues from legacy assets, partially offset by higher gains on investments. The pretax loss also reflected higher cost of credit, partially offset by lower expenses.
Revenues decreased 8%, driven by the continued wind-down of legacy assets, partially offset by gains on investments.
Expenses decreased 5%, as the continued wind-down of legacy assets was partially offset by higher infrastructure costs.increases related to Citi’s transformation.
Provisions increased $127 million toreflected a net benefit of $75$369 million, compared to costs of $178 million in the prior year, primarily duedriven by a net ACL release in the current year ($286 million compared to a lower net loan loss reservebuild of $200 million in the prior year). The release partially offset by lower net credit losses.reflected the continued improvement in the macroeconomic outlook.
Citi expects that
For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below.
For additional information about trends, uncertainties and risks related to Corporate/Other’s future results, will likely be impacted by ongoing investments in infrastructuresee “Executive Summary” above and controls as well as lower interest rates and lower investment gains during 2020.“Risk Factors—Strategic Risks” below.






OFF-BALANCE SHEET ARRANGEMENTS

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

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

Citi enters into these arrangements for a variety of business purposes. For example, securitization arrangements offer investors access to specific cash flows and risks created through the securitization process. Securitization arrangements also assist Citi and its customers in monetizing their financial assets and securing financing at more favorable rates than Citi or the customers could otherwise obtain.
The table below shows where a discussion of Citi’s various off-balance sheet arrangements may be found in this Form 10-K. In addition, see Note 1 to the Consolidated Financial Statements.

Types of Off-Balance Sheet Arrangements Disclosures in this Form 10-K
Variable interests and other obligations, including contingent obligations, arising from variable interests in nonconsolidated VIEsSee Note 21 to the Consolidated Financial Statements.
Letters of credit, and lending and other commitmentsSee Note 26 to the Consolidated Financial Statements.
GuaranteesSee Note 26 to the Consolidated Financial Statements.

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CONTRACTUAL OBLIGATIONS

The following table includes information on Citigroup’s contractual obligations, as specified and aggregated pursuant to SEC requirements:
 Contractual obligations by year 
In millions of dollars20202021202220232024ThereafterTotal
Long-term debt obligations—principal(1)
$37,257
$38,083
$27,090
$20,128
$16,023
$110,179
$248,760
Long-term debt obligations—interest payments(2)
7,548
6,313
5,244
4,470
3,877
34,220
61,672
Operating lease obligations(3)
801
695
572
425
314
935
3,742
Purchase obligations(4)
584
538
532
316
324
752
3,046
Other liabilities(5)
34,561
474
218
127
114
1,622
37,116
Total$80,751
$46,103
$33,656
$25,466
$20,652
$147,708
$354,336

(1)For additional information about long-term debt obligations, see “Liquidity Risk—Long-Term Debt” below and Note 17 to the Consolidated Financial Statements.
(2)Contractual obligations related to interest payments on long-term debt for 2020–2024 are calculated by applying the December 31, 2019 weighted-average interest rate (3.28%) on average outstanding long-term debt to the average remaining contractual obligations on long-term debt for each of those years. The “Thereafter” interest payments on long-term debt for the remaining years to maturity (2025–2098) are calculated by applying current interest rates on the remaining contractual obligations on long-term debt for each of those years.
(3)For additional information about operating leases, see Note 26 to the Consolidated Financial Statements.
(4)Purchase obligations consist of obligations to purchase goods or services that are enforceable and legally binding on Citi. For presentation purposes, purchase obligations are included in the table above through the termination date of the respective agreements, even if the contract is renewable. Many of the purchase agreements for goods or services include clauses that would allow Citi to cancel the agreement with specified notice; however, that impact is not included in the table above (unless Citi has already notified the counterparty of its intention to terminate the agreement).
(5)
Other liabilities reflected on Citigroup’s Consolidated Balance Sheet includes accounts payable, accrued expenses, uncertain tax positions and other liabilities that have been incurred and will ultimately be paid in cash; legal reserve accruals are not included in the table above. Also includes discretionary contributions in 2018 for Citi’s employee-defined benefit obligations for the pension, postretirement and post employment plans and defined contribution plans.


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, and equity issued through awards under employee benefit plans, among other issuances. Further, Citi’s capital levels may also be affected by changes in accounting and regulatory standards, as well as U.S. corporate tax laws and the impact of future events on Citi’s business results, such as changes in interest and foreign exchange rates, as well as business and asset dispositions. For additional information on capital-related trends, uncertainties and risks related to Citi’s legacy and exit businesses, including the impact of CTA losses, see “Executive Summary” above and “Risk Factors—Strategic Risks” and “—Operational Risks” below.
During 2019,2021, Citi returned a total of $22.3$11.8 billion of capital to common shareholders in the form of $4.2 billion in dividends and $7.6 billion in share repurchases (approximately 264totaling approximately 105 million common shares) and dividends.shares.

Capital Management
Citi’s capital management framework is designed to ensure that Citigroup and its principal subsidiaries maintain sufficient capital consistent with each entity’s respective risk profile, management targets and all applicable regulatory standards and guidelines. Citi assesses its capital adequacy against a series of internal quantitative capital goals, designed to evaluate its capital levels in expected and stressed economic environments. Underlying these internal quantitative capital goals are strategic capital considerations, centered on preserving and building financial strength.
The Citigroup Capital Committee, with oversight from the Risk Management Committee of Citigroup’s Board of Directors, has responsibility for Citi’s aggregate capital structure, including the capital assessment and planning process, which is integrated into Citi’s capital plan. Balance sheet management, including oversight of capital adequacy, for Citigroup’s subsidiaries is governed by each entity’s Asset and Liability Committee, where applicable.
Based on Citigroup’s current regulatory capital requirements, as well as consideration of potential future changes to the U.S. Basel III rules, management currently believes that a targeted Common Equity Tier 1 Capital ratio of approximately 11.5% represents the amount necessary to prudently operate and invest in Citi’s franchise, including when considering future growth plans, capital return projections and other factors that may impact Citi’s businesses. However, management may revise Citigroup’s targeted Common Equity Tier 1 Capital ratio in response to changing regulatory capital requirements as well as other relevant factors.
For additional information regarding Citi’s capital planning and stress testing exercises, see “Stress Testing Component of Capital Planning” below.


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

Risk-Based Capital Ratios
The U.S. Basel III rules set forth the composition of regulatory capital (including the application of regulatory capital adjustments and deductions), as well as two comprehensive methodologies (a Standardized Approach and Advanced Approaches) for measuring total risk-weighted assets.
Total risk-weighted assets under the Advanced Approaches, which are primarily models based, include credit, market and operational risk-weighted assets. The Standardized Approach generally applies prescribed supervisory risk weights to broad categories of credit risk exposures. As a result, credit risk-weighted assets calculated under the Advanced Approaches are more risk sensitive than those calculated under the Standardized Approach. Market risk-weighted assets are currently calculated on a generally consistent basis under both approaches. The Standardized Approach excludes operational risk-weighted assets.
TheUnder the U.S. Basel III rules, establishboth Citi and Citibank, N.A. (Citibank) are required to maintain stated minimum Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios for substantially all U.S. banking organizations, including Citiof 4.5%, 6.0% and Citibank, N.A. (Citibank). Moreover, these rules provide for both a fixed 2.5% Capital Conservation Buffer and, for Advanced Approaches banking organizations, such as Citi and Citibank, a discretionary Countercyclical Capital Buffer. These capital buffers would be available to absorb losses in advance of any potential impairment of regulatory capital below the stated minimum risk-based capital ratio requirements. Any breach of the buffers to absorb losses during periods of financial or economic stress would result in restrictions on earnings distributions (e.g.8.0%, dividends, equity repurchases and discretionary executive bonuses), with the degree of such restrictions based upon the extent to which the buffers are breached. The Federal Reserve Board last voted to affirm the Countercyclical Capital Buffer amount at the current level of 0% in March 2019.
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 lowermore binding of each of the resulting risk-based capital ratios.








GSIB Surcharge
The Federal Reserve Board imposes a risk-based capital surcharge upon U.S. bank holding companies that are identified as global systemically important bank holding companies (GSIBs), including Citi. The GSIB surcharge augments the Capital Conservation Buffer and, if invoked, any Countercyclical Capital Buffer.
Under the Federal Reserve Board’s rule, identification of a GSIB is based on the Basel Committee on Banking Supervision’s (Basel Committee) GSIB methodology, which primarily looks to five equally weighted broad categories of systemic importance: (i) size, (ii) interconnectedness, (iii) cross-jurisdictional activity, (iv) substitutability and (v) complexity. With the exception of size, each of the categories is composed of multiple indicators of equal weight, amounting to 12 indicators in total.
A U.S. bank holding company that is designated a GSIB is required, on an annual basis, to calculate a surcharge using two methods and is subject to the higher of the resulting two surcharges. The first method (“method 1”) is based on the Basel Committee’s GSIB methodology described above. Under the second method (“method 2”), the substitutability category is replaced with a quantitative measure intended to assess a GSIB’s reliance on short-term wholesale funding. In addition, method 1 incorporates relative measures of systemic importance across certain global banking organizations and a year-end spot foreign exchange rate, whereas method 2 uses fixed measures of systemic importance and application of an average foreign exchange rate over a three-year period. The GSIB surcharges calculated under both method 1 and method 2 are based on measures of systemic importance from the year immediately preceding that in which the GSIB surcharge calculations are being performed (e.g., the method 1 and method 2 GSIB surcharges to be calculated by December 31, 2020 will be based on 2019 systemic indicator data). Generally, Citi’s surcharge determined under method 2 will result in a higher surcharge than its surcharge determined under method 1.
Should a GSIB’s systemic importance change year-over-year such that it becomes subject to a higher surcharge, the higher surcharge would not become effective for a full year (e.g., a higher surcharge calculated by December 31, 2020 would not become effective until January 1, 2022). However, if a GSIB’s systemic importance changes such that the GSIB would be subject to a lower surcharge, the GSIB would be subject to the lower surcharge beginning with the next calendar year (e.g., a lower surcharge calculated by December 31, 2020 would become effective January 1, 2021).
The following table sets forth Citi’s GSIB surcharge as determined under method 1 and method 2 for 2019 and 2018:
 20192018
Method 12.0%2.0%
Method 23.0
3.0

Citi’s GSIB surcharge effective for both 2019 and 2018 was 3.0%, as derived under the higher method 2 result. Citi’s GSIB surcharge effective for 2020 will remain unchanged at 3.0%, as derived under the higher method 2 result. Citi expects that its method 2 GSIB surcharge will continue to remain higher than its method 1 GSIB surcharge. Citi’s GSIB surcharge effective for 2021 will not exceed 3.0%, and Citi’s GSIB surcharge effective for 2022 is not expected to exceed 3.0%.
Transition Provisions
Generally, the U.S. Basel III rules contain several differing, largely multi-year transition provisions, with various “phase-ins” and “phase-outs.” With the exception of the non-grandfathered trust preferred securities, which do not fully phase-out of Tier 2 Capital until January 1, 2022, all other transition provisions have occurred and were entirely reflected in Citi’s regulatory capital ratios beginning January 1, 2018. Moreover, the GSIB surcharge, Capital Conservation Buffer and any Countercyclical Capital Buffer (currently 0%) commenced phase-in on January 1, 2016, and became fully effective on January 1, 2019.

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

29


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 periodend-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. TheThese 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 ratiothis 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 changed 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.
The interim final rule was effective for Citigroup’s Supplementary Leverage ratio, as well as for Citigroup’s leverage-based total loss absorbing capacity (TLAC) and long-term debt (LTD) requirements, and expired as scheduled on March 31, 2021. Citigroup’s reported Supplementary Leverage ratio of 7.0% during the fourth quarter of 2020 benefited 109 basis points, as a result of the temporary relief.

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 modified the regulatory capital transition provision related to the current expected credit losses (CECL) methodology. The September 2020 final rule does not have any impact on U.S. GAAP accounting.
The final rule permitted 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 utilized a 25% scaling factor as an approximation of the increased reserve build under CECL compared to the previous incurred loss model and, therefore, allowed banks to add back to Common Equity Tier 1 Capital an amount equal to 25% of the change in CECL-based allowances in each quarter between January 1, 2020 and December 31, 2021. Beginning January 1, 2022, the cumulative 25% change in CECL-based allowances
between January 1, 2020 and December 31, 2021 will be phased in to regulatory capital (i) at 25% per year on January 1 of each year over the three-year transition period, and (ii) along with the delayed “Day One” impact.
Citigroup and Citibank 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 in each quarter between January 1, 2020 and December 31, 2021, started to be phased in on January 1, 2022 and will be fully reflected in Citi’s regulatory capital as of January 1, 2025.
As of December 31, 2021, Citigroup’s reported Common Equity Tier 1 Capital ratio of 12.2% benefited from the deferrals of the CECL transition provision by 24 basis points (bps), which resulted in an approximate 6 bps decrease to Citigroup’s Common Equity Tier 1 Capital ratio upon commencement of the phase-in on January 1, 2022. In addition, this phase-in is expected to result in an additional 6 bps decrease to Citigroup’s Common Equity Tier 1 Capital ratio on January 1 of each year through January 1, 2025. For additional information on Citigroup’s and Citibank’s regulatory capital ratios excluding the impact of the CECL transition provision, see “Capital Resources (Full Adoption of CECL)” below.

TLAC Holdings
As previously disclosed, in January 2021, the U.S. banking agencies issued a final rule that created a new regulatory capital deduction applicable to Advanced Approaches banking organizations for certain investments in covered debt instruments issued by GSIBs. The final rule became effective for Citigroup and Citibank on April 1, 2021, and did not have a significant impact on either Citigroup’s or Citibank’s regulatory capital.

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 regulatory capital ratio requirements.
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. ERI is equal to 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.
As of December 31, 2021, Citi’s regulatory capital ratios exceeded effective regulatory minimum requirements. Accordingly, Citi is not subject to payout limitations as a result of Basel III requirements.

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Stress Capital Buffer
Citigroup is subject to the Federal Reserve Board’s Stress Capital Buffer (SCB) rule, which integrates the annual stress testing requirements with ongoing regulatory capital requirements. The SCB 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%. SCB-based minimum capital requirements will be reviewed and updated annually by the Federal Reserve Board as part of the CCAR process. For additional information regarding CCAR and DFAST, see “Stress Testing Component of Capital Planning” below. The fixed 2.5% Capital Conservation Buffer (for additional information, see below) will continue to apply under the Advanced Approaches.
In August 2021, the Federal Reserve Board finalized and announced Citi’s SCB requirement of 3.0%. Accordingly, effective October 1, 2021, Citigroup is required to maintain a 10.5% effective minimum Common Equity Tier 1 Capital ratio under the Standardized Approach. Previously, from October 1, 2020 through September 30, 2021, Citi had been subject to a 2.5% SCB, and a 10.0% effective minimum Common Equity Tier 1 Capital ratio under the Standardized Approach.

Capital Conservation Buffer and Countercyclical Capital Buffer
Citigroup is subject to a fixed 2.5% Capital Conservation Buffer under the Advanced Approaches. Citibank is subject to the fixed 2.5% Capital Conservation Buffer under both the Advanced Approaches and the Standardized Approach.
In addition, Advanced Approaches banking organizations, such as Citigroup 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 calculated during 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 increase for more than one year, such that it becomes subject to a higher GSIB surcharge, the higher surcharge would not become effective for a full year after the second consecutive higher score (e.g., a higher surcharge calculated using data as of December 31, 2020 and December 30, 2021 would not become effective until January 1, 2023). However, if after two consecutive years of a higher score, 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 in the calendar year commencing one year later (e.g., a lower surcharge calculated using data as of December 31, 2022 would become effective January 1, 2024).
The following table sets forth Citi’s effective GSIB surcharge as determined under method 1 and method 2 during 2021 and 2020:

20212020
Method 12.0 %2.0 %
Method 23.0 3.0 

Citi’s GSIB surcharge effective during both 2021 and 2020 was 3.0%, as derived under the higher method 2 result. Citi’s GSIB surcharge effective for 2022 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, based on Citi’s method 2 result as of December 31, 2020, and its estimated method 2 result as of December 31, 2021, Citi’s GSIB surcharge is expected to increase to 3.5% effective January 1, 2023. Citi’s GSIB surcharge effective for 2024 will likely be based on the lower of its method 2 scores for year-end 2021 and 2022, and therefore is not expected to exceed 3.5%.
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
31


institution subsidiaries of U.S. GSIBs, including Citibank, must maintain a minimum Supplementary Leverage ratio of 6.0% to be considered “well capitalized.” Citibank was “well capitalized” as of December 31, 2019.2021.
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.

Stress Testing Component of Capital Planning
Citi is subject to an annual assessment by the Federal Reserve Board as to whether Citigroup has effective capital planning processes as well as sufficient regulatory capital to absorb losses during stressful economic and financial conditions, while also meeting obligations to creditors and counterparties and continuing to serve as a credit intermediary. This annual assessment includes two related programs: the Comprehensive Capital Analysis and Review (CCAR) and Dodd-Frank Act Stress Testing (DFAST).
For the largest and most complex firms, such as Citi, CCAR includes both a quantitativequalitative evaluation of a firm’s capital adequacy under stress and a qualitative evaluation of its abilities to determine its capital needs on a forward-looking
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 stockshare repurchases. The Federal Reserve Board assesses whether Citi has sufficient capital to continue operations throughout times of economic and financial market stress and whether Citi has robust, forward-looking capital planning processes that account for its unique risks. The Federal Reserve Board may object to Citi’s annual capital plan based on quantitative grounds. If the Federal Reserve Board objects to Citi’s annual capital plan, Citi may not undertake any capital distribution unless the Federal Reserve Board indicates in writing that it does not object to the distribution.
Based on recent changes to the Federal Reserve Board’s Capital Plan Rule, the qualitative objection to a firm’s capital plan will no longer apply. However, allAll CCAR firms, including Citi, will continue to beare 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.
Citigroup and Citibank are required to disclose the results of their company-run stress tests.

Temporary Federal Reserve Board Limitations on Capital Distributions
From the third quarter of 2020 to the second quarter of 2021, the Federal Reserve Board placed temporary limitations on capital distributions for Citi and other large banking organizations, to ensure that large banks maintained a high level of capital resilience throughout the COVID-19 pandemic. Commencing July 1, 2021, Citi’s common
stock dividends and share repurchases were no longer subject to limitations based on the average of Citi’s net income for the
four preceding calendar quarters.
All large banks, including Citi, remain subject to limitations on capital distributions in the event of a breach of
any regulatory capital buffers, including the Stress Capital
Buffer, with the degree of such restrictions based on the extent
to which the buffers are breached. For additional information, on potential changes to the stress testing component of capital planning and assessment process applicable to Citi,
see “Regulatory Capital Standards Developments”Buffers” above, and “Risk Factors—Strategic Risks” below.





32


Citigroup’s Capital Resources
Citi is required to maintain statedThe following table sets forth Citi’s effective minimum risk-based capital requirements as of December 31, 2021, September 30, 2021 and December 31, 2020:

Advanced ApproachesStandardized Approach
December 31, 2021September 30, 2021December 31, 2020December 31, 2021September 30, 2021December 31, 2020
Common Equity Tier 1 Capital ratio(1)
10.0 %10.0 %10.0 %10.5 %10.0 %10.0 %
Tier 1 Capital ratio(1)
11.5 11.5 11.5 12.0 11.5 11.5 
Total Capital ratio(1)
13.5 13.5 13.5 14.0 13.5 13.5 

(1)Beginning October 1, 2021, Citi’s effective minimum risk-based capital requirements include the 3.0% 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, Tier 1 Capital and Total Capital ratios of 4.5%, 6.0% and 8.0%, respectively.Capital). For prior periods presented, Citi’s effective minimum risk-based capital requirements are presented inincluded a 2.5% SCB and 3.0% GSIB surcharge under the table below.Standardized Approach, and the 2.5% Capital Conservation Buffer and 3.0% GSIB surcharge under the Advanced Approaches.
Furthermore, to be “well capitalized” under current federal bank regulatory agency definitions, a bank holding company must have a Tier 1 Capital ratio of at least 6.0%, a Total Capital ratio of at least 10.0% and not be subject to a Federal Reserve Board directive to maintain higher capital levels.
The following tables set forth Citi’s capital components and ratios as of December 31, 2019,2021, September 30, 20192021 and December 31, 2018:2020:

Advanced Approaches(5)
Standardized Approach(5)
In millions of dollars, except ratiosDecember 31, 2021September 30, 2021December 31, 2020December 31, 2021September 30, 2021December 31, 2020
Common Equity Tier 1 Capital(1)
$149,305 $149,631 $147,274 $149,305 $149,631 $147,274
Tier 1 Capital169,568 168,902 167,053 169,568 168,902 167,053
Total Capital (Tier 1 Capital + Tier 2 Capital)(1)
194,006 194,423 196,051 203,838 204,288 205,002
Total Risk-Weighted Assets1,209,374 1,265,297 1,278,977 1,219,175 1,284,316 1,242,381
   Credit Risk(1)
$840,483 $871,668 $859,698 $1,135,906 $1,187,516 $1,121,871
   Market Risk78,634 93,376 116,181 83,269 96,800 120,510
   Operational Risk290,257 300,253 303,098  — — 
Common Equity Tier 1 Capital ratio(2)
12.35 %11.83 %11.51 %12.25 %11.65 %11.85 %
Tier 1 Capital ratio(2)
14.02 13.35 13.06 13.91 13.15 13.45 
Total Capital ratio(2)
16.04 15.37 15.33 16.72 15.91 16.50 
In millions of dollars, except ratiosEffective Minimum RequirementDecember 31, 2021September 30, 2021December 31, 2020
Quarterly Adjusted Average Total Assets(1)(3)
$2,351,434 $2,311,830 $2,265,615 
Total Leverage Exposure(1)(4)
2,957,764 2,911,050 2,391,033 
Tier 1 Leverage ratio4.0%7.21 %7.31 %7.37 %
Supplementary Leverage ratio5.05.73 5.80 6.99 

(1)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 were deferred and have commenced phase-in to regulatory capital at 25% per year beginning January 1, 2022. For the ongoing impact of CECL, Citigroup was allowed to adjust retained earnings and the ACL in an amount equal to 25% of the change in the ACL (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 commenced phase-in to regulatory capital at 25% per year beginning 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 were deducted from risk-weighted assets (RWA) and commenced phase-in to RWA at 25% per year beginning January 1, 2022.
(2)Citi’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were derived under the Basel III Standardized Approach as of December 31, 2021 and September 30, 2021, and under the Basel III Advanced Approaches framework as of December 31, 2020, whereas Citi’s reportable Total Capital ratio was the lower derived under the Basel III Advanced Approaches framework for all periods presented.
(3)Tier 1 Leverage ratio denominator. Represents quarterly average total assets less amounts deducted from Tier 1 Capital.
(4)Supplementary Leverage ratio denominator. Commencing with the second quarter of 2020 and continuing through the first quarter of 2021, Citigroup’s Total Leverage Exposure temporarily excluded U.S. Treasuries and deposits at Federal Reserve Banks. For additional information, see “Temporary Supplementary Leverage Ratio Relief” above.
(5)Certain of the above prior-period amounts have been revised to conform with enhancements made in the current period.

33
 
Effective Minimum Requirement(1)
Advanced ApproachesStandardized Approach
In millions of dollars, except ratios20192018Dec. 31, 2019Sept. 30, 2019Dec. 31, 2018Dec. 31, 2019Sept. 30, 2019Dec. 31, 2018
Common Equity Tier 1 Capital  $137,798
$138,581
$139,252
$137,798
$138,581
$139,252
Tier 1 Capital  155,805
158,033
158,122
155,805
158,033
158,122
Total Capital (Tier 1 Capital + Tier 2 Capital)  181,337
183,996
183,144
193,682
196,354
195,440
Total Risk-Weighted Assets  1,135,553
1,145,091
1,131,933
1,166,523
1,197,050
1,174,448
   Credit Risk  $771,508
$776,367
$758,887
$1,107,775
$1,134,584
$1,109,007
   Market Risk  57,317
61,125
63,987
58,748
62,466
65,441
   Operational Risk  306,728
307,599
309,059



Common Equity Tier 1 Capital ratio(2)
10.0%8.625%12.13%12.10%12.30%11.81%11.58%11.86%
Tier 1 Capital ratio(2)
11.510.12513.72
13.80
13.97
13.36
13.20
13.46
Total Capital ratio(2)
13.512.12515.97
16.07
16.18
16.60
16.40
16.64



In millions of dollars, except ratiosEffective Minimum RequirementDec. 31, 2019Sept. 30, 2019Dec. 31, 2018
Quarterly Adjusted Average Total Assets(3)
 $1,957,039 $1,960,675 $1,896,959 
Total Leverage Exposure(4) 
 2,507,891 2,520,352 2,465,641 
Tier 1 Leverage ratio4.0%7.96%8.06%8.34%
Supplementary Leverage ratio5.06.21 6.27 6.41 

(1)Citi’s effective minimum risk-based capital requirements during 2019 and 2018 are inclusive of the 100% and 75% phase-in, respectively, of both the 2.5% Capital Conservation Buffer and the 3.0% GSIB surcharge (all of which must be composed of Common Equity Tier 1 Capital).
(2)Citi’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the Basel III Standardized Approach, whereas the reportable Total Capital ratio was the lower derived under the Basel III Advanced Approaches framework for all periods presented.
(3)Tier 1 Leverage ratio denominator. Represents quarterly average total assets less amounts deducted from Tier 1 Capital.
(4)Supplementary Leverage ratio denominator.

Common Equity Tier 1 Capital Ratio
As set forth in the table above, Citi’s Common Equity Tier 1 Capital ratio was 11.8% under the Basel III Standardized Approach at December 31, 2019, compared to 11.6% at2021 increased from September 30, 2019 and 11.9% at December 31, 2018. The quarter-over-quarter increase was2021, primarily due to a decrease in risk-weighted assets and a temporary pause in common share repurchases in the fourth quarter of 2021 in preparation for the implementation of the Standardized Approach for Counterparty Credit Risk (SA-CCR) on January 1, 2022. Citi’s Common Equity Tier 1
Capital ratio increased from year-end 2020, largely driven by net income of $5.0$22.0 billion, a reductionnet decrease in credit risk-weighted assets and beneficial net movementsa temporary pause in
Accumulated other comprehensive income (AOCI), common share repurchases in the fourth quarter of 2021 in preparation for the implementation of SA-CCR, partially offset by the return of $6.2 billion of capital to common shareholders. The decline year-over-year was primarily due to the return of $22.3$11.8 billion of capital to common shareholders partially offset by net incomein the form of $19.4 billion in 2019, beneficialshare repurchases and dividends, as well as adverse net movements in AOCI and a reduction in risk-weighted assets..

Components of Citigroup Capital
In millions of dollarsDecember 31,
2021
December 31,
2020
Common Equity Tier 1 Capital
Citigroup common stockholders’ equity(1)
$183,108 $180,118 
Add: Qualifying noncontrolling interests143 141 
Regulatory capital adjustments and deductions:
Add: CECL transition and 25% provision deferral(2)
3,028 5,348 
Less: Accumulated net unrealized gains (losses) on cash flow hedges, net of tax101 1,593 
Less: Cumulative unrealized net gain (loss) related to changes in fair value of financial liabilities attributable to own creditworthiness, net of tax(896)(1,109)
Less: Intangible assets:
  Goodwill, net of related DTLs(3)
20,619 21,124 
   Identifiable intangible assets other than MSRs, net of related DTLs3,800 4,166 
Less: Defined benefit pension plan net assets; other2,080 921 
Less: DTAs arising from net operating loss, foreign tax credit and general business credit
carry-forwards(4)
11,270 11,638 
Total Common Equity Tier 1 Capital (Standardized Approach and Advanced Approaches)$149,305 $147,274 
Additional Tier 1 Capital
Qualifying noncumulative perpetual preferred stock(1)
$18,864 $19,324 
Qualifying trust preferred securities(5)
1,399 1,393 
Qualifying noncontrolling interests34 35 
Regulatory capital deductions:
Less: Permitted ownership interests in covered funds(6)
 917 
Less: Other34 56 
Total Additional Tier 1 Capital (Standardized Approach and Advanced Approaches)$20,263 $19,779 
Total Tier 1 Capital (Common Equity Tier 1 Capital + Additional Tier 1 Capital)
(Standardized Approach and Advanced Approaches)
$169,568 $167,053 
Tier 2 Capital
Qualifying subordinated debt$20,064 $23,481 
Qualifying trust preferred securities(7)
248 331 
Qualifying noncontrolling interests42 41 
Eligible allowance for credit losses(2)(8)
14,209 14,127 
Regulatory capital deduction:
Less: Other293 31 
Total Tier 2 Capital (Standardized Approach)$34,270 $37,949 
Total Capital (Tier 1 Capital + Tier 2 Capital) (Standardized Approach)$203,838 $205,002 
Adjustment for excess of eligible credit reserves over expected credit losses(2)(8)
$(9,832)$(8,951)
Total Tier 2 Capital (Advanced Approaches)$24,438 $28,998 
Total Capital (Tier 1 Capital + Tier 2 Capital) (Advanced Approaches)$194,006 $196,051 
In millions of dollarsDecember 31,
2019
December 31,
2018
Common Equity Tier 1 Capital  
Citigroup common stockholders’ equity(1)
$175,414
$177,928
Add: Qualifying noncontrolling interests154
147
Regulatory capital adjustments and deductions:  
Less: Accumulated net unrealized gains (losses) on cash flow hedges, net of tax(2)
123
(728)
Less: Cumulative unrealized net gain (loss) related to changes in fair value of financial liabilities
   attributable to own creditworthiness, net of tax(3)
(679)580
Less: Intangible assets:  
  Goodwill, net of related DTLs(4)
21,066
21,778
    Identifiable intangible assets other than MSRs, net of related DTLs4,087
4,402
Less: Defined benefit pension plan net assets803
806
Less: DTAs arising from net operating loss, foreign tax credit and general business credit
   carry-forwards(5)
12,370
11,985
Total Common Equity Tier 1 Capital (Standardized Approach and Advanced Approaches)$137,798
$139,252
Additional Tier 1 Capital  
Qualifying noncumulative perpetual preferred stock(1)
$17,828
$18,292
Qualifying trust preferred securities(6)
1,389
1,384
Qualifying noncontrolling interests42
55
Regulatory capital deductions:  
Less: Permitted ownership interests in covered funds(7)
1,216
806
Less: Minimum regulatory capital requirements of insurance underwriting subsidiaries(8)
36
55
Total Additional Tier 1 Capital (Standardized Approach and Advanced Approaches)$18,007
$18,870
Total Tier 1 Capital (Common Equity Tier 1 Capital + Additional Tier 1 Capital)
   (Standardized Approach and Advanced Approaches)
$155,805
$158,122
Tier 2 Capital  
Qualifying subordinated debt$23,673
$23,324
Qualifying trust preferred securities(9)
326
321
Qualifying noncontrolling interests46
47
Eligible allowance for credit losses(10)
13,868
13,681
Regulatory capital deduction:  
Less: Minimum regulatory capital requirements of insurance underwriting subsidiaries(8)
36
55
Total Tier 2 Capital (Standardized Approach)$37,877
$37,318
Total Capital (Tier 1 Capital + Tier 2 Capital) (Standardized Approach)$193,682
$195,440
Adjustment for excess of eligible credit reserves over expected credit losses(10)
$(12,345)$(12,296)
Total Tier 2 Capital (Advanced Approaches)$25,532
$25,022
Total Capital (Tier 1 Capital + Tier 2 Capital) (Advanced Approaches)$181,337
$183,144

(1)Issuance costs of $152 million and $168 million related to noncumulative perpetual preferred stock outstanding at December 31, 2019 and 2018, respectively, are excluded from common stockholders’ equity and netted against such preferred stock in accordance with Federal Reserve Board regulatory reporting requirements, which differ from those under U.S. GAAP.
(2)
Common Equity Tier 1 Capital is adjusted for accumulated net unrealized gains (losses) on cash flow hedges included in AOCI that relate to the hedging of items not recognized at fair value on the balance sheet.
(3)The cumulative impact of changes in Citigroup’s own creditworthiness in valuing liabilities for which the fair value option has been elected, and own-credit valuation adjustments on derivatives, are excluded from Common Equity Tier 1 Capital, in accordance with the U.S. Basel III rules.
(4)Includes goodwill “embedded” in the valuation of significant common stock investments in unconsolidated financial institutions.



Footnotes continue on the following page.


34
(5)Of Citi’s $23.1 billion of net DTAs at December 31, 2019, $12.4 billion was includable in Common Equity Tier 1 Capital pursuant to the U.S. Basel III rules, while $10.7 billion was excluded. Excluded from Citi’s Common Equity Tier 1 Capital as of December 31, 2019 was $12.4 billion of net DTAs arising from net operating loss, foreign tax credit and general business credit carry-forwards, which was reduced by $1.7 billion of net DTLs primarily associated with goodwill and certain other intangible assets. Separately, under the U.S. Basel III rules, goodwill and these other intangible assets are deducted net of associated DTLs in arriving at Common Equity Tier 1 Capital. DTAs arising from net operating loss, foreign tax credit and general business credit carry-forwards are required to be entirely deducted from Common Equity Tier 1 Capital under the U.S. Basel III rules. Citi’s DTAs arising from temporary differences are less than the 10% limitation under the U.S. Basel III rules and therefore not subject to deduction from Common Equity Tier 1 Capital, but are subject to risk-weighting at 250%.
(6)Represents Citigroup Capital XIII trust preferred securities, which are permanently grandfathered as Tier 1 Capital under the U.S. Basel III rules.
(7)Banking entities are required to be in compliance with the Volcker Rule of the Dodd-Frank Act, which prohibits conducting certain proprietary investment activities and limits their ownership of, and relationships with, covered funds. Accordingly, Citi is required by the Volcker Rule to deduct from Tier 1 Capital all permitted ownership interests in covered funds.
(8)50% of the minimum regulatory capital requirements of insurance underwriting subsidiaries must be deducted from each of Tier 1 Capital and Tier 2 Capital.
(9)Represents the amount of non-grandfathered trust preferred securities eligible for inclusion in Tier 2 Capital under the U.S. Basel III rules, which will be fully phased-out of Tier 2 Capital by January 1, 2022.
(10)Under the Standardized Approach, the allowance for credit losses is eligible for inclusion in Tier 2 Capital up to 1.25% of credit risk-weighted assets, with any excess allowance for credit losses being deducted in arriving at credit risk-weighted assets, which differs from the Advanced Approaches framework, in which eligible credit reserves that exceed expected credit losses are eligible for inclusion in Tier 2 Capital to the extent that the excess reserves do not exceed 0.6% of credit risk-weighted assets. The total amount of eligible credit reserves in excess of expected credit losses that were eligible for inclusion in Tier 2 Capital, subject to limitation, under the Advanced Approaches framework was $1.5 billion and $1.4 billion at December 31, 2019 and 2018, respectively.







(1)Issuance costs of $131 million and $156 million related to noncumulative perpetual preferred stock outstanding at December 31, 2021 and 2020, 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 were deferred and commenced phase-in to regulatory capital at 25% per year beginning January 1, 2022. For the ongoing impact of CECL, Citigroup was allowed to adjust retained earnings and the ACL in an amount equal to 25% of the change in the ACL (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 have also commenced phase in to regulatory capital at 25% per year beginning January 1, 2022, along with the deferred impacts related to the January 1, 2020 CECL adoption date.
(3)Includes goodwill “embedded” in the valuation of significant common stock investments in unconsolidated financial institutions.
(4)Of Citi's $24.8 billion of net DTAs at December 31, 2021, $15.3 billion was included 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, 2021 was $11.3 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 $1.8 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 10%/15% 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. Commencing January 1, 2021, Citi no longer deducts permitted market-making positions in third-party covered funds from Tier 1 Capital, in accordance with the revised Volcker Rule 2.0 issued by the U.S. agencies in November 2019. Upon the removal of the capital deduction, permitted market-making positions in third-party covered funds are included in risk-weighted assets.
(7)Represents the amount of non-grandfathered trust preferred securities that were previously eligible for inclusion in Tier 2 Capital under the U.S. Basel III rules. Commencing January 1, 2022, non-grandfathered trust preferred securities have been fully phased out of Tier 2 Capital.
(8)Under the Standardized Approach, the allowance for credit losses is eligible for inclusion in Tier 2 Capital up to 1.25% of credit risk-weighted assets, with any excess allowance for credit losses being deducted in arriving at credit risk-weighted assets, which differs from the Advanced Approaches framework, in which eligible credit reserves that exceed expected credit losses are eligible for inclusion in Tier 2 Capital to the extent that the excess reserves do not exceed 0.6% of credit risk-weighted assets. The total amount of eligible credit reserves in excess of expected credit losses that were eligible for inclusion in Tier 2 Capital, subject to limitation, under the Advanced Approaches framework was $4.4 billion and $5.2 billion at December 30, 2021 and December 31, 2020, respectively.













35


Citigroup Capital Rollforward
In millions of dollarsThree months ended December 31, 2021Twelve months ended
December 31, 2021
Common Equity Tier 1 Capital, beginning of period$149,631 $147,274 
Net income3,173 21,952 
Common and preferred dividends declared(1,249)(5,236)
Net change in treasury stock6 (7,111)
Net increase in common stock and additional paid-in capital87 132 
Net change in foreign currency translation adjustment net of hedges, net of tax(462)(2,525)
Net change in unrealized gains (losses) on debt securities AFS, net of tax(1,396)(3,934)
Net decrease in defined benefit plans liability adjustment, net of tax76 1,012 
Net change in adjustment related to change in fair value of financial liabilities
attributable to own creditworthiness, net of tax
(3)19 
Net decrease in excluded component of fair value hedges12  
Net decrease in goodwill, net of related DTLs70 505 
Net decrease in identifiable intangible assets other than MSRs, net of related DTLs99 366 
Net increase in defined benefit pension plan net assets(133)(936)
Net change in DTAs arising from net operating loss, foreign tax credit and general business credit carry-forwards(373)368 
Net decrease in CECL 25% provision deferral(361)(2,320)
Other128 (261)
Net change in Common Equity Tier 1 Capital$(326)$2,031 
Common Equity Tier 1 Capital, end of period
(Standardized Approach and Advanced Approaches)
$149,305 $149,305 
Additional Tier 1 Capital, beginning of period$19,271 $19,779 
Net change in qualifying perpetual preferred stock994 (460)
Net increase in qualifying trust preferred securities1 6 
Net decrease in permitted ownership interests in covered funds 917 
Other(3)21 
Net increase in Additional Tier 1 Capital$992 $484 
Tier 1 Capital, end of period
(Standardized Approach and Advanced Approaches)
$169,568 $169,568 
Tier 2 Capital, beginning of period (Standardized Approach)$35,386 $37,949 
Net decrease in qualifying subordinated debt(392)(3,417)
Net change in eligible allowance for credit losses(651)82 
Other(73)(344)
Net decrease in Tier 2 Capital (Standardized Approach)$(1,116)$(3,679)
Tier 2 Capital, end of period (Standardized Approach)$34,270 $34,270 
Total Capital, end of period (Standardized Approach)$203,838 $203,838 
Tier 2 Capital, beginning of period (Advanced Approaches)$25,521 $28,998 
Net decrease in qualifying subordinated debt(392)(3,417)
Net decrease in excess of eligible credit reserves over expected credit losses(618)(799)
Other(73)(344)
Net decrease in Tier 2 Capital (Advanced Approaches)$(1,083)$(4,560)
Tier 2 Capital, end of period (Advanced Approaches)$24,438 $24,438 
Total Capital, end of period (Advanced Approaches)$194,006 $194,006 



In millions of dollarsThree Months Ended December 31, 2019Twelve Months Ended 
 December 31, 2019
Common Equity Tier 1 Capital, beginning of period$138,581
$139,252
Net income4,979
19,401
Common and preferred stock dividends declared(1,401)(5,512)
 Net increase in treasury stock(5,119)(17,290)
Net change in common stock and additional paid-in capital92
(98)
Net change in foreign currency translation adjustment net of hedges, net of tax972
(321)
Net change in unrealized gains (losses) on debt securities AFS, net of tax(160)1,985
Net change in defined benefit plans liability adjustment, net of tax15
(552)
Net change in adjustment related to change in fair value of financial liabilities
    attributable to own creditworthiness, net of tax
82
123
Net change in ASC 815—excluded component of fair value hedges(27)25
Net decrease in goodwill, net of related DTLs432
712
Net decrease in identifiable intangible assets other than MSRs, net of related DTLs45
315
Net decrease in defined benefit pension plan net assets187
3
 Net increase in DTAs arising from net operating loss, foreign tax credit and
      general business credit carry-forwards
(883)(385)
Other3
140
Net decrease in Common Equity Tier 1 Capital$(783)$(1,454)
Common Equity Tier 1 Capital, end of period
    (Standardized Approach and Advanced Approaches)
$137,798
$137,798
Additional Tier 1 Capital, beginning of period$19,452
$18,870
Net decrease in qualifying perpetual preferred stock(1,493)(464)
Net increase in qualifying trust preferred securities
5
Net change in permitted ownership interests in covered funds49
(410)
Other(1)6
Net decrease in Additional Tier 1 Capital$(1,445)$(863)
Tier 1 Capital, end of period
    (Standardized Approach and Advanced Approaches)
$155,805
$155,805
Tier 2 Capital, beginning of period (Standardized Approach)$38,321
$37,318
Net change in qualifying subordinated debt(408)349
Net change in eligible allowance for credit losses(46)187
Other10
23
Net change in Tier 2 Capital (Standardized Approach)$(444)$559
Tier 2 Capital, end of period (Standardized Approach)$37,877
$37,877
Total Capital, end of period (Standardized Approach)$193,682
$193,682
Tier 2 Capital, beginning of period (Advanced Approaches)$25,963
$25,022
Net change in qualifying subordinated debt(408)349
Net change in excess of eligible credit reserves over expected credit losses(33)138
Other10
23
Net change in Tier 2 Capital (Advanced Approaches)$(431)$510
Tier 2 Capital, end of period (Advanced Approaches)$25,532
$25,532
Total Capital, end of period (Advanced Approaches)$181,337
$181,337



36



Citigroup Risk-Weighted Assets Rollforward (Basel III Standardized Approach)
In millions of dollarsThree months ended December 31, 2021Twelve months ended
December 31, 2021
Total Risk-Weighted Assets, beginning of period$1,284,316 $1,242,381 
Changes in Credit Risk-Weighted Assets
General credit risk exposures(1,475)(1,775)
Repo-style transactions(1)
(15,160)(9,737)
Securitization exposures(2)
(1,306)3,593 
Equity exposures(340)494 
Over-the-counter (OTC) derivatives(3)
(22,954)3,224 
Other exposures(4)
(7,167)15,112 
Off-balance sheet exposures(3,208)3,124 
Net change in Credit Risk-Weighted Assets$(51,610)$14,035 
Changes in Market Risk-Weighted Assets
Risk levels$(4,108)$(21,499)
Model and methodology updates(9,423)(15,742)
Net decrease in Market Risk-Weighted Assets(5)
$(13,531)$(37,241)
Total Risk-Weighted Assets, end of period$1,219,175 $1,219,175 
In millions of dollarsThree Months Ended December 31, 2019Twelve Months Ended 
 December 31, 2019
 Total Risk-Weighted Assets, beginning of period$1,197,050
$1,174,448
Changes in Credit Risk-Weighted Assets  
General credit risk exposures(1)
2,821
10,376
Repo-style transactions(2)
(19,681)(7,420)
Securitization exposures(277)980
Equity exposures(3)
1,590
5,013
Over-the-counter (OTC) derivatives(4)
(13,283)(6,669)
Other exposures(5)
4,639
9,290
Off-balance sheet exposures(6)
(2,618)(12,802)
Net decrease in Credit Risk-Weighted Assets$(26,809)$(1,232)
Changes in Market Risk-Weighted Assets  
Risk levels(7)
$(4,718)$(6,847)
Model and methodology updates1,000
154
Net decrease in Market Risk-Weighted Assets$(3,718)$(6,693)
Total Risk-Weighted Assets, end of period$1,166,523
$1,166,523


(1)General credit risk exposures include cash and balances due from depository institutions, securities, and loans and leases. General credit risk exposures increased during the three and 12 months ended December 31, 2019, mainly driven by growth in commercial and retail loans and increases in investment securities.
(2)(1)Repo-style transactions include repurchase and reverse repurchase transactions as well as securities borrowing and securities lending transactions. Repo-style transactions decreased during the three and 12 months ended December 31, 2019, driven by volume reduction and matured deals.
(3)Equity exposures increased during the three months ended December 31, 2019, primarily due to increased exposures from existing investments. Equity exposures increased during the 12 months ended December 31, 2019, primarily due to an increase in market value of investments and increased exposures from existing investments.
(4)OTC derivatives decreased during the three and 12 months ended December 31, 2019, primarily due to decreases in notionals.
(5)
Other exposures include cleared transactions, unsettled transactions and other assets. Other exposures increased during the three months ended December 31, 2019, primarily due to increases in centrally cleared derivatives and various other assets. Other exposures increased during the 12 months ended December 31, 2019, primarily due to the recognition of right-of-use (ROU) assets in accordance with the adoption of ASU No. 2016-02, Leases (Topic 842), effective January 1, 2019, as well as increases in centrally cleared derivatives and various other assets.
(6)Off-balance sheet exposures decreased during the three months ended December 31, 2019, primarily due to a decrease in standby letters of credit. Off-balance sheet exposures decreased during the 12 months ended December 31, 2019, primarily due to decreases in standby letters of credit and loan commitments.
(7)Risk levels decreased during the three months ended December 31, 2019, primarily due to a decrease in exposure levels subject to Stressed Value at Risk and Incremental Risk charges. Risk levels decreased during the 12 months ended December 31, 2019, primarily due to a decrease in exposure levels subject to Stressed Value at Risk. 

As set forth in the table above, total risk-weighted assets under the Basel III Standardized Approach decreased from year-end 2018, due to decreases in market risk-weighted assetsthree months and credit risk-weighted assets. Market risk-weighted assets decreased from year-end 201812 months ended December 31, 2021, primarily due to a net reductionexposure-driven decreases.
(2)Securitization exposures increased during the 12 months ended December 31, 2021, primarily due to increases in exposure levels. The decrease in credit risk-weighted assets wasnew deals.
(3)OTC derivatives decreased during the three months ended December 31, 2021, primarily due to decreases in standby letters of creditmark-to-market and loan commitments as well as volume reduction and matured dealsnotional movement. OTC derivatives increased during the 12 months ended December 31, 2021, primarily due to increases in repo-stylemark-to-market for bilateral derivatives.
(4)Other exposures include cleared transactions, unsettled transactions, and changesother assets. Other exposures decreased during the three months ended December 31, 2021 primarily due to decreases in OTC derivative trade activity, partially offset bycleared transactions. Other exposures increased during the 12 months ended December 31, 2021 primarily due to increases in loan exposures,various other assets.
(5)Market risk-weighted assets decreased during the recognition of right-of-use (ROU) assets in accordance with the adoption of ASU No. 2016-02, Leases (Topic 842), effective January 1, 2019,three months and an increase in market value of investments.12 months ended December 31, 2021, primarily due to exposure changes.





37













Citigroup Risk-Weighted Assets Rollforward (Basel III Advanced Approaches)
In millions of dollarsThree months ended December 31, 2021Twelve months ended
December 31, 2021
Total Risk-Weighted Assets, beginning of period$1,265,297 $1,278,977 
Changes in Credit Risk-Weighted Assets
Retail exposures(1)
(8,043)(13,426)
Wholesale exposures(2)
(8,408)(10,630)
Repo-style transactions2,516 (3,861)
Securitization exposures(3)
528 5,816 
Equity exposures(253)206 
Over-the-counter (OTC) derivatives(4)
(8,465)(510)
Derivatives CVA(5)
(5,988)(2,715)
Other exposures(6)
(1,646)7,003 
Supervisory 6% multiplier(1,426)(1,098)
Net decrease in Credit Risk-Weighted Assets$(31,185)$(19,215)
Changes in Market Risk-Weighted Assets
Risk levels$(5,320)$(21,805)
Model and methodology updates(9,422)(15,742)
Net decrease in Market Risk-Weighted Assets(7)
$(14,742)$(37,547)
Net decrease in Operational Risk-Weighted Assets(8)
$(9,996)$(12,841)
Total Risk-Weighted Assets, end of period$1,209,374 $1,209,374 
In millions of dollarsThree Months Ended December 31, 2019Twelve Months Ended 
 December 31, 2019
 Total Risk-Weighted Assets, beginning of period$1,145,091
$1,131,933
Changes in Credit Risk-Weighted Assets  
Retail exposures(1)
6,140
4,959
Wholesale exposures(2)
(3,007)(9,288)
Repo-style transactions(3)
(8,761)(3,184)
Securitization exposures(4)
153
5,889
Equity exposures(5)
1,764
4,924
Over-the-counter (OTC) derivatives(6)
(2,992)8,508
Derivatives CVA(7)
(6,651)(15,034)
Other exposures(8)
8,394
14,282
Supervisory 6% multiplier101
1,565
Net change in Credit Risk-Weighted Assets$(4,859)$12,621
Changes in Market Risk-Weighted Assets  
Risk levels(9)
$(4,808)$(6,824)
Model and methodology updates1,000
154
Net decrease in Market Risk-Weighted Assets$(3,808)$(6,670)
Net decrease in Operational Risk-Weighted Assets(10)
$(871)$(2,331)
Total Risk-Weighted Assets, end of period$1,135,553
$1,135,553


(1)Retail exposures increased during the three months ended December 31, 2019, primarily due to seasonal spending for qualifying revolving (cards) exposures. Retail exposures increased during the 12 months ended December 31, 2019, primarily due to increases in consumer loans, partially offset by decreases due to annual parameter updates.
(2)Wholesale exposures decreased during the three months ended December 31, 2019, primarily due to decreases in commercial loans partially offset by increases in investment securities. Wholesale exposures decreased during the 12 months ended December 31, 2019, primarily due to annual model parameter updates reflecting Citi’s loss experience, partially offset by increases in commercial loans and investment securities.
(3)Repo-style transactions include repurchase and reverse repurchase transactions as well as securities borrowing and securities lending transactions. Repo-style transactions decreased during the three and 12 months ended December 31, 2019, driven by volume reduction and matured deals.
(4)Securitization exposures increased during the 12 months ended December 31, 2019, due to increased exposures from existing deals.
(5)Equity exposures increased during the three months ended December 31, 2019, primarily due to increased exposures from existing investments. Equity exposures increased during the 12 months ended December 31, 2019, primarily due to an increase in market value of investments and increased exposures from existing investments.
(6)OTC derivatives decreased during the three months ended December 31, 2019, primarily due to a reduction in notionals. OTC derivatives increased during the 12 months ended December 31, 2019, primarily due to approved model changes, partially offset by a reduction in notionals.
(7)Derivatives CVA decreased during the three months ended December 31, 2019, primarily due to exposure decreases and changes in credit spreads. Derivatives CVA decreased during the 12 months ended December 31, 2019, primarily due to approved model changes, exposure decreases and changes in credit spreads.
(8)
Other exposures include cleared transactions, unsettled transactions, assets other than those reportable in specific exposure categories and non-material portfolios. Other exposures increased during the three months ended December 31, 2019, primarily due to increases in centrally cleared derivatives and various other assets. Other exposures increased during the 12 months ended December 31, 2019, primarily due to the recognition of ROU assets in accordance with the adoption of ASU No. 2016-02, (1)Retail exposures decreased during the three months ended December 31, 2021, primarily driven by model recalibrations. Retail exposures decreased during the 12 months ended December 31, 2021, primarily driven by seasonal holiday spending repayments, less spending on qualifying revolving (card) exposures and model recalibrations.Leases (Topic 842), effective January 1, 2019, and increases in centrally cleared derivatives and various other assets.
(9)Risk levels decreased during the three months ended December 31, 2019, primarily due to a decrease in exposure levels subject to Stressed Value at Risk and Incremental Risk charges. Risk levels decreased during the 12 months ended December 31, 2019, primarily due to a decrease in exposure levels subject to Stressed Value at Risk. 
(10)Operational risk-weighted assets decreased during the 12 months ended December 31, 2019, primarily due to changes in operational loss severity and frequency.

As set forth in(2)Wholesale exposures decreased during the table above, total risk-weighted assets under the Basel III Advanced Approaches increased from year-end 2018three months and 12 months ended December 31, 2021, primarily due to an increasereductions in credit risk-weighted assets, partially offset by decreases in marketcommercial loans and operational risk-weighted assets. The increase in credit risk-weighted assets waswholesale loan commitments.
(3)Securitization exposures increased during the 12 months ended December 31, 2021, primarily due to recognition of ROU assetsincreases in accordance with the adoption of ASU 2016-02, changes in new deals.
(4)OTC derivatives trade activitiesdecreased during the three months ended December 31,2021, primarily due to decreases in mark-to-market and notional movement.
(5)Derivatives CVA decreased during the three months ended December 31, 2021, primarily due to decreases in exposure and volatility, as well as lower credit spreads and sensitivity.
(6)Other exposures increased during the 12 months ended December 31, 2021, primarily due to increases in securitization exposures, loan exposures and equity exposures, partially offset by decreases in derivatives CVA and wholesale exposures mainly due to annual model parameter updates. various other assets.
(7)Market risk-weighted assets decreased from year-end 2018,during the three months and 12 months ended December 31, 2021, primarily due to a net reduction in exposure levels. The
changes.
decrease in operational(8)Operational risk-weighted assets wasdecreased during the three months and 12 months ended December 31, 2021, primarily due to changes in operational loss severity and frequency.
38



Supplementary Leverage Ratio
The following table sets forth Citi’s Supplementary Leverage ratio and related components as of December 31, 2019,2021, September 30, 20192021 and December 31, 2018:2020:

In millions of dollars, except ratiosDecember 31, 2021September 30, 2021December 31, 2020
Tier 1 Capital$169,568 $168,902 $167,053 
Total Leverage Exposure
On-balance sheet assets(1)(2)(3)
$2,389,237 $2,349,414 $1,864,374 
Certain off-balance sheet exposures:(4)
Potential future exposure on derivative contracts222,241 222,157 186,959 
Effective notional of sold credit derivatives, net(5)
23,788 21,987 32,640 
Counterparty credit risk for repo-style transactions(6)
25,775 21,174 20,965 
Unconditionally cancelable commitments70,196 70,541 71,163 
Other off-balance sheet exposures264,330 263,361 253,754 
Total of certain off-balance sheet exposures$606,330 $599,220 $565,481 
Less: Tier 1 Capital deductions37,803 37,584 38,822 
Total Leverage Exposure(3)
$2,957,764 $2,911,050 $2,391,033 
Supplementary Leverage ratio5.73 %5.80 %6.99 %
In millions of dollars, except ratiosDecember 31, 2019September 30, 2019December 31, 2018
Tier 1 Capital$155,805
$158,033
$158,122
Total Leverage Exposure   
On-balance sheet assets(1)
$1,996,617
$2,000,082
$1,936,791
Certain off-balance sheet exposures:(2)
   
   Potential future exposure on derivative contracts169,478
176,546
187,130
   Effective notional of sold credit derivatives, net(3)
38,481
41,328
49,402
   Counterparty credit risk for repo-style transactions(4)
23,715
24,362
23,715
   Unconditionally cancelable commitments70,870
70,648
69,630
   Other off-balance sheet exposures248,308
246,793
238,805
Total of certain off-balance sheet exposures$550,852
$559,677
$568,682
Less: Tier 1 Capital deductions39,578
39,407
39,832
Total Leverage Exposure$2,507,891
$2,520,352
$2,465,641
Supplementary Leverage ratio6.21%6.27%6.41%


(1)Represents the daily average of on-balance sheet assets for the quarter.
(1)Represents the daily average of on-balance sheet assets for the quarter.
(2)Represents the average of certain off-balance sheet exposures calculated as of the last day of each month in the quarter.
(3)Under the U.S. Basel III rules, banking organizations are required to include in Total Leverage Exposure the effective notional amount of sold credit derivatives, with netting of exposures permitted if certain conditions are met.
(4)Repo-style transactions include repurchase or reverse repurchase transactions as well as securities borrowing or securities lending transactions.
(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 were deferred and commenced phase-in to regulatory capital at 25% per year beginning January 1, 2022. For the ongoing impact of CECL, Citigroup was allowed to adjust the ACL in an amount equal to 25% of the change in the ACL (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 have also commenced phase in to regulatory capital at 25% per year beginning 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 and continuing through the first quarter of 2021, Citigroup’s Total Leverage Exposure temporarily excluded 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 6.2%5.7% at December 31, 2019,2021, compared to 6.3%5.8% at September 30, 20192021 and 6.4%7.0% at December 31, 2018.2020. The quarter-over-quarter decrease was primarily driven by a reductionan increase in Tier 1 Capital resulting from the return of $6.2 billion of capital to common shareholders and a preferred stock redemption, Total Leverage Exposure, primarily driven by an increase in average on-balance sheet assets, as well as adverse net movements in AOCI,partially offset by net income and beneficial net movements in AOCI, as well as a decrease in average off-balance sheet exposures.the quarter. The year-over-year decrease was primarily driven by a reduction in Tier 1 Capital resulting from the return of $22.3 billion of capital to common shareholders, as well as an increase in average on-balance sheet assets, partially offset by net income and beneficial net movements in AOCI, as well as a decrease in average off-balance sheet exposures.Total Leverage Exposure, largely due to an approximate 100 basis point impact from the expiration of the Federal Reserve Board’s temporary Supplementary Leverage ratio relief. For additional information, see “Temporary Supplementary Leverage Ratio Relief” above.




Capital Resources of Citigroup’s Subsidiary U.S.
Depository Institutions
Citigroup’s subsidiary U.S. depository institutions are also subject to regulatory capital standards issued by their respective primary federal bank regulatory agencies, which are similar to the standards of the Federal Reserve Board.
39


The following tables set forth the capital components and ratios for Citibank, Citi’s primary subsidiary U.S. depository
institution, as of December 31, 2019,2021, September 30, 20192021 and December 31, 2018:2020:





Advanced Approaches(8)
Standardized Approach(8)
In millions of dollars, except ratios
Effective Minimum Requirement(1)
December 31, 2021September 30, 2021December 31, 2020December 31, 2021September 30, 2021December 31, 2020
Common Equity Tier 1 Capital(2)
$148,548 $147,459 $142,854 $148,548 $147,459 $142,854 
Tier 1 Capital150,679 149,588 144,962 150,679 149,588 144,962 
Total Capital (Tier 1 Capital + Tier 2 Capital)(2)(3)
166,921 166,196 161,447 175,427 174,745 169,449 
Total Risk-Weighted Assets1,017,774 1,067,406 1,047,088 1,066,015 1,107,021 1,054,056 
Credit Risk(2)
$737,802 $761,259 $737,953 $1,016,293 $1,048,581 $989,222 
Market Risk48,089 55,566 63,984 49,722 58,440 64,834 
Operational Risk231,883 250,581 245,151  — — 
Common Equity Tier 1 Capital ratio(4)(5)
7.0 %14.60 %13.81 %13.64 %13.93 %13.32 %13.55 %
Tier 1 Capital ratio(4)(5)
8.5 14.80 14.01 13.84 14.13 13.51 13.75 
Total Capital ratio(4)(5)
10.5 16.40 15.57 15.42 16.46 15.79 16.08 
 
Effective Minimum Requirement(1)
Advanced ApproachesStandardized Approach
In millions of dollars, except ratios20192018Dec. 31, 2019Sept. 30, 2019Dec. 31, 2018Dec. 31, 2019Sept. 30, 2019Dec. 31, 2018
Common Equity Tier 1 Capital  $130,791
$130,067
$129,091
$130,791
$130,067
$129,091
Tier 1 Capital  132,918
132,198
131,215
132,918
132,198
131,215
Total Capital (Tier 1 Capital + Tier 2 Capital)(2)
  145,989
144,829
144,358
157,324
155,735
155,154
Total Risk-Weighted Assets  932,432
946,433
926,229
1,019,916
1,047,550
1,032,809
   Credit Risk  $664,828
$664,014
$654,962
$990,319
$1,005,337
$994,294
   Market Risk  29,167
41,867
38,144
29,597
42,213
38,515
   Operational Risk  238,437
240,552
233,123



Common Equity Tier 1 Capital ratio(3)(4)
7.0%6.375%14.03%13.74%13.94%12.82%12.42%12.50%
Tier 1 Capital ratio(3)(4)
8.57.87514.26
13.97
14.17
13.03
12.62
12.70
Total Capital ratio(3)(4)
10.59.87515.66
15.30
15.59
15.43
14.87
15.02
In millions of dollars, except ratiosEffective Minimum RequirementDecember 31, 2021September 30, 2021December 31, 2020
Quarterly Adjusted Average Total Assets(2)(6)
$1,716,596 $1,682,993 $1,667,105 
Total Leverage Exposure(2)(7)
2,236,839 2,205,471 2,172,052 
Tier 1 Leverage ratio(5)
5.0%8.78 %8.89 %8.70 %
Supplementary Leverage ratio(5)
6.06.74 6.78 6.67 

(1)For all periods presented, 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 were deferred and have commenced phase-in to regulatory capital at 25% per year beginning on January 1, 2022. For the ongoing impact of CECL, Citibank was allowed to adjust retained earnings and the ACL in an amount equal to 25% of the change in the ACL (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 have also commenced phase-in to regulatory capital at 25% per year beginning 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 were deducted from risk-weighted assets (RWA) and commenced phase-in to RWA at 25% per year beginning 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 Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the Basel III Standardized Approach, whereas Total Capital ratio was derived under the Basel III Advanced Approaches 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.
(8)Certain of the above prior-period amounts have been revised to conform with enhancements made in the current period.


In millions of dollars, except ratiosEffective Minimum RequirementDec. 31, 2019Sept. 30, 2019Dec. 31, 2018
Quarterly Adjusted Average Total Assets(5)
 $1,459,851 $1,451,352 $1,398,875 
Total Leverage Exposure(6) 
 1,951,701 1,952,628 1,914,663 
Tier 1 Leverage ratio(4)
4.0%9.10%9.11%9.38%
Supplementary Leverage ratio(4)
6.06.81 6.77 6.85 

(1)Citibank’s effective minimum risk-based capital requirements during 2019 and 2018 are inclusive of the 100% and 75% phase-in, respectively, of the 2.5% Capital Conservation Buffer (all of which must be composed of Common Equity Tier 1 Capital).
(2)Under the Advanced Approaches framework, eligible credit reserves that exceed expected credit losses are eligible for inclusion in Tier 2 Capital to the extent that the excess reserves do not exceed 0.6% of credit risk-weighted assets, which differs from the Standardized Approach in which the allowance for credit losses is eligible for inclusion in Tier 2 Capital up to 1.25% of credit risk-weighted assets, with any excess allowance for credit losses being deducted in arriving at credit risk-weighted assets.
(3)Citibank’s reportable Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios were the lower derived under the Basel III Standardized Approach for all periods presented.
(4)Citibank must maintain minimum Common Equity Tier 1 Capital, Tier 1 Capital, Total Capital and Tier 1 Leverage ratios of 6.5%, 8.0%, 10.0% and 5.0%, respectively, to be considered “well capitalized” under the revised Prompt Corrective Action (PCA) regulations applicable to insured depository institutions as established by the U.S. Basel III rules. Citibank must also maintain a minimum Supplementary Leverage ratio of 6.0% to be considered “well capitalized.”
(5)Tier 1 Leverage ratio denominator. Represents quarterly average total assets less amounts deducted from Tier 1 Capital.
(6)Supplementary Leverage ratio denominator.

As indicated in the table above, Citibank’s capital ratios at December 31, 20192021 were in excess of the stated and effective minimum requirements under the U.S. Basel III rules. In addition, Citibank was also “well capitalized” as of December 31, 2019.2021.


40



Impact of Changes on Citigroup and Citibank Capital Ratios
The following tables present the estimated sensitivity of Citigroup’s and Citibank’s capital ratios to changes of $100 million in Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital (numerator), and changes of $1 billion in Advanced Approaches and Standardized Approach risk-weighted assets and quarterly adjusted average total assets, as well as Total Leverage Exposure (denominator), as of December 31, 2019.2021. 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 ratioTotal Capital ratio
In basis points
Impact of
$100 million
change in
Common Equity
Tier 1 Capital
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
Citigroup
Advanced Approaches0.81.00.81.20.81.3
Standardized Approach0.81.00.81.10.81.4
Citibank
Advanced Approaches1.01.41.01.51.01.6
Standardized Approach0.91.30.91.30.91.5
 
Common Equity
Tier 1 Capital ratio
Tier 1 Capital ratioTotal Capital ratio
In basis points
Impact of
$100 million
change in
Common Equity
Tier 1 Capital
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
Citigroup      
Advanced Approaches0.91.10.91.20.91.4
Standardized Approach0.91.00.91.10.91.4
Citibank      
Advanced Approaches1.11.51.11.51.11.7
Standardized Approach1.01.31.01.31.01.5
Tier 1 Leverage ratioSupplementary Leverage ratio
In basis points
Impact of
$100 million
change in
Tier 1 Capital
Impact of
$1 billion
change in quarterly adjusted average total assets
Impact of
$100 million
change in
Tier 1 Capital
Impact of
$1 billion
change in Total Leverage Exposure
Citigroup0.40.30.30.2
Citibank0.60.50.40.3

 Tier 1 Leverage ratioSupplementary Leverage ratio
In basis points
Impact of
$100 million
change in
Tier 1 Capital
Impact of
$1 billion
change in quarterly adjusted average total assets
Impact of
$100 million
change in
Tier 1 Capital
Impact of
$1 billion
change in Total Leverage Exposure
Citigroup0.50.40.40.2
Citibank0.70.60.50.3

Citigroup Broker-Dealer Subsidiaries
At December 31, 2019,2021, Citigroup Global Markets Inc., a U.S. broker-dealer registered with the SEC that is an indirect wholly owned subsidiary of Citigroup, had net capital, computed in accordance with the SEC’s net capital rule, of $10.1$13 billion, which exceeded the minimum requirement by $6.9$8 billion.
Moreover, Citigroup Global Markets Limited, a broker-dealer registered with the United Kingdom’s Prudential Regulation Authority (PRA) that is also an indirect wholly owned subsidiary of Citigroup, had total capital of $21.4$28 billion at December 31, 2019,2021, which exceeded the PRA'sPRA’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,operate, including requirements to maintain specified levels of net capital or its equivalent. Citigroup’s other principal broker-dealer subsidiaries were in compliance with their regulatory capital requirements at December 31, 2019.2021.

41



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 2021). Accordingly, Citi’s
total current minimum TLAC requirement was 22.5% of RWA for 2021.

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 2021), 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 long-term debt (LTD)LTD ratio requirement, as well as the surplus amount in dollars in excess of each requirement.

December 31, 2021
In billions of dollars, except ratiosExternal TLACLTD
Total eligible amount$318 $143 
% of Standardized Approach risk-
weighted assets
26.1 %11.7 %
Effective minimum requirement(1)(2)
22.5 9.0 
Surplus amount$44 $33 
% of Total Leverage Exposure10.8 %4.8 %
Effective minimum requirement9.5 4.5 
Surplus amount$37 $10 

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

As of December 31, 2019,2021, Citi exceeded each of the
minimum TLAC and LTD requirements, resulting in a $14 $10
billion surplus above its binding TLAC requirement of LTD as
a percentage of Total Leverage Exposure.
 December 31, 2019
In billions of dollars, except ratios
External TLAC

LTD
Total eligible amount$289
$127
% of Standardized Approach risk-
  weighted assets
24.7%10.9%
Effective minimum requirement(1)(2)
22.5
9.0
Surplus amount$26
$22
% of Total Leverage Exposure11.5%5.1%
Effective minimum requirement9.5
4.5
Surplus amount$50
$14

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

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

Regulatory
Capital Treatment—ImplementationResources (Full Adoption of CECL)(1)
The following tables set forth Citigroup’s and TransitionCitibank’s capital components and ratios had the full impact of CECL been adopted as of December 31, 2021:

CitigroupCitibank
Effective Minimum Requirement, Advanced Approaches
Effective Minimum Requirement, Standardized Approach(2)
Advanced ApproachesStandardized Approach
Effective Minimum Requirement(3)
Advanced ApproachesStandardized Approach
Common Equity Tier 1 Capital ratio10.0 %10.5 %12.10 %12.01 %7.0 %14.32 %13.68 %
Tier 1 Capital ratio11.5 12.0 13.78 13.68 8.5 14.53 13.88 
Total Capital ratio13.5 14.0 15.86 16.49 10.5 16.15 16.21 
Effective Minimum RequirementCitigroupEffective Minimum RequirementCitibank
Tier 1 Leverage ratio4.0 %7.09 %5.0 %8.62 %
Supplementary Leverage ratio5.0 5.646.0 6.61

(1)See footnote 2 on the “Components of Citigroup Capital” table above.
(2)The effective minimum requirements were applicable as of December 31, 2021. See “Stress Capital Buffer” above for additional information.
(3)Citibank’s effective minimum requirements were the same under the Standardized Approach and the Advanced Approaches Framework.


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Adoption of the Current ExpectedStandardized Approach for Counterparty Credit Losses (CECL) MethodologyRisk
In February 2019,January 2020, the U.S. banking agencies issued a final rule that provides banking organizations an optional phase-in over a three-year periodto introduce the Standardized Approach for Counterparty Credit Risk (SA-CCR). SA-CCR replaced the Current Exposure Method (CEM), which was the previous methodology used to calculate exposure for all derivative contracts under the Standardized Approach, as well as RWA for derivative contracts under the Advanced Approaches in cases where internal models are not used. In addition, SA-CCR replaced CEM in numerous other instances throughout the regulatory framework, including but not limited to the Supplementary Leverage Ratio, certain components of the “Day One” adverse regulatory capital effects resulting from adoptionGSIB score, single counterparty credit limits and legal lending limits.
Under SA-CCR, a banking organization calculates the exposure amount of its derivative contracts at the netting set level. Multiple derivative contracts are generally considered to be under the same netting set as long as each derivative contract is subject to the same qualifying master netting agreement. SA-CCR also introduced the concept of hedging sets, which allows a banking organization to fully or partially net derivative contracts within the same netting set that share similar risk factors. Moreover, SA-CCR incorporated updated supervisory and maturity factors to calculate the potential future exposure of a derivative contract, and provides for improved recognition of collateral. Under the final rule, the exposure amount of a netting set is equal to an alpha factor of 1.4 multiplied by the sum of the CECL methodology.
The rule is in recognitionreplacement cost and potential future exposure of the issuance bynetting set.
Citi adopted SA-CCR as of the Financial Accounting Standards Board of ASU No. 2016-13, Financial Instruments—Credit Losses (Topic 326). The ASU introduces a new credit loss methodology, the CECL methodology, which requires earlier recognition of credit losses while also providing additional transparency about credit risk. The ASU was effective for Citi asmandatory compliance date of January 1, 2020. For additional information regarding Citi’s adoption2022. Adoption of the CECL methodology, see Note 1SA-CCR increased Citigroup’s Standardized RWA by approximately $51 billion, which resulted in a 49 bps decrease to the Consolidated Financial Statements.
Citi and Citibank have elected the transition provisions provided by the U.S. banking agencies’ rule. Accordingly, the “Day One” regulatory capital effects resulting from adoption of the CECL methodology commenced phase-in on January 1, 2020, and will be fully reflected in Citi’s regulatory capital as of January 1, 2023. Based on Citi’s regulatory capital position as of December 31, 2019, the estimated impact of adopting the CECL methodology would reduce Citi’sCitigroup’s Common Equity Tier 1 Capital ratio under the Standardized Approach by approximately 25 basis points in total, or approximately 6
basis points per yearApproaches on January 1, 2022. Citigroup’s reported CET1 Capital ratio under the Standardized Approach as of each year overDecember 31, 2021 was 12.25%, 75 bps above its 11.5% CET1 Capital target, and 175 bps above its 10.5% effective regulatory minimum CET1 Capital requirement under the transition period. The actual basis pointStandardized Approach.
Adoption of SA-CCR also increased Citigroup’s Advanced RWA by approximately $29 billion, which resulted in a 29 bps decrease to Citigroup’s Common Equity Tier 1 Capital ratio under the Advanced Approaches on January 1, 2022. Citigroup’s reported CET1 Capital ratio under the Advanced Approaches as of December 31, 2021 was 12.35%, 85 bps above its 11.5% CET1 Capital target, and 235 bps above its 10.0% effective regulatory minimum CET1 Capital requirement under the Advanced Approaches.
Citigroup voluntarily suspended share repurchases during the fourth quarter of 2021, in anticipation of the adverse impact of adopting CECL on Citi’s regulatory capital ratios may change, if Citi’s capital position changes over time.resulting from SA-CCR adoption. Citi resumed common share repurchases in January 2022.
The Federal Reserve Board has issued a statement that it plans to maintain its current framework for calculating allowances on loans in the supervisory stress test for the 2020 and 2021 supervisory stress test cycles, and to evaluate appropriate future enhancements to this framework as best practices for implementing CECL are developed. However, banking organizations are required to incorporate CECL into their stress testing methodologies, data and disclosure beginning in the cycle coinciding with their first full year of CECL adoption (2020 for Citi).

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

U.S. Banking Agencies

Standardized Approach for Counterparty Credit Risk
In November 2019, the U.S. banking agencies released a final rule to introduce the Standardized Approach for Counterparty Credit Risk (SA-CCR) in the U.S. SA-CCR will replace the Current Exposure Method (CEM), which is the current methodology used to calculate risk-weighted assets for all derivative contracts under the Standardized Approach, as well as risk-weighted assets for derivative contracts under the Advanced Approaches in cases where internal models are not used. In addition, SA-CCR would replace CEM in numerous other instances throughout the regulatory framework, including but not limited to the Supplementary Leverage Ratio, single counterparty credit limits and legal lending limits.
Under SA-CCR, a banking organization would calculate the exposure amount of its derivative contracts at the netting set level. Multiple derivative contracts would generally be considered to be under the same netting set as long as each derivative contract is subject to the same qualifying master netting agreement. SA-CCR also introduces the concept of hedging sets, which would allow a banking organization to fully or partially net derivative contracts within the same netting set that share similar risk factors. Moreover, SA-CCR incorporates updated supervisory and maturity factors to calculate the potential future exposure of a derivative contract, and provides for improved recognition of collateral. Under the proposal, the exposure amount of a netting set would be equal to an alpha factor of 1.4 multiplied by the sum of the replacement cost and potential future exposure of the netting set.

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

Stress Capital Buffer
In April 2018, the Federal Reserve Board issued a proposal that is designed to more closely integrate the results of the quantitative assessment in CCAR with firms’ ongoing minimum capital requirements under the U.S. Basel III rules.Revisions
Specifically, the proposed rule would replace the existing Capital Conservation Buffer, currently fixed at 2.5% under the U.S. Basel III rules, with (i) a variable buffer known as the Stress Capital Buffer (as described below), plus (ii) for U.S. GSIBs, the GSIB’s then-current GSIB surcharge, plus (iii) the Countercyclical Capital Buffer, if any. These three components would constitute the new Capital Conservation Buffer under the Standardized Approach. The Stress Capital Buffer (SCB) would be based upon the maximum decline in a bank holding company’s Common Equity Tier 1 Capital ratio under the severely adverse scenario of the supervisory stress test. Under the April 2018 proposal, the SCB would be subject to a floor of 2.5%.
The proposed rule would also modify certain assumptions currently required in supervisory stress tests, including continued capital distributions during the nine-quarter capital planning horizon and balance sheet growth assumptions.
A final rule has not yet been issued. Senior staff at the Federal Reserve Board have indicated publicly that they plan to finalize certain components of the proposal for application in the 2020 CCAR cycle, and that they may re-propose certain other elements of the proposal to better balance the need to preserve the dynamism of stress testing while reducing unnecessary volatility, among other things. Senior staff at the Federal Reserve Board have also indicated publicly that they are considering two options in place of the “dividend add-on,” which was a component of the SCB under the April 2018 proposal: setting the Countercyclical Capital Buffer at a higher baseline level during normal times, or raising the floor of the SCB higher than 2.5%. The potential re-proposal may also address certain other elements of the original proposal, such as the relative timing between stress testing results and the submission of a firm’s capital plan, and the consequences of breaching a buffer.

TLAC Holdings
In April 2019, the U.S. banking agencies released a proposal that would create a new regulatory capital deduction applicable to Advanced Approaches banking organizations for certain investments in covered debt instruments issued by GSIBs. The proposed rule is intended to reduce systemic risk by creating an incentive for Advanced Approaches banking organizations to limit their exposure to GSIBs.
Under the U.S. Basel III rules, investments in the capital of unconsolidated financial institutions are subject to deduction to the extent that they exceed certain thresholds.
Under the proposed rule, an investment in a “covered debt instrument” would be treated as an investment in a Tier 2 capital instrument and, therefore, would be subject to deduction from the Advanced Approaches banking organization’s own Tier 2 Capital in accordance with the existing rules for investments in unconsolidated financial institutions. Covered debt instruments would include unsecured debt instruments that are “eligible debt securities” for purposes of the TLAC rule, or that are pari passu or subordinated to such securities, in addition to certain unsecured debt instruments issued by foreign GSIBs.
To support a deep and liquid market for covered debt instruments, the proposed rule provides an exception from the approach described above for covered debt instruments held for 30 days or less for market-making purposes, if the aggregate amount of such debt instruments does not exceed 5% of the banking organization’s Common Equity Tier 1 Capital.
The proposed rule does not specify a proposed effective date for the new regulatory capital deduction. If adopted as proposed, Citi does not expect the proposed rule to have a material impact on its regulatory capital.

Basel Committee

Revisions to the Minimum Capital Requirements for
Market Risk
In January 2019, the Basel Committee issued a final standard that revises the market risk capital framework—the so-called Fundamental Review of the Trading Book, or FRTB. The final rule revises the assessment process under the Advanced Approaches to determine whether a bank’s internal risk management models appropriately reflect the risks of individual trading desks, and clarifies the requirements for identification of risk factors that are eligible for internal modeling. In addition, the risk weights for general interest rate risk and foreign exchange risk under the Standardized Approach have been recalibrated.
If the U.S. banking agencies were to adopt the Basel Committee’s revised market risk framework unchanged, Citi believes its market risk-weighted assets could increase significantly. The ultimate impact on Citi, however, will depend upon the specific provisions of any final rule.

Leverage Ratio Treatment of Client-Cleared Derivatives
In June 2019,As previously disclosed, the Basel Committee on Banking Supervision issued(Basel Committee) has finalized certain Basel III post-crisis regulatory reforms. The reforms relate to the methodologies in deriving credit, market and operational risk-weighted assets, the imposition of a final standard that revises its leverage ratio frameworknew aggregate output floor for risk-weighted assets, and revisions to align the leverage ratio measurement of client-cleared derivatives with the measurement as determined per the Basel Committee’s standardized approach for measuring counterparty credit risk exposures, as used for risk-based capital requirements. Under the Basel Committee’s leverage ratio framework, the leverage ratio exposure measure is generally not adjusted for physical or financial collateral, guarantees or other credit risk mitigation techniques, including initial margin received from clients. However, the final rule permits both cash and non-cash forms of initial margin and variation margin received from clients to mitigate replacement cost and potential future exposure for client-cleared

derivatives only. The Basel Committee stated in the rule that this revision balances the robustness of the leverage ratio as a non-risk-based safeguard against unsustainable sources of leverage with the policy objective of promoting central clearing of standardized derivative contracts.
In the U.S., the Basel Committee’s leverage ratio framework and leverage ratio exposure measure are most closely aligned with the Supplementary Leverage Ratio and Total Leverage Exposure, respectively. As part of the SA-CCR final rule discussed previously, the U.S. agencies amended the Supplementary Leverage Ratio requirements in a manner similar to the Basel Committee. This particular aspect of the U.S. SA-CCR final rule will likely benefit Citi’s Supplementary Leverage Ratio modestly upon implementation.

Credit Valuation Adjustment Risk—Targeted Revisions
In November 2019, the Basel Committee on Banking Supervision issued a consultative document that proposes a targeted set of revisions to the credit valuation adjustment (CVA) risk framework previously finalized in December 2017. The revisions aim to align the revised CVA risk framework, in part, with the revised market risk capital framework that was finalized in January 2019. The Basel Committee also sought feedback on a possible adjustment to the overall calibration of capital requirements calculated under their CVA risk framework.
The U.S. banking agencies may consider revisions to the CVA risk framework underrevise the U.S. Basel III rules in the future, based upon any revisions adopted byin response to the Basel Committee.Committee’s Basel III post-crisis regulatory reforms. For information about risks related to changes in regulatory capital requirements, see “Risk Factors—Strategic Risks.” below.

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Tangible Common Equity, Book Value Per Share, Tangible Book Value Per Share and ReturnsReturn on Equity
Tangible common equity (TCE), as defined by Citi, represents common stockholders’ equity less goodwill and identifiable intangible assets (other than MSRs)mortgage servicing rights (MSRs)). Other companies may calculate TCE inRoTCE represents net income available to common shareholders as a different manner. TCE, tangiblepercentage of average TCE. Tangible book value (TBV) per share and return on averagerepresents TCE divided by common shares outstanding. These measures are non-GAAP financial measures. Other companies may calculate these measures in a different manner. Citi believes the presentation of TCE, TBV per share and return on average TCE providesRoTCE provide alternate measures of capital strength and performance that are commonly used byfor investors, industry analysts and industry analysts.others.

At December 31,
In millions of dollars or shares, except per share amounts20212020201920182017
Total Citigroup stockholders’ equity$201,972 $199,442 $193,242 $196,220 $200,740 
Less: Preferred stock18,995 19,480 17,980 18,460 19,253 
Common stockholders’ equity$182,977 $179,962 $175,262 $177,760 $181,487 
Less:
Goodwill21,299 22,162 22,126 22,046 22,256 
Identifiable intangible assets (other than MSRs)4,091 4,411 4,327 4,636 4,588 
Goodwill and identifiable intangible assets
(other than MSRs) related to assets held-for-sale (HFS)
510 — — — 32 
Tangible common equity (TCE)$157,077 $153,389 $148,809 $151,078 $154,611 
Common shares outstanding (CSO)1,984.4 2,082.1 2,114.1 2,368.5 2,569.9 
Book value per share (common stockholders’ equity/CSO)$92.21 $86.43 $82.90 $75.05 $70.62 
Tangible book value per share (TCE/CSO)79.16 73.67 70.39 63.79 60.16 
For the year ended December 31,
In millions of dollars2021202020192018
2017(1)
Net income available to common shareholders$20,912 $9,952 $18,292 $16,871 $14,583 
Average common stockholders’ equity182,421 175,508 177,363 179,497 207,747 
Average TCE156,253 149,892 150,994 153,343 180,458 
Return on average common stockholders’ equity11.5 %5.7 %10.3 %9.4 %7.0 %
Return on average TCE (RoTCE)13.4 6.6 12.1 11.0 8.1 

(1)Year ended December 31, 2017 excludes the one-time impact of Tax Reform. For a reconciliation of these amounts, see “Significant Accounting Policies and Significant Estimates—Income Taxes” below.



 At December 31,
In millions of dollars or shares, except per share amounts20192018201720162015
Total Citigroup stockholders’ equity$193,242
$196,220
$200,740
$225,120
$221,857
Less: Preferred stock17,980
18,460
19,253
19,253
16,718
Common stockholders’ equity$175,262
$177,760
$181,487
$205,867
$205,139
Less:     
    Goodwill22,126
22,046
22,256
21,659
22,349
    Identifiable intangible assets (other than MSRs)4,327
4,636
4,588
5,114
3,721
    Goodwill and identifiable intangible assets (other than
      MSRs) related to assets held-for-sale (HFS)


32
72
68
Tangible common equity (TCE)$148,809
$151,078
$154,611
$179,022
$179,001
Common shares outstanding (CSO)2,114.1
2,368.5
2,569.9
2,772.4
2,953.3
Book value per share (common equity/CSO)$82.90
$75.05
$70.62
$74.26
$69.46
Tangible book value per share (TCE/CSO)70.39
63.79
60.16
64.57
60.61
 For the Year Ended December 31,
In millions of dollars20192018
2017(1)
20162015
Net income available to common shareholders$18,292
$16,871
$14,583
$13,835
$16,473
Average common stockholders’ equity177,363
179,497
207,747
209,629
204,188
Average TCE150,994
153,343
180,458
182,135
176,505
Return on average common stockholders’ equity10.3%9.4%7.0%6.6%8.1%
Return on average TCE (RoTCE)(2)
12.1
11.0
8.1
7.6
9.3

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(1)Year ended December 31, 2017 excludes the one-time impact of Tax Reform. For a reconciliation of these measures, see “Significant Accounting Policies and Significant Estimates—Income Taxes” below.
(2)RoTCE represents net income available to common shareholders as a percentage of average TCE.






RISK FACTORS

The following discussion sets forth what management currently believes could be the most significantmaterial 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 that Citi may face. For additional information about risks and uncertainties that could impact Citi, see “Executive Summary” and each respective business’ results of operations above and “Managing Global Risk” below. The following risk factors are categorized to improve the readability and usefulness of the risk factor disclosure, and, while the headings and risk factors generally align with Citi’s risk categorization, in certain instances the risk factors may not directly correspond with how Citi categorizes or manages its risks.

MARKET-RELATED 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 below), 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, the recent action of Russian military forces and support personnel in Ukraine has escalated tensions between Russia and the U.S., NATO, the EU and the U.K. The U.S. has imposed, and is likely to impose material additional, financial and economic sanctions and export controls against certain Russian organizations and/or individuals, with similar actions either implemented or planned by the EU and the U.K. and other jurisdictions. During the week of February 21, 2022, the U.S., the U.K., and the EU each imposed packages of financial and economic sanctions that, in various ways, constrain transactions with numerous Russian entities and individuals; transactions in Russian sovereign debt; and investment, trade, and financing to, from, or in certain regions of Ukraine. Citi’s ability to engage in activity with certain consumer and institutional businesses in Russia and Ukraine or involving certain Russian or Ukrainian businesses and customers is dependent in part upon whether such engagement is restricted under any current or expected U.S., EU and other countries or U.K. sanctions and laws. Sanctions and export controls, as well as any actions by Russia, could adversely affect Citi’s business activities and customers in and from Russia and Ukraine. Moreover, actions by Russia, and any further measures taken by the U.S. or its allies, could have negative impacts on regional and global financial markets and economic conditions. For additional information about these and other related risks, see the operational processes and systems, cybersecurity and emerging markets risk factors below. For additional information about Citi’s exposures in
Russia, see “Managing Global Risk—Other Risks—Country Risk—Russia” below.
Additionally, 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. Further, it remains uncertain to what extent central banks may keep interest rates low or whether central banks might raise interest rates or reduce the size of their balance sheets, particularly as inflationary pressures continue and the U.S. and global economies continue to improve. While earlier in the pandemic the Federal Reserve Board (FRB) and other central banks took actions to support the global economy, including by further reducing their benchmark interest rates, mismatches between supply and demand of goods and services contributed to a rise in inflation in 2021, prompting the FRB to announce the approaching end of the period of extraordinarily low interest rates.
Interest rates on loans Citi makes are typically based off or set at a spread over a benchmark interest rate, and would likely decline or rise as benchmark rates decline or rise, respectively. While the interest rates at which Citi pays depositors are already low and unlikely to decline much further, declining or continued low interest rates for loans could further compress Citi’s net interest income. Citi’s net interest income 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.
In contrast, an abrupt and sustained increase in interest rates could interfere with the global macroeconomic recovery, whether due to continued or increased inflationary pressures or otherwise. And while Citi estimates its overall net interest income would generally increase due to higher interest rates, higher rates could adversely affect Citi’s funding costs, levels of deposits in its consumer and institutional businesses and certain business or product revenues. For additional information on Citi’s interest rate risk, see “Managing Global Risk—Market Risk—Net Interest Income at Risk” below.
Additional areas of uncertainty include, among others, an elevated level of inflation resulting in adverse spill-over effects; the ability of Congress to raise the federal debt ceiling; slowing of the Chinese economy, including negative economic impacts associated with such slowdown or any policy actions; significant disruptions and volatility in financial markets; other geopolitical tensions and conflicts; protracted or widespread trade tensions; financial market, other economic and political disruption driven by anti-establishment movements; natural disasters; other pandemics; and election outcomes. For example, Citi’s market-making businesses can suffer losses resulting from the widening of credit spreads due to unanticipated changes in financial markets. In addition, adverse developments or downturns in one or more of the world’s larger economies would likely have a significant impact on the global economy or the economies of other countries because of global financial and economic linkages.
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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).

STRATEGIC RISKS
Rapidly Evolving Challenges and Uncertainties Related to the COVID-19 Pandemic in the U.S. and Globally Will Likely Continue to Have Negative Impacts on Citi’s Businesses and Results of Operations and Financial Condition.
The COVID-19 pandemic has affected all of the countries and jurisdictions in which Citi operates, including severely impacting global health, financial markets, consumer and business spending and economic conditions. The extent of the future pandemic impacts remain uncertain and will likely 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 as well as any variants becoming more prevalent and impactful; further production, distribution, acceptance and effectiveness of vaccines; availability and efficiency of testing; the public response; and government actions. The future impacts to global economic conditions may include, among others:

further disruption of global supply chains;
higher inflation;
higher interest rates;
significant disruption and volatility in financial markets;
additional closures, reduced activity and failures of many businesses, leading to loss of revenues and net losses;
further institution of social distancing and restrictions on businesses and the movement of the public in and among the U.S. and other countries; and
reduced U.S. and global economic output.

The pandemic has had, and may 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. Such developments are uncertain and cannot be predicted, including the course of the coronavirus, as well as any weakness or slowing in the economic recovery or a further economic downturn, whether due to further supply chain disruptions, inflation trends, higher interest rates or otherwise.
The pandemic may not be sufficiently contained for an extended period of time. A prolonged health crisis could reduce economic activity in the U.S. and other countries, resulting in additional declines or weakness in employment trends and business and consumer confidence. These factors could 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 an 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.
The impact of the pandemic on Citi’s consumer and corporate borrowers will vary by sector or industry, with some borrowers experiencing greater stress levels, particularly as credit and customer assistance support further winds down, 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. These borrowers include, among others, businesses that are more directly impacted by the institution of social distancing, the movement of the public and store closures. In addition, stress levels ultimately experienced by Citi’s borrowers may be different from and more intense than assumptions made in prior estimates or models used by Citi, resulting in an increase in Citi’s ACL or net credit losses, particularly as the benefits of fiscal stimulus and government support programs diminish.
Ongoing legislative and regulatory changes in the U.S. and globally to address the economic impact from the pandemic could further affect Citi’s businesses, operations and financial performance. Citi could also face challenges, including legal and reputational, and scrutiny in its efforts to provide relief measures. Such 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.
Citi has taken measures to maintain the health and safety of its colleagues; however, these measures could result in additional expenses, and illness of employees could negatively affect staffing for a period of time. In addition, Citi’s ability to recruit, hire and onboard colleagues in key areas could be negatively impacted by pandemic restrictions as well as Citi’s COVID-19 vaccination requirement (see the qualified colleagues risk factor below).
Further, it is unclear how the macroeconomic or business environment or societal norms may be impacted after the pandemic. The post-pandemic environment may undergo unexpected developments or changes in financial markets, 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.
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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).

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 the Results of Regulatory Stress Tests.
Citi’s ability to return capital to its common shareholders consistent with its capital planning efforts and targets, whether through its common stock dividend or through a share repurchase program, substantially depends, among other things, on regulatory approval,capital requirements, including throughthe Stress Capital Buffer (SCB), which is based upon the results of the CCAR process required by the Federal Reserve Board (FRB) andFRB as well as the supervisory stress tests required under the Dodd-Frank Act. TheDodd- Frank Act (as described in more detail below).
Citi’s ability to return capital also depends on Citi’sits results of
operations and financial condition, the capital impact related to divestitures, forecasts of macroeconomic conditions, its implementation and maintenance of an effective capital planning process and management framework, and effectiveness in planning, managing and calculating 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 elevated levels of liquidity in the financial system related to the pandemic (see the macroeconomic challenges and uncertainties risk factor above).
Changes in regulatory capital rules, requirements or interpretations could have a material impact on Citi’s regulatory capital, both as a result of changes in Citi’s reported regulatory capital and integration into the CCAR process and regulatory stress tests. For example, Citi was required to adopt the Standardized Approach for Counterparty Credit Risk (SA-CCR) as of January 1, 2022, which resulted in an approximate $51 billion increase in Citi’s risk-weighted assets under the Standardized Approach. Citi voluntarily suspended common share repurchases during the fourth quarter of 2021, in anticipation of the adverse impact resulting from the adoption of SA-CCR. Citi will be required to adopt SA-CCR for purposes of the supervisory stress test during the 2023 cycle and SA-CCR may be considered by management during the 2022 cycle for purposes of management’s own capital adequacy assessment. In addition, the U.S. banking agencies may potentially consider a number of changes to the U.S. regulatory capital framework in the future, including, but not limited to, revisions to the U.S. Basel III rules, recalibration of the GSIB surcharge.surcharge and SLR, and enactment of the discretionary Countercyclical Capital Buffer. All of these potential changes could negatively impact Citi’s regulatory capital position or increase Citi’s regulatory capital requirements.
All CCAR firms, including Citi, will continue to be subject to a rigorous regulatory evaluation of capital planning practices, including, but not limited to, governance, risk management and internal controls. Citi’s ability to return
capital may be adversely impacted if such an evaluation of Citi resulted in negative findings. In addition, Citi’s ability to accurately predict, interpret or explain to stakeholders the outcomeresults 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 of capital to common shareholders, in 2019 as well as the CCAR process, supervisory stress test requirements and GSIB surcharge, see “Capital Resources—Overview” and “Capital Resources—Current Regulatory Capital Standards—Stress Testing Component of Capital Planning” above and the risk management risk factor below.
The FRB has stated that it expects leading capital adequacy practices to continue to evolve and to likely be determined by the FRB each year as a result of its cross-firm review of capital plan submissions. Similarly, the FRB has indicated that, as part of its stated goal to continually evolve its annual stress testing requirements, several parameters of the annual stress testing process may continue to be altered, including the severity of the stress test scenario, the FRB modeling of Citi’s balance sheet, pre-provision net revenue (PPNR) and stress losses, and the addition of components deemed important by the FRB.
Beginning January 1, 2022, Citi will bewas required to incorporatephase into regulatory capital at 25% per year the current expected credit losses (CECL) methodology into its stress testing methodologies, datachanges in retained earnings, deferred tax assets and disclosure beginning withACL determined upon the January 1, 2020 supervisory stress test cycle.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 forthrough the 2020 and 2021
2023 supervisory stress test cycles, andcycle, while continuing to evaluate appropriate future enhancements to this framework as best practices for implementing CECL are developed.framework. The impacts on Citi’s capital adequacy of incorporatingthe 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 “Day One” adverse regulatory capital effects resulting from adoption of the CECL methodology, see “Capital Resources—Current Regulatory Capital Standards—Regulatory Capital Treatment—Implementation andModified Transition of the Current Expected Credit Losses (CECL) Methodology” above and Note 1 to the Consolidated Financial Statements.
In addition, in 2018, the FRB proposed to more closely integratehas integrated the results of the quantitative assessment in CCAR with firms’ ongoing minimum capital requirements under the U.S. Basel III rules. Proposed changes to theannual stress testing regime include, among others, introduction of a firm-specific “stressrequirements with ongoing regulatory capital buffer” (SCB), which would be equal torequirements. For Citigroup, the SCB equals the maximum decline in a firm’sCiti’s Common Equity Tier 1 Capital ratio under athe supervisory 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%. The FRB proposed that theEffective October 1, 2021, Citi’s SCB would replace the capital conservation buffer in Citi’s ongoing regulatory capital requirements for Standardized Approach capital ratios.was 3.0%. The SCB would beis calculated by the FRB using its proprietary data and modeling of each firm’s results. Accordingly, a firm’sCiti’s SCB wouldmay change annually, or possibly more frequently, based on the supervisory stress test results, thus potentially resulting in year-to-year volatility in the calculation of the SCB. Similar to the other regulatory capital buffers, a breach of the SCB would result in graduated limitations on capital distributions. For additional
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information on the FRB’s proposal,SCB, including its calculation, of the SCB, see “Capital Resources—Regulatory Capital Standards Developments”Buffers” above.
Although various uncertainties exist regarding the extent of, and the ultimate impact to Citi from, these changes to the FRB’s regulatory capital, stress testing and CCAR regimes, these changes would likelycould increase the level of capital Citi is required or elects to hold, including as part of Citi’s estimated management buffer, thus potentially impacting the extent to which Citi is able to return capital to shareholders.

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

conflicts, natural disasters, pandemics and election outcomes. For example, it was reported in January 2020 that a novel strain of coronavirus which first surfaced in China, had spread to several other countries, resulting in various uncertainties, including the potential impact to Asian and global economies, trade and consumer and corporate clients.
Governmental fiscal and monetary actions, or expected actions, such as changes in interest rate policies and any program implemented by a central bank to change the size of its balance sheet, could significantly impact interest rates, economic growth rates, the volatility of global financial markets, foreign exchange rates and capital flows among countries. For example, in 2019, the FRB reduced its benchmark U.S. interest rate three times to add additional stimulus to the U.S. economy. The interest rates on Citi loans are typically based off or set at a spread over a benchmark interest rate, including the U.S. benchmark interest rate, and are therefore likely to decline as benchmark rates decline. By contrast, the interest rates at which Citi pays depositors are already low and unlikely to decline much further. Consequently, declining loan rates and largely unchanged deposit rates would likely compress Citi’s net interest revenue. Citi’s net interest revenue could also be adversely affected due to a flattening of the interest rate yield curve (e.g., a lower spread between shorter-term versus longer-term interest rates), as Citi, similar to other banks, typically pays interest on deposits based on shorter-term interest rates and earns money on loans typically based on longer-term interest rates. For additional information on Citi’s interest rate risk, see “Managing Global Risk—Market Risk—Net Interest Revenue at Risk” below.
Despite the U.K.’s official withdrawal from the European Union (EU) as of January 31, 2020, numerous uncertainties continue to exist regarding the U.K.’s future relationship with the EU. For example, the terms of the U.K. withdrawal continue to be negotiated between the U.K. and the EU, including their future trading relationship. It remains unclear whether the parties will be able to agree on terms prior to the end of the currently scheduled transition period on December 31, 2020. If no agreement is reached on terms of the exit in a timely manner, it would likely result in what is commonly referred to as a “no deal” or “hard” exit scenario. A hard exit scenario would result in the U.K. and EU losing reciprocal financial services license-passporting rights and require the U.K. to deal with the EU as a third-country regime, but without an equivalence regime or transition period in place. A hard exit scenario could cause severe disruptions in the movement of goods and services between the U.K. and EU countries and negatively impact financial markets and the U.K. and EU economies. Citi’s business and operations could be impacted by these and other factors, including the preparedness and reaction of clients, counterparties and financial markets infrastructure. For information about Citi’s actions to manage the U.K.’s exit from the EU, see “Managing Global Risk—Strategic Risk—Exit of U.K. from EU” below. Further, the economic and fiscal situations of some EU countries have remained fragile, and concerns and uncertainties remain in the U.K. and Europe over the resulting effects of the U.K.’s exit from the EU.
These and additional global macroeconomic, geopolitical and other challenges, uncertainties and volatilities have negatively impacted, and could continue to negatively impact, Citi’s businesses, results of operations and financial condition, including its credit costs, revenues in its Markets and securities services and other businesses, and AOCI (which would in turn negatively impact Citi’s book and tangible book value).

Citi, Its Management and Its Businesses Must Continually Review, Analyze and Successfully Adapt to Ongoing Regulatory and Legislative Uncertainties and Changes in the U.S. and Globally.
Despite the adoption of final regulations and laws in numerous areas impacting Citi and its businesses over the past several years, Citi, its management and its businesses continually face ongoing regulatory and legislative uncertainties and changes, both in the U.S. and globally. While the areas of ongoing regulatory and legislative uncertainties and changes facing Citi are too numerous to list completely, various examples include, but are not limited to (i) potential fiscal, monetary, regulatory, tax and other changes arising from the U.S. federal government and others;other governments, including as a result of the differing priorities of the current U.S. presidential administration, changes in regulatory leadership or focus and actions of 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) future legislative and regulatory requirements in the terms ofU.S. and other uncertainties resulting from the U.K.’s exit from the EUglobally related to climate change, including any new disclosure requirements (see the macroeconomic challenges and uncertaintiesclimate change risk factor above)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 budget planning difficult or subject to change. For example, U.S. and other regulators globally have implemented and continue to discuss various changes to certain regulatory requirements, which would require ongoing assessment by management as to the impact to Citi, its businesses and business planning. Business planning is required to be based on possible or proposed rules or outcomes, which can change dramatically upon finalization, or upon implementation or interpretive guidance from numerous regulatory bodies worldwide, and such guidance can change.
Moreover, U.S. and international regulatory and legislative initiatives have not always been undertaken or implemented on a coordinated basis, and areas of divergence have developed and continue to develop with respect to the scope, interpretation, timing, structure or approach, leading to inconsistent or even conflicting requirements, including within a single jurisdiction. For example, in May 2019, the European Commission adopted, as part of Capital Requirements Directive V (CRD V), a new requirement for major banking groups headquartered outside the EU (which would include Citi) to establish an intermediate EU holding company where the foreign bank has two or more institutions (broadly meaning banks, broker-dealers and similar financial firms) established in the EU. While in some respects the requirement mirrors an existing U.S. requirement for non-U.S. banking organizations to form U.S. intermediate holding companies,

the implementation of the EU holding company requirement could lead to additional complexity with respect to Citi’s resolution planning, capital and liquidity allocation and efficiency in various jurisdictions.
Moreover, 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.
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). and can adversely affect Citi’s businesses, results of operations and financial condition.

Citi’s Continued InvestmentsInvestment and EfficiencyOther Initiatives as Part of Its Transformation and Strategic Refresh May Not Be as Successful as It Projects or Expects.
As part of its transformation initiatives, Citi continues to leveragemake significant investments to improve its scaleinfrastructure, risk management and make incrementalcontrols and further enhance safety and soundness (for additional information, see the legal and regulatory proceedings risk factor below). Citi also continues to execute on its strategic refresh that includes, among other things, its exit of certain consumer banking businesses (see below) and its investments to deepen client relationships increase revenues and lower expenses. enhance client offerings and capabilities in order to simplify the Company and enhance its allocation of resources.
For example, Citi continues to make investments to enhanceinvest in its technology and digital capabilities across the franchise, including digital platforms and mobile and cloud-based solutions, as well as make investments in risk management and controls.solutions. In addition, Citi also has been investing in higher-return businesses,making other investments across the Company, such as the U.S. cards andin Citi’s wealth management businesses in Global Consumer Banking (GCB) andbusiness, commercial banking business, treasury and trade solutions, securities services and other businesses, in Institutional Clients Group (ICG). Citi also continues to execute on its previously disclosed investment of more than $1 billion in Citibanamex. Further,including implementing new capabilities and partnerships. Citi has also been pursuing efficiencyproductivity improvements through various technology and digital initiatives, organizational simplification and location strategies, which are intendedstrategies. Failure to self-fundproperly invest in and upgrade Citi’s incremental investment initiatives as well as offset growth-driven expenses.
Citi’s investmentstechnology and efficiency initiatives are being undertaken as part of its overall strategyprocesses could result in an inability to meetbe sufficiently competitive, serve clients effectively and avoid operational errors (for additional information, see the operational processes and financial objectives, including, among others, those relating to shareholder returns.systems risk factor below). There is no guarantee that these or other initiatives Citi may pursue will be as productive or effective as Citi expects, or at all.
Furthermore, Citi’s strategic refresh necessitates further changes in and exits of certain businesses, which involve significant execution complexity, and could result in additional losses, charges or other negative financial impacts. For example, Citi may not be able to achieve its objectives related to its exits of 13 consumer markets in Asia and EMEA or exit of the consumer, small business and middle-market banking operations in Mexico. These exits may not be as productive, effective or timely as Citi expects and may result
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in additional foreign currency translation adjustments (CTA) or other losses, charges or other negative financial or strategic impacts, which could be material. For additional information on CTA losses, see the incorrect assumptions or estimates risk factor below.
Citi’s investment and efficiencyother initiatives may continue to evolve as its business strategies, and 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, among others, interest rates; inflation; impacts related to the pandemic; customer, client and competitor actionsactions; and ongoing regulatory changes, among others.changes.

Uncertainties Regarding the Transition Away from or Possible Discontinuance of the London Inter-Bank Offered Rate (LIBOR) or Any Other Interest Rate Benchmark Could Have Adverse Consequences for Market Participants, Including Citi.
LIBOR is extensively used as a “benchmark” or “reference rate” across financial products and markets globally. The U.K. Financial Conduct Authority (FCA) has raised questions about the future sustainability of LIBOR, and, as a result, the FCA obtained voluntary panel bank support to sustain LIBOR only until 2021, and LIBOR is expected to be discontinued as early as January 1, 2022. In addition, following guidance provided by the Financial Stability Board, other regulators have suggested reforming or replacing other benchmark rates with alternative reference rates. Accordingly, the transition away from and discontinuance of LIBOR or any other benchmark
rate presents various uncertainties, risks and challenges to financial markets and institutions, including Citi. These include, among others, the pricing, liquidity, value of, return on and market for financial instruments and contracts that reference LIBOR or any other applicable benchmark rate.
Citi issues, trades, holds or otherwise uses a substantial amount of securities or products that reference LIBOR, including, among others, derivatives, corporate loans, commercial and residential mortgages, credit cards, securitized products and other securities. The transition away from and discontinuation of LIBOR presents significant operational, legal, reputational or compliance, financial and other risks to Citi. For example, LIBOR transition presents various challenges related to contractual mechanics of existing floating rate financial instruments and contracts that reference LIBOR and mature after 2021. Certain of these instruments and contracts do not provide for alternative benchmark rates, which makes it unclear what the future benchmark rates would be after LIBOR’s cessation. Even if the instruments and contracts provide for a transition to alternative benchmark rates, the new benchmark rates may significantly differ from the prior rates. As a result, Citi may need to proactively address any contractual uncertainties or rate differences in such instruments and contracts, which would likely be both time consuming and costly. In addition, the transition away from and discontinuance of LIBOR could result in disputes, including litigation, involving holders of outstanding instruments and contracts that reference LIBOR, whether or not the underlying documentation provides for alternative benchmark rates. Citi will also need to develop significant internal systems and infrastructure to transition to alternative benchmark rates to both manage its businesses and support clients.
For additional information about Citi’s ongoing management of LIBOR transition risk, see “Managing Global Risk—Strategic Risk—LIBOR Transition Risk” below.

Citi’s Ability to Utilize Its DTAs, and Thus Reduce the Negative Impact of the DTAs on Citi’s Regulatory Capital, Will Be Driven by Its Ability to Generate U.S. Taxable Income.
At December 31, 2019,2021, Citi’s net DTAs were $23.1$24.8 billion, net of a valuation allowance of $6.5$4.2 billion, of which $10.7$9.5 billion was excludeddeducted 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, 2019, $6.32021, $2.8 billion related to foreign tax credit (FTC) carry-forwards, (FTCs), net of a valuation allowance. The carry-forward utilization period for FTCs is 10 years and represents the most time-sensitive component of Citi’s DTAs. The FTC carry-forwards at December 31, 20192021 expire over the period of 2020–2022–2029. 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 Citi’sits 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 has not been and 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 Litigation or Examinations and the Payment of Additional Taxes, Penalties or Interest.
Citi is subject to various income-based and non-income-based tax laws of the U.S. and its states and municipalities, as well as the numerous non-U.S. jurisdictions in which it operates. These tax laws are inherently complex and Citi must make judgments and interpretations about the application of these laws, including the Tax Cuts and Jobs Act (Tax Reform), to its entities, operations and businesses. In addition, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding non-income-based tax matters. Citi’s interpretations andor application of the tax laws, including with respect to Tax Reform, withholding, stamp, service and other non-income taxes, could differ from that of the relevant governmental taxing authority, which could result in the payment ofrequirement to pay additional taxes, penalties or interest, which could be material.

Citi’s Presence in the Emerging Markets Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.
During 2019, emerging markets revenues accounted for approximately 37% of Citi’s total revenues (Citi generally defines emerging markets as countries in Latin America, Asia
(other than Japan, Australia and New Zealand), Central and Eastern Europe, the Middle East and Africa). Although Citi continues to pursue its target client strategy, Citi’s presence in the emerging markets subjects it to a number of risks, including limitations of hedges on foreign investments, foreign currency volatility, sovereign volatility, election outcomes, regulatory changes and political events, foreign exchange controls, limitations on foreign investment, sociopolitical instability (including from hyperinflation), fraud, nationalization or loss of licenses, business restrictions, sanctions or asset freezes, potential criminal charges, closure of branches or subsidiaries and confiscation of assets. For example, Citi operates in several countries that have, or have had in the past, strict foreign exchange controls, such as Argentina, that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries.
Moreover, if the economic situation in an emerging markets country where Citi operates were to deteriorate below
a certain level, U.S. regulators may impose mandatory loan loss or other reserve requirements on Citi, which would increase its credit costs and decrease its earnings (see “Strategic Risk—Country Risk—Argentina” below for additional information on emerging markets risk). In addition, political turmoilthe litigation and instability have occurred in certain regions and countries, including Asia,examinations involving non-U.S. tax authorities, see Note 27 to 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).Consolidated Financial Statements.
Citi’s emerging markets presence also increases its compliance and regulatory risks and costs. For example, Citi’s operations in emerging markets, including facilitating cross-border transactions on behalf of its clients, subject it to higher compliance risks under U.S. regulations that are primarily focused on various aspects of global corporate activities, such as anti-money laundering regulations and the Foreign Corrupt Practices Act. These risks can be more acute in less developed markets and thus require substantial investment in compliance infrastructure or could result in a reduction in certain of Citi’s business activities. Any failure by Citi to comply with applicable U.S. regulations, as well as the regulations in the countries and markets in which it operates as a result of its global footprint, could result in fines, penalties, injunctions or other similar restrictions, many of which could negatively impact Citi’s results of operations and reputation (see the implementation and interpretation of regulatory changes and legal and regulatory proceedings risk factors below).

A Deterioration in or Failure to Maintain Citi’s Co-Branding or Private Label Credit Card Relationships, Including as a Result of AnyEarly Termination, 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-brandedbranded 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. The five largest relationships across both businesses in North America GCB constituted an aggregate of approximately 9% of Citi’s revenues in 2021 (for additional information, see “Global Consumer BankingNorth America GCB” above). Citi’s co-branding and private label agreements provide for shared economics between the parties and generally have a fixed term. The five largest relationships, which include Sears, constituted an aggregate of approximately 11% of Citi’s revenues in 2019. These relationships could be negatively impacted by, among other things, the general economic environment, declining sales and revenues or other operational difficulties of the retailer or merchant, termination due to a contractual breach by Citi or by the retailer or merchant, or other factors, including bankruptcies, liquidations, restructurings, consolidations or other similar events.
Over the last several years, a number of U.S. retailers have continued to experience declining sales due to the pandemic or otherwise, which has resulted in significant numbers of store closures and, in a number of cases, bankruptcies, as retailers attempt to cut costs and reorganize. For example, despite its exit from bankruptcy in 2019, Sears continues to close stores and experience declining sales (for additional information regarding Citi retail

services’ co-brand and private label credit card products relationship with Sears, see “Global Consumer Banking—North America GCB” above). In addition, as has been widely reported, competition among card issuers, including Citi, for these relationships is significant, and it has become increasingly difficult in recent years to maintain such relationships on the same terms or at all.
Citi’s co-branding and private label relationships could be negatively impacted by, among other things, the general economic environment; changes in consumer sentiment, spending patterns and credit card usage behaviors; a decline in sales and revenues, partner store closures, government
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imposed restrictions, reduced air and business travel, or other operational difficulties of the retailer or merchant; early termination due to a contractual breach or exercise of other early termination right; 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 early termination and bankruptcies or liquidations, could negatively impact the results of operations or financial condition of Citi-brandedbranded 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 eight U.S. GSIBs, including Citi, filed their most recent resolution plans with 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.2021. For additional information on Citi’s resolution plan submissions, see “Managing Global Risk—Liquidity Risk” below.
Under Title I, if the FRB and the FDIC jointly determine that Citi’s resolution plan is not “credible” (which, although not defined, is generally believed to mean the regulators do
not believe the plan is feasible or would otherwise allow the regulatorsCiti to resolve Citibe 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 Employees.Colleagues.
Recent employment conditions have made the competition to hire and retain qualified employees significantly more challenging. Citi’s performance and the performance of its individual businesses largely dependsdepend on the talents and efforts of its diverse and highly skilled employees.qualified colleagues. Specifically, Citi’s continued ability to compete in each of its businesses,lines of business, to manage its businesses effectively and to continue to execute its overall global strategy depends on its ability to attract new employeescolleagues and to retain and motivate its existing employees.colleagues. If Citi is unable to continue to attract, retain and retainmotivate the most highly qualified employees,colleagues, Citi’s performance, including its competitive position, the successful execution of its overall strategy and its results of operations could be negatively impacted.
Citi’s ability to attract, retain and retain employeesmotivate colleagues depends on numerous factors, some of which are outside of its control. For example, the competition for talent recently has been particularly intense because of economic conditions associated with the pandemic. Also, the banking industry generally is subject to more comprehensive regulation of executive and employee compensation than other industries, including deferral and clawback requirements for incentive compensation.compensation, which can make it unusually challenging for Citi often competesto compete in the market for talent with entitieslabor markets against businesses that are not subject to such comprehensive regulatory requirements on the structure of incentive compensation,regulation. Citi often competes for talent with such businesses, including, among others, technology companies. Further, Citi’s vaccination requirement for its U.S.-based employees could make it more difficult to compete for or retain colleagues. Other factors that could impact Citi’sits ability to attract, retain and retain employeesmotivate colleagues include, its culture and the management and leadership of the Company as well as its individual businesses,among other things, Citi’s presence in thea particular market or region, at issue and the professional opportunities it offers.offers and its reputation. 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 evolving and competitive business 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 potentialCertain competitors may be subject to intensify competitiondifferent and, accelerate disruption in the financial services industry.some cases, less stringent legal and regulatory requirements, placing Citi at a competitive disadvantage.
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.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, money, save and invest. invest money.
Moreover, emerging technologies have the potential to intensify competition and accelerate disruption in the financial services industry. For example, there is increasing interest
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from clients and investors in digital assets such as cryptocurrencies. Financial services firms and other market participants have begun to offer services related to those assets such as custody and trading. However, Citi may not be able to provide the same or similar services for legal or regulatory reasons and such services increase compliance risk. In addition, changes in the payments space (e.g., instant and 24x7 payments) are accelerating, and, as a result, certain of Citi’s products and services could become less competitive.
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. Increased competition and emerging technologies have required and could require Citi to change or adapt its products and services to attract and retain customers or clients or to compete more effectively with competitors, including new market entrants. Simultaneously, as Citi develops new products and services leveraging emerging technologies, new risks may emerge that, if not designed and governed adequately, may result in control gaps and in Citi operating outside of its risk appetite. For example, instant and 24x7 payments products could be accompanied by challenges to forecasting and managing liquidity, as well as increased operational and compliance risks.
To the extent that Citi is not able to compete effectively with thesefinancial 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 and qualified colleagues risk factorfactors above and “Supervision, Regulation and Other—Competition” below.


OPERATIONAL RISKS
A Failure 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.
A significant portion of Citi’s global operations reliesrely heavily on its technology, including the accurate, timely and secure processing, management, storage and transmission of confidential transactions, data and other information as well as the monitoring of a large numbersubstantial amount of data and complex transactions on a minute-by-minute basis.in real time. For example, through GCB and treasury and trade solutions and securities services businesses in ICG, Citi obtains and stores an extensive amount of personal and client-specific information for its retail, corporateconsumer and governmentalinstitutional 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 increasingever-increasing risk of operational loss, failure or disruption, orincluding as a result of cyber or information security incidents from these activitiesincidents. 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 pandemic-related risk factor above and the cybersecurity risk factor below). These
Although Citi has continued to upgrade its technology, including systems to automate processes and enhance efficiencies, operational incidents are unpredictable and can arise from numerous sources, not all of which are infully within Citi’s control, including,control. These include, among others, human error, such as manual transaction processing errors; fraud or malice on the part of employees or third parties; accidental system or technological failure,failure; electrical or telecommunication outages,outages; failures of or cyber incidents involving computer servers or infrastructure; or other similar losses or damage to Citi’s property or assets. These issuesassets (see also the climate change risk factor below). For example, Citi has experienced and could experience further losses associated with manual transaction processing errors (for additional information, see “Revlon-Related Wire Transfer Litigation” in Note 27 to the Consolidated Financial Statements).
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 andor prevent system disruptions or cyber attacks.
Such events couldIncidents that impact information security and/or technology operations may cause interruptions disruptions and/or malfunctions in the operations of Citi (such aswithin 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 these coststhe consequences and consequences. Any such eventscosts. Operational incidents could also 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, perhaps significantly.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.


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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 statenation-state actors, as well as insiders who knowingly or unknowingly engage in or enable malicious cyber activities.
Third parties with which Citi does business, as well as retailers and other third parties with which Citi’s customers do business, may also be sources of cybersecurity risks, particularly where activities of customers are beyond Citi’s security and control systems. For example, Citi outsources certain functions, such as processing customer credit card transactions, uploading content on customer-facing websites and developing software for new products and services. These relationships allow for the storage and processing of customer information by third-party hosting of or access to Citi websites, which could lead to compromise or the potential to introduce vulnerable or malicious code, resulting in security breaches impacting Citi customers. Furthermore, because financial institutions are becoming increasingly interconnected with central agents, exchanges and clearing houses, including as a result of the derivatives reforms over the last few years, Citi has increased exposure to cyber attacks through third parties.While many of Citi’s agreements with the third parties include indemnification provisions, Citi may not be able to recover sufficiently, or at all, under the provisions to adequately offset any losses Citi may incur from third-party cyber incidents.
Citi has been subject to intentionalattempted and sometimes successful cyber incidentsattacks from external sources over the last several years, including (i) denial of service attacks, which attemptedattempt 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 which obtaineddue to unauthorized access to customer account data and (iii)(iv) malicious software attacks on client systems, which attemptedin an attempt to allowgain unauthorized entranceaccess to Citi’sCiti systems or client data under the guise of anormal client and the extraction of client data.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 occurbecome apparent for a substantial period until afterof time following discovery of the incident has been discovered.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-insuredself- insured deductibles, cover certain aspects of cyber risks, such insurance coverage may be insufficient to cover all losses.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 allowance for credit losses,ACL; reserves related to litigation, regulatory and tax matters exposures,exposures; valuation of DTAs andDTAs; the fair values of certain assets and liabilities, amongliabilities; and the assessment of goodwill or other items.assets 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
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losses or other adverse impacts, some of which could be significant.
For example, the CECL methodology 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, U.S. unemployment rate and U.S. Real GDP, and the credit indicators, composition and other characteristics of Citi’s loan and other applicable financial assets. 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 and financial condition, as well as regulatory capital due to the CECL phase-in beginning January 1, 2022.
Moreover, Citi has incurred losses related to its foreign operations that are reported in the foreign currency translation adjustment (CTA)CTA components of Accumulated other comprehensive income (loss) (AOCI). In accordance with U.S. GAAP, a sale, or substantial liquidation or any other deconsolidation event of any foreign operations, such as those related to Citi’s legacy or exit businesses, would result in reclassification of any foreign CTA component of AOCIrelated to that foreign operation, including related hedges and taxes, into Citi’s earnings. For example, Citi incurred a pretax loss of approximately $680 million ($580 million after-tax) in the third quarter of 2021 related to the sale of Citi’s Australia consumer banking business in Asia GCB, primarily reflecting the impact of a CTA loss. For additional information on Citi’s accounting policy for foreign currency translation and its foreign CTA components of AOCI, see Notes 1 and 19 to the Consolidated Financial Statements. 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.
In addition, changes
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 (see the changes to financial accounting and reporting standards risk factor below).businesses. For additional information on the key areas for which assumptionsCiti’s accounting
policies and estimates are used in preparing Citi’s financial statements, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 27 to the Consolidated Financial Statements.

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

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 if Its Risk Management Processes, Strategies or Models Are Deficient or Ineffective.Impacted.
Citi utilizes a broad and diversified set of risk management and mitigation processes and strategies, including the use of risk models in enacting processes and strategies as well as in analyzing and monitoring the various risks Citi
assumes in conducting its activities. For example, Citi uses models as part of its comprehensive stress testing initiatives across Citi.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 unintentionally from untimely, inaccurate or incomplete processes caused by unintentional human error.processes.
TheseIn addition, in October 2020, Citigroup and Citibank entered into consent orders with the FRB and OCC that require Citigroup and Citibank to make 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-weightedrisk- weighted assets. These changes can negatively impact Citi’s capital ratios and its ability to achieve its regulatory capital requirements as it projects or as required.requirements.


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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 GCBICG and ICGGCB. 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 $310$271 billion and end-of-period corporate loans of $390$397 billion at year-end 2019. 2021.
A default by a borrower or other counterparty, or a decline in the credit quality or value of any underlying collateral, exposes Citi to credit risk. Despite Citi’s target client strategy, various macroeconomic, geopolitical and other factors, among other things, can increase Citi’s credit risk and credit costs, particularly for certain sectors, industries or countries (for additional information, see the pandemic-related, co-branding and private label credit card and macroeconomic challenges and uncertainties risk factors above and the emerging markets risk factors above)factor below). For example, a weakening of economic conditions, including higher unemployment levels, can adversely affect borrowers’ ability to repay their obligations. In addition, weakening economic conditions may result in Citi being unable to liquidate its collateral, as well as disputes with counterparties regarding the valuation of collateral Citi holds and Citi being unable to realize the fair value of such collateral.
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 new CECL accounting standard, the allowance for credit lossesACL reflects expected losses, rather than incurred losses, which has resulted in and could lead to moreadditional 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 portfolio balances based on historical evidence showing that (i) credit card balances along with 30+ days past duetypically 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;approaches. However, these seasonal trends could be affected in 2022 due to the impacts of the pandemic, government stimulus and (ii) during the firstexpiration of consumer and second quarters, borrowers use tax refunds to pay down balances while delinquent balances from the prior third and fourth quarters are charged off.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 the impact of CECL,Citi’s ACL, see Note“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—Other Risks—Country Risk” below and NoteNotes 14 and 15 to the Consolidated Financial Statements.
Concentrations of risk particularlyto clients or counterparties engaged in the same or related industries or doing business in a particular geography, especially credit and market risks, can also increase Citi’s risk of significant losses. As of year-end 2019,
2021, 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 wherein which Citi has large exposures or guaranteesindemnifications 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.resources, whether due to the pandemic or otherwise. Citi competes with other banks and financial institutions for both institutional and consumer deposits, which represent Citi’s most stable and lowest cost source of long-term funding. The competition for retail banking deposits has increasedcontinued to increase in recent years, including, among others, as a result of online banks and digital banking, among others.banking. Furthermore, givenalthough Citi has had robust deposit growth since the decline in interest rates,

a growing numberonset of customers have transferredthe pandemic, it remains unclear how “sticky�� (likely to remain at Citi) those deposits to other products, including investments and interest-bearing accounts, and/or other financial institutions. This, along with slower growth in deposits, has resultedmay be, particularly in a more challenging environment for Citi. For additional information on the impact of interest rates, see the macroeconomic challenges and uncertainties risk factor above.less monetarily accommodative environment.
Moreover, Citi’s costs to obtain and access secured funding and long-term unsecured funding are directly related to its credit spreads.spreads and changes in interest and currency exchange rates. Changes in credit spreads are driven by both external market factors and factors specific to Citi, such as negative views by investors of the financial services industry or Citi’s financial prospects, 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 and its cost of funding could increase 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
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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.
AsIn addition, 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 liquidity, regulatory or contractual restrictions on their ability to provide such payments, including any local regulatory stress test requirements. Citi’s broker-dealer and bank subsidiaries are subject to restrictions on their ability to lend or transact with affiliates, as well as restrictions on their ability to use funds deposited with them in brokerage or bank accounts to fund their businesses. Limitations on the payments that Citi receives from its subsidiaries could also impact its liquidity. A bank holding company is required by law to act as a source of financial and managerial strength for its subsidiary banks. As a result, the FRB may require Citi to commit resources to its subsidiary banks even if doing so is not otherwise in the interests of Citi or its shareholders or creditors, reducing the amount of funds available to meet its obligations. In addition, in the event of a subsidiary’s liquidation or reorganization, Citi’s right to participate in a distribution of such subsidiary’s assets is subject to the prior claims of the subsidiary’s creditors.

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 Global Ratings, 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 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 andChanges and Heightened Regulatory Scrutiny and Expectations 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 in which 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. These requirements and expectations also include, among other things, those related to customer and client protection, market practices, anti-money laundering and sanctions. A failure to comply with these requirements and expectations or resolve any identified deficiencies could result in increased regulatory oversight and restrictions.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 infor compliance.
Examples of regulatory or legislative changes that have resulted in increased compliance risks and costs include (i) a proliferation ofvarious laws relating to the limitation of cross-border data movement and/or collection and use of customer information,

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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; and (iii) the U.S. banking agencies’ regulatory capital rules and requirements, which have continued to evolve (for additional information, see the capital return risk factor and “Capital Resources” above). In addition, the U.S. banking agencies have prioritized issues of social, economic and racial justice, and are in the process of considering ways in which these issues can be mitigated, including amongthrough rulemaking, supervision and other things, consequences of a breach of the clean holding company requirements, given there are no cure periods for the requirements.means.
Increased and ongoing compliance and regulatory requirements, uncertainties, scrutiny and uncertaintiesexpectations have resulted in higher compliance costs for Citi. For example, Citi, employed roughly 30,000in part due to an increase in risk, regulatory and compliance staff as of year-end 2019, out of a total employee population of 200,000, compared to approximately 14,000 as of year-end 2008 with a total employee population of 323,000. These higher compliance costs can require management to incur additional expense, including potentially away from ongoing business investment initiatives.
over the last several years. Extensive and changing compliance requirements can also result in increased reputational and legal risks for Citi, as failure to comply with regulations and requirements, or failure to comply with regulatory expectations, can result in enforcement and/or regulatory proceedings, (for additional discussion, see the legalpenalties and regulatory proceedings risk factor below).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 Other Negative Impacts on Citi, Its Businesses and Results of Operations.Collateral Consequences Arising from Such Outcomes.
At any given time, Citi is defendinga 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 October 2020 FRB and OCC consent orders require Citigroup and Citibank to implement targeted action plans and quarterly progress reports detailing the results and status of improvements relating principally to various aspects of enterprise-wide risk management, compliance, data quality management and governance and internal controls. These improvements will result in continued significant investments by Citi during 2022 and beyond, 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 OCC consent order requires Citibank to obtain prior approval of any significant new acquisition, including any portfolio or business acquisition, excluding ordinary course transactions. Moreover, the OCC consent order provides that the OCC has the right to assess future civil money 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 FRB 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. Citi can be subject to enforcement proceedings not only because of violations of law and regulation, but also due to a failure, as determined by its regulators, to have adequate policies and procedures, or to remedy deficiencies on a timely basis.
U.S. and non-U.S. regulators have been increasingly focused on “conduct risk,” a term used to describe the risks associated with behavior by employees and agents, including third parties, that could harm clients, customers, 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 generally 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.
In addition, Furthermore, the severity of the remedies sought in legal and regulatory proceedings to which Citi is subject has remained elevated. U.S. and certain internationalnon-U.S. 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 fromfor 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
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costs or other requirements in the future, including for matters or practices not yet known to Citi, any of which could materially and negatively affect Citi’s businesses, business practices, financial condition or results of operations, require material changes in Citi’s operations or cause Citi reputational harm.
Further, many large claims—both private civil and regulatory—asserted against Citi are highly complex, slow to develop and may involve novel or untested legal theories. The outcome of such proceedings is difficult to predict or estimate until late in the proceedings. Although Citi establishes accruals for its legal and regulatory matters according to accounting requirements, Citi’s estimates of, and changes to, these accruals involve significant judgment and may be subject to significant uncertainty, and the amount of loss ultimately incurred in relation to those matters may be substantially higher than the amounts accrued.accrued (see the incorrect assumptions or estimates risk factor above). In addition, certain settlements are subject to court approval and may not be approved.

OTHER RISKS
Citi’s Presence in the Emerging Markets Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.
During 2021, emerging markets revenues accounted for approximately 35% 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 or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations, sovereign volatility, election outcomes, regulatory changes and political events; foreign exchange controls, including inability to access indirect foreign exchange mechanisms; macroeconomic volatility and disruptions, including with respect to commodity prices; 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, whether related to geopolitical conflicts or otherwise; 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. Among other things, Citi faces a risk of devaluation on its unhedged Argentine peso-denominated assets, which continue to increase (for further information on this and other risks, see “Managing Global Risk—Other Risks—Country Risk—Argentina” below).
Moreover, if the economic situation in an emerging markets country in which 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 “Managing Global Risk—Other Risks—Country Risk—Argentina” below).
In addition, political turmoil and instability have occurred in various regions and emerging market countries across the globe 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).

Climate Change Could Have a Negative Impact on Citi’s Results of Operations and Financial Condition.
Citi operates in countries, states and regions in which many of its businesses, and the activities of many of its customers and clients, are exposed to the adverse impacts of climate change, as well as uncertainties related to the transition to a low-carbon economy. 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 both physical risks (those risks related to the physical effects of climate change) and transition risks (risks related to regulatory, compliance, technological, stakeholder and legal changes from a transition to a low-carbon economy). The physical and transition risks can manifest themselves differently across Citi’s risk categories in the short, medium and long terms.
The physical risk from climate change could result from increased frequency and/or severity of adverse weather events. For example, adverse weather events could damage or destroy Citi’s or its counterparties’ properties and other assets and disrupt operations, making it more difficult for counterparties to repay their obligations, whether due to reduced profitability, asset devaluations or otherwise. These events could also increase the volatility in financial markets affecting Citi’s trading businesses and increase its counterparty exposures and other financial risks, which may result in lower revenues and higher cost of credit.
Transition risks may arise from changes in regulations or market preferences toward a low-carbon economy, which in turn could have negative impacts on asset values, results of operations or the reputations of Citi and its customers and clients. For example, Citi’s corporate credit exposures include oil and gas, power and other industries that may experience reduced demand for carbon-intensive products due to the transition to a low-carbon economy. Moreover, U.S. and non-U.S. banking regulators and others are increasingly focusing on the issue of climate risk at financial institutions, both directly and with respect to their clients. As an example, on December 16, 2021, the OCC requested feedback on draft principles designed to support the identification and management of climate-related financial risks at institutions with more than $100 billion in total consolidated assets.
Even as regulators begin to mandate additional disclosure of climate-related information by companies across sectors, there may continue to be a lack of information for more robust climate-related risk analyses. Third party exposures to climate-related risks and other data generally are limited in availability and variable in quality. Modeling capabilities to analyze climate-related risks and interconnections are improving but
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remain incomplete. Legislative or regulatory uncertainties and changes regarding climate-related risk management and disclosures are likely to result in higher regulatory, compliance, credit, reputational and other risks and costs (for additional information, see the ongoing regulatory and legislative uncertainties and changes risk factor above). In addition, Citi could face increased regulatory, reputational and legal scrutiny as a result of its climate risk, sustainability and other ESG related commitments.
For information on Citi’s climate and other sustainability initiatives, see “Sustainability and Other ESG Matters” below. For additional information relatingon Citi’s management of climate risk, see “Managing Global Risk—Other Risks—Climate Risk” below.

The Transition Away from and Discontinuance of the London Inter-Bank Offered Rate (LIBOR) and Any Other Interest Rate Benchmark Could Have Adverse Consequences for Market Participants, Including Citi.
For decades, LIBOR and other rates or indices deemed to be benchmarks have been widely used across financial products and markets globally. These benchmarks have been the subject of ongoing national and international regulatory scrutiny and reform, resulting in regulators generally expecting or requiring banks, including Citi, to cease entering into new contracts that reference USD LIBOR as a benchmark by December 31, 2021. The LIBOR administrator ceased publication of non-USD LIBOR and one-week and two-month USD LIBOR on a representative basis on December 31, 2021, with plans to cease publication of all other USD LIBOR tenors on June 30, 2023. As a result, Citi ceased entering into new contracts referencing USD LIBOR as of January 1, 2022, other than for limited purposes as permitted by regulatory guidance.
LIBOR and other benchmarks have been used in a substantial number of Citi’s outstanding securities and products, including, among others, derivatives, corporate loans, commercial and residential mortgages, credit cards, securitized products and other structured securities. Despite ongoing actions to prepare for the transition away from LIBOR (see “Managing Global Risk—Other Risks—LIBOR Transition Risk” below), market participants, including Citi, may not be adequately prepared for uncertainties associated with these benchmarks’ discontinuance or, as necessary, be able to successfully modify their outstanding contracts or products that reference these benchmarks. For example, the transition away from and discontinuance of LIBOR or any other benchmark rate presents various uncertainties and operational, legal, reputational or compliance, financial and other risks and challenges to holders of these contracts and products, as well as financial markets and institutions, including Citi. These include, among others, the pricing, liquidity, observability, value of, return on and market for financial instruments and contracts that reference LIBOR or any other benchmark rate.
While Citi has adopted alternative reference rates for new contracts to replace these outgoing benchmarks, in some instances, it is possible that the characteristics of these new rates may not be sufficiently similar to, or produce the economic equivalent of, the benchmark rates that they are intended to replace. Alternative reference rates, such as the
Secured Overnight Financing Rate (SOFR), are calculated using components different from those used in the calculation of LIBOR and may fluctuate differently than, and not be representative of, LIBOR. In order to compensate for these differences, certain of Citi’s financial instruments and commercial agreements allow for a benchmark replacement adjustment. However, there can be no assurance that any benchmark replacement adjustment will be sufficient to produce the economic equivalent of LIBOR, either at the benchmark replacement date or over the life of such instruments and agreements.
Further, investors, counterparties and other market participants may not consider the new alternative rates to be a suitable substitute or successor for all of the purposes for which these benchmarks have historically been used (including, without limitation, as a representation of the unsecured short-term funding costs of banks), which may, in turn, reduce their market acceptance. Any failure of the alternative rates to gain broad market acceptance could adversely affect market demand for Citi’s products or securities linked to such alternative rates and thus market prices of such instruments. As part of its transition, Citi is relying or has relied on guidance provided by the accounting standard setters related to the transition away from LIBOR. In the event that such guidance is insufficient or otherwise unable to be implemented as intended, LIBOR transition could
disrupt Citi’s hedge accounting relationships and/or lead
to increased costs in connection with determining whether contract amendments result in a modification or an extinguishment from an accounting perspective. Changes in observability of the alternative reference rates could impact the fair value hierarchy classification of financial instruments and contracts.
Moreover, the LIBOR transition presents challenges related to contractual mechanics of existing financial instruments and contracts that reference such benchmarks that mature after discontinuance of the relevant benchmark. Certain of these legacy instruments and contracts do not provide for fallbacks to alternative reference rates, which makes it unclear what the applicable future replacement benchmark rates and associated payments might be after the current benchmark’s cessation. Citi may not be able to amend certain instruments and contracts due to an inability to obtain sufficient levels of consent from counterparties or security holders. Although this will depend on the precise contractual terms of the instrument, such consent requirements are often conditions of securities, such as floating rate notes.
Even if the instruments and contracts provide for a transition to an alternative reference rate, the new rate may, particularly in times of financial stress, significantly differ from the prior rates. As a result, Citi may need to consider proactively addressing 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. While statutory solutions have been enacted in certain jurisdictions to address these contractual concerns (for example, the State of New York and the EU), the availability and effectiveness of these statutory mechanisms to cover all impacted financial instruments and products to which Citi is a party is uncertain.
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In addition, the transition away from and discontinuance of LIBOR and other benchmark rates have subjected financial institutions, including Citi, to heightened scrutiny from regulators. Failure to successfully transition away from LIBOR and other benchmark rates could result in adverse regulatory proceedingsactions, disputes, including potential litigation involving holders of outstanding products and matters,contracts that reference LIBOR, and other benchmark rates and reputational harm to Citi. Citi may also need to further invest in and develop internal systems and infrastructure to transition to alternative benchmark rates to manage its businesses and support its clients.

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SUSTAINABILITY AND OTHER ESG MATTERS

Introduction
Citi has progressively developed its understanding of environmental, social and governance (ESG) issues for more than 20 years and has a demonstrated record of ESG progress, including participating in the creation and adoption of ESG-related principles and standards. This section summarizes some of Citi’s key ESG initiatives, including its Sustainable Progress Strategy and net zero and Action for Racial Equity commitments.
In January 2022, Citi published its 2021 Task Force on Climate-Related Financial Disclosures (TCFD) Report to provide its stakeholders with information on Citi’s continued progress to address climate risk and to fulfill its commitment to publish an initial net zero plan within one year of announcing the net zero commitment. This represents Citi’s fourth TCFD Report.
For information regarding Citi’s management of climate risk, see “Managing Global Risk—Other Risks—Climate Risk” below.

ESG and Climate-Related Governance

ESG Governance
Citi’s Board of Directors (Board) provides oversight of Citi’s management activities to ensure responsible business practices (for additional information, see “Managing Global Risk—Risk Governance” below). For example, the Nomination, Governance and Public Affairs Committee of the Board oversees many of Citi’s ESG activities, including reviewing Citi’s policies and programs for environmental and social sustainability, climate change, human rights, diversity and other ESG issues, as well as advising on establishing legal accruals, seeengagement with external stakeholders.
The Risk Management Committee of the Board provides oversight of Citi’s Independent Risk Management function and reviews Citi’s risk policies and frameworks, including receiving climate risk-related updates.
In 2021, Citi formed a Global ESG Council consisting of senior members of its management in order to provide enhanced oversight of Citi’s ESG goals and activities. In addition, a number of teams and senior managers contribute to the oversight of different areas such as sustainability; community investing; talent and diversity; ethics and business practices; and remuneration.

Climate Change Governance
Citi’s oversight of climate risk has continued to evolve with its expanding climate commitments. In 2021, Citi established its ESG Council, expanded its Climate Risk team and enhanced its climate risk and net zero-related governance through creation of a Net Zero Task Force. The Task Force, led by Citi’s Chief Sustainability Officer and including leaders from various business units, was established to support the development and launch of Citi’s net zero plan.


Key ESG Initiatives

Sustainable Progress Strategy
Citi’s Sustainable Progress Strategy is summarized in its Environmental and Social Policy Framework. The three pillars of the strategy each have climate-related elements and serve as the foundation for Citi’s climate commitments.

The first pillar, “Low-Carbon Transition,” focuses on financing and facilitating low-carbon solutions and supporting Citi’s clients in their decarbonization and transition strategies.
The second pillar, “Climate Risk,” focuses on Citi’s efforts to measure, manage and reduce the climate risk and impact of its client portfolio. Areas of activity include, portfolio analysis and stakeholder engagement as well as enhancing TCFD implementation and disclosure.
The third pillar, “Sustainable Operations,” focuses on Citi’s efforts to reduce the environmental footprint of its facilities and strengthen its sustainability culture. This includes minimizing the impact of its global operations through operational footprint goals and further integrates sustainable practices across all countries in which Citi operates.

Net Zero Emissions by 2050
In March 2021, Citi announced its commitment to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its operations by 2030; both are significant targets given the size and breadth of Citi’s lending portfolios and businesses. Citi made this commitment as part of its ongoing work to reduce its climate impact and help address the challenges that climate change poses to the global economy and broader society. Citi’s net zero commitment demonstrates how identifying, assessing and managing climate-related risks and opportunities remains a top business priority for Citi.
While many financial institutions, including Citi, face increasing public pressure to divest from carbon-intensive sectors, Citi believes it has an important role to play in advising and financing the transition to net zero, and it plans to work closely with clients in this effort. Citi recognizes that large-scale, rapid divestment could result in an abrupt and disorderly transition to a low-carbon economy, creating both economic and social upheaval on a global scale. Citi believes that an orderly, responsible and equitable transition, which accounts for the immediate economic needs of communities, workers, environmental justice and broader economic development concerns, is essential for the retention of political and social support to move to a low-carbon economy.
Citi’s 2021 TCFD Report discusses its initial 2050 net zero plan, including 2030 emissions targets for its Energy and Power loan portfolios that were developed in line with the Net Zero Banking Alliance Guidelines for Climate Target Setting for Banks. Citi’s net zero plan incorporates a twofold approach: (i) assessment of climate-related factors affecting its clients, and (ii) engagement to understand their transition opportunities.
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Citi’s net zero approach includes the following areas of activity:

Client Transition Assessment, Advisory and Finance: Seek to understand clients’ GHG emissions and work with them to develop their transition plans and advise on capacity building
Clean Tech Finance: Support clients and expedite the commercialization and adoption of climate technology globally through transition and environmental finance as well as public-private partnerships
Public Policy Engagement: Support enabling public policy and regulation in the U.S. and other countries, including through trade associations and other industry groups
Risk Management: Assess climate risk exposure across Citi’s lending portfolios and review client carbon reduction progress, with ongoing review and refining of Citi’s ESRM Policy as needed
Portfolio Management: Active portfolio management to align with net zero targets, including considerations of transition measures taken by clients

The 2050 net zero commitment includes the following framework, delineating the key areas required to achieve its commitment:

Calculate Emissions: Calculate baseline financed emissions for each carbon-intensive sector
Transition Pathway:Identify the appropriate climate scenario transition pathway
Target Setting:Establish emissions reduction targets for 2030 and beyond
Implementation Strategy:Engage with and assess clients to determine transition opportunities
External Engagement: Solicit feedback from clients, investors and other stakeholders, as the work continues to evolve and the parties collectively define net zero for the banking sector

In 2021, Citi continued to expand its participation in the financial industry’s net zero leadership initiatives. Citi is a member of key industry initiatives that enhance its understanding of climate-related issues, improve its access to data and promote efficient communication and coordination across various climate efforts. These initiatives include the Partnership for Carbon Accounting Financials, the Net Zero Banking Alliance and the Glasgow Financial Alliance for Net Zero.


Action for Racial Equity
Effectively responding to the needs of communities of color in the U.S. represents a strategic imperative for the private sector. A wide range of data and studies have found that many major gaps in economic opportunity, education, income, housing and wealth run along racial lines, particularly between Black and white households. These gaps have not only had implications for Black Americans and other people of color but the broader economy as well.
Accordingly, in September 2020, Citi and the Citi Foundation announced Action for Racial Equity to help provide greater access to banking and credit in communities of color, increase investment in Black-owned businesses, expand affordable housing and homeownership among Black Americans and advance anti-racist practices within Citi and across the financial services industry. As part of Action for Racial Equity, Citi and the Citi Foundation have invested more than $1 billion in strategic initiatives to help close the racial wealth gap and increase economic mobility in the U.S. Action for Racial Equity builds on Citi’s longstanding focus on advancing financial inclusion and economic opportunity for communities of color in the U.S. and accelerates its efforts in a time of increased calls for racial equity and shifting population demographics in a changing economy.

In line with Citi’s continued commitment to expand access to banking products and services that can help advance economic progress—especially for underbanked and unbanked communities—on February 24, 2022, Citi announced plans to eliminate overdraft fees, returned item fees and overdraft protection fees by mid 2022. In addition to eliminating these fees, Citi will continue to offer a robust suite of free overdraft protection services for its consumers. See Note 275 to the Consolidated Financial Statements.Statements for details of Citi’s Commissions and fees revenues.


Additional Information

For additional 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 2021 Annual Meeting Proxy Statement available at www.citigroup.com. Click on “Investors” and then “Annual Reports & Proxy Statements.”
The 2021 TCFD Report and any other ESG-related reports and information included elsewhere on Citi’s investor relations website are not incorporated by reference into, and do not form any part of this 2021 Annual Report on Form
10-K.



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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, to promote accountability, credibility and effectiveness in achieving those goals.


























Workforce Size and Distribution

As of December 31, 2021, Citi employed approximately 223,400 colleagues in nearly 100 countries. The Company’s workforce is constantly evolving and developing, benefiting from a strong mix of internal and external hiring into new and existing positions. In 2021, Citi welcomed 46,907 new colleagues in addition to the roles filled by colleagues through internal mobility. The following table shows the geographic distribution of those colleagues by segment, region and gender:


Segment or business(1)
North AmericaEMEALatin AmericaAsia
Total(2)
WomenMenUnspecified
Institutional Clients Group19,029 18,096 7,909 25,458 70,492 44.1 55.9  
Global Consumer Banking33,898  33,453 32,950 100,301 57.4 %42.5 %0.1 %
Corporate/Other23,218 10,364 7,012 12,057 52,651 46.3 53.6 0.1 
Total76,145 28,460 48,374 70,465 223,444 50.6 %49.3 %0.1 %


(1)    Colleague distribution is based on assigned business and region, which may not reflect where the colleague physically resides.

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






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Board Oversight

Citi devotes substantial resources to managing its workforce, guided by a culture of accountability and excellence. Citigroup’s Board of Directors (the Board) provides strategic oversight and direction to management regarding workforce policies and includes many members with experience in overseeing workforce issues.

In addition, the Board’s 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 assistant vice president (AVP) to managing director (MD) levels, as well as talent recruitment and development initiatives.

The Board works with the Nomination, Governance and Public Affairs Committee to evaluate potential successors to the Chief Executive Officer (CEO). With respect to regular succession of the CEO and senior management, Citi’s Board evaluates internal, and, when appropriate, external candidates. To find external candidates, Citi seeks input from members of the Board, senior management and recruiting firms. To develop internal candidates, Citi engages in a number of practices, formal and informal, designed to familiarize the Board with Citi’s talent pool. The formal process involves an annual talent review conducted by senior management at which the Board studies the most promising members of senior management. The Board learns about each person’s experience, skills, areas of expertise, accomplishments, goals and risk and control assessments. This review is conducted at a regularly scheduled Board meeting on an annual basis.
Diversity, Equity and Inclusion
Citigroup’s Board is committed to ensuring that the Board and Citi’s Executive Management Team (see “Managing Global Risk—Risk Governance” below) are composed of individuals whose backgrounds reflect the diversity represented by Citi’s employees, customers and stakeholders. In addition, over the past several years, Citi has increased efforts to diversify its workforce, including, among other things, taking actions with respect to pay equity, representation goals and use of diverse slates in recruiting.

Pay Equity
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 its compensation of women to men and U.S. minorities to U.S. non-minorities. Since 2018, Citi has continued to be transparent about pay equity, including disclosing its unadjusted or “raw” pay gap for both women and U.S. minorities.
Citi’s 2021 pay equity review determined that, on an adjusted basis, women globally are paid on average more than 99% of what men are paid at Citi. In addition, the review determined there was no statistically significant difference in adjusted compensation between U.S. minorities and non-minorities. Following the review,
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appropriate pay adjustments were made as part of Citi’s 2021 compensation cycle.
Citi’s 2021 raw gap analysis showed that the median pay for women globally is 74% of the median for men, similar to 2020, and up from 73% in 2019 and 71% in 2018. The median pay for U.S. minorities is more than 96% of the median for non-minorities, which is up from just under 94% in 2020, 94% in 2019 and 93% in 2018.

Representation Goals
Increasing the number of women globally and U.S. Black employees into senior AVP to MD levels will position Citi to further close the raw pay gap and increase the diversity of the Company. At the AVP to MD levels, Citi established representation goals of 40% for women globally and 8% for U.S. Black employees by the end of 2021. As of December 31, 2021, Citi exceeded its goals for AVP to MD levels for women globally (at 40.6%) and U.S. Black employees (at 8.1%).
Citi is the first major Wall Street bank to participate in Management Leadership for Tomorrow’s Black Equity at Work Certification, to help measure internal progress toward Black equity in the workplace.
In addition, consistent with its ongoing support of measurement and transparency, Citi will conduct a third-party racial equity audit to help assess the true impact of Citi’s Action for Racial Equity initiatives (for additional information, see “Sustainability and Other ESG Matters—Action for Racial Equity” above).

Diverse Slates in Recruitment
In 2021, Citi expanded the use of diverse slates in its recruiting efforts to have at least two women or U.S. minorities interview for U.S.-based roles and at least two women interview for global hire roles at the AVP to MD levels.
Since implementation, Citi has increased the share of diverse candidates on slates by 26% and more than doubled the total number of diverse slates between March and December 2021. Candidate slates were as follows:

74.4% of roles included a diverse slate with at least two women globally and/or U.S. underrepresented minorities for U.S. hires; and
92.2% of roles included a diverse slate with at least one woman globally and/or U.S. underrepresented minority for U.S. hires compared to 86% in 2020.

In 2021, women representation in Citi’s full-time global campus programs surpassed its goal of 50%, increasing to 51% from 49% in 2020. In addition, Black and Hispanic/Latino representation within Citi’s full-time U.S. campus programs increased to 28% from 24% in 2020.


Workforce Development
Citi highly values a workplace environment where colleagues can bring their authentic 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 37% of open positions filled internally in 2021. These opportunities are particularly important as Citi focuses on providing career paths for its internal talent base as part of its efforts to increase organic growth and promotions within the organization.

Moreover, in 2021, a diverse group of human resources and business stakeholders collaborated to provide input on the current state and target future state for promotions at Citi. Their analysis resulted in the identification of opportunities for improvement to create greater transparency and alignment of the promotion process across Citi’s businesses, functions and regions.

Wellness
During the past two years, the pandemic’s impact has been substantial on the mental and physical health of Citi colleagues and their families. As the Company transforms and the future of work evolves, colleague wellness is a central component of Citi’s focus. Coming out of the pandemic, Citi has announced three working models: colleagues will be designated as hybrid, resident or remote, based on job-specific requirements.
As colleagues pivoted to remote work during their respective country lockdowns, Citi’s health plans also expanded to keep colleagues at home and safe. In the U.S., Citi offered free virtual care visits, home delivery of prescriptions, enhanced bereavement leave and no-cost COVID testing.
In addition to providing access to COVID vaccinations, which included several onsite locations in Asia and the U.S., Citi organized drive-through flu vaccination programs in the U.S. for thousands of colleagues and their family members. All colleagues globally were provided time off for vaccinations and boosters and to recover from any side effects, if needed.
To support the ongoing health of its workforce, on October 28, 2021 Citi announced a COVID-19 vaccination policy requiring all U.S. colleagues and new hires to be fully vaccinated or receive an approved accommodation or state-permitted exemption, as a condition of employment. As of the January 14, 2022 deadline, over 99% of U.S. colleagues were in compliance with the vaccine policy.
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Citi also took actions to support the emotional well-being of its colleagues. Citi significantly enhanced free mental well-being programs in our largest region by doubling the number of free counseling sessions for colleagues and their family members and adding real-time text, video and message-based counseling. Citi also debuted a new online tool so that all colleagues around the globe could easily find their local Employee Assistance programs and resources. Citi also expanded live, town hall-style mental well-being programming to include targeted events with subject matter experts aimed at parents, caregivers and other at-risk groups.
Citi’s wellness vision is not simply a reaction to its external environment. It has consistently been about nurturing colleagues and their families, however their families are grown. Citi continues to broaden gender affirmation medical coverage and incorporate it in its basic medical plan coverage around the world. Citi also enhanced its fertility coverage and support. In North America, Citi’s new Adoption and Surrogacy Assistance Program provides reimbursement to help with certain expenses in the adoption of a child or surrogacy parenting arrangement.
In early 2020, Citi expanded its Paid Parental Leave Policy to include Citi colleagues around the world. At a minimum, all Citi colleagues are eligible for 16 weeks of paid pregnancy leave or four weeks of paid parental bonding leave. Colleagues working in countries that require leave policies above the global minimum continue to maintain even longer periods of paid time off.

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 upcoming 2022 proxy statement to be filed with the SEC in March 2022, as well as its 2020 ESG report available at www.citigroup.com. The 2020 ESG report and other information included elsewhere on Citi’s investor relations website are not incorporated by reference into, and do not form any part of, this 2021 Annual Report on Form 10-K.
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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 LoanCredit Losses on Loans (ACLL)7586
Non-Accrual Loans and Assets and Renegotiated Loans
Forgone Interest Revenue on Loans7991
LIQUIDITY RISK
Overview
Liquidity Monitoring and Measurement
High-Quality Liquid Assets (HQLA)8193
Loans8294
Deposits8294
Long-Term Debt8395
Secured Funding Transactions and Short-Term Borrowings8698
Credit Ratings8899
MARKET RISK(1)
Overview
Market Risk of Non-Trading Portfolios
Net Interest RevenueIncome at Risk
Interest Rate Risk of Investment Portfolios—Impact on AOCI
Changes in Foreign Exchange Rates—Impacts on AOCI and Capital
92103
Interest Revenue/Expense and Net Interest Margin (NIM)
Additional Interest Rate Details95106
Market Risk of Trading Portfolios
Factor Sensitivities100111
Value at Risk (VAR)100111
Stress Testing103114
OPERATIONAL RISK
Overview
Cybersecurity Risk
COMPLIANCE RISK
REPUTATION RISK
STRATEGIC RISK
   OverviewOTHER RISKS
   Exit of U.K. from EULIBOR Transition Risk
   LIBOR TransitionClimate Risk118
Country Risk
   Country Risk
Top 25 Country Exposures
Argentina
Russia
FFIEC—Cross-Border Claims on Third Parties and Local Country Assets

(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.
(1)    For additional information regarding certain credit risk, market risk and other quantitative and qualitative information, refer to Citi’s Pillar 3 Basel III Advanced Approaches Disclosures, as required by the rules of the Federal Reserve Board, on Citi’s Investor Relations website.
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MANAGING GLOBAL RISK

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 missionMission and value proposition,Value Proposition and the key principles that guide it, andas well as Citi's risk appetite. As discussed above, Citi is continuing its efforts to comply with the FRB 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 missionMission and value proposition,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 employeescolleagues to ensure that their decisions pass three tests: they are in Citi’s clients’ interests, create economic value and are always systemically responsible. In addition, Citi evaluates employees’colleagues’ performance against behavioral expectations set out in Citi’s leadership standards,Leadership Principles, which were designed in part to effectuate Citi’s missionMission and value proposition.Value Proposition. Other culture-related efforts in connection with conduct risk, ethics and leadership, escalation and treating customers fairly help Citi to execute its missionMission and value proposition.
Citi’s Company-wide risk governance framework consists of the key policies, standards and processes through which Citi identifies, assesses, measures, monitors and controls risks across the Company. It also emphasizes Citi’s risk culture and lays out standards, procedures and programs that are designed to set, reinforce and enhance the Company’s risk culture, integrate its values and conduct expectations into the organization, providing employees with tools to assist them with making prudent and ethical risk decisions and to escalate issues appropriately.Value Proposition.
Citi selectively takes risks in support of its underlying customer-centric strategy. Citi’s objective ishas established an Enterprise Risk Management (ERM) Framework to ensure that thoseall of Citi’s risks are consistent with its missionmanaged appropriately and value propositionconsistently across Citi and principleat an aggregate, enterprise-wide level. The ERM Framework details the principles used to support effective enterprise-wide risk management across the end-to-end risk management lifecycle. The ERM Framework also provides clarity on the expected activities in relation to risk management of responsible finance; that they are identified, assessed, measured, monitored and controlled; and that they are captured in Citi’s risk/reward assessment.
Citi’s risk appetite framework, which is approved by the Citigroup Board of Directors includes both(the Board), Citi’s Executive Management Team (See “Risk Governance—Executive Management Team” below) and employees across the lines of defense. The underlying pillars of the framework encompass:

Culture—the core principles and behaviors that underpin a strong culture of risk awareness, in line with Citi’s Mission and Value Proposition, and Leadership Principles;
Governance—the committee structure and reporting arrangements that support the appropriate oversight of risk management activities at the Board and Executive Management Team levels;
Risk Management—the end-to-end risk management cycle including the identification, measurement, monitoring, controlling and reporting of all risks including emerging, growing, idiosyncratic or otherwise material risks, and aggregated to an enterprise-wide level; and
Enterprise Programs—the key risk management programs performed across the risk management lifecycle for all risk categories; these programs also outline the specific roles played by each of the lines of defense in these processes.

Each of these pillars is underpinned by Supporting Capabilities, which are the infrastructure, people, technology and data, and modelling and analytical capabilities that are in place to enable the execution of the ERM Framework.
Citi’s approach to risk management requires that its risk-taking be consistent with its risk appetite. Risk appetite statement, which articulatesis the aggregate leveltype and typeslevel of risk that Citi is willing to accepttake in order to achievemeet its strategic objectives and business objectives,plan. Citi’s Risk Appetite Framework sets boundaries for risk-taking and consists of a set of risk appetite statements as well as the overall approachgovernance processes through which the risk appetite is established, communicated, cascaded and monitored. It is built on quantitative boundaries, which include risk limits or thresholds, and on qualitative principles to guide behavior. Citi’s risk appetite framework is comprehensive, incorporating all risks, enterprise-wide and applicable across products, functions and geographies.

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 Citi 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 Citi.
Market risk (Trading and Non-Trading): Market risk of trading portfolios is the risk of loss arising from changes in the value of Citi’s assets and liabilities resulting from changes in market variables, such as equity and commodity prices or credit spreads. Market risk of non-trading portfolios is the risk to current or projected financial condition and resilience arising from movements in interest rates and resulting from repricing risk, basis risk, yield curve risk and options risk.
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 Citi to comply with laws, regulations, prudent ethical standards and contractual obligations in any aspect of Citi’s business, but excludes strategic and reputation risks (see below).
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.
Reputation risk is the risk to current or projected financial conditions and resilience arising from negative public opinion.
Strategic risk is the risk of a sustained impact (not episodic impact) to Citi’s core strategic objectives as measured by impacts on anticipated earnings, market capitalization, or capital, arising from the external factors is the risk of loss resulting from the decline in credit quality or the failure of a borrower, counterparty, third party or issuer to honor its financial or contractual obligations.
Liquidity risk is the risk that the Company will not be able to efficiently meet both expected and unexpected current and future cash flow and collateral needs without adversely affecting either daily operations or financial conditions of the Company. The risk may be exacerbated by the inability of the Company to access funding sources or monetize assets and the composition of liability funding and liquid assets.
Market risk (including price risk and interest rate risk) is the risk of loss arising from changes in the value of Citi’s assets and liabilities resulting from changes in market variables, such as interest rates, exchange rates or credit spreads. Losses can be exacerbated by the negative convexity of positions, as well as the presence of basis or correlation risks.
Operational risk is the risk of loss resulting from inadequate or failed internal processes, systems, human factors or from external events. It includes the reputation and franchise risk impact associated with business practices or market conduct in which Citi is involved. It also includes the risk of failing to comply with applicable laws and regulations, but excludes strategic risk (see below).
Compliance risk is the risk to current or projected financial conditions and resilience arising from violations of laws, rules or regulations, or from nonconformance with prescribed practices, internal policies and procedures or ethical standards. It also includes the exposure to litigation (known as legal risk) from all aspects of banking, traditional and nontraditional.Compliance risk spans across all risk types outlined in the risk governance framework.
Reputation risk is the risk to current or projected financial conditions and resilience arising from negative public opinion.
Strategic risk is the risk to current or anticipated earnings, capital, or franchise or enterprise value arising from poor but authorized business decisions (in compliance with regulations, policies and procedures), an inability to adapt to changes in the operating environment or other external factors that may impair the ability to carry out a business strategy. Strategic risk also includes:

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


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affecting the Company’s operating environment; as well as the risks associated with defining the strategy and executing the strategy, which are identified, measured and managed as part of the Strategic Risk Framework at the Enterprise Level.

Citi manages its risks throughuses a “three lines of defense” model: (i) business management; (ii) Independentdefense model as a key component of its ERM Framework to manage its risks. The lines of defense model brings together risk-taking, risk oversight and risk assurance under one umbrella and provides an avenue for risk accountability of first line of defense, a construct for effective challenge by the second line of defense (Independent Risk Management and Independent Compliance Risk ManagementManagement), and other control functions;empowers independent risk assurance by the third line of defense (Internal Audit). In addition, Citi has enterprise support functions that support safety and (iii) Internal Audit. The threesoundness across Citi. Each of the lines of defense collaborateand enterprise support functions, along with each otherthe Board, are empowered to perform relevant risk management processes and responsibilities in structured forumsorder to manage Citi’s risks in a consistent and processes to bring together various perspectives and to lead the organization toward outcomes that are in clients’ interests, that create economic value and that are systemically responsible.effective manner.

First Line of Defense: Business ManagementFront Line Units and Front Line Unit Activities
Through Citi’s business management (“frontline units” or the “firstfirst line of defense”), each businessdefense owns the risks inherent in or arising from its businesses,their business and is responsible for identifying, assessingmeasuring, monitoring, controlling and controllingreporting those risks to ensure theyconsistent with Citi’s strategy, Mission and Value Proposition, Leadership Principles and 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 appetite, establishingmanagement. They are also responsible for designing and operatingimplementing effective internal controls to mitigate those risks,and maintaining processes for managing their risk profile, including concentration risks, performing manager assessmentsthrough risk mitigation, so that it remains consistent with Citi’s established risk appetite.
Front line unit activities are considered part of the designfirst line of defense and effectivenessare subject to the oversight and challenge of internal controls, implementing appropriate procedures to fulfill itsindependent risk governance responsibilities and promoting a culture of compliance and control.management.
The first line of defense is composed of Citi’s businesses (Institutional Clients Group (ICG)Business
Management, Regional and Country Management, certain Corporate Functions (Enterprise Operations and Technology, Chief Administrative Office, Global Consumer Bank (GCB))Public Affairs, Office of the Citibank Chief Executive Officer (CEO) and Finance), supporting clients globally as well as in regionsother front line unit activities. Front line units may also include enterprise support units and countries that execute Citi’s strategy locally. In addition, there are functional teams, such as Enterprise Infrastructure, Operations and Technology (EIO&T) that support the Citi CEO in a first line capacity. The CEOs of each region, business, EIO&T and certain functional teams report to the Citigroup CEO.activities—see “Enterprise Support Functions” below.

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

Second Line of Defense: Independent Risk Management; Control Functions
Citi’sManagement 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, controlling and reporting aggregate risks and for setting standards for the management and oversight of risk. Independent risk management is comprised of Independent Risk Management (IRM) and Independent Compliance Risk Management (ICRM) together with other control functions (Finance, Human Resources, Legal) set standards that Citiand are led by chief risk executives (i.e., Chief Risk Officer (CRO)
and Chief Compliance Officer (CCO)) who have unrestricted access to the Citigroup Board of Directors and its businesses and products are requiredRisk Management Committee to adherefacilitate the ability to in orderexecute their specific responsibilities pertaining to manage and oversee risks, including conformance with applicable laws, regulatory requirements, policies and other relevant standardsescalation to the Citigroup Board of ethical conduct. IRM and ICRM provide credible challenge to first line units in their assessment and management of risk. In addition, among other responsibilities, IRM, ICRM and the control functions provide advice and training to Citi’s businesses and establish tools, methodologies, processes and oversight of controls used by the businesses to foster a culture of compliance and control. Where certain activities of control functions constitute first line activity, such activities are subject to appropriate review and challenge.Directors.


Independent Risk Management
The Independent Risk ManagementIRM organization sets risk and control standards for the businessfirst line of defense and actively manages and oversees aggregate credit, market (price, FX(trading and interest rate)non-trading), liquidity, strategic, operational compliance and reputation risks across the Company,Citi, including risks that span categories, such as concentration risk, country risk and climate risk.
Independent Risk ManagementIRM is organized to align to businesses, risk categories, legal entities/regions risk types and to Citi-wide,Company-wide, cross-risk functions or processes.processes (i.e., foundational areas). There are teams that report to an independent Chief Risk Officer (CRO)CRO for Citi’s businesses (business CROs)various risk categories and regions (regional CROs).legal entities/regions. In addition, there are foundational teams that report to the heads for certain risk categories (e.g., Global Market Risk)Foundational Risk Management heads. The Risk Category, Legal Entity/Regional CROs and for certain foundational risk areas (e.g., GlobalFoundational Risk Review). All of the risk heads, together with the business and regional CROs,Management Heads report to the Citigroup CRO.
The head of Independent Risk Management is the Citigroup CRO, who reports directly to the Citigroup CEO and to the Citigroup Risk Management Committee (RMC) of the Board of Directors. As part of its responsibilities, the RMC approves the appointment and removal of the CRO. The CRO has regular and unrestricted access to the full Citigroup Board, as well as the Risk Management Committee of the Board, to discuss risks and issues identified through Independent Risk Management’s activities, including instances in which the CRO’s assessment differs from that of the business or the CEO, and instances in which the business or the CEO may not be adhering to the risk governance framework.

Independent Compliance Risk Management
The Independent Compliance Risk ManagementICRM organization is an independent risk management function that is designed to oversee and credibly challenge products, functions, jurisdictional activities and legal entities in managingactively oversees compliance risk as well as promotingacross Citi, sets compliance risk and control standards for the first line of defense to manage compliance risk and promotes business conduct and activity that is consistent with Citi’s missionMission and value propositionValue Proposition and the compliance risk appetite. Citi’s objective is to embed an enterprise-wide compliance risk management framework and culture that identifies, escalates, measures, monitors, reportscontrols and controlsescalates compliance risk across the three lines of defense. For further information on Citi’sCiti.
ICRM is aligned by product line, function and geography to provide compliance risk framework, see “Compliance Risk” below.
The Citigroup Chiefmanagement advice and credible challenge on day-to-day matters and strategic decision-making for key initiatives. ICRM also has program-level Enterprise Compliance Officer reports to the Citigroup CEOunits responsible for setting standards and has regular and unrestricted access to committees of the Citigroup and Citibank Boards of Directors, including the Audit Committees,establishing priorities for program-related compliance efforts. These Compliance Risk Management Committees and the Ethics, Conduct and Culture Committee of the Citigroup Board.

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

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

Legal
Citi Legal is responsible for advising Citi’s lines of business and control functions in order to facilitate the prudent management of Citi’s exposure to legal risk.
Citi Legal’s organizational structure is designed to insulate it from potential conflicts of interest that could undermine its role in providing advice in regard to legal obligations and exposures of Citi.
Activities within Citi Legal include providing legal advice to Citi’s businesses and other functions on the interpretation of legal and regulatory requirements, including contractual requirements, and on managing and mitigating legal exposure based on a proper understanding of legal requirements; providing legal advice to promote the reporting of Citi’s and its subsidiaries obligations to identify legal matters to regulators and investors, as required by law; helping to identify current and emerging legal risks that arise in the context of Citi’s provision of products and services to its clients; attending meetings of the Board of Directors and committees of the Board to facilitate the oversight role of these bodies; and participating in management committees and forums where legal risk should be considered and evaluated.
The General Counsel leads Citi Legal and reportsheads report directly to the Citigroup CEO. The General Counsel meets regularly with the Board of Directors, the Audit Committee, the Risk Management Committee, the Ethics, Conduct and Culture Committee and the Nomination, Governance and Public Affairs Committee and is involved in the discussion of legal issues that arise in the context of items being presented to the Board and its committees.CCO.

Finance
Finance’s mission is to serve as an advisor to the business, delivering timely, accurate and complete information to each of its constituencies, accompanied by insightful analytics, and operating in a cost-efficient manner with highly effective controls.
The Finance organization, led by the Chief Financial Officer (CFO), is composed of a set of core, global disciplines (capital planning, controllers, corporate M&A, corporate
treasury, financial planning and analysis, investor relations and tax). Through the disciplines, Finance advises business management, escalates identified risks and establishes policies, standards or processes to manage risk. Also reporting to the Citigroup CFO are a set of product, geographical and legal entity Finance Officers who, along with their teams, interact with the global finance disciplines in the execution of their responsibilities.
Citi’s CFO reports directly to the Citigroup CEO. The CFO chairs or co-chairs several management committees that serve as key governance and oversight forums for business activities. In addition, the CFO has regular and unrestricted access to the full Citigroup Board of Directors as well as to the Audit Committee of the Board of Directors.

Third Line of Defense: Internal Audit
Internal Audit is independent of front line units and independent risk management units. The role of Internal Audit is to provide independent, objective, reliable, valued and timely assurance to the Citigroup and Citibank Boards, theBoard of Directors, its Audit Committees of the Boards,Committee, Citi senior management and regulators regardingover the effectiveness of governance, risk management and controls that mitigate current and evolving risks and enhance the control culture within Citi.
Internal Audit reports to a chief audit executive (i.e., Citi’s Chief Auditor) who has unrestricted access to the Board and the board of directors of certain subsidiaries or their respective audit committees 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, includingoperates.

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Enterprise Support Functions
Enterprise support functions engage in activities that support safety and soundness across Citi. These functions provide advisory services and/or design, implement, maintain and oversee Company-wide programs that support Citi in maintaining an effective control environment.
Enterprise support functions are comprised of Human Resources, International Franchise Management, Legal (including Citi Security and Investigative Services).
Enterprise support functions, units and activities are subject to the relevant Company-wide independent oversight processes specific Chief Auditors for Finance, ICRMto the risk category that they generate (e.g., operational risk, compliance risk, reputation risk).

Risk Governance
Citi’s ERM Framework encompasses risk management processes to address risks undertaken by Citi through identification, measurement, monitoring, controlling and Independent Risk Management.reporting of all risks. The ERM Framework integrates these processes with appropriate governance to complement Citi’s commitment to maintaining strong and consistent risk management practices.

Board Oversight
The Board is responsible for oversight of risk management and holds the Executive Management Team accountable for implementing the ERM Framework and meeting strategic objectives within Citi’s risk appetite.

Executive Management Team
The Board delegates authority to an Executive Management Team for directing and overseeing day-to-day management of Citi. The Executive Management Team is led by the Citigroup Chief Auditor managesCEO and provides oversight of group activities, both directly and through authority delegated to committees it has established to oversee the management of risk, to ensure continued alignment with Citi’s strategy and risk appetite.

Board and Executive Management Committees
The Board executes its responsibilities either directly or through its committees. The Board has delegated authorities to the following Board standing committees to help fulfill its oversight and risk management responsibilities:

Risk Management Committee (RMC): assists the Board in fulfilling its responsibility with respect to (i) oversight of Citi’s risk management framework, including the significant policies and practices used in managing credit, market, liquidity, strategic, operational, compliance, reputation and certain other risks, including those pertaining to capital management, and (ii) performance oversight of the Global Risk Review—credit, capital and collateral review functions.
Audit Committee: provides oversight of Citi’s financial reporting and internal control risk, as well as Internal Audit and reports functionally to the Chair of the Citigroup Audit Committee and administratively to the CEO of Citigroup. Internal Audit’s responsibilities are carried out independently under the oversight of the Audit Committees, and Internal Audit employees accordingly report to the Citigroup Chief Auditor and do not have reporting lines to either first or second line of defense management.Citi’s external independent accountants.

Citigroup Board of Directors and Committees of the Board
Citigroup’s Board of Directors actively oversees Citi’s risk-taking activities and holds management accountable for adhering to the risk governance framework. Directors review reports prepared by and receive presentations from management, and exercise independent judgment to question, probe and challenge recommendations of and decisions made by management.
The standing committees of the Citigroup Board of Directors are the Executive Committee, Risk Management Committee, Audit Committee, Personnel and Compensation Committee:provides oversight of incentive compensation plans and risk related to compensation.
Ethics, Conduct and Culture Committee Operations and Technology Committee and : provides oversight of Citi’s Conduct Risk Management Program.
Nomination, Governance and Public Affairs Committee. Committee:provides oversight of reputational issues, Environmental, Social and Governance (ESG) and sustainability matters, and legal and regulatory compliance risks as they relate to corporate governance matters.

In addition to the above, the Board has established the following ad hoc committee:

Transformation Oversight Committee: provides oversight of the actions of Citi’s management to develop and execute a transformation of Citi’s risk and control environment pursuant to the recent regulatory consent orders (for additional information see “Citi’s Consent Order Compliance” above).

The Executive Management Team has established five standing committees that cover the primary risks to which Citi (i.e., Group) is exposed. These consist of:

Group Strategic Risk Committee (GSRC): provides governance oversight of Citi’s management actions to adequately identify, monitor, report, manage and escalate all material strategic risks facing Citi.
Citigroup Asset and Liability Committee (ALCO): responsible for governance over management’s Liquidity Risk and Market Risk (non-trading) management and for monitoring and influencing the balance sheet, investment securities and capital management activities of Citigroup.
Group Risk Management Committee (GRMC): provides governance oversight of Credit Risk and Market Risk (trading) management in the Trading Book.
Group Business Risk and Control Committee (GBRCC):provides governance oversight of Citi’s Compliance and Operational Risks.
Group Reputation Risk Committee (GRRC): provides governance oversight for Reputation Risk management across Citi.

In addition to the Executive Management committees listed above, the Board establishes additionalmay establish ad-hoc committees as necessary or appropriate in response to regulatory legalfeedback or other requirements.to manage additional activities where deemed necessary.





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The figure below illustrates the reporting lines between the Board and Executive Management committees:

c-20211231_g2.jpg


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 settlementclearing and clearingsettlement 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-establishedan established framework in place for managing credit risk across all businesses. Thisbusinesses that includes a defined risk appetite, credit limits and credit policies, both at the business level as well as at the Company-wide level.policies. 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 settlementclearing and clearingsettlement activities, intraday client usage of clearing lines is monitored against limits, as well as against usage patterns.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 settlementclearing and clearingsettlement lines are uncommitted and cancelable at any time.
To manage concentration of risk within credit risk, Citi has in place a correlation framework consisting of industry limits, an
idiosyncratic framework consisting of single name concentrations for each business and across Citigroup and a specialized framework consisting of product limits.
Credit exposures are generally reported in notional terms for accrual loans, reflecting the value at which the loans as well as loan and other off-balance sheet commitments are carried on the Consolidated Balance Sheet. Credit exposure arising from capital markets activities is generally expressed as the current mark-to-market, net of margin, reflecting the net value owed to Citi by a given counterparty.
The credit risk associated with these credit exposures is a function of the idiosyncratic creditworthiness of the obligor, as well as the terms and conditions of the specific obligation. Citi assesses the credit risk associated with its credit exposures on a regular basis through its loan loss reserveAllowance for Credit Losses (ACL) process (see “Significant Accounting Policies and Significant Estimates—Allowance for Credit Losses” below and Notes 1 and 15 to the Consolidated Financial Statements), as well as through regular
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.
















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CONSUMER CREDIT
Citi provides traditionalfulfills a broad spectrum of customers’ financial needs with activities spanning retail banking, includingwealth management, credit card, personal loan, mortgage and small business banking and credit card products in 19 countries and jurisdictions through North America GCB,. During 2021, Citi also provided such activities in 18 countries in Latin America GCB and Asia GCB (for information on Citi’s consumer market exits in Latin America GCB and Asia GCB, see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above). The retail banking products include consumer mortgages, home equity, personal and small business loans and lines of credit and similar related products withbuilding a focus ongenerally prime portfolio through well-defined lending to prime customers.parameters. Citi uses its risk appetite framework to define its lending parameters. In addition, Citi uses proprietary scoring models for new customer approvals.
As stated in “
Global Consumer Banking” above, GCB’s overall strategy is to leverage Citi’s global footprint and be the pre-eminent bank for the affluent and emerging affluent consumers in large urban centers. In credit cards and in certain retail markets, Citi serves customers in a somewhat broader set of segments and geographies. As of the fourth quarter of 2019, Citi’s commercial banking businesses previously reported as part of GCB in North America, Latin America and Asia, including approximately $28 billion in end-of-period loans, are now reported in ICG for all periods presented.    











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

In billions of dollars4Q’201Q’212Q’21
3Q’21(2)
4Q’21(2)
Retail banking:
Mortgages$88.9 $86.7 $86.3 $79.8 $79.5 
Personal, small business and other40.1 39.1 39.0 37.0 36.1 
Total retail banking$129.0 $125.8 $125.3 $116.8 $115.6 
Cards:
Branded cards$106.7 $99.6 $102.9 $100.6 $105.7 
Retail services46.4 42.5 42.7 42.7 46.0 
Total cards$153.1 $142.1 $145.6 $143.3 $151.7 
Total GCB
$282.1 $267.9 $270.9 $260.1 $267.3 
GCB regional distribution:
North America65 %64 %64 %67 %68 %
Latin America5 
Asia(3)
30 31 31 28 27 
Total GCB
100 %100 %100 %100 %100 %
Corporate/Other(4)
$6.7 $6.1 $5.0 $4.2 $3.9 
Total consumer loans$288.8 $274.0 $275.9 $264.3 $271.2 

(1)End-of-period loans include interest and fees on credit cards.
(2)As a result of Citi’s entry into agreements to sell its consumer banking businesses in Australia and the Philippines, the businesses were reclassified as held-for-sale and their assets and liabilities were included in Other assets and Other liabilities,respectively, on Citi’s Consolidated Balance Sheet and excluded from loans and related credit measures, of GCB and Asia GCB beginning in the third quarter of 2021 for Australia and the fourth quarter of 2021 for the Philippines. For additional information, see Note 2 to the Consolidated Financial Statements.
(3)Asia includes loans and leases in certain EMEA countries for all periods presented.
(4)Primarily consists of legacy assets, principally North America consumer mortgages.
In billions of dollars4Q’181Q’192Q’193Q’194Q’19
Retail banking:     
Mortgages$80.6
$80.8
$81.9
$83.0
$85.1
Personal, small business and other37.0
37.3
37.8
37.6
39.7
Total retail banking$117.6
$118.1
$119.7
$120.6
$124.8
Cards:     
Citi-branded cards$116.8
$111.4
$115.5
$115.8
$122.2
Citi retail services52.7
48.9
49.6
50.0
52.9
Total cards$169.5
$160.3
$165.1
$165.8
$175.1
Total GCB
$287.1
$278.4
$284.8
$286.4
$299.9
GCB regional distribution:
     
North America67%66%66%66%66%
Latin America6
6
6
6
6
Asia(2)
27
28
28
28
28
Total GCB
100%100%100%100%100%
Corporate/Other(3)
$15.3
$12.6
$11.7
$11.0
$9.6
Total consumer loans$302.4
$291.0
$296.5
$297.4
$309.5

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

For information on changes to Citi’s end-of-period consumer loans, see “Liquidity Risk—Loans” below.



70



Overall Consumer Credit Trends
The following charts show
Global Consumer Banking
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As shown in the quarterly trends in delinquencies (90+ days past due (90+ DPD) ratio) and thechart above, GCB’s net credit losses (NCL) ratio across both retail bankingloss rate decreased quarter-over-quarter and cardsyear-over-year for totalthe fourth quarter of 2021, primarily reflecting the continued impact of government stimulus, unemployment benefits and consumer relief programs in North America GCB, and a decline following the peak charge-offs in Asia GCB and by region.Latin America GCB in recent quarters.

GCB’s 90+ days past due delinquency rate remained unchanged quarter-over-quarter. The 90+days past due delinquency rate decreased year-over-year, primarily due to the continued impacts of government stimulus, unemployment benefits and consumer relief programs in North America GCB, as well as lower delinquencies in Asia GCB and Latin America GCB, following the charge-off of peak delinquencies in recent quarters.

Global Consumer BankingNorth America GCB
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cctglobalvf.jpgc-20211231_g5.jpg
North America GCB
legenda75.jpg
cctnav3.jpg

North America GCBprovides mortgage, home equity, small business and personal loans through Citi’s retail banking network and card products through Citi-brandedbranded cards and Citi retail services businesses. The retail bank is concentrated in six major metropolitan cities in the United StatesU.S. (for additional information on the U.S. retail bank, see “North America GCB” above).
As of December 31, 2019,2021, approximately 75%74% of North America GCB consumer loans consisted of Citi-brandedbranded and Citi retail services cards, which generally drives the overall credit performance of North America GCB(for (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 increasedfor the fourth quarter of 2021 decreased quarter-over-quarter and year-over-year, primarily reflecting the continued impact of high payment rates in cards, driven by seasonality in Citi retail servicesgovernment stimulus.
Year-over-year, the payment rates were also impacted by unemployment benefits and consumer relief programs.
portfolios. The 90+ days past due delinquency rate alsoin North America GCB increased modestly quarter-over-quarter, primarily due to seasonality in the cards, portfolios.
The net credit loss rate andwhile the 90+ days past due delinquency rate increaseddecreased year-over-year, primarily reflecting the continued impact of high payment rates in cards, driven by seasoning of more recent vintages in Citi-branded cards and an increase in net flow rates in later delinquency buckets in Citi retail services.government stimulus.


Latin America GCB
c-20211231_g3.jpg
cctlatamv3.jpgc-20211231_g6.jpg

Latin America GCBoperates in Mexico through
Citibanamex one of Mexico’s largest banks, and provides
credit cards, consumer mortgages and small business and personal loans. Latin America GCBserves a more mass-market segment in Mexico and focuses on developing multi-productmultiproduct relationships with customers.
As shown in the chart above, the net credit loss rate in Latin America GCB for the fourth quarter of 2021 decreased quarter-over-quarter primarily dueand year-over-year. The impact of charge-offs of delinquent loans in prior quarters resulted in lower delinquencies that led to seasonalitylower net credit losses in the cards portfolio, while thecurrent quarter.
The 90+ days past due delinquency rate remained broadly stable.
decreased quarter-over-quarter and year-over-year. The net credit lossimpact of charge-offs of delinquent loans in prior quarters and higher payment rates resulted in a lower 90+ days past due delinquency rate decreased year-over-year, primarily due to the growth in recent vintages for cards as well as a slower pace of acquisitions in the retail portfolios during 2019.current quarter.

Asia(1) GCB
c-20211231_g3.jpgcctasiav4a03.jpgc-20211231_g7.jpg

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

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

71


During 2021, Asia GCBoperates operated in 17 countries and jurisdictions in Asia and EMEA and EMEA
and providesprovided credit cards, consumer mortgages and small business and personal loans.
As shown in the chart above, the fourth quarter of 2021 net credit loss rate in Asia GCB decreased quarter-over-quarter, primarily duedriven by the charge-off of peak delinquencies in recent quarters. Year-over-year, the net credit loss rate decreased, as elevated losses during the prior year returned to seasonality, whilepre-pandemic levels. The decrease was also driven by the reclassification of approximately $10 billion of loans to held-for-sale as a result of Citi’s entry into agreements to sell its consumer banking businesses in Australia and the Philippines (Asia HFS reclass).
The 90+ days past due delinquency rate remained broadly stable quarter-over-quarter. Year-over-year,decreasedquarter-over-quarter and year-over-year, driven by the net credit loss andcharge-off of peak delinquencies in recent quarters, as elevated losses returned to pre-pandemic levels, as well as the 90+ days past due delinquency rate remained broadly stable.impact of the Asia HFS reclass.
The stability inperformance of Asia GCB’s portfolios reflectscontinues 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 stable portfolioimproved 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 NoteNotes 13 and 14 to the Consolidated Financial Statements.


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
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North America Citi-BrandedBranded Cards
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North America GCB’s Citi-brandedbranded cards portfolio issuesincludes proprietary and co-branded cards.
As shown in the chart above, the net credit loss rate in North America Citi-brandedbranded cards was relatively stablefor the fourth quarter of 2021 decreased quarter-over-quarter whileand year-over-year, primarily reflecting the continued impact of high payment rates, driven by government stimulus. Year-over-year, the payment rates were also impacted by unemployment benefits and consumer relief programs.
The 90+ days past due delinquency rate increased,remained unchanged quarter-over-quarter and decreased year-over-year, primarily reflecting the continued impact of high payment rates, driven by seasonality.government stimulus. Year-over-year, the payment rates were also impacted by unemployment benefits and consumer relief programs.

The net credit loss and 90+ days past due delinquency rate increased year-over-year, primarily driven by seasoning of more recent vintages.






North America Citi Retail Services
c-20211231_g3.jpg
ccnaretailv2.jpgc-20211231_g10.jpg

Citi retailRetail services partners directly with more than 20 retailers and dealers to offer private label and co-branded cards. Citi retailRetail services’ target market is focusedfocuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel.
Citi retailRetail services continually evaluates opportunities to add partners within target industries that have strong loyalty, lending or payment programs and growth potential.
As shown in the chart above, the net credit loss and 90+ days past due delinquency rate in Citi retail services increasedfor the fourth quarter of 2021 decreased quarter-over-quarter and year-over-year, primarily due to seasonality.reflecting the continued impact of high payment rates, driven by government stimulus. Year-over-year, the payment rates were also impacted by unemployment benefits and consumer relief programs.
The net credit loss rate and 90+ days past due delinquency rate increased quarter-over-quarter due to seasonality, and decreased year-over-year, primarily reflecting the continued impact of high payment rates, driven by an increase in net flowgovernment stimulus. Year-over-year, the payment rates in later delinquency buckets.were also impacted by unemployment benefits and consumer relief programs.

72


Latin America Citi-BrandedBranded Cards
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Latin America GCBissues proprietary and co-branded cards.
As shown in the chart above, the fourth quarter of 2021 net credit loss rate in Latin America branded cards decreased quarter-over-quarter and year-over-year. The impact of charge-offs of delinquent loans in prior quarters resulted in lower delinquencies that led to lower net credit losses in the current quarter.
The 90+ days past due delinquency rate decreased quarter-over-quarter and year-over-year. The impact of charge-offs of delinquent loans in prior quarters and higher payment rates resulted in a lower 90+ days past due delinquency rate.

Asia Branded Cards(1)
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(1)cards. Asia includes loans and leases in certain EMEA countries for all periods presented.

As shown in the chart above, the net credit loss rate in Latin AmericaAsia Citi-brandedbranded cards for the fourth quarter of 2021 decreased quarter-over-quarter primarily dueand year-over-year, driven by the charge-off of peak delinquencies in recent quarters, as elevated losses returned to seasonality,pre-pandemic levels, as well as the impact of the Asia HFS reclass.
while theThe 90+ days past due delinquency rate remained stable.decreased
The net credit lossquarter-over-quarter and 90+ days past due delinquency rate decreased year-over-year, primarily due to growthdriven by the charge-off of peak delinquencies in recent vintages.


Asia Citi-Branded Cards(1)
legenda75.jpg
ccasiacardsv3a01.jpg

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

Asia GCB issues proprietary and co-branded cards.
As set forth inquarters, as elevated losses returned to pre-pandemic levels, as well as the chart above, the net credit loss rate in Asia Citi-branded cards decreased quarter-over-quarter, primarily due to seasonality, while the 90+ days past due delinquency rate remained broadly stable.HFS reclass.
Year-over-year, the net credit loss rate and 90+ days past due delinquency rate remained broadly stable.
For additional information on cost of credit, delinquency and other information for Citi’s cards portfolios, see each respective business’s results of operations above and Note 1314 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 alla substantial share of the portfolio and on a quarterly basis for the remaining portfolio.

Branded Cards
FICO distribution(1)
Dec. 31, 2021Sept. 30, 2021Dec. 31, 2020
  > 76049 %48 %46 %
  680–76038 39 39 
  < 68013 13 15 
Total100 %100 %100 %
Citi-Branded Cards
FICO distribution(1)
Dec 31, 2019Sept. 30, 2019Dec 31, 2018
  > 76042%41%42%
   680–76041
41
41
  < 68017
18
17
Total100%100%100%
Retail Services


FICO distribution(1)
Dec. 31, 2021Sept. 30, 2021Dec. 31, 2020
  > 76028 %27 %27 %
  680–76044 45 44 
  < 68028 28 29 
Total100 %100 %100 %
Citi Retail Services
FICO distribution(1)
Dec 31, 2019Sept. 30, 2019Dec 31, 2018
   > 76025%24%25%
   680–76042
43
42
  < 68033
33
33
Total100%100%100%
(1)The FICO bands in the tables are consistent with general industry peer presentations.

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

BothThe FICO distribution of both cards portfolios remained largely stable compared to the Citi-branded cards’prior quarter and Citi retail services’ cards FICO distributions remained stableimproved compared to the prior year, demonstrating strong underlying credit quality and a benefit from the impacts of government stimulus, unemployment benefits and customer relief programs, as of year-end 2019.
well as lower credit utilization. For additional information on FICO scores, see Note 14 to the Consolidated Financial Statements.



73


Additional Consumer Credit Details

Consumer Loan Delinquencies Amounts and Ratios

 
EOP
loans(1)
90+ days past due(2)
30–89 days past due(2)
December 31,December 31,December 31,
In millions of dollars,
except EOP loan amounts in billions
2021202120202019202120202019
Global Consumer Banking(3)(4)
Total$267.3 $1,521 $2,507 $2,737 $1,661 $2,517 $3,001 
Ratio0.57 %0.89 %0.91 %0.62 %0.89 %1.00 %
Retail banking
Total$115.6 $462 $632 $438 $522 $860 $816 
Ratio0.40 %0.49 %0.35 %0.45 %0.67 %0.66 %
North America48.1 228 299 146 219 328 334 
Ratio0.49 %0.58 %0.29 %0.47 %0.63 %0.67 %
Latin America8.6 107 130 106 106 220 180 
Ratio1.24 %1.33 %0.91 %1.23 %2.24 %1.54 %
Asia(5)(6)
58.9 127 203 186 197 312 302 
Ratio0.22 %0.31 %0.30 %0.33 %0.47 %0.48 %
Cards
Total$151.7 $1,059 $1,875 $2,299 $1,139 $1,657 $2,185 
Ratio0.70 %1.22 %1.31 %0.75 %1.08 %1.25 %
North America—branded
87.9 389 686 915 408 589 814 
Ratio0.44 %0.82 %0.95 %0.46 %0.70 %0.85 %
North America—retail services
46.0 482 644 1,012 539 639 945 
Ratio1.05 %1.39 %1.91 %1.17 %1.38 %1.79 %
Latin America4.7 76 233 165 67 170 159 
Ratio1.62 %4.85 %2.75 %1.43 %3.54 %2.65 %
Asia(5)(6)
13.1 112 312 207 125 259 267 
Ratio0.85 %1.74 %1.04 %0.95 %1.45 %1.34 %
Corporate/Other—Consumer(7)
Total$3.9 $221 $313 $278 $88 $179 $295 
Ratio6.14 %5.13 %3.02 %2.44 %2.93 %3.21 %
Total Citigroup$271.2 $1,742 $2,820 $3,015 $1,749 $2,696 $3,296 
Ratio0.65 %0.98 %0.98 %0.65 %0.94 %1.07 %

(1)End-of-period (EOP) loans include interest and fees on credit cards.
(2)The ratios of 90+ days past due and 30–89 days past due are calculated based on EOP loans, net of unearned income.
(3)The 90+ days past due balances for North America—branded and North America—retail services are generally still accruing interest. Citigroup’s policy is generally to accrue interest on credit card loans until 180 days past due, unless notification of bankruptcy filing has been received earlier.
(4)The 90+ days past due and 30–89 days past due and related ratios for North America GCB exclude loans guaranteed by U.S. government-sponsored agencies since the potential loss predominantly resides with the U.S. government-sponsored agencies. The amounts excluded for loans 90+ days past due and (EOP loans) were $185 million ($1.1 billion), $171 million ($0.7 billion) and $135 million ($0.5 billion) at December 31, 2021, 2020 and 2019, 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 $74 million, $98 million and $72 million at December 31, 2021, 2020 and 2019, respectively.
(5)Asia includes delinquencies and loans in certain EMEA countries for all periods presented.
(6)During 2021, Citi’s Australia and the Philippines consumer banking businesses were reclassified as HFS, due to Citi’s entry into agreements to sell the businesses. Accordingly, Australia and the Philippines consumer loans are recorded in Other assets on the Consolidated Balance Sheet, and hence the loans and related delinquencies and ratios are not included in this table. See Note 2 to the Consolidated Financial Statements for additional information.
(7)The 90+ days past due and 30–89 days past due and related ratios exclude U.S. mortgage loans that are primarily related to U.S. mortgages guaranteed by U.S. government-sponsored agencies since the potential loss predominantly resides with the U.S. agencies. The amounts excluded for 90+ days past due EOP loans were $138 million ($0.4 billion), $183 million ($0.5 billion) and $172 million ($0.4 billion) at December 31, 2021, 2020 and 2019, 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 $35 million, $73 million and $55 million at December 31, 2021, 2020 and 2019, respectively.


74

 
EOP
loans(1)
90+ days past due(2)
30–89 days past due(2)
 December 31,December 31,December 31,
In millions of dollars, except EOP loan amounts in billions2019201920182017201920182017
Global Consumer Banking(3)(4)
       
Total$299.9
$2,737
$2,550
$2,378
$3,001
$2,864
$2,687
Ratio 0.91%0.89%0.84%1.00%1.00%0.95%
Retail banking       
Total$124.8
$438
$416
$415
$816
$752
$747
Ratio 0.35%0.36%0.35%0.66%0.64%0.64%
North America50.3
146
135
134
334
265
256
Ratio 0.29%0.29%0.29%0.67%0.56%0.55%
Latin America11.7
106
108
112
180
185
181
Ratio 0.91%0.95%0.96%1.54%1.62%1.55%
Asia(5)
62.8
186
173
169
302
302
310
Ratio 0.30%0.30%0.29%0.48%0.52%0.52%
Cards       
Total$175.1
$2,299
$2,134
$1,963
$2,185
$2,112
$1,940
Ratio 1.31%1.26%1.19%1.25%1.25%1.18%
North America—Citi-branded
96.3
915
812
768
814
755
698
Ratio 0.95%0.88%0.85%0.85%0.82%0.77%
North America—Citi retail services
52.9
1,012
952
845
945
932
830
Ratio 1.91%1.81%1.72%1.79%1.77%1.69%
Latin America6.0
165
171
151
159
170
153
Ratio 2.75%3.00%2.80%2.65%2.98%2.83%
Asia(5)
19.9
207
199
199
267
255
259
Ratio 1.04%1.03%1.01%1.34%1.32%1.31%
Corporate/Other—Consumer(6)
       
Total$9.6
$278
$382
$557
$295
$362
$542
Ratio 3.02%2.63%2.58%3.21%2.50%2.51%
Total Citigroup$309.5
$3,015
$2,932
$2,935
$3,296
$3,226
$3,229
Ratio 0.98%0.97%0.91%1.07%1.07%1.06%

(1)End-of-period (EOP) loans include interest and fees on credit cards.
(2)The ratios of 90+ days past due and 30–89 days past due are calculated based on EOP loans, net of unearned income.
(3)
The 90+ days past due balances for North America—Citi-brandedand North America—Citi retail services are generally still accruing interest. Citigroup’s policy is generally to accrue interest on credit card loans until 180 days past due, unless notification of bankruptcy filing has been received earlier.
(4)
The 90+ days past due and 30–89 days past due and related ratios for North America GCB exclude U.S. mortgage loans that are guaranteed by U.S. government-sponsored agencies since the potential loss predominantly resides within the agencies. The amounts excluded for loans 90+ days past due and (EOP loans) were $135 million ($0.5 billion), $211 million ($0.7 billion) and $305 million ($0.8 billion) at December 31, 2019, 2018 and 2017, respectively. The amounts excluded for loans 30–89 days past due (EOP loans have the same adjustment as above) were $72 million, $86 million and $93 million at December 31, 2019, 2018 and 2017, respectively.
(5)
Asia includes delinquencies and loans in certain EMEA countries for all periods presented.
(6)The 90+ days past due and 30–89 days past due and related ratios exclude U.S. mortgage loans that are guaranteed by U.S. government-sponsored agencies since the potential loss predominantly resides within the agencies. The amounts excluded for loans 90+ days past due and (EOP loans) were $172 million ($0.4 billion), $367 million ($0.8 billion) and $663 million ($1.2 billion) at December 31, 2019, 2018 and 2017, respectively. The amounts excluded for loans 30–89 days past due (EOP loans have the same adjustment as above) were $55 million, $122 million and $164 million at December 31, 2019, 2018 and 2017, respectively.



Consumer Loan Net Credit Losses and Ratios

 
Average
loans(1)
Net credit losses(2)(3)
In millions of dollars, except average loan amounts in billions2019201920182017
Global Consumer Banking    
Total$284.1
$7,382
$6,884
$6,462
Ratio 2.60 %2.48%2.39%
Retail banking    
Total$119.7
$910
$913
$923
Ratio 0.76 %0.78%0.79%
North America48.5
161
126
135
Ratio

0.33
0.27
0.29
Latin America11.5
494
545
550
Ratio 4.30
4.58
4.40
Asia(4)
59.7
255
242
238
Ratio 0.43
0.41
0.42
Cards    
Total$164.4
$6,472
$5,971
$5,539
Ratio 3.94 %3.72%3.60%
North America—Citi-branded
89.8
2,864
2,602
2,447
Ratio 3.19
2.97
2.90
North America—Citi retail services
49.9
2,558
2,357
2,155
Ratio 5.13
4.88
4.73
Latin America5.7
615
586
533
Ratio 10.79
10.65
10.06
Asia(4)
19.0
435
426
404
Ratio 2.29
2.25
2.17
Corporate/Other—Consumer(3)
    
Total$11.9
$(6)$24
$156
Ratio (0.05)%0.14%0.57%
International

42
82
Ratio 
6.00
4.32
North America11.9
(6)(18)74
Ratio (0.05)NM
0.29
Other(5)



(21)
Total Citigroup$296.0
$7,376
$6,908
$6,597
Ratio 2.49 %2.33%2.22%
(1)Average loans include interest and fees on credit cards.
(2)The ratios of net credit losses are calculated based on average loans, net of unearned income.
(3)
As a result of Citigroup's entry into agreements in 2016 to sell its Argentina and Brazil consumer banking businesses, these businesses were classified as HFS at the end of the fourth quarter of 2016. Loans HFS are excluded from this table as they are recorded in Other assets. In addition, as a result of HFS accounting treatment, approximately $128 million of net credit losses (NCLs) were recorded as a reduction in revenue (Other revenue) during 2017. Accordingly, these NCLs are not included in this table. The sales of the Argentina and Brazil consumer banking businesses were completed in 2017.
(4)
Asia includes NCLs and average loans in certain EMEA countries for all periods presented.
(5)2017 NCLs reflected a recovery related to legacy assets.

 
Average
loans(1)
Net credit losses(2)
In millions of dollars, except average loan amounts in billions2021202120202019
Global Consumer Banking   
Total$266.3 $4,582 $6,646 $7,382 
Ratio1.72 %2.39 %2.60 %
Retail banking
Total$122.3 $779 $805 $910 
Ratio0.64 %0.65 %0.76 %
North America50.0 109 132 161 
Ratio0.22 %0.25 %0.33 %
Latin America9.0 410 377 494 
Ratio4.56 %3.85 %4.30 %
Asia(3)(4)
63.3 260 296 255 
Ratio0.41 %0.47 %0.43 %
Cards
Total$144.0 $3,803 $5,841 $6,472 
Ratio2.64 %3.82 %3.94 %
North America—branded
81.1 1,659 2,708 2,864 
Ratio2.05 %3.20 %3.19 %
North America—retail services
43.1 1,169 2,150 2,558 
Ratio2.71 %4.62 %5.13 %
Latin America4.4 510 489 615 
Ratio11.59 %10.40 %10.79 %
Asia(3)(4)
15.4 465 494 435 
Ratio3.02 %2.84 %2.29 %
Corporate/Other—Consumer
Total$5.3 $(82)$(21)$(6)
Ratio(1.55)%0.25 %0.14 %
Total Citigroup$271.6 $4,500 $6,625 $7,376 
Ratio1.66 %2.32 %2.49 %


(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.
(4)As a result of Citi’s entry into agreements to sell its consumer banking businesses in Australia and the Philippines during 2021, these businesses were reclassified as HFS beginning in 2021. As a result of HFS accounting treatment, approximately $6 million of net credit losses (NCLs) was recorded as a reduction in revenue (Other revenue) in 2021. Accordingly, these NCLs are not included in this table, as well as Loans HFS that are recorded in Other assets on the Consolidated Balance Sheet. See Note 2 to the Consolidated Financial Statements for additional information.

75


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

In millions of dollars at December 31, 2021Due within
1 year
Greater than
1 year
but within
5 years
Greater than
5 years
but within 15 years
Greater than
15 years
Total
In North America offices
Residential first mortgages$15 $109 $2,573 $41,116 $43,813 
Home equity loans65 56 1,484 3,496 5,101 
Credit cards133,868    133,868 
Personal, small business and other1,092 1,678 237 151 3,158 
Total$135,040 $1,843 $4,294 $44,763 $185,940 
In offices outside North America
Residential mortgages$2,022 $651 $6,667 $25,261 $34,601 
Credit cards17,808    17,808 
Personal, small business and other23,323 8,180 1,124 260 32,887 
Total$43,153 $8,831 $7,791 $25,521 $85,296 

Fixed/Variable Pricing

In millions of dollars at December 31, 2021Due within
1 year
Greater than
1 year
but within
5 years
Greater than
5 years
but within 15 years
Greater than
15 years
Total
Loans at fixed interest rates
Residential first mortgages$225 $183 $1,990 $31,581 $33,979 
Home equity loans65 51 223 336 675 
Credit cards42,117    42,117 
Personal, small business and other11,883 6,407 37 83 18,410 
Total$54,290 $6,641 $2,250 $32,000 $95,181 
Loans at floating or adjustable interest rates
Residential first mortgages$1,812 $577 $7,250 $34,796 $44,435 
Home equity loans 5 1,261 3,160 4,426 
Credit cards109,559    109,559 
Personal, small business and other12,532 3,451 1,324 328 17,635 
Total$123,903 $4,033 $9,835 $38,284 $176,055 
In millions of dollars at December 31, 2019
Due
within
1 year
Greater
than 1 year
but within
5 years
Greater
than 5
years
Total
U.S. consumer mortgage loan portfolio    
Residential first mortgages$3
$118
$46,887
$47,008
Home equity loans92
330
8,801
9,223
Total$95
$448
$55,688
$56,231
Fixed/variable pricing of U.S. consumer mortgage loans with maturities due after one year    
Loans at fixed interest rates $430
$35,975
 
Loans at floating or adjustable interest rates 18
19,713
 
Total $448
$55,688
 

76


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. AsDuring 2021, Citi’s corporate credit exposures also included exposures in the private bank, excluding certain loans managed on a delinquency basis. For information on Citi’s planned revision to its reporting structure effective for the first quarter of 2022, including the reporting of the fourth quarter of 2019, Citi’s commercial banking businesses previously reportedprivate bank as part of a new reporting segment, GCB in North America, Latin AmericaPersonal Banking and AsiaWealth Management, including approximately $28 billion in end-of-period loans, are now reported in ICG for all periods presented.    see “Strategic Refresh—Market Exits and Planned Revision to Reporting Structure” above.

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
























December 31, 2019September 30, 2019December 31, 2018 December 31, 2021September 30, 2021December 31, 2020
In billions of dollars
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
Due
within
1 year
Greater
than 1 year
but within
5 years
Greater
than
5 years
Total
exposure
In billions of dollarsDue
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
Due
within
1 year
Greater
than 1 year
but within
5 years
Greater
than
5 years
Total
exposure
Direct outstandings
(on-balance sheet)(1)
$141
$117
$23
$281
$150
$115
$24
$289
$144
$119
$23
$286
Direct outstandings
(on-balance sheet)(1)
$187 $136 $21 $344 $192 $134 $21 $347 $175 $138 $25 $338 
Unfunded lending commitments
(off-balance sheet)(2)
145
249
17
411
133
250
16
399
111
253
18
382
Unfunded lending commitments
(off-balance sheet)(2)
159 278 13 450 164 286 11 461 158 272 11 441 
Total exposure$286
$366
$40
$692
$283
$365
$40
$688
$255
$372
$41
$668
Total exposure$346 $414 $34 $794 $356 $420 $32 $808 $333 $410 $36 $779 

(1)Includes drawn loans, overdrafts, bankers’ acceptances and leases.
(2)Includes unused commitments to lend, letters of credit and financial guarantees.
(1)    Includes drawn loans, overdrafts, bankers’ acceptances and leases.
(2)    Includes unused commitments to lend, letters of credit and financial guarantees.


Portfolio Mix—Geography Counterparty and IndustryCounterparty
Citi’s corporate credit portfolio is diverse byacross geography and counterparty. The following table shows the regional percentagespercentage of this portfolio by region (excluding the delinquency-managed private bank portfolio) based on Citi’s internal management geography:

December 31,
2021
September 30,
2021
December 31,
2020
North America57 %57 %56 %
EMEA24 25 25 
Asia13 13 13 
Latin America6 
Total100 %100 %100 %


 December 31,
2019
September 30,
2019
December 31,
2018
North America55%55%54%
EMEA26
26
26
Asia12
12
12
Latin America7
7
8
Total100%100%100%

The maintenance of accurate and consistent risk ratings across the corporate credit portfolio facilitates the comparison of credit exposure across all lines of business, geographic regions and products. Counterparty risk ratings reflect an estimated probability of default for a counterparty and are derived by leveraging validated statistical models, scorecard models and external agency ratings (under defined circumstances), in combination with consideration of factors specific to the obligor or market, such as management experience, competitive position, and regulatory environment
and
and commodity prices. Facility risk ratings are assigned that reflect the probability of default of the obligor and factors that affect the loss given default of the facility, such as support or collateral. Internal obligor ratings that generally correspond to
BBB and above are considered investment grade, while those below are considered non-investment grade.
Citigroup has also incorporated environmental factors such as climate risk assessment and reporting criteria for certain obligors, as necessary. Factors evaluated include consideration of climate risk to an obligor’s business and physical assets and, when relevant, consideration of cost-effective options to reduce greenhouse gas emissions.
77


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 Total exposure
December 31,
2019
September 30,
2019
December 31,
2018
December 31,
2021
September 30,
2021
December 31,
2020
AAA/AA/A46%46%47%AAA/AA/A51 %49 %49 %
BBB36
36
35
BBB32 32 31 
BB/B16
16
17
BB/B15 16 17 
CCC or below2
2
1
CCC or below2 
Total100%100%100%Total100 %100 %100 %


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

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 consumer retail, commercial real estate and transportation).
Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2021. Since the onset of the pandemic, Citi 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’s seeking to reduce exposure to an obligor or an industry sector. Citi will continue to review exposures to ensure that the appropriate probability of default is also diversified by industry. The following table shows the allocation of Citi’s total corporate credit portfolio by industry:
 Total exposure
 December 31,
2019
September 30,
2019
December 31,
2018
Transportation and
 industrial
21%21%22%
Consumer retail
and health
17
17
17
Technology, media
and telecom
12
12
13
Power, chemicals,
metals and mining
11
10
10
Banks/broker-dealers/finance companies8
8
8
Real estate8
8
8
Energy and commodities8
8
8
Public sector4
4
5
Insurance and special purpose entities4
4
4
Hedge funds4
4
4
Other industries3
4
1
Total100%100%100%

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,
2021
September 30,
2021
December 31,
2020
Transportation and
industrials
18 %19 %19 %
Private bank14 14 14 
Consumer retail10 10 11 
Technology, media
and telecom
11 10 10 
Real estate9 
Power, chemicals,
metals and mining
8 
Banks and finance companies7 
Energy and commodities6 
Health4 
Public sector3 
Insurance4 
Asset managers and funds3 
Financial markets infrastructure2 
Securities firms — — 
Other industries1 
Total100 %100 %100 %


78


The following table details Citi’s corporate credit portfolio by industry as of December 31, 2021:

Non-investment gradeSelected metrics
In millions of dollarsTotal credit exposure
Funded(1)
Unfunded(1)
Investment gradeNon-criticizedCriticized performing
Criticized non-performing(2)
30 days or more past due and accruing(3)
Net credit losses (recoveries)(4)
Credit derivative hedges(5)
Transportation and industrials$143,444 $51,502 $91,942 $110,047 $19,051 $13,196 $1,150 $384 $127 $(8,791)
Autos(6)
48,210 18,662 29,548 39,824 5,365 2,906 115 49 (3,228)
Transportation26,896 12,085 14,811 19,233 2,344 4,447 872 105 104 (1,334)
Industrials68,338 20,755 47,583 50,990 11,342 5,843 163 230 21 (4,229)
Private bank114,018 79,684 34,334 110,684 2,060 1,190 84 793 6 (1,080)
Consumer retail78,995 32,894 46,101 60,687 13,590 4,311 407 224 100 (5,115)
Technology, media and telecom84,334 28,542 55,792 64,677 15,873 3,587 197 156 11 (6,875)
Real estate69,808 46,220 23,588 58,089 6,761 4,923 35 116 50 (798)
Power, chemicals, metals and mining65,641 20,224 45,417 53,576 10,708 1,241 116 292 22 (5,808)
Power26,199 5,610 20,589 22,860 2,832 420 87 100 17 (3,032)
Chemicals25,550 8,525 17,025 20,789 4,224 528 88 (2,141)
Metals and mining13,892 6,089 7,803 9,927 3,652 293 20 104 (1)(635)
Banks and finance companies58,251 36,803 21,448 49,466 4,892 3,890 3 150 (5)(680)
Energy and commodities(7)
48,973 13,485 35,488 38,972 7,517 2,220 264 224 78 (3,679)
Health33,393 8,826 24,567 27,599 4,702 942 150 95  (2,465)
Public sector23,842 12,464 11,378 21,035 1,527 1,275 5 37 (3)(1,282)
Insurance28,495 3,163 25,332 27,447 987 61  2 1 (2,711)
Asset managers and funds22,269 6,649 15,620 20,871 1,019 377 2 12  (113)
Financial markets infrastructure14,342 109 14,233 14,323 18  1   (22)
Securities firms1,472 613 859 605 816 51  4  (5)
Other industries6,590 2,802 3,788 4,146 1,892 490 62  6 (169)
Total$793,867 $343,980 $449,887 $662,224 $91,413 $37,754 $2,476 $2,489 $393 $(39,593)

(1)    Excludes $46.5 billion and $1.7 billion of funded and unfunded exposure at December 31, 2021, respectively, primarily related to the delinquency-managed private bank portfolio. Funded balances also excludes loans carried at fair value of $6.1 billion at December 31, 2021.
(2)    Includes non-accrual loan exposures and criticized unfunded exposures.
(3)    Excludes $36 million of past due loans primarily related to the delinquency-managed private bank portfolio.
(4)    Net credit losses (recoveries) are for the year ended December 31, 2021 and exclude delinquency-managed private bank net credit losses of $2 million.
(5)    Represents the amount of purchased credit protection in the form of derivatives to economically hedge funded and unfunded exposures. Of the $39.6 billion of purchased credit protection, $36.0 billion represents the total notional amount of purchased credit derivatives on individual reference entities. The remaining $3.6 billion represents the first loss tranche of portfolios of purchased credit derivatives with a total notional of $28.4 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 $17.9 billion ($6.5 billion in funded, with more than 99% rated investment grade) as of December 31, 2021.
(7)    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, 2021, Citi’s total exposure to these energy-related entities was approximately $5.1 billion, of which approximately $2.6 billion consisted of direct outstanding funded loans.



79


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

Non-investment gradeSelected metrics
In millions of dollarsTotal credit exposure
Funded(1)
Unfunded(1)
Investment gradeNon-criticizedCriticized performing
Criticized non-performing(2)
30 days or more past due and accruing(3)
Net credit losses (recoveries)(4)
Credit derivative hedges(5)
Transportation and industrials$145,449 $58,353 $87,096 $104,311 $17,452 $21,887 $1,798 $136 $239 $(8,110)
Autos(6)
52,150 23,586 28,564 41,334 4,374 6,167 275 45 (3,220)
Transportation27,693 14,107 13,586 16,410 2,993 6,872 1,417 17 144 (1,166)
Industrials65,606 20,660 44,946 46,566 10,085 8,848 106 111 50 (3,724)
Private bank(1)
109,397 75,693 33,705 104,244 2,395 2,510 248 963 78 (1,080)
Consumer retail81,941 34,621 47,320 60,683 11,524 9,418 316 146 64 (5,493)
Technology, media and telecom81,598 29,821 51,777 60,236 15,924 5,214 223 107 74 (7,237)
Real estate64,817 42,711 22,106 53,839 5,342 5,453 185 334 18 (642)
Power, chemicals, metals and mining63,273 20,156 43,117 47,534 11,367 4,181 192 59 70 (5,341)
Power26,555 6,018 20,537 22,405 3,311 685 154 14 57 (2,637)
Chemicals22,227 7,839 14,387 16,535 3,804 1,882 32 (2,102)
Metals and mining14,492 6,299 8,193 8,593 4,251 1,614 34 13 (602)
Banks and finance companies52,639 29,570 23,069 43,546 4,648 4,387 59 27 79 (765)
Energy and commodities(7)
48,447 14,009 34,438 33,678 7,226 6,546 996 70 285 (4,199)
Health35,421 8,575 26,846 29,081 4,354 1,749 238 17 17 (1,964)
Public sector26,705 13,416 13,289 22,098 1,887 2,704 16 45 (1,089)
Insurance26,576 1,925 24,651 25,864 575 136 — 27 (2,682)
Asset managers and funds19,745 4,491 15,254 18,528 1,013 191 13 41 (1)(84)
Financial markets infrastructure12,610 229 12,382 12,590 20 — — — — (9)
Securities firms976 430 547 573 298 97 — — (6)
Other industries9,009 4,247 4,762 4,980 2,404 1,442 182 10 43 (138)
Total$778,603 $338,246 $440,357 $621,784 $86,427 $65,914 $4,477 $1,982 $976 $(38,839)

(1)    Excludes $42.0 billion and $4.4 billion of funded and unfunded exposure at December 31, 2020, respectively, primarily related to the delinquency-managed private bank portfolio. Funded balances also excludes loans carried at fair value of $6.8 billion at December 31, 2020.
(2)    Includes non-accrual loan exposures and criticized unfunded exposures.
(3)    Excludes $162 million of past due loans primarily related to the delinquency-managed private bank portfolio.
(4)    Net credit losses (recoveries) are for the year ended December 31, 2020 and exclude delinquency-managed private bank credit losses 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 amount 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) at December 31, 2020.
(7)    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.

80


Exposure to Commercial Real Estate
As of December 31, 2021, ICG’s total corporate credit exposure to commercial real estate (CRE) was $66 billion, with $44 billion consisting of direct outstanding funded loans (mainly included in the real estate and private bank categories in the above table), or 7% of Citi’s total outstanding loans. In addition, as of December 31, 2021, more than 70% of ICG’s total corporate CRE exposure was to borrowers in the U.S. Also as of December 31, 2021, approximately 77% of ICG’s total corporate CRE exposure was rated investment grade.
As of December 31, 2021, the ACLL was 0.9% of funded CRE exposure, including 2.4% of funded non-investment-grade exposure.

Of the total CRE exposure:

$20 billion ($12 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.
$20 billion ($16 billion of direct outstanding funded loans) relates to exposure secured by mortgages on underlying properties or in well-rated securitization exposures.
$15 billion ($5 billion of direct outstanding funded loans) relates to unsecured loans to large REITs, with nearly 74% of the exposure rated investment grade.
$11 billion ($11 billion of direct outstanding funded loans) relates to CRE exposure in the private bank, of which 100% is secured by mortgages. In addition, 48% of the exposure is also full recourse to the client. As of December 31, 2021, 82% of the exposure was rated investment grade.


Credit Risk Mitigation
As part of its overall risk management activities, CitigroupCiti uses credit derivatives and other risk mitigants to hedge portions of the credit risk in its corporate credit portfolio, in addition to outright asset sales. Citi may enter into partial-term hedges as well as full-term hedges. In advance of the expiration of partial-term hedges, Citi will determine, among other factors, the economic feasibility of hedging the remaining life of the instrument. The results of the mark-to-market and any realized gains or losses on credit derivatives are reflected primarily in Principal transactions in the Consolidated Statement of Income.
At December 31, 2019,2021, September 30, 20192021 and December 31, 2018, Citigroup2020, ICG (excluding the delinquency-managed private bank portfolio) had economic hedges in place on the corporate credit portfolio of $35.2$39.6 billion, $29.5$38.1 billion and $30.2$38.8 billion, respectively. Citigroup’sCiti’s expected credit loss model used in the calculation of its loan loss reserveACL 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,
2019
September 30,
2019
December 31,
2018
December 31,
2021
September 30,
2021
December 31,
2020
AAA/AA/A32%34%35%AAA/AA/A35 %32 %30 %
BBB51
48
50
BBB49 47 48 
BB/B15
17
14
BB/B13 17 19 
CCC or below2
1
1
CCC or below3 
Total100%100%100%Total100 %100 %100 %

The credit protection was economically hedging underlying corporate credit portfolio exposures with the following industry distribution:

Industry of Hedged Exposure
 December 31,
2019
September 30,
2019
December 31,
2018
Transportation and industrial24%23%23%
Technology, media and telecom19
19
17
Consumer retail and health18
16
16
Power, chemicals, metals and mining15
14
15
Energy and commodities9
9
11
Insurance and special purpose entities7
5
6
Banks/broker-dealers/finance companies3
5
4
Public sector3
4
3
Real estate2
4
4
Other industries
1
1
Total100%100%100%




















81


Loan Maturities and Fixed/Variable Pricing of Corporate
Loans

In millions of dollars at December 31, 2019
Due
within
1 year
Over 1
year
but
within
5 years
Over 5
years
Total
Corporate loans    
In U.S. offices    
Commercial and industrial loans$20,679
$21,623
$13,627
$55,929
Financial institutions19,938
20,846
13,138
53,922
Mortgage and real estate19,735
20,633
13,003
53,371
Installment, revolving credit and other11,550
12,077
7,611
31,238
Lease financing477
499
314
1,290
In offices outside the U.S.124,384
59,295
10,506
194,185
Total corporate loans$196,763
$134,973
$58,199
$389,935
Fixed/variable
pricing of corporate
loans with
maturities due after
one year(1)
    
Loans at fixed
interest rates
 $22,432
$20,676
 
Loans at floating or
adjustable interest
rates
 112,541
37,523
 
Total
$134,973
$58,199
 
In millions of dollars at December 31, 2021Due within
1 year
Over 1 year
but within
5 years
Over 5 years
but within
15 years
Over
15 years
Total
Corporate loans
In North America offices(1)
Commercial and industrial loans$25,694 $24,878 $973 $454 $51,999 
Financial institutions50,299 16,534 91 12 66,936 
Mortgage and real estate(2)
12,385 5,948 5,460 39,564 63,357 
Installment, revolving credit and other13,090 13,454 2,573 26 29,143 
Lease financing95 230 88  413 
Total$101,563 $61,044 $9,185 $40,056 $211,848 
In offices outside the North America(1)
Commercial and industrial loans$75,502 $22,905 $4,650 $110 $103,167 
Financial institutions26,672 5,147 92 292 32,203 
Mortgage and real estate(2)
4,359 4,541 912 600 10,412 
Installment, revolving credit and other25,518 7,440 455 1,023 34,436 
Governments and official institutions792 2,183 843 605 4,423 
Lease financing1 23 18  42 
Total$132,844 $42,239 $6,970 $2,630 $184,683 
Corporate loans, net of unearned income(3)
$234,407 $103,283 $16,155 $42,686 $396,531 
Loans at fixed interest rates(4)
Commercial and industrial loans$6,003 $752 $96 
Financial institutions4,982 26 12 
Mortgage and real estate(2)
1,506 4,557 17,150 
Installment, revolving credit and other4,481 856 92 
Lease financing240 88  
Total$17,212 $6,279 $17,350 
Loans at floating or adjustable interest rates(4)
Commercial and industrial loans$41,780 $4,871 $468 
Financial institutions16,699 157 292 
Mortgage and real estate(2)
8,983 1,815 23,015 
Installment, revolving credit and other18,597 3,015 1,561 
Lease financing12 18  
Total$86,071 $9,876 $25,336 
Total fixed/variable pricing of corporate loans with maturities due after one year, net of unearned income(3)
$103,283 $16,155 $42,686 

(1)Based on contractual terms. Repricing characteristics may effectively
(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 ($799) million. Unearned income on corporate loans primarily represents interest received in advance, but not yet earned, on loans originated on a discounted basis.
(4)    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.


82


ADDITIONAL CONSUMER AND CORPORATE CREDIT DETAILS

Loans Outstanding
December 31,
In millions of dollars20212020201920182017
Consumer loans
In North America offices(1)
Residential first mortgages(2)
$43,813 $47,778 $47,008 $47,412 $49,375 
Home equity loans(2)
5,101 7,128 9,223 11,543 14,827 
Credit cards133,868 130,385 149,163 144,542 139,718 
Personal, small business and other3,158 4,509 3,699 4,046 4,140 
Total$185,940 $189,800 $209,093 $207,543 $208,060 
In offices outside North America(1)
Residential mortgages(2)
$34,601 $39,969 $38,024 $36,388 $37,870 
Credit cards17,808 22,692 25,909 24,951 25,727 
Personal, small business and other32,887 36,378 36,522 33,478 34,157 
Total$85,296 $99,039 $100,455 $94,817 $97,754 
Consumer loans, net of unearned income(3)
$271,236 $288,839 $309,548 $302,360 $305,814 
Corporate loans
In North America offices(1)
Commercial and industrial$51,999 $57,731 $55,929 $60,861 $60,219 
Financial institutions66,936 55,809 53,922 48,447 39,128 
Mortgage and real estate(2)
63,357 60,675 53,371 50,124 44,683 
Installment and other29,143 26,744 31,238 32,425 31,932 
Lease financing413 673 1,290 1,429 1,470 
Total$211,848 $201,632 $195,750 $193,286 $177,432 
In offices outside North America(1)
Commercial and industrial$103,167 $104,072 $112,668 $114,029 $113,178 
Financial institutions32,203 32,334 40,211 36,837 35,273 
Mortgage and real estate(2)
10,412 11,371 9,780 7,376 7,309 
Installment and other34,436 33,759 27,303 25,685 22,638 
Lease financing42 65 95 103 190 
Governments and official institutions4,423 3,811 4,128 4,520 5,200 
Total$184,683 $185,412 $194,185 $188,550 $183,788 
Corporate loans, net of unearned income(4)
$396,531 $387,044 $389,935 $381,836 $361,220 
Total loans—net of unearned income$667,767 $675,883 $699,483 $684,196 $667,034 
Allowance for credit losses on loans (ACLL)(16,455)(24,956)(12,783)(12,315)(12,355)
Total loans—net of unearned income and ACLL$651,312 $650,927 $686,700 $671,881 $654,679 
ACLL as a percentage of total loans—
net of unearned income
(5)
2.49 %3.73 %1.84 %1.81 %1.86 %
ACLL for consumer loan losses as a percentage of
total consumer loans—net of unearned income
(5)
5.02 %6.77 %3.20 %3.14 %3.08 %
ACLL for corporate loan losses as a percentage of
total corporate loans—net of unearned income
(5)
0.73 %1.42 %0.75 %0.74 %0.82 %

(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 $659 million, $749 million, $783 million, $742 million and $768 million at December 31, 2021, 2020, 2019, 2018 and 2017, 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 $(799) million, $(844) million, $(814) million, $(855) million and $(794) million at December 31, 2021, 2020, 2019, 2018 and 2017, 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.
83
 December 31,
In millions of dollars20192018201720162015
Consumer loans     
In North America offices(1)
     
Residential first mortgages(2)
$47,008
$47,412
$49,375
$53,131
$56,872
Home equity loans(2)
9,223
11,543
14,827
19,454
22,745
Credit cards149,163
144,542
139,718
133,297
113,352
Personal, small business and other3,699
4,046
4,140
5,290
5,396
Total$209,093
$207,543
$208,060
$211,172
$198,365
In offices outside North America(1)
     
Residential first mortgages(2)
$37,686
$35,972
$37,419
$35,336
$40,139
Credit cards25,909
24,951
25,727
23,055
26,617
Personal, small business and other36,860
33,894
34,608
31,153
35,980
Total

$100,455
$94,817
$97,754
$89,544
$102,736
Consumer loans, net of unearned income(3)
$309,548
$302,360
$305,814
$300,716
$301,101
Corporate loans     
In North America offices(1)
     
Commercial and industrial$55,929
$60,861
$60,219
$57,886
$53,611
Financial institutions53,922
48,447
39,128
35,517
36,425
Mortgage and real estate(2)
53,371
50,124
44,683
38,691
32,623
Installment, revolving credit and other31,238
32,425
31,932
31,194
30,426
Lease financing1,290
1,429
1,470
1,518
1,780
Total

$195,750
$193,286
$177,432
$164,806
$154,865
In offices outside North America(1)
     
Commercial and industrial$112,668
$114,029
$113,178
$100,532
$99,442
Financial institutions40,211
36,837
35,273
26,886
28,704
Mortgage and real estate(2)
9,780
7,376
7,309
5,363
5,106
Installment, revolving credit and other27,303
25,685
22,638
19,965
23,185
Lease financing95
103
190
251
303
Governments and official institutions4,128
4,520
5,200
5,850
4,911
Total

$194,185
$188,550
$183,788
$158,847
$161,651
Corporate loans, net of unearned income(4)
$389,935
$381,836
$361,220
$323,653
$316,516
Total loans—net of unearned income$699,483
$684,196
$667,034
$624,369
$617,617
Allowance for loan losses—on drawn exposures(12,783)(12,315)(12,355)(12,060)(12,626)
Total loans—net of unearned income 
and allowance for credit losses
$686,700
$671,881
$654,679
$612,309
$604,991
Allowance for loan losses as a percentage of total loans—
net of unearned income
(5)
1.84%1.81%1.86%1.94%2.06%
Allowance for consumer loan losses as a percentage of
total consumer loans—net of unearned income
(5)
3.20%3.14%3.08%2.94%3.08%
Allowance for corporate loan losses as a percentage of
total corporate loans—net of unearned income
(5)
0.75%0.74%0.82%1.01%1.08%
(1)North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America. The classification of corporate loans between offices in North America and outside North America is based on the domicile of the booking unit. The difference between the domicile of the booking unit and the domicile of the managing unit is not material.
(2)Loans secured primarily by real estate.
(3)Consumer loans are net of unearned income of $783 million, $742 million, $768 million, $803 million and $850 million at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. Unearned income on consumer loans primarily represents unamortized origination fees and costs, premiums and discounts.
(4)Corporate loans are net of unearned income of $(814) million, $(855) million, $(794) million, $(730) million and $(686) million at December 31, 2019, 2018, 2017, 2016 and 2015, respectively. Unearned income on corporate loans primarily represents interest received in advance, but not yet earned, on loans originated on a discounted basis.
(5)All periods exclude loans that are carried at fair value.




Details of Credit Loss Experience

In millions of dollars20212020201920182017
Allowance for credit losses on loans (ACLL) at beginning of year$24,956 $12,783 $12,315 $12,355 $12,060 
Adjustments to opening balance:
Financial instruments—credit losses (CECL)(1)
 4,201 — — — 
Variable post-charge-off third-party collection costs(2)
 (443)— — — 
Adjusted ACLL at beginning of year$24,956 $16,541 $12,315 $12,355 $12,060 
Provision for credit losses on loans (PCLL)
Consumer(2)
(966)11,765 7,751 7,258 7,329 
Corporate(2,137)4,157 467 96 174 
Total$(3,103)$15,922 $8,218 $7,354 $7,503 
Gross credit losses on loans
Consumer
In U.S. offices$4,055 $6,047 $6,538 $5,971 $5,664 
In offices outside the U.S. 2,143 2,144 2,316 2,351 2,377 
Corporate
Commercial and industrial, and other
In U.S. offices239 562 265 121 223 
In offices outside the U.S. 256 409 196 208 401 
Loans to financial institutions
In U.S. offices1 14 — 
In offices outside the U.S. 1 12 
Mortgage and real estate
In U.S. offices20 71 23 
In offices outside the U.S.5 — 
Total$6,720 $9,263 $9,341 $8,665 $8,673 
Credit recoveries on loans(2)
Consumer
In U.S. offices$1,204 $1,106 $975 $912 $892 
In offices outside the U.S. 494 460 503 502 552 
Corporate
Commercial and industrial, and other
In U.S. offices67 43 28 47 31 
In offices outside the U.S. 56 28 59 78 117 
Loans to financial institutions
In U.S. offices3 — — — 
In offices outside the U.S. 1 14 — 
Mortgage and real estate
In U.S. offices — 
In offices outside the U.S.  — 
Total$1,825 $1,652 $1,573 $1,552 $1,597 
Net credit losses on loans (NCLs)
In U.S. offices$3,041 $5,545 $5,815 $5,132 $4,966 
In offices outside the U.S. 1,854 2,066 1,953 1,981 2,110 
Total$4,895 $7,611 $7,768 $7,113 $7,076 
Other—net(3)(4)(5)(6)(7)(8)
$(503)$104 $18 $(281)$(132)
Allowance for credit losses on loans (ACLL) at end of year$16,455 $24,956 $12,783 $12,315 $12,355 
ACLL as a percentage of EOP loans(9)
2.49 %3.73 %1.84 %1.81 %1.86 %
Allowance for credit losses on unfunded lending commitments (ACLUC)(10)(11)
$1,871 $2,655 $1,456 $1,367 $1,258 
84


In millions of dollars20192018201720162015
Allowance for loan losses at beginning of period$12,315
$12,355
$12,060
$12,626
$15,994
Provision for loan losses     
Consumer$7,751
$7,258
$7,329
$6,207
$6,073
Corporate467
96
174
542
1,035
Total

$8,218
$7,354
$7,503
$6,749
$7,108
Gross credit losses     
Consumer     
In U.S. offices$6,538
$5,971
$5,664
$4,874
$5,439
In offices outside the U.S. 2,316
2,351
2,377
2,594
3,077
Corporate     
Commercial and industrial, and other     
In U.S. offices265
121
223
370
173
In offices outside the U.S. 196
208
401
334
297
Loans to financial institutions     
In U.S. offices
3
3
5

In offices outside the U.S. 3
7
1
5
4
Mortgage and real estate     
In U.S. offices23
2
2
34
8
In offices outside the U.S.
2
2
6
43
Total

$9,341
$8,665
$8,673
$8,222
$9,041
Credit recoveries(1)
     
Consumer     
In U.S. offices$975
$912
$892
$972
$954
In offices outside the U.S. 503
502
552
576
642
Corporate     
Commercial and industrial, and other     
In U.S. offices28
47
31
31
43
In offices outside the U.S. 59
78
117
79
84
Loans to financial institutions     
In U.S. offices

1
1
7
In offices outside the U.S. 
3
1
1
2
Mortgage and real estate     
In U.S. offices8
6
2
1
7
In offices outside the U.S. 
4
1


Total

$1,573
$1,552
$1,597
$1,661
$1,739
Net credit losses     
In U.S. offices$5,815
$5,132
$4,966
$4,278
$4,609
In offices outside the U.S. 1,953
1,981
2,110
2,283
2,693
Total$7,768
$7,113
$7,076
$6,561
$7,302
Other—net(2)(3)(4)(5)(6)(7)(8)
$18
$(281)$(132)$(754)$(3,174)
Allowance for loan losses at end of period$12,783
$12,315
$12,355
$12,060
$12,626
Allowance for loan losses as a percentage of total loans(9)
1.84%1.81%1.86%1.94%2.06%
Allowance for unfunded lending commitments(8)(10)
$1,456
$1,367
$1,258
$1,418
$1,402
Total allowance for loan losses and unfunded lending commitments$14,239
$13,682
$13,613
$13,478
$14,028
Net consumer credit losses$7,376
$6,908
$6,597
$5,920
$6,920
Total ACLL and ACLUC$18,326 $27,611 $14,239 $13,682 $13,613 
Net consumer credit losses on loans$4,500 $6,625 $7,376 $6,908 $6,597 
As a percentage of average consumer loans1.66 %2.32 %2.49 %2.33 %2.22 %
Net corporate credit losses on loans$395 $986 $392 $205 $479 
As a percentage of average corporate loans0.10 %0.25 %0.10 %0.05 %0.14 %
ACLL by type at end of year(12)
Consumer$13,616 $19,554 $9,897 $9,504 $9,412 
Corporate2,839 5,402 2,886 2,811 2,943 
Total$16,455 $24,956 $12,783 $12,315 $12,355 


(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 that was recorded as an adjustment to its January 1, 2020 opening allowance for credit losses on loans of $443 million. See Note 1 to the Consolidated Financial Statements.
(3)Includes all adjustments to the allowance for credit losses, such as changes in the allowance from acquisitions, dispositions, securitizations, FX translation, purchase accounting adjustments, etc.
(4)2021 includes an approximate $280 million reclass related to Citi’s agreement to sell its consumer banking business in Australia and an approximate $90 million reclass related to Citi’s agreement to sell its consumer banking business in the Philippines. Those ACLL were reclassified to Other assets during 2021. 2021 also includes a decrease of approximately $134 million related to FX translation.
(5)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.
(6)2019 includes reductions of approximately $42 million related to the sale or transfer to HFS of various loan portfolios. In addition, 2019 includes a reduction of approximately $60 million related to FX translation.
(7)2018 includes reductions of approximately $201 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.
(8)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.
(9)December 31, 2021, 2020, 2019, 2018 and 2017 exclude $6.1 billion, $6.9 billion, $4.1 billion, $3.2 billion and $4.4 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.


85

As a percentage of average consumer loans2.49%2.33%2.22%2.00%2.19%
Net corporate credit losses$392
$205
$479
$641
$382
As a percentage of average corporate loans0.10%0.05%0.14%0.20%0.12%
Allowance by type at end of period(11)
     
Consumer$9,897
$9,504
$9,412
$8,842
$9,273
Corporate2,886
2,811
2,943
3,218
3,353
Total Citigroup$12,783
$12,315
$12,355
$12,060
$12,626
(1)Recoveries have been reduced by certain collection costs that are incurred only if collection efforts are successful.
(2)Includes all adjustments to the allowance for credit losses, such as changes in the allowance from acquisitions, dispositions, securitizations, FX translation, purchase accounting adjustments, etc.
(3)2019 includes reductions of approximately $42 million related to the transfer to HFS of various real estate loan portfolios. In addition, 2019 includes an increase of approximately $60 million related to FX translation.
(4)2018 includes reductions of approximately $201 million related to the sale or transfer to HFS of various loan portfolios, which include approximately $91 million related to the transfer of various real estate loan portfolios to HFS. In addition, 2018 includes a reduction of approximately $60 million related to FX translation.
(5)2017 includes reductions of approximately $261 million related to the sale or transfer to HFS of various loan portfolios, which include approximately $106 million related to the transfer of various real estate loan portfolios to HFS. In addition, 2017 includes an increase of approximately $115 million related to FX translation.
(6)2016 includes reductions of approximately $574 million related to the sale or transfer to HFS of various loan portfolios, which include approximately $106 million related to the transfer of various real estate loan portfolios to HFS. In addition, 2016 includes a reduction of approximately $199 million related to FX translation.
(7)2015 includes reductions of approximately $2.4 billion related to the sale or transfer to HFS of various loan portfolios, which include approximately $1.5 billion related to the transfer of various real estate loan portfolios to HFS. In addition, 2015 includes a reduction of approximately $474 million related to FX translation.
(8)
2015 includes a reclassification of $271 million of Allowance for loan losses to allowance for unfunded lending commitments, included in the Other line item. This reclassification reflects the re-attribution of $271 million in the allowance for credit losses between the funded and unfunded portions of the corporate credit portfolios and does not reflect a change in the underlying credit performance of these portfolios.

(9)December 31, 2019, 2018, 2017, 2016 and 2015 exclude $4.1 billion, $3.2 billion, $4.4 billion, $3.5 billion and $5.0 billion, respectively, of loans which are carried at fair value.
(10)
Represents additional credit reserves recorded as Other liabilities on the Consolidated Balance Sheet.
(11)Allowance for loan losses represents management’s best estimate of probable losses inherent in the portfolio, as well as probable losses related to large individually evaluated impaired loans and troubled debt restructurings. See “Significant Accounting Policies and Significant Estimates” and Note 1 to the Consolidated Financial Statements below. Attribution of the allowance is made for analytical purposes only and the entire allowance is available to absorb probable credit losses inherent in the overall portfolio.

Allowance for LoanCredit Losses on Loans (ACLL)
The following tables detail information on Citi’s allowance for loan losses,ACLL, loans and coverage ratios:

 December 31, 2021
In billions of dollarsACLLEOP loans, net of
unearned income
ACLL as a
percentage of EOP loans(1)
Consumer
North America cards(2)
$10.8 $133.8 8.1 %
North America mortgages(3)
0.2 48.9 0.4 
North America other
0.3 3.2 9.4 
International cards1.2 17.8 6.7 
International other(4)
1.2 67.5 1.8 
Total$13.7 $271.2 5.1 %
Corporate
Commercial and industrial$1.5 $151.1 1.0 %
Financial institutions0.3 98.9 0.3 
Mortgage and real estate0.7 73.8 0.9 
Installment and other0.3 66.7 0.4 
Total$2.8 $390.5 0.7 %
Loans at fair value(1)
N/A$6.1 N/A
Total Citigroup$16.5 $667.8 2.5 %

(1)Loans carried at fair value do not have an ACLL and are excluded from the ACLL ratio calculation.
(2)Includes both branded cards and retail services. The $10.8 billion of loan loss reserves represented approximately 63 months of coincident net credit loss coverage. As of December 31, 2021, North America branded cards ACLL as a percentage of EOP loans was 7.1% and North America retail services ACLL as a percentage of EOP loans was 10.0%.
(3)Of the $0.2 billion, approximately $0.1 billion and $0.1 billion determined in accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. Of the $48.9 billion in loans, approximately $47.5 billion and $1.4 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.
(4)Includes mortgages and other retail loans.

 December 31, 2020
In billions of dollarsACLLEOP loans, net of
unearned income
ACLL as a
percentage of EOP loans(1)
Consumer
North America cards(2)
$14.7 $130.4 11.3 %
North America mortgages(3)
0.7 54.9 1.3 
North America other
0.3 4.5 6.7 
International cards2.1 22.7 9.3 
International other(4)
1.8 76.3 2.4 
Total$19.6 $288.8 6.8 %
Corporate
Commercial and industrial$3.6 $156.3 2.3 %
Financial institutions0.4 87.7 0.5 
Mortgage and real estate1.1 72.1 1.5 
Installment and other0.3 64.1 0.5 
Total$5.4 $380.2 1.4 %
Loans at fair value(1)
N/A$6.9 N/A
Total Citigroup$25.0 $675.9 3.7 %

(1)Loans carried at fair value do not have an ACLL and are excluded from the ACLL ratio calculation.
(2)Includes both branded cards and 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, North America branded cards ACLL as a percentage of EOP loans was 10.0% and North America retail services ACLL as a percentage of EOP loans was 13.6%.
(3)Of the $0.7 billion, nearly all was allocated to North America mortgages in Corporate/Other, including approximately $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.
(4)Includes mortgages and other retail loans.
86


 December 31, 2019
In billions of dollars
Allowance for
loan losses
Loans, net of
unearned income
Allowance as a
percentage of loans(1)
North America cards(2)
$7.0
$149.2
4.7%
North America mortgages(3)
0.3
56.2
0.5
North America other
0.1
3.7
2.7
International cards0.7
25.9
2.7
International other(4)
1.8
74.6
2.4
Total consumer$9.9
$309.6
3.2%
Total corporate2.9
389.9
0.7
Total Citigroup$12.8
$699.5
1.8%
The following table details Citi’s corporate credit allowance for credit losses on loans (ACLL) by industry exposure as of December 31, 2021:
(1)Allowance as a percentage of loans excludes loans that are carried at fair value.
(2)Includes both Citi-branded cards and Citi retail services. The $7.0 billion of loan loss reserves represented approximately 15 months of coincident net credit loss coverage.
(3)
Of the $0.3 billion, nearly all was allocated to North America mortgages in Corporate/Other, including $0.1 billion and $0.2 billion determined in accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. Of the $56.2 billion in loans, approximately $54.2 billion and $2.0 billion of the loans were evaluated in accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. For additional information, see Note 15 to the Consolidated Financial Statements.
(4)Includes mortgages and other retail loans.

In millions of dollars, except percentages
Funded exposure(1)
ACLLACLL as a % of funded exposure
Transportation and industrials$51,502 $597 1.16 %
Private bank79,684 145 0.18 
Consumer retail32,894 288 0.88 
Technology, media and telecom28,542 170 0.60 
Real estate46,220 509 1.10 
Power, chemicals, metals and mining20,224 151 0.75 
Banks and finance companies36,804 197 0.54 
Energy and commodities13,485 268 1.99 
Health8,826 73 0.83 
Public sector12,464 74 0.59 
Insurance3,162 8 0.25 
Asset managers and funds6,649 34 0.51 
Financial markets infrastructure109   
Securities firms613 10 1.63 
Other industries2,802 28 1.00 
Total classifiably managed loans(2)
$343,980 $2,552 0.74 %
Loans managed on a delinquency basis(3)
$46,481 $287 0.62 %
Total$390,461 $2,839 0.73 %

(1)    Funded exposure excludes loans carried at fair value of $6.1 billion that are not subject to ACLL under the CECL standard.
(2)    As of December 31, 2021, the ACLL shown above reflects coverage of 0.4% of funded investment-grade exposure and 2.3% of funded non-investment-grade exposure.
(3)    Primarily associated with delinquency-managed private bank loans including non-rated mortgage and real estate loans to private banking clients at December 31, 2021.

The following table details Citi’s corporate credit allowance for credit losses on loans (ACLL) by industry exposure as of December 31, 2020:

In millions of dollars, except percentages
Funded exposure(1)
ACLLACLL as a % of funded exposure
Transportation and industrials$58,352 $1,558 2.67 %
Private bank75,693 224 0.30 
Consumer retail34,621 563 1.63 
Technology, media and telecom29,821 407 1.36 
Real estate42,711 718 1.68 
Power, chemicals, metals and mining20,156 312 1.55 
Banks and finance companies29,570 219 0.74 
Energy and commodities14,009 523 3.73 
Health8,575 144 1.68 
Public sector13,416 172 1.28 
Insurance1,925 0.36 
Asset managers and funds4,491 22 0.49 
Financial markets infrastructure229 — — 
Securities firms430 10 2.33 
Other industries4,247 122 2.87 
Total classifiably managed loans(2)
$338,246 $5,001 1.48 %
Loans managed on a delinquency basis(3)
$41,958 $401 0.96 %
Total$380,204 $5,402 1.42 %

(1)    Funded exposure excludes loans carried at fair value of $6.8 billion that are not subject to ACLL under the CECL standard.
(2)    As of December 31, 2021, the ACLL shown above reflects coverage of 0.5% of funded investment-grade exposure and 4.4% of funded non-investment-grade exposure.
(3)    Primarily associated with delinquency-managed private bank loans including non-rated mortgage and real estate loans to private banking clients at December 31, 2020.
87
 December 31, 2018
In billions of dollars
Allowance for
loan losses
Loans, net of
unearned income
Allowance as a
percentage of loans(1)
North America cards(2)
$6.6
$144.5
4.6%
North America mortgages(3)
0.4
59.0
0.7
North America other
0.1
4.0
2.5
International cards0.7
25.0
2.8
International other(4)
1.7
69.9
2.4
Total consumer$9.5
$302.4
3.1%
Total corporate2.8
381.8
0.7
Total Citigroup$12.3
$684.2
1.8%
(1)Allowance as a percentage of loans excludes loans that are carried at fair value.
(2)Includes both Citi-branded cards and Citi retail services. The $6.6 billion of loan loss reserves represented approximately 16 months of coincident net credit loss coverage.
(3)
Of the $0.4 billion, nearly all was allocated to North America mortgages in Corporate/Other, including approximately $0.1 billion and $0.3 billion determined in accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. Of the $59.0 billion in loans, approximately $56.3 billion and $2.5 billion were evaluated in accordance with ASC 450-20 and ASC 310-10-35 (troubled debt restructurings), respectively. For additional information, see Note 15 to the Consolidated Financial Statements.

(4)Includes mortgages and other retail loans.



Non-Accrual Loans and Assets and Renegotiated Loans
There is a certain amount of overlap among non-accrual loans and assets and renegotiated loans. The following summary provides a general description of each category.

Non-Accrual Loans and Assets:

Corporate and consumer (including commercial banking) non-accrual status is based on the determination that payment of interest or principal is doubtful.
A corporate loan may be classified as non-accrual and still be performing under the terms of the loan structure. Non-accrual loans may still be current on interest payments. Approximately 44%, 41% and 48% of Citi’s corporate non-accrual loans were $1.9 billion, $2.4 billion and $3.5 billion as of December 31, 2021, September 30, 2021 and December 31, 2020, respectively. Of these, approximately 54%, 56% and 59% were performing at December 31, 2019,2021, September 30, 20192021 and December 31, 2018,2020, 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
North America 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.

88



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.

December 31,December 31,
In millions of dollars20192018201720162015In millions of dollars20212020201920182017
Corporate non-accrual loans(1)(2)
 
Corporate non-accrual loans(1)
Corporate non-accrual loans(1)
North America$1,214
$586
$966
$1,291
$1,005
North America$801 $1,928 $1,214 $586 $966 
EMEA430
375
849
904
347
EMEA399 661 430 375 849 
Latin America473
307
348
441
421
Latin America568 719 473 307 348 
Asia71
243
70
220
191
Asia109 219 71 243 70 
Total corporate non-accrual loans$2,188
$1,511
$2,233
$2,856
$1,964
Total corporate non-accrual loans$1,877 $3,527 $2,188 $1,511 $2,233 
Consumer non-accrual loans(1)(3)
 
Consumer non-accrual loans(1)
Consumer non-accrual loans(1)
North America$905
$1,138
$1,468
$1,854
$2,328
North America$759 $1,059 $905 $1,138 $1,468 
Latin America632
638
688
648
756
Latin America524 774 632 638 688 
Asia(4)
279
250
243
221
206
Asia(2)
Asia(2)
219 308 279 250 243 
Total consumer non-accrual loans$1,816
$2,026
$2,399
$2,723
$3,290
Total consumer non-accrual loans$1,502 $2,141 $1,816 $2,026 $2,399 
Total non-accrual loans$4,004
$3,537
$4,632
$5,579
$5,254
Total non-accrual loans$3,379 $5,668 $4,004 $3,537 $4,632 
(1)Excludes purchased distressed loans, as they are generally accreting interest. The carrying value of these loans was $128 million at December 31, 2019, $128 million at December 31, 2018, $167 million at December 31, 2017, $187 million at December 31, 2016 and $250 million at December 31, 2015.
(2)

(1)For years prior to 2020, excludes purchased credit-deteriorated loans, as they are generally accruing interest. The carrying value of these loans was $128 million at December 31, 2019, $128 million at December 31, 2018 and $167 million at December 31, 2017.
(2)    Asia GCB includes balances in certain EMEA countries for all periods presented.
The 2016 increase in corporate non-accrual loans was primarily related to Citi’s North America and EMEA energy and energy-related corporate credit exposure.
(3)
The 2015 decline in consumer non-accrual loans includes the impact related to the transfer of approximately $8 billion of mortgage loans to Loans HFS (included within Other assets).
(4)
Asia includes balances in certain EMEA countries for all periods presented.

The changes in Citigroup’s non-accrual loans were as follows:

Year endedYear ended
December 31, 2021December 31, 2020
In millions of dollarsCorporateConsumerTotalCorporateConsumerTotal
Non-accrual loans at beginning of year$3,527 $2,141 $5,668 $2,188 $1,816 $4,004 
Additions1,708 2,018 3,726 5,103 2,829 7,932 
Sales and transfers to HFS(405)(199)(604)(2)(95)(97)
Returned to performing(217)(615)(832)(157)(389)(546)
Paydowns/settlements(2,215)(630)(2,845)(3,117)(677)(3,794)
Charge-offs(493)(1,180)(1,673)(446)(1,132)(1,578)
Other(28)(33)(61)(42)(211)(253)
Ending balance$1,877 $1,502 $3,379 $3,527 $2,141 $5,668 

 Year endedYear ended
 December 31, 2019December 31, 2018
In millions of dollarsCorporateConsumerTotalCorporateConsumerTotal
Non-accrual loans at beginning of period$1,511
$2,026
$3,537
$2,233
$2,399
$4,632
Additions3,407
2,954
6,361
2,108
3,148
5,256
Sales and transfers to HFS(23)(171)(194)(119)(268)(387)
Returned to performing(68)(431)(499)(127)(629)(756)
Paydowns/settlements(2,496)(902)(3,398)(2,282)(1,052)(3,334)
Charge-offs(268)(1,444)(1,712)(196)(1,634)(1,830)
Other125
(216)(91)(106)62
(44)
Ending balance$2,188
$1,816
$4,004
$1,511
$2,026
$3,537


Non-Accrual Assets89


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:

December 31,December 31,
In millions of dollars20192018201720162015In millions of dollars20212020201920182017
OREO OREO
North America$39
$64
$89
$161
$166
North America$15 $19 $39 $64 $89 
EMEA1
1
2

1
EMEA — 
Latin America14
12
35
18
38
Latin America8 14 12 35 
Asia7
22
18
7
4
Asia4 17 22 18 
Total OREO$61
$99
$144
$186
$209
Total OREO$27 $43 $61 $99 $144 
Non-accrual assets Non-accrual assets
Corporate non-accrual loans$2,188
$1,511
$2,233
$2,856
$1,964
Corporate non-accrual loans$1,877 $3,527 $2,188 $1,511 $2,233 
Consumer non-accrual loans1,816
2,026
2,399
2,723
3,290
Consumer non-accrual loans1,502 2,141 1,816 2,026 2,399 
Non-accrual loans (NAL)$4,004
$3,537
$4,632
$5,579
$5,254
Non-accrual loans (NAL)$3,379 $5,668 $4,004 $3,537 $4,632 
OREO$61
$99
$144
$186
$209
OREO$27 $43 $61 $99 $144 
Non-accrual assets (NAA)$4,065
$3,636
$4,776
$5,765
$5,463
Non-accrual assets (NAA)$3,406 $5,711 $4,065 $3,636 $4,776 
NAL as a percentage of total loans0.57%0.52%0.69%0.89%0.85%NAL as a percentage of total loans0.51 %0.84 %0.57 %0.52 %0.69 %
NAA as a percentage of total assets0.21
0.19
0.26
0.32
0.32
NAA as a percentage of total assets0.15 0.25 0.21 0.19 0.26 
Allowance for loan losses as a percentage of NAL(1)
319
348
267
216
240
ACLL as a percentage of NAL(1)
ACLL as a percentage of NAL(1)
487 440 319 348 267 

(1)The allowance for loan losses includes the allowance for Citi’s credit card portfolios and purchased distressed loans, while the non-accrual loans exclude credit card balances (with the exception of certain international portfolios) and purchased distressed loans as these continue to accrue interest until charge-off.
(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.


90



Renegotiated Loans
The following table presents Citi’s loans modified in TDRs:

In millions of dollarsDec. 31, 2021Dec. 31, 2020
Corporate renegotiated loans(1)
 
In U.S. offices 
Commercial and industrial(2)
$103 $193 
Mortgage and real estate51 60 
Financial institutions — 
Other32 30 
Total$186 $283 
In offices outside the U.S.
Commercial and industrial(2)
$133 $132 
Mortgage and real estate22 32 
Financial institutions — 
Other9 
Total$164 $167 
Total corporate renegotiated loans$350 $450 
Consumer renegotiated loans(3)
In U.S. offices
Mortgage and real estate$1,422 $1,904 
Cards1,269 1,449 
Installment and other26 33 
Total$2,717 $3,386 
In offices outside the U.S.
Mortgage and real estate$223 $361 
Cards313 533 
Installment and other428 519 
Total$964 $1,413 
Total consumer renegotiated loans$3,681 $4,799 

(1)Includes $321 million and $415 million of non-accrual loans included in the non-accrual loans table above at December 31, 2021 and 2020, respectively. The remaining loans were accruing interest.
(2)In addition to modifications reflected as TDRs at December 31, 2021 and 2020, Citi also modified none and $47 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 the modifications did not involve a concession or because the modifications qualified for exemptions from TDR accounting provided by the CARES Act or the interagency guidance.
(3)Includes $627 million and $873 million of non-accrual loans included in the non-accrual loans table above at December 31, 2021 and 2020, respectively. The remaining loans were accruing interest.








In millions of dollarsDec. 31, 2019Dec. 31, 2018
Corporate renegotiated loans(1)
  
In U.S. offices  
Commercial and industrial$226
$188
Mortgage and real estate57
111
Financial institutions
16
Other4
2
Total$287
$317
In offices outside the U.S.  
Commercial and industrial(2)
$200
$226
Mortgage and real estate22
12
Financial institutions
9
Other40

Total

$262
$247
Total corporate renegotiated loans$549
$564
Consumer renegotiated loans(3)
  
In U.S. offices  
Mortgage and real estate$1,956
$2,520
Cards1,464
1,338
Installment and other17
13
Total

$3,437
$3,871
In offices outside the U.S.  
Mortgage and real estate$305
$299
Cards466
480
Installment and other400
387
Total

$1,171
$1,166
Total consumer renegotiated loans$4,608
$5,037
(1)Includes $472 million and $466 million of non-accrual loans included in the non-accrual loans table above at December 31, 2019 and 2018, respectively. The remaining loans are accruing interest.
(2)In addition to modifications reflected as TDRs at December 31, 2019 and 2018, Citi also modified $26 million and $2 million in offices outside the U.S., respectively, of commercial loans risk rated “Substandard Non-Performing” or worse (asset category defined by banking regulators). These modifications were not considered TDRs because the modifications did not involve a concession.
(3)Includes $814 million and $933 million of non-accrual loans included in the non-accrual loans table above at December 31, 2019 and 2018, respectively. The remaining loans are accruing interest.








Forgone Interest Revenue on Loans(1)

In millions of dollarsIn U.S.
offices
In non-
U.S.
offices
2021
total
Interest revenue that would have been accrued at original contractual rates(2)
$343 $346 $689 
Amount recognized as interest revenue(2)
166 189 355 
Forgone interest revenue$177 $157 $334 
In millions of dollarsIn U.S.
offices
In non-
U.S.
offices
2019
total
Interest revenue that would have been accrued at original contractual rates(2)
$488
$421
$909
Amount recognized as interest revenue(2)
130
112
242
Forgone interest revenue$358
$309
$667

(1)     Relates to corporate non-accrual loans, renegotiated loans and consumer loans on which accrual of interest has been suspended.
(2)    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.

(1)Relates to corporate non-accrual loans, renegotiated loans and consumer loans on which accrual of interest has been suspended.
(2)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.

91


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”FactorsLiquidity 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.Limited. 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 funding sources of funding include (i) corporate and consumer deposits via Citi’s bank subsidiaries, which are Citi’s most stable and lowest cost source of long-term funding,including Citibank, N.A. (Citibank), (ii) long-term debt (primarily senior and subordinated debt) primarilymainly issued atby Citigroup Inc., as the parent, and certain bank subsidiaries,Citibank, 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 excesssufficient liquidity and tenor in the liability structure relative to the liquidity profile of the assets. This reduces the risk that liabilities will become due before assets mature or are
monetized. This excess liquidity is held primarily in the form of high-quality liquid assets (HQLA), as set forth in the table below.
Citi’s liquidity is managed via a centralized treasury model by Treasury, in conjunction with regional and in-country treasurers with independent oversight provided by Independent Risk Management.Management and various Asset & Liability Committees (ALCOs) at the Citigroup, region, country and business levels. Pursuant to this approach, Citi’s HQLA areis managed with emphasis on asset-liability management and entity-level liquidity adequacy throughout Citi.
TheCiti’s CRO and Chief RiskFinancial Officer and Citi’s CFO co-chair Citi’s Asset Liability Management Committee (ALCO),Citigroup’s ALCO, which includes Citi’s Treasurer and other senior executives. The ALCO among other things, sets the strategy of the liquidity portfolio and monitors its performance.portfolio performance (for additional information about the ALCO, see “Risk Governance—Board and Executive Management Committees” above). Significant changes to portfolio asset allocations need to beare approved by the ALCO. Citi also has other ALCOs, which are established at various organizational levels to ensure appropriate oversight for countries, franchise businesses and regions, serving as the primary governance committees for managing Citi’s balance sheet and liquidity.
As a supplement to ALCO, Citi’s Funding and Liquidity Risk Committee (FLRC) is a more focused assembly for funding and liquidity risk matters. The FLRC reviews and discusses the funding and liquidity risk profile of, as well as risk management practices for Citigroup and Citibank and reports its findings and recommendations to each relevant ALCO as appropriate.

Liquidity Monitoring and Measurement

Stress Testing
Liquidity stress testing is performed for each of Citi’s major entities, operating subsidiaries and/or countries. Stress testing and scenario analyses are intended to quantify the potential impact of an adverse liquidity event on the balance sheet and liquidity position, and to identify viable funding alternatives that can be utilized. These scenarios include assumptions about significant changes in key funding sources, market triggers (such as credit ratings), potential uses of funding and macroeconomic, geopolitical and other conditions. These conditions include expected and stressed market conditions as well as Company-specific events.
Liquidity stress tests are performed to ascertain potential mismatches between liquidity sources and uses over a variety of time horizons and over different stressed conditions. Liquidity limits are set accordingly. To monitor the liquidity of an entity, these stress tests and potential mismatches are calculated with varying frequencies, with several tests performed daily.
Given the range of potential stresses, Citi maintains contingency funding plans on a consolidated basis and for individual entities. These plans specify a wide range of readily available actions for a variety of adverse market conditions or idiosyncratic stresses.



92


High-Quality Liquid Assets (HQLA)

CitibankCiti non-bank and other entitiesTotalCitibankCiti non-bank and other entitiesTotal
In billions of dollarsDec. 31, 2019Sept. 30, 2019Dec. 31, 2018Dec. 31, 2019Sept. 30, 2019Dec. 31, 2018Dec. 31, 2019Sept. 30, 2019Dec. 31, 2018In billions of dollarsDec. 31, 2021Sept. 30, 2021Dec. 31, 2020Dec. 31, 2021Sept. 30, 2021Dec. 31, 2020Dec. 31, 2021Sept. 30, 2021Dec. 31, 2020
Available cash$158.7
$123.7
$97.1
$2.1
$31.8
$27.6
$160.8
$155.5
$124.7
Available cash$253.6 $255.1 $304.3 $2.6 $3.5 $2.1 $256.2 $258.6 $306.4 
U.S. sovereign100.2
94.3
103.2
29.6
32.4
24.0
129.8
126.7
127.2
U.S. sovereign119.6 108.9 77.8 63.1 64.3 64.8 182.7 173.2 142.6 
U.S. agency/agency MBS56.9
55.5
60.0
4.4
4.6
5.8
61.3
60.1
65.8
U.S. agency/agency MBS45.0 45.3 31.8 5.7 6.0 6.5 50.7 51.3 38.3 
Foreign government debt(1)
66.4
65.9
76.8
16.5
10.9
6.3
82.9
76.8
83.1
Foreign government debt(1)
48.9 50.2 39.6 13.6 11.2 16.2 62.5 61.4 55.8 
Other investment grade2.4
2.9
1.5
0.5
0.7
1.4
2.8
3.6
2.9
Other investment grade1.6 1.8 1.2 0.8 0.3 0.5 2.4 2.1 1.7 
Total HQLA (AVG)$384.6
$342.3
$338.6
$53.1
$80.4
$65.1
$437.6
$422.7
$403.7
Total HQLA (AVG)$468.7 $461.2 $454.7 $85.8 $85.3 $90.1 $554.5 $546.5 $544.8 

Note: The amounts set forth in the table above are presented on an average basis. For securities, the amounts represent the liquidity value that potentially could be realized and, therefore, exclude any securities that are encumbered and incorporate any haircuts that would be required for securities financing transactions.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 Mexico, Hong Kong, South Korea, Singapore, India and Brazil.
(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, South Korea, India 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 Ratioratio (LCR), pursuant to the U.S. LCR rules. These amounts include the HQLA needed to meet the minimum requirements at these entities and any amounts in excess of these minimums that are assumed to be transferable to other entities within Citigroup. Citigroup’s HQLA increased sequentially,quarter-over-quarter as of the fourth quarter of 2021, primarily reflecting deposit growthan increase in deposits.
As of December 31, 2021, Citigroup had $961 billion of available liquidity resources to support client and the issuance of long-term debt.
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 as set forth above does not include Citi’s available borrowing capacity from theto support Federal Home Loan Banks (FHLBs) of which Citi is a member, which was approximately $35 billion as of December 31, 2019 (compared to $40 billion as of September 30, 2019Bank (FHLB) and $29 billion as of December 31, 2018) and maintained by eligible collateral pledged to such banks. The HQLA also does not include Citi’s borrowing capacity at the U.S. Federal Reserve Bank discount window or other central banks, which would be in addition to the resources noted above.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 overassuming a stressed 30-day period, with the net outflows determined by applyingstandardized stress outflow and inflow rates prescribed outflow factors to various categories of liabilities, such as deposits, unsecured and secured wholesale borrowings, unused lending commitments and derivatives-related exposures,in the LCR rule. The outflows are partially offset by contractual inflows from assets maturing within 30 days. BanksSimilar to outflows, the inflows are requiredcalculated based on prescribed factors to calculate an add-on to address potential maturity mismatches between contractual cash outflowsvarious assets categories, such as retail loans as well as unsecured and inflows within the 30-day period in determining the total amount of net outflows.secured wholesale lending. 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 dollarsDec. 31, 2019Sept. 30, 2019Dec. 31, 2018In billions of dollarsDec. 31, 2021Sept. 30, 2021Dec. 31, 2020
HQLA$437.6
$422.7
$403.7
HQLA$554.5 $546.5 $544.8 
Net outflows382.0
373.4
334.8
Net outflows482.9 474.8 460.7 
LCR115%113%121%LCR115 %115 %118 %
HQLA in excess of net outflows$55.6
$49.3
$68.9
HQLA in excess of net outflows$71.6 $71.7 $84.1 

Note: The amounts are presented on an average basis.

As of December 31, 2021, Citi’s average LCR was unchanged sequentially, as Citi’s average HQLA and net outflows increased sequentially, reflecting the issuance of long-term debt.proportionately.


93


Long-Term Liquidity Measurement: Net Stable Funding Ratio (NSFR)
In 2016,As previously disclosed, in October 2020, the Federal Reserve Board, the FDIC and the OCC issuedU.S. banking agencies adopted a proposedfinal rule to implement the Basel III NSFR requirement.
The U.S.-proposed NSFR is largely consistent with the Basel Committee’s final NSFR rules. In general, the NSFR assessesassess the availability of a bank’s stable funding against a required level. A
In general, a bank’s available stable funding would includeincludes portions of equity, deposits and long-term debt, while its required stable funding wouldwill be based on the liquidity characteristics and encumbrance period of its assets, derivatives and commitments. Prescribed factors would beStandardized weightings are required to be applied to the various categories of asset and liabilities classes. The ratio of available stable funding to required stable funding would beis required to be greater than 100%.
WhileThe final rule became effective beginning July 1, 2021, while public disclosure requirements to report the ratio will occur on a semiannual basis beginning June 30, 2023. Citi believes that it is compliantwas in compliance with the proposed U.S. NSFR rulesfinal rule as of December 31, 2019, it will need to evaluate a final version of the rules. Citi expects that the NSFR final rules implementation period will be communicated along with the final version of the rules.2021.

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 dollarsDec. 31, 2019Sept. 30, 2019Dec. 31, 2018In billions of dollarsDec. 31, 2021Sept. 30, 2021Dec. 31, 2020
Global Consumer Banking Global Consumer Banking
North America$192.7
$188.8
$186.8
North America$176.8 $173.8 $179.4 
Latin America17.4
17.0
16.9
Latin America13.0 13.2 14.3 
Asia(1)
80.9
78.3
76.7
Asia(1)
72.5 75.9 82.4 
Total$291.0
$284.1
$280.4
Total$262.3 $262.9 $276.1 
Institutional Clients Group Institutional Clients Group
Corporate lending$154.2
$160.9
$158.2
Corporate lending$127.5 $129.2 $146.2 
Treasury and trade solutions (TTS)74.5
72.5
77.0
Treasury and trade solutions (TTS)76.3 73.7 67.1 
Private bank106.6
104.0
94.7
Private bank124.5 125.9 113.3 
Markets and securities services and other
56.0
52.3
49.2
Markets and securities services and other
72.5 72.0 56.1 
Total$391.3
$389.7
$379.1
Total$400.8 $400.8 $382.7 
Total Corporate/Other
$10.3
$11.2
$16.0
Total Corporate/Other
$4.3 $4.7 $7.4 
Total Citigroup loans (AVG)$692.6
$685.0
$675.5
Total Citigroup loans (AVG)$667.4 $668.5 $666.2 
Total Citigroup loans (EOP)$699.5
$691.7
$684.2
Total Citigroup loans (EOP)$667.8 $664.8 $676.1 

(1)
Includes loans in certain EMEA countries for all periods presented.

End-of(1)Includes loans in certain EMEA countries for all periods presented.

As of the fourth quarter of 2021, end-of period loans increased 2%declined 1% year-over-year and 1%were largely unchanged quarter-over-quarter.
On an average basis, loans increased 3%were largely unchanged both year-over-year and 1% quarter-over-quarter.
sequentially. Excluding the impact of FX translation, average loans increased 3%1% year-over-year driven by 4% aggregate acrossand were largely unchanged sequentially. On this basis, average GCB loans declined 4% year-over-year, primarily reflecting the reclassification of loans to held-for-sale as a result of Citi’s
entry into agreements to sell its consumer banking businesses in Australia and ICG. Within GCB, average loans grew 4%, driven by continued growth in North America GCB and Asia GCB. Average loans in Latin America GCB were largely unchanged year-over-year, reflecting lower overall industry volumes.the Philippines.
AverageExcluding the impact of FX translation, average ICG loans increased 3%5% year-over-year. Treasury and trade solutions (TTS) loansLoans in corporate lending declined 3% year-over-year,12% on an average basis, reflecting net repayments as Citi continued to utilizeassist its distribution capabilitiesclients in order to optimize its balance sheet while supporting its clients. Corporate lending loans declined 2%, reflectingaccessing the episodic nature of clients’ funding needs,capital markets, as well as an active quarter in debt capital markets originations.lower demand. Private bank loans increased 13%10%, reflecting growth across regions,largely driven by both new clients and the deepening of relationships with existingincreased secured lending to high-net-worth clients. Markets and securities services loans increased 14%29%, primarily driven by residentialreflecting an increase in securitization financing. TTS loans increased 15%, reflecting an increase in trade flows and commercial real estate warehouse lending.originations.
Average Corporate/Other loans continued to decline (down 34%46%), 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 dollarsDec. 31, 2019Sept. 30, 2019Dec. 31, 2018In billions of dollarsDec. 31, 2021Sept. 30, 2021Dec. 31, 2020
Global Consumer Banking 
Global Consumer Banking(1)
Global Consumer Banking(1)
North America$156.2
$153.6
$146.5
North America$214.0 $208.4 $188.9 
Latin America23.0
22.5
22.3
Latin America23.8 24.2 24.3 
Asia(1)
103.4
100.7
97.7
Asia(2)
Asia(2)
117.2 120.7 120.0 
Total$282.6
$276.8
$266.5
Total$355.0 $353.3 $333.2 
Institutional Clients Group Institutional Clients Group
Treasury and trade solutions (TTS)$558.7
$541.0
$510.9
Treasury and trade solutions (TTS)$690.6 $674.8 $686.5 
Banking ex-TTS
140.7
137.0
128.3
Banking ex-TTS
188.2 179.5 163.2 
Markets and securities services95.0
95.7
86.7
Markets and securities services129.3 127.2 109.3 
Total$794.4
$773.7
$725.9
Total$1,008.1 $981.6 $959.0 
Total Corporate/Other
$12.5
$15.8
$13.3
Corporate/OtherCorporate/Other$7.2 $8.2 $13.1 
Total Citigroup deposits (AVG)$1,089.5
$1,066.3
$1,005.7
Total Citigroup deposits (AVG)$1,370.3 $1,343.0 $1,305.3 
Total Citigroup deposits (EOP)$1,070.6
$1,087.8
$1,013.2
Total Citigroup deposits (EOP)$1,317.2 $1,347.5 $1,280.7 
(1)

(1)Reflects deposits within retail banking.
(2)Includes deposits in certain EMEA countriesfor all periods presented.

EMEA countriesfor all periods presented.

End-of-period deposits increased 6%3% year-over-year and declined 2% quarter-over-quarter. Onsequentially.
As of the fourth quarter of 2021, on an average basis, deposits increased 8%5% year-over-year and 2% quarter-over-quarter.sequentially. Excluding the impact of FX translation, average deposits grew 6% from the prior-year period and 3% sequentially. The year-over-year increase reflected continued client engagement as well as the elevated level of liquidity in the financial system. Excluding the impact of FX translation, average deposits in GCB increased 7%, with continued strong growth in North America.
Excluding the impact of FX translation, average deposits increased 9% year-over-year. Inin GCBICG, deposits increased grew 6%, driven by continued year-over-year, with strong growth in Asia GCBthe private bank and North America GCB. In North America GCB, deposit growth accelerated to 7%, with contributions from both traditional and digital channels.securities services.
In ICG, deposits increased 10%, primarily driven by high-quality deposit growth in TTS.


94


Long-Term Debt
Long-term debt (generally defined as debt with original maturities of one year or more) represents the most significant component of Citi’s funding for the Citigroup parent company and Citi’s non-bank subsidiaries and is a supplementary source of funding for the bank entities.
Long-term debt is an important funding source due in part to its multi-yearmultiyear 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 8.48.6 years as of December 31, 2019,2021, unchanged from September 30, 2019the prior quarter and a slight decline from the prior year. The weighted-average maturity is calculated based on the contractual maturity of each security. For securities that are redeemable prior to maturity at the option of the holder, the weighted-average maturity is calculated based on the earliest date an option becomes exercisable.
Citi’s long-term debt outstanding at the Citigroup parent company includes benchmark senior and subordinated debt and what Citi refers to as customer-related debt, consisting of structured notes, such as equity- and credit-linked notes, as well as non-structured notes. Citi’s issuance of customer-related debt is generally driven by customer demand and supplementscomplements benchmark debt issuance as a source of funding for Citi’s non-bank entities. Citi’s long-term debt at the bank includes Citibank benchmark senior debt, FHLB advancesborrowings 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 dollarsDec. 31, 2019Sept. 30, 2019Dec. 31, 2018In billions of dollarsDec. 31, 2021Sept. 30, 2021Dec. 31, 2020
Parent and other(1)
   
Non-bank(1)
Non-bank(1)
Benchmark debt: Benchmark debt:
Senior debt$106.6
$104.3
$104.6
Senior debt$117.8 $123.9 $126.2 
Subordinated debt25.5
25.9
24.5
Subordinated debt25.7 26.0 27.1 
Trust preferred1.7
1.7
1.7
Trust preferred1.7 1.7 1.7 
Customer-related debt53.8
50.1
37.1
Customer-related debt78.3 74.7 65.2 
Local country and other(2)
7.9
5.3
2.9
Local country and other(2)
7.3 7.2 6.7 
Total parent and other$195.5
$187.3
$170.8
Total non-bankTotal non-bank$230.8 $233.5 $226.9 
Bank Bank
FHLB borrowings$5.5
$5.5
$10.5
FHLB borrowings$5.3 $5.8 $10.9 
Securitizations(3)
20.7
22.8
28.4
Securitizations(3)
9.6 11.0 16.6 
Citibank benchmark senior debt23.1
23.1
18.8
Citibank benchmark senior debt3.6 3.6 13.6 
Local country and other(2)
4.0
3.5
3.5
Local country and other(2)
5.1 4.3 3.6 
Total bank$53.3
$54.9
$61.2
Total bank$23.6 $24.7 $44.7 
Total long-term debt$248.8
$242.2
$232.0
Total long-term debt$254.4 $258.2 $271.7 

Note: Amounts represent the current value of long-term debt on Citi’s Consolidated Balance Sheet which,that, for certain debt instruments, includes consideration of fair value, hedging impacts and unamortized discounts and premiums.
(1)Parent and other includes long-term debt issued to third parties by the parent holding company (Citigroup) and Citi’s non-bank subsidiaries (including broker-dealer subsidiaries) that are consolidated into Citigroup. As of December 31, 2019, parent and other included $46.9 billion of long-term debt issued by Citi’s broker-dealer subsidiaries.
(2)Local country and other includes debt issued by Citi’s affiliates in support of their local operations. Within parent and other, certain secured financing is also included.
(3)Predominantly credit card securitizations, primarily backed by Citi-branded credit card receivables.

(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, 2021, non-bank included $65.9 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 branded credit card receivables.

As of the fourth quarter of 2021, Citi’s total long-term debt outstanding increased bothdecreased year-over-year, and quarter-over-quarter, largelyprimarily driven by an increasedeclines in unsecured benchmark senior debt at the non-bank entities and the bank, as well as securitizations and FHLB borrowings at the bank. The decrease in total long-term debt was partially offset by the issuance of customer-related debt at the non-bank entities. Year-over-year, this growth wasSequentially, long-term debt outstanding decreased, driven primarily by decreases in unsecured benchmark senior debt at the non-bank entities and securitizations at the bank, partially offset by a decline in securitizationsthe issuance of customer-related debt at the bank.non-bank entities.
As part of its liability management, Citi also 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 2019,2021, Citi redeemed or repurchased $13.1an aggregate of approximately $33.8 billion of its outstanding long-term debt, including early redemptions of FHLB advances, but excluding the exercise of call options on $4.0 billion of securities with a remaining life of three months or less.debt.


95


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:

 201920182017
In billions of dollarsMaturitiesIssuancesMaturitiesIssuancesMaturitiesIssuances
Parent and other      
Benchmark debt:      
Senior debt$16.5
$16.2
$18.5
$14.8
$14.1
$21.6
Subordinated debt

2.9
0.6
1.6
1.3
Customer-related debt12.7
25.1
6.6
16.9
7.6
12.3
Local country and other1.1
5.4
1.2
2.3
1.2
0.1
Total parent and other$30.3
$46.7
$29.2
$34.6
$24.5
$35.3
Bank      
FHLB borrowings$7.1
$2.1
$15.8
$7.9
$7.8
$5.5
Securitizations7.9
0.1
8.6
6.8
5.3
12.2
Citibank benchmark senior debt4.8
8.8
2.3
8.5

12.6
Local country and other0.9
1.4
2.2
2.9
3.4
2.4
Total bank$20.7
$12.4
$28.9
$26.1
$16.5
$32.7
Total$51.0
$59.1
$58.1
$60.7
$41.0
$68.0

 202120202019
In billions of dollarsMaturitiesIssuancesMaturitiesIssuancesMaturitiesIssuances
Non-bank
Benchmark debt:
Senior debt$17.6 $15.4 $6.5 $20.4 $16.5 $16.2 
Subordinated debt  — — — — 
Trust preferred  — — — — 
Customer-related debt31.2 48.7 27.7 36.8 12.7 25.1 
Local country and other3.3 3.6 2.4 1.4 1.1 5.4 
Total non-bank$52.1 $67.7 $36.6 $58.6 $30.3 $46.7 
Bank
FHLB borrowings$5.7 $ $7.5 $12.9 $7.1 $2.1 
Securitizations6.1  4.6 0.3 7.9 0.1 
Citibank benchmark senior debt9.8  9.8 — 4.8 8.8 
Local country and other1.2 2.9 4.9 4.6 0.9 1.4 
Total bank$22.8 $2.9 $26.8 $17.8 $20.7 $12.4 
Total$74.9 $70.6 $63.4 $76.4 $51.0 $59.1 

The table below shows Citi’s aggregate long-term debt maturities (including repurchases and redemptions) in 2019,2021, as well as its aggregate expected annualremaining long-term debt maturities by year as of December 31, 2019:2021:
 Maturities
In billions of dollars201920202021202220232024ThereafterTotal
Parent and other        
Benchmark debt:        
Senior debt$16.5
$6.4
$14.2
$11.3
$12.5
$7.0
$55.2
$106.6
Subordinated debt


0.7
1.2
0.9
22.7
25.5
Trust preferred





1.7
1.7
Customer-related debt12.7
9.2
6.3
5.1
3.7
3.6
25.9
53.8
Local country and other1.1
1.0
3.6
1.5
0.1
0.1
1.6
7.9
Total parent and other$30.3
$16.6
$24.1
$18.6
$17.5
$11.6
$107.1
$195.5
Bank        
FHLB borrowings$7.1
$5.5
$
$
$
$
$
$5.5
Securitizations7.9
4.6
7.3
2.3
2.6
1.1
2.8
20.7
Citibank benchmark senior debt4.8
8.7
6.1
5.6

2.7

23.1
Local country and other0.9
1.9
0.6
0.6

0.6
0.3
4.0
Total bank$20.7
$20.7
$14.0
$8.5
$2.6
$4.4
$3.1
$53.3
Total long-term debt$51.0
$37.3
$38.1
$27.1
$20.1
$16.0
$110.2
$248.8


 Maturities
In billions of dollars202120222023202420252026ThereafterTotal
Non-bank
Benchmark debt:
Senior debt$17.6 $8.2 $12.6 $11.0 $10.7 $18.2 $57.1 $117.8 
Subordinated debt 0.8 1.3 1.0 5.2 2.6 14.8 25.7 
Trust preferred — — — — — 1.7 1.7 
Customer-related debt31.2 11.9 10.2 8.5 4.9 5.5 37.3 78.3 
Local country and other3.3 2.3 2.2 0.1 — 0.7 1.8 7.3 
Total non-bank$52.1 $23.2 $26.3 $20.6 $20.8 $27.0 $112.7 $230.8 
Bank
FHLB borrowings$5.7 $5.3 $— $— $— $— $— $5.3 
Securitizations6.1 2.1 3.3 1.4 0.4 — 2.4 9.6 
Citibank benchmark senior debt9.8 0.9 — 2.7 — — — 3.6 
Local country and other1.2 1.5 0.9 0.9 0.1 0.1 1.6 5.1 
Total bank$22.8 $9.8 $4.2 $5.0 $0.5 $0.1 $4.0 $23.6 
Total long-term debt$74.9 $33.0 $30.5 $25.6 $21.3 $27.1 $116.7 $254.4 
96


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 FRBFederal Reserve Board 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.
On December 17, 2019, the Federal Reserve Board and FDIC issued feedback on the resolution plans filed on July 1, 2019 by the eight U.S. Global Systemically Important Banks, including Citigroup. The Federal Reserve Board and FDIC identified one shortcoming, but no deficiencies, in Citigroup's resolution plan relating to governance mechanisms. Based on regulatory changes effective December 31, 2019, Citigroup's 2021 resolution plan submission, which was filed on July 1, 2021 was a targeted resolution plan, only including a subset of the information of a full resolution plan and additional information, identified by the Federal Reserve Board and FDIC on July 1, 2020. Citigroup will alternate between submitting a full resolution plan and a targeted resolution plan on a biennial cycle. 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 20192021 resolution plan, which can be found on the FRB’sFederal Reserve Board’s and FDIC’s websites) would remain operational and outside of any resolution or insolvency proceedings. Citigroup’s resolution plan has been designed to minimize the risk of systemic impact to the U.S. and global financial systems, while maximizing the value of the bankruptcy estate for the benefit of Citigroup’s creditors, including its unsecured long-term debt holders.
In addition, in line with the Federal Reserve’sReserve Board’s final total loss-absorbing capacity (TLAC) rule, Citigroup believes it has developed the resolution plan so that Citigroup’s shareholders and unsecured creditors—including its unsecured long-term debt holders—bear any losses resulting from Citigroup’s bankruptcy. Accordingly, any value realized by holders of its unsecured long-term debt may not be sufficient to repay the amounts owed to such debt holders in the event of a bankruptcy or other resolution proceeding of Citigroup.
The FDIC has also indicated that it was developing a single point of entry strategy to implement its resolution authoritythe Orderly Liquidation Authority under Title II of the Dodd-Frank Act.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 Board and FDIC, Citigroup took the following actions:

(i)Citicorp LLC (Citicorp), an existing wholly owned subsidiary of Citigroup, was established as an intermediate holding company (an IHC) for certain of Citigroup’s operating material legal entities;
(ii)Citigroup executed an inter-affiliate agreement with Citicorp, Citigroup’s operating material legal entities and certain other affiliated entities pursuant to which Citicorp is required to provide liquidity and capital support to Citigroup’s operating material legal entities in the event Citigroup were to enter bankruptcy proceedings (Citi Support Agreement);
(iii)pursuant to the Citi Support Agreement:

(i)Citicorp LLC (Citicorp), an existing wholly owned subsidiary of Citigroup, was established as an intermediate holding company (an IHC) for certain of Citigroup’s operating material legal entities;
(ii)Citigroup executed an inter-affiliate agreement with Citicorp, Citigroup’s operating material legal entities and certain other affiliated entities pursuant to which Citicorp is required to provide liquidity and capital support to Citigroup’s operating material legal entities in the event Citigroup were to enter bankruptcy proceedings (Citi Support Agreement);
(iii)pursuant to the Citi Support Agreement:

Citigroup made an initial contribution of assets, including certain high-quality liquid assets and inter-affiliate loans (Contributable Assets), to Citicorp, and Citicorp became the business as usualbusiness-as-usual funding vehicle for Citigroup’s operating material legal entities;
Citigroup will be obligated to continue to transfer Contributable Assets to Citicorp over time, subject to certain amounts retained by Citigroup to, among
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.
(iv)the obligations of both Citigroup and Citicorp under the Citi Support Agreement, as well as the Contributable Assets, are secured pursuant to a security agreement.

The Citi Support Agreement provides two mechanisms, besides Citicorp’s issuing of dividends to Citigroup, pursuant to which Citicorp will be required to transfer cash to Citigroup during business as usual so that Citigroup can fund its debt service as well as other operating needs: (i) one or more funding notes issued by Citicorp to Citigroup and (ii) a committed line of credit under which Citicorp may make loans to Citigroup.
On December 17, 2019, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2019 by the eight U.S. GSIBs, including Citi. The FRB and FDIC identified one shortcoming, but no deficiencies, in Citi’s resolution plan relating to governance mechanisms. Citi is required to submit a plan to address the shortcoming by March 31, 2020, which the FRB and FDIC will take into account in determining the scope of Citi’s targeted resolution plan due on July 1, 2021.

Total Loss-Absorbing Capacity(TLAC)
In 2016, the Federal Reserve Board imposed minimum external TLAC and long-term debt (LTD) requirements on U.S. global systemically important bank holding companies (GSIBs), including Citi, effective as of January 1, 2019. As a result, U.S. GSIBs are required to maintain minimum levels of TLAC and eligible LTD, each set by reference to the GSIB’s consolidated risk-weighted assets (RWA) and total leverage exposure, as described further below.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�� Resources—Current Regulatory Capital Standards” and “Risk Factors—Compliance Risks” above.

Minimum TLAC Requirements
The minimum TLAC requirement is the greater of (i) 18% of the GSIB’s RWA plus the then-applicable RWA-based TLAC buffer (see below) and (ii) 7.5% of the GSIB’s total leverage exposure plus a leveraged-based TLAC buffer of 2% (i.e., 9.5%).
The RWA-based TLAC buffer equals the 2.5% capital conservation buffer, plus any applicable countercyclical capital buffer (currently 0%), plus the GSIB’s capital surcharge as determined under method 1 of the GSIB surcharge rule (2.0% for Citi for 2020). Accordingly, Citi’s total current minimum TLAC requirement is 22.5% of RWA for 2020.
As of December 31, 2019, Citi exceeded each of the minimum TLAC requirements, with ratios of 11.5% of TLAC









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as a percentage of Total Leverage Exposure and 24.7% of TLAC as a percentage of Standardized Approach RWA.

Minimum Eligible LTD Requirements
The minimum LTD requirement is the greater of (i) 6% of the GSIB’s RWA plus its capital surcharge as determined under method 2 of the GSIB surcharge rule (3.0% for Citi for 2020), for a total current requirement of 9% of RWA for Citi, and (ii) 4.5% of the GSIB’s total leverage exposure.
As of December 31, 2019, Citi exceeded each of the minimum LTD requirements, with ratios of 10.9% of LTD as a percentage of Standardized Approach RWA and 5.1% of LTD as a percentage of Total Leverage Exposure.
For additional discussion of the method 1 and method 2 GSIB capital surcharge methodologies, see “Capital Resources—Current Regulatory Capital Standards” above.

Secured Funding Transactions and Short-Term BorrowingsSECURED 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, ori.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 makingmarket-making and customer activities. Citi also executes a smaller portion of its secured funding transactions through its bank entities, which are typically collateralized by government debt securities. Generally, daily changes in the level of Citi’s secured funding are primarily due to fluctuations in secured lending activity in the matched book (as described below) and securities inventory.
Secured funding of $166$191 billion as of December 31, 20192021 decreased 6%3% from the prior yearprior-year period and 15% from the prior quarter.9% sequentially. Excluding the impact of FX translation, secured funding decreased 7%1% from the prior yearprior-year period and 17% from the prior quarter, both8% sequentially, driven by normal business activity. Average balancesThe average balance for secured funding were $188was approximately $222 billion for the quarter ended December 31, 2019.2021.
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 makingmarket-making and customer activities. To maintain reliable funding under a wide range of market conditions, including under periods of stress, Citi manages these activities by taking into consideration the quality of the underlying collateral and establishing minimum required funding tenors. The weighted average maturity of Citi’s secured funding of less liquid securities inventory was greater than 110 days as of December 31, 2019.2021.
Citi manages the risks in its secured funding by conducting daily stress tests to account for changes in capacity, tenors,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 $45$28 billion increased 39%as of the fourth quarter of 2021 decreased 5% year-over-year, reflecting a decline in FHLB advances, and 28%6% sequentially, primarily driven by an increasea decline in FHLB advances as well as commercial paper issued out of the broker-dealer entitiesstructured notes (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 dollars201920182017201920182017
 Amounts outstanding at year end$166.3
$177.8
$156.3
$93.7
$96.9
$105.8
 
Average outstanding during the year(3)(4)
190.2
172.1
157.7
98.8
108.4
97.7
 Maximum month-end outstanding196.8
191.2
163.0
105.8
113.5
112.3
 
Weighted average interest rate during the year(3)(4)(5)
3.29%2.84%1.69%2.49%2.04%1.08%
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(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.
(3)Interest rates and amounts include the effects of risk management activities associated with the respective liability categories.
(4)Average volumes of securities sold under agreements to repurchase are reported net pursuant to ASC 210-20-45; average rates exclude the impact of ASC 210-20-45.
(5)Average rates reflect prevailing local interest rates, including inflationary effects and monetary correction in certain countries.





Credit RatingsCREDIT RATINGS
Citigroup’s funding and liquidity, funding capacity, ability to access capital markets and other sources of funds, the cost of these funds and its ability to maintain certain deposits are partially dependent on its credit ratings.
The table below shows the ratings for Citigroup and Citibank as of December 31, 2019.2021. 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’sS&P Global Ratings and A/A+/F1 at Fitch as of December 31, 20192021.


Ratings as of December 31, 20192021

Citigroup Inc.Citibank, N.A.
Senior

debt
Commercial

paper
Outlook
Long-

term
Short-

term
Outlook
Fitch Ratings (Fitch)AF1StableA+F1Stable
Moody’s Investors Service (Moody’s)A3P-2StableAa3P-1Stable
Standard & Poor’s (S&P)S&P Global RatingsBBB+A-2StableA+A-1Stable

Potential Impacts of Ratings Downgrades
Ratings downgrades by Moody’s, Fitch or S&P Global Ratings could negatively impact Citigroup’s and/or Citibank’s funding and liquidity due to reduced funding capacity, including derivative triggers, which could take the form of cash obligations and collateral requirements.
The following information is provided for the purpose of analyzing the potential funding and liquidity impact to Citigroup and Citibank of a hypothetical simultaneous
ratings downgrade across all three major rating agencies. This analysis is subject to certain estimates, estimation methodologies, judgments and uncertainties. Uncertainties include potential ratings limitations that certain entities may have with respect to permissible counterparties, as well as general subjective counterparty behavior. For example, certain corporate customers and markets counterparties could re-evaluate their business relationships with Citi and limit transactions in certain contracts or market instruments with Citi. Changes in counterparty behavior could impact Citi’s funding and liquidity, as well as the results of operations of certain of its businesses. The actual impact to Citigroup or Citibank is unpredictable and may differ materially from the potential funding and liquidity impacts described below. For additional information on the impact of credit rating changes on Citi and its applicable subsidiaries, see “Risk Factors—Liquidity Risks” above.

Citigroup Inc. and Citibank—Potential Derivative Triggers
As of December 31, 2019,2021, Citi estimates that a hypothetical one-notch downgrade of the senior debt/long-term rating of Citigroup Inc. across all three major rating agencies could impact Citigroup’s funding and liquidity due to derivative triggers by approximately $0.5$0.8 billion, compared to $0.3$1.1 billion as of September 30, 2019.2021. Other funding sources, such as secured financing transactions and other margin requirements, for which there are no explicit triggers, could also be adversely affected.



As of December 31, 2019,2021, 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 $0.3$0.6 billion, compared to $0.7$0.5 billion as of September 30, 2019.2021. 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, 2019,2021, Citi estimates that a one-notch downgrade of Citigroup and Citibank across all three major rating agencies could result in increased aggregate cash obligations and collateral requirements of approximately $0.8$1.4 billion, compared to $1.0$1.6 billion as of September 30, 20192021 (see also Note 22 to the Consolidated Financial Statements). As detailed under “High-Quality Liquid Assets” above, theCitigroup has various liquidity resources that are eligible for inclusion in the calculation of Citi’s consolidated HQLA were approximately $385 billion for Citibankavailable to its bank and $53 billion for Citi’s non-bank and other entities for a total of approximately $438 billion as of December 31, 2019. These liquidity resources are available in part as a contingency for the potential events described above.

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 fromat 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.
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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, 2019,2021, Citibank had liquidity commitments of approximately $10.2 billionapproximately $9.0 billion to consolidated asset-backed commercial paper conduits, compared to $10.0 billion as of September 30, 2019 (as referenced in2021 (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.

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MARKET RISK

OverviewOVERVIEW
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 and& Liability Committees and the Citigroup Risk Management and Asset and& Liability Committee.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 PortfoliosMARKET 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 inincome, and on Citi’s Accumulated other comprehensive income (loss) (AOCI) from its debt securities portfolios. Market risk from non-trading portfolios andalso includes the potential impact of changes in foreign exchange rates on Citi’s capital invested in foreign currencies.

Net Interest RevenueIncome at Risk
Net interest revenue,income, 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 revenueincome 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 revenueincome is interest rate exposure (IRE). IRE measures the change in expected net interest revenueincome 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.
Citi is planning to transition the sensitivity analysis for its IRE (see the current IRE sensitivity impacts below), employing enhanced methodologies and changes to certain
assumptions. The changes include, among other things, assumptions around the projected balance sheet (being more static), coupled with revisions to the treatment of certain business contributions to IRE, mainly accrual positions in ICG’s Markets businesses. These changes are planned for 2022, and will result in a higher impact to Citi’s NII and AOCI and a better reflection of the nature of the portfolios.
In order to manage changes in interest rates effectively, Citi may modify pricing on new customer loans and deposits, purchase fixed-rate securities, issue debt that is either fixed or floating or enter into derivative transactions that have the opposite risk exposures. Citi regularly assesses the viability of these and other strategies to reduce its interest rate risks and
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.


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The following table sets forth the estimated impact to Citi’s net interest revenue,income, 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 notedDec. 31, 2019Sept. 30, 2019Dec. 31, 2018In millions of dollars, except as otherwise notedDec. 31, 2021Sept. 30, 2021Dec. 31, 2020
Estimated annualized impact to net interest revenue   
Estimated annualized impact to net interest incomeEstimated annualized impact to net interest income
U.S. dollar(1)
$20
$292
$758
U.S. dollar(1)
$563 $151 $373 
All other currencies606
605
661
All other currencies612 586 683 
Total$626
$897
$1,419
Total$1,175 $737 $1,056 
As a percentage of average interest-earning assets0.03%0.05%0.08%As a percentage of average interest-earning assets0.05 %0.03 %0.05 %
Estimated initial impact to AOCI (after-tax)(2)
$(5,002)$(4,055)$(3,920)
Estimated initial negative impact to AOCI (after-tax)(2)
Estimated initial negative impact to AOCI (after-tax)(2)
$(4,609)$(4,914)$(5,645)
Estimated initial impact on Common Equity Tier 1 Capital ratio (bps)(31)(24)(28)Estimated initial impact on Common Equity Tier 1 Capital ratio (bps)(30)(30)(34)
(1)Certain trading-oriented businesses within Citi have accrual-accounted positions that are excluded from the estimated impact to net interest revenue in the table, since these exposures are managed economically in combination with mark-to-market positions. The U.S. dollar interest rate exposure associated with these businesses was $(240) million for a 100 bps instantaneous increase in interest rates as of December 31, 2019.
(2)

(1)Certain trading-oriented businesses within Citi have accrual-accounted positions that are excluded from the estimated impact to net interest income 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 $(179) million for a 100 bps instantaneous increase in interest rates as of December 31, 2021.
(2)Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension liability adjustments.


The year-over-year decreaseincrease in the estimated impact to net interest revenueincome primarily reflected changes in Citi’s balance sheet composition and Citi Treasury positioning. The year-over-year changes in the estimated impact to AOCI and the Common Equity Tier 1 Capital ratio primarily reflected the impact of the composition of Citi Treasury’s investment and derivatives portfolio.
In the event of an unanticipateda parallel instantaneous 100 bps increase in interest rates, Citi expects that the negative impact to AOCI would be offset in shareholders’ equity through the combination of expected incremental net interest
revenue and the expected recovery of the impact on AOCI through accretion of Citi’s investment portfolio over a period of time. As of December 31, 2019,2021, Citi expects that the negative $5.0$4.6 billion negative


impact to AOCI in such a scenario could potentially be offset over approximately 3727 months.
The following table sets forth the estimated impact to Citi’s net interest revenue,income, 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: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 millions of dollars, except as otherwise notedScenario 1Scenario 2Scenario 3Scenario 4Scenario 5
Overnight rate change (bps)100 100 — — (100)
10-year rate change (bps)100 — 100 (100)(100)
Estimated annualized impact to net interest income
U.S. dollar$563 $647 $86 $(244)$(770)
All other currencies612 655 41 (41)(353)
Total$1,175 $1,302 $127 $(285)$(1,123)
Estimated initial impact to AOCI (after-tax)(1)
$(4,609)$(2,934)$(1,757)$1,373 $3,050 
Estimated initial impact to Common Equity Tier 1 Capital ratio (bps)(30)(19)(12)18 
In millions of dollars, except as otherwise notedScenario 1Scenario 2Scenario 3Scenario 4Scenario 5
Overnight rate change (bps)100
100


(100)
10-year rate change (bps)100

100
(100)(100)
Estimated annualized impact to net interest revenue 
     
U.S. dollar$20
$92
$39
$(93)$(363)
All other currencies606
558
34
(34)(411)
Total$626
$650
$73
$(127)$(774)
Estimated initial impact to AOCI (after-tax)(1)
$(5,002)$(3,230)$(1,944)$1,570
$4,389
Estimated initial impact to Common Equity Tier 1 Capital ratio (bps)(31)(20)(13)9
26

Note: Each scenario assumes that the rate change will occur instantaneously. Changes in interest rates for maturities between the overnight rate and the 10-year rate are interpolated.
(1)
(1)Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension liability adjustments.

AOCI related to investment securities, cash flow hedges and pension liability adjustments.

As shown in the table above, the magnitude of the impact to Citi’s net interest revenueincome and AOCI is greater under scenarioScenario 2 as compared to scenarioScenario 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.

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Changes in Foreign Exchange Rates—Impacts on AOCI
and Capital
As of December 31, 2019,2021, Citi estimates that an unanticipated parallel instantaneous 5% appreciation of the U.S. dollar against all of the other currencies in which Citi has invested capital could reduce Citi’s tangible common equity (TCE) by approximately $1.5 billion, or 1%0.9%, as a result of changes to Citi’s foreign currencyFX translation adjustment in AOCI, net of hedges. This impact would be primarily due to changes in the value of the Mexican peso, Euro, AustralianSingapore dollar and Indian rupee.
This impact is also before any mitigating actions Citi may take, including ongoing management of its foreign currencyFX 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.
TheIn addition, the effect of Citi’s ongoing management strategies with respect to quarterly changes in foreign exchange rates, and the quarterly impact of these changes on Citi’s TCE and Common Equity Tier 1 Capital ratio, are shown in the table below. For additional information on the changes in AOCI, see Note 19 to the Consolidated Financial Statements.

For the quarter ended
In millions of dollars, except as otherwise notedDec. 31, 2021Sept. 30, 2021Dec. 31, 2020
Change in FX spot rate(1)
(0.6)%(2.7)%5.5 %
Change in TCE due to FX translation, net of hedges$(438)$(1,042)$1,829 
As a percentage of TCE(0.3)%(0.7)%1.2 %
Estimated impact to Common Equity Tier 1 Capital ratio (on a fully implemented basis)
due to changes in FX translation, net of hedges (bps)
(1)(1)

(1)     FX spot rate change is a weighted average based on Citi’s quarterly average GAAP capital exposure to foreign countries.


 For the quarter ended
In millions of dollars, except as otherwise notedDec. 31, 2019Sept. 30, 2019Dec. 31, 2018
Change in FX spot rate(1)
2.8%(3.0)%(1.6)%
Change in TCE due to FX translation, net of hedges$659
$(1,192)$(491)
As a percentage of TCE0.4%(0.8)%(0.3)%
Estimated impact to Common Equity Tier 1 Capital ratio (on a fully implemented basis) due
  to changes in FX translation, net of hedges (bps)
(3)(1)(1)

(1)FX spot rate change is a weighted average based on Citi’s quarterly average GAAP capital exposure to foreign countries.


103


Interest Revenue/Expense and Net Interest Margin (NIM)
a4qchartforwdeska02.jpg
c-20211231_g13.jpg
In millions of dollars, except as otherwise noted2019 2018 2017 Change 
 2019 vs. 2018
 Change 
 2018 vs. 2017
 In millions of dollars, except as otherwise noted2021 2020 2019Change 
 2021 vs. 2020
Change 
 2020 vs. 2019
Interest revenue(1)
$76,718
 $71,082
 $62,075
 8% 15% 
Interest revenue(1)
$50,667  $58,285  $76,718 (13)%(24)%
Interest expense(2)
29,163
 24,266
 16,518
 20
 47
 
Interest expense(2)
7,981  13,338  28,382 (40)(53)
Net interest revenue, taxable equivalent basis$47,555
 $46,816
 $45,557
 2% 3% 
Net interest income, taxable equivalent basis(1)
Net interest income, taxable equivalent basis(1)
$42,686  $44,947  $48,336 (5)%(7)%
Interest revenue—average rate(3)
4.27% 4.08% 3.71% 19
bps37
bps
Interest revenue—average rate(3)
2.36 %2.88 %4.27 %(52)bps(139)bps
Interest expense—average rate2.01
 1.77
 1.28
 24
bps49
bpsInterest expense—average rate0.46 0.81 1.95 (35)bps(114)bps
Net interest margin(3)(4)
2.65
 2.69
 2.73
 (4)bps(4)bps
Net interest margin(3)(4)
1.99 2.22 2.69 (23)bps(47)bps
Interest rate benchmarks          Interest rate benchmarks 
Two-year U.S. Treasury note—average rate1.97% 2.53% 1.40% (56)bps113
bpsTwo-year U.S. Treasury note—average rate0.27 %0.39 %1.97 %(12)bps(158)bps
10-year U.S. Treasury note—average rate2.14
 2.91
 2.33
 (77)bps58
bps10-year U.S. Treasury note—average rate1.45  0.89  2.14 56 bps(125)bps
10-year vs. two-year spread17
bps38
bps93
bps 
   10-year vs. two-year spread118 bps50 bps17 bps 

Note: AllRevenue previously referred to as net interest expense amounts include FDIC,revenue is now referred to as well asnet interest income. In addition, during the fourth quarter of 2021, Citi reclassified deposit insurance expenses (FDIC and other similar deposit insurance assessments outside of the U.S. As) from Interest expense to Other operating expenses for all periods presented. Amounts reclassified for each year were $1,207 million for 2021, $1,203 million for 2020 and $781 million for 2019.
(1)Interest revenue and Net interest income include the taxable equivalent adjustments related to the tax-exempt bond portfolio and certain tax-advantaged loan programs (based on the U.S. federal statutory tax rate of the fourth quarter21%) of 2018, Citi’s FDIC surcharge was eliminated (approximately $130$192 million, per quarter).$196 million and $208 million for 2021, 2020 and 2019, respectively.
(1)
(2)Interest expense associated with certain hybrid financial instruments, which are classified as Long-term debt and accounted for at fair value, is reported together
Net interest revenue    includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rates of 21% in 2019 and 2018 and 35% in 2017) of $208 million, $254 million and $496 million for 2019, 2018 and 2017, respectively.
(2)
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)
(3)    The average rate on interest revenue and net interest margin reflects the taxable equivalent gross-up adjustment. See footnote 1 on “Average Balances and Interest Rates—Assets” below.
(4)Citi’s net interest margin (NIM) is calculated by dividing net interest revenue 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 income by average interest-earning assets.


Net Interest Revenue Excluding
104


Non-ICG Markets Net Interest Income

In millions of dollars202120202019
Net interest income (NII)—taxable equivalent basis(1) per above
$42,686 $44,947 $48,338 
ICG Markets NII—taxable equivalent basis(1)
5,733 5,786 4,562 
Non-ICG Markets NII—taxable equivalent basis(1)
$36,953 $39,161 $43,776 

(1)    Interest revenue and Net interest income include the taxable equivalent adjustments discussed in the table above.
In millions of dollars201920182017
Net interest revenue—taxable equivalent basis(1) per above
$47,555
$46,816
$45,557
ICG Markets net interest revenue—taxable equivalent basis(1)
4,372
4,506
5,741
Net interest revenue excluding ICG Markets—taxable equivalent basis(1)
$43,183
$42,310
$39,816

(1)
Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rates of 21% in 2019 and 2018 and 35% in 2017) of $208 million, $254 million and $496 million for 2019, 2018 and 2017, respectively.

Citi’s net interest revenueincome (NII) in the fourth quarter of 2019 increased 1% to $12.02021 was $10.8 billion (also $12.0($10.9 billion on a taxable equivalent basis), largely unchanged versus the prior-year period. Excluding the impact of FX translation, net interest revenue also increased 1%, or approximately $70 million,prior year, as growtha modest increase in non-ICG Markets NII (approximately $60 million) offset an equivalent decline in ICG Markets (fixed income markets and equity markets) net interest revenue of 21%, or $210 million, was partially offset by a 1% decline, or $150 million, in net interest revenue ex-markets. The increase in markets net interest revenue was driven by ongoing changes in the composition and mix of the business’s revenues between net interest revenue and non-interest revenue. The decline in net interest revenue ex-markets was primarily due to the impact of lower interest rates, partially offset by growth in the non-markets franchise.. Citi’s NIM was 2.63%1.98% on a taxable equivalent basis in the fourth quarter of 2019, an increase2021, a decrease of 7one basis points (bps)point from the prior quarter, primarily driven by the higher markets net interest revenue, partially offset by the impact of lower interest rates.largely reflecting deposit growth.

Citi’s net interest revenueNII for the full year 2019 increased 2%2021 decreased 5%, or approximately $2.3 billion, to $47.3$42.5 billion ($47.642.7 billion on a taxable equivalent basis) versus the prior year. Excluding the impact of FX translation,The decrease was primarily related to a decline in non-ICG Markets NII, largely reflecting lower interest rates and lower loan balances. In 2021, Citi’s net interest revenue increased 3%, or approximately $1.4 billion, mainly reflecting strength in Citi-branded cards in North America GCB and treasury and trade solutions, including the impact of volume growth as well as interest rates. On a full-year basis, Citi’s
NIM was 2.65%1.99% on a taxable equivalent basis, compared to 2.69%2.22% in 2018. Citi’s markets2020, primarily driven by lower rates and non-markets net interest revenues are non-GAAP financial measures. Citi reviews non-markets net interest revenue to assess the performance of its lending, investing and deposit-raising activities. Citi believes disclosure of this metric assistsa mix-shift in providing a meaningful depiction of the underlying fundamentals of its non-markets businesses.balances.







105



Additional Interest Rate Details


Average Balances and Interest Rates—Assets(1)(2)(3)

Taxable Equivalent Basis
 Average volumeInterest revenue% Average rate
In millions of dollars, except rates202120202019202120202019202120202019
Assets      
Deposits with banks(4)
$298,319 $288,629 $188,523 $577 $928 $2,682 0.19 %0.32 %1.42 %
Securities borrowed and purchased under agreements to resell(5)
In U.S. offices$172,716 $149,076 $146,030 $385 $1,202 $4,752 0.22 %0.81 %3.25 %
In offices outside the U.S.(4)
149,944 138,074 119,550 667 1,081 2,133 0.44 0.78 1.78 
Total$322,660 $287,150 $265,580 $1,052 $2,283 $6,885 0.33 %0.80 %2.59 %
Trading account assets(6)(7)
In U.S. offices$140,215 $144,130 $109,064 $2,653 $3,624 $4,099 1.89 %2.51 %3.76 %
In offices outside the U.S.(4)
151,722 134,078 131,217 2,718 2,509 3,589 1.79 1.87 2.74 
Total$291,937 $278,208 $240,281 $5,371 $6,133 $7,688 1.84 %2.20 %3.20 %
Investments
In U.S. offices
Taxable$322,884 $265,833 $221,895 $3,547 $3,860 $5,162 1.10 %1.45 %2.33 %
Exempt from U.S. income tax12,296 14,084 15,227 437 452 577 3.55 3.21 3.79 
In offices outside the U.S.(4)
152,940 139,400 117,529 3,498 3,781 4,222 2.29 2.71 3.59 
Total$488,120 $419,317 $354,651 $7,482 $8,093 $9,961 1.53 %1.93 %2.81 %
Loans (net of unearned income)(8)
In U.S. offices$386,141 $396,846 $395,792 $24,023 $26,700 $30,563 6.22 %6.73 %7.72 %
In offices outside the U.S.(4)
281,895 288,379 288,319 11,509 13,569 17,266 4.08 4.71 5.99 
Total$668,036 $685,225 $684,111 $35,532 $40,269 $47,829 5.32 %5.88 %6.99 %
Other interest-earning assets(9)
$75,876 $67,547 $64,322 $653 $579 $1,673 0.86 %0.86 %2.60 %
Total interest-earning assets$2,144,948 $2,026,076 $1,797,468 $50,667 $58,285 $76,718 2.36 %2.88 %4.27 %
Non-interest-earning assets(6)
$202,761 $200,378 $181,337 
Total assets$2,347,709 $2,226,454 $1,978,805 

(1)Interest revenue and Net interest income include the taxable equivalent adjustments primarily related to the tax-exempt bond portfolio and certain tax-advantaged loan programs (based on the U.S. federal statutory tax rate of 21%) of $192 million, $196 million and $208 million for 2021, 2020 and 2019, respectively.
(2)Interest rates and amounts include the effects of risk management activities associated with the respective asset categories.
(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.
(7)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.
(8)Includes cash-basis loans.
(9)Includes Brokerage receivables.
106

 Average volumeInterest revenue% Average rate
In millions of dollars, except rates201920182017201920182017201920182017
Assets         
Deposits with banks(4)
$188,523
$177,294
$169,385
$2,682
$2,203
$1,635
1.42%1.24%0.97%
Securities borrowed and purchased under agreements to resell(5)
         
In U.S. offices$146,030
$149,879
$141,308
$4,752
$3,818
$1,922
3.25%2.55%1.36%
In offices outside the U.S.(4)
119,550
117,695
106,606
2,133
1,674
1,327
1.78
1.42
1.24
Total$265,580
$267,574
$247,914
$6,885
$5,492
$3,249
2.59%2.05%1.31%
Trading account assets(6)(7)
         
In U.S. offices$109,064
$94,065
$99,755
$4,099
$3,706
$3,531
3.76%3.94%3.54%
In offices outside the U.S.(4)
131,217
115,601
104,197
3,589
2,615
2,117
2.74
2.26
2.03
Total$240,281
$209,666
$203,952
$7,688
$6,321
$5,648
3.20%3.01%2.77%
Investments         
In U.S. offices         
Taxable$221,895
$228,686
$226,227
$5,162
$5,331
$4,450
2.33%2.33%1.97%
Exempt from U.S. income tax15,227
17,199
18,152
577
706
775
3.79
4.10
4.27
In offices outside the U.S.(4)
117,529
104,033
106,040
4,222
3,600
3,309
3.59
3.46
3.12
Total$354,651
$349,918
$350,419
$9,961
$9,637
$8,534
2.81%2.75%2.44%
Loans (net of unearned income)(8)
         
In U.S. offices$395,792
$385,350
$371,711
$30,563
$28,627
$25,944
7.72%7.43%6.98%
In offices outside the U.S.(4)
288,319
285,505
267,774
17,266
17,129
15,904
5.99
6.00
5.94
Total$684,111
$670,855
$639,485
$47,829
$45,756
$41,848
6.99%6.82%6.54%
Other interest-earning assets(9)
$64,322
$67,269
$60,626
$1,673
$1,673
$1,161
2.60%2.49%1.92%
Total interest-earning assets$1,797,468
$1,742,576
$1,671,781
$76,718
$71,082
$62,075
4.27%4.08%3.71%
Non-interest-earning assets(6)
$181,341
$177,654
$203,657
      
Total assets$1,978,809
$1,920,230
$1,875,438
      
(1)
Net interest revenue includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rates of 21% in 2019 and 2018 and 35% in 2017) of $208 million, $254 million and $496 million for 2019, 2018 and 2017, respectively.

(2)Interest rates and amounts include the effects of risk management activities associated with the respective asset categories.
(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.
(7)
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.
(8)Includes cash-basis loans.
(9)Includes brokerage receivables.

Average Balances and Interest Rates—Liabilities and Equity, and Net Interest RevenueIncome(1)(2)(3)

Taxable Equivalent Basis

Average volumeInterest expense% Average rate
In millions of dollars, except rates202120202019202120202019202120202019
Liabilities      
Deposits    
In U.S. offices(4)
$532,466 $485,848 $388,948 $1,084 $2,524 $5,873 0.20 %0.52 %1.51 %
In offices outside the U.S.(5)
557,207 541,301 487,318 1,812 2,810 5,979 0.33 0.52 1.23 
Total$1,089,673 $1,027,149 $876,266 $2,896 $5,334 $11,852 0.27 %0.52 %1.35 %
Securities loaned and sold under agreements to repurchase(6)
In U.S. offices$136,955 $137,348 $112,876 $676 $1,292 $4,194 0.49 %0.94 %3.72 %
In offices outside the U.S.(5)
93,744 79,426 77,283 336 785 2,069 0.36 0.99 2.68 
Total$230,699 $216,774 $190,159 $1,012 $2,077 $6,263 0.44 %0.96 %3.29 %
Trading account liabilities(7)(8)
In U.S. offices$47,871 $38,308 $37,099 $109 $283 $818 0.23 %0.74 %2.20 %
In offices outside the U.S.(5)
67,739 52,051 51,817 373 345 490 0.55 0.66 0.95 
Total$115,610 $90,359 $88,916 $482 $628 $1,308 0.42 %0.70 %1.47 %
Short-term borrowings and other interest-bearing liabilities(9)
In U.S. offices$69,683 $82,363 $78,230 $(27)$493 $2,138 (0.04)%0.60 %2.73 %
In offices outside the U.S.(5)
26,133 20,053 20,575 148 137 327 0.57 0.68 1.59 
Total$95,816 $102,416 $98,805 $121 $630 $2,465 0.13 %0.62 %2.49 %
Long-term debt(10)
In U.S. offices$186,522 $213,809 $193,972 $3,384 $4,656 $6,398 1.81 %2.18 %3.30 %
In offices outside the U.S.(5)
4,282 3,918 4,803 86 13 96 2.01 0.33 2.00 
Total$190,804 $217,727 $198,775 $3,470 $4,669 $6,494 1.82 %2.14 %3.27 %
Total interest-bearing liabilities$1,722,602 $1,654,425 $1,452,921 $7,981 $13,338 $28,382 0.46 %0.81 %1.95 %
Demand deposits in U.S. offices$98,414 $30,876 $27,737 
Other non-interest-bearing liabilities(7)
324,724 346,736 301,756 
Total liabilities$2,145,740 $2,032,037 $1,782,414 
Citigroup stockholders’ equity$201,360 $193,769 $195,685 
Noncontrolling interests609 648 706 
Total equity$201,969 $194,417 $196,391 
Total liabilities and stockholders’ equity$2,347,709 $2,226,454 $1,978,805 
Net interest income as a percentage of average interest-earning assets(11)
In U.S. offices$1,244,182 $1,187,077 $1,017,021 $26,404 $27,520 $28,898 2.12 %2.32 %2.84 %
In offices outside the U.S.(6)
900,766 838,999 780,447 16,282 17,427 19,440 1.81 2.08 2.49 
Total$2,144,948 $2,026,076 $1,797,468 $42,686 $44,947 $48,338 1.99 %2.22 %2.69 %

(1)Interest revenue and Net interest income include the taxable equivalent adjustments discussed in the table above.
(2)Interest rates and amounts include the effects of risk management activities associated with the respective liability categories.
(3)Monthly or quarterly averages have been used by certain subsidiaries where daily averages are unavailable.
(4)Consists of other time deposits and savings deposits. Savings deposits are made up of insured money market accounts, NOW accounts and other savings deposits. The interest expense on savings deposits includes FDIC deposit insurance assessments.
(5)Average rates reflect prevailing local interest rates, including inflationary effects and monetary corrections in certain countries.
(6)Average volumes of securities sold under agreements to repurchase are reported net pursuant to ASC 210-20-45. However, Interest expense excludes the impact of ASC 210-20-45.
(7)The fair value carrying amounts of derivative contracts are reported net, pursuant to ASC 815-10-45, in Non-interest-earning assets and Other non-interest-bearing liabilities.
107


 Average volumeInterest expense% Average rate
In millions of dollars, except rates201920182017201920182017201920182017
Liabilities         
Deposits         
In U.S. offices(4)
$388,948
$338,060
$313,094
$6,304
$4,500
$2,530
1.62%1.33%0.81%
In offices outside the U.S.(5)
487,318
453,793
436,949
6,329
5,116
4,057
1.30
1.13
0.93
Total$876,266
$791,853
$750,043
$12,633
$9,616
$6,587
1.44%1.21%0.88%
Securities loaned and sold under agreements to repurchase(6)
         
In U.S. offices$112,876
$102,843
$96,258
$4,194
$3,320
$1,574
3.72%3.23%1.64%
In offices outside the U.S.(5)
77,283
69,264
61,434
2,069
1,569
1,087
2.68
2.27
1.77
Total$190,159
$172,107
$157,692
$6,263
$4,889
$2,661
3.29%2.84%1.69%
Trading account liabilities(7)(8)
         
In U.S. offices$37,099
$37,305
$33,399
$818
$612
$380
2.20%1.64%1.14%
In offices outside the U.S.(5)
51,817
58,919
57,149
490
389
258
0.95
0.66
0.45
Total$88,916
$96,224
$90,548
$1,308
$1,001
$638
1.47%1.04%0.70%
Short-term borrowings(9)
         
In U.S. offices$78,230
$85,009
$74,825
$2,138
$1,885
$684
2.73%2.22%0.91%
In offices outside the U.S.(5)
20,575
23,402
22,837
327
324
375
1.59
1.38
1.64
Total$98,805
$108,411
$97,662
$2,465
$2,209
$1,059
2.49%2.04%1.08%
Long-term debt(10)
         
In U.S. offices$193,972
$197,933
$192,079
$6,398
$6,386
$5,382
3.30%3.23%2.80%
In offices outside the U.S.(5)
4,803
4,895
4,615
96
165
191
2.00
3.37
4.14
Total$198,775
$202,828
$196,694
$6,494
$6,551
$5,573
3.27%3.23%2.83%
Total interest-bearing liabilities$1,452,921
$1,371,423
$1,292,639
$29,163
$24,266
$16,518
2.01%1.77%1.28%
Demand deposits in U.S. offices$27,737
$33,398
$37,824
      
Other non-interest-bearing liabilities(7)
301,813
315,862
316,129
      
Total liabilities$1,782,471
$1,720,683
$1,646,592
      
Citigroup stockholders’ equity$195,632
$198,681
$227,849
      
Noncontrolling interests706
866
997
      
Total equity$196,338
$199,547
$228,846
      
Total liabilities and stockholders’ equity$1,978,809
$1,920,230
$1,875,438
      
Net interest revenue as a percentage of average interest-earning assets(11)
         
In U.S. offices$1,017,021
$992,543
$970,439
$28,466
$28,157
$27,551
2.80%2.84%2.84%
In offices outside the U.S.(6)
780,447
750,033
701,342
19,089
18,659
18,006
2.45
2.49
2.57
Total$1,797,468
$1,742,576
$1,671,781
$47,555
$46,816
$45,557
2.65%2.69%2.73%
(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.
(1)
Net interest revenue
(9)Includes Brokerage payables.
(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.

includes the taxable equivalent adjustments related to the tax-exempt bond portfolio (based on the U.S. federal statutory tax rates of 21% in 2019 and 2018 and 35% in 2017) of $208 million, $254 million and $496 million for 2019, 2018 and 2017, respectively.
(2)Interest rates and amounts include the effects of risk management activities associated with the respective liability categories.
(3)Monthly or quarterly averages have been used by certain subsidiaries where daily averages are unavailable.
(4)Consists of other time deposits and savings deposits. Savings deposits are made up of insured money market accounts, NOW accounts and other savings deposits. The interest expense on savings deposits includes FDIC deposit insurance assessments.
(5)Average rates reflect prevailing local interest rates, including inflationary effects and monetary corrections in certain countries.
(6)
Average volumes of securities sold under agreements to repurchase are reported net pursuant to ASC 210-20-45. However, Interest expense excludes the impact of ASC 210-20-45.
(7)
The fair value carrying amounts of derivative contracts are reported net, pursuant to ASC 815-10-45, in Non-interest-earning assets and Other non-interest-bearing liabilities.
(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.

(9)
Includes Brokerage payables.
(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)

 2021 vs. 20202020 vs. 2019
 Increase (decrease)
due to change in:
Increase (decrease)
due to change in:
In millions of dollarsAverage
volume
Average
rate
Net
change
Average
volume
Average
rate
Net
change
Deposits with banks(3)
$30 $(381)$(351)$976 $(2,730)$(1,754)
Securities borrowed and purchased under agreements to resell
In U.S. offices$166 $(983)$(817)$97 $(3,647)$(3,550)
In offices outside the U.S.(3)
86 (500)(414)290 (1,342)(1,052)
Total$252 $(1,483)$(1,231)$387 $(4,989)$(4,602)
Trading account assets(4)
In U.S. offices$(96)$(875)$(971)$1,103 $(1,578)$(475)
In offices outside the U.S.(3)
320 (111)209 77 (1,157)(1,080)
Total$224 $(986)$(762)$1,180 $(2,735)$(1,555)
Investments(1)
In U.S. offices$761 $(1,089)$(328)$911 $(2,338)$(1,427)
In offices outside the U.S.(3)
345 (628)(283)703 (1,144)(441)
Total$1,106 $(1,717)$(611)$1,614 $(3,482)$(1,868)
Loans (net of unearned income)(5)
In U.S. offices$(706)$(1,971)$(2,677)$81 $(3,945)$(3,864)
In offices outside the U.S.(3)
(299)(1,761)(2,060)(3,700)(3,696)
Total$(1,005)$(3,732)$(4,737)$85 $(7,645)$(7,560)
Other interest-earning assets(6)
$72 $2 $74 $80 $(1,174)$(1,094)
Total interest revenue$679 $(8,297)$(7,618)$4,322 $(22,755)$(18,433)

(1)Interest revenue and Net interest income include the taxable equivalent adjustments discussed in the table above.
(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.
(5)Includes cash-basis loans.
(6)Includes Brokerage receivables.
108

 2019 vs. 20182018 vs. 2017
 
Increase (decrease)
due to change in:
Increase (decrease)
due to change in:
In millions of dollars
Average
volume
Average
rate
Net
change
Average
volume
Average
rate
Net
change
Deposits with banks(3)
$146
$333
$479
$79
$489
$568
Securities borrowed and purchased under agreements to resell      
In U.S. offices$(100)$1,034
$934
$123
$1,773
$1,896
In offices outside the U.S.(3)
27
432
459
146
201
347
Total$(73)$1,466
$1,393
$269
$1,974
$2,243
Trading account assets(4)
      
In U.S. offices$570
$(177)$393
$(209)$384
$175
In offices outside the U.S.(3)
382
592
974
245
253
498
Total$952
$415
$1,367
$36
$637
$673
Investments(1)
      
In U.S. offices$(213)$(85)$(298)$32
$780
$812
In offices outside the U.S.(3)
481
141
622
(64)355
291
Total$268
$56
$324
$(32)$1,135
$1,103
Loans (net of unearned income)(5)
      
In U.S. offices$789
$1,149
$1,938
$974
$1,709
$2,683
In offices outside the U.S.(3)
169
(34)135
1,062
163
1,225
Total$958
$1,115
$2,073
$2,036
$1,872
$3,908
Other interest-earning assets(6)
$(75)$75
$
$137
$375
$512
Total interest revenue$2,176
$3,460
$5,636
$2,525
$6,482
$9,007
(1)The taxable equivalent adjustments related to the tax-exempt bond portfolio, based on the U.S. federal statutory tax rates of 21% in 2019 and 2018 and 35% in 2017, are included in this presentation.
(2)Rate/volume variance is allocated based on the percentage relationship of changes in volume and changes in rate to the total net change.
(3)Changes in average rates reflect changes in prevailing local interest rates, including inflationary effects and monetary corrections in certain countries.
(4)
Interest expense on Trading account liabilities of ICG is reported as a reduction of Interest revenue. Interest revenue and Interest expense on cash collateral positions are reported in interest on Trading account assets and Trading account liabilities, respectively.

(5)Includes cash-basis loans.
(6)
Includes Brokerage receivables.

Analysis of Changes in Interest Expense and Net Interest RevenueIncome(1)(2)(3)

 2021 vs. 20202020 vs. 2019
 Increase (decrease)
due to change in:
Increase (decrease)
due to change in:
In millions of dollarsAverage
volume
Average
rate
Net
change
Average
volume
Average
rate
Net
change
Deposits
In U.S. offices$222 $(1,661)$(1,439)$1,199 $(4,548)$(3,349)
In offices outside the U.S.(3)
80 (1,078)(998)601 (3,770)(3,169)
Total$302 $(2,739)$(2,437)$1,800 $(8,318)$(6,518)
Securities loaned and sold under agreements to repurchase
In U.S. offices$(4)$(612)$(616)$757 $(3,659)$(2,902)
In offices outside the U.S.(3)
122 (571)(449)56 (1,340)(1,284)
Total$118 $(1,183)$(1,065)$813 $(4,999)$(4,186)
Trading account liabilities(4)
In U.S. offices$58 $(232)$(174)$26 $(561)$(535)
In offices outside the U.S.(3)
93 (65)28 (147)(145)
Total$151 $(297)$(146)$28 $(708)$(680)
Short-term borrowings and other interest-bearing liabilities(5)
In U.S. offices$(66)$(454)$(520)$107 $(1,752)$(1,645)
In offices outside the U.S.(3)
37 (26)11 (8)(182)(190)
Total$(29)$(480)$(509)$99 $(1,934)$(1,835)
Long-term debt
In U.S. offices$(551)$(721)$(1,272)$603 $(2,346)$(1,743)
In offices outside the U.S.(3)
1 71 72 (15)(67)(82)
Total$(550)$(650)$(1,200)$588 $(2,413)$(1,825)
Total interest expense$(8)$(5,349)$(5,357)$3,328 $(18,372)$(15,044)
Net interest income$687 $(2,948)$(2,261)$993 $(4,382)$(3,389)

(1)Interest revenue and Net interest income include the taxable equivalent adjustments discussed in the table above.
(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.
(5)Includes Brokerage payables.

 2019 vs. 20182018 vs. 2017
 
Increase (decrease)
due to change in:
Increase (decrease)
due to change in:
In millions of dollars
Average
volume
Average
rate
Net
change
Average
volume
Average
rate
Net
change
Deposits      
In U.S. offices$738
$1,066
$1,804
$216
$1,754
$1,970
In offices outside the U.S.(3)
397
816
1,213
162
897
1,059
Total$1,135
$1,882
$3,017
$378
$2,651
$3,029
Securities loaned and sold under agreements to repurchase      
In U.S. offices$343
$531
$874
$115
$1,631
$1,746
In offices outside the U.S.(3)
194
306
500
151
331
482
Total$537
$837
$1,374
$266
$1,962
$2,228
Trading account liabilities(4)
      
In U.S. offices$(3)$209
$206
$49
$183
$232
In offices outside the U.S.(3)
(51)152
101
8
123
131
Total$(54)$361
$307
$57
$306
$363
Short-term borrowings(5)
      
In U.S. offices$(159)$412
$253
$105
$1,096
$1,201
In offices outside the U.S.(3)
(42)45
3
9
(60)(51)
Total$(201)$457
$256
$114
$1,036
$1,150
Long-term debt      
In U.S. offices$(129)$141
$12
$168
$836
$1,004
In offices outside the U.S.(3)
(3)(66)(69)11
(37)(26)
Total$(132)$75
$(57)$179
$799
$978
Total interest expense$1,285
$3,612
$4,897
$994
$6,754
$7,748
Net interest revenue$891
$(152)$739
$1,531
$(272)$1,259
(1)The taxable equivalent adjustments related to the tax-exempt bond portfolio, based on the U.S. federal statutory tax rates of 21% in 2019 and 2018 and 35% in 2017, are included in this presentation.
(2)Rate/volume variance is allocated based on the percentage relationship of changes in volume and changes in rate to the total net change.
(3)Changes in average rates reflect changes in prevailing local interest rates, including inflationary effects and monetary corrections in certain countries.
(4)
Interest expense on Trading account liabilities of ICG is reported as a reduction of Interest revenue. Interest revenue and Interest expense on cash collateral positions are reported in interest on Trading account assets and Trading account liabilities, respectively.
(5)
Includes Brokerage payables.

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 100%95.8% of the trading days in 2019.2021.


Daily Trading-Related Revenue (Loss)(1)—Twelve Months endedEnded December 31, 20192021
In millions of dollars

a2019vardailytradingrelatedr.jpgc-20211231_g14.jpg

(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.

(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 billBond for a one-basis-point change in interest rates. Citi’s market risk management,Global Market Risk function, within the Independent Risk Management 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��VAR Model Review and Validation” below), which has been designed to capture material risk sensitivities (such as first- and second-order sensitivities of positions to changes in market prices) of
various asset classes/risk types (such as interest rate, credit
spread, foreign exchange, equity and commodity risks). Citi’s VAR includes positions that are measured at fair value; it does not include investment securities classified as AFS or HTM. For information on these securities, see Note 13 to the Consolidated Financial Statements.
Citi believes its VAR model is conservatively calibrated to incorporate fat-tail scaling and the greater of short-term (approximately the most recent month) and long-term (three years) market volatility. The Monte Carlo simulation involves approximately 450,000 market factors, making use of approximately 350,000 time series, with sensitivities updated daily, volatility parameters updated intra-monthly and correlation parameters updated monthly. The conservative features of the VAR calibration contribute an approximate 26%33% add-on to what would be a VAR estimated under the assumption of stable and perfectly, normally distributed markets.
As set forth in the table below, Citi’s average trading VAR decreased $5 million from 20182020 to 2019,2021, mainly due to changes in interest rates in the ICGMarkets businesses. Thea reduction of market volatility, given improved macroeconomic conditions, compared to 2020. Citi’s average trading and credit portfolio VAR also declined, although the decrease in average tradingdecreased $24 million from 2020 to 2021 due to VAR was partially offset by additional hedging related to lending activities in 2019.volatility recalibration.



Year-end and Average Trading VAR and Trading and Credit Portfolio VAR
In millions of dollarsDecember 31, 20212021 AverageDecember 31, 20202020 Average
Interest rate$50 $65 $72 $66 
Credit spread59 71 70 86 
Covariance adjustment(1)
(35)(42)(51)(48)
Fully diversified interest rate and credit spread(2)
$74 $94 $91 $104 
Foreign exchange36 42 40 26 
Equity29 33 31 36 
Commodity28 34 17 22 
Covariance adjustment(1)
(88)(102)(85)(82)
Total trading VAR—all market risk factors, including general and specific risk (excluding credit portfolios)(2)
$79 $101 $94 $106 
Specific risk-only component(3)
$3 $1 $(1)$(2)
Total trading VAR—general market risk factors only (excluding credit portfolios)$76 $100 $95 $108 
Incremental impact of the credit portfolio(4)
$45 $30 $29 $49 
Total trading and credit portfolio VAR$124 $131 $123 $155 

(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

In millions of dollarsDecember 31, 20192019 AverageDecember 31, 20182018 Average
Interest rate$32
$35
$48
$60
Credit spread44
44
55
47
Covariance adjustment(1)
(27)(23)(23)(24)
Fully diversified interest rate and credit spread(2)
$49
$56
$80
$83
Foreign exchange22
23
18
25
Equity21
16
25
22
Commodity13
24
23
19
Covariance adjustment(1)
(52)(62)(66)(67)
Total trading VAR—all market risk factors, including general and specific risk (excluding credit portfolios)(2)
$53
$57
$80
$82
Specific risk-only component(3)
$3
$2
$4
$4
Total trading VAR—general market risk factors only (excluding credit portfolios)$50
$55
$76
$78
Incremental impact of the credit portfolio(4)
$30
$14
$18
$10
Total trading and credit portfolio VAR$83
$71
$98
$92

(1)Covariance adjustment (also known as diversification benefit) equals the difference between the total VAR and the sum of the VARs tied to each individual risk type. The benefit reflects the fact that the risks within each and across risk types are not perfectly correlated and, consequently, the total VAR on a given day will be lower than the sum of the VARs relating to each individual risk type. The determination of the primary drivers of changes to the covariance adjustment is made by an examination of the impact of both model parameter and position changes.    
(2)
The total trading VAR includes mark-to-market and certain fair value option trading positions in ICG, with the exception of hedges to the loan portfolio, fair value option loans and all CVA exposures. Available-for-sale and accrual exposures are not included.
(3)The specific risk-only component represents the level of equity and fixed income issuer-specific risk embedded in VAR.
(4)
The credit portfolio is composed of mark-to-market positions associated with non-trading business units including Citi Treasury, the CVA relating to derivative counterparties and all associated CVA hedges. FVA and DVA are not included. The credit portfolio also includes hedges to the loan portfolio, fair value option loans and hedges to the leveraged finance pipeline within capital markets origination in ICG.


The table below provides the range of market factor VARs associated with Citi’s total trading VAR, inclusive of specific risk:

2019201820212020
In millions of dollarsLowHighLowHighIn millions of dollarsLowHighLowHigh
Interest rate$25
$58
$34
$89
Interest rate$47 $96 $28 $137 
Credit spread36
55
38
64
Credit spread54 96 36 171 
Fully diversified interest rate and credit spread$43
$89
$59
$118
Fully diversified interest rate and credit spread$74 $123 $44 $223 
Foreign exchange12
34
13
44
Foreign exchange33 49 14 40 
Equity7
29
15
33
Equity21 50 13 141 
Commodity12
75
13
27
Commodity19 55 12 64 
Total trading$38
$87
$56
$120
Total trading$79 $130 $47 $245 
Total trading and credit portfolio54
103
66
124
Total trading and credit portfolio108 166 58 424 

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 dollarsDec. 31, 2021
Total—all market risk factors, including general and specific risk$81
Average—during year$103
High—during year134
Low—during year81
In millions of dollarsDec. 31, 2019
Total—all market risk factors, including general and specific risk$53
Average—during year$57
High—during year86
Low—during year38

VAR Model Review and Validation
Generally, Citi’s VAR review and model validation process entails reviewing the model framework, major assumptions and implementation of the mathematical algorithm. In addition, as part of the model validation process, product specific back-testing on portfolios is
periodically completed 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.
SignificantMaterial VAR model and assumption changes must be independently validated within Citi’s risk managementIndependent Risk Management organization. This validation process includes a reviewAll 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 “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 whenwhere 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.

112


The following graph shows the daily buy-and-hold profit and loss associated with Citi’s covered positions compared to Citi’s one-day Regulatory VAR during 2019.2021. As of December 31, 2019, there were no2021, one back-testing exceptionsexception was observed for Citi’s Regulatory VAR forat the prior 12 months.Citigroup level.
The difference between the 54.8%54.4% of days with buy-and-hold gains for Regulatory VAR back-testing and the 100%95.8% 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, 20192021
In millions of dollars
a2019varbacktestingexception.jpg
(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.

c-20211231_g15.jpg

(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 human factors, or from external events. ItThis includes legal risk, which is the risk of failingloss (including litigation costs, settlements, and regulatory fines) resulting from the failure of Citi to comply with applicable laws, regulations, prudent ethical standards, and regulations,contractual obligations in any aspect of its businesses, but excludes strategic risk. Operationaland reputation risks. Citi also recognizes the impact of operational risk includeson the reputation and franchise risk associated with Citi’s business practices or market conduct in which Citi is involved, as well as compliance, conduct and legal risks.activities.
Operational risk is inherent in Citi’s global business activities, as well as related support functions, and can result in losses arising from events associated with the following, among others:

fraud, theftlosses. Citi maintains a comprehensive Citi-wide risk taxonomy to classify operational risks that it faces using standardized definitions across Citi’s Operational Risk Management Framework (see discussion below). This taxonomy also supports regulatory requirements and unauthorized activity;
employment practicesexpectations inclusive of those related to U.S. Basel III, Comprehensive Capital Analysis and workplace environment;
clients, productsReview (CCAR), Heightened Standards for Large Financial Institutions and business practices;
physical assets and infrastructure; and
execution, delivery and process management.

Dodd Frank Annual Stress Testing (DFAST).
Citi manages operational risk consistent with the overall framework described in “Managing Global Risk—Overview” above. The Company’sCiti’s goal is to keep operational risk at appropriate levels relative to the characteristics of Citi’sits businesses, the markets in which it operates, its capital and liquidity and the competitive, economic and regulatory environment.
To anticipate, mitigate and control This includes effectively managing operational risk Citiand maintaining or reducing operational risk exposures within Citi’s operational risk appetite.
Citi’s Independent Operational Risk Management group has established a global-Operational Risk Management Framework with policies and a global frameworkpractices for assessing,identification, measurement, monitoring, managing and communicatingreporting operational risks and the overall operating effectiveness of the internal control environment across Citigroup.environment. As part of this framework, Citi has defined its operational risk appetite and has established a manager’s control assessment (MCA) process (a process through which managers at Citi identify, monitor, measure, report on and manage risks and the related controls) to help managers self-assessfor self-identification of significant operational risks, andassessment of the performance of key controls and identify and address weaknesses in the design and/or operating effectivenessmitigation of internal controls that mitigate significant operational risks.residual risk above acceptable levels.
Each major business segment must implement an operational risk processprocesses consistent with the requirements of this framework. The process forThis includes:

understanding the operational risk management includes the following steps:risks they are exposed to;

identify and assess key operational risks;
designdesigning controls to mitigate identified risks;
establishestablishing key risk indicators;
implement a process for early problem recognitionmonitoring and timely escalation;
produce comprehensivereporting whether the operational risk reporting;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
ensureensuring that sufficient resources are available to actively improve the operational risk environment and mitigate emerging risks.

As new products and business activities are developed, processes are designed, modified or sourced through alternative means and
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 considered.
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.
AnIn addition, Independent Risk Management, including the Operational Risk Management Committee has been established to provide oversight for operational risk across Citigroup and to provide a forum to assess Citi’s operational risk profile and ensure actions are taken so that Citi’s operational risk exposure is actively managed consistent with Citi’s risk appetite. The Committee seeks to ensure that these actions address the root causes that persistently lead to operational risk losses and create lasting solutions to minimize these losses. Members include Citi’s Chief Risk Officer and Citi’s Head of Operational Risk and senior members of their organizations. These members cover multiple dimensions of risk management and include business and regional Chief Risk Officers and senior operational risk managers.
In addition, risk management, including Operational Risk Management,group, works proactively with theCiti’s businesses and other independent control functions to embeddrive a strong and embedded operational risk management culture and framework across Citi. The Operational Risk Management engages with the businesses to ensure effectivegroup actively challenges business and functions implementation of the Operational Risk Management framework by focusing on (i) identification, analysisFramework requirements and assessment of operational risks, (ii) effective challenge of key control issues and operational risks and (iii) anticipation and mitigationthe quality of operational risk events.management practices and outcomes.
Information about the businesses’ key operational risk,risks, historical operational risk losses and the control environment is reported by each major business segment and functional area. TheCiti’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.Directors by the Head of Operational Risk Management.
Operational risk is measured and assessed through Operational Risk Capital and Operational Risk Regulatory Capital for the Advanced Approaches under Basel III. Projected operational risk losses under stress scenarios are alsoestimated as a required as part of the Federal Reserve Board’sFRB’s CCAR process.
For additional information on Citi’s operational risks, see “Risk Factors—Operational Risk” above.

Cybersecurity Risk

Overview
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 processes and systems and cybersecurity risk factors in “Risk Factors—Operational Risks” above). With an evolving threat landscape, ever-increasing sophistication of cybersecurity attacksthreat actor tactics, techniques and procedures, 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 forfrom cyber attacks and information security incidents. Citi recognizes the significance of these risks and, therefore, employsleverages an intelligence-led strategy to prevent,protect against, detect and 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 cybercybersecurity preparedness and resilience.

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Risk Management
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 commandcommands 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, inmanagement. In each case workingthe team works in coordination with a network of information security officers who are embedded within the businesses and functions on a global basis.globally.
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. 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 teams 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.
Internal audit serves as the third line of defense and independently provides assurance on how effectively the organization as a whole manages cybersecurity risk. Citi also has multiple senior committees such as the Information Security Risk Committee (ISRC), which governs enterprise-level risk tolerance inclusive of cybersecurity risk.
Citi seeks
Board Oversight
Citi’s Board of Directors provides oversight of management’s efforts to proactively identifymitigate cybersecurity risk and remediate technologyrespond to cyber incidents. The Board receives regular reports on cybersecurity and engages in discussions throughout the year with management and subject-matter experts on the effectiveness of Citi’s overall 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 withprogram. The Board also obtains updates on Citi’s defined Technology and Cyber Risk Appetite statements. To address evolvinginherent cybersecurity risks and corresponding regulations, ORM-T/C also monitorsCiti’s road map and progress for addressing these risks.
Moreover, Citi’s Board and its committee members receive contemporaneous reporting on significant cyber events including response, legal obligations, and regulatory requirements, identifiesoutreach and defines emerging risks, executes strategicnotification to regulators, and customers when needed, as well
as guidance to management as appropriate. In 2021, the Board of Directors underwent a cyber threat assessments, performs new products and initiative reviews, performs data management riskincident tabletop exercise. Also in 2021, the Board’s Risk Management Committee approved a standalone Cybersecurity Risk Appetite Statement against which Citi’s performance is measured quarterly. For additional information on the Board’s oversight and conducts cyber risk assurance reviews (inclusive of third-party assessments). In addition, ORM-T/C employs tools and oversees and challenges metrics that are both tailored to cybersecurity and technology and aligned with Citi’s overall operational risk management, frameworksee Citi’s 2022 proxy statement to effectively track, identify and manage risk.be filed with the SEC in March 2022.

COMPLIANCE RISK
Compliance riskis the risk to current or projected financial condition and resilience arising from violations of laws, rules, or regulations, or from nonconformancenon-conformance with prescribed practices, internal policies and procedures or ethical standards. ThisCompliance risk exposes a bankCiti to fines, civil money penalties, payment of damages and the voiding of contracts. Compliance risk is notcan result in diminished reputation, harm to Citi’s customers, limited to risk from failure to comply with consumer protection laws; itbusiness 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 includes theinclude exposure to litigation (known as legal risk) from all aspects of banking, traditional and nontraditional.
non-traditional banking.
Compliance risk spans all risk types in Citi’s risk governance framework and the risk categories outlined in the Governance, Risk, Compliance (GRC) taxonomy. Citi seeks to operate with integrity, maintain strong ethical standards and adhere to applicable policies and regulatory and legal requirements. Citi must maintain and execute a proactive Compliance Risk Management (CRM) Policy that is designed to manage compliance risk effectively across Citi, with a view to fundamentally strengthen the compliance risk management culture across the lines of defense taking into account Citi’s risk governance framework and regulatory requirements. Independent Compliance Risk Management’s (ICRM) primary objectives are to:

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
Drive and embed a culture of compliance and control throughout Citi; and
Provide compliance risk data aggregation and reporting capabilities.

To anticipate, control and mitigate compliance risk, Citi has established the CRM Policy to achieve standardization and centralization of methodologies and processes, and to enable more consistent and comprehensive execution of compliance risk management.
Citi has a commitment, as well as an obligation, to identify, assess and mitigate compliance risks associated with its businesses and functions. ICRM is responsible for oversight of Citi’s CRM Policy, while all businesses and global control functions are responsible for managing their compliance risks and operating within the Compliance Risk Appetite.
Citi carries out its objectives and fulfills its responsibilities through the integrated CRM Policy, Compliance Risk Framework,
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which is based upon four components: (i) governancecomposed of the following integrated key activities, to holistically manage compliance risk:

Management of Citi’s compliance with laws, rules and organization; (ii)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 the Compliance Risk Appetite, which is articulated through qualitative compliance risk requirements; (iii) processesstatements describing Citi’s appetite for certain types of risk and activities;quantitative measures to monitor the Company’s compliance risk exposure;
Monitoring and (iv) resourcestesting of compliance risks and capabilities. To achieve this, Citi follows these CRM Policy process steps:controls in assessing conformance with laws, rules, regulations and internal policies; and

Identifying regulatory changesIssue identification, escalation and performing the impact assessment, as well as capturingremediation to drive accountability, including measurement and monitoring adherence to existing regulatory requirements.
Establishing, maintaining and adhering to policies, standards and procedures for the managementreporting of compliance risk metrics against established thresholds in accordance with policy governance requirements.support of the CRM Policy and Compliance Risk Appetite.
Developing and providing training to support the effective execution of roles and responsibilities related to the identification, control, reporting and escalation of matters related to compliance risks.
Self-assessment (e.g., Managers Control Assessment) of compliance risk.

ICRM is responsible for independently assessing the management of compliance risks.
Independently testing and monitoring thatAs discussed above, Citi is operating withinworking to address the FRB and OCC consent orders, which include improvements to Citi’s Compliance Risk Appetite. Identifying instances of non-conformance with laws, regulations, rulesFramework and breaches of internal policies.its Enterprise-wide application (for additional information regarding the consent orders, see “Citi’s Consent Order Compliance” above).
Escalating through the appropriate channels, which may include governance forums, the results of monitoring, testing, reporting or other oversight activities that may represent a violation of law, regulation, policy or other significant compliance risk and take reasonable action to see that the matter is appropriately identified, tracked and resolved, including through the issuance of corrective action plans against the first line of defense.

REPUTATION RISK
Citi’s reputation is a vital asset in building trust with its stakeholders and Citi is diligent in communicatingenhancing and protecting its corporate values toreputation with its employees,colleagues, customers, investors and investors.regulators. To support this, Citi has defineddeveloped a reputation risk appetite approach.framework. Under this approach, each major business segment hasframework, Citigroup and Citibank have implemented a risk appetite statement and related key indicators to monitor corporate activities and address weaknesses that may result in significant reputation risks.operations relative to our risk appetite. The approachframework also requires that each business segment or region escalatessegments and regions escalate significant reputation risks that require review or mitigation through its business practice committeea Reputation Risk Committee or equivalent.
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. The Reputation Risk Committees determine the appropriate actions to be taken in line with risk appetite and regulatory expectations, while promoting a culture of risk awareness and high standards of integrity and ethical behavior across the Company, consistent with Citi’s mission and value proposition. The Reputation Risk Committees in the business practices committeessegments and regions are part of the governance infrastructure that Citi has in place to properly review the reputation risk posed by business activities, sales practices, product design, or perceived conflicts of interest and other potential franchise or reputation risks.interest. These committees may also raise potential franchise, reputation or systemic risks for due consideration by the business practices committeeReputation Risk Committee at the corporate level. AllThe Citigroup Reputation Risk Committee may escalate reputation risks to the Nomination, Governance and Public Affairs Committee or other appropriate committee of these committees, which are composedthe Citigroup Board of Citi’s most senior executives, provide the guidance necessary for Citi’s business practices to meet the highest standards of professionalism, integrity and ethical behavior consistent with Citi’s mission and value proposition.Directors.
Further, the
The responsibility for maintainingenhancing and protecting Citi’s reputation is shared by all employees,colleagues, who are guided by Citi’s codeCode of conduct. EmployeesConduct. 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 franchise, reputation and/or systemic risk.risk in line with policy.

STRATEGIC RISK

Overview
Citi executive management,As discussed above, strategic risk is the risk of a sustained impact (not episodic impact) to Citi’s core strategic objectives as measured by impacts on anticipated earnings, market capitalization, or capital, arising from the external factors affecting the Company’s operating environment; as well as the risks associated with Citi’s CEOdefining the strategy and executing the strategy, which are identified, measured and managed as part of the Strategic Risk Framework at the lead,Enterprise Level.
In this context, external factors affecting Citi’s operating environment are the economic environment, geopolitical/political landscape, industry/competitive landscape, societal trends, customer/client behavior, regulatory/legislative environment and trends related to investors/shareholders.
Citi’s Executive Management Team is responsible for the development and execution of Citi’s strategy. This strategy is translated into forward-looking plans (collectively Citi’s Strategic Plan) that are then cascaded across the organization. Citi’s Strategic Plan is presented to the board on an annual basis and is aligned with Risk Appetite thresholds and includes Top Risk identification as required by internal frameworks. It is also aligned with limit requirements for capital allocation. Governance and oversight of strategic risk is monitoredfacilitated by internal committees on a group-wide basis as well as strategic committees at the ICG, GCB and regional levels.
Citi works to ensure that strategic risks are adequately considered and addressed across its various risk management activities, and that strategic risks are assessed in the context of Citi’s risk appetite. Citi conducts a top-down, bottom-up risk identification process to identify risks, including strategic risks. Business segments undertake a quarterly risk identification process to systematically identify and document all material risks faced by Citi. Independent Risk Management oversees the Risk Identification process through a rangeregular reviews and coordinates identification and monitoring of practices: regular Citigroup Board of Director meetings provideTop Risks. Independent Risk Management also manages strategic external checkpoints where management’s progress against executing the plans is assessed and where decisions to refine therisk by monitoring risk appetite thresholds in conjunction with various strategic directionrisk committees, which are part of the Company are evaluated; Citi’s
executive management assesses progress against executing the defined plans; CEO reviews, which include a risk assessment of the plans, occur across products, regions and functions to focus on progress against executing the plans; products, regions and functions have internal reviews to assess performance at lower levels across the organization; and specific forums exist to focus on key areasgovernance structure that drive strategic risk such as balance sheet management, the introduction of new or modified products and services and country management, among others. In addition to these day-to-day practices, significant strategic actions, such as mergers, acquisitions or capital expenditures, are reviewed and approved by, or notified to, the Citigroup and Citibank Boards of Directors, as appropriate.

Exit of U.K. from EU
As a result of a 2016 U.K. referendum, Citi has reorganized certain U.K. and EU operations and implemented contingency plansin place to address the U.K.’s official exit from the EU, which occurred as of January 31, 2020. In addition, Citi has established a formal program with senior-level sponsorship and governance to deliver a coordinated response to the U.K.’s exit.manage its strategic risks.
Until negotiations between the U.K. and the EU are finalized and any exit agreement is ratified, Citi continues to plan for a “hard” exit scenario. Citi’s strategy focuses on providing continuity of services to its U.K. and EU clients with minimal disruption. Consequently, Citi has migrated certain business activities to alternative legal entities and branches with appropriate regulatory permissions to carry out such activity, and has established required capabilities in the U.K. and EU. Citi’s plans for a U.K. exit from the EU have primarily covered:

the enhancement of Citi’s European bank in Ireland, supported by its substantial European branch network to ensure business continuity for its EU clients;
the conversion of Citi’s banking subsidiary in Germany into Citi’s EU investment firm to support broker-dealer activities with EU clients;
the establishment of a new U.K. consumer bank to focus on servicing consumer business clients in the U.K.; and
the amendments to existing U.K. legal entities or branches, where required, to ensure continuity of services to U.K. and non-EU clients.

Citi has worked closely with clients, regulators and other relevant stakeholders in the execution of its plans to prepare for the U.K.’s exit from the EU. In addition, Citi continues to monitor macroeconomic scenarios and market events and has been undertaking stress testing to assess potential impacts on its businesses. For additional information on Citi’s strategic risks, see “Risk Factors—Strategic Risks” above.

OTHER RISKS

LIBOR Transition Risk
The LIBOR administrator ceased publication of non-USD LIBOR and one week and two-month USD LIBOR on a representative basis on December 31, 2021, with plans to cease publication of all other USD LIBOR tenors on June 30, 2023. Regulators expect banks, including Citi, to have ceased entering into new contracts that reference USD LIBOR as a
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benchmark by December 31, 2021, except for limited circumstances as set out in regulatory guidance.
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 benchmark rates, see “Risk Factors—StrategicOther Risks” above). Accordingly, Citi has continued its efforts to identify and manage its LIBOR transition risks.
For example, Citi continues to closely monitor legislative, regulatory and other developments related to LIBOR transition matters and legislative relief. The International Swaps and Derivatives Association (ISDA) published the Interbank Offered Rate (IBOR) Fallbacks Protocol for existing IBOR derivatives transactions, which became effective in January 2021. The IBOR Fallbacks Protocol provides derivatives market participants with new fallbacks for legacy and new derivatives contracts if both counterparties adhere to the protocol or engage in bilateral amendments (see discussion below regarding Citi’s adherence to the protocol). In April 2021, legislation was adopted in New York State that provides for the use of a statutory replacement for USD LIBOR in certain New York law legacy contracts. Similar federal legislation was passed in the House of Representatives in December 2021 and is pending passage by the Senate, although there is no guarantee that the federal legislative proposal will become law.
In addition, Citi has established a LIBOR governance and implementation program remains focused on identifying and addressing the impact of LIBOR transition impacts toon Citi’s clients, operational capabilities and legal and financial contracts, among others.contracts. The program operates globally across Citi’s businesses and functions and includes active involvement of senior management, oversight by Citi’s Asset and Liability Committee and reporting to the Risk Management Committee of Citigroup’s Board of Directors. As part of the program, Citi has developedcontinued 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 2019,2021, 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.FRB. These working groups continue to promote and advance development of alternative reference rates and seek to identify and address potential challenges from any transition to such rates. Citi’s LIBOR transition action plans and associated roadmaps are intended to be consistent with the timelines recommended by these working groups. This includes the Commodity Futures Trading Commission’s SOFR First Initiative, which is designed to promote derivatives trading in SOFR.Citi also continuescontinued to engage with and monitor developments involving regulators, financial accounting bodies and others on LIBOR transition mattersmatters.
Citi’s LIBOR transition efforts include, among other things, reducing its overall exposure to LIBOR, increasing
Citi’s virtual client communication efforts and relief.
Moreover,client transition facilitation, including outreach regarding new industry-led protocols and solutions, and using alternative reference rates in certain newly issued financial instruments and products. In the past several years, Citi has issued preferred stock and benchmark debt referencing the Secured Overnight Financing Rate (SOFR) and issued customer-related debt referencing SOFR and the Sterling Overnight Interbank Average Rate (SONIA), the recommended replacement rate for Sterling LIBOR. Citi has also originated and arranged loans referencing SOFR and SONIA and executed SOFR and SONIA-based derivatives contracts. Further, Citi has also been investing in its systems and infrastructure, as client activity moves away from LIBOR to alternative reference rates. Since the ARRC’s recommendation of CME Group’s Term SOFR in July 2021, Citi has focused on systems’ readiness to provide Term SOFR loan and derivatives to clients, where permitted.
In 2021, Citi also focused on remediating existing LIBOR contracts for whichpublication ceased on a representative basis on December 31, 2021. Substantially all of these contracts were remediated by December 31, 2021, and Citi continues to actively engage in and track the remediation of any remaining contracts after December 31, 2021. As of December 31, 2021, Citi’s overall USD LIBOR gross notional exposure for contracts maturing after the LIBOR cessation date of June 30, 2023 was approximately $7.1 trillion, which includes approximately $4 trillion of cleared derivatives that are covered by planned Central Counterparty Clearing House (CCP) conversions, and approximately $2.4 trillion of bilateral derivatives that are covered by robust contract fallback language. The remaining exposure of approximately $0.7 trillion includes bilateral derivatives and cash products that will be addressed by 2022 contract remediation plans.
In addition, for LIBOR contracts that have not yet been remediated, Citi continues to review the effect of relevant legislative solutions, which are expected to facilitate the transition to replacement rates.

Climate Risk
Climate change presents immediate and long-term risks to Citi and 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 comprised of both 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, business practices and market preferences to address climate change (e.g., carbon pricing 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 categories of risk, 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 risks to Citi’s facilities and personnel.
Citi currently identifies climate risk as an “emerging risk” within its enterprise risk management framework. Emerging
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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—Other Risks” above.
Citi reviews factors related to climate risk under its longstanding Environmental and Social Risk Management (ESRM) Policy, which includes a focus on climate risk related to financed projects and clients in high-carbon sectors. Cautious of the credit risk of stranded assets, as well as the reputational risks associated with the coal sector due to its high carbon emissions, Citi began a phase-down of its financing of thermal coal mining companies in 2015 and of new coal-fired power plants in 2018. As Citi’s phase-down has continued, Citi’s ESRM Policy was updated to identify its LIBOR transition exposures, including existing financial instruments thatinclude a prohibition on all project-related financing of new coal-fired power plants and new or expanding thermal coal mines as well as clear timetables to reduce financing of companies with high exposure to coal fired power and coal mining who do not contain contract provisionspursue low-carbon transition in the coming years. These sector approaches allow Citi to set a comprehensive and industry-wide approach to clarify its positions, set clear expectations for its clients and help address certain climate risk driven credit risk concerns while reducing reputation risk.
Citi continues to explore and test methodologies for quantifying how climate risks could impact the individual credit profiles of its clients across various sectors. To assist in embedding climate risk assessments in its credit assessment process, Citi is developing sector-specific climate risk assessments. Such climate risk assessments are designed to supplement publicly available client disclosures and data provided from third-party vendors and facilitate conversations with clients on their most material climate risks and management plans for adaptation and mitigation. In the near term, Citi’s assessments will consider sectors that adequately contemplatehave been identified as higher climate risk by Citi’s risk identification process. This will not only help Citi better understand its clients’ businesses and climate-related risks, but will also provide a source of climate data. Citi’s net zero plan is leading to the discontinuancefurther integration of reference ratesclimate risk discussions into client engagement and that would require additional negotiation with counterparties. client selection.
Furthermore, Citi is developing globally consistent principles and approaches for managing climate risk across Citi. Climate risk will be embedded into relevant policies and processes over time.
In addition, Citi has beguncontinues to mitigate its LIBOR transition exposures by, amongparticipate 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 additional information about sustainability and other things, using alternative reference rates in certain newly issued financial instrumentsESG matters at Citi, see “Sustainability and products. For example, since early 2019, Citi has issued both preferred stock and benchmark debt referencing the Secured Overnight Financing Rate (SOFR) and updated the LIBOR determination method in its debt documentation with the ARRC recommended fallback language. Citi has also been conducting LIBOR transition-related training for employees.Other ESG Matters” above.



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Country Risk

Top 25 Country Exposures
The following table presents Citi’s top 25 exposures by
country (excluding the U.S.) as of December 31, 2019. The2021. (Including the U.S., the total exposure as of December 31, 20192021 to the top 25 countries disclosed below, in combination with the U.S., would represent approximately 95%98% of Citi’s exposure to all countries.)
For purposes of the table, loan amounts are reflected in the country where the loan is booked, which is generally based on the domicile of the borrower. For example, a loan to a Chinese subsidiary of a Switzerland-based corporation will generally be categorized as a loan in China. In addition, Citi has developed regional booking centers in certain countries,
most significantly in the United Kingdom (U.K.) and Ireland, in order to more efficiently serve its corporate customers. As an example, with respect to the U.K., only 33% of corporate
loans presented in the table below are to U.K. domiciled
entities (35%(36% for unfunded commitments), with the balance of
the loans predominately to European domiciled counterparties.
Approximately 85%87% of the total U.K. funded loans and 89%88% of
the total U.K. unfunded commitments were investment grade
as of December 31, 2019. 2021.
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.

In billions of dollars
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
4Q21
Total
as of
3Q21
Total
as of
4Q20
Total as a % of Citi as of 4Q21
United Kingdom$42.8 $0.2 $1.2 $45.7 $12.8 $(5.7)$3.6 $(4.7)$95.9 $111.6 $115.2 5.5 %
Mexico14.2 13.3 0.3 7.7 3.4 (0.9)19.6 2.0 59.6 60.0 64.5 3.4 
Hong Kong18.8 15.3 0.2 7.1 0.7 (1.6)7.9 2.0 50.4 52.8 49.0 2.9 
Singapore15.6 14.0 0.1 7.4 1.2 (0.9)6.3 2.0 45.7 46.0 45.8 2.6 
Ireland13.9 — 0.6 28.9 0.4 (0.2)— 0.9 44.5 45.3 43.9 2.5 
South Korea3.8 15.7 0.1 2.1 1.0 (0.9)9.7 0.5 32.0 34.2 35.8 1.8 
India6.8 3.8 0.9 5.3 4.6 (0.7)8.5 0.6 29.8 30.3 31.4 1.7 
Brazil11.0 — 0.1 3.0 5.6 (0.7)5.7 2.6 27.3 24.4 26.2 1.6 
China7.3 3.6 0.8 1.8 2.5 (1.0)8.2 0.2 23.4 20.2 21.8 1.3 
Germany0.3 — — 6.0 6.4 (3.6)5.9 4.4 19.4 14.4 24.4 1.1 
Jersey7.3 — 0.1 10.4 — (0.1)— — 17.7 14.9 13.4 1.0 
Australia5.9 — 0.1 8.0 1.1 (0.7)1.3 0.7 16.4 17.7 21.7 0.9 
Japan2.3 — — 3.4 3.2 (1.8)5.0 3.8 15.9 19.3 21.8 0.9 
Taiwan4.1 8.6 0.1 1.4 0.5 (0.2)0.2 0.6 15.3 17.0 17.3 0.9 
United Arab Emirates7.3 1.5 0.1 3.8 0.4 (0.5)2.2 0.1 14.9 16.6 12.4 0.9 
Canada2.1 0.5 0.1 7.5 1.7 (1.5)3.3 1.0 14.7 16.9 17.8 0.8 
Poland3.2 1.8 — 2.6 0.4 (0.2)4.5 0.8 13.1 11.2 15.0 0.7 
Thailand1.1 2.7 — 2.1 — — 1.8 0.2 7.9 8.0 8.0 0.5 
Malaysia1.4 3.4 0.2 1.0 0.1 (0.1)1.9 (0.1)7.8 8.2 8.3 0.4 
Indonesia2.2 0.6 — 1.2 0.2 (0.1)1.5 (0.1)5.5 5.8 6.0 0.3 
Russia2.2 0.7 — 0.7 0.4 (0.1)1.5 — 5.4 5.5 5.2 0.3 
Luxembourg0.8 — — — 0.2 (0.9)4.0 (0.1)4.0 5.3 5.1 0.2 
South Africa1.4 — 0.1 0.6 0.2 (0.1)1.8 (0.2)3.8 3.8 3.6 0.2 
Czech Republic0.7 — — 0.9 1.6 (0.1)0.4 — 3.5 3.5 4.3 0.2 
Spain0.4 — — 2.9 0.4 (1.3)— 0.3 2.7 3.3 3.4 0.2 
Total as a % of Citi’s total exposure32.8 %
Total as a % of Citi’s non-U.S. total exposure93.4 %

(1)    ICG loans reflect funded corporate loans and private bank loans, net of unearned income. As of December 31, 2021, private bank loans in the table above totaled $31.8 billion, concentrated in the U.K. ($8.8 billion), Hong Kong ($8.6 billion) and Singapore ($7.5 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.
(3)    Unfunded exposure includes unfunded corporate lending commitments, letters of credit and other contingencies.
120


In billions of U.S. dollars
ICG
loans(1)
GCB loans
Other funded(2)
Unfunded(3)
Net MTM on derivatives/repos(4)
Total hedges (on loans and CVA)
Investment securities(5)
Trading account assets(6)
Total
as of
4Q19
Total
as of
3Q19
Total
as of
4Q18
Total as a % of Citi as of 4Q19
United Kingdom$41.8
$
$1.9
$50.0
$12.3
$(5.2)$7.3
$(2.3)$105.8
$116.6
$111.6
6.5%
Mexico17.8
17.6
0.3
8.9
0.8
(0.8)16.0
4.4
65.0
67.3
59.6
4.0
Hong Kong20.5
12.9
0.9
7.2
1.4
(0.7)6.2
0.6
49.0
52.5
48.1
3.0
Singapore14.5
13.3
0.1
5.0
0.7
(0.4)8.2
1.9
43.3
41.3
40.7
2.6
Ireland12.1

0.5
26.4
0.5


0.4
39.9
34.8
33.7
2.4
South Korea3.1
16.5
0.1
2.4
1.0
(0.4)8.9
3.1
34.7
31.2
33.8
2.1
India6.5
4.8
0.9
5.9
1.5
(0.6)10.1
0.9
30.0
29.6
30.2
1.8
Brazil12.7


3.1
5.6
(0.9)4.1
3.7
28.3
25.7
26.0
1.7
Germany0.5

0.1
6.0
3.9
(3.9)9.2
6.0
21.8
18.0
17.4
1.3
Australia4.7
9.8
0.1
6.2
1.6
(0.4)1.5
(2.0)21.5
20.8
23.5
1.3
China7.6
3.3
0.6
2.9
0.8
(0.5)5.0
(1.0)18.7
18.6
18.0
1.1
Taiwan5.9
8.0
0.1
1.9
0.4
(0.1)0.9
0.8
17.9
17.2
17.4
1.1
Japan2.7

0.1
2.5
2.4
(1.7)5.8
5.2
17.0
18.3
17.6
1.0
Canada2.4
0.6
0.1
6.8
1.7
(0.7)3.9
0.4
15.2
15.9
16.0
0.9
Poland4.1
2.0
0.1
2.4
0.2
(0.1)3.8
0.9
13.4
13.6
13.2
0.8
Jersey8.0

0.1
5.1

(0.4)

12.8
13.6
10.4
0.8
United Arab Emirates8.1
1.5
0.1
2.9
0.2
(0.1)0.1

12.8
11.6
9.6
0.8
Malaysia1.9
4.2
0.2
1.0
0.2
(0.1)1.0

8.4
9.1
10.0
0.5
Thailand0.9
2.9

1.8


1.7
0.4
7.7
7.8
7.4
0.5
Indonesia2.4
0.9

1.4
0.1
(0.1)1.1
0.1
5.9
5.9
6.3
0.4
Russia1.9
1.0

0.7
0.2
(0.1)1.1
0.2
5.0
5.0
4.6
0.3
Philippines0.7
1.6
0.1
0.5


1.9
0.1
4.9
4.6
5.3
0.3
Luxembourg



0.7
(0.3)3.7
0.5
4.6
3.1
4.9
0.3
Czech Republic0.8


0.7
2.7


0.1
4.3
3.8
3.0
0.3
Cayman Islands



0.1
(0.6)3.0
1.0
3.5
3.8
2.5
0.2
Total as a % of Citi’s Total Exposure      36.0%
Total as a % of Citi’s non-U.S. Total Exposure      89.7%
(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 amortized 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.

(1)
ICG loans reflect funded corporate loans and private bank loans, net of unearned income. As of December 31, 2019, private bank loans in the table above totaled $30 billion, concentrated in Hong Kong ($9.3 billion), Singapore ($7.6 billion) and the U.K. ($7.2 billion).                    
(2)
Other funded includes other direct exposure such as accounts receivable, loans HFS, other loans in Corporate/Other and investments accounted for under the equity method.                                        

(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 securities available-for-sale, recorded at fair market value, and securities held-to-maturity, recorded at historical cost. Investment securities are reflected in the country that holds, not issues, the investments.    
(6)Trading account assets are shown on a net basis and include issuer risk on cash products and derivative exposure where the underlying reference entity/issuer is located in that country.

Argentina
Citi operates in Argentina through its ICG businesses. As of December 31, 2019,2021, Citi’s net investment in its Argentine operations was approximately $730 million.$1.5 billion. Citi uses the U.S. dollar as the functional currency for its operations in Argentina because the Argentine economy is considered highly inflationary countries under U.S. GAAP.
During 2019, Citi uses Argentina’s official market exchange rate to remeasure its net Argentine peso-denominated assets into the U.S. dollar. As of December 31, 2021, the official Argentine peso depreciated 59%exchange rate against the U.S. dollar and the U.S. rating agencies downgraded Argentina’s sovereign debt rating given renewed concerns of a debt default. In addition, the governmentwas 102.73.
The Central Bank of Argentina re-profiledmaintains certain short-term debt obligations, and also implemented new capital and currency controls during the third quarter of 2019. Prior to the implementation of these new capital controls, Citi had already remitted all available earnings from its Argentine operations that could be remitted during the 2019 calendar year; the new controls maygenerally restrict Citi’s ability to access U.S. dollars in Argentina and remit substantially all of its earnings from its Argentine operations. Citi’s net investment in its Argentine operations is likely to increase as Citi continues to generate net income from its Argentine franchise and the majority of its earnings cannot be remitted.
Due to the currency controls implemented by the Central Bank of Argentina, certain indirect foreign exchange mechanisms have developed that some Argentine entities may use to obtain U.S. dollars, generally at rates that are significantly higher than Argentina’s official exchange rate. Citibank Argentina is precluded from accessing these alternative mechanisms, and these exchange mechanisms cannot be used to remeasure Citi’s net monetary assets into the U.S. dollar under U.S. GAAP. Citi cannot predict future fluctuations in Argentina’s official market exchange rate or to what extent Citi may be able to access U.S. dollars at the official exchange rate in the future.
Citi economically hedges the foreign currency risk in its net Argentine peso-denominated assets to the extent possible and prudent using non-deliverable forward (NDF) derivative instruments that are primarily executed outside of Argentina. As of December 31, 2019,2021, the international NDF market had very limited liquidity, resulting in Citi being unable to economically hedge a significant portionnearly all of its Argentine peso exposure. ToAs a result, and to the extent that Citi is unable todoes not execute additional NDF contracts for this unhedged exposure in the future, Citi would record devaluations on Citi’sits net Argentine peso-denominatedpeso‐denominated assets would be recorded in earnings, without any benefit from a change in the fair value of derivative positions used to economically hedge the exposure.
In addition, Citi continually evaluates its economic exposure to its Argentine counterparties and reserves for changes in credit risk and sovereign risk associated with its Argentine assets. Citi believes it has established appropriate loan loss reservesallowances 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, 2019.2021. However, given the recent events in Argentina, U.S. regulatory agencies may require Citi to record additional reserves in the future, increasing ICG’s cost of credit, based on the perceived country risk associated with its Argentine exposures.


For additional information on Citi’s emerging markets risks, including those related to its Argentine exposures, see “Risk Factors” above.

Russia
Citi operates both its ICG and GCB businesses in Russia, although the Company is currently pursuing the exit of its GCB business in the country. All of Citi’s domestic operations in Russia are conducted through a subsidiary of Citibank, which uses the Russian ruble as its functional currency. Citi’s net investment in Russia was approximately $1 billion as of December 31, 2021. The majority of Citi’s net investment was hedged for foreign currency depreciation as of December 31, 2021, using forward foreign exchange contracts. Citi’s total third-party exposure was approximately $8.2 billion as of December 31, 2021. These assets primarily consisted of corporate and consumer loans, local government debt securities, reverse repurchase agreements, and cash on deposit and placements with the Bank of Russia and other financial institutions. A significant portion of Citi’s third-party exposures were funded with domestic deposit liabilities from both ICG and GCB clients. Further, Citi has approximately $1.6 billion of additional exposures to Russian counterparties that are not held on the Russian subsidiary and are not included in the $8.2 billion above.
The $5.4 billion in Russia credit and other exposures in the “Top 25 Country Exposures” table above does not include approximately $1.0 billion of cash and placements with the Bank of Russia and other financial institutions and $1.8 billion of reverse repurchase agreements with various counterparties.
Citi continues to monitor the current Russia–Ukraine geopolitical situation and economic conditions and will mitigate its exposures and risks as appropriate. For additional information, see “Risk Factors—StrategicMarket-Related Risk,” “—Operational Risks” and “—Other Risks” above.






121



FFIEC—Cross-Border Claims on Third Parties and Local Country Assets
Citi’s cross-border disclosures are set forth below, 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.

122



The tables below show each country whose total outstandings exceeded 0.75% of total Citigroup assets:
December 31, 2021
Cross-border claims on third parties and local country assets
In billions of dollarsBanks (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)
United Kingdom$7.0 $31.1 $55.6 $19.2 $16.5 $70.8 $112.9 $23.0 $76.3 $70.8 
Cayman Islands  78.8 13.2 7.4 56.3 92.0 9.9 0.4 0.3 
Japan31.0 30.1 12.8 8.7 15.6 54.8 82.6 8.4 13.4 12.1 
Germany4.5 48.9 47.7 9.6 18.5 78.3 110.7 23.2 48.6 44.7 
Mexico2.8 28.4 9.3 25.8 2.7 33.4 66.3 19.7 6.7 6.1 
France9.7 9.6 27.0 9.8 14.0 41.6 56.1 85.3 62.6 55.7 
Singapore1.9 18.3 12.1 17.4 2.7 39.1 49.7 16.3 1.4 1.3 
South Korea3.6 17.9 3.2 21.9 2.0 37.7 46.6 12.7 9.0 8.1 
Hong Kong1.3 12.3 3.9 21.8 4.2 30.2 39.3 13.6 1.7 1.5 
Australia3.9 14.2 5.7 12.8 7.3 22.9 36.6 13.6 4.0 3.9 
China4.2 12.9 3.7 14.7 8.0 26.3 35.5 4.4 9.6 9.0 
India1.2 15.0 4.4 13.1 2.6 23.4 33.7 10.2 1.8 1.4 
Taiwan0.5 7.0 1.7 15.8 4.8 21.1 25.0 14.6  0.1 
Netherlands5.9 8.8 3.3 5.7 5.2 16.2 23.7 9.8 30.8 27.6 
Brazil2.0 12.9 2.2 12.5 3.9 20.3 29.6 3.2 6.2 5.6 
Italy2.8 10.9 0.9 1.8 8.1 2.4 16.4 1.6 38.8 37.0 
Switzerland1.4 13.7 0.9 6.0 3.1 20.0 22.0 9.7 18.9 17.6 
Canada6.5 12.2 4.7 4.1 3.8 21.0 27.5 12.9 5.7 5.3 
December 31, 2020
Cross-border claims on third parties and local country assets
In billions of dollarsBanks (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)
United Kingdom(6)
$16.0 $26.0 $50.5 $17.5 $14.2 $73.5 $110.0 $25.8 $76.2 $75.3 
Cayman Islands— — 85.8 12.7 8.0 69.7 98.5 11.9 0.3 0.2 
Japan32.9 35.5 12.1 6.6 16.2 63.3 87.1 6.6 16.1 15.1 
Germany(6)
7.1 51.8 15.9 9.6 11.3 58.6 84.4 14.1 49.7 48.1 
Mexico3.9 31.5 9.5 28.8 6.0 44.4 73.7 21.7 7.3 6.6 
France11.0 9.7 39.3 9.5 13.3 58.7 69.5 68.2 61.3 56.4 
Singapore2.5 25.6 10.7 17.5 2.8 46.5 56.3 13.8 1.9 1.5 
South Korea3.3 18.2 1.8 24.9 1.5 35.6 48.2 14.7 10.8 10.7 
Hong Kong1.5 13.8 3.9 19.8 7.2 33.2 39.0 13.1 2.1 1.7 
Australia5.1 16.4 4.0 13.0 9.6 31.6 38.5 13.0 5.7 5.2 
China4.5 16.3 3.3 14.1 9.7 33.4 38.2 5.8 10.5 10.0 
India1.9 14.0 2.5 12.9 2.3 22.1 31.3 11.3 1.8 1.6 
Taiwan0.4 7.8 2.0 16.5 5.1 23.7 26.7 14.1 — — 
Netherlands7.8 10.4 3.4 4.8 5.2 18.2 26.4 10.4 28.5 27.4 
Brazil2.8 11.3 1.6 9.9 5.2 20.0 25.6 2.7 6.0 6.0 
Italy2.5 19.1 0.6 1.9 15.0 16.1 24.1 2.7 42.3 41.3 
Switzerland1.8 14.3 1.4 4.9 2.6 20.0 22.4 7.3 18.0 17.4 
Canada4.5 6.3 5.9 4.5 3.4 15.1 21.2 14.5 3.9 4.0 
(1)    Non-bank financial institutions.
(2)    Included in total outstanding.
(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, 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.
(6)    Exposures for the United Kingdom and Germany for the December 31, 2020 period have been revised by $(5.4) billion and $4.8 billion, respectively, as compared to those previously reported, with the balance in the U.S. This revision reflects a correction in the domicile for Non-Bank Financial Institutions counterparties.
123
 December 31, 2019
 Cross-border claims on third parties and local country assets
In billions of U.S. dollarsBanks (a)Public (a)
NBFIs(1) (a)
Other (corporate
and households) (a)
Trading
assets(2) (included in (a))
Short-term claims(2) (included in (a))
Total outstanding(3) (sum of (a))
Commitments
 and
guarantees(4)
Credit derivatives purchased(5)
Credit derivatives
sold(5)
Cayman Islands$
$
$96.8
$10.3
$5.3
$75.9
$107.1
$10.0
$
$
United Kingdom13.3
24.4
34.8
20.6
12.9
61.3
93.1
23.2
71.6
71.6
Japan32.7
33.3
7.8
6.5
13.1
57.4
80.3
4.7
18.7
17.1
Mexico2.8
26.3
9.4
35.2
5.5
37.0
73.7
22.4
8.9
8.8
Germany6.8
29.8
7.7
9.7
9.3
33.6
54.0
13.1
48.0
46.4
France8.4
6.8
22.2
7.5
9.6
35.3
44.9
29.0
56.0
54.3
Singapore2.3
17.7
7.2
16.1
2.8
36.1
43.3
12.0
2.0
1.9
South Korea2.0
16.0
1.7
21.7
2.6
31.4
41.4
12.0
13.9
13.0
India1.7
12.9
3.1
16.3
2.7
23.4
34.0
10.8
2.3
2.0
Hong Kong0.6
10.2
3.0
20.0
4.1
27.9
33.8
13.7
2.2
2.0
Australia4.8
8.7
4.7
12.9
7.9
20.6
31.1
11.8
7.4
7.3
China3.4
11.0
3.1
12.7
3.9
25.3
30.2
5.1
12.8
11.6
Brazil3.3
13.3
1.8
11.0
6.1
20.8
29.4
3.2
8.1
8.2
Canada2.9
4.7
11.5
5.0
3.1
13.5
24.1
14.7
4.3
5.1
Netherlands6.8
8.5
3.9
4.6
4.6
15.7
23.8
11.0
26.9
26.5
Taiwan0.6
6.8
1.6
14.3
2.9
13.2
23.3
14.6
0.1
0.1
Italy3.3
15.9
0.7
1.7
12.8
14.9
21.6
2.5
44.5
44.0
Switzerland1.2
14.5
1.1
4.6
2.2
18.1
21.4
8.2
17.8
17.3
Ireland0.2
0.3
8.9
5.4
4.2
12.9
14.8
5.4
1.6
1.8


 December 31, 2018
 
Cross-border claims on third parties and local country assets

In billions of U.S. dollarsBanks (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)
United Kingdom$14.6
$23.5
$35.7
$22.4
$12.3
$67.8
$96.2
$25.1
$74.3
$76.4
Cayman Islands

81.6
9.2
5.4
62.5
90.8
5.0


Japan31.4
28.8
8.4
7.8
13.6
40.7
76.4
4.0
19.9
18.3
Mexico3.1
24.5
7.4
34.7
6.0
29.1
69.7
20.2
7.3
7.6
Germany6.3
45.6
7.2
7.6
6.6
49.8
66.7
10.7
51.3
50.2
France12.4
8.5
30.7
5.6
9.1
49.5
57.2
30.7
59.9
58.5
South Korea1.5
17.8
3.0
22.6
1.8
33.2
44.9
12.1
12.2
12.2
Singapore2.3
22.5
4.4
13.4
1.7
32.3
42.6
11.4
1.9
1.9
India3.3
12.7
3.3
15.3
4.3
22.5
34.6
9.7
2.5
2.0
Hong Kong0.9
11.2
3.2
16.9
3.9
27.5
32.2
14.6
2.2
2.2
China5.0
11.3
3.0
12.3
4.5
20.6
31.6
4.2
15.6
14.6
Australia3.1
7.8
4.8
13.4
7.1
14.4
29.1
12.1
10.6
10.5
Brazil3.8
10.4
1.4
10.9
5.0
16.8
26.5
2.6
8.4
8.1
Taiwan0.7
7.4
3.2
12.6
1.6
18.7
23.9
13.0
0.1
0.1
Netherlands6.8
9.0
3.2
4.7
3.7
14.7
23.7
8.6
28.4
28.3
Canada3.2
4.0
9.9
5.2
2.8
15.5
22.3
13.8
5.3
6.2
Switzerland1.4
13.9
1.1
3.6
1.6
5.1
20.0
6.0
19.7
19.6
Italy3.4
11.0
0.8
1.6
7.9
10.5
16.8
2.5
51.3
51.5

(1)Non-bank financial institutions.
(2)Included in total outstanding.
(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, 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.

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 allA substantial portion of
these assets and liabilities areis reflected at fair value on Citi’s
Consolidated Balance Sheet.Sheet as Trading account assets, Available-for-sale securities and Trading account liabilities.
Citi purchases securities under agreements to resell (reverse repos)repos or resale agreements) and sells securities under agreements
to repurchase (repos), a majoritysubstantial portion of which areis 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 theCiti’s 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 in active markets 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 uponon 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 forThe fair value of these instruments whereis reported on Citi’s Consolidated Balance Sheet with the changes in
fair value are recognized in either the Consolidated Statement of Income or in AOCI.
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.

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Citi’s Allowance for Credit Losses (ACL)
Management providesThe table below shows Citi’s ACL as of the fourth quarter of 2021. For information on the drivers of Citi’s ACL release in the fourth quarter, see below. For additional information on Citi’s accounting policy on accounting for credit losses under ASC Topic 326, Financial Instruments—Credit losses; Current Expected Credit Losses (CECL), see Note 1 to the Consolidated Financial Statements below.

 Allowance for credit losses (ACL)
In millions of dollarsBalance Dec. 31, 2020Build (release)
2021 FX/Other(1)
Balance Dec. 31, 2021
ACLL/EOP loans Dec. 31, 2021(2)
1Q212Q213Q214Q212021
Cards(2)
$16,805 $(1,523)$(1,106)$(906)$(957)$(4,492)$(322)$11,991 7.90 %
All other GCB
2,419 (283)(292)(125)18 (682)(149)1,588 
Global Consumer Banking$19,224 $(1,806)$(1,398)$(1,031)$(939)$(5,174)$(471)$13,579 5.08 %
Institutional Clients Group5,402 (1,312)(949)(65)(207)(2,533)(30)2,839 0.73 
Corporate/Other330 (109)(99)(53)(30)(291)(2)37 
Allowance for credit losses on loans (ACLL)$24,956 $(3,227)$(2,446)$(1,149)$(1,176)$(7,998)$(503)$16,455 2.49 %
Allowance for credit losses on unfunded lending commitments2,655 (626)44 (13)(193)(788)4 1,871 
Other146 (13)11  2 148 
Total allowance for credit losses (ACL)$27,757 $(3,852)$(2,401)$(1,175)$(1,358)$(8,786)$(497)$18,474 

(1)    Includes reclassifications to Other assets related to Citi’s agreements to sell its consumer banking businesses in Australia and the Philippines. See Notes 2 and 15 to the Consolidated Financial Statements.
(2)    As of December 31, 2021, in North America GCB, branded cards ACLL/EOP loans was 7.10% and retail services ACLL/EOP loans was 10.0%.

Citi’s reserves for an estimate of probableexpected credit losses inherent in theon funded loan portfolioloans and in unfunded loanlending commitments, and standby letters of credit and financial guarantees are reflected on the Consolidated Balance Sheet in the Allowance for loancredit losses on loans (ACLL) and in Other liabilities(Allowance for credit losses on unfunded lending commitments (ACLUC)), respectively. In addition, Citi reserves for expected credit losses on other financial assets carried at amortized cost, including held-to-maturity securities, reverse repurchase agreements, securities borrowed, deposits with banks and other financial receivables. These reserves, together with the ACLL and ACLUC, are referred to as the ACL.Changes in the ACL are reflected as Provision for credit losses in the Consolidated Statement of Income for each reporting period.
EstimatesThe ACL is composed of these probablequantitative and qualitative management adjustment components. The quantitative component uses a forward-looking base macroeconomic forecast. The qualitative management adjustment component reflects economic uncertainty using alternative downside macroeconomic scenarios and portfolio characteristics and current economic conditions not captured in the quantitative component, such as adjustments to reflect uncertainty around the estimated impact of the pandemic on credit losses. Both the quantitative and qualitative management adjustment components are further discussed below.


Quantitative Component
Citi estimates expected credit losses for its quantitative component using (i) its comprehensive internal data on loss and default history, (ii) internal credit risk ratings, (iii) external credit bureau and rating agencies information, and (iv) a reasonable and supportable forecast of macroeconomic conditions.
For its consumer and corporate portfolios, Citi’s expected credit losses are based upon (i) Citigroup’s internal systemdetermined primarily by utilizing models that consider the borrowers’ probability of credit-risk ratingsdefault (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 are analogous toinform the risk ratingsforecasts, and cover a wide range of the major credit rating agenciesgeographic, industry, product and (ii) historical default and loss data, including rating agency information regarding default rates from 1983 to 2017 and internal data dating to the early 1970s on severity of losses in the event of default. Adjustments may be made to this data, including (i) statistically calculated estimates to cover the historical fluctuation of the default rates over the credit cycle, the historical variability of loss severity among defaulted loans and the degree to which there are large obligor concentrations in the global portfolio and (ii) adjustments made for specifically known items, such as current environmental factors and credit trends.operating segments.
In addition, representatives from both the risk management and finance staffs who cover business areas with delinquency-managed portfolios containing smaller balance homogeneous loans present their recommended reserve balancesCiti’s models determine expected credit losses based uponon leading credit indicators, including loan delinquencies, and changes in portfolio size, default frequency, risk ratings and loss recovery rates (among other things), as well as other current economic factors and credit trends, including housing prices, unemployment and GDP.gross domestic product (GDP). This methodology is applied separately for each individual product within each geographic region in which these portfolios exist.
This evaluation process is subject to numerous estimates and judgments. The frequency of default, risk ratings, loss recovery rates, the size and diversity of individual large credits and the ability of borrowers with foreign currency obligations to obtain the foreign currency necessary for orderly debt servicing, among other things, are all taken into account during this review. account.
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Changes in these estimates could have a direct impact on Citi’s credit costs and the allowance in any period.

Qualitative Component
The qualitative management adjustment component includes, among other things, management adjustments to reflect economic uncertainty based on the likelihood and severity of downside scenarios and certain portfolio characteristics not captured in the quantitative component, such as concentrations, collateral valuation, model limitations, idiosyncratic events and other factors as required by banking supervisory guidance for the ACL. The qualitative management adjustment component also reflects the uncertainty around the estimated impact of the pandemic on credit loss estimates. The ultimate extent of the pandemic’s impact on Citi’s ACL will depend on, among other things, (i) how consumers respond to the conclusion of government stimulus and assistance programs, (ii) the impact on unemployment, (iii) the timing and extent of the economic recovery, (iv) the severity and duration of any resurgence of COVID-19, (v) the rate of distribution and administration of vaccines and (vi) the extent of any market volatility.

4Q21 Changes in the ACL
In the fourth quarter of 2021, Citi released $1.0 billion of the ACL for its consumer portfolios and $0.4 billion of the ACL for its corporate portfolios, for a total release of $1.4 billion. The releases in the consumer and corporate ACLs were driven primarily by the continued improvement in the macroeconomic outlook, as well as continued improvements in credit quality. The overall qualitative management adjustments declined compared to the previous quarter. Based on its latest macroeconomic forecast, Citi believes its analysis of the ACL reflects the forward view of the economic environment as of December 31, 2021.


Macroeconomic Variables
Citi considers a multitude of macroeconomic variables for both the base and downside macroeconomic forecasts it uses to estimate the ACL, including 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 the ACL.
The tables below show Citi’s forecasted quarterly average U.S. unemployment rate and year-over-year U.S. Real GDP growth rate used in determining Citi’s ACL for each quarterly reporting period from 4Q20 to 4Q21:

Quarterly average
U.S. unemployment4Q212Q224Q22
13-quarter average(1)
Citi forecast at 4Q206.3 6.1 5.7 6.1 
Citi forecast at 1Q214.9 4.1 3.8 4.3 
Citi forecast at 2Q214.6 4.1 3.9 4.1 
Citi forecast at 3Q214.5 4.1 3.9 4.0 
Citi forecast at 4Q214.3 4.0 3.8 3.8 
(1)    Represents the average unemployment rate for the rolling, forward-looking 13 quarters in the forecast horizon.
Year-over-year growth rate(1)
Full year
U.S. Real GDP202120222023
Citi forecast at 4Q203.7 2.7 2.6 
Citi forecast at 1Q216.2 4.1 1.9 
Citi forecast at 2Q216.5 3.7 2.0 
Citi forecast at 3Q215.9 3.9 2.1 
Citi forecast at 4Q215.5 4.0 2.2 
(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 4Q21, U.S. Real GDP growth is expected to remain strong during 2022, and the unemployment rate is 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 ACLL release (including Corporate/Other) of $1.0 billion in the fourth quarter of 2021 reduced the ACLL balance to $13.6 billion, or 5.0% of total consumer loans as of December 31, 2021. The release was primarily driven by the continued improvement in the macroeconomic outlook, as well as continued improvements in credit quality. Citi’s consumer ACLL is largely driven by the cards businesses.
For cards, including Citi’s international businesses, the level of reserves relative to EOP loans decreased to 7.9% as of December 31, 2021, compared to 9.1% at September 30, 2021, primarily driven by by the continued improvement in the macroeconomic outlook, as well as continued improvements
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in credit quality. For the remaining consumer exposures, the level of reserves relative to EOP loans was 1.4% at December 31, 2021, essentially unchanged from September 30, 2021.

Corporate
Citi’s corporate ACLL release of $0.2 billion in the fourth quarter of 2021 reduced the ACLL reserve balance to $2.8 billion, or 0.73% of total funded loans. The release was primarily driven by improvements in portfolio credit quality, as well as improvement in the macroeconomic outlook.
The Allowance for credit losses on unfunded lending commitments (ACLUC) release of $191 million in the fourth quarter of 2021 decreased the total ACLUC reserve balance included in Other liabilities to $1.9 billion at December 31, 2021.

ACLL and Non-accrual Ratios
At December 31, 2021, the ratio of the allowance for credit losses to total funded loans was 2.49% (5.02% for consumer loans and 0.73% for corporate loans) compared to 2.69% at September 30, 2021 (5.55% for consumer loans and 0.77% for corporateloans).
Citi’s total non-accrual loans were $3.4 billion at December 31, 2021, down $610 million from September 30, 2021. Consumer non-accrual loans decreased $87 million to $1.5 billion at December 31, 2021 from $1.6 billion at September 30, 2021, while corporate non-accrual loans decreased $523 million to $1.9 billion at December 31, 2021 from $2.4 billion at September 30, 2021. In addition, the ratio of non-accrual loans to total consumer loans was 0.55% and non-accrual loans to total corporate loans was 0.47%, at December 31, 2021.

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 impact of the build (pretax) in 2020 and 2021 were deferred and being amortized over the same timeframe.
For a further description of the loan loss reserveACL and related accounts, see Notes 1 and 15 to the Consolidated Financial Statements.

For a discussion of the recently adoptedadoption 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 more-likely-than-not reduce the fair value of a reporting unit below its carrying amount, such as a significant adverse change in the business climate, a decision to sell or dispose of all or a significant portion of a reporting unit or a significant decline in Citi’s stock price. During 2019,2021, the annual test was
performed, which resulted in no goodwill impairment as described in Note 16 to the Consolidated Financial Statements.
As of December 31, 2019,2021, Citigroup’s activities arewere conducted through the Global Consumer Banking and Institutional Clients Group business operating 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 businessesreporting units 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 thea reporting unit can be supported by theits fair value of the reporting unit using widely accepted valuation techniques, such as the market approach (earnings multiples and/or transaction multiples) and/or the income approach (discounted cash flow (DCF) method). In applying these methodologies, Citi utilizes a number of factors, including actual operating results, future business plans, economic projections and market data.
Similar to 2018, Citigroup2020, Citi engaged an independent valuation specialist in 20192021 to assist in Citi’s valuation forof all the reporting units, with goodwill balances, employing both the market approach and the DCF method. The resulting fair values were relatively consistent and appropriate weighting was given to outputs from both methods.
The DCF method utilized at the time of each impairment test used discount rates that Citi believes adequately reflected the risk and uncertainty in the financial markets in the internally generated cash flow projections.
The DCF method employs a capital asset pricing model in estimating the discount rate.
Since none of the Company’s reporting units are publicly traded, individual reporting unit fair value determinations cannot be directly correlated to Citigroup’s common stock price. The sum of the fair values of the
reporting units exceeded the overall market capitalization of Citi as of July 1, 2019.2021. 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.international. In addition, the market capitalization of Citigroup does not include consideration of the individual reporting unit’s control premium.
Citi performed its annual goodwill impairment test as of July 1, 2021. The fair values of Citi’s reporting units as a percentage of their carrying values ranged from approximately 125% to 153%, resulting in no impairment. While the inherent risk related to uncertainty is embedded in the key assumptions used in the valuations, the economic and business
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environments continue to evolve as management implements its strategic refresh, which includes, among others, the exits of consumer businesses in 13 markets in Asia and EMEA, as well as the exit of the Mexico consumer, small business and middle-market banking operations. If management’s future estimate of key economic and market assumptions were to differ from its current assumptions, Citi could potentially experience material goodwill impairment charges in the future. Citi expects that the implementation of its new operating segments and reporting units in the first quarter of 2022, as well as the timing and sequencing of the sales of its Asia consumer banking businesses, may result in goodwill impairment. See Notes 1 and 16 to the Consolidated Financial Statements for additional information on goodwill, including the changes in the goodwill balance year-over-year and the reporting units’segments’ goodwill balances as of December 31, 2019.2021.

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 (VA) 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 or automatically adopt the various new provisions of the U.S. Internal Revenue Code.
Citi’s non-U.S. branches and subsidiaries are subject to tax at their local tax rates. While non-U.S.Non-U.S. branches also continue to be subject to U.S. taxation,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 material residual U.S. tax on such earnings since its overall non-U.S.it currently has sufficient branch tax rate is in excess of 21%. carry-forwards.With respect to non-U.S. subsidiaries, dividends from these subsidiaries will beare excluded from U.S. taxation. While the majority of Citi’s non-U.S. subsidiary earnings are classified
as Global Intangible Low Taxed Income (GILTI), Citi similarly

expects no material residual U.S. tax on such earnings based on its non-U.S. subsidiaries’ local tax rates, which exceed, on average, the GILTI tax rate. Finally, Citi does not expect the Base Erosion Anti-Abuse Tax (BEAT) to affect its tax provision.

Deferred Tax Assets and Valuation Allowances
At December 31, 2019,2021, Citi had net DTAs of $23.1$24.8 billion. In the fourth quarter of 2019,2021, Citi’s DTAs increased by $0.6$0.3 billion, driven primarily by the releaseas a result of a portion of the valuation allowance related to Citi’s general basket FTC carry-forwards and losses in AOCIOther comprehensive income. On a full-year basis, Citi’s DTAs increased $0.2 billionat December 31, 2021 were essentially unchanged from $22.9$24.8 billion at December 31, 2018, primarily due to the releases of a portion of the valuation allowance related to Citi’s general basket FTC carry-forwards, partially offset by gains in AOCI.2020.
Of Citi’s total net DTAs of $23.1$24.8 billion as of December 31, 2019, $10.72021, $9.5 billion, primarily related to tax carry-forwards, was excludeddeducted in calculating Citi’s regulatory capital. The amount excluded from Citi’s regulatory capital decreased $0.9 billion in the full year 2019, adjusting for the impact of the valuation allowance releases. Net DTAs arising from temporary differences are deducted from regulatory capital if in excess of the 10%/15% limitations (see “Capital Resources” above). For the quarter and year ended December 31, 2019,2021, Citi did not have any such DTAs. Accordingly, the remaining $12.4$15.3 billion of net DTAs as of December 31, 20192021 was not deducted in calculating regulatory capital pursuant to Basel III standards, and was appropriately risk weighted under those rules.
Citi’s total valuation allowanceVA at December 31, 20192021 was $6.5$4.2 billion, a decrease of $2.8$1.0 billion from $9.3$5.2 billion at December 31, 2018.2020. The decrease was primarily driven by carry-forwardusage of carry-forwards and expirations in the FTC branch basket and in a non-U.S. NOL, FTC general basket valuation allowance releases and a reduction in the net U.S. residual DTA related to non-U.S. branches.basket. Citi’s valuation allowanceVA of $6.5$4.2 billion is composed of $4.6$2.5 billion on its FTC carry-forwards, $0.8$1.0 billion on its U.S. residual DTA related to its non-U.S. branches, $1.0$0.6 billion on local non-U.S. DTAs and $0.1 billion on state net operating loss and capital loss carry-forwards.
Citi’s valuation allowanceIn 2021, Citi reduced its VA for DTAs related to FTCs in its branch basket for 2021 and future periods. As stated above with regard to the impact of $3.5 billion against FTC carry-forwards relating to its non-U.S. branches decreased by $0.9 billion in 2019, primarily dueon 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 expirationbranch basket are the main factors in determining the branch VA. The allocated ODL was enhanced by significant taxable income generated in the current year. In addition, during 2021, the global interest rate environment and balance sheet requirements in non-U.S. branches resulted in a lower relative allocation of interest expense to non-U.S. branches. The combination of the 2009 FTC carry-forward.factors enumerated resulted in a VA release of $0.2 billion. Citi expects that the absolute amountalso released branch basket VA of its valuation allowance may change in$0.1 billion with respect to future years, based upon Citi’s operating plan and estimates of future branch basket factors, as it generates additional FTCs relating to the higher overall local tax rateoutlined above.
Citi’s VA of its non-U.S. branches, reduced by the expiration of FTC carry-forwards.
Citi’s valuation allowance of $1.1$0.8 billion against FTC carry-forwards in its general basket decreasedwas reduced by $0.5$0.2 billion in 2021, primarily dueas a result of audit adjustments made to actions taken to increase foreign source income in the U.S. and the updated forecast of foreign source income for the FTC carry-forward period.prior years’ returns. In the fourth quarter of 2019, Citi committed to a plan to move a financing business involving non-U.S. clients and its associated funding to the U.S. The incremental foreign
source income generated by this action over time will more-likely-than-not enable usage of FTC carry-forwards of $0.2 billion. See Note 9 to the Consolidated Financial Statements. As stated above, with respect to the portion of the valuation allowance established on Citi’s FTC carry-forwards that are available for use in the general basket for FTCs, changes in the forecasted amount of earningsincome 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 eventually needed against such FTCs.Citi continues to look for otheradditional actions that may improve foreign source income in the U.S. tax return and thus affect the valuation allowance. These actions can include the relocation of certain businesses to the U.S., each of which can raise client, regulatory or operational challenges. No other actions were deemedbecome prudent and feasible, as of December 31, 2019.taking into account client, regulatory and operational
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considerations. (See Note 9 to the Consolidated Financial Statements.)
Recognized FTCs comprised approximately $6.3$2.8 billion of Citi’s DTAs as of December 31, 2019,2021, compared to approximately $6.8$4.4 billion as of December 31, 2018.2020. The decrease in FTCs year-over-year was primarily due to current-year usage, partially offset by the valuation allowance release.usage. The FTC carry-forward period represents the most time-sensitive component of Citi’s DTAs.
Citi has an overall domestic loss (ODL)ODL of approximately $39$15 billion at December 31, 2019,2021, 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).ODL.)
Citi believes theThe 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 yearsyears. This provides enough time to fully utilize the net DTAs pertaining to thethese existing net operating loss carry-forwards. This is due to Citi’s forecast of sufficient U.S. taxable income and the continued taxation of Citi’s non-U.S. income by New York State and City.
Although realization is not assured, Citi believes that the realization of its recognized net DTAs of $23.1$24.8 billion at December 31, 20192021 is more-likely-than-not, based upon management’s expectations as toof 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, 20192021 (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.above and Note 9 to the Consolidated Financial Statements.


Potential U.S. Tax Cuts and Jobs ActLegislation
On December 22, 2017,January 4, 2022, final FTC regulations were published in the President signed Tax Reform into law, reflectingFederal Register. These regulations eliminate the creditability of foreign taxes paid in certain situations. These include countries that do not align with U.S. tax principles in significant part and for services performed outside the recipient country. Citi is examining the extent to which these regulations will impact its effective tax rate. Any adoption effect on Citi’s DTAs, including its valuation allowance against FTC carry-forwards, will be reported in the first quarter of 2022. Citi does not expect a significant impact on its 2022 effective tax rate. However, the U.S. president’s proposed legislation discussed below, if enacted, could exacerbate the impact of these regulations.
The president has proposed the Build Back Better Act, which makes substantial changes to U.S. corporatethe 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 chargemultinational corporations. While the Act does not presently contain an increase 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, it would impose a minimum level of U.S. taxation, computed on a jurisdiction by jurisdiction basis. The Organization for Economic Cooperation and the change toDevelopment (OECD) Inclusive Framework (140 countries) similarly proposed a “quasi-territorialminimum 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.that could impact Citi.
Citi completed its accounting for Tax Reform under SAB 118 during the fourth quarter of 2018 and recorded a one-time, non-cash tax benefit of $94 million in Corporate/Other, related to amounts that were considered provisional pursuant to SAB 118.
The table below details the fourth quarter of 2018 changes to Citi’s provisional impact from Tax Reform:



Provisional Impact of Tax Reform
In billions of dollars
Provisional amounts
included in the
2017 Form 10-K
SAB 118 impact to fourth quarter of 2018
tax provision
Quasi-territorial tax system$6.2
$0.2
Valuation allowance7.9
(1.2)
Deemed repatriation2.3
0.9
Total of provisional items$16.4
$(0.1)

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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.results:

In millions of dollars, except per share amounts and as otherwise noted
2018
as reported
(1)
2017
as reported
2017 one-time impact of
Tax Reform
 
2017
adjusted results(2)
2018 increase (decrease)
vs. 2017 ex-Tax Reform
 In millions of dollars, except per share amounts and
as otherwise noted
2018
as reported
(1)
2017
as reported
2017 one-time impact of
Tax Reform
2017
adjusted results(2)
2018 increase (decrease)
vs. 2017 ex-Tax Reform
$ Change% Change $ Change% Change
Net income (loss)$18,045
$(6,798)$(22,594) $15,796
$2,249
14% 
Net incomeNet income$18,045 $(6,798)$(22,594)$15,796 $2,249 14 %
Diluted earnings per share:      Diluted earnings per share:
Income (loss) from continuing operations6.69
(2.94)(8.31) 5.37
1.32
25
 
Net income (loss)6.68
(2.98)(8.31) 5.33
1.35
25
 
Income from continuing operations Income from continuing operations6.69 (2.94)(8.31)5.37 1.32 25 
Net income Net income6.68 (2.98)(8.31)5.33 1.35 25 
Effective tax rate22.8%129.1 %(9,930)bps29.8% (700)bps Effective tax rate22.8 %129.1 %(9,930)bps29.8 %(700)bps
Performance and other metrics:      Performance and other metrics:
Return on average assets0.94%(0.36)%(120)bps0.84% 10
bps Return on average assets0.94 %(0.36)%(120)bps0.84 %10 bps
Return on average common stockholders’
equity
9.4
(3.9)(1,090) 7.0
 240
  Return on average common stockholders’
equity
9.4 (3.9)(1,090)7.0 240 
Return on average total stockholders’ equity9.1
(3.0)(1,000) 7.0
 210
  Return on average total stockholders’ equity9.1 (3.0)(1,000)7.0 210 
Return on average tangible common equity11.0
(4.6)(1,270) 8.1
 290
  Return on average tangible common equity11.0 (4.6)(1,270)8.1 290 
Dividend payout ratio23.1
(32.2)(5,020) 18.0
 510
  Dividend payout ratio23.1 (32.2)(5,020)18.0 510 
Total payout ratio109.1
(213.9)(33,140) 117.5
 840
  Total payout ratio109.1 (213.9)(33,140)117.5 840 

(1)
(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.

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.

Accounting Changes
See Note 1 to the Consolidated Financial Statements for a discussion of changes in accounting standards.
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DISCLOSURE CONTROLS AND PROCEDURES

Citi’s disclosure controls and procedures are designed to ensure that information required to be disclosed under the Securities Exchange Act of 1934, as amended, is recorded, processed, summarized and reported within the time periods specified in the SEC’s rules and forms, including without limitation that information required to be disclosed by Citi in its SEC filings is accumulated and communicated to management, including the Chief Executive Officer (CEO) and Chief Financial Officer (CFO), as appropriate, to allow for timely decisions regarding required disclosure.
Citi’s Disclosure Committee assists the CEO and CFO in their responsibilities to design, establish, maintain and evaluate the effectiveness of Citi’s disclosure controls and procedures. The Disclosure Committee is responsible for, among other things, the oversight, maintenance and implementation of the disclosure controls and procedures, subject to the supervision and oversight of the CEO and CFO.
Citi’s management, with the participation of its CEO and CFO, has evaluated the effectiveness of Citigroup’s disclosure controls and procedures (as defined in Rule 13a-15(e) under the Securities Exchange Act of 1934) as of December 31, 2019.2021. Based on that evaluation, the CEO and CFO have concluded that at that date Citigroup’s disclosure controls and procedures were effective.

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MANAGEMENT’S ANNUAL REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING

Citi’s management is responsible for establishing and maintaining adequate internal control over financial reporting. Citi’s internal control over financial reporting is designed to provide reasonable assurance regarding the reliability of its financial reporting and the preparation of financial statements for external reporting purposes in accordance with U.S. generally accepted accounting principles. Citi’s internal control over financial reporting includes those policies and procedures that (i) pertain to the maintenance of records that in reasonable detail accurately and fairly reflect the transactions and dispositions of Citi’s assets, (ii) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles and that Citi’s receipts and expenditures are made only in accordance with authorizations of Citi’s management and directors and (iii) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of Citi’s assets that could have a material effect on its financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect all misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions or that the degree of compliance with the policies or procedures may deteriorate. In addition, given Citi’s large size, complex operations and global footprint, lapses or deficiencies in internal controls may occur from time to time.
Citi’s management assessed the effectiveness of Citigroup’s internal control over financial reporting as of December 31, 20192021 based on the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control—Integrated Framework (2013). Based on this assessment, management believes that, as of December 31, 2019,2021, 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, 20192021 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, 20192021 has been audited by KPMG LLP, Citi’s independent registered public accounting firm, as stated in their report below, which expressed an unqualified opinion on the effectiveness of Citi’s internal control over financial reporting as of December 31, 2019.2021.

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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 regulationsU.S. Private Securities Litigation Reform Act of the SEC.1995. 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.


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REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
c-20211231_g16.jpg


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 sheetsheets of Citigroup Inc. and subsidiaries (the Company) as of December 31, 20192021 and 2018,2020, the related consolidated statements of income, comprehensive income, changes in stockholders’ equity and cash flows for each of the years in the three-year period ended December 31, 2019,2021, and the related notes (collectively, the consolidated financial statements). We also have audited the Company’s internal control over financial reporting as of December 31, 2019,2021, based on criteria established in Internal Control—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, 20192021 and 2018,2020, and the results of its operations and its cash flows for each of the years in the three-year period ended December 31, 2019,2021, 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, 20192021 based on criteria established in Internal Control—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
134


inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.


Critical Audit Matters
The critical audit matters communicated below are matters arising from the current period audit of the consolidated financial statements that were communicated or required to be communicated to the audit committee and that:that (1) relate to accounts or disclosures that are material to the consolidated financial statements and (2) involved our especially challenging, subjective, or complex judgments. The communication of critical audit matters does not alter in any way our opinion on the consolidated financial statements, taken as a whole, and we are not, by communicating the critical audit matters below, providing separate opinions on the critical audit matters or on the accounts or disclosures to which they relate.

Assessment of the fair value of hard-to-price financial instrumentscertain Level 3 assets and liabilities measured on a recurring basis
As described in Notes 1, 6, 24 and 25 to the consolidated financial statements, the Company’s financial assets and liabilities recorded at fair value on a recurring basis were $1,148.7$856.6 billion and $615.5$313.4 billion, respectively at December 31, 2019. Financial instruments which are measured at fair value using valuation techniques, inclusive of complex internal valuation models or alternative pricing procedures with significant unobservable inputs, represent all Level 3 assets and liabilities ($8.0 billion and $23.0 billion, respectively) and certain Level 2 assets and liabilities (collectively, hard-to-price financial instruments).2021. The Company estimated the fair value of hard-to-price financial instrumentsLevel 3 assets and liabilities measured on a recurring basis ($14.7 billion and $35.2 billion, respectively at December 31, 2021) 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, price-basedalternative pricing procedures or comparables analysis and discounted cash flows.
We identified the assessment of the measurement of fair value for hard-to-price financial instrumentscertain Level 3 assets and liabilities recorded at fair value on a recurring basis as a critical audit matter, asmatter. A high degree of effort, including specialized skills and knowledge, and subjective and complex auditor judgment was involved in the assessment involved complex auditor judgment. In particular, there was a high level of subjectivity in the evaluation of the key assumptions and estimates utilized for prices and/or inputs that are not readily observable inLevel 3 fair values due to measurement uncertainty. Specifically, the current market and complex internally developed valuation techniques and/or models were used. This assessment encompassed the evaluation of the fair value estimate methodologies,methodology, including the Company’s keymethods, models and significant assumptions and inputs such asused to estimate fair value. Significant assumptions and inputs include interest rate, price, yield, credit spread, volatilities, correlations and forward prices. ThisThe assessment also included an evaluation of the underlying models for mathematical accuracyconceptual soundness and assessing ifperformance of the models are appropriate to value the financial instruments.valuation models.
The following are the primary procedures we performed to address this critical audit matter. We tested internal controls over hard-to-price financial instruments, including pricing methodologies and valuation techniques, and key inputs and assumptions to determine the fair value. We tested the Company’s process to develop the fair value estimate. This included performing an assessment of the key policies and methodologies used in the fair value determination. We involved valuation professionals with industryspecialized skills and knowledge and experience
who assisted in challengingevaluating the models’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 prices, inputs and assumptions
independent price verification
evaluating that are not readily observablesignificant model assumptions and which are used in the fair value determination, by testing the reliability of the process used by the Company to determine fair value and evaluating that:

the key assumptions and/or inputs reflected those which a market participant
would use to determine an exit price in the current market environment;environment
the valuation models used were mathematically accurate and appropriate to value the financial instruments; andinstruments
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 industryspecialized skills and knowledge and experience who assisted in developing an independent fair value estimate for a selection of certain financial instrumentsLevel 3 assets and liabilities recorded at fair value on a recurring basis, based on independently developed valuation models and/orand assumptions, as applicable, using market data sources we determined to be relevant and comparingreliable, and compared our independent expectation to the Company’s fair value measurements.

Assessment of the allowance for loancredit losses collectively evaluated for impairment
As discussed in Notes 1 and 15 to the consolidated financial statements, the Company’s allowance for loancredit losses related to loans and unfunded lending commitments collectively evaluated for impairment (ALL)(the collective ACLL) was $11.3$18.3 billion as of December 31, 2019.2021. 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 estimated this ALLuses 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, utilizing a migration analysis, in which historical delinquency andthese models consider leading credit loss experience is applied to the current aging of the portfolio, together with analyses that reflectindicators including loan delinquencies, as well as economic conditions.factors. For corporate loans, these models consider the ALL was determined using a statistical model considering the portfolio’s size, remaining tenor and credit quality as measured by internal risk ratings assigned to individual credit facilities, which reflect probabilityand economic factors. The qualitative component considers idiosyncratic events and the uncertainty of default and loss given default. The statistical model and migration analysis were each supplemented by qualitative assessments.forward-looking economic scenarios.
We identified the assessment of the ALLcollective ACLL as a critical audit matter, as thematter. The assessment involved significant measurement uncertainty requiring complex
135


auditor judgment, and specialized skills and knowledge andas well as experience in the industry. This assessment encompassed the evaluation of the various components of the ALLcollective 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 assessments.components. Key assumptions and inputs for consumer loans included historicalloan delinquencies, certain credit losses, delinquency statusindicators, 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 manner in which they are applied within a migration analysis.model. For corporate loans, key assumptions and inputs included internal risk ratings, probability of defaultreasonable and loss given defaultsupportable forecasts, credit conversion factor for unfunded lending commitments, and economic factors, including GDP and unemployment rates considered in the statistical model. Key assumptions and inputs for the qualitative component for both consumer and corporate loan portfolios 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 (1) the the:

approval of the ALLcollective ACLL methodologies and (2) the
determination of the key

assumptions and inputs used to estimate the quantitative and qualitative assessments. components of the collective ACLL
performance monitoring of the PD, LGD, and EAD models.

We evaluated the Company’s process to develop the ALLcollective 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. We assessed the methodologies used to develop the resulting qualitative assessments and the effect of those assessments on the ALL compared with credit trends. WeIn addition, we involved credit risk professionals with industryspecialized skills and knowledge, and experience who assisted in:

reviewing the Company’s ALLcollective ACLL methodologies and key assumptions for compliance with U.S. generally accepted accounting principles;principles
assessing the conceptual soundness and performance testing of the key assumptionsPD, LGD, and inputs inEAD models by inspecting the consumer loans migration analysismodel documentation to determine whether the models are suitable for their intended use
evaluating judgments made by the Company relative to the development and corporate loans statistical model;performance monitoring testing of the PD, LGD, and EAD models by comparing them to relevant Company-specific metrics
assessing the economic forecast scenarios through comparison to publicly available forecasts
evaluating the qualitative assessments of the ALL.methodologies used to develop certain economic forecast scenarios by comparing them to relevant industry practices

We testedtesting corporate loan internal risk ratings for a selection of credit facilitiesborrowers by (1) involvingevaluating the financial performance of the borrower, sources of repayment, and any relevant guarantees or underlying collateral
evaluating the methodologies used in determining the qualitative components and the effect of those components on the collective ACLL compared with relevant credit risk professionalsfactors and consistency with industry knowledge and risk rating experience to assist in evaluatingcredit trends.

We also assessed the appropriatenesssufficiency of the internal risk ratings and (2) testingaudit evidence obtained related to the historical accuracy of internal risk ratings compared to prior periods.collective ACLL by evaluating the:

Assessmentcumulative results of the realizability of deferred tax assets, specifically as it relates to foreign tax creditsaudit procedures
As discussed in Notes 1 and 9 to the consolidated financial statements, the Company’s net deferred tax assets (DTA) were $23.1 billion as of December 31, 2019. This balance is net of a valuation allowance of $6.5 billion recorded by the Company. The estimation of the DTA for foreign tax credits (FTCs) and related valuation allowance was $10.9 billion and $4.6 billion respectively. The Company evaluated the realization of the DTA for FTCs to determine whether there was more than a 50% likelihood that the DTA for FTCs would be realized, based primarily on the Company’s expectations of future taxable income in each relevant jurisdiction, available tax planning strategies and timing of tax credit expirations.
We identified the assessment of the realizability of the DTA for FTCs as a critical audit matter, as the
assessment involved complex auditor judgment and knowledge of global tax regulations. This assessment encompassed the evaluationqualitative aspects of the Company’s estimations that are complex due to its global structure and subjective, given the Company’s assumptions used to determine that sufficient taxable income will be generated or tax planning strategies implemented to support the realization of the DTA for FTCs before expiration of foreign tax credits.accounting practices
The following are the primary procedures we performed to address this critical audit matter. We tested certain internal controls over the Company’s analysis of the realizability of the DTA for FTCs, including future taxable income and tax planning strategies. We tested the Company’s process to develop the valuation allowance estimate. This included performing an assessment of the key policies and methodologies usedpotential bias in the valuation allowance determination. We involved income tax professionals with FTC knowledge and experience, including resources from our national office, who assisted in assessing:accounting estimates.

the assumptions used to determine the Company’s future taxable income, including the interpretation of the various tax laws and regulations and the source and character of future taxable income;
the timing of tax credit expirations; and
the prudence and feasibility of tax planning strategies.

We performed sensitivity analyses over the Company’s expectations of future taxable income and timing of tax credit expirations.



/s/ KPMG LLP

LLP)
We have served as the Company’s auditor since 1969.

New York, New York
(PCAOB ID # 185)
February 21, 202025, 2022






















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FINANCIAL STATEMENTS AND NOTES TABLE OF CONTENTS

CONSOLIDATED FINANCIAL STATEMENTS
Consolidated Statement of Income—
For the Years Ended December 31, 2019, 20182021, 2020 and 20172019
Consolidated Statement of Comprehensive Income—
For the Years Ended December 31, 2019, 20182021, 2020 and 20172019
Consolidated Balance Sheet—December 31, 20192021 and 20182020
Consolidated Statement of Changes in Stockholders’ Equity—For the Years Ended December 31, 2019, 20182021, 2020 and 20172019
Consolidated Statement of Cash Flows—
For the Years Ended December 31, 2019, 20182021, 2020 and 20172019


NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
Note 1—Summary of Significant Accounting Policies
Note 2—Discontinued Operations, and Significant Disposals and
Other Business Exits
Note 3—BusinessOperating 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


Note 16—Goodwill and Intangible Assets
Note 17—Debt
Note 18—Regulatory Capital
Note 19—Changes in Accumulated Other Comprehensive
Income (Loss) (AOCI)
Note 20—Preferred Stock
Note 21—Securitizations and Variable Interest Entities
Note 22—Derivatives
Note 23—Concentrations of Credit Risk
Note 24—Fair Value Measurement
Note 25—Fair Value Elections
Note 26—Pledged Assets, Collateral, Guarantees and

Commitments
Note 27—Contingencies
Note 28—Condensed Consolidating Financial Statements
Note 29—Selected Quarterly Financial Data (Unaudited)

137


CONSOLIDATED FINANCIAL STATEMENTS
CONSOLIDATED STATEMENT OF INCOME      Citigroup Inc. and Subsidiaries

Years ended December 31,
In millions of dollars, except per share amounts202120202019
Revenues   
Interest revenue$50,475 $58,089 $76,510 
Interest expense7,981 13,338 28,382 
Net interest income$42,494 $44,751 $48,128 
Commissions and fees$13,672 $11,385 $11,746 
Principal transactions10,154 13,885 8,892 
Administration and other fiduciary fees3,943 3,472 3,411 
Realized gains on sales of investments, net665 1,756 1,474 
Impairment losses on investments:
Impairment losses on investments and other assets(206)(165)(32)
Provision for credit losses on AFS debt securities(1)
(3)(3)— 
Net impairment losses recognized in earnings$(209)$(168)$(32)
Other revenue$1,165 $420 $1,448 
Total non-interest revenues$29,390 $30,750 $26,939 
Total revenues, net of interest expense$71,884 $75,501 $75,067 
Provisions for credit losses and for benefits and claims   
Provision for credit losses on loans$(3,103)$15,922 $8,218 
Provision for credit losses on held-to-maturity (HTM) debt securities(3)— 
Provision for credit losses on other assets — 
Policyholder benefits and claims116 113 73 
Provision for credit losses on unfunded lending commitments(788)1,446 92 
Total provisions for credit losses and for benefits and claims(2)
$(3,778)$17,495 $8,383 
Operating expenses   
Compensation and benefits$25,134 $22,214 $21,433 
Premises and equipment2,314 2,333 2,328 
Technology/communication7,828 7,383 7,077 
Advertising and marketing1,490 1,217 1,516 
Other operating11,427 11,227 10,429 
Total operating expenses$48,193 $44,374 $42,783 
Income from continuing operations before income taxes$27,469 $13,632 $23,901 
Provision for income taxes5,451 2,525 4,430 
Income from continuing operations$22,018 $11,107 $19,471 
Discontinued operations   
Income (loss) from discontinued operations$7 $(20)$(31)
Benefit for income taxes — (27)
Income (loss) from discontinued operations, net of taxes$7 $(20)$(4)
Net income before attribution of noncontrolling interests$22,025 $11,087 $19,467 
Noncontrolling interests73 40 66 
Citigroup’s net income$21,952 $11,047 $19,401 
Basic earnings per share(3)
   
Income from continuing operations$10.21 $4.75 $8.08 
Loss from discontinued operations, net of taxes (0.01)— 
Net income$10.21 $4.74 $8.08 
Weighted average common shares outstanding (in millions)
2,033.0 2,085.8 2,249.2 
Diluted earnings per share(3)
   
Income from continuing operations$10.14 $4.73 $8.04 
Loss from discontinued operations, net of taxes (0.01)— 
Net income$10.14 $4.72 $8.04 
Adjusted weighted average common shares outstanding
(in millions)
2,049.4 2,099.0 2,265.3 

138

CONSOLIDATED STATEMENT OF INCOME          Citigroup Inc. and Subsidiaries
 Years ended December 31,
In millions of dollars, except per share amounts201920182017
Revenues 
 
 
Interest revenue$76,510
$70,828
$61,579
Interest expense29,163
24,266
16,518
Net interest revenue$47,347
$46,562
$45,061
Commissions and fees$11,746
$11,857
$12,707
Principal transactions8,892
8,905
8,940
Administration and other fiduciary fees3,411
3,580
3,584
Realized gains on sales of investments, net1,474
421
778
Net impairment losses recognized in earnings$(32)$(132)$(63)
Other revenue$1,448
$1,661
$1,437
Total non-interest revenues$26,939
$26,292
$27,383
Total revenues, net of interest expense$74,286
$72,854
$72,444
Provisions for credit losses and for benefits and claims 
 
 
Provision for loan losses$8,218
$7,354
$7,503
Policyholder benefits and claims73
101
109
Provision (release) for unfunded lending commitments92
113
(161)
Total provisions for credit losses and for benefits and claims$8,383
$7,568
$7,451
Operating expenses 
 
 
Compensation and benefits$21,433
$21,154
$21,181
Premises and equipment2,328
2,324
2,453
Technology/communication7,077
7,193
6,909
Advertising and marketing1,516
1,545
1,608
Other operating9,648
9,625
10,081
Total operating expenses$42,002
$41,841
$42,232
Income from continuing operations before income taxes$23,901
$23,445
$22,761
Provision for income taxes4,430
5,357
29,388
Income (loss) from continuing operations$19,471
$18,088
$(6,627)
Discontinued operations 
 
 
Loss from discontinued operations$(31)$(26)$(104)
Provision (benefit) for income taxes(27)(18)7
Loss from discontinued operations, net of taxes$(4)$(8)$(111)
Net income (loss) before attribution of noncontrolling interests$19,467
$18,080
$(6,738)
Noncontrolling interests66
35
60
Citigroup’s net income (loss)$19,401
$18,045
$(6,798)
Basic earnings per share(1)
 
 
 
Income (loss) from continuing operations
$8.08
$6.69
$(2.94)
Loss from discontinued operations, net of taxes

(0.04)
Net income (loss)$8.08
$6.69
$(2.98)
Weighted average common shares outstanding (in millions)
2,249.2
2,493.3
2,698.5





CONSOLIDATED STATEMENT OF INCOME (Continued) 
Citigroup Inc. and Subsidiaries

 
 Years ended December 31,
In millions of dollars, except per share amounts201920182017
Diluted earnings per share(1)
 
 
 
Income (loss) from continuing operations
$8.04
$6.69
$(2.94)
Income (loss) from discontinued operations, net of taxes

(0.04)
Net income (loss)$8.04
$6.68
$(2.98)
Adjusted weighted average common shares outstanding
  (in millions)
2,265.3
2,494.8
2,698.5

(1)Due to rounding, earnings per share on continuing operations and discontinued operations may not sum to earnings per share on net income.
The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.


CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOMECitigroup Inc. and Subsidiaries
 Years ended December 31,
In millions of dollars201920182017
Citigroup’s net income (loss)$19,401
$18,045
$(6,798)
Add: Citigroup’s other comprehensive income (loss)   
Net change in unrealized gains and losses on debt securities, net of taxes(1)(2)
$1,985
$(1,089)$(863)
Net change in debt valuation adjustment (DVA), net of taxes(1)
(1,136)1,113
(569)
Net change in cash flow hedges, net of taxes851
(30)(138)
Benefit plans liability adjustment, net of taxes(3)
(552)(74)(1,019)
Net change in foreign currency translation adjustment, net of taxes and hedges(321)(2,362)(202)
Net change in excluded component of fair value hedges, net of taxes

25
(57)
Citigroup’s total other comprehensive income (loss)(4)
$852
$(2,499)$(2,791)
Citigroup’s total comprehensive income (loss)

$20,253
$15,546
$(9,589)
Add: Other comprehensive income (loss) attributable to noncontrolling interests$
$(43)$114
Add: Net income attributable to noncontrolling interests66
35
60
Total comprehensive income (loss)$20,319
$15,538
$(9,415)

(1)    See Note 1This presentation is in accordance with ASC 326, which requires the provision for credit losses on AFS securities to be included in revenue.
(2)    This total excludes the Consolidated Financial Statements.provision for credit losses on AFS securities, which is disclosed separately above.
(2)For the years ended December 31, 2019 and 2018, amounts represent the net change in unrealized gains and losses on available-for-sale (AFS) debt securities. Effective January 1, 2018, the AFS category was eliminated for equity securities under ASU 2016-01.
(3)    See Note 8Due to the Consolidated Financial Statements.
(4)Includes the impact of ASU 2018-02, adopted in 2017. See Note 1 to the Consolidated Financial Statements.

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 BALANCE SHEETSTATEMENT OF COMPREHENSIVE INCOMECitigroup Inc. and Subsidiaries
Years ended December 31,
In millions of dollars202120202019
Citigroup’s net income$21,952 $11,047 $19,401 
Add: Citigroup’s other comprehensive income (loss)
Net change in unrealized gains and losses on debt securities, net of taxes(1)
$(3,934)$3,585 $1,985 
Net change in debt valuation adjustment (DVA), net of taxes(1)
232 (475)(1,136)
Net change in cash flow hedges, net of taxes(1,492)1,470 851 
Benefit plans liability adjustment, net of taxes(2)
1,012 (55)(552)
Net change in foreign currency translation adjustment, net of taxes and hedges(2,525)(250)(321)
Net change in excluded component of fair value hedges, net of taxes (15)25 
Citigroup’s total other comprehensive income (loss)$(6,707)$4,260 $852 
Citigroup’s total comprehensive income$15,245 $15,307 $20,253 
Add: Other comprehensive income (loss) attributable to noncontrolling interests$(99)$26 $— 
Add: Net income attributable to noncontrolling interests73 40 66 
Total comprehensive income$15,219 $15,373 $20,319 

(1)     See Note 1 to the Consolidated Financial Statements.
(2)    See Note 8 to the Consolidated Financial Statements.

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

139
 December 31,
In millions of dollars20192018
Assets 
 
Cash and due from banks (including segregated cash and other deposits)$23,967
$23,645
Deposits with banks169,952
164,460
Securities borrowed and purchased under agreements to resell (including $153,193 and $147,701 as of December 31, 2019 and 2018, respectively, at fair value)251,322
270,684
Brokerage receivables39,857
35,450
Trading account assets (including $120,236 and $112,932 pledged to creditors at December 31, 2019 and 2018, respectively)276,140
256,117
Investments:  
  Available-for-sale debt securities (including $8,721 and $9,284 pledged to creditors as of December 31, 2019 and 2018, respectively)280,265
288,038
Held-to-maturity debt securities (including $1,923 and $971 pledged to creditors as of December 31, 2019 and 2018, respectively)80,775
63,357
Equity securities (including $1,162 and $1,109 as of December 31, 2019 and 2018, respectively, at fair value)7,523
7,212
Total investments$368,563
$358,607
Loans: 
 
Consumer (including $18 and $20 as of December 31, 2019 and 2018, respectively, at fair value)309,548
302,360
Corporate (including $4,067 and $3,203 as of December 31, 2019 and 2018, respectively, at fair value)389,935
381,836
Loans, net of unearned income$699,483
$684,196
Allowance for loan losses(12,783)(12,315)
Total loans, net$686,700
$671,881
Goodwill22,126
22,046
Intangible assets (including MSRs of $495 and $584 as of December 31, 2019 and 2018,
  respectively, at fair value)
4,822
5,220
Other assets (including $12,830 and $20,788 as of December 31, 2019 and 2018, respectively,
  at fair value)
107,709
109,273
Total assets$1,951,158
$1,917,383


CONSOLIDATED BALANCE SHEETCitigroup Inc. and Subsidiaries
December 31,
In millions of dollars20212020
Assets  
Cash and due from banks (including segregated cash and other deposits)$27,515 $26,349 
Deposits with banks, net of allowance234,518 283,266 
Securities borrowed and purchased under agreements to resell (including $216,466 and $185,204 as of December 31, 2021 and 2020, respectively, at fair value), net of allowance327,288 294,712 
Brokerage receivables, net of allowance54,340 44,806 
Trading account assets (including $133,828 and $168,967 pledged to creditors at December 31, 2021 and 2020, respectively)331,945 375,079 
Investments:
Available-for-sale debt securities (including $9,226 and $5,921 pledged to creditors as of December 31, 2021 and 2020, respectively), net of allowance288,522 335,084 
Held-to-maturity debt securities (including $1,460 and $547 pledged to creditors as of December 31, 2021 and 2020, respectively), net of allowance216,963 104,943 
Equity securities (including $1,032 and $1,066 as of December 31, 2021 and 2020, respectively, at fair value)7,337 7,332 
Total investments$512,822 $447,359 
Loans:  
Consumer (including $12 and $14 as of December 31, 2021 and 2020, respectively, at fair value)271,236 288,839 
Corporate (including 6,070 and 6,840 as of December 31, 2021 and 2020, respectively, at fair value)396,531 387,044 
Loans, net of unearned income$667,767 $675,883 
Allowance for credit losses on loans (ACLL)(16,455)(24,956)
Total loans, net$651,312 $650,927 
Goodwill21,299 22,162 
Intangible assets (including MSRs of $404 and $336 as of December 31, 2021 and 2020,
  respectively, at fair value)
4,495 4,747 
Other assets (including $12,342 and $14,6130 as of December 31, 2021 and 2020, respectively,
  at fair value), net of allowance
125,879 110,683 
Total assets$2,291,413 $2,260,090 

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.

December 31,
In millions of dollars20212020
Assets of consolidated VIEs to be used to settle obligations of consolidated VIEs  
Cash and due from banks$260 $281 
Trading account assets10,038 8,104 
Investments844 837 
Loans, net of unearned income 
Consumer34,677 37,561 
Corporate14,312 17,027 
Loans, net of unearned income$48,989 $54,588 
Allowance for credit losses on loans (ACLL)(2,668)(3,794)
Total loans, net$46,321 $50,794 
Other assets1,174 43 
Total assets of consolidated VIEs to be used to settle obligations of consolidated VIEs$58,637 $60,059 
 December 31,
In millions of dollars20192018
Assets of consolidated VIEs to be used to settle obligations of consolidated VIEs 
 
Cash and due from banks$108
$270
Trading account assets6,719
917
Investments1,295
1,796
Loans, net of unearned income 
 
Consumer46,977
49,403
Corporate16,175
19,259
Loans, net of unearned income$63,152
$68,662
Allowance for loan losses(1,841)(1,852)
Total loans, net$61,311
$66,810
Other assets73
151
Total assets of consolidated VIEs to be used to settle obligations of consolidated VIEs$69,506
$69,944

Statement continues on the next page.

140


CONSOLIDATED BALANCE SHEET                             Citigroup Inc. and Subsidiaries
(Continued)
December 31,
In millions of dollars, except shares and per share amounts20212020
Liabilities  
Non-interest-bearing deposits in U.S. offices$158,552 $126,942 
Interest-bearing deposits in U.S. offices (including $879 and $879 as of December 31, 2021 and 2020, respectively, at fair value)543,283 503,213 
Non-interest-bearing deposits in offices outside the U.S.97,270 100,543 
Interest-bearing deposits in offices outside the U.S. (including $787 and $1,079 as of December 31, 2021 and 2020, respectively, at fair value)518,125 549,973 
Total deposits$1,317,230 $1,280,671 
Securities loaned and sold under agreements to repurchase (including $56,694 and $60,206 as of December 31, 2021 and 2020, respectively, at fair value)191,285 199,525 
Brokerage payables (including $3,575 and $6,835 as of December 31, 2021 and 2020, respectively,
  at fair value), including allowance
61,430 50,484 
Trading account liabilities161,529 168,027 
Short-term borrowings (including $7,358 and $4,683 as of December 31, 2021 and 2020, respectively,
  at fair value)
27,973 29,514 
Long-term debt (including $82,609 and $67,063 as of December 31, 2021 and 2020, respectively,
  at fair value)
254,374 271,686 
Other liabilities74,920 59,983 
Total liabilities$2,088,741 $2,059,890 
Stockholders’ equity  
Preferred stock ($1.00 par value; authorized shares: 30 million), issued shares: 759,800 as of December 31, 2021 and 779,200 as of December 31, 2020, at aggregate liquidation value
$18,995 $19,480 
Common stock ($0.01 par value; authorized shares: 6 billion), issued shares: 3,099,651,835 as of December 31, 2021 and 3,099,633,160 as of December 31, 2020
31 31 
Additional paid-in capital108,003 107,846 
Retained earnings184,948 168,272 
Treasury stock, at cost: 1,115,296,641 shares as of December 31, 2021 and 1,017,543,951 shares as of
    December 31, 2020
(71,240)(64,129)
Accumulated other comprehensive income (loss) (AOCI)
(38,765)(32,058)
Total Citigroup stockholders’ equity$201,972 $199,442 
Noncontrolling interests700 758 
Total equity$202,672 $200,200 
Total liabilities and equity$2,291,413 $2,260,090 
 December 31,
In millions of dollars, except shares and per share amounts20192018
Liabilities 
 
Non-interest-bearing deposits in U.S. offices$98,811
$105,836
Interest-bearing deposits in U.S. offices (including $1,624 and $717 as of December 31, 2019 and 2018, respectively, at fair value)401,418
361,573
Non-interest-bearing deposits in offices outside the U.S.85,692
80,648
Interest-bearing deposits in offices outside the U.S. (including $695 and $758 as of December 31, 2019 and 2018, respectively, at fair value)484,669
465,113
Total deposits$1,070,590
$1,013,170
Securities loaned and sold under agreements to repurchase (including $40,651 and $44,510 as of December 31, 2019 and 2018, respectively, at fair value)166,339
177,768
Brokerage payables48,601
64,571
Trading account liabilities119,894
144,305
Short-term borrowings (including $4,946 and $4,483 as of December 31, 2019 and 2018, respectively,
  at fair value)
45,049
32,346
Long-term debt (including $55,783 and $38,229 as of December 31, 2019 and 2018, respectively,
  at fair value)
248,760
231,999
Other liabilities (including $6,343 and $15,906 as of December 31, 2019 and 2018, respectively,
  at fair value)
57,979
56,150
Total liabilities$1,757,212
$1,720,309
Stockholders’ equity 
 
Preferred stock ($1.00 par value; authorized shares: 30 million), issued shares: 719,200 as of December 31, 2019 and 738,400 as of December 31, 2018, at aggregate liquidation value
$17,980
$18,460
Common stock ($0.01 par value; authorized shares: 6 billion), issued shares: 3,099,602,856 as of December 31, 2019 and 3,099,567,177 as of December 31, 2018
31
31
Additional paid-in capital107,840
107,922
Retained earnings165,369
151,347
Treasury stock, at cost: 985,479,501 shares as of December 31, 2019 and 731,099,833 shares as of
    December 31, 2018
(61,660)(44,370)
Accumulated other comprehensive income (loss) (AOCI)(36,318)(37,170)
Total Citigroup stockholders’ equity$193,242
$196,220
Noncontrolling interest704
854
Total equity$193,946
$197,074
Total liabilities and equity$1,951,158
$1,917,383

The following table presents certain liabilities of consolidated VIEs, which are included on the Consolidated Balance Sheet above. The liabilities in the table below include third-party liabilities of consolidated VIEs only and exclude intercompany balances that eliminate in consolidation. The liabilities also exclude amounts where creditors or beneficial interest holders have recourse to the general credit of Citigroup.

December 31,
In millions of dollars20212020
Liabilities of consolidated VIEs for which creditors or beneficial interest holders
do not have recourse to the general credit of Citigroup
  
Short-term borrowings$8,376 $9,278 
Long-term debt12,579 20,405 
Other liabilities694 463 
Total liabilities of consolidated VIEs for which creditors or beneficial interest holders
do not have recourse to the general credit of Citigroup
$21,649 $30,146 
 December 31,
In millions of dollars20192018
Liabilities of consolidated VIEs for which creditors or beneficial interest holders do not have recourse to the general credit of Citigroup 
 
Short-term borrowings$10,031
$13,134
Long-term debt25,582
28,514
Other liabilities917
697
Total liabilities of consolidated VIEs for which creditors or beneficial interest holders do not have recourse to the general credit of Citigroup$36,530
$42,345

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.
141


CONSOLIDATED STATEMENT OF CHANGES IN STOCKHOLDERS’ EQUITYCitigroup Inc. and Subsidiaries
Years ended December 31,Years ended December 31,
AmountsSharesAmountsShares
In millions of dollars, except shares in thousands201920182017201920182017In millions of dollars, except shares in thousands202120202019202120202019
Preferred stock at aggregate liquidation value 
 
 
 
 
 
Preferred stock at aggregate liquidation value   
Balance, beginning of year$18,460
$19,253
$19,253
738
770
770
Balance, beginning of year$19,480 $17,980 $18,460 779 719 738 
Issuance of new preferred stock1,500


60


Issuance of new preferred stock3,300 3,000 1,500 132 120 60 
Redemption of preferred stock(1,980)(793)
(79)(32)
Redemption of preferred stock(3,785)(1,500)(1,980)(151)(60)(79)
Balance, end of period$17,980
$18,460
$19,253
719
738
770
Common stock and additional paid-in capital  
 
 
 
 
Balance, end of yearBalance, end of year$18,995 $19,480 $17,980 760 779 719 
Common stock and additional paid-in capital (APIC)Common stock and additional paid-in capital (APIC)   
Balance, beginning of year$107,953
$108,039
$108,073
3,099,567
3,099,523
3,099,482
Balance, beginning of year$107,877 $107,871 $107,953 3,099,633 3,099,603 3,099,567 
Employee benefit plans(112)(94)(27)36
44
41
Employee benefit plans85 (112)19 30 36 
Preferred stock issuance expense(4)




Preferred stock issuance costs (new issuances, net of reclassifications to retained earnings for redemptions)Preferred stock issuance costs (new issuances, net of reclassifications to retained earnings for redemptions)25 (4)(4) — — 
Other34
8
(7)


Other47 34  — — 
Balance, end of period$107,871
$107,953
$108,039
3,099,603
3,099,567
3,099,523
Balance, end of yearBalance, end of year$108,034 $107,877 $107,871 3,099,652 3,099,633 3,099,603 
Retained earnings  
 
 
 
 
Retained earnings   
Balance, beginning of year$151,347
$138,425
$146,477
 Balance, beginning of year$168,272 $165,369 $151,347 
Adjustment to opening balance, net of taxes(1)
151
(84)(660) 
Adjusted balance, beginning of period$151,498
$138,341
$145,817
 
 
 
Citigroup’s net income (loss)19,401
18,045
(6,798) 
 
 
Adjustments to opening balance, net of taxes(1)
Adjustments to opening balance, net of taxes(1)
Financial instruments—credit losses (CECL adoption)Financial instruments—credit losses (CECL adoption) (3,076)— 
Variable post-charge-off third-party collection costsVariable post-charge-off third-party collection costs 330 — 
Lease accounting, intra-entity transfers of assetsLease accounting, intra-entity transfers of assets — 151 
Adjusted balance, beginning of yearAdjusted balance, beginning of year$168,272 $162,623 $151,498   
Citigroup’s net incomeCitigroup’s net income21,952 11,047 19,401   
Common dividends(2)
(4,403)(3,865)(2,595) 
 
 
Common dividends(2)
(4,196)(4,299)(4,403)  
Preferred dividends(1,109)(1,174)(1,213) 
 
 
Preferred dividends(1,040)(1,095)(1,109)  
Impact of Tax Reform related to AOCI reclassification(3)


3,304
 
 
 
Other(4)
(18)
(90) 
Balance, end of period$165,369
$151,347
$138,425
 
 
 
Other (primarily reclassifications from APIC for preferred
issuance costs on redemptions)
Other (primarily reclassifications from APIC for preferred
issuance costs on redemptions)
(40)(4)(18)
Balance, end of yearBalance, end of year$184,948 $168,272 $165,369   
Treasury stock, at cost  
 
 
 
 
Treasury stock, at cost   
Balance, beginning of year$(44,370)$(30,309)$(16,302)(731,100)(529,615)(327,090)Balance, beginning of year$(64,129)$(61,660)$(44,370)(1,017,544)(985,480)(731,100)
Employee benefit plans(5)
585
484
531
9,872
10,557
11,651
Treasury stock acquired(6)
(17,875)(14,545)(14,538)(264,252)(212,042)(214,176)
Balance, end of period$(61,660)$(44,370)$(30,309)(985,480)(731,100)(529,615)
Employee benefit plans(3)
Employee benefit plans(3)
489 456 585 7,745 8,676 9,872 
Treasury stock acquired(4)
Treasury stock acquired(4)
(7,600)(2,925)(17,875)(105,498)(40,740)(264,252)
Balance, end of yearBalance, end of year$(71,240)$(64,129)$(61,660)(1,115,297)(1,017,544)(985,480)
Citigroup’s accumulated other comprehensive income (loss)  
 
 
 
 
Citigroup’s accumulated other comprehensive income (loss)   
Balance, beginning of year$(37,170)$(34,668)$(32,381) 
 
 
Balance, beginning of year$(32,058)$(36,318)$(37,170)  
Adjustment to opening balance, net of taxes(1)

(3)504
 
Adjusted balance, beginning of period$(37,170)$(34,671)$(31,877) 
Citigroup’s total other comprehensive income (loss)(3)
852
(2,499)(2,791) 
 
 
Balance, end of period$(36,318)$(37,170)$(34,668) 
 
 
Citigroup’s total other comprehensive income (loss)Citigroup’s total other comprehensive income (loss)(6,707)4,260 852   
Balance, end of yearBalance, end of year$(38,765)$(32,058)$(36,318)  
Total Citigroup common stockholders’ equity$175,262
$177,760
$181,487
2,114,123
2,368,467
2,569,908
Total Citigroup common stockholders’ equity$182,977 $179,962 $175,262 1,984,355 2,082,089 2,114,123 
Total Citigroup stockholders’ equity$193,242
$196,220
$200,740
  
Total Citigroup stockholders’ equity$201,972 $199,442 $193,242  
Noncontrolling interests  
 
 
 
 
Noncontrolling interests   
Balance, beginning of year$854
$932
$1,023
 
 
 
Balance, beginning of year$758 $704 $854   
Transactions between noncontrolling-interest shareholders and the related consolidated subsidiary

(28) 
Transactions between noncontrolling-interest shareholders
and the related consolidated subsidiary
 — — 
Transactions between Citigroup and the noncontrolling-interest shareholders(169)(50)(121) 
 
 
Transactions between Citigroup and the noncontrolling-interest shareholders(10)(4)(169)  
Net income attributable to noncontrolling-interest shareholders66
35
60
 
 
 
Net income attributable to noncontrolling-interest shareholders73 40 66   
Distributions paid to noncontrolling-interest shareholders(40)(38)(44) 
 
 
Distributions paid to noncontrolling-interest shareholders(10)(2)(40)  
Other comprehensive income (loss) attributable to
noncontrolling-interest shareholders

(43)114
 
 
 
Other comprehensive income (loss) attributable to
noncontrolling-interest shareholders
(99)26 —   
Other(7)18
(72) 
 
 
Other(12)(6)(7)  
Net change in noncontrolling interests$(150)$(78)$(91) 
 
 
Net change in noncontrolling interests$(58)$54 $(150)  
Balance, end of period$704
$854
$932
 
 
 
Balance, end of yearBalance, end of year$700 $758 $704   
Total equity$193,946
$197,074
$201,672
 Total equity$202,672 $200,200 $193,946 
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 2021 and 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.
(1)See Note 1 to the Consolidated Financial Statements for additional details.
(2)Common dividends declared were $0.45 per share in the first and second quarters of 2019 and $0.51 per share in the third and fourth quarters of 2019; $0.32 per share in the first and second quarters of 2018 and $0.45 per share in the third and fourth quarters of 2018; and $0.16 in the first and second quarters of 2017 and $0.32 per share in the third and fourth quarters of 2017.
(3)
Includes the impact of ASU 2018-02, which transferred those amounts from
(3)    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.
(4)    Primarily consists of open market purchases under Citi’s Board of Directors-approved common stock repurchase programs.

AOCI to 2017 Retained earnings. See Notes 1 and 19 to the Consolidated Financial Statements.
(4)
2017 includes the impact of ASU No. 2016-09, Compensation—Stock Compensation (Topic 718): Improvements to Employee Share-Based Payment Accounting. See Note 1 to the Consolidated Financial Statements.
(5)Includes treasury stock related to (i) certain activity on employee stock option program exercises where the employee delivers existing shares to cover the option exercise, or (ii) under Citi’s employee restricted or deferred stock programs where shares are withheld to satisfy tax requirements.
(6)Primarily consists of open market purchases under Citi’s Board of Directors-approved common stock repurchase program.

The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.
143



CONSOLIDATED STATEMENT OF CASH FLOWSCitigroup Inc. and Subsidiaries
Years ended December 31,
In millions of dollars202120202019
Cash flows from operating activities of continuing operations   
Net income before attribution of noncontrolling interests$22,025 $11,087 $19,467 
Net income attributable to noncontrolling interests73 40 66 
Citigroup’s net income$21,952 $11,047 $19,401 
Income (loss) from discontinued operations, net of taxes7 (20)(4)
Income from continuing operations—excluding noncontrolling interests$21,945 $11,067 $19,405 
Adjustments to reconcile net income to net cash provided by (used in) operating activities
of continuing operations
   
Net loss on significant disposals(1)
700 — — 
Depreciation and amortization3,964 3,937 3,905 
Deferred income taxes1,413 (2,333)(610)
Provision for credit losses on loans and unfunded lending commitments(3,891)17,368 8,310 
Realized gains from sales of investments(665)(1,756)(1,474)
Impairment losses on investments and other assets206 165 32 
Change in trading account assets43,059 (98,997)(20,124)
Change in trading account liabilities(6,498)48,133 (24,411)
Change in brokerage receivables net of brokerage payables1,412 (3,066)(20,377)
Change in loans HFS(3,809)1,202 (909)
Change in other assets(2,139)(1,012)4,724 
Change in other liabilities6,839 558 1,737 
Other, net(1,287)4,113 16,955 
Total adjustments$39,304 $(31,688)$(32,242)
Net cash provided by (used in) operating activities of continuing operations$61,249 $(20,621)$(12,837)
Cash flows from investing activities of continuing operations   
Change in securities borrowed and purchased under agreements to resell$(32,576)$(43,390)$19,362 
Change in loans(1,173)14,249 (22,466)
Proceeds from sales and securitizations of loans2,918 1,495 2,878 
Purchases of investments(359,158)(334,900)(274,491)
Proceeds from sales of investments126,728 146,285 137,173 
Proceeds from maturities of investments142,100 124,229 119,051 
Capital expenditures on premises and equipment and capitalized software(4,119)(3,446)(5,336)
Proceeds from sales of premises and equipment, subsidiaries and affiliates
and repossessed assets
190 50 259 
Other, net185 116 196 
Net cash used in investing activities of continuing operations$(124,905)$(95,312)$(23,374)
Cash flows from financing activities of continuing operations   
Dividends paid$(5,198)$(5,352)$(5,447)
Issuance of preferred stock3,300 2,995 1,496 
Redemption of preferred stock(3,785)(1,500)(1,980)
Treasury stock acquired(7,601)(2,925)(17,571)
Stock tendered for payment of withholding taxes(337)(411)(364)
Change in securities loaned and sold under agreements to repurchase(8,240)33,186 (11,429)
Issuance of long-term debt70,658 76,458 59,134 
Payments and redemptions of long-term debt(74,950)(63,402)(51,029)
Change in deposits44,966 210,081 57,420 
Change in short-term borrowings(1,541)(15,535)12,703 
144


 Years ended December 31,
In millions of dollars201920182017
Cash flows from operating activities of continuing operations 
 
 
Net income before attribution of noncontrolling interests$19,467
$18,080
$(6,738)
Net income attributable to noncontrolling interests66
35
60
Citigroup’s net income$19,401
$18,045
$(6,798)
Loss from discontinued operations, net of taxes(4)(8)(111)
Income (loss) from continuing operations—excluding noncontrolling interests$19,405
$18,053
$(6,687)
Adjustments to reconcile net income to net cash provided by (used in) operating activities of continuing operations 
 
 
Net gains on significant disposals(1)

(247)(602)
Depreciation and amortization3,905
3,754
3,659
Deferred income taxes(2)
(610)(51)24,877
Provision for loan losses8,218
7,354
7,503
Realized gains from sales of investments(1,474)(421)(778)
Net impairment losses on investments32
132
91
Change in trading account assets(20,124)(3,469)(7,038)
Change in trading account liabilities(24,411)19,135
(15,375)
Change in brokerage receivables net of brokerage payables(20,377)6,163
(5,307)
Change in loans HFS(909)770
247
Change in other assets4,724
(5,791)(3,364)
Change in other liabilities1,829
(871)(3,044)
Other, net16,955
(7,559)(2,956)
Total adjustments$(32,242)$18,899
$(2,087)
Net cash provided by (used in) operating activities of continuing operations$(12,837)$36,952
$(8,774)
Cash flows from investing activities of continuing operations 
 
 
   Change in securities borrowed and purchased under agreements to resell$19,362
$(38,206)$4,335
   Change in loans(22,466)(29,002)(58,062)
   Proceeds from sales and securitizations of loans2,878
4,549
8,365
   Purchases of investments(274,491)(152,487)(185,740)
   Proceeds from sales of investments137,173
61,491
107,368
   Proceeds from maturities of investments119,051
83,604
84,369
   Proceeds from significant disposals(1)

314
3,411
   Capital expenditures on premises and equipment and capitalized software(5,336)(3,774)(3,361)
   Proceeds from sales of premises and equipment, subsidiaries and affiliates
      and repossessed assets
259
212
377
   Other, net196
181
187
Net cash used in investing activities of continuing operations$(23,374)$(73,118)$(38,751)
Cash flows from financing activities of continuing operations 
 
 
   Dividends paid$(5,447)$(5,020)$(3,797)
   Issuance of preferred stock1,496


   Redemption of preferred stock(1,980)(793)
   Treasury stock acquired(17,571)(14,433)(14,541)
   Stock tendered for payment of withholding taxes(364)(482)(405)
   Change in securities loaned and sold under agreements to repurchase(11,429)21,491
14,456
   Issuance of long-term debt59,134
60,655
67,960
   Payments and redemptions of long-term debt(51,029)(58,132)(40,986)
   Change in deposits57,420
53,348
30,416
   Change in short-term borrowings12,703
(12,106)13,751
CONSOLIDATED STATEMENT OF CASH FLOWS
(Continued)


Citigroup Inc. and Subsidiaries


 Years ended December 31,
In millions of dollars202120202019
Net cash provided by financing activities of continuing operations$17,272 $233,595 $42,933 
Effect of exchange rate changes on cash and due from banks$(1,198)$(1,966)$(908)
Change in cash, due from banks and deposits with banks(47,582)115,696 5,814 
Cash, due from banks and deposits with banks at beginning of year309,615 193,919 188,105 
Cash, due from banks and deposits with banks at end of year$262,033 $309,615 $193,919 
Cash and due from banks (including segregated cash and other deposits)$27,515 $26,349 $23,967 
Deposits with banks, net of allowance234,518 283,266 169,952 
Cash, due from banks and deposits with banks at end of year$262,033 $309,615 $193,919 
Supplemental disclosure of cash flow information for continuing operations   
Cash paid during the year for income taxes$4,028 $4,797 $4,888 
Cash paid during the year for interest7,143 12,094 27,901 
Non-cash investing activities(1)(2)
Decrease in net loans associated with significant disposals reclassified to HFS$9,945 $— $— 
Transfers to loans HFS (Other assets) from loans
7,414 2,614 5,500 
Non-cash financing activities(1)
Decrease in long-term debt associated with significant disposals reclassified to HFS$479 $— $— 
Decrease in deposits associated with significant disposals reclassified to HFS8,407 — — 


(1)    See Note 2 to the Consolidated Financial Statements for further information on significant disposals.
CONSOLIDATED STATEMENT OF CASH FLOWS
(Continued)

Citigroup Inc. and Subsidiaries

 
 Years ended December 31,
In millions of dollars201920182017
Net cash provided by financing activities of continuing operations$42,933
$44,528
$66,854
Effect of exchange rate changes on cash and cash equivalents$(908)$(773)$693
Change in cash, due from banks and deposits with banks$5,814
$7,589
$20,022
Cash, due from banks and deposits with banks at beginning of period(3)
188,105
180,516
160,494
Cash, due from banks and deposits with banks at end of period(3)
$193,919
$188,105
$180,516
Cash and due from banks$23,967
$23,645
$23,775
Deposits with banks169,952
164,460
156,741
Cash, due from banks and deposits with banks at end of period$193,919
$188,105
$180,516
Supplemental disclosure of cash flow information for continuing operations 
 
 
Cash paid during the year for income taxes$4,888
$4,313
$2,083
Cash paid during the year for interest28,682
22,963
15,675
Non-cash investing activities(4)
 
 
 
Transfers to loans HFS (Other assets) from loans
$5,500
$4,200
$5,900
(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.

(1)See Note 2 to the Consolidated Financial Statements for further information on significant disposals.
(2)Includes the full impact of the $22.6 billion non-cash charge related to the Tax Cuts and Jobs Act (Tax Reform) in 2017. See Notes 1 and 9 to the Consolidated Financial Statements for further information.
(3)
Includes the impact of ASU 2016-18, Restricted Cash. See Notes 1 and 26 to the Consolidated Financial Statements.
(4)Operating and finance lease right-of-use assets and lease liabilities represent non-cash investing and financing activities, respectively, and are not included in the non-cash investing activities presented here. See Note 26 to the Consolidated Financial Statements for more information and balances as of December 31, 2019.
The Notes to the Consolidated Financial Statements are an integral part of these Consolidated Financial Statements.

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 and updates have been made to the prior periods’ financial statements and Notesnotes to conform to the current period’s presentation.

Principles of Consolidation
The Consolidated Financial Statements include the accounts of Citigroup and its subsidiaries prepared in accordance with U.S. generally accepted accounting principles (GAAP). The Company consolidates subsidiaries in which it holds, directly or indirectly, more than 50% of the voting rights or where it exercises control. Entities wherein which 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 indirect wholly owned subsidiary of Citigroup. Citibank’s principal offerings include consumer finance, mortgage lending and retailinvestment banking, (including commercial banking) products and services; investment banking, cash management, trade finance and trade finance; ande-commerce; private banking products and services; consumer finance, credit cards, and mortgage lending; and retail banking products and services.

Variable Interest Entities (VIEs)
An entity is a variable interest entity (VIE) if it meets either of the criteria outlined in Accounting Standards Codification (ASC) Topic 810, Consolidation, which are (i) the entity has equity that is insufficient to permit the entity to finance its activities without additional subordinated financial support from other parties, or (ii) the entity has equity investors that cannot make significant decisions about the entity’s operations or that do not absorb their proportionate share of the entity’s expected losses or expected returns.
The Company consolidates a VIE when it has both the power to direct the activities that most significantly impact the VIE’s economic performance and a right to receive benefits or the obligation to absorb losses of the entity that could be potentially significant to the VIE (that is, Citi is the primary beneficiary). In addition to variable interests held in
consolidated VIEs, the Company has variable interests in other
VIEs that are not consolidated because the Company is not the primary beneficiary.
All unconsolidated VIEs are monitored by the Company to assess whether any events have occurred to cause its primary beneficiary status to change.
All entities not deemed to be VIEs with which the Company has involvement are evaluated for consolidation under other subtopics of ASC 810. See Note 21 to the Consolidated Financial Statements for more detailed information.

Foreign Currency Translation
Assets and liabilities of Citi’s foreign operations are translated from their respective functional currencies into U.S. dollars using period-end spot foreign exchange rates. The effects of those translation adjustments are reported in Accumulated other comprehensive income (loss), a component of stockholders’ equity, net of any related hedge and tax effects, until realized upon sale or substantial liquidation of the foreign operation,entity, 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. dollarnon-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” (HTM) 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.
Interest revenue.
Debt securities classified as “available-for-sale” (AFS) 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.

146


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 less impairment (if any), 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 HTMheld-to-maturity (HTM) or AFS,available-for-sale (AFS), the accrual of interest income is suspended for investments that are in default or for which it is likely that future interest payments will not be made as scheduled.
Debt securities not measured at fair value through earnings such asinclude securities held in HTM or AFS, and equity securities accounted for under the measurement alternative,Measurement Alternative or equity method and Federal Reserve Bank, Federal Home Loan Bank stock and certain exchange seats. These securities are subject to evaluation for impairment as described in Note 1315 to the Consolidated Financial Statements.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 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., except when included in a hedge relationship. 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 theand debt host contract and accounted for at fair value. The debt host contract isare 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 paidreceived or receivedpaid for all securities lendingborrowing and borrowinglending transactions are recorded in Interest expenserevenue or Interest revenueexpense at the contractually specified rate.
Where the conditions of ASC 210-20-45-1, Balance
Sheet—Offsetting: Right of Setoff Conditions, are met, securities borrowing and lending transactions are presented net on the Consolidated Balance Sheet.
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
147


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 classified as non-accrual within 60 days of notification that the borrower has filed for bankruptcy, other thanwith the exception of 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 1 to 6) 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 1 to 3) 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 3 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 arecharged off no later than 180 days contractually past due if a decision has been made not to foreclose on the loans.
Real estate-secured loans arecharged 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.
148


Real estate-secured loans in bankruptcy, other than FHA-insured loans, are written down to the estimated value of the property, less costs to sell, within 60 days of notification that the borrower has filed for bankruptcy or in accordance with Citi’s charge-off policy, whichever is earlier.
Commercial banking loans are written down to the extent that principal is judged to be uncollectable.

Corporate Loans
Corporate loans represent loans and leases managed by Institutional Clients Group (ICG). Corporate loans are identified as impaired and placed on a cash (non-accrual) basis when it is determined, based on actual experience and a forward-looking assessment of the collectability of the loan in full, that the payment of interest or principal is doubtful or when interest or principal is 90 days past due, except when the loan is well collateralized and in the process of collection. Any interest accrued on impaired corporate loans and leases is reversed at 90 days past due and charged against current earnings, and interest is thereafter included in earnings only to the extent actually received in cash. When there is doubt regarding the ultimate collectability of principal, all cash receipts are thereafter applied to reduce the recorded investment in the loan.
Impaired corporate loans and leases are written down to the extent that principal is deemed to be uncollectable.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.

AllowanceAllowances for LoanCredit Losses (ACL)
AllowanceCommencing 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 represents management’s best estimateprior 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 probable losses inherentthe reported financial asset balances. If the asset’s life extends beyond the R&S forecast period, then historical experience is considered over the remaining life of the assets in the portfolio, including probableACL. The resulting ACL is adjusted in each subsequent reporting period through Provisions for credit losses related to large individually evaluated impaired loans and troubled debt restructurings. Attribution of the allowance is made for analytical purposes only, and the entire allowance is available to absorb probable loan losses inherent in the overall portfolio. AdditionsConsolidated 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 allowance are made through the Provision for loan losses. Loan losses areACL as a valuation account that is deducted from the allowance and subsequent recoveriesamortized 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 added. Assets received in exchange for loan claims in a restructuring are initially recordedthe 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 4Q21 forecasts are for U.S. unemployment to continue to improve as the U.S. continues to move past the peak of the pandemic-related health and economic crisis.
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 change in the ACL during 2021 were the ACL releases resulting from the recovery from the pandemic.
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
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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, home equity lines of credit (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 corporate loans 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., credit cards, etc.).
The reserves for TDRs are calculated using the discounted cash flow method and considers 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 gain orof the pools, it is evaluated for credit losses individually.

Quantitative and Qualitative Components of the ACL
The loss reflected aslikelihood 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 recovery or charge-offsingle 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 provision.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.
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Consumer Loans
For consumer loans, each portfoliomost portfolios including North America cards, mortgages and personal installment loans (PILs) are covered by the PD, LGD and EAD loss forecasting models. Some smaller international portfolios are covered by econometric models where the gross credit loss (GCL) rate is forecasted. The modeling of non-modified smaller-balance homogeneousall 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 is independently evaluated for impairment by product type (e.g., residential mortgage, credit card, etc.) in accordance with ASC 450, Contingencies. The allowance for loan losses attributedinto 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 these loans is established viathe contractual terms that are the result of a process that estimates the probable losses inherentre-underwriting are not included in the specific portfolio. This process includes migration analysis, inloan’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 historical delinquencyare subject to a non-accrual and credit loss experiencetimely write-off policy. As such, only the principal balance is appliedsubject to the current agingCECL 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 portfolio, together with analyses that reflect current and anticipated economic conditions, including changes in housing prices and unemployment trends. Citi’s allowance for loan losses under ASC 450 only considers contractual principal amounts due, except for credit card loans, where estimated loss amounts related to accrued interest receivable are also included.ASC.
Management also considers overall portfolio indicators, including historical credit losses; delinquent, non-performing and classified loans; trends in volumes and terms of loans; an evaluation of overall credit quality; the credit process, including lending policies and procedures; and economic, geographical, product and other environmental factors.
Separate valuation allowances are determined for impaired smaller-balance homogeneous loans whose terms have been modified in a troubled debt restructuring (TDR).TDR. Long-term modification programs, and short-term (less than 12 months) modifications that provide concessions (such as interest rate reductions) to borrowers in financial difficulty, are reported as TDRs. In addition, loan modifications that involve a trial period are reported as TDRs at the start of the trial period. The allowance for loan lossesACL for TDRs is determined in accordance with ASC 310-10-35, Receivables—Subsequent Measurement, considering all available evidence, including,using a discounted cash flow (DCF) approach. When a DCF approach is used, the initial allowance for ECLs is calculated as appropriate, the present value of the expected futurecontractual 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 credit 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, 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 effective rate,life of the secondary marketfinancial 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, was largely due to more precise contractual maturities that resulted 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.


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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 less disposal costs. Theseis 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.

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 cash flows incorporate modification program default rate assumptions. The original contractual effective rateTDRs are included in the life of the asset. A discounting technique or collateral-dependent practical expedient is used for credit cardnon-accrual and TDR loan exposures that do not share risk characteristics with other loans is the pre-modification rate, which may include interest rate increases under the original contractual agreementand are individually assessed. Loans modified in accordance with the borrower.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.
Corporate Loans
InCECL requires the corporate portfolios, the Allowance for loanestimation of credit losses includes an asset-specific component and a statistically based component. The asset-specific component is calculated under ASC 310-10-35 for larger-balance, non-homogeneous loans that are considered impaired. An asset-specific allowance is established when the discounted cash flows, collateral value (less disposal costs) or observable market price of the impaired loan are lower than its carrying value. This allowance considers the borrower’s overall financial condition, resources and payment record, the prospects for support from any financially responsible guarantors (discussed further below) and, if appropriate, the realizable value of any collateral. The asset-specific component of the allowance for smaller-balance impaired loans is calculated to be performed on a pool basis considering historical loss experience.
The allowanceunless 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 remainderdate 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 loan portfolioinitial 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 determined under ASC 450 usingrecognized as a statistical methodology, supplemented by management judgment. The statistical analysis considers“gross-up” of the portfolio’s size, remaining tenorpurchase price to arrive at the PCD asset’s (or pool’s) amortized cost. Any difference between the unpaid principal balance and credit qualitythe 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 acquisition of PCD assets and other assets and liabilities in a business combination are expensed as measured by internal risk ratings assigned to individual credit facilities, which reflect probability of default and loss given default. The statistical analysis considers historical default rates and historical loss severityincurred. Subsequent accounting for acquired PCD assets is the same as the accounting for originated assets; changes in the event of default, including historical average levels and historical variability. The result is an estimated rangeallowance are recorded in Provisions for inherent losses. The best estimate within the range is then determined by management’s quantitative and qualitative assessment of current conditions, including general economic conditions, specific industry and geographic trends and internal factors including portfolio concentrations, trends in internal credit quality indicators and current and past underwriting standards.losses.
For both the asset-specific and the statistically based components of the
Allowance for loan losses, management may incorporate guarantor support. The financial wherewithal of the guarantor is evaluated, as applicable, based on net worth, cash flow statements and personal or company financial statements, which are updated and reviewed at least annually. Citi seeks performance on guarantee arrangements in the normal course of business. Seeking performance entails obtaining satisfactory cooperation from the guarantor or borrower in the specific situation. This regular cooperation is indicative of pursuit and successful enforcement of the guarantee; the exposure is reduced without the expense and burden of pursuing a legal remedy. A guarantor’s reputation and willingness to work with Citigroup are evaluated based on the historical experience with the guarantor and knowledge of the marketplace. In the rare event that the guarantor is unwilling or unable to perform or facilitate borrower cooperation, Citi pursues a legal remedy; however, enforcing a guarantee via legal action against the guarantor is not the primary means of resolving a troubled loan situation and rarely occurs. If
Consumer
Citi does not pursuepurchase whole portfolios of PCD assets in its retail businesses. However, there may be a legal remedy,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 because Citi does not believe thatmore than 30 days past due at the guarantor has the financial wherewithal to perform regardless of legal action or because there are legal limitations on simultaneously pursuing guarantors and
foreclosure. A guarantor’s reputation does not impact Citi’s decision or ability to seek performance under the guarantee.purchase date.
In cases where a guarantee
Corporate
Citi generally classifies wholesale loans and debt securities classified as 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 factor insignificant difference (i.e., 10% or greater) between contractual cash flows, adjusted for prepayments, and expected cash flows at the assessmentdate of loan losses, it is included via adjustment to the loan’s internal risk rating, which in turn is the basis for the adjustment to the statistically based component of the Allowance for loan losses. To date, it is only in rare circumstances that an impaired commercial loan or commercial real estate loan is carried at a value in excess of the appraised value due to a guarantee.recognition.
When Citi’s monitoring of the loan indicates that the guarantor’s wherewithal to pay is uncertain or has deteriorated, there is either no change in the risk rating, because the guarantor’s credit support was never initially factored in, or the risk rating is adjusted to reflect that uncertainty or deterioration. Accordingly, a guarantor’s ultimate failure to perform or a lack of legal enforcement of the guarantee does not materially impact the allowance for loan losses, as there is typically no further significant adjustment of the loan’s risk rating at that time. Where Citi is not seeking performance under the guarantee contract, it provides for loan losses as if the loans were non-performing and not guaranteed.

Reserve Estimates and Policies
Management provides reserves for an estimate of probable losses inherentlifetime ECLs in the funded loan portfolio on the Consolidated Balance Sheet in the form of an allowance for loan losses.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 representatives from the risk management and finance staffsrepresentatives for each applicable business area. Applicable business areas include those having classifiably managed portfolios, where internal credit-riskcredit 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 probable losses for non-performing, non-homogeneous exposures within a business line’s classifiably managed portfolio and impaired smaller-balance homogeneous loans whose terms have been modified due to the borrowers’ financial difficulties, where it was determined that a concession was granted to the borrower.
Consideration may be given to the following, as appropriate, when determining this estimate: (i) the present value of expected future cash flows discounted at the loan’s original effective rate, (ii) the borrower’s overall financial condition, resources and payment record and (iii) the prospects for support from financially responsible guarantors or the realizable value of any collateral. In the determination of the allowance for loan losses for TDRs, management considers a combination of historical re-default rates, the current

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economic environment and the nature of the modification program when forecasting expected cash flows. When impairment is measured based on the present value of expected future cash flows, the entire change in present value is recorded in Provision for loan losses.

Statistically calculated losses inherentEstimated Credit Losses in the classifiably managed portfolioDelinquency-Managed Portfolios for performing and de minimis non-performing exposures. The calculation is based on (i) Citi’s internal system of credit-risk ratings, which are analogous to the risk ratings of the major rating agencies, and (ii) historical default and loss data, including rating agency information regarding default rates from 1983 to 2017 and internal data dating to the early 1970s on severity of losses in the event of default. Adjustments may be made to this data. Such adjustments include (i) statistically calculated estimates to cover the historical fluctuation of the default rates over the credit cycle, the historical variability of loss severity among defaulted loans and the degree to which there are large obligor concentrations in the global portfolio and (ii) adjustments made for specific known items, such as current environmental factors and credit trends.Performing Exposures
In addition, representatives from each of the risk management and finance staffsrepresentatives who cover business areas with delinquency-managed portfolios containing smaller-balance homogeneous loans present their recommended reserve balances based on leading credit indicators, including loan delinquencies and changes in portfolio size as well as economic trends, including current and future housing prices, unemployment, length of time in foreclosure, costs to sell and GDP. This methodology is applied separately for each individual product within each geographic region in which these portfolios exist.
This evaluation process is subject to numerous estimates and judgments. The frequency of default, risk ratings, loss recovery rates, the size and diversity of individual large credits and the ability of borrowers with foreign currency obligations to obtain the foreign currency necessary for orderly debt servicing, among other things, are all taken into account during this review. Changes in these estimates could have a direct impact on the credit costs in any period and could result in a change in the allowance.

Allowance for Unfunded Lending Commitments
A similar approachCredit 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 allowance for loan losses is used for calculating a reserve for the expected losses related toreporting date. Off-balance sheet commitments include unfunded lendingexposures, revolving facilities, securities underwriting commitments, and standby letters of credit.credit, HELOCs and financial guarantees (excluding 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 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 first step of the two-step goodwill impairmentquantitative test.
The Company has an unconditional option to bypass the qualitative assessment for any reporting unit in any reporting period and proceed directly to the first step of the goodwill impairmentquantitative test.
The first stepquantitative 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, thisan impairment loss is an indication of potential impairment and the second step of testing is performed to measure the amount of impairment, if any, for that reporting unit.
If required, the second step involves calculating the implied fair value of goodwill for each of the affected reporting units. The implied fair value of goodwill is determined in the same manner as the amount of goodwill recognized in a business combination, which is thean amount equal to that excess, of the fair value of the reporting unit determined in step one over the fair value of the net assets and identifiable intangibles as if the reporting unit were being acquired. If the amount of the goodwill allocatedlimited to the reporting unit exceeds the implied fair value of the goodwill in the pro forma purchase price allocation, an impairment charge is recorded for the excess. A recognized impairment charge cannot exceed thetotal amount of goodwill allocated to athat reporting unit and cannot subsequently be reversed even if the fair value of the reporting unit recovers.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 MSRsMSRs—are amortized over their estimated useful lives. Intangible assets that are deemed to have indefinite useful lives, primarily trade names, are not amortized and are subject to annual impairment tests. An impairment exists if the carrying value of the indefinite-lived intangible asset exceeds its fair value. For other intangible assets subject to amortization, an impairment is recognized if the carrying amount is not recoverable and exceeds the fair value of the intangible asset.

Other Assets and Other Liabilities
Other assets include, among other items, loans HFS, deferred tax assets, equity method investments, interest and fees receivable, lease right-of-use assets, premises and equipment (including purchased and developed software), repossessed assets and other receivables. Other liabilities include, among other items, accrued expenses and other payables, lease liabilities, deferred tax liabilities and reserves for legal claims, taxes, unfunded lending commitments, repositioning reserves and other matters.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.


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Securitizations
There are two key accounting determinations that must be made relating to securitizations. Citi first makes a determination as to whether the securitization entity must be consolidated. Second, it determines whether the transfer of financial assets to the entity is considered a sale under GAAP. If the securitization entity is a VIE, the Company consolidates the VIE if it is the primary beneficiary (as discussed in “Variable Interest Entities” above). For all other securitization entities determined not to be VIEs in which Citigroup participates, consolidation is based on which party has voting control of the entity, giving consideration to removal and liquidation rights in certain partnership structures. Only securitization entities controlled by Citigroup are consolidated.
Interests in the securitized and sold assets may be retained in the form of subordinated or senior interest-only strips, subordinated tranches, spread accounts and servicing rights. In credit card securitizations, the Company retains a
seller’s interest in the credit card receivables transferred to the trusts, which is not in securitized form. In the case of consolidated securitization entities, including the credit card trusts, these retained interests are not reported on Citi’s Consolidated Balance Sheet. The securitized loans remain on
the balance sheet. Substantially all of the consumer loans sold or securitized through non-consolidated trusts by Citigroup are U.S. prime residential mortgage loans. Retained interests in non-consolidated mortgage securitization trusts are classified as Trading account assets, except for MSRs, which are included in Intangible assets on Citigroup’s Consolidated Balance Sheet.

Debt
Short-term borrowings and Long-term debt are accounted for at amortized cost, except where the Company has elected to report the debt instruments, including certain structured notes, at fair value, or the debt is in a fair value hedging relationship.

Transfers of Financial Assets
For a transfer of financial assets to be considered a sale: (i) the assets must be legally isolated from the Company, even in bankruptcy or other receivership, (ii) the purchaser must have the right to pledge or sell the assets transferred (or, if the purchaser is an entity whose sole purpose is to engage in securitization and asset-backed financing activities through the issuance of beneficial interests and that entity is constrained from pledging the assets it receives, each beneficial interest holder must have the right to sell or pledge their beneficial interests) and (iii) the Company may not have an option or obligation to reacquire the assets.
If these sale requirements are met, the assets are removed from the Company’s Consolidated Balance Sheet. If the conditions for sale are not met, the transfer is considered to be a secured borrowing, the assets remain on the Consolidated Balance Sheet and the sale proceeds are recognized as the Company’s liability. A legal opinion on a sale generally is obtained for complex transactions or where the Company has continuing involvement with assets transferred or with the securitization entity. For a transfer to be eligible for sale accounting, that opinion must state that the asset transfer would be considered a sale and that the assets transferred
would not be consolidated with the Company’s other assets in the event of the Company’s insolvency.
For a transfer of a portion of a financial asset to be considered a sale, the portion transferred must meet the definition of a participating interest. A participating interest must represent a pro rata ownership in an entire financial asset; all cash flows must be divided proportionately, with the same priority of payment; no participating interest in the transferred asset may be subordinated to the interest of another participating interest holder; and no party may have the right to pledge or exchange the entire financial asset unless all participating interest holders agree. Otherwise, the transfer is accounted for as a secured borrowing.
See Note 21 to the Consolidated Financial Statements for further discussion.


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 and commodities, 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-specificInstrument-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.Debt Securities
For its most significant pension
Debt securities classified as “held-to-maturity” (HTM) are securities that the Company has both the ability and postretirement benefit plans (Significant Plans), Citigroup measuresthe intent to hold until maturity 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 assumptionsare carried at amortized cost. Interest income on a quarterly basissuch securities is reflectedincluded in Interest revenue.
Debt securities classified as “available-for-sale” (AFS) 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 periodic plan expense. All other plans (All hedges. Interest income on such securities is included in Interest revenue.

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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 less impairment (if any), 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 held-to-maturity (HTM) or available-for-sale (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 and Federal Reserve Bank, Federal Home Loan Bank stock and certain exchange seats. 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 Plans)than physical commodities inventory, all trading account assets and liabilities are remeasured annually. Seecarried at fair value. Revenues generated from trading assets and trading liabilities are generally reported in Principal transactions and include realized gains and losses as well as unrealized gains and losses resulting from changes in the fair value of such instruments.
Interest income on trading assets is recorded in Interest revenue reduced by interest expense on trading liabilities.
Physical commodities inventory is carried at the lower of cost or market with related losses reported in Principal transactions, except when included in a hedge relationship. 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 and debt host contract are carried at fair value under the fair value option, as described in Note 825 to the Consolidated Financial Statements.

Stock-Based CompensationDerivatives 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 recognizes compensation expense relateduses a number of techniques to stock and option awards overdetermine 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 accruedof trading assets and liabilities, which are described 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 724 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 received or paid for all securities borrowing and lending transactions are recorded in Interest revenue or Interest expense at the contractually specified rate.
Income TaxesWhere the conditions of ASC 210-20-45-1, Balance
Sheet—Offsetting: Right of Setoff Conditions, are met, securities borrowing and lending transactions are presented net on the Consolidated Balance Sheet.
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
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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 classified as non-accrual within 60 days of notification that the borrower has filed for bankruptcy, with the exception of 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 1 to 6) 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 1 to 3) 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 3 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 arecharged 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.
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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 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 4Q21 forecasts are for U.S. unemployment to continue to improve as the U.S. continues to move past the peak of the pandemic-related health and economic crisis.
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 change in the ACL during 2021 were the ACL releases resulting from the recovery from the pandemic.
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
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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, home equity lines of credit (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 corporate loans 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., credit cards, etc.).
The reserves for TDRs are calculated using the discounted cash flow method and considers 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.
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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. 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 income tax lawsCECL 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 U.S.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 its states and municipalities,short-term (less than 12 months) modifications that provide concessions (such as wellinterest 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 non-U.S. jurisdictionsexpected 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 credit 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 which it operates.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 tax lawspayment rates are complexdefined 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 mayfees, will be subject to different interpretations by the taxpayerCECL 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, 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, was largely due to more precise contractual maturities that resulted 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 relevant governmental taxing authorities. In establishingborrower’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 provision for income tax expense,more simplified approach based on historical loss rates to certain exposures recorded in Other assets and certain loan exposures in the Company must make judgments and interpretations about these tax laws. private bank.
The Company must also make estimates about whenconsiders 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.


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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 futurefair 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 itemsmargin loans presented in Loans on the Consolidated Balance Sheet, credit losses are estimated using the same approach as corporate loans.

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 affect taxable incomeresult 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 various tax jurisdictions, both domestic and foreign.
Disputes over interpretationslife of the tax laws may beasset. 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 review and adjudication byspecialized 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 court systemsnotion 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 various tax jurisdictions, or may be settled withinitial ACL at 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.pool level. The amount of the benefitinitial ACL for a PCD asset represents the portion of the total discount at acquisition that relates to credit and is then measuredrecognized 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 highest tax benefitlife of the individual asset (or pool). Direct expenses incurred related to the 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.

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 50% likely30 days past due at the purchase date.

Corporate
Citi generally classifies wholesale loans and debt securities classified as 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:


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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 (excluding 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 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.


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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 realized. ASC 740 also sets out disclosureVIEs 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 enhance transparencybe a secured borrowing, the assets remain on the Consolidated Balance Sheet and the sale proceeds are recognized as the Company’s liability. A legal opinion on a sale generally is obtained for complex transactions or where the Company has continuing involvement with assets transferred or with the securitization entity. For a transfer to be eligible for sale accounting, that opinion must state that the asset transfer would be considered a sale and that the assets transferred
would not be consolidated with the Company’s other assets in the event of the Company’s insolvency.
For a transfer of a portion of a financial asset to be considered a sale, the portion transferred must meet the definition of a participating interest. A participating interest must represent a pro rata ownership in an entity’s tax reserves.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, purchased options and commodities, 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 922 to the Consolidated Financial Statements for a further descriptiondiscussion of the Company’s tax provisionhedging and related income tax assets and liabilities.

Commissions, Underwriting and Principal Transactionsderivative activities.
Commissions and fees revenues are recognized
Instrument-Specific Credit Risk
Citi presents separately in income when earned. Underwriting revenues are recognized in income typically atAOCI the closingportion of the transaction. Principal transactions revenues are recognized in income on a trade-date basis. See Note 5 to the Consolidated Financial Statements for a description of the Company’s revenue recognition policies for Commissions and fees, and Note 6 to the Consolidated Financial Statements for details of Principal transactions revenue.

Earnings per Share
Earnings per share (EPS) is computed after deducting preferred stock dividends. The Company has granted restricted and deferred share awards with dividend rights that are considered to be participating securities, which are akin to a second class of common stock. Accordingly, a portion of Citigroup’s earnings is allocated to those participating securities in the EPS calculation.
Basic earnings per share is computed by dividing income available to common stockholders after the allocation of dividends and undistributed earnings to the participating securities by the weighted average number of

common shares outstanding for the period. Diluted earnings per share reflects the potential dilution that could occur if securities or other contracts to issue common stock were exercised. It is computed after giving consideration to the weighted average dilutive effect of the Company’s stock options and warrants and convertible securities and after the allocation of earnings to the participating securities. Anti-dilutive options and warrants are disregarded in the EPS calculations.

Use of Estimates
Management must make estimates and assumptions that affect the Consolidated Financial Statements and the related Notes to the Consolidated Financial Statements. Such estimates are used in connection with certain fair value measurements. See Note 24 to the Consolidated Financial Statements for further discussions on estimates used in the determination of fair value. Moreover, estimates are significant in determining the amounts of other-than-temporary impairments, impairments of goodwill and other intangible assets, provisions for probable losses that may arise from credit-related exposures and probable and estimable losses related to litigation and regulatory proceedings, and income taxes. While management makes its best judgment, actual amounts or results could differ from those estimates.

Cash Flows
Cash equivalents are defined as those amounts included in Cash and due from banks and predominately all of Deposits with banks. Cash flows from risk management activities are classified in the same category as the related assets and liabilities.

Related Party Transactions
The Company has related party transactions with certain of its subsidiaries and affiliates. These transactions, which are primarily short-term in nature, include cash accounts, collateralized financing transactions, margin accounts, derivative transactions, charges for operational support and the borrowing and lending of funds, and are entered into in the ordinary course of business.

ACCOUNTING CHANGES

Lease Accounting
In February 2016, the FASB issued ASU No. 2016-02, Leases (Topic 842), which increases the transparency and comparability of accounting for lease transactions. The ASU requires lessees to recognize liabilities for operating leases and corresponding right-of-use (ROU) assets on the balance sheet. The ASU also requires quantitative and qualitative disclosures regarding key information about leasing arrangements. Lessee accounting for finance leases, as well as lessor accounting, are largely unchanged.
Effective January 1, 2019, the Company prospectively adopted the provisions of the ASU. At adoption, Citi recognized a lease liability and a corresponding ROU asset of approximately $4.4 billion on the Consolidated Balance
Sheet related to its future lease payments as a lessee under operating leases. In addition, the Company recorded a $151 million increase in Retained earnings for the cumulative effect of recognizing previously deferred gains on sale/leaseback transactions. Adoption of the ASU did not have a material impact on the Consolidated Statement of Income. See Notes 14 and 26 for additional details.
The Company has elected not to separate lease and non-lease components in its lease contracts and accounts for them as a single lease component. Citi has also elected not to record an ROU asset for short-term leases that have a term of 12 months or less and do not contain purchase options that Citi is reasonably certain to exercise. The cost of short-term leases is recognized in the Consolidated Statement of Income on a straight-line basis over the lease term. In addition, Citi applies the portfolio approach to account for certain equipment leases with nearly identical contractual terms.

Lessee accounting
Operating lease ROU assets and lease liabilities are included in Other assets and Other liabilities, respectively, on the Consolidated Balance Sheet. Finance lease assets and liabilities are included in Other assets and Long-term debt, respectively, on the Consolidated Balance Sheet. The Company uses its incremental borrowing rate, factoring in the lease term, to determine the lease liability, which is measured at the present value of future lease payments. The ROU asset is initially measured at the amount of the lease liability plus any prepaid rent and remaining initial direct costs, less any remaining lease incentives and accrued rent. The ROU asset is subject to impairment, during the lease term, in a manner consistent with the impairment of long-lived assets. The lease terms include periods covered by options to extend or terminate the lease depending on whether Citi is reasonably certain to exercise such options.

Lessor accounting
Lessor accounting is largely unchanged under the ASU. Citi acts as a lessor for power, railcar, shipping and aircraft assets, where the Company has executed operating, direct financing and leveraged leasing arrangements. In a direct financing or a leveraged lease, Citi derecognizes the leased asset and records a lease financing receivable at lease commencement in Loans. Upon lease termination, Citi may obtain control of the asset, which is then recorded in Other assets on the Consolidated Balance Sheet and any remaining receivable for the asset’s residual value is derecognized. Under the ASU, leveraged lease accounting is grandfathered and may continue to be applied until the leveraged lease is terminated or modified. Upon modification, the lease must be classified as an operating, direct finance or sales-type lease in accordance with the ASU.
Separately, as part of managing its real estate footprint, Citi subleases excess real estate space via operating lease arrangements.


SEC Staff Accounting Bulletin 118
On December 22, 2017, the SEC issued Staff Accounting Bulletin (SAB) 118, which set forth the accounting for the changes in tax law caused by the enactment of the Tax Cuts and Jobs Act (Tax Reform). SAB 118 provided guidance where the accounting under ASC 740 was incomplete for certain income tax effects of Tax Reform, at the time of the issuance of an entity’s financial statements for the period in which Tax Reform was enacted (provisional items). Citi disclosed several provisional items recorded as part of its $22.6 billion fourth quarter 2017 charge related to Tax Reform.
Citi completed its accounting for Tax Reform under SAB 118 during the fourth quarter of 2018 and recorded a one-time, non-cash tax benefit of $94 million in Corporate/Other related to amounts that were considered provisional pursuant to SAB 118. The adjustments for the provisional amounts consisted of a $1.2 billion benefit relating to a reduction of the valuation allowance against Citi’s FTC carry-forwards and its U.S. residual DTAs related to its non-U.S. branches, offset by additional charges of $0.2 billion related to the impact of a change to a “quasi-territorial tax system” and $0.9 billion related to the impact of deemed repatriation of undistributed earnings of non-U.S. subsidiaries.
Also, Citi has made a policy election to account for taxes on Global Intangible Low Taxed Income (GILTI) as incurred.

Revenue Recognition
In May 2014, the FASB issued ASU No. 2014-09, Revenue from Contracts with Customers (Revenue Recognition), which outlines a single comprehensive model for entities to use in accounting for revenue arising from contracts with customers. The core principle of the revenue model is that an entity recognizes revenue to depict the transfer of promised goods or services to customers in an amount that reflects the consideration to which the entity expects to be entitled, in exchange for those goods or services. The ASU defines the promised good or service as the performance obligation under the contract.
While the guidance replaces most existing revenue recognition guidance in GAAP, the ASU is not applicable to financial instruments and, therefore, does not impact a majority of the Company’s revenues, including net interest income, loan fees, gains on sales and mark-to-market accounting.
In accordance with the new revenue recognition standard, Citi has identified the specific performance obligation (promised services) associated with the contract with the customer and has determined when that specific performance obligation has been satisfied, which may be at a point in time or over time depending on how the performance obligation is defined. The contracts with customers also contain the transaction price, which consists of fixed consideration and/or consideration that may vary (variable consideration), and is defined as the amount of consideration an entity expects to be entitled to when or as the performance obligation is satisfied, excluding amounts
collected on behalf of third parties (including transaction taxes). The amounts recognized at the point in time the performance obligation is satisfied may differ from the ultimate transaction price associated with that performance obligation when a portion of it is based on variable consideration. For example, some consideration is based on the client’s month-end balance or market values, which are unknown at the time the contract is executed. The remaining transaction price amount, if any, will be recognized as the variable consideration becomes determinable. In certain transactions, the performance obligation is considered satisfied at a point in time in the future. In this instance, Citi defers revenue on the balance sheet that will only be recognized upon completion of the performance obligation.
The new revenue recognition standard further clarified the guidance related to reporting revenue gross as principal versus net as an agent. In many cases, Citi outsources a component of its performance obligations to third parties. The Company has determined that it acts as principal in the majority of these transactions and therefore presents the amounts paid to these third parties gross within operating expenses.
The Company has retrospectively adopted this standard as of January 1, 2018 and as a result was required to report amounts paid to third parties where Citi is principal to the contract within Operating expenses. The adoption resulted in an increase in both revenue and expenses of approximately $1 billion for each of the years ended December 31, 2019 and 2018 with similar amounts for prior years. Prior to adoption, these expense amounts were reported as contra revenue primarily within Commissions and fees and Administration and other fiduciary fees revenues. Accordingly, prior periods have been reclassified to conform to the new presentation.
See Note 5 to the Consolidated Financial Statements for a description of the Company’s revenue recognition policies for Commissions and fees and Administration and other fiduciary fees.

Income Tax Impact of Intra-Entity Transfers of Assets
In October 2016, the FASB issued ASU No. 2016-16, Income Taxes—Intra-Entity Transfers of Assets Other Than Inventory, which requires an entity to recognize the income tax consequences of an intra-entity transfer of an asset other than inventory when the transfer occurs. The ASU was effective January 1, 2018 and was adopted as of that date. The impact of this standard was an increase of DTAs by approximately $300 million, a decrease of Retained earnings by approximately $80 million and a decrease of prepaid tax assets by approximately $380 million. 

Clarifying the Definition of a Business
In January 2017, the FASB issued ASU No. 2017-01, Business Combinations (Topic 805): Clarifying the Definition of a Business. The definition of a business directly and indirectly affects many areas of accounting (e.g., acquisitions, disposals, goodwill and consolidation). The ASU narrows the definition of a business by introducing a quantitative screen as the first step, such that if substantially

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, totalOperating 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 presenteda liability resulting from a change in the same income statement line asinstrument-specific credit risk, when the hedged item and also requires expanded disclosures. Citi adopted this standard on January 1, 2018 and transferred approximately $4 billion of pre-payable mortgage-backed securities and municipal bonds from held-to-maturity (HTM) into available-for-sale (AFS) securities classification as permitted as a one-time transfer upon adoption ofentity has elected to measure the standard, as these assets were deemed to be eligible to be hedged under the last-of-layer hedge strategy. The impact to opening Retained earnings was immaterial. See Note 19 to the Consolidated Financial Statements for more information.

Statement of Cash Flows
In November 2016, the FASB issued ASU No. 2016-18, Restricted Cash,which requires that companies present cash, cash equivalents and amounts generally described as restricted cash or restricted cash equivalents (restricted cash) when reconciling beginning-of-period and end-of-period totals on the Consolidated Statement of Cash Flows. In connectionliability at fair value in accordance with the adoptionfair value option for financial instruments. Accordingly, the change in fair value of liabilities for which the ASU, Citigroup also changed its definition of cash and cash equivalentsfair value option was elected, related to include all of Cash and due from banks and predominately all of Deposits with banks. The Company has retrospectively adopted this ASU as of January 1, 2018 and as a result Net cash provided by investing activities of continuing operations on the Consolidated Statement of Cash Flows for the year ended December 31, 2017 increased by $19.3 billion.

Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income
On February 14, 2018, the FASB issued ASU No. 2018-02, Reclassification of Certain Tax Effects from Accumulated Other Comprehensive Income. The ASU allows a reclassification from AOCI to Retained earnings for the deferred taxes previously recordedchanges in Citigroup’s own credit spreads, is presented in AOCI that exceed the current federal tax rate of 21%, resulting from the newly enacted corporate tax rate in Tax Reform, and other stranded tax amounts related to the application of Tax Reform that Citi elects to reclassify. The ASU allows adjustments to reclassification amounts in subsequent periods as a result of changes to the amounts recorded under SAB 118. Citi elected to early adopt the ASU effective December 31, 2017, which applied only to the period in which the effects related to the one-time Tax Reform charge were recognized. In addition to the reclassification of deferred taxes recorded in AOCI that exceed the current federal tax rate, Citi also reclassified amounts recorded in AOCI related to the effects of the shift to a territorial system related to the application of Tax Reform using the portfolio method..
The effect of adopting the ASU resulted in an increase of $3.3 billion to Retained earnings at December 31, 2017 due to the reclassification of AOCI to Retained earnings.

Premium Amortization on Purchased Callable
Debt Securities

Debt securities classified as “held-to-maturity” (HTM) 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” (AFS) 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.

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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 less impairment (if any), 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 held-to-maturity (HTM) or available-for-sale (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 and Federal Reserve Bank, Federal Home Loan Bank stock and certain exchange seats. 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 March 2017,addition, as described in Note 25 to the FASB issuedConsolidated Financial Statements, certain assets that Citigroup has elected to carry at fair value under the fair value option, such as loans and purchased guarantees, are also included in Trading account assets.
Trading account liabilities include securities sold, not yet purchased (short positions) and derivatives in a net payable position, as well as certain liabilities that Citigroup has elected to carry at fair value (as described in Note 25 to the Consolidated Financial Statements).
Other than physical commodities inventory, all trading account assets and liabilities are carried at fair value. Revenues generated from trading assets and trading liabilities are generally reported in Principal transactions and include realized gains and losses as well as unrealized gains and losses resulting from changes in the fair value of such instruments.
Interest income on trading assets is recorded in Interest revenue reduced by interest expense on trading liabilities.
Physical commodities inventory is carried at the lower of cost or market with related losses reported in Principal transactions, except when included in a hedge relationship. 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 and debt host contract are 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 received or paid for all securities borrowing and lending transactions are recorded in Interest revenue or Interest expense at the contractually specified rate.
Where the conditions of ASC 210-20-45-1, Balance
Sheet—Offsetting: Right of Setoff Conditions, are met, securities borrowing and lending transactions are presented net on the Consolidated Balance Sheet.
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
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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 classified as non-accrual within 60 days of notification that the borrower has filed for bankruptcy, with the exception of 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 1 to 6) 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 1 to 3) 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 3 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 arecharged 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.
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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 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 4Q21 forecasts are for U.S. unemployment to continue to improve as the U.S. continues to move past the peak of the pandemic-related health and economic crisis.
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 change in the ACL during 2021 were the ACL releases resulting from the recovery from the pandemic.
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
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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, home equity lines of credit (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 corporate loans 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., credit cards, etc.).
The reserves for TDRs are calculated using the discounted cash flow method and considers 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.
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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. 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 credit 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, 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, was largely due to more precise contractual maturities that resulted 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.


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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.

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 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.

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 as 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:


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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 (excluding 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 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. 2017-08, 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—Receivables—Nonrefundable Feesincluding 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 Costs (Subtopic 310-20): Premium Amortization on Purchased Callable Debt SecuritiesLiabilities
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.


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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 amendsCitigroup participates, consolidation is based on which party has voting control of the entity, giving consideration to removal and liquidation rights in certain partnership structures. Only securitization entities controlled by Citigroup are consolidated.
Interests in the securitized and sold assets may be retained in the form of subordinated or senior interest-only strips, subordinated tranches, spread accounts and servicing rights. In credit card securitizations, the Company retains a seller’s interest in the credit card receivables transferred to the trusts, which is not in securitized form. In the case of consolidated securitization entities, including the credit card trusts, these retained interests are not reported on Citi’s Consolidated Balance Sheet. The securitized loans remain on the balance sheet. Substantially all of the consumer loans sold or securitized through non-consolidated trusts by Citigroup are U.S. prime residential mortgage loans. Retained interests in non-consolidated mortgage securitization trusts are classified as Trading account assets, except for MSRs, which are included in Intangible assets on Citigroup’s Consolidated Balance Sheet.

Debt
Short-term borrowings and Long-term debt are accounted for at amortized cost, except where the Company has elected to report the debt instruments, including certain structured notes, at fair value, or the debt is in a fair value hedging relationship.

Transfers of Financial Assets
For a transfer of financial assets to be considered a sale: (i) the assets must be legally isolated from the Company, even in bankruptcy or other receivership, (ii) the purchaser must have the right to pledge or sell the assets transferred (or, if the purchaser is an entity whose sole purpose is to engage in securitization and asset-backed financing activities through the issuance of beneficial interests and that entity is constrained from pledging the assets it receives, each beneficial interest holder must have the right to sell or pledge their beneficial interests) and (iii) the Company may not have an option or obligation to reacquire the assets.
If these sale requirements are met, the assets are removed from the Company’s Consolidated Balance Sheet. If the conditions for sale are not met, the transfer is considered to be a secured borrowing, the assets remain on the Consolidated Balance Sheet and the sale proceeds are recognized as the Company’s liability. A legal opinion on a sale generally is obtained for complex transactions or where the Company has continuing involvement with assets transferred or with the securitization entity. For a transfer to be eligible for sale accounting, that opinion must state that the asset transfer would be considered a sale and that the assets transferred
would not be consolidated with the Company’s other assets in the event of the Company’s insolvency.
For a transfer of a portion of a financial asset to be considered a sale, the portion transferred must meet the definition of a participating interest. A participating interest must represent a pro rata ownership in an entire financial asset; all cash flows must be divided proportionately, with the same priority of payment; no participating interest in the transferred asset may be subordinated to the interest of another participating interest holder; and no party may have the right to pledge or exchange the entire financial asset unless all participating interest holders agree. Otherwise, the transfer is accounted for as a secured borrowing.
See Note 21 to the Consolidated Financial Statements for further discussion.

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, purchased options and commodities, 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.


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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 purchased callable debtclawback provisions are subject to variable accounting, pursuant to which the associated compensation expense fluctuates with changes in Citigroup’s common stock price. See Note 7 to the Consolidated Financial Statements.

Income Taxes
The Company is subject to the income tax laws of the U.S. and its states and municipalities, as well as the non-U.S. jurisdictions in which it operates. These tax laws are complex and may be subject to different interpretations by the taxpayer and the relevant governmental taxing authorities. In establishing a provision for income tax expense, the Company must make judgments and interpretations about these tax laws. The Company must also make estimates about when in the future certain items will affect taxable income in the various tax jurisdictions, both domestic and foreign.
Disputes over interpretations of the tax laws may be subject to review and adjudication by the court systems of the various tax jurisdictions, or may be settled with the taxing authority upon examination or audit. The Company treats interest and penalties on income taxes as a component of Income tax expense.
Deferred taxes are recorded for the future consequences of events that have been recognized in financial statements or tax returns, based upon enacted tax laws and rates. Deferred tax assets are recognized subject to management’s judgment about whether realization is more-likely-than-not. ASC 740, Income Taxes, sets out a consistent framework to determine the appropriate level of tax reserves to maintain for uncertain tax positions. This interpretation uses a two-step approach wherein a tax benefit is recognized if a position is more-likely-than-not to be sustained. The amount of the benefit is then measured to be the highest tax benefit that is more than 50% likely to be realized. ASC 740 also sets out disclosure requirements to enhance transparency of an entity’s tax reserves.
See Note 9 to the Consolidated Financial Statements for a further description of the Company’s tax provision and related income tax assets and liabilities.

Commissions, Underwriting and Principal Transactions
Commissions and fees revenues are recognized in income when earned. Underwriting revenues are recognized in income typically at the closing of the transaction. Principal transactions revenues are recognized in income on a trade-date basis. See Note 5 to the Consolidated Financial Statements for a description of the Company’s revenue recognition policies for Commissions and fees, and Note 6 to the Consolidated Financial Statements for details of Principal transactions revenue.
Earnings per Share
Earnings per share (EPS) is computed after deducting preferred stock dividends. The Company has granted restricted and deferred share awards with dividend rights that are considered to be participating securities, held atwhich are akin to a premium. The ASU requires entitiessecond class of common stock. Accordingly, a portion of Citigroup’s earnings is allocated to amortize premiums on debtthose 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 first call date whenweighted average number of common shares outstanding for the period. Diluted earnings per share reflects the potential dilution that could occur if securities have fixed and determinable call dates and prices. The scopeor other contracts to issue common stock were exercised. It is computed after giving consideration to the weighted average dilutive effect of the ASU includes all accounting premiums, such as purchase premiumsCompany’s stock options and cumulativewarrants 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 hedge adjustments. 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 ASU does not changeCompany 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.


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ACCOUNTING CHANGES

Accounting for Deposit Insurance Expenses
During the fourth quarter of 2021, Citi changed its presentation of accounting for discounts, which continuedeposit insurance costs paid to be recognized over the contractual lifeFederal Deposit Insurance Corporation (FDIC) and similar foreign regulators. These costs were previously presented within Interest expense and, as a result of a security.this change, are now presented within Other operating expenses. Citi concluded that this presentation was preferable in Citi’s circumstances, as it better reflected the nature of these deposit insurance costs in that these costs do not directly represent interest payments to creditors, but are similar in nature to other payments to regulatory agencies that are accounted for as operating expenses.
Citi early adoptedThis change in income statement presentation represents a “change in accounting principle” under ASC Topic 250, Accounting Changes and Error Corrections, with retrospective application to the ASUearliest period presented. This change in the second quarter of 2017, with an effective date of January 1, 2017. Adoption of the ASU is on a modified retrospective basis through a cumulative effect adjustment to Retained earnings as of the beginning of the year of adoption. Adoption of the ASU primarily affected Citi’s AFS and HTM portfolios of callable state and municipal debt securities. The ASU adoptionaccounting principle resulted in a net reduction to total stockholders’ equityreclassification of $156$1,207 million, (after-tax), effective as$1,203 million and $781 million of January 1, 2017. This amount is composed of a reduction of approximately $660 milliondeposit insurance expenses from Interest expense to Retained earningsOther operating expenses, for the incremental amortization of purchase premiums and cumulative hedge adjustments generated under fair value hedges of these callable debt securities, offset by an increase to AOCI of $504 million related to the cumulative fair value hedge adjustments reclassified to Retained earnings for AFS debt securities.

Fair Value Measurement
In August 2018, the FASB issued ASU No. 2018-13, Fair Value Measurement (Topic 820): Disclosure Framework—Changes to the Disclosure Requirements for Fair Value Measurement. The amendments modify certain disclosure requirements for fair value measurements and were effective January 1, 2020, with early adoption permitted. The Company early adopted this ASU as ofyears ended December 31, 2021, 2020 and 2019, in its entirety, withrespectively. This change had no material impact on Citi’s net income or the Company.total deposit insurance expense incurred by Citi.

FUTURE ACCOUNTING CHANGES

Accounting for Financial Instruments—InstrumentsCredit Losses

Overview
In June 2016, the Financial Accounting Standards Board (FASB) issued ASU No. 2016-13, Financial Instruments—InstrumentsCredit Losses (Topic 326). The ASU introducesintroduced a new credit loss methodology, the Current Expected Credit Losses (CECL)CECL methodology, which requires earlier recognition of credit losses while also providing additional transparencydisclosure 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-maturityHTM debt securities, receivables and other financial assets measured at amortized cost at the time the financial asset is originated or acquired. The allowance for credit lossesACL is adjusted each period for changes in lifetime expected lifetime credit losses. The CECL methodology represents a significant change from prior U.S. GAAP and replaced the prior multiple existing impairment methods, which generally required that a loss be incurred before it was recognized. Within the life cycle of a loan or other financial asset, the methodology generally results in the earlier recognition of the provision for credit losses and the related allowance for credit lossesACL than prior U.S. GAAP. For available-for-sale debt securities where fair value is less than cost that Citi intends to hold or more-likely-than-not will not be required to sell, credit-related impairment, if any, is recognized through an allowance for credit lossesACL 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 quality of Citi’s portfolios. At the January 1, 2020 date of adoption, based on forecasts of macroeconomic conditions and exposures at that time, the aggregate impact to Citi was an approximate $4.1 billion, or an approximate 29%, pretax increase in the Allowance for credit losses, along with a $3.1 billion after-tax decrease in Retained earnings and a deferred tax asset increase of $1.0 billion. This transition impact reflects (i) a $4.9 billion build to the Allowance for credit losses for Citi’s consumer exposures, primarily driven by the impact on credit card receivables of longer estimated tenors under the CECL lifetime expected credit loss methodology (loss coverage of approximately 23 months) compared to shorter estimated tenors under the probable loss methodology under prior U.S. GAAP (loss coverage of approximately 14 months), net of recoveries; and (ii) a release of $0.8 billion of reserves primarily related to Citi’s corporate net loan loss exposures, largely due to more precise contractual maturities that result in shorter remaining tenors, incorporation of recoveries and use of more specific historical loss data based on an increase in portfolio segmentation across industries and geographies.
Under the CECL methodology, the Allowance for credit losses consists of quantitative and qualitative components. Citi’s quantitative component of the Allowance for credit losses is model based and utilizes a single forward-looking macroeconomic forecast and discounts inputs for the corporate classifiably managed portfolios, complemented by the qualitative component described below, in estimating expected credit losses and discounts inputs for the corporate classifiably managed portfolios. Reasonable and supportable forecast periods vary by product. For example, Citi’s consumer cards models use a 13-quarter reasonable and supportable period and revert to historical loss experience thereafter, while its corporate loan models use a nine-quarter reasonable and supportable period followed by a three-quarter graduated transition to historical loss experience.

Citi’sThe qualitative management adjustment component of the Allowance for credit losses considers (i) theincludes, among other things, management adjustments to reflect economic uncertainty of forward-looking scenarios based on the likelihood and severity of a possible recession as another possible scenario; (ii)downside scenarios and certain portfolio characteristics not captured in the quantitative component, such as portfolio concentration andconcentrations, collateral coverage; and (iii)coverage, model limitations, idiosyncratic events and other factors as well as idiosyncratic events.required by banking supervisory guidance for the ACL. The qualitative management adjustment component also includes management adjustments to reflect the uncertainty around the estimated impact of the pandemic on credit loss estimates.


Accounting for Variable Post-Charge-Off Third-Party Collection Costs
Subsequent MeasurementDuring the second quarter of Goodwill2020, 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
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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 required 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 were revised to reflect this change as if it were effective as of January 2017,1, 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 effected by a change in accounting principle.

Reference Rate Reform
In March 2020, the FASB issued ASU No. 2017-04,2020-04, Intangibles—Goodwill and OtherReference Rate Reform (Topic 350)848): Simplifying the Test for Goodwill Impairment. The ASU simplifies the subsequent measurement of goodwill impairment by eliminating the requirement to calculate the implied fair value of goodwill (i.e., the current step 2Facilitation of the goodwill impairment test)Effects of Reference Rate Reform on Financial Reporting, which provides optional guidance to measure a goodwill impairment charge. Underease the ASU,potential burden in accounting for (or recognizing the impairment test iseffects of) reference rate reform on financial reporting. Specifically, the comparison ofguidance permits an entity, when certain criteria are met, to consider amendments to contracts made to comply with reference rate reform to meet the fair valuedefinition of a reporting unit with its carrying amount (the current step 1), withmodification 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 impairment charge being the deficit in fair value butamendments are permitted to be adopted any time through December 31, 2022 and do not exceeding the total amountapply 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 goodwill allocated to that reporting unit. The simplified one-step impairment test applies to all reporting units (including those with zero or negative carrying amounts).
December 31, 2022. The ASU was adopted by Citi as of January 1,
June 30, 2020 with prospective application.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 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
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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.


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 Mexico, that issue long-duration insurance contracts such as traditional life insurance policies and life-contingent annuity contracts that will be impacted by the requirements of ASU 2018-12.
The effective date of ASU 2018-12 was deferred for all insurance entities by ASU 2019-09, Finance Services—Insurance: Effective Date (issued in October 2019) and by ASU 2020-11, Financial Services—Insurance: Effective Date and Early Application (issued in 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

The following accounting principle was in effect for 2019 since ASU will depend uponNo. 2016-13, Financial InstrumentsCredit Losses (Topic 326) became effective beginning on January 1, 2020.
Allowance for Credit Losses
The allowance for credit losses on loans represents management’s best estimate of probable credit losses inherent in the performance of Citi’s reporting unitsportfolio, including probable losses related to large individually evaluated impaired loans and troubled debt restructurings. Additions to the market conditions impactingallowance are made through theProvision 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, of each reporting unit going forward.with any gain or loss reflected as a recovery or charge-off in the provision.




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2. DISCONTINUED OPERATIONS, AND SIGNIFICANT DISPOSALS AND OTHER BUSINESS EXITS

Summary of Discontinued Operations
The Company’s results from Discontinued operations consisted of residual activities related to the sales of the Brazil Credit Card business in 2013, the Egg Banking plc Credit Cardcredit card business in 2011 and the German Retail Bankingretail 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 dollars201920182017
Total revenues, net of interest expense$
$
$
Loss from discontinued operations$(31)$(26)$(104)
Provision (benefit) for income taxes(27)(18)7
Loss from discontinued operations, net of taxes$(4)$(8)$(111)

In millions of dollars202120202019
Total revenues, net of interest expense$ $— $— 
Income (loss) from discontinued operations$7 $(20)$(31)
Benefit for income taxes — (27)
Income (loss) from discontinued operations, net of taxes$7 $(20)$(4)

Cash flows from Discontinued operations were not material for all periodsany period presented.

Significant Disposals
There were no significant disposals during 2019. The following transactions described below were identified as significant disposals during 2018that are recorded within the GCB segment, including the assets and 2017.liabilities that were reclassified to held-for-sale within Other assets and Other liabilities on the Consolidated Balance Sheet and the Income (loss) before taxes (benefits) related to each business.

Agreement to Sell Australia Consumer Banking Business
On August 9, 2021, Citi entered into an agreement to sell its Australia consumer banking business, which is part of Asia GCB. The sale, which is subject to regulatory approvals and other closing conditions, is expected to close in the first half of 2022. As of December 31, 2021, Citi reported the business as held-for-sale, resulting in a pretax loss on sale of approximately $700 million recorded in Other revenue ($600 million after-tax), subject to closing adjustments. The loss on sale primarily reflected the impact of a pretax $625 million currency translation adjustment (CTA) loss (net of hedges) ($475 million after-tax) already reflected in the Accumulated other comprehensive income (AOCI) component of equity. Upon closing, the CTA-related balance will be removed from the AOCI component of equity, resulting in a neutral CTA impact to Citi’s Common Equity Tier 1 Capital. Income before taxes, excluding the above referenced pretax loss on sale, for the Australia consumer banking business was as follows:

In millions of dollars202120202019
Income before taxes$306 $181 $302 

The following assets and liabilities for the Australia consumer banking business were identified and reclassified to held-for-sale within Other assets and Other liabilities on the Consolidated Balance Sheet at December 31, 2021:

In millions of dollarsDecember 31, 2021
Assets
Cash and deposits with banks$24
Loans (net of allowance of $242 millionat December 31, 2021)
8,813
Goodwill and intangible assets257
Other assets81
Total assets$9,175
Liabilities
Deposits$7,034
Long-term debt479
Other liabilities171
Total liabilities$7,684

Agreement to Sell Philippines Consumer Banking Business
On December 23, 2021, Citi entered into an agreement to sell its Philippines consumer banking business, which is part of Asia GCB. The sale, which is subject to regulatory approvals and other closing conditions, is expected to close in the second half of 2022 and result in an after-tax gain upon closing. Income before taxes for the period in which the individually significant component was classified as held-for-sale and for all prior periods was as follows:

In millions of dollars202120202019
Income before taxes$145 $42 $196 

The following assets and liabilities for the Philippines consumer banking business were identified and reclassified to held-for-sale within Other assets and Other liabilities on the Consolidated Balance Sheet at December 31, 2021:

In millions of dollarsDecember 31, 2021
Assets
Cash and deposits with banks$20
Loans (net of allowance of $96 millionat December 31, 2021)
1,132
Goodwill244
Other assets, advances to/from subs588
Other assets63
Total assets$2,047
Liabilities
Deposits$1,373
Other liabilities76
Total liabilities$1,449



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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 $150 million after-tax) recorded in Other revenue in 2018. Further, Citi and the buyer entered into a 10-year services framework agreement, with Citi acting as the distributor in exchange for an ongoing fee.
Income before taxes for the divested business, excluding the pretax gain on sale, was as follows:
In millions of dollars201920182017
Income before taxes$
$123
$164


In millions of dollars202120202019
Income before taxes$ $— $123 
Sale
Other Business Exits

Wind-Down of Fixed Income Analytics and IndexKorea Consumer Banking Business
On August 31, 2017,October 25, 2021, Citi completed the sale of a fixed income analyticsannounced its decision to wind down and close its Korea consumer banking business, and a fixed income index business that werewhich is part of MarketsAsia GCB. In connection with the announcement, Citibank Korea Inc. (CKI) commenced a voluntary termination program (VERP). Due to the voluntary nature of this termination program, no liabilities for termination benefits are recorded until CKI makes formal offers to employees that are then irrevocably accepted by those employees. Related charges are recorded as Compensation and securities services benefitswithin. Institutional Clients Group (ICG). As part of
For the sale, Citi derecognized Total assets of $112 million, including goodwill of $72 million, while the derecognized liabilities were $18 million. The transaction resulted in ayear ended December 31, 2021, Citigroup recorded pretax gain on salecharges of approximately $580 million ($355 million after-tax) recorded in Other revenue in ICG during 2017.
Income before taxes for$1.1 billion, composed of gross charges connected to the divested businesses, excluding the pretax gain on sale, was immaterial.


Exit of U.S. Mortgage Service Operations
Citigroup executed agreements during the first quarter of 2017 to effectively exit its direct U.S. mortgage servicing operations, which included the sale of mortgage servicing rights and execution of a subservicing agreement for the remaining Citi-owned loans and certain other mortgage servicing rights. As part of this transaction, Citi also transferred certain employees.Korea voluntary termination program.
This transaction, which was part of Corporate/Other, resulted in a pretax loss of $331 million ($207 million after-tax) recorded in Other revenue during 2017. The loss on sale did not include certain other costs andfollowing table summarizes the reserve charges related to the disposed operation recorded primarilyvoluntary termination program and other initiatives reported in the Operating expensesGCB during 2017, resulting in abusiness segment:

In millions of dollars2021
Employee termination costs (pretax)
Original reserve charges$1,052
Utilization(1)
Foreign exchange3
Balance at December 31, 2021$1,054

The total pretax loss of $382 million. As part of the sale, Citi derecognized a total of $1,162 million of servicing-related assets, including $1,046 million of Mortgage servicing rights, related to approximately 750,000 Fannie Mae and Freddie Mac held loans with outstanding balances of approximately $93 billion.
Excluding the loss on sale and the additionalestimated cash charges income before taxes for the disposed operation was immaterial.termination program are approximately $1.1 billion, of which most are already recognized in 2021. Citi expects to recognize the remaining charges throughout 2022, as voluntary retirements are phased in and irrevocably accepted in order to minimize business and operational impacts.

Sale of CitiFinancial Canada Consumer Finance Business
On March 31, 2017, Citi completed the sale of CitiFinancial Canada (CitiFinancial), which was part of Corporate/Other and included 220 retail branches and approximately 1,400 employees. As part of the sale, Citi derecognized Total assets of approximately $1.9 billion, including $1.7 billion consumer loans (net of allowance), and Total liabilities of approximately $1.5 billion related to intercompany borrowings, which were settled at closing of the transaction. The sale of CitiFinancial generated a pretax gain on sale of approximately $350 million recorded in Other revenue ($178 million after-tax) during 2017.
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Income before taxes for the divested business, excluding the pretax gain on sale, was as follows:

In millions of dollars201920182017
Income before taxes$
$
$41




3. BUSINESS SEGMENTS
3. OPERATING SEGMENTS
As of December 31, 2021, Citigroup’s primary activities arewere conducted through the following businessoperating segments:Institutional Clients Group (ICG) and Global Consumer Banking (GCB)and Institutional Clients Group (ICG). In addition, Corporate/Other includes activitiesActivities not assigned to a specific business segment,the operating segments, as well as certain North America legacy consumer loan portfolios, discontinued operations and other legacy assets.assets, were included in Corporate/Other.
The businessoperating segments are determined based on productshow management allocates resources and services provided or type of customers served, of which those identified as non-core are recorded in Corporate/Othermeasures financial performance to make business decisions, and are reflective of how management currently evaluatesthe types of customers served, and products and services provided.
ICG consisted of Banking and Markets and securities services, providing institutional, public sector and high-net-worth clients in 95 countries and jurisdictions with a broad range of banking and financial information to make business decisions.products and services.
GCB includesincluded 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 consistsconsisted of three GCB businesses:reporting units: North America, Latin America and Asia (including consumer banking activities in certain EMEA countries).
ICG consists of Banking and Markets and securities services and provides corporate, institutional, public sector and high-net-worth clients in 98 countries and jurisdictions with a broad range of banking and financial products and services.
Corporate/Other includesincluded certain unallocated costs of global functions, other corporate expenses and net treasury results, unallocated corporate expenses, offsets to certain line-item reclassifications and eliminations, the results of certain
North America legacy loan portfolios, discontinued operations and unallocated taxes.
Beginning in 2021, Citi changed its allocation for certain recurring expenses that are attributable to the operating segments from Corporate/Other to GCB and ICG. These expenses include incremental investments related to risks and controls, technology capabilities and information security initiatives, as well as some incremental spend related to the pandemic. The prior-period reportable operating segment results have been revised to conform to the current-year presentation for all periods to reflect this revised allocation methodology. Citi’s consolidated results were unchanged for all periods presented as a result of the changes discussed above.
As part of its strategic refresh, Citi is making management reporting changes to align with its vision and strategy, including to assist Citi in decisions about resources and capital allocation and to assess business performance. In the first quarter of 2022, Citi plans to revise its financial reporting structure to align with these management reporting changes.
The accounting policies of these reportableoperating segments are the same as those disclosed in Note 1 to the Consolidated Financial Statements.
The prior-period balances reflect reclassifications to conform the presentation for all periods to the current period’s presentation. During 2019, financial data was reclassified to reflect:

Citi’s commercial banking businesses previously reported as part of GCB in North America, Latin America and Asia, including approximately $28 billion in end-of-period loans and approximately $37 billion in end-of-period deposits, are reported in ICG for all periods presented;
the re-attribution of certain costs between Corporate/Other and GCB and ICG; and
certain other immaterial reclassifications.

Citi’s consolidated Net income (loss) reported in its 2018 Annual Report on Form 10-K remains unchanged for all periods presented as a result of the changes and reclassifications discussed above.
The following table presents certain information regarding the Company’s continuing operations by segment:operating segment and Corporate/Other:






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 billions20212020201920212020201920212020201920212020
Institutional Clients Group$43,887 $45,088 $39,824 $4,524 $3,303 $3,524 $15,763 $11,553 $12,776 $1,762 $1,730 
Global Consumer Banking27,330 30,342 33,221 1,745 143 1,708 6,046 663 5,579 432 434 
Corporate/Other667 71 2,022 (818)(921)(802)209 (1,109)1,116 97 96 
Total$71,884 $75,501 $75,067 $5,451 $2,525 $4,430 $22,018 $11,107 $19,471 $2,291 $2,260 

(1)     Includes total revenues, net of interest expense (excluding Corporate/Other), in North America of $34.2 billion, $36.8 billion and $34.1 billion; in EMEA of $13.1 billion, $13.0 billion and $12.2 billion; in Latin America of $9.2 billion, $9.4 billion and $10.6 billion; and in Asia of $14.7 billion, $16.2 billion and $16.2 billion in 2021, 2020 and 2019, respectively. These regional numbers exclude Corporate/Other, which largely reflects U.S. activities.
(2)     Includes pretax provisions for credit losses and for benefits and claims in the ICG results of $(2.9) billion, $5.6 billion and $0.6 billion; in the GCB results of $(0.5) billion, $11.7 billion and $7.9 billion; and in the Corporate/Other results of $(0.4) billion, $0.2 billion and $(0.1) billion in 2021, 2020 and 2019, respectively.

161
 
Revenues,
net of interest expense
(1)
Provision (benefits)
for income taxes
(2)
Income (loss) from
continuing operations
(2)(3)
Identifiable assets
In millions of dollars, except identifiable assets in billions20192018201720192018201720192018201720192018
Global Consumer Banking$32,971
$32,339
$31,445
$1,746
$1,689
$3,067
$5,702
$5,309
$3,542
$407
$388
Institutional Clients Group39,301
38,325
37,822
3,570
3,756
7,241
12,944
12,574
9,375
1,447
1,438
Corporate/Other2,014
2,190
3,177
(886)(88)19,080
825
205
(19,544)97
91
Total$74,286
$72,854
$72,444
$4,430
$5,357
$29,388
$19,471
$18,088
$(6,627)$1,951
$1,917
(1)
Includes total revenues, net of interest expense (excluding Corporate/Other), in North America of $33.9 billion, $33.4 billion and $34.1 billion; in EMEA of $12.0 billion, $11.8 billion and $10.9 billion; in Latin America of $10.4 billion, $10.3 billion and $9.6 billion; and in Asia of $16.0 billion, $15.3 billion and $14.6 billion in 2019, 2018 and 2017, respectively. These regional numbers exclude Corporate/Other, which largely operates within the U.S.

(2)
Corporate/Other, GCB and ICG 2017 results include the one-time impact of Tax Reform.
(3)
Includes pretax provisions for credit losses and for benefits and claims in the GCB results of $7.9 billion, $7.6 billion and $7.6 billion; in the ICG results of $563 million, $215 million and $19 million; and in the Corporate/Other results of $(75) million, $(202) million and $(175) million in 2019, 2018 and 2017, respectively.

4.  INTEREST REVENUE AND EXPENSE

Interest revenue and Interest expense consisted of the following:

In millions of dollars202120202019
Interest revenue   
Loan interest, including fees$35,440 $40,185 $47,751 
Deposits with banks577 928 2,682 
Securities borrowed and purchased under agreements to resell1,052 2,283 6,872 
Investments, including dividends7,388 7,989 9,860 
Trading account assets(2)
5,365 6,125 7,672 
Other interest-bearing assets653 579 1,673 
Total interest revenue$50,475 $58,089 $76,510 
Interest expense   
Deposits(1)
$2,896 $5,334 $11,852 
Securities loaned and sold under agreements to repurchase1,012 2,077 6,263 
Trading account liabilities(2)
482 628 1,308 
Short-term borrowings and other interest-bearing liabilities121 630 2,465 
Long-term debt3,470 4,669 6,494 
Total interest expense$7,981 $13,338 $28,382 
Net interest income$42,494 $44,751 $48,128 
Provision for credit losses on loans(3,103)15,922 8,218 
Net interest income after provision for credit losses on loans$45,597 $28,829 $39,910 

(1)During 2021, Citi reclassified deposit insurance expenses from Interest expense to Other operating expenses for all periods presented. Amounts reclassified for each year were $1,207 million for 2021, $1,203 million for 2020 and $781 million for 2019. For additional information, see Note 1 to the Consolidated Financial Statements.
(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.



162
In millions of dollars201920182017
Interest revenue   
Loan interest, including fees$47,751
$45,682
$41,736
Deposits with banks2,682
2,203
1,635
Securities borrowed and purchased under agreements to resell6,872
5,492
3,249
Investments, including dividends9,860
9,494
8,295
Trading account assets(1)
7,672
6,284
5,501
Other interest1,673
1,673
1,163
Total interest revenue$76,510
$70,828
$61,579
Interest expense   
Deposits(2)
$12,633
$9,616
$6,587
Securities loaned and sold under agreements to repurchase6,263
4,889
2,661
Trading account liabilities(1)
1,308
1,001
638
Short-term borrowings2,465
2,209
1,059
Long-term debt6,494
6,551
5,573
Total interest expense$29,163
$24,266
$16,518
Net interest revenue$47,347
$46,562
$45,061
Provision for loan losses8,218
7,354
7,503
Net interest revenue after provision for loan losses$39,129
$39,208
$37,558
(1)
Interest expense on Trading account liabilities is reported as a reduction of interest revenue from Trading account assets.

(2)Includes deposit insurance fees and charges of $781 million, $1,182 million and $1,249 million for 2019, 2018 and 2017, respectively.




5.  COMMISSIONS AND FEES; ADMINISTRATION AND OTHER FIDUCIARY FEES

Commissions and Fees
The primary components of Commissions and fees revenue are investment banking fees, brokerage commissions, credit card and bank card income and deposit-related fees.
Investment banking fees are substantially composed of underwriting and advisory revenues. Such fees are recognized at the point in time when Citigroup’s performance under the terms of a contractual arrangement is completed, which is typically at the closing of a transaction. Reimbursed expenses related to these transactions are recorded as revenue and are included within investment banking fees. In certain instances for advisory contracts, Citi will receive amounts in advance of the deal’s closing. In these instances, the amounts received will be recognized as a liability and not recognized in revenue until the transaction closes. For the periods presented, the contract liability amount was negligible.
Out-of-pocket expenses associated with underwriting activity are deferred and recognized at the time the related revenue is recognized, while out-of-pocket expenses associated with advisory arrangements are expensed as incurred. In general, expenses incurred related to investment banking transactions, whether consummated or not, are recorded in Other operating expenses. The Company has determined that it acts as principal in the majority of these transactions and therefore presents expenses gross within Other operating expenses.
Brokerage commissions primarily include commissions and fees from the following: executing transactions for clients on exchanges and over-the-counter markets; sales of mutual funds and other annuity products; and assisting clients in clearing transactions, providing brokerage services and other such activities. Brokerage commissions are recognized in Commissions and fees at the point in time the associated service is fulfilled, generally on the trade execution date. Gains or losses, if any, on these transactions are included in Principal transactions (see Note 6 to the Consolidated Financial Statements). Sales of certain investment products include a portion of variable consideration associated with the underlying product. In these instances, a portion of the revenue associated with the sale of the product is not recognized until the variable consideration becomes fixed. The Company recognized $485$639 million, $521$495 million and $416$485 million of revenue related to such variable consideration for the years ended December 31, 2019, 20182021, 2020 and 2017,2019, 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. InterchangeCiti’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
Citi’s performance obligation to transmit funds to the payment
networks has been satisfied. Annual card fees, net of
origination costs, are deferred and amortized on a straight-line
basis over a 12-month period. Costs related to card reward
programs are recognized when the rewards are earned by the
cardholders. Payments to partners are recognized when
incurred.
Deposit-related fees consist of service charges on deposit
accounts and fees earned from performing cash management
activities and other deposit account services. Such fees are
recognized in the period in which the related service is
provided.
Transactional service fees primarily consist of fees
charged for processing services such as cash management,
global payments, clearing, international funds transfer and
other trade services. Such fees are recognized as/when the
associated service is satisfied, which normally occurs at the
point in time the service is requested by the customer and
provided by Citi.
Insurance distribution revenue consists of commissions
earned from third-party insurance companies for marketing
and selling insurance policies on behalf of such entities. Such
commissions are recognized in Commissions and fees at the
point in time the associated service is fulfilled, generally when
the insurance policy is sold to the policyholder. Sales of
certain insurance products include a portion of variable
consideration associated with the underlying product. In these
instances, a portion of the revenue associated with the sale of
the policy is not recognized until the variable consideration
becomes determinable. The Company recognized $322$260 million, $386$290 million and $440$322 million of revenue related to such variable consideration for the years ended December 31, 2019, 20182021, 2020 and 2017,2019, 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.













163


The following table presents Commissions and fees revenue:

202120202019
In millions of dollarsICGGCBCorp/OtherTotalICGGCBCorp/OtherTotalICGGCBCorp/OtherTotal
Investment banking$6,007 $ $ $6,007 $4,483 $— $— $4,483 $3,767 $— $— $3,767 
Brokerage commissions2,080 1,156  3,236 1,986 974 — 2,960 1,771 841 — 2,612 
Credit card and bank card income
Interchange fees817 9,004  9,821 703 7,301 — 8,004 1,222 8,621 — 9,843 
Card-related loan fees28 667  695 23 626 — 649 60 718 — 778 
Card rewards and partner payments(1)
(405)(9,830) (10,235)(380)(8,293)— (8,673)(691)(8,883)— (9,574)
Deposit-related fees(2)
1,044 287  1,331 958 376 — 1,334 1,048 470 — 1,518 
Transactional service fees1,003 95  1,098 886 88 — 974 824 123 — 947 
Corporate finance(3)
709   709 457 — — 457 616 — — 616 
Insurance distribution revenue11 462  473 11 492 — 503 12 524 — 536 
Insurance premiums 94  94 — 125 — 125 — 186 — 186 
Loan servicing43 40 15 98 82 30 25 137 78 55 21 154 
Other104 237 4 345 118 310 432 99 261 363 
Total commissions and fees(4)
$11,441 $2,212 $19 $13,672 $9,327 $2,029 $29 $11,385 $8,806 $2,916 $24 $11,746 

(1)Citi’s consumer credit card programs have certain partner-sharing agreements that vary by partner. These 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, 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.
(2)Includes overdraft fees of $107 million, $100 million and $127 million for the years ended December 31, 2021, 2020 and 2019, respectively. Overdraft fees are accounted for under ASC 310.
(3)Consists primarily of fees earned from structuring and underwriting loan syndications or related financing activity. This activity is accounted for under ASC 310.
(4)Commissions and fees include $(8,516) million, $(7,160) million and $(7,695) million not accounted for under ASC 606, Revenue from Contracts with Customers, for the years ended December 31, 2021, 2020 and 2019, 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.

 201920182017
In millions of dollarsICGGCBCorp/OtherTotalICGGCBCorp/OtherTotalICGGCBCorp/OtherTotal
Investment banking$3,767
$
$
$3,767
$3,568
$
$
$3,568
$3,817
$
$
$3,817
Brokerage commissions1,771
841

2,612
1,977
815

2,792
1,889
826
3
2,718
Credit card and bank card
  income
   

   

   

     Interchange fees1,222
8,621

9,843
1,077
8,112
11
9,200
953
7,523
99
8,575
     Card-related loan fees60
718

778
63
627
12
702
53
693
48
794
     Card rewards and partner
       payments
(691)(8,883)
(9,574)(504)(8,253)(12)(8,769)(426)(7,242)(57)(7,725)
Deposit-related fees(1)
1,048
470

1,518
1,031
572
1
1,604
1,031
642
14
1,687
Transactional service fees824
123

947
733
83
4
820
751
78
49
878
Corporate finance(2)
616


616
734


734
766


766
Insurance distribution
  revenue
12
524

536
14
565
11
590
12
562
68
642
Insurance premiums
186

186

119

119

122

122
Loan servicing78
55
21
154
100
91
37
228
117
71
95
283
Other99
261
3
363
116
139
14
269
30
90
30
150
Total commissions and
  fees(3)
$8,806
$2,916
$24
$11,746
$8,909
$2,870
$78
$11,857
$8,993
$3,365
$349
$12,707
164


(1)Includes overdraft fees of $127 million, $128 million and $135 million for the years ended December 31, 2019, 2018 and 2017, respectively. Overdraft fees are accounted for under ASC 310.
(2)Consists primarily of fees earned from structuring and underwriting loan syndications or related financing activity. This activity is accounted for under ASC 310.
(3)
Commissions and fees includes $(7,695) million, $(6,853) million and $(5,627) million not accounted for under ASC 606, Revenue from Contracts with Customers, for the years ended December 31, 2019, 2018 and 2017, respectively. Amounts reported in Commissions and fees accounted for under other guidance primarily include card-related loan fees, card reward programs and certain partner payments, corporate finance fees, insurance premiums and loan servicing fees.


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,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 fundsassets 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:

202120202019
In millions of dollarsICGGCBCorp/OtherTotalICGGCBCorp/OtherTotalICGGCBCorp/OtherTotal
Custody fees$1,872 $25 $1 $1,898 $1,590 $29 $38 $1,657 $1,453 $16 $73 $1,542 
Fiduciary fees798 659 7 1,464 668 602 1,274 647 621 28 1,296 
Guarantee fees569 8 4 581 529 541 558 573 
Total administration and other fiduciary fees(1)
$3,239 $692 $12 $3,943 $2,787 $638 $47 $3,472 $2,658 $645 $108 $3,411 

(1)    Administration and other fiduciary fees include $581 million, $541 million and $573 million for the years ended December 31, 2021, 2020 and 2019, respectively, that are not accounted for under ASC 606, Revenue from Contracts with Customers. These generally include guarantee fees.

165
 201920182017
In millions of dollarsICGGCBCorp/OtherTotalICGGCBCorp/OtherTotalICGGCBCorp/OtherTotal
Custody fees$1,453
$16
$73
$1,542
$1,497
$133
$65
$1,695
$1,508
$164
$56
$1,728
Fiduciary fees647
621
28
1,296
645
597
43
1,285
593
575
91
1,259
Guarantee fees558
8
7
573
584
9
7
600
584
5
8
597
Total administration
  and other fiduciary fees(1)
$2,658
$645
$108
$3,411
$2,726
$739
$115
$3,580
$2,685
$744
$155
$3,584
(1)
Administration and other fiduciary fees includes $573 million, $600 million and $597 million for the years ended December 31, 2019, 2018 and 2017, respectively, that are not accounted for under ASC 606, Revenue from Contracts with Customers. These amounts include guarantee fees.



6. PRINCIPAL TRANSACTIONS
Citi’s
Principal transactions revenue consists of realized and unrealized gains and losses from trading activities. Trading activities include revenues from fixed income, equities, credit and commodities products and foreign exchange transactions that are managed on a portfolio basis and characterized below based on the primary risk managed by primary risk.each trading desk. Not included in the table below is the impact of net interest revenueincome 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 revenueincome 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 dollars202120202019
Interest rate risks(1)
$2,790 $5,561 $3,831 
Foreign exchange risks(2)
3,886 4,158 3,850 
Equity risks(3)
2,197 1,343 808 
Commodity and other risks(4)
1,123 1,133 546 
Credit products and risks(5)
158 1,690 (143)
Total$10,154 $13,885 $8,892 

(1)    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.
(2)    Includes revenues from foreign exchange spot, forward, option and swap contracts, as well as foreign currency translation (FX translation) gains and losses.
(3)    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.
166
In millions of dollars201920182017
Interest rate risks(1)
$5,990
$5,178
$5,304
Foreign exchange risks(2)
1,650
1,398
2,435
Equity risks(3)
872
1,336
525
Commodity and other risks(4)
516
669
425
Credit products and risks(5)
(136)324
251
Total$8,892
$8,905
$8,940
(1)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.
(2)Includes revenues from foreign exchange spot, forward, option and swap contracts, as well as foreign currency translation (FX translation) gains and losses.
(3)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.



7. INCENTIVE PLANS
 
Discretionary Annual Incentive Awards
Citigroup grants immediate cash bonus payments and various forms of immediate and deferred awards as part of its discretionary annual incentive award program involving a large segment of Citigroup’s employees worldwide. Most of the shares of common stock issued by Citigroup as part of its equity compensation programs are issued to settle the vesting of the stock components of these awards.
Discretionary annual incentive awards are generally awarded in the first quarter of the year based on the previous year’s performance. Awards valued at less than U.S. $100,000 (or the local currency equivalent) are generally paid entirely in the form of an immediate cash bonus. Pursuant to Citigroup policy and/or regulatory requirements, certain employees and officers are subject to mandatory deferrals of incentive pay and generally receive 25%–60% of their awards in a combinationthe form of restricted or deferred stock and deferred cash stock units or deferred cash.units. 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 cashannual incentive 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-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 may be subject to performance conditions and are subject to one or more cancellation and 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 retentionreplacement awards is presented below:

Unvested stock awardsShares
Weighted-
average grant
date fair
value per share
Unvested stock awardsSharesWeighted-
average grant
date fair
value per share
Unvested at December 31, 201831,728,596
$57.30
Unvested at December 31, 2020Unvested at December 31, 202028,226,292 $69.25 
Granted(1)
14,920,917
61.78
Granted(1)
17,535,978 62.10 
Canceled(1,104,448)60.45
Canceled(1,453,029)67.01 
Vested(2)
(15,350,350)53.58
Vested(2)
(12,664,557)67.17 
Unvested at December 31, 201930,194,715
$61.30
Unvested at December 31, 2021Unvested at December 31, 202131,644,684 $66.22 

(1)The weighted-average fair value of the shares granted during 2018 and 2017 was $73.87 and $59.12, respectively.
(2)The weighted-average fair value of the shares vesting during 2019 was approximately $63.38 per share.
(1)The weighted-average fair value of the shares granted during 2020 and 2019 was $76.68 and $61.78, respectively.
(2)The weighted-average fair value of the shares vesting during 2021 was approximately $64.23 per share on the vesting date, compared to $67.17 on the grant date.

Total unrecognized compensation cost related to unvested stock awards was $538$654 million at December 31, 2019.2021. The cost is expected to be recognized over a weighted-average period of 1.6 years.



167


Performance Share Units
Certain executiveExecutive officers were awarded a target number of performance share units (PSUs) eachevery February from 20162018 to 2019,2021, for performance in the year prior to the award date.
The PSUs granted in February 2016 were earned over a three-year performance perioddate based on Citigroup’s relative total shareholder return as compared to peers.
Thetwo performance metrics. For PSUs grantedawarded in February 2017, 2018, 2019 and 2019 are earned over a three-year performance period, based half on2020, those metrics were 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 overshare. For PSUs awards in 2021, the three-year performance period.metrics were return on tangible common equity and tangible book value per share. In each year, the metrics were equally weighted.
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 against performance goals and/or peer firms. The number of PSUs ultimately earned could vary from 0,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 1 share of Citi common stock. Dividend equivalents will beare 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 and taking into account any mandatory equitable adjustments as per the terms of the award agreement, 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 assumptions201920182017
Expected volatility25.33%24.93%25.79%
Expected dividend yield2.67
1.75
1.30


Valuation assumptions202120202019
Expected volatility40.88 %22.26 %25.33 %
Expected dividend yield4.21 2.82 2.67 

















A summary of the performance share unit activity for 20192021 is presented below:

Performance share unitsUnits
Weighted-
average grant
date fair
value per unit
Performance share unitsUnitsWeighted-
average grant
date fair
value per unit
Outstanding, beginning of
period
1,768,362
$51.88
Outstanding, beginning of yearOutstanding, beginning of year1,333,803 $79.39 
Granted(1)
560,031
72.83
Granted(1)
418,098 78.55 
Canceled(194,782)42.24
Canceled(344,131)83.24 
Payments(641,611)27.03
Payments(133,497)83.24 
Outstanding, end of period1,492,000
$71.69
Outstanding, end of yearOutstanding, end of year1,274,273 $77.67 

(1)
The weighted-average grant date fair value per unit awarded in 2018 and 2017 was $83.24 and $59.22, respectively.

PSUs granted(1)The weighted-average grant date fair value per unit awarded in 20172020 and 2019 was $83.45 and $72.83, respectively.

Transformation Program
In order to provide an incentive for select employees to effectively execute Citi’s transformation program, in August 2021 the Personnel and Compensation (P&C) Committee of Citigroup’s Board of Directors approved a program for them to earn additional compensation based on the achievement of Citi’s transformation goals from August 2021 through December 2024 and satisfaction of other conditions. Eligible employees were equitably adjusted after the enactmentnotified of Tax Reform, as requiredtheir award under the terms of those awards.program in November 2021. Performance under the program is divided into three consecutive periods, ending on December 31, 2022, 2023 and 2024. The adjustments were intendedawards will be subject to reproducevariable accounting, pursuant to which the expectedassociated value of the awards immediately prioraward will fluctuate with the attainment of the performance conditions for each tranche and changes to Citigroup’s stock price. The amortization commenced after the passageservice inception date of Tax Reform.November 2021. Payment for each period will be in cash, in a lump sum, with the third payment indexed to changes in the value of Citi’s common stock from the service inception date through the payment date. Earnings generally will be based on collective performance with respect to Citi’s transformation goals and will be evaluated and approved by the Committee on an annual basis.
Payments in the event of any category of employment termination or change in job title or employment status are subject to Citi’s discretion. Cancellation and clawback is provided for in the event of misconduct and certain other circumstances. The PSUs granted in 2016 were not impacted by Tax Reform.program applies to senior leaders critical to helping deliver a successful transformation with the value varying based on individual compensation levels.



168


Stock Option Programs
All outstanding stock options are fully vested, with the related expense recognized as a charge to income in prior periods.


The following table presents information with respect to stock option activity under Citigroup’s stock option programs: 
 201920182017
 Options
Weighted-
average
exercise
price
Intrinsic
value
per share
Options
Weighted-
average
exercise
price
Intrinsic
value
per share
Options
Weighted-
average
exercise
price
Intrinsic
value
per share
Outstanding, beginning of period762,225
$101.84
$
1,138,813
$161.96
$
1,527,396
$131.78
$
Canceled(11,365)40.80







Expired(449,916)142.30

(376,588)283.63




Exercised(134,294)39.00
23.50



(388,583)43.35
15.67
Outstanding, end of period166,650
$47.42
$32.47
762,225
$101.84
$
1,138,813
$161.96
$
Exercisable, end of period166,650
  
762,225
 
 
1,138,813
 
 


 202120202019
 OptionsWeighted-
average
exercise
price
Intrinsic
value
per share
OptionsWeighted-
average
exercise
price
Intrinsic
value
per share
OptionsWeighted-
average
exercise
price
Intrinsic
value
per share
Outstanding, beginning of year166,650 $47.42 $14.24 166,650 $47.42 $32.47 762,225 $101.84 $— 
Canceled   — — — (11,365)40.80 — 
Expired   — — — (449,916)142.30 — 
Exercised(166,650)52.50 20.49 — — — (134,294)39.00 23.50 
Outstanding, end of year $ $ 166,650 $47.42 $14.24 166,650 $47.42 $32.47 
Exercisable, end of year  166,650   166,650   
The following table summarizes information about
As of December 31, 2021, Citigroup no longer has any stock options outstanding under Citigroup’s stock option programs at December 31, 2019:outstanding.

  Options outstandingOptions exercisable
Range of exercise prices
Number
outstanding
Weighted-average
contractual life
remaining
Weighted-average
exercise price
Number
exercisable
Weighted-average
exercise price
$41.54–$60.00166,650
1.4 years$47.42
166,650
$47.42
Total at December 31, 2019166,650
1.4 years$47.42
166,650
$47.42

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, Citi recognizes the entire expense is recognizedeach year equal to the grant date fair value of the awards that it estimates will be granted in the year prior to grant.following year.
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 payment awards generally are entitled to vote the shares in their award during the vestingsale-restriction period. Once a stock award
vests, the shares delivered to the participant are freely transferable, unless they are subject to a restriction on sale or transfer for a specified period.
All equity awards granted since April 19, 2005 have been made pursuant to stockholder-approved stock incentive plans that are administered by the Personnel and CompensationP&C Committee, of the Citigroup Board of Directors, which is composed entirely of independent non-employee directors.
At December 31, 2019,2021, approximately 29.739.0 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 20162018 to 2019,2021, and for the first quarter of 2020,2022, 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.
























169


Incentive Compensation Cost
The following table shows components of compensation expense, relating to certain of the incentive compensation programs described above:

In millions of dollars202120202019
Charges for estimated awards to retirement-eligible colleagues$807 $748 $683 
Amortization of deferred cash awards, deferred cash stock units and performance stock units384 201 355 
Immediately vested stock award expense(1)
99 95 82 
Amortization of restricted and deferred stock awards(2)
395 420 404 
Other variable incentive compensation435 627 666 
Total$2,120 $2,091 $2,190 

(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.



In millions of dollars201920182017
Charges for estimated awards to retirement-eligible employees$683
$669
$659
Amortization of deferred cash awards, deferred cash stock units and performance stock units355
202
354
Immediately vested stock award expense(1)
82
75
70
Amortization of restricted and deferred stock awards(2)
404
435
474
Other variable incentive compensation666
640
694
Total$2,190
$2,021
$2,251
(1)Represents expense for immediately vested stock awards that generally were stock payments in lieu of cash compensation. The expense is generally accrued as cash incentive compensation in the year prior to grant.
(2)All periods include amortization expense for all unvested awards to non-retirement-eligible employees.



170


8. RETIREMENT BENEFITS

Pension and Postretirement Plans
The Company has several non-contributory defined benefit pension plans covering certain U.S. employees and has various defined benefit pension and termination indemnity plans covering employees outside the U.S.
The U.S. qualified defined benefit plan was frozen effective January 1, 2008 for most employees. Accordingly, no additional compensation-based contributions have been credited to the cash balance portion of the plan for existing plan participants after 2007. However, certain employees covered under the prior final pay plan formula continue to accrue benefits. The Company also offers postretirement health care and life insurance benefits to certain eligible U.S. retired employees, as well as to certain eligible employees outside the U.S.
The Company also sponsors a number of non-contributory, nonqualified pension plans. These plans, which
are unfunded, provide supplemental defined pension benefits to certain U.S.
employees. With the exception of certain employees covered under the prior final pay plan formula, the benefits under these plans were frozen in prior years.
The plan obligations, plan assets and periodic plan expense for the Company’s most significant pension and postretirement benefit plans (Significant Plans) are measured and disclosed quarterly, instead of annually. The Significant Plans captured approximately 90% of the Company’s global pension and postretirement plan obligations as of December 31, 2019.2021. 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 plansPostretirement benefit plans
 U.S. plansNon-U.S. plansU.S. plansNon-U.S. plans
In millions of dollars201920182017201920182017201920182017201920182017
Benefits earned during the year$1
$1
$3
$146
$146
$153
$
$
$
$8
$9
$9
Interest cost on benefit obligation469
514
533
287
292
295
24
26
26
104
102
101
Expected return on plan assets(821)(844)(865)(281)(291)(299)(18)(14)(6)(84)(88)(89)
Amortization of unrecognized: 
 
 
 
 
 
 
 
 
 
 
 
Prior service cost (benefit)2
2
2
(4)(4)(3)


(10)(10)(10)
Net actuarial loss200
165
173
61
53
61

(1)
23
29
35
Curtailment loss (gain)(1)
1
1
6
(6)(1)






Settlement loss(1)



6
7
12






Total net (benefit) expense$(148)$(161)$(148)$209
$202
$219
$6
$11
$20
$41
$42
$46

(1)Curtailment and settlement relate to repositioning and divestiture actions.
 Pension plansPostretirement benefit plans
 U.S. plansNon-U.S. plansU.S. plansNon-U.S. plans
In millions of dollars202120202019202120202019202120202019202120202019
Benefits earned during the year$ $— $$149 $147 $146 $ $— $— $6 $$
Interest cost on benefit obligation351 378 469 268 246 287 13 17 24 96 93 104 
Expected return on assets(683)(824)(821)(253)(245)(281)(13)(17)(18)(84)(77)(84)
Amortization of unrecognized:            
Prior service cost (benefit)2 (6)(4)(9)(2)— (9)(9)(10)
Net actuarial loss (gain)228 233 200 62 70 61 (3)— — 13 20 23 
Curtailment loss (gain)(1)
 — 1 (8)(6) — —  — — 
Settlement loss (gain)(1)
 — — 10 (1) — —  — — 
Total net (benefit) expense$(102)$(211)$(148)$231 $214 $209 $(12)$(2)$$22 $34 $41 

(1)Losses (gains) due to curtailment and settlement relate to repositioning and divestiture activities.

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 20192021 or 2018.2020.

The following table summarizes the Company’s actual Company contributions for the years ended December 31, 20192021 and 2018,2020, as well as estimated expected Company contributions for 2020.2022. 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)
U.S. plans(2)
Non-U.S. plansU.S. plansNon-U.S. plans
In millions of dollars202220212020202220212020202220212020202220212020
Contributions made by the Company$ $— $— $74 $104 $115 $ $— $— $3 $$
Benefits paid directly by (reimbursements to) the Company(3)
57 56 56 413 51 43 5 22 (15)6 

(1)    Amounts reported for 2022 are expected amounts.     
(2)     The U.S. pension plans include benefits paid directly by the Company for the nonqualified pension plans.
(3)    Estimated 2022 benefit payments have increased due to the wind-down of Citi’s consumer banking business in Korea, as it is expected that employees who elected the VERP plan will be withdrawing their pension plan assets. See Note 2 to the Consolidated Financial Statements for additional information.

171

 
Pension plans(1)
Postretirement benefit plans(1)
 
U.S. plans(2)
Non-U.S. plansU.S. plansNon-U.S. plans
In millions of dollars202020192018202020192018202020192018202020192018
Contributions made by the Company$
$425
$
$111
$111
$140
$
$
$145
$4
$221
$3
Benefits paid directly by the Company58
56
55
53
39
42
6
4
5
6
4
6


(1)Amounts reported for 2020 are expected amounts.     
(2)The U.S. pension plans include benefits paid directly by the Company for the nonqualified pension plans.


Funded Status and Accumulated Other Comprehensive Income (AOCI)
The following table summarizes the funded status and amounts recognized inon the Consolidated Balance Sheet for the Company’s pension and postretirement plans:
 Pension plansPostretirement benefit plans
 U.S. plansNon-U.S. plansU.S. plansNon-U.S. plans
In millions of dollars20192018201920182019201820192018
Change in projected benefit obligation 
 
 
 
 
 
 
 
Projected benefit obligation at beginning of year$12,655
$14,040
$7,149
$7,433
$662
$699
$1,159
$1,261
Benefits earned during the year1
1
146
146


8
9
Interest cost on benefit obligation469
514
287
292
24
26
104
102
Plan amendments

7
7




Actuarial loss (gain)( 1)
1,263
(1,056)861
(99)46
(1)140
(123)
Benefits paid, net of participants’ contributions and government subsidy(2)
(936)(845)(304)(293)(40)(62)(72)(68)
Settlement gain(3)



(84)(121)



Curtailment loss (gain)(3)
1
1
(4)(1)



Foreign exchange impact and other

47
(215)

45
(22)
Projected benefit obligation at year end$13,453
$12,655
$8,105
$7,149
$692
$662
$1,384
$1,159
Change in plan assets 
 
 
 
 
 
 
 
Plan assets at fair value at beginning of year$11,490
$12,725
$6,699
$7,128
$345
$262
$1,036
$1,119
Actual return on plan assets(1)
1,682
(445)781
(11)36
(5)138
(26)
Company contributions481
55
150
182
4
150
225
9
Benefits paid, net of participants’ contributions and government subsidy(2)
(936)(845)(304)(293)(40)(62)(72)(68)
Settlement gain(3)


(84)(121)



Foreign exchange impact and other

314
(186)

(200)2
Plan assets at fair value at year end$12,717
$11,490
$7,556
$6,699
$345
$345
$1,127
$1,036
Funded status of the plans        
Qualified plans(4)
$(23)$(483)$(549)$(450)$(347)$(317)$(257)$(123)
Nonqualified plans(5)
(713)(682)





Funded status of the plans at year end$(736)$(1,165)$(549)$(450)$(347)$(317)$(257)$(123)
Net amount recognized 
 
 
 
 
 
 
 
Qualified plans        
Benefit asset$
$
$808
$806
$
$
$57
$175
Benefit liability(23)(483)(1,357)(1,256)(347)(317)(314)(298)
Qualified plans$(23)$(483)$(549)$(450)$(347)$(317)$(257)$(123)
Nonqualified plans(713)(682)





Net amount recognized on the balance sheet$(736)$(1,165)$(549)$(450)$(347)$(317)$(257)$(123)
Amounts recognized in AOCI
     
 
 
 
Net transition obligation$
$
$
$(1)$
$
$
$
Prior service (cost) benefit(12)(13)1
12


76
83
Net actuarial (loss) gain(7,092)(6,892)(1,735)(1,420)24
53
(416)(340)
Net amount recognized in equity (pretax)$(7,104)$(6,905)$(1,734)$(1,409)$24
$53
$(340)$(257)
Accumulated benefit obligation at year end

$13,447
$12,646
$7,618
$6,720
$692
$662
$1,384
$1,159


(1)During 2019, the actuarial loss is primarily due to the decline in global discount rates and actual return on plan assets due to favorable asset returns.
(2)U.S. postretirement benefit plans were net of Employer Group Waiver Plan subsidy of $22 million and $15 million in 2019 and 2018, respectively.
(3)Curtailment and settlement (gains) losses relate to repositioning and divestiture activities.
(4)The U.S. qualified pension plan is fully funded under specified Employee Retirement Income Security Act (ERISA) funding rules as of January 1, 2020 and no minimum required funding is expected for 2020.
(5)The nonqualified plans of the Company are unfunded.

 Pension plansPostretirement benefit plans
U.S. plansNon-U.S. plansU.S. plansNon-U.S. plans
In millions of dollars20212020202120202021202020212020
Change in projected benefit obligation        
Projected benefit obligation at beginning of year$13,815 $13,453 $8,629 $8,105 $559 $692 $1,390 $1,384 
Benefits earned during the year — 149 147  — 6 
Interest cost on benefit obligation351 378 268 246 13 17 96 93 
Plan amendments(1)
 — 6 (4) (104) — 
Actuarial (gain) loss(2)
(447)950 (344)518 (28)(18)(110)30 
Benefits paid, net of participants’ contributions and government subsidy(3)
(953)(966)(345)(298)(43)(28)(78)(64)
Settlement gain(4)
 — (124)(110) —  — 
Curtailment gain(4)
 — (30)(14) —  — 
Foreign exchange impact and other — (208)39  — (135)(60)
Projected benefit obligation at year end$12,766 $13,815 $8,001 $8,629 $501 $559 $1,169 $1,390 
Change in plan assets        
Plan assets at fair value at beginning of year$13,309 $12,717 $7,831 $7,556 $331 $345 $1,146 $1,127 
Actual return on assets(2)
565 1,502 217 584 9 29 97 129 
Company contributions (reimbursements)56 56 155 158 22 (15)8 
Benefits paid, net of participants’ contributions and government subsidy(3)
(953)(966)(345)(298)(43)(28)(78)(64)
Settlement gain(4)
 — (124)(110) —  — 
Foreign exchange impact and other — (120)(59) — (130)(55)
Plan assets at fair value at year end$12,977 $13,309 $7,614 $7,831 $319 $331 $1,043 $1,146 
Funded status of the plans
Qualified plans(5)
$894 $230 $(387)$(798)$(182)$(228)$(126)$(244)
Nonqualified plans(6)
(683)(736) —  —  — 
Funded status of the plans at year end$211 $(506)$(387)$(798)$(182)$(228)$(126)$(244)
Net amount recognized        
Qualified plans
Benefit asset$894 $230 $963 $741 $ $— $165 $25 
Benefit liability — (1,350)(1,539)(182)(228)(291)(269)
Qualified plans$894 $230 $(387)$(798)$(182)$(228)$(126)$(244)
Nonqualified plans(683)(736) —  —  — 
Net amount recognized on the balance sheet$211 $(506)$(387)$(798)$(182)$(228)$(126)$(244)
Amounts recognized in AOCI(7)
    
Net transition obligation$ $— $ $— $ $— $ $— 
Prior service (cost) benefit(8)(10)5 12 92 101 47 63 
Net actuarial (loss) gain(6,575)(7,132)(1,400)(1,863)77 56 (182)(348)
Net amount recognized in equity (pretax)$(6,583)$(7,142)$(1,395)$(1,851)$169 $157 $(135)$(285)
Accumulated benefit obligation at year end$12,765 $13,812 $7,559 $8,116 $501 $559 $1,169 $1,390 


(1)The U.S. postretirement benefit plan was amended in 2020 to move grandfathered Medicare-eligible retirees to the Medicare individual marketplace.
(2)During 2021, the actuarial gain was primarily due to the increase in global discount rates partially offset by lower than expected asset returns. During 2020, the actuarial loss was primarily due to the decline in global discount rates partially offset by favorable asset returns.
(3)U.S. postretirement benefit plans were net of Employer Group Waiver Plan subsidies of $11 million and $40 million in 2021 and 2020, respectively.
(4)Curtailment and settlement gains relate to repositioning and divestiture activities.
(5)The U.S. qualified pension plan was fully funded under specified Employee Retirement Income Security Act (ERISA) funding rules as of January 1, 2022 and no minimum required funding is expected for 2022.
(6)The nonqualified plans of the Company are unfunded.
172


(7)The framework for the Company’s pension oversight process includes monitoring of potential settlement charges for all plans. Settlement accounting is triggered when either the sum of all settlements (including lump sum payments) for the year is greater than service plus interest costs or if more than 10% of the plan’s projected benefit obligation will be settled. Because some of Citi’s significant plans are frozen and have no material service cost, settlement accounting may apply in the future.

The following table shows the change in AOCI related to the Company’s pension, postretirement and post employment plans:
In millions of dollars201920182017
Beginning of year balance, net of tax(1)(2)
$(6,257)$(6,183)$(5,164)
Actuarial assumptions changes and plan experience(2,300)1,288
(760)
Net asset gain (loss) due to difference between actual and expected returns1,427
(1,732)625
Net amortization274
214
229
Prior service (cost) credit(7)(7)(4)
Curtailment/settlement gain(3)
1
7
17
Foreign exchange impact and other(66)136
(93)
Impact of Tax Reform(4)


(1,020)
Change in deferred taxes, net119
20
(13)
Change, net of tax$(552)$(74)$(1,019)
End of year balance, net of tax(1)(2)
$(6,809)$(6,257)$(6,183)

(1)
In millions of dollars202120202019
Beginning of year balance, net of tax(1)(2)
$(6,864)$(6,809)$(6,257)
Actuarial assumptions changes and plan experience963 (1,464)(2,300)
Net asset gain (loss) due to difference between actual and expected returns(148)1,076 1,427 
Net amortization280 318 274 
Prior service credit (cost)(7)108 (7)
Curtailment/settlement gain(3)
11 (8)
Foreign exchange impact and other153 (108)(66)
Change in deferred taxes, net(240)23 119 
Change, net of tax$1,012 $(55)$(552)
End of year balance, net of tax(1)(2)
$(5,852)$(6,864)$(6,809)

(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.

AOCI balance.
(2)Includes net-of-tax amounts for certain profit-sharing plans outside the U.S.
(3)Curtailment and settlement relate to repositioning and divestiture activities.
(4)
In the fourth quarter of 2017, Citi adopted ASU 2018-02, which transferred these amounts from AOCI to Retained earnings. See Note 1 to the Consolidated Financial Statements.

At December 31, 20192021 and 2018,2020, 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 assetsABO exceeds fair value of plan assets
 
U.S. plans(1)
Non-U.S. plans
U.S. plans(1)
Non-U.S. plans
In millions of dollars20192018201920182019201820192018
Projected benefit obligation$13,453
$12,655
$4,445
$3,904
$13,453
$12,655
$2,748
$3,718
Accumulated benefit obligation13,447
12,646
4,041
3,528
13,447
12,646
2,435
3,387
Fair value of plan assets12,717
11,490
3,089
2,648
12,717
11,490
1,429
2,478
(1)At December 31, 2019 and 2018, for both the U.S. qualified plan and nonqualified plans, the aggregate PBO and the aggregate ABO exceeded plan assets.

 PBO exceeds fair value of plan assetsABO exceeds fair value of plan assets
 
U.S. plans(1)
Non-U.S. plans
U.S. plans(1)
Non-U.S. plans
In millions of dollars20212020202120202021202020212020
Projected benefit obligation$683 $736 $3,966 $4,849 $683 $736 $3,809 $4,723 
Accumulated benefit obligation682 734 3,574 4,400 682 734 3,477 4,329 
Fair value of plan assets — 2,616 3,310  — 2,486 3,212 


(1)As of December 31, 2021 and 2020, only the 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.

173


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 end20192018
Discount rate  
U.S. plans  
Qualified pension3.25%4.25%
Nonqualified pension3.254.25
Postretirement3.154.20
Non-U.S. pension plans  
Range(1)
-0.10 to 11.300.25 to 12.00
Weighted average3.654.47
Non-U.S. postretirement plans
 
  
Range0.90 to 9.101.75 to 10.75
Weighted average7.769.05
Future compensation increase rate(2)
 
Non-U.S. pension plans  
Range1.50 to 11.501.30 to 13.67
Weighted average3.173.16
Expected return on assets  
U.S. plans

Qualified pension6.706.70
Postretirement(3)
6.70/3.006.70/3.00
Non-U.S. pension plans  
Range0.00 to 11.501.00 to 11.50
Weighted average3.954.30
Non-U.S. postretirement plans  
Range6.20 to 8.008.00 to 9.20
Weighted average7.998.01

(1)Due to substantial downward movement in yields, there were negative discount rates for plans with relatively short duration in major markets, such as the Eurozone and Switzerland.
(2)Not material for U.S. plans.
(3)In 2019 and 2018, the expected rate of return for the VEBA Trust was 3.00%.

During the year201920182017
Discount rate   
U.S. plans   
Qualified pension4.25%/3.85%/ 3.45%/3.10%3.60%/3.95%/ 4.25%/4.30%4.10%/4.05%/ 3.80%/3.75%
Nonqualified pension4.25/3.90/ 3.50/3.103.60/3.95/ 4.25/4.304.00/3.95/ 3.75/3.65
Postretirement4.20/3.80/ 3.35/3.003.50/3.90/ 4.20/4.203.90/3.85/ 3.60/3.55
Non-U.S. pension plans(1)
  
Range(2)
-0.05 to 12.000.00 to 10.750.25 to 72.50
Weighted average4.474.174.40
Non-U.S. postretirement plans(1)
  
Range1.75 to 10.751.75 to 10.101.75 to 11.05
Weighted average9.058.108.27
Future compensation increase rate(3)
 
Non-U.S. pension plans(1)
  
Range1.30 to 13.671.17 to 13.671.25 to 70.00
Weighted average3.163.083.21
Expected return on assets  
U.S. plans


Qualified pension(4)
6.706.80/6.706.80
Postretirement(4)(5)
6.70/3.006.80/6.70/3.006.80
Non-U.S. pension plans(1)
  
Range1.00 to 11.500.00 to 11.601.00 to 11.50
Weighted average4.304.524.55
Non-U.S. postretirement plans(1)
  
Range8.00 to 9.208.00 to 9.808.00 to 10.30
Weighted average8.018.018.02

At year end20212020
Discount rate  
U.S. plans  
Qualified pension2.80%2.45%
Nonqualified pension2.802.35
Postretirement2.752.20
Non-U.S. pension plans
Range(1)
 -0.10 to 11.95 -0.25 to 11.15
Weighted average3.963.14
Non-U.S. postretirement plans
Range1.05 to 10.000.80 to 8.55
Weighted average8.287.42
Future compensation increase rate(2)
Non-U.S. pension plans
Range1.30 to 11.251.20 to 11.25
Weighted average3.103.10
Expected return on assets
U.S. plans
Qualified pension5.005.80
Postretirement(3)
5.00/1.505.80/1.50
Non-U.S. pension plans
Range0.00 to 11.500.00 to 11.50
Weighted average3.693.39
Non-U.S. postretirement plans
Range6.00 to 8.005.95 to 8.00
Weighted average7.997.99

(1)Reflects rates utilized to determine the quarterly expense for Significant non-U.S. pension and postretirement plans.
(2)Due to substantial downward movement in yields, there were negative discount rates for plans with relatively short duration in major markets, such as the Eurozone and Switzerland.
(3)Not material for U.S. plans.
(4)The expected rate of return for the U.S. pension and postretirement plans was lowered from 6.80% to 6.70% effective in the second quarter of 2018 to reflect a change in target asset allocation.
(5)In 2017, the VEBA Trust was funded with an expected rate of return on assets of 3.00%.
(1)    Due to historically low global interest rates, there were negative discount rates for plans with relatively short duration in certain major markets, such as the Eurozone and Switzerland.
(2)    Not material for U.S. plans.
(3)    For the years ended 2021 and 2020, the expected return on assets for the VEBA Trust was 1.50%.


During the year202120202019
Discount rate  
U.S. plans  
Qualified pension2.45%/3.10%/ 2.75%/2.80%3.25%/3.20%/ 2.60%/2.55%4.25%/3.85%/ 3.45%/3.10%
Nonqualified pension2.35/3.00/ 2.70/2.753.25/3.25/ 2.55/2.504.25/3.90/ 3.50/3.10
Postretirement2.20/2.85/ 2.60/2.653.15/3.20/ 2.45/2.354.20/3.80/ 3.35/3.00
Non-U.S. pension plans(1)
Range(2)
-0.25 to 11.15 -0.10 to 11.30-0.05 to 12.00
Weighted average3.143.654.47
Non-U.S. postretirement plans(1)
Range0.80 to 9.800.90 to 9.751.75 to 10.75
Weighted average7.427.769.05
Future compensation increase rate(3)
Non-U.S. pension plans(1)
Range1.20 to 11.251.50 to 11.501.30 to 13.67
Weighted average3.103.173.16
Expected return on assets
U.S. plans
Qualified pension(4)
5.80/5.60/5.60/5.006.706.70
Postretirement(4)
5.80/1.506.70/3.006.70/3.00
Non-U.S. pension plans(1)
Range0.00 to 11.500.00 to 11.501.00 to 11.50
Weighted average3.393.954.30
Non-U.S. postretirement plans(1)
Range5.95 to 8.006.20 to 8.008.00 to 9.20
Weighted average7.997.998.01

(1)    Reflects rates utilized to determine the quarterly expense for Significant non-U.S. pension and postretirement plans.
(2)    Due to historically low global interest rates, there were negative discount rates for plans with relatively short duration in certain 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 5.80% to 5.60% effective April 1, 2021 and to 5.00% effective October 1, 2021 to reflect the change in target asset allocation.



174


Discount Rate
The discount rates for the U.S. pension and postretirement plans were selected by reference to a Citigroup-specific analysis using each plan’s specific cash flows and compared with high-quality corporate bond indices for reasonableness. The discount rates for the non-U.S. pension and postretirement plans are selected by reference to high-quality corporate bond rates in countries that have developed corporate bond markets. However, where developed corporate bond markets do not exist, the discount rates are selected by reference to local government bond rates with a premium added to reflect the additional risk for corporate bonds in certain countries.
Effective December 31, 2019, the established rounding convention is to the nearest 5 bps for all countries.

Expected Rate of Return on Assets
The Company determines its assumptions for the expected rate of return on plan assets for its U.S. pension and postretirement plans using a “building block” approach, which focuses on ranges of anticipated rates of return for each asset class. A weighted average range of nominal rates is then determined based on target allocations to each asset class. Market performance over a number of earlier years is evaluated covering a wide range of economic conditions to determine whether there are sound reasons for projecting any past trends.
The Company considers the expected rate of return 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 rate of return for the U.S. pension and postretirement plans was 6.70% at December 31, 2019 and 2018 and 6.80% at December 31, 2017. The expected return on assets reflects the expected annual appreciation of the plan assets and reduces the Company’s annual pension expense. The expected return on assets is deducted from the sum of service cost, interest cost and other components of pension expense to arrive at the net pension (benefit) expense.
The following table shows the expected rates of return on assets used in determining the Company’s pension expense compared to the actual rate of return on plan assets during 2019, 20182021, 2020 and 20172019 for the U.S. pension and postretirement plans:

U.S. plans
(During the year)
202120202019
Expected return on assets
U.S. pension and postretirement trust5.80%/5.60%/5.60%/5.00%6.70%6.70%
VEBA trust1.503.003.00
Actual return on assets(1)
U.S. pension and postretirement trust5.1412.8415.20
VEBA trust1.522.111.91 to 2.76

(1)Actual return on assets is presented net of fees.


 U.S. plans201920182017
Expected rate of return


U.S. pension and postretirement trust6.70%6.80%/6.70%6.80%
VEBA trust(1)
3.003.003.00
Actual rate of return(2)



U.S. pension and postretirement trust15.20-3.4010.90
VEBA trust(1)
1.91 to 2.760.43 to 1.41
(1)In December 2017, the VEBA Trust was funded for postretirement benefits with an expected rate of return on assets of 3.00%.
(2)Actual rates of return are presented net of fees.

For the non-U.S. pension plans, pension expense for 2019 was reduced by the expected return of $281 million, compared with the actual return of $781 million. Pension expense for 2018 and 2017 was reduced by expected returns of $291 million and $299 million, respectively.

Mortality Tables
At December 31, 2019, the Company adopted the Private Retirement Plans (PRI-2012) mortality table and the Mortality Projection 2019 (MP-2019) projection table for the U.S. plans.
 U.S. plans
2019(1)
2018(2)
Mortality
PensionPRI-2012/MP-2019RP-2014/MP-2018
PostretirementPRI-2012/MP-2019RP-2014/MP-2018

(1)The PRI-2012 table is the white-collar PRI-2012 table. The MP-2019 projection scale is projected from 2012, with convergence to 0.75% ultimate rate of annual improvement by 2035.
(2)The RP-2014 table is the white-collar RP-2014 table. The MP-2018 projection scale is projected from 2006, with convergence to 0.75% ultimate rate of annual improvement by 2034.


Sensitivities of Certain Key Assumptions
The following tables summarize the effect on pension expense:
 Discount rate
 One-percentage-point increase
In millions of dollars201920182017
U.S. plans$28
$25
$29
Non-U.S. plans(19)(22)(27)
 One-percentage-point decrease
In millions of dollars201920182017
U.S. plans$(44)$(37)$(44)
Non-U.S. plans32
32
41

Discount rate
 One-percentage-point increase
In millions of dollars202120202019
U.S. plans$35 $34 $28 
Non-U.S. plans(4)(16)(19)
 One-percentage-point decrease
In millions of dollars202120202019
U.S. plans$(49)$(52)$(44)
Non-U.S. plans25 25 32 

The U.S. Qualified Pension Plan was frozen in 2008, and as a result, most service cost hascosts 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 rate of returnExpected return on assets
One-percentage-point increase One-percentage-point increase
In millions of dollars201920182017In millions of dollars202120202019
U.S. plans$(123)$(126)$(127)U.S. plans$(124)$(123)$(123)
Non-U.S. plans(64)(64)(64)Non-U.S. plans(70)(66)(64)
One-percentage-point decrease One-percentage-point decrease
In millions of dollars201920182017In millions of dollars202120202019
U.S. plans$123
$126
$127
U.S. plans$124 $123 $123 
Non-U.S. plans64
64
64
Non-U.S. plans70 66 64 

175


Health Care Cost Trend Rate
Assumed health care cost trend rates were as follows:
 20192018
Health care cost increase rate for 
  U.S. plans
  
Following year6.75%7.00%
Ultimate rate to which cost increase is
  assumed to decline
5.005.00
Year in which the ultimate rate is
reached
20272027
   
Health care cost increase rate for 
  Non-U.S. plans (weighted average)
  
Following year6.85%6.90%
Ultimate rate to which cost increase is
  assumed to decline
6.856.90
Year in which the ultimate rate
  is reached
20202019


 20212020
Health care cost increase rate for 
U.S. plans
  
Following year6.25%6.50%
Ultimate rate to which cost increase is assumed to decline5.005.00
Year in which the ultimate rate is
reached
20272027
Health care cost increase rate for 
non-U.S. plans (weighted average)
  
Following year6.92%6.85%
Ultimate rate to which cost increase is
assumed to decline
6.926.85
Year in which the ultimate rate
is reached
20222021
Interest Crediting Rate
The Company has cash balance plans and other plans with promised interest crediting rates. For these plans, the interest crediting rates are set in line with plan rules or country legislation and do not change with market conditions.

 Weighted average interest crediting rate
At year end201920182017
U.S. plans2.25%3.25%2.60%
Non-U.S. plans1.611.681.74

Weighted average interest crediting rate
At year end202120202019
U.S. plans1.80%1.45%2.25%
Non-U.S. plans1.611.601.61



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:

Target asset
allocation
U.S. pension assets
at December 31,
U.S. postretirement assets
at December 31,
Target asset
allocation
U.S. pension assets
at December 31,
U.S. postretirement assets
at December 31,
Asset category(1)
20202019201820192018
Asset category(1)
20222021202020212020
Equity securities(2)
0–26%17%15%17%15%
Equity securities(2)
0–22%7 %16 %7 %16 %
Debt securities(3)
35–8258
57
58
57
Debt securities(3)
55–11472 59 72 59 
Real estate0–74
5
4
5
Real estate0–42 2 
Private equity0–103
3
3
3
Private equity0–56 6 
Other investments0–3018
20
18
20
Other investments0–2313 18 13 18 
Total 100%100%100%100%Total 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 2019 and 2018.
(3)The VEBA Trust for postretirement benefits are primarily invested in cash equivalents and debt securities in 2019 and 2018, respectively, and are not reflected in the table above.

(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 2021 and 2020.
(3)The VEBA Trust for postretirement benefits is primarily invested in cash equivalents and debt securities in 2021 and 2020 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:
 Non-U.S. pension plans
 Target asset
allocation
Actual range
at December 31,
Weighted-average
at December 31,
Asset category(1)
20222021202020212020
Equity securities0–100%0–100%0–100%16 %15 %
Debt securities0–1000–1000–10076 77 
Real estate0–150–140–121 
Other investments0–1000–1000–1007 
Total100 %100 %
 Non-U.S. pension plans
 
Target asset
allocation
Actual range
at December 31,
Weighted-average
at December 31,
Asset category(1)
20202019201820192018
Equity securities0–100%0–100%0–66%13%13%
Debt securities0–1000–1000–10080
80
Real estate0–150–150–121
1
Other investments0–1000–1000–1006
6
Total


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.

(1)Similar to the U.S. plans, asset allocations for certain non-U.S. plans are set by investment strategy, not by investment product.
 Non-U.S. postretirement plans
 
Target asset
allocation
Actual range
at December 31,
Weighted-average
at December 31,
Asset category(1)
20202019201820192018
Equity securities0–38%0–31%0–35%27%35%
Debt securities56–10066–10062–10071
62
Other investments0–60–30–32
3
Total


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.


176



 Non-U.S. postretirement plans
 Target asset
allocation
Actual range
at December 31,
Weighted-average
at December 31,
Asset category(1)
20222021202020212020
Equity securities0–42%0–42%0–38%41 %38 %
Debt securities54–10053–10056–10053 56 
Other investments0–40–60–66 
Total100 %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. ASU 2015-07 removed the requirement to categorize within the fair value hierarchy investments for which fair value isInvestments measured using the NAV per share practical expedient.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:

U.S. pension and postretirement benefit plans(1)
U.S. pension and postretirement benefit plans(1)
In millions of dollarsFair value measurement at December 31, 2019In millions of dollarsFair value measurement at December 31, 2021
Asset categoriesLevel 1Level 2Level 3TotalAsset categoriesLevel 1Level 2Level 3Total
U.S. equities

$739
$
$
$739
U.S. equities$358 $ $ $358 
Non-U.S. equities

553


553
Non-U.S. equities460   460 
Mutual funds and other registered investment companies

280


280
Mutual funds and other registered investment companies297   297 
Commingled funds


1,410

1,410
Commingled funds 1,143  1,143 
Debt securities

1,534
4,046

5,580
Debt securities1,657 5,770  7,427 
Annuity contracts

1
1
Annuity contracts  4 4 
Derivatives10
245

255
Derivatives2 17  19 
Other investments

75
75
Other investments13  25 38 
Total investments$3,116
$5,701
$76
$8,893
Total investments$2,787 $6,930 $29 $9,746 
Cash and short-term investments$93
$1,080
$
$1,173
Cash and short-term investments$635 $75 $ $710 
Other investment liabilities(87)(249)
(336)Other investment liabilities(7)(17) (24)
Net investments at fair value$3,122
$6,532
$76
$9,730
Net investments at fair value$3,415 $6,988 $29 $10,432 
Other investment receivables redeemed at NAV $22
Other investment liabilities redeemed at NAVOther investment liabilities redeemed at NAV$(87)
Securities valued at NAV 3,310
Securities valued at NAV2,951 
Total net assets $13,062
Total net assets$13,296 
(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.

(1)The investments of the U.S. pension and postretirement plans are commingled in one trust. At December 31, 2021, 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.
177


 
U.S. pension and postretirement benefit plans(1)
In millions of dollarsFair value measurement at December 31, 2018
Asset categoriesLevel 1Level 2Level 3Total
U.S. equities

$625
$
$
$625
Non-U.S. equities

481


481
Mutual funds and other registered investment companies


215


215
Commingled funds
1,344

1,344
Debt securities1,346
3,443

4,789
Annuity contracts

1
1
Derivatives16
252

268
Other investments

127
127
Total investments$2,683
$5,039
$128
$7,850
Cash and short-term investments$93
$897
$
$990
Other investment liabilities(100)(254)
(354)
Net investments at fair value$2,676
$5,682
$128
$8,486
Other investment receivables redeemed at NAV   $80
Securities valued at NAV    3,269
Total net assets   $11,835
(1)The investments of the U.S. pension and postretirement plans are commingled in one trust. At December 31, 2018, the allocable interests of the U.S. pension and postretirement plans were 98.0% and 2.0%, respectively. The investments of the VEBA Trust for postretirement benefits are reflected in the above table.

U.S. pension and postretirement benefit plans(1)
In millions of dollarsFair value measurement at December 31, 2020
Asset categoriesLevel 1Level 2Level 3Total
U.S. equities$813 $— $— $813 
Non-U.S. equities725 — — 725 
Mutual funds and other registered investment companies447 — — 447 
Commingled funds— 1,056 — 1,056 
Debt securities1,275 4,430 — 5,705 
Annuity contracts— — 
Derivatives— 14 
Other investments16 — 57 73 
Total investments$3,284 $5,492 $58 $8,834 
Cash and short-term investments$72 $1,035 $— $1,107 
Other investment liabilities(2)(10)— (12)
Net investments at fair value$3,354 $6,517 $58 $9,929 
Other investment receivables redeemed at NAV$99 
Securities valued at NAV 3,612 
Total net assets$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.
Non-U.S. pension and postretirement benefit plansNon-U.S. pension and postretirement benefit plans
In millions of dollarsFair value measurement at December 31, 2019In millions of dollarsFair value measurement at December 31, 2021
Asset categoriesLevel 1Level 2Level 3TotalAsset categoriesLevel 1Level 2Level 3Total
U.S. equities$4
$12
$
$16
U.S. equities$127 $19 $ $146 
Non-U.S. equities127
262

389
Non-U.S. equities713 92  805 
Mutual funds and other registered investment companies3,223
63

3,286
Mutual funds and other registered investment companies2,888 66  2,954 
Commingled funds23


23
Commingled funds21   21 
Debt securities4,307
1,615
10
5,932
Debt securities4,263 1,341  5,604 
Real estate
3
1
4
Real estate 3 2 5 
Annuity contracts

5
5
Annuity contracts  2 2 
Derivatives
1,590

1,590
Derivatives 239  239 
Other investments1

274
275
Other investments  318 318 
Total investments$7,685
$3,545
$290
$11,520
Total investments$8,012 $1,760 $322 $10,094 
Cash and short-term investments$86
$3
$
$89
Cash and short-term investments$117 $5 $ $122 
Other investment liabilities(3)(2,938)
(2,941)Other investment liabilities (1,578) (1,578)
Net investments at fair value$7,768
$610
$290
$8,668
Net investments at fair value$8,129 $187 $322 $8,638 
Securities valued at NAV  $15
Securities valued at NAV $19 
Total net assets $8,683
Total net assets$8,657 
 
 Non-U.S. pension and postretirement benefit plans
In millions of dollarsFair value measurement at December 31, 2018
Asset categoriesLevel 1Level 2Level 3Total
U.S. equities$4
$9
$
$13
Non-U.S. equities100
100

200
Mutual funds and other registered investment companies

2,887
63

2,950
Commingled funds21


21
Debt securities5,145
1,500
9
6,654
Real estate
3
1
4
Annuity contracts
1
10
11
Derivatives
156

156
Other investments1

210
211
Total investments$8,158
$1,832
$230
$10,220
Cash and short-term investments$91
$3
$
$94
Other investment liabilities(1)(2,589)
(2,590)
Net investments at fair value$8,248
$(754)$230
$7,724
Securities valued at NAV    $11
Total net assets   $7,735
178


Non-U.S. pension and postretirement benefit plans
In millions of dollarsFair value measurement at December 31, 2020
Asset categoriesLevel 1Level 2Level 3Total
U.S. equities$$16 $— $21 
Non-U.S. equities105 670 — 775 
Mutual funds and other registered investment companies3,137 73 — 3,210 
Commingled funds24 — — 24 
Debt securities6,705 1,420 — 8,125 
Real estate— 
Annuity contracts— — 
Derivatives— 1,005 — 1,005 
Other investments— — 312 312 
Total investments$9,976 $3,186 $319 $13,481 
Cash and short-term investments$129 $$— $132 
Other investment liabilities— (4,650)— (4,650)
Net investments at fair value$10,105 $(1,461)$319 $8,963 
Securities valued at NAV $14 
Total net assets$8,977 


179



Level 3 Rollforward
The reconciliations of the beginning and ending balances during the year for Level 3 assets are as follows:

In millions of dollarsIn millions of dollarsU.S. pension and postretirement benefit plans
Asset categoriesAsset categoriesBeginning Level 3 fair value at
Dec. 31, 2020
Realized (losses)Unrealized gainsPurchases, sales and issuancesTransfers in and/or out of Level 3Ending Level 3 fair value at
Dec. 31, 2021
Annuity contractsAnnuity contracts$$— $— $$— $4 
Other investmentsOther investments57 (6)(28)— 25 
In millions of dollarsU.S. pension and postretirement benefit plans
Asset categories
Beginning Level 3 fair value at
Dec. 31, 2018
Realized (losses)Unrealized gainsPurchases, sales and issuancesTransfers in and/or out of Level 3Ending Level 3 fair value at Dec. 31, 2019
Annuity contracts$1
$
$
$
$
$1
Other investments127
(7)12
(57)
75
Total investments$128
$(7)$12
$(57)$
$76
Total investments$58 $(6)$$(25)$— $29 
 

In millions of dollarsU.S. pension and postretirement benefit plans
Asset categoriesBeginning Level 3 fair value at
Dec. 31, 2019
Realized (losses)Unrealized (losses)Purchases, sales and
issuances
Transfers in and/or out of Level 3Ending Level 3 fair value at
Dec. 31, 2020
Annuity contracts$$— $— $— $— $
Other investments75 (3)(18)— 57 
Total investments$76 $(3)$$(18)$— $58 
In millions of dollarsU.S. pension and postretirement benefit plans In millions of dollarsNon-U.S. pension and postretirement benefit plans
Asset categories
Beginning Level 3 fair value at
Dec. 31, 2017
Realized (losses)Unrealized (losses)Purchases, sales and issuancesTransfers in and/or out of Level 3Ending Level 3 fair value at Dec. 31, 2018Asset categoriesBeginning Level 3 fair value at
Dec. 31, 2020
Unrealized gainsPurchases, sales and issuancesTransfers in and/or out of Level 3Ending Level 3
fair value at
Dec. 31, 2021
Debt securitiesDebt securities$— $— $— $— $ 
Real estateReal estate— — — 2 
Annuity contracts$1
$
$
$
$
$1
Annuity contracts— (3)— 2 
Other investments148
(2)(18)(1)
127
Other investments312 — 318 
Total investments$149
$(2)$(18)$(1)$
$128
Total investments$319 $$(1)$— $322 

 In millions of dollarsNon-U.S. pension and postretirement benefit plans
Asset categories
Beginning Level 3 fair value at
Dec. 31, 2018
Unrealized gainsPurchases, sales and issuancesTransfers in and/or out of Level 3Ending Level 3 fair value at Dec. 31, 2019
Debt securities$9
$1
$
$
$10
Real estate1



1
Annuity contracts10

(5)
5
Other investments210
7
57

274
Total investments$230
$8
$52
$
$290


 In millions of dollarsNon-U.S. pension and postretirement benefit plans
Asset categoriesBeginning Level 3 fair value at
Dec. 31, 2017
Unrealized (losses)Purchases, sales and issuancesTransfers in and/or out of Level 3
Ending Level 3 fair value at
Dec. 31, 2018
Non-U.S. equities$1
$
$
$(1)$
Debt securities7
(1)3

9
Real estate1



1
Annuity contracts9
(1)1
1
10
Other investments214
(3)(1)
210
Total investments$232
$(5)$3
$
$230


 In millions of dollarsNon-U.S. pension and postretirement benefit plans
Asset categoriesBeginning Level 3 fair value at
Dec. 31, 2019
Unrealized (losses)Purchases, sales and issuancesTransfers in and/or out of Level 3Ending Level 3
fair value at
Dec. 31, 2020
Debt securities$10 $— $(10)$— $— 
Real estate— — 
Annuity contracts— — — 
Other investments274 23 15 — 312 
Total investments$290 $24 $$— $319 



180



Investment Strategy
The Company’s global pension and postretirement funds’ investment strategy is to invest in a prudent manner for the exclusive purpose of providing benefits to participants. The investment strategies are targeted to produce a total return that, when combined with the Company’s contributions to the funds, will maintain the funds’ ability to meet all required benefit obligations. Risk is controlled through diversification of asset types and investments in domestic and international equities, fixed income securities and cash and short-term investments. The target asset allocation in most locations outside the U.S. is primarily in equity and debt securities. These allocations may vary by geographic region and country depending on the nature of applicable obligations and various other regional considerations. The wide variation in the actual range of plan asset allocations for the funded non-U.S. plans is a result of differing local statutory requirements and economic conditions. For example, in certain countries local law requires that all pension plan assets must be invested in fixed income investments, government funds or local-country securities.
 
Significant Concentrations of Risk in Plan Assets
The assets of the Company’s pension plans are diversified to limit the impact of any individual investment. The U.S. qualified pension plan is diversified across multiple asset classes, with publicly traded fixed income, hedge funds, publicly traded equity, 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 plansPostretirement benefit plans Pension plansPostretirement benefit plans
In millions of dollarsU.S. plansNon-U.S. plansU.S. plansNon-U.S. plansIn millions of dollarsU.S. plans
Non-U.S. plans(1)
U.S. plansNon-U.S. plans
2020$821
$476
$64
$75
2021840
434
63
80
2022851
464
61
85
2022$956 $958 $64 $71 
2023866
480
59
91
2023837 452 50 74 
2024873
495
57
97
2024844 460 47 78 
2025–20294,282
2,651
244
567
20252025846 462 44 82 
20262026838 467 41 86 
2027–20312027–20313,946 2,428 164 493 

(1)Estimated 2022 benefit payments have increased due to the wind-down of Citi’s consumer banking business in Korea, as it is expected that employees who elected the VERP plan will be withdrawing their pension plan assets. See Note 2 to the Consolidated Financial Statements for additional information.



181


Post Employment Plans
The Company sponsors U.S. post employment plans that provide income continuation and health and welfare benefits to certain eligible U.S. employees on long-term disability.
As of December 31, 2019 and 2018,The following table summarizes the plans’ funded status and amounts recognized inon the Company’s Consolidated Balance Sheet was $(38) million and $(32) million, respectively. The pretax amounts recognized in Sheet:

In millions of dollars20212020
Funded status of the plan at year end$(41)$(40)
Net amount recognized in AOCI (pretax)
$(15)$(17)
AOCI as of December 31, 2019 and 2018 were $(15) million and $(15) million, respectively.
The following table summarizes the components of net expense recognized in the Consolidated Statement of Income for the Company’s U.S. post employment plans:
 Net expense
In millions of dollars201920182017
Service-related expense 
 
 
Interest cost on benefit obligation$2
$2
$2
Expected return on plan assets(1)(1)
Amortization of unrecognized:   
   Prior service cost
(23)(31)
   Net actuarial loss2
2
2
Total service-related (benefit) expense$3
$(20)$(27)
Non-service-related expense (benefit)$6
$2
$30
Total net expense (benefit)$9
$(18)$3


In millions of dollars202120202019
Net expense$10 $$
The following table summarizes certain assumptions used in determining the post employment benefit obligations and net benefit expense for the Company’s U.S. post employment plans: 
 20192018
Discount rate2.90%3.95%
Expected return on assets3.003.00
Health care cost increase rate  
Following year6.757.00
Ultimate rate to which cost increase is assumed to decline5.005.00
Year in which the ultimate rate is reached20272027


Defined Contribution Plans
The Company sponsors defined contribution plans in the U.S. and in certain non-U.S. locations, all of which are administered in accordance with local laws. The most significant defined contribution plan is the Citi Retirement Savings Plan (formerly known as the Citigroup 401(k) Plan) sponsored by the Company in the U.S.
Under the Citi Retirement Savings Plan, eligible U.S. employees received matching contributions of up to 6% of their eligible compensation for 20192021 and 2018,2020, 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 dollars201920182017
Company contributions$404
$396
$383
    
 Non-U.S. plans
In millions of dollars201920182017
Company contributions$281
$283
$270


 U.S. plans
In millions of dollars202120202019
Company contributions$436 $414 $404 
 Non-U.S. plans
In millions of dollars202120202019
Company contributions$364 $304 $281 
182



9. INCOME TAXES

Income Tax Provision
Details of the Company’s income tax provision are presented below:

In millions of dollars201920182017In millions of dollars202120202019
Current 
 
 
Current 
Federal$365
$834
$332
Federal$522 $305 $365 
Non-U.S.4,352
4,290
3,910
Non-U.S.3,288 4,113 4,352 
State323
284
269
State228 440 323 
Total current income taxes$5,040
$5,408
$4,511
Total current income taxes$4,038 $4,858 $5,040 
Deferred 
 
 
Deferred 
Federal$(907)$(620)$24,902
Federal$1,059 $(1,430)$(907)
Non-U.S.10
371
(377)Non-U.S.8 (690)10 
State287
198
352
State346 (213)287 
Total deferred income taxes$(610)$(51)$24,877
Total deferred income taxes$1,413 $(2,333)$(610)
Provision for income tax on continuing operations before noncontrolling interests(1)
$4,430
$5,357
$29,388
Provision for income tax on continuing operations before noncontrolling interests(1)
$5,451 $2,525 $4,430 
Provision (benefit) for income taxes on discontinued operations(27)(18)7
Provision (benefit) for income taxes on discontinued operations — (27)
Income tax expense (benefit) reported in stockholders’ equity related to:  
 
Income tax expense (benefit) reported in stockholders’ equity related to: 
FX translation(11)(263)188
FX translation(146)23 (11)
Investment securities648
(346)(149)Investment securities(1,367)1,214 648 
Employee stock plans(16)(2)(4)Employee stock plans(6)(4)(16)
Cash flow hedges269
(8)(12)Cash flow hedges(476)455 269 
Benefit plans(119)(20)13
Benefit plans240 (23)(119)
FVO DVA(337)302
(250)FVO DVA64 (141)(337)
Excluded fair value hedges8
(17)
Excluded fair value hedges2 (8)
Retained earnings(2)
46
(305)(295)
Retained earnings(2)
 (911)46 
Income taxes before noncontrolling interests$4,891
$4,680
$28,886
Income taxes before noncontrolling interests$3,762 $3,130 $4,891 
(1)Includes the tax on realized investment gains and other-than-temporary-impairment losses resulting in a provision (benefit) of $373 million and $(9) million in 2019, $104 million and $(32) million in 2018 and $272 million and $(22) million in 2017, respectively.
(2)2019 reflects the tax effect of the accounting change for ASU 2016-02. 2018 reflects the tax effect of the accounting change for ASU 2016-16 and the tax effect of the accounting change for ASU 2018-03, to report the net unrealized gains on former AFS equity securities. 2017 reflects the tax effect of the accounting change for ASU 2017-08. See Note 1 to the Consolidated Financial Statements. 

(1)Includes the tax on realized investment gains and impairment losses resulting in a provision (benefit) of $169 million and $(57) million in 2021, $454 million and $(14) million in 2020 and $373 million and $(9) million in 2019, respectively.
(2)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.

 
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:

201920182017 202120202019
Federal statutory rate21.0 %21.0 %35.0 %Federal statutory rate21.0 %21.0 %21.0 %
State income taxes, net of federal benefit1.9
1.8
1.1
State income taxes, net of federal benefit2.1 1.3 1.9 
Non-U.S. income tax rate differential1.3
5.3
(1.6)Non-U.S. income tax rate differential1.6 3.5 1.3 
Effect of tax law changes(1)
(0.5)(0.6)99.7
Basis difference in affiliates(0.1)(2.4)(2.1)
Nondeductible FDIC premiumsNondeductible FDIC premiums0.6 1.3 0.4 
Tax advantaged investments(2.3)(2.0)(2.2)Tax advantaged investments(2.3)(4.4)(2.3)
Valuation allowance releases(2)
(3.0)

Valuation allowance releases(1)
Valuation allowance releases(1)
(1.7)(4.4)(3.0)
Other, net0.2
(0.3)(0.8)Other, net(1.5)0.2 (0.8)
Effective income tax rate18.5 %22.8 %129.1 %Effective income tax rate19.8 %18.5 %18.5 %
(1)2018 includes one-time Tax Reform benefits of $94 million for amounts that were considered provisional pursuant to SAB 118. 2017 includes the one-time $22,594 million charge for Tax Reform.
(2)See the Deferred Tax Assets section below for a description of the components.

(1)See “Deferred Tax Assets” below for a description of the components.

As set forth in the table above, Citi’s effective tax rate for 20192021 was 19.8%, compared to 18.5%. The rate is lower than the 22.8% reported in 2018,2020, primarily due to the general basket FTCreduced effect of permanent differences, including the valuation allowance release.releases, on a much higher level of pretax income.

Deferred Income Taxes
Deferred income taxes at December 31 related to the following:
In millions of dollars20192018
Deferred tax assets 
 
Credit loss deduction$3,809
$3,419
Deferred compensation and employee benefits2,224
1,975
Repositioning and settlement reserves345
428
U.S. tax on non-U.S. earnings1,030
2,080
Investment and loan basis differences2,727
4,891
Tax credit and net operating loss carry-forwards19,711
20,759
Fixed assets and leases2,607
1,006
Other deferred tax assets2,996
2,385
Gross deferred tax assets$35,449
$36,943
Valuation allowance$6,476
$9,258
Deferred tax assets after valuation allowance$28,973
$27,685
Deferred tax liabilities 
 
Intangibles and leases$(2,640)$(1,284)
Debt issuances(201)(530)
Non-U.S. withholding taxes(974)(1,040)
Interest-related items(587)(594)
Other deferred tax liabilities(1,477)(1,334)
Gross deferred tax liabilities$(5,879)$(4,782)
Net deferred tax assets$23,094
$22,903

In millions of dollars20212020
Deferred tax assets  
Credit loss deduction$5,330 $6,791 
Deferred compensation and employee benefits2,335 2,510 
U.S. tax on non-U.S. earnings1,138 1,195 
Investment and loan basis differences2,970 1,486 
Tax credit and net operating loss carry-forwards15,620 17,416 
Fixed assets and leases3,064 2,935 
Other deferred tax assets3,549 3,832 
Gross deferred tax assets$34,006 $36,165 
Valuation allowance$4,194 $5,177 
Deferred tax assets after valuation allowance$29,812 $30,988 
Deferred tax liabilities  
Intangibles and leases$(2,446)$(2,526)
Non-U.S. withholding taxes(987)(921)
Interest-related items (597)
Other deferred tax liabilities(1,590)(2,104)
Gross deferred tax liabilities$(5,023)$(6,148)
Net deferred tax assets$24,789 $24,840 

183


Unrecognized Tax Benefits
The following is a rollforward of the Company’s unrecognized tax benefits:
In millions of dollars201920182017
Total unrecognized tax benefits at January 1$607
$1,013
$1,092
Net amount of increases for current year’s tax positions50
40
43
Gross amount of increases for prior years’ tax positions151
46
324
Gross amount of decreases for prior years’ tax positions(44)(174)(246)
Amounts of decreases relating to settlements(21)(283)(199)
Reductions due to lapse of statutes of limitation(23)(23)(11)
Foreign exchange, acquisitions and dispositions1
(12)10
Total unrecognized tax benefits at December 31$721
$607
$1,013

In millions of dollars202120202019
Total unrecognized tax benefits at January 1$861 $721 $607 
Net amount of increases for current year’s tax positions97 51 50 
Gross amount of increases for prior years’ tax positions515 217 151 
Gross amount of decreases for prior years’ tax positions(107)(74)(44)
Amounts of decreases relating to settlements(64)(40)(21)
Reductions due to lapse of statutes of limitation(2)(13)(23)
Foreign exchange, acquisitions and dispositions(4)(1)
Total unrecognized tax benefits at December 31$1,296 $861 $721 
The portions of the total amounts of unrecognized tax benefits at December 31, 2019, 20182021, 2020 and 20172019 that, if recognized, would affect Citi’s tax expense are $0.6$1.0 billion, $0.4$0.7 billion and $0.8$0.6 billion, respectively. The remaining uncertain tax positions have offsetting amounts in other jurisdictions or are temporary differences.
Interest and penalties (not included in “unrecognizedunrecognized tax benefits”benefits above) are a component of Provision for income taxes
 202120202019
In millions of dollarsPretaxNet of taxPretaxNet of taxPretaxNet of tax
Total interest and penalties on the Consolidated Balance Sheet at January 1$118 $96 $100 $82 $103 $85 
Total interest and penalties in the Consolidated Statement of Income32 24 14 10 (4)(4)
Total interest and penalties on the Consolidated Balance Sheet at December 31(1)
214 164 118 96 100 82 

(1)Includes $3 million, $4 million and $3 million for non-U.S. penalties in 2021, 2020 and 2019, respectively. Also includes $0 million, $1 million and $1 million for state penalties in 2021, 2020 and 2019, respectively.
 201920182017
In millions of dollarsPretaxNet of taxPretaxNet of taxPretaxNet of tax
Total interest and penalties on the Consolidated Balance Sheet at January 1$103
$85
$121
$101
$260
$164
Total interest and penalties in the Consolidated Statement of Income(4)(4)6
6
5
21
Total interest and penalties on the Consolidated Balance Sheet at December 31(1)
100
82
103
85
121
101
(1)Includes $3 million, $2 million and $3 million for non-U.S. penalties in 2019, 2018 and 2017. Also includes $1 million, $1 million and $3 million for state penalties in 2019, 2018 and 2017.

As of December 31, 2019,2021, Citi was under audit by the Internal Revenue Service and other major taxing jurisdictions around the world. It is thus reasonably possible that significant changes in the gross balance of unrecognized tax benefits may occur within the next 12 months, although Citi does not expect such audits to result inmonths. The potential range of amounts that would cause a significant change to itscould affect Citi’s effective tax rate.rate is between $0 and $500 million.
The following are the major tax jurisdictions in which the Company and its affiliates operate and the earliest tax year subject to examination:

JurisdictionTax year
United States2016
Mexico2016
New York State and City2009
United Kingdom2016
India2017
JurisdictionSingaporeTax year2019
United StatesHong Kong20162015
MexicoIreland2014
New York State and City2009
United Kingdom2015
India2016
Singapore2011
Hong Kong2013
Ireland20152017


Non-U.S. Earnings
Non-U.S. pretax earnings approximated $12.9 billion in 2021, $13.8 billion in 2020 and $16.7 billion in 2019, $16.1 billion in 2018 and $13.7 billion in 2017.2019. As a U.S. corporation, Citigroup and its U.S. subsidiaries are currently subject to U.S. taxation on all non-U.S. pretax earnings of non-U.S. branches. Beginning in 2018, there is a separate foreign tax credit (FTC) basket for branches. Also, dividends from a non-U.S. subsidiary or affiliate are effectively exempt from U.S. taxation. The Company provides income taxes on the book over tax basis differences of non-U.S. subsidiaries except to the extent that such differences are indefinitely reinvested outside the U.S.
At December 31, 2019, $10.92021, $6.5 billion of basis differences of non-U.S. entities was indefinitely invested compared to $15.5 billion at December 31, 2018.invested. At the existing tax rates (including withholding taxes), additional taxes (net of U.S. FTCs)FTCs and valuation allowances) of $4.1$1.8 billion would have to be provided if such assertions were reversed. The decrease of $4.6 billion in basis differences from the prior year end was primarily due to a tax election to treat a contiguous country affiliate as a branch rather than a subsidiary.
Income taxes are not provided for the Company’s “savings bank base year bad debt reserves” that arose before 1988, because under current U.S. tax rules, such taxes will become payable only to the extent that such amounts are distributed in excess of limits prescribed by federal law. At December 31, 2019,2021, the amount of the base year reserves

totaled approximately $358 million (subject to a tax of $75 million).
184


Deferred Tax Assets
As of December 31, 2019,2021, Citi had a valuation allowance of $6.5$4.2 billion, composed of valuation allowances of $4.6$0.8 billion on its general basket FTC carry-forwards, $0.8$1.7 billion on its branch basket FTC carry-forwards, $1.0 billion on its U.S. residual DTA related to its non-U.S. branches, $1.0$0.6 billion on local non-U.S. DTAs and $0.1 billion on state net operating loss carry-forwards. The valuation allowance against FTCs resultsThere was a decrease of $1.0 billion from the impactDecember 31, 2020 balance of $5.2 billion. The amount of Citi’s valuation allowances (VA) may change in future years.
In 2021, Citi’s VA for carry-forward FTCs in its branch basket decreased by $0.7 billion and the related VA for the U.S. tax effect on non-U.S. branch temporary differences was unchanged. Of this total branch-related change of $0.7 billion, $0.3 billion impacted the tax provision as discussed below. The remainder of the lowerbranch basket-related VA decrease of $0.4 billion was primarily due to carry-forward expirations.
The level of branch pretax income, the local branch tax rate and the new separate FTCallocations of overall domestic losses (ODL) and expenses for U.S. tax purposes to the branch basket forare the main factors in determining the branch VA. The allocated ODL was enhanced by significant taxable income generated in the current year. In addition, the global interest rate environment and balance sheet requirements in non-U.S. branches resulted in a lower relative allocation of interest expense to non-U.S. branches. The absolute amountcombination of the factors enumerated resulted in a VA release of $0.2 billion in Citi’s post-Tax Reform-related valuation allowances may change in future years. First, the separate FTC basket for non-U.S. branches may result in additional DTAs (for FTCs) requiring a valuation allowance, given that the localfull-year effective tax rate for these branches exceeds on average the U.S. tax rate of 21%, offset by expirations of carry-forwards. The valuation allowance for therate. Citi also released branch basket FTCs was reduced from $4.4VA of $0.1 billion with respect to $3.5 billion, primarilyfuture years, based upon Citi’s Operating Plan and estimates of future branch basket factors, as a result of the expiration of the 2009 FTC carry-forward.outlined above.
Second, inIn Citi’s general basket for FTCs, changes in the forecasted amount of income in U.S. locations derived from sources outside the U.S., as well as actions that Citi may be able to take to enhance such income, in addition to tax examination changes from prior years, could alter the amount of valuation allowanceVA that is needed against such FTCs. The valuation allowanceVA for the general basket decreased from $1.6by $0.2 billion to $1.1 billion. $0.8 billion, primarily due to audit adjustments. Citi continues to look for additional actions that may become prudent and feasible, taking into account client, regulatory and operational considerations.
The decrease consists of the following items. Citi committed to a plan to move a financing business involving non-U.S. clients and its associated funding to the U.S. The incremental foreign source income generated by this action over time will more-likely-than-not enable usage of FTC carry-forwards of $0.2 billion. In addition, Citi committed to a plan as part of the Company’s liquidity management program, to increase its ownership of certain types of non-U.S. securities and to hold such securities in its U.S. operations. The incremental foreign source income generated by this action will more-likely-than-not enable the usage of FTC carry-forwards of another $0.2 billion. The remainder of the decrease in the valuation allowance in the general basket was the result of other increases in foreign source income of $0.3 billion (of which $0.2 billion is considered discrete and $0.1 billion is related to changes in 2019 foreign source income), partially offset by an increase of $0.2 billion relating to prior years’ tax return adjustments that increased FTCs and the corresponding valuation allowance. The valuation allowanceVA for U.S. residual DTA related to its non-U.S. branches decreased from $1.7 billion to $0.8 billion primarily due to a tax election to convert a contiguous country subsidiary into a branch, which resulted in $0.9 billion of U.S. DTLs offsetting non-U.S local DTAs.was unchanged at $1.0 billion. In addition, the non-U.S. local valuation allowanceVA was reduced from $1.5 billion to $1.0 billion, primarily due to an expiration of NOL carry-forwards in a non-U.S. jurisdiction. unchanged at $0.6 billion.
The following table summarizes Citi’s DTAs:

In billions of dollars
Jurisdiction/component(1)
DTAs balance December 31, 2021DTAs balance December 31, 2020
U.S. federal(2)
  
Net operating losses (NOLs)(3)
$3.2 $3.0 
Foreign tax credits (FTCs)2.8 4.4 
General business credits (GBCs)4.5 3.6 
Future tax deductions and credits8.4 7.9 
Total U.S. federal$18.9 $18.9 
State and local 
New York NOLs$1.2 $1.5 
Other state NOLs0.2 0.1 
Future tax deductions1.8 1.7 
Total state and local$3.2 $3.3 
Non-U.S.  
NOLs$0.5 $0.6 
Future tax deductions2.2 2.0 
Total non-U.S.$2.7 $2.6 
Total$24.8 $24.8 

(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, 2021 were deferred tax liabilities of $2.7 billion that will reverse in the relevant carry-forward period and may be used to support the DTAs.
In billions of dollars  
Jurisdiction/component(1)
DTAs balance December 31, 2019DTAs balance December 31, 2018
U.S. federal(2)
 
 
Net operating losses (NOLs)(3)
$2.8
$2.6
Foreign tax credits (FTCs)6.3
6.8
General business credits (GBCs)2.5
1.0
Future tax deductions and credits6.2
6.7
Total U.S. federal$17.8
$17.1
State and local 
 
New York NOLs$1.7
$2.0
Other state NOLs0.2
0.2
Future tax deductions1.3
1.4
Total state and local$3.2
$3.6
Non-U.S. 
 
NOLs$0.5
$0.6
Future tax deductions1.6
1.6
Total non-U.S.$2.1
$2.2
Total$23.1
$22.9
(3)Consists of non-consolidated tax return NOL carry-forwards that are eventually expected to be utilized in Citigroup’s consolidated tax return. 
(1)All amounts are net of valuation allowances.
(2)Included in the net U.S. federal DTAs of $17.8 billion as of December 31, 2019 were deferred tax liabilities of $3.4 billion that will reverse in the relevant carry-forward period and may be used to support the DTAs.
(3)Consists of non-consolidated tax return NOL carry-forwards that are eventually expected to be utilized in Citigroup’s consolidated tax return. 


185


The following table summarizes the amounts of tax carry-forwards and their expiration dates: 

In billions of dollars
Year of expirationDecember 31, 2021December 31, 2020
U.S. tax return general basket foreign tax credit carry-forwards(1)
  
2022$0.5 $2.3 
20230.4 0.4 
20251.5 1.4 
20271.1 1.2 
Total U.S. tax return general basket foreign tax credit carry-forwards$3.5 $5.3 
U.S. tax return branch basket foreign tax credit carry-forwards(1)
  
2021$ $0.7 
20221.0 1.0 
20280.6 0.6 
20290.2 0.2 
Total U.S. tax return branch basket foreign tax credit carry-forwards$1.8 $2.5 
U.S. tax return general business credit carry-forwards
2032$0.4 $0.3 
20330.3 0.3 
20340.2 0.2 
20350.2 0.2 
20360.2 0.2 
20370.5 0.5 
20380.5 0.5 
20390.7 0.7 
20400.7 0.7 
20410.8 — 
Total U.S. tax return general business credit carry-forwards$4.5 $3.6 
U.S. subsidiary separate federal NOL carry-forwards  
2027$0.1 $0.1 
20280.1 0.1 
20300.3 0.3 
20331.6 1.5 
20342.0 2.0 
20353.3 3.3 
20362.1 2.1 
20371.0 1.0 
Unlimited carry-forward period4.6 3.9 
Total U.S. subsidiary separate federal NOL carry-forwards(2)
$15.1 $14.3 
New York State NOL carry-forwards(2)
  
2034$6.6 $8.1 
New York City NOL carry-forwards(2)
 
2034$7.2 $8.7 
Non-U.S. NOL carry-forwards(1)
  
Various$1.1 $1.2 

(1)Before valuation allowance.
(2)Pretax.

In billions of dollars 
Year of expirationDecember 31, 2019December 31, 2018
U.S. tax return general basket foreign tax credit carry-forwards(1)
 
 
2020$0.9
$2.0
20211.1
1.1
20222.4
2.4
20230.4
0.4
20251.4
1.4
20271.2
1.1
Total U.S. tax return general basket foreign tax credit carry-forwards$7.4
$8.4
U.S. tax return branch basket foreign tax credit carry-forwards(1)
 
 
2019$
$0.9
20200.7
0.6
20210.6
0.7
20221.0
0.9
20280.9
1.3
20290.3

Total U.S. tax return branch basket foreign tax credit carry-forwards$3.5
$4.4
U.S. tax return general business credit carry-forwards  
2033$0.3
$
20340.2

20350.2

20360.1
0.1
20370.5
0.4
20380.5
0.5
20390.7

Total U.S. tax return general business credit carry-forwards$2.5
$1.0
U.S. subsidiary separate federal NOL carry-forwards 
 
2027$0.1
$0.2
20280.1
0.1
20300.3
0.3
2032
0.1
20331.6
1.6
20342.0
2.1
20353.3
3.3
20362.1
2.1
20371.0
1.0
Unlimited carry-forward period3.0
1.7
Total U.S. subsidiary separate federal NOL carry-forwards(2)
$13.5
$12.5
New York State NOL carry-forwards(2)
 
 
2034$9.9
$11.7
New York City NOL carry-forwards(2)
 
 
2034$10.0
$11.5
Non-U.S. NOL carry-forwards(1)
 
 
Various$1.5
$2.0

(1)Before valuation allowance.
(2)Pretax.

The time remaining for utilization of the FTC component has shortened, given the passage of time. Although realization is not assured, Citi believes that the realization of the recognized net DTAs of $23.1$24.8 billion at December 31, 20192021 is more-likely-than-not, based upon expectations as to future taxable income in the jurisdictions in which the DTAs arise and consideration of available tax planning strategies (as defined in ASC 740, Income Taxes).
Citi believes theThe majority of Citi’s U.S. federal net operating loss carry-forward and all of its New York State and City NOLnet operating loss carry-forwards are subject to a carry-forward period of 20 yearsyears. This provides enough time to fully utilize the DTAs pertaining to thethese existing NOL carry-forwards. This is due to Citi’s forecast of sufficient U.S. taxable income and the fact thatbecause 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 lossesODL that Citi has incurred of approximately $39$15 billion as of December 31, 20192021 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 coversupport the realization of the FTC carry-forwards after valuation allowance.VA. As noted in the tables above, Citi’s FTC carry-forwards were $6.3$2.8 billion ($10.95.3 billion before valuation allowance)VA) as of December 31, 2019,2021, compared to $6.8$4.4 billion as of December 31, 2018.2020. Citi believes that it will more-likely-than-not 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,VA, after considering any FTCs produced in the tax return for such period, which must be used prior to any carry-forward utilization.

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 amounts202120202019
Earnings per common share
Income from continuing operations before attribution of noncontrolling interests$22,018 $11,107 $19,471 
Less: Noncontrolling interests from continuing operations73 40 66 
Net income from continuing operations (for EPS purposes)$21,945 $11,067 $19,405 
Loss from discontinued operations, net of taxes7 (20)(4)
Citigroup’s net income$21,952 $11,047 $19,401 
Less: Preferred dividends(1)
1,040 1,095 1,109 
Net income available to common shareholders$20,912 $9,952 $18,292 
Less: Dividends and undistributed earnings allocated to employee restricted and deferred shares
with rights to dividends, applicable to basic EPS
154 73 121 
Net income allocated to common shareholders for basic EPS$20,758 $9,879 $18,171 
Weighted-average common shares outstanding applicable to basic EPS (in millions)
2,033.0 2,085.8 2,249.2 
Basic earnings per share(2)
   
Income from continuing operations$10.21 $4.75 $8.08 
Discontinued operations (0.01)— 
Net income per share—basic$10.21 $4.74 $8.08 
Diluted earnings per share  
Net income allocated to common shareholders for basic EPS$20,758 $9,879 $18,171 
Add back: Dividends allocated to employee restricted and deferred shares with rights to dividends
that are forfeitable
31 30 33 
Net income allocated to common shareholders for diluted EPS$20,789 $9,909 $18,204 
Weighted-average common shares outstanding applicable to basic EPS (in millions)
$2,033.0 $2,085.8 $2,249.2 
Effect of dilutive securities
   Options(3)
 0.1 0.1 
   Other employee plans16.4 13.1 16.0 
Adjusted weighted-average common shares outstanding applicable to diluted EPS (in millions)(4)
2,049.4 2,099.0 2,265.3 
Diluted earnings per share(2)
Income from continuing operations$10.14 $4.73 $8.04 
Discontinued operations (0.01)— 
Net income per share—diluted$10.14 $4.72 $8.04 

(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 2021, there were no weighted-average options outstanding. During 2021, no significant options to purchase shares of common stock were outstanding. 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.
(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
In millions of dollars, except per share amounts201920182017
Earnings per common share   
Income from continuing operations before attribution of noncontrolling interests$19,471
$18,088
$(6,627)
Less: Noncontrolling interests from continuing operations66
35
60
Net income from continuing operations (for EPS purposes)$19,405
$18,053
$(6,687)
Loss from discontinued operations, net of taxes(4)(8)(111)
Citigroup's net income$19,401
$18,045
$(6,798)
Less: Preferred dividends(1)
1,109
1,174
1,213
Net income available to common shareholders$18,292
$16,871
$(8,011)
Less: Dividends and undistributed earnings allocated to employee restricted and deferred shares
with rights to dividends, applicable to basic EPS
121
200
37
Net income allocated to common shareholders for basic EPS$18,171
$16,671
$(8,048)
Weighted-average common shares outstanding applicable to basic EPS (in millions)
2,249.2
2,493.3
2,698.5
Basic earnings per share(2)
 
  
Income from continuing operations$8.08
$6.69
$(2.94)
Discontinued operations

(0.04)
Net income per share—basic$8.08
$6.69
$(2.98)
Diluted earnings per share 
   
Net income allocated to common shareholders for basic EPS$18,171
$16,671
$(8,048)
Add back: Dividends allocated to employee restricted and deferred shares with rights to dividends
that are forfeitable
33


Net income allocated to common shareholders for diluted EPS$18,204
$16,671
$(8,048)
Weighted-average common shares outstanding applicable to basic EPS (in millions)
$2,249.2
$2,493.3
$2,698.5
Effect of dilutive securities   
   Options(3)
0.1
0.1

   Other employee plans16.0
1.4

Adjusted weighted-average common shares outstanding applicable to diluted EPS (in millions)(4)
2,265.3
2,494.8
2,698.5
Diluted earnings per share(2)
   
Income from continuing operations$8.04
$6.69
$(2.94)
Discontinued operations

(0.04)
Net income per share—diluted$8.04
$6.68
$(2.98)
(1)See Note 20 to the Consolidated Financial Statements for the potential future impact of preferred stock dividends.
(2)Due to rounding, earnings per share on continuing operations and discontinued operations may not sum to earnings per share on net income.
(3)During 2019, no significant options to purchase shares of common stock were outstanding. During 2018 and 2017, weighted-average options to purchase 0.5 million and 0.8 million shares of common stock, respectively, were outstanding but not included in the computation of earnings per share because the weighted-average exercise prices of $145.69 and $204.80 per share, respectively, were anti-dilutive.
(4)Due to rounding, common shares outstanding applicable to basic EPS and the effect of dilutive securities may not sum to common shares outstanding applicable to diluted EPS.




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:
 December 31,December 31,
In millions of dollars20192018
Securities purchased under agreements to resell$169,874
$159,364
Deposits paid for securities borrowed81,448
111,320
Total(1)
$251,322
$270,684

December 31,
In millions of dollars20212020
Securities purchased under agreements to resell$236,252 $204,655 
Deposits paid for securities borrowed91,042 90,067 
Total, net(1)
$327,294 $294,722 
Allowance for credit losses on securities purchased and borrowed(2)
(6)(10)
Total, net of allowance$327,288 $294,712 
Securities loaned and sold under agreements to repurchase, at their respective carrying values, consisted of the following:
 December 31,December 31,
In millions of dollars20192018
Securities sold under agreements to repurchase$155,164
$166,090
Deposits received for securities loaned11,175
11,678
Total(1)
$166,339
$177,768

(1)
The above tables do not include securities-for-securities lending transactions of $6.3 billion and $15.9 billion at December 31, 2019 and 2018,
December 31,
In millions of dollars20212020
Securities sold under agreements to repurchase$174,255 $181,194 
Deposits received for securities loaned17,030 18,331 
Total, net(1)
$191,285 $199,525 

(1)     The above tables do not include securities-for-securities lending transactions of $3.6 billion and $6.8 billion at December 31, 2021 and 2020, 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.

Other assets and the obligation to return those securities as a liability within Brokerage payables.

The resale and repurchase agreements represent collateralized financing transactions. Citi executes these transactions primarily through its broker-dealer subsidiaries to facilitate customer matched-book activity and to efficiently fund a portion of Citi’s trading inventory. Transactions executed by Citi’s bank subsidiaries primarily facilitate customer financing activity.
To maintain reliable funding under a wide range of market conditions, including under periods of stress, Citi manages these activities by taking into consideration the quality of the underlying collateral and stipulating financing tenor. Citi manages the risks in its collateralized financing transactions by conducting daily stress tests to account for changes in capacity, tenors, haircut, collateral profile and client actions. In addition, Citi maintains counterparty diversification by establishing concentration triggers and assessing counterparty reliability and stability under stress.
It is the Company’s policy to take possession of the underlying collateral, monitor its market value relative to the amounts due under the agreements and, when necessary,
require prompt transfer of additional collateral in order to maintain contractual margin protection. For resale and repurchase agreements, when necessary, the Company posts additional collateral in order to maintain contractual margin protection.
Collateral typically consists of government and government-agency securities, corporate and municipal bonds, equities and mortgage- and other asset-backed securities.
The resale and repurchase agreements are generally documented under industry standard agreements that allow the prompt close-out of all transactions (including the liquidation of securities held) and the offsetting of obligations to return cash or securities by the non-defaulting party, following a payment default or other type of default under the relevant master agreement. Events of default generally include (i) failure to deliver cash or securities as required under the transaction, (ii) failure to provide or return cash or securities as used for margining purposes, (iii) breach of representation, (iv) cross-default to another transaction entered into among the parties, or, in some cases, their affiliates and (v) a repudiation of obligations under the agreement. The counterparty that receives the securities in these transactions is generally unrestricted in its use of the securities, with the exception of transactions executed on a tri-party basis, where the collateral is maintained by a custodian and operational limitations may restrict its use of the securities.
A substantial portion of the resale and repurchase agreements is recorded at fair value, as described in Notes 24 and 25 to the Consolidated Financial Statements. The remaining portion is carried at the amount of cash initially advanced or received, plus accrued interest, as specified in the respective agreements.
The securities borrowing and lending agreements also represent collateralized financing transactions similar to the resale and repurchase agreements. Collateral typically consists of government and government-agency securities and corporate debt and equity securities.
Similar to the resale and repurchase agreements, securities borrowing and lending agreements are generally documented under industry standard agreements that allow the prompt close-out of all transactions (including the liquidation of securities held) and the offsetting of obligations to return cash or securities by the non-defaulting party, following a payment default or other default by the other party under the relevant master agreement. Events of default and rights to use securities under the securities borrowing and lending agreements are similar to the resale and repurchase agreements referenced above.
A substantial portion of securities borrowing and lending agreements is recorded at the amount of cash advanced or received. The remaining portion is recorded at fair value as the Company elected the fair value option for certain securities borrowed and loaned portfolios, as described in Note 25 to the Consolidated Financial Statements. With respect to securities loaned, the Company receives cash collateral in an amount generally in excess of the market value of the securities loaned. The Company monitors the market value of securities borrowed and securities loaned on a daily basis and obtains or posts additional collateral in order to maintain contractual margin protection.
188


The enforceability of offsetting rights incorporated in the master netting agreements for resale and repurchase agreements, and securities borrowing and lending agreements, is evidenced to the extent that (i) a supportive legal opinion

has been obtained from counsel of recognized standing that provides the requisite level of certainty regarding the enforceability of these agreements and (ii) the exercise of rights by the non-defaulting party to terminate and close out transactions on a net basis under these agreements will not be stayed or avoided under applicable law upon an event of default including bankruptcy, insolvency or similar proceeding.
A legal opinion may not have been sought or obtained for certain jurisdictions where local law is silent or sufficiently ambiguous to determine the enforceability of offsetting rights or where adverse case law or conflicting regulation may cast doubt on the enforceability of such rights. In some jurisdictions and for some counterparty types, the insolvency
law for a particular counterparty type may be nonexistent or
unclear as overlapping regimes may exist. For example, this may be the case for certain sovereigns, municipalities, central banks and U.S. pension plans.
The following tables present the gross and net resale and repurchase agreements and securities borrowing and lending
agreements and the related offsetting amounts permitted under ASC 210-20-45. The tables also include amounts related to financial instruments that are not permitted to be offset under ASC 210-20-45, but would be eligible for offsetting to the extent that an event of default has occurred and a legal opinion supporting enforceability of the offsetting rights has been obtained. Remaining exposures continue to be secured by financial collateral, but the Company may not have sought or been able to obtain a legal opinion evidencing enforceability of the offsetting right.

 As of December 31, 2019
In millions of dollarsGross 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)
Securities purchased under agreements to resell$281,274
$111,400
$169,874
$134,150
$35,724
Deposits paid for securities borrowed90,047
8,599
81,448
27,067
54,381
Total$371,321
$119,999
$251,322
$161,217
$90,105

In millions of dollarsGross 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)
Securities sold under agreements to repurchase$266,564
$111,400
$155,164
$91,034
$64,130
Deposits received for securities loaned19,774
8,599
11,175
3,138
8,037
Total$286,338
$119,999
$166,339
$94,172
$72,167

 As of December 31, 2021
In millions of dollarsGross 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)
Securities purchased under agreements to resell$367,594 $131,342 $236,252 $205,349 $30,903 
Deposits paid for securities borrowed107,041 15,999 91,042 17,326 73,716 
Total$474,635 $147,341 $327,294 $222,675 $104,619 
In millions of dollarsGross 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)
Securities sold under agreements to repurchase$305,597 $131,342 $174,255 $85,184 $89,071 
Deposits received for securities loaned33,029 15,999 17,030 2,868 14,162 
Total$338,626 $147,341 $191,285 $88,052 $103,233 

 As of December 31, 2020
In millions of dollarsGross 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)
Securities purchased under agreements to resell$362,025 $157,370 $204,655 $159,232 $45,423 
Deposits paid for securities borrowed96,425 6,358 90,067 13,474 76,593 
Total$458,450 $163,728 $294,722 $172,706 $122,016 
189


As of December 31, 2018
In millions of dollarsGross 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)
In millions of dollarsGross 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)
Securities purchased under agreements to resell$246,788
$87,424
$159,364
$124,557
$34,807
Deposits paid for securities borrowed111,320

111,320
35,766
75,554
Securities sold under agreements to repurchaseSecurities sold under agreements to repurchase$338,564 $157,370 $181,194 $95,563 $85,631 
Deposits received for securities loanedDeposits received for securities loaned24,689 6,358 18,331 7,982 10,349 
Total$358,108
$87,424
$270,684
$160,323
$110,361
Total$363,253 $163,728 $199,525 $103,545 $95,980 

In millions of dollarsGross 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)
Securities sold under agreements to repurchase$253,514
$87,424
$166,090
$82,823
$83,267
Deposits received for securities loaned11,678

11,678
3,415
8,263
Total$265,192
$87,424
$177,768
$86,238
$91,530
(1)Includes financial instruments subject to enforceable master netting agreements that are permitted to be offset under ASC 210-20-45.

(2)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.
(1)Includes financial instruments subject to enforceable master netting agreements that are permitted to be offset under ASC 210-20-45.
(2)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.
(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:

As of December 31, 2021
In millions of dollarsOpen and overnightUp to 30 days31–90 daysGreater than 90 daysTotal
Securities sold under agreements to repurchase$127,679 $93,257 $32,908 $51,753 $305,597 
Deposits received for securities loaned23,387 6 1,392 8,244 33,029 
Total$151,066 $93,263 $34,300 $59,997 $338,626 
 As of December 31, 2019
In millions of dollarsOpen and overnightUp to 30 days31–90 daysGreater than 90 daysTotal
Securities sold under agreements to repurchase$108,534
$82,749
$35,108
$40,173
$266,564
Deposits received for securities loaned15,758
208
1,789
2,019
19,774
Total$124,292
$82,957
$36,897
$42,192
$286,338


As of December 31, 2020
In millions of dollarsOpen and overnightUp to 30 days31–90 daysGreater than 90 daysTotal
Securities sold under agreements to repurchase$160,754 $98,226 $41,679 $37,905 $338,564 
Deposits received for securities loaned17,038 2,770 4,878 24,689 
Total$177,792 $98,229 $44,449 $42,783 $363,253 
 As of December 31, 2018
In millions of dollarsOpen and overnightUp to 30 days31–90 daysGreater than 90 daysTotal
Securities sold under agreements to repurchase$108,405
$70,850
$29,898
$44,361
$253,514
Deposits received for securities loaned6,296
774
2,626
1,982
11,678
Total$114,701
$71,624
$32,524
$46,343
$265,192

The following tables present the gross amounts of liabilities associated with repurchase agreements and securities lending agreements by class of underlying collateral:
 As of December 31, 2019
In millions of dollarsRepurchase agreementsSecurities lending agreementsTotal
U.S. Treasury and federal agency securities$100,781
$27
$100,808
State and municipal securities1,938
5
1,943
Foreign government securities95,880
272
96,152
Corporate bonds18,761
249
19,010
Equity securities12,010
19,069
31,079
Mortgage-backed securities28,458

28,458
Asset-backed securities4,873

4,873
Other3,863
152
4,015
Total$266,564
$19,774
$286,338


As of December 31, 2021
In millions of dollarsRepurchase agreementsSecurities lending agreementsTotal
U.S. Treasury and federal agency securities$85,861 $90 $85,951 
State and municipal securities1,053  1,053 
Foreign government securities133,352 212 133,564 
Corporate bonds20,398 152 20,550 
Equity securities25,653 32,517 58,170 
Mortgage-backed securities33,573  33,573 
Asset-backed securities1,681  1,681 
Other4,026 58 4,084 
Total$305,597 $33,029 $338,626 
 As of December 31, 2018
In millions of dollarsRepurchase agreementsSecurities lending agreementsTotal
U.S. Treasury and federal agency securities$86,785
$41
$86,826
State and municipal securities2,605

2,605
Foreign government securities99,131
179
99,310
Corporate bonds21,719
749
22,468
Equity securities12,920
10,664
23,584
Mortgage-backed securities19,421

19,421
Asset-backed securities6,207

6,207
Other4,726
45
4,771
Total$253,514
$11,678
$265,192

190


As of December 31, 2020
In millions of dollarsRepurchase agreementsSecurities lending agreementsTotal
U.S. Treasury and federal agency securities$112,437 $— $112,437 
State and municipal securities664 666 
Foreign government securities130,017 194 130,211 
Corporate bonds20,149 78 20,227 
Equity securities21,497 24,149 45,646 
Mortgage-backed securities45,566 — 45,566 
Asset-backed securities3,307 — 3,307 
Other4,927 266 5,193 
Total$338,564 $24,689 $363,253 

191


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:

December 31,
In millions of dollars20212020
Receivables from customers, net$26,403 $18,097 
Receivables from brokers, dealers and clearing organizations27,937 26,709 
Total brokerage receivables(1)
$54,340 $44,806 
Payables to customers$52,158 $39,319 
Payables to brokers, dealers and clearing organizations9,272 11,165 
Total brokerage payables(1)
$61,430 $50,484 

(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.
 December 31,
In millions of dollars20192018
Receivables from customers$15,912
$14,415
Receivables from brokers, dealers and clearing organizations23,945
21,035
Total brokerage receivables(1)
$39,857
$35,450
Payables to customers$37,613
$40,273
Payables to brokers, dealers and clearing organizations10,988
24,298
Total brokerage payables(1)
$48,601
$64,571
192

(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.


13.  INVESTMENTS


The following table presents Citi’s investments by category:
 December 31,
In millions of dollars20192018
Debt securities AFS$280,265
$288,038
Debt securities HTM(1)
80,775
63,357
Marketable equity securities carried at fair value(2)
458
220
Non-marketable equity securities carried at fair value(2)
704
889
Non-marketable equity securities measured using the measurement alternative(3)
700
538
Non-marketable equity securities carried at cost(4)
5,661
5,565
Total investments$368,563
$358,607

December 31,
In millions of dollars20212020
Debt securities available-for-sale (AFS)$288,522 $335,084 
Debt securities held-to-maturity (HTM)(1)
216,963 104,943 
Marketable equity securities carried at fair value(2)
543 515 
Non-marketable equity securities carried at fair value(2)
489 551 
Non-marketable equity securities measured using the measurement alternative(3)
1,413 962 
Non-marketable equity securities carried at cost(4)
4,892 5,304 
Total investments$512,822 $447,359 

(1)Carried at adjusted amortized cost basis, net of any credit-related impairment.
(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.
(4)Primarily consists of shares issued by the Federal Reserve Bank, Federal Home Loan Banks and certain exchanges of which Citigroup is a member.
(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 dollars201920182017
Taxable interest$9,269
$8,704
$7,538
Interest exempt from U.S. federal income tax404
521
535
Dividend income187
269
222
Total interest and dividend income$9,860
$9,494
$8,295

In millions of dollars202120202019
Taxable interest$6,975 $7,554 $9,269 
Interest exempt from U.S. federal income tax279 301 404 
Dividend income134 134 187 
Total interest and dividend income on investments$7,388 $7,989 $9,860 

The following table presents realized gains and losses on the sales of investments, which exclude OTTIimpairment losses:
In millions of dollars201920182017
Gross realized investment gains$1,599
$682
$1,039
Gross realized investment losses(125)(261)(261)
Net realized gains on sale of investments$1,474
$421
$778



In millions of dollars202120202019
Gross realized investment gains$860 $1,895 $1,599 
Gross realized investment losses(195)(139)(125)
Net realized gains on sales of investments$665 $1,756 $1,474 
The Company from time to time may sell certain debt securities that were classified as HTM. These sales were in response to significant deterioration in the creditworthiness of the issuers or securities or because the Company has collected a substantial portion (at least 85%) of the principal outstanding at acquisition of the security. In addition, certain other debt securities were reclassified to AFS investments in
response to significant credit deterioration. Because the Company generally intends to sell these reclassified debt securities, Citi recorded OTTI on the securities. The following table presents, for the periods indicated, the carrying value of HTM debt securities sold and reclassified to AFS, as well as the related gain (loss) or the OTTI losses recorded on these securities:
In millions of dollars201920182017
Carrying value of HTM debt securities sold$
$61
$81
Net realized gain (loss) on sale of HTM debt securities

13
Carrying value of debt securities reclassified to AFS
8
74
OTTI losses on debt securities reclassified to AFS


193



Debt Securities Available-for-Sale
The amortized cost and fair value of AFS debt securities were as follows:

20192018 December 31, 2021December 31, 2020
In millions of dollars
Amortized
cost
Gross
unrealized
gains
Gross
unrealized
losses
Fair
value
Amortized
cost
Gross
unrealized
gains
Gross
unrealized
losses
Fair
value
In millions of dollarsAmortized
cost
Gross
unrealized
gains
Gross
unrealized
losses
Allowance for credit lossesFair
value
Amortized
cost
Gross
unrealized
gains
Gross
unrealized
losses
Allowance for credit lossesFair
value
Debt securities AFS   Debt securities AFS     
Mortgage-backed securities(1)
   
Mortgage-backed securities(1)
     
U.S. government agency guaranteed$34,963
$547
$280
$35,230
$43,504
$241
$725
$43,020
U.S. government-sponsored agency guaranteedU.S. government-sponsored agency guaranteed$33,064 $453 $301 $ $33,216 $42,836 $1,134 $52 $— $43,918 
Non-U.S. residential789
3

792
1,310
4
2
1,312
Non-U.S. residential380 1 1  380 568 — — 571 
Commercial75


75
174
1
2
173
Commercial25    25 49 — — 50 
Total mortgage-backed securities$35,827
$550
$280
$36,097
$44,988
$246
$729
$44,505
Total mortgage-backed securities$33,469 $454 $302 $ $33,621 $43,453 $1,138 $52 $— $44,539 
U.S. Treasury and federal agency securities   U.S. Treasury and federal agency securities
U.S. Treasury$106,429
$50
$380
$106,099
$109,376
$33
$1,339
$108,070
U.S. Treasury$122,669 $615 $844 $ $122,440 $144,094 $2,108 $49 $— $146,153 
Agency obligations5,336
3
20
5,319
9,283
1
132
9,152
Agency obligations     50 — — 51 
Total U.S. Treasury and federal agency securities$111,765
$53
$400
$111,418
$118,659
$34
$1,471
$117,222
Total U.S. Treasury
and federal agency securities
$122,669 $615 $844 $ $122,440 $144,144 $2,109 $49 $— $146,204 
State and municipal$5,024
$43
$89
$4,978
$9,372
$96
$262
$9,206
State and municipal$2,643 $79 $101 $ $2,621 $3,753 $123 $157 $— $3,719 
Foreign government110,958
586
241
111,303
100,872
415
596
100,691
Foreign government119,426 337 1,023  118,740 123,467 1,623 122 — 124,968 
Corporate11,266
52
101
11,217
11,714
42
157
11,599
Corporate5,972 33 77 8 5,920 10,444 152 91 10,500 
Asset-backed securities(1)
524

2
522
845
2
4
843
Asset-backed securities(1)
304  1  303 277 — 278 
Other debt securities4,729
1

4,730
3,973

1
3,972
Other debt securities4,880 1 4  4,877 4,871 — — 4,876 
Total debt securities AFS$280,093
$1,285
$1,113
$280,265
$290,423
$835
$3,220
$288,038
Total debt securities AFS$289,363 $1,519 $2,352 $8 $288,522 $330,409 $5,155 $475 $$335,084 
(1)The Company invests in mortgage- and asset-backed securities. These securitization entities are generally considered VIEs. The Company’s maximum exposure to loss from these VIEs is equal to the carrying amount of the securities, which is reflected in the table above. For mortgage- and asset-backed securitizations in which the Company has other involvement, see Note 21 to the Consolidated Financial Statements.

(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, 2019,2021, the amortized cost of fixed income securities exceeded their fair value by $1,113$2,352 million. Of the $1,113$2,352 million, $802$1,895 million represented unrealized losses on fixed income investments that have been in a gross-unrealized-loss position for less than a year and, of these, 93%77% were rated investment grade; and $311$457 million represented unrealized losses on fixed income investments that have been in a gross-unrealized-loss position for a year or more and, of these, 92%99% were rated investment grade. Of the $311$457 million, mentioned above, $132$197 million represents U.S. Treasuryforeign government securities.
    

194


The following table shows the fair value of AFS debt securities that have been in an unrealized loss position:
 Less than 12 months12 months or longerTotal
In millions of dollars
Fair
value
Gross
unrealized
losses
Fair
value
Gross
unrealized
losses
Fair
value
Gross
unrealized
losses
December 31, 2019      
Debt securities AFS      
Mortgage-backed securities      
U.S. government agency guaranteed$9,780
$242
$1,877
$38
$11,657
$280
Non-U.S. residential208

1

209

Commercial16

27

43

Total mortgage-backed securities$10,004
$242
$1,905
$38
$11,909
$280
U.S. Treasury and federal agency securities      
U.S. Treasury$45,484
$248
$26,907
$132
$72,391
$380
Agency obligations781
2
3,897
18
4,678
20
Total U.S. Treasury and federal agency securities$46,265
$250
$30,804
$150
$77,069
$400
State and municipal$362
$62
$266
$27
$628
$89
Foreign government35,485
149
8,170
92
43,655
241
Corporate2,916
98
123
3
3,039
101
Asset-backed securities112
1
166
1
278
2
Other debt securities1,307



1,307

Total debt securities AFS$96,451
$802
$41,434
$311
$137,885
$1,113
December 31, 2018 
 
 
 
 
 
Debt securities AFS

 
 
 
 
 
 
Mortgage-backed securities 
 
 
 
 
 
U.S. government agency guaranteed$11,160
$286
$13,143
$439
$24,303
$725
Non-U.S. residential284
2
2

286
2
Commercial79
1
82
1
161
2
Total mortgage-backed securities$11,523
$289
$13,227
$440
$24,750
$729
U.S. Treasury and federal agency securities 
 
 
 
 
 
U.S. Treasury$8,389
$42
$77,883
$1,297
$86,272
$1,339
Agency obligations277
2
8,660
130
8,937
132
Total U.S. Treasury and federal agency securities$8,666
$44
$86,543
$1,427
$95,209
$1,471
State and municipal$1,614
$34
$1,303
$228
$2,917
$262
Foreign government40,655
265
15,053
331
55,708
596
Corporate4,547
115
2,077
42
6,624
157
Asset-backed securities441
4
55

496
4
Other debt securities1,790
1


1,790
1
Total debt securities AFS$69,236
$752
$118,258
$2,468
$187,494
$3,220


 Less than 12 months12 months or longerTotal
In millions of dollarsFair
value
Gross
unrealized
losses
Fair
value
Gross
unrealized
losses
Fair
value
Gross
unrealized
losses
December 31, 2021      
Debt securities AFS      
Mortgage-backed securities      
U.S. government-sponsored agency guaranteed$17,039 $270 $698 $31 $17,737 $301 
Non-U.S. residential96 1 1  97 1 
Commercial      
Total mortgage-backed securities$17,135 $271 $699 $31 $17,834 $302 
U.S. Treasury and federal agency securities    
U.S. Treasury$56,448 $713 $6,310 $131 $62,758 $844 
Agency obligations      
Total U.S. Treasury and federal agency securities$56,448 $713 $6,310 $131 $62,758 $844 
State and municipal$229 $3 $874 $98 $1,103 $101 
Foreign government64,319 826 9,924 197 74,243 1,023 
Corporate2,655 77 22  2,677 77 
Asset-backed securities108 1   108 1 
Other debt securities3,439 4   3,439 4 
Total debt securities AFS$144,333 $1,895 $17,829 $457 $162,162 $2,352 
December 31, 2020      
Debt securities AFS      
Mortgage-backed securities      
U.S. government-sponsored agency guaranteed$3,588 $30 $298 $22 $3,886 $52 
Non-U.S. residential— — — — 
Commercial— — 11 — 
Total mortgage-backed securities$3,596 $30 $302 $22 $3,898 $52 
U.S. Treasury and federal agency securities 
U.S. Treasury$25,031 $49 $— $— $25,031 $49 
Agency obligations50 — — — 50 — 
Total U.S. Treasury and federal agency securities$25,081 $49 $— $— $25,081 $49 
State and municipal$836 $34 $893 $123 $1,729 $157 
Foreign government29,344 61 3,502 61 32,846 122 
Corporate1,083 90 24 1,107 91 
Asset-backed securities194 39 233 
Other debt securities182 — — — 182 — 
Total debt securities AFS$60,316 $267 $4,760 $208 $65,076 $475 


195


The following table presents the amortized cost and fair value of AFS debt securities by contractual maturity dates:

December 31,
 20212020
In millions of dollarsAmortized
cost
Fair
value
Weighted average yield(1)
Amortized
cost
Fair
value
Mortgage-backed securities(2)
    
Due within 1 year$188 $189 0.79 %$27 $27 
After 1 but within 5 years211 211 1.07 567 571 
After 5 but within 10 years523 559 3.41 688 757 
After 10 years32,547 32,662 2.73 42,171 43,184 
Total$33,469 $33,621 2.72 %$43,453 $44,539 
U.S. Treasury and federal agency securities    
Due within 1 year$34,321 $34,448 1.05 %$34,834 $34,951 
After 1 but within 5 years87,987 87,633 0.81 108,160 110,091 
After 5 but within 10 years361 359 1.42 1,150 1,162 
After 10 years   — — 
Total$122,669 $122,440 0.87 %$144,144 $146,204 
State and municipal    
Due within 1 year$40 $40 2.09 %$427 $428 
After 1 but within 5 years121 124 3.16 189 198 
After 5 but within 10 years156 161 3.18 276 267 
After 10 years2,326 2,296 3.15 2,861 2,826 
Total$2,643 $2,621 3.14 %$3,753 $3,719 
Foreign government    
Due within 1 year$49,263 $49,223 2.53 %$48,133 $48,258 
After 1 but within 5 years64,555 63,961 3.14 67,365 68,586 
After 5 but within 10 years3,736 3,656 1.72 5,908 6,011 
After 10 years1,872 1,900 1.52 2,061 2,113 
Total$119,426 $118,740 2.82 %$123,467 $124,968 
All other(3)
    
Due within 1 year$5,175 $5,180 0.94 %$6,661 $6,665 
After 1 but within 5 years5,177 5,149 1.91 7,814 7,891 
After 5 but within 10 years750 750 2.08 1,018 1,034 
After 10 years54 21 4.28 99 64 
Total$11,156 $11,100 1.48 %$15,592 $15,654 
Total debt securities AFS$289,363 $288,522 1.94 %$330,409 $335,084 

(1)Weighted average yields are weighted based on the amortized cost of each security. The average yield considers the contractual coupon, amortization of premiums and accretion of discounts and excludes the effects of any related hedging derivatives.
(2)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.
(3)Includes corporate, asset-backed and other debt securities.



196

 December 31,
 20192018
In millions of dollars
Amortized
cost
Fair
value
Amortized
cost
Fair
value
Mortgage-backed securities(1)
    
Due within 1 year$20
$20
$14
$14
After 1 but within 5 years573
574
662
661
After 5 but within 10 years594
626
2,779
2,828
After 10 years(2)
34,640
34,877
41,533
41,002
Total$35,827
$36,097
$44,988
$44,505
U.S. Treasury and federal agency securities    
Due within 1 year$40,757
$40,688
$41,941
$41,867
After 1 but within 5 years70,128
69,850
76,139
74,800
After 5 but within 10 years854
851
489
462
After 10 years(2)
26
29
90
93
Total$111,765
$111,418
$118,659
$117,222
State and municipal    
Due within 1 year$932
$932
$2,586
$2,586
After 1 but within 5 years714
723
1,676
1,675
After 5 but within 10 years195
215
585
602
After 10 years(2)
3,183
3,108
4,525
4,343
Total$5,024
$4,978
$9,372
$9,206
Foreign government    
Due within 1 year$42,611
$42,666
$39,078
$39,028
After 1 but within 5 years58,820
59,071
50,125
49,962
After 5 but within 10 years8,192
8,198
10,153
10,149
After 10 years(2)
1,335
1,368
1,516
1,552
Total$110,958
$111,303
$100,872
$100,691
All other(3)
    
Due within 1 year$7,306
$7,311
$6,166
$6,166
After 1 but within 5 years8,279
8,275
8,459
8,416
After 5 but within 10 years818
797
1,474
1,427
After 10 years(2)
116
86
433
405
Total$16,519
$16,469
$16,532
$16,414
Total debt securities AFS$280,093
$280,265
$290,423
$288,038

(1)Includes mortgage-backed securities of U.S. government-sponsored agencies.
(2)Investments with no stated maturities are included as contractual maturities of greater than 10 years. Actual maturities may differ due to call or prepayment rights.
(3)Includes corporate, asset-backed and other debt securities.


Debt Securities Held-to-Maturity

The carrying value and fair value of debt securities HTM were as follows:

In millions of dollars
Carrying
value
Gross
unrealized
gains
Gross
unrealized
losses
Fair
value
December 31, 2019    
Debt securities HTM    
Mortgage-backed securities(1)(2)
    
U.S. government agency guaranteed$46,637
$1,047
$21
$47,663
Non-U.S. residential1,039
5

1,044
Commercial582
1

583
Total mortgage-backed securities$48,258
$1,053
$21
$49,290
State and municipal(3)
$9,104
$455
$28
$9,531
Foreign government1,934
37
1
1,970
Asset-backed securities(1)
21,479
12
59
21,432
Total debt securities HTM$80,775
$1,557
$109
$82,223
December 31, 2018 
 
 
 
Debt securities HTM 
 
 
 
Mortgage-backed securities(1)(4)
 
 
 
 
U.S. government agency guaranteed$34,239
$199
$578
$33,860
Non-U.S. residential1,339
12
1
1,350
Commercial368


368
Total mortgage-backed securities$35,946
$211
$579
$35,578
State and municipal$7,628
$167
$138
$7,657
Foreign government1,027

24
1,003
Asset-backed securities(1)
18,756
8
112
18,652
Total debt securities HTM$63,357
$386
$853
$62,890
(1)The Company invests in mortgage- and asset-backed securities. These securitization entities are generally considered VIEs. The Company’s maximum exposure to loss from these VIEs is equal to the carrying amount of the securities, which is reflected in the table above. For mortgage- and asset-backed securitizations in which the Company has other involvement, see Note 21 to the Consolidated Financial Statements.
(2)
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.
(3)
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.
(4)
In November 2018, Citibank transferred $10 billion of agency residential mortgage-backed securities (RMBS) and commercial mortgage-backed securities (CMBS) from AFS classification to HTM classification in accordance with ASC 320. At the time of transfer, the securities were in an unrealized loss position of $598 million. This amount will remain in AOCI and be amortized over the remaining life of the securities.

In millions of dollars
Amortized
cost, net(1)
Gross
unrealized
gains
Gross
unrealized
losses
Fair
value
December 31, 2021    
Debt securities HTM    
Mortgage-backed securities(2)
    
U.S. government-sponsored agency guaranteed$63,885 $1,076 $925 $64,036 
Non-U.S. residential736 3  739 
Commercial1,070 4 2 1,072 
Total mortgage-backed securities$65,691 $1,083 $927 $65,847 
U.S. Treasury securities$111,819 $30 $1,632 $110,217 
State and municipal(3)
8,923 589 12 9,500 
Foreign government1,651 4 36 1,619 
Asset-backed securities(2)
28,879 8 32 28,855 
Total debt securities HTM, net$216,963 $1,714 $2,639 $216,038 
December 31, 2020    
Debt securities HTM    
Mortgage-backed securities(2)
    
U.S. government-sponsored agency guaranteed$49,004 $2,162 $15 $51,151 
Non-U.S. residential1,124 1,126 
Commercial825 825 
Total mortgage-backed securities$50,953 $2,166 $17 $53,102 
U.S. Treasury securities(4)
$21,293 $$55 $21,242 
State and municipal9,185 755 11 9,929 
Foreign government1,931 91 — 2,022 
Asset-backed securities(2)
21,581 92 21,495 
Total debt securities HTM$104,943 $3,022 $175 $107,790 


(1)Amortized cost is reported net of ACL of $87 million and $86 million at December 31, 2021 and December 31, 2020, respectively.
(2)The Company invests in mortgage- and asset-backed securities. These securitizations are generally considered VIEs. The Company’s maximum exposure to loss from these VIEs is equal to the carrying amount of the securities, which is reflected in the table above. For mortgage- and asset-backed securitizations in which the Company has other involvement, see Note 21 to the Consolidated Financial Statements.
(3)In February 2021, the Company transferred $237 million of state and municipal bonds 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 $14 million. The gain amounts will remain in AOCI and will be amortized over the remaining life of the securities.
(4)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.

The Company has the positive intent and ability to hold these securities to maturity or, where applicable, tountil the exercise of any issuer call options,option, 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 debt 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:
 Less than 12 months12 months or longerTotal
In millions of dollarsFair
value
Gross
unrecognized
losses
Fair
value
Gross
unrecognized
losses
Fair
value
Gross
unrecognized
losses
December 31, 2019      
Debt securities HTM      
Mortgage-backed securities$3,590
$10
$1,116
$11
$4,706
$21
State and municipal34
1
1,125
27
1,159
28
Foreign government1,970
1


1,970
1
Asset-backed securities7,972
11
765
48
8,737
59
Total debt securities HTM$13,566
$23
$3,006
$86
$16,572
$109
December 31, 2018      
Debt securities HTM      
Mortgage-backed securities$2,822
$20
$18,086
$559
$20,908
$579
State and municipal981
34
1,242
104
2,223
138
Foreign government1,003
24


1,003
24
Asset-backed securities13,008
112


13,008
112
Total debt securities HTM$17,814
$190
$19,328
$663
$37,142
$853
197


Note: Excluded from the gross unrecognized losses presented in the above table are $(582) million and $(653) million of net unrealized losses recorded in AOCI as of December 31, 2019 and 2018, respectively, primarily related to the difference between the amortized cost and carrying value of HTM debt securities that were reclassified from AFS. Substantially all of these net unrecognized losses relate to securities that have been in a loss position for 12 months or longer at December 31, 2019 and 2018.

The following table presents the carrying value and fair value of HTM debt securities by contractual maturity dates:

December 31,
 20212020
In millions of dollars
Amortized cost(1)
Fair value
Weighted average yield(2)
Amortized cost(1)
Fair value
Mortgage-backed securities    
Due within 1 year$152 $151 1.70 %$81 $81 
After 1 but within 5 years684 725 3.01 463 477 
After 5 but within 10 years1,655 1,739 2.74 1,699 1,873 
After 10 years63,200 63,232 2.55 48,710 50,671 
Total$65,691 $65,847 2.56 %$50,953 $53,102 
U.S. Treasury securities
After 1 but within 5 years$65,498 $64,516 0.69 %$18,955 $19,127 
After 5 but within 10 years46,321 45,701 1.15 2,338 2,115 
After 10 years   — — 
Total$111,819 $110,217 0.88 %$21,293 $21,242 
State and municipal  
Due within 1 year$51 $50 3.82 %$$
After 1 but within 5 years166 170 2.82 139 142 
After 5 but within 10 years908 951 3.23 818 869 
After 10 years7,798 8,329 2.65 8,222 8,912 
Total$8,923 $9,500 2.72 %$9,185 $9,929 
Foreign government  
Due within 1 year$292 $291 7.86 %$361 $360 
After 1 but within 5 years1,359 1,328 6.30 1,570 1,662 
After 5 but within 10 years   — — 
After 10 years   — — 
Total$1,651 $1,619 6.58 %$1,931 $2,022 
All other(3)
  
Due within 1 year$ $  %$— $— 
After 1 but within 5 years   — — 
After 5 but within 10 years11,520 11,515 2.78 11,795 15,020 
After 10 years17,359 17,340 1.34 9,786 6,475 
Total$28,879 $28,855 1.92 %$21,581 $21,495 
Total debt securities HTM$216,963 $216,038 1.65 %$104,943 $107,790 

(1)Amortized cost is reported net of ACL of $87 million and $86 million at December 31, 2021 and December 30, 2020, respectively.
(2)Weighted average yields are weighted based on the amortized cost of each security. The average yield considers the contractual coupon, amortization of premiums and accretion of discounts and excludes the effects of any related hedging derivatives.
(3)Includes corporate and asset-backed securities.


HTM Debt Securities Delinquency and Non-Accrual
Details
Citi did not have any HTM debt securities that were delinquent or on non-accrual status at December 31, 2021 and 2020.

There were no purchased credit-deteriorated HTM debt
securities held by the Company as of December 31, 2021 and 2020.
 December 31,
 20192018
In millions of dollarsCarrying valueFair valueCarrying valueFair value
Mortgage-backed securities    
Due within 1 year$17
$17
$3
$3
After 1 but within 5 years458
463
539
540
After 5 but within 10 years1,662
1,729
997
1,011
After 10 years(1)
46,121
47,081
34,407
34,024
Total$48,258
$49,290
$35,946
$35,578
State and municipal    
Due within 1 year$2
$26
$37
$37
After 1 but within 5 years123
160
168
174
After 5 but within 10 years597
590
540
544
After 10 years(1)
8,382
8,755
6,883
6,902
Total$9,104
$9,531
$7,628
$7,657
Foreign government    
Due within 1 year$650
$652
$60
$36
After 1 but within 5 years1,284
1,318
967
967
After 5 but within 10 years



After 10 years(1)




Total$1,934
$1,970
$1,027
$1,003
All other(2)
    
Due within 1 year$
$
$
$
After 1 but within 5 years



After 5 but within 10 years8,545
8,543
2,535
2,539
After 10 years(1)
12,934
12,889
16,221
16,113
Total$21,479
$21,432
$18,756
$18,652
Total debt securities HTM$80,775
$82,223
$63,357
$62,890
(1)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.
(2)Includes corporate and asset-backed securities.

198



Evaluating Investments for Other-Than-Temporary Impairment (OTTI)

AFS Debt Securities
Overview
Overview—AFS Debt Securities
The Company conducts periodic reviews of all AFS debt securities with unrealized losses to evaluate whether the impairment is other-than-temporary. This review appliesresulted from expected credit losses or from other factors and to all debt securities that are not measured at fair value through earnings. Effective January 1, 2018,evaluate the AFS category was eliminated for equity securities and, therefore, other-than-temporary impairment (OTTI) review is not required for thoseCompany’s intent to sell such securities.
An unrealized loss existsAFS debt security is impaired when the current fair value of an individual AFS debt security is lowerless than its adjusted amortized cost basis. Unrealized losses that are determined to be temporary in nature are recorded, net of tax, in AOCI for AFS debt securities. Temporary losses related to HTM debt securities generally are not recorded, as these investments are carried at adjusted amortized cost basis. However, for HTM debt securities with credit-related impairment, the credit loss is recognized in earnings as OTTI, and any difference between the cost basis adjusted for the OTTI and fair value is recognized in AOCI and amortized as an adjustment of yield over the remaining contractual life of the security. For debt securities transferred to HTM from Trading account assets, amortized cost is defined as the fair value of the securities at the date of transfer, plus any accretion income and less any impairment recognized in earnings subsequent to transfer. For debt securities transferred to HTM from AFS, amortized cost is defined as the original purchase cost, adjusted for the cumulative accretion or amortization of any purchase discount or premium, plus or minus any cumulative fair value hedge adjustments, net of accretion or amortization, and less any impairment recognized in earnings.
Regardless of the classification of debt securities as AFS or HTM, the Company assesses each position with an unrealized loss for OTTI. Factors considered in determining whether a loss is temporary include:

the length of time and the extent to which fair value has been below cost;
the severity of the impairment;
the cause of the impairment and the financial condition and near-term prospects of the issuer;
activity in the market of the issuer that may indicate adverse credit conditions; and
the Company’s ability and intent to hold the investment for a period of time sufficient to allow for any anticipated recovery.

The Company’s review for impairment generally entails:

identification and evaluation of impaired investments;
analysis of individual positions that have fair values lower than amortized cost, including consideration of the length of time the position has been in an unrealized loss position and the expected recovery period;
consideration of evidential matter, including an evaluation of factors or triggers that could cause individual positions to qualify as having other-than-
temporary impairment and those that would not support other-than-temporary impairment; and
documentation of the results of these analyses, as required under business policies.

The Company recognizes the entire difference between amortized cost basis and fair value is recognized in earnings as OTTI for impaired AFS debt securities that the CompanyCiti has an intent to sell or for which the CompanyCiti 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 and any non-credit-related impairmentby recording an allowance for credit losses. 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 impairment existslosses exist where managementCiti does not expect to receive contractual principal and interest cash flows sufficient to recover the entire amortized cost basis of a security. The allowance for credit losses 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 credit-relatedexpected credit impairments for debt security types that have the most significant unrealized losses as of December 31, 2019.2021.

Mortgage-Backed Securities
ForCiti records no allowances for credit losses on U.S. government-agency-guaranteed mortgage-backed securities, because the Company expects to incur no credit impairment is assessed usinglosses in the event of default due to a cash flow model that estimates the principalhistory of incurring no credit losses and interest cash flows on the underlying mortgages using the security-specific collateral and transaction structure. The model distributes the estimated cash flowsdue to the various tranches of securities, considering the transaction structure and any subordination and credit enhancements that exist in that structure. The cash flow model incorporates actual cash flows on the mortgage-backed securities through the current period and then estimates the remaining cash flows using a number of assumptions, including default rates, prepayment rates, recovery rates (on foreclosed properties) and loss severity rates (on non-agency mortgage-backed securities).
Management develops specific assumptions using market data, internal estimates and estimates published by rating agencies and other third-party sources. Default rates are projected by considering current underlying mortgage loan performance, generally assuming the default of (i) 10% of current loans, (ii) 25% of 30–59 day delinquent loans, (iii) 70% of 60–90 day delinquent loans and (iv) 100% of 91+ day delinquent loans. These estimates are extrapolated along a default timing curve to estimate the total lifetime pool default rate. Other assumptions contemplate the actual collateral attributes, including geographic concentrations, rating actions and current market prices.
Cash flow projections are developed using different stress test scenarios. Management evaluates the results of those stress tests (including the severity of any cash shortfall indicated and the likelihoodnature of the stress scenarios actually occurring based on the underlying pool’s characteristics and performance) to assess whether management expects to recover the amortized cost basis of the security. If cash flow projections indicate that the Company does not expect to recover its amortized cost basis, the Company recognizes the estimated credit loss in earnings.counterparties.


State and Municipal Securities
The process for identifyingestimating credit impairmentslosses in Citigroup’s AFS and HTM state and municipal bonds is primarily based on a credit analysis that incorporates third-party credit ratings. CitigroupCiti monitors the bond issuers and any insurers providing default protection in the form of financial guarantee insurance. The average external credit rating, ignoringdisregarding any insurance, is Aa3/AA-.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 CitigroupCiti plans to sell or would more-likely-than-not be more-likely-than-not 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 lowerless than their respective carrying values for OTTI.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 in Other revenue 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 OTTIImpairment
The following tables present total OTTIimpairment on Investments recognized in earnings:

Year ended 
  December 31, 2019
In millions of dollarsAFSHTM
Other
assets
Total
Impairment losses related to debt securities that the Company does not intend to sell nor will likely be required to sell:    
Total OTTI losses recognized during the period$1
$
$1
$2
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$1
$
$1
$2
Impairment losses recognized in earnings for debt securities that the Company intends to sell, would be more-likely-than-not required to sell or will be subject to an issuer call deemed probable of exercise20

1
21
Total OTTI losses recognized in earnings$21
$
$2
$23


Year ended
December 31, 2021
In millions of dollarsAFSOther
assets
Total
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 exercise181  181 
Total impairment losses recognized in earnings$181 $ $181 



Year ended 
  December 31, 2018
In millions of dollars
AFS(1)
HTMOther
assets
Total
Impairment losses related to debt securities that the Company does not intend to sell nor will likely be required to sell:    
Total OTTI losses recognized during the period$
$
$
$
Less: portion of impairment loss recognized in AOCI (before taxes)




Net impairment losses recognized in earnings for debt securities that the Company does not intend to sell nor will likely be required to sell$
$
$
$
Impairment losses recognized in earnings for debt securities that the Company intends to sell, would be more-likely-than-not required to sell or will be subject to an issuer call deemed probable of exercise125


125
Total OTTI losses recognized in earnings$125
$
$
$125


(1)For the year ended December 31, 2018, amounts represent AFS debt securities.

Year ended
December 31, 2020
In millions of dollarsAFSHTMOther
assets
Total
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 exercise109 — — 109 
Total impairment losses recognized in earnings$109 $— $— $109 

Year ended
December 31, 2019
In millions of dollarsAFSHTMOther
assets
Total
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 exercise20 — 21 
Total impairment losses recognized in earnings$21 $— $$23 







200

 
Year ended
December 31, 2017
In millions of dollars
AFS(1)
HTMOther
assets
Total
Impairment losses related to securities that the Company does not intend to sell nor will likely be required to sell:    
Total OTTI losses recognized during the period$2
$
$
$2
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$2
$
$
$2
Impairment losses recognized in earnings for securities that the Company intends to sell, would be more-likely-than-not required to sell or will be subject to an issuer call deemed probable of exercise59
2

61
Total OTTI losses recognized in earnings$61
$2
$
$63


(1)Includes OTTI on non-marketable equity securities.







The following are 12-month rollforwards ofpresents 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 will be required to sell:sell at December 31, 2021 and 2020:

 Cumulative OTTI credit losses recognized in earnings on debt securities still held
In millions of dollarsDec. 31, 2018 balanceCredit
impairments
recognized in
earnings on
securities not
previously
impaired
Credit
impairments
recognized in
earnings on
securities 
that have been previously
impaired
Changes due to
credit-impaired
securities sold,
transferred or
matured
(1)
Dec. 31, 2019 balance
AFS debt securities     
Mortgage-backed securities(1)
$1
$
$
$
$1
State and municipal

4

4
Corporate4



4
All other debt securities
1


1
Total OTTI credit losses recognized for AFS debt securities$5
$1
$4
$
$10
HTM debt securities     
State and municipal3



3
Total OTTI credit losses recognized for HTM debt securities$3
$
$
$
$3

Allowance for Credit Losses on AFS Debt Securities
 Cumulative OTTI credit losses recognized in earnings on debt securities still held
In millions of dollarsDec. 31, 2017 balanceCredit
impairments
recognized in
earnings on
securities not
previously
impaired
Credit
impairments
recognized in
earnings on
securities 
that have
been previously
impaired
Changes due to
credit-impaired
securities sold,
transferred or
matured
(3)
Dec. 31, 2018 balance
AFS debt securities     
Mortgage-backed securities(1)
$38
$
$
$(37)$1
State and municipal4


(4)
Corporate4



4
All other debt securities2


(2)
Total OTTI credit losses recognized for AFS debt securities$48
$
$
$(43)$5
HTM debt securities     
Mortgage-backed securities(2)
$54
$
$
$(54)$
State and municipal

3



3
Total OTTI credit losses recognized for HTM debt securities$57
$
$
$(54)$3

(1)Primarily consists of Prime securities.
(2)Primarily consists of Alt-A securities.
(3)
Includes $18 million in cumulative OTTI reclassified from HTM to AFS due to the transfer of the related debt securities from HTM to AFS. Citi adopted ASU 2017-12, Targeted Improvements to Accounting for Hedging Activities, on January 1, 2018 and transferred approximately $4 billion of HTM debt securities into AFS classification as permitted as a one-time transfer under the standard.
Year ended December 31, 2021
In millions of dollarsMortgage-backedU.S. Treasury and federal agencyState and municipalForeign governmentCorporateTotal AFS
Allowance for credit losses at beginning of year$ $ $ $ $5 $5 
Gross write-offs      
Gross recoveries      
Net credit losses (NCLs)$ $ $ $ $ $ 
NCLs$ $ $ $ $ $ 
Credit losses on securities without previous credit losses    3 3 
Net reserve builds (releases) on securities with previous credit losses      
Total provision for credit losses$ $ $ $ $3 $3 
Initial allowance on newly purchased credit-deteriorated securities during the year      
Allowance for credit losses at end of year$ $ $ $ $8 $8 

Year ended December 31, 2020
In millions of dollarsMortgage-backedU.S. Treasury and federal agencyState and municipalForeign governmentCorporateTotal AFS
Allowance for credit losses at beginning of year$— $— $— $— $— $— 
Gross write-offs— — — — — — 
Gross recoveries— — — — 
Net credit losses (NCLs)$— $— $— $— $$
NCLs$— $— $— $— $(2)$(2)
Credit losses on securities without previous credit losses— — — 
Net reserve builds (releases) on securities with previous credit losses— — — (3)— (3)
Total provision for credit losses$— $— $— $— $$
Initial allowance on newly purchased credit-deteriorated securities during the year— — — — — — 
Allowance for credit losses at end of year$— $— $— $— $$
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. See Note 1 to the Consolidated Financial Statements for additional details.
The election to measure a non-marketable equity security using the measurement alternative is made on an instrument-by-instrument basis. Under the measurement alternative, an equity security is carried at cost plus or minus changes resulting from observable prices in orderly transactions for the identical or a similar investment of the same issuer. The carrying value of the equity security is adjusted to fair value on the date of an observed transaction. Fair value may differ from the observed transaction price due to a number of factors, including marketability adjustments and differences in rights and obligations when the observed transaction is not for the identical investment held by Citi.
Equity securities under the measurement alternative are also assessed for impairment. On a quarterly basis, management qualitatively assesses whether each equity security under the measurement alternative is impaired. Impairment indicators that are considered include, but are not limited to, the following:

a significant deterioration in the earnings performance, credit rating, asset quality or business prospects of the investee;
a significant adverse change in the regulatory, economic or technological environment of the investee;
a significant adverse change in the general market condition of either the geographical area or the industry in which the investee operates;
a bona fide offer to purchase, an offer by the investee to sell or a completed auction process for the same or similar investment for an amount less than the carrying amount of that investment; and
factors that raise significant concerns about the investee’s ability to continue as a going concern, such as negative cash flows from operations, working capital deficiencies or noncompliance with statutory capital requirements or debt covenants.
When the qualitative assessment indicates that impairment exists, the investment is written down to fair value, with the full difference between the fair value of the investment and its carrying amount recognized in earnings.
Below is the carrying value of non-marketable equity securities measured using the measurement alternative at December 31, 20192021 and 2018:2020:

In millions of dollarsDecember 31, 2019December 31, 2018In millions of dollarsDecember 31, 2021December 31, 2020
Measurement alternative: Measurement alternative:
Carrying value$700
$538
Carrying value$1,413 $962 

Below are amounts recognized in earnings and life-to-date amounts for non-marketable equity securities measured using the measurement alternative:

 Years Ended December 31,
In millions of dollars20192018
Measurement alternative:



Impairment losses(1)
$9
$7
Downward changes for observable prices(1)
16
18
Upward changes for observable prices(1)
123
219
Years ended December 31,
In millions of dollars20212020
Measurement alternative(1):
Impairment losses$25 $56 
Downward changes for observable prices 19 
Upward changes for observable prices406 144 

(1)     See Note 24 to the Consolidated Financial Statements for additional information on these nonrecurring fair value measurements.


(1)See Note 24 to the Consolidated Financial StatementsLife-to-date amounts on securities still held
In millions of dollarsDecember 31, 2021
Measurement alternative:
Impairment losses$87
Downward changes for additional information on these nonrecurring fair value measurements.observable prices3
Upward changes for observable prices699

 Life-to-date amounts on securities still held
In millions of dollarsDecember 31, 2019
Measurement alternative: 
Impairment losses$16
Downward changes for observable prices34
Upward changes for observable prices342


A similar impairment analysis is performed for non-marketable equity securities carried at cost. For the years ended December 31, 20192021 and 2018,2020, there was 0no 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 valueUnfunded
commitments
Redemption frequency
(if currently eligible)
monthly, quarterly, annually
Redemption 
notice
period
In millions of dollarsDecember 31, 2021December 31, 2020December 31, 2021December 31, 2020
Private equity funds(1)(2)
$123 $123 $60 $62 
Real estate funds(2)(3)
2 1 20 
Mutual/collective investment funds20 20  — 
Total$145 $152 $61 $82 

(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.
(3)Includes several real estate funds that invest primarily in commercial real estate in the U.S., Europe and Asia.

203
 Fair valueUnfunded
commitments
Redemption frequency
(if currently eligible)
monthly, quarterly, annually
Redemption 
notice
period
In millions of dollarsDecember 31, 2019December 31, 2018December 31, 2019December 31, 2018  
Private equity funds(1)(2)
$134
$168
$62
$62
Real estate funds(2)(3)
10
14
18
19
Mutual/collective
  investment funds
26
25


  
Total$170
$207
$80
$81
(1)Private equity funds include funds that invest in infrastructure, emerging markets and venture capital.
(2)With respect to the Company’s investments in private equity funds and real estate funds, distributions from each fund will be received as the underlying assets held by these funds are liquidated. It is estimated that the underlying assets of these funds will be liquidated over a period of several years as market conditions allow. Private equity and real estate funds do not allow redemption of investments by their investors. Investors are permitted to sell or transfer their investments, subject to the approval of the general partner or investment manager of these funds, which generally may not be unreasonably withheld.
(3)Includes several real estate funds that invest primarily in commercial real estate in the U.S., Europe and Asia.



14.  LOANS

Citigroup loans are reported in 2 categories: consumer and corporate. These categories are classified primarily according to the operating segment and subsegmentbusiness that manage the loans.

Consumer Loans
Consumer loans represent loans and leases managed primarily by GCB and Corporate/Other.
Citigroup has established a risk management process to monitor, evaluate and manage the principal risks associated with its consumer loan portfolio. Credit quality indicators that are actively monitored include delinquency status, consumer credit scores under Fair Isaac Corporation (FICO) and loan to value (LTV) ratios, each as discussed in more detail below.
Included in the loan table above are lending products whose terms may give rise to greater credit issues. Credit cards with below-market introductory interest rates and interest-only loans are examples of such products. These products are closely managed using credit techniques that are intended to mitigate their higher inherent risk.

Delinquency Status
Delinquency status is monitored and considered a key indicator of credit quality of consumer loans. Principally, the U.S. residential first mortgage loans use the Mortgage Bankers Association (MBA) method of reporting delinquencies, which considers a loan delinquent if a monthly payment has not been received by the end of the day immediately preceding the loan’s next due date. All other loans use a method of reporting delinquencies that considers a loan delinquent if a monthly payment has not been received by the close of business on the loan’s next due date.
As a general policy, residential first mortgages, home equity loans and installment loans are classified as non-accrual when loan payments are 90 days contractually past due. Credit cards and unsecured revolving loans generally accrue interest until payments are 180 days past due. Home equity loans in regulated bank entities are classified as non-accrual if the related residential first mortgage is 90 days or more past due. Mortgage loans, other than Federal Housing Administration (FHA)-insured loans, are classified as non-accrual within 60 days of notification that the borrower has filed for bankruptcy.

The policy for re-aging modified U.S. consumer loans to current status varies by product. Generally, one of the conditions to qualify for these modifications is that a minimum number of payments (typically ranging from 1 to 3) 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 3 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.










































204


The following table providestables provide Citi’s consumer loans by type:


Consumer LoanLoans, Delinquencies and Non-Accrual DetailsStatus at December 31, 20192021
In millions of dollars
Total
current(1)(2)
30–89 days
past due(3)
≥ 90 days
past due(3)
Past due
government
guaranteed(4)
Total
loans(2)
Total
non-accrual
90 days past due
and accruing
In North America offices(5)
       
Residential first mortgages(6)
$45,942
$411
$221
$434
$47,008
$479
$288
Home equity loans(7)(8)
8,860
174
189

9,223
405

Credit cards145,477
1,759
1,927

149,163

1,927
Personal, small business and other3,641
44
14

3,699
21

Total$203,920
$2,388
$2,351
$434
$209,093
$905
$2,215
In offices outside North America(5)
       
Residential first mortgages(6)
$37,316
$210
$160
$
$37,686
$421
$
Credit cards25,111
426
372

25,909
310
242
Personal, small business and other

36,456
272
132

36,860
180

Total$98,883
$908
$664
$
$100,455
$911
$242
Total Citigroup(9)
$302,803
$3,296
$3,015
$434
$309,548
$1,816
$2,457


In millions of dollars
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 is no ACLLNon-accrual loans for which there is an ACLLTotal
non-accrual
90 days 
past due and accruing
In North America offices(6)
      
Residential first mortgages(7)
$42,894 $245 $280 $394 $43,813 $134 $339 $473 $282 
Home equity loans(8)(9)
4,899 43 159  5,101 63 206 269  
Credit cards132,050 947 871  133,868    871 
Personal, small business and other3,091 19 10 38 3,158 2 15 17 28 
Total$182,934 $1,254 $1,320 $432 $185,940 $199 $560 $759 $1,181 
In offices outside North America(6)
       
Residential mortgages(7)
$34,289 $159 $153 $ $34,601 $ $403 $403 $ 
Credit cards17,428 192 188  17,808  140 140 120 
Personal, small business and other32,662 144 81  32,887  200 200 22 
Total$84,379 $495 $422 $ $85,296 $ $743 $743 $142 
Total Citigroup(10)
$267,313 $1,749 $1,742 $432 $271,236 $199 $1,303 $1,502 $1,323 

Consumer LoanLoans, Delinquencies and Non-Accrual DetailsStatus at December 31, 20182020

In millions of dollars
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 is no ACLLNon-accrual loans for which there is an ACLLTotal
non-accrual
90 days 
past due and accruing
In North America offices(6)
       
Residential first mortgages(7)
$46,471 $402 $381 $524 $47,778 $136 $509 $645 $332 
Home equity loans(8)(9)
6,829 78 221 — 7,128 72 307 379 — 
Credit cards127,827 1,228 1,330 — 130,385 — — — 1,330 
Personal, small business and other4,472 27 10 — 4,509 33 35 — 
Total$185,599 $1,735 $1,942 $524 $189,800 $210 $849 $1,059 $1,662 
In offices outside North America(6)
       
Residential mortgages(7)
$39,557 $213 $199 $— $39,969 $— $486 $486 $— 
Credit cards21,718 429 545 — 22,692 — 384 384 324 
Personal, small business and other35,925 319 134 — 36,378 — 212 212 52 
Total$97,200 $961 $878 $— $99,039 $— $1,082 $1,082 $376 
Total Citigroup(10)
$282,799 $2,696 $2,820 $524 $288,839 $210 $1,931 $2,141 $2,038 

(1)Loans less than 30 days past due are presented as current.
(2)Includes $12 million and $14 million at December 31, 2021 and 2020, respectively, of residential first mortgages recorded at fair value.
(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. Most modified loans in North America 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). Consumer relief programs in Asia and Mexico largely expired during the fourth quarter of 2020 and began to age at that time.
(5)Consists of loans that are guaranteed by U.S. government-sponsored agencies that are 30–89 days past due of $0.1 billion and $0.2 billion and 90 days or more past due of $0.3 billion and $0.3 billion at December 31, 2021 and 2020, respectively.
(6)North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America.
(7)Includes approximately $0.1 billion and $0.1 billion at December 31, 2021 and 2020, respectively, of residential first mortgage loans in process of foreclosure.
(8)Includes approximately $0.1 billion and $0.1 billion at December 31, 2021 and 2020, respectively, of home equity loans in process of foreclosure.
(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 $659 million and $749 million at December 31, 2021 and 2020, respectively. Unearned income on consumer loans primarily represents unamortized origination fees and costs, premiums and discounts.



205



In millions of dollars
Total
current(1)(2)
30–89 days
past due(3)
≥ 90 days
past due(3)
Past due
government
guaranteed(4)
Total
loans(2)
Total
non-accrual
90 days past due
and accruing
In North America offices(5)
       
Residential first mortgages(6)
$45,953
$420
$253
$786
$47,412
$583
$549
Home equity loans(7)(8)
11,135
161
247

11,543
527

Credit cards141,091
1,687
1,764

144,542

1,764
Personal, small business and other3,983
46
17

4,046
28

Total$202,162
$2,314
$2,281
$786
$207,543
$1,138
$2,313
In offices outside North America(5)
       
Residential first mortgages(6)
$35,624
$203
$145
$
$35,972
$383
$
Credit cards24,156
425
370

24,951
312
235
Personal, small business and other33,474
284
136

33,894
193

Total$93,254
$912
$651
$
$94,817
$888
$235
Total Citigroup (9)
$295,416
$3,226
$2,932
$786
$302,360
$2,026
$2,548
Interest Income Recognized for Non-Accrual Consumer Loans
(1)Loans less than 30 days past due are presented as current.
(2)Includes $18 million and $20 million at December 31, 2019 and 2018, respectively, of residential first mortgages recorded at fair value.
(3)Excludes loans guaranteed by U.S. government-sponsored agencies.
(4)Consists of residential first mortgages that are guaranteed by U.S. government-sponsored agencies that are 30–89 days past due of $0.1 billion and $0.2 billion and 90 days or more past due of $0.3 billion and $0.6 billion at December 31, 2019 and 2018, respectively.
(5)North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America.
(6)Includes approximately $0.1 billion and $0.1 billion at December 31, 2019 and 2018, respectively, of residential first mortgage loans in process of foreclosure.
(7)Includes approximately $0.1 billion and $0.1 billion at December 31, 2019 and 2018, respectively, of home equity loans in process of foreclosure.
(8)Fixed-rate home equity loans and loans extended under home equity lines of credit, which are typically in junior lien positions.
(9)Consumer loans are net of unearned income of $783 million and $742 million at December 31, 2019 and 2018, respectively. Unearned income on consumer loans primarily represents unamortized origination fees and costs, premiums and discounts.

For the years ended
In millions of dollarsDecember 31, 2021December 31, 2020
In North America offices(1)
Residential first mortgages$13 $15 
Home equity loans7 
Credit cards — 
Personal, small business and other — 
Total$20 $23 
In offices outside North America(1)
Residential mortgages$1 $— 
Credit cards — 
Personal, small business and other — 
Total$1 $— 
Total Citigroup$21 $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, 20192021 and 2018,2020, the Company sold and/or reclassified to HFS $2.9 billion$1,473 million and $3.2 billion, respectively,$414 million of consumer loans.loans, respectively. Loans of businesses that are HFS are not included in the above. For additional information, see Note 2 to the Consolidated Financial Statements.

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 FICOFair 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.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)(2)
December 31, 2021
In millions of dollarsLess than
680
680
to 760
Greater
than 760
FICO not availableTotal loans
Residential first mortgages
2021$201 $3,415 $7,363 
20202002,7327,339
20191401,1783,082
2018196431747
20172406251,143
Prior1,5073,8177,903
Total residential first mortgages$2,484 $12,198 $27,577 $1,554 $43,813 
Home equity loans (pre-reset)$222 $836 $1,309 
Home equity loans (post-reset)609 989 1,095 
Total home equity loans$831 $1,825 $2,404 $41 $5,101 
Credit cards(3)
$23,115 $52,907 $55,137 $2,192 $133,351 
Personal, small business and other
2021$59 $201 $319 
202022 41 64 
201942 53 68 
201834 35 37 
20177 8 9 
Prior120 179 143 
Total personal, small business and other$284 $517 $640 $1,717 $3,158 
Total$26,714 $67,447 $85,758 $5,504 $185,423 
FICO score distribution in U.S. portfolio(1)(2)(3)
December 31, 2019
In millions of dollars
Less than
680
680 to 760Greater
than 760
Residential first mortgages$3,602
$13,178
$28,235
Home equity loans1,881
3,475
3,630
Credit cards33,290
59,536
52,935
Personal, small business and other

564
907
1,473
Total$39,337
$77,096
$86,273
207


FICO score distribution in U.S. portfolio(1)(2)
December 31, 2020
In millions of dollarsLess than
680
680
to 760
Greater
than 760
FICO not availableTotal
loans
Residential first mortgages
2020$187 $3,741 $9,052 
20191501,8575,384
20182466551,227
20172988461,829
20163231,3683,799
Prior1,7084,1339,105
Total residential first mortgages$2,912 $12,600 $30,396 $1,870 $47,778 
Home equity loans (pre-reset)$292 $1,014 $1,657 
Home equity loans (post-reset)1,055 1,569 1,524 
Total home equity loans$1,347 $2,583 $3,181 $17 $7,128 
Credit cards(3)
$26,227 $52,778 $49,767 $1,041 $129,813 
Personal, small business and other
2020$23 $58 $95 
201979 106 134 
201882 80 84 
201726 27 30 
201610 
Prior214 393 529 
Total personal, small business and other$434 $673 $880 $2,522 $4,509 
Total$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)FICO scores are updated on either a monthly or quarterly basis. For updates that are made only quarterly, certain current-period loans by year of origination are greater than those disclosed in the prior periods. Loans that did not have FICO scores as of the prior period have been updated with FICO scores as they become available.
(3)Excludes $517 million and $572 million of balances related to Canada for December 31, 2021 and December 31, 2020, respectively.


FICO score distribution in U.S. portfolio(1)(2)(3)
December 31, 2018

In millions of dollars
Less than
680
680 to 760Greater
than 760
Residential first mortgages$4,530
$13,848
$26,546
Home equity loans2,438
4,296
4,471
Credit cards32,686
58,722
51,299
Personal, small business and other

625
1,097
1,121
Total$40,279
$77,963
$83,437
208


(1)The FICO bands in the tables are consistent with general industry peer presentations.
(2)Excludes loans guaranteed by U.S. government-sponsored agencies, loans subject to long-term standby commitments (LTSC) with U.S. government-sponsored agencies and loans recorded at fair value.
(3)Excludes balances where FICO was not available. Such amounts are not material.

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.portfolios by year of origination. 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. portfolioDecember 31, 2021
In millions of dollarsLess than
or equal
to 80%
> 80% but less
than or equal to 100%
Greater
than
100%
LTV not availableTotal
Residential first mortgages
2021$10,515 $474 $1 
202010,206 75  
20194,372 35 1 
20181,300 74 5 
20171,986 27 2 
Prior13,271 34 8 
Total residential first mortgages$41,650 $719 $17 $1,427 $43,813 
Home equity loans (pre-reset)$2,315 $26 $9 
Home equity loans (post-reset)2,608 48 25 
Total home equity loans$4,923 $74 $34 $70 $5,101 
Total$46,573 $793 $51 $1,497 $48,914 
LTV distribution in U.S. portfolioDecember 31, 2020
In millions of dollarsLess than
or equal
to 80%
> 80% but less
than or equal
to 100%
Greater
than
100%
LTV not availableTotal
Residential first mortgages
2020$11,447 $1,543 $— 
20197,029 376 
20181,617 507 11 
20172,711 269 
20165,423 84 
Prior14,966 66 16 
Total residential first mortgages$43,193 $2,845 $35 $1,705 $47,778 
Home equity loans (pre-reset)$2,876 $50 $16 
Home equity loans (post-reset)3,782 290 58 
Total home equity loans$6,658 $340 $74 $56 $7,128 
Total$49,851 $3,185 $109 $1,761 $54,906 



LTV distribution in U.S. portfolio(1)(2)
December 31, 2019
In millions of dollars
Less than or
equal to 80%
> 80% but less
than or equal to
100%
Greater
than
100%
Residential first mortgages$41,705
$3,302
$98
Home equity loans7,934
819
235
Total$49,639
$4,121
$333
LTV distribution in U.S. portfolio(1)(2)
December 31, 2018
In millions of dollars
Less than or
equal to 80%
> 80% but less
than or equal to
100%
Greater
than
100%
Residential first mortgages$42,379
$2,474
$197
Home equity loans9,465
1,287
390
Total$51,844
$3,761
$587

(1)Excludes loans guaranteed by U.S. government-sponsored agencies, loans subject to LTSCs with U.S. government-sponsored agencies and loans recorded at fair value.
(2)Excludes balances where LTV was not available. Such amounts are not material.


209



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:
At and for the year ended December 31, 2021
In millions of dollars
Recorded
investment(1)(2)
Unpaid
principal balance
Related
specific allowance(3)(4)
Average
carrying value(5)
Interest income
recognized(6)
Mortgage and real estate   
Residential first mortgages$1,457 $1,531 $87 $1,548 $87 
Home equity loans188 342 (1)335 9 
Credit cards1,582 1,609 594 1,795 116 
Personal, small business and other454 461 120 505 52 
Total$3,681 $3,943 $800 $4,183 $264 
At and for the year ended December 31, 2019 At and for the year ended December 31, 2020
In millions of dollars
Recorded
investment(1)(2)
Unpaid
principal balance
Related
specific allowance(3)
Average
carrying value(4)
Interest income
recognized(5)
In millions of dollars
Recorded
investment
(1)(2)
Unpaid
principal
balance
Related
specific allowance(3)
Average
carrying 
value(5)
Interest income
recognized(6)
Mortgage and real estate  Mortgage and real estate 
Residential first mortgages$1,666
$1,838
$161
$1,925
$60
Residential first mortgages$1,787 $1,962 $157 $1,661 $68 
Home equity loans592
824
123
637
9
Home equity loans478 651 60 527 13 
Credit cards1,931
2,288
771
1,890
103
Credit cards1,982 2,135 918 1,926 106 
Installment and other    
Personal, small business and other

703
738
135
754
55
Personal, small business and other552 552 210 463 63 
Total$4,892
$5,688
$1,190
$5,206
$227
Total$4,799 $5,300 $1,345 $4,577 $250 
(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.

(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) $405For December 31, 2021, $190 million of residential first mortgages and $212$94 million of home equity loans do not have a specific allowance.
(3)
Included in the For December 31, 2020, $211 million of residential first mortgages and $147 million of home equity loans do not have a specific allowance.Allowance for loan losses.
(4)Average carrying value represents the average recorded investment ending balance for the last 4 quarters and does not include the related specific allowance.
(5)Includes amounts recognized on both an accrual and cash basis.

(3)Included in the Allowance for credit losses on loans.
(4)The negative allowance on home equity loans resulted from expected recoveries on previously written-off accounts.
(5)Average carrying value represents the average recorded investment ending balance for the last 4 quarters and does not include the related specific allowance.
(6)    Includes amounts recognized on both an accrual and cash basis.



210


 At and for the year ended December 31, 2018
In millions of dollars
Recorded
investment(1)(2)
Unpaid
principal balance
Related
specific allowance(3)
Average
carrying 
value(4)
Interest income
recognized
(5)(6)
Mortgage and real estate    
Residential first mortgages$2,130
$2,329
$178
$2,483
$81
Home equity loans684
946
122
698
12
Credit cards1,818
1,842
677
1,815
105
Installment and other     
Personal, small business and other452
666
139
500
22
Total$5,084
$5,783
$1,116
$5,496
$220
(1)Recorded investment in a loan includes net deferred loan fees and costs, unamortized premium or discount and direct write-downs and includes accrued interest only on credit card loans.
(2)$484 million of residential first mortgages and $263 million of home equity loans do not have a specific allowance.
(3)
Included in the Allowance for loan losses.
(4)Average carrying value represents the average recorded investment ending balance for the last 4 quarters and does not include the related specific allowance.
(5)Includes amounts recognized on both an accrual and cash basis.
(6)Interest income recognized for the year ended December 31, 2017 was $342 million.




Consumer Troubled Debt Restructurings(1)
 For the year ended December 31, 2019
In millions of dollars, except number of loans modified
Number of
loans modified
Post-
modification
recorded
investment(1)(2)
Deferred
principal(3)
Contingent
principal
forgiveness(4)
Principal
forgiveness(5)
Average
interest rate
reduction
North America      
Residential first mortgages1,122
$172
$
$
$
%
Home equity loans717
79
3


1
Credit cards268,778
1,165



17
Personal, small business and other1,719
15



5
Total(6)
272,336
$1,431
$3
$
$
 
International      
Residential first mortgages2,448
$74
$
$
$
%
Credit cards72,325
288


10
17
Personal, small business and other29,192
204


6
9
Total(6)
103,965
$566
$
$
$16
 

 For the year ended December 31, 2018
In millions of dollars, except number of loans modified
Number of
loans modified
Post-
modification
recorded
investment(1)(7)
Deferred
principal(3)
Contingent
principal
forgiveness(4)
Principal
forgiveness(5)
Average
interest rate
reduction
North America      
Residential first mortgages2,019
$300
$2
$
$
%
Home equity loans1,381
130
5


1
Credit cards243,253
978



18
   Personal, small business and other1,349
12



4
Total(6)
248,002
$1,420
$7
$
$
 
International      
Residential first mortgages2,572
$85
$
$
$
%
Credit cards77,823
323


9
16
Personal, small business and other

30,849
216


7
9
Total(6)
111,244
$624
$
$
$16
 

 
For the year ended December 31, 2021(1)
In millions of dollars, except number of loans modifiedNumber of
loans modified
Post-
modification
recorded
investment(2)(3)
Deferred
principal(4)
Contingent
principal
forgiveness(5)
Principal
forgiveness(6)
Average
interest rate
reduction
North America      
Residential first mortgages1,333 $227 $ $ $ 1 %
Home equity loans187 12    1 
Credit cards165,098 794    18 
Personal, small business and other1,000 13    3 
Total(7)
167,618 $1,046 $ $ $ 
International      
Residential mortgages1,975 $86 $ $ $  %
Credit cards74,202 339   13 13 
Personal, small business and other28,206 201   7 10 
Total(7)
104,383 $626 $ $ $20  
 
For the year ended December 31, 2020(1)
In millions of dollars, except number of loans modifiedNumber of
loans modified
Post-
modification
recorded
investment(2)(8)
Deferred
principal(4)
Contingent
principal
forgiveness(5)
Principal
forgiveness(6)
Average
interest rate
reduction
North America      
Residential first mortgages1,225 $209 $— $— $— — %
Home equity loans296 27 — — — 
Credit cards215,466 1,038 — — — 17 
Personal, small business and other2,452 28 — — — 
Total(7)
219,439 $1,302 $— $— $— 
International      
Residential mortgages2,542 $141 $$— $— %
Credit cards90,694 401 — — 12 15 
Personal, small business and other41,079 301 — — 10 
Total(7)
134,315 $843 $$— $20 

(1)Post-modification balances include past due amounts that are capitalized at the modification date.
(2)
Post-modification balances in North America include $19 million of residential first mortgages and $7 million of home equity loans to borrowers who have gone through Chapter 7 bankruptcy in the year ended December 31, 2019. These amounts include $11 million of residential first mortgages and $6 million of home equity loans that were newly classified as TDRs during 2019,
(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 $15 million of residential first mortgages to borrowers who have gone through Chapter 7 bankruptcy in the year ended December 31, 2021. These amounts include $5 million of residential first mortgages that were newly classified as TDRs during 2021, based on previously received OCC guidance.
(4)Represents the 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 the portion of contractual loan principal that is non-interest bearing and, depending upon borrower performance, eligible for forgiveness.
(6)Represents the 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 $13 million of residential first mortgages 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 that were newly classified as TDRs during 2020, based on previously received OCC guidance.


211


(3)Represents portion of contractual loan principal that is non-interest bearing but still due from the borrower. Such deferred principal is charged off at the time of permanent modification to the extent that the related loan balance exceeds the underlying collateral value.
(4)Represents portion of contractual loan principal that is non-interest bearing and, depending upon borrower performance, eligible for forgiveness.
(5)Represents portion of contractual loan principal that was forgiven at the time of permanent modification.
(6)The above tables reflect activity for restructured loans that were considered TDRs during the year.
(7)
Post-modification balances in North America include $38 million of residential first mortgages and $12 million of home equity loans to borrowers who have gone through Chapter 7 bankruptcy in the year ended December 31, 2018. These amounts include $27 million of residential first mortgages and $10 million of home equity loans that were newly classified as TDRs during 2018, based on previously received OCC guidance.



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.
Years ended December 31,Years ended December 31,
In millions of dollars20192018In millions of dollars20212020
North America North America 
Residential first mortgages$85
$136
Residential first mortgages$57 $71 
Home equity loans15
23
Home equity loans8 14 
Credit cards301
241
Credit cards252 317 
Personal, small business and other

4
4
Personal, small business and other4 
Total$405
$404
Total$321 $406 
International International 
Residential first mortgages$13
$9
Residential mortgagesResidential mortgages$38 $26 
Credit cards142
198
Credit cards152 178 
Personal, small business and other

74
80
Personal, small business and other96 78 
Total$229
$287
Total$286 $282 


Purchased Credit-Deteriorated Assets

Years ended December 31,
 20212020
In millions of dollarsCredit
cards
Mortgages(1)
Installment and otherCredit
cards
Mortgages(1)
Installment and other
Purchase price$ $23 $ $$49 $— 
Allowance for credit losses at acquisition date   — — 
Discount or premium attributable to non-credit factors   — — — 
Par value (amortized cost basis)$ $23 $ $$49 $— 


(1)    Includes loans sold to agencies that were bought back at par due to repurchase agreements.

212


Corporate Loans
Corporate loans represent loans and leases managed by ICG. The following table presents information by corporate loan type:
In millions of dollarsDecember 31,
2019
December 31,
2018
In North America offices(1)
  
Commercial and industrial$55,929
$60,861
Financial institutions53,922
48,447
Mortgage and real estate(2)
53,371
50,124
Installment, revolving credit and other31,238
32,425
Lease financing1,290
1,429
Total$195,750
$193,286
In offices outside
North America
(1)
  
Commercial and industrial$112,668
$114,029
Financial institutions40,211
36,837
Mortgage and real estate(2)
9,780
7,376
Installment, revolving credit and other27,303
25,685
Lease financing95
103
Governments and official institutions4,128
4,520
Total$194,185
$188,550
Corporate loans, net of unearned income(3)
$389,935
$381,836

(1)North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America. The classification between offices in North America and outside North America is based on the domicile of the booking unit. The difference between the domicile of the booking unit and the domicile of the managing unit is not material.
(2)Loans secured primarily by real estate.
(3)Corporate loans are net of unearned income of ($814) million and ($855) million at December 31, 2019 and 2018, respectively. Unearned income on corporate loans primarily represents interest received in advance, but not yet earned, on loans originated on a discounted basis.
In millions of dollarsDecember 31,
2021
December 31,
2020
In North America offices(1)
  
Commercial and industrial$51,999 $57,731 
Financial institutions66,936 55,809 
Mortgage and real estate(2)
63,357 60,675 
Installment and other29,143 26,744 
Lease financing413 673 
Total$211,848 $201,632 
In offices outside North America(1)
  
Commercial and industrial$103,167 $104,072 
Financial institutions32,203 32,334 
Mortgage and real estate(2)
10,412 11,371 
Installment and other34,436 33,759 
Lease financing42 65 
Governments and official institutions4,423 3,811 
Total$184,683 $185,412 
Corporate loans, net of unearned income(3)
$396,531 $387,044 

(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 ($799) million and ($844) million at December 31, 2021 and 2020, respectively. Unearned income on corporate loans primarily represents interest received in advance, but not yet earned, on loans originated on a discounted basis.

The Company sold and/or reclassified to held-for-sale $2.6$5.9 billion and $1.0$2.2 billion of corporate loans during the years ended December 31, 20192021 and 2018,2020, respectively. The Company did not have significant purchases of corporate
loans classified as held-for-investment for the years ended December 31, 20192021 or 2018.2020.
Lease financing
Citi is a lessor in the power, railcars, shipping and aircraft sectors, where the Company has executed operating, direct financing and leveraged leases. Citi’s $1.4$0.5 billion of lease financing receivables, as of December 31, 2019,2021, 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, 20192021 was not material.
The Company’s leases have an average remaining maturity of approximately three and a half years. In certain cases, Citi obtains residual value insurance from third parties and/or the lessee to manage the risk associated with the residual value of the leased assets. The receivable related to the residual value of the leased assets is $0.9$0.2 billion as of December 31, 2019,2021, while the amount covered by residual value guarantees is $0.3 billion.nil.
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.

213


Corporate Loan Delinquencies and Non-Accrual Details at December 31, 20192021
In millions of dollars
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)
Commercial and industrial$676
$93
$769
$1,828
$164,249
$166,846
Financial institutions791
3
794
50
91,008
91,852
Mortgage and real estate534
4
538
188
62,425
63,151
Lease financing58
9
67
41
1,277
1,385
Other190
22
212
81
62,341
62,634
Loans at fair value    

4,067
Total$2,249
$131
$2,380
$2,188
$381,300
$389,935

In millions of dollars
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)
Commercial and industrial$1,100 $249 $1,349 $1,264 $148,459 $151,072 
Financial institutions505 233 738 33 98,172 98,943 
Mortgage and real estate283 1 284 419 73,066 73,769 
Lease financing   14 441 455 
Other128 26 154 147 65,921 66,222 
Loans at fair value6,070 
Total$2,016 $509 $2,525 $1,877 $386,059 $396,531 

Corporate Loan Delinquencies and Non-Accrual Details at December 31, 2018
2020
In millions of dollars
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)
Commercial and industrial$403
$111
$514
$1,119
$173,257
$174,890
Financial institutions87
7
94
102
85,088
85,284
Mortgage and real estate128
5
133
215
57,152
57,500
Lease financing5
10
15

1,517
1,532
Other151
52
203
75
59,149
59,427
Loans at fair value     3,203
Total$774
$185
$959
$1,511
$376,163
$381,836

(1)Corporate loans that are 90 days past due are generally classified as non-accrual. Corporate loans are considered past due when principal or interest is contractually due but unpaid.
(2)Non-accrual loans generally include those loans that are 90 days or more past due or those loans for which Citi believes, based on actual experience and a forward-looking assessment of the collectability of the loan in full, that the payment of interest or principal is doubtful.
(3)Loans less than 30 days past due are presented as current.
(4)Total loans include loans at fair value, which are not included in the various delinquency columns.
In millions of dollars
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)
Commercial and industrial$400 $109 $509 $2,795 $153,036 $156,340 
Financial institutions668 65 733 92 86,864 87,689 
Mortgage and real estate450 247 697 505 70,836 72,038 
Lease financing62 12 74 24 640 738 
Other112 19 131 111 63,157 63,399 
Loans at fair value6,840 
Total$1,692 $452 $2,144 $3,527 $374,533 $387,044 

(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 gradeinvestment-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, doubtful and doubtfulloss will have risk ratings within the non-investment-grade categories.










214


Corporate Loans Credit Quality Indicators

 
Recorded investment in loans(1)
In millions of dollarsDecember 31, 2019December 31,
2018
Investment grade(2)
  
Commercial and industrial$110,797
$113,925
Financial institutions80,533
73,533
Mortgage and real estate27,571
26,799
Lease financing816
1,035
Other57,339
58,916
Total investment grade$277,056
$274,208
Non-investment grade(2)
  
Accrual  
Commercial and industrial$54,220
$53,942
Financial institutions11,269
10,866
Mortgage and real estate3,811
4,200
Lease financing528
497
Other5,206
5,753
Non-accrual  
Commercial and industrial1,828
1,119
Financial institutions50
102
Mortgage and real estate188
215
Lease financing41

Other81
75
Total non-investment grade$77,222
$76,769
Non-rated private bank loans managed on a delinquency basis(2)
$31,590
$27,656
Loans at fair value4,067
3,203
Corporate loans, net of unearned income$389,935
$381,836
(1)Recorded investment in a loan includes net deferred loan fees and costs, unamortized premium or discount, less any direct write-downs.
(2)Held-for-investment loans are accounted for on an amortized cost basis.
 
Recorded investment in loans(1)
Term loans by year of origination
Revolving line
of credit arrangements(2)
December 31,
2021
In millions of dollars20212020201920182017Prior
Investment grade(3)
 
Commercial and industrial(4)
$42,730 $5,744 $4,762 $3,825 $3,060 $8,928 $32,894 $101,943 
Financial institutions(4)
14,096 1,985 1,290 1,118 599 2,536 67,184 88,808 
Mortgage and real estate4,423 6,013 5,421 3,630 1,801 3,561 1,341 26,190 
Other(5)
11,928 3,993 1,392 2,974 524 6,321 32,807 59,939 
Total investment grade$73,177 $17,735 $12,865 $11,547 $5,984 $21,346 $134,226 $276,880 
Non-investment grade(3)
 
Accrual 
Commercial and industrial(4)
$16,814 $2,313 $2,466 $2,024 $1,412 $3,987 $18,849 $47,865 
Financial institutions(4)
4,471 399 571 107 74 586 3,894 10,102 
Mortgage and real estate1,819 980 1,842 1,163 640 761 644 7,849 
Other(5)
1,517 399 594 384 148 383 3,152 6,577 
Non-accrual
Commercial and industrial(4)
54 119 64 104 94 117 712 1,264 
Financial institutions      33 33 
Mortgage and real estate13 10 2 49 10 25 310 419 
Other(5)
19 5 19 19  90 9 161 
Total non-investment grade$24,707 $4,225 $5,558 $3,850 $2,378 $5,949 $27,603 $74,270 
Non-rated private bank loans managed on a delinquency basis(3)(6)
$9,984 $8,901 $5,926 $2,895 $2,925 $8,680 $ $39,311 
Loans at fair value(7)
6,070 
Corporate loans, net of unearned income$107,868 $30,861 $24,349 $18,292 $11,287 $35,975 $161,829 $396,531 
215


 
Recorded investment in loans(1)
Term loans by year of origination
Revolving line
of credit arrangements(2)
December 31, 2020
In millions of dollars20202019201820172016Prior
Investment grade(3)
 
Commercial and industrial(4)
$38,398 $7,607 $5,929 $3,909 $2,094 $8,670 $25,819 $92,426 
Financial institutions(4)
10,560 2,964 2,106 782 681 2,030 56,239 75,362 
Mortgage and real estate6,793 6,714 5,174 2,568 1,212 1,719 1,557 25,737 
Other(5)
10,874 3,566 4,597 952 780 5,290 31,696 57,755 
Total investment grade$66,625 $20,851 $17,806 $8,211 $4,767 $17,709 $115,311 $251,280 
Non-investment grade(3)
 
Accrual 
Commercial and industrial(4)
$19,683 $4,794 $4,645 $2,883 $1,182 $4,533 $23,400 $61,120 
Financial institutions(4)
7,413 700 654 274 141 197 2,855 12,234 
Mortgage and real estate1,882 1,919 2,058 1,457 697 837 551 9,401 
Other(5)
1,407 918 725 370 186 657 1,986 6,249 
Non-accrual
Commercial and industrial(4)
260 203 192 143 57 223 1,717 2,795 
Financial institutions— — — — — 91 92 
Mortgage and real estate13 18 32 427 505 
Other(5)
15 12 29 65 135 
Total non-investment grade$30,674 $8,541 $8,289 $5,174 $2,273 $6,544 $31,036 $92,531 
Non-rated private bank loans managed on a delinquency basis(3)(6)
$9,823 $7,121 $3,533 $3,674 $4,300 $7,942 $— $36,393 
Loans at fair value(7)
6,840 
Corporate loans, net of unearned income$107,122 $36,513 $29,628 $17,059 $11,340 $32,195 $146,347 $387,044 

(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 arewith 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.















216


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:

At and for the year ended December 31, 2021
At and for the year ended December 31, 2019
In millions of dollars
Recorded
investment(1)
Unpaid
principal balance
Related specific
allowance
Average
carrying value(2)
Interest income recognized(3)
In millions of dollars
Recorded
investment(1)
Unpaid
principal balance
Related specific
allowance
Average
carrying value(2)
Interest income recognized(3)
Non-accrual corporate loans   Non-accrual corporate loans  
Commercial and industrial$1,828
$1,942
$283
$1,449
$33
Commercial and industrial$1,264 $1,863 $198 $1,840 $37 
Financial institutions50
120
2
63

Financial institutions33 98 4 40  
Mortgage and real estate188
362
10
192

Mortgage and real estate419 582 15 448  
Lease financing41
41

8

Lease financing14 14  20  
Other81
202
4
76
9
Other147 241 8 142 18 
Total non-accrual corporate loans$2,188
$2,667
$299
$1,788
$42
Total non-accrual corporate loans$1,877 $2,798 $225 $2,490 $55 
At and for the year ended December 31, 2020
In millions of dollars
Recorded
investment(1)
Unpaid
principal balance
Related specific
allowance
Average
carrying value(2)
Interest income recognized(3)
Non-accrual corporate loans    
Commercial and industrial$2,795 $3,664 $442 $2,649 $14 
Financial institutions92 181 17 132 — 
Mortgage and real estate505 803 38 413 — 
Lease financing24 24 — 34 — 
Other111 235 18 174 21 
Total non-accrual corporate loans$3,527 $4,907 $515 $3,402 $35 
At and for the year ended December 31, 2018 December 31, 2021December 31, 2020
In millions of dollars
Recorded
investment(1)
Unpaid
principal balance
Related specific
allowance
Average
carrying value(2)
Interest income recognized(3)
In millions of dollars
Recorded
investment(1)
Related specific
allowance
Recorded
investment(1)
Related specific
allowance
Non-accrual corporate loans   
Non-accrual corporate loans with specific allowancesNon-accrual corporate loans with specific allowances   
Commercial and industrial$1,119
$1,270
$245
$1,299
$49
Commercial and industrial$638 $198 $1,523 $442 
Financial institutions102
123
35
99

Financial institutions27 4 90 17 
Mortgage and real estate215
323
39
233
1
Mortgage and real estate294 15 246 38 
Lease financing
28

21

Lease financing  — — 
Other75
165
6
83
6
Other37 8 68 18 
Total non-accrual corporate loans$1,511
$1,909
$325
$1,735
$56
Total non-accrual corporate loans with specific allowancesTotal non-accrual corporate loans with specific allowances$996 $225 $1,927 $515 
Non-accrual corporate loans without specific allowancesNon-accrual corporate loans without specific allowances   
Commercial and industrialCommercial and industrial$626 $1,272  
Financial institutionsFinancial institutions6  
Mortgage and real estateMortgage and real estate125 259  
Lease financingLease financing14 24  
OtherOther110 43  
Total non-accrual corporate loans without specific allowancesTotal non-accrual corporate loans without specific allowances$881 N/A$1,600 N/A

(1)Recorded investment in a loan includes net deferred loan fees and costs, unamortized premium or discount, less any direct write-downs.
 December 31, 2019December 31, 2018
In millions of dollars
Recorded
investment(1)
Related specific
allowance
Recorded
investment(1)
Related specific
allowance
Non-accrual corporate loans with specific allowance    
Commercial and industrial$714
$283
$801
$245
Financial institutions40
2
76
35
Mortgage and real estate48
10
100
39
Lease financing



Other7
4
24
6
Total non-accrual corporate loans with specific allowance$809
$299
$1,001
$325
Non-accrual corporate loans without specific allowance    
Commercial and industrial$1,114
 
$318
 
Financial institutions10
 
26
 
Mortgage and real estate140
 
115
 
Lease financing41
 

 
Other74
 
51
 
Total non-accrual corporate loans without specific allowance$1,379
N/A
$510
N/A
(2)Average carrying value represents the average recorded investment balance and does not include related specific allowances.
(1)Recorded investment in a loan includes net deferred loan fees and costs, unamortized premium or discount, less any direct write-downs.
(2)Average carrying value represents the average recorded investment balance and does not include related specific allowance.
(3)Interest income recognized for the year ended December 31, 2017 was $35 million.
(3)Interest income recognized for the year ended December 31, 2019 was $42 million.
N/A Not applicable


217


Corporate Troubled Debt Restructurings

(1)

For the year ended December 31, 2019:2021
In millions of dollarsCarrying value of TDRs modified during the period
TDRs
involving changes
in the amount
and/or timing of
principal payments(1)
TDRs
involving changes
in the amount
and/or timing of
interest payments(2)
TDRs
involving changes
in the amount
and/or timing of
both principal and
interest payments
Commercial and industrial$283
$19
$
$264
Mortgage and real estate16


16
Other6
6


Total$305
$25
$
$280


In millions of dollarsCarrying value of TDRs modified
during the year
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
Commercial and industrial$82 $ $ $82 
Mortgage and real estate8   8 
Other10 1 09 
Total$100 $1 $ $99 

For the year ended December 31, 2018:
In millions of dollarsCarrying value of TDRs modified during the period
TDRs
involving changes
in the amount
and/or timing of
principal payments(1)
TDRs
involving changes
in the amount
and/or timing of
interest payments(2)
TDRs
involving changes
in the amount
and/or timing of
both principal and
interest payments
Commercial and industrial$159
$5
$8
$146
Mortgage and real estate60
3

57
Total$219
$8
$8
$203
(1)TDRs involving changes in the amount or timing of principal payments may involve principal forgiveness or deferral of periodic and/or final principal payments. Because forgiveness of principal is rare for corporate loans, modifications typically have little to no impact on the loans’ projected cash flows and thus little to no impact on the allowance established for the loans. Charge-offs for amounts deemed uncollectable may be recorded at the time of the restructuring or may have already been recorded in prior periods such that no charge-off is required at the time of the modification.
(2)TDRs involving changes in the amount or timing of interest payments may involve a below-market interest rate.


2020

In millions of dollarsCarrying value of TDRs modified during the year
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
Commercial and industrial$247 $— $— $247 
Mortgage and real estate19 — — 19 
Other19 — 13 
Total$285 $$— $279 

(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 dollarsTDR balances at December 31, 2019TDR loans in payment default during the year ended December 31, 2019
TDR balances at
December 31, 2018
TDR loans in payment default during the year ended December 31, 2018
Commercial and industrial$603
$35
$568
$111
Financial institutions

25

Mortgage and real estate79

123

Lease financing



Other44

2

Total(1)
$726
$35
$718
$111


(1)The above table reflects activity for loans outstanding that were considered TDRs as of the end of the reporting period.

In millions of dollarsTDR balances at December 31, 2021TDR loans that re-defaulted in 2021 within one year of modificationTDR balances at
December 31, 2020
TDR loans that re-defaulted in 2020 within one year of modification
Commercial and industrial$236 $ $325 $— 
Financial institutions  — — 
Mortgage and real estate73  92 — 
Lease financing  — — 
Other41  33 — 
Total(1)
$350 $ $450 $— 


(1)The above table reflects activity for loans outstanding that were considered TDRs as of the end of the reporting period.




218


15. ALLOWANCE FOR CREDIT LOSSES
In millions of dollars201920182017
Allowance for loan losses at beginning of period$12,315
$12,355
$12,060
Gross credit losses(9,341)(8,665)(8,673)
Gross recoveries(1)
1,573
1,552
1,597
Net credit losses (NCLs)$(7,768)$(7,113)$(7,076)
NCLs$7,768
$7,113
$7,076
Net reserve builds (releases)364
394
544
Net specific reserve builds (releases)86
(153)(117)
Total provision for loan losses$8,218
$7,354
$7,503
Other, net (see table below)18
(281)(132)
Allowance for loan losses at end of period$12,783
$12,315
$12,355
Allowance for credit losses on unfunded lending commitments at beginning of period$1,367
$1,258
$1,418
Provision (release) for unfunded lending commitments92
113
(161)
Other, net(3)(4)1
Allowance for credit losses on unfunded lending commitments at end of period(2)
$1,456
$1,367
$1,258
Total allowance for loans, leases and unfunded lending commitments$14,239
$13,682
$13,613
In millions of dollars202120202019
Allowance for credit losses on loans (ACLL) at beginning of year$24,956 $12,783 $12,315 
Adjustments to opening balance(1):
Financial instruments—credit losses (CECL) adoption 4,201 — 
Variable post-charge-off third-party collection costs (443)— 
Adjusted ACLL at beginning of year$24,956 $16,541 $12,315 
Gross credit losses on loans$(6,720)$(9,263)$(9,341)
Gross recoveries on loans1,825 1,652 1,573 
Net credit losses on loans (NCLs)$(4,895)$(7,611)$(7,768)
Replenishment of NCLs$4,895 $7,611 $7,768 
Net reserve builds (releases) for loans(7,283)7,635 364 
Net specific reserve builds (releases) for loans(715)676 86 
Total provision for credit losses on loans (PCLL)$(3,103)$15,922 $8,218 
Initial allowance for credit losses on newly purchased credit-deteriorated assets during the period — 
Other, net (see table below)(503)100 18 
ACLL at end of year$16,455 $24,956 $12,783 
Allowance for credit losses on unfunded lending commitments (ACLUC) at beginning of year(2)
$2,655 $1,456 $1,367 
Adjustment to opening balance for CECL adoption(1)
 (194)— 
Provision (release) for credit losses on unfunded lending commitments(788)1,446 92 
Other, net(3)
4 (53)(3)
ACLUC at end of year(2)
$1,871 $2,655 $1,456 
Total allowance for credit losses on loans, leases and unfunded lending commitments$18,326 $27,611 $14,239 

(1)Recoveries have been reduced by certain collection costs that are incurred only if collection efforts are successful.
(2)
Represents additional credit loss reserves for unfunded lending commitments and letters of credit recorded in Other liabilities on the Consolidated Balance Sheet.

Other, net details   
In millions of dollars201920182017
Sales or transfers of various consumer loan portfolios to HFS   
Transfer of real estate loan portfolios$(42)$(91)$(106)
Transfer of other loan portfolios
(110)(155)
Sales or transfers of various consumer loan portfolios to HFS$(42)$(201)$(261)
FX translation, primarily consumer60
(60)115
Other
(20)14
Other, net$18
$(281)$(132)



Other, net details
In millions of dollars202120202019
Sales or transfers of various consumer loan portfolios to HFS
Reclass of Australia consumer ACLL to HFS$(280)$— $— 
Reclass of the Philippines consumer ACLL to HFS(90)— — 
Transfer of real estate loan portfolios (4)(42)
Sales or transfers of various consumer loan portfolios to HFS$(370)$(4)$(42)
FX translation and other(133)104 60 
Other, net$(503)$100 $18 

(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 Sheetbeginning in 2020.

219


Allowance for Credit Losses on Loans and End-of-Period Loans at December 31, 20192021

In millions of dollarsCorporateConsumerTotal
ACLL at beginning of year$5,402 $19,554 $24,956 
Gross credit losses on loans(522)$(6,198)$(6,720)
Gross recoveries on loans127 1,698 1,825 
Replenishment of NCLs395 4,500 4,895 
Net reserve builds (releases)(2,254)(5,029)(7,283)
Net specific reserve builds (releases)(278)(437)(715)
Initial allowance for credit losses on newly purchased credit-deteriorated assets
during the year
   
Other(31)(472)(503)
Ending balance$2,839 $13,616 $16,455 
ACLL   
Collectively evaluated$2,614 $12,816 $15,430 
Individually evaluated225 800 1,025 
Purchased credit deteriorated   
Total ACLL$2,839 $13,616 $16,455 
Loans, net of unearned income
Collectively evaluated$388,584 $267,424 $656,008 
Individually evaluated1,877 3,681 5,558 
Purchased credit deteriorated 119 119 
Held at fair value6,070 12 6,082 
Total loans, net of unearned income$396,531 $271,236 $667,767 



220


In millions of dollarsCorporateConsumerTotal
Allowance for loan losses at beginning of year$2,811
$9,504
$12,315
Charge-offs(487)(8,854)(9,341)
Recoveries95
1,478
1,573
Replenishment of net charge-offs392
7,376
7,768
Net reserve builds (releases)96
268
364
Net specific reserve builds (releases)(21)107
86
Other
18
18
Ending balance$2,886
$9,897
$12,783
Allowance for loan losses 
 
 
Collectively evaluated in accordance with ASC 450$2,587
$8,706
$11,293
Individually evaluated in accordance with ASC 310-10-35299
1,190
1,489
Purchased credit impaired in accordance with ASC 310-30
1
1
Total allowance for loan losses$2,886
$9,897
$12,783
Loans, net of unearned income   
Collectively evaluated in accordance with ASC 450$383,828
$304,510
$688,338
Individually evaluated in accordance with ASC 310-10-352,040
4,892
6,932
Purchased credit impaired in accordance with ASC 310-30
128
128
Held at fair value4,067
18
4,085
Total loans, net of unearned income$389,935
$309,548
$699,483


Allowance for Credit Losses on Loans and End-of-Period Loans at December 31, 20182020

In millions of dollarsCorporateConsumerTotal
Allowance for loan losses at beginning of year$2,943
$9,412
$12,355
Charge-offs(343)(8,322)(8,665)
Recoveries138
1,414
1,552
Replenishment of net charge-offs205
6,908
7,113
Net reserve builds (releases)42
352
394
Net specific reserve builds (releases)(151)(2)(153)
Other(23)(258)(281)
Ending balance$2,811
$9,504
$12,315
Allowance for loan losses 
 
 
Collectively evaluated in accordance with ASC 450$2,486
$8,386
$10,872
Individually evaluated in accordance with ASC 310-10-35325
1,116
1,441
Purchased credit impaired in accordance with ASC 310-30
2
2
Total allowance for loan losses$2,811
$9,504
$12,315
Loans, net of unearned income   
Collectively evaluated in accordance with ASC 450$377,186
$297,128
$674,314
Individually evaluated in accordance with ASC 310-10-351,447
5,084
6,531
Purchased credit impaired in accordance with ASC 310-30
128
128
Held at fair value3,203
20
3,223
Total loans, net of unearned income$381,836
$302,360
$684,196




In millions of dollarsCorporateConsumerTotal
ACLL at beginning of year$2,886 $9,897 $12,783 
Adjustments to opening balance:
   Financial instruments—credit losses (CECL)(1)
(721)4,922 4,201 
  Variable post-charge-off third-party collection costs(1)
— (443)(443)
Adjusted ACLL at beginning of year$2,165 $14,376 $16,541 
Gross credit losses on loans$(1,072)$(8,191)$(9,263)
Gross recoveries on loans86 1,566 1,652 
Replenishment of NCLs986 6,625 7,611 
Net reserve builds (releases)2,890 4,745 7,635 
Net specific reserve builds (releases)282 394 676 
Initial allowance for credit losses on newly purchased credit-deteriorated assets
during the year
— 
Other65 35 100 
Ending balance$5,402 $19,554 $24,956 
ACLL   
Collectively evaluated$4,887 $18,207 $23,094 
Individually evaluated515 1,345 1,860 
Purchased credit deteriorated— 
Total ACLL$5,402 $19,554 $24,956 
Loans, net of unearned income
Collectively evaluated$376,677 $283,885 $660,562 
Individually evaluated3,527 4,799 8,326 
Purchased credit deteriorated— 141 141 
Held at fair value6,840 14 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 at December 31, 20172019
In millions of dollarsCorporateConsumerTotal
Allowance for loan losses at beginning of year$3,218
$8,842
$12,060
Charge-offs(632)(8,041)(8,673)
Recoveries153
1,444
1,597
Replenishment of net charge-offs479
6,597
7,076
Net reserve builds (releases)(274)818
544
Net specific reserve builds (releases)(31)(86)(117)
Other30
(162)(132)
Ending balance$2,943
$9,412
$12,355


In millions of dollarsCorporateConsumerTotal
ACLL at beginning of year$2,811 $9,504 $12,315 
Gross credit losses on loans(487)(8,854)(9,341)
Gross recoveries on loans95 1,478 1,573 
Replenishment of NCLs392 7,376 7,768 
Net reserve builds (releases)96 268 364 
Net specific reserve builds (releases)(21)107 86 
Other— 18 18 
Ending balance$2,886 $9,897 $12,783 



221


Allowance for Credit Losses on HTM Debt Securities

Year ended December 31, 2021
In millions of dollarsMortgage-backedState and municipalForeign governmentAsset-backedAll other debt securitiesTotal HTM
Allowance for credit losses on HTM debt securities at beginning of year$3 $74 $6 $3 $ $86 
Gross credit losses      
Gross recoveries3     3 
Net credit losses (NCLs)$3 $ $ $ $ $3 
Replenishment of NCLs$(3)$ $ $ $ $(3)
Net reserve builds (releases)7 1 (2)(2) 4 
Net specific reserve builds (releases)(4)    (4)
Total provision for credit losses on HTM debt securities$ $1 $(2)$(2)$ $(3)
Other, net$ $ $ $1 $ $1 
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$6 $75 $4 $2 $ $87 

Allowance for Credit Losses on HTM Debt Securities

Year ended December 31, 2020
In millions of dollarsMortgage-backedState and municipalForeign governmentAsset-
backed
All other debt securitiesTotal HTM
Allowance for credit losses on HTM debt securities at beginning of year$— $— $— $— $— $— 
Adjustment to opening balance for CECL adoption— 61 070 
Gross credit losses— — — — — — 
Gross recoveries— — — — — — 
Net credit losses (NCLs)$— $— $— $— $— $— 
Replenishment of NCLs$— $— $— $— $— $— 
Net reserve builds (releases)(2)10 (2)— 
Net specific reserve builds (releases)— — — — — — 
Total provision for credit losses on HTM debt securities$(2)$10 $(2)$$— $
Other, net$$$$(3)$— $
Initial allowance for credit losses on newly purchased credit-deteriorated securities during the year— — — — — — 
Allowance for credit losses on HTM debt securities at
end of year
$$74 $$$— $86 




222


Allowance for Credit Losses on Other Assets

Year ended December 31, 2021
In millions of dollarsCash and due from banksDeposits with banksSecurities borrowed and purchased under agreements
to resell
Brokerage receivables
All other assets(1)
Total
Allowance for credit losses on other assets at beginning of year$ $20 $10 $ $25 $55 
Gross credit losses    (2)(2)
Gross recoveries      
Net credit losses (NCLs)$ $ $ $ $(2)$(2)
Replenishment of NCLs$ $ $ $ $2 $2 
Net reserve builds (releases) 2 (4)  (2)
Total provision for credit losses$ $2 $(4)$ $2 $ 
Other, net$ $(1)$ $ $1 $ 
Allowance for credit losses on other assets at
end of year
$ $21 $6 $ $26 $53 

(1)Primarily accounts receivable.

Allowance for Credit Losses on Other Assets

Year ended December 31, 2020
In millions of dollarsCash and
due from banks
Deposits with banksSecurities borrowed and purchased under agreements
to resell
Brokerage receivables
All other assets(1)
Total
Allowance for credit losses on other assets at beginning of year$— $— $— $— $— $— 
Adjustment to opening balance for CECL adoption14 26 
Gross credit losses— — — — — — 
Gross recoveries— — — — — — 
Net credit losses (NCLs)$— $— $— $— $— $— 
Replenishment of NCLs$— $— $— $— $— $— 
Net reserve builds (releases)(6)(1)
Total provision for credit losses$(6)$$$(1)$$
Other, net$— $$— $— $21 $22 
Allowance for credit losses on other assets at end of year$— $20 $10 $— $25 $55 

(1)Primarily accounts receivable.

For ACL on AFS debt securities, see Note 13 to the Consolidated Financial Statements.
223


16.  GOODWILL AND INTANGIBLE ASSETS
Goodwill

Goodwill
The changes in Goodwill by segment were as follows:

In millions of dollarsIn millions of dollarsInstitutional Clients GroupGlobal Consumer BankingTotal
Balance at December 31, 2018Balance at December 31, 2018$9,959 $12,087 $22,046 
Foreign exchange translationForeign exchange translation65 15 80 
In millions of dollarsGlobal Consumer BankingInstitutional Clients GroupCorporate/OtherTotal
Balance at December 31, 2016(1)
$11,874
$9,741
$44
$21,659
Balance at December 31, 2019Balance at December 31, 2019$10,024 $12,102 $22,126 
Foreign exchange translation$286
$443
$
$729
Foreign exchange translation(4)40 36 
Divestitures(2)
(32)(72)
(104)
Impairment of goodwill(3)


(28)(28)
Balance at December 31, 2017$12,128
$10,112
$16
$22,256
Balance at December 31, 2020Balance at December 31, 2020$10,020 $12,142 $22,162 
Foreign exchange translation$(41)$(153)$
$(194)Foreign exchange translation(267)(116)(383)
Divestitures(4)


(16)(16)
Balance at December 31, 2018$12,087
$9,959
$
$22,046
Foreign exchange translation$15
$65
$
$80
Balance at December 31, 2019$12,102
$10,024
$
$22,126
Divestitures(1)
Divestitures(1)
— (480)(480)
Balance at December 31, 2021Balance at December 31, 2021$9,753 $11,546 $21,299 

(1)
December 31, 2016 has been revised to reflect intersegment goodwill allocations that resulted from the 2019 reorganization of the Citi commercial banking business from GCB to ICG. See Note 3 to the Consolidated Financial Statements.
(2) Primarily related(1)    Goodwill allocated primarily to the sale of a fixed income analytics businessAustralia and a fixed income index business completed in 2017 and agreement to sell a Mexico asset management businessthe Philippines consumer banking businesses, which were reclassified as of December 31, 2017.HFS during 2021. See Note 2 to the Consolidated Financial Statements.
(3)
Related to the transfer of the mortgage servicing business from

North America GCB to Corporate/Other effective January 1, 2017.
(4)Primarily related to the sale of consumer operations in Colombia in 2018.


GoodwillThe Company performed its annual goodwill impairment testing is performedtest using data as of July 1, 2021, at the level below each businessoperating segment (referred to as a reporting unit). See Note 3 for further information on business segments.
The Company performed its annual goodwill impairment test as of July 1, 2019. The fair values of the Company’s reporting units exceededas a percentage of their carrying values byranged from approximately 33%125% to 134% and153%, resulting in no reporting unitimpairment. While the inherent risk related to uncertainty is at risk of impairment.    
Effectiveembedded in the fourth quarterkey assumptions used in the valuations, the economic and business environments continue to evolve as management implements its strategic refresh, which includes, among others, the exits of 2019, the Citi commercial banking business, previously includedconsumer businesses in 13 markets in North America GCB, Latin America GCBAsia and Asia GCB, EMEAwas reorganized, as well as the exit of the Mexico consumer, small business and is now partmiddle-market banking operations, and Citi’s implementation of its new operating segment and reporting unit structure in the first quarter of 2022. If management’s future estimate of key economic and market assumptions were to differ from its current assumptions, Citi could potentially experience material goodwill impairment charges in the future. Citi expects that the implementation of its new operating segments and reporting units in the first quarter of 2022, as well as the timing and sequencing of the sales of its ICGAsia. Goodwill was allocated consumer banking businesses, may result in goodwill impairment.
For additional information regarding Citi’s goodwill impairment testing process, see the following Notes to the transferred business based on relative fair value to the legacy reporting units. An interimConsolidated Financial Statements: Note 1 for Citi’s accounting policy for goodwill, impairment test was performed under both the legacy and current reporting unit structures, which resulted in no impairment. No additional triggering events were identified and 0 goodwill was impaired during the year.Note 3 for a description of Citi’s operating segments.















224



Intangible Assets
The components of intangible assets were as follows:
 December 31, 2019December 31, 2018
In millions of dollars
Gross
carrying
amount
Accumulated
amortization
Net
carrying
amount
Gross
carrying
amount
Accumulated
amortization
Net
carrying
amount
Purchased credit card relationships$5,676
$4,059
$1,617
$5,733
$3,936
$1,797
Credit card contract-related intangibles(1)
5,393
3,069
2,324
5,225
2,791
2,434
Core deposit intangibles434
433
1
419
415
4
Other customer relationships424
275
149
470
299
171
Present value of future profits34
31
3
32
29
3
Indefinite-lived intangible assets228

228
218

218
Other82
77
5
84
75
9
Intangible assets (excluding MSRs)$12,271
$7,944
$4,327
$12,181
$7,545
$4,636
Mortgage servicing rights (MSRs)(2)
495

495
584

584
Total intangible assets$12,766
$7,944
$4,822
$12,765
$7,545
$5,220

(1)Primarily reflects contract-related intangibles associated with the American Airlines, The Home Depot, Costco and AT&T credit card program agreements, which represented 96% of the aggregate net carrying amount as of December 31, 2019.
(2)For additional information on Citi’s MSRs, see Note 21 to the Consolidated Financial Statements.
 December 31, 2021December 31, 2020
In millions of dollarsGross
carrying
amount
Accumulated
amortization
Net
carrying
amount
Gross
carrying
amount
Accumulated
amortization
Net
carrying
amount
Purchased credit card relationships$5,579 $4,348 $1,231 $5,648 $4,229 $1,419 
Credit card contract-related intangibles(1)
3,912 1,372 2,540 3,929 1,276 2,653 
Core deposit intangibles39 39  45 44 
Other customer relationships429 305 124 455 314 141 
Present value of future profits31 29 2 32 30 
Indefinite-lived intangible assets183  183 190 — 190 
Other37 26 11 72 67 
Intangible assets (excluding MSRs)$10,210 $6,119 $4,091 $10,371 $5,960 $4,411 
Mortgage servicing rights (MSRs)(2)
404  404 336 — 336 
Total intangible assets$10,614 $6,119 $4,495 $10,707 $5,960 $4,747 

(1)     Primarily reflects contract-related intangibles associated with the American Airlines, The Home Depot, Costco and AT&T credit card program agreements, which represented 97% of the aggregate net carrying amount as of December 31, 2021.
(2)    For additional information on Citi’s MSRs, see Note 21 to the Consolidated Financial Statements.

Intangible assets amortization expense was $360 million, $419 million and $564 million $557 millionfor 2021, 2020 and $603 million for 2019, 2018 and 2017, respectively. Intangible assets amortization expense is estimated to be $424 million in 2020, $399 million in 2021, $1,025$345 million in 2022, $226$347 million in 2023, and $219$367 million in 2024.


2024, $371 million in 2025 and $342 million in 2026.
The changes in intangible assets were as follows:
 Net carrying
amount at
    
Net carrying
amount at
In millions of dollarsDecember 31, 2018Acquisitions/ divestituresAmortizationImpairmentsFX translation and otherDecember 31,
2019
Purchased credit card relationships(1)
$1,797
$9
$(189)$
$
$1,617
Credit card contract-related intangibles(2)
2,434
73
(336)
153
2,324
Core deposit intangibles4

(4)
1
1
Other customer relationships171

(24)
2
149
Present value of future profits3




3
Indefinite-lived intangible assets218
4


6
228
Other9
6
(11)
1
5
Intangible assets (excluding MSRs)$4,636
$92
$(564)$
$163
$4,327
Mortgage servicing rights (MSRs)(3)
584
    495
Total intangible assets$5,220
    $4,822

(1)Reflects intangibles for the value of cardholder relationships, which are discrete from partner contract-related intangibles and include credit card accounts primarily in the Costco, Macy’s and Sears portfolios.
(2)Primarily reflects contract-related intangibles associated with the American Airlines, The Home Depot, Costco and AT&T credit card program agreements, which represent 96% of the aggregate net carrying amount at December 31, 2019 and 2018.
(3)For additional information on Citi’s MSRs, including the rollforward from 2018 to 2019, see Note 21 to the Consolidated Financial Statements.

Net carrying
amount at
Acquisitions/Net carrying
amount at
In millions of dollarsDecember 31, 2020renewals/ divestituresAmortizationImpairmentsFX translation and otherDecember 31,
2021
Purchased credit card relationships(1)
$1,419 $(15)$(171)$ $(2)$1,231 
Credit card contract-related intangibles(2)
2,653 29 (140)(1)(1)2,540 
Core deposit intangibles (1)   
Other customer relationships141 20 (24) (13)124 
Present value of future profits    2 
Indefinite-lived intangible assets190    (7)183 
Other29 (24) 1 11 
Intangible assets (excluding MSRs)$4,411 $63 $(360)$(1)$(22)$4,091 
Mortgage servicing rights (MSRs)(3)
336 404 
Total intangible assets$4,747 $4,495 

(1)Reflects intangibles for the value of cardholder relationships, which are discrete from partner contract-related intangibles, and includes 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 97% and 96% of the aggregate net carrying amount at December 31, 2021 and 2020, respectively.
(3)For additional information on Citi’s MSRs, including the rollforward from 2020 to 2021, see Note 21 to the Consolidated Financial Statements.

225



17.  DEBT

Short-Term Borrowings

December 31,December 31,

2019201820212020
In millions of dollarsBalanceWeighted average couponBalanceWeighted average couponIn millions of dollarsBalanceWeighted average couponBalanceWeighted average coupon
Commercial paper    Commercial paper
Bank(1)
$10,155
 $13,238
 
Bank(1)
$9,026 $10,022 
Broker-dealer and other(2)
6,321
 
 
Broker-dealer and other(2)
6,992 7,988 
Total commercial paper$16,476
1.98%$13,238
1.95%Total commercial paper$16,018 0.22 %$18,010 0.24 %
Other borrowings(3)
28,573
2.57
19,108
2.99
Other borrowings(3)
11,955 0.91 11,504 0.48 
Total$45,049
 $32,346

Total$27,973 $29,514 

(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.
(3)Includes borrowings from the Federal Home Loan Banks and other market participants. At December 31, 2019 and 2018, collateralized short-term advances from the Federal Home Loan Banks were $17.6 billion and $9.5 billion, respectively.
(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.
(3)Includes borrowings from Federal Home Loan Banks and other market participants. At December 31, 2021 and 2020, collateralized short-term advances from Federal Home Loan Banks were $0.0 billion and $4.0 billion, respectively.

Borrowings under bank lines of credit may be at interest rates based on LIBOR, CD rates, the prime rate or bids submitted by the banks. Citigroup pays commitment fees for its lines of credit.
Some of Citigroup’s non-bank subsidiaries have credit facilities with Citigroup’s subsidiary depository institutions, including Citibank. Borrowings under these facilities are secured in accordance with Section 23A of the Federal Reserve Act.
Citigroup Global Markets Holdings Inc. (CGMHI) has borrowing agreements consisting of facilities that CGMHI has been advised are available, but where no contractual lending obligation exists. These arrangements are reviewed on an ongoing basis to ensure flexibility in meeting CGMHI’s short-term requirements.
Long-Term Debt




Balances at
December 31,
Balances at
December 31,
In millions of dollars
Weighted
average
coupon
(1)
Maturities20192018In millions of dollars
Weighted
average
coupon
(1)
Maturities20212020
Citigroup Inc.(2)



Citigroup Inc.(2)
Senior debt3.11%2020-2098$123,292
$117,511
Senior debt2.88 %
20222098
$137,651 $142,197 
Subordinated debt(3)
5.59
2022-204625,463
24,545
Subordinated debt(3)
4.65 
20222046
25,560 26,636 
Trust preferred
securities
8.15
2036-20671,722
1,711
Trust preferred securities6.30 
20362067
1,734 1,730 
Bank(4)
   
Bank(4)
Senior debt2.51
2020-203853,340
61,237
Senior debt1.54 
20222039
23,567 44,742 
Broker-dealer(5)
   
Broker-dealer(5)
Senior debt2.43
2020-209844,817
26,947
Senior debt0.84 
20222070
65,652 55,896 
Subordinated debt(3)
2.37
2022-2046126
48
Subordinated debt(3)
— 
20222046
210 485 
Total3.28% $248,760
$231,999
Total2.94 %$254,374 $271,686 
Senior debt  $221,449
$205,695
Senior debt$226,870 $242,835 
Subordinated debt(3)
  25,589
24,593
Subordinated debt(3)
25,770 27,121 
Trust preferred
securities
  1,722
1,711
Trust preferred securities1,734 1,730 
Total  $248,760
$231,999
Total$254,374 $271,686 

(1)The weighted average coupon excludes structured notes accounted for at fair value.
(2)Represents the parent holding company.
(3)Includes notes that are subordinated within certain countries, regions or subsidiaries.
(4)Represents Citibank entities as well as other bank entities. At December 31, 2019 and 2018, collateralized long-term advances from the Federal Home Loan Banks were $5.5 billion and $10.5 billion, respectively.
(5)Represents broker-dealer and other non-bank subsidiaries that are consolidated into Citigroup Inc., the parent holding company.
(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, 2021 and 2020, collateralized long-term advances from Federal Home Loan Banks were $5.3 billion and $10.9 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, 2019,2021, the Company’s overall weighted average interest rate for long-term debt, excluding structured notes accounted for at fair value, was 3.28%2.94% on a contractual basis and 3.54%3.12% including the effects of derivative contracts.



226


Aggregate annual maturities of long-term debt obligations (based on final maturity dates) including trust preferred securities are as follows:
In millions of dollars20202021202220232024ThereafterTotal
Citigroup Inc.$7,033
$15,208
$13,061
$14,202
$8,247
$92,726
$150,477
Bank20,654
14,023
8,471
2,634
4,417
3,141
53,340
Broker-dealer9,570
8,852
5,558
3,292
3,359
14,312
44,943
Total$37,257
$38,083
$27,090
$20,128
$16,023
$110,179
$248,760


In millions of dollars20222023202420252026ThereafterTotal
Citigroup Inc.$9,955 $14,440 $12,475 $16,798 $21,483 $89,794 $164,945 
Bank9,839 4,227 5,028 473 68 3,932 23,567 
Broker-dealer13,199 11,813 8,066 3,995 5,499 23,290 65,862 
Total$32,993 $30,480 $25,569 $21,266 $27,050 $117,016 $254,374 

The following table summarizes Citi’s outstanding trust preferred securities at December 31, 2019:2021:

    Junior subordinated debentures owned by trust  Junior subordinated debentures owned by trust
Trust
Issuance
date
Securities
issued
Liquidation
value(1)
Coupon
rate(2)
Common
shares
issued
to parent
AmountMaturity
Redeemable
by issuer
beginning
TrustIssuance
date
Securities
issued
Liquidation
value(1)
Coupon
rate(2)
Common
shares
issued
to parent
AmountMaturityRedeemable
by issuer
beginning
In millions of dollars, except securities and share amounts
In millions of dollars, except securities and share amounts








In millions of dollars, except securities and share amounts
Citigroup Capital IIIDec. 1996194,053
$194
7.625%6,003
$200
Dec. 1, 2036Not redeemableCitigroup Capital IIIDec. 1996194,053 $194 7.625 %6,003 $200 Dec. 1, 2036Not redeemable
Citigroup Capital XIIISept. 201089,840,000
2,246
3 mo LIBOR + 637 bps
1,000
2,246
Oct. 30, 2040Oct. 30, 2015Citigroup Capital XIIISept. 201089,840,000 2,246 3 mo LIBOR + 637 bps1,000 2,246 Oct. 30, 2040Oct. 30, 2015
Citigroup Capital XVIIIJune 200799,901
132
3 mo LIBOR + 88.75 bps
50
132
June 28, 2067June 28, 2017Citigroup Capital XVIIIJune 200799,901 135 3 mo sterling LIBOR + 88.75 bps50 135 June 28, 2067June 28, 2017
Total obligated  
$2,572
  $2,578
 Total obligated $2,575  $2,581  

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.
(2)In each case, the coupon rate on the subordinated debentures is the same as that on the trust preferred securities.
(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.
(2)In each case, the coupon rate on the subordinated debentures is the same as that on the trust preferred securities.
227


18. REGULATORY CAPITAL
 
Citigroup is subject to risk-based capital and leverage standards issued by the Federal Reserve Board, which constitute the U.S. Basel III rules. Citi’s U.S.-insured depository institution subsidiaries, including Citibank, are subject to similar standards issued by their respective primary federal bank regulatory agencies. These standards are used to evaluate
capital adequacy and include the required minimums
shown in the following table. The regulatory agencies are required by law to take specific, prompt corrective actions with respect to institutions that do not meet minimum capital standards.
 The following table sets forth for Citigroup and Citibank the regulatory capital tiers, total risk-weighted assets, quarterly adjusted average total assets, Total Leverage Exposure, risk-based capital ratios and leverage ratios:
In millions of dollars, except ratiosStated
minimum
Citigroup(4)
Citibank(4)
Well-
capitalized
minimum
December 31, 2021December 31, 2020Well-
capitalized
minimum
December 31, 2021December 31, 2020
Common Equity Tier 1 Capital  $149,305 $147,274  $148,548 $142,854 
Tier 1 Capital  169,568 167,053  150,679 144,962 
Total Capital (Tier 1 Capital + Tier 2 Capital)—Standardized Approach
203,838 205,002 175,427 169,449 
Total Capital (Tier 1 Capital + Tier 2 Capital)—Advanced Approaches
194,006 196,051 166,921 161,447 
Total risk-weighted assets—Standardized Approach1,219,175 1,242,381 1,066,015 1,054,056 
Total risk-weighted assets—Advanced Approaches1,209,374 1,278,977 1,017,774 1,047,088 
Quarterly adjusted average total assets(1)
 2,351,434 2,265,615 1,716,596 1,667,105 
Total Leverage Exposure(2)
2,957,764 2,391,033 2,236,839 2,172,052 
Common Equity Tier 1 Capital ratio(3)
4.5 %    N/A12.25 %11.51 %6.5 %13.93 %13.55 %
Tier 1 Capital ratio(3)
6.0 6.0 %13.91 13.06 8.0 14.13 13.75 
Total Capital ratio(3)
8.0 10.0 16.04 15.33 10.0 16.40 15.42 
Tier 1 Leverage ratio4.0 N/A7.21 7.37 5.0 8.78 8.70 
Supplementary Leverage ratio3.0 N/A5.73 6.99 6.0 6.74 6.67 
In millions of dollars, except ratios
Stated
minimum
CitigroupCitibank
Well-
capitalized
minimum
December 31, 2019December 31, 2018
Well-
capitalized
minimum
December 31, 2019December 31, 2018
Common Equity Tier 1 Capital 
 
$137,798
$139,252
 
$130,791
$129,091
Tier 1 Capital 
 
155,805
158,122
 
132,918
131,215
Total Capital (Tier 1 Capital + Tier 2 Capital)—Standardized Approach
  193,682
195,440
 157,324
155,154
Total Capital (Tier 1 Capital + Tier 2 Capital)—Advanced Approaches
  181,337
183,144
 145,989
144,358
Total risk-weighted assets—Standardized Approach  1,166,523
1,174,448
 1,019,916
1,032,809
Total risk-weighted assets—Advanced Approaches  1,135,553
1,131,933
 932,432
926,229
Quarterly adjusted average total assets(1)
  
1,957,039
1,896,959
 1,459,851
1,398,875
Total Leverage Exposure(2)
  2,507,891
2,465,641
 1,951,701
1,914,663
Common Equity Tier 1 Capital ratio(3)
4.5%    N/A
11.81%11.86%6.5%12.82%12.50%
Tier 1 Capital ratio(3)
6.0
6.0%13.36
13.46
8.0
13.03
12.70
Total Capital ratio(3)
8.0
10.0
15.97
16.18
10.0
15.43
15.02
Tier 1 Leverage ratio4.0
N/A
7.96
8.34
5.0
9.10
9.38
Supplementary Leverage ratio3.0
N/A
6.21
6.41
6.0
6.81
6.85


(1)Tier 1 Leverage ratio denominator.
(1)Tier 1 Leverage ratio denominator.
(2)Supplementary Leverage ratio denominator.
(3)As of December 31, 2019 and 2018, Citigroup’s reportable Common Equity Tier 1 Capital and Tier 1 Capital ratios were the lower derived under the Basel III Standardized Approach, whereas the reportable Total Capital ratios were the lower derived under the Basel III Advanced Approaches framework. As of December 31, 2019 and 2018, Citibank’s reportable Common Equity Tier 1 Capital, Tier 1 Capital and Total Capital ratios were the lower derived under the Basel III Standardized Approach.
(2)Supplementary Leverage ratio denominator.
(3)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, 2021, whereas 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 framework. As of December 31, 2021 and 2020, 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 framework.
(4)Certain of the above prior-period amounts have been revised to conform with enhancements made in the current period.
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, 20192021 and 2018.2020.


Banking Subsidiaries—Constraints on Dividends
There are various legal limitations on the ability of Citigroup’s subsidiary depository institutions to extend credit, pay dividends or otherwise supply funds to Citigroup and its non-bank subsidiaries. The approval of the Office of the Comptroller of the Currency is required if total dividends declared in any calendar year were to exceed amounts specified by the agency’s regulations.
In determining the dividends, each subsidiary depository institution must also consider its effect on applicable risk-based capital and leverage ratio requirements, as well as policy statements of the federal bank regulatory agencies that indicate that banking organizations should generally pay dividends out of current operating earnings. Citigroup received $17.3$6.2 billion and $8.3$2.3 billion in dividends from Citibank during 20192021 and 2018,2020, respectively.

228


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 dollarsNet
unrealized
gains (losses)
on debt securities
Debt valuation adjustment (DVA)(1)
Cash flow hedges(2)
Benefit plans(3)
Foreign
currency
translation
adjustment (CTA), net of hedges
(4)(5)
Excluded component of fair value hedgesAccumulated
other
comprehensive income (loss)
Balance, December 31, 2018$(2,250)$192 $(728)$(6,257)$(28,070)$(57)$(37,170)
Other comprehensive income before reclassifications3,065 (1,151)549 (758)(321)25 1,409 
Increase (decrease) due to amounts
reclassified from AOCI
(1,080)15 302 206 — — (557)
Change, net of taxes
$1,985 $(1,136)$851 $(552)$(321)$25 $852 
Balance, December 31, 2019$(265)$(944)$123 $(6,809)$(28,391)$(32)$(36,318)
Other comprehensive income before reclassifications4,837 (490)2,027 (287)(250)(15)5,822 
Increase (decrease) due to amounts
reclassified from AOCI
(1,252)15 (557)232 — — (1,562)
Change, net of taxes
$3,585 $(475)$1,470 $(55)$(250)$(15)$4,260 
Balance, December 31, 2020$3,320 $(1,419)$1,593 $(6,864)$(28,641)$(47)$(32,058)
Other comprehensive income before reclassifications(3,556)121 (679)797 (2,537)(11)(5,865)
Increase (decrease) due to amounts
reclassified from AOCI
(378)111 (813)215 12 11 (842)
Change, net of taxes$(3,934)$232 $(1,492)$1,012 $(2,525)$ $(6,707)
Balance, December 31, 2021$(614)$(1,187)$101 $(5,852)$(31,166)$(47)$(38,765)

(1)Reflects the after-tax valuation of Citi’s fair value option liabilities. See “Market Valuation Adjustments” in Note 24 to the Consolidated Financial Statements.
(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, Euro, South Korean won, Chilean peso and Japanese yen against the U.S. dollar and changes in related tax effects and hedges for the year ended December 31, 2021. 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. 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)December 31, 2021 includes an approximate $475 million (after-tax) ($625 million pretax) currency translation adjustment (CTA) loss (net of hedges) associated with Citi’s agreement to sell its consumer banking business in Australia (see Note 2 to the Consolidated Financial Statements). The loss on sale primarily reflects the impact of the CTA loss (net of hedges) already reflected in AOCI. Upon closing, the CTA-related balance will be removed from AOCI, resulting in a neutral impact from CTA to Citi’s Common Equity Tier 1 Capital.

229

In millions of dollarsNet
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)
Balance, December 31, 2016$(799)$(352)$(560)$(5,164)$(25,506)$
$(32,381)
Adjustment to opening balance, net
  of taxes(6)
$504
$
$
$
$
$
$504
Adjusted balance, beginning of period$(295)$(352)$(560)$(5,164)$(25,506)$
$(31,877)
Impact of Tax Reform(7)
$(223)$(139)$(113)$(1,020)$(1,809)$
$(3,304)
Other comprehensive income before
  reclassifications
(186)(426)(111)(158)1,607

726
Increase (decrease) due to amounts
  reclassified from AOCI 
(454)(4)86
159


(213)
Change, net of taxes 
$(863)$(569)$(138)$(1,019)$(202)$
$(2,791)
Balance, December 31, 2017$(1,158)$(921)$(698)$(6,183)$(25,708)$
$(34,668)
Adjustment to opening balance, net
  of taxes(8)
$(3)$
$
$
$
$
$(3)
Adjusted balance, beginning of period$(1,161)$(921)$(698)$(6,183)$(25,708)$
$(34,671)
Other comprehensive income before reclassifications(866)1,081
(135)(240)(2,607)(57)(2,824)
Increase (decrease) due to amounts reclassified from AOCI(9)
(223)32
105
166
245

325
Change, net of taxes 
$(1,089)$1,113
$(30)$(74)$(2,362)$(57)$(2,499)
Balance at December 31, 2018$(2,250)$192
$(728)$(6,257)$(28,070)$(57)$(37,170)
Other comprehensive income before
  reclassifications
3,065
(1,151)549
(758)(647)25
1,083
Increase (decrease) due to amounts
  reclassified from AOCI
(1,080)15
302
206
326

(231)
Change, net of taxes$1,985
$(1,136)$851
$(552)$(321)$25
$852
Balance at December 31, 2019$(265)$(944)$123
$(6,809)$(28,391)$(32)$(36,318)
(1)
Changes in DVA are reflected as a component of AOCI, pursuant to the adoption of ASU 2016-01 relating to the presentation of DVA on fair value option liabilities.

(2)Primarily driven by Citi’s pay fixed/receive floating interest rate swap programs that hedge the floating rates on liabilities.
(3)Primarily reflects adjustments based on the quarterly actuarial valuations of the Company’s significant pension and postretirement plans, annual actuarial valuations of all other plans and amortization of amounts previously recognized in other comprehensive income.
(4)Primarily reflects the movements in (by order of impact) the Indian rupee, Brazilian real, Chilean peso, and Euro against the U.S. dollar and changes in related tax effects and hedges for the year ended December 31, 2019. Primarily reflects the movements in (by order of impact) the Brazilian real, Indian rupee, Mexican peso, and Australian dollar against the U.S. dollar and changes in related tax effects and hedges for the year ended December 31, 2018. Primarily reflects the movements in (by order of impact) the Euro, Mexican peso, Polish zloty and South Korean won against the U.S. dollar and changes in related tax effects and hedges for the year ended December 31, 2017. Amounts recorded in the CTA component of AOCI remain in AOCI until the sale or substantial liquidation of the foreign entity, at which point such amounts related to the foreign entity are reclassified into earnings.
(5)
Beginning in the first quarter of 2018, changes in the excluded component of fair value hedges are reflected as a component of AOCI, pursuant to the early adoption of ASU 2017-12, Targeted Improvements to Accounting for Hedging Activities. See Note 1 of the Consolidated Financial Statements for further information regarding this change.
(6)
In the second quarter of 2017, Citi early adopted ASU 2017-08Upon adoption, a cumulative effect adjustment was recorded to reduce Retained earnings, effective January 1, 2017, for the incremental amortization of cumulative fair value hedge adjustments on callable state and municipal debt securities. See Note 1 to the Consolidated Financial Statements.
(7)
In the fourth quarter of 2017, Citi adopted ASU 2018-02, which transferred these amounts from AOCI to Retained earnings. See Note 1 to the Consolidated Financial Statements.
(8)
Citi adopted ASU 2016-01 and ASU 2018-03 on January 1, 2018. Upon adoption, a cumulative effect adjustment was recorded from AOCI to Retained earnings for net unrealized gains on former AFS equity securities. For additional information, see Note 1 to the Consolidated Financial Statements.
(9)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.

The pretax and after-tax changes in each component of Accumulated other comprehensive income (loss) were as follows:
In millions of dollarsPretax
Tax effect(1)
After-tax
Balance, December 31, 2016$(42,035)$9,654
$(32,381)
Adjustment to opening balance(2)
803
(299)504
Adjusted balance, beginning of period

$(41,232)$9,355
$(31,877)
Change in net unrealized gains (losses) on investment securities(1,088)225
(863)
Debt valuation adjustment (DVA)(680)111
(569)
Cash flow hedges(37)(101)(138)
Benefit plans14
(1,033)(1,019)
Foreign currency translation adjustment1,795
(1,997)(202)
Change$4
$(2,795)$(2,791)
Balance, December 31, 2017$(41,228)$6,560
$(34,668)
Adjustment to opening balance(3)
(4)1
(3)
Adjusted balance, beginning of period$(41,232)$6,561
$(34,671)
Change in net unrealized gains (losses) on investment securities(1,435)346
(1,089)
Debt valuation adjustment (DVA)1,415
(302)1,113
Cash flow hedges(38)8
(30)
Benefit plans(94)20
(74)
Foreign currency translation adjustment(2,624)262
(2,362)
Excluded component of fair value hedges

(74)17
(57)
Change$(2,850)$351
$(2,499)
Balance, December 31, 2018$(44,082)$6,912
$(37,170)
Change in net unrealized gains (losses) on AFS debt securities2,633
(648)1,985
Debt valuation adjustment (DVA)(1,473)337
(1,136)
Cash flow hedges1,120
(269)851
Benefit plans(671)119
(552)
Foreign currency translation adjustment(332)11
(321)
Excluded component of fair value hedges33
(8)25
Change$1,310
$(458)$852
Balance, December 31, 2019$(42,772)$6,454
$(36,318)

(1)
Includes the impact of ASU 2018-02, which transferred amounts from AOCI to Retained earnings. See Note 1 to the Consolidated Financial Statements.
In millions of dollarsPretaxTax effectAfter-tax
Balance, December 31, 2018$(44,082)$6,912 $(37,170)
Change in net unrealized gains (losses) on debt securities2,633 (648)1,985 
Debt valuation adjustment (DVA)(1,473)337 (1,136)
Cash flow hedges1,120 (269)851 
Benefit plans(671)119 (552)
Foreign currency translation adjustment(332)11 (321)
Excluded component of fair value hedges33 (8)25 
Change$1,310 $(458)$852 
Balance, December 31, 2019$(42,772)$6,454 $(36,318)
Change in net unrealized gains (losses) on debt securities4,799 (1,214)3,585 
Debt valuation adjustment (DVA)(616)141 (475)
Cash flow hedges1,925 (455)1,470 
Benefit plans(78)23 (55)
Foreign currency translation adjustment(227)(23)(250)
Excluded component of fair value hedges(23)(15)
Change$5,780 $(1,520)$4,260 
Balance, December 31, 2020$(36,992)$4,934 $(32,058)
Change in net unrealized gains (losses) on debt securities(5,301)1,367 (3,934)
Debt valuation adjustment (DVA)296 (64)232 
Cash flow hedges(1,969)477 (1,492)
Benefit plans1,252 (240)1,012 
Foreign currency translation adjustment(2,671)146 (2,525)
Excluded component of fair value hedges2 (2) 
Change$(8,391)$1,684 $(6,707)
Balance, December 31, 2021$(45,383)$6,618 $(38,765)



230


(2)
In the second quarter of 2017, Citi early adopted ASU 2017-08. Upon adoption, a cumulative effect adjustment was recorded to reduce Retained earnings, effective January 1, 2017, for the incremental amortization of cumulative fair value hedge adjustments on callable state and municipal debt securities. See Note 1 to the Consolidated Financial Statements.
(3)
Citi adopted ASU 2016-01 and ASU 2018-03 on January 1, 2018. Upon adoption, a cumulative effect adjustment was recorded from AOCI to Retained earnings for net unrealized gains on former AFS equity securities. For additional information, see Note 1 to the Consolidated Financial Statements.






The Company recognized pretax gains (losses)(gains) losses related to amounts in AOCI reclassified to the Consolidated Statement of Income as follows:

Increase (decrease) in AOCI due to amounts reclassified to Consolidated Statement of Income
Year ended December 31,
In millions of dollars202120202019
Realized (gains) losses on sales of investments$(665)$(1,756)$(1,474)
Gross impairment losses181 109 23 
Subtotal, pretax$(484)$(1,647)$(1,451)
Tax effect106 395 371 
Net realized (gains) losses on investments, after-tax(1)
$(378)$(1,252)$(1,080)
Realized DVA (gains) losses on fair value option liabilities, pretax$144 $20 $20 
Tax effect(33)(5)(5)
Net realized DVA, after-tax$111 $15 $15 
Interest rate contracts$(1,075)$(734)$384 
Foreign exchange contracts4 
Subtotal, pretax$(1,071)$(730)$391 
Tax effect258 173 (89)
Amortization of cash flow hedges, after-tax(2)
$(813)$(557)$302 
Amortization of unrecognized:
Prior service cost (benefit)$(23)$(5)$(12)
Net actuarial loss302 322 286 
Curtailment/settlement impact(3)
11 (8)
Subtotal, pretax$290 $309 $275 
Tax effect(75)(77)(69)
Amortization of benefit plans, after-tax(3)
$215 $232 $206 
Excluded component of fair value hedges, pretax$15 $— $— 
Tax effect(4)— — 
Excluded component of fair value hedges, after-tax$11 $— $— 
Foreign currency translation adjustment, pretax$19 $— $— 
Tax effect(7)— — 
Foreign currency translation adjustment, after-tax$12 $— $— 
Total amounts reclassified out of AOCI, pretax
$(1,087)$(2,048)$(765)
Total tax effect245 486 208 
Total amounts reclassified out of AOCI, after-tax
$(842)$(1,562)$(557)

(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.

231
 
Increase (decrease) in AOCI due to amounts reclassified to Consolidated Statement of Income
 Year ended December 31,
In millions of dollars201920182017
Realized (gains) losses on sales of investments$(1,474)$(421)$(778)
Gross impairment losses23
125
63
Subtotal, pretax$(1,451)$(296)$(715)
Tax effect371
73
261
Net realized (gains) losses on investments, after-tax(1)
$(1,080)$(223)$(454)
Realized DVA (gains) losses on fair value option liabilities, pretax$20
$41
$(7)
Tax effect(5)(9)3
Net realized DVA, after-tax$15
$32
$(4)
Interest rate contracts$384
$301
$126
Foreign exchange contracts7
17
10
Subtotal, pretax$391
$318
$136
Tax effect(89)(213)(50)
Amortization of cash flow hedges, after-tax(2)
$302
$105
$86
Amortization of unrecognized   
Prior service cost (benefit)$(12)$(34)$(42)
Net actuarial loss286
248
271
Curtailment/settlement impact(3)
1
6
17
Subtotal, pretax$275
$220
$246
Tax effect(69)(54)(87)
Amortization of benefit plans, after-tax(3)
$206
$166
$159
Foreign currency translation adjustment$
$34
$
Tax effect326
211

Foreign currency translation adjustment$326
$245
$
Total amounts reclassified out of AOCI, pretax
$(765)$317
$(340)
Total tax effect534
8
127
Total amounts reclassified out of AOCI, after-tax
$(231)$325
$(213)
(1)
The pretax amount is reclassified to Realized gains (losses) on sales of investments, net and Gross impairment losses in the Consolidated Statement of Income. See Note 13 to the Consolidated Financial Statements for additional details.

(2)See Note 22 to the Consolidated Financial Statements for additional details.
(3)See Note 8 to the Consolidated Financial Statements for additional details.


20.  PREFERRED STOCK


The following table summarizes the Company’s preferred stock outstanding:

     Redemption
price per depositary
share/preference share
 
Carrying value
 in millions of dollars
 Issuance dateRedeemable by issuer beginningDividend
rate
Number
of depositary
shares
December 31,
2019
December 31,
2018
Series A(1)
October 29, 2012January 30, 20235.950%$1,000
1,500,000
$1,500
$1,500
Series B(2)
December 13, 2012February 15, 20235.900
1,000
750,000
750
750
Series D(3)
April 30, 2013May 15, 20235.350
1,000
1,250,000
1,250
1,250
Series J(4)
September 19, 2013September 30, 20237.125
25
38,000,000
950
950
Series K(5)
October 31, 2013November 15, 20236.875
25
59,800,000
1,495
1,495
Series L(6)
February 12, 2014February 12, 20196.875
25
19,200,000

480
Series M(7)
April 30, 2014May 15, 20246.300
1,000
1,750,000
1,750
1,750
Series N(8)
October 29, 2014November 15, 20195.800
1,000
1,500,000

1,500
Series O(9)
March 20, 2015March 27, 20205.875
1,000
1,500,000
1,500
1,500
Series P(10)
April 24, 2015May 15, 20255.950
1,000
2,000,000
2,000
2,000
Series Q(11)
August 12, 2015August 15, 20205.950
1,000
1,250,000
1,250
1,250
Series R(12)
November 13, 2015November 15, 20206.125
1,000
1,500,000
1,500
1,500
Series S(13)
February 2, 2016February 12, 20216.300
25
41,400,000
1,035
1,035
Series T(14)
April 25, 2016August 15, 20266.250
1,000
1,500,000
1,500
1,500
Series U(15)
September 12, 2019September 12, 20245.000
1,000
1,500,000
1,500

    
 
 $17,980
$18,460
   Redemption
price per depositary
share/preference share
 
Carrying value
 in millions of dollars
 Issuance dateRedeemable by issuer beginningDividend
rate
Number
of depositary
shares
December 31,
2021
December 31,
2020
Series A(1)
October 29, 2012January 30, 20235.950 %$1,000 1,500,000 $1,500 $1,500 
Series B(2)
December 13, 2012February 15, 20235.900 1,000 750,000 750 750 
Series D(3)
April 30, 2013May 15, 20235.350 1,000 1,250,000 1,250 1,250 
Series J(4)
September 19, 2013September 30, 20237.125 25 38,000,000 950 950 
Series K(5)
October 31, 2013November 15, 20236.875 25 59,800,000 1,495 1,495 
Series M(6)
April 30, 2014May 15, 20246.300 1,000 1,750,000 1,750 1,750 
Series P(7)
April 24, 2015May 15, 20255.950 1,000 2,000,000 2,000 2,000 
Series Q(8)
August 12, 2015August 15, 20204.316 1,000 1,250,000  1,250 
Series R(9)
November 13, 2015November 15, 20204.699 1,000 1,500,000  1,500 
Series S(10)
February 2, 2016February 12, 20216.300 25 41,400,000  1,035 
Series T(11)
April 25, 2016August 15, 20266.250 1,000 1,500,000 1,500 1,500 
Series U(12)
September 12, 2019September 12, 20245.000 1,000 1,500,000 1,500 1,500 
Series V(13)
January 23, 2020January 30, 20254.700 1,000 1,500,000 1,500 1,500 
Series W(14)
December 10, 2020December 10, 20254.000 1,000 1,500,000 1,500 1,500 
Series X(15)
February 18, 2021February 18, 20263.875 1,000 2,300,000 2,300 — 
Series Y(16)
October 20, 2021October 20, 20264.150 1,000 1,000,000 1,000  
  $18,995 $19,480 
(1)

(1)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.
(2)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on February 15 and August 15 at a fixed rate until February 15, 2023, thereafter payable quarterly on February 15, May 15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(3)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on May 15 and November 15 at a fixed rate until May 15, 2023, thereafter payable quarterly on February 15, May 15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(4)
Issued as depositary shares, each representing a 1/1,000th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable quarterly on March 30, June 30, September 30 and December 30 at a fixed rate until September 30, 2023, thereafter payable quarterly on the same dates at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(5)
Issued as depositary shares, each representing a 1/1,000th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable quarterly on February 15, May 15, August 15 and November 15 at a fixed rate until November 15, 2023, thereafter payable quarterly on the same dates at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(6)The Series L preferred stock was redeemed in full on February 12, 2019.
(7)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on May 15 and November 15 at a fixed rate until May 15, 2024, thereafter payable quarterly on February 15, May 15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(8)The Series N preferred stock was redeemed in full on November 15, 2019.
(9)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on March 27 and September 27 at a fixed rate until, but excluding, March 27, 2020, and thereafter payable quarterly on March 27, June 27, September 27 and December 27 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(10)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on May 15 and November 15 at a fixed rate until, but excluding, May 15, 2025, and thereafter payable quarterly on February 15, May 15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(11)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on February 15 and August 15 at a fixed rate until, but excluding, August 15, 2020, and thereafter payable quarterly on February 15, May 15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(12)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on May 15 and November 15 at a fixed rate until, but excluding, November 15, 2020, and thereafter payable quarterly on February 15, May 15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.
(13)
Issued as depositary shares, each representing a 1/1,000th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable quarterly on February 12, May 12, August 12 and November 12 at a fixed rate, in each case when, as and if declared by the Citi Board of Directors.
(14)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on February 15 and August 15 at a fixed rate until, but excluding, August 15, 2026, thereafter payable quarterly on February 15, May 15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

(15)
Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on March 12 and September 12 at a fixed rate until, but excluding, September 12, 2024, thereafter payable quarterly on March 12, June 12, September 12 and December 12 at a floating rate, in each case when, as and if declared by the Citi Board of Directors.

During 2019, Citi distributed $1,109 million in dividends on its outstanding preferred stock. On January 15, 2020, Citi declared preferred dividends of approximately $291 million for the first quarter of 2020. During the first quarter of 2020, Citi issued 1.5 million Series V preferred shares for $1.5 billion. Semi-annual dividends on Series V, assuming such dividends are declared by the Citi Board of Directors, will be distributed beginningDirectors.
(2)Issued as depositary shares, each representing a 1/25th interest in a share of the third quartercorresponding series of 2020. Asnon-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.
(3)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 21, 2020,15, May 15, August 15 and November 15 at a floating rate, in each case when, as and if declared by the Citi estimates it will distributeBoard of Directors.
(4)Issued as depositary shares, each representing a 1/1,000th interest in a share of the corresponding series of non-cumulative perpetual preferred dividendsstock. 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 approximately $253 million, $328 millionDirectors.
(5)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 $253 millionNovember 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 second, thirdCiti Board of Directors.
(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 May 15 and fourth quartersNovember 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 2020, respectively.Directors.

(7)Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on May 15 and November 15 at a fixed rate until, 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.

(8)The Series Q preferred stock was redeemed in full on May 17, 2021.
(9)The Series R preferred stock was redeemed in full on May 17, 2021.
(10)The Series S preferred stock was redeemed in full on February 12, 2021.
(11)Issued as depositary shares, each representing a 1/25th interest in a share of the corresponding series of non-cumulative perpetual preferred stock. Dividends are payable semiannually on February 15 and August 15 at a fixed rate until, but excluding, August 15, 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.
(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 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.
(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 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.
(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 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.
232


(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 February 18, May 18, August 18 and November 18 at a fixed rate until, but excluding, February 18, 2026, 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.
(16)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 February 15, May 15, August 15 and November 15 at a fixed rate until, but excluding, November 15, 2026, 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.








233


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.clients and to obtain liquidity and optimize capital efficiency by securitizing certain of Citi’s financial assets. 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 insufficientdescribed in Note 1 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).Consolidated Financial Statements. 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,(e.g., 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.


234


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, 2019As of December 31, 2021
 
Maximum exposure to loss in significant unconsolidated VIEs(1)
Maximum exposure to loss in significant unconsolidated VIEs(1)
 
Funded exposures(2)
Unfunded exposures 
Funded exposures(2)
Unfunded exposures
In millions of dollars
Total
involvement
with SPE
assets
Consolidated
VIE/SPE assets
Significant
unconsolidated
VIE assets(3)
Debt
investments
Equity
investments
Funding
commitments
Guarantees
and
derivatives
TotalIn millions of dollarsTotal
involvement
with SPE
assets
Consolidated
VIE/SPE assets
Significant
unconsolidated
VIE assets(3)
Debt
investments
Equity
investments
Funding
commitments
Guarantees
and
derivatives
Total
Credit card securitizations$43,534
$43,534
$
$
$
$
$
$
Credit card securitizations$31,518 $31,518 $ $ $ $ $ $ 
Mortgage securitizations(4)
   
Mortgage securitizations(4)
U.S. agency-sponsored117,374

117,374
2,671


72
2,743
U.S. agency-sponsored113,641  113,641 1,582   43 1,625 
Non-agency-sponsored39,608
1,187
38,421
876


1
877
Non-agency-sponsored60,851 632 60,219 2,479  5  2,484 
Citi-administered asset-backed commercial paper conduits15,622
15,622






Citi-administered asset-backed commercial paper conduits14,018 14,018       
Collateralized loan obligations (CLOs)17,395

17,395
4,199



4,199
Collateralized loan obligations (CLOs)8,302  8,302 2,636    2,636 
Asset-based financing196,728
6,139
190,589
23,756
1,151
9,524

34,431
Asset-based financing(5)
Asset-based financing(5)
246,632 11,085 235,547 32,242 1,139 12,189  45,570 
Municipal securities tender option bond trusts (TOBs)6,950
1,458
5,492
4

3,544

3,548
Municipal securities tender option bond trusts (TOBs)3,251 905 2,346 2  1,498  1,500 
Municipal investments20,312

20,312
2,636
4,274
3,034

9,944
Municipal investments20,597 3 20,594 2,512 3,617 3,562  9,691 
Client intermediation1,455
1,391
64
4



4
Client intermediation904 297 607 75   224 299 
Investment funds827
174
653
5

16
1
22
Investment funds498 179 319   12 1 13 
Other352
1
351
169

39

208
Other        
Total$460,157
$69,506
$390,651
$34,320
$5,425
$16,157
$74
$55,976
Total$500,212 $58,637 $441,575 $41,528 $4,756 $17,266 $268 $63,818 
As of December 31, 2020
Maximum exposure to loss in significant unconsolidated VIEs(1)
Funded exposures(2)
Unfunded exposures
In millions of dollarsTotal
involvement
with SPE
assets
Consolidated
VIE/SPE assets
Significant
unconsolidated
VIE assets(3)
Debt
investments
Equity
investments
Funding
commitments
Guarantees
and
derivatives
Total
Credit card securitizations$32,423 $32,423 $— $— $— $— $— $— 
Mortgage securitizations(4)
U.S. agency-sponsored123,999 — 123,999 1,948 — — 61 2,009 
Non-agency-sponsored46,132 939 45,193 2,550 — 2,553 
Citi-administered asset-backed commercial paper conduits16,730 16,730 — — — — — — 
Collateralized loan obligations (CLOs)18,332 — 18,332 4,273 — — — 4,273 
Asset-based financing(5)
222,274 8,069 214,205 25,153 1,587 9,114 — 35,854 
Municipal securities tender option bond trusts (TOBs)3,349 835 2,514 — 1,611 — 1,611 
Municipal investments20,335 — 20,335 2,569 4,056 3,041 — 9,666 
Client intermediation1,352 910 442 88 — — 56 144 
Investment funds488 153 335 — — 15 — 15 
Other— — — 
Total$485,414 $60,059 $425,355 $36,581 $5,643 $13,783 $118 $56,125 

(1)    The definition of maximum exposure to loss is included in the text that follows this table.
(2)    Included on Citigroup’s December 31, 2021 and 2020 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 re-securitization SPEs are not consolidated. See “Re-securitizations” below for further discussion.
(5)    Included within this line are loans to third-party sponsored private equity funds, which represent $100 billion and $78 billion in unconsolidated VIE assets and $497 million and $425 million in maximum exposure to loss as of December 31, 2021 and 2020, respectively.
 As of December 31, 2018
    
Maximum exposure to loss in significant unconsolidated VIEs(1)
    
Funded exposures(2)
Unfunded exposures 
In millions of dollars
Total
involvement
with SPE
assets
Consolidated
VIE/SPE assets
Significant
unconsolidated
VIE assets(3)
Debt
investments
Equity
investments
Funding
commitments
Guarantees
and
derivatives
Total
Credit card securitizations$46,232
$46,232
$
$
$
$
$
$
Mortgage securitizations(4)
        
U.S. agency-sponsored116,563

116,563
3,038


60
3,098
Non-agency-sponsored30,886
1,498
29,388
431


1
432
Citi-administered asset-backed commercial paper conduits18,750
18,750






Collateralized loan obligations (CLOs)21,837

21,837
5,891


9
5,900
Asset-based financing99,433
628
98,805
21,640
715
9,757

32,112
Municipal securities tender option bond trusts (TOBs)7,998
1,776
6,222
9

4,262

4,271
Municipal investments18,044
3
18,041
2,813
3,922
2,738

9,473
Client intermediation858
614
244
172


2
174
Investment funds1,272
440
832
12

1
1
14
Other63
3
60
37

23

60
Total$361,936
$69,944
$291,992
$34,043
$4,637
$16,781
$73
$55,534
235


(1)The definition of maximum exposure to loss is included in the text that follows this table.
(2)Included on Citigroup’s December 31, 2019 and 2018 Consolidated Balance Sheet.
(3)A significant unconsolidated VIE is an entity in which the Company has any variable interest or continuing involvement considered to be significant, regardless of the likelihood of loss.
(4)Citigroup mortgage securitizations also include agency and non-agency (private label) re-securitization activities. These SPEs are not consolidated. See “Re-securitizations” below for further discussion.




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 commitmentcommitment. As of December 31, 2021 and 2020, the Company’s maximum exposure to loss related to these deals was $55.6 billion and $57.0 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);
Trading account assets or Investments, in which the Company has no other involvement with the related securitization entity deemed to be significant (for more information on these positions, see Notes 13 and 24 to the Consolidated Financial Statements);
certain representations and warranties exposures in legacy ICG-sponsored mortgage- and asset-backed securitizations in which the Company has no variable interest or continuing involvement as servicer. The outstanding balance of mortgage loans securitized during 2005 to 2008 in which the Company has no variable interest or continuing involvement as servicer was approximately $6 billion and $7 billion at December 31, 2019 and 2018, respectively;
certain representations and warranties exposures in Citigroup residential mortgage securitizations, in which the original mortgage loan balances are no longer outstanding; and
VIEs such as trust preferred securities trusts used in connection with the Company’s funding activities. The Company does not have a variable interest in these trusts.


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 formclassification of the asset (e.g., loan or security) and the Company’s standardassociated accounting policies for the asset type and line of business.model ascribed to that classification.
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.

236


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:

December 31, 2019December 31, 2018December 31, 2021December 31, 2020
In millions of dollars
Liquidity
facilities
Loan/equity
commitments
Liquidity
facilities
Loan/equity
commitments
In millions of dollarsLiquidity
facilities
Loan/equity
commitments
Liquidity
facilities
Loan/equity
commitments
Non-agency-sponsored mortgage securitizationsNon-agency-sponsored mortgage securitizations$ $5 $— $
Asset-based financing$
$9,524
$
$9,757
Asset-based financing 12,189 — 9,114 
Municipal securities tender option bond trusts (TOBs)3,544

4,262

Municipal securities tender option bond trusts (TOBs)1,498  1,611 — 
Municipal investments
3,034

2,738
Municipal investments 3,562 — 3,041 
Investment funds
16

1
Investment funds 12 — 15 
Other
39

23
Other  — — 
Total funding commitments$3,544
$12,613
$4,262
$12,519
Total funding commitments$1,498 $15,768 $1,611 $12,172 

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 dollarsDecember 31, 2019December 31, 2018
Cash$
$
Trading account assets2.6
3.0
Investments9.9
10.7
Total loans, net of allowance26.7
24.5
Other0.5
0.5
Total assets$39.7
$38.7


In billions of dollarsDecember 31, 2021December 31, 2020
Cash$ $— 
Trading account assets1.4 2.0 
Investments8.8 10.6 
Total loans, net of allowance35.4 29.3 
Other0.8 0.3 
Total assets$46.4 $42.2 
237


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 2 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 0no 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 dollarsDecember 31, 2019December 31, 2018
Ownership interests in principal amount of trust credit card receivables
   Sold to investors via trust-issued securities$19.7
$27.3
   Retained by Citigroup as trust-issued securities6.2
7.6
   Retained by Citigroup via non-certificated interests17.8
11.3
Total$43.7
$46.2

In billions of dollarsDecember 31, 2021December 31, 2020
Ownership interests in principal amount of trust credit card receivables
Sold to investors via trust-issued securities$9.7 $15.7 
Retained by Citigroup as trust-issued securities7.2 7.9 
Retained by Citigroup via non-certificated interests16.1 11.1 
Total$33.0 $34.7 

The following table summarizes selected cash flow information related to Citigroup’s credit card securitizations:
In billions of dollars201920182017
Proceeds from new securitizations$
$6.8
$11.1
Pay down of maturing notes(7.6)(8.3)(5.0)

In billions of dollars202120202019
Proceeds from new securitizations$ $0.3 $— 
Pay down of maturing notes(6.0)(4.3)(7.6)

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 2 securitization trusts—Master Trust and Omni Trust. The liabilities of the trusts are included on the Consolidated Balance Sheet, excluding those retained by Citigroup.
    


Master Trust Liabilities (at Par Value)
The Master Trust issues fixed- and floating-rate term notes. Some of the term notes may be issued to multi-seller commercial paper conduits. The weighted average maturity of
the third-party term notes issued by the Master Trust was 3.13.6 years as of December 31, 20192021 and 3.02.9 years as of December 31, 2018.2020.
In billions of dollarsDec. 31, 2019Dec. 31, 2018
Term notes issued to third parties$18.2
$25.8
Term notes retained by Citigroup affiliates4.3
5.7
Total Master Trust liabilities$22.5
$31.5

In billions of dollarsDec. 31, 2021Dec. 31, 2020
Term notes issued to third parties$8.4 $13.9 
Term notes retained by Citigroup affiliates2.2 2.7 
Total Master Trust liabilities$10.6 $16.6 

Omni Trust Liabilities (at Par Value)
The Omni Trust issues fixed- and floating-rate term notes, some of which are purchased by multi-seller commercial paper conduits. The weighted average maturity of the third-party term notes issued by the Omni Trust was 1.6 years as of December 31, 20192021 and 2.71.1 years as of December 31, 2018.2020.
In billions of dollarsDec. 31, 2019Dec. 31, 2018
Term notes issued to third parties$1.5
$1.5
Term notes retained by Citigroup affiliates1.9
1.9
Total Omni Trust liabilities$3.4
$3.4

In billions of dollarsDec. 31, 2021Dec. 31, 2020
Term notes issued to third parties$1.3 $1.8 
Term notes retained by Citigroup affiliates5.0 5.2 
Total Omni Trust liabilities$6.3 $7.0 


238


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 that most significantly impact the entities’ economic performance 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:
201920182017202120202019
In billions of dollarsU.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
In billions of dollarsU.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
Principal securitized$5.3
$18.9
$4.0
$5.6
$7.8
$7.3
Principal securitized$6.1 $25.2 $9.4 $11.3 $5.3 $15.6 
Proceeds from new securitizations(1)
5.5
18.9
4.2
7.1
8.1
7.3
Proceeds from new securitizations(1)
6.4 25.4 10.0 11.4 5.5 15.5 
Contractual servicing fees received0.1

0.1

0.2

Contractual servicing fees received0.1  0.1 — 0.1 
Cash flows received on retained interests and other net cash flowsCash flows received on retained interests and other net cash flows 0.1 — — — 
Purchases of previously transferred financial assets

0.2

0.2

0.4

Purchases of previously transferred financial assets0.2  0.4 — 0.2 

Note: Excludes re-securitization transactions.
(1)The proceeds from new securitizations in 2019 include $0.2 billion related to personal loan securitizations.
(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, 20192021 were $16$3.9 million and $99$493.4 million, respectively.
Agency and non-agency securitization gains for the year ended December 31, 20182020 were $17$88.4 million and $36$139.4 million, respectively, and $28$16 million and $70$73.4 million, respectively, for the year ended December 31, 2017.2019.

20212020
Non-agency-sponsored mortgages(1)
Non-agency-sponsored mortgages(1)
In millions of dollarsU.S. agency-
sponsored mortgages
Senior
interests(2)
Subordinated
interests
U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Carrying value of retained interests(3)
$374 $1,452 $955 $315 $1,210 $145 

239


 20192018
  
Non-agency-sponsored mortgages(1)
 
Non-agency-sponsored mortgages(1)
In millions of dollarsU.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
(3)
U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Carrying value of retained interests(2)
$491
$748
$102
$564
$300
$51
(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 $73 million related to personal loan securitizations at December 31, 2021.
(3)    Retained interests consist of Level 2 and 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.

(1)Disclosure of non-agency-sponsored mortgages as senior and subordinated interests is indicative of the interests’ position in the capital structure of the securitization.
(2)Retained interests consist of Level 2 or Level 3 assets depending on the observability of significant inputs. See Note 24 to the Consolidated Financial Statements for more information about fair value measurements.
(3)Senior interests in non-agency-sponsored mortgages include $150 million related to personal loan securitizations at December 31, 2019.

Key assumptions used in measuring the fair value of retained interests at the date of sale or securitization of mortgage receivables were as follows:

December 31, 2019December 31, 2021
 
Non-agency-sponsored mortgages(1)
Non-agency-sponsored mortgages(1)
U.S. agency- 
sponsored mortgages
Senior 
interests
Subordinated 
interests
U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Weighted average discount rate9.3%3.6%4.6%Weighted average discount rate8.7 %2.2 %2.8 %
Weighted average constant prepayment rate12.9%10.5%7.6%Weighted average constant prepayment rate5.5 %6.3 %11.0 %
Weighted average anticipated net credit losses(2)
   NM
3.9%2.8%
Weighted average anticipated net credit losses(2)
   NM1.8 %1.0 %
Weighted average life6.6 years
3 years
11.4 years
Weighted average life7.4 years3.9 years5.4 years
December 31, 2020
Non-agency-sponsored mortgages(1)
U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Weighted average discount rate5.4 %1.7 %3.0 %
Weighted average constant prepayment rate25.8 %3.4 %25.0 %
Weighted average anticipated net credit losses(2)
   NM1.7 %0.5 %
Weighted average life4.8 years3.8 years2.3 years
 December 31, 2018
  
Non-agency-sponsored mortgages(1)
 U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Weighted average discount rate9.6%2.8%4.4%
Weighted average constant prepayment rate5.8%8.0%9.1%
Weighted average anticipated net credit losses(2)
   NM
4.4%3.4%
Weighted average life7.5 years
5.5 years
6.7 years

(1)    Disclosure of non-agency-sponsored mortgages as senior and subordinated interests is indicative of the interests’ position in the capital structure of the securitization.
(2)    Anticipated net credit losses represent estimated loss severity associated with defaulted mortgage loans underlying the mortgage securitizations disclosed above. Anticipated net credit losses, in this instance, do not represent total credit losses incurred to date, nor do they represent credit losses expected on retained interests in mortgage securitizations.
NM Anticipated net credit losses are not meaningful due to U.S. agency guarantees.

(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.
NMAnticipated 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 or securitization of mortgage receivables were as follows:

December 31, 2021
Non-agency-sponsored mortgages(1)
U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Weighted average discount rate3.7 %16.2 %4.0 %
Weighted average constant prepayment rate14.5 %6.8 %9.0 %
Weighted average anticipated net credit losses(2)
NM1.0 %2.0 %
Weighted average life5.1 years8.8 years18.0 years
December 31, 2020
Non-agency-sponsored mortgages(1)
U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Weighted average discount rate5.9 %7.2 %4.3 %
Weighted average constant prepayment rate22.7 %5.3 %4.7 %
Weighted average anticipated net credit losses(2)
   NM1.2 %1.4 %
Weighted average life4.5 years5.3 years4.7 years

(1)    Disclosure of non-agency-sponsored mortgages as senior and subordinated interests is indicative of the interests’ position in the capital structure of the securitization.
240


 December 31, 2019
  
Non-agency-sponsored mortgages(1)
 
U.S. agency- 
sponsored mortgages
Senior 
interests
Subordinated 
interests
Weighted average discount rate9.8%7.6%4.2%
Weighted average constant prepayment rate10.1%3.6%6.1%
Weighted average anticipated net credit losses(2)
NM
5.2%2.7%
Weighted average life6.6 years
5.9 years
29.3 years
(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.
 December 31, 2018
  
Non-agency-sponsored mortgages(1)
 
U.S. agency- 
sponsored mortgages
Senior 
interests
Subordinated 
interests
Weighted average discount rate7.8%9.3%
Weighted average constant prepayment rate9.1%8.0%
Weighted average anticipated net credit losses(2)
   NM
40.0%
Weighted average life6.4 years
6.6 years


(1)Disclosure of non-agency-sponsored mortgages as senior and subordinated interests is indicative of the interests’ position in the capital structure of the securitization.
(2)Anticipated net credit losses represent estimated loss severity associated with defaulted mortgage loans underlying the mortgage securitizations disclosed above. Anticipated net credit losses, in this instance, do not represent total credit losses incurred to date, nor do they represent credit losses expected on retained interests in mortgage securitizations.
NMAnticipated net credit losses are not meaningful due to U.S. agency guarantees.





The sensitivity of the fair value to adverse changes of 10% and 20% in each of the key assumptions areis 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.
 December 31, 2019
  Non-agency-sponsored mortgages
In millions of dollars
U.S. agency- 
sponsored mortgages
Senior 
interests
Subordinated 
interests
Discount rate   
   Adverse change of 10%$(18)$
$(1)
   Adverse change of 20%(35)(1)(1)
Constant prepayment rate   
   Adverse change of 10%(18)

   Adverse change of 20%(35)

Anticipated net credit losses   
   Adverse change of 10%NM


   Adverse change of 20%NM



 December 31, 2018
  Non-agency-sponsored mortgages
In millions of dollars
U.S. agency- 
sponsored mortgages
Senior 
interests
Subordinated 
interests
Discount rate   
   Adverse change of 10%$(16)$
$
   Adverse change of 20%(32)

Constant prepayment rate   
   Adverse change of 10%(21)

   Adverse change of 20%(41)

Anticipated net credit losses   
   Adverse change of 10%NM


   Adverse change of 20%NM



December 31, 2021
Non-agency-sponsored mortgages
In millions of dollars
U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Discount rate
Adverse change of 10%$(6)$(1)$ 
Adverse change of 20%(11)(1) 
Constant prepayment rate
Adverse change of 10%(19)  
Adverse change of 20%(37)  
Anticipated net credit losses
Adverse change of 10%NM  
Adverse change of 20%NM  
December 31, 2020
Non-agency-sponsored mortgages
In millions of dollars
U.S. agency-
sponsored mortgages
Senior
interests
Subordinated
interests
Discount rate
Adverse change of 10%$(8)$— $(1)
Adverse change of 20%(15)(1)(1)
Constant prepayment rate
Adverse change of 10%(21)— — 
Adverse change of 20%(40)— — 
Anticipated net credit losses
Adverse change of 10%NM— — 
Adverse change of 20%NM— — 

NMAnticipated net credit losses are not meaningful due to U.S. agency guarantees.
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:
 Securitized assets90 days past dueLiquidation losses
In billions of dollars, except liquidation losses in millions201920182019201820192018
Securitized assets      
Residential mortgages$11.7
$5.2
$0.4
$0.4
$49.0
$54.0
Commercial and other22.3
13.1




Total$34.0
$18.3
$0.4
$0.4
$49.0
$54.0


Securitized assets90 days past dueLiquidation losses
In billions of dollars, except liquidation losses in millions202120202021202020212020
Securitized assets
Residential mortgages(1)
$29.2 $16.9 $0.4 $0.5 $10.6 $26.2 
Commercial and other26.2 23.9  —  — 
Total$55.4 $40.8 $0.4 $0.5 $10.6 $26.2 


(1)     Securitized assets include $0.2 billion of personal loan securitizations as of December 31, 2021.



241


Mortgage Servicing Rights (MSRs)
In connection with the securitization of mortgage loans, Citi’s U.S. consumer mortgage business generally retains the servicing rights, which entitle the Company to a future stream of cash flows based on the outstanding principal balances of the loans and the contractual servicing fee. Failure to service the loans in accordance with contractual requirements may lead to a termination of the servicing rights and the loss of future servicing fees.
These transactions create intangible assets referred to as MSRs, which are recorded at fair value on Citi’s Consolidated Balance Sheet. The fair value of Citi’s capitalized MSRs was $495$404 million and $584$336 million at December 31, 20192021 and 2018,2020, respectively. The MSRs correspond to principal loan balances of $58$47 billion and $62$53 billion as of December 31, 20192021 and 2018,2020, respectively.
The following table summarizes the changes in capitalized MSRs:

In millions of dollars20192018In millions of dollars20212020
Balance, beginning of year$584
$558
Balance, beginning of year$336 $495 
Originations70
58
Originations92 123 
Changes in fair value of MSRs due to changes in inputs and assumptions(84)54
Changes in fair value of MSRs due to changes in inputs and assumptions43 (204)
Other changes(1)
(75)(68)
Other changes(1)
(67)(78)
Sale of MSRs
(18)
Sales of MSRsSales of MSRs  
Balance, as of December 31$495
$584
Balance, as of December 31$404 $336 

(1)Represents changes due to customer payments and passage of time.

(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 dollars201920182017
Servicing fees$148
$172
$276
Late fees8
4
10
Ancillary fees1
8
13
Total MSR fees$157
$184
$299

In millions of dollars202120202019
Servicing fees$131 $142 $148 
Late fees3 58
Ancillary fees  1
Total MSR fees$134 $147 $157 

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, 20192021 and 2018.2020. These securities are
backed by either residential or commercial mortgages and are often structured on behalf of clients.
As of December 31, 2019,2021 and December 31, 2020, Citi held no retained interests in private label re-securitization transactions structured by Citi. As of December 31, 2018, the fair value of Citi-retained interests in private label re-securitization transactions structured by Citi totaled approximately $16 million (all related to re-securitization transactions executed prior to 2016). Of this amount, all was related to subordinated beneficial interests. The original par value of private label re-securitization transactions in which Citi held a retained interest as of December 31, 2018 was approximately $271 million.
The Company also re-securitizes U.S. government-agency guaranteedgovernment-agency-guaranteed mortgage-backed (agency) securities. During the years ended December 31, 20192021 and 2018,2020, Citi transferred agency securities with a fair value of approximately $31.9$46.6 billion and $26.3$42.8 billion, respectively, to re-securitization entities.
As of December 31, 2019,2021, the fair value of Citi-retained interests in agency re-securitization transactions structured by Citi totaled approximately $2.2$1.2 billion (including $1.3 billion$641 million related to re-securitization transactions executed in 2019)2021) compared to $2.5$1.6 billion as of December 31, 20182020 (including $1.4 billion$916 million related to re-securitization transactions executed in 2018)2020), which is recorded in Trading account assets. The original fair valuevalues of agency re-securitization transactions in which Citi holds a retained interest as of December 31, 20192021 and 2018 was2020 were approximately $73.5$78.4 billion and $70.9$83.6 billion, respectively.
As of December 31, 20192021 and 2018,2020, 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.
242


The conduits administered by Citi do not generally invest in liquid securities that are formally rated by third parties. The assets are privately negotiated and structured transactions that are generally designed to be held by the conduit, rather than actively traded and sold. The yield earned by the conduit on each asset is generally tied to the rate on the commercial paper issued by the conduit, thus passing interest rate risk to the client. Each asset purchased by the conduit is structured with transaction-specific credit enhancement features provided by the third-party client seller, including over-collateralization, cash and excess spread collateral accounts, direct recourse or third-party guarantees. These credit enhancements are sized with the objective of approximating a credit rating of A or above, based on Citi’s internal risk ratings. At December 31, 20192021 and 2018,2020, the commercial paper conduits administered by Citi had approximately $15.6$14.0 billion and $18.8$16.7 billion of purchased assets outstanding, respectively, and had incremental funding commitments with clients of approximately $16.3$18.3 billion and $14.0$17.1 billion, respectively.
Substantially all of the funding of the conduits is in the form of short-term commercial paper. At December 31, 20192021 and 2018,2020, the weighted average remaining lives of the commercial paper issued by the conduits were approximately 4970 and 5354 days, respectively.
The primary credit enhancement provided to the conduit investors is in the form of transaction-specific credit enhancements described above. 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. In addition to the transaction-specific credit enhancements, the conduits, other than the governmentgovernment- guaranteed loan conduit, have obtained a letterletters 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 $1.4$1.3 billion as of December 31, 20192021 and $1.7$1.5 billion as of December 31, 2018.2020. 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 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, 20192021 and 2018,2020, the Company owned $5.5$4.9 billion and $5.5$6.6 billion, respectively, of the commercial paper issued by its administered conduits. The Company'sCompany’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
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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 makingmarket-making activities.
The Company generally does not have the power to direct the activities that most significantly impact the economic performance of the CLOs, as this power is generally held by a third-party asset manager of the CLO. As such, those CLOs are not consolidated.
The following tables summarize selected cash flow information and retained interests related to Citigroup CLOs:
In millions of dollars201920182017
Principal securitized$
$
$133
Proceeds from new securitizations

133
Cash flows received on retained interests and other net cash flows72
127
107

In billions of dollars202120202019
Principal securitized$ $0.1 $— 
Proceeds from new securitizations 0.1 — 
Cash flows received on retained interests and other net cash flows1.1 — — 
Purchases of previously transferred financial assets0.2 — — 
In millions of dollarsDec. 31, 2019Dec. 31, 2018Dec. 31, 2017In millions of dollarsDec. 31, 2021Dec. 31, 2020Dec. 31, 2019
Carrying value of retained interests$1,404
$3,142
$4,079
Carrying value of retained interests$921 $1,611 $1,404 


All of Citi’s retained interests were held-to-maturity securities as of December 31, 20192021 and 2018.2020.

Asset-Based Financing
The Company provides loans and other forms of financing to VIEs that hold assets. Those loans are subject to the same credit approvals as all other loans originated or purchased by the Company. Financings in the form of debt securities or derivatives are, in most circumstances, reported in Trading account assets and accounted for at fair value through earnings. The Company generally does not have the power to direct the activities that most significantly impact these VIEs’ economic performance; thus, it does not consolidate them.
The primary types of Citi’s asset-based financings, total assets of the unconsolidated VIEs with significant involvement and Citi’s maximum exposure to loss are shown below. For Citi to realize the maximum loss, the VIE (borrower) would have to default with no recovery from the assets held by the VIE.
 December 31, 2019
In millions of dollars
Total 
unconsolidated 
VIE assets
Maximum 
exposure to 
unconsolidated VIEs
Type  
Commercial and other real estate$31,377
$7,489
Corporate loans7,088
5,802
Other (including investment funds, airlines and shipping)152,124
21,140
Total$190,589
$34,431
 December 31, 2018
In millions of dollars
Total 
unconsolidated 
VIE assets
Maximum 
exposure to 
unconsolidated VIEs
Type  
Commercial and other real estate$23,918
$6,928
Corporate loans6,973
5,744
Other (including investment funds, airlines and shipping)

67,914
19,440
Total$98,805
$32,112

December 31, 2021
In millions of dollars
Total
unconsolidated
VIE assets
Maximum
exposure to
unconsolidated VIEs
Type
Commercial and other real estate$32,932 $7,461 
Corporate loans18,257 12,581 
Other (including investment funds, airlines and shipping)184,358 25,528 
Total$235,547 $45,570 
December 31, 2020
In millions of dollars
Total
unconsolidated
VIE assets
Maximum
exposure to
unconsolidated VIEs
Type
Commercial and other real estate$34,570 $7,758 
Corporate loans12,022 7,654 
Other (including investment funds, airlines and shipping)167,613 20,442 
Total$214,205 $35,854 

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 2 types of TOB trusts: customer and non-customer. Customer TOB trusts are those trusts utilized by customers of the Company to finance their securities, generally municipal securities. The Residuals issued by these trusts are purchased by the customer being financed. Non-customer TOB trusts are generally used by the Company to finance its own municipal securities investments; the Residuals issued by non-customer TOB trusts are purchased by the Company.
With respect to both customer and non-customer TOB trusts, Citi may provide remarketing agent services. If Floaters are optionally tendered and the Company, in its role as remarketing agent, is unable to find a new investor to purchase the optionally tendered Floaters within a specified period of time, Citigroup may, but is not obligated to, purchase the tendered Floaters into its own inventory. The level of the Company’s inventory of such Floaters fluctuates.
For certain customer TOB trusts, Citi may also serve as a voluntary advance provider. In this capacity, the Company may, but is not obligated to, make loan advances to customer TOB trusts to purchase optionally tendered Floaters that have not otherwise been successfully remarketed to new investors. Such loans are secured by pledged Floaters. As of December 31, 2019,2021, Citi had no outstanding voluntary advances to customer TOB trusts.
For certain non-customer trusts, the Company also provides credit enhancement. At December 31, 20192021 and 2018, NaN2020, none of the municipal bonds owned by non-customer TOB trusts were subject to a credit guarantee provided by the Company.
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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 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, 20192021 and 2018,2020, liquidity agreements provided with respect to customer TOB trusts totaled $3.5$1.5 billion and $4.3$1.6 billion, respectively, of which $1.6$0.6 billion and $2.3$0.8 billion, respectively, were offset by reimbursement agreements. For the remaining exposure related to TOB transactions, where the residual owned by the customer was at least 25% of the bond value at the inception of the transaction, no reimbursement agreement was executed.
Citi considers both customer and non-customer TOB trusts to be VIEs. Customer TOB trusts are not consolidated by the Company, as the power to direct the activities that most significantly impact the trust’s economic performance rests with the customer Residual holder, which may unilaterally cause the sale of the trust’s bonds.
Non-customer TOB trusts generally are consolidated because the Company holds the Residual interest and thus has the unilateral power to cause the sale of the trust’s bonds.
The Company also provides other liquidity agreements or letters of credit to customer-sponsored municipal investment funds, which are not variable interest entities, and municipality-related issuers that totaled $7.0$2 billion as of December 31, 20192021 and $6.1$3.6 billion as of December 31, 2018.2020. 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 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,(e.g., 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 employeescolleagues to invest in private equity investments. The Company acts as investment manager for these funds and may provide employeescolleagues with financing on both recourse and non-recourse bases for a portion of the employees’colleagues’ investment commitments.

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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.

,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-
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 the creditworthiness of a party’sparty 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

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example, this may be the case for certain sovereigns, municipalities, central banks and U.S. pension plans.
Exposure to credit risk on derivatives is affected by market volatility, which may impair the ability of counterparties to satisfy their obligations to the Company. Credit limits are established and closely monitored for customers engaged in derivatives transactions. Citi considers the level of legal certainty regarding enforceability of its offsetting rights under master netting agreements and credit support annexes to be an important factor in its risk management process. Specifically, Citi generally transacts much lower volumes of derivatives under master netting agreements where Citi does not have the requisite level of legal certainty regarding enforceability, because such derivatives consume greater amounts of single counterparty credit limits than those executed under enforceable master netting agreements.
Cash collateral and security collateral in the form of G10 government debt securities are often posted by a party to a master netting agreement to secure the net open exposure of the other party; the receiving party is free to commingle/rehypothecate such collateral in the ordinary course of its business. Nonstandard collateral such as corporate bonds, municipal bonds, U.S. agency securities and/or MBS may also be pledged as collateral for derivative transactions. Security collateral posted to open and maintain a master netting agreement with a counterparty, in the form of cash and/or securities, may from time to time be segregated in an account at a third-party custodian pursuant to a tri-party account control agreement.
As of January 1, 2018, Citigroup early adopted ASU 2017-12, Targeted Improvements to Accounting for Hedge Activities. This standard primarily impacts Citi’s accounting for derivatives designated as cash flow hedges and fair value hedges. Refer to the respective sections below for details.
















Information pertaining to Citigroup’s derivativederivatives 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
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.

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Derivative Notionals
 Hedging instruments under
ASC 815
Trading derivative instruments
In millions of dollarsDecember 31,
2019
December 31,
2018
December 31,
2019
December 31,
2018
Interest rate contracts    
Swaps$318,089
$273,636
$17,063,272
$18,138,686
Futures and forwards

3,636,658
4,632,257
Written options

2,114,511
3,018,469
Purchased options

1,857,770
2,532,479
Total interest rate contracts$318,089
$273,636
$24,672,211
$28,321,891
Foreign exchange contracts    
Swaps$63,104
$57,153
$6,063,853
$6,738,158
Futures, forwards and spot38,275
41,410
3,979,188
5,115,504
Written options80
1,726
908,061
1,566,717
Purchased options80
2,104
959,149
1,543,516
Total foreign exchange contracts$101,539
$102,393
$11,910,251
$14,963,895
Equity contracts    
Swaps$
$
$197,893
$217,580
Futures and forwards

66,705
52,053
Written options

560,571
454,675
Purchased options

422,393
341,018
Total equity contracts$
$
$1,247,562
$1,065,326
Commodity and other contracts    
Swaps$
$
$69,445
$79,133
Futures and forwards1,195
802
137,192
146,647
Written options

91,587
62,629
Purchased options

86,631
61,298
Total commodity and other contracts$1,195
$802
$384,855
$349,707
Credit derivatives(1)
    
Protection sold$
$
$603,387
$724,939
Protection purchased

703,926
795,649
Total credit derivatives$
$
$1,307,313
$1,520,588
Total derivative notionals$420,823
$376,831
$39,522,192
$46,221,407

 Hedging instruments under
ASC 815
Trading derivative instruments
In millions of dollarsDecember 31,
2021
December 31,
2020
December 31,
2021
December 31,
2020
Interest rate contracts    
Swaps$267,035 $334,351 $21,873,538 $17,724,147 
Futures and forwards — 2,383,702 4,142,514 
Written options — 1,584,451 1,573,483 
Purchased options — 1,428,376 1,418,255 
Total interest rate contracts$267,035 $334,351 $27,270,067 $24,858,399 
Foreign exchange contracts
Swaps$47,298 $65,709 $6,288,193 $6,567,304 
Futures, forwards and spot50,926 37,080 4,316,242 3,945,391 
Written options 47 664,942 907,338 
Purchased options 53 651,958 900,626 
Total foreign exchange contracts$98,224 $102,889 $11,921,335 $12,320,659 
Equity contracts
Swaps$ $— $269,062 $274,098 
Futures and forwards — 71,363 67,025 
Written options — 492,433 441,003 
Purchased options — 398,129 328,202 
Total equity contracts$ $— $1,230,987 $1,110,328 
Commodity and other contracts
Swaps$ $— $91,962 $80,127 
Futures and forwards2,096 924 157,195 143,175 
Written options — 51,224 71,376 
Purchased options — 47,868 67,849 
Total commodity and other contracts$2,096 $924 $348,249 $362,527 
Credit derivatives(1)
Protection sold$ $— $572,486 $543,607 
Protection purchased — 645,996 612,770 
Total credit derivatives$ $— $1,218,482 $1,156,377 
Total derivative notionals$367,355 $438,164 $41,989,120 $39,808,290 

(1)Credit derivatives are arrangements designed to allow one party (protection buyer) to transfer the credit risk of a “reference asset” to another party (protection seller). These arrangements allow a protection seller to assume the credit risk associated with the reference asset without directly purchasing that asset. The Company enters into credit derivative positions for purposes such as risk management, yield enhancement, reduction of credit concentrations and diversification of overall risk.

(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.

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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, 20192021 and 2018.2020. 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 changesrules 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 $180$340 billion and $100$280 billion as of December 31, 20192021 and 2018,2020, 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.

249


Derivative Mark-to-Market (MTM) Receivables/Payables

In millions of dollars at December 31, 2021
Derivatives classified in
Trading account assets/liabilities(1)(2)
Derivatives instruments designated as ASC 815 hedgesAssetsLiabilities
Over-the-counter$1,167 $6 
Cleared122 89 
Interest rate contracts$1,289 $95 
Over-the-counter$1,338 $1,472 
Cleared6  
Foreign exchange contracts$1,344 $1,472 
Total derivatives instruments designated as ASC 815 hedges$2,633 $1,567 
Derivatives instruments not designated as ASC 815 hedges
Over-the-counter$152,524 $138,114 
Cleared11,579 11,821 
Exchange traded96 44 
Interest rate contracts$164,199 $149,979 
Over-the-counter$133,357 $133,548 
Cleared848 278 
Foreign exchange contracts$134,205 $133,826 
Over-the-counter$23,452 $28,352 
Cleared19  
Exchange traded21,781 21,332 
Equity contracts$45,252 $49,684 
Over-the-counter$29,279 $29,833 
Exchange traded1,065 1,546 
Commodity and other contracts$30,344 $31,379 
Over-the-counter$6,896 $6,959 
Cleared3,322 4,056 
Credit derivatives$10,218 $11,015 
Total derivatives instruments not designated as ASC 815 hedges$384,218 $375,883 
Total derivatives$386,851 $377,450 
Less: Netting agreements(3)
$(292,628)$(292,628)
Less: Netting cash collateral received/paid(4)
(24,447)(29,306)
Net receivables/payables included on the Consolidated Balance Sheet(5)
$69,776 $55,516 
Additional amounts subject to an enforceable master netting agreement,
but not offset on the Consolidated Balance Sheet
Less: Cash collateral received/paid$(907)$(538)
Less: Non-cash collateral received/paid(5,777)(13,607)
Total net receivables/payables(5)
$63,092 $41,371 

(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)Represents the netting of balances with the same counterparty under enforceable netting agreements. Approximately $259 billion, $14 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.
(4)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.
(5)The net receivables/payables include approximately $10 billion of derivative asset and $11 billion of derivative liability fair values not subject to enforceable master netting agreements, respectively.
250


In millions of dollars at December 31, 2020
Derivatives classified in
Trading account assets/liabilities(1)(2)
Derivatives instruments designated as ASC 815 hedgesAssetsLiabilities
Over-the-counter$1,781 $161 
Cleared74 319 
Interest rate contracts$1,855 $480 
Over-the-counter$2,037 $2,042 
Foreign exchange contracts$2,037 $2,042 
Total derivatives instruments designated as ASC 815 hedges$3,892 $2,522 
Derivatives instruments not designated as ASC 815 hedges
Over-the-counter$228,519 $209,330 
Cleared11,041 12,563 
Exchange traded46 38 
Interest rate contracts$239,606 $221,931 
Over-the-counter$153,791 $152,784 
Cleared842 1,239 
Exchange traded— 
Foreign exchange contracts$154,633 $154,024 
Over-the-counter$29,244 $41,036 
Cleared18 
Exchange traded21,274 22,515 
Equity contracts$50,519 $63,569 
Over-the-counter$13,659 $17,076 
Exchange traded879 1,017 
Commodity and other contracts$14,538 $18,093 
Over-the-counter$7,826 $7,951 
Cleared1,963 2,178 
Credit derivatives$9,789 $10,129 
Total derivatives instruments not designated as ASC 815 hedges$469,085 $467,746 
Total derivatives$472,977 $470,268 
Less: Netting agreements(3)
$(364,879)$(364,879)
Less: Netting cash collateral received/paid(4)
(31,137)(37,432)
Net receivables/payables included on the Consolidated Balance Sheet(5)
$76,961 $67,957 
Additional amounts subject to an enforceable master netting agreement,
but not offset on the Consolidated Balance Sheet
Less: Cash collateral received/paid$(1,567)$(473)
Less: Non-cash collateral received/paid(7,408)(13,087)
Total net receivables/payables(5)
$67,986 $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)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.
(4)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.
(5)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.
In millions of dollars at December 31, 2019
Derivatives classified
in Trading account assets/liabilities
(1)(2)
Derivatives instruments designated as ASC 815 hedgesAssetsLiabilities
Over-the-counter$1,682
$143
Cleared41
111
Interest rate contracts$1,723
$254
Over-the-counter$1,304
$908
Cleared
2
Foreign exchange contracts$1,304
$910
Total derivatives instruments designated as ASC 815 hedges$3,027
$1,164
Derivatives instruments not designated as ASC 815 hedges  
Over-the-counter$189,892
$169,749
Cleared5,896
7,472
Exchange traded157
180
Interest rate contracts$195,945
$177,401
Over-the-counter$105,401
$108,807
Cleared862
1,015
Exchange traded3

Foreign exchange contracts$106,266
$109,822
Over-the-counter$21,311
$22,411
Exchange traded7,160
8,075
Equity contracts$28,471
$30,486
Over-the-counter$13,582
$16,773
Exchange traded630
542
Commodity and other contracts$14,212
$17,315
Over-the-counter$8,896
$8,975
Cleared1,513
1,763
Credit derivatives$10,409
$10,738
Total derivatives instruments not designated as ASC 815 hedges$355,303
$345,762
Total derivatives$358,330
$346,926
Cash collateral paid/received(3)
$17,926
$14,391
Less: Netting agreements(4)
(274,970)(274,970)
Less: Netting cash collateral received/paid(5)
(44,353)(38,919)
Net receivables/payables included on the Consolidated Balance Sheet(6)
$56,933
$47,428
Additional amounts subject to an enforceable master netting agreement, but not offset on the Consolidated Balance Sheet  
Less: Cash collateral received/paid$(861)$(128)
Less: Non-cash collateral received/paid(13,143)(7,308)
Total net receivables/payables(6)
$42,929
$39,992
(1)The derivatives fair values are presented in Note 24 to the Consolidated Financial Statements.
(2)Over-the-counter (OTC) derivatives are derivatives executed and settled bilaterally with counterparties without the use of an organized exchange or central clearing house. Cleared derivatives include derivatives executed bilaterally with a counterparty in the OTC market, but then novated to a central clearing house, whereby the central clearing house becomes the counterparty to both of the original counterparties. Exchange-traded derivatives include derivatives executed directly on an organized exchange that provides pre-trade price transparency.
(3)Reflects the net amount of the $56,845 million and $58,744 million of gross cash collateral paid and received, respectively. Of the gross cash collateral paid, $38,919 million was used to offset trading derivative liabilities and, of the gross cash collateral received, $44,353 million was used to offset trading derivative assets.
(4)Represents the netting of derivative receivable and payable balances with the same counterparty under enforceable netting agreements. Approximately $262 billion, $6 billion and $7 billion of the netting against trading account asset/liability balances is attributable to each of the OTC, cleared and exchange-traded derivatives, respectively.
(5)Represents the netting of cash collateral paid and received by counterparties under enforceable credit support agreements. Substantially all cash collateral received and paid is netted against OTC derivative assets and liabilities, respectively.
(6)The net receivables/payables include approximately $7 billion of derivative asset and $6 billion of derivative liability fair values not subject to enforceable master netting agreements, respectively.

In millions of dollars at December 31, 2018
Derivatives classified
in Trading account assets/liabilities
(1)(2)
Derivatives instruments designated as ASC 815 hedgesAssetsLiabilities
Over-the-counter$1,631
$172
Cleared238
53
Interest rate contracts$1,869
$225
Over-the-counter$1,402
$736
Cleared
4
Foreign exchange contracts$1,402
$740
Total derivatives instruments designated as ASC 815 hedges$3,271
$965
Derivatives instruments not designated as ASC 815 hedges  
Over-the-counter$161,183
$146,909
Cleared8,489
7,594
Exchange traded91
99
Interest rate contracts$169,763
$154,602
Over-the-counter$159,099
$156,904
Cleared1,900
1,671
Exchange traded53
40
Foreign exchange contracts$161,052
$158,615
Over-the-counter$18,253
$21,527
Cleared17
32
Exchange traded11,623
12,249
Equity contracts$29,893
$33,808
Over-the-counter$16,661
$19,894
Exchange traded894
795
Commodity and other contracts$17,555
$20,689
Over-the-counter$6,967
$6,155
Cleared3,798
4,196
Credit derivatives$10,765
$10,351
Total derivatives instruments not designated as ASC 815 hedges$389,028
$378,065
Total derivatives$392,299
$379,030
Cash collateral paid/received(3)
$11,518
$13,906
Less: Netting agreements(4)
(311,089)(311,089)
Less: Netting cash collateral received/paid(5)
(38,608)(29,911)
Net receivables/payables included on the Consolidated Balance Sheet(6)
$54,120
$51,936
Additional amounts subject to an enforceable master netting agreement, but not offset on the Consolidated Balance Sheet  
Less: Cash collateral received/paid$(767)$(164)
Less: Non-cash collateral received/paid(13,509)(13,354)
Total net receivables/payables(6)
$39,844
$38,418
251


(1)The derivatives fair values are presented in Note 24 to the Consolidated Financial Statements.
(2)Over-the-counter (OTC) derivatives include derivatives executed and settled bilaterally with counterparties without the use of an organized exchange or central clearing house. Cleared derivatives include derivatives executed bilaterally with a counterparty in the OTC market, but then novated to a central clearing house, whereby the central clearing house becomes the counterparty to both of the original counterparties. Exchange-traded derivatives include derivatives executed directly on an organized exchange that provides pre-trade price transparency.
(3)Reflects the net amount of the $41,429 million and $52,514 million of gross cash collateral paid and received, respectively. Of the gross cash collateral paid, $29,911 million was used to offset trading derivative liabilities and, of the gross cash collateral received, $38,608 million was used to offset trading derivative assets.
(4)Represents the netting of balances with the same counterparty under enforceable netting agreements. Approximately $296 billion, $4 billion and $11 billion of the netting against trading account asset/liability balances is attributable to each of the OTC, cleared and exchange-traded derivatives, respectively.
(5)Represents the netting of cash collateral paid and received by counterparties under enforceable credit support agreements. Substantially all netting of cash collateral received and paid is against OTC derivative assets and liabilities, respectively.

(6)The net receivables/payables include approximately $5 billion of derivative asset and $7 billion of derivative liability fair values not subject to enforceable master netting agreements, respectively.

For the years ended December 31, 2019, 20182021, 2020 and 2017, the2019, 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 dollars201920182017
Interest rate contracts$57
$(25)$(73)
Foreign exchange(29)(197)2,062
Total$28
$(222)$1,989

 Gains (losses) included in
Other revenue
Year ended December 31,
In millions of dollars202120202019
Interest rate contracts$(70)$63 $57 
Foreign exchange(102)(57)(29)
Total$(172)$$28 

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
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.


252


Fair Value Hedges

Hedging of Benchmark Interest Rate Risk
Citigroup’s fair value hedges are primarily hedges of fixed-rate long-term debt or assets, such as available-for-sale debt securities or loans.
For qualifying fair value hedges of interest rate risk, the changes in the fair value of the derivative and the change in the fair value of the hedged item attributable to the hedged risk are presented within Interest revenue or Interest expense based on whether the hedged item is an asset or a liability.
In the first quarter of 2019, Citigroup 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 inventory.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 reflects 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.

253


The following table summarizes the gains (losses) on the Company’s fair value hedges:
 
Gains (losses) on fair value hedges(1)

 Year Ended December 31,
 20192018
2017(2)
In millions of dollarsOther revenueNet interest revenue
Other
revenue
Net interest revenue
Other
revenue
Gain (loss) on the hedging derivatives included in assessment of the effectiveness of fair value hedges     
Interest rate hedges$
$2,273
$
$794
$(891)
Foreign exchange hedges337

(2,064)
(824)
Commodity hedges(33)
(123)
(17)
Total gain (loss) on the hedging derivatives included in assessment of the effectiveness of fair value hedges$304
$2,273
$(2,187)$794
$(1,732)
Gain (loss) on the hedged item in designated and qualifying fair value hedges     
Interest rate hedges$
$(2,085)$
$(747)$853
Foreign exchange hedges(337)
2,064

969
Commodity hedges33

124

18
Total gain (loss) on the hedged item in designated and qualifying fair value hedges$(304)$(2,085)$2,188
$(747)$1,840
Net gain (loss) on the hedging derivatives excluded from assessment of the effectiveness of fair value hedges     
Interest rate hedges$
$3
$
$(5)$(7)
Foreign exchange hedges(3)
(109)
(4)
96
Commodity hedges41

(19)
1
Total net gain (loss) on the hedging derivatives excluded from assessment of the effectiveness of fair value hedges$(68)$3
$(23)$(5)$90

(1)
Beginning January 1, 2018, gain (loss) amounts for interest rate risk hedges are included in Interest income/Interest expense, while the remaining amounts including the amounts for interest rate hedges prior to January 1, 2018 are included in Other revenue or Principal transactions on the Consolidated Statement of Income. The accrued interest income on fair value hedges both prior to and after January 1, 2018 is recorded in Net interest revenue and is excluded from this table.
(2)Hedge ineffectiveness recognized in earnings on designated and qualifying fair value hedges for the year ended December 31, 2017 was $(31) million for interest rate hedges and $49 million for foreign exchange hedges, for a total of $18 million.
(3)
Amounts relate to the premium associated with forward contracts (differential between spot and contractual forward rates) that are excluded from the assessment of hedge effectiveness and are generally reflected directly in earnings. After January 1, 2018, amounts related to cross-currency basis, which are recognized in AOCI, are not reflected in the table above. The amount of cross-currency basis that was included in AOCI was $33 million and $(74) million for the years ended December 31, 2019 and 2018,
 
Gains (losses) on fair value hedges(1)
Year ended December 31,
202120202019
In millions of dollarsOther revenueNet interest incomeOther
revenue
Net interest incomeOther
revenue
Net interest income
Gain (loss) on the hedging derivatives included in assessment of the effectiveness of fair value hedges
Interest rate hedges$ $(5,425)$— $4,189 $— $2,273 
Foreign exchange hedges(627) 1,442 — 337 — 
Commodity hedges(3,983) (164)— (33)— 
Total gain (loss) on the hedging derivatives included in assessment of the effectiveness of fair value hedges$(4,610)$(5,425)$1,278 $4,189 $304 $2,273 
Gain (loss) on the hedged item in designated and qualifying fair value hedges
Interest rate hedges$ $5,043 $— $(4,537)$— $(2,085)
Foreign exchange hedges628  (1,442)— (337)— 
Commodity hedges3,973  164 — 33 — 
Total gain (loss) on the hedged item in designated and qualifying fair value hedges$4,601 $5,043 $(1,278)$(4,537)$(304)$(2,085)
Net gain (loss) on the hedging derivatives excluded from assessment of the effectiveness of fair value hedges
Interest rate hedges$ $(9)$— $(23)$— $
Foreign exchange hedges(2)
79  (73)— (109)— 
Commodity hedges5  131 — 41 — 
Total net gain (loss) on the hedging derivatives excluded from assessment of the effectiveness of fair value hedges$84 $(9)$58 $(23)$(68)$

(1)Gain (loss) amounts for interest rate risk hedges are included in Interest revenue/Interest expense. The accrued interest income on fair value hedges is recorded in Net interest income 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 included in AOCI was $2 million and $(23) million for the years ended December 31, 2021 and 2020, respectively.



254


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. TheThis cumulative hedge basis adjustment whether from an active or de-designated hedge relationship, remains withbecomes 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, 20192021 and 2018,2020, 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 recordedCarrying amount of hedged asset/ liabilityCumulative fair value hedging adjustment increasing (decreasing) the carrying amount
ActiveDe-designated
As of December 31, 2019  
Debt securities
  AFS(1)(2)
$94,659
$(114)$743
Long-term
  debt
157,387
2,334
3,445
As of December 31, 2018  
Debt securities
  AFS(2)
$81,632
$(196)$295
Long-term
  debt
$149,054
$1,211
$869

In millions of dollars
Balance sheet line item in which hedged item is recordedCarrying amount of hedged asset/ liabilityCumulative fair value hedging adjustment increasing (decreasing) the carrying amount
ActiveDe-designated
As of December 31, 2021
Debt securities AFS(1)(3)
$62,733 $149 $212 
Long-term debt149,305 623 3,936 
As of December 31, 2020
Debt securities AFS(2)(3)
$81,082 $28 $342 
Long-term debt169,026 5,554 4,989 

(1)These amounts include a cumulative basis adjustment of $(8) million for active hedges and $157 million for de-designated hedges as of December 31, 2019 related to certain prepayable financial assets designated as the hedged item in a fair value hedge using the last-of-layer approach. The Company designated approximately $605 million as the hedged amount (from a closed portfolio of prepayable financial assets with a carrying value of $20 billion as of December 31, 2019) in a last-of-layer hedging relationship, which commenced in the first quarter of 2019.
(2)Carrying amount represents the amortized cost.
(1)    These amounts include a cumulative basis adjustment of $24 million for active hedges and $(92) million for de-designated hedges as of December 31, 2021, 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 $6 billion as the hedged amount (from a closed portfolio of prepayable financial assets with a carrying value of $25 billion as of December 31, 2021) in a last-of-layer hedging relationship.
(2)    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 $3 billion 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.
(3)    Carrying amount represents the amortized cost.


255


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 theThe 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 dollars202120202019
Amount of gain (loss) recognized in AOCI on derivatives
Interest rate contracts$(847)$2,670 $746 
Foreign exchange contracts(51)(15)(17)
Total gain (loss) recognized in AOCI
$(898)$2,655 $729 

Other revenueNet interest incomeOther
revenue
Net interest
income
Other
revenue
Net interest
income
Amount of gain (loss) reclassified from AOCI to earnings(1)
Interest rate contracts$ $1,075 $— $734 $— $(384)
Foreign exchange contracts(4) (4)— (7)— 
Total gain (loss) reclassified from AOCI into earnings
$(4)$1,075 $(4)$734 $(7)$(384)
Net pretax change in cash flow hedges included within AOCI
$(1,969)$1,925 $1,120 
In millions of dollars201920182017
Amount of gain (loss) recognized in AOCI on derivatives
   
Interest rate contracts$746 $(361)$(165)
Foreign exchange contracts(17)5 (8)
Total gain (loss) recognized in AOCI
$729 $(356)$(173)
Amount of gain (loss) reclassified from AOCI to earnings(1)
Other revenueNet Interest revenue
Other
revenue
Net interest
revenue
Other
revenue
Interest rate contracts$
$(384)$
$(301)$(126)
Foreign exchange contracts(7)
(17)
(10)
Total gain (loss) reclassified from AOCI into earnings
$(7)$(384)$(17)$(301)$(136)
Net pretax change in cash flow hedges included within AOCI
 $1,120
 $(38)$(37)

(1)
(1)All amounts reclassified into earnings for interest rate contracts are included in Interest revenue/Interest expense (Net interest income). For all other hedges, the amounts reclassified to earnings are included primarily in Other revenue and Net interest income in the Consolidated Statement of Income.

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, 20192021 is approximately $84$614 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.

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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), 0no ineffectiveness is recorded in earnings.
The pretax gain (loss) recorded in Foreign currency translation adjustment within AOCI, related to net investment hedges, is $(556)was $855 million, $1,207$(600) million and $2,528$(569) million for the years ended December 31, 2019, 20182021, 2020 and 2017,2019, 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 both December 31, 20192021 and 2018,2020, approximately 98%99% and 97%, respectively, of the gross receivables are from counterparties with which Citi maintains master netting agreements, collateral agreements.agreements or settles daily. 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 creditentity and are generally limited to the market standard of failure to pay on indebtedness and bankruptcy of the reference creditentity 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

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protection seller will be required to make a payment to the protection buyer. Under certain contracts, the seller of protection may not be required to make a payment until a specified amount of losses has occurred with respect to the portfolio and/or may only be required to pay for losses up to a specified amount.
A total return swap typically transfers the total economic performance of a reference asset, which includes all associated cash flows, as well as capital appreciation or depreciation. The protection buyer receives a floating rate of interest and any depreciation on the reference asset from the protection seller and, in return, the protection seller receives the cash flows associated with the reference asset plus any appreciation. Thus, according to the total return swap agreement, the protection seller will be obligated to make a payment any time the floating interest rate payment plus any depreciation of the reference asset exceeds the cash flows associated with the underlying asset. A total return swap may terminate upon a default of the reference asset or a credit event with respect to the reference entity, subject to the provisions of the related total return swap agreement between the protection seller and the protection buyer.
A credit option is a credit derivative that allows investors to trade or hedge changes in the credit quality of a reference entity. For example, in a credit spread option, the option writer assumes the obligation to purchase or sell credit protection on the reference entity at a specified “strike” spread level. The option purchaser buys the right to sell credit default protection on the reference entity to, or purchase it from, the option writer at the strike spread level. The payments on credit spread options depend either on a particular credit spread or the price of the underlying credit-sensitive asset or other reference entity. The options usually terminate if a credit event occurs with respect to the underlying reference entity.
A credit-linked note is a form of credit derivative structured as a debt security with an embedded credit default swap. The purchaser of the note effectively provides credit protection to the issuer by agreeing to receive a return that could be negatively affected by credit events on the underlying reference credit.entity. 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.

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The following tables summarize the key characteristics of Citi’s credit derivatives portfolio by counterparty and derivative form:

 Fair valuesNotionals
In millions of dollars at December 31, 2021
Receivable(1)
Payable(2)
Protection
purchased
Protection
sold
By industry of counterparty
Banks$2,375 $3,031 $108,415 $103,756 
Broker-dealers1,962 1,139 44,364 40,068 
Non-financial113 306 2,785 2,728 
Insurance and other financial institutions5,768 6,539 490,432 425,934 
Total by industry of counterparty$10,218 $11,015 $645,996 $572,486 
By instrument
Credit default swaps and options$9,923 $10,234 $628,136 $565,131 
Total return swaps and other295 781 17,860 7,355 
Total by instrument$10,218 $11,015 $645,996 $572,486 
By rating of reference entity
Investment grade$4,149 $4,258 $511,652 $448,944 
Non-investment grade6,069 6,757 134,344 123,542 
Total by rating of reference entity$10,218 $11,015 $645,996 $572,486 
By maturity
Within 1 year$878 $1,462 $133,866 $115,603 
From 1 to 5 years6,674 6,638 454,617 413,174 
After 5 years2,666 2,915 57,513 43,709 
Total by maturity$10,218 $11,015 $645,996 $572,486 

(1)The fair value amount receivable is composed of $3,705 million under protection purchased and $6,513 million under protection sold.
(2)The fair value amount payable is composed of $7,354 million under protection purchased and $3,661 million under protection sold.
 Fair valuesNotionals
In millions of dollars at December 31, 2020
Receivable(1)
Payable(2)
Protection
purchased
Protection
sold
By industry of counterparty
Banks$2,902 $3,187 $117,685 $120,739 
Broker-dealers1,770 1,215 46,928 44,692 
Non-financial109 90 5,740 2,217 
Insurance and other financial institutions5,008 5,637 442,417 375,959 
Total by industry of counterparty$9,789 $10,129 $612,770 $543,607 
By instrument
Credit default swaps and options$9,254 $9,254 $599,633 $538,426 
Total return swaps and other535 875 13,137 5,181 
Total by instrument$9,789 $10,129 $612,770 $543,607 
By rating of reference entity
Investment grade$4,136 $4,037 $478,643 $418,147 
Non-investment grade5,653 6,092 134,127 125,460 
Total by rating of reference entity$9,789 $10,129 $612,770 $543,607 
By maturity
Within 1 year$914 $1,355 $134,080 $125,464 
From 1 to 5 years6,022 5,991 421,682 374,376 
After 5 years2,853 2,783 57,008 43,767 
Total by maturity$9,789 $10,129 $612,770 $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.
 Fair valuesNotionals
In millions of dollars at December 31, 2019
Receivable(1)
Payable(2)
Protection
purchased
Protection
sold
By industry of counterparty    
Banks$4,017
$4,102
$172,461
$169,546
Broker-dealers1,724
1,528
54,843
53,846
Non-financial92
76
2,601
1,968
Insurance and other financial institutions4,576
5,032
474,021
378,027
Total by industry of counterparty$10,409
$10,738
$703,926
$603,387
By instrument    
Credit default swaps and options$9,759
$9,791
$685,643
$593,850
Total return swaps and other650
947
18,283
9,537
Total by instrument$10,409
$10,738
$703,926
$603,387
By rating of reference entity    
Investment grade$4,579
$4,578
$560,806
$470,778
Non-investment grade5,830
6,160
143,120
132,609
Total by rating of reference entity$10,409
$10,738
$703,926
$603,387
By maturity    
Within 1 year$1,806
$2,181
$231,135
$176,188
From 1 to 5 years7,275
7,265
414,237
379,915
After 5 years1,328
1,292
58,554
47,284
Total by maturity$10,409
$10,738
$703,926
$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.

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 Fair valuesNotionals
In millions of dollars at December 31, 2018
Receivable(1)
Payable(2)
Protection
purchased
Protection
sold
By industry of counterparty    
Banks$4,785
$4,432
$214,842
$218,273
Broker-dealers1,706
1,612
62,904
63,014
Non-financial64
87
2,687
1,192
Insurance and other financial institutions4,210
4,220
515,216
442,460
Total by industry of counterparty$10,765
$10,351
$795,649
$724,939
By instrument    
Credit default swaps and options$10,030
$9,755
$771,865
$712,623
Total return swaps and other735
596
23,784
12,316
Total by instrument$10,765
$10,351
$795,649
$724,939
By rating of reference entity    
Investment grade$4,725
$4,544
$637,790
$568,849
Non-investment grade6,040
5,807
157,859
156,090
Total by rating of reference entity$10,765
$10,351
$795,649
$724,939
By maturity    
Within 1 year$2,037
$2,063
$251,994
$225,597
From 1 to 5 years6,720
6,414
493,096
456,409
After 5 years2,008
1,874
50,559
42,933
Total by maturity$10,765
$10,351
$795,649
$724,939


(1)The fair value amount receivable is composed of $5,126 million under protection purchased and $5,639 million under protection sold.
(2)The fair value amount payable is composed of $5,882 million under protection purchased and $4,469 million under protection sold.

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 gradenon-investment-grade reference creditentity represent greater payment risk to the Company. The non-investment gradenon-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, 20192021 and 20182020 was $30$19 billion and $33$25 billion, respectively. The Company posted $28$16 billion and $33$22 billion as collateral for this exposure in the normal course of business as of December 31, 20192021 and 2018,2020, 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 3 major rating agencies as of December 31, 2019,2021, the Company could be required to post an additional $0.6$1.3 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$0.1 billion upon the single notch downgrade, resulting in aggregate cash obligations and collateral requirements of approximately $0.8$1.4 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
260


or loss on the sale of the security, because the transferred security was held at fair value in the Company’s trading portfolio. For transfers of financial assets accounted for as a sale by the Company, and for which the Company has retained substantially all of the economic exposure to the transferred asset through a total return swap executed with the same counterparty in contemplation of the initial sale (and still outstanding), both the asset amounts derecognized and the gross cash proceeds received as of the date of derecognition were $5.8$2.9 billion and $4.6$2.0 billion as of December 31, 20192021 and 2018,2020, respectively.
At December 31, 2019,2021, the fair value of these previously derecognized assets was $5.9$2.9 billion. The fair value of the total return swaps as of December 31, 20192021 was $117$13 million recorded as gross derivative assets and $43$58 million recorded as gross derivative liabilities. At December 31, 2018,2020, the fair value of these previously derecognized assets was $4.5$2.2 billion, and the fair value of the total return swaps was $55$135 million recorded as gross derivative assets and $40$7 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.

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23. CONCENTRATIONS OF CREDIT RISK

Concentrations of credit risk exist when changes in economic, industry or geographic factors similarly affect groups of counterparties whose aggregate credit exposure is material in relation to Citigroup’s total credit exposure. Although Citigroup’s portfolio of financial instruments is broadly diversified along industry, product and geographic lines, material transactions are completed with other financial institutions, particularly in the securities trading, derivatives and foreign exchange businesses.
In connection with the Company’s efforts to maintain a diversified portfolio, the Company limits its exposure to any one geographic region, country or individual creditor and monitors this exposure on a continuous basis. At December 31, 2019,2021, Citigroup’s most significant concentration of credit risk was with the U.S. government and its agencies. The Company’s exposure, which primarily results from trading assets and investments issued by the U.S. government and its agencies, amounted to $250.9$414.5 billion and $250.0$370.1 billion at December 31, 20192021 and 2018,2020, respectively. The JapaneseGerman, United Kingdom and GermanJapanese 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 JapanGermany amounted to $33.3$48.9 billion and $28.8$51.8 billion at December 31, 20192021 and 2018, respectively, and was composed of investment securities, loans and trading assets.2020, respectively. The Company’s exposure to Germanythe United Kingdom amounted to $29.8$31.1 billion and $45.6$26.0 billion at December 31, 20192021 and 2018, respectively,2020, respectively. The Company’s exposure to Japan amounted to $30.1 billion and was$35.5 billion at December 31, 2021 and 2020, respectively. The foreign government exposures are composed of investment securities, loans and trading assets.
The Company’s exposure to states and municipalities amounted to $23.8$22.0 billion and $27.9$26.1 billion at December 31, 20192021 and 2018,2020, respectively, and was composed of trading assets, investment securities, derivatives and lending activities.

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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 counterparty default of a counterparty is factored into the valuation of derivative and other positions, as well asand the impact of Citigroup’s own credit risk onis also factored into the valuation of derivatives and other liabilities that are 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 the market.
Level 3: Valuations derived from valuation techniques in which one or more significant inputs or significant value drivers are unobservable.

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 fair value hierarchy classification approach typically utilizes rules-based and data driven selection criteria to determine whether an instrument is classified as Level 1, Level 2, or Level 3:

The determination of whether an instrument is quoted in an active market and therefore considered a Level 1 instrument is based upon the frequency of observed transactions the size of the bid-ask spread and the amountquality of adjustment necessary when comparing similarindependent market data available on the measurement date.
A Level 2 classification is assigned where there is observability of prices / market inputs to models, or where any unobservable inputs are not significant to the valuation. The determination of whether an input is considered observable is based on the availability of independent market data and its corroboration, for example through observed transactions are all factors in determining the relevance of observed prices in those markets.market.
Otherwise, an instrument is classified as Level 3.

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, a non-recurring lower-of-cost-or-market (LOCOM) adjustment, or whetherbecause 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 acceptableapply practical expedients (such as matrix pricing) to calculate fair value, in which case the items aremay be classified as Level 2.
The Company may also apply a price-based methodology whichthat utilizes, where available, quoted prices or other market information obtained from recent trading activity in positions with the same or similar characteristics to the position being valued. The frequency and size of transactions are among the factors that are driven by the liquidity of markets and determine the relevance of observed prices in those markets. If relevant and observable prices are available, those valuations may be classified as Level 2. When that is not the case, andHowever, when there are one or more significant unobservable “price” inputs, then those valuations will be classified as Level 3. Furthermore, when less liquidity exists for a security or loan, a quoted price is considered stale, a significant adjustment to the price of a similar security ismay be necessary to reflect differences in the terms of the actual security or loan being valued, or alternatively, when prices from independent sources aremay be insufficient to corroborate thea 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.value. 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
263


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 reflectrepresents 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 consistsmethodologies consist 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 unsecuredterm funding risk, 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-creditown 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.exposures (e.g., the market liquidity spread used to represent the term funding premium associated with certain OTC derivatives).

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, 20192021 and 2018:2020:
 Credit and funding valuation adjustments
contra-liability (contra-asset)
In millions of dollarsDecember 31,
2021
December 31,
2020
Counterparty CVA$(705)$(800)
Asset FVA(433)(525)
Citigroup (own credit) CVA379 403 
Liability FVA110 67 
Total CVA and FVA —derivative instruments$(649)$(855)


264


 
Credit and funding valuation adjustments
contra-liability (contra-asset)
In millions of dollarsDecember 31,
2019
December 31,
2018
Counterparty CVA$(705)$(1,085)
Asset FVA(530)(544)
Citigroup (own-credit) CVA341
482
Liability FVA72
135
Total CVA—derivative instruments(1)
$(822)$(1,012)

(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:
Credit/funding/debt valuation
adjustments gain (loss)
Credit/funding/debt valuation
adjustments gain (loss)
In millions of dollars201920182017In millions of dollars202120202019
Counterparty CVA$149
$(109)$276
Counterparty CVA$79 $(101)$149 
Asset FVA13
46
90
Asset FVA96 (95)13 
Own-credit CVA(131)178
(153)
Own credit CVAOwn credit CVA(33)133 (131)
Liability FVA(63)56
(15)Liability FVA(22)(6)(63)
Total CVA—derivative instruments$(32)$171
$198
Total CVA and FVA —derivative instrumentsTotal CVA and FVA —derivative instruments$120 $(69)$(32)
DVA related to own FVO liabilities(1)
$(1,473)$1,415
$(680)
DVA related to own FVO liabilities(1)
$296 $(616)$(1,473)
Total CVA and DVA(2)
$(1,505)$1,586
$(482)
Total CVA, FVA and FVO DVATotal CVA, FVA and FVO DVA$416 $(685)$(1,505)

(1)See Notes 1, 17 and 19 to the Consolidated Financial Statements.

(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, sosince fair value is determined using a discounted cash flow technique. Cash flows are estimated based on the terms of the contract, taking into account any embedded derivative or other features. These cash flows are discounted using interest rates appropriate to the maturity of the instrument as well as the nature of the underlying collateral. Generally, when such instruments are recorded at fair value, they are classified within Level 2 of the fair value hierarchy, as the inputs used in the valuation are readily observable. However, certain long-dated positions are classified within Level 3 of the fair value hierarchy.

Trading Account Assets and Liabilities—Trading Securities and Trading Loans
When available, the Company uses quoted market prices in active markets to determine the fair value of trading securities; such items are classified as Level 1 of the fair value hierarchy. Examples include government securities and exchange-traded equity securities.
For bonds and secondary market loans traded over the counter, the Company generally determines fair value utilizing various valuation techniques, including discounted cash flows, price-based and internal models. Fair value estimates from these internal valuation techniques are verified, where possible, to prices obtained from independent sources, including third-party vendors. Vendors compile prices from various sources and may apply matrix pricing for similar bonds or loans where no price is observable. A price-based methodology utilizes, where available, quoted prices or other market information obtained from recent trading activity of assets with similar characteristics to the bond or loan being valued. The yields used in discounted cash flow models are derived from the same price information. Trading securities and loans priced using such methods are generally classified as Level 2. However, when less liquidity exists for a security or loan, a quoted price is stale, a significant adjustmentthe primary inputs 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,valuation are unobservable, or prices from independent sources are insufficient to corroborate valuation, a loan or security is generally classified as Level 3. The price input used in a price-based methodology may be zero for a security, such as a subprime CDO, that is not receiving any principal or interest and is currently written downFair value estimates from these internal valuation techniques are verified, where possible, to zero.
prices obtained from independent sources, including third-party vendors.
When the Company’s principal exit market for a portfolio of loans is thethrough securitization, market, the Company uses the securitization price to determineas a key input into the fair value of the loan portfolio. The securitization price is determined from the assumed proceeds of a hypothetical securitization inwithin the current market adjusted for transformation costs (i.e., direct costs other than transaction costs) and securitization uncertaintiesenvironment. Where such as market conditions and liquidity. As a result of the severe reduction in the level of activity in certain securitization markets since the second half of 2007,
observable securitization prices for certain directly comparable portfolios of loans have not been readily available. Therefore, such portfolios of loans are generally classified as Level 3 of the fair value hierarchy. However, for other loan securitization markets, such as commercial real estate loans, price verification of the hypothetical securitizations has beenis possible, since these markets have remained active. Accordingly, this loan portfolio isportfolios are typically classified as Level 2 ofin the fair value hierarchy.
For most of the lending and structured direct 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 data for similar assets in markets that are not active and other internal valuation techniques.proxies. The valuation of certain asset-backed security (ABS) CDO positions utilizes prices based onis 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 managementmanagement’s judgment, as no quoted prices exist and such securities are not generally thinly traded. In addition, there may be transfer restrictions on private equity securities. The Company’s process for determining the fair value of such securities utilizes commonly accepted valuation techniques, including comparables analysis.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.
265


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 beenare categorized within the fair value hierarchy and are not included in the tables below. See Note 13 to the Consolidated Financial Statements for additional information.

Short-Term Borrowings and Long-Term Debt
Where fair value accounting has been elected, the fair value of non-structured liabilities is determined by utilizing internal models using the appropriate discount rate for the applicable maturity. Such instruments are generally classified as Level 2 of the fair value hierarchy when all significant inputs are readily observable.
The Company determines the fair value of hybrid financial instruments, including structured liabilities, using the appropriate derivative valuation methodology (described above in “Trading Account Assets and Liabilities—Derivatives”) given the nature of the embedded risk profile. Such instruments are classified as Level 2 or Level 3 depending on the observability of significant inputs to the model.

266


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, 20192021 and 2018.2020. 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.2. The effects of these hedges are presented gross in the following tables:

Fair Value Levels

In millions of dollars at December 31, 2019Level 1Level 2Level 3Gross
inventory
Netting(1)
Net
balance
In millions of dollars at December 31, 2021In millions of dollars at December 31, 2021Level 1Level 2Level 3Gross
inventory
Netting(1)
Net
balance
Assets     Assets    
Securities borrowed and purchased under agreements to resell$
$254,253
$303
$254,556
$(101,363)$153,193
Securities borrowed and purchased under agreements to resell$ $342,030 $231 $342,261 $(125,795)$216,466 
Trading non-derivative assets     Trading non-derivative assets
Trading mortgage-backed securities     Trading mortgage-backed securities
U.S. government-sponsored agency guaranteed
27,661
10
27,671

27,671
U.S. government-sponsored agency guaranteed 34,534 496 35,030  35,030 
Residential
573
123
696

696
Residential1 643 104 748  748 
Commercial
1,632
61
1,693

1,693
Commercial 778 81 859  859 
Total trading mortgage-backed securities$
$29,866
$194
$30,060
$
$30,060
Total trading mortgage-backed securities$1 $35,955 $681 $36,637 $ $36,637 
U.S. Treasury and federal agency securities$26,159
$3,736
$
$29,895
$
$29,895
U.S. Treasury and federal agency securities$44,900 $3,230 $4 $48,134 $ $48,134 
State and municipal
2,573
64
2,637

2,637
State and municipal 1,995 37 2,032  2,032 
Foreign government50,948
20,326
52
71,326

71,326
Foreign government39,176 31,485 23 70,684  70,684 
Corporate1,332
17,246
313
18,891

18,891
Corporate1,544 16,156 412 18,112  18,112 
Equity securities41,663
9,878
100
51,641

51,641
Equity securities53,833 10,047 174 64,054  64,054 
Asset-backed securities
1,539
1,177
2,716

2,716
Asset-backed securities 981 613 1,594  1,594 
Other trading assets(2)
74
11,412
555
12,041

12,041
Other trading assets(2)
 20,346 576 20,922  20,922 
Total trading non-derivative assets$120,176
$96,576
$2,455
$219,207
$
$219,207
Total trading non-derivative assets$139,454 $120,195 $2,520 $262,169 $ $262,169 
Trading derivatives


  Trading derivatives
Interest rate contracts$7
$196,493
$1,168
$197,668
  Interest rate contracts$90 $161,500 $3,898 $165,488 
Foreign exchange contracts1
107,022
547
107,570
  Foreign exchange contracts 134,912 637 135,549 
Equity contracts83
28,148
240
28,471
  Equity contracts41 43,904 1,307 45,252 
Commodity contracts
13,498
714
14,212
  Commodity contracts 28,547 1,797 30,344 
Credit derivatives
9,960
449
10,409
  Credit derivatives 9,299 919 10,218 
Total trading derivatives$91
$355,121
$3,118
$358,330
  
Cash collateral paid(3)
  $17,926
  
Total trading derivatives—before netting and collateralTotal trading derivatives—before netting and collateral$131 $378,162 $8,558 $386,851 
Netting agreements   $(274,970) Netting agreements$(292,628)
Netting of cash collateral received   (44,353) 
Total trading derivatives$91
$355,121
$3,118
$376,256
$(319,323)$56,933
Netting of cash collateral received (3)
Netting of cash collateral received (3)
(24,447)
Total trading derivatives—after netting and collateralTotal trading derivatives—after netting and collateral$131 $378,162 $8,558 $386,851 $(317,075)$69,776 
Investments     Investments
Mortgage-backed securities     Mortgage-backed securities
U.S. government-sponsored agency guaranteed$
$35,198
$32
$35,230
$
$35,230
U.S. government-sponsored agency guaranteed$ $33,165 $51 $33,216 $ $33,216 
Residential
793

793

793
Residential 286 94 380  380 
Commercial
74

74

74
Commercial 25  25  25 
Total investment mortgage-backed securities$
$36,065
$32
$36,097
$
$36,097
Total investment mortgage-backed securities$ $33,476 $145 $33,621 $ $33,621 
U.S. Treasury and federal agency securities$106,103
$5,315
$
$111,418
$
$111,418
U.S. Treasury and federal agency securities$122,271 $168 $1 $122,440 $ $122,440 
State and municipal
4,355
623
4,978

4,978
State and municipal 1,849 772 2,621  2,621 
Foreign government69,957
41,196
96
111,249

111,249
Foreign government56,842 61,112 786 118,740  118,740 
Corporate5,150
6,076
45
11,271

11,271
Corporate2,861 2,871 188 5,920  5,920 
Marketable equity securities87
371

458

458
Marketable equity securities350 177 16 543  543 
Asset-backed securities
500
22
522

522
Asset-backed securities 300 3 303  303 
Other debt securities
4,730

4,730

4,730
Other debt securities 4,877  4,877  4,877 
Non-marketable equity securities(4)

93
441
534

534
Non-marketable equity securities(4)
 28 316 344  344 
Total investments$181,297
$98,701
$1,259
$281,257
$
$281,257
Total investments$182,324 $104,858 $2,227 $289,409 $ $289,409 

Table continues on the next page.

267


In millions of dollars at December 31, 2021Level 1Level 2Level 3Gross
inventory
Netting(1)
Net
balance
Loans$ $5,371 $711 $6,082 $ $6,082 
Mortgage servicing rights  404 404  404 
Non-trading derivatives and other financial assets measured on a recurring basis$4,075 $8,194 $73 $12,342 $ $12,342 
Total assets$325,984 $958,810 $14,724 $1,299,518 $(442,870)$856,648 
Total as a percentage of gross assets(5)
25.1 %73.8 %1.1 %
Liabilities
Interest-bearing deposits$ $1,483 $183 $1,666 $ $1,666 
Securities loaned and sold under agreements to repurchase 174,318 643 174,961 (118,267)56,694 
Trading account liabilities
Securities sold, not yet purchased82,675 23,268 65 106,008  106,008 
Other trading liabilities 5  5  5 
Total trading liabilities$82,675 $23,273 $65 $106,013 $ $106,013 
Trading derivatives
Interest rate contracts$56 $147,846 $2,172 $150,074 
Foreign exchange contracts 134,572 726 135,298 
Equity contracts60 46,177 3,447 49,684 
Commodity contracts 30,004 1,375 31,379 
Credit derivatives 10,065 950 11,015 
Total trading derivatives—before netting and collateral$116 $368,664 $8,670 $377,450 
Netting agreements$(292,628)
Netting of cash collateral paid (3)
(29,306)
Total trading derivatives—after netting and collateral$116 $368,664 $8,670 $377,450 $(321,934)$55,516 
Short-term borrowings$ $7,253 $105 $7,358 $ $7,358 
Long-term debt 57,100 25,509 82,609  82,609 
Total non-trading derivatives and other financial liabilities measured on a recurring basis$3,574 $ $1 $3,575 $ $3,575 
Total liabilities$86,365 $632,091 $35,176 $753,632 $(440,201)$313,431 
Total as a percentage of gross liabilities(5)
11.5 %83.9 %4.7 %

(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 repurchase and (ii) derivative exposures covered by a qualifying master netting agreement and cash collateral offsetting.
(2)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)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.
(4)Amounts exclude $0.1 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.

268

In millions of dollars at December 31, 2019Level 1Level 2Level 3Gross
inventory
Netting(1)
Net
balance
Loans$
$3,683
$402
$4,085
$
$4,085
Mortgage servicing rights

495
495

495
Non-trading derivatives and other financial assets measured on a recurring basis$5,628
$7,201
$1
$12,830
$
$12,830
Total assets$307,192
$815,535
$8,033
$1,148,686
$(420,686)$728,000
Total as a percentage of gross assets(5)
27.2%72.1%0.7%





Liabilities      
Interest-bearing deposits$
$2,104
$215
$2,319
$
$2,319
Securities loaned and sold under agreements to repurchase
111,567
757
112,324
(71,673)40,651
Trading account liabilities      
Securities sold, not yet purchased60,429
11,965
48
72,442

72,442
Other trading liabilities
24

24

24
Total trading liabilities$60,429
$11,989
$48
$72,466
$
$72,466
Trading derivatives      
Interest rate contracts$8
$176,480
$1,167
$177,655
  
Foreign exchange contracts
110,180
552
110,732
  
Equity contracts144
28,506
1,836
30,486
  
Commodity contracts
16,542
773
17,315
  
Credit derivatives
10,233
505
10,738
  
Total trading derivatives$152
$341,941
$4,833
$346,926
  
Cash collateral received(6)
   $14,391
  
Netting agreements    $(274,970) 
Netting of cash collateral paid    (38,919) 
Total trading derivatives$152
$341,941
$4,833
$361,317
$(313,889)$47,428
Short-term borrowings$
$4,933
$13
$4,946
$
$4,946
Long-term debt
38,614
17,169
55,783

55,783
Total non-trading derivatives and other financial liabilities measured on a recurring basis$6,280
$63
$
$6,343
$
$6,343
Total liabilities$66,861
$511,211
$23,035
$615,498
$(385,562)$229,936
Total as a percentage of gross liabilities(5)
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 repurchase and (ii) derivative exposures covered by a qualifying master netting agreement and cash collateral offsetting.
(2)Includes positions related to investments in unallocated precious metals, as discussed in Note 25 to the Consolidated Financial Statements. Also includes physical commodities accounted for at the lower of cost or fair value and unfunded credit products.
(3)Reflects the net amount of $56,845 million of gross cash collateral paid, of which $38,919 million was used to offset trading derivative liabilities.
(4)
Amounts exclude $0.2 billion of investments measured at net asset value (NAV) in accordance with ASU No. 2015-07, Fair Value Measurement (Topic 820): Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent).
(5)Because the amount of the cash collateral paid/received has not been allocated to the Level 1, 2 and 3 subtotals, these percentages are calculated based on total assets and liabilities measured at fair value on a recurring basis, excluding the cash collateral paid/received on derivatives.
(6)Reflects the net amount of $58,744 million of gross cash collateral received, of which $44,353 million was used to offset trading derivative assets.

Fair Value Levels
In millions of dollars at December 31, 2020Level 1Level 2Level 3Gross
inventory
Netting(1)
Net
balance
Assets      
Securities borrowed and purchased under agreements to resell$— $335,073 $320 $335,393 $(150,189)$185,204 
Trading non-derivative assets
Trading mortgage-backed securities
U.S. government-sponsored agency guaranteed— 42,903 27 42,930 — 42,930 
Residential— 391 340 731 — 731 
Commercial— 893 136 1,029 — 1,029 
Total trading mortgage-backed securities$— $44,187 $503 $44,690 $— $44,690 
U.S. Treasury and federal agency securities$64,529 $2,269 $— $66,798 $— $66,798 
State and municipal— 1,224 94 1,318 — 1,318 
Foreign government68,195 15,143 51 83,389 — 83,389 
Corporate1,607 18,840 375 20,822 — 20,822 
Equity securities54,117 12,289 73 66,479 — 66,479 
Asset-backed securities— 776 1,606 2,382 — 2,382 
Other trading assets(2)
— 11,295 945 12,240 — 12,240 
Total trading non-derivative assets$188,448 $106,023 $3,647 $298,118 $— $298,118 
Trading derivatives
Interest rate contracts$42 $238,026 $3,393 $241,461 
Foreign exchange contracts155,994 674 156,670 
Equity contracts66 48,362 2,091 50,519 
Commodity contracts— 13,546 992 14,538 
Credit derivatives— 8,634 1,155 9,789 
Total trading derivatives—before netting and collateral$110 $464,562 $8,305 $472,977 
Netting agreements$(364,879)
Netting of cash collateral received(3)
(31,137)
Total trading derivatives—after netting and collateral$110 $464,562 $8,305 $472,977 $(396,016)$76,961 
Investments
Mortgage-backed securities
U.S. government-sponsored agency guaranteed$— $43,888 $30 $43,918 $— $43,918 
Residential— 571 — 571 — 571 
Commercial— 50 — 50 — 50 
Total investment mortgage-backed securities$— $44,509 $30 $44,539 $— $44,539 
U.S. Treasury and federal agency securities$146,032 $172 $— $146,204 $— $146,204 
State and municipal— 2,885 834 3,719 — 3,719 
Foreign government77,056 47,644 268 124,968 — 124,968 
Corporate6,326 4,114 60 10,500 — 10,500 
Marketable equity securities287 228 — 515 — 515 
Asset-backed securities— 277 278 — 278 
Other debt securities— 4,876 — 4,876 — 4,876 
Non-marketable equity securities(4)
— 50 349 399 — 399 
Total investments$229,701 $104,755 $1,542 $335,998 $— $335,998 
In millions of dollars at December 31, 2018Level 1Level 2Level 3Gross
inventory
Netting(1)
Net
balance
Assets      
Securities borrowed and purchased under agreements to resell$
$214,570
$115
$214,685
$(66,984)$147,701
Trading non-derivative assets      
Trading mortgage-backed securities      
U.S. government-sponsored agency guaranteed
24,090
156
24,246

24,246
Residential
709
268
977

977
Commercial
1,323
77
1,400

1,400
Total trading mortgage-backed securities$
$26,122
$501
$26,623
$
$26,623
U.S. Treasury and federal agency securities$26,439
$4,802
$1
$31,242
$
$31,242
State and municipal
3,782
200
3,982

3,982
Foreign government43,309
21,179
31
64,519

64,519
Corporate1,026
14,510
360
15,896

15,896
Equity securities36,342
7,308
153
43,803

43,803
Asset-backed securities
1,429
1,484
2,913

2,913
Other trading assets(2)
3
12,198
818
13,019

13,019
Total trading non-derivative assets$107,119
$91,330
$3,548
$201,997
$
$201,997
Trading derivatives      
Interest rate contracts$101
$169,860
$1,671
$171,632
  
Foreign exchange contracts
162,108
346
162,454
  
Equity contracts647
28,903
343
29,893
  
Commodity contracts
16,788
767
17,555
  
Credit derivatives
9,839
926
10,765
  
Total trading derivatives$748
$387,498
$4,053
$392,299
  
Cash collateral paid(3)
   $11,518
  
Netting agreements    $(311,089) 
Netting of cash collateral received    (38,608) 
Total trading derivatives$748
$387,498
$4,053
$403,817
$(349,697)$54,120
Investments      
Mortgage-backed securities      
U.S. government-sponsored agency guaranteed$
$42,988
$32
$43,020
$
$43,020
Residential
1,313

1,313

1,313
Commercial
172

172

172
Total investment mortgage-backed securities$
$44,473
$32
$44,505
$
$44,505
U.S. Treasury and federal agency securities$107,577
$9,645
$
$117,222
$
$117,222
State and municipal
8,498
708
9,206

9,206
Foreign government58,252
42,371
68
100,691

100,691
Corporate4,410
7,033
156
11,599

11,599
Marketable equity securities206
14

220

220
Asset-backed securities
656
187
843

843
Other debt securities
3,972

3,972

3,972
Non-marketable equity securities(4)

96
586
682

682
Total investments$170,445
$116,758
$1,737
$288,940
$
$288,940

Table continues on the next page.

269


In millions of dollars at December 31, 2020Level 1Level 2Level 3Gross
inventory
Netting(1)
Net
balance
Loans$— $4,869 $1,985$6,854 $— $6,854 
Mortgage servicing rights— — 336 336 — 336 
Non-trading derivatives and other financial assets measured on a recurring basis$6,230 $8,383 $— $14,613 $— $14,613 
Total assets$424,489 $1,023,665 $16,135 $1,464,289 $(546,205)$918,084 
Total as a percentage of gross assets(5)
29.0 %69.9 %1.1 %
Liabilities
Interest-bearing deposits$— $1,752 $206 $1,958 $— $1,958 
Securities loaned and sold under agreements to repurchase— 156,644 631 157,275 (97,069)60,206 
Trading account liabilities
Securities sold, not yet purchased85,353 14,477 214 100,044 — 100,044 
Other trading liabilities— — 26 26 — 26 
Total trading account liabilities$85,353 $14,477 $240 $100,070 $— $100,070 
Trading derivatives
Interest rate contracts$25 $220,607 $1,779 $222,411 
Foreign exchange contracts155,441 622 156,066 
Equity contracts53 58,212 5,304 63,569 
Commodity contracts— 17,393 700 18,093 
Credit derivatives— 9,022 1,107 10,129 
Total trading derivatives—before netting and collateral$81 $460,675 $9,512 $470,268 
Netting agreements$(364,879)
Netting of cash collateral paid (3)
(37,432)
Total trading derivatives—after netting and collateral$81 $460,675 $9,512 $470,268 $(402,311)$67,957 
Short-term borrowings$— $4,464 $219 $4,683 $— $4,683 
Long-term debt— 41,853 25,210 67,063 — 67,063 
Non-trading derivatives and other financial liabilities measured on a recurring basis$6,762 $72 $$6,835 $— $6,835 
Total liabilities$92,196 $679,937 $36,019 $808,152 $(499,380)$308,772 
Total as a percentage of gross liabilities(5)
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 repurchase and (ii) derivative exposures covered by a qualifying master netting agreement and cash collateral offsetting.
(2)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)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.
(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.





















270
In millions of dollars at December 31, 2018Level 1Level 2Level 3Gross
inventory
Netting(1)
Net
balance
Loans$
$2,946
$277
$3,223
$
$3,223
Mortgage servicing rights

584
584

584
Non-trading derivatives and other financial assets measured on a recurring basis$15,839
$4,949
$
$20,788
$
$20,788
Total assets$294,151
$818,051
$10,314
$1,134,034
$(416,681)$717,353
Total as a percentage of gross assets(5)
26.2%72.9%0.9%   
Liabilities      
Interest-bearing deposits$
$980
$495
$1,475
$
$1,475
Securities loaned and sold under agreements to repurchase
110,511
983
111,494
(66,984)44,510
Trading account liabilities      
Securities sold, not yet purchased78,872
11,364
586
90,822

90,822
Other trading liabilities
1,547

1,547

1,547
Total trading liabilities$78,872
$12,911
$586
$92,369
$
$92,369
Trading account derivatives      
Interest rate contracts$71
$152,931
$1,825
$154,827
  
Foreign exchange contracts
159,003
352
159,355
  
Equity contracts351
32,330
1,127
33,808
  
Commodity contracts
19,904
785
20,689
  
Credit derivatives
9,486
865
10,351
  
Total trading derivatives$422
$373,654
$4,954
$379,030
  
Cash collateral received(6)
   $13,906
  
Netting agreements    $(311,089) 
Netting of cash collateral paid    (29,911) 
Total trading derivatives$422
$373,654
$4,954
$392,936
$(341,000)$51,936
Short-term borrowings$
$4,446
$37
$4,483
$
$4,483
Long-term debt
25,659
12,570
38,229

38,229
Non-trading derivatives and other financial liabilities measured on a recurring basis$15,839
$67
$
$15,906
$
$15,906
Total liabilities$95,133
$528,228
$19,625
$656,892
$(407,984)$248,908
Total as a percentage of gross liabilities(5)
14.8%82.1%3.1%   


(1)Represents netting of (i) the amounts due under securities purchased under agreements to resell and the amounts owed under securities sold under agreements to repurchase and (ii) derivative exposures covered by a qualifying master netting agreement and cash collateral offsetting.
(2)Includes positions related to investments in unallocated precious metals, as discussed in Note 25 to the Consolidated Financial Statements. Also includes physical commodities accounted for at the lower of cost or fair value and unfunded credit products.
(3)Reflects the net amount of $41,429 million of gross cash collateral paid, of which $29,911 million was used to offset trading derivative liabilities.
(4)
Amounts exclude $0.2 billion of investments measured at net asset value (NAV) in accordance with ASU 2015-07, Fair Value Measurement (Topic 820): Disclosures for Investments in Certain Entities That Calculate Net Asset Value per Share (or Its Equivalent).
(5)Because the amount of the cash collateral paid/received has not been allocated to the Level 1, 2 and 3 subtotals, these percentages are calculated based on total assets and liabilities measured at fair value on a recurring basis, excluding the cash collateral paid/received on derivatives.
(6)Reflects the net amount of $52,514 million of gross cash collateral received, of which $38,608 million was used to offset trading derivative assets.

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, 20192021 and 2018.2020. 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

 Net realized/unrealized
gains/losses included in
Transfers 
Unrealized
gains/
losses
still held
(3)
 
Net realized/unrealized
gains (losses) included in(1)
Transfers 
Unrealized
gains (losses)
still held
(3)
In millions of dollarsDec. 31, 2018Principal
transactions
Other(1)(2)
into
Level 3
out of
Level 3
PurchasesIssuancesSalesSettlementsDec. 31, 2019In millions of dollarsDec. 31, 2020Principal
transactions
Other(1)(2)
into
Level 3
out of
Level 3
PurchasesIssuancesSalesSettlementsDec. 31, 2021
Assets   Assets
Securities borrowed and purchased under agreements to resell$115
$(5)$
$191
$(4)$195
$
$
$(189)$303
$3
Securities borrowed and purchased under agreements to resell$320 $(36)$ $45 $(49)$362 $ $ $(411)$231 $ 
Trading non-derivative assets   Trading non-derivative assets
Trading mortgage-backed securities   Trading mortgage-backed securities
U.S. government-sponsored agency guaranteed156


54
(72)160
(1)(287)
10
1
U.S. government-sponsored agency guaranteed27 8  355 (131)447  (210) 496 11 
Residential268
15

86
(80)227

(393)
123
10
Residential340 25  89 (96)282  (536) 104 13 
Commercial77
14

150
(105)136

(211)
61
(4)Commercial136 23  96 (58)62  (178) 81  
Total trading mortgage-backed securities$501
$29
$
$290
$(257)$523
$(1)$(891)$
$194
$7
Total trading mortgage-backed securities$503 $56 $ $540 $(285)$791 $ $(924)$ $681 $24 
U.S. Treasury and federal agency securities$1
$(9)$
$
$
$20
$
$(11)$(1)$
$
U.S. Treasury and federal agency securities$— $ $ $4 $ $ $ $ $ $4 $ 
State and municipal200
(2)
1
(19)2

(118)
64
(2)State and municipal94 (4) 20 (29)17  (61) 37 (6)
Foreign government31
28

12
(7)88

(100)
52
1
Foreign government51 29  143 (129)83  (154) 23 (2)
Corporate360
284

213
(86)323
(29)(742)(10)313
(11)Corporate375 74  461 (384)867  (981) 412 (38)
Marketable equity securities153
(21)
13
(19)117

(143)
100
(51)
Equity securitiesEquity securities73 67  156 (52)118  (188) 174 23 
Asset-backed securities1,484
(65)
51
(127)738

(904)
1,177
29
Asset-backed securities1,606 371  173 (297)1,313  (2,553) 613 (43)
Other trading assets818
(52)
97
(283)598
36
(630)(29)555
(257)Other trading assets945 97  158 (457)980 4 (1,147)(4)576 (37)
Total trading non-derivative assets$3,548
$192
$
$677
$(798)$2,409
$6
$(3,539)$(40)$2,455
$(284)Total trading non-derivative assets$3,647 $690 $ $1,655 $(1,633)$4,169 $4 $(6,008)$(4)$2,520 $(79)
Trading derivatives, net(4)
   
Trading derivatives, net(4)
Interest rate contracts$(154)$116
$
$(129)$172
$154
$45
$(1)$(202)$1
$2,194
Interest rate contracts$1,614 $(376)$ $102 $562 $27 $(84)$ $(119)$1,726 $4 
Foreign exchange contracts(6)(73)
152
(97)113

(114)20
(5)(134)Foreign exchange contracts52 (8) (57)104 220  (326)(74)(89)7 
Equity contracts(784)(425)
(213)274
(111)(147)(8)(182)(1,596)(422)Equity contracts(3,213)964  (1,101)1,923 364  (364)(713)(2,140)(729)
Commodity contracts(18)(121)
(15)(15)252

(133)(9)(59)(33)Commodity contracts292 474  174 (454)162  (238)12 422 261 
Credit derivatives61
(412)
(114)204


14
191
(56)(289)Credit derivatives48 (136) (96)40    113 (31)(130)
Total trading derivatives, net(4)
$(901)$(915)$
$(319)$538
$408
$(102)$(242)$(182)$(1,715)$1,316
Total trading derivatives, net(4)
$(1,207)$918 $ $(978)$2,175 $773 $(84)$(928)$(781)$(112)$(587)

Table continues on the next page.

271


  
Net realized/unrealized
gains (losses) included in(1)
Transfers     
Unrealized
gains (losses)
still held
(3)
In millions of dollarsDec. 31, 2020Principal
transactions
Other(1)(2)
into
Level 3
out of
Level 3
PurchasesIssuancesSalesSettlementsDec. 31, 2021
Investments
Mortgage-backed securities
U.S. government-sponsored agency guaranteed$30 $ $2 $42 $(10)$3 $ $(16)$ $51 $2 
Residential—   54 (12)52    94 (1)
Commercial—           
Total investment mortgage-backed securities$30 $ $2 $96 $(22)$55 $ $(16)$ $145 $1 
U.S. Treasury and federal agency securities$— $ $ $1 $ $ $ $ $ $1 $ 
State and municipal834  (21)58 (108)49  (40) 772 (12)
Foreign government268  (49)512 (565)871  (251) 786 (2)
Corporate60  (14)183 (44)37  (34) 188 2 
Marketable equity securities—   16      16  
Asset-backed securities (21)36    (13) 3 (2)
Other debt securities—           
Non-marketable equity securities349  (27)2    (8) 316 (6)
Total investments$1,542 $ $(130)$904 $(739)$1,012 $ $(362)$ $2,227 $(19)
Loans$1,985 $ $90 $311 $(2,071)$ $529 $ $(133)$711 $(77)
Mortgage servicing rights336  43    92  (67)404 52 
Other financial assets measured on a recurring basis—  6 65 (27)58  (26)(3)73  
Liabilities
Interest-bearing deposits$206 $ $(18)$ $(44)$ $38 $ $(35)$183 $(19)
Securities loaned and sold under agreements to repurchase631 (9) 183 (483)488   (185)643 32 
Trading account liabilities
Securities sold, not yet purchased214 48  87 (34)59   (213)65 (4)
Other trading liabilities26 26          
Short-term borrowings219 43  137 (57) 49  (200)105 (2)
Long-term debt25,210 2,774  8,611 (9,771) 10,262  (6,029)25,509 1,756 
Other financial liabilities measured on a recurring basis (3) (4) 14  (13)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, 2021.
(4)Total Level 3 trading derivative assets and liabilities have been netted in these tables for presentation purposes only.



272


  Net realized/unrealized
gains/losses included in
Transfers     
Unrealized
gains/
losses
still held
(3)
In millions of dollarsDec. 31, 2018Principal
transactions
Other(1)(2)
into
Level 3
out of
Level 3
PurchasesIssuancesSalesSettlementsDec. 31, 2019
Investments           
Mortgage-backed securities           
U.S. government-sponsored agency guaranteed$32
$
$
$
$
$
$
$
$
$32
$(1)
Residential










Commercial










Total investment mortgage-backed securities$32
$
$
$
$
$
$
$
$
$32
$(1)
U.S. Treasury and federal agency securities$
$
$
$
$
$
$
$
$
$
$
State and municipal708

86
14
(318)430

(297)
623
82
Foreign government68

2


145

(119)
96
2
Corporate156

(14)3
(94)

(6)
45

Marketable equity securities










Asset-backed securities187

(11)122
(612)550

(214)
22
13
Other debt securities










Non-marketable equity securities586

(11)39
(1)11

(151)(32)441
16
Total investments$1,737
$
$52
$178
$(1,025)$1,136
$
$(787)$(32)$1,259
$112
Loans$277
$
$192
$148
$(189)$16
$
$(40)$(2)$402
$186
Mortgage servicing rights584

(84)


70

(75)495
(68)
Other financial assets measured on a recurring basis

96
6
(2)2
32
(21)(112)1
18
Liabilities           
Interest-bearing deposits$495
$
$(16)$10
$(783)$
$843
$
$(366)$215
$(25)
Securities loaned and sold under agreements to repurchase983
121

1
4


(168)58
757
(26)
Trading account liabilities           
Securities sold, not yet purchased586
122

68
(443)19

(12)(48)48
3
Other trading liabilities










Short-term borrowings37
32

13
(42)
168

(131)13
(1)
Long-term debt12,570
(2,140)
3,892
(5,188)23
8,262
(5)(4,525)17,169
(3,300)
Other financial liabilities measured on a recurring basis

4
5


4

(5)

(1)
Changes in fair value of available-for-sale investments are recorded in AOCI, unless related to other-than-temporary impairment, while gains and losses from sales are recorded in Realized gains (losses) from sales of investments in the Consolidated Statement of Income.
(2)
Unrealized gains (losses) on MSRs are recorded in Other revenue in the Consolidated Statement of Income.
(3)
Represents the amount of total gains or losses for the period, included in earnings (and AOCI for changes in fair value of available-for-sale investments), attributable to the change in fair value relating to assets and liabilities classified as Level 3 that are still held at December 31, 2019.
(4)Total Level 3 trading derivative assets and liabilities have been netted in these tables for presentation purposes only.

  
Net realized/unrealized
gains (losses) included in(1)
Transfers     
Unrealized
gains
(losses)
still held
(3)
In millions of dollarsDec. 31, 2019Principal
transactions
Other(1)(2)
into
Level 3
out of
Level 3
PurchasesIssuancesSalesSettlementsDec. 31, 2020
Assets           
Securities borrowed and purchased under agreements to resell$303 $23 $— $— $— $194 $— $— $(200)$320 $43 
Trading non-derivative assets           
Trading mortgage-backed securities           
U.S. government-sponsored agency guaranteed10 (79)— 21 (11)392 — (306)— 27 (1)
Residential123 79 — 234 (68)486 — (514)— 340 (20)
Commercial61 — — 162 (35)174 — (226)— 136 (14)
Total trading mortgage-backed securities$194 $— $— $417 $(114)$1,052 $— $(1,046)$— $503 $(35)
U.S. Treasury and federal agency securities$— $— $— $— $— $— $— $— $— $— $— 
State and municipal64 — 33 (3)62 — (64)— 94 
Foreign government52 (35)— (1)169 — (143)— 51 (7)
Corporate313 246 — 211 (136)770 — (1,023)(6)375 (37)
Marketable equity securities100 (16)— 43 (2)240 — (292)— 73 (11)
Asset-backed securities1,177 (105)— 677 (131)1,406 — (1,418)— 1,606 (248)
Other trading assets555 315 — 471 (343)387 19 (440)(19)945 (56)
Total trading non-derivative assets$2,455 $407 $— $1,861 $(730)$4,086 $19 $(4,426)$(25)$3,647 $(390)
Trading derivatives, net(4)
Interest rate contracts$$429 $— $1,644 $16 $41 $134 $(34)$(617)$1,614 $161 
Foreign exchange contracts(5)105 — (61)48 74 — (55)(54)52 130 
Equity contracts(1,596)(536)— (519)378 35 — (886)(89)(3,213)(3,868)
Commodity contracts(59)(1)— 99 (108)101 — (61)321 292 407 
Credit derivatives(56)123 — 173 (334)— — — 142 48 (136)
Total trading derivatives, net(4)
$(1,715)$120 $— $1,336 $— $251 $134 $(1,036)$(297)$(1,207)$(3,306)
Investments
Mortgage-backed securities
U.S. government-sponsored agency guaranteed$32 $— $(5)$$— $$— $— $— $30 $(104)
Residential— — 76 — — — — (76)— — 
Commercial— — — — — — — — — — — 
Total investment mortgage-backed securities$32 $— $71 $$— $$— $(76)$— $30 $(99)
U.S. Treasury and federal agency securities$— $— $— $— $— $— $— $— $— $— $— 
State and municipal623 — (3)322 (131)121 — (98)— 834 (20)
Foreign government96 — 11 27 (64)381 — (183)— 268 (4)
Corporate45 — 49 (152)162 — (50)— 60 — 
Marketable equity securities— — (1)— — — — — — — 
Asset-backed securities22 — (1)— — — — (20)— (4)
Other debt securities— — — — — — — — — — — 
Non-marketable equity securities441 — (35)— (2)(3)(57)349 10 
Total investments$1,259 $— $48 $401 $(349)$667 $$(430)$(57)$1,542 $(117)



  Net realized/unrealized
gains (losses) included in
Transfers     
Unrealized
gains
(losses)
still held
(3)
In millions of dollarsDec. 31, 2017Principal
transactions
Other(1)(2)
into
Level 3
out of
Level 3
PurchasesIssuancesSalesSettlementsDec. 31, 2018
Assets           
Securities borrowed and purchased under agreements to resell$16
$17
$
$50
$
$95
$
$16
$(79)$115
$9
Trading non-derivative assets           
Trading mortgage-backed securities           
U.S. government-sponsored agency guaranteed163
5

92
(107)281

(278)
156
186
Residential164
112

124
(133)154

(153)
268
4
Commercial57
(7)
24
(49)110

(58)
77

Total trading mortgage-backed securities$384
$110
$
$240
$(289)$545
$
$(489)$
$501
$190
U.S. Treasury and federal agency securities$
$
$
$6
$(4)$1
$
$
$(2)$1
$
State and municipal274
22


(96)45

(45)
200
9
Foreign government16
(2)
5
(13)75

(50)
31
(28)
Corporate275
(72)
138
(122)596
(40)(415)
360
(32)
Marketable equity securities120
2

25
(62)290

(222)
153
(56)
Asset-backed securities1,590
28

77
(90)1,238

(1,359)
1,484
(21)
Other trading assets615
276

197
(82)598
8
(777)(17)818
91
Total trading non-derivative assets$3,274
$364
$
$688
$(758)$3,388
$(32)$(3,357)$(19)$3,548
$153
Trading derivatives, net(4)
           
Interest rate contracts$(422)$414
$
$(6)$(193)$8
$17
$(32)$60
$(154)$336
Foreign exchange contracts130
(99)
(29)77
11

(89)(7)(6)(72)
Equity contracts(2,027)479

(131)1,114
25
(44)(17)(183)(784)52
Commodity contracts(1,861)(505)
(32)2,180
62

(19)157
(18)(171)
Credit derivatives(799)261

(7)391
2

1
212
61
87
Total trading derivatives, net(4)
$(4,979)$550
$
$(205)$3,569
$108
$(27)$(156)$239
$(901)$232
Investments           
Mortgage-backed securities           
U.S. government-sponsored agency guaranteed$24
$
$10
$
$
$
$
$(2)$
$32
$14
Residential










Commercial3

2
1
(1)

(5)


Total investment mortgage-backed securities$27
$
$12
$1
$(1)$
$
$(7)$
$32
$14
U.S. Treasury and federal agency securities$
$
$
$
$
$
$
$
$
$
$
State and municipal737

(20)
(18)211

(202)
708
(29)
Foreign government92

(3)3
(4)141

(161)
68
4
Corporate71

(1)61
(66)101

(10)
156

Marketable equity securities2

1




(2)(1)

Asset-backed securities827

(21)10
(524)63

(168)
187

Other debt securities










Non-marketable equity securities681

(95)193

91

(234)(50)586
55
Total investments$2,437
$
$(127)$268
$(613)$607
$
$(784)$(51)$1,737
$44
Table continues on the next page.

273


 Net realized/unrealized
gains (losses) included in
Transfers 
Unrealized
gains
(losses)
still held
(3)
 
Net realized/unrealized
gains (losses) included in(1)
Transfers 
Unrealized
gains
(losses)
still held
(3)
In millions of dollarsDec. 31, 2017Principal
transactions
Other(1)(2)
into
Level 3
out of
Level 3
PurchasesIssuancesSalesSettlementsDec. 31, 2018In millions of dollarsDec. 31, 2019Principal
transactions
Other(1)(2)
into
Level 3
out of
Level 3
PurchasesIssuancesSalesSettlementsDec. 31, 2020
Loans$550
$
$(319)$
$13
$140
$
$(103)$(4)$277
$236
Loans$402 $— $1,143 $451 $(6)$— $— $— $(5)$1,985 $1,424 
Mortgage servicing rights558

54



58
(18)(68)584
59
Mortgage servicing rights495 — (204)— — — 123 — (78)336 (180)
Other financial assets measured on a recurring basis16

51

(11)4
12
(12)(60)
63
Other financial assets measured on a recurring basis— — — — — — (1)— — — 
Liabilities   Liabilities
Interest-bearing deposits$286
$
$14
$13
$(1)$
$215
$
$(4)$495
$(355)Interest-bearing deposits$215 $— $11 $278 $(152)$— $34 $— $(158)$206 $(142)
Securities loaned and sold under agreements to repurchase726
(8)
1


243
(31)36
983
24
Securities loaned and sold under agreements to repurchase757 — — — — — — (121)631 (18)
Trading account liabilities   Trading account liabilities
Securities sold, not yet purchased22
(454)
187
(172)7
226
(39)(99)586
(238)Securities sold, not yet purchased48 (102)— 271 (17)— — 10 (200)214 (163)
Other trading liabilities5
5









Other trading liabilities— — 35 — — — — — 26 23 
Short-term borrowings18
53

72
(46)
86

(40)37
25
Short-term borrowings13 78 — 220 (6)— 86 — (16)219 (91)
Long-term debt13,082
(182)
2,850
(3,514)36
(18)(45)(3)12,570
(2,871)Long-term debt17,169 (1,489)— 6,553 (2,615)— 10,270 — (7,656)25,210 (1,679)
Other financial liabilities measured on a recurring basis8

(2)1
(10)
2

(3)
(8)Other financial liabilities measured on a recurring basis— — — — — — — (2)— 

(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 derivative assets and liabilities have been netted in these tables for presentation purposes only.
(1)
Changes in fair value of available-for-sale debt securities are recorded in AOCI, unless related to other-than-temporary impairment, while gains and losses from sales are recorded in Realized gains (losses) from sales of investments in the Consolidated Statement of Income.
(2)
Unrealized gains (losses) on MSRs are recorded in Other revenue in the Consolidated Statement of Income.
(3)
Represents the amount of total gains or losses for the period, included in earnings (and AOCI for changes in fair value of available-for-sale debt securities), attributable to the change in fair value relating to assets and liabilities classified as Level 3 that are still held at December 31, 2018.
(4)Total Level 3 derivative assets and liabilities have been netted in these tables for presentation purposes only.

Level 3 Fair Value Rollforward
The following were the significant Level 3 transfers for the period December 31, 20182020 to December 31, 2019:2021:

Transfers
During the 12 months ended December 31, 2021, transfers of Loans of $2.1 billion from Level 3 to Level 2 were primarily driven by equity forward and volatility inputs that have been assessed as not significant to the overall valuation of certain hybrid loan instruments, including equity options and long dated equity call spreads.
During the 12 months ended December 31, 2021, transfers of Equity contracts of $1.1 billion from Level 2 to Level 3 were due to equity forward and volatility inputs becoming an unobservable and/or significant input relative to the overall valuation of equity options and equity swaps. In other instances, market changes have resulted in observable equity forward and volatility inputs becoming an insignificant input 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 $1.9 billion of certain Equity contracts being transferred from Level 3 to Level 2.
During the 12 months ended December 31, 2021, transfers of Long-term debt were $8.6 billion from Level 2 to Level 3. Of the $8.6 billion transfer in, approximately $7.2 billion related to interest rate option volatility inputs becoming unobservable and/or significant relative to their
overall valuation, and $1.0 billion related to equity volatility inputs (in addition toothervolatility inputs, e.g., interest rate volatility inputs) becoming unobservable and/or significant to their overall valuation. In other instances, market changes have resulted in some inputs becoming more observable, and some unobservable inputs becoming less significant to the overall valuation of the instruments (e.g., when an option becomes deep-in or deep-out of the money). This has resulted in $9.8 billion of certain structured long-term debt products being transferred from Level 3 to Level 2 during the 12 months ended December 31, 2021.

Long-Term Debt of $3.9 billion from Level 2 to Level 3, and of $5.2 billion from Level 3 to Level 2, mainly related to structured debt, reflecting changes in the significance of unobservable inputs as well as certain underlying market inputs becoming less or more observable.

The following were the significant Level 3 transfers for the period December 31, 20172019 to December 31, 2018:2020:

Transfers of Equity Contract Derivatives of $1.1 billion from Level 3 to Level 2, related to equity derivatives where the unobservable components were deemed insignificant.
Transfers of Commodity Contract Derivatives of $2.2 billion from Level 3 to Level 2, related to commodity derivatives where the unobservable component of the derivatives were deemed insignificant.
Transfers of Long-term debt of $2.9 billion from Level 2 to Level 3, and of $3.5 billion from Level 3 to Level 2, mainly related to structured debt, reflecting changes in the significance of unobservable inputs as well as certain underlying market inputs becoming less or more observable.


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
274


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.
275


Valuation Techniques and Inputs for Level 3 Fair
Value Measurements
The Company’s Level 3 inventory consists of both cash
instruments and derivatives of varying complexity. The
valuation methodologies used to measure the fair value of
these positions include discounted cash flow analysis, internal
models and comparative analysis. A position is classified
within Level 3 of the fair value hierarchy when at least one
input is unobservable and is considered significant to its
valuation. The specific reason an input is deemed
unobservable varies; for example, at least one significant
input to the pricing model is not observable in the market, at
least one significant input has been adjusted to make it more
representative of the position being valued or the price quote
available does not reflect sufficient trading activities.
The following tables present the valuation techniques covering the majority of Level 3 inventory and the most
significant unobservable inputs used in Level 3 fair value measurements. Differences between this table and amounts presented in the Level 3 Fair Value Rollforward table represent individually immaterial items that have been measured using a variety of valuation techniques other than those listed.
As of December 31, 2021
Fair value(1)
 (in millions)
MethodologyInput
Low(2)(3)
High(2)(3)
Weighted
average(4)
Assets      
Securities borrowed and purchased under agreements to resell$231 Model-basedCredit spread15 bps15 bps15 bps
Interest rate0.26 %0.72 %0.50 %
Mortgage-backed securities$279 Price-basedPrice$4 $118 $79 
526 Yield analysisYield1.43 %23.79 %7.25 %
State and municipal, foreign government, corporate and other debt securities$2,264 Price-basedPrice$ $995 $193 
415 Model-basedEquity volatility0.08 %290.64 %53.94 %
Marketable equity securities(5)
$128 Price-basedPrice$ $73,000 $6,477 
43 Model-basedWAL1.73 years1.73 years1.73 years
Recovery
(in millions)
$7,148 $7,148 $7,148 
Asset-backed securities$386 Price-basedPrice$5 $754 $87 
208 Yield analysisYield2.43 %19.35 %8.18 %
Non-marketable equities$121 Price-basedIlliquidity discount10.00 %36.00 %26.43 %
112 Comparables analysisPE ratio11.00x29.00x15.42x
83 Model-basedPrice$3 $2,601 $2,029 
Adjustment factor0.33x0.44x0.34x
Revenue multiple19.80x30.00x20.48x
Cost of capital17.50 %20.00 %17.57 %
Derivatives—gross(6)
Interest rate contracts (gross)$6,054 Model-basedIR normal volatility0.24 %0.94 %0.70 %
Foreign exchange contracts (gross)$1,364 Model-basedIR Normal volatility0.24 %0.74 %0.58 %
FX volatility2.13 %107.42 %11.21 %
Credit spread140 bps696 bps639 bps
Equity contracts (gross)(7)
$4,690 Model-basedEquity volatility0.08 %290.64 %47.67 %
Equity forward57.99 %165.83 %89.45 %
Equity-FX Correlation(95.00)%80.00 %(16.00)%
Equity-Equity Correlation(6.49)%99.00 %85.61 %
Commodity and other contracts (gross)$3,172 Model-basedForward price8.00 %599.44 %123.22 %
Commodity volatility10.87 %188.30 %26.85 %
Commodity correlation(50.52)%89.83 %(7.11)%
Credit derivatives (gross)$1,480 Model-basedCredit spread1.00 bps874.72 bps68.83 bps
427 Price-basedRecovery rate20.00 %75.00 %44.72 %
Upfront points2.74 %99.96 %59.37 %
Price$40 $103 $80 
Credit correlation30.00 %80.00 %54.57 %
Non-trading derivatives and other financial assets and liabilities measured on a recurring basis (gross)$69 Price-basedPrice$94 $2,598 $591 
Loans and leases$691 Model-basedEquity volatility22.48 %85.44 %50.56 %
276


As of December 31, 2021
Fair value(1)
 (in millions)
MethodologyInput
Low(2)(3)
High(2)(3)
Weighted
average(4)
Forward price26.95 %333.08 %106.97 %
Commodity volatility10.87 %188.30 %26.85 %
Commodity correlation(50.52)%89.83 %(7.11)%
Mortgage servicing rights$331 Cash flowYield(1.20)%12.10 %4.51 %
73 Model-basedWAL2.75 years5.86 years5.14 years
Liabilities
Interest-bearing deposits$183 Model-basedIR Normal volatility0.34 %0.88 %0.68 %
Equity volatility0.08 %290.64 %54.05 %
Equity forward57.99 %165.83 %89.39 %
Securities loaned and sold under agreements to repurchase$643 Model-basedInterest rate0.12 %1.95 %1.47 %
Trading account liabilities
Securities sold, not yet purchased and other trading liabilities$63 Price-basedPrice$ $12,875 $1,707 
Short-term borrowings and long-term debt$25,514 Model-basedIR Normal volatility0.07 %0.88 %0.60 %
Equity volatility0.08 %290.64 %53.21 %
Equity-IR correlation(3.53)%60.00 %32.12 %
Equity-FX correlation(95.00)%80.00 %(15.98)%
FX volatility0.06 %41.76 %9.38 %
As of December 31, 2020
Fair value(1)
 (in millions)
MethodologyInput
Low(2)(3)
High(2)(3)
Weighted
average(4)
Securities borrowed and purchased under agreements to resell$320 Model-basedCredit spread15 bps15 bps15 bps
Interest rate0.30 %0.35 %0.32 %
Mortgage-backed securities$344 Price-basedPrice$30 $111 $80 
168 Yield analysisYield2.63 %21.80 %10.13 %
State and municipal, foreign government, corporate and other debt securities$1,566 Price-basedPrice$— $2,265 $90 
852 Model-basedCredit spread35 bps375 bps226 bps
Marketable equity securities(5)
$36 Model-basedPrice$— $31,000 $5,132 
36 Price-basedWAL1.48 years1.48 years1.48 years
Recovery
(in millions)
$5,733 $5,733 $5,733 
Asset-backed securities$863 Price-basedPrice$$157 $59 
744 Yield analysisYield3.77 %21.77 %9.01 %
Non-marketable equities$205 Comparables analysisIlliquidity discount10.00 %45.00 %25.29 %
PE ratio13.60x28.00x22.83x
142 Price-basedPrice$136 $2,041 $1,647 
EBITDA multiples3.30x36.70x15.10x
Adjustment factor0.20x0.61x0.25x
Appraised value
(in thousands)
$287 $39,745 $21,754 
Revenue multiple2.70x28.00x8.92x
Derivatives—gross(6)
Interest rate contracts (gross)$5,143 Model-basedInflation volatility0.27 %2.36 %0.78 %
IR normal volatility0.11 %0.73 %0.52 %
Foreign exchange contracts (gross)$1,296 Model-basedFX volatility1.70 %12.63 %5.41 %
277


As of December 31, 2020
Fair value(1)
 (in millions)
MethodologyInput
Low(2)(3)
High(2)(3)
Weighted
average(4)
Contingent event100.00 %100.00 %100.00 %
Interest rate0.84 %84.09 %17.55 %
IR normal volatility0.11 %0.52 %0.46 %
IR-FX correlation40.00 %60.00 %50.00 %
IR-IR correlation(21.71)%40.00 %38.09 %
Equity contracts (gross)(7)
$7,330 Model-basedEquity volatility5.00 %91.43 %42.74 %
Forward price65.88 %105.20 %91.82 %
Commodity and other contracts (gross)$1,636 Model-basedCommodity correlation(44.92)%95.91 %70.60 %
Commodity volatility0.16 %80.17 %23.72 %
Forward price15.40 %262.00 %98.53 %
Credit derivatives (gross)$1,854 Model-basedCredit spread3.50 bps352.35 bps99.89 bps
408 Price-basedRecovery rate20.00 %60.00 %41.60 %
Credit correlation25.00 %80.00 %43.36 %
Upfront points— %107.20 %48.10 %
Loans and leases$1,804 Model-basedEquity volatility24.65 %83.09 %58.23 %
Mortgage servicing rights$258 Cash flowYield2.86 %16.00 %6.32 %
78 Model-basedWAL2.66 years5.40 years4.46 years
Liabilities
Interest-bearing deposits$206 Model-basedIR Normal volatility0.11 %0.73 %0.54 %
Securities loaned and sold under agreements to repurchase$631 Model-basedInterest rate0.08 %1.86 %0.71 %
Trading account liabilities
Securities sold, not yet purchased and other trading liabilities$178 Model-basedIR lognormal volatility52.06 %128.87 %89.82 %
$62 Price-basedPrice$— $866 $80 
Interest rate10.03 %20.07 %13.70 %
Short-term borrowings and long-term debt$24,827 Model-basedIR normal volatility0.11 %0.73 %0.51 %
Forward price15.40 %262.00 %92.48 %

(1)The tables above include the fair values for the items listed and may not foot to the total population for each category.
(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 non-trading account derivatives—assets and liabilities—are presented on a gross absolute value basis.
(7)Includes hybrid products.


As of December 31, 2019
Fair value(1)
 (in millions)
MethodologyInput
Low(2)(3)
High(2)(3)
Weighted
average(4)
Assets      
Securities borrowed and purchased under agreements to resell$303
Model-basedCredit spread15 bps
15 bps
15 bps
   Interest rate1.59 %3.67%2.72%
Mortgage-backed securities$196
Price-basedPrice$36
$505
$97
 22
Model-based 





State and municipal, foreign government, corporate and other debt securities$880
Model-basedPrice$
$1,238
$90
 677
Price-basedCredit spread35 bps
295 bps
209 bps
Marketable equity securities(5)
$70
Price-basedPrice$
$38,500
$2,979
 30
Model-basedWAL1.48 years
1.48 years
1.48 years
   
Recovery
(in millions)
$5,450
$5,450
$5,450
Asset-backed securities$812
Price-basedPrice$4
$103
$60
 $368
Yield analysisYield0.61 %23.38%8.88%
Non-marketable equities$316
Comparables analysisEBITDA multiples7.00x
17.95x
10.34x
\97
Price-based
Appraised value
(in thousands)
$397
$33,246
$8,446
   Price$3
$2,019
$1,020
   PE ratio14.70x
28.70x
20.54x
   Price to book ratio1.50x
3.00x
1.88x
   Discount to price %10.00%2.32%
Derivatives—gross(6)
      
Interest rate contracts (gross)$2,196
Model-basedInflation volatility0.21 %2.74%0.79%
   Mean reversion1.00 %20.00%10.50%
   IR normal volatility0.09 %0.66%0.53%
Foreign exchange contracts (gross)$1,099
Model-basedFX volatility1.27 %12.16%9.17%
 

 IR normal volatility0.27 %0.66%0.58%
   FX rate37.39 %586.84%80.64%
   Interest rate2.72 %56.14%13.11%
   IR-IR correlation(51.00)%40.00%32.00%
   IR-FX correlation40.00 %60.00%50.00%
Equity contracts (gross)(7)
$2,076
Model-basedEquity volatility3.16 %52.80%28.43%
   Forward price62.60 %112.69%98.46%
   WAL1.48 years
1.48 years
1.48 years
   
Recovery
(in millions)
$5,450
$5,450
$5,450
278



As of December 31, 2019
Fair value(1)
 (in millions)
MethodologyInput
Low(2)(3)
High(2)(3)
Weighted
average(4)
Commodity and other contracts (gross)$1,487
Model-basedForward price37.62 %362.57%119.32%
   
Commodity
volatility
5.25 %93.63%23.55%
   
Commodity
correlation
(39.65)%87.81%41.80%
Credit derivatives (gross)$613
Model-basedCredit spread8 bps
283 bps
80 bps
 341
Price-basedUpfront points2.59 %99.94%59.41%
   Price$12
$100
$87
   Credit
correlation
25.00 %87.00%48.57%
   Recovery rate20.00 %65.00%48.00%
Loans and leases$378
Model-basedCredit spread9 bps
52 bps
48 bps
 
 Equity volatility32.00 %32.00%32.00%
Mortgage servicing rights$418
Cash flowYield1.78 %12.00%9.49%
 77
Model-basedWAL4.07 years
8.13 years
6.61 years
Liabilities      
Interest-bearing deposits$215
Model-basedMean reversion1.00 %20.00%10.50%
   Forward price97.59 %111.06%102.96%
Securities loaned and sold under agreements to repurchase$757
Model-basedInterest rate1.59 %2.38%1.95%
Trading account liabilities      
Securities sold, not yet purchased$46
Price-basedPrice$
$866
$96
Short-term borrowings and long-term debt$17,182
Model-basedMean reversion1.00 %20.00%10.50%
   IR normal volatility0.09 %0.66%0.46%
   Forward price37.62 %362.57%97.52%
   
Equity-IR
Correlation
15.00 %44.00%32.66%
As of December 31, 2018
Fair value(1)
 (in millions)
MethodologyInput
Low(2)(3)
High(2)(3)
Weighted
average(4)
Assets      
Securities borrowed and purchased under agreements to resell$115
Model-basedInterest rate2.52 %7.43%5.08 %
Mortgage-backed securities$313
Price-basedPrice$11
$110
$90
 198
Yield analysisYield2.27 %8.70%3.74 %
State and municipal, foreign government, corporate and other debt securities$1,212
Price-basedPrice$
$104
$91
 938
Model-basedCredit spread35 bps
446 bps
238 bps
Marketable equity securities(5)$108
Price-basedPrice$
$20,255
$1,248
 45
Model-basedWAL1.47 years
1.47 years
1.47 years
Asset-backed securities$1,608
Price-basedPrice$3
$101
$66
Non-marketable equities$293
Comparables analysisDiscount to price %100.00%0.66 %
 255
Price-basedEBITDA multiples5.00x
34.00x
9.73x
 

 Net operating income multiple24.70x
24.70x
24.70x
   Price$2
$1,074
$420
   Revenue multiple2.25x
16.50x
7.06x
Derivatives—gross(6)      

As of December 31, 2018
Fair value(1)
 (in millions)
MethodologyInput
Low(2)(3)
High(2)(3)
Weighted
average(4)
Interest rate contracts (gross)$3,467
Model-basedMean reversion1.00 %20.00%10.50 %
   Inflation volatility0.22 %2.65%0.77 %
   IR normal volatility0.16 %0.86%0.56 %
Foreign exchange contracts (gross)$626
Model-basedForeign exchange (FX) volatility3.15 %17.35%11.37 %
 73
Cash flowIR-IR correlation(51.00)%40.00%32.69 %
   IR-FX correlation40.00 %60.00%50.00 %
   Credit spread39 bps
676 bps
423 bps
   IR basis(0.65)%0.11%(0.17)%
   Yield6.98 %7.48%7.23 %
Equity contracts (gross)(7)$1,467
Model-basedEquity volatility3.00 %78.39%37.53 %
 

 Forward price64.66 %144.45%98.55 %
   Equity-Equity correlation(81.39)%100.00%35.49 %
 

 Equity-FX correlation(86.27)%70.00%(1.20)%
   WAL1.47 years
1.47 years
1.47 years
Commodity and other contracts (gross)$1,552
Model-basedForward price15.30 %585.07%145.08 %
 

 Commodity volatility8.92 %59.86%20.34 %
 
 Commodity correlation(51.90)%92.11%40.71 %
Credit derivatives (gross)$1,089
Model-basedCredit correlation5.00 %85.00%41.06 %
 701
Price-basedUpfront points7.41 %99.04%58.95 %
 

 Credit spread2 bps
1,127 bps
87 bps
   Recovery rate5.00 %65.00%46.40 %
   Price$17
$98
$81
Loans and leases$248
Model-basedCredit spread138 bps
255 bps
147 bps
 29
Price-basedYield0.30 %0.47%0.32 %
 
 Price$56
$110
$92
Mortgage servicing rights$501
Cash flowYield4.60 %12.00%7.79 %
 84
Model-basedWAL3.55 years
7.45 years
6.39 years
Liabilities   





Interest-bearing deposits$495
Model-basedMean reversion1.00 %20.00%10.50 %
 

 Forward price64.66 %144.45%98.55 %
 

 Equity volatility3.00 %78.39%43.49 %
Securities loaned and sold under agreements to repurchase$983
Model-basedInterest rate2.52 %3.21%2.87 %
Trading account liabilities

  





Securities sold, not yet purchased$509
Model-basedForward price15.30 %585.07%105.69 %
 77
Price-basedEquity volatility3.00 %78.39%43.49 %
   Equity-Equity correlation(81.39)%100.00%34.04 %
   Equity-FX correlation(86.27)%70.00%(1.20)%
   Commodity volatility8.92 %59.86%20.34 %
   Commodity correlation(51.90)%92.11%40.71 %
   Equity-IR correlation(40.00)%70.37%30.80 %
Short-term borrowings and long-term debt$12,289
Model-basedMean reversion1.00 %20.00%10.50 %
   Forward price64.66 %144.45%98.58 %
   Equity volatility3.00 %78.39%43.24 %
(1)The fair value amounts presented in these tables represent the primary valuation technique or techniques for each class of assets or liabilities.

(2)Some inputs are shown as zero due to rounding.
(3)When the low and high inputs are the same, there is either a constant input applied to all positions, or the methodology involving the input applies to only one large position.
(4)Weighted averages are calculated based on the fair values of the instruments.
(5)For equity securities, the price inputs are expressed on an absolute basis, not as a percentage of the notional amount.
(6)Both trading and nontrading account derivatives—assets and liabilities—are presented on a gross absolute value basis.
(7)Includes hybrid products.

Uncertainty of Fair Value Measurements Relating to Unobservable Inputs
Valuation uncertainty arises when there is insufficient or disperse market data to allow a precise determination of the exit value of a fair-valued position or portfolio in today’s market. This is especially prevalent in Level 3 fair value instruments, where uncertainty exists in valuation inputs that may be both unobservable and significant to the instrument’s (or portfolio’s) overall fair value measurement. The uncertainties associated with key unobservable inputs on the Level 3 fair value measurements may not be independent of one another. In addition, the amount and direction of the uncertainty on a fair value measurement for a given change in an unobservable input depends on the nature of the instrument as well as whether the Company holds the instrument as an asset or a liability. For certain instruments, the pricing, hedging and risk management are sensitive to the correlation between various inputs rather than on the analysis and aggregation of the individual inputs.
The following section describes some of the most significant unobservable inputs used by the Company in Level 3 fair value measurements.

Correlation
Correlation is a measure of the extent to which two or more variables change in relation to each other. A variety of correlation-related assumptions are required for a wide range of instruments, including equity and credit baskets, foreign exchange options, CDOs backed by loans or bonds, mortgages, subprime mortgagesCredit Index Tranches 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 an instrument (or a portfolioportfolio) 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)equities) depends on the volatility of the individual underlying securities as well as their correlations.

Yield
In some circumstances, the yield of an instrument is not observable in the market and must be estimated from historical data or from yields of similar securities. This estimated yield may need to be adjusted to capture the characteristics of the security being valued. In other situations, the estimated yield may not represent sufficient market liquidity and must be adjusted as well. Whenever the amount of the adjustment is significant to the value of the security, the fair value measurement is classified as Level 3.
Adjusted yield is generally used to discount the projected future principal and interest cash flows on instruments, such as asset-backed securities. Adjusted yield is impacted by changes in the interest rate environment and relevant credit spreads.

Prepayment
Voluntary unscheduled payments (prepayments) change the future cash flows for the investor and thereby change the fair value of the security. The effect of prepayments is more pronounced for residential mortgage-backed securities. An increase in prepayments—in speed or magnitude—generally creates losses for the holder of these securities. Prepayment is generally negatively correlated with delinquency and interest rate. A combination of low prepaymentprepayments 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(e.g., commercial mortgage backed securities), therethe expected recovery amount of a defaulted property is no directly observable market input for recovery, but indicationstypically unknown until a liquidation of recovery levels are available from pricing services.the property is imminent. 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.


279


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.
280


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 dollarsFair valueLevel 2Level 3
December 31, 2019   
Loans HFS(1)
$4,579
$3,249
$1,330
Other real estate owned20
6
14
Loans(2)
344
93
251
Non-marketable equity securities measured using the measurement alternative249
249

Total assets at fair value on a nonrecurring basis$5,192
$3,597
$1,595

In millions of dollarsFair valueLevel 2Level 3
December 31, 2021   
Loans HFS(1)
$2,298 $986 $1,312 
Other real estate owned11  11 
Loans(2)
144  144 
Non-marketable equity securities measured using the measurement alternative655 104 551 
Total assets at fair value on a nonrecurring basis$3,108 $1,090 $2,018 
In millions of dollarsFair valueLevel 2Level 3In millions of dollarsFair valueLevel 2Level 3
December 31, 2018 
December 31, 2020December 31, 2020   
Loans HFS(1)
$5,055
$3,261
$1,794
Loans HFS(1)
$2,430 $207 $2,223 
Other real estate owned78
62
16
Other real estate owned17 13 
Loans(2)
390
139
251
Loans(2)
703 — 703 
Non-marketable equity securities measured using the measurement alternative261
192
69
Non-marketable equity securities measured using the measurement alternative458 403 55 
Total assets at fair value on a nonrecurring basis$5,784
$3,654
$2,130
Total assets at fair value on a nonrecurring basis$3,608 $614 $2,994 

(1)
(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.

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.

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 there are insufficient market observations to conclude the inputs are observable, where significant adjustments are made to the observed transaction priceprices 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.


281


Valuation Techniques and Inputs for Level 3 Nonrecurring Fair Value Measurements
The following tables present the valuation techniques covering the majority of Level 3 nonrecurring fair value measurements and the most significant unobservable inputs used in those measurements:
As of December 31, 2019
Fair value(1)
 (in millions)
MethodologyInput
Low(2)
High
Weighted
average(3)
Loans HFS$1,320
Price-basedPrice$86
$100
$99
Other real estate owned$11
Price-based
Appraised value(4)
$2,297,358
$8,394,102
$5,615,884
 $5
Recovery analysis    
Loans(6)
$100
Recovery analysisRecovery rate0.57%100.00%64.78%
 54
Cash flowPrice$2
$54
$27
 47
Price-basedCost of capital0.10%100.00%54.84%
 29
Price-based
Appraised value(4)
$17,521,218
$43,646,426
$30,583,822

As of December 31, 2021
Fair value(1)
 (in millions)
MethodologyInput
Low(2)
High
Weighted
average(3)
Loans HFS$1,312 Price-basedPrice$89 $100 $99 
Other real estate owned$4 Price-based
Appraised value(4)
$14,000 $2,392,464 $1,660,120 
5 Recovery analysis
Loans(5)
$120 Recovery analysis
Appraised value(4)
$10,000 $3,900,000 $247,018 
24 Price-basedPrice$3 $75 $35 
Recovery rate84.00 %100.00 %84.00 %
Non-marketable equity securities measured using the measurement alternative$551 Price-basedPrice$6 $1,339 $52 
As of December 31, 2018
Fair value(1)
 (in millions)
MethodologyInput
Low(2)
High
Weighted
average(3)
As of December 31, 2020As of December 31, 2020
Fair value(1)
 (in millions)
MethodologyInput
Low(2)
High
Weighted
average(3)
Loans HFS$1,729
Price-basedPrice$81
$100
$98
Loans HFS$2,182 Price-basedPrice$78 $100 $97 
Other real estate owned$15
Price-based
Appraised value(4)
$8,394,102
$8,394,102
$8,394,102
Other real estate owned$Price-based
Appraised value(4)
$3,110,711 $4,241,357 $3,586,975 
2
Recovery analysisDiscount to price13.00%13.00%13.00%Recovery analysisPrice51 51 51 
Loans(5)
Loans(5)
$96 Price-basedPrice$$49 $23 
  Price$56
$83
$58
429 Recovery analysis
Appraised value(4)
$95 $43,646,426 $1,698,938 
Loans(6)
$251
Recovery analysisRecovery rate30.60%100.00%50.51%


 Price$3
$85
$28
Non-marketable equity securities measured using the measurement alternative$66
Price-basedPrice$46
$1,514
$570
Non-marketable equity securities measured using the measurement alternative$36 Comparable analysisRevenue multiple1.70x15.10x10.88x
18 Net asset approachIlliquidity discount20.00 %20.00 %20.00 %
Price$ $17 $6 

(1)The table above includes the fair values for the items listed and may not foot to the total population for each category.
(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.

(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)Includes estimated costs to sell.
(6)Represents impaired loans held for investment whose carrying amounts are based on the fair value of the underlying collateral, primarily real estate secured loans.

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:
 Year ended December 31,
In millions of dollars2019
Loans HFS$
Other real estate owned(1)
Loans(1)
(56)
Non-marketable equity securities measured using the measurement alternative99
Total nonrecurring fair value gains (losses)$42




 Year ended December 31,
In millions of dollars2018
Loans HFS$(13)
Other real estate owned(2)
Loans(1)
(22)
Non-marketable equity securities measured using the measurement alternative194
Total nonrecurring fair value gains (losses)$157
(1)Represents loans held for investment whose carrying amount is based onYear ended December 31,
In millions of dollars2021
Loans HFS$(31)
Other real estate owned
Loans(1)
9
Non-marketable equity securities measured using the measurement alternative468
Total nonrecurring fair value of the underlying collateral, primarily real estate.gains (losses)$446
Year ended December 31,
In millions of dollars2020
Loans HFS$(93)
Other real estate owned(1)
Loans(1)
109 
Non-marketable equity securities measured using the measurement alternative221 
Total nonrecurring fair value gains (losses)$236 

(1)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.
282


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.

December 31, 2019Estimated fair value December 31, 2021Estimated fair value
Carrying
value
Estimated
fair value
  Carrying
value
Estimated
fair value
In billions of dollarsLevel 1Level 2Level 3In billions of dollarsLevel 1Level 2Level 3
Assets Assets�� 
Investments$86.4
$87.8
$1.9
$83.8
$2.1
Investments, net of allowanceInvestments, net of allowance$221.9 $221.0 $111.8 $106.4 $2.8 
Securities borrowed and purchased under agreements to resell98.1
98.1

98.1

Securities borrowed and purchased under agreements to resell110.8 110.8  106.4 4.4 
Loans(1)(2)
681.2
677.7

4.7
673.0
Loans(1)(2)
644.8 659.6   659.6 
Other financial assets(2)(3)
262.4
262.4
177.6
16.3
68.5
Other financial assets(2)(3)
351.9 351.9 242.1 19.9 89.9 
Liabilities Liabilities 
Deposits$1,068.3
$1,066.7
$
$875.5
$191.2
Deposits$1,315.6 $1,316.2 $ $1,153.9 $162.3 
Securities loaned and sold under agreements to repurchase125.7
125.7

125.7

Securities loaned and sold under agreements to repurchase134.6 134.6  134.5 0.1 
Long-term debt(4)
193.0
203.8

187.3
16.5
Long-term debt(4)
171.8 184.6  171.9 12.7 
Other financial liabilities(5)
110.2
110.2

37.5
72.7
Other financial liabilities(5)
111.1 111.1  17.0 94.1 
 December 31, 2020Estimated fair value
 Carrying
value
Estimated
fair value
In billions of dollarsLevel 1Level 2Level 3
Assets     
Investments, net of allowance$110.3 $113.2 $23.3 $87.0 $2.9 
Securities borrowed and purchased under agreements to resell109.5 109.5 — 109.5 — 
Loans(1)(2)
643.3 663.9 — 0.6 663.3 
Other financial assets(2)(3)
383.2 383.2 291.5 18.1 73.6 
Liabilities     
Deposits$1,278.7 $1,278.8 $— $1,093.3 $185.5 
Securities loaned and sold under agreements to repurchase139.3 139.3 — 139.3 — 
Long-term debt(4)
204.6 221.2 — 197.8 23.4 
Other financial liabilities(5)
102.4 102.4 — 19.2 83.2 

(1)The carrying value of loans is net of the Allowance for credit losses on loans of $16.5 billion for December 31, 2021 and $25.0 billion for December 31, 2020. In addition, the carrying values exclude $0.5 billion and $0.7 billion of lease finance receivables at December 31, 2021 and 2020, respectively.
(2)Includes items measured at fair value on a nonrecurring basis.
(3)Includes cash and due from banks, deposits with banks, brokerage receivables, reinsurance recoverables and other financial instruments included in Other assets on the Consolidated Balance Sheet, for all of which the carrying value is a reasonable estimate of fair value.
283


 December 31, 2018Estimated fair value
 
Carrying
value
Estimated
fair value
   
In billions of dollarsLevel 1Level 2Level 3
Assets     
Investments$68.9
$68.5
$1.0
$65.4
$2.1
Securities borrowed and purchased under agreements to resell123.0
123.0

121.6
1.4
Loans(1)(2)
667.1
666.9

5.6
661.3
Other financial assets(2)(3)
249.7
250.1
172.3
15.8
62.0
Liabilities     
Deposits$1,011.7
$1,009.5
$
$847.1
$162.4
Securities loaned and sold under agreements to repurchase133.3
133.3

133.3

Long-term debt(4)
193.8
193.7

178.4
15.3
Other financial liabilities(5)
103.8
103.8

17.2
86.6
(4)The carrying value includes long-term debt balances under qualifying fair value hedges.
(1)
(5)
The carrying value of loans is net of the Allowance for loan losses of $12.8 billion for December 31, 2019 and $12.3 billion for December 31, 2018. In addition, the carrying values exclude $1.4 billion and $1.6 billion of lease finance receivables at December 31, 2019 and 2018, respectively.
(2)Includes items measured at fair value on a nonrecurring basis.

(3)
Includes cash and due from banks, deposits with banks, brokerage receivables, reinsurance recoverables and other financial instruments included in Other assets on the Consolidated Balance Sheet, for all of which the carrying value is a reasonable estimate of fair value.
(4)The carrying value includes long-term debt balances under qualifying fair value hedges.
(5)
Includes brokerage payables, separate and variable accounts, short-term borrowings (carried at cost) and other financial instruments included in Other liabilities on the Consolidated Balance Sheet, for all of which the carrying value is a reasonable estimate of fair value.

The estimated fair values of the Company’s corporate unfunded lending commitments at December 31, 20192021 and 20182020 were off-balance liabilities of $5.1$8.1 billion and $7.8$7.3 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 cancelablecancellable by providing notice to the borrower.

284


25.  FAIR VALUE ELECTIONS
The Company may elect to report most financial instruments and certain other items at fair value on an instrument-by-instrument basis with changes in fair value reported in earnings, other than DVA (see below). The election is made upon the initial recognition of an eligible financial asset, financial liability or firm commitment or when certain specified reconsideration events occur. The fair value election may not otherwise be revoked once an election is made. The
changes in fair value are recorded in current earnings, other thanearnings. Movements in DVA which isare reported inas 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 ofadditional details on Citi’s MSRs.

The following table presents the changes in fair value of those items for which the fair value option has been elected:
 
Changes in fair value for the years ended
December 31,
 
In millions of dollars20192018
Assets  
Securities borrowed and purchased under agreements to resell$6
$(6)
Trading account assets77
(337)
Investments

Loans  
Certain corporate loans 
(222)(116)
Certain consumer loans

Total loans$(222)$(116)
Other assets
 
MSRs$(84)$54
Certain mortgage loans HFS(1)
91
38
Total other assets$7
$92
Total assets$(132)$(367)
Liabilities  
Interest-bearing deposits$(205)$20
Securities loaned and sold under agreements to repurchase

386
(118)
Trading account liabilities27
(13)
Short-term borrowings(78)150
Long-term debt(2)
(5,174)3,048
Total liabilities$(5,044)$3,087

(1)Includes gains (losses) associated with interest rate lock commitments for those loans that have been originated and elected under the fair value option.
(2)
Changes in fair valuegains (losses) for the years ended December 31,
In millions of dollars20212020
Assets
Securities borrowed and purchased under agreements to resell$(87)$— 
Trading account assets59 (136)
Investments — 
Loans
Certain corporate loans
(171)2,486 
Certain consumer loans 
Total loans$(171)$2,487 
Other assets
MSRs$43 $(204)
Certain mortgage loans HFS(1)
70 299 
Total other assets$113 $95 
Total assets$(86)$2,446 
Liabilities
Interest-bearing deposits$(118)$(154)
Securities loaned and sold under agreements to repurchase66 (559)
Trading account liabilities17 (1)
Short-term borrowings(2)
675 802 
Long-term debt(2)
386 (2,700)
Total liabilities$1,026 $(2,612)

(1)    Includes gains (losses) associated with interest rate lock commitments for those loans that have been originated and elected under the fair value option.
(2)     Includes DVA that is included in AOCI. See Notes 19 and 24 to the Consolidated Financial Statements.

285




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 lossgain of $1,473$296 million and a gainloss of $1,415$616 million for the years ended December 31, 20192021 and 2018,2020, 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-CollateralizedUncollateralized 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:
 December 31, 2019December 31, 2018
In millions of dollarsTrading assetsLoansTrading assetsLoans
Carrying amount reported on the Consolidated Balance Sheet$8,320
$4,086
$10,108
$3,224
Aggregate unpaid principal balance in excess of (less than) fair value410
315
435
741
Balance of non-accrual loans or loans more than 90 days past due
1

1
Aggregate unpaid principal balance in excess of (less than) fair value for non-accrual loans or loans more than 90 days past due




 December 31, 2021December 31, 2020
In millions of dollarsTrading assetsLoansTrading assetsLoans
Carrying amount reported on the Consolidated Balance Sheet$9,530 $6,082 $8,063 $6,854 
Aggregate unpaid principal balance in excess of (less than) fair value(100)226 (915)(14)
Balance of non-accrual loans or loans more than 90 days past due 1 — 
Aggregate unpaid principal balance in excess of (less than) fair value for non-accrual loans or loans more than 90 days past due  — — 

In addition to the amounts reported above, $1,062$719 million and $1,137$1,068 million of unfunded commitments related to certain credit products selected for fair value accounting were outstanding as of December 31, 20192021 and 2018,2020, respectively.

286


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, 20192021 and 20182020 due to instrument-specific credit risk totaled to a gainloss of $95$21 million and a loss of $27$16 million, respectively.

Certain Investments in Unallocated Precious Metals
Citigroup invests in unallocated precious metals accounts (gold, silver, platinum and palladium) as part of its commodity and foreign currency trading activities or to economically hedge certain exposures from issuing structured liabilities. Under ASC 815, the investment is bifurcated into a debt host contract and a commodity forward derivative instrument. Citigroup elects the fair value option for the debt host contract, and reports the debt host contract within Trading account assets on the Company’s Consolidated Balance Sheet. The total carrying amount of debt host contracts across unallocated precious metals accounts was approximately $0.2$0.3 billion and $0.4$0.5 billion at December 31, 20192021 and 2018,2020, respectively. The amounts are expected to fluctuate based on trading activity in future periods.
As part of its commodity and foreign currency trading activities, Citi trades unallocated precious metals investments and executes forward purchase and forward sale derivative contracts with trading counterparties. When Citi sells an unallocated precious metals investment, Citi’s receivable from its depository bank is repaid and Citi derecognizes its investment in the unallocated precious metal. The forward purchase or sale contract with the trading counterparty indexed to unallocated precious metals is accounted for as a derivative, at fair value through earnings. As of December 31, 2019,2021, there were approximately $7.4$15.2 billion and $6.8$10.5 billion inof notional amounts of such forward purchase and forward sale derivative contracts outstanding, respectively.

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.

The following table provides information about certain mortgage loans HFS carried at fair value:
In millions of dollarsDecember 31,
2019
December 31, 2018
Carrying amount reported on the Consolidated Balance Sheet$1,254
$556
Aggregate fair value in excess of (less than) unpaid principal balance(31)21
Balance of non-accrual loans or loans more than 90 days past due1

Aggregate unpaid principal balance in excess of fair value for non-accrual loans or loans more than 90 days past due


In millions of dollarsDecember 31,
2021
December 31, 2020
Carrying amount reported on the Consolidated Balance Sheet$3,035 $1,742 
Aggregate fair value in excess of (less than) unpaid principal balance70 91 
Balance of non-accrual loans or loans more than 90 days past due1 — 
Aggregate unpaid principal balance in excess of fair value for non-accrual loans or loans more than 90 days past due — 

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, 20192021 and 20182020 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.

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Certain StructuredDebt 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.debt liabilities. The Company elected the fair value option because these exposures are considered to be trading-related positions and, therefore, they are managed on a fair value basis. These positions will continue to be classified as debt, deposits or derivatives (classified as 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 carried at fair value, disaggregated by type of embedded derivative instrument:risk:

In billions of dollarsDecember 31, 2019December 31, 2018In billions of dollarsDecember 31, 2021December 31, 2020
Interest rate linked$22.9
$17.3
Interest rate linked$38.9 $34.5 
Foreign exchange linked0.9
0.5
Foreign exchange linked 1.2 
Equity linked21.7
14.8
Equity linked36.1 27.3 
Commodity linked1.8
1.2
Commodity linked3.9 1.4 
Credit linked2.4
1.9
Credit linked3.7 2.6 
Total$49.7
$35.7
Total$82.6 $67.0 

The portion of the changes in fair value attributable to changes in Citigroup’s own credit spreads (DVA)(i.e., 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)(i.e., 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 dollarsDecember 31, 2019December 31, 2018
Carrying amount reported on the Consolidated Balance Sheet$55,783
$38,229
Aggregate unpaid principal balance in excess of (less than) fair value(2,967)3,814

In millions of dollarsDecember 31, 2021December 31, 2020
Carrying amount reported on the Consolidated Balance Sheet$82,609 $67,063 
Aggregate unpaid principal balance in excess of (less than) fair value(2,459)(5,130)

The following table provides information about short-term borrowings carried at fair value:
In millions of dollarsDecember 31, 2019December 31, 2018
Carrying amount reported on the Consolidated Balance Sheet$4,946
$4,483
Aggregate unpaid principal balance in excess of (less than) fair value1,411
861

In millions of dollarsDecember 31, 2021December 31, 2020
Carrying amount reported on the Consolidated Balance Sheet$7,358 $4,683 
Aggregate unpaid principal balance in excess of (less than) fair value(644)68 
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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 dollarsDecember 31, 2019December 31,
2018
Investment securities$152,352
$148,756
Loans236,033
227,840
Trading account assets132,332
120,292
Total$520,717
$496,888

In millions of dollarsDecember 31, 2021December 31,
2020
Investment securities$252,192 $231,696 
Loans232,319 239,699 
Trading account assets140,980 174,717 
Total$625,491 $646,112 

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 CommoditiesCommodity 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 dollarsDecember 31,
2019
December 31,
2018
Cash and due from banks$3,758
$4,000
Deposits with banks26,493
27,208
Total$30,251
$31,208

In millions of dollarsDecember 31,
2021
December 31,
2020
Cash and due from banks$2,786 $3,774 
Deposits with banks, net of allowance10,636 14,203 
Total$13,422 $17,977 

In addition, included in Cash and due from banks and Deposits with banks at December 31, 20192021 and 20182020 were $8.5$13.7 billion and $8.3$9.4 billion, respectively, of cash segregated under federal and other brokerage regulations or deposited with clearing organizations.

Collateral
At December 31, 20192021 and 2018,2020, the approximate fair value of collateral received by Citi that may be resold or repledged, excluding the impact of allowable netting, was $569.8$650.8 billion and $526.0$671.6 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, 20192021 and 2018,2020, a substantial portion of the collateral received by Citi had been sold or repledged in connection with repurchase agreements, securities sold, not yet purchased, securities borrowings and loans,lendings, pledges to clearing organizations, segregation requirements under securities laws and regulations, derivative transactions and bank loans.
In addition, at December 31, 20192021 and 2018,2020, Citi had pledged $389.8$481.0 billion and $373.7$470.7 billion, respectively, of collateral that may not be sold or repledged by the secured parties.

Leases
The Company’s operating leases, where Citi is a lessee, include real estate such as office space and branches and various types of equipment. These leases 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, 2019.2021 and 2020. The operating lease ROU asset and lease liability were $3.1 was $2.9 billion and $3.3$2.8 billion, respectively, as of December 31, 2019.2021 and 2020, respectively. The operating lease ROU liability was $3.1 billion and $3.1 billion, as of December 31, 2021 and 2020, 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 $56$12 million and $27 million of sublease income, was $1,084$1,061 million and $1,054 million for the yearyears ended December 31, 2019. 2021 and 2020, respectively.
The table below provides the Cash Flow Statement Supplemental Information:

In millions of dollarsDecember 31,
2021
December 31,
2020
Cash paid for amounts included in the measurement of lease liabilities$806 $814 
Right-of-use assets obtained in exchange for new operating lease liabilities(1)(2)
845 447 

(1)     Represents non-cash activity and, accordingly, is not reflected in the Consolidated Statement of Cash Flows.
(2)    Excludes the decrease in the lease liability (and related operating lease financial information) from January 1, 2019 is primarilyright-of-use assets related to the purchase of a previously leased property in London during the second quarter of 2019. See Note 1 for additionalproperty.

289


Citi’s future lease liability details and balances at January 1, 2019. The purchased property is included in payments are as follows:
Other assets on the Consolidated Balance Sheet at December 31, 2019.
While Citi has certain finance leases as a lessee, such leases are not material to the Company's Consolidated Financial Statements.
In millions of dollars
2022$763 
2023648 
2024542 
2025445 
2026346 
Thereafter753 
Total future lease payments$3,497 
Less imputed interest (based on weighted-average discount rate of 3.0%)$(381)
Lease liability$3,116 
Citi’s
Operating lease arrangements that have not yet commenced as of December 31, 2019 and the Company’s short-term lease, variable lease and finance lease costs,expense was $1.1 billion for the year ended December 31, 2019, are not material to the Consolidated Financial Statements.
2019.

Citi’s cash outflows related to operating leases were $942 million for the year ended December 31, 2019, while the future lease payments are as follows:
In millions of dollars 
2020$801
2021695
2022572
2023425
2024314
Thereafter935
Total future lease payments$3,742
Less imputed interest (based on weighted-average discount rate of 3.6%)$(402)
Lease liability$3,340


The minimum annual rent commitments under non-cancelable leases, net of sublease income, as ofDecember 31, 2018 prior to the adoption of ASU 2016-02, were as follows:
In millions of dollars 
2019$925
2020748
2021657
2022525
2023394
Thereafter1,890
Total lease commitments$5,139


Operating lease expenses were $1.0 billion and $1.1 billion for the years ended December 31, 2018 and 2017, respectively.

Guarantees
Citi provides a variety of guarantees and indemnifications to its customers to enhance their credit standing and enable them to complete a wide variety of business transactions. For
certain contracts meeting the definition of a guarantee, the guarantor must recognize, at inception, a liability for the fair value of the obligation undertaken in issuing the guarantee.
In addition, the guarantor must disclose the maximum potential amount of future payments that the guarantor could be required to make under the guarantee, if there were a total
default by the guaranteed parties. The determination of the maximum potential future payments is based on the notional amount of the guarantees without consideration of possible recoveries under recourse provisions or from collateral held or pledged. As such, Citi believes such amounts bear no relationship to the anticipated losses, if any, on these guarantees.



The following tables present information about Citi’s guarantees:

 Maximum potential amount of future payments 
In billions of dollars at December 31, 2021Expire within
1 year
Expire after
1 year
Total amount
outstanding
Carrying value
(in millions of dollars)
Financial standby letters of credit$34.3 $58.4 $92.7 $791 
Performance guarantees6.6 6.4 13.0 47 
Derivative instruments considered to be guarantees14.6 48.9 63.5 514 
Loans sold with recourse 1.7 1.7 15 
Securities lending indemnifications(1)
121.9  121.9  
Credit card merchant processing(2)
119.4  119.4 1 
Credit card arrangements with partners 0.8 0.8 7 
Other2.0 12.0 14.0 34 
Total$298.8 $128.2 $427.0 $1,409 
 Maximum potential amount of future payments 
In billions of dollars at December 31, 2020Expire within
1 year
Expire after
1 year
Total amount
outstanding
Carrying value
(in millions of dollars)
Financial standby letters of credit$25.3 $68.4 $93.7 $1,407 
Performance guarantees7.3 6.0 13.3 72 
Derivative instruments considered to be guarantees20.0 60.9 80.9 671 
Loans sold with recourse— 1.2 1.2 
Securities lending indemnifications(1)
112.2 — 112.2 — 
Credit card merchant processing(2)
101.9 — 101.9 
Credit card arrangements with partners0.2 0.8 1.0 
Other— 12.0 12.0 35 
Total$266.9 $149.3 $416.2 $2,204 

(1)The carrying values of securities lending indemnifications were not material for either period presented, as the probability of potential liabilities arising from these guarantees is minimal.
(2)At December 31, 2021 and 2020, this maximum potential exposure was estimated to be $119 billion and $102 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.


 Maximum potential amount of future payments 
In billions of dollars at December 31, 2019
Expire within
1 year
Expire after
1 year
Total amount
outstanding
Carrying value
(in millions of dollars)
Financial standby letters of credit$31.9
$62.4
$94.3
$140
Performance guarantees6.9
5.5
12.4
21
Derivative instruments considered to be guarantees37.5
60.1
97.6
289
Loans sold with recourse
1.2
1.2
7
Securities lending indemnifications(1)
87.8

87.8

Credit card merchant processing(1)(2)
91.6

91.6

Credit card arrangements with partners0.2
0.4
0.6
23
Custody indemnifications and other
33.7
33.7
41
Total$255.9
$163.3
$419.2
$521
290


 Maximum potential amount of future payments 
In billions of dollars at December 31, 2018Expire within
1 year
Expire after
1 year
Total amount
outstanding
Carrying value
(in millions of dollars)

Financial standby letters of credit$32.1
$67.5
$99.6
$131
Performance guarantees7.7
4.2
11.9
29
Derivative instruments considered to be guarantees23.5
87.4
110.9
567
Loans sold with recourse
1.2
1.2
9
Securities lending indemnifications(1)
98.3

98.3

Credit card merchant processing(1)(2)
94.7

94.7

Credit card arrangements with partners

0.3
0.8
1.1
162
Custody indemnifications and other
35.4
35.4
41
Total$256.6
$196.5
$453.1
$939
(1)The carrying values of securities lending indemnifications and credit card merchant processing were not material for either period presented, as the probability of potential liabilities arising from these guarantees is minimal.
(2)
At December 31, 2019 and 2018, this maximum potential exposure was estimated to be $92 billion and $95 billion, respectively. However, Citi believes that the maximum exposure is not representative of the actual potential loss exposure based on its historical experience. This contingent liability is unlikely to arise, as most products and services are delivered when purchased and amounts are refunded when items are returned to merchants.

Financial Standby Letters of Credit
Citi issues standby letters of credit, which substitute its own credit for that of the borrower. If a letter of credit is drawn down, the borrower is obligated to repay Citi. Standby letters of credit protect a third party from defaults on contractual obligations. Financial standby letters of credit include (i) guarantees of payment of insurance premiums and reinsurance risks that support industrial revenue bond underwriting, (ii) settlement of payment obligations to clearing houses, including futures and over-the-counter derivatives clearing (see further discussion below), (iii) support options and purchases of securities in lieu of escrow deposit accounts and (iv) letters of credit that backstop loans, credit facilities, promissory notes and trade acceptances.

Performance Guarantees
Performance guarantees and letters of credit are issued to guarantee a customer’s tender bid on a construction or systems-installation project or to guarantee completion of such projects in accordance with contract terms. They are also issued to support a customer’s obligation to supply specified products, commodities or maintenance or warranty services to a third party.

Derivative Instruments Considered to Be Guarantees
Derivatives are financial instruments whose cash flows are based on a notional amount and an underlying instrument, reference credit or index, where there is little or no initial investment, and whose terms require or permit net settlement. For a discussion of Citi’s derivatives activities, see Note 22 to the Consolidated Financial Statements.
Derivative instruments considered to be guarantees include only those instruments that require Citi to make payments to the counterparty based on changes in an underlying instrument that is related to an asset, a liability or an equity security held by the guaranteed party. More specifically, derivative instruments considered to be

guarantees include certain over-the-counter written put options where the counterparty is not a bank, hedge fund or broker-dealer (such counterparties are considered to be dealers in these markets and may, therefore, not hold the underlying instruments). Credit derivatives sold by Citi are excluded from the tables above as they are disclosed separately in Note 22 to the Consolidated Financial Statements. In instances where Citi’s maximum potential future payment is unlimited, the notional amount of the contract is disclosed.

Loans Sold with Recourse
Loans sold with recourse represent Citi’s obligations to reimburse the buyers for loan losses under certain circumstances. Recourse refers to the clause in a sales agreement under which a seller/lender will fully reimburse the buyer/investor for any losses resulting from the purchased loans. This may be accomplished by the sellersellers taking back any loans that become delinquent.
In addition to the amounts shown in the tables above, Citi has recorded a repurchase reserve for its potential repurchases or make-whole liability regarding residential mortgage representation and warranty claims related to its whole loan sales to U.S. government-sponsored agencies and, to a lesser
extent, private investors. The repurchase reserve was approximately $37$19 million and $49$31 million at December 31, 20192021 and 2018,2020, 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 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, 20192021 and 2018,2020, this maximum potential exposure was estimated to be $91.6$119.4 billion and $94.7$101.9 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
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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, 20192021 and 2018,2020, 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 certainone 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.


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.certain travel-related purchases. 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, 20192021 and 2018,2020, 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. NaNNo 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 0no stated or notional amounts included in the indemnification clauses, and the contingencies potentially triggering the obligation to indemnify have not occurred and are not expected to occur. As a result, these indemnifications are not included in the tables above.

Value-Transfer Networks (Including Exchanges and Clearing Houses) (VTNs)
Citi is a member of, or shareholder in, hundreds of value-transfer networks (VTNs) (payment, clearing and settlement systems as well as exchanges) around the world. As a condition of membership, many of these VTNs require that members stand ready to pay a pro rata share of the losses incurred by the organization due to another member’s default on its obligations. Citi’s potential obligations may be limited to its membership interests in the VTNs, contributions to the VTN’s funds, or, in certain narrow cases, to the full pro rata
share. The maximum exposure is difficult to estimate as this would require an assessment of claims that have not yet occurred; however, Citi believes the risk of loss is remote given historical experience with the VTNs. Accordingly, Citi’s participation in VTNs is not reported in the guarantees tables above, and there are no amounts reflected on the Consolidated Balance Sheet as of December 31, 20192021 or 20182020 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 2 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.
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In connection with Citi’s 2005 sale of Travelers to MetLife Inc. (MetLife), Citi provided an indemnification to MetLife for losses (including policyholder claims) relating to the LTC business for the entire term of the Travelers LTC policies, which, as noted above, are reinsured by subsidiaries of Genworth. In 2017, MetLife spun off its retail insurance business to Brighthouse. As a result, the Travelers LTC policies now reside with Brighthouse. The original reinsurance agreement between Travelers (now Brighthouse) and Genworth remains in place and Brighthouse is the sole beneficiary of the Genworth Trusts. The fair value of the Genworth Trusts was approximately $8.6 billion as of December 31, 2019, compared to approximately $7.5 billion at December 31, 2018. The Genworth Trusts are designed to provide collateral to Brighthouse in an amount equal to the statutory liabilities of Brighthouse in respect of the Travelers LTC policies. The assets in the Genworth Trusts are evaluated and adjusted periodically by Genworth to ensure

that the fair value of the assets continues to provide collateral in an amount equal to these estimated statutory liabilities, as the liabilities change over time.
If both (i) Genworth fails to perform under the original Travelers/GE Life reinsurance agreement for any reason, including its insolvency or the failure of UFLIC to perform under its reinsurance contract or GE to perform under the capital maintenance agreement, and (ii) the assets of the two Genworth Trusts are insufficient or unavailable, then Citi, through its LTC reinsurance indemnification, must reimburse Brighthouse for any losses incurred in connection with the LTC policies. Since both events would have to occur before Citi would become responsible for any payment to Brighthouse pursuant to its indemnification obligation, and the likelihood of such events occurring is currently not probable, there is 0no liability reflected on the Consolidated Balance Sheet as of December 31, 20192021 and 20182020 related to this indemnification. However, if both events become reasonably possible (meaning more than remote but less than probable), Citi will be required to estimate and disclose a reasonably possible loss or range of loss to the extent that such an estimate could be made. In addition, if both events become probable, Citi will be required to accrue for such liability in accordance with applicable accounting principles.
Citi continues to closely monitor its potential exposure under the Brighthouse indemnification obligation, given GE’s 2018 LTC and other charges and the September 2019 AM Best credit ratings downgrade for the two Genworth insurance subsidiaries.
Separately, Genworth announced that it had agreed to be purchased by China Oceanwide Holdings Co., Ltd, subject to a series of conditions and regulatory approvals. Citi is monitoring these developments.

Futures and Over-the-Counter Derivatives Clearing
Citi provides clearing services on central clearing parties (CCPs)(CCP) 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 2 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.
However, for exchange-traded and OTC-cleared derivatives contracts where Citi does not obtain benefits from or control the client cash balances, the client cash initial margin collected from clients and remitted to the CCP or depository institutions is not reflected on Citi’s Consolidated Balance Sheet. These conditions are met when Citi has contractually agreed with the client that (i) Citi will pass through to the client all interest paid by the CCP or depository institutions on the cash initial margin, (ii) Citi will not utilize its right as a clearing member to transform cash margin into other assets, (iii) Citi does not guarantee and is not liable to the client for the performance of the CCP or the depository institution and (iv) the client cash balances are legally isolated from Citi’s bankruptcy estate. The total amount of cash initial margin collected and remitted in this manner was approximately $13.3$18.7 billion and $13.8$16.6 billion as of December 31, 20192021 and 2018,2020, 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.


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Carrying Value—Guarantees and Indemnifications
At December 31, 20192021 and 2018,2020, the total carrying amounts of the liabilities related to the guarantees and indemnifications included in the tables above amounted to approximately $0.5$1.4 billion and $0.9$2.2 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 $46.7$56.5 billion and $38.0$51.6 billion at December 31, 20192021 and 2018,2020, respectively. Securities and other marketable assets held as collateral amounted to $45.8$84.2 billion and $54.7$80.1 billion at December 31, 20192021 and 2018,2020, respectively. The majority of collateral is held to reimburse losses realized under securities lending indemnifications. In addition, letters of credit in favor of Citi held as collateral amounted to $4.4$4.1 billion and $4.1$6.6 billion at December 31, 20192021 and 2018,2020, respectively. Other property may also be available to Citi to cover losses under certain guarantees and indemnifications; however, the value of such property has not been determined.
Performance Risk
Citi evaluates the performance risk of its guarantees based on the assigned referenced counterparty internal or external ratings. Where external ratings are used, investment-grade ratings are considered to be Baa/BBB and above, while anything below is considered non-investment grade. Citi’s internal ratings are in line with the related external rating system. On certain underlying referenced assets or entities, ratings are not available. Such referenced assets are included in the “not rated” category. The maximum potential amount of the future payments related to the outstanding guarantees is determined to be the notional amount of these contracts, which is the par amount of the assets guaranteed.
Presented in the tables below are the maximum potential
amounts of future payments that are classified based uponon 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
In billions of dollars at December 31, 2019
Investment
grade
Non-investment
grade
Not
rated
Total
Financial standby letters of credit$66.4
$12.5
$15.4
$94.3
Performance guarantees9.7
2.3
0.4
12.4
Derivative instruments deemed to be guarantees

97.6
97.6
Loans sold with recourse

1.2
1.2
Securities lending indemnifications

87.8
87.8
Credit card merchant processing

91.6
91.6
Credit card arrangements with partners

0.6
0.6
Custody indemnifications and other21.3
12.4

33.7
Total$97.4
$27.2
$294.6
$419.2

 Maximum potential amount of future payments
In billions of dollars at December 31, 2018
Investment
grade
Non-investment
grade
Not
rated
Total
Financial standby letters of credit$71.3
$11.9
$16.4
$99.6
Performance guarantees9.2
2.1
0.6
11.9
Derivative instruments deemed to be guarantees

110.9
110.9
Loans sold with recourse

1.2
1.2
Securities lending indemnifications

98.3
98.3
Credit card merchant processing

94.7
94.7
Credit card arrangements with partners



1.1
1.1
Custody indemnifications and other22.2
13.2

35.4
Total$102.7
$27.2
$323.2
$453.1

 Maximum potential amount of future payments
In billions of dollars at December 31, 2021Investment
grade
Non-investment
grade
Not
rated
Total
Financial standby letters of credit$81.4 $11.3 $ $92.7 
Performance guarantees10.5 2.5  13.0 
Derivative instruments deemed to be guarantees  63.5 63.5 
Loans sold with recourse  1.7 1.7 
Securities lending indemnifications  121.9 121.9 
Credit card merchant processing  119.4 119.4 
Credit card arrangements with partners  0.8 0.8 
Other 12.0 2.0 14.0 
Total$91.9 $25.8 $309.3 $427.0 
 Maximum potential amount of future payments
In billions of dollars at December 31, 2020Investment
grade
Non-investment
grade
Not
rated
Total
Financial standby letters of credit$78.5 $14.6 $0.6 $93.7 
Performance guarantees9.8 3.0 0.5 13.3 
Derivative instruments deemed to be guarantees— — 80.9 80.9 
Loans sold with recourse— — 1.2 1.2 
Securities lending indemnifications— — 112.2 112.2 
Credit card merchant processing— — 101.9 101.9 
Credit card arrangements with partners— — 1.0 1.0 
Other— 12.0 — 12.0 
Total$88.3 $29.6 $298.3 $416.2 

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Credit Commitments and Lines of Credit
The table below summarizes Citigroup’s credit commitments:

In millions of dollarsU.S.
Outside of 
U.S.
December 31,
2019
December 31, 2018In millions of dollarsU.S.Outside of 
U.S.
December 31,
2021
December 31, 2020
Commercial and similar letters of credit$746
$3,787
$4,533
$5,461
Commercial and similar letters of credit$654 $5,256 $5,910 $5,221 
One- to four-family residential mortgages2,088
1,633
3,721
2,671
One- to four-family residential mortgages1,752 2,599 4,351 5,002 
Revolving open-end loans secured by one- to four-family residential properties9,511
1,288
10,799
11,374
Revolving open-end loans secured by one- to four-family residential properties6,790 1,123 7,913 9,626 
Commercial real estate, construction and land development10,623
2,358
12,981
11,293
Commercial real estate, construction and land development15,877 1,966 17,843 12,867 
Credit card lines609,866
98,157
708,023
696,007
Credit card lines601,018 99,541 700,559 710,399 
Commercial and other consumer loan commitments212,569
111,790
324,359
300,115
Commercial and other consumer loan commitments207,234 113,322 320,556 322,458 
Other commitments and contingencies1,852
96
1,948
3,321
Other commitments and contingencies5,276 373 5,649 5,715 
Total$847,255
$219,109
$1,066,364
$1,030,242
Total$838,601 $224,180 $1,062,781 $1,071,288 

The majority of unused commitments are contingent upon customers maintaining specific credit standards.
Commercial commitments generally have floating interest rates and fixed expiration dates and may require payment of fees. Such fees (net of certain direct costs) are deferred and, upon exercise of the commitment, amortized over the life of the loan or, if exercise is deemed remote, amortized over the commitment period.

Commercial and Similar Letters of Credit
A commercial letter of credit is an instrument by which Citigroup substitutes its credit for that of a customer to enable the customer to finance the purchase of goods or to incur other commitments. Citigroup issues a letter on behalf
of its client to a supplier and agrees to pay the supplier upon
presentation of documentary evidence that the supplier has performed in accordance with the terms of the letter of credit. When a letter of credit is drawn, the customer is then required to reimburse Citigroup.

One- to Four-Family Residential Mortgages
A one- to four-family residential mortgage commitment is a written confirmation from Citigroup to a seller of a property that the bank will advance the specified sums enabling the buyer to complete the purchase.

Revolving Open-End Loans Secured by One- to Four-Family Residential Properties
Revolving open-end loans secured by one- to four-family residential properties are essentially home equity lines of credit. A home equity line of credit is a loan secured by a primary residence or second home to the extent of the excess of fair market value over the debt outstanding for the first mortgage.

Commercial Real Estate, Construction and Land Development
Commercial real estate, construction and land development include unused portions of commitments to extend credit for the purpose of financing commercial and multifamily residential properties as well as land development projects.





Both secured-by-real-estate and unsecured commitments are included in this line, as well as 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, 20192021 and 2018,2020, Citigroup had approximately $34.0$126.6 billion and $36.1$71.8 billion inof unsettled reverse repurchase and securities borrowing agreements, respectively, and $38.7approximately $41.1 billion and $30.7$62.5 billion inof 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.

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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 theany litigation, regulatory andor 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.
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Inherent Uncertainty of the Matters Disclosed. Certain of the matters disclosed below involve claims for substantial or indeterminate damages. The claims asserted in these matters typically are broad, often spanning a multi-yearmultiyear period and sometimes a wide range of business activities, and the plaintiffs’ or claimants’ alleged damages frequently are not quantified or factually supported in the complaint or statement of claim. Other matters relate to regulatory investigations or proceedings, as to which there may be no objective basis for quantifying the range of potential fine, penalty or other remedy. As a result, Citigroup is often unable to estimate the loss in such matters, even if it believes that a loss is probable or reasonably possible, until developments in the case, proceeding or investigation have yielded additional information sufficient to support a quantitative assessment of the range of reasonably possible loss. Such developments may include, among other things, discovery from adverse parties or third parties, rulings by the court on key issues, analysis by retained experts and engagement in settlement negotiations. Depending on a range of factors, such as the complexity of the facts, the novelty of the legal theories, the pace of discovery, the court’s scheduling order, the timing of court decisions and the adverse party’s, regulator’s or other authority’s willingness to negotiate in good faith toward a resolution, it may be months or years after the filing of a case or commencement of a proceeding or an investigation before an estimate of the range of reasonably possible loss can be made.
Matters as to Which an Estimate Can Be Made. For some of the matters disclosed below, Citigroup is currently able to estimate a reasonably possible loss or range of loss in excess of amounts accrued (if any). For some of the matters included within this estimation, an accrual has been made because a loss is believed to be both probable and reasonably estimable, but an exposure to loss exists in excess of the amount accrued. In these cases, the estimate reflects the reasonably possible range of loss in excess of the accrued amount. For other matters included within this estimation, no accrual has been made because a loss, although estimable, is believed to be reasonably possible, but not probable; in these cases, the estimate reflects the reasonably possible loss or range of loss. As of December 31, 2019,2021, Citigroup estimates that the reasonably possible unaccrued loss for these matters ranges up to approximately $1.3$1.5 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 regulatorytax 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
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 incurredamounts accrued in relation to matters for the matters as to which an estimate has been made could be substantially higher or lower than the range of loss included in the estimate.
Matters as to Which an Estimate Cannot Be Made. For other matters disclosed below, Citigroup is not currently able to estimate the reasonably possible loss or range of loss. Many of these matters remain in very preliminary stages (even in some cases where a substantial period of time has passed since the commencement of the matter), with few or no substantive legal decisions by the court, tribunal or other authority defining the scope of the claims, the class (if any) or the potentially available damages or other exposure, and fact discovery is still in progress or has not yet begun. In many of these matters, Citigroup has not yet answered the complaint or statement of claim or asserted its defenses, nor has it engaged in any negotiations with the adverse party (whether a regulator, taxing authority or a private party). For all these reasons, Citigroup cannot at this time estimate the reasonably possible loss or range of loss, if any, for these matters.
Opinion of Management as to Eventual Outcome. Subject to the foregoing, it is the opinion of Citigroup’s management, based on current knowledge and after taking into account its current legal or other accruals, that the eventual outcome of all matters described in this Note would not be likely to have a material adverse effect on the consolidated financial condition of Citigroup. Nonetheless, given the substantial or indeterminate amounts sought in certain of these matters, and the inherent unpredictability of such matters, an adverse outcome in certain of these matters could, from time to time, have a material adverse effect on Citigroup’s consolidated results of operations or cash flows in particular quarterly or annual periods.

ANZ Underwriting Matter
In June 2018,On February 11, 2022, the Australian Commonwealth Director of Public Prosecutions (CDPP) fileddiscontinued the prosecution of charges that were brought against Citigroup Global Markets Australia Pty Limited (CGMA) and two Citi employees for alleged criminal cartel offenses followingin relation to CGMA’s role as a referral byjoint underwriter and lead manager with other banks in the Australian Competition and Consumer Commission. CDPP alleges that the cartel conduct took place following an2015 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. The case, captioned R v. CITIGROUP GLOBAL MARKETS AUSTRALIA PTY LIMITED. The matterLIMITED is before the Downing Centre LocalFederal Court in Sydney,New South Wales, Australia. Additional information concerning this action is

publicly available in court filings under the docket number 2018/00175168.NSD 1316–NSD 1324/2020.


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Facilitation Trading Matters
On January 28, 2022, the Securities and Futures Commission of Hong Kong (SFC) entered into a resolution with Citigroup Global Markets Asia Limited (CGMAL) of the SFC’s investigation into CGMAL’s equity sales trading desks in connection with facilitation trades. As part of the resolution, CGMAL agreed to pay a civil penalty of $44.6 million. Citigroup is cooperating with related investigations and inquiries by other government and regulatory agencies in Asia Pacific countries and elsewhere.

Foreign Exchange Matters
Regulatory Actions: Government and regulatory agencies in the U.S. and in other jurisdictions are conducting investigations or making inquiries regarding Citigroup’s foreign exchange business. Citigroup is cooperating with these and related investigations and inquiries.
Antitrust and Other Litigation:In 2018, a number of institutional investors who opted out of the previously disclosed August 2018 final settlement filed an action against Citigroup, Citibank, CGMICitigroup 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. InOn July 2019, defendants moved to dismiss plaintiffs’ second28, 2020, plaintiffs filed a third amended complaint. Additional information concerning this action is publicly available in court filings under the docket number 18 Civ. 1036418-CV-10364 (S.D.N.Y.) (Schofield, J.).
In December 2018, a group of institutional investors issued a claim against Citigroup, Citibank Citigroup 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. In July 2019, defendants respondedDecember 2021, the High Court ordered that the case be transferred to plaintiffs’ claims, and in September 2019, claimants filed their reply.the U.K.’s Competition Appeal Tribunal. Additional information concerning this action is publicly available in court filings under the docketcase number CL-2018-000840.CL-2018-000840 in the High Court and under the case number 1430/5/7/22 (T) in the Competition Appeal Tribunal.
In 2015, a putative class of consumers and businesses in the United StatesU.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.California (later transferred to the United States District Court for the Southern District of New York). Subsequently, plaintiffs filed a thirdan amended class action complaint namingagainst 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. 229015-CV-2290 (N.D. Cal.) (Chhabria, J.) and 15 Civ. 930015-CV-9300 (S.D.N.Y.) (Schofield, J.).
In 2017, putative classes of indirect purchasers of certain foreign exchange instruments filed an action2019, two applications, captioned MICHAEL O’HIGGINS FX CLASS REPRESENTATIVE LIMITED v. BARCLAYS BANK PLC AND OTHERS and PHILLIP EVANS v. BARCLAYS BANK PLC AND OTHERS, were made to the U.K.’s Competition Appeal Tribunal requesting permission to commence collective proceedings 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, anddefendants. The applications seek compensatory damages and treble damages. In Julyfor 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 the court granted preliminary approval of a settlement between plaintiffs and Citigroup, Citibank, Citicorp and CGMI.in Case AT.40135-FOREX (Three Way Banana Split) C(2019) 3631 final). Additional information concerning this actionthese actions is publicly available in court filings under the docket number 17 Civ. 3139 (S.D.N.Y.) (Schofield, J.).case numbers 1329/7/7/19 and 1336/7/7/19.
On May 27,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.
On July 29, 2019, an application, captioned MICHAEL O’HIGGINS FX CLASS REPRESENTATIVE LIMITED v. BARCLAYS BANK PLC AND OTHERS, was made to the U.K.’s Competition Appeal Tribunal requesting permission to commence collective proceedings against Citibank, Citigroup and other defendants. The application seeks compensatory damages for losses alleged to have arisen from the actions at issue in the European Commission’s foreign exchange spot trading infringement decision (European Commission Decision of May 16, 2019 in Case AT.40135-FOREX (Three Way Banana Split) C(2019) 3631 final). Additional information concerning this action is publicly available in court filings under the docket number 1329/7/7/19.
On December 20, 2019, an application, captioned PHILLIP EVANS v. BARCLAYS BANK PLC AND OTHERS, was made to the U.K.’s Competition Appeal Tribunal requesting permission to commence collective proceedings against Citibank, Citigroup and other defendants. The application seeks compensatory damages similar to those in the Michael O’Higgins FX Class Representative Limited application. Additional information concerning this action is publicly available in court filings under the docket number 1336/7/7/19.
In September 2019, two motions for certification of class actions filed against Citigroup, Citibank Citigroup and Citicorp and other defendants were consolidated, under the caption GERTLER, ET AL. v. DEUTSCHE BANK AG, in the Tel Aviv Central District Court in Israel. Plaintiffs allege that defendants manipulated the foreign exchange markets. The amendedCitibank’s motion to dismiss plaintiffs’ petition for certification was denied on April 12, 2021. A motion for certification has not yet been served on Citigroup or Citicorp.leave to appeal this decision is currently pending before the Supreme Court of Israel. Additional information concerning this action is publicly available in court filings under the docket number CA 29013-09-18.

Interbank Offered Rates-RelatedHong Kong Private Bank Litigation and Other Matters
Antitrust and Other Litigation: In 2016,2007, a putative class actionclaim was filed in the High Court of Hong Kong claiming damages of over $51 million against Citibank, Citigroup and other defendants, nowCitibank. The case, captioned FUND LIQUIDATION HOLDINGS LLC, AS ASSIGNOR AND SUCCESSOR-IN-INTEREST TO

FRONTPOINT ASIAN EVENT DRIVEN FUND L.P., ET AL.PT ASURANSI TUGU PRATAMA INDONESIA TBK v. CITIBANK N.A., ET AL.,was dismissed in 2018 by the United States District Court for the Southern District of New York. Plaintiffs allege that defendants manipulated the Singapore Interbank Offered Rate and Singapore Swap Offer Rate. Plaintiffs assert claims under the Sherman Act, the Clayton Act, the RICO Act and state law. In May 2018, plaintiffs entered into a settlement with Citibank and Citigroup, under which Citibank and Citigroup agreed to pay approximately $10 million. In July 2019, the court found that it lacked subject-matter jurisdiction over the non-settling defendants and dismissed the case. The court also found that it lacked jurisdiction to approve the settlement and denied plaintiffs’ motion for preliminary approval of the settlement. In August 2019, plaintiffs filed a notice of appeal with the United StatesHong Kong Court of Appeals forFirst Instance on grounds that the Second Circuit.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 numbers 16 Civ. 5263 (S.D.N.Y.) (Hellerstein, J.) and 19-2719 (2d Cir.).number CACV 548/2018.
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.
Interbank Offered Rates-Related Litigation
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 offor the Southern District of New York. In July 2019, Plaintiffs filed a consolidated amended complaint. Plaintiffs allege that defendants suppressed ICE LIBOR. Plaintiffs assert
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claims under the Sherman Act, the Clayton Act, and unjust enrichment, and seek compensatory damages, disgorgement, and treble damages. In August 2019, defendants movedMarch 2020, the court granted defendants’ motion to dismiss the action.action for failure to state a claim, which plaintiffs appealed to 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 19-CV-439 (S.D.N.Y.) (Daniels, J.) and 20-1492 (2d Cir.).
In August 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. Additional information concerning this action is publicly available in court filings under the docket number 19 Civ. 439 (S.D.N.Y.20-CV-5832 (N.D. Cal.) (Daniels,(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 asand various membership associations that claim to represent certain groups of merchants, allege, among other things, that defendants have engaged in conspiracies to set the price of interchange and merchant discount fees on credit and debit card transactions and to restrain trade unreasonably through various Visa and MasterCard rules governing merchant conduct, all in violation of Section 1 of the Sherman Act and certain California statutes. Plaintiffs further alleged violations of Section 2 of the Sherman Act. Supplemental complaints also were filed against defendants in the putative class actions alleging that Visa’s and MasterCard’s respective initial public offerings were anticompetitive and violated Section 7 of the Clayton Act, and that MasterCard’s initial public offering constituted a fraudulent conveyance.
In 2014, the district court entered a final judgment approving the terms of a class settlement providing for, among other things, cash payment to the class of $6.05 billion; a rebate to merchants participating in the damages class settlement of 10 bps on interchange collected for a period of eight months by the Visa and MasterCard networks; and changes to certain network rules. Various objectors appealed from the final class settlement approval order to the United States Court of Appeals for the Second Circuit.
In 2016, the Court of Appeals reversed the district court’s approval of thea class settlement and remanded for further proceedings. The district court thereafter appointed separate interim counsel for a putative class seeking damages and a putative class seeking injunctive relief. Amended or new complaints on behalf of the putative classes and various individual merchants were subsequently filed, including a further amended complaint on behalf of a putative damages class and a new complaint on behalf of a putative injunctive class, both of which named Citigroup and Related Parties. In addition, numerous merchants have filed amended or new
complaints against Visa, MasterCard, and in some instances one or more issuing banks. Three of these suits—7-ELEVEN, INC., ET AL. v. VISA INC., ET AL.; ROUNDY’S SUPERMARKETS, INC. v. VISA INC. ET AL.; and LUBY’S FUDDRUCKERS RESTAURANTS, LLC, v. VISA INC., ET AL—brought on behalf of numerous individual merchants, namebanks, including Citigroup and affiliates as defendants.affiliates.
On December 13,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, though that amount has beenlater reduced by $700 million based on the transaction volume of class members that opted-outopted out from the settlement. Several merchants and merchant groups have appealed the final approval order. On September 27, 2021, the court granted the injunctive relief class plaintiffs’ motion to certify a non-opt-out class. 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 complaintsactions allege that defendants colluded to prevent the development of exchange-like trading for IRS and assert federal and state antitrust claims and claims for unjust enrichment. Also consolidated under the same caption are individual actions filed by swap execution facilities, asserting federal and state antitrust claims, as well as claims for unjust enrichment and tortious interference with business relations. Plaintiffs in all of these actions seek treble damages, fees, costs and injunctive relief. Lead plaintiffs in the class action moved for class certification in February 2019, and subsequently filed a fourthan amended complaint. Additional information concerning these actions is publicly available in court filings under the docket numbers 18-CV-5361 (S.D.N.Y.) (Oetken, J.) and 16-MD-2704 (S.D.N.Y.) (Oetken, J.).
In 2017, Citigroup, Citibank, CGMI, CGML and numerous other parties were named as defendants in an action filed in the United States District Court for the Southern District of New York under the caption TERA GROUP, INC., ET AL. v. CITIGROUP, INC., ET AL. The complaint alleges that defendants colluded to prevent the development of exchange-like trading for credit default swaps and asserts federal and state antitrust claims and state law tort claims. In January 2020, plaintiffs filed an amended complaint.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.).


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Madoff-Related Litigation
In December 2008, a Securities Investor Protection Act (SIPA) trustee was appointed for the SIPA liquidation of Bernard L. Madoff Investment Securities LLC (BLMIS), in the United States Bankruptcy Court for the Southern District of New York. Beginning in 2010, he commenced actions against multiple Citi entities, including Citibank, Citicorp North America, Inc., CGML and Citibank (Switzerland) AG, seeking recovery of monies that originated at BLMIS and were allegedly received by the Citi entities as subsequent transferees. On August 30, 2021, the United States Court of Appeals for the Second Circuit reversed the bankruptcy court’s denial of the SIPA trustee’s motion for leave to amend his complaint and remanded the case to the bankruptcy court for further proceedings. On January 27, 2022, Citibank and Citicorp North America, Inc. filed a petition for a writ of certiorari in the United States Supreme Court seeking review of the Second Circuit’s holding that good faith is an affirmative defense. The SIPA trustee filed an amended complaint against Citibank, Citicorp North America, Inc. and CGML on February 11, 2022. The action against Citibank (Switzerland) AG was dismissed on February 23, 2022. Additional information concerning these actions is publicly available in court filings under the docket numbers 10-5345, 12-1700 (Bankr. S.D.N.Y.) (Morris, J.); 12-MC-115 (S.D.N.Y.) (Rakoff, J.); and 17-2992, 17-3076, 17-3139, 19-4282, 20-1333 (2d Cir.).
Also beginning in 2010, the British Virgin Islands liquidators of Fairfield Sentry Limited, whose assets were invested with BLMIS, commenced multiple actions in the United States Bankruptcy Court for the Southern District of New York against over 400 defendants, including CGML Citibank (Switzerland) AG; Citibank, N.A., London; Citivic Nominees Limited; and Cititrust (Bahamas) Limited. The actions seek recovery of monies that were allegedly received directly or indirectly by Citi entities from Fairfield Sentry. Appeals concerning various dismissed claims and a petition for interlocutory review on the one claim remaining are pending before the United States District Court for the Southern District of New York, and the remaining claim is proceeding in the Bankruptcy Court. Citi (Switzerland) AG and Citivic Nominees Limited filed a motion to dismiss for lack of personal jurisdiction on October 29, 2021. These actions are captioned FAIRFIELD SENTRY LTD., ET AL. v. CGML, ET AL.; FAIRFIELD SENTRY LTD., ET AL. v. CITIBANK NA LONDON, ET AL.; and FAIRFIELD SENTRY LTD., ET AL. v. ZURICH CAPITAL MARKETS COMPANY, ET AL. Additional information is publicly available in court filings under the docket numbers 10-13164, 10-3496, 10-3622, 10-3634, 11-2770 (Bankr. S.D.N.Y.) (Morris, J.); and 19-3911, 19-4267, 19-4396, 19-4484, 19-5106, 19-5135, 21-2997, 21-3243, 21-3526, 21-3529, 21-3530, 21-4307, 21-4498, 21-4496 (S.D.N.Y.) (Broderick, 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 Partiesrelated parties, alleging that the defendants facilitated a number of frauds by
Parmalat insiders. In 2008, a jury rendered a verdict in Citigroup’s favor and awarded Citi $431 million. Citigroup has taken steps to enforce the judgment in Italian court. In April 2019, the Italian Supreme Court affirmed the decision in the full amount of $431 million.awarded. Citigroup has taken steps to enforce the judgment in Italian and Belgian courts. Additional information concerning this actionthese actions is publicly available in court filings under (in Italy) the docket numbers 27618/20144133/2019 and 10540/2019.224/2022 (Court of Milan Enforcement Section) and (in Belgium) 20/3617/A (Brussels Court of First Instance) and 21/AR/1658 (Brussels Court of Appeal).
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 Milanrelated parties, which the court later dismissed Parmalat’s claim on grounds that it was duplicative of Parmalat’s previously
unsuccessful claims. In May 2019, the Milan Court of Appeal rejected Parmalat’s appeal against the decision of the Milan court. In June 2019,court’s dismissal, which Parmalat filed a further appeal withappealed to the Italian Supreme Court. Additional information concerning this action is publicly available in court filings under the docket number 20598/2019.
OnIn 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.Citibank, which Citibank is seeking to dismiss. 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.

Record-Keeping Matters
The U.S. Securities and Exchange Commission is conducting an investigation of CGMI and other firms regarding compliance with record-keeping obligations for broker-dealers and investment advisers in connection with business-related communications sent over unapproved electronic messaging channels. CGMI is cooperating with the investigation.

Revlon-Related Wire Transfer Litigation
In August 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 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. On February 16, 2021, the court issued a judgment in favor of the defendants, which Citibank later appealed in the United States Court of Appeals for the Second Circuit. In response to the district court’s denial of Citibank’s motion to extend the temporary restraining
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orders, Citibank filed a motion for an injunction with the United States Court of Appeals. Additional information concerning this action is publicly available in court filings under docket numbers 20-CV-6539 (S.D.N.Y.) (Furman, J.) and 21-487 (2d Cir.).

Shareholder Derivative and Securities Litigation
Beginning in October 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 certain of Citigroup’s current and former directors. The actions were later consolidated under the case name IN RE CITIGROUP INC. SHAREHOLDER DERIVATIVE LITIGATION. The consolidated complaint asserts 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. On February 8, 2021, the court stayed the action pending resolution of defendants’ motion to dismiss in IN RE CITIGROUP SECURITIES LITIGATION. 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 in December 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 certain of Citigroup’s current and former directors, and certain current and former officers. The actions were later consolidated under the case name IN RE CITIGROUP INC. DERIVATIVE LITIGATION, and the court stayed the action pending resolution of defendants’ motion to dismiss in IN RE CITIGROUP SECURITIES LITIGATION. Additional information concerning this action is publicly available in court filings under the docket number 656759/2020 (N.Y. Sup. Ct.) (Schecter, J.).
Beginning in October 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 Exchange Act of 1934 in connection with defendants’ alleged misstatements concerning Citigroup’s internal controls. The actions were later consolidated under the case name IN RE CITIGROUP SECURITIES LITIGATION. The consolidated complaint later added certain of Citigroup’s current and former directors as defendants. Defendants have moved to dismiss the consolidated amended complaint. Additional information concerning this action is publicly available in court filings under the docket number 1:20-CV-9132 (S.D.N.Y.) (Nathan, J.).

Sovereign Securities MattersLitigation
Regulatory Actions: Government and regulatory agencies in the U.S. and in other jurisdictions are conducting investigations or making inquiries regarding Citigroup’s sales and trading activities in connection with sovereign and other government-related securities. Citigroup is cooperating with these investigations and inquiries.
Antitrust and Other Litigation: In 2015, putative class actions filed against CGMI and other defendants were consolidated under the caption IN RE TREASURY SECURITIES AUCTION ANTITRUST LITIGATION in the United States District Court for the
Southern District of New York. In December 2017, a consolidated amended complaint was filed, allegingPlaintiffs allege that defendants colluded to fix TreasuryU.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 assertsPlaintiffs assert claims under antitrust laws, and seeksseek damages, including treble damages where authorized by statute, and injunctive relief. In February 2018,On March 31, 2021, the court granted defendants’ motion to dismiss, without prejudice. On May 14, 2021, plaintiffs filed an amended consolidated complaint. On June 14, 2021, certain defendants, including CGMI, moved to dismiss the amended complaint. Additional information concerning this action is publicly available in court filings under the docket number 15-MD-2673 (S.D.N.Y.) (Gardephe, J.).
In 2016 and 2017, class actions by direct purchasers of supranational, sub-sovereign and agency (SSA) bonds filed against Citigroup, Citibank, CGMI, CGML and other defendants were consolidated, under the caption IN RE SSA BONDS ANTITRUST LITIGATION, in the United States District Court for the Southern District of New York. In November 2018, a second amended consolidated complaint was filed, alleging that defendants, as market makers and traders of SSA bonds, colluded to fix the price at which they bought and sold SSA bonds in the secondary market. The complaint asserts claims under the antitrust laws and unjust enrichment, and seeks damages, including treble damages where authorized by statute, and disgorgement. In September 2019, the court granted defendants’ motion to dismiss certain

defendants, including CGML. Additional information concerning this action is publicly available in court filings under the docket number 16 Civ. 3711 (S.D.N.Y.) (Ramos, J.).
On February 7, 2019, a putativeproposed class action captioned STACHON v. BANK OF AMERICA N.A., ET AL., was filed against Citigroup, Citibank, CGMI, CGMLon behalf of direct and other defendants, captioned STACHON v. BANK OF AMERICA N.A., ET AL., in the United States District Court for the Southern District of New York. Plaintiffs assert claims under New York antitrust laws based on the same conduct alleged in IN RE SSA BONDS ANTITRUST LITIGATION and seek treble damages and injunctive relief. The action is currently stayed pending a decision on the remaining motion to dismiss in IN RE SSA BONDS ANTITRUST LITIGATION. Additional information concerning this action is publicly available in court filings under the docket number 19 Civ. 01205 (S.D.N.Y.) (Swain, J.).
In 2017, a class action related to the SSA bond market was filed in the Ontario Court of Justice in Canada, against Citigroup, Citibank, CGMI, CGML, Citibank Canada, Citigroup Global Markets Canada, Inc. and other defendants, asserting plaintiff claims under breach of contract, breach of the competition act, breach of foreign law, unjust enrichment and civil conspiracy. Plaintiffs seek compensatory and punitive damages and declaratory relief. Additional information concerning this action is publicly available in court filings under the docket number CV-17-586082-00CP (Ont. S.C.J.).
In 2017,indirect purchasers of SSA 296 bonds filed a similar action against Citigroup, Citibank, CGMI, CGML, Citibank Canada, Citigroup Global Markets Canada, Inc. and other defendants, captioned JOSEPH MANCINELLI, ET AL. v. BANK OF AMERICA CORPORATION, ET AL., in the Federal Court in Canada. In October 2019, plaintiffsPlaintiffs have filed an amended claim. Plaintiffs allegeclaim that alleges defendants manipulated, and colluded to manipulate, the SSA bonds market. Plaintiffs assertmarket, asserts claims underfor breach of the competition law,Competition Act, breach of foreign law, civil conspiracy, unjust enrichment, waiver of tort and breach of contract.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.).
On September 10, 2019, plaintiffs filed a third consolidated amended complaint against CGMI and other defendants, under the caption IN RE GSE BONDS ANTITRUST LITIGATION, in the United States District Court for the Southern District of New York. Plaintiffs allege that defendants conspired to manipulate the market for bonds issued by U.S. government-sponsored agencies. Plaintiffs assert a claim under the Sherman Act, and seek treble damages and injunctive relief. In December 2019, plaintiffs moved for preliminary approval of a settlement with CGMI and 11 other defendants. Additional information concerning this action is publicly available in court filings under the docket number 19 Civ. 1704 (S.D.N.Y.) (Rakoff, J.).
On September 23, 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. Plaintiff alleges that defendants conspired to
manipulate the market for bonds issued by U.S. government-sponsored agencies. Plaintiff asserts a claim against defendants for a violation of the Sherman Act, and seeks treble damages and injunctive relief. Additional information concerning this action is publicly available in court filings under the docket number 19 Civ. 638 (M.D. La.) (Dick, C.J.).
On October 21, 2019, the City of Baton Rouge and related plaintiffs filed a substantially similar action against CGMI and other defendants, captioned CITY OF BATON ROUGE, ET AL. v. BANK OF AMERICA, N.A., ET AL., in the United States District Court for the Middle District of Louisiana. Plaintiffs allege that defendants conspired to manipulate the market for U.S. government-sponsored agencies bonds. Plaintiffs assert a claim under the Sherman Act, and seek treble damages and injunctive relief. Additional information concerning this action is publicly available in court filings under the docket number 19 Civ. 725 (M.D. La.) (Dick, C.J.).
In 2018, a putative class action was filed against Citigroup, CGMI, Citigroup Financial Products Inc., Citigroup Global Markets Holdings Inc., Citibanamex, Grupo Banamex and other banks, captioned IN RE MEXICAN GOVERNMENT BONDS ANTITRUST LITIGATION, in the United States District Court for the Southern District of New York. Plaintiffs allegeThe complaint alleges that defendants colluded in the Mexican sovereign bond market. In September 2019, the court granted defendants’ motion to dismiss. Subsequently,In December 2019, plaintiffs filed an amended complaint against Citibanamex and other market makers in the Mexican sovereign bond market. Plaintiffs no longer assert any claims against Citigroup and any other 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 seekseeks treble damages, restitution and injunctive relief. In February 2020, certain defendants, including Citibanamex, moved to dismiss the amended complaint, which the court later granted. On June 10, 2021, plaintiffs moved for reconsideration of the decision dismissing certain defendants, including Citibanamex, which those defendants have jointly opposed. Additional information concerning this consolidated action is publicly available in court filings under the docket number 18 Civ. 2830 (S.D.N.Y.) (Oetken, J.).
On February 9, 2021, purchasers of Euro-denominated sovereign debt issued by European central governments added CGMI, CGML and others as defendants to a putative class
301


action, captioned IN RE EUROPEAN GOVERNMENT BONDS ANTITRUST LITIGATION, in the United States District Court for the Southern District of New York. Plaintiffs allege that defendants engaged in a conspiracy to inflate prices of European government bonds in primary market auctions and to fix the prices of European government bonds in secondary markets. Plaintiffs assert a claim under the Sherman Act and seek treble damages and attorneys’ fees. On June 4, 2021, certain defendants, including CGMI and CGML, filed a pre-motion letter with the court requesting leave to move to dismiss the action. Additional information concerning this action is publicly available in court filings under the docket number 19-CV-2601 (S.D.N.Y.) (Marrero, 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 approximatelyapproximate $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 July 2019, the litigation trustee filed an appeal to the United States Court of Appeals for the Second Circuit.
Several Citigroup affiliates, along with numerous other parties, are named as defendants in certain actions brought by Tribune noteholders, which seek to recover the transfers of Tribune stock that occurred as a part of the leveraged buyout, as state-law constructive fraudulent conveyances. The noteholders’ claims were previously dismissed and the dismissal was affirmed on appeal. In May 2018, the United States Court of Appeals for the Second Circuit withdrew its 2016 transfer of jurisdiction to the district court to reconsider its decision in light of a recent United States Supreme Court decision. In December 2019, the Court of Appeals issued an amended decision again affirming the dismissal. In January 2020, the noteholders filed a petition for rehearing.
Citigroup Global Markets Inc. (CGMI)CGMI was named as a defendant in a separate action, KIRSCHNER v. CGMI, in connection with its role as advisor to Tribune. In January 2019, the court dismissed the action, which the litigation trustee has appealed to the United States Court of Appeals for the Second Circuit.
On August 20, 2021, the United States Court of Appeals for the Second Circuit issued its decision in the consolidated appeals in KIRSCHNER v. FITZSIMONS and KIRSCHNER v. CGMI. In the FITZSIMONS action, the Second Circuit affirmed the dismissal of the actual fraudulent transfer claim against the shareholder defendants, including the Citigroup affiliates. In the CGMI action, the Second Circuit affirmed the dismissal of all claims against CGMI except for the claim of constructive fraudulent conveyance. As to that claim, the Second Circuit vacated the dismissal and remanded to the
district court for further proceedings on that claim and other claims that remain against certain other defendants that are not Citigroup affiliates. On November 29, 2021, on remand from the Second Circuit, the litigation trustee notified the United States District Court for the Southern District of New York that it was voluntarily dismissing all claims against CGMI pursuant to a settlement agreement. The district court approved the voluntary dismissal on December 10, 2021. 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.11 MD 2296 (S.D.N.Y.) (Cote, J.), 19-0449 (2d Cir.), and 19-3049 (2d Cir.) and 16-317 (U.S.).

Variable Rate Demand Obligation Litigation
On May 31,In 2019, the plaintiffs in the consolidated actions CITY OF PHILADELPHIA v. BANK OF AMERICA CORP.,CORP, ET AL. and MAYOR AND CITY COUNCIL OF BALTIMORE v. BANK OF AMERICA CORP., ET AL. filed a consolidated complaint naming as defendants Citigroup, Citibank, CGMI, CGML and numerous other industry participants. The consolidated complaint asserts violations of the Sherman Act, as well as claims for breach of contract, breach of fiduciary duty, and unjust enrichment, and seeks damages and injunctive relief based on allegations that defendants served as remarketing agents for municipal bonds called variable rate demand obligations (VRDOs) and colluded to set artificially high VRDO interest rates. In July 2019, defendants filed aNovember 2020, the court granted in part and denied in part defendants’ motion to dismiss the consolidated complaint.
On June 2, 2021, the Board of Directors of the San Diego Association of Governments, acting as the San Diego County Regional Transportation Commission, filed a parallel putative class action against the same defendants named in the already pending nationwide consolidated class action. The two actions were consolidated and on August 6, 2021, the plaintiffs in the nationwide putative class action filed a consolidated amended complaint, captioned THE CITY OF PHILADELPHIA, MAYOR AND CITY COUNCIL OF BALTIMORE, THE BOARD OF DIRECTORS OF THE SAN DIEGO ASSOCIATION OF GOVERNMENTS, ACTING AS THE SAN DIEGO COUNTY REGIONAL TRANSPORTATION COMMISSION v. BANK OF AMERICA CORP., ET AL. On September 14, 2021, defendants moved to dismiss the consolidated amended complaint in part. Additional information concerning this action is publicly available in court filings under the docket number 19-CV-1608 (S.D.N.Y.) (Furman, J.).

Wind Farm Litigations
Beginning in March 2021, six wind farms in Texas commenced actions in New York and Texas state courts for declaratory judgments and breach of contract, asserting that the February 2021 winter storm in Texas excused their performance to deliver energy to Citi Energy Inc. (CEI) under the force majeure provisions of their contracts with CEI. In addition, the wind farms sought temporary restraining orders and/or preliminary injunctions, preventing CEI from exercising remedies under the contracts.
Preliminary injunctions were denied with respect to five of the six wind farms: the New York court denied preliminary
302


injunctions with respect to the Stephens Ranch I and Stephens Ranch II wind farms; the Texas court denied preliminary injunctions with respect to the Flat Top, Shannon and Midway wind farms. Later in 2021, Stephens Ranch I, Stephens Ranch II and Flat Top each voluntarily dismissed its action with prejudice. The Mariah del Norte wind farm voluntarily dismissed its action with prejudice on February 18, 2022. A motion to dismiss the remaining Shannon and Midway actions remains pending. Additional information concerning these actions is publicly available in court filings under the docket numbers 19-CV-1608 (S.D.N.Y.652078/2021 (Sup. Ct. N.Y. Cnty.) (Furman,(Reed, J.), 2021-01387 (1st Dep’t), 652312/2021 (Sup. Ct. N.Y. Cnty.) (Reed, J.), 2021-23588 (District Court Harris County TX) (Schaffer, J.), and 19-CV-2667 (S.D.N.Y.) (Furman,2021-26150 (District Court Harris County TX) (Engelhart, 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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28.  CONDENSED CONSOLIDATING FINANCIAL STATEMENTS

Citigroup amended itsCitigroup’s Registration Statement on Form S-3 on file with the SEC (File No. 33-192302) to addincludes its wholly owned subsidiary, Citigroup Global Markets Holdings Inc. (CGMHI), as a co-registrant. Any securities issued by CGMHI under the Form S-3 will be fully and unconditionally guaranteed by Citigroup.
The following are the Condensed Consolidating Statements of Income and Comprehensive Income for the years ended December 31, 2019, 20182021, 2020 and 2017,2019, Condensed Consolidating Balance Sheet as of December 31, 20192021 and 20182020 and Condensed Consolidating Statement of Cash Flows for the years ended December 31, 2019, 20182021, 2020 and 20172019 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.




































Condensed Consolidating Statements of Income and Comprehensive Income
 Year ended December 31, 2019
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Revenues     
Dividends from subsidiaries$23,347
$
$
$(23,347)$
Interest revenue
10,661
65,849

76,510
Interest revenue—intercompany5,091
1,942
(7,033)

Interest expense4,949
7,010
17,204

29,163
Interest expense—intercompany1,038
4,243
(5,281)

Net interest revenue$(896)$1,350
$46,893
$
$47,347
Commissions and fees$
$5,265
$6,481
$
$11,746
Commissions and fees—intercompany(21)354
(333)

Principal transactions(2,537)277
11,152

8,892
Principal transactions—intercompany1,252
2,464
(3,716)

Other income767
832
4,702

6,301
Other income—intercompany(55)102
(47)

Total non-interest revenues$(594)$9,294
$18,239
$
$26,939
Total revenues, net of interest expense$21,857
$10,644
$65,132
$(23,347)$74,286
Provisions for credit losses and for benefits and claims$
$
$8,383
$
$8,383
Operating expenses  
  
Compensation and benefits$32
$4,680
$16,721
$
$21,433
Compensation and benefits—intercompany134

(134)

Other operating(16)2,326
18,259

20,569
Other operating—intercompany20
2,410
(2,430)

Total operating expenses$170
$9,416
$32,416
$
$42,002
Equity in undistributed income of subsidiaries$(3,620)$
$
$3,620
$
Income (loss) from continuing operations before income taxes$18,067
$1,228
$24,333
$(19,727)$23,901
Provision (benefit) for income taxes(1,334)176
5,588

4,430
Income (loss) from continuing operations$19,401
$1,052
$18,745
$(19,727)$19,471
Income (loss) from discontinued operations, net of taxes

(4)
(4)
Net income before attribution of noncontrolling interests$19,401
$1,052
$18,741
$(19,727)$19,467
Noncontrolling interests

66

66
Net income (loss)$19,401
$1,052
$18,675
$(19,727)$19,401
Comprehensive income  

  
Add: Other comprehensive income (loss)$852
$(651)$1,600
$(949)$852
Total Citigroup comprehensive income (loss)$20,253
$401
$20,275
$(20,676)$20,253
Add: Other comprehensive income attributable to noncontrolling interests$
$
$
$
$
Add: Net income attributable to noncontrolling interests

66

66
Total comprehensive income (loss)$20,253
$401
$20,341
$(20,676)$20,319


305


Condensed Consolidating Statements of Income and Comprehensive Income
 Year ended December 31, 2018
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Revenues     
Dividends from subsidiaries$22,854
$
$
$(22,854)$
Interest revenue67
8,732
62,029

70,828
Interest revenue—intercompany4,933
1,659
(6,592)

Interest expense4,783
5,430
14,053

24,266
Interest expense—intercompany1,198
3,539
(4,737)

Net interest revenue$(981)$1,422
$46,121
$
$46,562
Commissions and fees$
$5,146
$6,711
$
$11,857
Commissions and fees—intercompany(2)237
(235)

Principal transactions(1,310)1,599
8,616

8,905
Principal transactions—intercompany(929)1,328
(399)

Other income1,373
710
3,447

5,530
Other income—intercompany(107)143
(36)

Total non-interest revenues$(975)$9,163
$18,104
$
$26,292
Total revenues, net of interest expense$20,898
$10,585
$64,225
$(22,854)$72,854
Provisions for credit losses and for benefits and claims$
$(22)$7,590
$
$7,568
Operating expenses     
Compensation and benefits$4
$4,484
$16,666
$
$21,154
Compensation and benefits—intercompany115

(115)

Other operating(192)2,224
18,655

20,687
Other operating—intercompany49
2,312
(2,361)

Total operating expenses$(24)$9,020
$32,845
$
$41,841
Equity in undistributed income of subsidiaries$(2,163)$
$
$2,163
$
Income (loss) from continuing operations before income taxes$18,759
$1,587
$23,790
$(20,691)$23,445
Provision (benefit) for income taxes714
1,123
3,520

5,357
Income (loss) from continuing operations$18,045
$464
$20,270
$(20,691)$18,088
Income (loss) from discontinued operations, net of taxes

(8)
(8)
Net income (loss) before attribution of noncontrolling interests$18,045
$464
$20,262
$(20,691)$18,080
Noncontrolling interests

35

35
Net income (loss)$18,045
$464
$20,227
$(20,691)$18,045
Comprehensive income  $
  
Add: Other comprehensive income (loss)$(2,499)$257
$3,500
$(3,757)$(2,499)
Total Citigroup comprehensive income (loss)$15,546
$721
$23,727
$(24,448)$15,546
Add: Other comprehensive income attributable to noncontrolling interests
$
$
$(43)$
$(43)
Add: Net income attributable to noncontrolling interests

35

35
Total comprehensive income (loss)$15,546
$721
$23,719
$(24,448)$15,538



Year ended December 31, 2021
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Revenues
Dividends from subsidiaries$6,482 $ $ $(6,482)$ 
Interest revenue 3,566 46,909  50,475 
Interest revenue—intercompany3,757 531 (4,288)  
Interest expense4,791 778 2,412  7,981 
Interest expense—intercompany294 1,320 (1,614)  
Net interest income$(1,328)$1,999 $41,823 $ $42,494 
Commissions and fees$ $7,770 $5,902 $ $13,672 
Commissions and fees—intercompany(36)407 (371)  
Principal transactions976 10,140 (962) 10,154 
Principal transactions—intercompany(1,375)(6,721)8,096   
Other revenue(64)576 5,052  5,564 
Other revenue—intercompany(133)(60)193   
Total non-interest revenues$(632)$12,112 $17,910 $ $29,390 
Total revenues, net of interest expense$4,522 $14,111 $59,733 $(6,482)$71,884 
Provisions for credit losses and for benefits and claims$ $6 $(3,784)$ $(3,778)
Operating expenses
Compensation and benefits$10 $5,251 $19,873 $ $25,134 
Compensation and benefits—intercompany69  (69)  
Other operating83 2,868 20,108  23,059 
Other operating—intercompany11 2,826 (2,837)  
Total operating expenses$173 $10,945 $37,075 $ $48,193 
Equity in undistributed income of subsidiaries$16,596 $ $ $(16,596)$ 
Income from continuing operations before income taxes$20,945 $3,160 $26,442 $(23,078)$27,469 
Provision (benefit) for income taxes(1,007)625 5,833  5,451 
Income from continuing operations$21,952 $2,535 $20,609 $(23,078)$22,018 
Income (loss) from discontinued operations, net of taxes  7  7 
Net income before attribution of noncontrolling interests$21,952 $2,535 $20,616 $(23,078)$22,025 
Noncontrolling interests  73  73 
Net income$21,952 $2,535 $20,543 $(23,078)$21,952 
Comprehensive income
Add: Other comprehensive income (loss)$(6,707)$(76)$(450)$526 $(6,707)
Total Citigroup comprehensive income$15,245 $2,459 $20,093 $(22,552)$15,245 
Add: Other comprehensive income attributable to noncontrolling interests$ $ $(99)$ $(99)
Add: Net income attributable to noncontrolling interests  73  73 
Total comprehensive income$15,245 $2,459 $20,067 $(22,552)$15,219 
306


Condensed Consolidating Statements of Income and Comprehensive Income
 Year ended December 31, 2017
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Revenues     
Dividends from subsidiaries$22,499
$
$
$(22,499)$
Interest revenue1
5,279
56,299

61,579
Interest revenue—intercompany3,972
1,178
(5,150)

Interest expense4,766
2,340
9,412

16,518
Interest expense—intercompany829
2,297
(3,126)

Net interest revenue$(1,622)$1,820
$44,863
$
$45,061
Commissions and fees$
$5,366
$7,341
$
$12,707
Commissions and fees—intercompany(2)182
(180)

Principal transactions1,654
1,183
6,103

8,940
Principal transactions—intercompany934
1,200
(2,134)

Other income(2,581)867
7,450

5,736
Other income—intercompany5
170
(175)

Total non-interest revenues$10
$8,968
$18,405
$
$27,383
Total revenues, net of interest expense$20,887
$10,788
$63,268
$(22,499)$72,444
Provisions for credit losses and for benefits and claims$
$
$7,451
$
$7,451
Operating expenses     
Compensation and benefits$(107)$4,403
$16,885
$
$21,181
Compensation and benefits—intercompany120

(120)

Other operating(318)2,184
19,185

21,051
Other operating—intercompany(35)2,231
(2,196)

Total operating expenses$(340)$8,818
$33,754
$
$42,232
Equity in undistributed income of subsidiaries$(19,088)$
$
$19,088
$
Income (loss) from continuing operations before income taxes$2,139
$1,970
$22,063
$(3,411)$22,761
Provision (benefit) for income taxes8,937
873
19,578

29,388
Income (loss) from continuing operations$(6,798)$1,097
$2,485
$(3,411)$(6,627)
Income (loss) from discontinued operations, net of taxes

(111)
(111)
Net income before attribution of noncontrolling interests$(6,798)$1,097
$2,374
$(3,411)$(6,738)
Noncontrolling interests
(1)61

60
Net income (loss)$(6,798)$1,098
$2,313
$(3,411)$(6,798)
Comprehensive income  $
  
Add: Other comprehensive income (loss)$(2,791)$(117)$(4,160)$4,277
$(2,791)
Total Citigroup comprehensive income (loss)$(9,589)$981
$(1,847)$866
$(9,589)
Add: Other comprehensive income attributable to noncontrolling interests
$
$
$114
$
$114
Add: Net income attributable to noncontrolling interests
(1)61

60
Total comprehensive income (loss)$(9,589)$980
$(1,672)$866
$(9,415)



Year ended December 31, 2020
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Revenues
Dividends from subsidiaries$2,355 $— $— $(2,355)$— 
Interest revenue— 5,364 52,725 — 58,089 
Interest revenue—intercompany4,162 920 (5,082)— — 
Interest expense4,992 1,989 6,357 — 13,338 
Interest expense—intercompany502 2,170 (2,672)— — 
Net interest income$(1,332)$2,125 $43,958 $— $44,751 
Commissions and fees$— $6,216 $5,169 $— $11,385 
Commissions and fees—intercompany(36)290 (254)— — 
Principal transactions(1,254)(4,252)19,391 — 13,885 
Principal transactions—intercompany693 9,064 (9,757)— — 
Other revenue(127)706 4,901 — 5,480 
Other revenue—intercompany111 23 (134)— — 
Total non-interest revenues$(613)$12,047 $19,316 $— $30,750 
Total revenues, net of interest expense$410 $14,172 $63,274 $(2,355)$75,501 
Provisions for credit losses and for benefits and claims$— $(1)$17,496 $— $17,495 
Operating expenses
Compensation and benefits$(5)$4,941 $17,278 $— $22,214 
Compensation and benefits—intercompany191 — (191)— — 
Other operating37 2,393 19,730 — 22,160 
Other operating—intercompany15 2,317 (2,332)— — 
Total operating expenses$238 $9,651 $34,485 $— $44,374 
Equity in undistributed income of subsidiaries$9,894 $— $— $(9,894)$— 
Income from continuing operations before income taxes$10,066 $4,522 $11,293 $(12,249)$13,632 
Provision (benefit) for income taxes(981)1,249 2,257 — 2,525 
Income from continuing operations$11,047 $3,273 $9,036 $(12,249)$11,107 
Income (loss) from discontinued operations, net of taxes— — (20)— (20)
Net income (loss) before attribution of noncontrolling interests$11,047 $3,273 $9,016 $(12,249)$11,087 
Noncontrolling interests— — 40 — 40 
Net income$11,047 $3,273 $8,976 $(12,249)$11,047 
Comprehensive income
Add: Other comprehensive income (loss)$4,260 $(223)$4,244 $(4,021)$4,260 
Total Citigroup comprehensive income$15,307 $3,050 $13,220 $(16,270)$15,307 
Add: Other comprehensive income attributable to noncontrolling interests$— $— $26 $— $26 
Add: Net income attributable to noncontrolling interests— — 40 — 40 
Total comprehensive income$15,307 $3,050 $13,286 $(16,270)$15,373 


307


Condensed Consolidating Statements of Income and Comprehensive Income


Year ended December 31, 2019
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Revenues
Dividends from subsidiaries$23,347 $— $— $(23,347)$— 
Interest revenue— 10,661 65,849 — 76,510 
Interest revenue—intercompany5,091 1,942 (7,033)— — 
Interest expense4,949 7,010 16,423 — 28,382 
Interest expense—intercompany1,038 4,243 (5,281)— — 
Net interest income$(896)$1,350 $47,674 $— $48,128 
Commissions and fees$— $5,265 $6,481 $— $11,746 
Commissions and fees—intercompany(21)354 (333)— — 
Principal transactions(2,537)277 11,152 — 8,892 
Principal transactions—intercompany1,252 2,464 (3,716)— — 
Other revenue767 832 4,702 — 6,301 
Other revenue—intercompany(55)102 (47)— — 
Total non-interest revenues$(594)$9,294 $18,239 $— $26,939 
Total revenues, net of interest expense$21,857 $10,644 $65,913 $(23,347)$75,067 
Provisions for credit losses and for benefits and claims$— $— $8,383 $— $8,383 
Operating expenses
Compensation and benefits$32 $4,680 $16,721 $— $21,433 
Compensation and benefits—intercompany134 — (134)— — 
Other operating(16)2,326 19,040 — 21,350 
Other operating—intercompany20 2,410 (2,430)— — 
Total operating expenses$170 $9,416 $33,197 $— $42,783 
Equity in undistributed income of subsidiaries$(3,620)$— $— $3,620 $— 
Income from continuing operations before income taxes$18,067 $1,228 $24,333 $(19,727)$23,901 
Provision (benefit) for income taxes(1,334)176 5,588 — 4,430 
Income from continuing operations$19,401 $1,052 $18,745 $(19,727)$19,471 
Income (loss) from discontinued operations, net of taxes— — (4)— (4)
Net income before attribution of noncontrolling interests$19,401 $1,052 $18,741 $(19,727)$19,467 
Noncontrolling interests— — 66 — 66 
Net income$19,401 $1,052 $18,675 $(19,727)$19,401 
Comprehensive income
Add: Other comprehensive income (loss)$852 $(651)$1,600 $(949)$852 
Total Citigroup comprehensive income$20,253 $401 $20,275 $(20,676)$20,253 
Add: Other comprehensive income attributable to noncontrolling interests$— $— $— $— $— 
Add: Net income attributable to noncontrolling interests— — 66 — 66 
Total comprehensive income$20,253 $401 $20,341 $(20,676)$20,319 


308


Condensed Consolidating Balance Sheet

December 31, 2021
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Assets
Cash and due from banks$ $834 $26,681 $ $27,515 
Cash and due from banks—intercompany17 6,890 (6,907)  
Deposits with banks, net of allowance 7,936 226,582  234,518 
Deposits with banks—intercompany3,500 11,005 (14,505)  
Securities borrowed and purchased under resale agreements 269,608 57,680  327,288 
Securities borrowed and purchased under resale agreements—intercompany 23,362 (23,362)  
Trading account assets248 189,841 141,856  331,945 
Trading account assets—intercompany1,215 1,438 (2,653)  
Investments, net of allowance1 224 512,597  512,822 
Loans, net of unearned income 2,293 665,474  667,767 
Loans, net of unearned income—intercompany     
Allowance for credit losses on loans (ACLL)  (16,455) (16,455)
Total loans, net$ $2,293 $649,019 $ $651,312 
Advances to subsidiaries$142,144 $ $(142,144)$ $ 
Investments in subsidiaries223,303   (223,303) 
Other assets, net of allowance(1)
10,589 69,312 126,112  206,013 
Other assets—intercompany2,737 60,567 (63,304)  
Total assets$383,754 $643,310 $1,487,652 $(223,303)$2,291,413 
Liabilities and equity
Deposits$ $ $1,317,230 $ $1,317,230 
Deposits—intercompany     
Securities loaned and sold under repurchase agreements 171,818 19,467  191,285 
Securities loaned and sold under repurchase agreements—intercompany 62,197 (62,197)  
Trading account liabilities17 122,383 39,129  161,529 
Trading account liabilities—intercompany777 500 (1,277)  
Short-term borrowings 13,425 14,548  27,973 
Short-term borrowings—intercompany 17,230 (17,230)  
Long-term debt164,945 61,416 28,013  254,374 
Long-term debt—intercompany 76,335 (76,335)  
Advances from subsidiaries13,469  (13,469)  
Other liabilities, including allowance2,574 68,206 65,570  136,350 
Other liabilities—intercompany 11,774 (11,774)  
Stockholders’ equity201,972 38,026 185,977 (223,303)202,672 
Total liabilities and equity$383,754 $643,310 $1,487,652 $(223,303)$2,291,413 

(1)Other assets for Citigroup parent company at December 31, 2021 included $30.5 billion of placements to Citibank and its branches, of which $19.5 billion had a remaining term of less than 30 days.



309

 December 31, 2019
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Assets     
Cash and due from banks$
$586
$23,381
$
$23,967
Cash and due from banks—intercompany21
5,095
(5,116)

Deposits with banks
4,050
165,902

169,952
Deposits with banks—intercompany3,000
6,710
(9,710)

Securities borrowed and purchased under resale agreements
195,537
55,785

251,322
Securities borrowed and purchased under resale agreements—intercompany
21,446
(21,446)

Trading account assets286
152,115
123,739

276,140
Trading account assets—intercompany426
5,858
(6,284)

Investments1
541
368,021

368,563
Loans, net of unearned income
2,497
696,986

699,483
Loans, net of unearned income—intercompany




Allowance for loan losses

(12,783)
(12,783)
Total loans, net$
$2,497
$684,203
$
$686,700
Advances to subsidiaries$144,587
$
$(144,587)$
$
Investments in subsidiaries202,116


(202,116)
Other assets(1)
12,377
54,784
107,353

174,514
Other assets—intercompany2,799
45,588
(48,387)

Total assets$365,613
$494,807
$1,292,854
$(202,116)$1,951,158
Liabilities and equity     
Deposits$
$
$1,070,590
$
$1,070,590
Deposits—intercompany




Securities loaned and sold under repurchase agreements
145,473
20,866

166,339
Securities loaned and sold under repurchase agreements—intercompany
36,581
(36,581)

Trading account liabilities1
80,100
39,793

119,894
Trading account liabilities—intercompany379
5,109
(5,488)

Short-term borrowings66
11,096
33,887

45,049
Short-term borrowings—intercompany
17,129
(17,129)

Long-term debt150,477
39,578
58,705

248,760
Long-term debt—intercompany
66,791
(66,791)

Advances from subsidiaries20,503

(20,503)

Other liabilities937
51,777
53,866

106,580
Other liabilities—intercompany8
8,414
(8,422)

Stockholders’ equity193,242
32,759
170,061
(202,116)193,946
Total liabilities and equity$365,613
$494,807
$1,292,854
$(202,116)$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.




Condensed Consolidating Balance Sheet

December 31, 2020
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Assets
Cash and due from banks$— $628 $25,721 $— $26,349 
Cash and due from banks—intercompany16 6,081 (6,097)— — 
Deposits with banks, net of allowance— 5,224 278,042 — 283,266 
Deposits with banks—intercompany4,500 8,179 (12,679)— — 
Securities borrowed and purchased under resale agreements— 238,718 55,994 — 294,712 
Securities borrowed and purchased under resale agreements—intercompany— 24,309 (24,309)— — 
Trading account assets307 222,278 152,494 — 375,079 
Trading account assets—intercompany(1)
723 2,340 (3,063)— — 
Investments, net of allowance374 446,984 — 447,359 
Loans, net of unearned income— 2,524 673,359 — 675,883 
Loans, net of unearned income—intercompany— — — — — 
Allowance for credit losses on loans (ACLL)— — (24,956)— (24,956)
Total loans, net$— $2,524 $648,403 $— $650,927 
Advances to subsidiaries$152,383 $— $(152,383)$— $— 
Investments in subsidiaries213,267 — — (213,267)— 
Other assets, net of allowance(2)
12,156 60,273 109,969 — 182,398 
Other assets—intercompany2,781 51,489 (54,270)— — 
Total assets$386,134 $622,417 $1,464,806 $(213,267)$2,260,090 
Liabilities and equity
Deposits$— $— $1,280,671 $— $1,280,671 
Deposits—intercompany— — — — — 
Securities loaned and sold under repurchase agreements— 184,786 14,739 — 199,525 
Securities loaned and sold under repurchase agreements—intercompany— 76,590 (76,590)— — 
Trading account liabilities— 113,100 54,927 — 168,027 
Trading account liabilities—intercompany(1)
397 1,531 (1,928)— — 
Short-term borrowings— 12,323 17,191 — 29,514 
Short-term borrowings—intercompany— 12,757 (12,757)— — 
Long-term debt170,563 47,732 53,391 — 271,686 
Long-term debt—intercompany— 67,322 (67,322)— — 
Advances from subsidiaries12,975 — (12,975)— — 
Other liabilities, including allowance2,692 55,217 52,558 — 110,467 
Other liabilities—intercompany65 15,378 (15,443)— — 
Stockholders’ equity199,442 35,681 178,344 (213,267)200,200 
Total liabilities and equity$386,134 $622,417 $1,464,806 $(213,267)$2,260,090 

(1)The balances of Trading account assets—intercompany and Trading account liabilities—intercompany within CGMHI and within Other Citigroup subsidiaries and eliminations have been revised to reflect the netting of $7 billion of intercompany derivative and related collateral assets and liabilities subject to enforceable netting agreements. Because the adjustment was limited to transactions between affiliated entities, it had no impact to Citigroup consolidated.
(2)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.


310

 December 31, 2018
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Assets     
Cash and due from banks$1
$689
$22,955
$
$23,645
Cash and due from banks—intercompany19
3,545
(3,564)

Deposits with banks
4,915
159,545

164,460
Deposits with banks—intercompany3,000
6,528
(9,528)

Securities borrowed and purchased under resale agreements
212,720
57,964

270,684
Securities borrowed and purchased under resale agreements—intercompany
20,074
(20,074)

Trading account assets302
146,233
109,582

256,117
Trading account assets—intercompany627
1,728
(2,355)

Investments7
224
358,376

358,607
Loans, net of unearned income
1,292
682,904

684,196
Loans, net of unearned income—intercompany




Allowance for loan losses

(12,315)
(12,315)
Total loans, net$
$1,292
$670,589
$
$671,881
Advances to subsidiaries$143,119
$
$(143,119)$
$
Investments in subsidiaries205,337


(205,337)
Other assets(1)
9,861
59,734
102,394

171,989
Other assets—intercompany3,037
44,255
(47,292)

Total assets$365,310
$501,937
$1,255,473
$(205,337)$1,917,383
Liabilities and equity     
Deposits$
$
$1,013,170
$
$1,013,170
Deposits—intercompany




Securities loaned and sold under repurchase agreements
155,830
21,938

177,768
Securities loaned and sold under repurchase agreements—intercompany
21,109
(21,109)

Trading account liabilities1
95,571
48,733

144,305
Trading account liabilities—intercompany410
1,398
(1,808)

Short-term borrowings207
3,656
28,483

32,346
Short-term borrowings—intercompany
11,343
(11,343)

Long-term debt143,767
25,986
62,246

231,999
Long-term debt—intercompany
73,884
(73,884)

Advances from subsidiaries21,471

(21,471)

Other liabilities3,011
66,732
50,978

120,721
Other liabilities—intercompany223
13,763
(13,986)

Stockholders’ equity196,220
32,665
173,526
(205,337)197,074
Total liabilities and equity$365,310
$501,937
$1,255,473
$(205,337)$1,917,383

(1)
Other assets for Citigroup parent company at December 31, 2018 included $34.7 billion of placements to Citibank and its branches, of which $22.4 billion had a remaining term of less than 30 days.



Condensed Consolidating Statement of Cash Flows
Year ended December 31, 2021
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Net cash provided by operating activities of continuing operations$3,947 $43,227 $14,075 $ $61,249 
Cash flows from investing activities of continuing operations
Purchases of investments$ $ $(359,158)$ $(359,158)
Proceeds from sales of investments  126,728  126,728 
Proceeds from maturities of investments  142,100  142,100 
Change in loans  (1,173) (1,173)
Proceeds from sales and securitizations of loans  2,918  2,918 
Change in securities borrowed and purchased under agreements to resell (29,944)(2,632) (32,576)
Changes in investments and advances—intercompany8,260 (9,040)780   
Other investing activities (2)(3,742) (3,744)
Net cash provided by (used in) investing activities of continuing operations$8,260 $(38,986)$(94,179)$ $(124,905)
Cash flows from financing activities of continuing operations
Dividends paid$(5,198)$(196)$196 $ $(5,198)
Issuance of preferred stock3,300    3,300 
Redemption of preferred stock(3,785)   (3,785)
Treasury stock acquired(7,601)   (7,601)
Proceeds (repayments) from issuance of long-term debt, net(86)15,071 (19,277) (4,292)
Proceeds (repayments) from issuance of long-term debt—intercompany, net 14,410 (14,410)  
Change in deposits  44,966  44,966 
Change in securities loaned and sold under agreements to repurchase (27,241)19,001  (8,240)
Change in short-term borrowings 1,102 (2,643) (1,541)
Net change in short-term borrowings and other advances—intercompany501 (917)416   
Capital contributions from (to) parent 71 (71)  
Other financing activities(337)12 (12) (337)
Net cash provided by (used in ) financing activities of continuing operations$(13,206)$2,312 $28,166 $ $17,272 
Effect of exchange rate changes on cash and due from banks$ $ $(1,198)$ $(1,198)
Change in cash and due from banks and deposits with banks$(999)$6,553 $(53,136)$ $(47,582)
Cash and due from banks and deposits with banks at
beginning of year
4,516 20,112 284,987  309,615 
Cash and due from banks and deposits with banks at end of year$3,517 $26,665 $231,851 $ $262,033 
Cash and due from banks (including segregated cash and other deposits)$17 $7,724 $19,774 $ $27,515 
Deposits with banks, net of allowance3,500 18,941 212,077  234,518 
Cash and due from banks and deposits with banks at end of year$3,517 $26,665 $231,851 $ $262,033 
Supplemental disclosure of cash flow information for continuing operations
Cash paid (received) during the year for income taxes$(2,406)$919 $5,515 $ $4,028 
Cash paid during the year for interest3,101 2,210 1,832  7,143 
Non-cash investing activities
Decrease in net loans associated with significant disposals reclassified to HFS$ $ $9,945 $ $9,945 
Transfers to loans HFS (Other assets) from loans
  7,414  7,414 
Non-cash financing activities
Decrease in long-term debt associated with significant disposals reclassified to HFS$ $ $479 $ $479 
Decrease in deposits associated with significant disposals reclassified to HFS  8,407  8,407 
 Year ended December 31, 2019
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Net cash provided by (used in) operating activities of continuing operations$25,011
$(35,396)$(2,452)$
$(12,837)
Cash flows from investing activities of continuing operations     
Purchases of investments$
$
$(274,491)$
$(274,491)
Proceeds from sales of investments5

137,168

137,173
Proceeds from maturities of investments

119,051

119,051
Change in loans

(22,466)
(22,466)
Proceeds from sales and securitizations of loans

2,878

2,878
Change in securities borrowed and purchased under agreements to resell
15,811
3,551

19,362
Changes in investments and advances—intercompany(1,847)(870)2,717


Other investing activities
(64)(4,817)
(4,881)
Net cash provided by (used in) investing activities of continuing operations$(1,842)$14,877
$(36,409)$
$(23,374)
Cash flows from financing activities of continuing operations     
Dividends paid$(5,447)$
$
$
$(5,447)
Issuance of preferred stock1,496



1,496
Redemption of preferred stock(1,980)


(1,980)
Treasury stock acquired(17,571)


(17,571)
Proceeds (repayments) from issuance of long-term debt, net1,666
10,389
(3,950)
8,105
Proceeds (repayments) from issuance of long-term debt—intercompany, net
(7,177)7,177


Change in deposits

57,420

57,420
Change in securities loaned and sold under agreements to repurchase
5,115
(16,544)
(11,429)
Change in short-term borrowings
7,440
5,263

12,703
Net change in short-term borrowings and other advances—intercompany(968)5,843
(4,875)

Capital contributions from (to) parent
(74)74


Other financing activities(364)(253)253

(364)
Net cash provided by (used in) financing activities of continuing operations$(23,168)$21,283
$44,818
$
$42,933
Effect of exchange rate changes on cash and due from banks$
$
$(908)$
$(908)
Change in cash and due from banks and deposits with banks$1
$764
$5,049
$
$5,814
Cash and due from banks and deposits with banks at
beginning of period
3,020
15,677
169,408

188,105
Cash and due from banks and deposits with banks at end of period$3,021
$16,441
$174,457
$
$193,919
Cash and due from banks$21
$5,681
$18,265
$
$23,967
Deposits with banks3,000
10,760
156,192

169,952
Cash and due from banks and deposits with banks at end of period$3,021
$16,441
$174,457
$
$193,919
Supplemental disclosure of cash flow information for continuing operations     
Cash paid during the year for income taxes$(393)$418
$4,863
$
$4,888
Cash paid during the year for interest3,820
12,664
12,198

28,682
Non-cash investing activities     
Transfers to loans HFS from loans$
$
$5,500
$
$5,500
311



Condensed Consolidating Statement of Cash Flows
 Year ended December 31, 2018
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Net cash provided by (used in) operating activities of continuing operations$21,314
$13,287
$2,351
$
$36,952
Cash flows from investing activities of continuing operations  

  
Purchases of investments$(7,955)$(18)$(144,514)$
$(152,487)
Proceeds from sales of investments7,634
3
53,854

61,491
Proceeds from maturities of investments

83,604

83,604
Change in loans

(29,002)
(29,002)
Proceeds from sales and securitizations of loans

4,549

4,549
Proceeds from significant disposals

314

314
Change in securities borrowed and purchased under agreements to resell
(34,018)(4,188)
(38,206)
Changes in investments and advances—intercompany(5,566)(832)6,398


Other investing activities556
(59)(3,878)
(3,381)
Net cash provided by (used in) investing activities of continuing operations$(5,331)$(34,924)$(32,863)$
$(73,118)
Cash flows from financing activities of continuing operations     
Dividends paid$(5,020)$
$
$
$(5,020)
Redemption of preferred stock(793)


(793)
Treasury stock acquired(14,433)


(14,433)
Proceeds from issuance of long-term debt, net(5,099)10,278
(2,656)
2,523
Proceeds (repayments) from issuance of long-term debt—intercompany, net
10,708
(10,708)

Change in deposits

53,348

53,348
Change in securities loaned and sold under agreements to repurchase
23,454
(1,963)
21,491
Change in short-term borrowings32
88
(12,226)
(12,106)
Net change in short-term borrowings and other advances—intercompany1,819
(19,111)17,292


Capital contributions from parent
(798)798


Other financing activities(482)


(482)
Net cash provided by (used in) financing activities of continuing operations$(23,976)$24,619
$43,885
$
$44,528
Effect of exchange rate changes on cash and due from banks$
$
$(773)$
$(773)
Change in cash and due from banks and deposits with banks$(7,993)$2,982
$12,600
$
$7,589
Cash and due from banks and deposits with banks at
beginning of period
11,013
12,695
156,808

180,516
Cash and due from banks and deposits with banks at end of period$3,020
$15,677
$169,408
$
$188,105
Cash and due from banks$20
$4,234
$19,391
$
$23,645
Deposits with banks3,000
11,443
150,017

164,460
Cash and due from banks and deposits with banks at end of period$3,020
$15,677
$169,408
$
$188,105
Supplemental disclosure of cash flow information for continuing operations     
Cash paid (received) during the year for income taxes$(783)$458
$4,638
$
$4,313
Cash paid during the year for interest3,854
8,671
10,438

22,963
Non-cash investing activities     
Transfers to loans HFS from loans$
$
$4,200
$
$4,200


Year ended December 31, 2020
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Net cash provided by (used in) operating activities of continuing operations$5,002 $(26,195)$572 $— $(20,621)
Cash flows from investing activities of continuing operations
Purchases of investments$— $— $(334,900)$— $(334,900)
Proceeds from sales of investments— — 146,285 — 146,285 
Proceeds from maturities of investments— — 124,229 — 124,229 
Change in loans— — 14,249 — 14,249 
Proceeds from sales and securitizations of loans— — 1,495 — 1,495 
Change in securities borrowed and purchased under agreements to resell— (46,044)2,654 — (43,390)
Changes in investments and advances—intercompany(5,584)(6,917)12,501 — — 
Other investing activities— (54)(3,226)— (3,280)
Net cash used in investing activities of continuing operations$(5,584)$(53,015)$(36,713)$— $(95,312)
Cash flows from financing activities of continuing operations
Dividends paid$(5,352)$(172)$172 $— $(5,352)
Issuance of preferred stock2,995 — — — 2,995 
Redemption of preferred stock(1,500)— — — (1,500)
Treasury stock acquired(2,925)— — — (2,925)
Proceeds from issuance of long-term debt, net16,798 6,349 (10,091)— 13,056 
Proceeds (repayments) from issuance of long-term debt—intercompany, net— 3,960 (3,960)— — 
Change in deposits— — 210,081 — 210,081 
Change in securities loaned and sold under agreements to repurchase— 79,322 (46,136)— 33,186 
Change in short-term borrowings— 1,228 (16,763)— (15,535)
Net change in short-term borrowings and other advances—intercompany(7,528)(7,806)15,334 — — 
Other financing activities(411)— — — (411)
Net cash provided by financing activities of continuing operations$2,077 $82,881 $148,637 $— $233,595 
Effect of exchange rate changes on cash and due from banks$— $— $(1,966)$— $(1,966)
Change in cash and due from banks and deposits with banks$1,495 $3,671 $110,530 $— $115,696 
Cash and due from banks and deposits with banks at
beginning of year
3,021 16,441 174,457 — 193,919 
Cash and due from banks and deposits with banks at end of year$4,516 $20,112 $284,987 $— $309,615 
Cash and due from banks (including segregated cash and other deposits)$16 $6,709 $19,624 $— $26,349 
Deposits with banks, net of allowance4,500 13,403 265,363 — 283,266 
Cash and due from banks and deposits with banks at end of year$4,516 $20,112 $284,987 $— $309,615 
Supplemental disclosure of cash flow information for continuing operations 
Cash paid (received) during the year for income taxes$(1,883)$1,138 $5,542 $— $4,797 
Cash paid during the year for interest2,681 4,516 4,897 — 12,094 
Non-cash investing activities
Transfers to loans HFS (Other assets) from loans
$— $— $2,614 $— $2,614 
312


Condensed Consolidating Statements of Cash Flows
 Year ended December 31, 2017
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Net cash provided by (used in) operating activities of continuing operations$25,270
$(33,365)$(679)$
$(8,774)
Cash flows from investing activities of continuing operations     
Purchases of investments$
$(14)$(185,726)$
$(185,740)
Proceeds from sales of investments132
18
107,218

107,368
Proceeds from maturities of investments

84,369

84,369
Change in loans

(58,062)
(58,062)
Proceeds from sales and securitizations of loans

8,365

8,365
Proceeds from significant disposals

3,411

3,411
Change in securities borrowed and purchased under agreements to resell
9,731
(5,396)
4,335
Changes in investments and advances—intercompany(899)9,755
(8,856)

Other investing activities
(24)(2,773)
(2,797)
Net cash provided by (used in) investing activities of continuing operations$(767)$19,466
$(57,450)$
$(38,751)
Cash flows from financing activities of continuing operations     
Dividends paid$(3,797)$
$
$
$(3,797)
Issuance of preferred stock




Treasury stock acquired(14,541)


(14,541)
Proceeds (repayments) from issuance of long-term debt, net6,544
4,909
15,521

26,974
Proceeds (repayments) from issuance of long-term debt—intercompany, net
(2,031)2,031


Change in deposits

30,416

30,416
Change in securities loaned and sold under agreements to repurchase
5,748
8,708

14,456
Change in short-term borrowings49
2,212
11,490

13,751
Net change in short-term borrowings and other advances—intercompany(22,152)(8,615)30,767


Capital contributions from parent
(748)748


Other financing activities(405)


(405)
Net cash provided by financing activities of continuing operations$(34,302)$1,475
$99,681
$
$66,854
Effect of exchange rate changes on cash and due from banks$
$
$693
$
$693
Change in cash and due from banks and deposits with banks$(9,799)$(12,424)$42,245
$
$20,022
Cash and due from banks and deposits with banks at
beginning of period
20,812
25,119
114,563

160,494
Cash and due from banks and deposits with banks at end of period$11,013
$12,695
$156,808
$
$180,516
Cash and due from banks$13
$4,128
$19,634
$
$23,775
Deposits with banks11,000
8,567
137,174

156,741
Cash and due from banks and deposits with banks at end of period$11,013
$12,695
$156,808
$
$180,516
Supplemental disclosure of cash flow information for continuing operations     
Cash paid during the year for income taxes$(3,730)$678
$5,135
$
$2,083
Cash paid during the year for interest4,151
4,513
7,011

15,675
Non-cash investing activities     
Transfers to loans held-for-sale from loans$
$
$5,900
$
$5,900

Year ended December 31, 2019
In millions of dollarsCitigroup parent companyCGMHIOther Citigroup subsidiaries and eliminationsConsolidating adjustmentsCitigroup consolidated
Net cash provided by (used in) operating activities of continuing operations$25,011 $(35,396)$(2,452)$— $(12,837)
Cash flows from investing activities of continuing operations
Purchases of investments$— $— $(274,491)$— $(274,491)
Proceeds from sales of investments— 137,168 — 137,173 
Proceeds from maturities of investments— — 119,051 — 119,051 
Change in loans— — (22,466)— (22,466)
Proceeds from sales and securitizations of loans— — 2,878 — 2,878 
Change in securities borrowed and purchased under agreements to resell— 15,811 3,551 — 19,362 
Changes in investments and advances—intercompany(1,847)(870)2,717 — — 
Other investing activities— (64)(4,817)— (4,881)
Net cash provided by (used in) investing activities of continuing operations$(1,842)$14,877 $(36,409)$— $(23,374)
Cash flows from financing activities of continuing operations
Dividends paid$(5,447)$— $— $— $(5,447)
Issuance of preferred stock1,496 — — — 1,496 
Redemption of preferred stock(1,980)— — — (1,980)
Treasury stock acquired(17,571)— — — (17,571)
Proceeds (repayments) from issuance of long-term debt, net1,666 10,389 (3,950)— 8,105 
Proceeds (repayments) from issuance of long-term debt—intercompany, net— (7,177)7,177 — — 
Change in deposits— — 57,420 — 57,420 
Change in securities loaned and sold under agreements to repurchase— 5,115 (16,544)— (11,429)
Change in short-term borrowings— 7,440 5,263 — 12,703 
Net change in short-term borrowings and other advances—intercompany(968)5,843 (4,875)— — 
Capital contributions from (to) parent— (74)74 — — 
Other financing activities(364)(253)253 — (364)
Net cash provided by (used in) financing activities of continuing operations$(23,168)$21,283 $44,818 $— $42,933 
Effect of exchange rate changes on cash and due from banks$— $— $(908)$— $(908)
Change in cash and due from banks and deposits with banks$$764 $5,049 $— $5,814 
Cash and due from banks and deposits with banks at
beginning of year
3,020 15,677 169,408 — 188,105 
Cash and due from banks and deposits with banks at end of year$3,021 $16,441 $174,457 $— $193,919 
Cash and due from banks (including segregated cash and other deposits)$21 $5,681 $18,265 $— $23,967 
Deposits with banks, net of allowance3,000 10,760 156,192 — 169,952 
Cash and due from banks and deposits with banks at end of year$3,021 $16,441 $174,457 $— $193,919 
Supplemental disclosure of cash flow information for continuing operations 
Cash paid (received) during the year for income taxes$(393)$418 $4,863 $— $4,888 
Cash paid during the year for interest3,820 12,664 11,417 — 27,901 
Non-cash investing activities
Transfers to loans HFS (Other assets) from loans
$— $— $5,500 $— $5,500 
313


29. SELECTED QUARTERLY FINANCIAL DATA (UNAUDITED)


20192018 20212020
In millions of dollars, except per share amountsFourthThirdSecondFirstFourthThirdSecondFirstIn millions of dollars, except per share amountsFourthThirdSecondFirstFourthThirdSecondFirst
Revenues, net of interest expense$18,378
$18,574
$18,758
$18,576
$17,124
$18,389
$18,469
$18,872
Operating expenses10,454
10,464
10,500
10,584
9,893
10,311
10,712
10,925
Provisions for credit losses and for benefits and claims2,222
2,088
2,093
1,980
1,925
1,974
1,812
1,857
Revenues, net of interest expense(1)(2)
Revenues, net of interest expense(1)(2)
$17,017 $17,447 $17,753 $19,667 $16,832 $17,677 $20,036 $20,956 
Operating expenses(1)(3)
Operating expenses(1)(3)
13,532 11,777 11,471 11,413 11,437 11,339 10,730 10,868 
Provisions (release) for credit losses and for benefits
and claims
Provisions (release) for credit losses and for benefits
and claims
(465)(192)(1,066)(2,055)(46)2,384 8,197 6,960 
Income from continuing operations before income taxes$5,702
$6,022
$6,165
$6,012
$5,306
$6,104
$5,945
$6,090
Income from continuing operations before income taxes$3,950 $5,862 $7,348 $10,309 $5,441 $3,954 $1,109 $3,128 
Income taxes(1)
703
1,079
1,373
1,275
1,001
1,471
1,444
1,441
Income taxes(4)
Income taxes(4)
771 1,193 1,155 2,332 1,116 777 52 580 
Income from continuing operations$4,999
$4,943
$4,792
$4,737
$4,305
$4,633
$4,501
$4,649
Income from continuing operations$3,179 $4,669 $6,193 $7,977 $4,325 $3,177 $1,057 $2,548 
Income (loss) from discontinued operations, net of taxes(4)(15)17
(2)(8)(8)15
(7)Income (loss) from discontinued operations, net of taxes (1)10 (2)(7)(1)(18)
Net income before attribution of noncontrolling interests$4,995
$4,928
$4,809
$4,735
$4,297
$4,625
$4,516
$4,642
Net income before attribution of noncontrolling interests$3,179 $4,668 $6,203 $7,975 $4,331 $3,170 $1,056 $2,530 
Noncontrolling interests16
15
10
25
(16)3
26
22
Noncontrolling interests6 24 10 33 22 24 — (6)
Citigroup’s net income$4,979
$4,913
$4,799
$4,710
$4,313
$4,622
$4,490
$4,620
Citigroup’s net income$3,173 $4,644 $6,193 $7,942 $4,309 $3,146 $1,056 $2,536 
Earnings per share(2)
 
 
 
 
 
 
 
 
Earnings per share(5)
Earnings per share(5)
 
Basic 
 
 
 
 
 
 
 
Basic 
Income from continuing operations$2.16
$2.09
$1.94
$1.88
$1.65
$1.74
$1.62
$1.68
Income from continuing operations$1.47 $2.17 $2.86 $3.64 $1.93 $1.37 $0.38 $1.07 
Net income2.16
2.09
1.95
1.88
1.65
1.73
1.63
1.68
Net income1.47 2.17 2.87 3.64 1.93 1.37 0.38 1.06 
Diluted    Diluted
Income from continuing operations2.15
2.08
1.94
1.87
1.65
1.74
1.62
1.68
Income from continuing operations1.46 2.15 2.84 3.62 1.92 1.36 0.38 1.06 
Net income2.15
2.07
1.95
1.87
1.64
1.73
1.63
1.68
Net income1.46 2.15 2.85 3.62 1.92 1.36 0.38 1.06 

This Note to the Consolidated Financial Statements is unaudited due to the Company’s individual quarterly results not being subject to an audit.
(1)The fourth quarter of 2019 includes discrete tax items of roughly $540 million including an approximate $430 million benefit of a reduction in Citi’s valuation allowance related to its DTAs. The third quarter of 2019 includes discrete tax items of roughly $230 million, including an approximate $180 million benefit of a reduction in Citi’s valuation allowance related to its DTAs.
(2)Due to averaging of shares, quarterly earnings per share may not sum to the totals reported for the full year.

(1)     During the fourth quarter of 2021, Citi reclassified deposit insurance expenses from Interest expense to Other operating expenses for all periods presented. Amounts reclassified for each quarter were $295 million for 4Q21, $293 million for 3Q21, $279 million for 2Q21, $340 million for 1Q21, $333 million for 4Q20, $375 million for 3Q20, $270 million for 2Q20 and $225 million for 1Q20. For additional information, see Note 1 to the Consolidated Financial Statements.
(2)    The third quarter of 2021 includes an approximate $700 million loss on sale (approximately $600 million after-tax) related to Citi’s agreement to sell its consumer banking business in Australia.
(3)    The fourth quarter of 2021 includes an approximate $1.052 billion charge (approximately $792 million after-tax) in connection with the voluntary early retirement plan (VERP) related to the announced wind-down of Citi’s consumer banking business in Korea.
(4)    The second quarter of 2021 includes an approximate $450 million benefit in tax rate from a reduction in Citi’s valuation allowance related to its deferred tax assets (DTAs).
(5)    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, which uses an averaging of shares across each quarter. 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

314


FINANCIAL DATA SUPPLEMENT

RATIOS

202120202019
Return on average assets0.94 %0.50 %0.98 %
Return on average common stockholders’ equity(1)
11.5 5.7 10.3 
Return on average total stockholders’ equity(2)
10.9 5.7 9.9 
Total average equity to average assets(3)
8.6 8.7 9.9 
Dividend payout ratio(4)
20 43 24 

(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.

 201920182017
Citigroup’s net income to average assets(1)
0.98%0.94%0.84%
Return on average common stockholders’ equity(1)(2)
10.3
9.4
7.0
Return on average total stockholders’ equity(1)(3)
9.9
9.1
7.0
Total average equity to average assets(4)
9.9
10.3
12.1
Dividend payout ratio(1)(5)
23.9
23.1
18.0
(1)2017 excludes the one-time impact of Tax Reform. See “Significant Accounting Policies and Estimates—Income Taxes” above.
(2)Based on Citigroup’s net income less preferred stock dividends as a percentage of average common stockholders’ equity.
(3)Based on Citigroup’s net income as a percentage of average total Citigroup stockholders’ equity.
(4)Based on average Citigroup stockholders’ equity as a percentage of average assets.
(5)Dividends declared per common share as a percentage of net income per diluted share.


AVERAGE DEPOSIT LIABILITIES IN OFFICES OUTSIDE THE U.S.(1)

202120202019
In millions of dollars at year end, except ratiosAverage
interest rate
Average
balance
Average
interest rate
Average
balance
Average
interest rate
Average
balance
Banks0.16 %$42,222 0.10 %$130,970 0.59 %$52,699 
Other demand deposits0.15 412,815 0.33 311,342 1.08 293,209 
Other time and savings deposits(2)
0.55 200,194 0.94 210,896 1.28 223,450 
Total0.10 %$655,231 0.48 %$653,208 1.11 %$569,358 

(1)    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.
(2)    Primarily consists of certificates of deposit and other time deposits in denominations of $100,000 or more.

UNINSURED DEPOSITS

The table below shows the estimated amount of uninsured time deposits by maturity profile:

In millions of dollars at December 31, 2021Under 3 months or lessOver 3 months but within 6
months
Over 6 months but within 12
months
Over 12
months
Total
In U.S. offices(1)
Time deposits in excess of FDIC insurance limits(2)
$5,779 $2,653 $1,861 $2,950 $13,243 
In offices outside the U.S.(1)
Time deposits in excess of foreign jurisdiction insurance limits(3)
57,248 6,471 4,080 1,095 68,894 
Total uninsured time deposits(4)
$63,027 $9,124 $5,941 $4,045 $82,137 

(1)    The classification between offices in the U.S. and outside the U.S. is based on the domicile of the booking unit, rather than the domicile of the depositor.
(2)    The standard insurance amount is $250,000 and $500,000 per depositor, per insured bank, for single and joint account ownership categories, respectively.
(3)    The standard insurance amount for time deposits outside the U.S. is based on the insurance limits approved by the regulator in the respective foreign jurisdiction. For certain depositors outside the U.S., Citi has not considered the account ownership category and other time deposit accounts that the depositors may own when allocating the insurance limits used to determine the uninsured time deposit balances. As a result, the uninsured time deposit balances disclosed above may differ from actual uninsured balances.
(4)    The maturity term is based on the remaining term of the time deposit rather than the original maturity date.

Total uninsured deposits as of December 31, 2021 were $1.082 trillion (see notes 1, 2 and 3 to the table above).

  2019 2018 2017
In millions of dollars at year end, except ratiosAverage
interest rate
Average
balance
Average
interest rate
Average
balance
Average
interest rate
Average
balance
Banks1.71%$52,235
1.35%$44,426
0.49%$36,063
Other demand deposits1.05
300,101
0.61
287,665
0.52
293,389
Other time and savings deposits(2)
1.05
217,944
1.31
209,410
1.23
191,363
Total1.11%$570,280
0.94%$541,501
0.78%$520,815
(1)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.
(2)Primarily consists of certificates of deposit and other time deposits in denominations of $100,000 or more.


315


MATURITY PROFILE OF TIME DEPOSITSIN U.S. OFFICES
     
In millions of dollars at December 31, 2019Under 3
months
Over 3 to 6
months
Over 6 to 12
months
Over 12
months
Over $100,000    
Certificates of deposit$15,866
$8,152
$9,008
$694
Other time deposits3,924
29
38
1,556
Over $250,000    
Certificates of deposit$14,026
$5,008
$4,953
$539
Other time deposits3,923
29
2
11




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.Board (FRB). 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 BoardFRB and OCC and overseas subsidiary banks by the Federal Reserve Board.FRB. 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 BoardFRB may also expect Citi to commit resources to its subsidiary banks in certain circumstances. Citi is also subject to anti-money laundering and financial transparency laws, including standards for verifying client identification at account opening and obligations to monitor client transactions and report suspicious activities.

Securities and Commodities Regulation
Citi conducts securities underwriting, brokerage and dealing activities in the U.S. through Citigroup Global Markets Inc. (CGMI), its primary broker-dealer, and other broker-dealer subsidiaries, which are subject to regulations of the U.S. Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority and certain exchanges. Citi conducts similar securities activities outside the U.S., subject to local requirements, through various subsidiaries and affiliates, principally Citigroup Global Markets Limited in London (CGML), which is regulated principally by the U.K.

Financial Conduct Authority (FCA)and Prudential Regulation Authority (PRA), 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.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 (CGME) and CGML are also registered as swap dealers with the CFTC.CFTC (for additional information, see below). 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.

Recent Rules Regarding Swap Dealers/Security-Based Swap
Dealers
On July 22, 2020, the CFTC adopted final rules establishing
capital and financial reporting requirements for swap dealers
that took effect in October 2021.
In addition, the SEC has adopted rules governing the
registration and regulation of security-based swap dealers. The
regulations include requirements related to (i) capital, margin
and segregation, (ii) record-keeping, reporting and notification
and (iii) risk management practices for uncleared security based swaps and the cross-border application of certain
security-based swap requirements. These requirements also
took effect in November 2021. Citibank, CGML and CGME registered with the SEC as securities-based swap dealers.

Transactions with Affiliates
Transactions between Citi’s U.S. subsidiary depository institutions and their non-bank affiliates are regulated by the Federal Reserve Board,FRB, 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.companies, as well as certain non-financial services firms. 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, maintenance of partner relationships, emerging technologies and technology advances, customer
316


service and convenience; the effectiveness of transaction execution, interest rates, lending limits and lending limits;risk appetite; regulatory constraints and regulatory constraints.compliance; and changes in the macroeconomic business environment or societal norms. Citi’s ability to compete effectively also depends upon its ability to attract new employeescolleagues and retain and motivate existing employees,colleagues, while managing compensation and other costs. For additional information on competitive factors and uncertainties impacting Citi’s businesses, see “Risk Factors—OperationalStrategic Risks” above.

CLIMATE CHANGE
Climate change presents immediate and long-term risks to Citi and to its clients and customers, with the risks potentially increasing over time. Climate risk can arise from physical risks (risks related to the physical effects of climate change) and transition risks (risks related to regulatory, legal, technological and market changes from a transition to a low-carbon economy).
Citi’s Environmental and Social Risk Management Policy incorporates climate risk assessment for credit underwriting purposes and reporting criteria for certain corporate obligors

and transactions. Factors evaluated include consideration of climate risk to an obligor’s business and physical assets and, when relevant, consideration of cost-effective options to reduce greenhouse gas (GHG) emissions. Citi engages clients to support their low-carbon transition, including through Citi’s growing environmental finance offerings.
To manage the risks of climate change to Citi’s own operations and facilities, Citi assesses its exposure to climate hazards to inform business continuity and resilience planning. In addition, Citi has developed programs for its properties to achieve long-term energy efficiency objectives and reduce its GHG emissions to lessen its impact on climate change. 
Citi has adopted the Taskforce on Climate-related Financial Disclosures (TCFD) recommendations and published its first TCFD report, Finance for a Climate Resilient Future, in 2018. As detailed in that report, Citi participated in the United Nations Environment Finance Initiative Banking Sector TCFD Project in 2017–2018 and piloted climate scenario analyses on Citi’s North America oil and gas exploration and production and U.S. power portfolios, to understand their exposure to climate risk under select scenarios. Citi continues to participate in financial industry collaborations to develop and pilot new methodologies and approaches for measuring and assessing the potential financial risks of climate change. Citi is also closely monitoring regulatory developments on climate risk and sustainable finance, and actively engaging with regulators on these topics.
For information on Citi’s environmental and social policies and priorities, see Citi’s website at www.citigroup.com. Click on “About Us” and then “Corporate Governance” and “Citizenship Report” or “Environmental and Social Information.” For information on Citi’s citizenship and sustainability governance, see Citi’s 2019 Annual Meeting Proxy Statement available at www.citigroup.com. Click on “Investors” and then “Annual Reports & Proxy Statements.”



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 toof 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 discloseddid not identify any reportable activities for the first and third quarters of 2021. Citi identified and reported certain activities pursuant to Section 219 for the first, second and third quartersquarter of 2019.2021.
Citi had no reportable activities pursuant to Section 219 forDuring the fourth quarter of 2019.2021, Citigroup reported one transaction pursuant to Section 219. In October 2021, Citigroup’s Russian subsidiary (Citi Russia), acting as the beneficiary bank, released a payment that had been initiated by a Russian entity from its account with MB Bank, an entity designated pursuant to Executive Order 13224, for the benefit of Citi Russia’s customer. The total value of the payment was RUB 16,533.12 (approximately USD 224.70), and the transaction was authorized pursuant to a specific license issued by the Office of Foreign Assets Control on October 1, 2021, which expired on December 31, 2021. Citi did not realize any fees for the processing of the payment.

 


317



UNREGISTERED SALES OF EQUITY SECURITIES, REPURCHASES OF EQUITY SECURITIES AND DIVIDENDS

Unregistered Sales of Equity Securities
None.

Equity Security Repurchases
The following table summarizes Citi’sAs previously announced, Citigroup voluntarily suspended common stockshare repurchases during the three months ended December 31, 2019:

In millions, except per share amounts
Total shares
purchased
Average
price paid
per share
Approximate dollar
value of shares that
may yet be purchased
under the plan or
programs
October 2019   
Open market repurchases(1)
21.6
$69.77
$10,473
Employee transactions(2)


N/A
November 2019   
Open market repurchases(1)
21.0
74.80
8,902
Employee transactions(2)


N/A
December 2019   
Open market repurchases(1)
26.6
77.03
6,855
Employee transactions(2)


N/A
Total for 4Q19 and remaining program balance as of December 31, 201969.2
$74.09
$6,855
(1)Represents repurchases under the $17.1 billion 2019 common stock repurchase program (2019 Repurchase Program) that was approved byfourth quarter of 2021, in anticipation of the adverse regulatory capital impact resulting from adoption of the Standardized Approach for Counterparty Credit Risk (SA-CCR) on January 1, 2022. For additional information on the adoption of SA-CCR, see “Capital Resources—Adoption of the Standardized Approach for Counterparty Credit Risk” above. Accordingly, Citi did not have any share repurchases in the fourth quarter of 2021, other than repurchases relating to issuances of common stock related to employee stock ownership plans. During the quarter, pursuant to Citigroup’s Board of Directors and announced on June 27, 2019. The 2019 Repurchase Program was part of the planned capital actions included by Citi as part of the 2019 Comprehensive Capital Analysis and Review (CCAR). Shares repurchased under the 2019 Repurchase Program were added to treasury stock. The 2019 Repurchase Program expires on June 30, 2020.
(2)Consisted of shares added to treasury stock related to (i) certain activity on employee stock option program exercises where the employee delivers existing shares to cover the option exercise, or (ii) under Citi’s employee restricted share rewards where shares are withheld to satisfy tax requirements.
N/A Not applicable

Dividends
In addition to Board of Directors’ approval,authorization, Citi repurchased 1,855 shares (at an average price of $66.37) of common stock, added to treasury stock, related to activity on employee stock programs where shares were withheld to satisfy the employee tax requirements. Citi resumed common share repurchases in January 2022.
All large banks, including Citi, are subject to limitations on capital distributions in the event of a breach of any regulatory capital buffers, including the Stress Capital Buffer, with the degree of such restrictions based on the extent to which the buffers are breached. For additional information, see “Capital Resources—Regulatory Capital Buffers” and “Risk Factors—Strategic Risks” above.

Dividends
Citi paid common dividends of $0.51 per share for the fourth quarter of 2021 and the first quarter of 2022. As previously announced, Citi intends to maintain its planned capital actions, which include a quarterly common dividend of at least $0.51 per share, subject to financial and macroeconomic conditions as well as Board of Directors’ approval.
As discussed above, Citi’s ability to pay common stock dividends substantially dependsis subject to limitations on capital distributions in the event of a breach of any regulatory approval,capital buffers, including an annual regulatory reviewthe Stress Capital Buffer, with the degree of such restrictions based on the results ofextent to which the CCAR process required by the Federal Reserve Board and the supervisory stress tests required under the Dodd-Frank Act.buffers are breached. For additional information, regarding Citi’s capital planning and stress testing, see “Capital Resources—Current Regulatory Capital Standards—Stress Testing Component of Capital Planning”Buffers” and “Risk Factors—Strategic Risks” above.
Any dividend on Citi’s outstanding common stock would also need to be made in compliance with Citi’s obligations on its outstanding preferred stock.

During 2021, Citi distributed $1,040 million in dividends on its outstanding preferred stock. On January 12, 2022, Citi declared preferred dividends of approximately $277 million for the first quarter of 2022.
As of February 25, 2022, Citi estimates it will distribute preferred dividends of approximately $238 million, $277 million and $238 million in the second, third and fourth quarters of 2022, respectively, subject to such dividends being declared by the Citi Board of Directors.
For information on the ability of Citigroup’s subsidiary depository institutions to pay dividends, see Note 18 to the Consolidated Financial Statements.





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PERFORMANCE GRAPH

Comparison of Five-Year Cumulative Total Return
The following graph and table compare the cumulative total return on Citi’s common stock with the cumulative total return of the S&P 500 Index and the S&P Financials Index over the five-year period through December 31, 2019.2021. The graph and table assume that $100 was invested on December 31, 20142016 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
chart-d93e2dd479fc52ddbc7.jpgc-20211231_g17.jpg

DATECitigroupS&P 500 IndexS&P Financials Index
31-Dec-2016100.0 100.0 100.0 
31-Dec-2017127.0 121.8 122.2 
31-Dec-201890.9 116.5 106.3 
31-Dec-2019143.3 153.2 140.4 
31-Dec-2020115.2 181.4 138.0 
31-Dec-2021116.3 233.4 186.4 
DATECitigroup
S&P 500 Index
S&P Financials Index
31-Dec-2014100.0
100.0
100.0
31-Dec-201595.9
101.4
98.5
31-Dec-2016111.2
113.5
120.9
31-Dec-2017141.2
138.3
147.7
31-Dec-2018

101.0
132.2
128.5
31-Dec-2019159.4
173.9
169.8


Note: Citi’s common stock is listed on the NYSE under the ticker symbol “C” and held by 66,99061,355 common stockholders of record as of January 31, 2020.2022.

319


CORPORATE INFORMATION

EXECUTIVE OFFICERS
Citigroup’s executive officers as of February 21, 202025, 2022 are:

NameAgePosition and office held
Raja J. Akram47Controller and Chief Accounting Officer
Peter Babej5658CEO, Asia Pacific
Michael L. CorbatJane Fraser5954Chief Executive Officer, Citigroup Inc.
Jane FraserSunil Garg5256President; CEO, Global Consumer BankingChief Executive Officer, Citibank, N.A.
Bradford Hu56Chief Risk Officer
David Livingstone5658CEO, Europe, Middle East and Africa
Mark A. L. Mason5052Chief Financial Officer
Mary McNiffBrent McIntosh4948CEO, Citibank, N.A.
Ernesto Torres Cantú55CEO, Latin America
Sara Wechter39Head of Human Resources
Rohan Weerasinghe69General Counsel and Corporate Secretary
Mary McNiff51Chief Compliance Officer
Johnbull Okpara50Controller and Chief Accounting Officer
Karen Peetz66Chief Administrative Officer
Anand Selvakesari        54CEO, Personal Banking and Wealth Management
Edward Skyler48Head of Global Public Affairs
Ernesto Torres Cantú57CEO, Latin America
Zdenek Turek57Chief Risk Officer
Sara Wechter41Head of Human Resources
Mike Whitaker5658Head of Enterprise Operations and Technology
Paco Ybarra5860CEO, Institutional Clients Group

EachThe following executive officers have not held their current executive officer has held senior executive or management positions with Citigroup for at least five years, except that:years:

Mr. AkramBabej joined Citi in 20062010 and assumed his current position in November 2017.October 2019. Previously, he served as Deputy Controller since April 2017. He held a number of other roles in Citi Finance, including Lead Finance Officer for Treasury and Trade Solutions, Brazil Country Controller, Brazil Country Finance Officer andICG’s Global Head of the Corporate Accounting Policy team supporting M&A activities;
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 joined Citi in 2010 and assumed his current position in October 2019. Previously, he served as Co-Head, Financial Institutions—Americas at Deutsche Bank, among other roles;
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.on February 26, 2021. 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. Garg joined Citi in May 1988 and assumed his current position in February 2021. Previously, he was global CEO of the Commercial Bank beginning in 2011. Prior to that, Mr. Garg led the U.S. Commercial Banking business from 2008 until 2011. In addition, he held various other roles at Citi in Operations and Technology, Treasury and Trade Solutions, Corporate and Investment Banking and Commercial Banking.
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 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;
Mr. McIntosh joined Citi in his current position in October 2021. Previously, he served as Under Secretary for International Affairs at the U.S. Treasury from 2019 to 2021. From 2017 to 2019, Mr. McIntosh served as U.S. Treasury’s General Counsel. Prior to that, he was a partner in the law firm of Sullivan & Cromwell and served in the U.S. White House from 2006 until 2009;
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 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, the 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
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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’sGlobal 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.


Mr. Mason joined Citi in 2001 and assumed his current position in February 2019. Previously, he served as CFO of ICG since September 2014. He held a number of other senior operational, strategic and financial executive roles across the organization, including CEO of Citi Private Bank, CEO of Citi Holdings and CFO and Head of Strategy and M&A for Citi’s Global Wealth Management Division;
Ms. McNiff joined Citi in 2012 and assumed her current position in April 2019. Previously, she served as Chief Auditor since February 2017. She held a number of other roles across the organization, including Chief Auditor of GCB, Chief Administrative Officer for Citi Latin America & Mexico and interim Chief Auditor, ICG. She also previously led the Global Transformation initiative within Internal Audit;
Mr. Torres Cantú joined Citi in 1989 and assumed his current position in October 2019. Previously, he served as CEO of Citibanamex since October 2014. He served as CEO of GCB in Mexico from 2006 to 2011 and CEO of Crédito Familiar from 2003 to 2006. In addition, he previously held roles in Citibanamex, including Regional Director and Divisional Director;
Ms. Wechter joined Citi in 2004 and assumed her current position in July 2018. Previously, she served as Citi's Head of Talent and Diversity as well as Chief of Staff to Citi CEO Michael Corbat. She served as Chief of Staff to both Michael O'Neill and Richard Parsons during their terms as Chairman of Citi's Board of Directors. In addition, she held roles in Citi's ICG, including Corporate M&A and Strategy and Investment Banking;
Mr. Whitaker joined Citi in 2009 and assumed his current position in November 2018. Previously, he served as Head of Operations & Technology for ICG since September 2014 and held various other roles at Citi, including Head of Securities & Banking Operations & Technology, Head of ICG Technology and Regional Chief Information Officer; and
Mr. Ybarra joined Citi in 1987 and assumed his current position in May 2019. Previously, he served as ICG’sGlobal 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, capital planning, tax, productivity and 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.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, Conduct and Culture Committee, the Nomination, Governance and Public Affairs Committee, the Operations and Technology Committee, the Personnel and Compensation Committee and the Risk Management Committee of the Board.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.

Ellen M. Costello
Former President and CEO
BMO Financial Corporation and Former U.S. Country Head
BMO Financial Group

Grace E. Dailey
Former Senior Deputy Comptroller for Bank Supervision Policy and Chief National Bank Examiner
Office of the Comptroller of the Currency (OCC)

Barbara Desoer
Former Chief Executive Officer Chair
Citibank, N.A.

John C. Dugan
Chair
Citigroup Inc.



Jane Fraser
Chief Executive Officer
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 and
Operating Executive
The Carlyle Group

Eugene (Gene) M. McQuade
Former Chief Executive Officer Citibank, N.A. and
Former Vice Chairman
Citigroup Inc.

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
Chief Executive Officer and Chairman of the Management and Executive Boards
Aegon N.V.

Ernesto Zedillo Ponce de Leon
Director, Center for the
Study of Globalization and
Professor in the Field
of International
Economics and Politics
Yale University


321




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 21st25th day of February, 2020.2022.

Citigroup Inc.
(Registrant)

/s/ Mark A. L. Mason

Mark A. L. Mason
Chief Financial Officer

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 21st25th day of February, 2020.2022.

Citigroup’s Principal Executive Officer and a Director:

/s/ Michael L. CorbatJane Fraser

Michael L. CorbatJane Fraser



Citigroup’s Principal Financial Officer:

/s/ Mark A. L. Mason

Mark A. L. Mason



Citigroup’s Principal Accounting Officer:

/s/ Raja J. AkramJohnbull E. Okpara

Raja J. AkramJohnbull E. Okpara

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. CostelloRenée J. James
Grace E. DaileyEugene M. McQuade
Barbara DesoerGary M. Reiner
John C. DuganDiana L. Taylor
Duncan P. HennesJames S. Turley
Peter Blair HenryDeborah C. Wright
S. Leslie IrelandAlexander Wynaendts
Lew W. (Jay) Jacobs, IV
Grace E. DaileyRenée J. James
Barbara DesoerGary M. Reiner
John C. DuganDiana L. Taylor
Duncan P. HennesJames S. Turley
Peter Blair HenryDeborah C. Wright
S. Leslie IrelandErnesto Zedillo Ponce de Leon


/s/ Mark A. L. Mason

Mark A. L. Mason


322


GLOSSARY OF TERMS AND ACRONYMS

The following is a list of terms and acronyms that are used in this Annual Report on Form 10-K and other Citigroup presentations.

* Denotes a Citi metric


2021 Annual Report on Form 10-K: Annual report on Form 10-K for year ended December 31, 2021, filed with the SEC.
90+ days past due delinquency rate*: Represents consumer loans that are past due by 90 or more days, divided by that period’s total EOP loans.
ABS: Asset-backed securities
ACL: Allowance for credit losses
ACLL: Allowance for credit losses on loans
ACLUC: Allowance for credit losses on unfunded lending commitments
AFS: Available-for-sale
ALCO: Asset Liability Committee
Amortized cost: Amount at which a financing receivable or investment is originated or acquired, adjusted for accretion or amortization of premium, discount, and net deferred fees or costs, collection of cash, charge-offs, foreign exchange, and fair value hedge accounting adjustments. For AFS securities, amortized cost is also reduced by any impairment losses recognized in earnings. Amortized cost is not reduced by the allowance for credit losses, except where explicitly presented net.
AOCI: Accumulated other comprehensive income (loss)
ARM: Adjustable rate mortgage(s)
ASC: Accounting Standards Codification under GAAP issued by the FASB.
ASU: Accounting Standards Update under GAAP issued by the FASB.
AUC: Assets under custody
AUM: Assets under management. Represent assets managed on behalf of Citi’s clients.
Available liquidity resources*: Resources available at the balance sheet date to support Citi’s client and business needs, including 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.
Basel III: Liquidity and capital rules adopted by the FRB based on an internationally agreed set of measures developed by the Basel Committee on Banking Supervision.
Beneficial interests issued by consolidated VIEs: Represents the interest of third-party holders of debt, equity securities or other obligations, issued by VIEs that Citi consolidates.
Benefit obligation: Refers to the projected benefit obligation for pension plans and the accumulated postretirement benefit obligation for OPEB plans.
BHC: Bank holding company
Book value per share*: EOP common equity divided by EOP common shares outstanding.
Bps: Basis points. One basis point equals 1/100th of one percent.
Branded cards: Citi’s branded-cards business with a portfolio of proprietary cards (Double Cash, Custom Cash, ThankYou and Value cards) and co-branded cards (including, among others, American Airlines and Costco).
Build: A net increase in ACL through the provision for credit losses.
Cards: Citi’s credit cards’ businesses or activities.
CCAR: Comprehensive Capital Analysis and Review
CCO: Chief Compliance Officer
CDS: Credit default swaps
CECL: Current Expected Credit Losses
CEO: Chief Executive Officer
CET1 Capital: Common Equity Tier 1 Capital. See “Capital Resources—Components of Citigroup Capital” above for the components of CET1.
CET1 Capital Ratio*: Common Equity Tier 1 Capital ratio. A primary regulatory capital ratio representing end-of-period CET1 Capital divided by total risk-weighted assets.
CFO: Chief Financial Officer
CFTC: Commodity Futures Trading Commission
CGMHI: Citigroup Global Markets Holdings Inc.
Citi: Citigroup Inc.
Citibank or CBNA: Citibank, N.A. (National Association)
Client assets: Represent assets under management as well as custody, brokerage, administration and deposit accounts.
CLO: Collateralized loan obligations
Collateral-dependent: A loan is considered collateral dependent when repayment of the loan is expected to be provided substantially through the operation or sale of the collateral when the borrower is experiencing financial difficulty, including when foreclosure is deemed probable based on borrower delinquency.
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Commercial Cards: Provides a wide range of payment services to corporate and public sector clients worldwide through commercial card products. Services include procurement, corporate travel and entertainment, expense management services, and business-to-business payment solutions.
Consent orders: In October 2020, Citigroup and Citibank entered into consent orders with the Federal Reserve and OCC that require Citigroup and Citibank to make improvements in various aspects of enterprise-wide risk management, compliance, data quality management and governance and internal controls.
CRE: Commercial real estate
Credit card spend volume*: Dollar amount of card customers’ purchases, net of returns. Also known as purchase sales.
Credit cycle: A period of time over which credit quality improves, deteriorates and then improves again (or vice versa). The duration of a credit cycle can vary from a couple of years to several years.
Credit derivatives: Financial instruments whose value is derived from the credit risk associated with the debt of a third-party issuer (the reference entity), which allow one party (the protection purchaser) to transfer that risk to another party (the protection seller). Upon the occurrence of a credit event by the reference entity, which may include, among other events, the bankruptcy or failure to pay its obligations, or certain restructurings of the debt of the reference entity, neither party has recourse to the reference entity. The protection purchaser has recourse to the protection seller for the difference between the face value of the CDS contract and the fair value at the time of settling the credit derivative contract. The determination as to whether a credit event has occurred is generally made by the relevant International Swaps and Derivatives Association (ISDA) Determinations Committee.
Critical Audit Matters: Audit matters communicated by KPMG to Citi’s Audit Committee of the Board of Directors, relating to accounts or disclosures that are material to the consolidated financial statements and involved especially challenging, subjective or complex judgments. See “Report of Independent Registered Public Accounting Firm” above.
Criticized: Criticized loans, lending-related commitments and derivative receivables that are classified as special mention, substandard and doubtful categories for regulatory purposes.
CRO: Chief Risk Officer
CVA: Credit valuation adjustment
Dividend payout ratio*: Represents dividends declared per common share as a percentage of net income per diluted share.
Dodd-Frank Act: Wall Street Reform and Consumer Protection Act
DPD: Days past due
DVA: Debit valuation adjustment
EC: European Commission
Efficiency ratio*: A ratio signifying how much of a dollar in expenses (as a percentage) it takes to generate one dollar in revenue. Represents total operating expenses divided by total revenues, net.
EMEA: Europe, Middle East and Africa
EOP: End-of-period
EPS*: Earnings per share
ERISA: Employee Retirement Income Security Act of 1974
ETR: Effective tax rate
EU: European Union
Fannie Mae: Federal National Mortgage Association
FASB: Financial Accounting Standards Board
FDIC: Federal Deposit Insurance Corporation
Federal Reserve: The Board of the Governors of the Federal Reserve System
FFIEC: Federal Financial Institutions Examination Council
FHA: Federal Housing Administration
FHLB: Federal Home Loan Bank
FICO: Fair Issac Corporation
FICO score: A measure of consumer credit risk provided by credit bureaus, typically produced from statistical models by Fair Isaac Corporation utilizing data collected by the credit bureaus.
FINRA: Financial Industry Regulatory Authority
Firm: Citigroup Inc.
FRBNY: Federal Reserve Bank of New York
Freddie Mac: Federal Home Loan Mortgage Corporation
Free standing derivatives: A derivative contract entered into either separate and apart from any of the Company’s other financial instruments or equity transactions, or in conjunction with some other transaction and legally detachable and separately exercisable.
FTCs: Foreign tax credit carry-forwards
FTE: Full time employee
FVA: Funding valuation adjustment
FX: Foreign exchange
FX translation: The impact of converting non-U.S.-dollar currencies into U.S. dollars.
G7: Group of Seven nations. Countries in the G7 are Canada, France, Germany, Italy, Japan, the U.K. and the U.S.
GAAP or U.S. GAAP: Generally accepted accounting principles in the United States of America.
GCB: Global Consumer Banking
Ginnie Mae: Government National Mortgage Association
GSIB: Global systemically important banks
HELOC: Home equity line of credit
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HFI loans: Loans that are held-for-investment (i.e., excludes loans held-for-sale).
HFS: Held-for-sale
HQLA: High-quality liquid assets. Consist of cash and certain high-quality liquid securities as defined in the LCR rule.
HTM: Held-to-maturity
IBOR: Interbank Offered Rate
ICG: Institutional Clients Group
ICRM: Independent Compliance Risk Management
IPO: Initial public offering
ISDA: International Swaps and Derivatives Association
KM: Key financial and non-financial metric used by management when evaluating consolidated and/or individual business results.
KPMG LLP: Citi’s Independent Registered Public Accounting Firm.
LATAM: Latin America, which for Citi, includes Mexico.
LCR: Liquidity coverage ratio. Represents HQLA divided by net outflows in the period.
LDA: Loss Distribution Approach
LGD: Loss given default
LIBOR: London Interbank Offered Rate
LLC: Limited Liability Company
LTD: Long-term debt
LTV: Loan-to-value. For residential real estate loans, the relationship, expressed as a percentage, between the principal amount of a loan and the appraised value of the collateral (i.e., residential real estate) securing the loan.
Master netting agreement: A single agreement with a counterparty that permits multiple transactions governed by that agreement to be terminated or accelerated and settled through a single payment in a single currency in the event of a default (e.g., bankruptcy, failure to make a required payment or securities transfer or deliver collateral or margin when due).
MBS: Mortgage-backed securities
MCA: Manager’s control assessment
MD&A: Management’s discussion and analysis
Measurement alternative: Measures equity securities without readily determinable fair values at cost less impairment (if any), plus or minus observable price changes from an identical or similar investment of the same issuer.
Moody’s: Moody’s Investor Services
MSRs: Mortgage servicing rights
N/A: Data is not applicable or available for the period presented.
NAA: Non-accrual assets. Consists of non-accrual loans and OREO.
NAL: Non-accrual loans. Loans for which interest income is not recognized on an accrual basis. Loans (other than credit card loans and certain consumer loans insured by U.S. government sponsored agencies) are placed on non-accrual status when full payment of principal and interest is not expected, regardless of delinquency status, or when principal and interest have been in default for a period of 90 days or more unless the loan is both well-secured and in the process of collection. Collateral-dependent loans are typically maintained on non-accrual status.
NAV: Net asset value
NCL(s): Net credit losses. Represents gross credit losses, less gross credit recoveries.
NCL ratio*: Represents net credit losses (recoveries) (annualized), divided by average loans for the reporting period.
Net Capital Rule: Rule 15c3-1 under the Securities Exchange Act of 1934.
Net interchange income: Includes the following components:
•    Interchange revenue: Fees earned from merchants based on Citi’s credit and debit card customers’ sales transactions.
•    Reward costs: The cost to Citi for points earned by cardholders enrolled in credit card rewards programs generally tied to sales transactions.
•    Partner payments: Payments to co-brand credit card partners based on the cost of loyalty program rewards earned by cardholders on credit card transactions.
NII: Net interest income. Represents total interest revenue, less total interest expenses.
NIM*: Net interest margin expressed as a yield percentage, calculated as annualized net interest income divided by average interest-earning assets for the period.
NIR: Non-interest revenues
NM: Not meaningful
Noncontrolling interests: The portion of an investment that has been consolidated by Citi that is not 100% owned by Citi.
Non-GAAP financial measure: Management uses these financial measures because it believes they provide information to enable investors to understand the underlying operational performance and trends of Citi and its businesses.
NSFR: Net Stable Funding Ratio
O/S: Outstanding
OCC: Office of the Comptroller of the Currency
OCI: Other comprehensive income (loss)
OREO: Other real estate owned
OTTI: Other-than-temporary impairment
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Over-the-counter cleared (OTC-cleared) derivatives: Derivative contracts that are negotiated and executed bilaterally, but subsequently settled via a central clearing house, such that each derivative counterparty is only exposed to the default of that clearing house.
Over-the-counter (OTC) derivatives: Derivative contracts that are negotiated, executed and settled bilaterally between two derivative counterparties, where one or both counterparties is a derivatives dealer.
Parent Company: Citigroup Inc.
Participating securities: Represents unvested share-based compensation awards containing nonforfeitable rights to dividends or dividend equivalents (collectively, “dividends”), which are included in the earnings per share calculation using the two-class method. Citi grants RSUs to certain employees under its share-based compensation programs, which entitle the recipients to receive non-forfeitable dividends during the vesting period on a basis equivalent to the dividends paid to holders of common stock. These unvested awards meet the definition of participating securities. Under the two-class method, all earnings (distributed and undistributed) are allocated to each class of common stock and participating securities, based on their respective rights to receive dividends.
PCD: Purchased credit-deteriorated assets are financial assets that as of the date of acquisition have experienced a more-than-insignificant deterioration in credit quality since origination, as determined by the Company.
PCI: Purchased credit-impaired loans represented certain loans that were acquired and deemed to be credit impaired on the acquisition date. The now superseded FASB guidance that allowed purchasers to aggregate credit-impaired loans acquired in the same fiscal quarter into one or more pools, provided that the loans had common risk characteristics (e.g., product type, LTV ratios).
PD: Probability of default
Principal transactions revenue: Primarily trading-related revenues predominantly generated by the ICG businesses. See Note 6 to the Consolidated Financial Statements.
Provisions: Provisions for credit losses and for benefits and claims.
PSUs: Performance share units
Real GDP: Real gross domestic product is the inflation-adjusted value of the goods and services produced by labor and property located in a country.
Regulatory VAR: Daily aggregated VAR calculated in accordance with regulatory rules.
REITs: Real estate investment trusts
Release: A net decrease in ACL through the provision for credit losses.
Reported basis: Financial statements prepared under U.S. GAAP.
Results of operations that exclude certain impacts from gains or losses on sale, or one-time charges*: Represents GAAP items, excluding the impact of gains or losses on sales, or one-time charges (e.g., the loss on sale related to the sale of Citi’s consumer banking business in Australia).
Results of operations that exclude the impact of FX translation*: Represents GAAP items, excluding the impact of FX translation, whereby the prior periods’ foreign currency balances are translated into U.S. dollars at the current periods’ conversion rates (also known as Constant dollar).
Retail services: Citi’s U.S. retail services cards business with a portfolio of co-brand and private label relationships (including, among others, The Home Depot, Sears, Best Buy and Macy’s).
ROA*: Return on assets. Represents net income (annualized), divided by average assets for the period.
ROCE*: Return on Common Equity. Represents net income less preferred dividends (both annualized), divided by average common equity for the period.
ROE: Return on equity. Represents net income less preferred dividends (both annualized), divided by average Citigroup equity for the period.
RoTCE*: Return on tangible common equity. Represents net income less preferred dividends (both annualized), divided by average tangible common equity for the period.
RSU(s): Restricted stock units
RWA: Risk-weighted assets. Basel III establishes two comprehensive approaches for calculating RWA (a Standardized approach and an Advanced approach), which include capital requirements for credit risk, market risk, and in the case of Basel III Advanced, also operational risk. Key differences in the calculation of credit risk RWA between the Standardized and Advanced approaches are that for Basel III Advanced, credit risk RWA is based on risk-sensitive approaches which largely rely on the use of internal credit models and parameters, whereas for Basel III Standardized, credit risk RWA is generally based on supervisory risk-weightings, which vary primarily by counterparty type and asset class. Market risk RWA is calculated on a generally consistent basis between Basel III Standardized and Basel III Advanced Approaches.
S&P: Standard and Poor’s Global Ratings
SCB: Stress Capital Buffer
SEC: The U.S. Securities and Exchange Commission
Securities financing agreements: Include resale, repurchase, securities borrowed and securities loaned agreements.
SLR: Supplementary leverage ratio. Represents Tier 1 Capital, divided by total leverage exposure.
SOFR: Secured Overnight Financing Rate
SPEs: Special purpose entities
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Structured notes: Financial instruments whose cash flows are linked to the movement in one or more indexes, interest rates, foreign exchange rates, commodities prices, prepayment rates, or other market variables. The notes typically contain embedded (but not separable or detachable) derivatives. Contractual cash flows for principal, interest or both can vary in amount and timing throughout the life of the note based on non-traditional indexes or non-traditional uses of traditional interest rates or indexes.
Tangible book value per share (TBVPS)*: Represents tangible common equity divided by EOP common shares outstanding.
Tangible common equity (TCE): Represents common stockholders’ equity less goodwill and identifiable intangible assets, other than MSRs.
Taxable-equivalent basis: Represents the total revenue, net of interest expense for the business, adjusted for revenue from investments that receive tax credits and the impact of tax-exempt securities. This metric presents results on a level comparable to taxable investments and securities.
Tax Reform: Tax Cuts and Jobs Act of 2017
TDR: Troubled debt restructuring. TDR is deemed to occur when the Company modifies the original terms of a loan agreement by granting a concession to a borrower that is experiencing financial difficulty. Loans with short-term and other insignificant modifications that are not considered concessions are not TDRs.
TLAC: Total loss-absorbing capacity
Total payout ratio*: Represents total common dividends declared plus common share repurchases as a percentage of net income available to common shareholders.
Transformation: Citi has embarked 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.
U.K.: United Kingdom
Unaudited: Financial statements and information that have not been subjected to auditing procedures sufficient to permit an independent certified public accountant to express an opinion.
USD: U.S. dollar
U.S.: United States of America
U.S. government agencies: U.S. government agencies include, but are not limited to, agencies such as Ginnie Mae and FHA, and do not include Fannie Mae and Freddie Mac, which are U.S. government-sponsored enterprises (U.S. GSEs). In general, obligations of U.S. government agencies are fully and explicitly guaranteed as to the timely payment of principal and interest by the full faith and credit of the U.S. government in the event of a default.
U.S. Treasury: U.S. Department of the Treasury
VAR: Value at risk. A measure of the dollar amount of potential loss from adverse market moves in an ordinary market environment.
VIEs: Variable interest entities
Wallet: Proportion of fee revenue based on estimates of investment banking fees generated across the industry (i.e., the revenue wallet) from investment banking transactions in M&A, equity and debt underwriting, and loan syndications.
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EXHIBIT INDEX
 
Exhibit
NumberDescription of Exhibit
4.09
328


4.11Indenture, dated as of March 15, 1987, between Primerica Corporation, a New Jersey corporation, and The Bank of New York, as trustee, incorporated by reference to Exhibit 4.01 to the Company’s Registration Statement on Form S-3 filed on December 8, 1992 (No.(File No. 03355542).
4.104.12First Supplemental Indenture, dated as of December 15, 1988, among Primerica Corporation, Primerica Holdings, Inc. and The Bank of New York, as trustee, incorporated by reference to Exhibit 4.02 to the Company’s Registration Statement on Form S-3 filed on December 8, 1992 (No.(File No. 03355542).

4.114.13Second Supplemental Indenture, dated as of January 31, 1991, between Primerica Holdings, Inc. and The Bank of New York, as trustee, incorporated by reference to Exhibit 4.03 to the Company’s Registration Statement on Form S-3 filed on December 8, 1992 (No.(File No. 03355542).
4.124.14Third Supplemental Indenture, dated as of December 9, 1992, among Primerica Holdings, Inc., Primerica Corporation and The Bank of New York, as trustee, incorporated by reference to Exhibit 5 to the Company’s Form 8-A dated December 21, 1992, with respect to its 7 3/4% Notes Due June 15, 1999 (No.(File No. 001-09924).
329



4.26Form of Amended and Restated Declaration of Trust for Citigroup Capital III (previously known as Travelers Capital III), incorporated by reference to Exhibit 4.8 to Travelers Group Inc.’s Registration Statement on Form S-3 (File No. 333-12439).


330




331



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 20192021 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.



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