--- ticker: C company: Citigroup Inc. filing_type: 10-K year_current: 2025 year_prior: 2024 risks_added: 9 risks_removed: 12 risks_modified: 77 risks_unchanged: 35 source: SEC EDGAR url: https://riskdiff.com/c/2025-vs-2024/ markdown_url: https://riskdiff.com/c/2025-vs-2024/index.md generated: 2026-06-01 --- # Citigroup Inc.: 10-K Risk Factor Changes 2025 vs 2024 > Source: U.S. Securities and Exchange Commission (EDGAR) > Generated: 2026-06-01 > All data extracted directly from official filings. No hallucinated content. ## Summary | Status | Count | |--------|-------| | New risks added | 9 | | Risks removed | 12 | | Risks modified | 77 | | Unchanged | 35 | --- ## New in Current Filing: NET ZERO AND SUSTAINABILITY This section summarizes Citi's net zero commitment, sustainable operations and sustainable finance goals. For information regarding Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. --- ## New in Current Filing: Sustainable Operations In addition to the 2030 net zero GHG emissions commitment for its own operations, Citi measures progress against operational footprint goals, which include efforts to reduce the environmental impact of its facilities through reductions in emissions, energy usage, water consumption and waste generation. In 2024, Citi made progress toward these goals by increasing on-site solar generation, promoting initiatives on waste diversion and recycling, and employing more carbon-efficient techniques for building renovations. --- ## New in Current Filing: Sustainable Finance Citi's $1 Trillion Sustainable Finance Goal, as previously disclosed, is an integrated effort across the organization to finance and facilitate $1 trillion in environmental and social finance activities with product and service offerings across multiple lines of business. --- ## New in Current Filing: Talent Management Citi is committed to a workforce consisting of the best talent from the broadest pools available to drive innovation and best serve its clients, customers and communities. --- ## New in Current Filing: Third Line of Defense: Internal Audit Internal Audit is independent of the first line, second line and enterprise support functions. The role of Internal Audit is to provide independent, objective, reliable, valued and timely assurance to the Board, its Audit Committee, Citi senior management and regulators over the effectiveness of governance, risk management and controls that mitigate current and evolving risks and enhance the control culture within Citi. The Citi Chief Auditor manages Internal Audit and reports functionally to the Chair of the Citi Audit Committee and administratively to Citi's CEO. The Citi Chief Auditor has unrestricted access to the Board and the Board Audit Committee to address risks and issues identified through Internal Audit's activities. --- ## New in Current Filing: 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: Total exposure December 31,2024September 30,2024December 31,2023Transportation and industrials20 %20 %21 %Technology, media and telecom12 12 12 Banks and finance companies(1)12 11 12 Consumer retail11 12 11 Real estate11 10 10 Commercial8 7 8 Residential3 3 2 Power, chemicals, metals and mining9 8 8 Energy and commodities6 6 7 Health5 5 5 Insurance4 5 4 Public sector4 4 3 Asset managers and funds3 3 3 Financial markets infrastructure2 3 3 Other industries1 1 1 Total100 %100 %100 % Banks and finance companies(1) (1) As of the periods in the table, Citi had less than 1% exposure to securities firms. See corporate credit portfolio by industry, below. 74 74 74 The following table details Citi's corporate credit portfolio by industry as of December 31, 2024: Non-investment gradeSelected metricsIn millions of dollarsTotal credit exposureFunded(1)UnfundedInvestment gradeNon-criticizedCriticized performingCriticized non-performing(2)30 days or more past due and accruingNet credit losses (recoveries)Credit derivative hedges(3)Transportation and industrials$144,381 $57,166 $87,215 $106,336 $32,849 $4,944 $252 $73 $19 $(7,643)Autos(4)50,266 23,427 26,839 40,758 8,591 909 8 3 4 (2,420)Transportation26,138 11,416 14,722 19,460 5,792 795 91 3 (7)(1,165)Industrials67,977 22,323 45,654 46,118 18,466 3,240 153 67 22 (4,058)Technology, media and telecom88,797 29,534 59,263 68,615 16,776 3,217 189 68 55 (6,720)Banks and finance companies86,500 56,716 29,784 76,754 8,625 882 239 7 5 (560)Consumer retail80,871 32,212 48,659 57,425 19,579 3,676 191 30 43 (5,423)Real estate74,481 53,186 21,295 61,430 8,976 3,545 530 6 173 (813)Commercial55,810 36,200 19,610 42,960 8,782 3,545 523 6 156 (813)Residential18,671 16,986 1,685 18,470 194 - 7 - 17 - Power, chemicals, metals and mining66,669 18,504 48,165 49,383 12,653 4,416 217 35 75 (5,267)Power32,185 5,092 27,093 27,204 4,414 417 150 1 48 (2,406)Chemicals20,618 7,529 13,089 12,747 5,034 2,779 58 33 28 (2,064)Metals and mining13,866 5,883 7,983 9,432 3,205 1,220 9 1 (1)(797)Energy and commodities(5)41,919 11,686 30,233 33,899 7,266 555 199 3 (5)(3,153)Health39,028 8,537 30,491 29,579 8,018 1,411 20 19 13 (3,267)Insurance28,317 2,115 26,202 26,734 1,560 17 6 2 - (4,089)Public sector26,022 13,209 12,813 23,344 2,308 360 10 28 7 (678)Asset managers and funds19,648 5,258 14,390 17,679 1,788 181 - - (4)(97)Financial markets infrastructure17,368 181 17,187 17,238 130 - - - - (29)Securities firms1,876 590 1,286 1,407 468 1 - - - (20)Other industries(6)7,213 4,733 2,480 4,979 2,099 114 21 42 16 (51)Total$723,090 $293,627 $429,463 $574,802 $123,095 $23,319 $1,874 $313 $397 $(37,810) Funded(1) --- ## New in Current Filing: Consumer Credit Portfolio The following table presents Citi's quarterly end-of-period consumer loans(1): In billions of dollars4Q231Q242Q243Q244Q24Wealth(2)(3)Mortgages(4)$89.9 $90.2 $92.0 $91.5 $89.0 Margin lending(5)29.4 27.3 27.6 28.1 29.4 Personal, small business and other(6)27.1 26.7 25.9 26.4 24.1 Cards5.0 4.7 4.9 5.0 5.0 Total$151.4 $148.9 $150.4 $151.0 $147.5 USPBBranded Cards$111.1 $108.0 $111.8 $112.1 $117.3 Retail Services53.6 50.8 51.7 51.6 53.8 Retail Banking44.4 45.6 46.2 49.4 50.6 Mortgages(4)39.9 41.0 41.4 44.4 45.5 Personal, small business and other4.5 4.6 4.8 5.0 5.1 Total$209.1 $204.4 $209.7 $213.1 $221.7 All Other - Legacy FranchisesMexico Consumer (excludes Mexico SBMM)$18.7 $19.6 $18.2 $17.4 $17.2 Asia Consumer(7)7.4 6.5 5.6 5.5 4.7 Legacy Holdings Assets(8)2.6 2.4 2.2 2.2 2.0 Total$28.7 $28.5 $26.0 $25.1 $23.9 Total consumer loans$389.2 $381.8 $386.1 $389.2 $393.1 --- ## New in Current Filing: Branded Cards USPB's Branded Cards portfolio consists of both proprietary Citi branded cards portfolios (Value, Rewards and Cash) and co-branded cards portfolios (including Costco and American Airlines). Citi's Branded Cards portfolio benefits from a diverse combination of products. Citi's proprietary cards provide customers with a suite of products with rewards, cash rebates and lending solutions, while co-branded cards provide significant affinity benefits through partnerships with large-scale partners across the airline, retail and telecom sectors. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Branded Cards was broadly stable quarter-over-quarter. The net credit loss rate increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. The 90+ days past due delinquency rate increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. 80 80 80 Retail ServicesUSPB's Retail Services partners directly with more than20 retailers and dealers to offer private label and co-brandedcards. Retail Services' target market focuses on select industrysegments such as home improvement, specialty retail,consumer electronics and fuel. Retail Services continuallyevaluates opportunities to add partners within target industriesthat have strong loyalty, lending or payment programs andgrowth potential.As presented in the chart above, the fourth quarter of 2024net credit loss rate in Retail Services increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15.Retail BankingUSPB's Retail Banking portfolio consists primarily ofconsumer mortgages (including home equity) and unsecuredlending products, such as small business loans and personalloans. The portfolio is generally delinquency managed, whereCiti evaluates credit risk based on FICO scores, delinquenciesand the value of underlying collateral. The consumermortgages in this portfolio have historically been extended tohigh credit quality customers, generally with loan-to-valueratios that are less than or equal to 80% on first and secondmortgages. For additional information, see "Loan-to-Value(LTV) Ratios" in Note 15.As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Banking increased quarter-over-quarter and year-over-year, primarily driven by consumer overdraft loans. The 90+ days past due delinquency rate was largely unchanged quarter-over-quarter and decreased year-over-year. The decrease was primarily driven by lower delinquencies in consumer mortgages.WealthWealth provides consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold businesses. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and credit cards. Retail ServicesUSPB's Retail Services partners directly with more than20 retailers and dealers to offer private label and co-brandedcards. Retail Services' target market focuses on select industrysegments such as home improvement, specialty retail,consumer electronics and fuel. Retail Services continuallyevaluates opportunities to add partners within target industriesthat have strong loyalty, lending or payment programs andgrowth potential.As presented in the chart above, the fourth quarter of 2024net credit loss rate in Retail Services increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15. --- ## New in Current Filing: Consumer loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(3) Unallocated portfolio-layer cumulative basis adjustments --- ## No Match in Current: Citi's Ability to Return Capital to Common Shareholders Substantially Depends on Regulatory Capital Requirements, Including the Results of the CCAR Process and Dodd-Frank Act Regulatory Stress Tests, and Other Factors. *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* 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 its regulatory capital requirements, including the annual recalibration of the Stress Capital Buffer (SCB), which is based upon the results of the CCAR process required by the FRB, and recalibration of the GSIB surcharge,as well as the supervisory expectations and assessments regarding individual institutions. The FRB's annual stress testing requirements are integrated into ongoing regulatory capital requirements. Citi's SCB equals the maximum projected decline in its CET1 Capital ratio under the supervisory severely adverse scenario over a nine-quarter CCAR measurement period, plus four quarters of planned common stock dividends as a percentage of Citi's risk-weighted assets, subject to a minimum requirement of 2.5%. The SCB is calculated by the FRB using its proprietary data and modeling of each firm's results. Accordingly, Citi's SCB may change annually, based on the supervisory stress test results, thus potentially resulting in variability in the calculation of Citi's required regulatory CET1 Capital ratio under the Standardized Approach. On October 1, 2023, Citi's required regulatory CET1 Capital ratio increased to 12.3% from 12% under the Standardized Approach, reflecting the increase in the SCB requirement to 4.3% from 4.0%. In addition, a breach of the SCB and other regulatory capital buffers may result in gradual limitations on capital distributions and discretionary bonus payments to executive officers. For additional information on the SCB, see "Capital Resources - Regulatory Capital Buffers" above. Moreover, changes in regulatory capital rules, requirements or interpretations could materially increase Citi's required regulatory capital. For example, the U.S. banking regulators have proposed a number of changes to the U.S. regulatory capital framework, including, but not limited to, significant revisions to the U.S. Basel III rules, known as the Basel III Endgame (capital proposal); changes to the method for calculating the GSIB surcharge; and changes to aspects of the total loss-absorbing capacity (TLAC) requirements. The capital proposal would replace the Advanced Approaches with a new Expanded Risk-based Approach for calculating risk- weighted assets. Under the capital proposal, a single capital buffer, including the SCB, would apply to a firm's risk-based capital ratios, regardless of whether the applicable ratios result from the Expanded Risk-based Approach or the Modified Standardized Approach. Additionally, the capital proposal would make various changes to the calculations of credit risk, market risk and operational risk components of risk-weighted assets (see "Capital Resources - Regulatory Capital Standards and Developments" above). All of these potential changes, if adopted as proposed, would likely materially impact Citi's regulatory capital position and substantially increase Citi's regulatory capital requirements, and thus adversely impact the extent to which Citi is able to return capital to shareholders.Citi's ability to return capital also depends on its results of operations and financial condition, including the capital impact related to its remaining divestitures, such as, among other things, any temporary capital impact from CTA losses (net of hedges) between transaction signings and closings (see the continued investments and the incorrect assumptions or estimates risk factors below); Citi's effectiveness in planning, managing and calculating its level of regulatory capital and risk-weighted assets under both the Advanced Approaches and the Standardized Approach, as well as the Supplementary Leverage ratio (SLR); its implementation and maintenance of an effective capital planning process and management framework; forecasts of macroeconomic conditions; and deferred tax asset (DTA) utilization (see the ability to utilize DTA risk factor below). The FRB could also limit or prohibit capital actions, such as paying or increasing dividends or repurchasing common stock due to macroeconomic disruptions or events, some of which occurred for a period of time during the COVID-19 pandemic.All firms subject to CCAR requirements, including Citi, will continue to be subject to a rigorous regulatory evaluation of capital planning practices and other reviews and examinations, including, but not limited to data quality, whichis a key regulatory focus, governance, risk management and internal controls. For example, the FRB has stated that it expects capital adequacy practices to continue to evolve and to likely be determined by its yearly 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 number and severity of the stress test scenarios, the FRB modeling of Citi's balance sheet, pre-provision net revenue and stress losses, and the addition of components deemed important by the FRB. Additionally, Citi's ability to return capital may be adversely impacted if a regulatory evaluation or examination results in negative findings regarding absolutecapital levels or other aspects of Citi's operations, including as a result of the imposition of additional capital buffers, limitations on capital distributions or otherwise. For information on limitations on Citi's ability to return capital to common shareholders, as well as the CCAR process, supervisory stress test requirements and GSIB surcharge, see "Capital Resources - Overview" and "Capital Resources - Stress Testing Component of Capital Planning" above and the risk management risk factor below. weighted assets. Under the capital proposal, a single capital buffer, including the SCB, would apply to a firm's risk-based capital ratios, regardless of whether the applicable ratios result from the Expanded Risk-based Approach or the Modified Standardized Approach. Additionally, the capital proposal would make various changes to the calculations of credit risk, market risk and operational risk components of risk-weighted assets (see "Capital Resources - Regulatory Capital Standards and Developments" above). All of these potential changes, if adopted as proposed, would likely materially impact Citi's regulatory capital position and substantially increase Citi's regulatory capital requirements, and thus adversely impact the extent to which Citi is able to return capital to shareholders. Citi's ability to return capital also depends on its results of operations and financial condition, including the capital impact related to its remaining divestitures, such as, among other things, any temporary capital impact from CTA losses (net of hedges) between transaction signings and closings (see the continued investments and the incorrect assumptions or estimates risk factors below); Citi's effectiveness in planning, managing and calculating its level of regulatory capital and risk-weighted assets under both the Advanced Approaches and the Standardized Approach, as well as the Supplementary Leverage ratio (SLR); its implementation and maintenance of an effective capital planning process and management framework; forecasts of macroeconomic conditions; and deferred tax asset (DTA) utilization (see the ability to utilize DTA risk factor below). The FRB could also limit or prohibit capital actions, such as paying or increasing dividends or repurchasing common stock due to macroeconomic disruptions or events, some of which occurred for a period of time during the COVID-19 pandemic. All firms subject to CCAR requirements, including Citi, will continue to be subject to a rigorous regulatory evaluation of capital planning practices and other reviews and examinations, including, but not limited to data quality, which is a key regulatory focus, governance, risk management and internal controls. For example, the FRB has stated that it expects capital adequacy practices to continue to evolve and to likely be determined by its yearly 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 number and severity of the stress test scenarios, the FRB modeling of Citi's balance sheet, pre-provision net revenue and stress losses, and the addition of components deemed important by the FRB. Additionally, Citi's ability to return capital may be adversely impacted if a regulatory evaluation or examination results in negative findings regarding absolute capital levels or other aspects of Citi's operations, including as a result of the imposition of additional capital buffers, limitations on capital distributions or otherwise. For information on limitations on Citi's ability to return capital to common shareholders, as well as the CCAR process, supervisory stress test requirements and GSIB surcharge, see "Capital Resources - Overview" and "Capital Resources - Stress Testing Component of Capital Planning" above and the risk management risk factor below. 49 49 49 In December 2023, the FRB announced that it will maintain its current framework for calculating allowances on loans in the supervisory stress test through the 2024 stress test cycle, while continuing to evaluate appropriate future enhancements to this framework. The impacts on Citi's capital adequacy of any potential incorporation by the FRB of CECL into its supervisory stress tests in future stress test cycles, and of other potential regulatory changes in the FRB's stress testing methodologies, remain unclear. For additional information regarding the CECL methodology, including the transition provisions related to the adverse regulatory capital effects resulting from adoption of the CECL methodology, see "Capital Resources - Current Regulatory Capital Standards - Regulatory Capital Treatment - Modified Transition of the Current Expected Credit Losses Methodology" above and Note 1.Although various uncertainties exist regarding the extent of, and the ultimate impact to Citi from, changes to regulatory capital, results from the FRB's stress testing and CCAR regimes, and regulatory evaluation or examination findings, these changes could increase the level of capital Citi is required or elects to hold, including as part of Citi's management buffer, thus potentially adversely impacting the extent to which Citi is able to return capital to shareholders.Citi Must Continually Review, Analyze and Successfully Adapt to Ongoing Regulatory and Legislative Uncertainties and Changes in the U.S. and Globally.Citi, its management and its businesses continue to face regulatory and legislative uncertainties and changes, both in the U.S. and globally. While the ongoing regulatory and legislative uncertainties and changes facing Citi are too numerous to list completely, examples include, but are not limited to (i) potential changes to various aspects of the U.S. regulatory capital framework and requirements applicable to Citi, including, among others, significant revisions to the U.S. Basel III rules, known as the Basel III Endgame (for information about the Basel III Endgame, see the capital return risk factor and "Capital Resources - Regulatory Capital Standards Developments" above); (ii) potential fiscal, monetary, tax, sanctions and other changes promulgated by the U.S. federal government and other governments, including potential changes in regulatory requirements relating to interest rate risk management; and (iii) rapidly evolving legislative and regulatory requirements and other government initiatives in the EU, the U.S. and globally related to climate change and other ESG areas that vary, and may conflict, across jurisdictions, including any new disclosure requirements (see the climate change and heightened regulatory scrutiny and ongoing interpretation of regulatory changes risk factors below). References to "regulatory" refer to both formal regulation and the views and expectations of Citi's regulators in their supervisory roles, which, as theychange over time, can have a major impact. In particular, theU.S. regulators have indicated that the level of theirexpectations is increasing and prompt negative examinationfindings/ratings and enforcements actions are more likely.For example, in February 2023, the Consumer Financial Protection Bureau (CFPB) proposed significant changes to the maximum amounts on credit card late fees, which, if adopted as proposed, would reduce credit card fee revenues in Branded Cards and Retail Services in USPB. In addition, 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 their scope, interpretation, timing, structure or approach, leading to inconsistent or even conflicting requirements, including within a single jurisdiction. Further, ongoing regulatory and legislative uncertainties and changes make Citi's long-term business, balance sheet and strategic budget planning difficult, subject to change and potentially more costly and may impact its results of operations. 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 must necessarily be based on possible or proposed rules or outcomes, which can change significantly 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 competitive position, as well as its businesses, results of operations and financial condition.Citi's Ability to Achieve Its Objectives from Its Transformation, Organizational, Simplification and Other Strategic and Other Initiatives May Not Be as Successful as It Projects or Expects.As part of its transformation initiatives, Citi continues to make significant investments to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" above and the legal and regulatory proceedings risk factor below). Citi also continues to make business-led investments, as part of the execution of its strategic initiatives. For example, Citi has been making investments across the Company, including hiring front office colleagues in key strategic markets and businesses; enhancing product capabilities and platforms to grow key businesses, improve client digital experiences and add scalability; and implementing new capabilities and partnerships. These business-led investments are designed to grow revenues as well as result in retention and efficiency improvements. Additionally, Citi has been pursuing overall simplification initiatives that include management and operating model changes and actions to enhance focus on clients and reduce expenses. Citi's simplification actions also include divestiture of the Mexico Consumer/SBMM operations and completing other exits and wind-downs in order to streamline Citi and assist in optimizing its allocation of resources. These overall simplification initiatives involve various execution challenges and may result in higher than expected expenses, litigation and regulatory scrutiny, CTA and other losses or other negative financial or strategic impacts, which could be material (for information about potential CTA impacts, see the capital In December 2023, the FRB announced that it will maintain its current framework for calculating allowances on loans in the supervisory stress test through the 2024 stress test cycle, while continuing to evaluate appropriate future enhancements to this framework. The impacts on Citi's capital adequacy of any potential incorporation by the FRB of CECL into its supervisory stress tests in future stress test cycles, and of other potential regulatory changes in the FRB's stress testing methodologies, remain unclear. For additional information regarding the CECL methodology, including the transition provisions related to the adverse regulatory capital effects resulting from adoption of the CECL methodology, see "Capital Resources - Current Regulatory Capital Standards - Regulatory Capital Treatment - Modified Transition of the Current Expected Credit Losses Methodology" above and Note 1.Although various uncertainties exist regarding the extent of, and the ultimate impact to Citi from, changes to regulatory capital, results from the FRB's stress testing and CCAR regimes, and regulatory evaluation or examination findings, these changes could increase the level of capital Citi is required or elects to hold, including as part of Citi's management buffer, thus potentially adversely impacting the extent to which Citi is able to return capital to shareholders.Citi Must Continually Review, Analyze and Successfully Adapt to Ongoing Regulatory and Legislative Uncertainties and Changes in the U.S. and Globally.Citi, its management and its businesses continue to face regulatory and legislative uncertainties and changes, both in the U.S. and globally. While the ongoing regulatory and legislative uncertainties and changes facing Citi are too numerous to list completely, examples include, but are not limited to (i) potential changes to various aspects of the U.S. regulatory capital framework and requirements applicable to Citi, including, among others, significant revisions to the U.S. Basel III rules, known as the Basel III Endgame (for information about the Basel III Endgame, see the capital return risk factor and "Capital Resources - Regulatory Capital Standards Developments" above); (ii) potential fiscal, monetary, tax, sanctions and other changes promulgated by the U.S. federal government and other governments, including potential changes in regulatory requirements relating to interest rate risk management; and (iii) rapidly evolving legislative and regulatory requirements and other government initiatives in the EU, the U.S. and globally related to climate change and other ESG areas that vary, and may conflict, across jurisdictions, including any new disclosure requirements (see the climate change and heightened regulatory scrutiny and ongoing interpretation of regulatory changes risk factors below). References to "regulatory" refer to both formal regulation and the views and expectations of Citi's regulators in their supervisory roles, which, as theychange over time, can have a major impact. In particular, theU.S. regulators have indicated that the level of theirexpectations is increasing and prompt negative examinationfindings/ratings and enforcements actions are more likely.For example, in February 2023, the Consumer Financial Protection Bureau (CFPB) proposed significant changes to the maximum amounts on credit card late fees, which, if adopted In December 2023, the FRB announced that it will maintain its current framework for calculating allowances on loans in the supervisory stress test through the 2024 stress test cycle, while continuing to evaluate appropriate future enhancements to this framework. The impacts on Citi's capital adequacy of any potential incorporation by the FRB of CECL into its supervisory stress tests in future stress test cycles, and of other potential regulatory changes in the FRB's stress testing methodologies, remain unclear. For additional information regarding the CECL methodology, including the transition provisions related to the adverse regulatory capital effects resulting from adoption of the CECL methodology, see "Capital Resources - Current Regulatory Capital Standards - Regulatory Capital Treatment - Modified Transition of the Current Expected Credit Losses Methodology" above and Note 1. Although various uncertainties exist regarding the extent of, and the ultimate impact to Citi from, changes to regulatory capital, results from the FRB's stress testing and CCAR regimes, and regulatory evaluation or examination findings, these changes could increase the level of capital Citi is required or elects to hold, including as part of Citi's management buffer, thus potentially adversely impacting the extent to which Citi is able to return capital to shareholders. --- ## No Match in Current: A Ratings Downgrade Could Adversely Impact Citi's Funding and Liquidity. *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* The credit rating agencies, such as Fitch Ratings, Moody's Investors Service and S&P Global Ratings, continuously evaluate Citi and certain of its subsidiaries. Their ratings of Citi and its rated subsidiaries' long-term debt and short-term obligations are based on firm-specific factors, including the financial strength of Citi and such subsidiaries, 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, potential impact from negative actions on U.S. sovereign ratings and conditions affecting the financial services industry and markets generally. Citi and its subsidiaries may not be able to maintain their current respective ratings and outlooks. Rating downgrades could negatively impact Citi and its rated subsidiaries' ability to access the capital markets and other sources of funds as well as increase credit spreads and the costs of those funds. A ratings downgrade could also have a negative impact on Citi and its rated subsidiaries' ability to obtain funding and liquidity due to reduced funding capacity and the impact from derivative triggers, which could require Citi and its rated subsidiaries to meet cash obligations and collateral requirements or permit counterparties to terminate certain contracts. 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. Furthermore, a credit ratings downgrade could have impacts that may not be currently known to Citi or are not possible to quantify. Some of Citi's counterparties and clients could have ratings limitations on their permissible counterparties, of which Citi may or may not be aware. 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 market instruments, and limit or withdraw deposits placed 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. --- ## No Match in Current: Introduction *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* This section summarizes Citi's Operational Footprint goals and Net Zero commitment. Citi's annual ESG Report provides information on a broad set of ESG-related efforts. The upcoming Citi Climate Report, formerly named the Task Force on Climate-Related Financial Disclosures (TCFD) Report, provides information on Citi's continued progress to manage climate risk and its Net Zero plan, including information on financed emissions and 2030 interim emissions reduction targets. For information regarding Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. --- ## No Match in Current: ESG and Climate-Related Governance *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* Citi's Board of Directors (Board) provides oversight of Citi's management activities (see "Managing Global Risk - Risk Governance" below). •The Nomination, Governance and Public Affairs Committee of the Board provides oversight and receives updates on Citi's environmental and social policies and commitments. •The Risk Management Committee of the Board provides oversight of Citi's Risk Management Framework and risk culture and reviews Citi's key risk policies and frameworks, including receiving climate risk-related updates. •The Audit Committee of the Board provides oversight of controls and procedures pertaining to the ESG-related metrics and related disclosures in Citi's SEC filed reports and group-level voluntary ESG reporting, as well as management's evaluation of the effectiveness of Citi's disclosure controls and procedures for group-level ESG reporting. Additionally, Citi's ESG Council consists of senior members of the management team and certain subject matter experts who provide oversight of Citi's ESG goals and activities. --- ## No Match in Current: Net Zero Emissions by 2050 *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* As previously disclosed, Citi has committed to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its own operations by 2030; both are significant targets given the size and breadth of Citi's lending portfolios, businesses and operational footprint. Citi's Net Zero plan includes: •Net Zero Metrics and Target Setting: Calculate metrics and assess targets for carbon-intensive sectors •Client Engagement and Assessment: Seek to understand client GHG emissions and transition plans and advise on capacity building •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 risk appetite and thresholds and policies related to Climate Risk Management •Clean Technology and Transition Finance: Support existing and, where possible, new technologies to accelerate commercialization and provide transition advisory and finance products and services •Portfolio Management: Active portfolio management of Citi financings to align with net zero targets, including considerations of transition measures taken by clients •Public Policy and Regulatory Engagement: Contribute to an enabling public policy and regulatory environment which is essential to stimulating demand for clean technologies and helping ensure a responsible transition Progress on Citi's Net Zero plan: •Citi has published interim 2030 emissions targets for six loan portfolios: auto manufacturing, commercial real estate (North America), energy, power, steel and thermal coal mining. •Citi has developed a client transition assessment process to help internal teams better understand the alignment of clients' strategies with transition or decarbonization pathways applicable to their respective sectors. In 2022-2023, Citi completed the initial assessment process for energy and power clients, and in 2023 began the transition assessment process for auto manufacturing and steel clients. The assessment process focuses on clients with material emissions relative to each sector's baseline emission profiles. --- ## No Match in Current: Operational Footprint Goals *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* Citi measures progress against operational footprint goals, which include efforts to reduce the environmental impact of its facilities through reductions in emissions, energy, water consumption and waste generation. Citi's efforts to integrate sustainable practices include sustainable building certifications, renewable electricity sourcing, employee engagement and seeking opportunities for efficiency in business travel. In 2023, Citi made progress toward these goals by increasing on-site solar generation, promoting initiatives on waste diversion and recycling, mapping weather- 62 62 62 related risk at its facilities and employing carbon-reduction techniques for building renovations. Additional InformationFor additional information on Citi's environmental and social policies and priorities, click on "Our Impact" on Citi's website at www.citigroup.com. For information on Citi's ESG and Sustainability (including climate change) governance, see Citi's 2024 Annual Meeting Proxy Statement to be filed with the SEC in March 2024.Citi's climate reporting and any other ESG-related reports and information included elsewhere on Citi's website are not incorporated by reference into, and do not form any part of, this 2023 Annual Report on Form 10-K. related risk at its facilities and employing carbon-reduction techniques for building renovations. Additional InformationFor additional information on Citi's environmental and social policies and priorities, click on "Our Impact" on Citi's website at www.citigroup.com. For information on Citi's ESG and Sustainability (including climate change) governance, see Citi's 2024 Annual Meeting Proxy Statement to be filed with the SEC in March 2024.Citi's climate reporting and any other ESG-related reports and information included elsewhere on Citi's website are not incorporated by reference into, and do not form any part of, this 2023 Annual Report on Form 10-K. related risk at its facilities and employing carbon-reduction techniques for building renovations. --- ## No Match in Current: Independent Compliance Risk Management *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* The ICRM organization actively oversees compliance risk across Citi, sets compliance standards for the first line of defense to manage compliance risk and promotes business conduct and activity that is consistent with Citi's Mission and Value Proposition and the compliance risk appetite. Citi's objective is to embed an enterprise-wide compliance risk management framework and culture that identifies, measures, monitors, controls and escalates compliance risk across Citi. ICRM is aligned by product line, function and geography to provide compliance risk management advice and credible challenge on day-to-day matters and strategic decision-making for key initiatives. ICRM also has program-level Enterprise Compliance units responsible for setting standards and establishing priorities for program-related compliance efforts. The CCO reports to Citi's General Counsel and ICRM is organizationally part of the Global Legal Affairs & Compliance group. In addition, the CCO has matrix reporting into the CRO and is part of the Risk Management Executive Council. --- ## No Match in Current: All Other(1) *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* (1)See footnote 2 to the table in "Credit Risk - Consumer Credit - Consumer Credit Portfolio" below. End-of-period loans increased 5% year-over-year, largely reflecting growth in cards in USPB. End-of-period loans increased 3% sequentially. On an average basis, loans increased 3% year-over-year and 2% sequentially. The year-over-year increase was largely due to growth in USPB, Services and Markets, partially offset by a decline in Banking. As of the fourth quarter of 2023, average loans for: •USPB increased 12% year-over-year, driven by growth in Branded Cards, Retail Banking and Retail Services. •Wealth were largely unchanged. •Services increased 6% year-over-year, primarily driven by strong demand for working capital loans in TTS in North America and internationally. •Markets increased 4% year-over-year, reflecting increased client demand in warehouse lending. •Banking decreased 9% year-over-year, primarily driven by capital optimization efforts. 69 69 69 CORPORATE CREDITConsistent with its overall strategy, Citi's corporate clients are typically corporations that value the depth and breadth of Citi's global network. Citi aims to establish relationships with these clients whose needs encompass multiple products, including cash management and trade services, foreign exchange, lending, capital markets and M&A advisory. CORPORATE CREDITConsistent with its overall strategy, Citi's corporate clients are typically corporations that value the depth and breadth of Citi's global network. Citi aims to establish relationships with these clients whose needs encompass multiple products, including cash management and trade services, foreign exchange, lending, capital markets and M&A advisory. --- ## No Match in Current: Portfolio Mix - Industry *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* Citi's corporate credit portfolio is diversified by industry. The following table details the allocation of Citi's total corporate credit portfolio by industry: Total exposure December 31,2023September 30,2023December 31,2022Transportation and industrials21 %21 %20 %Technology, media and telecom12 12 12 Banks and finance companies(1)12 10 10 Consumer retail11 12 11 Real estate10 10 10 Commercial8 8 8 Residential2 2 2 Power, chemicals, metals and mining8 9 9 Energy and commodities7 7 7 Health5 5 6 Insurance4 4 4 Public sector3 3 3 Asset managers and funds3 3 5 Financial markets infrastructure3 3 2 Other industries1 1 1 Total100 %100 %100 % Banks and finance companies(1) (1) As of the periods in the table, Citi had less than 1% exposure to securities firms. See corporate credit portfolio by industry, below. 71 71 71 The following table details Citi's corporate credit portfolio by industry as of December 31, 2023: Non-investment gradeSelected metricsIn millions of dollarsTotal credit exposureFunded(1)UnfundedInvestment gradeNon-criticizedCriticized performingCriticized non-performing(2)30 days or more past due and accruingNet credit losses (recoveries)Credit derivative hedges(3)Transportation and industrials$149,429 $59,917 $89,512 $118,380 $26,345 $4,469 $235 $125 $39 $(7,060)Autos(4)49,443 22,843 26,600 43,008 5,376 999 60 7 19 (2,304)Transportation28,448 11,996 16,452 21,223 6,208 952 65 3 5 (1,185)Industrials71,538 25,078 46,460 54,149 14,761 2,518 110 115 15 (3,571)Technology, media and telecom84,409 29,832 54,577 67,077 13,637 3,212 483 112 56 (5,546)Banks and finance companies83,512 52,569 30,943 74,364 7,768 1,277 103 7 37 (638)Consumer retail81,799 33,548 48,251 63,017 15,259 3,342 181 130 57 (5,360)Real estate72,827 51,660 21,167 61,226 7,084 3,602 915 69 31 (608)Commercial54,843 35,058 19,785 43,340 7,042 3,602 859 69 31 (608)Residential17,984 16,602 1,382 17,886 42 - 56 - - - Power, chemicals, metals and mining59,572 19,004 40,568 46,551 10,098 2,696 227 36 4 (4,884)Power24,535 5,220 19,315 20,967 3,200 209 159 1 4 (2,280)Chemicals21,963 8,287 13,676 16,418 3,888 1,613 44 34 1 (2,019)Metals and mining13,074 5,497 7,577 9,166 3,010 874 24 1 (1)(585)Energy and commodities(5)46,290 12,606 33,684 40,081 5,528 543 138 5 (15)(3,090)Health36,230 9,135 27,095 30,099 4,871 1,098 162 16 22 (3,023)Insurance27,216 2,390 24,826 25,580 1,607 29 - 7 - (4,516)Public sector24,736 12,621 12,115 21,845 2,399 479 13 36 15 (1,092)Asset managers and funds19,681 4,232 15,449 17,826 1,723 112 20 4 - (65)Financial markets infrastructure18,705 156 18,549 18,705 - - - - - (7)Securities firms1,737 734 1,003 870 822 45 - 2 - (2)Other industries(6)6,992 4,480 2,512 5,079 1,629 257 27 45 4 (6)Total$713,135 $292,884 $420,251 $590,700 $98,770 $21,161 $2,504 $594 $250 $(35,897) Funded(1) --- ## No Match in Current: Consumer Credit Portfolio *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* The following table presents Citi's quarterly end-of-period consumer loans(1): In billions of dollars4Q221Q232Q233Q234Q23USPBBranded Cards$100.2 $97.1 $103.0 $105.2 $111.1 Retail Services50.5 48.4 50.0 50.5 53.6 Retail Banking37.1 39.2 41.5 43.1 44.4 Mortgages(2)33.4 35.3 37.4 38.8 39.9 Personal, small business and other3.7 3.9 4.1 4.3 4.5 Total$187.8 $184.7 $194.5 $198.8 $209.1 Wealth(3)(4)Mortgages(2)$84.0 $85.2 $87.0 $88.8 $89.9 Margin lending(5)28.9 29.3 29.6 28.7 29.4 Personal, small business and other(6)31.7 31.0 29.4 28.5 27.2 Cards4.6 4.4 4.5 4.6 5.0 Total$149.2 $149.9 $150.5 $150.6 $151.5 All Other - Legacy FranchisesMexico Consumer (excludes Mexico SBMM)$14.8 $16.3 $17.8 $17.8 $18.7 Asia Consumer(7)13.3 10.0 9.1 8.0 7.4 Legacy Holdings Assets(8)3.0 2.8 2.7 2.5 2.5 Total$31.1 $29.1 $29.6 $28.3 $28.6 Total consumer loans$368.1 $363.7 $374.6 $377.7 $389.2 Mortgages(2) --- ## No Match in Current: Branded Cards *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* USPB's Branded Cards portfolio includes proprietary and co-branded cards. As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in Branded Cards increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment. --- ## No Match in Current: Consumer non-accrual loans(1) *This section from the 2024 filing does not have a high-confidence textual match in 2025. It may have been removed, merged, or substantially reworded.* Asia Consumer(5) Legacy Holdings Assets (consumer) (1)Corporate loans are placed on non-accrual status based on a review by Citigroup's risk officers. Corporate non-accrual loans may still be current on interest payments. With limited exceptions, the following practices are applied for consumer loans: consumer loans, excluding credit cards and mortgages, are placed on non-accrual status at 90 days past due and are charged off at 120 days past due; residential mortgage loans are placed on non-accrual status at 90 days past due and written down to net realizable value at 180 days past due. Consistent with industry conventions, Citigroup generally accrues interest on credit card loans until such loans are charged off, which typically occurs at 180 days contractual delinquency. As such, the non-accrual loan disclosures do not include credit card loans. The balances above represent non-accrual loans within Corporate loans and Consumer loans on the Consolidated Balance Sheet. (2)Approximately 50%, 50%, 56%, 64% and 44% of Citi's corporate non-accrual loans remain current on interest and principal payments at December 31, 2023, 2022, 2021, 2020 and 2019, respectively. (3)The December 31, 2023 total corporate non-accrual loans represented 0.63% of total corporate loans. (4)The increase at December 31, 2023 was primarily related to two commercial real estate loans. (5) Asia Consumer includes balances in Poland and Russia for all periods presented and in Bahrain for December 31, 2021, 2020 and 2019. Modified Loans to Borrowers Experiencing Financial DifficultyOn January 1, 2023, Citi adopted ASU 2022-02, which eliminated the accounting and disclosure requirements for TDRs (see Note 1). See Note 15 for information on loan modifications during the year ended December 31, 2023. Modified Loans to Borrowers Experiencing Financial DifficultyOn January 1, 2023, Citi adopted ASU 2022-02, which eliminated the accounting and disclosure requirements for TDRs (see Note 1). See Note 15 for information on loan modifications during the year ended December 31, 2023. --- ## Modified: CONSUMER CREDIT **Key changes:** - Reworded sentence: "USPB provides credit cards, consumer mortgages, personal loans, small business banking and retail banking, and Wealth offers wealth management lending and other products globally that range from the affluent to ultra-high net worth customer segments through the Private Bank, Wealth at Work and Citigold." - Reworded sentence: "All Other - Legacy Franchises also provides such products in its remaining markets through Mexico Consumer and Asia Consumer (Korea, Poland and Russia)." **Prior (2024):** Citi's consumer credit risk management framework is designed for a variety of environments. Underwriting and portfolio management policies are calibrated based on risk-return trade-offs by product and segment and changes are made based on performance against benchmarks as well as environmental stress. As warranted, Citi adjusts underwriting criteria to address consumer credit risks and macroeconomic challenges and uncertainties. USPB provides credit cards, mortgages, personal loans, small business banking and retail banking, and Wealth offers wealth management lending and other products globally that range from the affluent to ultra-high net worth customer segments through the Private Bank, Wealth at Work and Citigold. USPB's retail banking products include a generally prime portfolio built through well-defined lending parameters within Citi's risk appetite framework. All Other - Legacy Franchises also provides such products in its remaining markets through Mexico Consumer and Asia Consumer (Korea, Poland, China and Russia). All Other - Legacy Franchises also provides such products in its remaining markets through Mexico Consumer and Asia Consumer (Korea, Poland, China and Russia). **Current (2025):** Citi's consumer credit risk management framework is designed for a variety of environments. Underwriting and portfolio management policies are calibrated based on risk-return trade-offs by product and segment and changes are made based on performance against benchmarks as well as environmental stress. As warranted, Citi adjusts underwriting criteria to address consumer credit risks and macroeconomic challenges and uncertainties. USPB provides credit cards, consumer mortgages, personal loans, small business banking and retail banking, and Wealth offers wealth management lending and other products globally that range from the affluent to ultra-high net worth customer segments through the Private Bank, Wealth at Work and Citigold. USPB's retail banking products include a generally prime portfolio built through well-defined lending parameters within Citi's risk appetite framework. All Other - Legacy Franchises also provides such products in its remaining markets through Mexico Consumer and Asia Consumer (Korea, Poland and Russia). USPB provides credit cards, consumer mortgages, personal loans, small business banking and retail banking, and Wealth offers wealth management lending and other products globally that range from the affluent to ultra-high net worth customer segments through the Private Bank, Wealth at Work and Citigold. USPB's retail banking products include a generally prime portfolio built through well-defined lending parameters within Citi's risk appetite framework. All Other - Legacy Franchises also provides such products in its remaining markets through Mexico Consumer and Asia Consumer (Korea, Poland and Russia). --- ## Modified: and Capital **Key changes:** - Reworded sentence: "As of December 31, 2024, Citi estimates that an unanticipated parallel instantaneous 5% appreciation of the U.S." - Reworded sentence: "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 compared to an unanticipated parallel shock, as described above.The effect of Citi's ongoing management strategies with respect to quarterly changes in foreign exchange rates (versus the U.S." - Added sentence: "denominated in those same currencies." - Reworded sentence: "The effect of Citi's ongoing management strategies with respect to quarterly changes in foreign exchange rates (versus the U.S." - Reworded sentence: "For the quarter endedIn millions of dollarsDec." **Prior (2024):** As of December 31, 2023, Citi estimates that an unanticipated parallel instantaneous 5% appreciation of the U.S. dollar against all of the other currencies in which Citi has invested capital could reduce Citi's tangible common equity (TCE) by approximately $1.7 billion, or 1.0%, as a result of changes to Citi's CTA in AOCI, net of hedges. This impact would be primarily due to changes in the value of the Mexican peso, Euro, Singapore dollar and Indian rupee. This impact is also before any mitigating actions Citi may take, including ongoing management of its foreign currency translation exposure. Specifically, as currency movements change the value of Citi's net investments in foreign currency-denominated capital, these movements also change the value of Citi's risk-weighted assets denominated in those currencies. This, coupled with Citi's foreign currency hedging strategies, such as foreign currency borrowings, foreign currency forwards and other currency hedging instruments, lessens the impact of foreign currency movements on Citi's CET1 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 compared to an unanticipated parallel shock, as described above.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 CET1 Capital ratio, are presented in the table below. See Note 21 for additional information on the changes in AOCI. 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 CET1 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 compared to an unanticipated parallel shock, as described above. 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 CET1 Capital ratio, are presented in the table below. See Note 21 for additional information on the changes in AOCI. For the quarter endedIn millions of dollars, except as otherwise notedDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Change in FX spot rate(1)3.2 %(2.5)%4.0 %Change in TCE due to FX translation, net of hedges$960 $(1,314)$1,193 As a percentage of TCE0.6 %(0.8)%0.8 %Estimated impact to CET1 Capital ratio (on a fully implemented basis) due to changes in FX translation, net of hedges (bps)1 (1)(3) Change in FX spot rate(1) (1) FX spot rate change is a weighted average based on Citi's quarterly average GAAP capital exposure to foreign countries. 103 103 103 **Current (2025):** As of December 31, 2024, 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%, as a result of changes to Citi's CTA in AOCI, net of hedges. This reduction in the TCE would be primarily driven by depreciation in the value of the euro, Mexican peso and Indian rupee. This reduction in the TCE does not reflect any mitigating actions Citi may take, including ongoing management of its foreign currency translation exposure. TCE is used as a simplified metric to manage CET1 capital ratio volatility. 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 RWA denominated in those same 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 CET1 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 compared to an unanticipated parallel shock, as described above.The effect of Citi's ongoing management strategies with respect to quarterly changes in foreign exchange rates (versus the U.S. dollar), and the quarterly impact of these changes on Citi's TCE and CET1 Capital ratio, are presented in the table below. See Note 21 for additional information on the changes in AOCI. denominated in those same 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 CET1 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 compared to an unanticipated parallel shock, as described above. The effect of Citi's ongoing management strategies with respect to quarterly changes in foreign exchange rates (versus the U.S. dollar), and the quarterly impact of these changes on Citi's TCE and CET1 Capital ratio, are presented in the table below. See Note 21 for additional information on the changes in AOCI. For the quarter endedIn millions of dollarsDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Change in FX spot rate(1)(6.1)%2.5 %3.2 %Change in TCE due to FX translation, net of hedges$(2,465)$421 $960 As a percentage of TCE(1.5)%0.2 %0.6 % Change in FX spot rate(1) (1) FX spot rate change is a weighted average based on Citi's quarterly average GAAP capital exposure to foreign countries. A negative change in FX spot rate represents foreign currency depreciation versus the U.S. dollar. 105 105 105 --- ## Modified: Portfolio Mix - Geography and Counterparty **Key changes:** - Reworded sentence: "The following table presents the percentages of this portfolio across North America and the clusters within International, based on Citi's internal management geography (see "Other Risks - Country Risk - Top 25 Country Exposures" below): December 31,2024September 30,2024December 31,2023North America56 %57 %56 %International44 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)United Kingdom11 %11 %10 %Japan, Asia North and Australia (JANA)7 7 7 LATAM6 6 8 Asia South5 5 5 Europe12 11 11 Middle East and Africa (MEA)3 3 3 The maintenance of accurate and consistent risk ratings across the corporate credit portfolio facilitates the comparison of credit exposure across all lines of business, geographies and products." - Reworded sentence: "Internal ratings that generally correspond to BBB and above are considered investment grade, while those below are considered non-investment grade.The following table presents the corporate credit portfolio by facility risk rating as a percentage of the total corporate credit portfolio: Total exposure December 31,2024September 30,2024December 31,2023AAA/AA/A49 %49 %50 %BBB30 33 33 BB/B19 17 16 CCC or below2 1 1 Total100 %100 %100 %Note: Total exposure includes direct outstandings and unfunded lending commitments." - Reworded sentence: "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.Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2024." - Reworded sentence: "Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2024." - Reworded sentence: "In addition, appetite per obligor is reduced consistent with the ratings, and downgrades may result in the purchase of additional credit derivatives or other risk/structural mitigants to hedge the incremental credit risk, or may result in Citi seeking to reduce exposure to an obligor or an industry sector." **Prior (2024):** Citi's corporate credit portfolio is diverse across geography and counterparty. The following table presents the percentage of this portfolio by region based on Citi's internal management geography: December 31,2023September 30,2023December 31,2022North America56 %56 %56 %International44 44 44 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 internal risk ratings are derived by leveraging validated statistical models and scorecards in combination with consideration of factors specific to the obligor or market, such as management experience, competitive position, regulatory environment 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. The following table presents the corporate credit portfolio by facility risk rating as a percentage of the total corporate credit portfolio: Total exposure December 31,2023September 30,2023December 31,2022AAA/AA/A50 %49 %50 %BBB33 34 34 BB/B16 15 14 CCC or below1 2 2 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. The following table presents the corporate credit portfolio by facility risk rating as a percentage of the total corporate credit portfolio: Total exposure December 31,2023September 30,2023December 31,2022AAA/AA/A50 %49 %50 %BBB33 34 34 BB/B16 15 14 CCC or below1 2 2 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. 70 70 70 Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2023. 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, appetite per obligor is reduced consistent with the ratings, and downgrades may result in the purchase of additional credit derivatives or other risk/structural 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 incorporated into all risk assessments.See Note 15 for additional information on Citi's corporate credit portfolio.Portfolio Mix - IndustryCiti's corporate credit portfolio is diversified by industry. The following table details the allocation of Citi's total corporate credit portfolio by industry: Total exposure December 31,2023September 30,2023December 31,2022Transportation and industrials21 %21 %20 %Technology, media and telecom12 12 12 Banks and finance companies(1)12 10 10 Consumer retail11 12 11 Real estate10 10 10 Commercial8 8 8 Residential2 2 2 Power, chemicals, metals and mining8 9 9 Energy and commodities7 7 7 Health5 5 6 Insurance4 4 4 Public sector3 3 3 Asset managers and funds3 3 5 Financial markets infrastructure3 3 2 Other industries1 1 1 Total100 %100 %100 %(1) As of the periods in the table, Citi had less than 1% exposure to securities firms. See corporate credit portfolio by industry, below. Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2023. 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, appetite per obligor is reduced consistent with the ratings, and downgrades may result in the purchase of additional credit derivatives or other risk/structural 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 incorporated into all risk assessments.See Note 15 for additional information on Citi's corporate credit portfolio. Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2023. 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, appetite per obligor is reduced consistent with the ratings, and downgrades may result in the purchase of additional credit derivatives or other risk/structural 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 incorporated into all risk assessments. See Note 15 for additional information on Citi's corporate credit portfolio. Portfolio Mix - IndustryCiti's corporate credit portfolio is diversified by industry. The following table details the allocation of Citi's total corporate credit portfolio by industry: Total exposure December 31,2023September 30,2023December 31,2022Transportation and industrials21 %21 %20 %Technology, media and telecom12 12 12 Banks and finance companies(1)12 10 10 Consumer retail11 12 11 Real estate10 10 10 Commercial8 8 8 Residential2 2 2 Power, chemicals, metals and mining8 9 9 Energy and commodities7 7 7 Health5 5 6 Insurance4 4 4 Public sector3 3 3 Asset managers and funds3 3 5 Financial markets infrastructure3 3 2 Other industries1 1 1 Total100 %100 %100 %(1) As of the periods in the table, Citi had less than 1% exposure to securities firms. See corporate credit portfolio by industry, below. **Current (2025):** Citi's corporate credit portfolio is diverse across geography and counterparty. The following table presents the percentages of this portfolio across North America and the clusters within International, based on Citi's internal management geography (see "Other Risks - Country Risk - Top 25 Country Exposures" below): December 31,2024September 30,2024December 31,2023North America56 %57 %56 %International44 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)United Kingdom11 %11 %10 %Japan, Asia North and Australia (JANA)7 7 7 LATAM6 6 8 Asia South5 5 5 Europe12 11 11 Middle East and Africa (MEA)3 3 3 The maintenance of accurate and consistent risk ratings across the corporate credit portfolio facilitates the comparison of credit exposure across all lines of business, geographies and products. Counterparty risk ratings reflect an estimated probability of default for a counterparty, and internal risk ratings are derived by leveraging validated statistical models and scorecards in combination with consideration of factors specific to the obligor or market, such as management experience, competitive position, regulatory environment 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 ratings that generally correspond to BBB and above are considered investment grade, while those below are considered non-investment grade.The following table presents the corporate credit portfolio by facility risk rating as a percentage of the total corporate credit portfolio: Total exposure December 31,2024September 30,2024December 31,2023AAA/AA/A49 %49 %50 %BBB30 33 33 BB/B19 17 16 CCC or below2 1 1 Total100 %100 %100 %Note: Total exposure includes direct outstandings and unfunded lending commitments. The maintenance of accurate and consistent risk ratings across the corporate credit portfolio facilitates the comparison of credit exposure across all lines of business, geographies and products. Counterparty risk ratings reflect an estimated probability of default for a counterparty, and internal risk ratings are derived by leveraging validated statistical models and scorecards in combination with consideration of factors specific to the obligor or market, such as management experience, competitive position, regulatory environment 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 ratings that generally correspond to BBB and above are considered investment grade, while those below are considered non-investment grade. The following table presents the corporate credit portfolio by facility risk rating as a percentage of the total corporate credit portfolio: Total exposure December 31,2024September 30,2024December 31,2023AAA/AA/A49 %49 %50 %BBB30 33 33 BB/B19 17 16 CCC or below2 1 1 Total100 %100 %100 % Note: Total exposure includes direct outstandings and unfunded lending commitments. 73 73 73 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.Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2024. Citi has applied management judgment 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 observed. 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, appetite per obligor is reduced consistent with the ratings, and downgrades may result in the purchase of additional credit derivatives or other risk/structural mitigants to hedge the incremental credit risk, or may result in Citi seeking to reduce exposure to an obligor or an industry sector. Citi will continue to review exposures to ensure that the appropriate probability of default is incorporated into all risk assessments.See Note 15 for additional information on Citi's corporate credit portfolio.Portfolio Mix - IndustryCiti's corporate credit portfolio is diversified by industry. The following table details the allocation of Citi's total corporate credit portfolio by industry: Total exposure December 31,2024September 30,2024December 31,2023Transportation and industrials20 %20 %21 %Technology, media and telecom12 12 12 Banks and finance companies(1)12 11 12 Consumer retail11 12 11 Real estate11 10 10 Commercial8 7 8 Residential3 3 2 Power, chemicals, metals and mining9 8 8 Energy and commodities6 6 7 Health5 5 5 Insurance4 5 4 Public sector4 4 3 Asset managers and funds3 3 3 Financial markets infrastructure2 3 3 Other industries1 1 1 Total100 %100 %100 %(1) As of the periods in the table, Citi had less than 1% exposure to securities firms. See corporate credit portfolio by industry, below. 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.Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2024. Citi has applied management judgment 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 observed. 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, appetite per obligor is reduced consistent with the ratings, and downgrades may result in the purchase of additional credit derivatives or other risk/structural mitigants to hedge the incremental credit risk, or may result in Citi seeking to reduce exposure to an obligor or an industry sector. Citi will continue to review exposures to ensure that the appropriate probability of default is incorporated into all risk assessments.See Note 15 for additional information on Citi's corporate credit portfolio. 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. Citi believes the corporate credit portfolio to be appropriately rated and classified as of December 31, 2024. Citi has applied management judgment 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 observed. 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, appetite per obligor is reduced consistent with the ratings, and downgrades may result in the purchase of additional credit derivatives or other risk/structural mitigants to hedge the incremental credit risk, or may result in Citi seeking to reduce exposure to an obligor or an industry sector. Citi will continue to review exposures to ensure that the appropriate probability of default is incorporated into all risk assessments. See Note 15 for additional information on Citi's corporate credit portfolio. Portfolio Mix - IndustryCiti's corporate credit portfolio is diversified by industry. The following table details the allocation of Citi's total corporate credit portfolio by industry: Total exposure December 31,2024September 30,2024December 31,2023Transportation and industrials20 %20 %21 %Technology, media and telecom12 12 12 Banks and finance companies(1)12 11 12 Consumer retail11 12 11 Real estate11 10 10 Commercial8 7 8 Residential3 3 2 Power, chemicals, metals and mining9 8 8 Energy and commodities6 6 7 Health5 5 5 Insurance4 5 4 Public sector4 4 3 Asset managers and funds3 3 3 Financial markets infrastructure2 3 3 Other industries1 1 1 Total100 %100 %100 %(1) As of the periods in the table, Citi had less than 1% exposure to securities firms. See corporate credit portfolio by industry, below. --- ## Modified: Consumer non-accrual loans(1) **Key changes:** - Reworded sentence: "Asia Consumer(4) Legacy Holdings Assets (consumer) (1)Corporate loans are placed on non-accrual status based on a review by Citigroup's risk officers." - Reworded sentence: "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,In millions of dollars20242023202220212020OREONorth America$9 $17 $10 $15 $19 International(1)9 19 5 12 24 Total OREO$18 $36 $15 $27 $43 Non-accrual assetsCorporate non-accrual loans$1,377 $1,882 $1,122 $1,553 $3,046 Consumer non-accrual loans1,310 1,315 1,317 1,826 2,622 Non-accrual loans (NAL)$2,687 $3,197 $2,439 $3,379 $5,668 OREO18 36 15 27 43 Non-accrual assets (NAA)$2,705 $3,233 $2,454 $3,406 $5,711 NAL as a percentage of total loans0.39 %0.46 %0.37 %0.51 %0.84 %NAA as a percentage of total assets0.11 0.13 0.10 0.15 0.25 ACLL as a percentage of NAL(2)691 568 696 487 440 International(1) ACLL as a percentage of NAL(2) (1)The International OREO details by cluster are not provided due to the immateriality of such amounts." - Reworded sentence: "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 Limited and Citigroup Global Markets Japan Inc.) and other bank and non-bank subsidiaries that are consolidated into Citigroup (including Banamex).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." - Reworded sentence: "Citi's liquidity is managed centrally by Corporate Treasury, reported within Corporate/Other in All Other, in conjunction with regional and in-country treasurers with oversight provided by Independent Risk Management and various Asset and Liability Committees (ALCOs) at the individual entity, region, country and business levels." - Reworded sentence: "Citi also has other ALCOs, which are established at various organizational levels to ensure appropriate oversight for individual entities, countries, franchise businesses and regions, serving as the primary governance committees for managing Citi's balance sheet and liquidity.As a supplement to Citigroup's ALCO, Citi's Funding and Liquidity Risk Committee (FLRC) is focused on funding and liquidity risk matters." **Prior (2024):** On January 1, 2023, Citi adopted ASU 2022-02, which eliminated the accounting and disclosure requirements for TDRs (see Note 1). See Note 15 for information on loan modifications during the year ended December 31, 2023. 89 89 89 The changes in Citigroup's non-accrual loans were as follows: Year endedYear endedDecember 31, 2023December 31, 2022In millions of dollarsCorporateConsumerTotalCorporateConsumerTotalNon-accrual loans at beginning of year$1,122 $1,317 $2,439 $1,553 $1,826 $3,379 Additions2,103 1,702 3,805 2,123 1,374 3,497 Sales and transfers to HFS(110)(22)(132)(21)(240)(261)Returned to performing(141)(315)(456)(378)(408)(786)Paydowns/settlements(819)(476)(1,295)(1,814)(585)(2,399)Charge-offs(264)(851)(1,115)(260)(598)(858)Other(9)(40)(49)(81)(52)(133)Ending balance$1,882 $1,315 $3,197 $1,122 $1,317 $2,439 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,In millions of dollars20232022202120202019OREONorth America$17 $10 $15 $19 $39 International19 5 12 24 22 Total OREO$36 $15 $27 $43 $61 Non-accrual assetsCorporate non-accrual loans$1,882 $1,122 $1,553 $3,046 $2,024 Consumer non-accrual loans1,315 1,317 1,826 2,622 1,980 Non-accrual loans (NAL)$3,197 $2,439 $3,379 $5,668 $4,004 OREO$36 $15 $27 $43 $61 Non-accrual assets (NAA)$3,233 $2,454 $3,406 $5,711 $4,065 NAL as a percentage of total loans0.46 %0.37 %0.51 %0.84 %0.52 %NAA as a percentage of total assets0.13 0.10 0.15 0.25 0.21 ACLL as a percentage of NAL(1)568 696 487 440 319 ACLL as a percentage of NAL(1) (1)The ACLL includes the allowance for Citi's credit card portfolios and purchased credit-deteriorated 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 90 90 LIQUIDITY RISKOverviewAdequate 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 of Citi's control, such as disruptions in the financial markets, changes in key funding sources, credit spreads, changes in Citi's credit ratings and macroeconomic, geopolitical and other conditions. For additional information, see "Risk Factors - Liquidity Risks" above.Citi's funding and liquidity management objectives are aimed at (i) funding its existing asset base, (ii) growing its core businesses, (iii) maintaining sufficient liquidity, structured appropriately, so that Citi can operate under a variety of adverse circumstances, including potential Company-specific and/or market liquidity events in varying durations and severity, and (iv) satisfying regulatory requirements, including, but not limited to, those related to resolution planning (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 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 include (i) corporate and consumer deposits via Citi's bank subsidiaries, including Citibank, N.A. (Citibank), (ii) long-term debt (primarily senior and subordinated debt) mainly issued by Citigroup Inc., as the parent, and Citibank, and (iii) stockholders' equity. These sources may be supplemented by short-term borrowings, primarily in the form of secured funding transactions.Citi's funding and liquidity framework, working in concert with overall asset/liability management, helps ensure that there is sufficient liquidity and tenor in the overall liability structure (including funding products) of the Company relative to the liquidity requirements of Citi's assets. This reduces the risk that liabilities will become due before assets mature or are monetized. The Company holds excess liquidity, primarily in the form of high-quality liquid assets (HQLA), as presented in the table below. Citi's liquidity is managed centrally by Corporate Treasury, in conjunction with regional and in-country treasurers with oversight provided by Independent Risk Management and various Asset & Liability Committees (ALCOs) at the individual entity, region, country and business levels. Pursuant to this approach, Citi's HQLA are managed with emphasis on asset/liability management and entity-level liquidity adequacy throughout Citi.Citi's CRO and CFO co-chair Citigroup's ALCO, which includes Citi's Treasurer and other senior executives. The ALCO sets the strategy of the liquidity portfolio and monitors portfolio performance (see "Risk Governance - Board and Executive Management Committees" above). Significant changes to portfolio asset allocations are approved by the ALCO. Citi also has other ALCOs, which are established at various organizational levels to ensure appropriate oversight for individual entities, 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 focused on 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 MeasurementStress Testing Liquidity stress testing is performed for each of Citi's major entities, operating subsidiaries and 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, in order to have sufficient liquidity on hand to manage through such an event. These scenarios include assumptions about significant changes in key funding sources, market triggers (such as credit ratings), potential uses of funding and macroeconomic, geopolitical and other conditions. These conditions include expected and stressed market conditions as well as Company-specific events.Liquidity stress tests are performed to ascertain potential mismatches between liquidity sources and uses over a variety of time horizons and over different stressed conditions. To monitor the liquidity of an entity, these stress tests and potential mismatches are calculated on a daily basis. 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. LIQUIDITY RISKOverviewAdequate 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 of Citi's control, such as disruptions in the financial markets, changes in key funding sources, credit spreads, changes in Citi's credit ratings and macroeconomic, geopolitical and other conditions. For additional information, see "Risk Factors - Liquidity Risks" above.Citi's funding and liquidity management objectives are aimed at (i) funding its existing asset base, (ii) growing its core businesses, (iii) maintaining sufficient liquidity, structured appropriately, so that Citi can operate under a variety of adverse circumstances, including potential Company-specific and/or market liquidity events in varying durations and severity, and (iv) satisfying regulatory requirements, including, but not limited to, those related to resolution planning (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 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 include (i) corporate and consumer deposits via Citi's bank subsidiaries, including Citibank, N.A. (Citibank), (ii) long-term debt (primarily senior and subordinated debt) mainly issued by Citigroup Inc., as the parent, and Citibank, and (iii) stockholders' equity. These sources may be supplemented by short-term borrowings, primarily in the form of secured funding transactions.Citi's funding and liquidity framework, working in concert with overall asset/liability management, helps ensure that there is sufficient liquidity and tenor in the overall liability structure (including funding products) of the Company relative to the liquidity requirements of Citi's assets. This reduces the **Current (2025):** Asia Consumer(4) Legacy Holdings Assets (consumer) (1)Corporate loans are placed on non-accrual status based on a review by Citigroup's risk officers. Corporate non-accrual loans may still be current on interest payments. With limited exceptions, the following practices are applied for consumer loans: consumer loans, excluding credit cards and mortgages, are placed on non-accrual status at 90 days past due and are charged off at 120 days past due; residential mortgage loans are placed on non-accrual status at 90 days past due and written down to net realizable value at 180 days past due. Consistent with industry conventions, Citigroup generally accrues interest on credit card loans until such loans are charged off, which typically occurs at 180 days contractual delinquency. As such, the non-accrual loan disclosures do not include credit card loans. The balances above represent non-accrual loans within Corporate loans and Consumer loans on the Consolidated Balance Sheet. (2)Approximately 61%, 50%, 50%, 56% and 64% of Citi's corporate non-accrual loans remain current on interest and principal payments at December 31, 2024, 2023, 2022, 2021 and 2020, respectively. (3)The December 31, 2024 total corporate non-accrual loans represented 0.46% of total corporate loans. (4) Asia Consumer includes balances in Poland and Russia for all periods presented and in Bahrain for December 31, 2021 and 2020. 92 92 92 The changes in Citigroup's non-accrual loans were as follows: Year endedYear endedDecember 31, 2024December 31, 2023In millions of dollarsCorporateConsumerTotalCorporateConsumerTotalNon-accrual loans at beginning of year$1,882 $1,315 $3,197 $1,122 $1,317 $2,439 Additions1,517 1,966 3,483 2,103 1,702 3,805 Sales and transfers to HFS(443)(14)(457)(110)(22)(132)Returned to performing(269)(206)(475)(141)(315)(456)Paydowns/settlements(934)(531)(1,465)(819)(476)(1,295)Charge-offs(372)(951)(1,323)(264)(851)(1,115)Other(4)(269)(273)(9)(40)(49)Ending balance$1,377 $1,310 $2,687 $1,882 $1,315 $3,197 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,In millions of dollars20242023202220212020OREONorth America$9 $17 $10 $15 $19 International(1)9 19 5 12 24 Total OREO$18 $36 $15 $27 $43 Non-accrual assetsCorporate non-accrual loans$1,377 $1,882 $1,122 $1,553 $3,046 Consumer non-accrual loans1,310 1,315 1,317 1,826 2,622 Non-accrual loans (NAL)$2,687 $3,197 $2,439 $3,379 $5,668 OREO18 36 15 27 43 Non-accrual assets (NAA)$2,705 $3,233 $2,454 $3,406 $5,711 NAL as a percentage of total loans0.39 %0.46 %0.37 %0.51 %0.84 %NAA as a percentage of total assets0.11 0.13 0.10 0.15 0.25 ACLL as a percentage of NAL(2)691 568 696 487 440 International(1) ACLL as a percentage of NAL(2) (1)The International OREO details by cluster are not provided due to the immateriality of such amounts. (2)The ACLL includes the allowance for Citi's credit card portfolios and purchased credit-deteriorated loans, while the non-accrual loans exclude credit card balances (with the exception of certain international portfolios). 93 93 93 LIQUIDITY RISKOverviewAdequate 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 of Citi's control, such as disruptions in the financial markets, changes in key funding sources, credit spreads, changes in Citi's credit ratings and macroeconomic, geopolitical and other conditions. For additional information, see "Risk Factors - Liquidity Risks" above.Citi's funding and liquidity management objectives are aimed at (i) funding its existing asset base, (ii) growing its core businesses, (iii) maintaining sufficient liquidity, structured appropriately, so that Citi can operate under a variety of adverse circumstances, including potential Company-specific and/or market liquidity events in varying durations and severity, and (iv) satisfying regulatory requirements, including, but not limited to, those related to resolution planning (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 Limited and Citigroup Global Markets Japan Inc.) and other bank and non-bank subsidiaries that are consolidated into Citigroup (including Banamex).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 include (i) corporate and consumer deposits via Citi's bank subsidiaries, including Citibank, N.A. (Citibank), (ii) long-term debt (primarily senior and subordinated debt) mainly issued by Citigroup Inc., as the parent, and Citibank, and (iii) stockholders' equity. These sources may be supplemented by short-term borrowings, primarily in the form of secured funding transactions.Citi's funding and liquidity framework, working in concert with overall asset/liability management, helps ensure that there is sufficient liquidity and tenor in the overall liability structure (including funding products) of the Company relative to the liquidity requirements of Citi's assets. This reduces the risk that liabilities will become due before assets mature or are monetized. The Company holds excess liquidity, primarily in the form of high-quality liquid assets (HQLA), as presented in the table below. Citi's liquidity is managed centrally by Corporate Treasury, reported within Corporate/Other in All Other, in conjunction with regional and in-country treasurers with oversight provided by Independent Risk Management and various Asset and Liability Committees (ALCOs) at the individual entity, region, country and business levels. Pursuant to this approach, Citi's HQLA are managed with emphasis on asset/liability management and entity-level liquidity adequacy throughout Citi.Citi's CRO and CFO co-chair Citigroup's ALCO, which includes Citi's Treasurer and other senior executives. The ALCO sets the strategy of the liquidity portfolio and monitors portfolio performance (see "Risk Governance - Board and Executive Management Committees" above). Significant changes to portfolio asset allocations are approved by the ALCO. Citi also has other ALCOs, which are established at various organizational levels to ensure appropriate oversight for individual entities, countries, franchise businesses and regions, serving as the primary governance committees for managing Citi's balance sheet and liquidity.As a supplement to Citigroup's ALCO, Citi's Funding and Liquidity Risk Committee (FLRC) is focused on 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 MeasurementStress Testing Liquidity stress testing is performed for each of Citi's major entities, operating subsidiaries and 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, in order to have sufficient liquidity on hand to manage through such an event. These scenarios include assumptions about significant changes in key funding sources, market triggers (such as credit ratings), potential uses of funding and macroeconomic, geopolitical and other conditions. These conditions include expected and stressed market conditions as well as Company-specific events.Liquidity stress tests are performed to ascertain potential mismatches between liquidity sources and uses over a variety of time horizons and over different stressed conditions. To monitor the liquidity of an entity, these stress tests and potential mismatches are calculated on a daily basis. 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. LIQUIDITY RISKOverviewAdequate 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 of Citi's control, such as disruptions in the financial markets, changes in key funding sources, credit spreads, changes in Citi's credit ratings and macroeconomic, geopolitical and other conditions. For additional information, see "Risk Factors - Liquidity Risks" above.Citi's funding and liquidity management objectives are aimed at (i) funding its existing asset base, (ii) growing its core businesses, (iii) maintaining sufficient liquidity, structured appropriately, so that Citi can operate under a variety of adverse circumstances, including potential Company-specific and/or market liquidity events in varying durations and severity, and (iv) satisfying regulatory requirements, including, but not limited to, those related to resolution planning (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 Limited and Citigroup Global Markets Japan Inc.) and other bank and non-bank subsidiaries that are consolidated into Citigroup (including Banamex).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 include (i) corporate and consumer deposits via Citi's bank subsidiaries, including Citibank, N.A. (Citibank), (ii) long-term debt (primarily senior and subordinated debt) mainly issued by Citigroup Inc., as the parent, and Citibank, and (iii) stockholders' equity. These sources may be supplemented by short-term borrowings, primarily in the form of secured funding transactions.Citi's funding and liquidity framework, working in concert with overall asset/liability management, helps ensure that there is sufficient liquidity and tenor in the overall liability structure (including funding products) of the Company relative to the liquidity requirements of Citi's assets. This reduces the risk that liabilities will become due before assets mature or are --- ## Modified: The Application of U.S. Resolution Plan Requirements May Pose a Greater Risk of Loss to Citi's Debt and Equity Securities Holders, and Citi's Inability in Its Resolution Plan Submissions to Address Any Shortcomings or Deficiencies or Guidance 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. **Key changes:** - Reworded sentence: "In addition, a wholly owned, direct subsidiary of Citigroup serves as a resolution funding vehicle (the intermediate holding company, or IHC) to which Citigroup has transferred, and has agreed to transfer on an ongoing basis, certain assets." - Reworded sentence: "In line with the FRB's total loss-absorbing capacity (TLAC) rule, Citigroup's shareholders and unsecured creditors - including its unsecured long-term debt holders - would bear any losses resulting from Citigroup's bankruptcy." - Reworded sentence: "GSIBs, including Citigroup." - Reworded sentence: "Citi is required to submit a targeted resolution plan by July 1, 2025." - Reworded sentence: "Any such restrictions or actions would negatively impact Citi's reputation, market and investor perception, operations and strategy.Citi's Performance and Its Ability to Effectively Execute Its Transformation, Simplification and Other Priorities Could Be Negatively Impacted if It Is Not Able to Hire and Retain Qualified Employees.Citi's performance and the performance of its individual businesses largely depend on the talents and efforts of its diverse and highly qualified employees." **Prior (2024):** 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. 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 2023 resolution plan, which can be found on the FRB's and FDIC's websites) would remain operational outside of any resolution or insolvency proceedings. As a result, Citigroup's losses and any losses incurred by its material legal entity subsidiaries would be imposed first on holders of Citigroup's equity securities and thereafter on its unsecured creditors, including holders of eligible long-term debt and other debt securities. In addition, a wholly owned, direct subsidiary of Citigroup serves as a resolution funding vehicle (the IHC) to which Citigroup has transferred, and has agreed to transfer on an ongoing basis, certain assets. The obligations of Citigroup and of the IHC, respectively, under the amended and restated secured support agreement, are secured on a senior basis by the assets of Citigroup (other than shares in subsidiaries of the parent company and certain other assets), and the assets of the IHC, as applicable. As a result, claims of the operating material legal entities against the assets of Citigroup with respect to such secured assets are effectively senior to unsecured obligations of Citigroup. Citi's single point of entry resolution plan strategy and the obligations under the amended and restated secured support agreement may result in the recapitalization of and/or provision of liquidity to Citi's operating material legal entities, and the commencement of bankruptcy proceedings by Citigroup at an earlier stage of financial stress than might otherwise occur without such mechanisms in place. In line with the FRB's TLAC rule, Citigroup's shareholders and unsecured creditors - including its unsecured long-term debt holders - would 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. For additional information on Citi's single point of entry resolution plan strategy and the IHC and secured support agreement, see "Managing Global Risk - Liquidity Risk" below. On November 22, 2022, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2021 by the eight U.S. GSIBs, including Citi. The FRB and FDIC identified one shortcoming, but no deficiencies, in Citi's 2021 resolution plan. The shortcoming related to data integrity and data quality management issues, specifically, weaknesses in Citi's processes and practices for producing certain data that could materially impact its resolution capabilities. If a shortcoming is not satisfactorily explained or addressed before, or in, the submission of the next resolution plan, the shortcoming may be found to be a deficiency in the next resolution plan (see discussion below). Citi submitted its 2023 resolution plan in June 2023. More generally, data continuesto be a subject of regulatory focus, and Citi continues to workon enhancing its data availability and quality.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 understood to mean the regulators do not believe the plan is feasible or would otherwise allow Citi to be resolved in a way that protects systemically important functions without severe systemic disruption), or would not facilitate an orderly resolution of Citi under the U.S. Bankruptcy Code, and Citi fails to resubmit a resolution plan that remedies any identified deficiencies, Citi could be subjected to more stringent capital, leverage or liquidity requirements, or restrictions on its growth, activities or operations. If within two years from the imposition of any such requirements or restrictions Citi has still not remediated any identified deficiencies, then Citi could eventually be required to divest certain assets or operations. Any such restrictions or actions would negatively impact Citi's reputation, market and investor perception, operations and strategy.Citi's Performance and Its Ability to Effectively Execute Its Transformation and Strategic and Other Initiatives Could Be Negatively Impacted if It Is Not Able to Hire and Retain Qualified Employees.Citi's performance and the performance of its individual businesses largely depend on the talents and efforts of its diverse and highly qualified colleagues. Specifically, Citi's continued ability to compete in each of its lines of business, to manage its businesses effectively and to execute its transformation and strategic and other initiatives, including, for example, hiring front office colleagues to grow businesses or hiring colleagues to support Citi's transformation and strategic and other initiatives, depends on its ability to attract new colleagues and to retain and motivate its existing colleagues. If Citi is unable to continue to attract, retain and motivate highly qualified colleagues, Citi's performance, including its competitive position, the execution of its transformation and strategic and other initiatives and its results of operations could be negatively impacted.Citi's ability to attract, retain and motivate colleagues depends on numerous factors, some of which are outside of Citi's control. For example, the competition for talent continues to be particularly intense due to factors such as low unemployment and changes in worker expectations, concerns and preferences, including an increased demand for remote work options and other job flexibility. Also, the banking industry generally is subject to more comprehensive regulation of employee compensation than other industries, including deferral and clawback requirements for incentive compensation, which can make it unusually challenging for Citi to compete in labor markets against businesses, including, for example, technology companies, that are not subject to Citi's processes and practices for producing certain data that could materially impact its resolution capabilities. If a shortcoming is not satisfactorily explained or addressed before, or in, the submission of the next resolution plan, the shortcoming may be found to be a deficiency in the next resolution plan (see discussion below). Citi submitted its 2023 resolution plan in June 2023. More generally, data continues to be a subject of regulatory focus, and Citi continues to work on enhancing its data availability and quality. 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 understood to mean the regulators do not believe the plan is feasible or would otherwise allow Citi to be resolved in a way that protects systemically important functions without severe systemic disruption), or would not facilitate an orderly resolution of Citi under the U.S. Bankruptcy Code, and Citi fails to resubmit a resolution plan that remedies any identified deficiencies, Citi could be subjected to more stringent capital, leverage or liquidity requirements, or restrictions on its growth, activities or operations. If within two years from the imposition of any such requirements or restrictions Citi has still not remediated any identified deficiencies, then Citi could eventually be required to divest certain assets or operations. Any such restrictions or actions would negatively impact Citi's reputation, market and investor perception, operations and strategy. **Current (2025):** 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. 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 2023 resolution plan, which can be found on the FRB's and FDIC's websites) would remain operational outside of any resolution or insolvency proceedings. As a result, Citigroup's losses and any losses incurred by its material legal entity subsidiaries would be imposed first on holders of Citigroup's equity securities and thereafter on its unsecured creditors, including holders of eligible long-term debt and other debt securities. In addition, a wholly owned, direct subsidiary of Citigroup serves as a resolution funding vehicle (the intermediate holding company, or IHC) to which Citigroup has transferred, and has agreed to transfer on an ongoing basis, certain assets. The obligations of Citigroup and of the IHC, respectively, under the amended and restated secured support agreement, are secured on a senior basis by the assets of Citigroup (other than shares in subsidiaries of the parent company and certain other assets), and the assets of the IHC, as applicable. As a result, claims of the operating material legal entities against the assets of Citigroup with respect to such secured assets are effectively senior to unsecured obligations of Citigroup. Citi's single point of entry resolution plan strategy and the obligations under the amended and restated secured support agreement may result in the recapitalization of and/or provision of liquidity to Citi's operating material legal entities, and the commencement of bankruptcy proceedings by Citigroup at an earlier stage of financial stress than might otherwise occur without such mechanisms in place. In line with the FRB's total loss-absorbing capacity (TLAC) rule, Citigroup's shareholders and unsecured creditors - including its unsecured long-term debt holders - would 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. For additional information on Citi's single point of entry resolution plan strategy and the IHC and secured support agreement, see "Managing Global Risk - Liquidity Risk" below. On November 22, 2022, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2021 by the eight U.S. GSIBs, including Citigroup. The FRB and FDIC jointly identified one shortcoming in Citigroup's 2021 resolution plan. The shortcoming related to data integrity and 54 54 54 data quality management issues, specifically, weaknesses in Citi's processes and practices for producing certain data that could materially impact its resolution capabilities. On June 20, 2024, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2023 by the eight U.S. GSIBs, including Citigroup. The FRB and FDIC jointly identified one shortcoming in Citigroup's 2023 resolution plan regarding Citi's derivatives unwind capabilities. If a shortcoming is not satisfactorily explained or addressed before, or in, the submission of the next resolution plan, the shortcoming may be found to be a deficiency in the next resolution plan (see discussion below). Citi is required to submit a targeted resolution plan by July 1, 2025. More generally, data continues to be a subject of regulatory focus, and Citi continues to work on enhancing its data availability and quality (see "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor 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 understood to mean the regulators do not believe the plan is feasible or would otherwise allow Citi to be resolved in a way that protects systemically important functions without severe systemic disruption), or would not facilitate an orderly resolution of Citi under the U.S. Bankruptcy Code, and Citi fails to resubmit a resolution plan that remedies any identified deficiencies, Citi could be subjected to more stringent capital, leverage or liquidity requirements, or restrictions on its growth, activities or operations. If within two years from the imposition of any such requirements or restrictions Citi has still not remediated any identified deficiencies, then Citi could eventually be required to divest certain assets or operations. Any such restrictions or actions would negatively impact Citi's reputation, market and investor perception, operations and strategy.Citi's Performance and Its Ability to Effectively Execute Its Transformation, Simplification and Other Priorities Could Be Negatively Impacted if It Is Not Able to Hire and Retain Qualified Employees.Citi's performance and the performance of its individual businesses largely depend on the talents and efforts of its diverse and highly qualified employees. Specifically, Citi's continued ability to compete in each of its lines of business, to manage its businesses effectively and to execute its transformation, simplification and other priorities, including, for example, hiring employees to grow businesses or hiring employees to support Citi's priorities, depends on its ability to hire new employees and to retain and motivate its existing employees. If Citi is unable to continue to hire, retain and motivate highly qualified employees, Citi's performance, including its competitive position, the execution of its transformation, simplification and other priorities and its results of operations could be negatively impacted.Citi's ability to attract, retain and motivate employees depends on numerous factors, some of which are outside of Citi's control. For example, the competition for talent continues to be particularly intense due to various factors, such as changes in worker expectations, concerns and preferences, including demands for remote work options and other job flexibility. Also, the banking industry generally is subject to more comprehensive regulation of employee compensation than other industries, including deferral and clawback requirements for incentive compensation, which can make it unusually challenging for Citi to compete in labor markets against businesses, including, for example, technology companies, that are not subject to such regulation. In addition, Citi recently completed a significant organizational simplification initiative, which included reducing management layers and significant reductions in functional roles that could continue to impact its ability to attract and retain employees. Other factors that could impact Citi's ability to attract, retain and motivate employees include, among other things, Citi's presence in a particular market or region, the professional and development opportunities it offers, its reputation and its diversity. For information on Citi's employee and workforce management, see "Human Capital Resources and Management" below.Citi Faces Increased Competitive Challenges, Including from Financial Services and Other Companies and Emerging Technologies.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, private credit and 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. Certain competitors may be subject to different and, in some cases, less stringent legal, regulatory and supervisory requirements, whether due to size, jurisdiction, entity type or other factors, placing Citi at a competitive disadvantage. Moreover, new or rapidly developing technologies with the potential to have significant economic or social effects (emerging technologies) also pose competitive challenges for Citi.For example, Citi competes with other financial services companies in the U.S. and globally that have grown rapidly over the last several years or have introduced new products and services. Potential mergers and acquisitions involving traditional financial services companies, such as regional banks or credit card issuers, as well as networks and merchant acquirers, may also increase competition and impact Citi's ability to offer competitive pricing and rewards. Non-traditional financial services firms, such as private credit, financial technology and digital asset companies, are less regulated and supervised and continue to expand their offerings of services traditionally provided by financial institutions. In addition, emerging technologies have the potential to intensify competition and accelerate disruption in the financial services industry. Clients and investors have shown increased interest in these technologies, prompting financial services firms and other market participants to develop related products and services. As blockchain and digital assets continue to evolve, customer demand for enhanced offerings may increase. Failure to strategically embrace the potential of emerging technologies may result in a competitive disadvantage to Citi. The new U.S. administration has stated its support for the growth and use of digital assets and data quality management issues, specifically, weaknesses in Citi's processes and practices for producing certain data that could materially impact its resolution capabilities. On June 20, 2024, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2023 by the eight U.S. GSIBs, including Citigroup. The FRB and FDIC jointly identified one shortcoming in Citigroup's 2023 resolution plan regarding Citi's derivatives unwind capabilities. If a shortcoming is not satisfactorily explained or addressed before, or in, the submission of the next resolution plan, the shortcoming may be found to be a deficiency in the next resolution plan (see discussion below). Citi is required to submit a targeted resolution plan by July 1, 2025. More generally, data continues to be a subject of regulatory focus, and Citi continues to work on enhancing its data availability and quality (see "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor 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 understood to mean the regulators do not believe the plan is feasible or would otherwise allow Citi to be resolved in a way that protects systemically important functions without severe systemic disruption), or would not facilitate an orderly resolution of Citi under the U.S. Bankruptcy Code, and Citi fails to resubmit a resolution plan that remedies any identified deficiencies, Citi could be subjected to more stringent capital, leverage or liquidity requirements, or restrictions on its growth, activities or operations. If within two years from the imposition of any such requirements or restrictions Citi has still not remediated any identified deficiencies, then Citi could eventually be required to divest certain assets or operations. Any such restrictions or actions would negatively impact Citi's reputation, market and investor perception, operations and strategy.Citi's Performance and Its Ability to Effectively Execute Its Transformation, Simplification and Other Priorities Could Be Negatively Impacted if It Is Not Able to Hire and Retain Qualified Employees.Citi's performance and the performance of its individual businesses largely depend on the talents and efforts of its diverse and highly qualified employees. Specifically, Citi's continued ability to compete in each of its lines of business, to manage its businesses effectively and to execute its transformation, simplification and other priorities, including, for example, hiring employees to grow businesses or hiring employees to support Citi's priorities, depends on its ability to hire new employees and to retain and motivate its existing employees. If Citi is unable to continue to hire, retain and motivate highly qualified employees, Citi's performance, including its competitive position, the execution of its transformation, simplification and other priorities and its results of operations could be negatively impacted.Citi's ability to attract, retain and motivate employees depends on numerous factors, some of which are outside of Citi's control. For example, the competition for talent continues to be particularly intense due to various factors, such as changes in worker expectations, concerns and preferences, including demands for remote work options and other job data quality management issues, specifically, weaknesses in Citi's processes and practices for producing certain data that could materially impact its resolution capabilities. On June 20, 2024, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2023 by the eight U.S. GSIBs, including Citigroup. The FRB and FDIC jointly identified one shortcoming in Citigroup's 2023 resolution plan regarding Citi's derivatives unwind capabilities. If a shortcoming is not satisfactorily explained or addressed before, or in, the submission of the next resolution plan, the shortcoming may be found to be a deficiency in the next resolution plan (see discussion below). Citi is required to submit a targeted resolution plan by July 1, 2025. More generally, data continues to be a subject of regulatory focus, and Citi continues to work on enhancing its data availability and quality (see "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor 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 understood to mean the regulators do not believe the plan is feasible or would otherwise allow Citi to be resolved in a way that protects systemically important functions without severe systemic disruption), or would not facilitate an orderly resolution of Citi under the U.S. Bankruptcy Code, and Citi fails to resubmit a resolution plan that remedies any identified deficiencies, Citi could be subjected to more stringent capital, leverage or liquidity requirements, or restrictions on its growth, activities or operations. If within two years from the imposition of any such requirements or restrictions Citi has still not remediated any identified deficiencies, then Citi could eventually be required to divest certain assets or operations. Any such restrictions or actions would negatively impact Citi's reputation, market and investor perception, operations and strategy. --- ## Modified: Short-Term Borrowings **Key changes:** - Reworded sentence: "Citi's short-term borrowings of $49 billion as of December 31, 2024 increased 29% year-over-year, reflecting higher commercial paper issuances at the broker-dealer subsidiaries, as Citi continues to diversify its funding profile, and increased 17% sequentially, driven by the commercial paper issuances and normal business activity (see Note 19 for further information on Citigroup's and its affiliates' outstanding short-term borrowings)." - Reworded sentence: "(CGMHI) were A+/F1 at Fitch Ratings, A2/P-1 at Moody's Ratings and A/A-1 at S&P Global Ratings as of December 31, 2024." - Reworded sentence: "The table below presents the ratings for Citigroup and Citibank as of December 31, 2024." - Reworded sentence: "(CGMHI) were A+/F1 at Fitch Ratings, A2/P-1 at Moody's Ratings and A/A-1 at S&P Global Ratings as of December 31, 2024." **Prior (2024):** Citi's short-term borrowings of $37 billion as of the fourth quarter of 2023 decreased 20% year-over-year, reflecting lower commercial paper issuances at the broker-dealer subsidiaries, as Citi continues to diversify its funding profile, and decreased 1% sequentially, driven by normal business activity (see Note 18 for further information on Citigroup's and its affiliates' outstanding short-term borrowings). 97 97 97 CREDIT RATINGSCitigroup'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 presents the ratings for Citigroup and Citibank as of December 31, 2023. While not included in the table below, the long-term and short-term ratings of Citigroup Global Markets Holding Inc. (CGMHI) were A+/F1 at Fitch Ratings, A2/P-1 at Moody's Investors Service and A/A-1 at S&P Global Ratings as of December 31, 2023. CREDIT RATINGSCitigroup'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 presents the ratings for Citigroup and Citibank as of December 31, 2023. While not included in the table below, the long-term and short-term ratings of Citigroup Global Markets Holding Inc. (CGMHI) were A+/F1 at Fitch Ratings, A2/P-1 at Moody's Investors Service and A/A-1 at S&P Global Ratings as of December 31, 2023. **Current (2025):** Citi's short-term borrowings of $49 billion as of December 31, 2024 increased 29% year-over-year, reflecting higher commercial paper issuances at the broker-dealer subsidiaries, as Citi continues to diversify its funding profile, and increased 17% sequentially, driven by the commercial paper issuances and normal business activity (see Note 19 for further information on Citigroup's and its affiliates' outstanding short-term borrowings). 100 100 100 CREDIT RATINGSCitigroup'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 presents the ratings for Citigroup and Citibank as of December 31, 2024. While not included in the table below, the long-term and short-term ratings of Citigroup Global Markets Holding Inc. (CGMHI) were A+/F1 at Fitch Ratings, A2/P-1 at Moody's Ratings and A/A-1 at S&P Global Ratings as of December 31, 2024. CREDIT RATINGSCitigroup'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 presents the ratings for Citigroup and Citibank as of December 31, 2024. While not included in the table below, the long-term and short-term ratings of Citigroup Global Markets Holding Inc. (CGMHI) were A+/F1 at Fitch Ratings, A2/P-1 at Moody's Ratings and A/A-1 at S&P Global Ratings as of December 31, 2024. --- ## Modified: All Other - Legacy Franchises (managed basis)(3) **Key changes:** - Reworded sentence: "(3)All Other (managed basis) excludes divestiture-related impacts (Reconciling Items) related to (i) Citi's divestitures of its Asia Consumer businesses and (ii) the planned IPO of Mexico Consumer/SBMM within Legacy Franchises." - Reworded sentence: "See "All Other - Divestiture-Related Impacts (Reconciling Items)" above." **Prior (2024):** Asia Consumer (managed basis)(3)(4)(5) Reconciling Items(3) (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)All Other (managed basis) excludes divestiture-related impacts (Reconciling Items) related to (i) Citi's divestitures of its Asia Consumer businesses and (ii) the planned divestiture of Mexico consumer banking and small business and middle-market banking within Legacy Franchises. The Reconciling Items are fully reflected in the various line items in Citi's Consolidated Statement of Income. See "All Other - Divestiture-Related Impacts (Reconciling Items)" below. (4)Asia Consumer also includes NCLs and average loans in Poland and Russia for all periods presented and in Bahrain for 2021 only. (5)Approximately $25 million, $155 million and $6 million in NCLs relating to certain Asia Consumer businesses classified as held-for-sale in Other assets and Other liabilities on the Consolidated Balance Sheet were recorded as a reduction in revenue (Other revenue) in 2023, 2022 and 2021, respectively. Accordingly, these NCLs are not included in this table. See footnote 3 to this table. 81 81 81 **Current (2025):** Asia Consumer (managed basis)(3)(4)(5) Reconciling Items(3) (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)All Other (managed basis) excludes divestiture-related impacts (Reconciling Items) related to (i) Citi's divestitures of its Asia Consumer businesses and (ii) the planned IPO of Mexico Consumer/SBMM within Legacy Franchises. The Reconciling Items are fully reflected in the various line items in Citi's Consolidated Statement of Income. See "All Other - Divestiture-Related Impacts (Reconciling Items)" above. (4)Asia Consumer also includes NCLs and average loans in Poland and Russia for all periods presented. (5)Approximately $0 million, $25 million and $155 million in NCLs relating to certain Asia Consumer businesses classified as held-for-sale in Other assets and Other liabilities on the Consolidated Balance Sheet were recorded as a reduction in revenue (Other revenue) in 2024, 2023 and 2022, respectively. Accordingly, these NCLs are not included in this table. See footnote 3 to this table. 84 84 84 --- ## Modified: Citibank - Additional Potential Impacts **Key changes:** - Reworded sentence: "As of December 31, 2024, Citibank had liquidity commitments of approximately $14.9 billion to consolidated asset-backed commercial paper conduits (compared to $11.0 billion at December 31, 2023) (see Note 23)." - Reworded sentence: "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.MARKET RISKOverviewMarket 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." - Reworded sentence: "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 Committees." - Reworded sentence: "Market risk from non-trading portfolios also includes the potential impact of changes in foreign exchange rates on Citi's capital invested in foreign currencies.Banking Book Interest Rate Risk For interest rate risk purposes, Citi's non-trading portfolios are referred to as the Banking Book." - Reworded sentence: "Citigroup's Asset and Liability Committee (ALCO) establishes Citi's risk appetite and related limits for interest rate risk in the Banking Book, which are subject to approval by Citigroup's Board of Directors." **Prior (2024):** 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, 2023, Citibank had liquidity commitments of approximately $11.0 billion to consolidated asset-backed commercial paper conduits, unchanged from December 31, 2022 (see Note 23). In addition to the above-referenced liquidity resources of certain Citibank entities, Citibank could reduce the funding and liquidity risk, if any, of the potential downgrades described above through mitigating actions, including repricing or reducing certain commitments to commercial paper conduits. In the event of the potential downgrades described above, Citi believes that certain corporate customers could re-evaluate their deposit relationships with Citibank. This re-evaluation could result in clients adjusting their discretionary deposit levels or changing their depository institution, which could potentially reduce certain deposit levels at Citibank. However, Citi could choose to adjust pricing, offer alternative deposit products to its existing customers or seek to attract deposits from new customers, in addition to the mitigating actions referenced above. 99 99 99 MARKET RISKOverviewMarket 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 arises from both Citi's trading and non-trading portfolios. For additional information on market risk and market risk management at Citi, see "Risk Factors" above.Each business is required to establish, with approval from Citi's market risk management, a market risk limit framework for identified risk factors that clearly defines approved risk profiles and is within the parameters of Citi's overall risk appetite. These limits are monitored by the Risk organization, including various regional, legal entity and business Risk Management committees, Citi's country and business Asset & Liability Committees and the Citigroup Risk Management and Asset & Liability Committees. In all cases, the businesses are ultimately responsible for the market risks taken and for remaining within their defined limits.MARKET RISK OF NON-TRADING PORTFOLIOS Market risk from non-trading portfolios stems predominantly from the potential impact of changes in interest rates and foreign exchange rates on Citi's net interest income and on Citi's Accumulated other comprehensive income (loss) (AOCI) from its investment securities portfolios. Market risk from non-trading portfolios also includes the potential impact of changes in foreign exchange rates on Citi's capital invested in foreign currencies. Banking Book Interest Rate Risk For interest rate risk purposes, Citi's non-trading portfolios are referred to as the Banking Book. Management of interest rate risk in the Banking Book is governed by Citi's Non-Trading Market Risk Policy. Management's Asset & Liability Committee (ALCO) establishes Citi's risk appetite and related limits for interest rate risk in the Banking Book, which are subject to approval by Citigroup's Board of Directors. Corporate Treasury is responsible for the day-to-day management of Citi's Banking Book interest rate risk as well as periodically reviewing it with the ALCO. Citi's Banking Book interest rate risk management is also subject to independent oversight from the second line of defense team reporting to the Chief Risk Officer.Changes in interest rates impact Citi's net income, AOCI and CET1. These changes primarily affect Citi's Banking Book through net interest income, due to a variety of risk factors, including:•Differences in timing and amounts of the maturity or repricing of assets, liabilities and off-balance sheet instruments;•Changes in the level and/or shape of interest rate curves;•Client behavior in response to changes in interest rates (e.g., mortgage prepayments, deposit betas); and•Changes in the maturity of instruments resulting from changes in the interest rate environment.As part of their ongoing activities, Citi's businesses generate interest rate-sensitive positions from their client-facing products, such as loans and deposits. The component of this interest rate risk that can be hedged is transferred via Citi's funds transfer pricing process to Corporate Treasury. Corporate Treasury uses various tools to manage the total interest rate risk position within the established risk appetite and target Citi's desired risk profile, including its investment securities portfolio, company-issued debt and interest rate derivatives. In addition, Citi uses multiple metrics to measure its Banking Book interest rate risk. Interest Rate Exposure (IRE) is a key metric that analyzes the impact of a range of scenarios on Citi's Banking Book net interest income and certain other interest rate-sensitive income versus a base case. IRE does not represent a forecast of Citi's net interest income.The scenarios, methodologies and assumptions used in this analysis are periodically evaluated and enhanced in response to changes in the market environment, changes in Citi's balance sheet composition, enhancements in Citi's modeling and other factors.Since the third quarter of 2022, Citi has employed enhanced IRE methodologies and changes to certain assumptions. The changes included, among other things, assumptions around the projected balance sheet and revisions to the treatment of certain business contributions (notably accrual positions in the Markets businesses). These changes resulted in a higher impact to Citi's net interest income over a 12-month period.Under the enhanced methodology, Citi utilizes the most recent quarter-end balance sheet, assuming no changes to its composition and size over the forecasted horizon (holding the balance sheet static). The forecasts incorporate expectations and assumptions of deposit pricing, loan spreads and mortgage prepayment behavior implied by the interest rate curves in each scenario. The base case scenario reflects the market-implied forward interest rates, and sensitivity scenarios assume instantaneous shocks to the base case. The forecasts do not assume Citi takes any risk-mitigating actions in response to changes in the interest rate environment. Certain interest rates are subject to flooring assumptions in downward rate scenarios. Deposit pricing sensitivities (i.e., deposit betas) are informed by historical and expected behavior. Actual deposit pricing could differ from the assumptions used in these forecasts.Citi's IRE analysis primarily reflects the impacts from the following Banking Book assets and liabilities: loans, client deposits, Citi's deposits with other banks, investment securities, long-term debt, any related interest rate hedges and the funds transfer pricing of positions in total trading and credit portfolio value at risk (VAR). It excludes impacts from any positions that are included in total trading and credit portfolio VAR.In addition to IRE, Citi analyzes economic value sensitivity (EVS) as a longer-term interest rate risk metric. EVS is a net present value (NPV)-based measure of the lifetime cash flows of Citi's Banking Book. It estimates the interest rate sensitivity of the Banking Book's economic value from longer-term assets being potentially funded with shorter-term liabilities, or vice versa. Citi manages EVS within risk MARKET RISKOverviewMarket 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 arises from both Citi's trading and non-trading portfolios. For additional information on market risk and market risk management at Citi, see "Risk Factors" above.Each business is required to establish, with approval from Citi's market risk management, a market risk limit framework for identified risk factors that clearly defines approved risk profiles and is within the parameters of Citi's overall risk appetite. These limits are monitored by the Risk organization, including various regional, legal entity and business Risk Management committees, Citi's country and business Asset & Liability Committees and the Citigroup Risk Management and Asset & Liability Committees. In all cases, the businesses are ultimately responsible for the market risks taken and for remaining within their defined limits.MARKET RISK OF NON-TRADING PORTFOLIOS Market risk from non-trading portfolios stems predominantly from the potential impact of changes in interest rates and foreign exchange rates on Citi's net interest income and on Citi's Accumulated other comprehensive income (loss) (AOCI) from its investment securities portfolios. Market risk from non-trading portfolios also includes the potential impact of changes in foreign exchange rates on Citi's capital invested in foreign currencies. Banking Book Interest Rate Risk For interest rate risk purposes, Citi's non-trading portfolios are referred to as the Banking Book. Management of interest rate risk in the Banking Book is governed by Citi's Non-Trading Market Risk Policy. Management's Asset & Liability Committee (ALCO) establishes Citi's risk appetite and related limits for interest rate risk in the Banking Book, which are subject to approval by Citigroup's Board of Directors. Corporate Treasury is responsible for the day-to-day management of Citi's Banking Book interest rate risk as well as periodically reviewing it with the ALCO. Citi's Banking Book interest rate risk management is also subject to independent oversight from the second line of defense team reporting to the Chief Risk Officer.Changes in interest rates impact Citi's net income, AOCI and CET1. These changes primarily affect Citi's Banking Book through net interest income, due to a variety of risk factors, including:•Differences in timing and amounts of the maturity or repricing of assets, liabilities and off-balance sheet instruments;•Changes in the level and/or shape of interest rate curves;•Client behavior in response to changes in interest rates (e.g., mortgage prepayments, deposit betas); and•Changes in the maturity of instruments resulting from changes in the interest rate environment. **Current (2025):** 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, 2024, Citibank had liquidity commitments of approximately $14.9 billion to consolidated asset-backed commercial paper conduits (compared to $11.0 billion at December 31, 2023) (see Note 23). 101 101 101 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.MARKET RISKOverviewMarket 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 arises from both Citi's trading and non-trading portfolios. For additional information on market risk and market risk management at Citi, 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 Committees. In all cases, the businesses are ultimately responsible for the market risks taken and for remaining within their defined limits.MARKET RISK OF NON-TRADING PORTFOLIOS Market risk from non-trading portfolios stems predominantly from the potential impact of changes in interest rates and foreign exchange rates on Citi's net interest income and on Citi's Accumulated other comprehensive income (loss) (AOCI) from its investment securities portfolios. Market risk from non-trading portfolios also includes the potential impact of changes in foreign exchange rates on Citi's capital invested in foreign currencies.Banking Book Interest Rate Risk For interest rate risk purposes, Citi's non-trading portfolios are referred to as the Banking Book. Management of interest rate risk in the Banking Book is governed by Citi's Non-Trading Market Risk Policy. Citigroup's Asset and Liability Committee (ALCO) establishes Citi's risk appetite and related limits for interest rate risk in the Banking Book, which are subject to approval by Citigroup's Board of Directors. Corporate Treasury is responsible for the day-to-day management of Citi's Banking Book interest rate risk as well as periodically reviewing it with the ALCO. Citi's Banking Book interest rate risk management is also subject to independent oversight from the second line of defense team reporting to the Chief Risk Officer.Changes in interest rates impact Citi's net income, AOCI and CET1. These changes primarily affect Citi's Banking Book through net interest income, due to a variety of risk factors, including:•Differences in timing and amounts of the maturity or repricing of assets, liabilities and off-balance sheet instruments;•Changes in the level and/or shape of interest rate curves;•Client behavior in response to changes in interest rates (e.g., mortgage prepayments, deposit betas); and•Changes in the maturity of instruments resulting from changes in the interest rate environment.As part of their ongoing activities, Citi's businesses generate interest rate-sensitive positions from their client-facing products, such as loans and deposits. Interest rate risk is transferred via Citi's funds transfer-pricing process to Citi Corporate Treasury. Citi Corporate Treasury uses various tools to manage the total interest rate risk position within the established risk appetite and target Citi's desired risk profile, including its investment securities portfolio, company-issued debt and interest rate derivatives. In addition, Citi uses multiple metrics to measure its Banking Book interest rate risk. Interest Rate Exposure (IRE) is a key metric that analyzes the impact of a range of scenarios on Citi's Banking Book net interest income versus a base case. IRE does not represent a forecast of Citi's net interest income.The scenarios, methodologies and assumptions used in Citi's IRE analysis are periodically evaluated and enhanced in response to changes in the market environment, changes in Citi's balance sheet composition, enhancements in Citi's modeling and other factors.Citi utilizes the most recent quarter-end balance sheet, assuming no changes to its composition and size over the forecasted horizon (holding the balance sheet static). The forecasts incorporate expectations and assumptions of deposit pricing, loan spreads and mortgage prepayment behavior implied by the interest rate curves in each scenario. The base case scenario reflects the market-implied forward interest rates, and sensitivity scenarios assume instantaneous shocks to the base case. The forecasts do not assume Citi takes any risk-mitigating actions in response to changes in the interest rate environment. Certain interest rates are subject to flooring assumptions in downward rate scenarios. Deposit pricing sensitivities (i.e., deposit betas) are informed by historical and expected behavior. Actual deposit pricing could differ from the assumptions used in these forecasts. 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.MARKET RISKOverviewMarket 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 arises from both Citi's trading and non-trading portfolios. For additional information on market risk and market risk management at Citi, 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 Committees. In all cases, the businesses are ultimately responsible for the market risks taken and for remaining within their defined limits.MARKET RISK OF NON-TRADING PORTFOLIOS Market risk from non-trading portfolios stems predominantly from the potential impact of changes in interest rates and foreign exchange rates on Citi's net interest income and on Citi's Accumulated other comprehensive income (loss) (AOCI) from its investment securities portfolios. Market risk from non-trading portfolios also includes the potential impact of changes in foreign exchange rates on Citi's capital invested in foreign currencies.Banking Book Interest Rate Risk For interest rate risk purposes, Citi's non-trading portfolios are referred to as the Banking Book. Management of interest rate risk in the Banking Book is governed by Citi's Non-Trading Market Risk Policy. Citigroup's Asset and Liability Committee (ALCO) establishes Citi's risk appetite and related limits for interest rate risk in the Banking Book, which are subject to approval by Citigroup's Board of Directors. 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. --- ## Modified: Credit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses. **Key changes:** - Reworded sentence: "and various countries and jurisdictions globally, including end-of-period consumer loans of $393 billion and end-of-period corporate loans of $301 billion at December 31, 2024." - Added sentence: "For information on Citi's credit and country risk, see also each respective business's results of operations above and "Managing Global Risk - Other Risks - Country Risk" below and Notes 15 and 16." - Reworded sentence: "Additionally, despite Citi's target client strategy, various macroeconomic, geopolitical, market and other factors, among other things, can increase Citi's credit risk and credit costs, particularly for vulnerable sectors, industries or countries (see the macroeconomic challenges and uncertainties and co-branding and private label credit card risk factors above and the emerging markets risk factor below)." - Reworded sentence: "For example, the failure of regional banks and other banking stresses in recent years resulted in market volatility across the financial sector.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." - Reworded sentence: "Citi's liquidity, sources of funding and costs of funding can be significantly and negatively impacted by factors it cannot control, such as general disruptions in the financial markets; changes in fiscal and monetary policies; regulatory requirements, including changes in regulations; negative investor or counterparty perceptions of Citi's creditworthiness; deposit outflows or unfavorable changes in deposit mix; unexpected increases in cash or collateral requirements; credit ratings; and the consequent inability to monetize available liquidity resources." **Prior (2024):** 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 $389 billion and end-of-period corporate loans of $300 billion at December 31, 2023. For additional information on Citi's corporate and consumer loan portfolios, see "Managing Global Risk - Corporate Credit" and " - Consumer Credit" below. A default by or a significant downgrade in the credit ratings of 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, market and other factors, among other things, can increase Citi's credit risk and credit costs, particularly for vulnerable sectors, industries or countries (see the macroeconomic challenges and uncertainties and co-branding and private label credit card risk factors above and the emerging markets risk factor below). For example, a weakening of economic conditions can adversely affect borrowers' ability to repay their obligations, as well as result in Citi being unable to liquidate the collateral it holds or forced to liquidate the collateral at prices that do not cover the full amount owed to Citi. Citi is also a member of various central clearing counterparties and could incur financial losses as a result of defaults by other clearing members due to the requirements of clearing members to share losses. Additionally, due to the interconnectedness among financial institutions, concerns about the creditworthiness of or defaults by a financial institution could spread to other financial market participants and result in market-wide losses and disruption. For example, the failure of regional banks and other banking stresses in the first half of 2023 resulted in market volatility across the financial sector.While Citi provides reserves for expected losses for its credit exposures, as applicable, such reserves are subject to judgments and estimates that could be incorrect or differ from actual future events. Under the CECL accounting standard, the ACL reflects expected losses, which has resulted in and could lead to additional volatility in the allowance and the provision for credit losses (including provisions for loans and unfunded lending commitments, and ACL builds for Other assets) as forecasts of economic conditions change. For additional information, see the incorrect assumptions or estimates and changes to financial accounting and reporting standards risk factors above. For additional information on Citi's ACL, see "Significant Accounting Policies and Significant Estimates" below and Notes 1 and 16. For additional information on Citi's credit and country risk, see also each respective business's results of operations above, "Managing Global Risk - Credit Risk" and "Managing Global Risk - Other Risks - Country Risk" below and Notes 15 and 16. Concentrations of risk to clients or counterparties engaged in the same or related industries or doing business in a particular geography, or to a particular product or asset class, especially credit and market risks, can also increase Citi's risk of significant losses. For example, 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 (see Note 28). A rapid deterioration of a large borrower or other counterparty or within a sector or country in which Citi has large exposures or indemnifications or unexpected market dislocations could lead to concerns about the creditworthiness of other borrowers or counterparties in a certain geography and in related or dependent industries, and such conditions could cause Citi to incur significant losses.LIQUIDITY RISKSCiti's Businesses, Results of Operations and Financial Condition Could Be Negatively Impacted if It Does Not Effectively Manage Its Liquidity. As a large, global financial institution, adequate liquidity and sources of funding are essential to Citi's businesses. Citi's liquidity, sources of funding and costs of funding can be significantly and negatively impacted by factors it cannot control, such as general disruptions in the financial markets (e.g., the failure of regional banks and other banking stresses in the first half of 2023); changes in fiscal and monetary policies and regulatory requirements; negative investor perceptions of Citi's creditworthiness; deposit outflows or unfavorable changes in deposit mix; unexpected increases in cash or collateral requirements; credit ratings; and the consequent inability to monetize available liquidity resources. For example, the failure of regional banks and other banking stresses in the first half of 2023 resulted in market volatility across the financial sector. While Citi provides reserves for expected losses for its credit exposures, as applicable, such reserves are subject to judgments and estimates that could be incorrect or differ from actual future events. Under the CECL accounting standard, the ACL reflects expected losses, which has resulted in and could lead to additional volatility in the allowance and the provision for credit losses (including provisions for loans and unfunded lending commitments, and ACL builds for Other assets) as forecasts of economic conditions change. For additional information, see the incorrect assumptions or estimates and changes to financial accounting and reporting standards risk factors above. For additional information on Citi's ACL, see "Significant Accounting Policies and Significant Estimates" below and Notes 1 and 16. For additional information on Citi's credit and country risk, see also each respective business's results of operations above, "Managing Global Risk - Credit Risk" and "Managing Global Risk - Other Risks - Country Risk" below and Notes 15 and 16. Concentrations of risk to clients or counterparties engaged in the same or related industries or doing business in a particular geography, or to a particular product or asset class, especially credit and market risks, can also increase Citi's risk of significant losses. For example, 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 (see Note 28). A rapid deterioration of a large borrower or other counterparty or within a sector or country in which Citi has large exposures or indemnifications or unexpected market dislocations could lead to concerns about the creditworthiness of other borrowers or counterparties in a certain geography and in related or dependent industries, and such conditions could cause Citi to incur significant losses. **Current (2025):** 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 $393 billion and end-of-period corporate loans of $301 billion at December 31, 2024. For additional information on Citi's corporate and consumer loan portfolios, see "Managing Global Risk - Corporate Credit" and " - Consumer Credit" below. For information on Citi's credit and country risk, see also each respective business's results of operations above and "Managing Global Risk - Other Risks - Country Risk" below and Notes 15 and 16. A default by or a significant downgrade in the credit ratings of a borrower or other counterparty, or a decline in the credit quality or value of any underlying collateral, exposes Citi to credit risk. Additionally, despite Citi's target client strategy, various macroeconomic, geopolitical, market and other factors, among other things, can increase Citi's credit risk and credit costs, particularly for vulnerable sectors, industries or countries (see the macroeconomic challenges and uncertainties and co-branding and private label credit card risk factors above and the emerging markets risk factor below). For example, a weakening of economic conditions can adversely affect borrowers' ability to repay their obligations, as well as result in Citi being unable to liquidate the collateral it holds or forced to liquidate the collateral at prices that do not cover the full amount owed to Citi. Citi is also a member of various central clearing counterparties and could incur financial losses as a result of defaults by other clearing members due to the requirements of clearing members to share losses. Additionally, due to the interconnectedness among financial institutions, concerns about the creditworthiness of or defaults by a financial institution could spread to other financial market participants and result in market-wide losses and disruption. For example, the failure of regional banks and other banking stresses in recent years resulted in market volatility across the financial sector.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. For additional information, see the incorrect assumptions or estimates risk factor above. Concentrations of risk to clients or counterparties engaged in the same or related industries or doing business in a particular geography, or to a particular product or asset class, especially credit and market risks, can also increase Citi's risk of significant losses. For example, 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 (see Note 28). A rapid deterioration of a large borrower or other counterparty or within a sector or country in which Citi has large exposures or indemnifications or unexpected market dislocations could lead to concerns about the creditworthiness of other borrowers or counterparties in a certain geography and in related or dependent industries, and such conditions could cause Citi to incur significant losses.LIQUIDITY RISKSCiti's Businesses, Results of Operations and Financial Condition Could Be Negatively Impacted if It Does Not Effectively Manage Its Liquidity. As a large, global financial institution, adequate liquidity and sources of funding are essential to Citi's businesses. Citi's liquidity, sources of funding and costs of funding can be significantly and negatively impacted by factors it cannot control, such as general disruptions in the financial markets; changes in fiscal and monetary policies; regulatory requirements, including changes in regulations; negative investor or counterparty perceptions of Citi's creditworthiness; deposit outflows or unfavorable changes in deposit mix; unexpected increases in cash or collateral requirements; credit ratings; and the consequent inability to monetize available liquidity resources. In addition, Citi competes with other banks example, a weakening of economic conditions can adversely affect borrowers' ability to repay their obligations, as well as result in Citi being unable to liquidate the collateral it holds or forced to liquidate the collateral at prices that do not cover the full amount owed to Citi. Citi is also a member of various central clearing counterparties and could incur financial losses as a result of defaults by other clearing members due to the requirements of clearing members to share losses. Additionally, due to the interconnectedness among financial institutions, concerns about the creditworthiness of or defaults by a financial institution could spread to other financial market participants and result in market-wide losses and disruption. For example, the failure of regional banks and other banking stresses in recent years resulted in market volatility across the financial sector. 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. For additional information, see the incorrect assumptions or estimates risk factor above. Concentrations of risk to clients or counterparties engaged in the same or related industries or doing business in a particular geography, or to a particular product or asset class, especially credit and market risks, can also increase Citi's risk of significant losses. For example, 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 (see Note 28). A rapid deterioration of a large borrower or other counterparty or within a sector or country in which Citi has large exposures or indemnifications or unexpected market dislocations could lead to concerns about the creditworthiness of other borrowers or counterparties in a certain geography and in related or dependent industries, and such conditions could cause Citi to incur significant losses. --- ## Modified: Funded exposure(1) **Key changes:** - Reworded sentence: "Real estate(2) Other industries(3) Total(4) (1) Funded exposure excludes loans carried at fair value of $7.8 billion that are not subject to ACLL under the CECL standard." - Reworded sentence: "90 90 90 Non-Accrual Loans and AssetsThere is a certain amount of overlap among non-accrual loans and assets." - Removed sentence: "Citi's corporate non-accrual loans were $1.9 billion, $2.0 billion and $1.1 billion as of December 31, 2023, September 30, 2023 and December 31, 2022, respectively." - Added sentence: "Uninsured consumer mortgage loans are classified as non-accrual if the loan is 90 days or more past due." - Removed sentence: "Citi's corporate non-accrual loans were $1.9 billion, $2.0 billion and $1.1 billion as of December 31, 2023, September 30, 2023 and December 31, 2022, respectively." **Prior (2024):** Real estate(2) Other industries(3) Total(4) (1) Funded exposure excludes loans carried at fair value of $7.3 billion that are not subject to ACLL under the CECL standard. (2) As of December 31, 2023, the portion of the ACLL attributed to the total funded CRE exposure (including the Private Bank) was approximately 1.49%. (3) Includes $0.6 billion of funded exposure at December 31, 2023, primarily related to commercial credit card delinquency-managed loans. (4) As of December 31, 2023, the ACLL above reflects coverage of 0.3% of funded investment-grade exposure and 2.9% of funded non-investment-grade exposure. The following table details Citi's corporate credit ACLL by industry exposure: December 31, 2022In millions of dollars, except percentagesFunded exposure(1)ACLLACLL as a % of funded exposureTransportation and industrials$57,271 $699 1.2 %Banks and finance companies42,276 225 0.5 Real estate48,539 500 1.0 Commercial34,112 428 1.3 Residential14,427 72 0.5 Consumer retail32,687 358 1.1 Technology, media and telecom28,931 330 1.1 Power, chemicals, metals and mining18,326 288 1.6 Public sector11,736 58 0.5 Energy and commodities13,069 188 1.4 Health8,771 81 0.9 Asset managers and funds13,162 38 0.3 Insurance4,417 11 0.2 Securities firms569 11 1.9 Financial markets infrastructure60 - - Other industries(2)4,217 68 1.6 Total(3)$284,031 $2,855 1.0 % Funded exposure(1) Other industries(2) Total(3) (1) Funded exposure excludes loans carried at fair value of $5.1 billion that are not subject to ACLL under the CECL standard. (2) Includes $0.6 billion of funded exposure at December 31, 2022, primarily related to commercial credit card delinquency-managed loans. (3) As of December 31, 2022, the ACLL above reflects coverage of 0.4% of funded investment-grade exposure and 3.0% of funded non-investment-grade exposure. 87 87 87 Non-Accrual Loans and AssetsThere is a certain amount of overlap among non-accrual loans and assets. The following summary provides a general description of each category:•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 current on principal and interest payments under the terms of the loan structure. Citi's corporate non-accrual loans were $1.9 billion, $2.0 billion and $1.1 billion as of December 31, 2023, September 30, 2023 and December 31, 2022, 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.•U.S. Branded Cards and 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. Non-Accrual Loans and AssetsThere is a certain amount of overlap among non-accrual loans and assets. The following summary provides a general description of each category:•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 current on principal and interest payments under the terms of the loan structure. Citi's corporate non-accrual loans were $1.9 billion, $2.0 billion and $1.1 billion as of December 31, 2023, September 30, 2023 and December 31, 2022, 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.•U.S. Branded Cards and 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. **Current (2025):** Real estate(2) Other industries(3) Total(4) (1) Funded exposure excludes loans carried at fair value of $7.8 billion that are not subject to ACLL under the CECL standard. (2) As of December 31, 2024, the portion of the ACLL attributed to the total funded CRE exposure (including the Private Bank) was approximately 1.60%. (3) Includes $0.6 billion of funded exposure at December 31, 2024, primarily related to commercial credit card delinquency-managed loans. (4) As of December 31, 2024, the ACLL above reflects coverage of 0.4% of funded investment-grade exposure and 2% of funded non-investment-grade exposure. The following table details Citi's corporate credit ACLL by industry exposure: December 31, 2023In millions of dollars, except percentagesFunded exposure(1)ACLLACLL as a % of funded exposureTransportation and industrials$59,917 $453 0.8 %Banks and finance companies52,569 179 0.3 Real estate(2)51,660 663 1.3 Commercial35,058 599 1.7 Residential16,602 64 0.4 Consumer retail33,548 282 0.8 Technology, media and telecom29,832 376 1.3 Power, chemicals, metals and mining19,004 270 1.4 Public sector12,621 102 0.8 Energy and commodities12,606 166 1.3 Health9,135 72 0.8 Asset managers and funds4,232 36 0.9 Insurance2,390 14 0.6 Securities firms734 23 3.1 Financial markets infrastructure156 - - Other industries(3)4,480 78 1.7 Total(4)$292,884 $2,714 0.9 % Funded exposure(1) Real estate(2) Other industries(3) Total(4) (1) Funded exposure excludes loans carried at fair value of $7.3 billion that are not subject to ACLL under the CECL standard. (2) As of December 31, 2023, the portion of the ACLL attributed to the total funded CRE exposure (including the Private Bank) was approximately 1.49%. (3) Includes $0.6 billion of funded exposure at December 31, 2023, primarily related to commercial credit card delinquency-managed loans. (4) As of December 31, 2023, the ACLL above reflects coverage of 0.3% of funded investment-grade exposure and 2.9% of funded non-investment-grade exposure. 90 90 90 Non-Accrual Loans and AssetsThere is a certain amount of overlap among non-accrual loans and assets. The following summary provides a general description of each category:•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 current on principal and interest payments under the terms of the loan structure. •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. Uninsured consumer mortgage loans are classified as non-accrual if the loan is 90 days or more past due. In addition, home equity loans are classified as non-accrual if the related residential first mortgage loan is 90 days or more past due.•U.S. Branded Cards and 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. Non-Accrual Loans and AssetsThere is a certain amount of overlap among non-accrual loans and assets. The following summary provides a general description of each category:•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 current on principal and interest payments under the terms of the loan structure. •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. Uninsured consumer mortgage loans are classified as non-accrual if the loan is 90 days or more past due. In addition, home equity loans are classified as non-accrual if the related residential first mortgage loan is 90 days or more past due.•U.S. Branded Cards and 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. --- ## Modified: Interest Rate Risk of Investment Portfolios - Impact **Key changes:** - Reworded sentence: "on AOCI Citi 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." - Removed sentence: "AOCI at risk considers potential changes in AOCI (and the corresponding impact on the CET1 Capital ratio) relative to Citi's capital generation capacity.Citi uses 100 basis point (bps) shocks in each scenario to reflect its net interest income sensitivity to unanticipated changes in market interest rates, as potential monetary policy decisions and changes in economic conditions may be reflected in current market-implied forward rates." - Removed sentence: "The following table presents the 12-month estimated impact to Citi's net interest income, AOCI and the CET1 Capital ratio, each assuming an unanticipated parallel instantaneous 100 bps increase in interest rates: AOCI at risk is managed as part of the Company-wide interest rate risk position." - Reworded sentence: "31, 2023Parallel interest rate shock +100 bpsInterest rate exposure(1)(2)U.S." **Prior (2024):** 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 CET1 and other regulatory capital ratios. Citi seeks to manage its exposure to changes in the market level of interest rates, while limiting the potential impact on its AOCI and 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 CET1 Capital ratio) relative to Citi's capital generation capacity.Citi uses 100 basis point (bps) shocks in each scenario to reflect its net interest income sensitivity to unanticipated changes in market interest rates, as potential monetary policy decisions and changes in economic conditions may be reflected in current market-implied forward rates. The following table presents the 12-month estimated impact to Citi's net interest income, AOCI and the CET1 Capital ratio, each assuming an unanticipated parallel instantaneous 100 bps increase in interest rates: 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 CET1 Capital ratio) relative to Citi's capital generation capacity. Citi uses 100 basis point (bps) shocks in each scenario to reflect its net interest income sensitivity to unanticipated changes in market interest rates, as potential monetary policy decisions and changes in economic conditions may be reflected in current market-implied forward rates. The following table presents the 12-month estimated impact to Citi's net interest income, AOCI and the CET1 Capital ratio, each assuming an unanticipated parallel instantaneous 100 bps increase in interest rates: In millions of dollars, except as otherwise notedDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Parallel interest rate shock +100 bpsInterest rate exposure(1)(2)U.S. dollar$(33)$82 $186 All other currencies1,219 1,214 1,650 Total$1,186 $1,296 $1,836 As a percentage of average interest-earning assets0.05 %0.06 %0.08 %Estimated initial negative impact to AOCI (after-tax)(2)$(829)$(807)$(1,102)Estimated initial impact on CET1 Capital ratio (bps) from AOCI scenario(12)(12)(10) **Current (2025):** on AOCI Citi 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 CET1 and other regulatory capital ratios. Citi seeks to manage its exposure to changes in the market level of interest rates, while limiting the potential impact on its AOCI and 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 CET1 Capital ratio) relative to Citi's capital generation capacity. Citi uses 100 basis point (bps) shocks in each scenario to reflect its net interest income sensitivity to unanticipated changes in market interest rates, as potential monetary policy decisions and changes in economic conditions may be reflected in current market-implied forward rates. The following table presents the 12-month estimated impact to Citi's net interest income, AOCI and the CET1 Capital ratio, each assuming an unanticipated parallel instantaneous 100 bps increase in interest rates: In millions of dollars, except as otherwise notedDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Parallel interest rate shock +100 bpsInterest rate exposure(1)(2)U.S. dollar$(93)$(227)$(33)All other currencies1,068 1,388 1,219 Total net interest income$975 $1,161 $1,186 As a percentage of average interest-earning assets0.04 %0.05 %0.05 %Estimated initial negative impact to AOCI (after-tax)(2)$(1,111)$(1,084)$(829)Estimated initial impact on CET1 Capital ratio (bps) from AOCI scenario(3)(13)(14)(12) --- ## Modified: Consumer loans, net of unearned income(3) **Key changes:** - Reworded sentence: "In North America offices(1) Mortgage and real estate(2) Installment and other(4) In offices outside North America(1) Mortgage and real estate(2) Installment and other(4)" **Prior (2024):** In North America offices(1) Mortgage and real estate(2) In offices outside North America(1) Mortgage and real estate(2) **Current (2025):** In North America offices(1) Mortgage and real estate(2) Installment and other(4) In offices outside North America(1) Mortgage and real estate(2) Installment and other(4) --- ## Modified: Board and Executive Management Committees **Key changes:** - Reworded sentence: "The Board has delegated authority to the following Board standing committees to help fulfill its oversight and risk management responsibilities: •Audit Committee: assists the Board in fulfilling its oversight responsibility relating to (i) the integrity of Citigroup's consolidated financial statements, financial reporting process and systems of internal accounting and financial controls, (ii) the performance of the internal audit function (Internal Audit), (iii) the annual independent integrated audit of Citigroup's consolidated financial statements and effectiveness of Citigroup's internal control over financial reporting, the engagement of the independent registered public accounting firm (Independent Auditors) and the evaluation of the Independent Auditors' qualifications, independence and performance, (iv) holding management accountable for the effectiveness of Citigroup's control environment and status of corrective actions, including the timely remediation of control breaks (including, without limitation, significant compliance or operational control breaks), (v) policy standards and guidelines for risk assessment and risk management, (vi) Citigroup's compliance with legal and regulatory requirements, including Citigroup's disclosure controls and procedures and (vii) the fulfillment of the other responsibilities set out in the Audit Committee's Charter." - Reworded sentence: "These consist of:•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 Business Risk and Control Committee (GBRCC): provides governance oversight of Citi's compliance and operational risks and is responsible for ensuring that these risks are adequately identified, monitored, reported, managed and escalated, and that appropriate action is taken." - Reworded sentence: "The figure below illustrates the reporting lines between the Board and Executive Management committees: 71 71 71 CREDIT RISKOverviewCredit 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." - Reworded sentence: "Citi's loans are reported in two categories: corporate and consumer." - Reworded sentence: "See Notes 15 and 16 for additional information on Citi's credit risk management." **Prior (2024):** The Board executes its responsibilities either directly or through its committees. The Board has delegated authority 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 and risk culture, including the significant policies and practices used in managing credit, market (trading and non-trading), liquidity, strategic, operational, compliance, reputation and certain other risks, including those pertaining to capital management, and (ii) oversight of the Global Risk Review - credit, capital and collateral review functions.•Audit Committee: provides oversight of Citi's financial and regulatory reporting and internal control risk, as well as Internal Audit and Citi's external independent accountants.•Compensation, Performance Management and Culture Committee: provides oversight of compensation of Citi's employees and Citi management's sustained focus on fostering a principled culture of sound ethics, responsible conduct and accountability within the organization.•Nomination, Governance and Public Affairs Committee: responsible for (i) identifying individuals qualified to become Board members and recommending to the Board the director nominees for the next annual meeting of stockholders, (ii) leading the Board in its annual review of the Board's performance, (iii) recommending to the Board directors for each committee for appointment by the Board, (iv) reviewing the Company's policies and programs that relate to public issues of significance to the Company and the public at large, including but not limited to Environmental, Social and Corporate Governance (ESG) matters and (v) reviewing the Company's relationships with external constituencies and issues that impact the Company's reputation, and advising management as to its approach to each.•Technology Committee: assists the Board in fulfilling its responsibility with respect to oversight of (i) the planning and execution of Citigroup's technology, strategy and operating plan, (ii) the development of Citi's target state operating model and architecture, including the incorporation of Global Business Services, (iii) technology-based risk management, including risk management framework, risk appetite and risk exposures of the Company, (iv) resource and talent planning of the Technology function and (v) the Company's third-party management policies, practices and standards that relate to Technology.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 FRB and OCC consent orders (see "Citi's Consent Order Compliance" above).The Citigroup CEO has established four standing committees that cover the primary risks to which Citi (i.e., Group) is exposed. These consist of:•Group Risk Management Committee (GRMC): the primary senior executive level committee responsible for (i) overseeing the execution of Citigroup's ERM Framework, (ii) monitoring Citi's risk profile at an aggregate level inclusive of individual risk categories, (iii) ensuring that Citi's risk profile remains consistent with its approved risk appetite and (iv) discussing material and emerging risk issues facing the Company. The Committee also provides comprehensive Group-wide coverage of all capital management, and (ii) oversight of the Global Risk Review - credit, capital and collateral review functions. •Audit Committee: provides oversight of Citi's financial and regulatory reporting and internal control risk, as well as Internal Audit and Citi's external independent accountants. •Compensation, Performance Management and Culture Committee: provides oversight of compensation of Citi's employees and Citi management's sustained focus on fostering a principled culture of sound ethics, responsible conduct and accountability within the organization. •Nomination, Governance and Public Affairs Committee: responsible for (i) identifying individuals qualified to become Board members and recommending to the Board the director nominees for the next annual meeting of stockholders, (ii) leading the Board in its annual review of the Board's performance, (iii) recommending to the Board directors for each committee for appointment by the Board, (iv) reviewing the Company's policies and programs that relate to public issues of significance to the Company and the public at large, including but not limited to Environmental, Social and Corporate Governance (ESG) matters and (v) reviewing the Company's relationships with external constituencies and issues that impact the Company's reputation, and advising management as to its approach to each. •Technology Committee: assists the Board in fulfilling its responsibility with respect to oversight of (i) the planning and execution of Citigroup's technology, strategy and operating plan, (ii) the development of Citi's target state operating model and architecture, including the incorporation of Global Business Services, (iii) technology-based risk management, including risk management framework, risk appetite and risk exposures of the Company, (iv) resource and talent planning of the Technology function and (v) the Company's third-party management policies, practices and standards that relate to Technology. 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 FRB and OCC consent orders (see "Citi's Consent Order Compliance" above). The Citigroup CEO has established four standing committees that cover the primary risks to which Citi (i.e., Group) is exposed. These consist of: •Group Risk Management Committee (GRMC): the primary senior executive level committee responsible for (i) overseeing the execution of Citigroup's ERM Framework, (ii) monitoring Citi's risk profile at an aggregate level inclusive of individual risk categories, (iii) ensuring that Citi's risk profile remains consistent with its approved risk appetite and (iv) discussing material and emerging risk issues facing the Company. The Committee also provides comprehensive Group-wide coverage of all 67 67 67 risk categories, including Credit Risk, Market Risk (trading) and Strategic Risk.•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 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, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. risk categories, including Credit Risk, Market Risk (trading) and Strategic Risk.•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 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, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. risk categories, including Credit Risk, Market Risk (trading) and Strategic Risk. •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 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, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. The figure below illustrates the reporting lines between the Board and Executive Management committees: 68 68 68 CREDIT RISK OverviewCredit 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 is one of the most significant risks Citi faces as an institution (see "Risk Factors - Credit Risks" above). Credit risk arises in many of Citigroup's business activities, including:•consumer, commercial and corporate lending; •capital markets derivative transactions; •structured finance; and •securities financing transactions (repurchase and reverse repurchase agreements, and securities loaned and borrowed).Credit risk also arises from clearing and settlement activities, when Citi transfers an asset in advance of receiving its counter-value or advances funds to settle a transaction on behalf of a client. Concentration risk, within credit risk, is the risk associated with having credit exposure concentrated within a specific client, industry, region or other category.Citi has an established framework in place for managing credit risk across all businesses that includes a defined risk appetite, credit limits and credit policies. Citi's credit risk management framework also includes policies and procedures to manage problem exposures.To manage concentration risk, Citi has in place a framework consisting of industry limits, single-name concentrations for each business and across Citigroup and a specialized product limit framework.Credit exposures are generally reported in notional terms for accrual loans, reflecting the value at which the loans as well as other off-balance sheet commitments are carried on the Consolidated Balance Sheet. Credit exposure arising from capital markets activities is generally expressed as the current mark-to-market, net of margin, reflecting the net value owed to Citi by a given counterparty. The credit risk associated with Citi's 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 allowance for credit losses (ACL) process (see "Significant Accounting Policies and Significant Estimates - Allowance for Credit Losses" below and Notes 1 and 16), 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. See Note 15 for additional information on Citi's credit risk management. LoansThe table below details the average loans, by business and/or segment, and the total Citigroup end-of-period loans for each of the periods indicated:In billions of dollars4Q233Q234Q22Services$83 $83 $78 Markets115 108 111 Banking87 87 96 USPB Branded Cards$107 $103 $95 Retail Services52 50 48 Retail Banking43 43 37 Total USPB$202 $196 $180 Wealth$150 $151 $150 All Other(1)$38 $37 $38 Total Citigroup loans (AVG)$675 $662 $653 Total Citigroup loans (EOP)$689 $666 $657 (1)See footnote 2 to the table in "Credit Risk - Consumer Credit - Consumer Credit Portfolio" below.End-of-period loans increased 5% year-over-year, largely reflecting growth in cards in USPB. End-of-period loans increased 3% sequentially.On an average basis, loans increased 3% year-over-year and 2% sequentially. The year-over-year increase was largely due to growth in USPB, Services and Markets, partially offset by a decline in Banking. As of the fourth quarter of 2023, average loans for: •USPB increased 12% year-over-year, driven by growth in Branded Cards, Retail Banking and Retail Services. •Wealth were largely unchanged. •Services increased 6% year-over-year, primarily driven by strong demand for working capital loans in TTS in North America and internationally. •Markets increased 4% year-over-year, reflecting increased client demand in warehouse lending. •Banking decreased 9% year-over-year, primarily driven by capital optimization efforts. CREDIT RISK OverviewCredit 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 is one of the most significant risks Citi faces as an institution (see "Risk Factors - Credit Risks" above). Credit risk arises in many of Citigroup's business activities, including:•consumer, commercial and corporate lending; •capital markets derivative transactions; •structured finance; and •securities financing transactions (repurchase and reverse repurchase agreements, and securities loaned and borrowed).Credit risk also arises from clearing and settlement activities, when Citi transfers an asset in advance of receiving its counter-value or advances funds to settle a transaction on behalf of a client. Concentration risk, within credit risk, is the risk associated with having credit exposure concentrated within a specific client, industry, region or other category.Citi has an established framework in place for managing credit risk across all businesses that includes a defined risk appetite, credit limits and credit policies. Citi's credit risk management framework also includes policies and procedures to manage problem exposures.To manage concentration risk, Citi has in place a framework consisting of industry limits, single-name concentrations for each business and across Citigroup and a specialized product limit framework.Credit exposures are generally reported in notional terms for accrual loans, reflecting the value at which the loans as well as other off-balance sheet commitments are carried on the Consolidated Balance Sheet. Credit exposure arising from capital markets activities is generally expressed as the current mark-to-market, net of margin, reflecting the net value owed to Citi by a given counterparty. The credit risk associated with Citi's 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 allowance for credit losses (ACL) process (see "Significant Accounting Policies and Significant Estimates - Allowance for Credit Losses" below and Notes 1 and 16), 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. See Note 15 for additional information on Citi's credit risk management. **Current (2025):** The Board executes its responsibilities either directly or through its committees. The Board has delegated authority to the following Board standing committees to help fulfill its oversight and risk management responsibilities: •Audit Committee: assists the Board in fulfilling its oversight responsibility relating to (i) the integrity of Citigroup's consolidated financial statements, financial reporting process and systems of internal accounting and financial controls, (ii) the performance of the internal audit function (Internal Audit), (iii) the annual independent integrated audit of Citigroup's consolidated financial statements and effectiveness of Citigroup's internal control over financial reporting, the engagement of the independent registered public accounting firm (Independent Auditors) and the evaluation of the Independent Auditors' qualifications, independence and performance, (iv) holding management accountable for the effectiveness of Citigroup's control environment and status of corrective actions, including the timely remediation of control breaks (including, without limitation, significant compliance or operational control breaks), (v) policy standards and guidelines for risk assessment and risk management, (vi) Citigroup's compliance with legal and regulatory requirements, including Citigroup's disclosure controls and procedures and (vii) the fulfillment of the other responsibilities set out in the Audit Committee's Charter. •Compensation, Performance Management and Culture Committee: is responsible for overseeing compensation of employees of the Company and its subsidiaries and affiliates and Citi management's sustained focus on fostering a principled culture of sound ethics, responsible conduct and accountability within the organization. The Committee regularly reviews Citi's management resources and the performance of senior management. The Committee is responsible for determining the compensation for the Chief Executive Officer and approving the compensation of other executive officers of the Company and members of Citi's Executive Management Team. The Committee is also responsible for approving the incentive compensation structure for other members of senior management and certain highly compensated employees (including discretionary incentive awards to covered employees as defined in applicable bank regulatory guidance), in accordance with guidelines established by the Committee from time to time. The Committee also has broad oversight over compliance with bank regulatory guidance governing Citi's incentive compensation. •Nomination, Governance and Public Affairs Committee: is responsible for (i) identifying individuals qualified to become Board members and recommending to the Board the director nominees for the next annual meeting of stockholders, (ii) leading the Board in its annual review of the Board's performance, (iii) recommending to the Board directors for each committee for appointment by the Board, (iv) reviewing the Company's policies and programs that relate to public issues of significance to the 70 70 70 Company and the public at large and (v) reviewing the Company's relationships with external constituencies and issues that impact the Company's reputation, and advising management as to its approach to each.•Risk Management Committee: assists the Board in fulfilling its responsibility with respect to (i) oversight of Citigroup's risk management framework and risk culture, including the significant policies and practices used in managing credit, market (trading and non-trading), liquidity, strategic, operational, compliance and reputation, including those pertaining to capital management, and (ii) oversight of the performance of the Global Risk Review (GRR) credit and collateral review function. The Committee reports to the Board of Directors regarding Citigroup's risk profile, as well as management's adherence to its risk management framework, including the significant policies and practices employed to manage risks in Citigroup, as well as the overall adequacy of the Risk Management function.•Technology Committee: assists the Board in fulfilling its responsibility for oversight of the Company and its subsidiaries and affiliates with respect to (i) the planning and execution of Citigroup's technology strategy and operating plan, (ii) the development of Citi's target state operating model and architecture, (iii) technology-based risk management, including risk management framework, risk appetite and risk exposures of the Company, including cybersecurity, (iv) resource and talent planning of the Technology function and (v) the Company's third-party management policies, practices and standards that relate to Technology. 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 FRB and OCC Consent Orders (see "Citi's Multiyear Transformation - FRB and OCC Consent Orders Compliance" above).The Citigroup CEO has established four standing committees that cover the primary risks to which Citi (i.e., Group) is exposed. These consist of:•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 Business Risk and Control Committee (GBRCC): provides governance oversight of Citi's compliance and operational risks and is responsible for ensuring that these risks are adequately identified, monitored, reported, managed and escalated, and that appropriate action is taken. •Group Reputation Risk Committee (GRRC): provides governance oversight for reputation risk management across Citi, while promoting the culture of risk awareness and high standards of culture and conduct.•Group Risk Management Committee (GRMC): the primary senior executive level committee responsible for (i) overseeing the execution of Citigroup's ERM Framework, (ii) monitoring Citi's risk profile at an aggregate level inclusive of individual risk categories, (iii) ensuring that Citi's risk profile remains consistent with its approved risk appetite and (iv) discussing material and emerging risks facing the Company. The Committee also provides comprehensive Group-wide coverage of credit risk, market risk (trading) and strategic risk.In addition to the Executive Management committees listed above, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. Company and the public at large and (v) reviewing the Company's relationships with external constituencies and issues that impact the Company's reputation, and advising management as to its approach to each.•Risk Management Committee: assists the Board in fulfilling its responsibility with respect to (i) oversight of Citigroup's risk management framework and risk culture, including the significant policies and practices used in managing credit, market (trading and non-trading), liquidity, strategic, operational, compliance and reputation, including those pertaining to capital management, and (ii) oversight of the performance of the Global Risk Review (GRR) credit and collateral review function. The Committee reports to the Board of Directors regarding Citigroup's risk profile, as well as management's adherence to its risk management framework, including the significant policies and practices employed to manage risks in Citigroup, as well as the overall adequacy of the Risk Management function.•Technology Committee: assists the Board in fulfilling its responsibility for oversight of the Company and its subsidiaries and affiliates with respect to (i) the planning and execution of Citigroup's technology strategy and operating plan, (ii) the development of Citi's target state operating model and architecture, (iii) technology-based risk management, including risk management framework, risk appetite and risk exposures of the Company, including cybersecurity, (iv) resource and talent planning of the Technology function and (v) the Company's third-party management policies, practices and standards that relate to Technology. 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 FRB and OCC Consent Orders (see "Citi's Multiyear Transformation - FRB and OCC Consent Orders Compliance" above). Company and the public at large and (v) reviewing the Company's relationships with external constituencies and issues that impact the Company's reputation, and advising management as to its approach to each. •Risk Management Committee: assists the Board in fulfilling its responsibility with respect to (i) oversight of Citigroup's risk management framework and risk culture, including the significant policies and practices used in managing credit, market (trading and non-trading), liquidity, strategic, operational, compliance and reputation, including those pertaining to capital management, and (ii) oversight of the performance of the Global Risk Review (GRR) credit and collateral review function. The Committee reports to the Board of Directors regarding Citigroup's risk profile, as well as management's adherence to its risk management framework, including the significant policies and practices employed to manage risks in Citigroup, as well as the overall adequacy of the Risk Management function. •Technology Committee: assists the Board in fulfilling its responsibility for oversight of the Company and its subsidiaries and affiliates with respect to (i) the planning and execution of Citigroup's technology strategy and operating plan, (ii) the development of Citi's target state operating model and architecture, (iii) technology-based risk management, including risk management framework, risk appetite and risk exposures of the Company, including cybersecurity, (iv) resource and talent planning of the Technology function and (v) the Company's third-party management policies, practices and standards that relate to Technology. 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 FRB and OCC Consent Orders (see "Citi's Multiyear Transformation - FRB and OCC Consent Orders Compliance" above). The Citigroup CEO has established four standing committees that cover the primary risks to which Citi (i.e., Group) is exposed. These consist of:•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 Business Risk and Control Committee (GBRCC): provides governance oversight of Citi's compliance and operational risks and is responsible for ensuring that these risks are adequately identified, monitored, reported, managed and escalated, and that appropriate action is taken. •Group Reputation Risk Committee (GRRC): provides governance oversight for reputation risk management across Citi, while promoting the culture of risk awareness and high standards of culture and conduct.•Group Risk Management Committee (GRMC): the primary senior executive level committee responsible for (i) overseeing the execution of Citigroup's ERM Framework, (ii) monitoring Citi's risk profile at an aggregate level inclusive of individual risk categories, (iii) ensuring that Citi's risk profile remains consistent with its approved risk appetite and (iv) discussing material and emerging risks facing the Company. The Committee also provides comprehensive Group-wide coverage of credit risk, market risk (trading) and strategic risk.In addition to the Executive Management committees listed above, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. The Citigroup CEO has established four standing committees that cover the primary risks to which Citi (i.e., Group) is exposed. These consist of: •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 Business Risk and Control Committee (GBRCC): provides governance oversight of Citi's compliance and operational risks and is responsible for ensuring that these risks are adequately identified, monitored, reported, managed and escalated, and that appropriate action is taken. •Group Reputation Risk Committee (GRRC): provides governance oversight for reputation risk management across Citi, while promoting the culture of risk awareness and high standards of culture and conduct. •Group Risk Management Committee (GRMC): the primary senior executive level committee responsible for (i) overseeing the execution of Citigroup's ERM Framework, (ii) monitoring Citi's risk profile at an aggregate level inclusive of individual risk categories, (iii) ensuring that Citi's risk profile remains consistent with its approved risk appetite and (iv) discussing material and emerging risks facing the Company. The Committee also provides comprehensive Group-wide coverage of credit risk, market risk (trading) and strategic risk. In addition to the Executive Management committees listed above, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. The figure below illustrates the reporting lines between the Board and Executive Management committees: 71 71 71 CREDIT RISKOverviewCredit 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. For example, credit risk can arise from a deterioration in (i) the operating and financial performance of a borrower or (ii) a decline in the quality or value of any underlying collateral, both of which may also be impacted by adverse changes in macroeconomic, geopolitical, market and other factors. Credit risk is one of the most significant risks Citi faces as an institution (see "Risk Factors - Credit Risks" above). Credit risk arises in many of Citigroup's business activities, including:•consumer, commercial and corporate lending; •capital markets derivative transactions; •structured finance; and •securities financing transactions (repurchase and reverse repurchase agreements, and securities loaned and borrowed).Credit risk also arises from clearing and settlement activities, when Citi transfers an asset in advance of receiving its counter-value or advances funds to settle a transaction on behalf of a client. Concentration risk, within credit risk, is the risk associated with having credit exposure concentrated within a specific client, industry, region or other category.Citi has an established framework in place for managing credit risk across all businesses that includes a defined risk appetite, credit limits and credit policies. Citi's credit risk management framework also includes policies and procedures to manage problem exposures.To manage concentration risk, Citi has in place a framework consisting of industry limits, single-name concentrations for each business and across Citigroup and a specialized product limit framework.Credit exposures are generally reported in notional terms for accrual loans, reflecting the value at which the loans as well as other off-balance sheet commitments are carried on the Consolidated Balance Sheet. Credit exposure arising from capital markets activities is generally expressed as the current mark-to-market, net of margin, reflecting the net value owed to Citi by a given counterparty. Citi's loans are reported in two categories: corporate and consumer. These categories are classified primarily according to the operating segment, reporting unit and component that manage the loans in addition to the nature of the obligor, with corporate loans generally made for corporate institutional and public sector clients around the world and consumer loans to retail and small business customers.The credit risk associated with Citi's 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 allowance for credit losses (ACL) process (see "Significant Accounting Policies and Significant Estimates - Allowance for Credit Losses" below and Notes 1 and 16), 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. See Notes 15 and 16 for additional information on Citi's credit risk management. LoansThe table below details the average loans, by segment and/or business, and the total Citigroup end-of-period loans for each of the periods indicated:In billions of dollars4Q243Q244Q23Services$87 $87 $83 Markets122 119 115 Banking84 88 89 Wealth148 150 150 USPB Branded Cards$113 $111 $107 Retail Services52 51 52 Retail Banking51 48 43 Total USPB$216 $210 $202 All Other$31 $33 $36 Total Citigroup loans (AVG)$688 $687 $675 Total Citigroup loans (EOP)$694 $689 $689 On an average basis, loans increased 2% year-over-year and were relatively unchanged sequentially. The year-over-year increase was largely due to growth in USPB, Markets and Services. As of the fourth quarter of 2024, average loans for: •Services increased 5% year-over-year, primarily driven by strong demand in TTS for export and agency finance, as well as working capital loans. •Markets increased 6% year-over-year, largely driven by asset-backed securitization lending and North America residential financing in spread products. •Banking decreased 6% year-over-year, primarily driven by regulatory capital optimization efforts. •Wealth decreased 1%, primarily driven by regulatory capital optimization efforts. •USPB increased 7% year-over-year, driven by growth in Retail Banking due to an increase in mortgage loans as a result of lower refinancings due to a higher interest rate environment and higher mortgage originations, as well as Branded Cards due to lower card payment rates and higher card spend volume.End-of-period loans increased 1% year-over-year and sequentially. The year-over-year increase was largely due to growth in Branded Cards and Retail Banking in USPB, as well as growth in Markets and Services. CREDIT RISKOverviewCredit 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. For example, credit risk can arise from a deterioration in (i) the operating and financial performance of a borrower or (ii) a decline in the quality or value of any underlying collateral, both of which may also be impacted by adverse changes in macroeconomic, geopolitical, market and other factors. Credit risk is one of the most significant risks Citi faces as an institution (see "Risk Factors - Credit Risks" above). Credit risk arises in many of Citigroup's business activities, including:•consumer, commercial and corporate lending; •capital markets derivative transactions; •structured finance; and •securities financing transactions (repurchase and reverse repurchase agreements, and securities loaned and borrowed).Credit risk also arises from clearing and settlement activities, when Citi transfers an asset in advance of receiving its counter-value or advances funds to settle a transaction on behalf of a client. Concentration risk, within credit risk, is the risk associated with having credit exposure concentrated within a specific client, industry, region or other category.Citi has an established framework in place for managing credit risk across all businesses that includes a defined risk appetite, credit limits and credit policies. Citi's credit risk management framework also includes policies and procedures to manage problem exposures.To manage concentration risk, Citi has in place a framework consisting of industry limits, single-name concentrations for each business and across Citigroup and a specialized product limit framework.Credit exposures are generally reported in notional terms for accrual loans, reflecting the value at which the loans as well as other off-balance sheet commitments are carried on the Consolidated Balance Sheet. Credit exposure arising from capital markets activities is generally expressed as the current mark-to-market, net of margin, reflecting the net value owed to Citi by a given counterparty. Citi's loans are reported in two categories: corporate and consumer. These categories are classified primarily according to the operating segment, reporting unit and component that manage the loans in addition to the nature of the obligor, with corporate loans generally made for corporate institutional and public sector clients around the world and consumer loans to retail and small business customers.The credit risk associated with Citi's 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 allowance for credit losses (ACL) process (see "Significant Accounting Policies and Significant Estimates - Allowance for Credit Losses" below and Notes 1 --- ## Modified: ACLL by type at end of year(11) **Key changes:** - Reworded sentence: "(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." - Reworded sentence: "(9)December 31, 2024, 2023, 2022, 2021 and 2020 exclude $8.0 billion, $7.6 billion, $5.4 billion, $6.1 billion and $6.9 billion, respectively, of loans that are carried at fair value." **Prior (2024):** (1)On January 1, 2023, Citi adopted Accounting Standards Update (ASU) 2022-02, Financial Instruments - Credit Losses (Topic 326): TDRs and Vintage Disclosures. The ASU eliminated the accounting and disclosure requirements for TDRs, including the requirement to measure the ACLL for TDRs using a discounted cash flow (DCF) approach. On January 1, 2023, Citi recorded a $352 million decrease in the Allowance for loan losses, along with a $290 million after-tax increase to Retained earnings. See Note 1. (2)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. (3)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. (4)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. (5)2023 includes an approximate $175 million increase related to FX translation. (6)2022 includes an approximate $350 million reclass related to the announced sales of Citi's consumer banking businesses in Thailand, India, Malaysia, Taiwan, Indonesia, Bahrain and Vietnam. Also includes a decrease of approximately $100 million related to FX translation. (7)2021 includes an approximate $280 million reclass related to Citi's agreement to sell its Australia consumer banking business and an approximate $90 million reclass related to Citi's agreement to sell its Philippines consumer banking business. Those ACLL were reclassified to Other assets during 2021. 2021 also includes a decrease of approximately $134 million related to FX translation. (8)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. (9)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. (10)December 31, 2023, 2022, 2021, 2020 and 2019 exclude $7.6 billion, $5.4 billion, $6.1 billion, $6.9 billion and $4.1 billion, respectively, of loans that are carried at fair value. (11)Represents additional credit reserves recorded as Other liabilities on the Consolidated Balance Sheet. (12)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. (13)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." 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. 85 85 85 **Current (2025):** (1)On January 1, 2023, Citi adopted Accounting Standards Update (ASU) 2022-02, Financial Instruments - Credit Losses (Topic 326): TDRs and Vintage Disclosures. The ASU eliminated the accounting and disclosure requirements for TDRs, including the requirement to measure the ACLL for TDRs using a discounted cash flow (DCF) approach. On January 1, 2023, Citi recorded a $352 million decrease in the Allowance for loan losses, along with a $290 million after-tax increase to Retained earnings. See Note 1. (2)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. (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)2024 includes an approximate $300 million decrease related to FX translation, as well as an initial allowance for credit losses on newly purchased credit-deteriorated assets during the year. (5)2023 includes an approximate $175 million increase related to FX translation. (6)2022 includes an approximate $350 million reclass related to the announced sales of Citi's consumer banking businesses in Thailand, India, Malaysia, Taiwan, Indonesia, Bahrain and Vietnam. Also includes a decrease of approximately $100 million related to FX translation. (7)2021 includes an approximate $280 million reclass related to Citi's agreement to sell its Australia consumer banking business and an approximate $90 million reclass related to Citi's agreement to sell its Philippines consumer banking business. Those ACLL were reclassified to Other assets during 2021. 2021 also includes a decrease of approximately $134 million related to FX translation. (8)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. (9)December 31, 2024, 2023, 2022, 2021 and 2020 exclude $8.0 billion, $7.6 billion, $5.4 billion, $6.1 billion and $6.9 billion, respectively, of loans that are carried at fair value. (10)Represents additional credit reserves recorded as Other liabilities on the Consolidated Balance Sheet. (11)The ACLL represents management's estimate of expected credit losses in the portfolio and troubled debt restructurings. See "Significant Accounting Policies and Significant Estimates" below. Attribution of the allowance is made for analytical purposes only and is available to absorb probable credit losses inherent in the overall portfolio. 88 88 88 --- ## Modified: A Deterioration in or Failure to Maintain Citi's Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi. **Key changes:** - Reworded sentence: "Citi has co-branding and private label relationships with various retailers and merchants through its Branded Cards and Retail Services credit card businesses in USPB, whereby in the ordinary course of business Citi issues credit cards to consumers, including customers of the retailers or merchants." - Reworded sentence: "Competition among credit card issuers, including Citi, for these relationships is significant, and Citi may not be able to maintain such relationships on existing terms or at all." - Reworded sentence: "The Application of U.S." - Reworded sentence: "In addition, a wholly owned, direct subsidiary of Citigroup serves as a resolution funding vehicle (the intermediate holding company, or IHC) to which Citigroup has transferred, and has agreed to transfer on an ongoing basis, certain assets." - Reworded sentence: "Citi's single point of entry resolution plan strategy and the obligations under the amended and restated secured support agreement may result in the recapitalization of and/or provision of liquidity to Citi's operating material legal entities, and the commencement of bankruptcy proceedings by Citigroup at an earlier stage of financial stress than might otherwise occur without such mechanisms in place.In line with the FRB's total loss-absorbing capacity (TLAC) rule, Citigroup's shareholders and unsecured creditors - including its unsecured long-term debt holders - would bear any losses resulting from Citigroup's bankruptcy." **Prior (2024):** Citi has co-branding and private label relationships through its Branded Cards and Retail Services credit card businesses with various retailers and merchants, whereby in the ordinary course of business Citi issues credit cards to consumers, including customers of the retailers or merchants. The five largest relationships across both businesses in USPB constituted an aggregate of approximately 11% of Citi's revenues in 2023 (see "U.S. Personal Banking" above). Citi's co-branding and private label agreements often provide for shared economics between the parties and generally have a fixed term. Competition among card issuers, including Citi, for these relationships is significant, and Citi may not be able to maintain such relationships on existing terms or at all. Citi's co-branding and private label relationships could also be negatively impacted by, among other things, the general economic environment, including the impacts of continued elevated interest rates and inflation, and lower economic growth rates, as well as a continuing risk of recession; changes in consumer sentiment, spending patterns and credit card usage behaviors; a decline in sales and revenues, partner store closures, any reduction in 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 a challenging macroeconomic environment or otherwise. These events, particularly early termination and bankruptcies or liquidations, could negatively impact the results of operations or financial condition of Branded Cards, 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 (see Note 17 for information on Citi's credit card related intangibles generally). 52 52 52 The Application of U.S. Resolution Plan Requirements May Pose a Greater Risk of Loss to Citi's Debt and Equity Securities Holders, and Citi's Inability in Its Resolution Plan Submissions to Address Any Shortcomings or Deficiencies or Guidance 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. 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 2023 resolution plan, which can be found on the FRB's and FDIC's websites) would remain operational outside of any resolution or insolvency proceedings. As a result, Citigroup's losses and any losses incurred by its material legal entity subsidiaries would be imposed first on holders of Citigroup's equity securities and thereafter on its unsecured creditors, including holders of eligible long-term debt and other debt securities. In addition, a wholly owned, direct subsidiary of Citigroup serves as a resolution funding vehicle (the IHC) to which Citigroup has transferred, and has agreed to transfer on an ongoing basis, certain assets. The obligations of Citigroup and of the IHC, respectively, under the amended and restated secured support agreement, are secured on a senior basis by the assets of Citigroup (other than shares in subsidiaries of the parent company and certain other assets), and the assets of the IHC, as applicable. As a result, claims of the operating material legal entities against the assets of Citigroup with respect to such secured assets are effectively senior to unsecured obligations of Citigroup. Citi's single point of entry resolution plan strategy and the obligations under the amended and restated secured support agreement may result in the recapitalization of and/or provision of liquidity to Citi's operating material legal entities, and the commencement of bankruptcy proceedings by Citigroup at an earlier stage of financial stress than might otherwise occur without such mechanisms in place.In line with the FRB's TLAC rule, Citigroup's shareholders and unsecured creditors - including its unsecured long-term debt holders - would 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. For additional information on Citi's single point of entry resolution plan strategy and the IHC and secured support agreement, see "Managing Global Risk - Liquidity Risk" below.On November 22, 2022, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2021 by the eight U.S. GSIBs, including Citi. The FRB and FDIC identified one shortcoming, but no deficiencies, in Citi's 2021 resolution plan. The shortcoming related to data integrity and data quality management issues, specifically, weaknesses in Citi's processes and practices for producing certain data that could materially impact its resolution capabilities. If a shortcoming is not satisfactorily explained or addressed before, or in, the submission of the next resolution plan, the shortcoming may be found to be a deficiency in the next resolution plan (see discussion below). Citi submitted its 2023 resolution plan in June 2023. More generally, data continuesto be a subject of regulatory focus, and Citi continues to workon enhancing its data availability and quality.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 understood to mean the regulators do not believe the plan is feasible or would otherwise allow Citi to be resolved in a way that protects systemically important functions without severe systemic disruption), or would not facilitate an orderly resolution of Citi under the U.S. Bankruptcy Code, and Citi fails to resubmit a resolution plan that remedies any identified deficiencies, Citi could be subjected to more stringent capital, leverage or liquidity requirements, or restrictions on its growth, activities or operations. If within two years from the imposition of any such requirements or restrictions Citi has still not remediated any identified deficiencies, then Citi could eventually be required to divest certain assets or operations. Any such restrictions or actions would negatively impact Citi's reputation, market and investor perception, operations and strategy.Citi's Performance and Its Ability to Effectively Execute Its Transformation and Strategic and Other Initiatives Could Be Negatively Impacted if It Is Not Able to Hire and Retain Qualified Employees.Citi's performance and the performance of its individual businesses largely depend on the talents and efforts of its diverse and highly qualified colleagues. Specifically, Citi's continued ability to compete in each of its lines of business, to manage its businesses effectively and to execute its transformation and strategic and other initiatives, including, for example, hiring front office colleagues to grow businesses or hiring colleagues to support Citi's transformation and strategic and other initiatives, depends on its ability to attract new colleagues and to retain and motivate its existing colleagues. If Citi is unable to continue to attract, retain and motivate highly qualified colleagues, Citi's performance, including its competitive position, the execution of its transformation and strategic and other initiatives and its results of operations could be negatively impacted.Citi's ability to attract, retain and motivate colleagues depends on numerous factors, some of which are outside of Citi's control. For example, the competition for talent continues to be particularly intense due to factors such as low unemployment and changes in worker expectations, concerns and preferences, including an increased demand for remote work options and other job flexibility. Also, the banking industry generally is subject to more comprehensive regulation of employee compensation than other industries, including deferral and clawback requirements for incentive compensation, which can make it unusually challenging for Citi to compete in labor markets against businesses, including, for example, technology companies, that are not subject to The Application of U.S. Resolution Plan Requirements May Pose a Greater Risk of Loss to Citi's Debt and Equity Securities Holders, and Citi's Inability in Its Resolution Plan Submissions to Address Any Shortcomings or Deficiencies or Guidance 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. 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 2023 resolution plan, which can be found on the FRB's and FDIC's websites) would remain operational outside of any resolution or insolvency proceedings. As a result, Citigroup's losses and any losses incurred by its material legal entity subsidiaries would be imposed first on holders of Citigroup's equity securities and thereafter on its unsecured creditors, including holders of eligible long-term debt and other debt securities. In addition, a wholly owned, direct subsidiary of Citigroup serves as a resolution funding vehicle (the IHC) to which Citigroup has transferred, and has agreed to transfer on an ongoing basis, certain assets. The obligations of Citigroup and of the IHC, respectively, under the amended and restated secured support agreement, are secured on a senior basis by the assets of Citigroup (other than shares in subsidiaries of the parent company and certain other assets), and the assets of the IHC, as applicable. As a result, claims of the operating material legal entities against the assets of Citigroup with respect to such secured assets are effectively senior to unsecured obligations of Citigroup. Citi's single point of entry resolution plan strategy and the obligations under the amended and restated secured support agreement may result in the recapitalization of and/or provision of liquidity to Citi's operating material legal entities, and the commencement of bankruptcy proceedings by Citigroup at an earlier stage of financial stress than might otherwise occur without such mechanisms in place.In line with the FRB's TLAC rule, Citigroup's shareholders and unsecured creditors - including its unsecured long-term debt holders - would 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. For additional information on Citi's single point of entry resolution plan strategy and the IHC and secured support agreement, see "Managing Global Risk - Liquidity Risk" below.On November 22, 2022, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2021 by the eight U.S. GSIBs, including Citi. The FRB and FDIC identified one shortcoming, but no deficiencies, in Citi's 2021 resolution plan. The shortcoming related to data integrity and data quality management issues, specifically, weaknesses in **Current (2025):** Citi has co-branding and private label relationships with various retailers and merchants through its Branded Cards and Retail Services credit card businesses in USPB, whereby in the ordinary course of business Citi issues credit cards to consumers, including customers of the retailers or merchants. The five largest relationships across both businesses in USPB constituted an aggregate of approximately 12% of Citi's revenues in 2024 (see "U.S. Personal Banking" above). Citi's co-branding and private label agreements often provide for shared economics between the parties and generally have a fixed term. Competition among credit card issuers, including Citi, for these relationships is significant, and Citi may not be able to maintain such relationships on existing terms or at all. Citi's co-branding and private label relationships could also be negatively impacted by, among other things, the general economic environment, including the impacts stemming from potential increases in unemployment, inflation or interest rates or lower economic growth rates, as well as a risk of recession; changes in consumer sentiment, spending patterns and credit card usage behaviors; a decline in sales and revenues, partner store closures, any reduction in air and business travel, or other operational difficulties of the retailer or merchant; changes in partner business strategies, including changes in products and services offered; termination or non-renewal of partner agreements, including 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 a challenging macroeconomic environment or otherwise. These events, particularly early termination and bankruptcies or liquidations, could negatively impact the results of operations or financial condition of Branded Cards, 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 (see Note 17 for information on Citi's credit card related intangibles generally). The Application of U.S. Resolution Plan Requirements May Pose a Greater Risk of Loss to Citi's Debt and Equity Securities Holders, and Citi's Inability in Its Resolution Plan Submissions to Address Any Shortcomings or Deficiencies or Guidance 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. 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 2023 resolution plan, which can be found on the FRB's and FDIC's websites) would remain operational outside of any resolution or insolvency proceedings. As a result, Citigroup's losses and any losses incurred by its material legal entity subsidiaries would be imposed first on holders of Citigroup's equity securities and thereafter on its unsecured creditors, including holders of eligible long-term debt and other debt securities. In addition, a wholly owned, direct subsidiary of Citigroup serves as a resolution funding vehicle (the intermediate holding company, or IHC) to which Citigroup has transferred, and has agreed to transfer on an ongoing basis, certain assets. The obligations of Citigroup and of the IHC, respectively, under the amended and restated secured support agreement, are secured on a senior basis by the assets of Citigroup (other than shares in subsidiaries of the parent company and certain other assets), and the assets of the IHC, as applicable. As a result, claims of the operating material legal entities against the assets of Citigroup with respect to such secured assets are effectively senior to unsecured obligations of Citigroup. Citi's single point of entry resolution plan strategy and the obligations under the amended and restated secured support agreement may result in the recapitalization of and/or provision of liquidity to Citi's operating material legal entities, and the commencement of bankruptcy proceedings by Citigroup at an earlier stage of financial stress than might otherwise occur without such mechanisms in place.In line with the FRB's total loss-absorbing capacity (TLAC) rule, Citigroup's shareholders and unsecured creditors - including its unsecured long-term debt holders - would 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. For additional information on Citi's single point of entry resolution plan strategy and the IHC and secured support agreement, see "Managing Global Risk - Liquidity Risk" below.On November 22, 2022, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2021 by the eight U.S. GSIBs, including Citigroup. The FRB and FDIC jointly identified one shortcoming in Citigroup's 2021 resolution plan. The shortcoming related to data integrity and --- ## Modified: USPB(5)(6) **Key changes:** - Reworded sentence: "Cards(6) Retail Banking(5) Asia Consumer(7)(8) Legacy Holdings Assets (consumer)(9) (1)End-of-period (EOP) loans include interest and fees on credit cards." - Reworded sentence: "(3)Excludes EOP classifiably managed Private Bank loans." - Reworded sentence: "The amounts excluded for loans 90+ days past due and (EOP loans) were $69 million ($0.5 billion), $63 million ($0.5 billion) and $89 million ($0.6 billion) at December 31, 2024, 2023 and 2022, respectively." - Reworded sentence: "(6)The 90+ days past due balances for Branded Cards and Retail Services are generally still accruing interest." - Reworded sentence: "(7)Asia Consumer includes delinquencies and loans in Poland and Russia for all periods presented." **Prior (2024):** Asia Consumer(7)(8) Legacy Holdings Assets (consumer)(9) (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 and 30-89 days past due and related ratios for Retail Banking exclude loans guaranteed by U.S. government-sponsored agencies since the potential risk of loss predominantly resides with the U.S. government-sponsored agencies. The amounts excluded for loans 90+ days past due and (EOP loans) were $63 million ($0.5 billion), $89 million ($0.6 billion) and $185 million ($1.1 billion) at December 31, 2023, 2022 and 2021, respectively. The amounts excluded for loans 30-89 days past due (the 30-89 days past due EOP loans have the same adjustments as the 90+ days past due EOP loans) were $73 million, $70 million and $74 million at December 31, 2023, 2022 and 2021, respectively. The EOP loans in the table include the guaranteed loans. (4)The 90+ days past due balances for Branded Cards and Retail Services are generally still accruing interest. Citi's policy is generally to accrue interest on credit card loans until 180 days past due, unless notification of bankruptcy filing has been received earlier. (5)Excludes EOP classifiably managed Private Bank loans. These loans are not included in the delinquency numerator, denominator and ratios. (6)These loans are evaluated for non-accrual status and write-off primarily based on their internal risk classification and not solely on their delinquency status, and therefore delinquency metrics are excluded from this table. As of December 31, 2023, 2022 and 2021, 85%, 96% and 94% of Wealth classifiably managed loans were rated investment grade. For additional information on the credit quality of the Wealth portfolio, including classifiably managed portfolios, see "Consumer Credit Trends" above. (7)Asia Consumer includes delinquencies and loans in Poland and Russia for all periods presented and in Bahrain for 2021 only. (8)Citi has entered into agreements to sell certain Asia Consumer banking businesses. Accordingly, the loans of these businesses have been reclassified as HFS in Other assets on the Consolidated Balance Sheet, and hence the loans and related delinquencies and ratios are not included in this table. The reclassifications commenced as follows: Bahrain, India, Indonesia, Malaysia, Taiwan, Thailand and Vietnam in 1Q22 (Bahrain, Malaysia and Thailand closed in 4Q22; India and Vietnam closed in 1Q23; Taiwan closed in 3Q23; and Indonesia closed in 4Q23); Australia in 3Q21 (closed in 2Q22); and the Philippines in 4Q21 (closed in 3Q22). In addition, a portfolio was reclassified to HFS in the first quarter of 2023 and subsequently sold in the second quarter of 2023. See Note 2. 80 80 80 (9)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 risk of loss predominantly resides with the U.S. agencies. The amounts excluded for 90+ days past due and (EOP loans) were $67 million ($0.2 billion), $90 million ($0.3 billion) and $138 million ($0.4 billion) at December 31, 2023, 2022 and 2021, 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 $36 million, $37 million and $35 million at December 31, 2023, 2022 and 2021, respectively. The EOP loans in the table include the guaranteed loans. N/A Not applicable **Current (2025):** Cards(6) Retail Banking(5) Asia Consumer(7)(8) Legacy Holdings Assets (consumer)(9) (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)Excludes EOP classifiably managed Private Bank loans. These loans are not included in the delinquency numerator, denominator and ratios. (4)These loans are evaluated for non-accrual status and write-off primarily based on their internal risk classification and not solely on their delinquency status, and, therefore, delinquency metrics are excluded from this table. As of December 31, 2024, 2023 and 2022, 72%, 85% and 96% of Wealth classifiably managed loans were rated investment grade. For additional information on the credit quality of the Wealth portfolio, including classifiably managed portfolios, see "Consumer Credit Trends" above. (5)The 90+ days past due and 30-89 days past due and related ratios for Retail Banking exclude loans guaranteed by U.S. government-sponsored agencies since the potential risk of loss predominantly resides with the U.S. government-sponsored agencies. The amounts excluded for loans 90+ days past due and (EOP loans) were $69 million ($0.5 billion), $63 million ($0.5 billion) and $89 million ($0.6 billion) at December 31, 2024, 2023 and 2022, 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 $66 million, $73 million and $70 million at December 31, 2024, 2023 and 2022, respectively. The EOP loans in the table include the guaranteed loans. (6)The 90+ days past due balances for Branded Cards and Retail Services are generally still accruing interest. Citi'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. (7)Asia Consumer includes delinquencies and loans in Poland and Russia for all periods presented. (8)Citi has entered into agreements to sell certain Asia Consumer banking businesses. Accordingly, the loans of these businesses have been reclassified as HFS in Other assets on the Consolidated Balance Sheet, and, hence, the loans and related delinquencies and ratios are not included in this table. The most recent reclassifications commenced as follows: Taiwan and Indonesia in the first quarter of 2022; Taiwan closed in the third quarter of 2023 and Indonesia closed in the fourth quarter of 2023. See Note 2. 83 83 83 (9)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 risk of loss predominantly resides with the U.S. agencies. The amounts excluded for 90+ days past due and (EOP loans) were $66 million ($0.2 billion), $67 million ($0.2 billion) and $90 million ($0.3 billion) at December 31, 2024, 2023 and 2022, 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 $34 million, $36 million and $37 million at December 31, 2024, 2023 and 2022, respectively. The EOP loans in the table include the guaranteed loans. N/A Not applicable --- ## Modified: High-Quality Liquid Assets (HQLA) **Key changes:** - Reworded sentence: "31, 2023Available cash$227.1 $211.6 $200.6 $7.7 $6.9 $5.6 $234.8 $218.5 $206.2 U.S." - Added sentence: "Changes in HQLA line categories from the prior-year period were primarily driven by the reallocation of nontransferable HQLA, which did not change total average HQLA, and thus did not impact Citi's LCR ratio." - Reworded sentence: "Foreign government debt securities are held largely to support local liquidity requirements and Citi's local franchises and principally include government bonds from Japan, Korea, the United Kingdom, Mexico and Hong Kong." - Reworded sentence: "Citigroup's average HQLA increased quarter-over-quarter as of the fourth quarter of 2024, primarily driven by an increase in average wholesale funding." - Reworded sentence: "31, 2023HQLA$558.4 $551.2 $560.5 Net outflows480.8 469.6 482.7 LCR116 %117 %116 %HQLA in excess of net outflows$77.6 $81.6 $77.8 Note: The amounts are presented on an average basis.As of December 31, 2024, Citigroup's average LCR decreased from the quarter ended September 30, 2024." **Prior (2024):** CitibankCiti non-bank and other entitiesTotalIn billions of dollarsDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Dec. 31, 2023Sept. 30, 2023Dec. 31, 2022Dec. 31, 2023Sept. 30, 2023Dec. 31, 2022Available cash$200.6 $203.1 $241.2 $5.6 $5.4 $4.3 $206.2 $208.5 $245.5 U.S. sovereign131.6 134.2 130.0 74.3 79.3 68.7 205.9 213.5 198.7 U.S. agency/agency MBS51.0 48.5 46.3 3.1 3.6 4.0 54.1 52.1 50.3 Foreign government debt(1)76.0 74.3 59.1 18.0 19.9 19.4 94.0 94.2 78.5 Other investment grade0.2 0.3 1.7 0.1 0.7 0.5 0.3 1.0 2.2 Total HQLA (AVG)$459.4 $460.4 $478.3 $101.1 $108.9 $96.9 $560.5 $569.3 $575.2 U.S. sovereign U.S. agency/agency MBS Foreign government debt(1) Other investment grade Note: The amounts in the table above are presented on an average basis. For securities, the amounts represent the liquidity value that potentially could be realized and, therefore, exclude any securities that are encumbered and incorporate any haircuts applicable under the U.S. LCR rule. The table above incorporates various restrictions that could limit the transferability of liquidity between legal entities, including Section 23A of the Federal Reserve Act. (1) Foreign government debt includes securities issued or guaranteed by foreign sovereigns, agencies and multilateral development banks. Foreign government debt securities are held largely to support local liquidity requirements and Citi's local franchises and principally include government bonds from Japan, Korea, Mexico, 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 ratio (LCR), pursuant to the U.S. LCR rules. These amounts include the HQLA needed to meet the minimum requirements at these entities as well as any amounts in excess of these minimums that are available to be transferred to other entities within Citigroup. Citigroup's average HQLA decreased quarter-over-quarter as of the fourth quarter of 2023, primarily driven by a reduction in average unsecured debt. As of December 31, 2023, Citigroup had approximately $965 billion of available liquidity resources to support client and business needs, including end-of-period HQLA ($562 billion); additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($232 billion); and unused borrowing capacity from available assets not already accounted for within Citi's HQLA to support additional advances from the Federal Home Loan Bank (FHLB) and the Federal Reserve Bank discount window ($171 billion).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.The LCR is calculated by dividing HQLA by estimated net outflows assuming a stressed 30-day period, with the net outflows determined by standardized stress outflow and inflow rates prescribed in the LCR rule. The outflows are partially offset by contractual inflows from assets maturing within 30 days. Similar to outflows, the inflows are calculated based on prescribed factors to various asset categories, such as retail loans as well as unsecured and 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, 2023Sept. 30, 2023Dec. 31, 2022HQLA$560.5 $569.3 $575.2 Net outflows482.7 485.3 489.0 LCR116 %117 %118 %HQLA in excess of net outflows$77.8 $84.0 $86.2 Note: The amounts are presented on an average basis.As of December 31, 2023, Citigroup's average LCR decreased from the quarter ended September 30, 2023. The decrease was primarily driven by the reduction in average HQLA.In addition, considering Citi's total available liquidity resources at quarter end of $965 billion, Citi maintained approximately $482 billion of excess liquidity above the stressed average net outflow of approximately $483 billion, shown in the LCR table above. The table above includes average amounts of HQLA held at Citigroup's operating entities that are eligible for inclusion in the calculation of Citigroup's consolidated Liquidity Coverage ratio (LCR), pursuant to the U.S. LCR rules. These amounts include the HQLA needed to meet the minimum requirements at these entities as well as any amounts in excess of these minimums that are available to be transferred to other entities within Citigroup. Citigroup's average HQLA decreased quarter-over-quarter as of the fourth quarter of 2023, primarily driven by a reduction in average unsecured debt. As of December 31, 2023, Citigroup had approximately $965 billion of available liquidity resources to support client and business needs, including end-of-period HQLA ($562 billion); additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($232 billion); and unused borrowing capacity from available assets not already accounted for within Citi's HQLA to support additional advances from the Federal Home Loan Bank (FHLB) and the Federal Reserve Bank discount window ($171 billion). The table above includes average amounts of HQLA held at Citigroup's operating entities that are eligible for inclusion in the calculation of Citigroup's consolidated Liquidity Coverage ratio (LCR), pursuant to the U.S. LCR rules. These amounts include the HQLA needed to meet the minimum requirements at these entities as well as any amounts in excess of these minimums that are available to be transferred to other entities within Citigroup. Citigroup's average HQLA decreased quarter-over-quarter as of the fourth quarter of 2023, primarily driven by a reduction in average unsecured debt. As of December 31, 2023, Citigroup had approximately $965 billion of available liquidity resources to support client and business needs, including end-of-period HQLA ($562 billion); additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($232 billion); and unused borrowing capacity from available assets not already accounted for within Citi's HQLA to support additional advances from the Federal Home Loan Bank (FHLB) and the Federal Reserve Bank discount window ($171 billion). 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.The LCR is calculated by dividing HQLA by estimated net outflows assuming a stressed 30-day period, with the net outflows determined by standardized stress outflow and inflow rates prescribed in the LCR rule. The outflows are partially offset by contractual inflows from assets maturing within 30 days. Similar to outflows, the inflows are calculated based on prescribed factors to various asset categories, such as retail loans as well as unsecured and 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, 2023Sept. 30, 2023Dec. 31, 2022HQLA$560.5 $569.3 $575.2 Net outflows482.7 485.3 489.0 LCR116 %117 %118 %HQLA in excess of net outflows$77.8 $84.0 $86.2 Note: The amounts are presented on an average basis.As of December 31, 2023, Citigroup's average LCR decreased from the quarter ended September 30, 2023. The decrease was primarily driven by the reduction in average HQLA.In addition, considering Citi's total available liquidity resources at quarter end of $965 billion, Citi maintained approximately $482 billion of excess liquidity above the stressed average net outflow of approximately $483 billion, shown in the LCR table above. **Current (2025):** CitibankCiti non-bank and other entitiesTotalIn billions of dollarsDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Dec. 31, 2024Sept. 30, 2024Dec. 31, 2023Dec. 31, 2024Sept. 30, 2024Dec. 31, 2023Available cash$227.1 $211.6 $200.6 $7.7 $6.9 $5.6 $234.8 $218.5 $206.2 U.S. sovereign191.2 205.0 131.6 46.8 43.2 74.3 238.0 248.2 205.9 U.S. agency/agency MBS26.6 28.2 51.0 2.1 2.0 3.1 28.7 30.2 54.1 Foreign government debt(1)44.2 38.1 76.0 12.6 16.2 18.0 56.8 54.3 94.0 Other investment grade - - 0.2 0.1 - 0.1 0.1 - 0.3 Total HQLA (AVG)$489.1 $482.9 $459.4 $69.3 $68.3 $101.1 $558.4 $551.2 $560.5 U.S. sovereign U.S. agency/agency MBS Foreign government debt(1) Other investment grade Note: The amounts in the table above are presented on an average basis. For securities, the amounts represent the liquidity value that potentially could be realized and, therefore, exclude any securities that are encumbered and incorporate any haircuts applicable under the U.S. LCR rule. The table above incorporates various restrictions that could limit the transferability of liquidity between legal entities, including Section 23A of the Federal Reserve Act. Changes in HQLA line categories from the prior-year period were primarily driven by the reallocation of nontransferable HQLA, which did not change total average HQLA, and thus did not impact Citi's LCR ratio. (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, Korea, the United Kingdom, Mexico 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 LCR, pursuant to the U.S. LCR rules. These amounts include the HQLA needed to meet the minimum requirements at these entities as well as any amounts in excess of these minimums that are available to be transferred to other entities within Citigroup. Citigroup's average HQLA increased quarter-over-quarter as of the fourth quarter of 2024, primarily driven by an increase in average wholesale funding. As of December 31, 2024, Citigroup had approximately $933 billion of available liquidity resources to support client and business needs, including end-of-period HQLA ($554 billion); additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($227 billion); and unused borrowing capacity from available assets not already accounted for within Citi's HQLA to support additional advances from the Federal Home Loan Bank (FHLB) and the Federal Reserve Bank discount window ($152 billion).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.The LCR is calculated by dividing HQLA by estimated net outflows assuming a stressed 30-day period, with the net outflows determined by standardized stress outflow and inflow rates prescribed in the LCR rule. The outflows are partially offset by contractual inflows from assets maturing within 30 days. Similar to outflows, the inflows are calculated based on prescribed factors to various asset categories, such as retail loans as well as unsecured and 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, 2024Sept. 30, 2024Dec. 31, 2023HQLA$558.4 $551.2 $560.5 Net outflows480.8 469.6 482.7 LCR116 %117 %116 %HQLA in excess of net outflows$77.6 $81.6 $77.8 Note: The amounts are presented on an average basis.As of December 31, 2024, Citigroup's average LCR decreased from the quarter ended September 30, 2024. The decrease was primarily driven by increased market activity and client lending within Citi's broker-dealer subsidiaries, partially offset by the increase in average HQLA.In addition, considering Citi's total available liquidity resources at quarter end of $933 billion, Citi maintained approximately $452 billion of excess liquidity resources above the stressed average net outflow of approximately $481 billion, presented in the LCR table above. 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 LCR, pursuant to the U.S. LCR rules. These amounts include the HQLA needed to meet the minimum requirements at these entities as well as any amounts in excess of these minimums that are available to be transferred to other entities within Citigroup. Citigroup's average HQLA increased quarter-over-quarter as of the fourth quarter of 2024, primarily driven by an increase in average wholesale funding. As of December 31, 2024, Citigroup had approximately $933 billion of available liquidity resources to support client and business needs, including end-of-period HQLA ($554 billion); additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($227 billion); and unused borrowing capacity from available assets not already accounted for within Citi's HQLA to support additional advances from the Federal Home Loan Bank (FHLB) and the Federal Reserve Bank discount window ($152 billion). 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 LCR, pursuant to the U.S. LCR rules. These amounts include the HQLA needed to meet the minimum requirements at these entities as well as any amounts in excess of these minimums that are available to be transferred to other entities within Citigroup. Citigroup's average HQLA increased quarter-over-quarter as of the fourth quarter of 2024, primarily driven by an increase in average wholesale funding. As of December 31, 2024, Citigroup had approximately $933 billion of available liquidity resources to support client and business needs, including end-of-period HQLA ($554 billion); additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($227 billion); and unused borrowing capacity from available assets not already accounted for within Citi's HQLA to support additional advances from the Federal Home Loan Bank (FHLB) and the Federal Reserve Bank discount window ($152 billion). 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.The LCR is calculated by dividing HQLA by estimated net outflows assuming a stressed 30-day period, with the net outflows determined by standardized stress outflow and inflow rates prescribed in the LCR rule. The outflows are partially offset by contractual inflows from assets maturing within 30 days. Similar to outflows, the inflows are calculated based on prescribed factors to various asset categories, such as retail loans as well as unsecured and 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, 2024Sept. 30, 2024Dec. 31, 2023HQLA$558.4 $551.2 $560.5 Net outflows480.8 469.6 482.7 LCR116 %117 %116 %HQLA in excess of net outflows$77.6 $81.6 $77.8 Note: The amounts are presented on an average basis.As of December 31, 2024, Citigroup's average LCR decreased from the quarter ended September 30, 2024. The decrease was primarily driven by increased market activity and client lending within Citi's broker-dealer subsidiaries, partially offset by the increase in average HQLA.In addition, considering Citi's total available liquidity resources at quarter end of $933 billion, Citi maintained approximately $452 billion of excess liquidity resources above the stressed average net outflow of approximately $481 billion, presented in the LCR table above. --- ## Modified: Independent Compliance Risk Management **Key changes:** - Reworded sentence: "The ICRM organization actively oversees compliance risk across Citi, sets compliance standards for the first line of defense to manage compliance risk and promotes business conduct and activity that is consistent with Citi's Mission and Value Proposition and the compliance risk appetite." - Reworded sentence: "The Citi Chief Auditor manages Internal Audit and reports functionally to the Chair of the Citi Audit Committee and administratively to Citi's CEO." - Reworded sentence: "The Board has delegated authority to the following Board standing committees to help fulfill its oversight and risk management responsibilities: •Audit Committee: assists the Board in fulfilling its oversight responsibility relating to (i) the integrity of Citigroup's consolidated financial statements, financial reporting process and systems of internal accounting and financial controls, (ii) the performance of the internal audit function (Internal Audit), (iii) the annual independent integrated audit of Citigroup's consolidated financial statements and effectiveness of Citigroup's internal control over financial reporting, the engagement of the independent registered public accounting firm (Independent Auditors) and the evaluation of the Independent Auditors' qualifications, independence and performance, (iv) holding management accountable for the effectiveness of Citigroup's control environment and status of corrective actions, including the timely remediation of control breaks (including, without limitation, significant compliance or operational control breaks), (v) policy standards and guidelines for risk assessment and risk management, (vi) Citigroup's compliance with legal and regulatory requirements, including Citigroup's disclosure controls and procedures and (vii) the fulfillment of the other responsibilities set out in the Audit Committee's Charter.•Compensation, Performance Management and Culture Committee: is responsible for overseeing compensation of employees of the Company and its subsidiaries and affiliates and Citi management's sustained focus on fostering a principled culture of sound ethics, responsible conduct and accountability within the organization." - Reworded sentence: "The CEO leads the Company through the Executive Management Team and provides oversight of group activities, both directly and through authority delegated to committees established to oversee the management of risk, to ensure continued alignment with Citi's risk strategy." **Prior (2024):** Internal Audit is independent of the first line, second line and enterprise support functions. The role of Internal Audit is to provide independent, objective, reliable, valued and timely assurance to the Board, its Audit Committee, Citi senior management and regulators over the effectiveness of governance, risk management and controls that mitigate current and evolving risks and enhance the control culture within Citi. The Citi Chief Auditor manages Internal Audit 66 66 66 and reports functionally to the Chair of the Citi Audit Committee and administratively to the Citi Chief Executive Officer. The Citi Chief Auditor has unrestricted access to the Board and the Board Audit Committee to address risks and issues identified through Internal Audit's activities. Enterprise Support FunctionsEnterprise 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 composed of Human Resources and Global Legal Affairs and Compliance (exclusive of ICRM, which is part of the second line of defense). Front line units may also include enterprise support units and/or conduct enterprise support activities (e.g., the Controllers Group within Finance). Enterprise support functions, units and activities are subject to the relevant Company-wide independent oversight processes specific to the risks for which they are accountable (e.g., operational risk, compliance risk, reputation risk).Risk GovernanceCiti's ERM Framework encompasses risk management processes to address risks undertaken by Citi through identification, measurement, monitoring, controlling and 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 OversightThe Board is responsible for oversight of Citi and holds the Executive Management Team accountable for implementing the ERM Framework and meeting strategic objectives within Citi's risk appetite.Executive Management TeamThe Citigroup CEO directs and oversees the day-to-day management of Citi as delegated by the Board of Directors. The CEO leads the Company through the Executive Management Team and provides oversight of group activities, both directly and through authority delegated to committees established to oversee the management of risk, to ensure continued alignment with Citi's risk strategy.Board and Executive Management CommitteesThe Board executes its responsibilities either directly or through its committees. The Board has delegated authority 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 and risk culture, including the significant policies and practices used in managing credit, market (trading and non-trading), liquidity, strategic, operational, compliance, reputation and certain other risks, including those pertaining to capital management, and (ii) oversight of the Global Risk Review - credit, capital and collateral review functions.•Audit Committee: provides oversight of Citi's financial and regulatory reporting and internal control risk, as well as Internal Audit and Citi's external independent accountants.•Compensation, Performance Management and Culture Committee: provides oversight of compensation of Citi's employees and Citi management's sustained focus on fostering a principled culture of sound ethics, responsible conduct and accountability within the organization.•Nomination, Governance and Public Affairs Committee: responsible for (i) identifying individuals qualified to become Board members and recommending to the Board the director nominees for the next annual meeting of stockholders, (ii) leading the Board in its annual review of the Board's performance, (iii) recommending to the Board directors for each committee for appointment by the Board, (iv) reviewing the Company's policies and programs that relate to public issues of significance to the Company and the public at large, including but not limited to Environmental, Social and Corporate Governance (ESG) matters and (v) reviewing the Company's relationships with external constituencies and issues that impact the Company's reputation, and advising management as to its approach to each.•Technology Committee: assists the Board in fulfilling its responsibility with respect to oversight of (i) the planning and execution of Citigroup's technology, strategy and operating plan, (ii) the development of Citi's target state operating model and architecture, including the incorporation of Global Business Services, (iii) technology-based risk management, including risk management framework, risk appetite and risk exposures of the Company, (iv) resource and talent planning of the Technology function and (v) the Company's third-party management policies, practices and standards that relate to Technology.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 FRB and OCC consent orders (see "Citi's Consent Order Compliance" above).The Citigroup CEO has established four standing committees that cover the primary risks to which Citi (i.e., Group) is exposed. These consist of:•Group Risk Management Committee (GRMC): the primary senior executive level committee responsible for (i) overseeing the execution of Citigroup's ERM Framework, (ii) monitoring Citi's risk profile at an aggregate level inclusive of individual risk categories, (iii) ensuring that Citi's risk profile remains consistent with its approved risk appetite and (iv) discussing material and emerging risk issues facing the Company. The Committee also provides comprehensive Group-wide coverage of all and reports functionally to the Chair of the Citi Audit Committee and administratively to the Citi Chief Executive Officer. The Citi Chief Auditor has unrestricted access to the Board and the Board Audit Committee to address risks and issues identified through Internal Audit's activities. Enterprise Support FunctionsEnterprise 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 composed of Human Resources and Global Legal Affairs and Compliance (exclusive of ICRM, which is part of the second line of defense). Front line units may also include enterprise support units and/or conduct enterprise support activities (e.g., the Controllers Group within Finance). Enterprise support functions, units and activities are subject to the relevant Company-wide independent oversight processes specific to the risks for which they are accountable (e.g., operational risk, compliance risk, reputation risk).Risk GovernanceCiti's ERM Framework encompasses risk management processes to address risks undertaken by Citi through identification, measurement, monitoring, controlling and 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 OversightThe Board is responsible for oversight of Citi and holds the Executive Management Team accountable for implementing the ERM Framework and meeting strategic objectives within Citi's risk appetite.Executive Management TeamThe Citigroup CEO directs and oversees the day-to-day management of Citi as delegated by the Board of Directors. The CEO leads the Company through the Executive Management Team and provides oversight of group activities, both directly and through authority delegated to committees established to oversee the management of risk, to ensure continued alignment with Citi's risk strategy.Board and Executive Management CommitteesThe Board executes its responsibilities either directly or through its committees. The Board has delegated authority 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 and risk culture, including the significant policies and practices used in managing credit, market (trading and non-trading), liquidity, strategic, operational, compliance, reputation and certain other risks, including those pertaining to and reports functionally to the Chair of the Citi Audit Committee and administratively to the Citi Chief Executive Officer. The Citi Chief Auditor has unrestricted access to the Board and the Board Audit Committee to address risks and issues identified through Internal Audit's activities. **Current (2025):** The ICRM organization actively oversees compliance risk across Citi, sets compliance standards for the first line of defense to manage compliance risk and promotes business conduct and activity that is consistent with Citi's Mission and Value Proposition and the compliance risk appetite. Citi's objective is to embed an enterprise-wide compliance risk management framework and culture that identifies, measures, monitors, controls and escalates compliance risk across Citi. ICRM is aligned by business, function and geography to provide compliance risk management advice and credible challenge on day-to-day matters and strategic decision-making for key initiatives. ICRM also has program-level Enterprise Compliance units responsible for setting standards and establishing priorities for program-related compliance efforts. The CCO reports to Citi's Chief Legal Officer and ICRM is organizationally part of the Global Legal Affairs & Compliance group. In addition, the CCO has matrix reporting into the CRO and is part of the Risk Management Executive Council. 69 69 69 Third Line of Defense: Internal AuditInternal Audit is independent of the first line, second line and enterprise support functions. The role of Internal Audit is to provide independent, objective, reliable, valued and timely assurance to the Board, its Audit Committee, Citi senior management and regulators over the effectiveness of governance, risk management and controls that mitigate current and evolving risks and enhance the control culture within Citi. The Citi Chief Auditor manages Internal Audit and reports functionally to the Chair of the Citi Audit Committee and administratively to Citi's CEO. The Citi Chief Auditor has unrestricted access to the Board and the Board Audit Committee to address risks and issues identified through Internal Audit's activities. Enterprise Support FunctionsEnterprise 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 composed of Human Resources and Global Legal Affairs and Compliance (exclusive of ICRM, which is part of the second line of defense). Front line units may also include enterprise support units and/or conduct enterprise support activities (e.g., the Controllers Group within Finance). Enterprise support functions, units and activities are subject to the relevant Company-wide independent oversight processes specific to the risks for which they are accountable (e.g., operational risk, compliance risk, reputation risk).Risk GovernanceCiti's ERM Framework encompasses risk management processes to address risks undertaken by Citi through identification, measurement, monitoring, controlling and 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 OversightThe Board is responsible for oversight of Citi and holds the Executive Management Team accountable for implementing the ERM Framework and meeting strategic objectives within Citi's risk appetite.Executive Management TeamThe Citigroup CEO directs and oversees the day-to-day management of Citi as delegated by the Board of Directors. The CEO leads the Company through the Executive Management Team and provides oversight of group activities, both directly and through authority delegated to committees established to oversee the management of risk, to ensure continued alignment with Citi's risk strategy.Board and Executive Management CommitteesThe Board executes its responsibilities either directly or through its committees. The Board has delegated authority to the following Board standing committees to help fulfill its oversight and risk management responsibilities: •Audit Committee: assists the Board in fulfilling its oversight responsibility relating to (i) the integrity of Citigroup's consolidated financial statements, financial reporting process and systems of internal accounting and financial controls, (ii) the performance of the internal audit function (Internal Audit), (iii) the annual independent integrated audit of Citigroup's consolidated financial statements and effectiveness of Citigroup's internal control over financial reporting, the engagement of the independent registered public accounting firm (Independent Auditors) and the evaluation of the Independent Auditors' qualifications, independence and performance, (iv) holding management accountable for the effectiveness of Citigroup's control environment and status of corrective actions, including the timely remediation of control breaks (including, without limitation, significant compliance or operational control breaks), (v) policy standards and guidelines for risk assessment and risk management, (vi) Citigroup's compliance with legal and regulatory requirements, including Citigroup's disclosure controls and procedures and (vii) the fulfillment of the other responsibilities set out in the Audit Committee's Charter.•Compensation, Performance Management and Culture Committee: is responsible for overseeing compensation of employees of the Company and its subsidiaries and affiliates and Citi management's sustained focus on fostering a principled culture of sound ethics, responsible conduct and accountability within the organization. The Committee regularly reviews Citi's management resources and the performance of senior management. The Committee is responsible for determining the compensation for the Chief Executive Officer and approving the compensation of other executive officers of the Company and members of Citi's Executive Management Team. The Committee is also responsible for approving the incentive compensation structure for other members of senior management and certain highly compensated employees (including discretionary incentive awards to covered employees as defined in applicable bank regulatory guidance), in accordance with guidelines established by the Committee from time to time. The Committee also has broad oversight over compliance with bank regulatory guidance governing Citi's incentive compensation.•Nomination, Governance and Public Affairs Committee: is responsible for (i) identifying individuals qualified to become Board members and recommending to the Board the director nominees for the next annual meeting of stockholders, (ii) leading the Board in its annual review of the Board's performance, (iii) recommending to the Board directors for each committee for appointment by the Board, (iv) reviewing the Company's policies and programs that relate to public issues of significance to the Third Line of Defense: Internal AuditInternal Audit is independent of the first line, second line and enterprise support functions. The role of Internal Audit is to provide independent, objective, reliable, valued and timely assurance to the Board, its Audit Committee, Citi senior management and regulators over the effectiveness of governance, risk management and controls that mitigate current and evolving risks and enhance the control culture within Citi. The Citi Chief Auditor manages Internal Audit and reports functionally to the Chair of the Citi Audit Committee and administratively to Citi's CEO. The Citi Chief Auditor has unrestricted access to the Board and the Board Audit Committee to address risks and issues identified through Internal Audit's activities. Enterprise Support FunctionsEnterprise 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 composed of Human Resources and Global Legal Affairs and Compliance (exclusive of ICRM, which is part of the second line of defense). Front line units may also include enterprise support units and/or conduct enterprise support activities (e.g., the Controllers Group within Finance). Enterprise support functions, units and activities are subject to the relevant Company-wide independent oversight processes specific to the risks for which they are accountable (e.g., operational risk, compliance risk, reputation risk).Risk GovernanceCiti's ERM Framework encompasses risk management processes to address risks undertaken by Citi through identification, measurement, monitoring, controlling and 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 OversightThe Board is responsible for oversight of Citi and holds the Executive Management Team accountable for implementing the ERM Framework and meeting strategic objectives within Citi's risk appetite.Executive Management TeamThe Citigroup CEO directs and oversees the day-to-day management of Citi as delegated by the Board of Directors. The CEO leads the Company through the Executive Management Team and provides oversight of group activities, both directly and through authority delegated to committees established to oversee the management of risk, to ensure continued alignment with Citi's risk strategy. --- ## Modified: Citi's Interpretation or Application of the Complex Tax Laws to Which It Is Subject Could Differ from Those of Governmental Authorities, Which Could Result in Litigation or Examinations and the Payment of Additional Taxes, Penalties or Interest. **Key changes:** - Reworded sentence: "For example, the OECD Pillar 2 framework contemplates a 15% global minimum tax with respect to earnings in each country." - Reworded sentence: "Beginning in 2024, countries that adopted the OECD Pillar 2 rules can collect the top-up tax only with respect to earnings of entities in their jurisdiction or subsidiaries of such entities." - Reworded sentence: "While Citi does not currently expect the rules to have a material impact on its earnings, many aspects of the application of the rules and their implementation remain uncertain." - Reworded sentence: "tax authorities.A Deterioration in or Failure to Maintain Citi's Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi.Citi has co-branding and private label relationships with various retailers and merchants through its Branded Cards and Retail Services credit card businesses in USPB, whereby in the ordinary course of business Citi issues credit cards to consumers, including customers of the retailers or merchants." - Reworded sentence: "Citi's co-branding and private label agreements often provide for shared economics between the parties and generally have a fixed term.Competition among credit card issuers, including Citi, for these relationships is significant, and Citi may not be able to maintain such relationships on existing terms or at all." **Prior (2024):** Citi is subject to various income-based tax laws of the U.S. and its states and municipalities, as well as the numerous non-U.S. jurisdictions in which it operates. These tax laws are inherently complex, and Citi must make judgments and interpretations about the application of these laws to its entities, operations and businesses. For example, the Organization for Economic Cooperation and Development (OECD) Pillar 2 initiative contemplates a 15% global minimum tax with respect to earnings in each country. EU member states were required to adopt the OECD Pillar 2 rules in 2023, with an effective date of January 1, 2024 (unless an exception applied), and other non-U.S. countries have similarly adopted or are expected to adopt the rules. Under these rules, Citi will be required to pay a "top-up" tax to the extent that Citi's effective tax rate in any given country is below 15%. Beginning in 2024, countries that adopted the OECD Pillar 2 rules in 2023 can collect the top-up tax only with respect to earnings of entities in their jurisdiction or subsidiaries of such entities. Beginning in 2025, all countries that have adopted the OECD Pillar 2 rules can collect a share of the top-up tax owed with respect to any member of the Pillar 2 multinational group. While Citi does not currently expect the rules to have a material impact on its earnings, many aspects of the application of the rules remain uncertain.Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding non-income-based tax matters. While Citi has appropriately reserved for such matters where there is a probable loss, and has disclosed reasonably possible losses, the outcome of the matters may be different than Citi's expectations. Citi's interpretations or application of the tax laws, including with respect to withholding, stamp, service and other non-income taxes, could differ from that of the relevant governmental taxing authority, which could result in the requirement to pay additional taxes, penalties or interest, the reduction of certain tax benefits or the requirement to make adjustments to amounts recorded, which could be material. See Note 30 for additional information on litigation and examinations involving non-U.S. tax authorities.A Deterioration in or Failure to Maintain Citi's Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi.Citi has co-branding and private label relationships through its Branded Cards and Retail Services credit card businesses with various retailers and merchants, whereby in the ordinary course of business Citi issues credit cards to consumers, including customers of the retailers or merchants. The five largest relationships across both businesses in USPB constituted an aggregate of approximately 11% of Citi's revenues in 2023 (see "U.S. Personal Banking" above). Citi's co-branding and private label agreements often provide for shared economics between the parties and generally have a fixed term.Competition among card issuers, including Citi, for these relationships is significant, and Citi may not be able to maintain such relationships on existing terms or at all. Citi's co-branding and private label relationships could also be negatively impacted by, among other things, the general economic environment, including the impacts of continued elevated interest rates and inflation, and lower economic growth rates, as well as a continuing risk of recession; changes in consumer sentiment, spending patterns and credit card usage behaviors; a decline in sales and revenues, partner store closures, any reduction in 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 a challenging macroeconomic environment or otherwise.These events, particularly early termination and bankruptcies or liquidations, could negatively impact the results of operations or financial condition of Branded Cards, 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 (see Note 17 for information on Citi's credit card related intangibles generally). that have adopted the OECD Pillar 2 rules can collect a share of the top-up tax owed with respect to any member of the Pillar 2 multinational group. While Citi does not currently expect the rules to have a material impact on its earnings, many aspects of the application of the rules remain uncertain. Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding non-income-based tax matters. While Citi has appropriately reserved for such matters where there is a probable loss, and has disclosed reasonably possible losses, the outcome of the matters may be different than Citi's expectations. Citi's interpretations or application of the tax laws, including with respect to withholding, stamp, service and other non-income taxes, could differ from that of the relevant governmental taxing authority, which could result in the requirement to pay additional taxes, penalties or interest, the reduction of certain tax benefits or the requirement to make adjustments to amounts recorded, which could be material. See Note 30 for additional information on litigation and examinations involving non-U.S. tax authorities. **Current (2025):** Citi is subject to various income-based tax laws of the U.S. and its states and municipalities, as well as the numerous non-U.S. jurisdictions in which it operates. These tax laws are inherently complex, and Citi must make judgments and interpretations about the application of these laws to its entities, operations and businesses. For example, the OECD Pillar 2 framework contemplates a 15% global minimum tax with respect to earnings in each country. The majority of EU member states have adopted the OECD Pillar 2 rules, and other non-U.S. countries have similarly adopted or are expected to adopt the rules. Under these rules, Citi will be required to pay a "top-up" tax to the extent that Citi's effective tax rate in any given country is below 15%. Beginning in 2024, countries that adopted the OECD Pillar 2 rules can collect the top-up tax only with respect to earnings of entities in their jurisdiction or subsidiaries of such entities. Beginning in 2025, all countries that have adopted the OECD Pillar 2 rules can collect a share of the top-up tax owed with respect to any member of the Pillar 2 multinational group. While Citi does not currently expect the rules to have a material impact on its earnings, many aspects of the application of the rules and their implementation remain uncertain. Separately, the new U.S. administration has stated its opposition to the application of the global minimum tax to U.S. companies' U.S. operations, and has indicated it may take retaliatory measures against other countries that seek to collect the minimum tax with respect to the U.S. operations of U.S. companies. Citi is 53 53 53 closely monitoring developments relating to the Pillar 2 negotiations to determine their potential impact.Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding non-income-based tax matters. While Citi has appropriately reserved for such matters where there is a probable loss, and has disclosed reasonably possible losses, the outcome of the matters may be different than Citi's expectations. Citi's interpretations or application of the tax laws, including with respect to withholding, stamp, service and other non-income taxes, could differ from that of the relevant governmental taxing authority, which could result in the requirement to pay additional taxes, penalties or interest, the reduction of certain tax benefits or the requirement to make adjustments to amounts recorded, which could be material. See Note 30 for additional information on litigation and examinations involving non-U.S. tax authorities.A Deterioration in or Failure to Maintain Citi's Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi.Citi has co-branding and private label relationships with various retailers and merchants through its Branded Cards and Retail Services credit card businesses in USPB, whereby in the ordinary course of business Citi issues credit cards to consumers, including customers of the retailers or merchants. The five largest relationships across both businesses in USPB constituted an aggregate of approximately 12% of Citi's revenues in 2024 (see "U.S. Personal Banking" above). Citi's co-branding and private label agreements often provide for shared economics between the parties and generally have a fixed term.Competition among credit card issuers, including Citi, for these relationships is significant, and Citi may not be able to maintain such relationships on existing terms or at all. Citi's co-branding and private label relationships could also be negatively impacted by, among other things, the general economic environment, including the impacts stemming from potential increases in unemployment, inflation or interest rates or lower economic growth rates, as well as a risk of recession; changes in consumer sentiment, spending patterns and credit card usage behaviors; a decline in sales and revenues, partner store closures, any reduction in air and business travel, or other operational difficulties of the retailer or merchant; changes in partner business strategies, including changes in products and services offered; termination or non-renewal of partner agreements, including 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 a challenging macroeconomic environment or otherwise.These events, particularly early termination and bankruptcies or liquidations, could negatively impact the results of operations or financial condition of Branded Cards, 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 (see Note 17 for information on Citi's credit card related intangibles generally).The Application of U.S. Resolution Plan Requirements May Pose a Greater Risk of Loss to Citi's Debt and Equity Securities Holders, and Citi's Inability in Its Resolution Plan Submissions to Address Any Shortcomings or Deficiencies or Guidance 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. 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 2023 resolution plan, which can be found on the FRB's and FDIC's websites) would remain operational outside of any resolution or insolvency proceedings. As a result, Citigroup's losses and any losses incurred by its material legal entity subsidiaries would be imposed first on holders of Citigroup's equity securities and thereafter on its unsecured creditors, including holders of eligible long-term debt and other debt securities. In addition, a wholly owned, direct subsidiary of Citigroup serves as a resolution funding vehicle (the intermediate holding company, or IHC) to which Citigroup has transferred, and has agreed to transfer on an ongoing basis, certain assets. The obligations of Citigroup and of the IHC, respectively, under the amended and restated secured support agreement, are secured on a senior basis by the assets of Citigroup (other than shares in subsidiaries of the parent company and certain other assets), and the assets of the IHC, as applicable. As a result, claims of the operating material legal entities against the assets of Citigroup with respect to such secured assets are effectively senior to unsecured obligations of Citigroup. Citi's single point of entry resolution plan strategy and the obligations under the amended and restated secured support agreement may result in the recapitalization of and/or provision of liquidity to Citi's operating material legal entities, and the commencement of bankruptcy proceedings by Citigroup at an earlier stage of financial stress than might otherwise occur without such mechanisms in place.In line with the FRB's total loss-absorbing capacity (TLAC) rule, Citigroup's shareholders and unsecured creditors - including its unsecured long-term debt holders - would 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. For additional information on Citi's single point of entry resolution plan strategy and the IHC and secured support agreement, see "Managing Global Risk - Liquidity Risk" below.On November 22, 2022, the FRB and FDIC issued feedback on the resolution plans filed on July 1, 2021 by the eight U.S. GSIBs, including Citigroup. The FRB and FDIC jointly identified one shortcoming in Citigroup's 2021 resolution plan. The shortcoming related to data integrity and closely monitoring developments relating to the Pillar 2 negotiations to determine their potential impact.Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding non-income-based tax matters. While Citi has appropriately reserved for such matters where there is a probable loss, and has disclosed reasonably possible losses, the outcome of the matters may be different than Citi's expectations. Citi's interpretations or application of the tax laws, including with respect to withholding, stamp, service and other non-income taxes, could differ from that of the relevant governmental taxing authority, which could result in the requirement to pay additional taxes, penalties or interest, the reduction of certain tax benefits or the requirement to make adjustments to amounts recorded, which could be material. See Note 30 for additional information on litigation and examinations involving non-U.S. tax authorities.A Deterioration in or Failure to Maintain Citi's Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi.Citi has co-branding and private label relationships with various retailers and merchants through its Branded Cards and Retail Services credit card businesses in USPB, whereby in the ordinary course of business Citi issues credit cards to consumers, including customers of the retailers or merchants. The five largest relationships across both businesses in USPB constituted an aggregate of approximately 12% of Citi's revenues in 2024 (see "U.S. Personal Banking" above). Citi's co-branding and private label agreements often provide for shared economics between the parties and generally have a fixed term.Competition among credit card issuers, including Citi, for these relationships is significant, and Citi may not be able to maintain such relationships on existing terms or at all. Citi's co-branding and private label relationships could also be negatively impacted by, among other things, the general economic environment, including the impacts stemming from potential increases in unemployment, inflation or interest rates or lower economic growth rates, as well as a risk of recession; changes in consumer sentiment, spending patterns and credit card usage behaviors; a decline in sales and revenues, partner store closures, any reduction in air and business travel, or other operational difficulties of the retailer or merchant; changes in partner business strategies, including changes in products and services offered; termination or non-renewal of partner agreements, including 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 a challenging macroeconomic environment or otherwise.These events, particularly early termination and bankruptcies or liquidations, could negatively impact the results of operations or financial condition of Branded Cards, 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 (see Note 17 for information on Citi's credit card related intangibles generally). closely monitoring developments relating to the Pillar 2 negotiations to determine their potential impact. Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding non-income-based tax matters. While Citi has appropriately reserved for such matters where there is a probable loss, and has disclosed reasonably possible losses, the outcome of the matters may be different than Citi's expectations. Citi's interpretations or application of the tax laws, including with respect to withholding, stamp, service and other non-income taxes, could differ from that of the relevant governmental taxing authority, which could result in the requirement to pay additional taxes, penalties or interest, the reduction of certain tax benefits or the requirement to make adjustments to amounts recorded, which could be material. See Note 30 for additional information on litigation and examinations involving non-U.S. tax authorities. --- ## Modified: Citi's Ability to Achieve Its Objectives from Its Transformation, Simplification and Other Priorities May Not Be as Successful as It Projects or Expects. **Key changes:** - Reworded sentence: "As part of its multiyear transformation, Citi continues to make significant investments and undertake substantial actions across the Company to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" and "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor below)." - Reworded sentence: "Citi's ability to achieve its expected returns, including expense savings and revenue growth objectives, and operational improvements from these priorities depends, in part, on factors that it cannot control, including, among others, macroeconomic challenges and uncertainties; customer, client and competitor actions; and ongoing regulatory requirements or changes.Moreover, Citi's transformation, simplification and other priorities may continue to evolve as its business strategies, the market environment and regulatory expectations change, which could make the initiatives more costly and more challenging to implement, and limit their effectiveness." - Reworded sentence: "Physical risks from climate change include acute risks, such as wildfires, hurricanes, floods and droughts, as well as consequences of chronic changes in climate, such as rising sea levels, prolonged droughts and systemic changes to geographies and any resulting population migration." - Reworded sentence: "These impacts can include destruction, damage or impairment of owned or leased properties and other assets, destruction or deterioration of the value of collateral, such as real estate, disruptions to business operations and supply chains, and reduced availability or increase in the cost of insurance." - Reworded sentence: "sufficiently competitive, serve clients effectively and avoid disruptions to its businesses and operational errors (see the operational processes and systems and legal and regulatory proceedings risk factors below)." **Prior (2024):** As part of its transformation initiatives, Citi continues to make significant investments to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" above and the legal and regulatory proceedings risk factor below). Citi also continues to make business-led investments, as part of the execution of its strategic initiatives. For example, Citi has been making investments across the Company, including hiring front office colleagues in key strategic markets and businesses; enhancing product capabilities and platforms to grow key businesses, improve client digital experiences and add scalability; and implementing new capabilities and partnerships. These business-led investments are designed to grow revenues as well as result in retention and efficiency improvements. Additionally, Citi has been pursuing overall simplification initiatives that include management and operating model changes and actions to enhance focus on clients and reduce expenses. Citi's simplification actions also include divestiture of the Mexico Consumer/SBMM operations and completing other exits and wind-downs in order to streamline Citi and assist in optimizing its allocation of resources. These overall simplification initiatives involve various execution challenges and may result in higher than expected expenses, litigation and regulatory scrutiny, CTA and other losses or other negative financial or strategic impacts, which could be material (for information about potential CTA impacts, see the capital 50 50 50 return risk factor above and the incorrect assumptions or estimates risk factor below).Citi's multiyear transformation, as well as its simplification initiatives, involve significant complexities and uncertainties. In addition, there is inherent risk that Citi's transformation and simplification initiatives will not be as productive or effective as Citi expects, or at all. Conversely, failure to adequately invest in and upgrade Citi's technology and processes or properly implement its enterprise-wide simplification could result in Citi's inability to meet regulatory expectations, be sufficiently competitive, serve clients effectively and avoid disruptions to its businesses and operational errors (see the operational processes and systems and legal and regulatory proceedings risk factors below). Citi's ability to achieve expected returns and operational improvements depends, in part, on factors that it cannot control, including, among others, macroeconomic challenges and uncertainties; customer, client and competitor actions; and ongoing regulatory requirements or changes.Citi's transformation, strategic and other initiatives may continue to evolve as its business strategies, the market environment and regulatory expectations change, which could make the initiatives more costly and more challenging to implement, and limit their effectiveness. Climate Change Presents Various Financial and Non-Financial Risks to Citi and Its Customers and Clients.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, market, technological, stakeholder and legal changes from a transition to a low-carbon economy). Physical and transition risks can manifest themselves differently across Citi's risk categories in the short, medium and long terms. Physical risks from climate change include acute risks, such as hurricanes, floods and droughts, as well as consequences of chronic changes in climate, such as rising sea levels, prolonged droughts and systemic changes to geographies and any resulting population migration. For example, physical risks could have adverse financial, operational and other impacts on Citi, both directly on its business and operations, and indirectly as a result of impacts to Citi's clients, customers, vendors and other counterparties. These impacts can include destruction, damage or impairment of owned or leased properties and other assets, destruction or deterioration of the value of collateral, such as real estate, disruptions to business operations and supply chains and reduced availability or increase in the cost of insurance. Physical risks can also impact Citi's credit risk exposures, for example, in its mortgage and commercial real estate lending businesses.Transition risks may arise from changes in regulations or market preferences toward low-carbon industries or sectors, 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. Failure to adequately consider transition risk in developing and executing on its business strategy could lead to a loss of market share, lower revenues and higher credit costs. Transition risks also include potential increased operational, compliance and energy costs driven by government policies to promote decarbonization. Moreover, increasing legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures are likely to result in increased regulatory, compliance, credit, reputational and other risks and costs for Citi. New regulations have been enacted and/or are expected in several jurisdictions, including the EU's Corporate Sustainability Reporting Directive (CSRD), the SEC climate-related disclosures that could require disclosure of climate-related information and the State of California's legislation enacted in October 2023 requiring broad disclosure of greenhouse gas emissions and other climate-related information largely beginning in 2026. In addition, Citi could face increased regulatory scrutiny and reputation and litigation risks as a result of its climate risk, sustainability and other ESG-related commitments and disclosures. Even as some regulators seek to mandate additional disclosure of climate-related information, Citi's ability to comply with such requirements and conduct more robust climate-related risk analyses may be hampered by lack of information and reliable data. Data on climate-related risks is limited in availability, often based on estimated or unverified figures, collected and reported on a time-lag, and variable in quality. Modeling capabilities to analyze climate-related risks and interconnections are improving, but remain incomplete. 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. For example, in October 2023, the FRB, FDIC and OCC jointly released principles that provide a high-level framework for the safe and sound management of exposures to climate-related financial risks, including physical and transition risks, for financial institutions with more than $100 billion in assets. Additionally, if Citi's response to climate change is perceived to be ineffective or insufficient or Citi is unable to achieve its objectives or commitments relating to climate change, its businesses, reputation, attractiveness to certain investors and efforts to recruit and retain employees may suffer. For example, Citi's approach to supporting client decarbonization in a gradual and orderly way, while promoting energy security, may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Citi also faces anti-ESG challenges from certain U.S. state and other governments that may impact its ability to conduct certain business within those jurisdictions.For information on Citi's climate and other sustainability initiatives, see "Climate Change and Net Zero" below. For additional information on Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. return risk factor above and the incorrect assumptions or estimates risk factor below).Citi's multiyear transformation, as well as its simplification initiatives, involve significant complexities and uncertainties. In addition, there is inherent risk that Citi's transformation and simplification initiatives will not be as productive or effective as Citi expects, or at all. Conversely, failure to adequately invest in and upgrade Citi's technology and processes or properly implement its enterprise-wide simplification could result in Citi's inability to meet regulatory expectations, be sufficiently competitive, serve clients effectively and avoid disruptions to its businesses and operational errors (see the operational processes and systems and legal and regulatory proceedings risk factors below). Citi's ability to achieve expected returns and operational improvements depends, in part, on factors that it cannot control, including, among others, macroeconomic challenges and uncertainties; customer, client and competitor actions; and ongoing regulatory requirements or changes.Citi's transformation, strategic and other initiatives may continue to evolve as its business strategies, the market environment and regulatory expectations change, which could make the initiatives more costly and more challenging to implement, and limit their effectiveness. Climate Change Presents Various Financial and Non-Financial Risks to Citi and Its Customers and Clients.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, market, technological, stakeholder and legal changes from a transition to a low-carbon economy). Physical and transition risks can manifest themselves differently across Citi's risk categories in the short, medium and long terms. Physical risks from climate change include acute risks, such as hurricanes, floods and droughts, as well as consequences of chronic changes in climate, such as rising sea levels, prolonged droughts and systemic changes to geographies and any resulting population migration. For example, physical risks could have adverse financial, operational and other impacts on Citi, both directly on its business and operations, and indirectly as a result of impacts to Citi's clients, customers, vendors and other counterparties. These impacts can include destruction, damage or impairment of owned or leased properties and other assets, destruction or deterioration of the value of collateral, such as real estate, disruptions to business operations and supply chains and reduced availability or increase in the cost of insurance. Physical risks can also impact Citi's credit risk exposures, for example, in its mortgage and commercial real estate lending businesses.Transition risks may arise from changes in regulations or market preferences toward low-carbon industries or sectors, 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 return risk factor above and the incorrect assumptions or estimates risk factor below). Citi's multiyear transformation, as well as its simplification initiatives, involve significant complexities and uncertainties. In addition, there is inherent risk that Citi's transformation and simplification initiatives will not be as productive or effective as Citi expects, or at all. Conversely, failure to adequately invest in and upgrade Citi's technology and processes or properly implement its enterprise-wide simplification could result in Citi's inability to meet regulatory expectations, be sufficiently competitive, serve clients effectively and avoid disruptions to its businesses and operational errors (see the operational processes and systems and legal and regulatory proceedings risk factors below). Citi's ability to achieve expected returns and operational improvements depends, in part, on factors that it cannot control, including, among others, macroeconomic challenges and uncertainties; customer, client and competitor actions; and ongoing regulatory requirements or changes. Citi's transformation, strategic and other initiatives may continue to evolve as its business strategies, the market environment and regulatory expectations change, which could make the initiatives more costly and more challenging to implement, and limit their effectiveness. **Current (2025):** As part of its multiyear transformation, Citi continues to make significant investments and undertake substantial actions across the Company to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" and "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor below). Citi has also been pursuing overall simplification initiatives that have included management and operating model changes and actions to enhance focus on clients and reduce expenses. Citi's simplification actions also include completing its remaining divestitures, including the planned IPO of Mexico Consumer/SBMM. These simplification initiatives involve various execution challenges, may take longer than expected and may result in higher than expected expenses, CTA and other losses or other negative financial or strategic impacts, which could be material, and litigation and regulatory scrutiny (for information about potential CTA impacts, see the capital return risk factor above and the incorrect assumptions or estimates and emerging markets risk factors below). Additionally, Citi continues to make business-led investments, as part of the execution of its strategic priorities. For example, Citi has been making investments across the Company, including hiring front office employees in key strategic markets and businesses; enhancing product capabilities and platforms to grow key businesses, improve client digital experiences and add scalability; and implementing new capabilities and partnerships. These business-led investments are designed to reduce expenses and grow revenues as well as result in retention and efficiency improvements. Citi's transformation, as well as its simplification and business investment initiatives, involve significant complexities and uncertainties. In addition, there is inherent risk that these initiatives will not be as productive or effective as Citi expects, or at all. Conversely, failure to adequately invest in and upgrade Citi's technology and processes or properly implement its enterprise-wide simplification could result in Citi's inability to meet regulatory expectations, be sufficiently competitive, serve clients effectively and avoid disruptions to its businesses and operational errors (see the operational processes and systems and legal and regulatory proceedings risk factors below). Citi's ability to achieve its expected returns, including expense savings and revenue growth objectives, and operational improvements from these priorities depends, in part, on factors that it cannot control, including, among others, macroeconomic challenges and uncertainties; customer, client and competitor actions; and ongoing regulatory requirements or changes.Moreover, Citi's transformation, simplification and other priorities may continue to evolve as its business strategies, the market environment and regulatory expectations change, which could make the initiatives more costly and more challenging to implement, and limit their effectiveness. Climate Change Presents Various Financial and Non-Financial Risks to Citi and Its Customers and Clients.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, market, technological, stakeholder and legal changes from a transition to a low-carbon economy). Physical and transition risks can manifest themselves differently across Citi's risk categories in the short, medium and long terms. Physical risks from climate change include acute risks, such as wildfires, hurricanes, floods and droughts, as well as consequences of chronic changes in climate, such as rising sea levels, prolonged droughts and systemic changes to geographies and any resulting population migration. For example, physical risks could have adverse financial, operational and other impacts on Citi, both directly on its business and operations, and indirectly as a result of impacts to Citi's clients, customers, vendors and other counterparties. These impacts can include destruction, damage or impairment of owned or leased properties and other assets, destruction or deterioration of the value of collateral, such as real estate, disruptions to business operations and supply chains, and reduced availability or increase in the cost of insurance. Physical risks can also impact Citi's credit risk exposures, for example, in its mortgage and commercial real estate lending businesses.Transition risks may arise from changes in regulations or market preferences toward low-carbon industries or sectors, 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. Failure to adequately consider transition risk in developing and executing on its business strategy could lead to a loss of market share, lower revenues and higher credit costs. Transition risks also include potential increased operational, compliance and energy costs driven by government policies to promote decarbonization. sufficiently competitive, serve clients effectively and avoid disruptions to its businesses and operational errors (see the operational processes and systems and legal and regulatory proceedings risk factors below). Citi's ability to achieve its expected returns, including expense savings and revenue growth objectives, and operational improvements from these priorities depends, in part, on factors that it cannot control, including, among others, macroeconomic challenges and uncertainties; customer, client and competitor actions; and ongoing regulatory requirements or changes. Moreover, Citi's transformation, simplification and other priorities may continue to evolve as its business strategies, the market environment and regulatory expectations change, which could make the initiatives more costly and more challenging to implement, and limit their effectiveness. --- ## Modified: Citigroup Inc. and Citibank - Potential Derivative Triggers **Key changes:** - Reworded sentence: "As of December 31, 2024, Citi estimates that a hypothetical one-notch downgrade of the senior debt/long-term rating across all three major rating agencies could impact funding and liquidity due to derivative triggers by approximately $0.1 billion, unchanged from September 30, 2024, for Citigroup Inc., and $0.1 billion, unchanged from September 30, 2024, for Citibank." - Reworded sentence: "In total, as of December 31, 2024, Citi estimates that a one-notch downgrade of Citigroup Inc." - Reworded sentence: "Citi believes these mitigating actions could substantially reduce the funding and liquidity risk, if any, of the potential downgrades described above.Citibank - Additional Potential Impacts In addition to the above derivative triggers, Citi believes that a potential downgrade of Citibank's senior debt/long-term rating across any of the three major rating agencies could also have an adverse impact on the commercial paper/short-term rating of Citibank." - Removed sentence: "98 98 98 Citibank - Additional Potential Impacts In addition to the above derivative triggers, Citi believes that a potential downgrade of Citibank's senior debt/long-term rating across any of the three major rating agencies could also have an adverse impact on the commercial paper/short-term rating of Citibank." - Removed sentence: "Citibank has provided liquidity commitments to consolidated asset-backed commercial paper conduits, primarily in the form of asset purchase agreements." **Prior (2024):** As of December 31, 2023, 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 $0.2 billion, compared to $0.3 billion as of September 30, 2023. 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, 2023, 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 billion, compared to $0.4 billion as of September 30, 2023. 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, 2023, Citi estimates that a one-notch downgrade of Citigroup Inc. and Citibank across all three major rating agencies could result in increased aggregate cash obligations and collateral requirements of approximately $0.5 billion, compared to $0.7 billion as of September 30, 2023 (see also Note 20). As detailed under "High-Quality Liquid Assets (HQLA)" above, Citigroup has various liquidity resources available to its bank and non-bank entities in part as a contingency for the potential events described above.In addition, a broad range of mitigating actions are currently included in Citigroup's and Citibank's contingency funding plans. For Citigroup, these mitigating factors include, but are not limited to, accessing surplus funding capacity from existing clients, tailoring levels of secured lending and adjusting the size of select trading books and collateralized borrowings at certain Citibank subsidiaries. Mitigating actions available to Citibank include, but are not limited to, selling or financing highly liquid government securities, tailoring levels of secured lending, adjusting the size of select trading assets, reducing loan originations and renewals, raising additional deposits or borrowing from the FHLB or central banks. Citi believes these mitigating actions could substantially reduce the funding and liquidity risk, if any, of the potential downgrades described above. As of December 31, 2023, 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 billion, compared to $0.4 billion as of September 30, 2023. 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, 2023, Citi estimates that a one-notch downgrade of Citigroup Inc. and Citibank across all three major rating agencies could result in increased aggregate cash obligations and collateral requirements of approximately $0.5 billion, compared to $0.7 billion as of September 30, 2023 (see also Note 20). As detailed under "High-Quality Liquid Assets (HQLA)" above, Citigroup has various liquidity resources available to its bank and non-bank entities in part as a contingency for the potential events described above. In addition, a broad range of mitigating actions are currently included in Citigroup's and Citibank's contingency funding plans. For Citigroup, these mitigating factors include, but are not limited to, accessing surplus funding capacity from existing clients, tailoring levels of secured lending and adjusting the size of select trading books and collateralized borrowings at certain Citibank subsidiaries. Mitigating actions available to Citibank include, but are not limited to, selling or financing highly liquid government securities, tailoring levels of secured lending, adjusting the size of select trading assets, reducing loan originations and renewals, raising additional deposits or borrowing from the FHLB or central banks. Citi believes these mitigating actions could substantially reduce the funding and liquidity risk, if any, of the potential downgrades described above. 98 98 98 Citibank - Additional Potential Impacts In addition to the above derivative triggers, Citi believes that a potential downgrade of Citibank's senior debt/long-term rating across any of the three major rating agencies could also have an adverse impact on the commercial paper/short-term rating of Citibank. Citibank has provided liquidity commitments to consolidated asset-backed commercial paper conduits, primarily in the form of asset purchase agreements. As of December 31, 2023, Citibank had liquidity commitments of approximately $11.0 billion to consolidated asset-backed commercial paper conduits, unchanged from December 31, 2022 (see Note 23).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. 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, 2023, Citibank had liquidity commitments of approximately $11.0 billion to consolidated asset-backed commercial paper conduits, unchanged from December 31, 2022 (see Note 23).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. **Current (2025):** As of December 31, 2024, Citi estimates that a hypothetical one-notch downgrade of the senior debt/long-term rating across all three major rating agencies could impact funding and liquidity due to derivative triggers by approximately $0.1 billion, unchanged from September 30, 2024, for Citigroup Inc., and $0.1 billion, unchanged from September 30, 2024, for Citibank. 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, 2024, Citi estimates that a one-notch downgrade of Citigroup Inc. and Citibank across all three major rating agencies could result in increased aggregate cash obligations and collateral requirements of approximately $0.2 billion, compared to $0.2 billion as of September 30, 2024. As detailed under "High-Quality Liquid Assets (HQLA)" above, Citigroup has various liquidity resources available to its bank and non-bank entities in part as a contingency for the potential events described above.In addition, a broad range of mitigating actions are currently included in Citigroup's and Citibank's contingency funding plans. For Citigroup, these mitigating factors include, but are not limited to, accessing surplus funding capacity from existing clients, tailoring levels of secured lending and adjusting the size of select trading books and collateralized borrowings at certain Citibank subsidiaries. Mitigating actions available to Citibank include, but are not limited to, selling or financing highly liquid government securities, tailoring levels of secured lending, adjusting the size of select trading assets, reducing loan originations and renewals, raising additional deposits or borrowing from the FHLB or central banks. Citi believes these mitigating actions could substantially reduce the funding and liquidity risk, if any, of the potential downgrades described above.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, 2024, Citibank had liquidity commitments of approximately $14.9 billion to consolidated asset-backed commercial paper conduits (compared to $11.0 billion at December 31, 2023) (see Note 23). In total, as of December 31, 2024, Citi estimates that a one-notch downgrade of Citigroup Inc. and Citibank across all three major rating agencies could result in increased aggregate cash obligations and collateral requirements of approximately $0.2 billion, compared to $0.2 billion as of September 30, 2024. As detailed under "High-Quality Liquid Assets (HQLA)" above, Citigroup has various liquidity resources available to its bank and non-bank entities in part as a contingency for the potential events described above. In addition, a broad range of mitigating actions are currently included in Citigroup's and Citibank's contingency funding plans. For Citigroup, these mitigating factors include, but are not limited to, accessing surplus funding capacity from existing clients, tailoring levels of secured lending and adjusting the size of select trading books and collateralized borrowings at certain Citibank subsidiaries. Mitigating actions available to Citibank include, but are not limited to, selling or financing highly liquid government securities, tailoring levels of secured lending, adjusting the size of select trading assets, reducing loan originations and renewals, raising additional deposits or borrowing from the FHLB or central banks. Citi believes these mitigating actions could substantially reduce the funding and liquidity risk, if any, of the potential downgrades described above. --- ## Modified: Other industries(6) **Key changes:** - Reworded sentence: "(1) Funded excludes loans carried at fair value of $7.8 billion at December 31, 2024." - Reworded sentence: "Of the $37.8 billion of purchased credit protection, $34.8 billion represents the total notional amount of purchased credit derivatives on individual reference entities." **Prior (2024):** (1) Funded excludes loans carried at fair value of $7.3 billion at December 31, 2023. (2) Includes non-accrual loan exposures and related criticized unfunded exposures. (3) Represents the amount of purchased credit protection in the form of derivatives to economically hedge funded and unfunded exposures. Of the $35.9 billion of purchased credit protection, $33.7 billion represents the total notional amount of purchased credit derivatives on individual reference entities. The remaining $2.2 billion represents the first loss tranche of portfolios of purchased credit derivatives with a total notional of $16.7 billion, where the protection seller absorbs the first loss on the referenced loan portfolios. (4) 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 $16.9 billion ($10.6 billion in funded, with 100% rated investment grade) as of December 31, 2023. (5) 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, 2023, Citi's total exposure to these energy-related entities was approximately $4.9 billion, of which approximately $2.5 billion consisted of direct outstanding funded loans. (6) Includes $0.6 billion and $0.1 billion of funded and unfunded exposure at December 31, 2023, respectively, primarily related to commercial credit card delinquency-managed loans. Exposure to Commercial Real EstateAs of December 31, 2023, Citi's total credit exposure to commercial real estate (CRE) was $66 billion, including $8 billion of exposure related to office buildings. This total CRE exposure consisted of approximately $55 billion related to corporate clients, included in the real estate category in the table above, and approximately $11 billion related to Wealth clients that is not in the table above as they are not considered corporate exposures. In addition, as of December 31, 2023, approximately 80% of Citi's total CRE exposure was rated investment grade and more than 77% was to borrowers in the U.S.As of December 31, 2023, the ACLL attributed to the total funded CRE exposure (including the Private Bank) was approximately 1.49%, and there were $759 million of non-accrual CRE loans. Exposure to Commercial Real EstateAs of December 31, 2023, Citi's total credit exposure to commercial real estate (CRE) was $66 billion, including $8 billion of exposure related to office buildings. This total CRE exposure consisted of approximately $55 billion related to corporate clients, included in the real estate category in the table above, and approximately $11 billion related to Wealth clients that is not in the table above as they are not considered corporate exposures. **Current (2025):** (1) Funded excludes loans carried at fair value of $7.8 billion at December 31, 2024. (2) Includes non-accrual loan exposures and related criticized unfunded exposures. (3) Represents the amount of purchased credit protection in the form of derivatives to economically hedge funded and unfunded exposures. Of the $37.8 billion of purchased credit protection, $34.8 billion represents the total notional amount of purchased credit derivatives on individual reference entities. The remaining $3 billion represents the first loss tranche of portfolios of purchased credit derivatives with a total notional amount of $22.9 billion, where the protection seller absorbs the first loss on the referenced loan portfolios. (4) 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 $17.5 billion ($10.5 billion of which was funded exposure with 100% rated investment grade) as of December 31, 2024. (5) 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., offshore drilling entities) included in the table above. As of December 31, 2024, Citi's total exposure to these energy-related entities was approximately $4.4 billion, of which approximately $2.1 billion consisted of direct outstanding funded loans. (6) Includes $0.6 billion and $0.1 billion of funded and unfunded exposure at December 31, 2024, respectively, primarily related to commercial credit card delinquency-managed loans. Exposure to Commercial Real EstateAs of December 31, 2024 and 2023, Citi's total credit exposure to commercial real estate (CRE) was $65 billion and $66 billion, including $6 billion and $8 billion of exposure related to office buildings, respectively. This total CRE exposure consisted of approximately $56 billion and $55 billion, respectively, related to corporate clients, included in the real estate category in the tables above and below. Total CRE exposure also includes approximately $9 billion and $11 billion, respectively, related to Wealth clients that is not in the tables as they are not considered corporate exposures.In addition, as of December 31, 2024, approximately 78% of Citi's total CRE exposure was rated investment grade and more than 75% was to borrowers in the U.S (compared to approximately 80% rated investment grade and more than 77% to borrowers in the U.S. as of December 31, 2023).As of December 31, 2024, the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.60%, and there were $574 million of non-accrual CRE loans. As of December 31, 2023, the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.49%, and there were $759 million of non-accrual CRE loans. Exposure to Commercial Real EstateAs of December 31, 2024 and 2023, Citi's total credit exposure to commercial real estate (CRE) was $65 billion and $66 billion, including $6 billion and $8 billion of exposure related to office buildings, respectively. This total CRE exposure consisted of approximately $56 billion and $55 billion, respectively, related to corporate clients, included in the real estate category in the tables above and below. Total CRE exposure also includes approximately $9 billion and $11 billion, respectively, related to Wealth clients that is not in the tables as they are not considered corporate exposures. --- ## Modified: Climate Change Presents Various Financial and Non-Financial Risks to Citi and Its Customers and Clients. **Key changes:** - Reworded sentence: "Physical risks from climate change include acute risks, such as wildfires, hurricanes, floods and droughts, as well as consequences of chronic changes in climate, such as rising sea levels, prolonged droughts and systemic changes to geographies and any resulting population migration." - Reworded sentence: "These impacts can include destruction, damage or impairment of owned or leased properties and other assets, destruction or deterioration of the value of collateral, such as real estate, disruptions to business operations and supply chains, and reduced availability or increase in the cost of insurance." - Reworded sentence: "52 52 52 Moreover, increasing legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures may result in increased regulatory, compliance, credit, reputational and other risks and costs for Citi." - Reworded sentence: "Modeling capabilities to analyze climate-related risks and interconnections continue to evolve.Additionally, if Citi is unable to achieve its objectives or commitments relating to climate change, its businesses, reputation, attractiveness to certain investors and efforts to recruit and retain employees may suffer." - Reworded sentence: "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.The new U.S." **Prior (2024):** 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, market, technological, stakeholder and legal changes from a transition to a low-carbon economy). Physical and transition risks can manifest themselves differently across Citi's risk categories in the short, medium and long terms. Physical risks from climate change include acute risks, such as hurricanes, floods and droughts, as well as consequences of chronic changes in climate, such as rising sea levels, prolonged droughts and systemic changes to geographies and any resulting population migration. For example, physical risks could have adverse financial, operational and other impacts on Citi, both directly on its business and operations, and indirectly as a result of impacts to Citi's clients, customers, vendors and other counterparties. These impacts can include destruction, damage or impairment of owned or leased properties and other assets, destruction or deterioration of the value of collateral, such as real estate, disruptions to business operations and supply chains and reduced availability or increase in the cost of insurance. Physical risks can also impact Citi's credit risk exposures, for example, in its mortgage and commercial real estate lending businesses. Transition risks may arise from changes in regulations or market preferences toward low-carbon industries or sectors, 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. Failure to adequately consider transition risk in developing and executing on its business strategy could lead to a loss of market share, lower revenues and higher credit costs. Transition risks also include potential increased operational, compliance and energy costs driven by government policies to promote decarbonization. Moreover, increasing legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures are likely to result in increased regulatory, compliance, credit, reputational and other risks and costs for Citi. New regulations have been enacted and/or are expected in several jurisdictions, including the EU's Corporate Sustainability Reporting Directive (CSRD), the SEC climate-related disclosures that could require disclosure of climate-related information and the State of California's legislation enacted in October 2023 requiring broad disclosure of greenhouse gas emissions and other climate-related information largely beginning in 2026. In addition, Citi could face increased regulatory scrutiny and reputation and litigation risks as a result of its climate risk, sustainability and other ESG-related commitments and disclosures. Even as some regulators seek to mandate additional disclosure of climate-related information, Citi's ability to comply with such requirements and conduct more robust climate-related risk analyses may be hampered by lack of information and reliable data. Data on climate-related risks is limited in availability, often based on estimated or unverified figures, collected and reported on a time-lag, and variable in quality. Modeling capabilities to analyze climate-related risks and interconnections are improving, but remain incomplete. 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. For example, in October 2023, the FRB, FDIC and OCC jointly released principles that provide a high-level framework for the safe and sound management of exposures to climate-related financial risks, including physical and transition risks, for financial institutions with more than $100 billion in assets. Additionally, if Citi's response to climate change is perceived to be ineffective or insufficient or Citi is unable to achieve its objectives or commitments relating to climate change, its businesses, reputation, attractiveness to certain investors and efforts to recruit and retain employees may suffer. For example, Citi's approach to supporting client decarbonization in a gradual and orderly way, while promoting energy security, may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Citi also faces anti-ESG challenges from certain U.S. state and other governments that may impact its ability to conduct certain business within those jurisdictions.For information on Citi's climate and other sustainability initiatives, see "Climate Change and Net Zero" below. For additional information on Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. due to the transition to a low-carbon economy. Failure to adequately consider transition risk in developing and executing on its business strategy could lead to a loss of market share, lower revenues and higher credit costs. Transition risks also include potential increased operational, compliance and energy costs driven by government policies to promote decarbonization. Moreover, increasing legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures are likely to result in increased regulatory, compliance, credit, reputational and other risks and costs for Citi. New regulations have been enacted and/or are expected in several jurisdictions, including the EU's Corporate Sustainability Reporting Directive (CSRD), the SEC climate-related disclosures that could require disclosure of climate-related information and the State of California's legislation enacted in October 2023 requiring broad disclosure of greenhouse gas emissions and other climate-related information largely beginning in 2026. In addition, Citi could face increased regulatory scrutiny and reputation and litigation risks as a result of its climate risk, sustainability and other ESG-related commitments and disclosures. Even as some regulators seek to mandate additional disclosure of climate-related information, Citi's ability to comply with such requirements and conduct more robust climate-related risk analyses may be hampered by lack of information and reliable data. Data on climate-related risks is limited in availability, often based on estimated or unverified figures, collected and reported on a time-lag, and variable in quality. Modeling capabilities to analyze climate-related risks and interconnections are improving, but remain incomplete. 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. For example, in October 2023, the FRB, FDIC and OCC jointly released principles that provide a high-level framework for the safe and sound management of exposures to climate-related financial risks, including physical and transition risks, for financial institutions with more than $100 billion in assets. Additionally, if Citi's response to climate change is perceived to be ineffective or insufficient or Citi is unable to achieve its objectives or commitments relating to climate change, its businesses, reputation, attractiveness to certain investors and efforts to recruit and retain employees may suffer. For example, Citi's approach to supporting client decarbonization in a gradual and orderly way, while promoting energy security, may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Citi also faces anti-ESG challenges from certain U.S. state and other governments that may impact its ability to conduct certain business within those jurisdictions. For information on Citi's climate and other sustainability initiatives, see "Climate Change and Net Zero" below. For additional information on Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. 51 51 51 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, 2023, Citi's net DTAs were $29.6 billion, net of a valuation allowance of $3.6 billion, of which $12.8 billion was deducted from Citi's CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $12.1 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $2.3 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $1.6 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital.Citi's overall ability to realize its DTAs will primarily be dependent upon Citi's ability to generate U.S. taxable income in the relevant reversal periods. Failure to realize any portion of the net DTAs would have a corresponding negative impact on Citi's net income and financial returns.The accounting treatment for realization of DTAs 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, macroeconomic conditions. In addition, any future increase in U.S. corporate tax rates could result in an increase in Citi's DTAs, which may subject more of Citi's DTAs to exclusion from regulatory capital. 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 10.Citi's Interpretation or Application of the Complex Tax Laws to Which It Is Subject Could Differ from Those of 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 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 to its entities, operations and businesses. For example, the Organization for Economic Cooperation and Development (OECD) Pillar 2 initiative contemplates a 15% global minimum tax with respect to earnings in each country. EU member states were required to adopt the OECD Pillar 2 rules in 2023, with an effective date of January 1, 2024 (unless an exception applied), and other non-U.S. countries have similarly adopted or are expected to adopt the rules. Under these rules, Citi will be required to pay a "top-up" tax to the extent that Citi's effective tax rate in any given country is below 15%. Beginning in 2024, countries that adopted the OECD Pillar 2 rules in 2023 can collect the top-up tax only with respect to earnings of entities in their jurisdiction or subsidiaries of such entities. Beginning in 2025, all countries that have adopted the OECD Pillar 2 rules can collect a share of the top-up tax owed with respect to any member of the Pillar 2 multinational group. While Citi does not currently expect the rules to have a material impact on its earnings, many aspects of the application of the rules remain uncertain.Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding non-income-based tax matters. While Citi has appropriately reserved for such matters where there is a probable loss, and has disclosed reasonably possible losses, the outcome of the matters may be different than Citi's expectations. Citi's interpretations or application of the tax laws, including with respect to withholding, stamp, service and other non-income taxes, could differ from that of the relevant governmental taxing authority, which could result in the requirement to pay additional taxes, penalties or interest, the reduction of certain tax benefits or the requirement to make adjustments to amounts recorded, which could be material. See Note 30 for additional information on litigation and examinations involving non-U.S. tax authorities.A Deterioration in or Failure to Maintain Citi's Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi.Citi has co-branding and private label relationships through its Branded Cards and Retail Services credit card businesses with various retailers and merchants, whereby in the ordinary course of business Citi issues credit cards to consumers, including customers of the retailers or merchants. The five largest relationships across both businesses in USPB constituted an aggregate of approximately 11% of Citi's revenues in 2023 (see "U.S. Personal Banking" above). Citi's co-branding and private label agreements often provide for shared economics between the parties and generally have a fixed term.Competition among card issuers, including Citi, for these relationships is significant, and Citi may not be able to maintain such relationships on existing terms or at all. Citi's co-branding and private label relationships could also be negatively impacted by, among other things, the general economic environment, including the impacts of continued elevated interest rates and inflation, and lower economic growth rates, as well as a continuing risk of recession; changes in consumer sentiment, spending patterns and credit card usage behaviors; a decline in sales and revenues, partner store closures, any reduction in 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 a challenging macroeconomic environment or otherwise.These events, particularly early termination and bankruptcies or liquidations, could negatively impact the results of operations or financial condition of Branded Cards, 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 (see Note 17 for information on Citi's credit card related intangibles generally). 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, 2023, Citi's net DTAs were $29.6 billion, net of a valuation allowance of $3.6 billion, of which $12.8 billion was deducted from Citi's CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $12.1 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $2.3 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $1.6 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital.Citi's overall ability to realize its DTAs will primarily be dependent upon Citi's ability to generate U.S. taxable income in the relevant reversal periods. Failure to realize any portion of the net DTAs would have a corresponding negative impact on Citi's net income and financial returns.The accounting treatment for realization of DTAs 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, macroeconomic conditions. In addition, any future increase in U.S. corporate tax rates could result in an increase in Citi's DTAs, which may subject more of Citi's DTAs to exclusion from regulatory capital. 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 10.Citi's Interpretation or Application of the Complex Tax Laws to Which It Is Subject Could Differ from Those of 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 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 to its entities, operations and businesses. For example, the Organization for Economic Cooperation and Development (OECD) Pillar 2 initiative contemplates a 15% global minimum tax with respect to earnings in each country. EU member states were required to adopt the OECD Pillar 2 rules in 2023, with an effective date of January 1, 2024 (unless an exception applied), and other non-U.S. countries have similarly adopted or are expected to adopt the rules. Under these rules, Citi will be required to pay a "top-up" tax to the extent that Citi's effective tax rate in any given country is below 15%. Beginning in 2024, countries that adopted the OECD Pillar 2 rules in 2023 can collect the top-up tax only with respect to earnings of entities in their jurisdiction or subsidiaries of such entities. Beginning in 2025, all countries **Current (2025):** 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, market, technological, stakeholder and legal changes from a transition to a low-carbon economy). Physical and transition risks can manifest themselves differently across Citi's risk categories in the short, medium and long terms. Physical risks from climate change include acute risks, such as wildfires, hurricanes, floods and droughts, as well as consequences of chronic changes in climate, such as rising sea levels, prolonged droughts and systemic changes to geographies and any resulting population migration. For example, physical risks could have adverse financial, operational and other impacts on Citi, both directly on its business and operations, and indirectly as a result of impacts to Citi's clients, customers, vendors and other counterparties. These impacts can include destruction, damage or impairment of owned or leased properties and other assets, destruction or deterioration of the value of collateral, such as real estate, disruptions to business operations and supply chains, and reduced availability or increase in the cost of insurance. Physical risks can also impact Citi's credit risk exposures, for example, in its mortgage and commercial real estate lending businesses. Transition risks may arise from changes in regulations or market preferences toward low-carbon industries or sectors, 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. Failure to adequately consider transition risk in developing and executing on its business strategy could lead to a loss of market share, lower revenues and higher credit costs. Transition risks also include potential increased operational, compliance and energy costs driven by government policies to promote decarbonization. 52 52 52 Moreover, increasing legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures may result in increased regulatory, compliance, credit, reputational and other risks and costs for Citi. In addition, Citi could face increased regulatory scrutiny and reputation and litigation risks as a result of its climate risk, sustainability and other environmental and social commitments, disclosures, marketing and positioning. For example, any actual or perceived overstatement of the environmental benefits of Citi's actions may result in legal or regulatory actions and/or reputational harm. Even as some regulators seek to mandate additional disclosure of climate-related information, Citi's ability to comply with such requirements and conduct more robust climate-related risk analyses may be hampered by lack of information and reliable data. Data on climate-related risks is limited in availability, often based on estimated or unverified figures, collected and reported on a time-lag, and variable in quality. Modeling capabilities to analyze climate-related risks and interconnections continue to evolve.Additionally, if Citi is unable to achieve its objectives or commitments relating to climate change, its businesses, reputation, attractiveness to certain investors and efforts to recruit and retain employees may suffer. For example, Citi's approach to supporting client decarbonization in a gradual and orderly way, while promoting energy security, may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Citi may also face challenges and scrutiny from stakeholders with varied views on climate change that may impact its ability to conduct certain business.For information on Citi's climate and other sustainability initiatives, see "Net Zero and Sustainability" below. For additional information on Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate 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, 2024, Citi's net DTAs were $29.8 billion, net of a valuation allowance of $4.3 billion, of which $12.8 billion was deducted from Citi's CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $11.6 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $3.0 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $1.8 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital.Citi's overall ability to realize its DTAs will primarily be dependent upon Citi's ability to generate U.S. taxable income in the relevant reversal periods. Failure to realize any portion of the net DTAs would have a corresponding negative impact on Citi's net income and financial returns.The accounting treatment for realization of DTAs 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, macroeconomic conditions. In addition, any future increase in U.S. corporate tax rates could result in an increase in Citi's DTAs, which may subject more of Citi's DTAs to exclusion from regulatory capital. 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.The new U.S. administration has discussed potential reductions to the U.S. federal corporate tax rate and changes to the U.S. approach to the Organization for Economic Cooperation and Development (OECD) Pillar 2 framework. It is unclear whether any corporate tax rate reduction would apply to services companies like Citi. If the U.S. federal corporate tax rate applicable to Citi is reduced, Citi may benefit on a prospective net income basis, but the reduction could result in a material decrease in the value of Citi's DTAs, which would also result in a material reduction to Citi's net income during the period in which the change is enacted. Citi's regulatory capital could also be reduced if the decrease in the value of Citi's DTAs exceeds certain levels.For additional information on Citi's DTAs, including FTCs, see "Significant Accounting Policies and Significant Estimates - Income Taxes" below and Notes 1 and 10.Citi's Interpretation or Application of the Complex Tax Laws to Which It Is Subject Could Differ from Those of 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 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 to its entities, operations and businesses. For example, the OECD Pillar 2 framework contemplates a 15% global minimum tax with respect to earnings in each country. The majority of EU member states have adopted the OECD Pillar 2 rules, and other non-U.S. countries have similarly adopted or are expected to adopt the rules. Under these rules, Citi will be required to pay a "top-up" tax to the extent that Citi's effective tax rate in any given country is below 15%. Beginning in 2024, countries that adopted the OECD Pillar 2 rules can collect the top-up tax only with respect to earnings of entities in their jurisdiction or subsidiaries of such entities. Beginning in 2025, all countries that have adopted the OECD Pillar 2 rules can collect a share of the top-up tax owed with respect to any member of the Pillar 2 multinational group. While Citi does not currently expect the rules to have a material impact on its earnings, many aspects of the application of the rules and their implementation remain uncertain. Separately, the new U.S. administration has stated its opposition to the application of the global minimum tax to U.S. companies' U.S. operations, and has indicated it may take retaliatory measures against other countries that seek to collect the minimum tax with respect to the U.S. operations of U.S. companies. Citi is Moreover, increasing legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures may result in increased regulatory, compliance, credit, reputational and other risks and costs for Citi. In addition, Citi could face increased regulatory scrutiny and reputation and litigation risks as a result of its climate risk, sustainability and other environmental and social commitments, disclosures, marketing and positioning. For example, any actual or perceived overstatement of the environmental benefits of Citi's actions may result in legal or regulatory actions and/or reputational harm. Even as some regulators seek to mandate additional disclosure of climate-related information, Citi's ability to comply with such requirements and conduct more robust climate-related risk analyses may be hampered by lack of information and reliable data. Data on climate-related risks is limited in availability, often based on estimated or unverified figures, collected and reported on a time-lag, and variable in quality. Modeling capabilities to analyze climate-related risks and interconnections continue to evolve.Additionally, if Citi is unable to achieve its objectives or commitments relating to climate change, its businesses, reputation, attractiveness to certain investors and efforts to recruit and retain employees may suffer. For example, Citi's approach to supporting client decarbonization in a gradual and orderly way, while promoting energy security, may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Citi may also face challenges and scrutiny from stakeholders with varied views on climate change that may impact its ability to conduct certain business.For information on Citi's climate and other sustainability initiatives, see "Net Zero and Sustainability" below. For additional information on Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate 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, 2024, Citi's net DTAs were $29.8 billion, net of a valuation allowance of $4.3 billion, of which $12.8 billion was deducted from Citi's CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $11.6 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $3.0 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $1.8 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital.Citi's overall ability to realize its DTAs will primarily be dependent upon Citi's ability to generate U.S. taxable income in the relevant reversal periods. Failure to realize any portion of the net DTAs would have a corresponding negative impact on Citi's net income and financial returns.The accounting treatment for realization of DTAs 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 Moreover, increasing legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures may result in increased regulatory, compliance, credit, reputational and other risks and costs for Citi. In addition, Citi could face increased regulatory scrutiny and reputation and litigation risks as a result of its climate risk, sustainability and other environmental and social commitments, disclosures, marketing and positioning. For example, any actual or perceived overstatement of the environmental benefits of Citi's actions may result in legal or regulatory actions and/or reputational harm. Even as some regulators seek to mandate additional disclosure of climate-related information, Citi's ability to comply with such requirements and conduct more robust climate-related risk analyses may be hampered by lack of information and reliable data. Data on climate-related risks is limited in availability, often based on estimated or unverified figures, collected and reported on a time-lag, and variable in quality. Modeling capabilities to analyze climate-related risks and interconnections continue to evolve. Additionally, if Citi is unable to achieve its objectives or commitments relating to climate change, its businesses, reputation, attractiveness to certain investors and efforts to recruit and retain employees may suffer. For example, Citi's approach to supporting client decarbonization in a gradual and orderly way, while promoting energy security, may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Citi may also face challenges and scrutiny from stakeholders with varied views on climate change that may impact its ability to conduct certain business. For information on Citi's climate and other sustainability initiatives, see "Net Zero and Sustainability" below. For additional information on Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. --- ## Modified: U.S. Cards FICO Distribution **Key changes:** - Reworded sentence: "FICO scores are updated as they become available." **Prior (2024):** The following tables present the current FICO score distributions for Citi's Branded Cards and Retail Services portfolios based on end-of-period receivables. FICO scores are updated monthly for substantially all of the portfolio and on a quarterly basis for the remaining portfolio. **Current (2025):** The following tables present the current FICO score distributions for Citi's Branded Cards and Retail Services portfolios based on end-of-period receivables. FICO scores are updated as they become available. --- ## Modified: Citi Is Subject to Extensive Legal and Regulatory Proceedings, Examinations, Investigations, Consent Orders and Related Compliance Efforts and Other Inquiries That Could Result in Large Monetary Penalties, Supervisory or Enforcement Orders, Business Restrictions, Limitations on Dividends, Changes to Directors and/or Officers and Collateral Consequences Arising from Such Outcomes. **Key changes:** - Added sentence: "Citi's regulators have broad powers and discretion under their prudential and supervisory authority, and have pursued active inspection and investigatory oversight." - Reworded sentence: "Citi could face further scrutiny and consequences from regulators for failing to timely resolve open regulatory issues or having repeat regulatory issues." - Reworded sentence: "Responding to regulatory inquiries and proceedings can be time consuming and costly, and divert management attention from Citi's businesses." - Reworded sentence: "and other governments may, in the future, have significant collateral consequences for Citi, including loss of customers and business, operational loss and the inability to offer certain products or services and/or operate certain businesses." - Added sentence: "Furthermore, regulators may be more likely to pursue investigations or proceedings against financial institutions, such as Citi, that have previously been the subject of other regulatory actions.For further information on Citi's legal and regulatory proceedings, see Note 30.OTHER RISKSCiti's Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.Citi's presence in the emerging markets subjects it to various risks." **Prior (2024):** At any given time, Citi is a party to a significant number of legal and regulatory proceedings and is subject to numerous governmental and regulatory examinations. Additionally, Citi remains subject to governmental and regulatory investigations, consent orders (see discussion below) and related compliance efforts, and other inquiries. Citi could also be subject to enforcement proceedings and negative regulatory evaluation or examination findings 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 (see also the capital return and resolution plan risk factors above). Citi's regulators have broad powers and discretion under their prudential and supervisory authority, and have pursued active inspection and investigatory oversight. As previously disclosed, the October 2020 FRB and OCC consent orders require Citigroup and Citibank to implement extensive targeted action plans and submit quarterly progress reports on a timely and sufficient basis 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 2024 and beyond, as an essential part of Citi's broader transformation efforts to enhance its risk, controls, data and finance infrastructure and compliance. There can be no assurance that such improvements will be implemented in a manner satisfactory, in both timing and sufficiency, to the FRB and OCC. 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. 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, which have been subject to increased regulatory scrutiny. 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 foreign jurisdictions, as well as multiple civil litigation claims in multiple jurisdictions. Violations of law by other financial institutions may also result in regulatory scrutiny of Citi. Responding to regulatory 60 60 60 inquiries and proceedings can be time consuming and costly, and divert management attention from Citi's businesses. U.S. and non-U.S. regulators have been increasingly focused on the culture of financial services firms, including Citi, as well as "conduct risk," a term used to describe the risks associated with behavior by employees and agents, including third parties, that could harm clients, customers, employees or the integrity of the markets, such as improperly creating, selling, marketing or managing products and services or improper incentive compensation programs with respect thereto, failures to safeguard a party's personal information, or failures to identify and manage conflicts of interest. In addition to the greater focus on conduct risk, the general heightened scrutiny and expectations from regulators could lead to investigations and other inquiries, as well as remediation requirements, regulatory restrictions, structural changes, more regulatory or other enforcement proceedings, civil litigation and higher compliance and other risks and costs. For additional information, see the capital return andheightened regulatory scrutiny and ongoing interpretation ofregulatory changes risk factors above. 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. Moreover, the severity of the remedies sought in legal and regulatory proceedings to which Citi is subject has remained elevated. For example, U.S. and certain non-U.S. governmental entities have increasingly brought criminal actions against, or have sought and obtained criminal guilty pleas or deferred prosecution agreements from, financial institutions and individual employees. These types of actions by U.S. and other governments may, in the future, have significant collateral consequences for Citi, including loss of customers and business, operational loss, and the inability to offer certain products or services and/or operate certain businesses. Citi may be required to accept or be subject to similar types of criminal remedies, consent orders, sanctions, substantial fines and penalties, remediation and other financial costs or other requirements in the future, including for matters or practices not yet known to Citi, any of which could materially and negatively affect Citi's businesses, business practices, financial condition or results of operations, require material changes in Citi's operations or cause Citi substantial reputational harm. Additionally, 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 (see the incorrect assumptions or estimates risk factor above). In addition, certain settlements are subject to court approval and may not be approved. For further information on Citi's legal and regulatory proceedings, see Note 30.OTHER RISKSCiti's Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.During 2023, emerging markets revenues accounted for approximately 40% 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). Citi's presence in the emerging markets subjects it to various risks. Emerging market risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations and strength in the U.S. dollar; sustained elevated interest rates and quantitative tightening; elevated inflation and hyperinflation; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; macroeconomic, geopolitical and domestic political challenges, uncertainties and volatility, including with respect to Russia (see the macroeconomic and geopolitical risk factor above and "Managing Global Risk - Other Risks - Country Risk - Russia" and " - Ukraine" below); cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; election outcomes; regulatory changes, including potential conflicts among regulations with other jurisdictions where Citi does business; limitations on foreign investment; sociopolitical instability; civil unrest; crime, corruption and fraud; nationalization or loss of licenses; potential criminal charges; closure of branches or subsidiaries; and confiscation of assets; and these risks can be exacerbated in the event of a deterioration in the relationship 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 controls, currency controls and/or sanctions, such as Argentina and Russia, that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. For instance, Citi may need to record additional translation losses due to currency controls in Argentina (see "Managing Global Risk - Other Risks - Country Risk - Argentina" below). Moreover, Citi may need to record additional reserves for expected losses for its credit exposures based on the transfer risk associated with exposures outside the U.S., driven by safety and soundness considerations under U.S. banking law (see "Managing Global Risk - Other Risks - Country Risk - Argentina" and " - Russia" and "Significant AccountingPolicies and Significant Estimates" below). In addition, political turmoil and instability; geopolitical challenges, tensions and conflicts (including those related to Russia's war in Ukraine as well as a persistent and/or escalating conflict in the Middle East); terrorism; and other instabilities have occurred in various regions and emerging market countries across the globe, which impact Citi's businesses, results of operations and financial conditions in affected countries and have required, and may continue to require, management time and attention and other resources, such as managing the impact of sanctions and their effect on Citi's operations in certain emerging market countries. For inquiries and proceedings can be time consuming and costly, and divert management attention from Citi's businesses. U.S. and non-U.S. regulators have been increasingly focused on the culture of financial services firms, including Citi, as well as "conduct risk," a term used to describe the risks associated with behavior by employees and agents, including third parties, that could harm clients, customers, employees or the integrity of the markets, such as improperly creating, selling, marketing or managing products and services or improper incentive compensation programs with respect thereto, failures to safeguard a party's personal information, or failures to identify and manage conflicts of interest. In addition to the greater focus on conduct risk, the general heightened scrutiny and expectations from regulators could lead to investigations and other inquiries, as well as remediation requirements, regulatory restrictions, structural changes, more regulatory or other enforcement proceedings, civil litigation and higher compliance and other risks and costs. For additional information, see the capital return andheightened regulatory scrutiny and ongoing interpretation ofregulatory changes risk factors above. 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. Moreover, the severity of the remedies sought in legal and regulatory proceedings to which Citi is subject has remained elevated. For example, U.S. and certain non-U.S. governmental entities have increasingly brought criminal actions against, or have sought and obtained criminal guilty pleas or deferred prosecution agreements from, financial institutions and individual employees. These types of actions by U.S. and other governments may, in the future, have significant collateral consequences for Citi, including loss of customers and business, operational loss, and the inability to offer certain products or services and/or operate certain businesses. Citi may be required to accept or be subject to similar types of criminal remedies, consent orders, sanctions, substantial fines and penalties, remediation and other financial costs or other requirements in the future, including for matters or practices not yet known to Citi, any of which could materially and negatively affect Citi's businesses, business practices, financial condition or results of operations, require material changes in Citi's operations or cause Citi substantial reputational harm. Additionally, 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 (see the incorrect assumptions or estimates risk factor above). In addition, certain settlements are subject to court approval and may not be approved. For further information on Citi's legal and regulatory proceedings, see Note 30. inquiries and proceedings can be time consuming and costly, and divert management attention from Citi's businesses. U.S. and non-U.S. regulators have been increasingly focused on the culture of financial services firms, including Citi, as well as "conduct risk," a term used to describe the risks associated with behavior by employees and agents, including third parties, that could harm clients, customers, employees or the integrity of the markets, such as improperly creating, selling, marketing or managing products and services or improper incentive compensation programs with respect thereto, failures to safeguard a party's personal information, or failures to identify and manage conflicts of interest. In addition to the greater focus on conduct risk, the general heightened scrutiny and expectations from regulators could lead to investigations and other inquiries, as well as remediation requirements, regulatory restrictions, structural changes, more regulatory or other enforcement proceedings, civil litigation and higher compliance and other risks and costs. For additional information, see the capital return and heightened regulatory scrutiny and ongoing interpretation of regulatory changes risk factors above. 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. Moreover, the severity of the remedies sought in legal and regulatory proceedings to which Citi is subject has remained elevated. For example, U.S. and certain non-U.S. governmental entities have increasingly brought criminal actions against, or have sought and obtained criminal guilty pleas or deferred prosecution agreements from, financial institutions and individual employees. These types of actions by U.S. and other governments may, in the future, have significant collateral consequences for Citi, including loss of customers and business, operational loss, and the inability to offer certain products or services and/or operate certain businesses. Citi may be required to accept or be subject to similar types of criminal remedies, consent orders, sanctions, substantial fines and penalties, remediation and other financial costs or other requirements in the future, including for matters or practices not yet known to Citi, any of which could materially and negatively affect Citi's businesses, business practices, financial condition or results of operations, require material changes in Citi's operations or cause Citi substantial reputational harm. Additionally, 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 (see the incorrect assumptions or estimates risk factor above). In addition, certain settlements are subject to court approval and may not be approved. For further information on Citi's legal and regulatory proceedings, see Note 30. OTHER RISKSCiti's Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.During 2023, emerging markets revenues accounted for approximately 40% 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). Citi's presence in the emerging markets subjects it to various risks. Emerging market risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations and strength in the U.S. dollar; sustained elevated interest rates and quantitative tightening; elevated inflation and hyperinflation; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; macroeconomic, geopolitical and domestic political challenges, uncertainties and volatility, including with respect to Russia (see the macroeconomic and geopolitical risk factor above and "Managing Global Risk - Other Risks - Country Risk - Russia" and " - Ukraine" below); cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; election outcomes; regulatory changes, including potential conflicts among regulations with other jurisdictions where Citi does business; limitations on foreign investment; sociopolitical instability; civil unrest; crime, corruption and fraud; nationalization or loss of licenses; potential criminal charges; closure of branches or subsidiaries; and confiscation of assets; and these risks can be exacerbated in the event of a deterioration in the relationship 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 controls, currency controls and/or sanctions, such as Argentina and Russia, that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. For instance, Citi may need to record additional translation losses due to currency controls in Argentina (see "Managing Global Risk - Other Risks - Country Risk - Argentina" below). Moreover, Citi may need to record additional reserves for expected losses for its credit exposures based on the transfer risk associated with exposures outside the U.S., driven by safety and soundness considerations under U.S. banking law (see "Managing Global Risk - Other Risks - Country Risk - Argentina" and " - Russia" and "Significant AccountingPolicies and Significant Estimates" below). In addition, political turmoil and instability; geopolitical challenges, tensions and conflicts (including those related to Russia's war in Ukraine as well as a persistent and/or escalating conflict in the Middle East); terrorism; and other instabilities have occurred in various regions and emerging market countries across the globe, which impact Citi's businesses, results of operations and financial conditions in affected countries and have required, and may continue to require, management time and attention and other resources, such as managing the impact of sanctions and their effect on Citi's operations in certain emerging market countries. For **Current (2025):** Citi's regulators have broad powers and discretion under their prudential and supervisory authority, and have pursued active inspection and investigatory oversight. At any given time, Citi is a party to a significant number of legal and regulatory proceedings and is subject to numerous governmental and regulatory examinations. Additionally, Citi remains subject to governmental and regulatory investigations, consent orders (see discussion below) and related compliance efforts, and other inquiries. Citi could also be subject to enforcement proceedings and negative regulatory evaluation or examination findings 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 (see also the capital return and resolution plan risk factors above). Citi could face further scrutiny and consequences from regulators for failing to timely resolve open regulatory issues or having repeat regulatory issues. As previously disclosed, the 2020 FRB Consent Order and the 2020 OCC Consent Order require Citigroup and Citibank, respectively, to implement extensive targeted action plans and submit quarterly progress reports on a timely and sufficient basis detailing the results and status of improvements relating principally to various aspects of enterprise-wide risk management, compliance, data quality management related to governance, and internal controls. These improvements will result in continued significant investments by Citi during 2025 and beyond, as an essential part of Citi's broader transformation efforts to enhance its risk, controls, data and finance infrastructure and compliance (see the transformation, simplification and other priorities-related risk factor above). Additionally, on July 10, 2024, the FRB entered into a Civil Money Penalty Consent Order with Citigroup, and the OCC entered into a Civil Money Penalty Consent Order with Citibank. The OCC and Citibank also entered into an Amendment to the OCC's 2020 Consent Order (the Amendment). The FRB found that Citigroup had ongoing deficiencies related to its data quality management program and had inadequate measures for managing and controlling its data quality risks. The OCC found that Citibank had failed to make sufficient and sustainable progress toward achieving compliance with its 2020 Consent Order. The Amendment requires Citibank to formalize a process to determine whether sufficient resources are being appropriately allocated toward achieving timely and sustainable compliance with the OCC's 2020 Consent Order, including any requirements on which Citibank is not making sufficient and sustainable progress (such process, the Resource Review Plan). There can be no assurance that the Resource 62 62 62 Review Plan and other efforts by Citi to address the deficiencies and resolve the OCC and FRB Consent Orders will occur in a manner satisfactory, in both timing and sufficiency, to the FRB and OCC. (For additional information, see "Citi's Multiyear Transformation" above.)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. Such actions by the OCC could include imposing business restrictions, including possible additional limitations on the declaration or payment of dividends by Citibank and changes in directors and/or senior executive officers. More generally, the OCC and/or the FRB could again take enforcement or other actions if the regulatory agency believes that Citi has not met regulatory expectations regarding compliance with the consent orders. The global judicial, regulatory and political environment has generally been challenging for large financial institutions, which have been subject to increased regulatory scrutiny. 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 foreign jurisdictions, as well as multiple civil litigation claims in multiple jurisdictions. Violations of law by other financial institutions may also result in regulatory scrutiny of Citi. Responding to regulatory inquiries and proceedings can be time consuming and costly, and divert management attention from Citi's businesses. U.S. and non-U.S. regulators have been increasingly focused on the culture of financial services firms, including Citi, as well as "conduct risk," a term used to describe the risks associated with behavior by employees and agents, including third parties, that could harm clients, customers, employees or the integrity of the markets, such as improperly creating, selling, marketing or managing products and services or improper incentive compensation programs with respect thereto, failures to safeguard a party's personal information or failures to identify and manage conflicts of interest. In addition to the greater focus on conduct risk, the general heightened scrutiny and expectations from regulators could lead to investigations and other inquiries, as well as remediation requirements, regulatory restrictions, structural changes, more regulatory or other enforcement proceedings, civil litigation and higher compliance and other risks and costs. For additional information, see the capital return and heightened regulatory scrutiny and ongoing interpretation of regulatory changes risk factors above. 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. Moreover, the severity of the remedies sought in legal and regulatory proceedings to which Citi is subject has remained elevated. For example, U.S. and certain non-U.S. governmental entities have increasingly brought criminal actions against, or have sought and obtained criminal guilty pleas or deferred prosecution agreements from, financial institutions and individual employees. These types of actions by U.S. and other governments may, in the future, have significant collateral consequences for Citi, including loss of customers and business, operational loss and the inability to offer certain products or services and/or operate certain businesses. Citi may be required to accept or be subject to similar types of criminal remedies, consent orders, sanctions, substantial fines and penalties, remediation and other financial costs or other requirements in the future, including for matters or practices not yet known to Citi, any of which could materially and negatively affect Citi's businesses, business practices, financial condition or results of operations, require material changes in Citi's operations or cause Citi substantial reputational harm. Additionally, 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 (see the incorrect assumptions or estimates risk factor above). In addition, certain settlements are subject to court approval and may not be approved. Furthermore, regulators may be more likely to pursue investigations or proceedings against financial institutions, such as Citi, that have previously been the subject of other regulatory actions.For further information on Citi's legal and regulatory proceedings, see Note 30.OTHER RISKSCiti's Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.Citi's presence in the emerging markets subjects it to various risks. During 2024, emerging markets revenues accounted for approximately 28% of Citi's total revenues (based, beginning in 2024, on the IMF and FFIEC classifications, which resulted in the exclusion of certain countries that Citi previously classified as emerging markets). Emerging market risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations and strength in the U.S. dollar; central bank interest rate and other monetary policies, including the impact of sustained high interest rates in the U.S.; unemployment, recessions or weak or slowing economic growth; elevated inflation and hyperinflation; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; macroeconomic, Review Plan and other efforts by Citi to address the deficiencies and resolve the OCC and FRB Consent Orders will occur in a manner satisfactory, in both timing and sufficiency, to the FRB and OCC. (For additional information, see "Citi's Multiyear Transformation" above.)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. Such actions by the OCC could include imposing business restrictions, including possible additional limitations on the declaration or payment of dividends by Citibank and changes in directors and/or senior executive officers. More generally, the OCC and/or the FRB could again take enforcement or other actions if the regulatory agency believes that Citi has not met regulatory expectations regarding compliance with the consent orders. The global judicial, regulatory and political environment has generally been challenging for large financial institutions, which have been subject to increased regulatory scrutiny. 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 foreign jurisdictions, as well as multiple civil litigation claims in multiple jurisdictions. Violations of law by other financial institutions may also result in regulatory scrutiny of Citi. Responding to regulatory inquiries and proceedings can be time consuming and costly, and divert management attention from Citi's businesses. U.S. and non-U.S. regulators have been increasingly focused on the culture of financial services firms, including Citi, as well as "conduct risk," a term used to describe the risks associated with behavior by employees and agents, including third parties, that could harm clients, customers, employees or the integrity of the markets, such as improperly creating, selling, marketing or managing products and services or improper incentive compensation programs with respect thereto, failures to safeguard a party's personal information or failures to identify and manage conflicts of interest. In addition to the greater focus on conduct risk, the general heightened scrutiny and expectations from regulators could lead to investigations and other inquiries, as well as remediation requirements, regulatory restrictions, structural changes, more regulatory or other enforcement proceedings, civil litigation and higher compliance and other risks and costs. For additional information, see the capital return and heightened regulatory scrutiny and ongoing interpretation of regulatory changes risk factors above. 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. Review Plan and other efforts by Citi to address the deficiencies and resolve the OCC and FRB Consent Orders will occur in a manner satisfactory, in both timing and sufficiency, to the FRB and OCC. (For additional information, see "Citi's Multiyear Transformation" above.) 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. Such actions by the OCC could include imposing business restrictions, including possible additional limitations on the declaration or payment of dividends by Citibank and changes in directors and/or senior executive officers. More generally, the OCC and/or the FRB could again take enforcement or other actions if the regulatory agency believes that Citi has not met regulatory expectations regarding compliance with the consent orders. The global judicial, regulatory and political environment has generally been challenging for large financial institutions, which have been subject to increased regulatory scrutiny. 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 foreign jurisdictions, as well as multiple civil litigation claims in multiple jurisdictions. Violations of law by other financial institutions may also result in regulatory scrutiny of Citi. Responding to regulatory inquiries and proceedings can be time consuming and costly, and divert management attention from Citi's businesses. U.S. and non-U.S. regulators have been increasingly focused on the culture of financial services firms, including Citi, as well as "conduct risk," a term used to describe the risks associated with behavior by employees and agents, including third parties, that could harm clients, customers, employees or the integrity of the markets, such as improperly creating, selling, marketing or managing products and services or improper incentive compensation programs with respect thereto, failures to safeguard a party's personal information or failures to identify and manage conflicts of interest. In addition to the greater focus on conduct risk, the general heightened scrutiny and expectations from regulators could lead to investigations and other inquiries, as well as remediation requirements, regulatory restrictions, structural changes, more regulatory or other enforcement proceedings, civil litigation and higher compliance and other risks and costs. For additional information, see the capital return and heightened regulatory scrutiny and ongoing interpretation of regulatory changes risk factors above. 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. Moreover, the severity of the remedies sought in legal and regulatory proceedings to which Citi is subject has remained elevated. For example, U.S. and certain non-U.S. governmental entities have increasingly brought criminal actions against, or have sought and obtained criminal guilty pleas or deferred prosecution agreements from, financial institutions and individual employees. These types of actions by U.S. and other governments may, in the future, have significant collateral consequences for Citi, including loss of customers and business, operational loss and the inability to offer certain products or services and/or operate certain businesses. Citi may be required to accept or be subject to similar types of criminal remedies, consent orders, sanctions, substantial fines and penalties, remediation and other financial costs or other requirements in the future, including for matters or practices not yet known to Citi, any of which could materially and negatively affect Citi's businesses, business practices, financial condition or results of operations, require material changes in Citi's operations or cause Citi substantial reputational harm. Additionally, 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 (see the incorrect assumptions or estimates risk factor above). In addition, certain settlements are subject to court approval and may not be approved. Furthermore, regulators may be more likely to pursue investigations or proceedings against financial institutions, such as Citi, that have previously been the subject of other regulatory actions.For further information on Citi's legal and regulatory proceedings, see Note 30.OTHER RISKSCiti's Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.Citi's presence in the emerging markets subjects it to various risks. During 2024, emerging markets revenues accounted for approximately 28% of Citi's total revenues (based, beginning in 2024, on the IMF and FFIEC classifications, which resulted in the exclusion of certain countries that Citi previously classified as emerging markets). Emerging market risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations and strength in the U.S. dollar; central bank interest rate and other monetary policies, including the impact of sustained high interest rates in the U.S.; unemployment, recessions or weak or slowing economic growth; elevated inflation and hyperinflation; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; macroeconomic, Moreover, the severity of the remedies sought in legal and regulatory proceedings to which Citi is subject has remained elevated. For example, U.S. and certain non-U.S. governmental entities have increasingly brought criminal actions against, or have sought and obtained criminal guilty pleas or deferred prosecution agreements from, financial institutions and individual employees. These types of actions by U.S. and other governments may, in the future, have significant collateral consequences for Citi, including loss of customers and business, operational loss and the inability to offer certain products or services and/or operate certain businesses. Citi may be required to accept or be subject to similar types of criminal remedies, consent orders, sanctions, substantial fines and penalties, remediation and other financial costs or other requirements in the future, including for matters or practices not yet known to Citi, any of which could materially and negatively affect Citi's businesses, business practices, financial condition or results of operations, require material changes in Citi's operations or cause Citi substantial reputational harm. Additionally, 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 (see the incorrect assumptions or estimates risk factor above). In addition, certain settlements are subject to court approval and may not be approved. Furthermore, regulators may be more likely to pursue investigations or proceedings against financial institutions, such as Citi, that have previously been the subject of other regulatory actions. For further information on Citi's legal and regulatory proceedings, see Note 30. --- ## Modified: Retail Banking **Key changes:** - Reworded sentence: "As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Banking increased quarter-over- quarter and year-over-year, primarily driven by consumer overdraft loans." - Reworded sentence: "The delinquency-managed portfolio consists primarily of mortgages, margin lending and credit cards." - Reworded sentence: "Mexico ConsumerMexico Consumer operates in Mexico through Banamex and provides credit cards, consumer mortgages and small business and personal loans." - Added sentence: "Mexico ConsumerMexico Consumer operates in Mexico through Banamex and provides credit cards, consumer mortgages and small business and personal loans." - Added sentence: "Mexico Consumer serves a mass-market segment in Mexico and focuses on developing multiproduct relationships with customers.As of December 31, 2024, approximately 40% of Mexico Consumer EOP loans consisted of credit card loans, which generally drives the overall credit performance of Mexico Consumer, as the cards net credit losses represented approximately 60% of total Mexico Consumer net credit losses for the fourth quarter of 2024.As presented in the chart above, the fourth quarter of 2024 net credit loss rate and the 90+ days past due delinquency rate in Mexico Consumer increased quarter-over-quarter and year-over-year, primarily driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows." **Prior (2024):** USPB's Retail Banking portfolio consists primarily of consumer mortgages (including home equity) and unsecured lending products, such as small business loans and personal loans. The portfolio is generally delinquency managed, where Citi evaluates credit risk based on FICO scores, delinquencies and the value of underlying collateral. The consumer mortgages in this portfolio have historically been extended to high credit quality customers, generally with loan-to-value ratios that are less than or equal to 80% on first and second mortgages. For additional information, see "Loan-to-Value (LTV) Ratios" in Note 15. As presented in the chart above, the net credit loss rate in Retail Banking for the fourth quarter of 2023 was broadly stable quarter-over-quarter and increased year-over-year, primarily driven by the growth and seasoning of personal loans. The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and decreased year-over-year, primarily driven by lower delinquencies in U.S. mortgages. Wealth As indicated above, Wealth provides consumer mortgages, margin lending, cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and cards. As of December 31, 2023, approximately $46 billion, or 30%, of the portfolio was classifiably managed and primarily consisted of margin lending, commercial real estate, subscription credit finance and other lending programs. These classifiably managed loans are primarily evaluated for credit risk based on their internal risk rating, of which 85% is rated investment grade. While the delinquency rate in the chart above is calculated only for the delinquency-managed portfolio, the net credit loss rate is calculated using net credit losses for both the delinquency and classifiably managed portfolios.As presented in the chart above, the net credit loss rate and 90+ days past due delinquency rate in Wealth for the fourth quarter of 2023 were broadly stable quarter-over-quarter and year-over-year. The low net credit loss and the 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. Mexico ConsumerMexico Consumer operates in Mexico through Citibanamex and provides credit cards, consumer mortgages and small business and personal loans. Mexico Consumer serves a more mass-market segment in Mexico and focuses on developing multiproduct relationships with customers.As presented in the chart above, the fourth quarter of 2023 net credit loss rate in Mexico Consumer increased quarter-over-quarter and year-over-year, primarily driven by the ongoing normalization of loss rates from post-pandemic lows. The 90+ days past due delinquency rate was relatively stable quarter-over-quarter and year-over-year. For additional information on cost of credit, loan delinquency and other information for Citi's consumer loan portfolios, see each respective business's results of operations above and Note 15. risk based on their internal risk rating, of which 85% is rated investment grade. While the delinquency rate in the chart above is calculated only for the delinquency-managed portfolio, the net credit loss rate is calculated using net credit losses for both the delinquency and classifiably managed portfolios. As presented in the chart above, the net credit loss rate and 90+ days past due delinquency rate in Wealth for the fourth quarter of 2023 were broadly stable quarter-over-quarter and year-over-year. The low net credit loss and the 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. **Current (2025):** USPB's Retail Banking portfolio consists primarily of consumer mortgages (including home equity) and unsecured lending products, such as small business loans and personal loans. The portfolio is generally delinquency managed, where Citi evaluates credit risk based on FICO scores, delinquencies and the value of underlying collateral. The consumer mortgages in this portfolio have historically been extended to high credit quality customers, generally with loan-to-value ratios that are less than or equal to 80% on first and second mortgages. For additional information, see "Loan-to-Value (LTV) Ratios" in Note 15. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Banking increased quarter-over- quarter and year-over-year, primarily driven by consumer overdraft loans. The 90+ days past due delinquency rate was largely unchanged quarter-over-quarter and decreased year-over-year. The decrease was primarily driven by lower delinquencies in consumer mortgages. Wealth Wealth provides consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold businesses. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and credit cards. 81 81 81 As of December 31, 2024, approximately $43 billion, or 29%, of the portfolios were classifiably managed and primarily consisted of mortgage loans, margin loans, personal and small business loans and other lending programs. These classifiably managed loans are primarily evaluated for credit risk based on their internal risk rating, of which 72% were rated investment grade. While the 90+ days past due delinquency rates shown in the chart above were calculated only for the delinquency-managed portfolio, the net credit loss rates presented were calculated using net credit losses for both the delinquency and classifiably managed portfolios.As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Wealth was broadly stable quarter-over-quarter and year-over-year. The 90+ days past due delinquency rate increased quarter-over-quarter and year-over-year, primarily driven by consumer mortgages. The low net credit loss and the 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. Mexico ConsumerMexico Consumer operates in Mexico through Banamex and provides credit cards, consumer mortgages and small business and personal loans. Mexico Consumer serves a mass-market segment in Mexico and focuses on developing multiproduct relationships with customers.As of December 31, 2024, approximately 40% of Mexico Consumer EOP loans consisted of credit card loans, which generally drives the overall credit performance of Mexico Consumer, as the cards net credit losses represented approximately 60% of total Mexico Consumer net credit losses for the fourth quarter of 2024.As presented in the chart above, the fourth quarter of 2024 net credit loss rate and the 90+ days past due delinquency rate in Mexico Consumer increased quarter-over-quarter and year-over-year, primarily driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows. For additional details on cost of credit, loan delinquency and other information for Citi's consumer loan portfolios, see each respective business's results of operations above and Note 15.U.S. Cards FICO DistributionThe following tables present the current FICO score distributions for Citi's Branded Cards and Retail Services portfolios based on end-of-period receivables. FICO scores are updated as they become available.Branded CardsFICO distribution(1)Dec. 31, 2024Sept. 30, 2024Dec. 31, 2023≥ 74056 %55 %57 %660-73933 34 33 < 66011 11 10 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec. 31, 2024Sept. 30, 2024Dec. 31, 2023≥ 74036 %34 %36 %660-73941 42 41 < 66023 24 23 Total100 %100 %100 %(1)Excludes immaterial balances for Canada and for customers for which no FICO scores are available. The FICO distribution of both Branded Cards and Retail Services portfolios was broadly stable quarter-over-quarter and year-over-year. The FICO distribution continued to reflect the strong underlying credit quality of the portfolios. See Note 15 for additional information on FICO scores. As of December 31, 2024, approximately $43 billion, or 29%, of the portfolios were classifiably managed and primarily consisted of mortgage loans, margin loans, personal and small business loans and other lending programs. These classifiably managed loans are primarily evaluated for credit risk based on their internal risk rating, of which 72% were rated investment grade. While the 90+ days past due delinquency rates shown in the chart above were calculated only for the delinquency-managed portfolio, the net credit loss rates presented were calculated using net credit losses for both the delinquency and classifiably managed portfolios.As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Wealth was broadly stable quarter-over-quarter and year-over-year. The 90+ days past due delinquency rate increased quarter-over-quarter and year-over-year, primarily driven by consumer mortgages. The low net credit loss and the 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. Mexico ConsumerMexico Consumer operates in Mexico through Banamex and provides credit cards, consumer mortgages and small business and personal loans. Mexico Consumer serves a mass-market segment in Mexico and focuses on developing multiproduct relationships with customers.As of December 31, 2024, approximately 40% of Mexico Consumer EOP loans consisted of credit card loans, which generally drives the overall credit performance of Mexico Consumer, as the cards net credit losses represented approximately 60% of total Mexico Consumer net credit losses for the fourth quarter of 2024.As presented in the chart above, the fourth quarter of 2024 net credit loss rate and the 90+ days past due delinquency rate in Mexico Consumer increased quarter-over-quarter and year-over-year, primarily driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows. For additional details on cost of credit, loan delinquency and other information for Citi's consumer loan portfolios, see each respective business's results of operations above and Note 15. As of December 31, 2024, approximately $43 billion, or 29%, of the portfolios were classifiably managed and primarily consisted of mortgage loans, margin loans, personal and small business loans and other lending programs. These classifiably managed loans are primarily evaluated for credit risk based on their internal risk rating, of which 72% were rated investment grade. While the 90+ days past due delinquency rates shown in the chart above were calculated only for the delinquency-managed portfolio, the net credit loss rates presented were calculated using net credit losses for both the delinquency and classifiably managed portfolios. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Wealth was broadly stable quarter-over-quarter and year-over-year. The 90+ days past due delinquency rate increased quarter-over-quarter and year-over-year, primarily driven by consumer mortgages. The low net credit loss and the 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. --- ## Modified: Long-Term Debt **Key changes:** - Reworded sentence: "31, 2023Unsecured debt7.3 7.5 7.5 Non-bank benchmark debt6.9 7.0 7.0 Customer-related debt8.7 8.6 8.6 TLAC-eligible debt8.4 8.5 8.6 The WAM is calculated based on the contractual maturity of each security." - Reworded sentence: "31, 2023Non-bank(1)Benchmark debt:Senior debt$107.4 $114.0 $110.3 Subordinated debt28.7 27.9 24.9 Trust preferred1.6 1.6 1.6 Customer-related debt103.3 108.8 110.1 Local country and other(2)10.8 10.3 8.0 Total non-bank$251.8 $262.6 $254.9 BankFHLB borrowings$8.5 $11.5 $11.5 Securitizations(3)5.1 5.4 6.7 Citibank benchmark senior debt19.4 16.9 10.1 Local country and other(2)2.5 2.7 3.4 Total bank$35.5 $36.5 $31.7 Total long-term debt$287.3 $299.1 $286.6 Note: Amounts represent the current value of long-term debt on Citi's Consolidated Balance Sheet that, for certain debt instruments, includes consideration of fair value, hedging impacts and unamortized discounts and premiums.(1) Non-bank includes long-term debt issued to third parties by the parent holding company (Citigroup) and Citi's non-bank subsidiaries (including broker-dealer subsidiaries) that are consolidated into Citigroup." - Reworded sentence: "Within non-bank, certain secured financing is also included.(3) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.Citi's total long-term debt outstanding was essentially unchanged year-over-year." - Reworded sentence: "During 2024, Citi redeemed or repurchased an aggregate of $46.8 billion of its outstanding long-term debt." - Reworded sentence: "31, 2023Non-bank(1)Benchmark debt:Senior debt$107.4 $114.0 $110.3 Subordinated debt28.7 27.9 24.9 Trust preferred1.6 1.6 1.6 Customer-related debt103.3 108.8 110.1 Local country and other(2)10.8 10.3 8.0 Total non-bank$251.8 $262.6 $254.9 BankFHLB borrowings$8.5 $11.5 $11.5 Securitizations(3)5.1 5.4 6.7 Citibank benchmark senior debt19.4 16.9 10.1 Local country and other(2)2.5 2.7 3.4 Total bank$35.5 $36.5 $31.7 Total long-term debt$287.3 $299.1 $286.6" **Prior (2024):** 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. Weighted-Average Maturity (WAM) The following table presents Citigroup and its affiliates' (including Citibank) WAM of unsecured long-term debt issued with a remaining life greater than one year: WAM in yearsDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Unsecured debt7.5 7.4 7.6 Non-bank benchmark debt7.0 7.1 7.4 Customer-related debt8.6 8.2 8.1 TLAC-eligible debt8.6 8.7 9.0 The WAM is calculated based on the contractual maturity of each security. For securities that are redeemable prior to maturity where the option is not held by the issuer, the WAM is calculated based on the earliest date an option becomes exercisable. Long-Term Debt OutstandingThe following table presents Citi's end-of-period total long-term debt outstanding for each of the dates indicated:In billions of dollarsDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Non-bank(1)Benchmark debt:Senior debt$110.3 $110.3 $117.5 Subordinated debt24.9 24.5 22.5 Trust preferred1.6 1.6 1.6 Customer-related debt110.1 106.4 101.1 Local country and other(2)8.0 8.5 7.8 Total non-bank$254.9 $251.3 $250.5 BankFHLB borrowings$11.5 $8.5 $7.3 Securitizations(3)6.7 5.2 7.6 Citibank benchmark senior debt10.1 7.6 2.6 Local country and other(2)3.4 3.2 3.6 Total bank$31.7 $24.5 $21.1 Total long-term debt$286.6 $275.8 $271.6 Note: Amounts represent the current value of long-term debt on Citi's Consolidated Balance Sheet that, for certain debt instruments, includes consideration of fair value, hedging impacts and unamortized discounts and premiums.(1) Non-bank includes long-term debt issued to third parties by the parent holding company (Citigroup) and Citi's non-bank subsidiaries (including broker-dealer subsidiaries) that are consolidated into Citigroup. As of December 31, 2023, non-bank included $92.6 billion of long-term debt issued by Citi's broker-dealer and other subsidiaries that are consolidated into Citigroup. Certain Citigroup consolidated hedging activities are also included in this line.(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.(3) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.Citi's total long-term debt outstanding increased 6% year-over-year, largely driven by issuance of customer-related debt at the non-bank entities, as well as increased senior benchmark debt and FHLB borrowings at the bank. The increase was partially offset by a decline in senior benchmark debt at the non-bank entities. Sequentially, long-term debt outstanding also increased 4%, largely driven by an increase in customer-related debt at the non-bank entities and increased FHLB borrowings and benchmark senior debt at the bank.As part of its liability management, Citi has considered, and may continue to consider, opportunities to redeem or repurchase its long-term debt pursuant to open market purchases, tender offers or other means. Such redemptions and repurchases help reduce Citi's overall funding costs. During 2023, Citi redeemed or repurchased an aggregate of approximately $32.0 billion of its outstanding long-term debt. Long-Term Debt Outstanding The following table presents Citi's end-of-period total long-term debt outstanding for each of the dates indicated: In billions of dollarsDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Non-bank(1)Benchmark debt:Senior debt$110.3 $110.3 $117.5 Subordinated debt24.9 24.5 22.5 Trust preferred1.6 1.6 1.6 Customer-related debt110.1 106.4 101.1 Local country and other(2)8.0 8.5 7.8 Total non-bank$254.9 $251.3 $250.5 BankFHLB borrowings$11.5 $8.5 $7.3 Securitizations(3)6.7 5.2 7.6 Citibank benchmark senior debt10.1 7.6 2.6 Local country and other(2)3.4 3.2 3.6 Total bank$31.7 $24.5 $21.1 Total long-term debt$286.6 $275.8 $271.6 **Current (2025):** 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. Weighted-Average Maturity (WAM) The following table presents Citigroup and its affiliates' (including Citibank) WAM of unsecured long-term debt issued with a remaining life greater than one year: WAM in yearsDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Unsecured debt7.3 7.5 7.5 Non-bank benchmark debt6.9 7.0 7.0 Customer-related debt8.7 8.6 8.6 TLAC-eligible debt8.4 8.5 8.6 The WAM is calculated based on the contractual maturity of each security. For securities that are redeemable prior to maturity where the option is not held by the issuer, the WAM is calculated based on the earliest date an option becomes exercisable. Long-Term Debt OutstandingThe following table presents Citi's end-of-period total long-term debt outstanding for each of the dates indicated:In billions of dollarsDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Non-bank(1)Benchmark debt:Senior debt$107.4 $114.0 $110.3 Subordinated debt28.7 27.9 24.9 Trust preferred1.6 1.6 1.6 Customer-related debt103.3 108.8 110.1 Local country and other(2)10.8 10.3 8.0 Total non-bank$251.8 $262.6 $254.9 BankFHLB borrowings$8.5 $11.5 $11.5 Securitizations(3)5.1 5.4 6.7 Citibank benchmark senior debt19.4 16.9 10.1 Local country and other(2)2.5 2.7 3.4 Total bank$35.5 $36.5 $31.7 Total long-term debt$287.3 $299.1 $286.6 Note: Amounts represent the current value of long-term debt on Citi's Consolidated Balance Sheet that, for certain debt instruments, includes consideration of fair value, hedging impacts and unamortized discounts and premiums.(1) Non-bank includes long-term debt issued to third parties by the parent holding company (Citigroup) and Citi's non-bank subsidiaries (including broker-dealer subsidiaries) that are consolidated into Citigroup. As of December 31, 2024, non-bank included $87.8 billion of long-term debt issued by Citi's broker-dealer and other subsidiaries that are consolidated into Citigroup. Certain Citigroup consolidated hedging activities are also included in this line.(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.(3) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.Citi's total long-term debt outstanding was essentially unchanged year-over-year. Sequentially, long-term debt outstanding decreased 4%, largely related to net maturities of senior benchmark debt at the bank and non-bank entities and customer-related debt issuances at the non-bank entities. As part of its liability management, Citi has considered, and may continue to consider, opportunities to redeem or repurchase its long-term debt pursuant to open market purchases, tender offers or other means. Such redemptions and repurchases help reduce Citi's overall funding costs. During 2024, Citi redeemed or repurchased an aggregate of $46.8 billion of its outstanding long-term debt. Long-Term Debt Outstanding The following table presents Citi's end-of-period total long-term debt outstanding for each of the dates indicated: In billions of dollarsDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Non-bank(1)Benchmark debt:Senior debt$107.4 $114.0 $110.3 Subordinated debt28.7 27.9 24.9 Trust preferred1.6 1.6 1.6 Customer-related debt103.3 108.8 110.1 Local country and other(2)10.8 10.3 8.0 Total non-bank$251.8 $262.6 $254.9 BankFHLB borrowings$8.5 $11.5 $11.5 Securitizations(3)5.1 5.4 6.7 Citibank benchmark senior debt19.4 16.9 10.1 Local country and other(2)2.5 2.7 3.4 Total bank$35.5 $36.5 $31.7 Total long-term debt$287.3 $299.1 $286.6 --- ## Modified: Citi Faces Increased Competitive Challenges, Including from Financial Services and Other Companies and Emerging Technologies. **Key changes:** - Reworded sentence: "Certain competitors may be subject to different and, in some cases, less stringent legal, regulatory and supervisory requirements, whether due to size, jurisdiction, entity type or other factors, placing Citi at a competitive disadvantage." - Reworded sentence: "and globally that have grown rapidly over the last several years or have introduced new products and services." - Reworded sentence: "Clients and investors have shown increased interest in these technologies, prompting financial services firms and other market participants to develop related products and services." - Reworded sentence: "For example, the use or development of emerging technologies, such as AI or digital assets, without sufficient controls, governance and risk management may result in increased risks across various risk categories (for additional information, see the operational processes and systems risk factor below).As another example, instant and 24/7 payments products could be accompanied by challenges to forecasting and managing liquidity, as well as increased operational and compliance risks." - Reworded sentence: "Citi's operations must also comply with complex and evolving laws, regulations and heightened regulatory expectations in the jurisdictions in which it operates (see the implementation and interpretation of regulatory changes and legal proceedings risk factors below)." **Prior (2024):** 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, private credit and 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. Certain competitors may be subject to different and, in some cases, less stringent legal and regulatory requirements, whether due to size, jurisdiction, entity type or other factors, placing Citi at a competitive disadvantage. For example, Citi competes with other financial services companies in the U.S. and globally that have grown rapidly over the last several years or have developed and introduced new products and services. Potential mergers and acquisitions involving traditional financial services companies such as regional banks or credit card issuers, as well as networks and merchant acquirers, may also increase competition and impact Citi's ability to offer competitive pricing and rewards. Non-traditional financial services firms, such as private credit and financial technology companies, are less regulated and continue to expand their offerings of services traditionally provided by financial institutions. The growth of certain of these competitors has increased market and counterparty credit risks, particularly in a more challenging macroeconomic environment (see the risk factor on credit and concentrations of risk below). In addition, emerging technologies have the potential to intensify competition and accelerate disruption in the financial services industry. For example, despite difficulties and turmoil faced by the digital asset market in recent years, clients and investors have exhibited a sustained interest in digital assets. Financial services firms and other market participants have begun to offer services related to those assets. Citi may not be able to provide the same or similar services for legal or regulatory reasons, which may be exacerbated by rapidly evolving and conflicting regulatory requirements, and due to increased compliance and other risks. Further, 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. Increased competition and emerging technologies have required and could require Citi to change or adapt its products and services, as well as invest in and develop related infrastructure, 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, failure to strategically embrace the potential of artificial intelligence (AI) may result in a competitive disadvantage to Citi. At the same time, as a new technology, use of AI without sufficient controls, governance and risk management may result in increased risks across all of Citi's risk categories. As another example, instant and 24x7 payments products could be accompanied by challenges to forecasting and managing liquidity, as well as increased operational and compliance risks. Moreover, Citi relies on third parties to support certain of its product and service offerings, which may put Citi at a disadvantage to competitors who may directly offer a broader array of products and services. Also, Citi's businesses, results of operations and reputation may suffer if any third party is unable to provide adequate support for such product and service offerings, whether due to operational incidents or otherwise (see the operational processes and systems, cybersecurity and emerging markets risk factors below).To the extent that Citi is not able to compete effectively with financial services companies, including private credit and financial technology companies, and non-financial services 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 factors above and "Supervision, Regulation and Other - Competition" below.OPERATIONAL RISKSA Failure or Disruption of Citi's Operational Processes or Systems Could Negatively Impact Its Reputation, Customers, Clients, Businesses or Results of Operations and Financial Condition.Citi's global operations rely heavily on its technology systems and infrastructure, including the accurate, timely and secure processing, management, storage and transmission of data, including confidential transactions, and other information, as well as the monitoring of a substantial amount of data and complex transactions in real time. Citi obtains and stores an extensive amount of personal and client-specific information for its consumer and institutional customers and clients, and must accurately record and reflect their account transactions. Citi's operations must also comply with complex and evolving laws, regulations and heightened regulatory expectations in the countries in which it operates (see the implementation and interpretation of regulatory changes and legal proceedings risk factors below). With the evolving proliferation of new technologies and the increasing use of the internet, mobile devices and cloud services to conduct financial transactions and customers' and clients' increasing use of online banking and trading systems and other platforms, large global financial institutions such as Citi have been, and will continue to be, subject to an ever-increasing risk of operational loss, failure or disruption. 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, failure to strategically embrace the potential of artificial intelligence (AI) may result in a competitive disadvantage to Citi. At the same time, as a new technology, use of AI without sufficient controls, governance and risk management may result in increased risks across all of Citi's risk categories. As another example, instant and 24x7 payments products could be accompanied by challenges to forecasting and managing liquidity, as well as increased operational and compliance risks. Moreover, Citi relies on third parties to support certain of its product and service offerings, which may put Citi at a disadvantage to competitors who may directly offer a broader array of products and services. Also, Citi's businesses, results of operations and reputation may suffer if any third party is unable to provide adequate support for such product and service offerings, whether due to operational incidents or otherwise (see the operational processes and systems, cybersecurity and emerging markets risk factors below). To the extent that Citi is not able to compete effectively with financial services companies, including private credit and financial technology companies, and non-financial services 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 factors above and "Supervision, Regulation and Other - Competition" below. **Current (2025):** 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, private credit and 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. Certain competitors may be subject to different and, in some cases, less stringent legal, regulatory and supervisory requirements, whether due to size, jurisdiction, entity type or other factors, placing Citi at a competitive disadvantage. Moreover, new or rapidly developing technologies with the potential to have significant economic or social effects (emerging technologies) also pose competitive challenges for Citi. For example, Citi competes with other financial services companies in the U.S. and globally that have grown rapidly over the last several years or have introduced new products and services. Potential mergers and acquisitions involving traditional financial services companies, such as regional banks or credit card issuers, as well as networks and merchant acquirers, may also increase competition and impact Citi's ability to offer competitive pricing and rewards. Non-traditional financial services firms, such as private credit, financial technology and digital asset companies, are less regulated and supervised and continue to expand their offerings of services traditionally provided by financial institutions. In addition, emerging technologies have the potential to intensify competition and accelerate disruption in the financial services industry. Clients and investors have shown increased interest in these technologies, prompting financial services firms and other market participants to develop related products and services. As blockchain and digital assets continue to evolve, customer demand for enhanced offerings may increase. Failure to strategically embrace the potential of emerging technologies may result in a competitive disadvantage to Citi. The new U.S. administration has stated its support for the growth and use of digital assets and 55 55 55 blockchain technology, including a more favorable regulatory approach to crypto assets. Citi may not be able to provide the same or similar products and services for legal or regulatory reasons, which may be exacerbated by rapidly evolving and conflicting regulatory requirements, as well as increased compliance and other risks. Further, the introduction of mobile platforms and emerging technologies, such as artificial intelligence (AI) and digital assets, and changes in the payments space (e.g., instant and 24/7 payments) are accelerating, and, as a result, certain of Citi's products and services could become less competitive. Increased competition and emerging technologies have required and could require Citi to change or adapt its products and services, as well as invest in and develop related infrastructure, 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, the use or development of emerging technologies, such as AI or digital assets, without sufficient controls, governance and risk management may result in increased risks across various risk categories (for additional information, see the operational processes and systems risk factor below).As another example, instant and 24/7 payments products could be accompanied by challenges to forecasting and managing liquidity, as well as increased operational and compliance risks. Additionally, the growth of certain competitors has increased market and counterparty credit risks, with such risks particularly heightened in the case of a challenging macroeconomic environment (see the risk factor on credit and concentrations of risk below).Moreover, Citi relies on third parties to support certain of its product and service offerings, which may put Citi at a disadvantage to competitors who may directly offer a broader array of products and services. Also, Citi's businesses, results of operations and reputation may suffer if any third party is unable to provide adequate support for such product and service offerings, whether due to operational incidents or otherwise (see the operational processes and systems, cybersecurity and emerging markets risk factors below).To the extent that Citi is not able to compete effectively with other financial services companies, including private credit and financial technology companies, and non-financial services firms, or adequately assess the competitive landscape, 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 employees risk factors above and "Supervision, Regulation and Other - Competition" below.OPERATIONAL RISKSA Failure or Disruption of Citi's Operational Processes or Systems Could Negatively Impact Its Reputation, Customers, Clients, Businesses or Results of Operations and Financial Condition.Citi's global operations rely heavily on its technology systems and infrastructure, including the accurate, complete, timely and secure processing, management, storage and transmission of data, including confidential transactions, and other information, as well as the monitoring of a substantial amount of data and complex transactions in real time. Citi obtains and stores an extensive amount of personal and client-specific information for its consumer and institutional customers and clients, and must accurately record and reflect their account transactions. Citi's operations must also comply with complex and evolving laws, regulations and heightened regulatory expectations in the jurisdictions in which it operates (see the implementation and interpretation of regulatory changes and legal proceedings risk factors below). With the proliferation of emerging technologies, including AI, and the use of the internet, mobile devices and cloud services to conduct financial transactions, and customers' and clients' increasing use of online banking and trading systems and other platforms, large global financial institutions such as Citi have been, and will continue to be, subject to an ever-increasing risk of operational loss, failure or disruption.Citi has been working with AI and machine learning for a period of time and has more recently begun using Generative AI, a type of artificial intelligence that uses generative models to create text and other content. Generative AI tools are available to employees within parts of the Company, and in the future Citi may more broadly use, develop and incorporate Generative AI within its technology platform and services, systems and its businesses and functions. While Citi has policies which govern the use of emerging technologies, ineffective, inadequate or faulty Generative AI development or deployment practices by Citi or third parties could result in unintended consequences, such as AI algorithms that produce inaccurate or incomplete output or output based on biased, incomplete and/or inaccurate datasets, or cause other issues, concerns or deficiencies. Moreover, the use of increasingly sophisticated AI technologies by malicious actors and others has increased the risk of fraud, including identity theft and bypassing of verification controls, and failure to effectively manage such risks could result in misappropriation of funds, unauthorized transactions, exposure of sensitive client or Company information, reputational harm and increased litigation and regulatory risk. In addition, compliance with new or changing laws, regulations or industry standards relating to AI may impose additional operational risks and costs.Although Citi has continued to upgrade its technology, including systems to automate processes and gain efficiencies, operational incidents are unpredictable and can arise from numerous sources, not all of which are fully within Citi's control. These include, among others, operational or execution failures or deficiencies by third parties and third parties that provide products or services to Citi (e.g., cloud service blockchain technology, including a more favorable regulatory approach to crypto assets. Citi may not be able to provide the same or similar products and services for legal or regulatory reasons, which may be exacerbated by rapidly evolving and conflicting regulatory requirements, as well as increased compliance and other risks. Further, the introduction of mobile platforms and emerging technologies, such as artificial intelligence (AI) and digital assets, and changes in the payments space (e.g., instant and 24/7 payments) are accelerating, and, as a result, certain of Citi's products and services could become less competitive. Increased competition and emerging technologies have required and could require Citi to change or adapt its products and services, as well as invest in and develop related infrastructure, 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, the use or development of emerging technologies, such as AI or digital assets, without sufficient controls, governance and risk management may result in increased risks across various risk categories (for additional information, see the operational processes and systems risk factor below).As another example, instant and 24/7 payments products could be accompanied by challenges to forecasting and managing liquidity, as well as increased operational and compliance risks. Additionally, the growth of certain competitors has increased market and counterparty credit risks, with such risks particularly heightened in the case of a challenging macroeconomic environment (see the risk factor on credit and concentrations of risk below).Moreover, Citi relies on third parties to support certain of its product and service offerings, which may put Citi at a disadvantage to competitors who may directly offer a broader array of products and services. Also, Citi's businesses, results of operations and reputation may suffer if any third party is unable to provide adequate support for such product and service offerings, whether due to operational incidents or otherwise (see the operational processes and systems, cybersecurity and emerging markets risk factors below).To the extent that Citi is not able to compete effectively with other financial services companies, including private credit and financial technology companies, and non-financial services firms, or adequately assess the competitive landscape, 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 employees risk factors above and "Supervision, Regulation and Other - Competition" below. blockchain technology, including a more favorable regulatory approach to crypto assets. Citi may not be able to provide the same or similar products and services for legal or regulatory reasons, which may be exacerbated by rapidly evolving and conflicting regulatory requirements, as well as increased compliance and other risks. Further, the introduction of mobile platforms and emerging technologies, such as artificial intelligence (AI) and digital assets, and changes in the payments space (e.g., instant and 24/7 payments) are accelerating, and, as a result, certain of Citi's products and services could become less competitive. Increased competition and emerging technologies have required and could require Citi to change or adapt its products and services, as well as invest in and develop related infrastructure, 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, the use or development of emerging technologies, such as AI or digital assets, without sufficient controls, governance and risk management may result in increased risks across various risk categories (for additional information, see the operational processes and systems risk factor below). As another example, instant and 24/7 payments products could be accompanied by challenges to forecasting and managing liquidity, as well as increased operational and compliance risks. Additionally, the growth of certain competitors has increased market and counterparty credit risks, with such risks particularly heightened in the case of a challenging macroeconomic environment (see the risk factor on credit and concentrations of risk below). Moreover, Citi relies on third parties to support certain of its product and service offerings, which may put Citi at a disadvantage to competitors who may directly offer a broader array of products and services. Also, Citi's businesses, results of operations and reputation may suffer if any third party is unable to provide adequate support for such product and service offerings, whether due to operational incidents or otherwise (see the operational processes and systems, cybersecurity and emerging markets risk factors below). To the extent that Citi is not able to compete effectively with other financial services companies, including private credit and financial technology companies, and non-financial services firms, or adequately assess the competitive landscape, 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 employees risk factors above and "Supervision, Regulation and Other - Competition" below. OPERATIONAL RISKSA Failure or Disruption of Citi's Operational Processes or Systems Could Negatively Impact Its Reputation, Customers, Clients, Businesses or Results of Operations and Financial Condition.Citi's global operations rely heavily on its technology systems and infrastructure, including the accurate, complete, timely and secure processing, management, storage and transmission of data, including confidential transactions, and other information, as well as the monitoring of a substantial amount of data and complex transactions in real time. Citi obtains and stores an extensive amount of personal and client-specific information for its consumer and institutional customers and clients, and must accurately record and reflect their account transactions. Citi's operations must also comply with complex and evolving laws, regulations and heightened regulatory expectations in the jurisdictions in which it operates (see the implementation and interpretation of regulatory changes and legal proceedings risk factors below). With the proliferation of emerging technologies, including AI, and the use of the internet, mobile devices and cloud services to conduct financial transactions, and customers' and clients' increasing use of online banking and trading systems and other platforms, large global financial institutions such as Citi have been, and will continue to be, subject to an ever-increasing risk of operational loss, failure or disruption.Citi has been working with AI and machine learning for a period of time and has more recently begun using Generative AI, a type of artificial intelligence that uses generative models to create text and other content. Generative AI tools are available to employees within parts of the Company, and in the future Citi may more broadly use, develop and incorporate Generative AI within its technology platform and services, systems and its businesses and functions. While Citi has policies which govern the use of emerging technologies, ineffective, inadequate or faulty Generative AI development or deployment practices by Citi or third parties could result in unintended consequences, such as AI algorithms that produce inaccurate or incomplete output or output based on biased, incomplete and/or inaccurate datasets, or cause other issues, concerns or deficiencies. Moreover, the use of increasingly sophisticated AI technologies by malicious actors and others has increased the risk of fraud, including identity theft and bypassing of verification controls, and failure to effectively manage such risks could result in misappropriation of funds, unauthorized transactions, exposure of sensitive client or Company information, reputational harm and increased litigation and regulatory risk. In addition, compliance with new or changing laws, regulations or industry standards relating to AI may impose additional operational risks and costs.Although Citi has continued to upgrade its technology, including systems to automate processes and gain efficiencies, operational incidents are unpredictable and can arise from numerous sources, not all of which are fully within Citi's control. These include, among others, operational or execution failures or deficiencies by third parties and third parties that provide products or services to Citi (e.g., cloud service --- ## Modified: Scenario Analysis **Key changes:** - Reworded sentence: "The following table presents the estimated impact to Citi's net interest income and AOCI under eight different interest rate scenarios for the U.S." - Reworded sentence: "The following table presents the estimated impact to Citi's net interest income and AOCI under eight different interest rate scenarios for the U.S." - Reworded sentence: "The following table presents the estimated impact to Citi's net interest income and AOCI under eight different interest rate scenarios for the U.S." - Reworded sentence: "In millions of dollars, except as otherwise notedScenario 1Scenario 2Scenario 3Scenario 4Scenario 5Scenario 6Scenario 7Scenario 8Overnight rate change (bps)100 100 - - (100)(100)200 (200)10-year rate change (bps)100 - 100 (100) - (100)200 (200)Interest rate exposureU.S." - Reworded sentence: "The interest rate exposure in the table above assumes no change in deposit size or mix from the baseline forecast included in the different interest rate scenarios presented." **Prior (2024):** The following table presents the estimated impact to Citi's net interest income, AOCI and CET1 Capital ratio (on a fully implemented basis) under six different scenarios of changes in interest rates for the U.S. dollar and all other currencies in which Citi has invested capital as of December 31, 2023. 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 interest rate scenarios are also impacted by convexity related to mortgage products and deposit pricing. The following table presents the estimated impact to Citi's net interest income, AOCI and CET1 Capital ratio (on a fully implemented basis) under six different scenarios of changes in interest rates for the U.S. dollar and all other currencies in which Citi has invested capital as of December 31, 2023. 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 interest rate scenarios are also impacted by convexity related to mortgage products and deposit pricing. The following table presents the estimated impact to Citi's net interest income, AOCI and CET1 Capital ratio (on a fully implemented basis) under six different scenarios of changes in interest rates for the U.S. dollar and all other currencies in which Citi has invested capital as of December 31, 2023. 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 interest rate scenarios are also impacted by convexity related to mortgage products and deposit pricing. In millions of dollars, except as otherwise notedScenario 1Scenario 2Scenario 3Scenario 4Scenario 5Scenario 6Overnight rate change (bps)100 100 - - (100)(100)10-year rate change (bps)100 - 100 (100) - (100)Interest rate exposureU.S. dollar$(33)$(112)$109 $(79)$(343)$(448)All other currencies(1)1,219 1,039 183 (180)(936)(1,104)Total$1,186 $927 $292 $(259)$(1,279)$(1,552)Estimated initial impact to AOCI (after-tax)(2)$(829)$(1,157)$296 $(592)$1,147 $538 Estimated initial impact to CET1 Capital ratio (bps) from AOCI scenario(12)(10)(3)1 10 11 All other currencies(1) Estimated initial impact to AOCI (after-tax)(2) Estimated initial impact to CET1 Capital ratio (bps) from AOCI scenario 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. The interest rate exposure in the table above assumes no change in deposit size or mix from the baseline forecast included in the different interest scenarios presented. As a result, in higher interest rate scenarios, customer activity resulting in a shift from non-interest-bearing and low interest rate deposit products to higher-yielding deposits would reduce the expected benefit to net interest income. Conversely, in lower interest rate scenarios, customer activity resulting in a shift from higher-yielding deposits to non-interest-bearing and low interest rate deposit products would reduce the expected decrease to net interest income. (1)Scenario 1 includes the impact from the following top six non-U.S. dollar currencies, which represents approximately 50% of the total non-U.S. dollar currency impact: approximately $0.2 billion from the Japanese yen, and approximately $0.1 billion each from the Indian rupee, Singapore dollar, Korean won, Swiss franc and Chinese yuan. These impacts per currency are generally in the same direction (estimated positive impact in the +100 bps shock scenario) and not offsetting. (2)Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension liability adjustments. As presented in the table above, the estimated impact to Citi's net interest income is larger under Scenario 2 than Scenario 3, as Citi's Banking Book has relatively higher interest rate exposure to the short end of the yield curve. For U.S. dollars, exposure to downward rate shocks is larger in magnitude than to upward rate shocks. This is because of the lower benefit to net interest income from Citi's deposit base at higher rate levels, as well as the prepayment effects on mortgage loans and mortgage-backed securities. For other non-U.S. dollar currencies, exposure to downward rate shocks is smaller in magnitude as a result of Citi's flooring assumption, given low rate levels for certain non-U.S. dollar currencies.The magnitude of the impact to AOCI is greater under Scenario 2 compared to Scenario 3. This is because the combination of changes to Citi's investment portfolio, partially offset by changes related to Citi's pension liabilities, results in a net position that is more sensitive to rates at shorter- and intermediate-term maturities. As presented in the table above, the estimated impact to Citi's net interest income is larger under Scenario 2 than Scenario 3, as Citi's Banking Book has relatively higher interest rate exposure to the short end of the yield curve. For U.S. dollars, exposure to downward rate shocks is larger in magnitude than to upward rate shocks. This is because of the lower benefit to net interest income from Citi's deposit base at higher rate levels, as well as the prepayment effects on mortgage loans and mortgage-backed securities. For other non-U.S. dollar currencies, exposure to downward rate shocks is smaller in magnitude as a result of Citi's flooring assumption, given low rate levels for certain non-U.S. dollar currencies.The magnitude of the impact to AOCI is greater under Scenario 2 compared to Scenario 3. This is because the combination of changes to Citi's investment portfolio, partially offset by changes related to Citi's pension liabilities, results in a net position that is more sensitive to rates at shorter- and intermediate-term maturities. As presented in the table above, the estimated impact to Citi's net interest income is larger under Scenario 2 than Scenario 3, as Citi's Banking Book has relatively higher interest rate exposure to the short end of the yield curve. For U.S. dollars, exposure to downward rate shocks is larger in magnitude than to upward rate shocks. This is because of the lower benefit to net interest income from Citi's deposit base at higher rate levels, as well as the prepayment effects on mortgage loans and mortgage-backed securities. For other non-U.S. dollar currencies, exposure to downward rate shocks is smaller in magnitude as a result of Citi's flooring assumption, given low rate levels for certain non-U.S. dollar currencies. The magnitude of the impact to AOCI is greater under Scenario 2 compared to Scenario 3. This is because the combination of changes to Citi's investment portfolio, partially offset by changes related to Citi's pension liabilities, results in a net position that is more sensitive to rates at shorter- and intermediate-term maturities. 102 102 102 Changes in Foreign Exchange Rates - Impacts on AOCI and CapitalAs of December 31, 2023, Citi estimates that an unanticipated parallel instantaneous 5% appreciation of the U.S. dollar against all of the other currencies in which Citi has invested capital could reduce Citi's tangible common equity (TCE) by approximately $1.7 billion, or 1.0%, as a result of changes to Citi's CTA in AOCI, net of hedges. This impact would be primarily due to changes in the value of the Mexican peso, Euro, Singapore dollar and Indian rupee.This impact is also before any mitigating actions Citi may take, including ongoing management of its foreign currency translation exposure. Specifically, as currency movements change the value of Citi's net investments in foreign currency-denominated capital, these movements also change the value of Citi's risk-weighted assets denominated in those currencies. This, coupled with Citi's foreign currency hedging strategies, such as foreign currency borrowings, foreign currency forwards and other currency hedging instruments, lessens the impact of foreign currency movements on Citi's CET1 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 compared to an unanticipated parallel shock, as described above.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 CET1 Capital ratio, are presented in the table below. See Note 21 for additional information on the changes in AOCI. Changes in Foreign Exchange Rates - Impacts on AOCI and CapitalAs of December 31, 2023, Citi estimates that an unanticipated parallel instantaneous 5% appreciation of the U.S. dollar against all of the other currencies in which Citi has invested capital could reduce Citi's tangible common equity (TCE) by approximately $1.7 billion, or 1.0%, as a result of changes to Citi's CTA in AOCI, net of hedges. This impact would be primarily due to changes in the value of the Mexican peso, Euro, Singapore dollar and Indian rupee.This impact is also before any mitigating actions Citi may take, including ongoing management of its foreign currency translation exposure. Specifically, as currency movements change the value of Citi's net investments in foreign currency-denominated capital, these movements also change the value of Citi's risk-weighted assets denominated in those currencies. **Current (2025):** The following table presents the estimated impact to Citi's net interest income and AOCI under eight different interest rate scenarios for the U.S. dollar and all other currencies in which Citi has invested capital as of December 31, 2024. The 100 bps and 200 bps downward rate scenarios potentially may be 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 interest rate scenarios are also impacted by convexity related to mortgage products and deposit pricing. The following table presents the estimated impact to Citi's net interest income and AOCI under eight different interest rate scenarios for the U.S. dollar and all other currencies in which Citi has invested capital as of December 31, 2024. The 100 bps and 200 bps downward rate scenarios potentially may be 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 interest rate scenarios are also impacted by convexity related to mortgage products and deposit pricing. The following table presents the estimated impact to Citi's net interest income and AOCI under eight different interest rate scenarios for the U.S. dollar and all other currencies in which Citi has invested capital as of December 31, 2024. The 100 bps and 200 bps downward rate scenarios potentially may be 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 interest rate scenarios are also impacted by convexity related to mortgage products and deposit pricing. In millions of dollars, except as otherwise notedScenario 1Scenario 2Scenario 3Scenario 4Scenario 5Scenario 6Scenario 7Scenario 8Overnight rate change (bps)100 100 - - (100)(100)200 (200)10-year rate change (bps)100 - 100 (100) - (100)200 (200)Interest rate exposureU.S. dollar$(93)$(302)$240 $(182)$(456)$(661)$(144)$(1,261)All other currencies(1)1,068 898 171 (170)(836)(997)2,107 (1,954)Total$975 $596 $411 $(352)$(1,292)$(1,658)$1,963 $(3,215)Estimated initial impact to AOCI (after-tax)(2)$(1,111)$(1,239)$(89)$(387)$1,242 $880 $(2,336)$1,388 All other currencies(1) Estimated initial impact to AOCI (after-tax)(2) 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. The interest rate exposure in the table above assumes no change in deposit size or mix from the baseline forecast included in the different interest rate scenarios presented. As a result, in higher interest rate scenarios, customer activity resulting in a shift from non-interest-bearing and low interest rate deposit products to higher-yielding deposits would reduce the expected benefit to net interest income. Conversely, in lower interest rate scenarios, customer activity resulting in a shift from higher-yielding deposits to non-interest-bearing and low interest rate deposit products would reduce the expected decrease to net interest income. (1)The Scenario 1 impact of $1,068 million consists of the following top five non-U.S. dollar currencies as of December 31, 2024 by absolute size: approximately $(0.2) billion from the euro, $0.2 billion from the British pound sterling, and approximately $0.1 billion each from the Chinese yuan, Swiss franc and Indian rupee. The remaining balance is spread across more than 30 additional currencies. (2)Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension liability adjustments. As presented in the table above, the estimated impact to Citi's net interest income is larger in the short end compared to the long end as Citi's Banking Book has relatively higher interest rate exposure to the short end of the yield curve. For the U.S. dollar, exposure to downward rate shocks is larger in magnitude than to upward rate shocks. This is because of the lower benefit to net interest income from Citi's deposit base at higher rate levels, as well as the prepayment effects on mortgage loans and mortgage-backed securities.The magnitude of the impact to AOCI is greater in the short end compared to the long end. This is because Citi's investment portfolio and pension liabilities are more sensitive to rates at shorter- and intermediate-term maturities. As presented in the table above, the estimated impact to Citi's net interest income is larger in the short end compared to the long end as Citi's Banking Book has relatively higher interest rate exposure to the short end of the yield curve. For the U.S. dollar, exposure to downward rate shocks is larger in magnitude than to upward rate shocks. This is because of the lower benefit to net interest income from Citi's deposit base at higher rate levels, as well as the prepayment effects on mortgage loans and mortgage-backed securities.The magnitude of the impact to AOCI is greater in the short end compared to the long end. This is because Citi's investment portfolio and pension liabilities are more sensitive to rates at shorter- and intermediate-term maturities. As presented in the table above, the estimated impact to Citi's net interest income is larger in the short end compared to the long end as Citi's Banking Book has relatively higher interest rate exposure to the short end of the yield curve. For the U.S. dollar, exposure to downward rate shocks is larger in magnitude than to upward rate shocks. This is because of the lower benefit to net interest income from Citi's deposit base at higher rate levels, as well as the prepayment effects on mortgage loans and mortgage-backed securities. The magnitude of the impact to AOCI is greater in the short end compared to the long end. This is because Citi's investment portfolio and pension liabilities are more sensitive to rates at shorter- and intermediate-term maturities. 104 104 104 Changes in Foreign Exchange Rates - Impacts on AOCI and CapitalAs of December 31, 2024, 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%, as a result of changes to Citi's CTA in AOCI, net of hedges. This reduction in the TCE would be primarily driven by depreciation in the value of the euro, Mexican peso and Indian rupee.This reduction in the TCE does not reflect any mitigating actions Citi may take, including ongoing management of its foreign currency translation exposure. TCE is used as a simplified metric to manage CET1 capital ratio volatility. 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 RWA denominated in those same 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 CET1 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 compared to an unanticipated parallel shock, as described above.The effect of Citi's ongoing management strategies with respect to quarterly changes in foreign exchange rates (versus the U.S. dollar), and the quarterly impact of these changes on Citi's TCE and CET1 Capital ratio, are presented in the table below. See Note 21 for additional information on the changes in AOCI. Changes in Foreign Exchange Rates - Impacts on AOCI and CapitalAs of December 31, 2024, 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%, as a result of changes to Citi's CTA in AOCI, net of hedges. This reduction in the TCE would be primarily driven by depreciation in the value of the euro, Mexican peso and Indian rupee.This reduction in the TCE does not reflect any mitigating actions Citi may take, including ongoing management of its foreign currency translation exposure. TCE is used as a simplified metric to manage CET1 capital ratio volatility. 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 RWA --- ## Modified: Details of Credit Loss Experience **Key changes:** - Reworded sentence: "In millions of dollars20242023202220212020Allowance for credit losses on loans (ACLL) at beginning of year$18,145 $16,974 $16,455 $24,956 $12,783 Adjustments to opening balance:Financial instruments - TDRs and vintage disclosures(1) - (352) - - - Financial instruments - credit losses (CECL)(2) - - - - 4,201 Variable post-charge-off third-party collection costs - - - - (443)Adjusted ACLL at beginning of year$18,145 $16,622 $16,455 $24,956 $16,541 Provision for credit losses on loans (PCLL)Consumer$9,459 $7,665 $4,128 $(1,159)$12,222 Corporate267 121 617 (1,944)3,700 Total$9,726 $7,786 $4,745 $(3,103)$15,922 Gross credit losses on loansConsumerIn U.S." **Prior (2024):** In millions of dollars20232022202120202019Allowance for credit losses on loans (ACLL) at beginning of year$16,974 $16,455 $24,956 $12,783 $12,315 Adjustments to opening balance:Financial instruments - TDRs and vintage disclosures(1)(352) - - - - Financial instruments - credit losses (CECL)(2) - - - 4,201 - Variable post-charge-off third-party collection costs(3) - - - (443) - Adjusted ACLL at beginning of year$16,622 $16,455 $24,956 $16,541 $12,315 Provision for credit losses on loans (PCLL)Consumer$7,665 $4,128 $(1,159)$12,222 $7,788 Corporate121 617 (1,944)3,700 430 Total$7,786 $4,745 $(3,103)$15,922 $8,218 Gross credit losses on loansConsumerIn U.S. offices$6,339 $3,944 $4,076 $6,141 $6,590 In offices outside the U.S. 1,214 934 2,144 2,146 2,316 CorporateCommercial and industrial, and otherIn U.S. offices129 110 228 466 213 In offices outside the U.S. 119 81 259 409 196 Loans to financial institutionsIn U.S. offices4 - 1 14 - In offices outside the U.S. 36 80 1 12 3 Mortgage and real estateIn U.S. offices31 - 10 71 23 In offices outside the U.S.9 7 1 4 - Total$7,881 $5,156 $6,720 $9,263 $9,341 Gross recoveries on loansConsumerIn U.S. offices$1,124 $1,045 $1,215 $1,094 $988 In offices outside the U.S. 242 222 496 482 504 CorporateCommercial and industrial, and otherIn U.S. offices38 44 57 34 15 In offices outside the U.S. 37 46 54 27 58 Loans to financial institutionsIn U.S. offices - 6 2 - - In offices outside the U.S. - 3 1 14 - Mortgage and real estateIn U.S. offices - - - - 8 In offices outside the U.S. 3 1 - 1 - Total$1,444 $1,367 $1,825 $1,652 $1,573 Net credit losses on loans (NCLs)In U.S. offices$5,341 $2,959 $3,041 $5,564 $5,815 Financial instruments - TDRs and vintage disclosures(1) Financial instruments - credit losses (CECL)(2) Variable post-charge-off third-party collection costs(3) 84 84 84 In offices outside the U.S. 1,096 830 1,854 2,047 1,953 Total$6,437 $3,789 $4,895 $7,611 $7,768 Other - net(4)(5)(6)(7)(8)(9)$174 $(437)$(503)$104 $18 Allowance for credit losses on loans (ACLL) at end of year$18,145 $16,974 $16,455 $24,956 $12,783 ACLL as a percentage of EOP loans(10)2.66 %2.60 %2.49 %3.73 %1.84 %Allowance for credit losses on unfunded lending commitments (ACLUC)(11)(12)$1,728 $2,151 $1,871 $2,655 $1,456 Total ACLL and ACLUC$19,873 $19,125 $18,326 $27,611 $14,239 Net consumer credit losses on loans$6,187 $3,611 $4,509 $6,711 $7,414 As a percentage of average consumer loans1.66 %1.02 %1.20 %1.77 %1.94 %Net corporate credit losses on loans$250 $178 $386 $900 $354 As a percentage of average corporate loans0.09 %0.06 %0.13 %0.29 %0.12 %ACLL by type at end of year(13)Consumer$15,431 $14,119 $14,040 $20,180 $10,056 Corporate2,714 2,855 2,415 4,776 2,727 Total$18,145 $16,974 $16,455 $24,956 $12,783 Other - net(4)(5)(6)(7)(8)(9) ACLL as a percentage of EOP loans(10) Allowance for credit losses on unfunded lending commitments (ACLUC)(11)(12) **Current (2025):** In millions of dollars20242023202220212020Allowance for credit losses on loans (ACLL) at beginning of year$18,145 $16,974 $16,455 $24,956 $12,783 Adjustments to opening balance:Financial instruments - TDRs and vintage disclosures(1) - (352) - - - Financial instruments - credit losses (CECL)(2) - - - - 4,201 Variable post-charge-off third-party collection costs - - - - (443)Adjusted ACLL at beginning of year$18,145 $16,622 $16,455 $24,956 $16,541 Provision for credit losses on loans (PCLL)Consumer$9,459 $7,665 $4,128 $(1,159)$12,222 Corporate267 121 617 (1,944)3,700 Total$9,726 $7,786 $4,745 $(3,103)$15,922 Gross credit losses on loansConsumerIn U.S. offices$8,989 $6,339 $3,944 $4,076 $6,141 In offices outside the U.S. 1,212 1,214 934 2,144 2,146 CorporateCommercial and industrial, and otherIn U.S. offices149 129 110 228 466 In offices outside the U.S. 170 119 81 259 409 Loans to financial institutionsIn U.S. offices - 4 - 1 14 In offices outside the U.S. 10 36 80 1 12 Mortgage and real estateIn U.S. offices144 31 - 10 71 In offices outside the U.S.20 9 7 1 4 Total$10,694 $7,881 $5,156 $6,720 $9,263 Gross recoveries on loansConsumerIn U.S. offices$1,406 $1,124 $1,045 $1,215 $1,094 In offices outside the U.S. 192 242 222 496 482 CorporateCommercial and industrial, and otherIn U.S. offices51 38 44 57 34 In offices outside the U.S. 35 37 46 54 27 Loans to financial institutionsIn U.S. offices5 - 6 2 - In offices outside the U.S. 4 - 3 1 14 Mortgage and real estateIn U.S. offices - - - - - In offices outside the U.S. 1 3 1 - 1 Financial instruments - TDRs and vintage disclosures(1) Financial instruments - credit losses (CECL)(2) 87 87 87 Total$1,694 $1,444 $1,367 $1,825 $1,652 Net credit losses on loans (NCLs)In U.S. offices$7,820 $5,341 $2,959 $3,041 $5,564 In offices outside the U.S. 1,180 1,096 830 1,854 2,047 Total$9,000 $6,437 $3,789 $4,895 $7,611 Other - net(3)(4)(5)(6)(7)(8)$(297)$174 $(437)$(503)$104 Allowance for credit losses on loans (ACLL) at end of year$18,574 $18,145 $16,974 $16,455 $24,956 ACLL as a percentage of EOP loans(9)2.71 %2.66 %2.60 %2.49 %3.73 %Allowance for credit losses on unfunded lending commitments (ACLUC)(10)$1,601 $1,728 $2,151 $1,871 $2,655 Total ACLL and ACLUC$20,175 $19,873 $19,125 $18,326 $27,611 Net consumer credit losses on loans$8,603 $6,187 $3,611 $4,509 $6,711 As a percentage of average consumer loans2.24 %1.66 %1.02 %1.20 %1.77 %Net corporate credit losses on loans$397 $250 $178 $386 $900 As a percentage of average corporate loans0.13 %0.09 %0.06 %0.13 %0.29 %ACLL by type at end of year(11)Consumer$16,018 $15,431 $14,119 $14,040 $20,180 Corporate2,556 2,714 2,855 2,415 4,776 Total$18,574 $18,145 $16,974 $16,455 $24,956 Other - net(3)(4)(5)(6)(7)(8) ACLL as a percentage of EOP loans(9) Allowance for credit losses on unfunded lending commitments (ACLUC)(10) --- ## Modified: Significantly Heightened Regulatory Expectations and Scrutiny in the U.S. and Globally and Ongoing Interpretation and Implementation of Regulatory and Legislative Requirements and Changes Have Increased Citi's Compliance, Regulatory and Other Risks and Costs. **Key changes:** - Reworded sentence: "Large financial institutions, such as Citi, face significantly heightened regulatory and supervisory expectations and scrutiny in the U.S." - Reworded sentence: "These regulatory and supervisory expectations extend to employees and agents and also include, among other things, those related to customer and client protection, market practices, anti-money laundering, increasingly complex sanctions and disclosure regimes and various regulatory reporting requirements." - Reworded sentence: "Moreover, over the past several years, Citi has been required to implement a large number of regulatory, supervisory and legislative changes, including new regulatory, supervisory or legislative requirements or regimes, across its businesses and functions, and these changes continue." - Reworded sentence: "regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and "Capital Resources" above); (ii) various laws relating to the limitation of cross-border data movement and/or collection and use of customer information, including data localization and protection and privacy laws, which also can conflict with or increase compliance complexity with respect to other laws, including anti-money laundering laws; and (iii) the EU's Corporate Sustainability Reporting Directive, which may overlap but also diverge from climate-related disclosure requirements expected to come into effect in other jurisdictions." **Prior (2024):** Large financial institutions, such as Citi, face significantly heightened regulatory expectations and scrutiny in the U.S. and globally, including with respect to, among other things, governance, infrastructure, data and risk management practices and controls. These regulatory expectations extend to their employees and agents and also include, among other things, those related to customer and client protection, market practices, anti-money laundering, increasingly complex sanctions and disclosure regimes and various regulatory 59 59 59 reporting requirements. U.S. financial institutions also face increased expectations and scrutiny in the wake of the failures of several regional banks and other banking stresses in the first half of 2023. In addition, 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, which may overlap or conflict across jurisdictions, resulting in substantial compliance, regulatory and other risks and costs.A failure to comply with these expectations and requirements, even if inadvertent, or resolve any identified deficiencies in a timely and sufficiently satisfactory manner to regulators, could result in increased regulatory oversight; material restrictions, including, among others, imposition ofadditional capital buffers and limitations on capitaldistributions; enforcement proceedings; penalties; and fines (see the capital return risk factor above and legal and regulatory proceedings risk factor below). Over the past several years, Citi has been required to implement a large number of regulatory and legislative changes, including new regulatory or legislative requirements or regimes, across its businesses and functions, and these changes continue. The changes themselves may be complex and subject to interpretation, and result in changes to Citi's businesses. In addition, the changes require continued substantial technology and other investments. In some cases, Citi's implementation of a regulatory or legislative requirement is occurring simultaneously with changing or conflicting regulatory guidance from multiple jurisdictions(including various U.S. states) and regulators, legal challenges or legislative action to modify or repeal existing rules or enact new rules. Examples of regulatory or legislative changes that have resulted in increased compliance risks and costs include (i) the U.S. regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and "Capital Resources" above); (ii) various laws relating to the limitation of cross-border data movement and/or collection and use of customer information, including data localization and protection and privacy laws, which also can conflict with or increase compliance complexity with respect to other laws, including anti-money laundering laws; and (iii) the EU's Corporate Sustainability Reporting Directive, which may overlap but also diverge from climate-related disclosure requirements expected to come into effect in other jurisdictions, including in the U.S. In addition, certain U.S. regulatory agencies and states and non-U.S. authorities 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 through rulemaking, supervision and other means, even while certain U.S. state and other governments are pursuing and signaling challenges that may conflict with corporate ESG initiatives. Citi Is Subject to Extensive Legal and Regulatory Proceedings, Examinations, Investigations, Consent Orders and Related Compliance Efforts and Other Inquiries That Could Result in Large Monetary Penalties, Supervisory or Enforcement Orders, Business Restrictions, Limitations on Dividends, Changes to Directors and/or Officers and Collateral Consequences Arising from Such Outcomes.At any given time, Citi is a party to a significant number of legal and regulatory proceedings and is subject to numerous governmental and regulatory examinations. Additionally, Citi remains subject to governmental and regulatory investigations, consent orders (see discussion below) and related compliance efforts, and other inquiries. Citi could also be subject to enforcement proceedings and negative regulatory evaluationor examination findings 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 (see also the capital return and resolution plan risk factors above). Citi's regulators have broad powers and discretion under their prudential and supervisory authority, and have pursued active inspection and investigatory oversight.As previously disclosed, the October 2020 FRB and OCC consent orders require Citigroup and Citibank to implement extensive targeted action plans and submit quarterly progress reports on a timely and sufficient basis 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 2024 and beyond, as an essential part of Citi's broader transformation efforts to enhance its risk, controls, data and finance infrastructure and compliance. There can be no assurance that such improvements will be implemented in a manner satisfactory, in both timing and sufficiency, to the FRB and OCC. 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. 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, which have been subject to increased regulatory scrutiny. 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 foreign jurisdictions, as well as multiple civil litigation claims in multiple jurisdictions. Violations of law by other financial institutions may also result in regulatory scrutiny of Citi. Responding to regulatory reporting requirements. U.S. financial institutions also face increased expectations and scrutiny in the wake of the failures of several regional banks and other banking stresses in the first half of 2023. In addition, 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, which may overlap or conflict across jurisdictions, resulting in substantial compliance, regulatory and other risks and costs.A failure to comply with these expectations and requirements, even if inadvertent, or resolve any identified deficiencies in a timely and sufficiently satisfactory manner to regulators, could result in increased regulatory oversight; material restrictions, including, among others, imposition ofadditional capital buffers and limitations on capitaldistributions; enforcement proceedings; penalties; and fines (see the capital return risk factor above and legal and regulatory proceedings risk factor below). Over the past several years, Citi has been required to implement a large number of regulatory and legislative changes, including new regulatory or legislative requirements or regimes, across its businesses and functions, and these changes continue. The changes themselves may be complex and subject to interpretation, and result in changes to Citi's businesses. In addition, the changes require continued substantial technology and other investments. In some cases, Citi's implementation of a regulatory or legislative requirement is occurring simultaneously with changing or conflicting regulatory guidance from multiple jurisdictions(including various U.S. states) and regulators, legal challenges or legislative action to modify or repeal existing rules or enact new rules. Examples of regulatory or legislative changes that have resulted in increased compliance risks and costs include (i) the U.S. regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and "Capital Resources" above); (ii) various laws relating to the limitation of cross-border data movement and/or collection and use of customer information, including data localization and protection and privacy laws, which also can conflict with or increase compliance complexity with respect to other laws, including anti-money laundering laws; and (iii) the EU's Corporate Sustainability Reporting Directive, which may overlap but also diverge from climate-related disclosure requirements expected to come into effect in other jurisdictions, including in the U.S. In addition, certain U.S. regulatory agencies and states and non-U.S. authorities 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 through rulemaking, supervision and other means, even while certain U.S. state and other governments are pursuing and signaling challenges that may conflict with corporate ESG initiatives. Citi Is Subject to Extensive Legal and Regulatory Proceedings, Examinations, Investigations, Consent Orders and Related Compliance Efforts and Other Inquiries That Could Result in Large Monetary Penalties, Supervisory or Enforcement Orders, Business Restrictions, Limitations on reporting requirements. U.S. financial institutions also face increased expectations and scrutiny in the wake of the failures of several regional banks and other banking stresses in the first half of 2023. In addition, 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, which may overlap or conflict across jurisdictions, resulting in substantial compliance, regulatory and other risks and costs. A failure to comply with these expectations and requirements, even if inadvertent, or resolve any identified deficiencies in a timely and sufficiently satisfactory manner to regulators, could result in increased regulatory oversight; material restrictions, including, among others, imposition of additional capital buffers and limitations on capital distributions; enforcement proceedings; penalties; and fines (see the capital return risk factor above and legal and regulatory proceedings risk factor below). Over the past several years, Citi has been required to implement a large number of regulatory and legislative changes, including new regulatory or legislative requirements or regimes, across its businesses and functions, and these changes continue. The changes themselves may be complex and subject to interpretation, and result in changes to Citi's businesses. In addition, the changes require continued substantial technology and other investments. In some cases, Citi's implementation of a regulatory or legislative requirement is occurring simultaneously with changing or conflicting regulatory guidance from multiple jurisdictions (including various U.S. states) and regulators, legal challenges or legislative action to modify or repeal existing rules or enact new rules. Examples of regulatory or legislative changes that have resulted in increased compliance risks and costs include (i) the U.S. regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and "Capital Resources" above); (ii) various laws relating to the limitation of cross-border data movement and/or collection and use of customer information, including data localization and protection and privacy laws, which also can conflict with or increase compliance complexity with respect to other laws, including anti-money laundering laws; and (iii) the EU's Corporate Sustainability Reporting Directive, which may overlap but also diverge from climate-related disclosure requirements expected to come into effect in other jurisdictions, including in the U.S. In addition, certain U.S. regulatory agencies and states and non-U.S. authorities 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 through rulemaking, supervision and other means, even while certain U.S. state and other governments are pursuing and signaling challenges that may conflict with corporate ESG initiatives. **Current (2025):** Large financial institutions, such as Citi, face significantly heightened regulatory and supervisory expectations and scrutiny in the U.S. and globally, including with respect to, among other things, governance, infrastructure, data and risk management practices and controls. These regulatory and supervisory expectations extend to employees and agents and also include, among other things, those related to customer and client protection, market practices, anti-money laundering, increasingly complex sanctions and disclosure regimes and various regulatory reporting requirements. U.S. financial institutions also face increased expectations and scrutiny in the wake of the failures of several regional banks and other banking stresses in 2023. In addition, 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, which may overlap or conflict across jurisdictions, resulting in substantial compliance, regulatory and other risks and costs. A failure to comply with these expectations and requirements, even if inadvertent, or resolve any identified deficiencies in a timely and sufficiently satisfactory manner to regulators, could result in increased regulatory oversight; material restrictions, including, among others, imposition of additional capital buffers and limitations on capital distributions; enforcement proceedings; penalties; and fines (see the capital return risk factor above and legal and regulatory proceedings risk factor below). Moreover, over the past several years, Citi has been required to implement a large number of regulatory, supervisory and legislative changes, including new regulatory, supervisory or legislative requirements or regimes, across its businesses and functions, and these changes continue. The changes themselves may be complex and subject to interpretation, and result in changes to Citi's businesses. In addition, the changes require continued substantial technology and other investments. In some cases, Citi's implementation of a regulatory or legislative requirement is occurring simultaneously with changing or conflicting regulatory guidance from multiple jurisdictions (including various U.S. states) and regulators, legal challenges or legislative action to modify or repeal existing rules or enact new rules. Examples of regulatory or legislative changes that have resulted in increased compliance risks and costs include (i) the U.S. regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and "Capital Resources" above); (ii) various laws relating to the limitation of cross-border data movement and/or collection and use of customer information, including data localization and protection and privacy laws, which also can conflict with or increase compliance complexity with respect to other laws, including anti-money laundering laws; and (iii) the EU's Corporate Sustainability Reporting Directive, which may overlap but also diverge from climate-related disclosure requirements expected to come into effect in other jurisdictions. Citi Is Subject to Extensive Legal and Regulatory Proceedings, Examinations, Investigations, Consent Orders and Related Compliance Efforts and Other Inquiries That Could Result in Large Monetary Penalties, Supervisory or Enforcement Orders, Business Restrictions, Limitations on Dividends, Changes to Directors and/or Officers and Collateral Consequences Arising from Such Outcomes.Citi's regulators have broad powers and discretion under their prudential and supervisory authority, and have pursued active inspection and investigatory oversight. At any given time, Citi is a party to a significant number of legal and regulatory proceedings and is subject to numerous governmental and regulatory examinations. Additionally, Citi remains subject to governmental and regulatory investigations, consent orders (see discussion below) and related compliance efforts, and other inquiries. Citi could also be subject to enforcement proceedings and negative regulatory evaluation or examination findings 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 (see also the capital return and resolution plan risk factors above). Citi could face further scrutiny and consequences from regulators for failing to timely resolve open regulatory issues or having repeat regulatory issues.As previously disclosed, the 2020 FRB Consent Order and the 2020 OCC Consent Order require Citigroup and Citibank, respectively, to implement extensive targeted action plans and submit quarterly progress reports on a timely and sufficient basis detailing the results and status of improvements relating principally to various aspects of enterprise-wide risk management, compliance, data quality management related to governance, and internal controls. These improvements will result in continued significant investments by Citi during 2025 and beyond, as an essential part of Citi's broader transformation efforts to enhance its risk, controls, data and finance infrastructure and compliance (see the transformation, simplification and other priorities-related risk factor above). Additionally, on July 10, 2024, the FRB entered into a Civil Money Penalty Consent Order with Citigroup, and the OCC entered into a Civil Money Penalty Consent Order with Citibank. The OCC and Citibank also entered into an Amendment to the OCC's 2020 Consent Order (the Amendment). The FRB found that Citigroup had ongoing deficiencies related to its data quality management program and had inadequate measures for managing and controlling its data quality risks. The OCC found that Citibank had failed to make sufficient and sustainable progress toward achieving compliance with its 2020 Consent Order. The Amendment requires Citibank to formalize a process to determine whether sufficient resources are being appropriately allocated toward achieving timely and sustainable compliance with the OCC's 2020 Consent Order, including any requirements on which Citibank is not making sufficient and sustainable progress (such process, the Resource Review Plan). There can be no assurance that the Resource requirements expected to come into effect in other jurisdictions. --- ## Modified: Long-Term Liquidity Measurement: Net Stable Funding Ratio (NSFR) **Key changes:** - Reworded sentence: "The NSFR measures the availability of an institution's stable funding against the required stable funding in accordance with a calculation required by the rule." - Reworded sentence: "For the quarter ended December 31, 2024, Citigroup's consolidated NSFR was compliant with the 100% minimum requirement of the rule." **Prior (2024):** As previously disclosed, the U.S. banking agencies adopted a rule to assess the availability of a bank's stable funding against a required level. In general, a bank's available stable funding includes portions of equity, deposits and long-term debt, while its required stable funding will be based on the liquidity characteristics of its assets, derivatives and commitments. Standardized weightings are required to be applied to the various asset and liability classes. The ratio of available stable funding to required stable funding is required to be greater than 100%. For the quarter ended December 31, 2023, Citigroup's consolidated NSFR was compliant with the rule. Refer to Citi's U.S. NSFR Disclosure report covering December 31, 2023 and September 30, 2023 on its website for additional information. **Current (2025):** The NSFR measures the availability of an institution's stable funding against the required stable funding in accordance with a calculation required by the rule. The ratio of available stable funding to required stable funding must be greater than 100%. In general, an institution's available stable funding includes portions of equity, deposits and long-term debt, while its required stable funding is based on the liquidity characteristics of its assets, derivatives and commitments. Standardized weightings are required to be applied to the various asset and liability classes. For the quarter ended December 31, 2024, Citigroup's consolidated NSFR was compliant with the 100% minimum requirement of the rule. (For additional information, see the Consolidated Citigroup NSFR Disclosure for the quarterly periods ended December 31, 2024 and September 30, 2024, on Citi's Investor Relations website. The Consolidated Citigroup NSFR Disclosure on Citi's Investor Relations website is not incorporated by reference into, and does not form any part of, this Form 10-K). --- ## Modified: Citi Must Continually Review, Analyze and Successfully Adapt to Ongoing Regulatory and Legislative Uncertainties and Changes in the U.S. and Globally. **Key changes:** - Reworded sentence: "Basel III rules (see the capital return risk factor and "Capital Resources - Regulatory Capital Standards and Developments" above) and (ii) potential fiscal, monetary, tax, sanctions, human capital and other changes promulgated by the U.S." - Removed sentence: "For example, in February 2023, the Consumer Financial Protection Bureau (CFPB) proposed significant changes to the maximum amounts on credit card late fees, which, if adopted as proposed, would reduce credit card fee revenues in Branded Cards and Retail Services in USPB." - Reworded sentence: "Further, ongoing regulatory and legislative uncertainties and changes make Citi's long-term business, balance sheet and strategic budget planning difficult, subject to change and 51 51 51 potentially more costly and may impact its results of operations." - Reworded sentence: "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 competitive position, as well as its businesses, revenues, results of operations and financial condition.Citi's Ability to Achieve Its Objectives from Its Transformation, Simplification and Other Priorities May Not Be as Successful as It Projects or Expects.As part of its multiyear transformation, Citi continues to make significant investments and undertake substantial actions across the Company to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" and "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor below)." - Reworded sentence: "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 competitive position, as well as its businesses, revenues, results of operations and financial condition.Citi's Ability to Achieve Its Objectives from Its Transformation, Simplification and Other Priorities May Not Be as Successful as It Projects or Expects.As part of its multiyear transformation, Citi continues to make significant investments and undertake substantial actions across the Company to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" and "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor below)." **Prior (2024):** Citi, its management and its businesses continue to face regulatory and legislative uncertainties and changes, both in the U.S. and globally. While the ongoing regulatory and legislative uncertainties and changes facing Citi are too numerous to list completely, examples include, but are not limited to (i) potential changes to various aspects of the U.S. regulatory capital framework and requirements applicable to Citi, including, among others, significant revisions to the U.S. Basel III rules, known as the Basel III Endgame (for information about the Basel III Endgame, see the capital return risk factor and "Capital Resources - Regulatory Capital Standards Developments" above); (ii) potential fiscal, monetary, tax, sanctions and other changes promulgated by the U.S. federal government and other governments, including potential changes in regulatory requirements relating to interest rate risk management; and (iii) rapidly evolving legislative and regulatory requirements and other government initiatives in the EU, the U.S. and globally related to climate change and other ESG areas that vary, and may conflict, across jurisdictions, including any new disclosure requirements (see the climate change and heightened regulatory scrutiny and ongoing interpretation of regulatory changes risk factors below). References to "regulatory" refer to both formal regulation and the views and expectations of Citi's regulators in their supervisory roles, which, as they change over time, can have a major impact. In particular, the U.S. regulators have indicated that the level of their expectations is increasing and prompt negative examination findings/ratings and enforcements actions are more likely. For example, in February 2023, the Consumer Financial Protection Bureau (CFPB) proposed significant changes to the maximum amounts on credit card late fees, which, if adopted as proposed, would reduce credit card fee revenues in Branded Cards and Retail Services in USPB. In addition, 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 their scope, interpretation, timing, structure or approach, leading to inconsistent or even conflicting requirements, including within a single jurisdiction. Further, ongoing regulatory and legislative uncertainties and changes make Citi's long-term business, balance sheet and strategic budget planning difficult, subject to change and potentially more costly and may impact its results of operations. 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 must necessarily be based on possible or proposed rules or outcomes, which can change significantly 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 competitive position, as well as its businesses, results of operations and financial condition.Citi's Ability to Achieve Its Objectives from Its Transformation, Organizational, Simplification and Other Strategic and Other Initiatives May Not Be as Successful as It Projects or Expects.As part of its transformation initiatives, Citi continues to make significant investments to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" above and the legal and regulatory proceedings risk factor below). Citi also continues to make business-led investments, as part of the execution of its strategic initiatives. For example, Citi has been making investments across the Company, including hiring front office colleagues in key strategic markets and businesses; enhancing product capabilities and platforms to grow key businesses, improve client digital experiences and add scalability; and implementing new capabilities and partnerships. These business-led investments are designed to grow revenues as well as result in retention and efficiency improvements. Additionally, Citi has been pursuing overall simplification initiatives that include management and operating model changes and actions to enhance focus on clients and reduce expenses. Citi's simplification actions also include divestiture of the Mexico Consumer/SBMM operations and completing other exits and wind-downs in order to streamline Citi and assist in optimizing its allocation of resources. These overall simplification initiatives involve various execution challenges and may result in higher than expected expenses, litigation and regulatory scrutiny, CTA and other losses or other negative financial or strategic impacts, which could be material (for information about potential CTA impacts, see the capital as proposed, would reduce credit card fee revenues in Branded Cards and Retail Services in USPB. In addition, 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 their scope, interpretation, timing, structure or approach, leading to inconsistent or even conflicting requirements, including within a single jurisdiction. Further, ongoing regulatory and legislative uncertainties and changes make Citi's long-term business, balance sheet and strategic budget planning difficult, subject to change and potentially more costly and may impact its results of operations. 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 must necessarily be based on possible or proposed rules or outcomes, which can change significantly 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 competitive position, as well as its businesses, results of operations and financial condition. **Current (2025):** Citi, its management and its businesses continue to face regulatory and legislative uncertainties and changes, both in the U.S. and globally. While the ongoing regulatory and legislative uncertainties and changes facing Citi are too numerous to list completely, examples include, but are not limited to (i) potential changes to various aspects of the U.S. regulatory capital framework and requirements applicable to Citi, including, among others, significant revisions to the U.S. Basel III rules (see the capital return risk factor and "Capital Resources - Regulatory Capital Standards and Developments" above) and (ii) potential fiscal, monetary, tax, sanctions, human capital and other changes promulgated by the U.S. federal government and other governments (see the macroeconomic and geopolitical risk factor above and the ability to utilize DTAs risk factor below). References to "regulatory" refer to both formal regulation and the views and expectations of Citi's regulators in their supervisory and enforcement roles, which, as they change over time, can have a major impact. In particular, U.S. regulators have indicated that the level of their expectations is increasing and prompt negative examination findings/ratings and enforcements actions are more likely. Additionally, 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 their scope, interpretation, timing, structure or approach, leading to inconsistent or even conflicting requirements, including within a single jurisdiction. Further, ongoing regulatory and legislative uncertainties and changes make Citi's long-term business, balance sheet and strategic budget planning difficult, subject to change and 51 51 51 potentially more costly and may impact its results of operations. 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 must necessarily be based on possible or proposed rules or outcomes, which can change significantly 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 competitive position, as well as its businesses, revenues, results of operations and financial condition.Citi's Ability to Achieve Its Objectives from Its Transformation, Simplification and Other Priorities May Not Be as Successful as It Projects or Expects.As part of its multiyear transformation, Citi continues to make significant investments and undertake substantial actions across the Company to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" and "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor below). Citi has also been pursuing overall simplification initiatives that have included management and operating model changes and actions to enhance focus on clients and reduce expenses. Citi's simplification actions also include completing its remaining divestitures, including the planned IPO of Mexico Consumer/SBMM. These simplification initiatives involve various execution challenges, may take longer than expected and may result in higher than expected expenses, CTA and other losses or other negative financial or strategic impacts, which could be material, and litigation and regulatory scrutiny (for information about potential CTA impacts, see the capital return risk factor above and the incorrect assumptions or estimates and emerging markets risk factors below).Additionally, Citi continues to make business-led investments, as part of the execution of its strategic priorities. For example, Citi has been making investments across the Company, including hiring front office employees in key strategic markets and businesses; enhancing product capabilities and platforms to grow key businesses, improve client digital experiences and add scalability; and implementing new capabilities and partnerships. These business-led investments are designed to reduce expenses and grow revenues as well as result in retention and efficiency improvements. Citi's transformation, as well as its simplification and business investment initiatives, involve significant complexities and uncertainties. In addition, there is inherent risk that these initiatives will not be as productive or effective as Citi expects, or at all. Conversely, failure to adequately invest in and upgrade Citi's technology and processes or properly implement its enterprise-wide simplification could result in Citi's inability to meet regulatory expectations, be sufficiently competitive, serve clients effectively and avoid disruptions to its businesses and operational errors (see the operational processes and systems and legal and regulatory proceedings risk factors below). Citi's ability to achieve its expected returns, including expense savings and revenue growth objectives, and operational improvements from these priorities depends, in part, on factors that it cannot control, including, among others, macroeconomic challenges and uncertainties; customer, client and competitor actions; and ongoing regulatory requirements or changes.Moreover, Citi's transformation, simplification and other priorities may continue to evolve as its business strategies, the market environment and regulatory expectations change, which could make the initiatives more costly and more challenging to implement, and limit their effectiveness. Climate Change Presents Various Financial and Non-Financial Risks to Citi and Its Customers and Clients.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, market, technological, stakeholder and legal changes from a transition to a low-carbon economy). Physical and transition risks can manifest themselves differently across Citi's risk categories in the short, medium and long terms. Physical risks from climate change include acute risks, such as wildfires, hurricanes, floods and droughts, as well as consequences of chronic changes in climate, such as rising sea levels, prolonged droughts and systemic changes to geographies and any resulting population migration. For example, physical risks could have adverse financial, operational and other impacts on Citi, both directly on its business and operations, and indirectly as a result of impacts to Citi's clients, customers, vendors and other counterparties. These impacts can include destruction, damage or impairment of owned or leased properties and other assets, destruction or deterioration of the value of collateral, such as real estate, disruptions to business operations and supply chains, and reduced availability or increase in the cost of insurance. Physical risks can also impact Citi's credit risk exposures, for example, in its mortgage and commercial real estate lending businesses.Transition risks may arise from changes in regulations or market preferences toward low-carbon industries or sectors, 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. Failure to adequately consider transition risk in developing and executing on its business strategy could lead to a loss of market share, lower revenues and higher credit costs. Transition risks also include potential increased operational, compliance and energy costs driven by government policies to promote decarbonization. potentially more costly and may impact its results of operations. 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 must necessarily be based on possible or proposed rules or outcomes, which can change significantly 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 competitive position, as well as its businesses, revenues, results of operations and financial condition.Citi's Ability to Achieve Its Objectives from Its Transformation, Simplification and Other Priorities May Not Be as Successful as It Projects or Expects.As part of its multiyear transformation, Citi continues to make significant investments and undertake substantial actions across the Company to improve its risk and controls environment, modernize its data and technology infrastructure and further enhance safety and soundness (see "Executive Summary" and "Citi's Multiyear Transformation" above and the legal and regulatory proceedings risk factor below). Citi has also been pursuing overall simplification initiatives that have included management and operating model changes and actions to enhance focus on clients and reduce expenses. Citi's simplification actions also include completing its remaining divestitures, including the planned IPO of Mexico Consumer/SBMM. These simplification initiatives involve various execution challenges, may take longer than expected and may result in higher than expected expenses, CTA and other losses or other negative financial or strategic impacts, which could be material, and litigation and regulatory scrutiny (for information about potential CTA impacts, see the capital return risk factor above and the incorrect assumptions or estimates and emerging markets risk factors below).Additionally, Citi continues to make business-led investments, as part of the execution of its strategic priorities. For example, Citi has been making investments across the Company, including hiring front office employees in key strategic markets and businesses; enhancing product capabilities and platforms to grow key businesses, improve client digital experiences and add scalability; and implementing new capabilities and partnerships. These business-led investments are designed to reduce expenses and grow revenues as well as result in retention and efficiency improvements. Citi's transformation, as well as its simplification and business investment initiatives, involve significant complexities and uncertainties. In addition, there is inherent risk that these initiatives will not be as productive or effective as Citi expects, or at all. Conversely, failure to adequately invest in and upgrade Citi's technology and processes or properly implement its enterprise-wide simplification could result in Citi's inability to meet regulatory expectations, be potentially more costly and may impact its results of operations. 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 must necessarily be based on possible or proposed rules or outcomes, which can change significantly 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 competitive position, as well as its businesses, revenues, results of operations and financial condition. --- ## Modified: Interest rate exposure(1)(2) **Key changes:** - Reworded sentence: "Estimated initial negative impact to AOCI (after-tax)(2) Estimated initial impact on CET1 Capital ratio (bps) from AOCI scenario(3) (1)Excludes trading book and fair value option banking book portfolios and replaces them with the associated transfer pricing." - Reworded sentence: "(3)Excludes the effect of changes in interest rates on AOCI related to cash flow hedges, as those changes are excluded from CET1 Capital." - Reworded sentence: "Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE for a 100 bps upward rate shock.All other currencies of $1.1 billion as of December 31, 2024 in the table above includes the impact from the following top five non-U.S." - Reworded sentence: "Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE for a 100 bps upward rate shock." - Reworded sentence: "Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE for a 100 bps upward rate shock." **Prior (2024):** Estimated initial negative impact to AOCI (after-tax)(2) Estimated initial impact on CET1 Capital ratio (bps) from AOCI scenario (1)Excludes trading book and fair value option banking book portfolios and replaces them with the associated transfer pricing. (2)Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension liability adjustments. The All other currencies of $1,219 billion as of December 31, 2023 in the table above includes the impact from the following top six non-U.S. dollar currencies, which represents approximately 50% of the total non-U.S. dollar currency impact: approximately $0.2 billion from the Japanese yen, and approximately $0.1 billion each from the Indian rupee, Singapore dollar, Korean won, Swiss franc and Chinese yuan. These impacts per currency are generally in the same direction (estimated positive impact in the +100 bps shock scenario) and not offsetting.Citi's balance sheet is asset sensitive (assets reprice faster than liabilities), resulting in higher net interest income in increasing interest rate scenarios. The estimated impact to Citi's net interest income in a 100 bps upward rate shock scenario as of December 31, 2023 decreased quarter-over-quarter and year-over-year, primarily reflecting the net impact of lower expected gains due to U.S. dollar interest rate moves that have already been realized and changes in Citi's balance sheet. At progressively higher interest rate levels, the marginal net interest income benefit is lower, as Citi assumes it will pass on a larger share of rate changes to depositors (i.e., higher betas), further reducing Citi's IRE sensitivity. Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE.In a 100 bps upward rate shock scenario, Citi expects that the approximate $0.8 billion initial negative impact to AOCI could potentially be offset in shareholders' equity through the expected recovery of the impact on AOCI through accretion of Citi's investment portfolio and expected net interest income benefit over a period of approximately four months. The All other currencies of $1,219 billion as of December 31, 2023 in the table above includes the impact from the following top six non-U.S. dollar currencies, which represents approximately 50% of the total non-U.S. dollar currency impact: approximately $0.2 billion from the Japanese yen, and approximately $0.1 billion each from the Indian rupee, Singapore dollar, Korean won, Swiss franc and Chinese yuan. These impacts per currency are generally in the same direction (estimated positive impact in the +100 bps shock scenario) and not offsetting.Citi's balance sheet is asset sensitive (assets reprice faster than liabilities), resulting in higher net interest income in increasing interest rate scenarios. The estimated impact to Citi's net interest income in a 100 bps upward rate shock scenario as of December 31, 2023 decreased quarter-over-quarter and year-over-year, primarily reflecting the net impact of lower expected gains due to U.S. dollar interest rate moves that have already been realized and changes in Citi's balance sheet. At progressively higher interest rate levels, the marginal net interest income benefit is lower, as Citi assumes it will pass on a larger share of rate changes to depositors (i.e., higher betas), further reducing Citi's IRE sensitivity. Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE.In a 100 bps upward rate shock scenario, Citi expects that the approximate $0.8 billion initial negative impact to AOCI could potentially be offset in shareholders' equity through the expected recovery of the impact on AOCI through accretion of Citi's investment portfolio and expected net interest income benefit over a period of approximately four months. The All other currencies of $1,219 billion as of December 31, 2023 in the table above includes the impact from the following top six non-U.S. dollar currencies, which represents approximately 50% of the total non-U.S. dollar currency impact: approximately $0.2 billion from the Japanese yen, and approximately $0.1 billion each from the Indian rupee, Singapore dollar, Korean won, Swiss franc and Chinese yuan. These impacts per currency are generally in the same direction (estimated positive impact in the +100 bps shock scenario) and not offsetting. Citi's balance sheet is asset sensitive (assets reprice faster than liabilities), resulting in higher net interest income in increasing interest rate scenarios. The estimated impact to Citi's net interest income in a 100 bps upward rate shock scenario as of December 31, 2023 decreased quarter-over-quarter and year-over-year, primarily reflecting the net impact of lower expected gains due to U.S. dollar interest rate moves that have already been realized and changes in Citi's balance sheet. At progressively higher interest rate levels, the marginal net interest income benefit is lower, as Citi assumes it will pass on a larger share of rate changes to depositors (i.e., higher betas), further reducing Citi's IRE sensitivity. Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE. In a 100 bps upward rate shock scenario, Citi expects that the approximate $0.8 billion initial negative impact to AOCI could potentially be offset in shareholders' equity through the expected recovery of the impact on AOCI through accretion of Citi's investment portfolio and expected net interest income benefit over a period of approximately four months. 101 101 101 **Current (2025):** Estimated initial negative impact to AOCI (after-tax)(2) Estimated initial impact on CET1 Capital ratio (bps) from AOCI scenario(3) (1)Excludes trading book and fair value option banking book portfolios and replaces them with the associated transfer pricing. (2)Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension liability adjustments. (3)Excludes the effect of changes in interest rates on AOCI related to cash flow hedges, as those changes are excluded from CET1 Capital. As presented in the table above, Citi's balance sheet is asset sensitive (assets reprice faster than liabilities), resulting in higher net interest income in increasing interest rate scenarios. The estimated impact to Citi's net interest income in a 100 bps upward rate shock scenario as of December 31, 2024 remained relatively stable year-over-year. At progressively higher interest rate levels, the marginal net interest income benefit is lower, as Citi assumes it will pass on a larger share of rate changes to depositors (i.e., higher betas), further reducing Citi's IRE sensitivity. Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE for a 100 bps upward rate shock.All other currencies of $1.1 billion as of December 31, 2024 in the table above includes the impact from the following top five non-U.S. dollar currencies by absolute size: approximately $(0.2) billion from the euro, $0.2 billion from the British pound sterling, and approximately $0.1 billion each from the Chinese yuan, Swiss franc and Indian rupee. The remaining impact is spread across more than 30 additional currencies.In a 100 bps upward rate shock scenario, Citi expects that the approximate $1.0 billion initial negative impact to AOCI could potentially be offset in shareholders' equity through the expected recovery of the impact on AOCI through accretion of Citi's investment portfolio and expected net interest income benefit over a period of approximately six months. As presented in the table above, Citi's balance sheet is asset sensitive (assets reprice faster than liabilities), resulting in higher net interest income in increasing interest rate scenarios. The estimated impact to Citi's net interest income in a 100 bps upward rate shock scenario as of December 31, 2024 remained relatively stable year-over-year. At progressively higher interest rate levels, the marginal net interest income benefit is lower, as Citi assumes it will pass on a larger share of rate changes to depositors (i.e., higher betas), further reducing Citi's IRE sensitivity. Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE for a 100 bps upward rate shock. As presented in the table above, Citi's balance sheet is asset sensitive (assets reprice faster than liabilities), resulting in higher net interest income in increasing interest rate scenarios. The estimated impact to Citi's net interest income in a 100 bps upward rate shock scenario as of December 31, 2024 remained relatively stable year-over-year. At progressively higher interest rate levels, the marginal net interest income benefit is lower, as Citi assumes it will pass on a larger share of rate changes to depositors (i.e., higher betas), further reducing Citi's IRE sensitivity. Currency-specific interest rate changes and balance sheet factors may drive quarter-to-quarter volatility in Citi's estimated IRE for a 100 bps upward rate shock. All other currencies of $1.1 billion as of December 31, 2024 in the table above includes the impact from the following top five non-U.S. dollar currencies by absolute size: approximately $(0.2) billion from the euro, $0.2 billion from the British pound sterling, and approximately $0.1 billion each from the Chinese yuan, Swiss franc and Indian rupee. The remaining impact is spread across more than 30 additional currencies.In a 100 bps upward rate shock scenario, Citi expects that the approximate $1.0 billion initial negative impact to AOCI could potentially be offset in shareholders' equity through the expected recovery of the impact on AOCI through accretion of Citi's investment portfolio and expected net interest income benefit over a period of approximately six months. All other currencies of $1.1 billion as of December 31, 2024 in the table above includes the impact from the following top five non-U.S. dollar currencies by absolute size: approximately $(0.2) billion from the euro, $0.2 billion from the British pound sterling, and approximately $0.1 billion each from the Chinese yuan, Swiss franc and Indian rupee. The remaining impact is spread across more than 30 additional currencies. In a 100 bps upward rate shock scenario, Citi expects that the approximate $1.0 billion initial negative impact to AOCI could potentially be offset in shareholders' equity through the expected recovery of the impact on AOCI through accretion of Citi's investment portfolio and expected net interest income benefit over a period of approximately six months. 103 103 103 --- ## Modified: Loans Outstanding **Key changes:** - Reworded sentence: "December 31,In millions of dollars20242023202220212020Consumer loansIn North America offices(1)Residential first mortgages(2)$114,593 $108,711 $96,039 $83,361 $83,956 Home equity loans(2)3,141 3,592 4,580 5,745 7,890 Credit cards171,059 164,720 150,643 133,868 130,385 Personal, small business and other33,155 36,135 37,752 40,713 39,259 Total$321,948 $313,158 $289,014 $263,687 $261,490 In offices outside North America(1)Residential mortgages(2)$24,456 $26,426 $28,114 $37,889 $42,817 Credit cards12,927 14,233 12,955 17,808 22,692 Personal, small business and other33,995 35,380 37,984 57,150 59,475 Total$71,378 $76,039 $79,053 $112,847 $124,984 Consumer loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(3)$393,326 $389,197 $368,067 $376,534 $386,474 Unallocated portfolio-layer cumulative basis adjustments$(224)$ - $ - $ - $ - Consumer loans, net of unearned income(3)$393,102 $389,197 $368,067 $376,534 $386,474 Corporate loansIn North America offices(1)Commercial and industrial$57,730 $61,008 $56,176 $48,364 $53,930 Financial institutions41,815 39,393 43,399 49,804 39,390 Mortgage and real estate(2)18,411 17,813 17,829 15,965 16,522 Installment and other(4)25,529 23,335 23,767 20,143 17,362 Lease financing235 227 308 415 673 Total$143,720 $141,776 $141,479 $134,691 $127,877 In offices outside North America(1)Commercial and industrial$92,856 $93,402 $93,967 $102,735 $103,234 Financial institutions27,276 26,143 21,931 22,158 25,111 Mortgage and real estate(2)8,136 7,197 4,179 4,374 5,277 Installment and other(4)25,800 27,907 23,347 22,812 24,034 Lease financing40 48 46 40 65 Governments and official institutions3,630 3,599 4,205 4,423 3,811 Total$157,738 $158,296 $147,675 $156,542 $161,532 Corporate loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(5)$301,458 $300,072 $289,154 $291,233 $289,409 Unallocated portfolio-layer cumulative basis adjustments$(72)$93 $ - $ - $ - Corporate loans, net of unearned income(5)$301,386 $300,165 $289,154 $291,233 $289,409 Total loans - net of unearned income$694,488 $689,362 $657,221 $667,767 $675,883 Allowance for credit losses on loans (ACLL)(18,574)(18,145)(16,974)(16,455)(24,956)Total loans - net of unearned income and ACLL$675,914 $671,217 $640,247 $651,312 $650,927 ACLL as a percentage of total loans - net of unearned income(6)2.71 %2.66 %2.60 %2.49 %3.73 %ACLL for consumer loan losses as a percentage of total consumer loans - net of unearned income(6)4.08 %3.97 %3.84 %3.73 %5.22 %ACLL for corporate loan losses as a percentage of total corporate loans - net of unearned income(6)0.87 %0.93 %1.01 %0.85 %1.69 % In North America offices(1) Residential first mortgages(2) Home equity loans(2) In offices outside North America(1) Residential mortgages(2)" **Prior (2024):** December 31,In millions of dollars20232022202120202019Consumer loansIn North America offices(1)Residential first mortgages(2)$108,711 $96,039 $83,361 $83,956 $78,664 Home equity loans(2)3,592 4,580 5,745 7,890 10,174 Credit cards164,720 150,643 133,868 130,385 149,163 Personal, small business and other36,135 37,752 40,713 39,259 36,548 Total$313,158 $289,014 $263,687 $261,490 $274,549 In offices outside North America(1)Residential mortgages(2)$26,426 $28,114 $37,889 $42,817 $40,467 Credit cards14,233 12,955 17,808 22,692 25,909 Personal, small business and other35,380 37,984 57,150 59,475 60,013 Total$76,039 $79,053 $112,847 $124,984 $126,389 Consumer loans, net of unearned income(3)$389,197 $368,067 $376,534 $386,474 $400,938 Corporate loansIn North America offices(1)Commercial and industrial$61,008 $56,176 $48,364 $53,930 $52,229 Financial institutions39,393 43,399 49,804 39,390 38,782 Mortgage and real estate(2)17,813 17,829 15,965 16,522 13,696 Installment and other23,335 23,767 20,143 17,362 22,219 Lease financing227 308 415 673 1,290 Total$141,776 $141,479 $134,691 $127,877 $128,216 In offices outside North America(1)Commercial and industrial$93,402 $93,967 $102,735 $103,234 $112,332 Financial institutions26,143 21,931 22,158 25,111 28,176 Mortgage and real estate(2)7,197 4,179 4,374 5,277 4,325 Installment and other27,907 23,347 22,812 24,034 21,273 Lease financing48 46 40 65 95 Governments and official institutions3,599 4,205 4,423 3,811 4,128 Total$158,296 $147,675 $156,542 $161,532 $170,329 Corporate loans, net of unearned income, excluding portfolio layer cumulative basis adjustments(4)$300,072 $289,154 $291,233 $289,409 $298,545 Unallocated portfolio layer cumulative basis adjustments$93 $ - $ - $ - $ - Corporate loans, net of unearned income(4)$300,165 $289,154 $291,233 $289,409 $298,545 Total loans - net of unearned income$689,362 $657,221 $667,767 $675,883 $699,483 Allowance for credit losses on loans (ACLL)(18,145)(16,974)(16,455)(24,956)(12,783)Total loans - net of unearned income and ACLL$671,217 $640,247 $651,312 $650,927 $686,700 ACLL as a percentage of total loans - net of unearned income(5)2.66 %2.60 %2.49 %3.73 %1.84 %ACLL for consumer loan losses as a percentage of total consumer loans - net of unearned income(5)3.97 %3.84 %3.73 %5.22 %2.51 %ACLL for corporate loan losses as a percentage of total corporate loans - net of unearned income(5)0.93 %1.01 %0.85 %1.69 %0.93 % In North America offices(1) Residential first mortgages(2) Home equity loans(2) In offices outside North America(1) Residential mortgages(2) **Current (2025):** December 31,In millions of dollars20242023202220212020Consumer loansIn North America offices(1)Residential first mortgages(2)$114,593 $108,711 $96,039 $83,361 $83,956 Home equity loans(2)3,141 3,592 4,580 5,745 7,890 Credit cards171,059 164,720 150,643 133,868 130,385 Personal, small business and other33,155 36,135 37,752 40,713 39,259 Total$321,948 $313,158 $289,014 $263,687 $261,490 In offices outside North America(1)Residential mortgages(2)$24,456 $26,426 $28,114 $37,889 $42,817 Credit cards12,927 14,233 12,955 17,808 22,692 Personal, small business and other33,995 35,380 37,984 57,150 59,475 Total$71,378 $76,039 $79,053 $112,847 $124,984 Consumer loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(3)$393,326 $389,197 $368,067 $376,534 $386,474 Unallocated portfolio-layer cumulative basis adjustments$(224)$ - $ - $ - $ - Consumer loans, net of unearned income(3)$393,102 $389,197 $368,067 $376,534 $386,474 Corporate loansIn North America offices(1)Commercial and industrial$57,730 $61,008 $56,176 $48,364 $53,930 Financial institutions41,815 39,393 43,399 49,804 39,390 Mortgage and real estate(2)18,411 17,813 17,829 15,965 16,522 Installment and other(4)25,529 23,335 23,767 20,143 17,362 Lease financing235 227 308 415 673 Total$143,720 $141,776 $141,479 $134,691 $127,877 In offices outside North America(1)Commercial and industrial$92,856 $93,402 $93,967 $102,735 $103,234 Financial institutions27,276 26,143 21,931 22,158 25,111 Mortgage and real estate(2)8,136 7,197 4,179 4,374 5,277 Installment and other(4)25,800 27,907 23,347 22,812 24,034 Lease financing40 48 46 40 65 Governments and official institutions3,630 3,599 4,205 4,423 3,811 Total$157,738 $158,296 $147,675 $156,542 $161,532 Corporate loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(5)$301,458 $300,072 $289,154 $291,233 $289,409 Unallocated portfolio-layer cumulative basis adjustments$(72)$93 $ - $ - $ - Corporate loans, net of unearned income(5)$301,386 $300,165 $289,154 $291,233 $289,409 Total loans - net of unearned income$694,488 $689,362 $657,221 $667,767 $675,883 Allowance for credit losses on loans (ACLL)(18,574)(18,145)(16,974)(16,455)(24,956)Total loans - net of unearned income and ACLL$675,914 $671,217 $640,247 $651,312 $650,927 ACLL as a percentage of total loans - net of unearned income(6)2.71 %2.66 %2.60 %2.49 %3.73 %ACLL for consumer loan losses as a percentage of total consumer loans - net of unearned income(6)4.08 %3.97 %3.84 %3.73 %5.22 %ACLL for corporate loan losses as a percentage of total corporate loans - net of unearned income(6)0.87 %0.93 %1.01 %0.85 %1.69 % In North America offices(1) Residential first mortgages(2) Home equity loans(2) In offices outside North America(1) Residential mortgages(2) --- ## Modified: Driving a Culture of Excellence and Accountability **Key changes:** - Reworded sentence: "Citi's talent and culture initiatives focus on fostering a culture of excellence and accountability that is supported by strong risk and controls management." **Prior (2024):** Citi continues to embark on a talent and culture transformation to drive a culture of excellence and accountability that is supported by strong risk and controls management. Citi's Leadership Principles of "taking ownership, delivering with pride and succeeding together" have been reinforced through a behavioral science-led campaign, referred to as Citi's New Way, that reinforces the key working habits that support Citi's leadership culture. Citi's performance management approach also emphasizes the Leadership Principles through a four-pillar system, evaluating colleagues against financial performance, risk and controls, and client and franchise goals as well as how colleagues deliver from a leadership perspective. The performance management and incentive compensation processes and associated policies and frameworks have enhanced accountability through increased rigor and consistency, in particular for risk and controls. The culture shift is supported by changes in the way Citi identifies, assesses, develops and promotes talent, particularly at senior levels of the Company. Citi promotes a new class of managing directors each year. This is a testament to these individuals' performance and commitment to living the Leadership Principles and instilling them throughout their teams and the entire company. Further, all potential successors to Executive Management Team roles are evaluated by the Board and are now subject to a risk and controls assessment. **Current (2025):** Citi's talent and culture initiatives focus on fostering a culture of excellence and accountability that is supported by strong risk and controls management. Citi's Leadership Principles of "taking ownership, delivering with pride and succeeding together" have been reinforced through a behavioral science-led campaign, Citi's New Way, which reinforces the key working habits that support Citi's leadership culture. Citi's performance management approach emphasizes the Leadership Principles through a four-pillar system, evaluating what employees deliver against financial, risk and controls, and client and franchise goals, as well as how employees deliver from a leadership perspective. The performance management and incentive compensation processes, policies and frameworks promote accountability and consistency, in particular for risk and controls. Citi's culture initiatives are also supported by changes in the way Citi identifies, assesses, develops and promotes talent, particularly at the most senior levels of the organization. --- ## Modified: Short-Term Liquidity Measurement: Liquidity Coverage Ratio (LCR) **Key changes:** - Reworded sentence: "31, 2023HQLA$558.4 $551.2 $560.5 Net outflows480.8 469.6 482.7 LCR116 %117 %116 %HQLA in excess of net outflows$77.6 $81.6 $77.8 Note: The amounts are presented on an average basis." - Reworded sentence: "For the quarter ended December 31, 2024, Citigroup's consolidated NSFR was compliant with the 100% minimum requirement of the rule." - Reworded sentence: "EOP cash and investments decreased 5% quarter-over-quarter, primarily driven by reductions in deposits and total long-term debt." - Reworded sentence: "For the quarter ended December 31, 2024, Citigroup's consolidated NSFR was compliant with the 100% minimum requirement of the rule." - Reworded sentence: "EOP cash and investments decreased 5% quarter-over-quarter, primarily driven by reductions in deposits and total long-term debt." **Prior (2024):** 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. The LCR is calculated by dividing HQLA by estimated net outflows assuming a stressed 30-day period, with the net outflows determined by standardized stress outflow and inflow rates prescribed in the LCR rule. The outflows are partially offset by contractual inflows from assets maturing within 30 days. Similar to outflows, the inflows are calculated based on prescribed factors to various asset categories, such as retail loans as well as unsecured and 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, 2023Sept. 30, 2023Dec. 31, 2022HQLA$560.5 $569.3 $575.2 Net outflows482.7 485.3 489.0 LCR116 %117 %118 %HQLA in excess of net outflows$77.8 $84.0 $86.2 Note: The amounts are presented on an average basis. As of December 31, 2023, Citigroup's average LCR decreased from the quarter ended September 30, 2023. The decrease was primarily driven by the reduction in average HQLA. In addition, considering Citi's total available liquidity resources at quarter end of $965 billion, Citi maintained approximately $482 billion of excess liquidity above the stressed average net outflow of approximately $483 billion, shown in the LCR table above. 92 92 92 Long-Term Liquidity Measurement: Net Stable Funding Ratio (NSFR) As previously disclosed, the U.S. banking agencies adopted a rule to assess the availability of a bank's stable funding against a required level. In general, a bank's available stable funding includes portions of equity, deposits and long-term debt, while its required stable funding will be based on the liquidity characteristics of its assets, derivatives and commitments. Standardized weightings are required to be applied to the various asset and liability classes. The ratio of available stable funding to required stable funding is required to be greater than 100%. For the quarter ended December 31, 2023, Citigroup's consolidated NSFR was compliant with the rule. Refer to Citi's U.S. NSFR Disclosure report covering December 31, 2023 and September 30, 2023 on its website for additional information. Select Balance Sheet ItemsThis section provides details of select liquidity-related assets and liabilities reported on Citigroup's Consolidated Balance Sheet on an average and end-of-period basis.Cash and InvestmentsThe table below details average and end-of-period Cash and due from banks, Deposits with banks (collectively cash) and Investment securities. Citi's investment portfolio consists largely of highly liquid U.S. Treasury, U.S. agency and other sovereign bonds, with an aggregate duration of less than three years. At December 31, 2023, Citi's EOP cash and Investment securities comprised approximately 32% of Citigroup's total assets:In billions of dollars4Q233Q234Q22Cash and due from banks$27 $27 $30 Deposits with banks252 260 306 Investment securities516 509 519 Total Citigroup cash and investment securities (AVG)$795 $796 $855 Total Citigroup cash and investment securities (EOP)$780 $763 $869 Deposits The table below details the average deposits, by business and/or segment, and the total Citigroup end-of-period deposits for each of the periods indicated:In billions of dollars4Q233Q234Q22Services$802 $796 $825 TTS 680 676 694 Securities Services122 120 131 Markets and Banking24 25 23 USPB105 110 111 Wealth312 311 320 All Other - Legacy Franchises49 52 50 All Other - Corporate/Other28 21 32 Total Citigroup deposits (AVG)$1,320 $1,315 $1,361 Total Citigroup deposits (EOP)$1,309 $1,274 $1,366 End-of-period deposits decreased 4% year-over-year, largely due to a reduction in Services reflecting quantitative tightening, and a reduction in USPB and Wealth reflecting a shift of deposits to higher-yielding products. End-of-period deposits increased 3% sequentially. On an average basis, deposits declined 3% year-over-year and were largely unchanged sequentially. As of the fourth quarter of 2023, average deposits for: •Services decreased 3% year-over-year, while TTS and Securities Services decreased 2% and 7%, respectively. These declines reflected the impact of quantitative tightening that more than offset deposits from new client acquisitions and deepening of relationships with existing clients. •USPB decreased 5% year-over-year, driven by the transfer of relationships and the associated deposits to Wealth. •Wealth decreased 3% year-over-year, reflecting the continued mix shift of deposits to higher-yielding investments on Citi's platform, partially offset by the benefits of the transfer of certain relationships and the associated deposit balances from USPB. Long-Term Liquidity Measurement: Net Stable Funding Ratio (NSFR) As previously disclosed, the U.S. banking agencies adopted a rule to assess the availability of a bank's stable funding against a required level. In general, a bank's available stable funding includes portions of equity, deposits and long-term debt, while its required stable funding will be based on the liquidity characteristics of its assets, derivatives and commitments. Standardized weightings are required to be applied to the various asset and liability classes. The ratio of available stable funding to required stable funding is required to be greater than 100%. For the quarter ended December 31, 2023, Citigroup's consolidated NSFR was compliant with the rule. Refer to Citi's U.S. NSFR Disclosure report covering December 31, 2023 and September 30, 2023 on its website for additional information. Select Balance Sheet ItemsThis section provides details of select liquidity-related assets and liabilities reported on Citigroup's Consolidated Balance Sheet on an average and end-of-period basis.Cash and InvestmentsThe table below details average and end-of-period Cash and due from banks, Deposits with banks (collectively cash) and Investment securities. Citi's investment portfolio consists largely of highly liquid U.S. Treasury, U.S. agency and other sovereign bonds, with an aggregate duration of less than three years. At December 31, 2023, Citi's EOP cash and Investment securities comprised approximately 32% of Citigroup's total assets:In billions of dollars4Q233Q234Q22Cash and due from banks$27 $27 $30 Deposits with banks252 260 306 Investment securities516 509 519 Total Citigroup cash and investment securities (AVG)$795 $796 $855 Total Citigroup cash and investment securities (EOP)$780 $763 $869 **Current (2025):** 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. The LCR is calculated by dividing HQLA by estimated net outflows assuming a stressed 30-day period, with the net outflows determined by standardized stress outflow and inflow rates prescribed in the LCR rule. The outflows are partially offset by contractual inflows from assets maturing within 30 days. Similar to outflows, the inflows are calculated based on prescribed factors to various asset categories, such as retail loans as well as unsecured and 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, 2024Sept. 30, 2024Dec. 31, 2023HQLA$558.4 $551.2 $560.5 Net outflows480.8 469.6 482.7 LCR116 %117 %116 %HQLA in excess of net outflows$77.6 $81.6 $77.8 Note: The amounts are presented on an average basis. As of December 31, 2024, Citigroup's average LCR decreased from the quarter ended September 30, 2024. The decrease was primarily driven by increased market activity and client lending within Citi's broker-dealer subsidiaries, partially offset by the increase in average HQLA. In addition, considering Citi's total available liquidity resources at quarter end of $933 billion, Citi maintained approximately $452 billion of excess liquidity resources above the stressed average net outflow of approximately $481 billion, presented in the LCR table above. 95 95 95 Long-Term Liquidity Measurement: Net Stable Funding Ratio (NSFR) The NSFR measures the availability of an institution's stable funding against the required stable funding in accordance with a calculation required by the rule. The ratio of available stable funding to required stable funding must be greater than 100%.In general, an institution's available stable funding includes portions of equity, deposits and long-term debt, while its required stable funding is based on the liquidity characteristics of its assets, derivatives and commitments. Standardized weightings are required to be applied to the various asset and liability classes. For the quarter ended December 31, 2024, Citigroup's consolidated NSFR was compliant with the 100% minimum requirement of the rule. (For additional information, see the Consolidated Citigroup NSFR Disclosure for the quarterly periods ended December 31, 2024 and September 30, 2024, on Citi's Investor Relations website. The Consolidated Citigroup NSFR Disclosure on Citi's Investor Relations website is not incorporated by reference into, and does not form any part of, this Form 10-K).Select Balance Sheet ItemsThis section provides details of select liquidity-related assets and liabilities reported on Citigroup's Consolidated Balance Sheet.Cash and InvestmentsThe table below details average and end-of-period Cash and due from banks, Deposits with banks (collectively cash) and Investment securities. Citi's investment securities portfolio consists largely of highly liquid U.S. Treasury, U.S. agency and other sovereign bonds, with an aggregate duration of less than three years. EOP cash and investments decreased 5% quarter-over-quarter, primarily driven by reductions in deposits and total long-term debt. At December 31, 2024, Citi's EOP cash and Investment securities comprised approximately 32% of total assets:In billions of dollars4Q243Q244Q23Cash and due from banks$30 $26 $27 Deposits with banks284 266 252 Investment securities484 500 516 Total Citigroup cash and investment securities (AVG)$798 $792 $795 Total Citigroup cash and investment securities (EOP)$753 $794 $780 Deposits The table below details the average deposits, by segment and/or business, and the total Citigroup end-of-period deposits for each of the periods indicated:In billions of dollars4Q243Q244Q23Services$839 $825 $803 TTS 704 690 681 Securities Services135 135 122 Markets(1)15 19 23 Banking1 1 1 Wealth315 316 307 USPB86 85 105 All Other - Legacy Franchises42 45 52 All Other - Corporate/Other(1)22 20 29 Total Citigroup deposits (AVG)$1,320 $1,311 $1,320 Total Citigroup deposits (EOP)$1,284 $1,310 $1,309 (1) During the third quarter of 2024, approximately $9 billion of institutional deposits were moved from Markets to All Other - Corporate/Other. Prior periods were not reclassified. For additional information about the reallocated deposits, see Note 3.Citi's deposit base is spread across a diversified set of countries, industries, clients and currencies and is subject to Citi's Liquidity Risk Management Policy and Procedures. End-of-period deposits decreased 2% year-over-year, primarily driven by declines in Legacy Franchises, reflecting the continued wind-downs, the impact of FX translation and reductions of corporate certificates of deposit in Corporate/Other. End-of-period deposits decreased 2% sequentially, primarily driven by temporary reductions at year end in Services.On an average basis, deposits were relatively flat year-over-year and increased 1% sequentially, primarily driven by Services. In the fourth quarter of 2024, average deposits for:•Services increased 4% year-over-year, as TTS increased 3% due to deepened client relationships and growth in operational deposits, and Securities Services increased 11% driven by AUC growth.•USPB decreased 18% year-over-year, as the transfer of certain relationships and the associated deposits to Wealth more than offset underlying deposit growth.•Wealth increased 3% year-over-year, largely reflecting the transfer of certain relationships and the associated deposits from USPB, partially offset by the shift in deposits to higher-yielding investments on Citi's platform.•All Other decreased 21% year-over-year, primarily reflecting the continued wind-downs, the impact of FX translation of deposits in Legacy Franchises and reductions of corporate certificates of deposit in Corporate/Other. Long-Term Liquidity Measurement: Net Stable Funding Ratio (NSFR) The NSFR measures the availability of an institution's stable funding against the required stable funding in accordance with a calculation required by the rule. The ratio of available stable funding to required stable funding must be greater than 100%.In general, an institution's available stable funding includes portions of equity, deposits and long-term debt, while its required stable funding is based on the liquidity characteristics of its assets, derivatives and commitments. Standardized weightings are required to be applied to the various asset and liability classes. For the quarter ended December 31, 2024, Citigroup's consolidated NSFR was compliant with the 100% minimum requirement of the rule. (For additional information, see the Consolidated Citigroup NSFR Disclosure for the quarterly periods ended December 31, 2024 and September 30, 2024, on Citi's Investor Relations website. The Consolidated Citigroup NSFR Disclosure on Citi's Investor Relations website is not incorporated by reference into, and does not form any part of, this Form 10-K).Select Balance Sheet ItemsThis section provides details of select liquidity-related assets and liabilities reported on Citigroup's Consolidated Balance Sheet.Cash and InvestmentsThe table below details average and end-of-period Cash and due from banks, Deposits with banks (collectively cash) and Investment securities. Citi's investment securities portfolio consists largely of highly liquid U.S. Treasury, U.S. agency and other sovereign bonds, with an aggregate duration of less than three years. EOP cash and investments decreased 5% quarter-over-quarter, primarily driven by reductions in deposits and total long-term debt. At December 31, 2024, Citi's EOP cash and Investment securities comprised approximately 32% of total assets:In billions of dollars4Q243Q244Q23Cash and due from banks$30 $26 $27 Deposits with banks284 266 252 Investment securities484 500 516 Total Citigroup cash and investment securities (AVG)$798 $792 $795 Total Citigroup cash and investment securities (EOP)$753 $794 $780 --- ## Modified: 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. **Key changes:** - Removed sentence: "See Note 1 for additional information on Citi's accounting policies and changes in accounting, including the expected impacts on Citi's results of operations and financial condition.If Citi's Risk Management and Other Processes, Strategies or Models Are Deficient or Ineffective, Citi May Incur Significant Losses and Its Regulatory Capital and Capital Ratios Could Be Negatively Impacted.Citi utilizes a broad and diversified set of risk management and other processes and strategies, including the use of models in analyzing and monitoring the various risks Citi assumes in conducting its activities." - Removed sentence: "For example, Citi uses models as part of its comprehensive stress testing initiatives across the Company." - Removed sentence: "Citi also relies on data to aggregate, assess and manage various risk exposures." - Removed sentence: "Management of these risks and the reliability of the data are made more challenging within a large, global financial institution, such as Citi, particularly due to complex, diverse and rapidly changing financial markets and conditions in which Citi operates." - Removed sentence: "Unexpected losses can result from untimely, inaccurate or incomplete processes and data." **Prior (2024):** 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, the SEC, U.S. banking regulators or others, 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 Note 1 for additional information on Citi's accounting policies and changes in accounting, including the expected impacts on Citi's results of operations and financial condition.If Citi's Risk Management and Other Processes, Strategies or Models Are Deficient or Ineffective, Citi May Incur Significant Losses and Its Regulatory Capital and Capital Ratios Could Be Negatively Impacted.Citi utilizes a broad and diversified set of risk management and other processes and strategies, including the use of models in analyzing and monitoring the various risks Citi assumes in conducting its activities. For example, Citi uses models as part of its comprehensive stress testing initiatives across the Company. Citi also relies on data to aggregate, assess and manage various risk exposures. Management of these risks and the reliability of the data are made more challenging within a large, global financial institution, such as Citi, particularly due to complex, diverse and rapidly changing financial markets and conditions in which Citi operates. Unexpected losses can result from untimely, inaccurate or incomplete processes and data. As discussed below, 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 and other 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, particularly given various macroeconomic, geopolitical and other challenges and uncertainties (see the macroeconomic challenges and uncertainties risk factor above), nor can they anticipate the specifics and timing of such outcomes. For example, many models used by Citi include assumptions about correlation or lack thereof among prices of various asset classes or other market indicators that may not necessarily hold in times of market stress, limited liquidity or other unforeseen circumstances, or identify changes in markets or client behaviors not yet inherent in historical data. Citi could incur significant losses, receivenegative regulatory evaluation or examination findings or besubject to additional enforcement actions, and its regulatory capital, capital ratios and ability to return capital could be negatively impacted, if Citi's risk management and other processes, including its ability to manage and aggregate data in a timely and accurate manner, strategies or models are deficient or ineffective. For additional information, see the capital return risk factor above and the heightened regulatory reporting standards or interpretations, whether promulgated or required by the FASB, the SEC, U.S. banking regulators or others, 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 Note 1 for additional information on Citi's accounting policies and changes in accounting, including the expected impacts on Citi's results of operations and financial condition. **Current (2025):** 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, the SEC, U.S. banking regulators or others, 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 Note 1 for additional information on Citi's accounting policies and changes in accounting, including the expected impacts on Citi's results of operations and financial condition. --- ## Modified: 2024 vs. 2023 **Key changes:** - Reworded sentence: "2022 Interest income(1) Interest expense(2) Net interest income, taxable equivalent basis(1) Interest income - average rate(3) Net interest margin(3)(4) (1)Interest income and Net interest income include the taxable equivalent gross-up adjustments (TEGU) primarily related to the tax-exempt bond portfolio and certain tax-advantaged loan programs of $94 million, $101 million and $165 million for 2024, 2023 and 2022, respectively." - Reworded sentence: "(3) The average rate on interest income and NIM reflects TEGU." - Reworded sentence: "(4) Citi's NIM is calculated by dividing net interest income (including TEGU) by average interest-earning assets." **Prior (2024):** Change 2022 vs. 2021 Interest income(1) Interest expense(2) Net interest income, taxable equivalent basis(1) Interest income - average rate(3) Net interest margin(3)(4) (1)Interest income and Net interest income include the taxable equivalent adjustments primarily related to the tax-exempt bond portfolio and certain tax-advantaged loan programs of $101 million, $165 million and $192 million for 2023, 2022 and 2021, 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) The average rate on interest income and net interest margin reflects the taxable equivalent gross-up adjustment. See footnote 1 above. (4) Citi's NIM is calculated by dividing net interest income by average interest-earning assets. 104 104 104 **Current (2025):** Change 2023 vs. 2022 Interest income(1) Interest expense(2) Net interest income, taxable equivalent basis(1) Interest income - average rate(3) Net interest margin(3)(4) (1)Interest income and Net interest income include the taxable equivalent gross-up adjustments (TEGU) primarily related to the tax-exempt bond portfolio and certain tax-advantaged loan programs of $94 million, $101 million and $165 million for 2024, 2023 and 2022, 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) The average rate on interest income and NIM reflects TEGU. See footnote 1 above. (4) Citi's NIM is calculated by dividing net interest income (including TEGU) by average interest-earning assets. 106 106 106 --- ## Modified: Exposure to Commercial Real Estate **Key changes:** - Reworded sentence: "As of December 31, 2024 and 2023, Citi's total credit exposure to commercial real estate (CRE) was $65 billion and $66 billion, including $6 billion and $8 billion of exposure related to office buildings, respectively." - Reworded sentence: "Of the $35.9 billion of purchased credit protection, $33.7 billion represents the total notional amount of purchased credit derivatives on individual reference entities." - Reworded sentence: "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, 2024, September 30, 2024 and December 31, 2023, Banking had economic hedges on the corporate credit portfolio of $37.8 billion, $39.7 billion and $35.9 billion, respectively." - Reworded sentence: "The credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution:Rating of Hedged ExposureDecember 31,2024September 30,2024December 31,2023AAA/AA/A44 %44 %45 %BBB45 47 44 BB/B10 8 10 CCC or below1 1 1 Total100 %100 %100 % Credit Risk MitigationAs part of its overall risk management activities, Citigroup uses credit derivatives, both partial and full term, and other risk mitigants to economically hedge portions of the credit risk in its corporate credit portfolio, in addition to outright asset sales." - Reworded sentence: "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, 2024, September 30, 2024 and December 31, 2023, Banking had economic hedges on the corporate credit portfolio of $37.8 billion, $39.7 billion and $35.9 billion, respectively." **Prior (2024):** As of December 31, 2023, Citi's total credit exposure to commercial real estate (CRE) was $66 billion, including $8 billion of exposure related to office buildings. This total CRE exposure consisted of approximately $55 billion related to corporate clients, included in the real estate category in the table above, and approximately $11 billion related to Wealth clients that is not in the table above as they are not considered corporate exposures. In addition, as of December 31, 2023, approximately 80% of Citi's total CRE exposure was rated investment grade and more than 77% was to borrowers in the U.S.As of December 31, 2023, the ACLL attributed to the total funded CRE exposure (including the Private Bank) was approximately 1.49%, and there were $759 million of non-accrual CRE loans. In addition, as of December 31, 2023, approximately 80% of Citi's total CRE exposure was rated investment grade and more than 77% was to borrowers in the U.S. As of December 31, 2023, the ACLL attributed to the total funded CRE exposure (including the Private Bank) was approximately 1.49%, and there were $759 million of non-accrual CRE loans. 72 72 72 The following table details Citi's corporate credit portfolio by industry as of December 31, 2022: Non-investment gradeSelected metricsIn millions of dollarsTotal credit exposureFunded(1)UnfundedInvestment gradeNon-criticizedCriticized performingCriticized non-performing(2)30 days or more past due and accruingNet credit losses (recoveries)Credit derivative hedges(3)Transportation and industrials$139,225 $57,271 $81,954 $109,197 $19,697 $9,850 $481 $403 $ - $(8,459)Autos(4)47,482 21,995 25,487 40,795 5,171 1,391 125 52 - (3,084)Transportation24,843 10,374 14,469 18,078 3,156 3,444 165 57 (30)(1,270)Industrials66,900 24,902 41,998 50,324 11,370 5,015 191 294 30 (4,105)Technology, media and telecom81,211 28,931 52,280 65,386 12,308 3,308 209 169 11 (6,050)Banks and finance companies65,623 42,276 23,347 57,368 5,718 2,387 150 266 65 (1,113)Consumer retail78,255 32,687 45,568 60,215 14,830 2,910 300 195 28 (5,395)Real estate70,676 48,539 22,137 63,023 4,722 2,881 50 138 2 (739)Commercial54,139 34,112 20,027 46,670 4,716 2,703 50 96 2 (739)Residential16,537 14,427 2,110 16,353 6 178 - 42 - - Power, chemicals, metals and mining59,404 18,326 41,078 47,395 10,466 1,437 106 226 34 (5,063)Power22,718 4,827 17,891 18,822 3,325 512 59 129 (3)(2,306)Chemicals23,147 7,765 15,382 19,033 3,534 564 16 55 30 (2,098)Metals and mining13,539 5,734 7,805 9,540 3,607 361 31 42 7 (659)Energy and commodities(5)46,309 13,069 33,240 38,918 6,076 1,200 115 180 11 (3,852)Health41,836 8,771 33,065 36,954 3,737 978 167 84 7 (2,855)Insurance29,932 4,417 25,515 29,090 801 41 - 44 - (3,884)Public sector23,705 11,736 11,969 20,663 2,084 956 2 77 4 (1,633)Asset managers and funds35,983 13,162 22,821 34,431 1,492 60 - 95 - (759)Financial markets infrastructure8,742 60 8,682 8,672 70 - - - - (18)Securities firms1,462 569 893 625 678 157 2 2 - (2)Other industries(6)7,374 4,217 3,157 4,842 2,245 238 49 19 16 (8)Total$689,737 $284,031 $405,706 $576,779 $84,924 $26,403 $1,631 $1,898 $178 $(39,830) Funded(1) Criticized non-performing(2) Credit derivative hedges(3) Autos(4) Energy and commodities(5) Other industries(6) (1) Funded excludes loans carried at fair value of $5.1 billion at December 31, 2022. (2) Includes non-accrual loan exposures and related criticized unfunded exposures. (3) Represents the amount of purchased credit protection in the form of derivatives to economically hedge funded and unfunded exposures. Of the $39.8 billion of purchased credit protection, $36.6 billion represents the total notional amount of purchased credit derivatives on individual reference entities. The remaining $3.2 billion represents the first loss tranche of portfolios of purchased credit derivatives with a total notional of $27.6 billion, where the protection seller absorbs the first loss on the referenced loan portfolios. (4) 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 $17.4 billion ($10.3 billion in funded, with more than 99% rated investment grade) at December 31, 2022. (5) 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, 2022, Citi's total exposure to these energy-related entities was approximately $4.7 billion, of which approximately $2.4 billion consisted of direct outstanding funded loans. (6) Includes $0.6 billion and $0.1 billion of funded and unfunded exposure at December 31, 2022, respectively, primarily related to commercial credit card delinquency-managed loans. 73 73 73 Credit Risk MitigationAs part of its overall risk management activities, Citigroup uses credit derivatives, both partial and full term, and other risk mitigants to economically hedge portions of the credit risk in its corporate credit portfolio, in addition to outright asset sales. In advance of the expiration of partial-term economic 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, 2023, September 30, 2023 and December 31, 2022, Banking had economic hedges on the corporate credit portfolio of $35.9 billion, $36.0 billion and $39.8 billion, respectively. Citi's expected credit loss model used in the calculation of its ACL does not include the favorable impact of credit derivatives and other mitigants that are marked-to-market. In addition, the reported amounts of direct outstandings and unfunded lending commitments in the tables above do not reflect the impact of these hedging transactions. The credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution:Rating of Hedged ExposureDecember 31,2023September 30,2023December 31,2022AAA/AA/A45 %45 %39 %BBB44 43 45 BB/B10 10 12 CCC or below1 2 4 Total100 %100 %100 % Credit Risk MitigationAs part of its overall risk management activities, Citigroup uses credit derivatives, both partial and full term, and other risk mitigants to economically hedge portions of the credit risk in its corporate credit portfolio, in addition to outright asset sales. In advance of the expiration of partial-term economic 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, 2023, September 30, 2023 and December 31, 2022, Banking had economic hedges on the corporate credit portfolio of $35.9 billion, $36.0 billion and $39.8 billion, respectively. Citi's expected credit loss model used in the calculation of its ACL does not include the favorable impact of credit derivatives and other mitigants that are marked-to-market. In addition, the reported amounts of direct outstandings and unfunded lending commitments in the tables above do not reflect the impact of these hedging transactions. The credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution:Rating of Hedged ExposureDecember 31,2023September 30,2023December 31,2022AAA/AA/A45 %45 %39 %BBB44 43 45 BB/B10 10 12 CCC or below1 2 4 Total100 %100 %100 % **Current (2025):** As of December 31, 2024 and 2023, Citi's total credit exposure to commercial real estate (CRE) was $65 billion and $66 billion, including $6 billion and $8 billion of exposure related to office buildings, respectively. This total CRE exposure consisted of approximately $56 billion and $55 billion, respectively, related to corporate clients, included in the real estate category in the tables above and below. Total CRE exposure also includes approximately $9 billion and $11 billion, respectively, related to Wealth clients that is not in the tables as they are not considered corporate exposures. In addition, as of December 31, 2024, approximately 78% of Citi's total CRE exposure was rated investment grade and more than 75% was to borrowers in the U.S (compared to approximately 80% rated investment grade and more than 77% to borrowers in the U.S. as of December 31, 2023).As of December 31, 2024, the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.60%, and there were $574 million of non-accrual CRE loans. As of December 31, 2023, the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.49%, and there were $759 million of non-accrual CRE loans. In addition, as of December 31, 2024, approximately 78% of Citi's total CRE exposure was rated investment grade and more than 75% was to borrowers in the U.S (compared to approximately 80% rated investment grade and more than 77% to borrowers in the U.S. as of December 31, 2023). As of December 31, 2024, the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.60%, and there were $574 million of non-accrual CRE loans. As of December 31, 2023, the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.49%, and there were $759 million of non-accrual CRE loans. 75 75 75 The following table details Citi's corporate credit portfolio by industry as of December 31, 2023: Non-investment gradeSelected metricsIn millions of dollarsTotal credit exposureFunded(1)UnfundedInvestment gradeNon-criticizedCriticized performingCriticized non-performing(2)30 days or more past due and accruingNet credit losses (recoveries)Credit derivative hedges(3)Transportation and industrials$149,429 $59,917 $89,512 $118,380 $26,345 $4,469 $235 $125 $39 $(7,060)Autos(4)49,443 22,843 26,600 43,008 5,376 999 60 7 19 (2,304)Transportation28,448 11,996 16,452 21,223 6,208 952 65 3 5 (1,185)Industrials71,538 25,078 46,460 54,149 14,761 2,518 110 115 15 (3,571)Technology, media and telecom84,409 29,832 54,577 67,077 13,637 3,212 483 112 56 (5,546)Banks and finance companies83,512 52,569 30,943 74,364 7,768 1,277 103 7 37 (638)Consumer retail81,799 33,548 48,251 63,017 15,259 3,342 181 130 57 (5,360)Real estate72,827 51,660 21,167 61,226 7,084 3,602 915 69 31 (608)Commercial54,843 35,058 19,785 43,340 7,042 3,602 859 69 31 (608)Residential17,984 16,602 1,382 17,886 42 - 56 - - - Power, chemicals, metals and mining59,572 19,004 40,568 46,551 10,098 2,696 227 36 4 (4,884)Power24,535 5,220 19,315 20,967 3,200 209 159 1 4 (2,280)Chemicals21,963 8,287 13,676 16,418 3,888 1,613 44 34 1 (2,019)Metals and mining13,074 5,497 7,577 9,166 3,010 874 24 1 (1)(585)Energy and commodities(5)46,290 12,606 33,684 40,081 5,528 543 138 5 (15)(3,090)Health36,230 9,135 27,095 30,099 4,871 1,098 162 16 22 (3,023)Insurance27,216 2,390 24,826 25,580 1,607 29 - 7 - (4,516)Public sector24,736 12,621 12,115 21,845 2,399 479 13 36 15 (1,092)Asset managers and funds19,681 4,232 15,449 17,826 1,723 112 20 4 - (65)Financial markets infrastructure18,705 156 18,549 18,705 - - - - - (7)Securities firms1,737 734 1,003 870 822 45 - 2 - (2)Other industries(6)6,992 4,480 2,512 5,079 1,629 257 27 45 4 (6)Total$713,135 $292,884 $420,251 $590,700 $98,770 $21,161 $2,504 $594 $250 $(35,897) Funded(1) Criticized non-performing(2) Credit derivative hedges(3) Autos(4) Energy and commodities(5) Other industries(6) (1) Funded excludes loans carried at fair value of $7.3 billion at December 31, 2023. (2) Includes non-accrual loan exposures and related criticized unfunded exposures. (3) Represents the amount of purchased credit protection in the form of derivatives to economically hedge funded and unfunded exposures. Of the $35.9 billion of purchased credit protection, $33.7 billion represents the total notional amount of purchased credit derivatives on individual reference entities. The remaining $2.2 billion represents the first loss tranche of portfolios of purchased credit derivatives with a total notional amount of $16.7 billion, where the protection seller absorbs the first loss on the referenced loan portfolios. (4) 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 $16.9 billion ($10.6 billion of which was funded exposure with 100% rated investment grade) as of December 31, 2023. (5) 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., offshore drilling entities) included in the table above. As of December 31, 2023, Citi's total exposure to these energy-related entities was approximately $4.9 billion, of which approximately $2.5 billion consisted of direct outstanding funded loans. (6) Includes $0.6 billion and $0.1 billion of funded and unfunded exposure at December 31, 2023, respectively, primarily related to commercial credit card delinquency-managed loans. 76 76 76 Credit Risk MitigationAs part of its overall risk management activities, Citigroup uses credit derivatives, both partial and full term, and other risk mitigants to economically hedge portions of the credit risk in its corporate credit portfolio, in addition to outright asset sales. In advance of the expiration of partial-term economic 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, 2024, September 30, 2024 and December 31, 2023, Banking had economic hedges on the corporate credit portfolio of $37.8 billion, $39.7 billion and $35.9 billion, respectively. Citi's expected credit loss model used in the calculation of its ACL does not include the favorable impact of credit derivatives and other mitigants that are marked-to-market. In addition, the reported amounts of direct outstandings and unfunded lending commitments in the tables above do not reflect the impact of these hedging transactions. The credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution:Rating of Hedged ExposureDecember 31,2024September 30,2024December 31,2023AAA/AA/A44 %44 %45 %BBB45 47 44 BB/B10 8 10 CCC or below1 1 1 Total100 %100 %100 % Credit Risk MitigationAs part of its overall risk management activities, Citigroup uses credit derivatives, both partial and full term, and other risk mitigants to economically hedge portions of the credit risk in its corporate credit portfolio, in addition to outright asset sales. In advance of the expiration of partial-term economic 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, 2024, September 30, 2024 and December 31, 2023, Banking had economic hedges on the corporate credit portfolio of $37.8 billion, $39.7 billion and $35.9 billion, respectively. Citi's expected credit loss model used in the calculation of its ACL does not include the favorable impact of credit derivatives and other mitigants that are marked-to-market. In addition, the reported amounts of direct outstandings and unfunded lending commitments in the tables above do not reflect the impact of these hedging transactions. The credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution:Rating of Hedged ExposureDecember 31,2024September 30,2024December 31,2023AAA/AA/A44 %44 %45 %BBB45 47 44 BB/B10 8 10 CCC or below1 1 1 Total100 %100 %100 % --- ## Modified: Non-Markets Net Interest Income **Key changes:** - Reworded sentence: "In millions of dollars202420232022Net interest income - taxable equivalent basis(1) per above$54,189 $55,001 $48,833 Markets net interest income - taxable equivalent basis(1)7,099 7,334 5,933 Non-Markets net interest income - taxable equivalent basis(1)$47,090 $47,667 $42,900 Net interest income - taxable equivalent basis(1) per above Markets net interest income - taxable equivalent basis(1) Non-Markets net interest income - taxable equivalent basis(1) (1) Interest income and Net interest income include TEGU discussed in the table above." **Prior (2024):** In millions of dollars202320222021Net interest income - taxable equivalent basis(1) per above$55,001 $48,833 $42,686 Markets net interest income - taxable equivalent basis(1)7,267 5,828 6,153 Non-Markets net interest income - taxable equivalent basis(1)$47,734 $43,005 $36,533 Net interest income - taxable equivalent basis(1) per above Markets net interest income - taxable equivalent basis(1) Non-Markets net interest income - taxable equivalent basis(1) (1) Interest income and Net interest income include the taxable equivalent adjustments discussed in the table above. Citi's net interest income in the fourth quarter of 2023 was $13.8 billion, on both a reported and taxable equivalent basis, an increase of $0.6 billion versus the prior year, primarily driven by Markets (up approximately $0.4 billion) and non-Markets (up approximately $0.1 billion). The increase in Markets net interest income was primarily driven by Fixed Income. The increase in non-Markets primarily reflected higher interest rates and growth in U.S. cards interest-earning balances, partially offset by a reduction from the exited markets and continued wind-downs in All Other - Legacy Franchises. Citi's net interest margin was 2.46% on a taxable equivalent basis in the fourth quarter of 2023, a decrease of three basis points from the prior quarter, largely driven by higher deposit costs, partially offset by higher Markets net interest margin.Citi's net interest income for 2023 increased 13%, or approximately $6.2 billion, to $54.9 billion ($55.0 billion on a taxable equivalent basis) versus the prior year. The increase was primarily due to an increase in non-Markets net interest income, largely reflecting higher interest rates and higher loan balances in USPB. In 2023, Citi's net interest margin increased to 2.46% on a taxable equivalent basis, compared to 2.25% in 2022, primarily driven by higher interest rates and a mix-shift in balances. Citi's net interest income in the fourth quarter of 2023 was $13.8 billion, on both a reported and taxable equivalent basis, an increase of $0.6 billion versus the prior year, primarily driven by Markets (up approximately $0.4 billion) and non-Markets (up approximately $0.1 billion). The increase in Markets net interest income was primarily driven by Fixed Income. The increase in non-Markets primarily reflected higher interest rates and growth in U.S. cards interest-earning balances, partially offset by a reduction from the exited markets and continued wind-downs in All Other - Legacy Franchises. Citi's net interest margin was 2.46% on a taxable equivalent basis in the fourth quarter of 2023, a decrease of three basis points from the prior quarter, largely driven by higher deposit costs, partially offset by higher Markets net interest margin.Citi's net interest income for 2023 increased 13%, or approximately $6.2 billion, to $54.9 billion ($55.0 billion on a taxable equivalent basis) versus the prior year. The increase was primarily due to an increase in non-Markets net interest income, largely reflecting higher interest rates and higher loan balances in USPB. In 2023, Citi's net interest margin increased to 2.46% on a taxable equivalent basis, compared to 2.25% in 2022, primarily driven by higher interest rates and a mix-shift in balances. Citi's net interest income in the fourth quarter of 2023 was $13.8 billion, on both a reported and taxable equivalent basis, an increase of $0.6 billion versus the prior year, primarily driven by Markets (up approximately $0.4 billion) and non-Markets (up approximately $0.1 billion). The increase in Markets net interest income was primarily driven by Fixed Income. The increase in non-Markets primarily reflected higher interest rates and growth in U.S. cards interest-earning balances, partially offset by a reduction from the exited markets and continued wind-downs in All Other - Legacy Franchises. Citi's net interest margin was 2.46% on a taxable equivalent basis in the fourth quarter of 2023, a decrease of three basis points from the prior quarter, largely driven by higher deposit costs, partially offset by higher Markets net interest margin. Citi's net interest income for 2023 increased 13%, or approximately $6.2 billion, to $54.9 billion ($55.0 billion on a taxable equivalent basis) versus the prior year. The increase was primarily due to an increase in non-Markets net interest income, largely reflecting higher interest rates and higher loan balances in USPB. In 2023, Citi's net interest margin increased to 2.46% on a taxable equivalent basis, compared to 2.25% in 2022, primarily driven by higher interest rates and a mix-shift in balances. 105 105 105 **Current (2025):** In millions of dollars202420232022Net interest income - taxable equivalent basis(1) per above$54,189 $55,001 $48,833 Markets net interest income - taxable equivalent basis(1)7,099 7,334 5,933 Non-Markets net interest income - taxable equivalent basis(1)$47,090 $47,667 $42,900 Net interest income - taxable equivalent basis(1) per above Markets net interest income - taxable equivalent basis(1) Non-Markets net interest income - taxable equivalent basis(1) (1) Interest income and Net interest income include TEGU discussed in the table above. Citi's net interest income in the fourth quarter of 2024 was $13.7 billion on a reported basis and $13.8 billion on a taxable equivalent basis, a decrease of $0.1 billion from the prior-year period, primarily driven by Markets (down approximately $0.1 billion), partially offset by non-Markets (up approximately $0.04 billion). The decline in Markets net interest income was primarily driven by higher funding costs related to trading inventory in Fixed Income Markets.The increase in non-Markets net interest income was largely due to loan growth in cards in USPB and maturing assets in Citi's securities portfolio being reinvested at higher yields, partially offset by net investment securities losses reflecting the repositioning of the investment securities portfolio.Citi's net interest margin was 2.42% on a taxable equivalent basis in the fourth quarter of 2024, an increase of nine basis points from the prior quarter, largely driven by higher Markets net interest margin. Citi's net interest income for 2024 decreased 1%, or approximately $0.8 billion, to $54.1 billion ($54.2 billion on a taxable equivalent basis) versus the prior year. The decrease was primarily due to a decrease in non-Markets net interest income, largely driven by higher funding costs in the mortgage-backed securities portfolio in Corporate Treasury within All Other and lower revenue from Citi's net investment in Argentina, partially offset by growth in USPB and Wealth. In 2024, Citi's net interest margin decreased to 2.40% on a taxable equivalent basis, compared to 2.46% in 2023, primarily driven by lower revenue from Citi's net investment in Argentina and higher funding cost. Citi's net interest income in the fourth quarter of 2024 was $13.7 billion on a reported basis and $13.8 billion on a taxable equivalent basis, a decrease of $0.1 billion from the prior-year period, primarily driven by Markets (down approximately $0.1 billion), partially offset by non-Markets (up approximately $0.04 billion). The decline in Markets net interest income was primarily driven by higher funding costs related to trading inventory in Fixed Income Markets.The increase in non-Markets net interest income was largely due to loan growth in cards in USPB and maturing assets in Citi's securities portfolio being reinvested at higher yields, partially offset by net investment securities losses reflecting the repositioning of the investment securities portfolio.Citi's net interest margin was 2.42% on a taxable equivalent basis in the fourth quarter of 2024, an increase of nine basis points from the prior quarter, largely driven by higher Markets net interest margin. Citi's net interest income for 2024 decreased 1%, or approximately $0.8 billion, to $54.1 billion ($54.2 billion on a taxable equivalent basis) versus the prior year. The decrease was primarily due to a decrease in non-Markets net interest income, largely driven by higher funding costs in the mortgage-backed securities portfolio in Corporate Treasury within All Other and lower revenue from Citi's net investment in Argentina, partially offset by growth in USPB and Wealth. In 2024, Citi's net interest margin decreased to 2.40% on a taxable equivalent basis, compared to 2.46% in 2023, primarily driven by lower revenue from Citi's net investment in Argentina and higher funding cost. Citi's net interest income in the fourth quarter of 2024 was $13.7 billion on a reported basis and $13.8 billion on a taxable equivalent basis, a decrease of $0.1 billion from the prior-year period, primarily driven by Markets (down approximately $0.1 billion), partially offset by non-Markets (up approximately $0.04 billion). The decline in Markets net interest income was primarily driven by higher funding costs related to trading inventory in Fixed Income Markets. The increase in non-Markets net interest income was largely due to loan growth in cards in USPB and maturing assets in Citi's securities portfolio being reinvested at higher yields, partially offset by net investment securities losses reflecting the repositioning of the investment securities portfolio. Citi's net interest margin was 2.42% on a taxable equivalent basis in the fourth quarter of 2024, an increase of nine basis points from the prior quarter, largely driven by higher Markets net interest margin. Citi's net interest income for 2024 decreased 1%, or approximately $0.8 billion, to $54.1 billion ($54.2 billion on a taxable equivalent basis) versus the prior year. The decrease was primarily due to a decrease in non-Markets net interest income, largely driven by higher funding costs in the mortgage-backed securities portfolio in Corporate Treasury within All Other and lower revenue from Citi's net investment in Argentina, partially offset by growth in USPB and Wealth. In 2024, Citi's net interest margin decreased to 2.40% on a taxable equivalent basis, compared to 2.46% in 2023, primarily driven by lower revenue from Citi's net investment in Argentina and higher funding cost. 107 107 107 --- ## Modified: Citi's Performance and Its Ability to Effectively Execute Its Transformation, Simplification and Other Priorities Could Be Negatively Impacted if It Is Not Able to Hire and Retain Qualified Employees. **Key changes:** - Reworded sentence: "Citi's performance and the performance of its individual businesses largely depend on the talents and efforts of its diverse and highly qualified employees." - Reworded sentence: "Certain competitors may be subject to different and, in some cases, less stringent legal, regulatory and supervisory requirements, whether due to size, jurisdiction, entity type or other factors, placing Citi at a competitive disadvantage." - Reworded sentence: "Clients and investors have shown increased interest in these technologies, prompting financial services firms and other market participants to develop related products and services." **Prior (2024):** Citi's performance and the performance of its individual businesses largely depend on the talents and efforts of its diverse and highly qualified colleagues. Specifically, Citi's continued ability to compete in each of its lines of business, to manage its businesses effectively and to execute its transformation and strategic and other initiatives, including, for example, hiring front office colleagues to grow businesses or hiring colleagues to support Citi's transformation and strategic and other initiatives, depends on its ability to attract new colleagues and to retain and motivate its existing colleagues. If Citi is unable to continue to attract, retain and motivate highly qualified colleagues, Citi's performance, including its competitive position, the execution of its transformation and strategic and other initiatives and its results of operations could be negatively impacted. Citi's ability to attract, retain and motivate colleagues depends on numerous factors, some of which are outside of Citi's control. For example, the competition for talent continues to be particularly intense due to factors such as low unemployment and changes in worker expectations, concerns and preferences, including an increased demand for remote work options and other job flexibility. Also, the banking industry generally is subject to more comprehensive regulation of employee compensation than other industries, including deferral and clawback requirements for incentive compensation, which can make it unusually challenging for Citi to compete in labor markets against businesses, including, for example, technology companies, that are not subject to 53 53 53 such regulation. In addition, in 2023 Citi announced plans to reduce management layers from 13 to a median of eight as part of organizational simplification initiatives that also involve significant reductions in functional roles, which could also impact its ability to attract and retain colleagues. Other factors that could impact its ability to attract, retain and motivate colleagues include, among other things, Citi's presence in a particular market or region, the professional and development opportunities, its reputation and its diversity. For information on Citi's colleagues and workforce management, see "Human Capital Resources and Management" below.Citi Faces Increased Competitive Challenges, Including from Financial Services and Other Companies and Emerging Technologies.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, private credit and 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. Certain competitors may be subject to different and, in some cases, less stringent legal and regulatory requirements, whether due to size, jurisdiction, entity type or other factors, placing Citi at a competitive disadvantage.For example, Citi competes with other financial services companies in the U.S. and globally that have grown rapidly over the last several years or have developed and introduced new products and services. Potential mergers and acquisitions involving traditional financial services companies such as regional banks or credit card issuers, as well as networks and merchant acquirers, may also increase competition and impact Citi's ability to offer competitive pricing and rewards. Non-traditional financial services firms, such as private credit and financial technology companies, are less regulated and continue to expand their offerings of services traditionally provided by financial institutions. The growth of certain of these competitors has increased market and counterparty credit risks, particularly in a more challenging macroeconomic environment (see the risk factor on credit and concentrations of risk below). In addition, emerging technologies have the potential to intensify competition and accelerate disruption in the financial services industry. For example, despite difficulties and turmoil faced by the digital asset market in recent years, clients and investors have exhibited a sustained interest in digital assets. Financial services firms and other market participants have begun to offer services related to those assets. Citi may not be able to provide the same or similar services for legal or regulatory reasons, which may be exacerbated by rapidly evolving and conflicting regulatory requirements, and due to increased compliance and other risks. Further, 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. Increased competition and emerging technologies have required and could require Citi to change or adapt its products and services, as well as invest in and develop related infrastructure, 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, failure to strategically embrace the potential of artificial intelligence (AI) may result in a competitive disadvantage to Citi. At the same time, as a new technology, use of AI without sufficient controls, governance and risk management may result in increased risks across all of Citi's risk categories. As another example, instant and 24x7 payments products could be accompanied by challenges to forecasting and managing liquidity, as well as increased operational and compliance risks. Moreover, Citi relies on third parties to support certain of its product and service offerings, which may put Citi at a disadvantage to competitors who may directly offer a broader array of products and services. Also, Citi's businesses, results of operations and reputation may suffer if any third party is unable to provide adequate support for such product and service offerings, whether due to operational incidents or otherwise (see the operational processes and systems, cybersecurity and emerging markets risk factors below).To the extent that Citi is not able to compete effectively with financial services companies, including private credit and financial technology companies, and non-financial services 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 factors above and "Supervision, Regulation and Other - Competition" below.OPERATIONAL RISKSA Failure or Disruption of Citi's Operational Processes or Systems Could Negatively Impact Its Reputation, Customers, Clients, Businesses or Results of Operations and Financial Condition.Citi's global operations rely heavily on its technology systems and infrastructure, including the accurate, timely and secure processing, management, storage and transmission of data, including confidential transactions, and other information, as well as the monitoring of a substantial amount of data and complex transactions in real time. Citi obtains and stores an extensive amount of personal and client-specific information for its consumer and institutional customers and clients, and must accurately record and reflect their account transactions. Citi's operations must also comply with complex and evolving laws, regulations and heightened regulatory expectations in the countries in which it operates (see the implementation and interpretation of regulatory changes and legal proceedings risk factors below). With the evolving proliferation of new technologies and the increasing use of the internet, mobile devices and cloud services to conduct financial transactions and customers' and clients' increasing use of online banking and trading systems and other platforms, large global financial institutions such as Citi have been, and will continue to be, subject to an ever-increasing risk of operational loss, failure or disruption. such regulation. In addition, in 2023 Citi announced plans to reduce management layers from 13 to a median of eight as part of organizational simplification initiatives that also involve significant reductions in functional roles, which could also impact its ability to attract and retain colleagues. Other factors that could impact its ability to attract, retain and motivate colleagues include, among other things, Citi's presence in a particular market or region, the professional and development opportunities, its reputation and its diversity. For information on Citi's colleagues and workforce management, see "Human Capital Resources and Management" below.Citi Faces Increased Competitive Challenges, Including from Financial Services and Other Companies and Emerging Technologies.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, private credit and 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. Certain competitors may be subject to different and, in some cases, less stringent legal and regulatory requirements, whether due to size, jurisdiction, entity type or other factors, placing Citi at a competitive disadvantage.For example, Citi competes with other financial services companies in the U.S. and globally that have grown rapidly over the last several years or have developed and introduced new products and services. Potential mergers and acquisitions involving traditional financial services companies such as regional banks or credit card issuers, as well as networks and merchant acquirers, may also increase competition and impact Citi's ability to offer competitive pricing and rewards. Non-traditional financial services firms, such as private credit and financial technology companies, are less regulated and continue to expand their offerings of services traditionally provided by financial institutions. The growth of certain of these competitors has increased market and counterparty credit risks, particularly in a more challenging macroeconomic environment (see the risk factor on credit and concentrations of risk below). In addition, emerging technologies have the potential to intensify competition and accelerate disruption in the financial services industry. For example, despite difficulties and turmoil faced by the digital asset market in recent years, clients and investors have exhibited a sustained interest in digital assets. Financial services firms and other market participants have begun to offer services related to those assets. Citi may not be able to provide the same or similar services for legal or regulatory reasons, which may be exacerbated by rapidly evolving and conflicting regulatory requirements, and due to increased compliance and other risks. Further, 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. Increased competition and emerging technologies have required and could require Citi to change or adapt its products and services, as well as invest in and develop related infrastructure, to attract and retain customers or clients or to compete more effectively with competitors, including new such regulation. In addition, in 2023 Citi announced plans to reduce management layers from 13 to a median of eight as part of organizational simplification initiatives that also involve significant reductions in functional roles, which could also impact its ability to attract and retain colleagues. Other factors that could impact its ability to attract, retain and motivate colleagues include, among other things, Citi's presence in a particular market or region, the professional and development opportunities, its reputation and its diversity. For information on Citi's colleagues and workforce management, see "Human Capital Resources and Management" below. **Current (2025):** Citi's performance and the performance of its individual businesses largely depend on the talents and efforts of its diverse and highly qualified employees. Specifically, Citi's continued ability to compete in each of its lines of business, to manage its businesses effectively and to execute its transformation, simplification and other priorities, including, for example, hiring employees to grow businesses or hiring employees to support Citi's priorities, depends on its ability to hire new employees and to retain and motivate its existing employees. If Citi is unable to continue to hire, retain and motivate highly qualified employees, Citi's performance, including its competitive position, the execution of its transformation, simplification and other priorities and its results of operations could be negatively impacted. Citi's ability to attract, retain and motivate employees depends on numerous factors, some of which are outside of Citi's control. For example, the competition for talent continues to be particularly intense due to various factors, such as changes in worker expectations, concerns and preferences, including demands for remote work options and other job flexibility. Also, the banking industry generally is subject to more comprehensive regulation of employee compensation than other industries, including deferral and clawback requirements for incentive compensation, which can make it unusually challenging for Citi to compete in labor markets against businesses, including, for example, technology companies, that are not subject to such regulation. In addition, Citi recently completed a significant organizational simplification initiative, which included reducing management layers and significant reductions in functional roles that could continue to impact its ability to attract and retain employees. Other factors that could impact Citi's ability to attract, retain and motivate employees include, among other things, Citi's presence in a particular market or region, the professional and development opportunities it offers, its reputation and its diversity. For information on Citi's employee and workforce management, see "Human Capital Resources and Management" below.Citi Faces Increased Competitive Challenges, Including from Financial Services and Other Companies and Emerging Technologies.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, private credit and 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. Certain competitors may be subject to different and, in some cases, less stringent legal, regulatory and supervisory requirements, whether due to size, jurisdiction, entity type or other factors, placing Citi at a competitive disadvantage. Moreover, new or rapidly developing technologies with the potential to have significant economic or social effects (emerging technologies) also pose competitive challenges for Citi.For example, Citi competes with other financial services companies in the U.S. and globally that have grown rapidly over the last several years or have introduced new products and services. Potential mergers and acquisitions involving traditional financial services companies, such as regional banks or credit card issuers, as well as networks and merchant acquirers, may also increase competition and impact Citi's ability to offer competitive pricing and rewards. Non-traditional financial services firms, such as private credit, financial technology and digital asset companies, are less regulated and supervised and continue to expand their offerings of services traditionally provided by financial institutions. In addition, emerging technologies have the potential to intensify competition and accelerate disruption in the financial services industry. Clients and investors have shown increased interest in these technologies, prompting financial services firms and other market participants to develop related products and services. As blockchain and digital assets continue to evolve, customer demand for enhanced offerings may increase. Failure to strategically embrace the potential of emerging technologies may result in a competitive disadvantage to Citi. The new U.S. administration has stated its support for the growth and use of digital assets and flexibility. Also, the banking industry generally is subject to more comprehensive regulation of employee compensation than other industries, including deferral and clawback requirements for incentive compensation, which can make it unusually challenging for Citi to compete in labor markets against businesses, including, for example, technology companies, that are not subject to such regulation. In addition, Citi recently completed a significant organizational simplification initiative, which included reducing management layers and significant reductions in functional roles that could continue to impact its ability to attract and retain employees. Other factors that could impact Citi's ability to attract, retain and motivate employees include, among other things, Citi's presence in a particular market or region, the professional and development opportunities it offers, its reputation and its diversity. For information on Citi's employee and workforce management, see "Human Capital Resources and Management" below. --- ## Modified: Non-Accrual Loans **Key changes:** - Reworded sentence: "The table below summarizes Citigroup's non-accrual loans (NAL) as of the periods indicated." - Reworded sentence: "December 31,In millions of dollars20242023202220212020Corporate non-accrual loans by region(1)(2)(3)North America$757 $978 $138 $510 $1,486 International620 904 984 1,043 1,560 Total$1,377 $1,882 $1,122 $1,553 $3,046 International NAL by clusterUnited Kingdom$190 $268 $288 $227 $422 Japan, Asia North and Australia (JANA)22 70 50 82 118 LATAM301 367 429 568 719 Asia South17 35 3 26 94 Europe58 139 117 88 193 Middle East and Africa (MEA)32 25 97 52 14 Corporate non-accrual loans(1)(2)(3)Banking$498 $799 $757 $1,166 $2,595 Services651031537079Markets7157911385193Mexico SBMM99189199232179Total$1,377 $1,882 $1,122 $1,553 $3,046 Consumer non-accrual loans(1)Wealth$404 $288 $259 $336 $494 USPB290 291 282 344 456 Mexico Consumer411 479 457 524 774 Asia Consumer(4)19 22 30 209 296 Legacy Holdings Assets (consumer)186 235 289 413 602 Total $1,310 $1,315 $1,317 $1,826 $2,622 Total non-accrual loans$2,687 $3,197 $2,439 $3,379 $5,668" **Prior (2024):** 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,In millions of dollars20232022202120202019Corporate non-accrual loans by region(1)(2)(3)North America(4)$978 $138 $510 $1,486 $1,082 International904 984 1,043 1,560 942 Total$1,882 $1,122 $1,553 $3,046 $2,024 Corporate non-accrual loans(1)(2)(3)Banking$799 $757 $1,166 $2,595 $1,565 Services1031537079113Markets(4)7911385193179Mexico SBMM189199232179167Total$1,882 $1,122 $1,553 $3,046 $2,024 Consumer non-accrual loans(1)USPB$291 $282 $344 $456 $269 Wealth288 259 336 494 174 Asia Consumer(5)22 30 209 296 267 Mexico Consumer479 457 524 774 632 Legacy Holdings Assets (consumer)235 289 413 602 638 Total $1,315 $1,317 $1,826 $2,622 $1,980 Total non-accrual loans$3,197 $2,439 $3,379 $5,668 $4,004 **Current (2025):** The table below summarizes Citigroup's non-accrual loans (NAL) 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,In millions of dollars20242023202220212020Corporate non-accrual loans by region(1)(2)(3)North America$757 $978 $138 $510 $1,486 International620 904 984 1,043 1,560 Total$1,377 $1,882 $1,122 $1,553 $3,046 International NAL by clusterUnited Kingdom$190 $268 $288 $227 $422 Japan, Asia North and Australia (JANA)22 70 50 82 118 LATAM301 367 429 568 719 Asia South17 35 3 26 94 Europe58 139 117 88 193 Middle East and Africa (MEA)32 25 97 52 14 Corporate non-accrual loans(1)(2)(3)Banking$498 $799 $757 $1,166 $2,595 Services651031537079Markets7157911385193Mexico SBMM99189199232179Total$1,377 $1,882 $1,122 $1,553 $3,046 Consumer non-accrual loans(1)Wealth$404 $288 $259 $336 $494 USPB290 291 282 344 456 Mexico Consumer411 479 457 524 774 Asia Consumer(4)19 22 30 209 296 Legacy Holdings Assets (consumer)186 235 289 413 602 Total $1,310 $1,315 $1,317 $1,826 $2,622 Total non-accrual loans$2,687 $3,197 $2,439 $3,379 $5,668 --- ## Modified: 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. **Key changes:** - Reworded sentence: "At December 31, 2024, Citi's net DTAs were $29.8 billion, net of a valuation allowance of $4.3 billion, of which $12.8 billion was deducted from Citi's CET1 Capital under the U.S." - Added sentence: "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.The new U.S." - Added sentence: "administration has discussed potential reductions to the U.S." - Added sentence: "federal corporate tax rate and changes to the U.S." - Added sentence: "approach to the Organization for Economic Cooperation and Development (OECD) Pillar 2 framework." **Prior (2024):** At December 31, 2023, Citi's net DTAs were $29.6 billion, net of a valuation allowance of $3.6 billion, of which $12.8 billion was deducted from Citi's CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $12.1 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $2.3 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $1.6 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital. Citi's overall ability to realize its DTAs will primarily be dependent upon Citi's ability to generate U.S. taxable income in the relevant reversal periods. Failure to realize any portion of the net DTAs would have a corresponding negative impact on Citi's net income and financial returns. The accounting treatment for realization of DTAs 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, macroeconomic conditions. In addition, any future increase in U.S. corporate tax rates could result in an increase in Citi's DTAs, which may subject more of Citi's DTAs to exclusion from regulatory capital. 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 10. **Current (2025):** At December 31, 2024, Citi's net DTAs were $29.8 billion, net of a valuation allowance of $4.3 billion, of which $12.8 billion was deducted from Citi's CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $11.6 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $3.0 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $1.8 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital. Citi's overall ability to realize its DTAs will primarily be dependent upon Citi's ability to generate U.S. taxable income in the relevant reversal periods. Failure to realize any portion of the net DTAs would have a corresponding negative impact on Citi's net income and financial returns. The accounting treatment for realization of DTAs 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, macroeconomic conditions. In addition, any future increase in U.S. corporate tax rates could result in an increase in Citi's DTAs, which may subject more of Citi's DTAs to exclusion from regulatory capital. 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.The new U.S. administration has discussed potential reductions to the U.S. federal corporate tax rate and changes to the U.S. approach to the Organization for Economic Cooperation and Development (OECD) Pillar 2 framework. It is unclear whether any corporate tax rate reduction would apply to services companies like Citi. If the U.S. federal corporate tax rate applicable to Citi is reduced, Citi may benefit on a prospective net income basis, but the reduction could result in a material decrease in the value of Citi's DTAs, which would also result in a material reduction to Citi's net income during the period in which the change is enacted. Citi's regulatory capital could also be reduced if the decrease in the value of Citi's DTAs exceeds certain levels.For additional information on Citi's DTAs, including FTCs, see "Significant Accounting Policies and Significant Estimates - Income Taxes" below and Notes 1 and 10.Citi's Interpretation or Application of the Complex Tax Laws to Which It Is Subject Could Differ from Those of 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 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 to its entities, operations and businesses. For example, the OECD Pillar 2 framework contemplates a 15% global minimum tax with respect to earnings in each country. The majority of EU member states have adopted the OECD Pillar 2 rules, and other non-U.S. countries have similarly adopted or are expected to adopt the rules. Under these rules, Citi will be required to pay a "top-up" tax to the extent that Citi's effective tax rate in any given country is below 15%. Beginning in 2024, countries that adopted the OECD Pillar 2 rules can collect the top-up tax only with respect to earnings of entities in their jurisdiction or subsidiaries of such entities. Beginning in 2025, all countries that have adopted the OECD Pillar 2 rules can collect a share of the top-up tax owed with respect to any member of the Pillar 2 multinational group. While Citi does not currently expect the rules to have a material impact on its earnings, many aspects of the application of the rules and their implementation remain uncertain. Separately, the new U.S. administration has stated its opposition to the application of the global minimum tax to U.S. companies' U.S. operations, and has indicated it may take retaliatory measures against other countries that seek to collect the minimum tax with respect to the U.S. operations of U.S. companies. Citi is of future taxable earnings will depend upon various factors, including, among others, macroeconomic conditions. In addition, any future increase in U.S. corporate tax rates could result in an increase in Citi's DTAs, which may subject more of Citi's DTAs to exclusion from regulatory capital. 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. The new U.S. administration has discussed potential reductions to the U.S. federal corporate tax rate and changes to the U.S. approach to the Organization for Economic Cooperation and Development (OECD) Pillar 2 framework. It is unclear whether any corporate tax rate reduction would apply to services companies like Citi. If the U.S. federal corporate tax rate applicable to Citi is reduced, Citi may benefit on a prospective net income basis, but the reduction could result in a material decrease in the value of Citi's DTAs, which would also result in a material reduction to Citi's net income during the period in which the change is enacted. Citi's regulatory capital could also be reduced if the decrease in the value of Citi's DTAs exceeds certain levels. For additional information on Citi's DTAs, including FTCs, see "Significant Accounting Policies and Significant Estimates - Income Taxes" below and Notes 1 and 10. --- ## Modified: Interest Income/Expense and Net Interest Margin (NIM) **Key changes:** - Reworded sentence: "In millions of dollars, except as otherwise noted2024 2023 2022Change 2024 vs." **Prior (2024):** In millions of dollars, except as otherwise noted2023 2022 2021Change 2023 vs. 2022Change 2022 vs. 2021Interest income(1)$133,359 $74,573 $50,667 79 %47 %Interest expense(2)78,358 25,740 7,981 204 223 Net interest income, taxable equivalent basis(1)$55,001 $48,833 $42,686 13 %14 %Interest income - average rate(3)5.97 %3.43 %2.36 %254 bps107 bpsInterest expense - average rate4.35 1.48 0.46 287 bps102 bpsNet interest margin(3)(4)2.46 2.25 1.99 21 bps26 bpsInterest rate benchmarks Two-year U.S. Treasury note - average rate4.58 %2.99 %0.27 %159 bps272 bps10-year U.S. Treasury note - average rate3.96 2.95 1.45 101 bps150 bps10-year vs. two-year spread(62)bps(4)bps118 bps Change **Current (2025):** In millions of dollars, except as otherwise noted2024 2023 2022Change 2024 vs. 2023Change 2023 vs. 2022Interest income(1)$143,807 $133,359 $74,573 8 %79 %Interest expense(2)89,618 78,358 25,740 14 204 Net interest income, taxable equivalent basis(1)$54,189 $55,001 $48,833 (1)%13 %Interest income - average rate(3)6.36 %5.97 %3.43 %39 bps254 bpsInterest expense - average rate4.90 4.35 1.48 55 bps287 bpsNet interest margin(3)(4)2.40 2.46 2.25 (6)bps21 bpsInterest rate benchmarks Two-year U.S. Treasury note - average rate4.37 %4.58 %2.99 %(21)bps159 bps10-year U.S. Treasury note - average rate4.21 3.96 2.95 25 bps101 bps10-year vs. two-year spread(16)bps(62)bps(4)bps Change --- ## Modified: Loans at fair value(1) **Key changes:** - Reworded sentence: "December 31, 2023In billions of dollarsACLLEOP loans, net ofunearned incomeACLL as a% of EOP loans(1)ConsumerNorth America cards(2)$12.6 $164.7 7.7 %North America mortgages(3)0.2 112.0 0.2 North America other(3)0.7 36.2 1.9 International cards0.9 14.2 6.3 International other(3)1.0 61.8 1.6 Total(1)$15.4 $388.9 4.0 %Corporate(4)Commercial and industrial$1.7 $151.5 1.1 %Financial institutions0.3 65.1 0.5 Mortgage and real estate(4)0.6 24.9 2.4 Installment and other0.1 51.4 0.2 Total(1)$2.7 $292.9 0.9 %Loans at fair value(1)N/A$7.6 N/ATotal Citigroup$18.1 $689.4 2.7 % ACLL as a % of EOP loans(1) North America cards(2) North America mortgages(3) North America other(3) International other(3) Total(1) Corporate(4) Mortgage and real estate(4) Total(1) Loans at fair value(1) (1)Excludes loans carried at fair value, since they do not have an ACLL and are excluded from the ACLL ratio calculation." - Added sentence: "As of December 31, 2024, the $13.6 billion of ACLL represented approximately 22 months of coincident net credit loss coverage (based on 4Q24 NCLs)." - Added sentence: "As of December 31, 2024, Branded Cards ACLL as a percentage of EOP loans was 6.4% and Retail Services ACLL as a percentage of EOP loans was 11.3%." - Removed sentence: "As of December 31, 2022, the $11.4 billion of ACLL represented approximately 43 months of coincident net credit loss coverage (based on 4Q22 NCLs)." - Removed sentence: "The decrease in the coincident coverage ratio at December 31, 2023 was primarily due to the higher levels of NCLs in 4Q23 versus 4Q22." **Prior (2024):** December 31, 2022In billions of dollarsACLLEOP loans, net ofunearned incomeACLL as a% of EOP loans(1)ConsumerNorth America cards(2)$11.4 $150.6 7.6 %North America mortgages(3)0.5 100.4 0.5 North America other(3)0.6 37.8 1.6 International cards0.8 13.0 6.2 International other(3)0.8 66.0 1.2 Total(1)$14.1 $367.8 3.8 %CorporateCommercial and industrial$1.9 $147.8 1.3 %Financial institutions0.4 64.9 0.6 Mortgage and real estate0.4 21.9 1.8 Installment and other0.2 49.4 0.4 Total(1)$2.9 $284.0 1.0 %Loans at fair value(1)N/A$5.4 N/ATotal Citigroup$17.0 $657.2 2.6 % ACLL as a % of EOP loans(1) North America cards(2) North America mortgages(3) North America other(3) International other(3) Total(1) Total(1) Loans at fair value(1) (1)Excludes loans carried at fair value, since they do not have an ACLL and are excluded from the ACLL ratio calculation. (2)Includes both Branded Cards and Retail Services. As of December 31, 2023, the $12.6 billion of ACLL represented approximately 25 months of coincident net credit loss coverage (based on 4Q23 NCLs). As of December 31, 2023, Branded Cards ACLL as a percentage of EOP loans was 6.0% and Retail Services ACLL as a percentage of EOP loans was 11.1%. As of December 31, 2022, the $11.4 billion of ACLL represented approximately 43 months of coincident net credit loss coverage (based on 4Q22 NCLs). The decrease in the coincident coverage ratio at December 31, 2023 was primarily due to the higher levels of NCLs in 4Q23 versus 4Q22. As of December 31, 2022, Branded Cards ACLL as a percentage of EOP loans was 6.2% and Retail Services ACLL as a percentage of EOP loans was 10.3%. (3)Includes residential mortgages, retail loans and personal, small business and other loans, including those extended through the Private Bank network. N/A Not applicable 86 86 86 The following table details Citi's corporate credit ACLL by industry exposure: December 31, 2023In millions of dollars, except percentagesFunded exposure(1)ACLLACLL as a % of funded exposureTransportation and industrials$59,917 $453 0.8 %Banks and finance companies52,569 179 0.3 Real estate(2)51,660 663 1.3 Commercial35,058 599 1.7 Residential16,602 64 0.4 Consumer retail33,548 282 0.8 Technology, media and telecom29,832 376 1.3 Power, chemicals, metals and mining19,004 270 1.4 Public sector12,621 102 0.8 Energy and commodities12,606 166 1.3 Health9,135 72 0.8 Asset managers and funds4,232 36 0.9 Insurance2,390 14 0.6 Securities firms734 23 3.1 Financial markets infrastructure156 - - Other industries(3)4,480 78 1.7 Total(4)$292,884 $2,714 0.9 % **Current (2025):** December 31, 2023In billions of dollarsACLLEOP loans, net ofunearned incomeACLL as a% of EOP loans(1)ConsumerNorth America cards(2)$12.6 $164.7 7.7 %North America mortgages(3)0.2 112.0 0.2 North America other(3)0.7 36.2 1.9 International cards0.9 14.2 6.3 International other(3)1.0 61.8 1.6 Total(1)$15.4 $388.9 4.0 %Corporate(4)Commercial and industrial$1.7 $151.5 1.1 %Financial institutions0.3 65.1 0.5 Mortgage and real estate(4)0.6 24.9 2.4 Installment and other0.1 51.4 0.2 Total(1)$2.7 $292.9 0.9 %Loans at fair value(1)N/A$7.6 N/ATotal Citigroup$18.1 $689.4 2.7 % ACLL as a % of EOP loans(1) North America cards(2) North America mortgages(3) North America other(3) International other(3) Total(1) Corporate(4) Mortgage and real estate(4) Total(1) Loans at fair value(1) (1)Excludes loans carried at fair value, since they do not have an ACLL and are excluded from the ACLL ratio calculation. (2)Includes both Branded Cards and Retail Services. As of December 31, 2024, the $13.6 billion of ACLL represented approximately 22 months of coincident net credit loss coverage (based on 4Q24 NCLs). As of December 31, 2024, Branded Cards ACLL as a percentage of EOP loans was 6.4% and Retail Services ACLL as a percentage of EOP loans was 11.3%. As of December 31, 2023, the $12.6 billion of ACLL represented approximately 25 months of coincident net credit loss coverage (based on 4Q23 NCLs). As of December 31, 2023, Branded Cards ACLL as a percentage of EOP loans was 6.0% and Retail Services ACLL as a percentage of EOP loans was 11.1%. (3)Includes residential mortgages, retail loans and personal, small business and other loans, including those extended through the Private Bank network. (4)The above corporate loan classifications are broadly based on the loan's collateral, purpose and type of borrower, which may be different from the following industry table. For example, commercial and industrial, financial institutions, and installment and other loan classifications include various forms of loans to borrowers across multiple industries, whereas mortgage and real estate includes loans secured primarily by real estate. N/A Not applicable 89 89 89 The following table details Citi's corporate credit ACLL by industry exposure: December 31, 2024In millions of dollars, except percentagesFunded exposure(1)ACLLACLL as a % of funded exposureTransportation and industrials$57,166 $460 0.8 %Banks and finance companies56,716 307 0.5 Real estate(2)53,186 717 1.3 Commercial36,200 645 1.8 Residential16,986 72 0.4 Consumer retail32,212 258 0.8 Technology, media and telecom29,534 238 0.8 Power, chemicals, metals and mining18,504 257 1.4 Public sector13,209 47 0.4 Energy and commodities11,686 136 1.2 Health8,537 77 0.9 Asset managers and funds5,258 28 0.5 Insurance2,115 8 0.4 Securities firms590 9 1.5 Financial markets infrastructure181 1 0.6 Other industries(3)4,733 13 0.3 Total(4)$293,627 $2,556 0.9 % --- ## Modified: Allowance for Credit Losses on Loans (ACLL) **Key changes:** - Reworded sentence: "The following tables detail information on Citi's ACLL, loans and coverage ratios: December 31, 2024In billions of dollarsACLLEOP loans, net ofunearned incomeACLL as a% of EOP loans(1)ConsumerNorth America cards(2)$13.6 $171.1 7.9 %North America mortgages(3)0.1 117.2 0.1 North America other(3)0.7 33.2 2.1 International cards0.9 12.9 7.0 International other(3)0.7 58.4 1.2 Total(1)$16.0 $392.8 4.1 %Corporate(4)Commercial and industrial$1.3 $148.7 0.9 %Financial institutions0.4 68.4 0.6 Mortgage and real estate(4)0.7 26.4 2.7 Installment and other0.2 50.1 0.4 Total(1)$2.6 $293.6 0.9 %Loans at fair value(1)N/A$8.0 N/ATotal Citigroup$18.6 $694.5 2.7 % ACLL as a" **Prior (2024):** The following tables detail information on Citi's ACLL, loans and coverage ratios: December 31, 2023In billions of dollarsACLLEOP loans, net ofunearned incomeACLL as a% of EOP loans(1)ConsumerNorth America cards(2)$12.6 $164.7 7.7 %North America mortgages(3)0.2 112.0 0.2 North America other(3)0.7 36.2 1.9 International cards0.9 14.2 6.3 International other(3)1.0 61.8 1.6 Total(1)$15.4 $388.9 4.0 %CorporateCommercial and industrial$1.7 $151.5 1.1 %Financial institutions0.3 65.1 0.5 Mortgage and real estate0.6 24.9 2.4 Installment and other0.1 51.3 0.2 Total(1)$2.7 $292.9 0.9 %Loans at fair value(1)N/A$7.6 N/ATotal Citigroup$18.1 $689.4 2.7 % ACLL as a **Current (2025):** The following tables detail information on Citi's ACLL, loans and coverage ratios: December 31, 2024In billions of dollarsACLLEOP loans, net ofunearned incomeACLL as a% of EOP loans(1)ConsumerNorth America cards(2)$13.6 $171.1 7.9 %North America mortgages(3)0.1 117.2 0.1 North America other(3)0.7 33.2 2.1 International cards0.9 12.9 7.0 International other(3)0.7 58.4 1.2 Total(1)$16.0 $392.8 4.1 %Corporate(4)Commercial and industrial$1.3 $148.7 0.9 %Financial institutions0.4 68.4 0.6 Mortgage and real estate(4)0.7 26.4 2.7 Installment and other0.2 50.1 0.4 Total(1)$2.6 $293.6 0.9 %Loans at fair value(1)N/A$8.0 N/ATotal Citigroup$18.6 $694.5 2.7 % ACLL as a --- ## Modified: Retail Services **Key changes:** - Reworded sentence: "As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Services increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years." - Reworded sentence: "Retail BankingUSPB's Retail Banking portfolio consists primarily ofconsumer mortgages (including home equity) and unsecuredlending products, such as small business loans and personalloans." - Reworded sentence: "The delinquency-managed portfolio consists primarily of mortgages, margin lending and credit cards." **Prior (2024):** USPB's Retail Services partners directly with more than 20 retailers and dealers to offer private label and co-branded cards. Retail Services' target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel. Retail Services continually evaluates opportunities to add partners within target industries that have strong loyalty, lending or payment programs and growth potential. As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in Retail Services increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment. For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15. 77 77 77 Retail BankingUSPB's Retail Banking portfolio consists primarily of consumer mortgages (including home equity) and unsecured lending products, such as small business loans and personal loans. The portfolio is generally delinquency managed, where Citi evaluates credit risk based on FICO scores, delinquencies and the value of underlying collateral. The consumer mortgages in this portfolio have historically been extended to high credit quality customers, generally with loan-to-value ratios that are less than or equal to 80% on first and second mortgages. For additional information, see "Loan-to-Value (LTV) Ratios" in Note 15.As presented in the chart above, the net credit loss rate in Retail Banking for the fourth quarter of 2023 was broadly stable quarter-over-quarter and increased year-over-year, primarily driven by the growth and seasoning of personal loans.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and decreased year-over-year, primarily driven by lower delinquencies in U.S. mortgages.WealthAs indicated above, Wealth provides consumer mortgages, margin lending, cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and cards. As of December 31, 2023, approximately $46 billion, or 30%, of the portfolio was classifiably managed and primarily consisted of margin lending, commercial real estate, subscription credit finance and other lending programs. These classifiably managed loans are primarily evaluated for credit risk based on their internal risk rating, of which 85% is rated investment grade. While the delinquency rate in the chart above is calculated only for the delinquency-managed portfolio, the net credit loss rate is calculated using net credit losses for both the delinquency and classifiably managed portfolios.As presented in the chart above, the net credit loss rate and 90+ days past due delinquency rate in Wealth for the fourth quarter of 2023 were broadly stable quarter-over-quarter and year-over-year. The low net credit loss and the 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. Mexico ConsumerMexico Consumer operates in Mexico through Citibanamex and provides credit cards, consumer mortgages and small business and personal loans. Mexico Consumer serves a more mass-market segment in Mexico and focuses on developing multiproduct relationships with customers.As presented in the chart above, the fourth quarter of 2023 net credit loss rate in Mexico Consumer increased quarter-over-quarter and year-over-year, primarily driven by the ongoing normalization of loss rates from post-pandemic lows. The 90+ days past due delinquency rate was relatively stable quarter-over-quarter and year-over-year. For additional information on cost of credit, loan delinquency and other information for Citi's consumer loan portfolios, see each respective business's results of operations above and Note 15. Retail BankingUSPB's Retail Banking portfolio consists primarily of consumer mortgages (including home equity) and unsecured lending products, such as small business loans and personal loans. The portfolio is generally delinquency managed, where Citi evaluates credit risk based on FICO scores, delinquencies and the value of underlying collateral. The consumer mortgages in this portfolio have historically been extended to high credit quality customers, generally with loan-to-value ratios that are less than or equal to 80% on first and second mortgages. For additional information, see "Loan-to-Value (LTV) Ratios" in Note 15.As presented in the chart above, the net credit loss rate in Retail Banking for the fourth quarter of 2023 was broadly stable quarter-over-quarter and increased year-over-year, primarily driven by the growth and seasoning of personal loans.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and decreased year-over-year, primarily driven by lower delinquencies in U.S. mortgages.WealthAs indicated above, Wealth provides consumer mortgages, margin lending, cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and cards. As of December 31, 2023, approximately $46 billion, or 30%, of the portfolio was classifiably managed and primarily consisted of margin lending, commercial real estate, subscription credit finance and other lending programs. These classifiably managed loans are primarily evaluated for credit **Current (2025):** USPB's Retail Services partners directly with more than 20 retailers and dealers to offer private label and co-branded cards. Retail Services' target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel. Retail Services continually evaluates opportunities to add partners within target industries that have strong loyalty, lending or payment programs and growth potential. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Services increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15. Retail BankingUSPB's Retail Banking portfolio consists primarily ofconsumer mortgages (including home equity) and unsecuredlending products, such as small business loans and personalloans. The portfolio is generally delinquency managed, whereCiti evaluates credit risk based on FICO scores, delinquenciesand the value of underlying collateral. The consumermortgages in this portfolio have historically been extended tohigh credit quality customers, generally with loan-to-valueratios that are less than or equal to 80% on first and secondmortgages. For additional information, see "Loan-to-Value(LTV) Ratios" in Note 15.As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Banking increased quarter-over-quarter and year-over-year, primarily driven by consumer overdraft loans. The 90+ days past due delinquency rate was largely unchanged quarter-over-quarter and decreased year-over-year. The decrease was primarily driven by lower delinquencies in consumer mortgages.WealthWealth provides consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold businesses. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and credit cards. --- ## Modified: All Other, including Legacy Franchises, Operations and Technology, and Global Staff Functions **Key changes:** - Reworded sentence: "(1) Employee distribution is based on business and region, which may not reflect where the employee physically resides." **Prior (2024):** (1) Colleague distribution is based on assigned region, which may not reflect where the colleague physically resides. (2) Mexico is included in International. (3) Part-time colleagues represented less than 0.9% of Citi's global workforce. (4) Information regarding gender is self-identified by colleagues. **Current (2025):** (1) Employee distribution is based on business and region, which may not reflect where the employee physically resides. (2) See Note 3 for compensation by reportable segment. Compensation expense related to services provided by employees in the Corporate/Other unit within All Other is allocated to each respective reportable segment, as applicable, through non-compensation expense. (3) Mexico is included in International. (4) Part-time employees represented less than 1.0% of Citi's global workforce. --- ## Modified: Workforce Size and Distribution **Key changes:** - Reworded sentence: "As of December 31, 2024, Citi employed approximately 229,000 people in over 90 countries." - Reworded sentence: "In 2024, Citi welcomed over 24,000 new employees in addition to 39,700 roles filled by existing employees through internal mobility, including promotions." **Prior (2024):** As of December 31, 2023, Citi employed approximately 239,000 colleagues in over 90 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 2023, Citi welcomed over 38,000 new colleagues in addition to 44,600 roles filled by colleagues through internal mobility and promotions. Citi also sustains connections with former colleagues through its Alumni Network, and in 2023 hired more than 3,000 "returnees" back to Citi. The following table presents the geographic distribution of Citi's colleagues by segment or component and gender: **Current (2025):** As of December 31, 2024, Citi employed approximately 229,000 people in over 90 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 2024, Citi welcomed over 24,000 new employees in addition to 39,700 roles filled by existing employees through internal mobility, including promotions. Citi also maintains connections with former employees through its alumni network, and in 2024, welcomed more than 3,400 individuals back to Citi. The following table presents the geographic distribution of Citi's employees by segment, component and gender: --- ## Modified: CREDIT RISK **Key changes:** - Added sentence: "For example, credit risk can arise from a deterioration in (i) the operating and financial performance of a borrower or (ii) a decline in the quality or value of any underlying collateral, both of which may also be impacted by adverse changes in macroeconomic, geopolitical, market and other factors." - Added sentence: "Citi's loans are reported in two categories: corporate and consumer." - Added sentence: "These categories are classified primarily according to the operating segment, reporting unit and component that manage the loans in addition to the nature of the obligor, with corporate loans generally made for corporate institutional and public sector clients around the world and consumer loans to retail and small business customers." - Reworded sentence: "See Notes 15 and 16 for additional information on Citi's credit risk management." **Prior (2024):** 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 is one of the most significant risks Citi faces as an institution (see "Risk Factors - Credit Risks" above). Credit risk arises in many of Citigroup's business activities, including: •consumer, commercial and corporate lending; •capital markets derivative transactions; •structured finance; and •securities financing transactions (repurchase and reverse repurchase agreements, and securities loaned and borrowed). Credit risk also arises from clearing and settlement activities, when Citi transfers an asset in advance of receiving its counter-value or advances funds to settle a transaction on behalf of a client. Concentration risk, within credit risk, is the risk associated with having credit exposure concentrated within a specific client, industry, region or other category. Citi has an established framework in place for managing credit risk across all businesses that includes a defined risk appetite, credit limits and credit policies. Citi's credit risk management framework also includes policies and procedures to manage problem exposures. To manage concentration risk, Citi has in place a framework consisting of industry limits, single-name concentrations for each business and across Citigroup and a specialized product limit framework. Credit exposures are generally reported in notional terms for accrual loans, reflecting the value at which the loans as well as other off-balance sheet commitments are carried on the Consolidated Balance Sheet. Credit exposure arising from capital markets activities is generally expressed as the current mark-to-market, net of margin, reflecting the net value owed to Citi by a given counterparty. The credit risk associated with Citi's 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 allowance for credit losses (ACL) process (see "Significant Accounting Policies and Significant Estimates - Allowance for Credit Losses" below and Notes 1 and 16), 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. See Note 15 for additional information on Citi's credit risk management. LoansThe table below details the average loans, by business and/or segment, and the total Citigroup end-of-period loans for each of the periods indicated:In billions of dollars4Q233Q234Q22Services$83 $83 $78 Markets115 108 111 Banking87 87 96 USPB Branded Cards$107 $103 $95 Retail Services52 50 48 Retail Banking43 43 37 Total USPB$202 $196 $180 Wealth$150 $151 $150 All Other(1)$38 $37 $38 Total Citigroup loans (AVG)$675 $662 $653 Total Citigroup loans (EOP)$689 $666 $657 (1)See footnote 2 to the table in "Credit Risk - Consumer Credit - Consumer Credit Portfolio" below.End-of-period loans increased 5% year-over-year, largely reflecting growth in cards in USPB. End-of-period loans increased 3% sequentially.On an average basis, loans increased 3% year-over-year and 2% sequentially. The year-over-year increase was largely due to growth in USPB, Services and Markets, partially offset by a decline in Banking. As of the fourth quarter of 2023, average loans for: •USPB increased 12% year-over-year, driven by growth in Branded Cards, Retail Banking and Retail Services. •Wealth were largely unchanged. •Services increased 6% year-over-year, primarily driven by strong demand for working capital loans in TTS in North America and internationally. •Markets increased 4% year-over-year, reflecting increased client demand in warehouse lending. •Banking decreased 9% year-over-year, primarily driven by capital optimization efforts. Loans The table below details the average loans, by business and/or segment, and the total Citigroup end-of-period loans for each of the periods indicated: In billions of dollars4Q233Q234Q22Services$83 $83 $78 Markets115 108 111 Banking87 87 96 USPB Branded Cards$107 $103 $95 Retail Services52 50 48 Retail Banking43 43 37 Total USPB$202 $196 $180 Wealth$150 $151 $150 All Other(1)$38 $37 $38 Total Citigroup loans (AVG)$675 $662 $653 Total Citigroup loans (EOP)$689 $666 $657 Retail Banking Total USPB **Current (2025):** 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. For example, credit risk can arise from a deterioration in (i) the operating and financial performance of a borrower or (ii) a decline in the quality or value of any underlying collateral, both of which may also be impacted by adverse changes in macroeconomic, geopolitical, market and other factors. Credit risk is one of the most significant risks Citi faces as an institution (see "Risk Factors - Credit Risks" above). Credit risk arises in many of Citigroup's business activities, including: •consumer, commercial and corporate lending; •capital markets derivative transactions; •structured finance; and •securities financing transactions (repurchase and reverse repurchase agreements, and securities loaned and borrowed). Credit risk also arises from clearing and settlement activities, when Citi transfers an asset in advance of receiving its counter-value or advances funds to settle a transaction on behalf of a client. Concentration risk, within credit risk, is the risk associated with having credit exposure concentrated within a specific client, industry, region or other category. Citi has an established framework in place for managing credit risk across all businesses that includes a defined risk appetite, credit limits and credit policies. Citi's credit risk management framework also includes policies and procedures to manage problem exposures. To manage concentration risk, Citi has in place a framework consisting of industry limits, single-name concentrations for each business and across Citigroup and a specialized product limit framework. Credit exposures are generally reported in notional terms for accrual loans, reflecting the value at which the loans as well as other off-balance sheet commitments are carried on the Consolidated Balance Sheet. Credit exposure arising from capital markets activities is generally expressed as the current mark-to-market, net of margin, reflecting the net value owed to Citi by a given counterparty. Citi's loans are reported in two categories: corporate and consumer. These categories are classified primarily according to the operating segment, reporting unit and component that manage the loans in addition to the nature of the obligor, with corporate loans generally made for corporate institutional and public sector clients around the world and consumer loans to retail and small business customers. The credit risk associated with Citi's 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 allowance for credit losses (ACL) process (see "Significant Accounting Policies and Significant Estimates - Allowance for Credit Losses" below and Notes 1 and 16), 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. See Notes 15 and 16 for additional information on Citi's credit risk management. LoansThe table below details the average loans, by segment and/or business, and the total Citigroup end-of-period loans for each of the periods indicated:In billions of dollars4Q243Q244Q23Services$87 $87 $83 Markets122 119 115 Banking84 88 89 Wealth148 150 150 USPB Branded Cards$113 $111 $107 Retail Services52 51 52 Retail Banking51 48 43 Total USPB$216 $210 $202 All Other$31 $33 $36 Total Citigroup loans (AVG)$688 $687 $675 Total Citigroup loans (EOP)$694 $689 $689 On an average basis, loans increased 2% year-over-year and were relatively unchanged sequentially. The year-over-year increase was largely due to growth in USPB, Markets and Services. As of the fourth quarter of 2024, average loans for: •Services increased 5% year-over-year, primarily driven by strong demand in TTS for export and agency finance, as well as working capital loans. •Markets increased 6% year-over-year, largely driven by asset-backed securitization lending and North America residential financing in spread products. •Banking decreased 6% year-over-year, primarily driven by regulatory capital optimization efforts. •Wealth decreased 1%, primarily driven by regulatory capital optimization efforts. •USPB increased 7% year-over-year, driven by growth in Retail Banking due to an increase in mortgage loans as a result of lower refinancings due to a higher interest rate environment and higher mortgage originations, as well as Branded Cards due to lower card payment rates and higher card spend volume.End-of-period loans increased 1% year-over-year and sequentially. The year-over-year increase was largely due to growth in Branded Cards and Retail Banking in USPB, as well as growth in Markets and Services. and 16), 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. See Notes 15 and 16 for additional information on Citi's credit risk management. Loans The table below details the average loans, by segment and/or business, and the total Citigroup end-of-period loans for each of the periods indicated: In billions of dollars4Q243Q244Q23Services$87 $87 $83 Markets122 119 115 Banking84 88 89 Wealth148 150 150 USPB Branded Cards$113 $111 $107 Retail Services52 51 52 Retail Banking51 48 43 Total USPB$216 $210 $202 All Other$31 $33 $36 Total Citigroup loans (AVG)$688 $687 $675 Total Citigroup loans (EOP)$694 $689 $689 Retail Banking Total USPB On an average basis, loans increased 2% year-over-year and were relatively unchanged sequentially. The year-over-year increase was largely due to growth in USPB, Markets and Services. As of the fourth quarter of 2024, average loans for: •Services increased 5% year-over-year, primarily driven by strong demand in TTS for export and agency finance, as well as working capital loans. •Markets increased 6% year-over-year, largely driven by asset-backed securitization lending and North America residential financing in spread products. •Banking decreased 6% year-over-year, primarily driven by regulatory capital optimization efforts. •Wealth decreased 1%, primarily driven by regulatory capital optimization efforts. •USPB increased 7% year-over-year, driven by growth in Retail Banking due to an increase in mortgage loans as a result of lower refinancings due to a higher interest rate environment and higher mortgage originations, as well as Branded Cards due to lower card payment rates and higher card spend volume. End-of-period loans increased 1% year-over-year and sequentially. The year-over-year increase was largely due to growth in Branded Cards and Retail Banking in USPB, as well as growth in Markets and Services. 72 72 72 CORPORATE CREDITConsistent with its overall strategy, Citi's corporate clients are typically corporations that value the depth and breadth of Citi's global network. Citi aims to establish relationships with these clients whose needs encompass multiple products, including cash management and trade services, foreign exchange, lending, capital markets and M&A advisory. CORPORATE CREDITConsistent with its overall strategy, Citi's corporate clients are typically corporations that value the depth and breadth of Citi's global network. Citi aims to establish relationships with these clients whose needs encompass multiple products, including cash management and trade services, foreign exchange, lending, capital markets and M&A advisory. --- ## Modified: Workforce Development **Key changes:** - Reworded sentence: "Citi encourages career growth and development by offering broad and diverse opportunities to employees, including the following: •Providing a range of internal development and rotational programs to employees at all levels, including an extensive leadership curriculum, allowing the opportunity to build the skills needed to transition to supervisory and managerial roles." - Reworded sentence: "•Continuing to encourage all employees to create developmental plans and consider the competencies and skills they need to develop in order to achieve their career aspirations." **Prior (2024):** Citi's numerous programmatic offerings aim to reinforce its culture and values, foster understanding of compliance requirements and develop competencies required to deliver excellence to its clients. Citi encourages career growth and development by offering broad and diverse opportunities to colleagues, including the following: •Citi provides a range of internal development and rotational programs to colleagues at all levels, including an extensive leadership curriculum, allowing the opportunity to build the skills needed to transition to supervisory and managerial roles. Citi's tuition assistance program further enables colleagues in North America to pursue their educational goals. •Citi continues to focus on internal talent development and aims to provide colleagues with career growth opportunities. Of the 44,600 mobility opportunities filled in 2023, 14% were open roles applied for and filled by internal candidates, and 38% were filled by colleagues who applied for, and were promoted into, new opportunities. 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 within the organization. •Citi enabled Development Plans for colleagues of all levels. Last year, more than 100,000 employees completed a plan, setting a roadmap for how they can achieve their career aspirations. **Current (2025):** Citi's numerous programmatic offerings aim to reinforce its culture and values, foster understanding of compliance requirements and develop competencies required to deliver excellence to its clients. Citi encourages career growth and development by offering broad and diverse opportunities to employees, including the following: •Providing a range of internal development and rotational programs to employees at all levels, including an extensive leadership curriculum, allowing the opportunity to build the skills needed to transition to supervisory and managerial roles. Citi's tuition assistance program further enables employees in North America to pursue their educational goals. •Continuing to focus on internal talent development and aims to provide employees with career growth opportunities. There was a total of 39,700 mobility opportunities filled in 2024. 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 within the organization. •Continuing to encourage all employees to create developmental plans and consider the competencies and skills they need to develop in order to achieve their career aspirations. In 2023, Citi launched a "Development 365" campaign that drove significant increases in the number of employees across Citi who had developmental plans and conversations with their managers. --- ## Modified: Additional Information **Key changes:** - Added sentence: "The "Citi Climate Report," formerly the "Task Force on Climate-Related Financial Disclosure (TCFD) Report," provides additional information on Citi's continued progress to manage climate risk and its Net Zero Plan, including information on financed and facilitated emissions and 2030 interim emissions reduction targets." - Reworded sentence: "For information on Citi's environmental and social governance, see Citi's 2025 Annual Meeting Proxy Statement to be filed with the SEC in March 2025." **Prior (2024):** For additional information on Citi's environmental and social policies and priorities, click on "Our Impact" on Citi's website at www.citigroup.com. For information on Citi's ESG and Sustainability (including climate change) governance, see Citi's 2024 Annual Meeting Proxy Statement to be filed with the SEC in March 2024. Citi's climate reporting and any other ESG-related reports and information included elsewhere on Citi's website are not incorporated by reference into, and do not form any part of, this 2023 Annual Report on Form 10-K. **Current (2025):** The "Citi Climate Report," formerly the "Task Force on Climate-Related Financial Disclosure (TCFD) Report," provides additional information on Citi's continued progress to manage climate risk and its Net Zero Plan, including information on financed and facilitated emissions and 2030 interim emissions reduction targets. For additional information on Citi's environmental and social policies and priorities, click on "Our Impact" on Citi's website at www.citigroup.com. For information on Citi's environmental and social governance, see Citi's 2025 Annual Meeting Proxy Statement to be filed with the SEC in March 2025. Citi's climate reporting and any other environmental and social governance-related reports and information included elsewhere on Citi's website are not incorporated by reference into, and do not form any part of, this Form 10-K. 65 65 65 --- ## Modified: Corporate Credit Portfolio **Key changes:** - Reworded sentence: "The following table details Citi's corporate credit portfolio across Services, Markets, Banking and the Mexico SBMM component of All Other - Legacy Franchises (excluding loans carried at fair value and loans held-for-sale), and before consideration of collateral or hedges, by remaining tenor for the periods indicated: December 31, 2024September 30, 2024December 31, 2023In billions of dollarsDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDirect outstandings (on-balance sheet)(1)$133 $122 $39 $294 $137 $118 $37 $292 $132 $122 $39 $293 Unfunded lending commitments (off-balance sheet)(2)131 274 24 429 132 285 25 442 134 268 18 420 Total exposure$264 $396 $63 $723 $269 $403 $62 $734 $266 $390 $57 $713 Direct outstandings (on-balance sheet)(1) Unfunded lending commitments (off-balance sheet)(2) (1) Includes drawn loans, overdrafts, bankers' acceptances and leases." - Reworded sentence: "The following table presents the percentages of this portfolio across North America and the clusters within International, based on Citi's internal management geography (see "Other Risks - Country Risk - Top 25 Country Exposures" below):December 31,2024September 30,2024December 31,2023North America56 %57 %56 %International44 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)United Kingdom11 %11 %10 %Japan, Asia North and Australia (JANA)7 7 7 LATAM6 6 8 Asia South5 5 5 Europe12 11 11 Middle East and Africa (MEA)3 3 3 The maintenance of accurate and consistent risk ratings across the corporate credit portfolio facilitates the comparison of credit exposure across all lines of business, geographies and products." - Reworded sentence: "Internal ratings that generally correspond to BBB and above are considered investment grade, while those below are considered non-investment grade.The following table presents the corporate credit portfolio by facility risk rating as a percentage of the total corporate credit portfolio: Total exposure December 31,2024September 30,2024December 31,2023AAA/AA/A49 %49 %50 %BBB30 33 33 BB/B19 17 16 CCC or below2 1 1 Total100 %100 %100 %Note: Total exposure includes direct outstandings and unfunded lending commitments." - Reworded sentence: "The following table presents the percentages of this portfolio across North America and the clusters within International, based on Citi's internal management geography (see "Other Risks - Country Risk - Top 25 Country Exposures" below):December 31,2024September 30,2024December 31,2023North America56 %57 %56 %International44 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)United Kingdom11 %11 %10 %Japan, Asia North and Australia (JANA)7 7 7 LATAM6 6 8 Asia South5 5 5 Europe12 11 11 Middle East and Africa (MEA)3 3 3" **Prior (2024):** The following table details Citi's corporate credit portfolio within Services, Markets, Banking and the Mexico SBMM component of All Other - Legacy Franchises (excluding loans carried at fair value and loans held-for-sale), and before consideration of collateral or hedges, by remaining tenor for the periods indicated: December 31, 2023September 30, 2023December 31, 2022In billions of dollarsDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDirect outstandings (on-balance sheet)(1)$132 $122 $39 $293 $125 $118 $38 $281 $135 $122 $27 $284 Unfunded lending commitments (off-balance sheet)(2)134 268 18 420 144 259 19 422 140 256 10 406 Total exposure$266 $390 $57 $713 $269 $377 $57 $703 $275 $378 $37 $690 Direct outstandings (on-balance sheet)(1) Unfunded lending commitments (off-balance sheet)(2) (1) Includes drawn loans, overdrafts, bankers' acceptances and leases. (2) Includes unused commitments to lend, letters of credit and financial guarantees. Portfolio Mix - Geography and CounterpartyCiti's corporate credit portfolio is diverse across geography and counterparty. The following table presents the percentage of this portfolio by region based on Citi's internal management geography:December 31,2023September 30,2023December 31,2022North America56 %56 %56 %International44 44 44 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 internal risk ratings are derived by leveraging validated statistical models and scorecards in combination with consideration of factors specific to the obligor or market, such as management experience, competitive position, regulatory environment 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.The following table presents the corporate credit portfolio by facility risk rating as a percentage of the total corporate credit portfolio: Total exposure December 31,2023September 30,2023December 31,2022AAA/AA/A50 %49 %50 %BBB33 34 34 BB/B16 15 14 CCC or below1 2 2 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. Portfolio Mix - Geography and CounterpartyCiti's corporate credit portfolio is diverse across geography and counterparty. The following table presents the percentage of this portfolio by region based on Citi's internal management geography:December 31,2023September 30,2023December 31,2022North America56 %56 %56 %International44 44 44 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 internal risk ratings are derived by leveraging validated statistical models and scorecards in combination with consideration of factors specific to the obligor or market, such as management experience, competitive position, regulatory environment 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. **Current (2025):** The following table details Citi's corporate credit portfolio across Services, Markets, Banking and the Mexico SBMM component of All Other - Legacy Franchises (excluding loans carried at fair value and loans held-for-sale), and before consideration of collateral or hedges, by remaining tenor for the periods indicated: December 31, 2024September 30, 2024December 31, 2023In billions of dollarsDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDuewithin1 yearGreaterthan 1 yearbut within5 yearsGreaterthan5 yearsTotalexposureDirect outstandings (on-balance sheet)(1)$133 $122 $39 $294 $137 $118 $37 $292 $132 $122 $39 $293 Unfunded lending commitments (off-balance sheet)(2)131 274 24 429 132 285 25 442 134 268 18 420 Total exposure$264 $396 $63 $723 $269 $403 $62 $734 $266 $390 $57 $713 Direct outstandings (on-balance sheet)(1) Unfunded lending commitments (off-balance sheet)(2) (1) Includes drawn loans, overdrafts, bankers' acceptances and leases. (2) Includes unused commitments to lend, letters of credit and financial guarantees. Portfolio Mix - Geography and CounterpartyCiti's corporate credit portfolio is diverse across geography and counterparty. The following table presents the percentages of this portfolio across North America and the clusters within International, based on Citi's internal management geography (see "Other Risks - Country Risk - Top 25 Country Exposures" below):December 31,2024September 30,2024December 31,2023North America56 %57 %56 %International44 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)United Kingdom11 %11 %10 %Japan, Asia North and Australia (JANA)7 7 7 LATAM6 6 8 Asia South5 5 5 Europe12 11 11 Middle East and Africa (MEA)3 3 3 The maintenance of accurate and consistent risk ratings across the corporate credit portfolio facilitates the comparison of credit exposure across all lines of business, geographies and products. Counterparty risk ratings reflect an estimated probability of default for a counterparty, and internal risk ratings are derived by leveraging validated statistical models and scorecards in combination with consideration of factors specific to the obligor or market, such as management experience, competitive position, regulatory environment 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 ratings that generally correspond to BBB and above are considered investment grade, while those below are considered non-investment grade.The following table presents the corporate credit portfolio by facility risk rating as a percentage of the total corporate credit portfolio: Total exposure December 31,2024September 30,2024December 31,2023AAA/AA/A49 %49 %50 %BBB30 33 33 BB/B19 17 16 CCC or below2 1 1 Total100 %100 %100 %Note: Total exposure includes direct outstandings and unfunded lending commitments. Portfolio Mix - Geography and CounterpartyCiti's corporate credit portfolio is diverse across geography and counterparty. The following table presents the percentages of this portfolio across North America and the clusters within International, based on Citi's internal management geography (see "Other Risks - Country Risk - Top 25 Country Exposures" below):December 31,2024September 30,2024December 31,2023North America56 %57 %56 %International44 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)United Kingdom11 %11 %10 %Japan, Asia North and Australia (JANA)7 7 7 LATAM6 6 8 Asia South5 5 5 Europe12 11 11 Middle East and Africa (MEA)3 3 3 --- ## Modified: Taxable Equivalent Basis **Key changes:** - Reworded sentence: "AssetsAverage balanceInterest income% Average rateIn millions of dollars, except rates202420232022202420232022202420232022Deposits with banks(4)$263,236 $287,518 $262,504 $11,417 $11,238 $4,515 4.34 %3.91 %1.72 %Securities borrowed and purchased under agreements to resell(5)In U.S." **Prior (2024):** Average balanceInterest income% Average rateIn millions of dollars, except rates202320222021202320222021202320222021Assets Deposits with banks(4)$287,518 $262,504 $298,319 $11,238 $4,515 $577 3.91 %1.72 %0.19 %Securities borrowed and purchased under agreements to resell(5)In U.S. offices$171,307 $188,672 $172,716 $13,194 $3,933 $385 7.70 %2.08 %0.22 %In offices outside the U.S.(4)189,548 164,675 149,944 13,693 3,221 667 7.22 1.96 0.44 Total$360,855 $353,347 $322,660 $26,887 $7,154 $1,052 7.45 %2.02 %0.33 %Trading account assets(6)(7)In U.S. offices$187,318 $142,146 $140,215 $8,808 $4,005 $2,653 4.70 %2.82 %1.89 %In offices outside the U.S.(4)144,684 132,046 151,722 5,652 3,422 2,718 3.91 2.59 1.79 Total$332,002 $274,192 $291,937 $14,460 $7,427 $5,371 4.36 %2.71 %1.84 %InvestmentsIn U.S. officesTaxable$335,975 $355,012 $322,884 $8,903 $5,642 $3,547 2.65 %1.59 %1.10 %Exempt from U.S. income tax11,502 11,742 12,296 454 424 437 3.95 3.61 3.55 In offices outside the U.S.(4)164,923 150,968 152,940 8,978 5,210 3,498 5.44 3.45 2.29 Total$512,400 $517,722 $488,120 $18,335 $11,276 $7,482 3.58 %2.18 %1.53 %Consumer loans(8)In U.S. offices$293,476 $268,910 $253,184 $30,127 $23,127 $19,810 10.27 %8.60 %7.82 %In offices outside the U.S.(4)78,420 86,497 121,794 6,737 5,264 6,598 8.59 6.09 5.42 Total$371,896 $355,407 $374,978 $36,864 $28,391 $26,408 9.91 %7.99 %7.04 %Corporate loans(8)In U.S. offices$136,065 $139,906 $132,957 $7,561 $5,417 $4,213 5.56 %3.87 %3.17 %In offices outside the U.S.(4)153,111 158,008 160,101 13,507 7,528 4,911 8.82 4.76 3.07 Total$289,176 $297,914 $293,058 $21,068 $12,945 $9,124 7.29 %4.35 %3.11 %Total loans(8)In U.S. offices$429,541 $408,816 $386,141 $37,688 $28,544 $24,023 8.77 %6.98 %6.22 %In offices outside the U.S.(4)231,531 244,505 281,895 20,244 12,792 11,509 8.74 5.23 4.08 Total$661,072 $653,321 $668,036 $57,932 $41,336 $35,532 8.76 %6.33 %5.32 %Other interest-earning assets(9)$81,431 $112,549 $75,876 $4,507 $2,865 $653 5.53 %2.55 %0.86 %Total interest-earning assets$2,235,278 $2,173,635 $2,144,948 $133,359 $74,573 $50,667 5.97 %3.43 %2.36 %Non-interest-earning assets(6)$206,955 $222,388 $202,761 Total assets$2,442,233 $2,396,023 $2,347,709 **Current (2025):** AssetsAverage balanceInterest income% Average rateIn millions of dollars, except rates202420232022202420232022202420232022Deposits with banks(4)$263,236 $287,518 $262,504 $11,417 $11,238 $4,515 4.34 %3.91 %1.72 %Securities borrowed and purchased under agreements to resell(5)In U.S. offices$149,521 $171,307 $188,672 $13,492 $13,194 $3,933 9.02 %7.70 %2.08 %In offices outside the U.S.(4)194,417 189,548 164,675 15,681 13,693 3,221 8.07 7.22 1.96 Total$343,938 $360,855 $353,347 $29,173 $26,887 $7,154 8.48 %7.45 %2.02 %Trading account assets(6)(7)In U.S. offices$233,698 $187,318 $142,146 $11,103 $8,808 $4,005 4.75 %4.70 %2.82 %In offices outside the U.S.(4)162,227 144,684 132,046 6,473 5,652 3,422 3.99 3.91 2.59 Total$395,925 $332,002 $274,192 $17,576 $14,460 $7,427 4.44 %4.36 %2.71 %InvestmentsIn U.S. officesTaxable$307,066 $335,975 $355,012 $7,952 $8,903 $5,642 2.59 %2.65 %1.59 %Exempt from U.S. income tax11,170 11,502 11,742 441 454 424 3.95 3.95 3.61 In offices outside the U.S.(4)184,536 164,923 150,968 10,299 8,978 5,210 5.58 5.44 3.45 Total$502,772 $512,400 $517,722 $18,692 $18,335 $11,276 3.72 %3.58 %2.18 %Consumer loans(8)In U.S. offices$309,668 $293,476 $268,910 $32,684 $30,127 $23,127 10.55 %10.27 %8.60 %In offices outside the U.S.(4)75,215 78,420 86,497 6,858 6,737 5,264 9.12 8.59 6.09 Total$384,883 $371,896 $355,407 $39,542 $36,864 $28,391 10.27 %9.91 %7.99 %Corporate loans(8)In U.S. offices$137,047 $136,065 $139,906 $8,944 $7,561 $5,417 6.53 %5.56 %3.87 %In offices outside the U.S.(4)161,294 153,111 158,008 13,682 13,507 7,528 8.48 8.82 4.76 Total$298,341 $289,176 $297,914 $22,626 $21,068 $12,945 7.58 %7.29 %4.35 %Total loans(8)In U.S. offices$446,715 $429,541 $408,816 $41,628 $37,688 $28,544 9.32 %8.77 %6.98 %In offices outside the U.S.(4)236,509 231,531 244,505 20,540 20,244 12,792 8.68 8.74 5.23 Total$683,224 $661,072 $653,321 $62,168 $57,932 $41,336 9.10 %8.76 %6.33 %Other interest-earning assets(9)$73,418 $81,431 $112,549 $4,781 $4,507 $2,865 6.51 %5.53 %2.55 %Total interest-earning assets$2,262,513 $2,235,278 $2,173,635 $143,807 $133,359 $74,573 6.36 %5.97 %3.43 %Non-interest-earning assets(6)$205,918 $206,955 $222,388 Total assets$2,468,431 $2,442,233 $2,396,023 --- ## Modified: Cash and Investments **Key changes:** - Reworded sentence: "Citi's investment securities portfolio consists largely of highly liquid U.S." - Reworded sentence: "EOP cash and investments decreased 5% quarter-over-quarter, primarily driven by reductions in deposits and total long-term debt." **Prior (2024):** The table below details average and end-of-period Cash and due from banks, Deposits with banks (collectively cash) and Investment securities. Citi's investment portfolio consists largely of highly liquid U.S. Treasury, U.S. agency and other sovereign bonds, with an aggregate duration of less than three years. At December 31, 2023, Citi's EOP cash and Investment securities comprised approximately 32% of Citigroup's total assets: In billions of dollars4Q233Q234Q22Cash and due from banks$27 $27 $30 Deposits with banks252 260 306 Investment securities516 509 519 Total Citigroup cash and investment securities (AVG)$795 $796 $855 Total Citigroup cash and investment securities (EOP)$780 $763 $869 Investment securities Deposits The table below details the average deposits, by business and/or segment, and the total Citigroup end-of-period deposits for each of the periods indicated:In billions of dollars4Q233Q234Q22Services$802 $796 $825 TTS 680 676 694 Securities Services122 120 131 Markets and Banking24 25 23 USPB105 110 111 Wealth312 311 320 All Other - Legacy Franchises49 52 50 All Other - Corporate/Other28 21 32 Total Citigroup deposits (AVG)$1,320 $1,315 $1,361 Total Citigroup deposits (EOP)$1,309 $1,274 $1,366 End-of-period deposits decreased 4% year-over-year, largely due to a reduction in Services reflecting quantitative tightening, and a reduction in USPB and Wealth reflecting a shift of deposits to higher-yielding products. End-of-period deposits increased 3% sequentially. On an average basis, deposits declined 3% year-over-year and were largely unchanged sequentially. As of the fourth quarter of 2023, average deposits for: •Services decreased 3% year-over-year, while TTS and Securities Services decreased 2% and 7%, respectively. These declines reflected the impact of quantitative tightening that more than offset deposits from new client acquisitions and deepening of relationships with existing clients. •USPB decreased 5% year-over-year, driven by the transfer of relationships and the associated deposits to Wealth. •Wealth decreased 3% year-over-year, reflecting the continued mix shift of deposits to higher-yielding investments on Citi's platform, partially offset by the benefits of the transfer of certain relationships and the associated deposit balances from USPB. Deposits The table below details the average deposits, by business and/or segment, and the total Citigroup end-of-period deposits for each of the periods indicated: In billions of dollars4Q233Q234Q22Services$802 $796 $825 TTS 680 676 694 Securities Services122 120 131 Markets and Banking24 25 23 USPB105 110 111 Wealth312 311 320 All Other - Legacy Franchises49 52 50 All Other - Corporate/Other28 21 32 Total Citigroup deposits (AVG)$1,320 $1,315 $1,361 Total Citigroup deposits (EOP)$1,309 $1,274 $1,366 Securities Services **Current (2025):** The table below details average and end-of-period Cash and due from banks, Deposits with banks (collectively cash) and Investment securities. Citi's investment securities portfolio consists largely of highly liquid U.S. Treasury, U.S. agency and other sovereign bonds, with an aggregate duration of less than three years. EOP cash and investments decreased 5% quarter-over-quarter, primarily driven by reductions in deposits and total long-term debt. At December 31, 2024, Citi's EOP cash and Investment securities comprised approximately 32% of total assets: In billions of dollars4Q243Q244Q23Cash and due from banks$30 $26 $27 Deposits with banks284 266 252 Investment securities484 500 516 Total Citigroup cash and investment securities (AVG)$798 $792 $795 Total Citigroup cash and investment securities (EOP)$753 $794 $780 Investment securities Deposits The table below details the average deposits, by segment and/or business, and the total Citigroup end-of-period deposits for each of the periods indicated:In billions of dollars4Q243Q244Q23Services$839 $825 $803 TTS 704 690 681 Securities Services135 135 122 Markets(1)15 19 23 Banking1 1 1 Wealth315 316 307 USPB86 85 105 All Other - Legacy Franchises42 45 52 All Other - Corporate/Other(1)22 20 29 Total Citigroup deposits (AVG)$1,320 $1,311 $1,320 Total Citigroup deposits (EOP)$1,284 $1,310 $1,309 (1) During the third quarter of 2024, approximately $9 billion of institutional deposits were moved from Markets to All Other - Corporate/Other. Prior periods were not reclassified. For additional information about the reallocated deposits, see Note 3.Citi's deposit base is spread across a diversified set of countries, industries, clients and currencies and is subject to Citi's Liquidity Risk Management Policy and Procedures. End-of-period deposits decreased 2% year-over-year, primarily driven by declines in Legacy Franchises, reflecting the continued wind-downs, the impact of FX translation and reductions of corporate certificates of deposit in Corporate/Other. End-of-period deposits decreased 2% sequentially, primarily driven by temporary reductions at year end in Services.On an average basis, deposits were relatively flat year-over-year and increased 1% sequentially, primarily driven by Services. In the fourth quarter of 2024, average deposits for:•Services increased 4% year-over-year, as TTS increased 3% due to deepened client relationships and growth in operational deposits, and Securities Services increased 11% driven by AUC growth.•USPB decreased 18% year-over-year, as the transfer of certain relationships and the associated deposits to Wealth more than offset underlying deposit growth.•Wealth increased 3% year-over-year, largely reflecting the transfer of certain relationships and the associated deposits from USPB, partially offset by the shift in deposits to higher-yielding investments on Citi's platform.•All Other decreased 21% year-over-year, primarily reflecting the continued wind-downs, the impact of FX translation of deposits in Legacy Franchises and reductions of corporate certificates of deposit in Corporate/Other. Deposits The table below details the average deposits, by segment and/or business, and the total Citigroup end-of-period deposits for each of the periods indicated: In billions of dollars4Q243Q244Q23Services$839 $825 $803 TTS 704 690 681 Securities Services135 135 122 Markets(1)15 19 23 Banking1 1 1 Wealth315 316 307 USPB86 85 105 All Other - Legacy Franchises42 45 52 All Other - Corporate/Other(1)22 20 29 Total Citigroup deposits (AVG)$1,320 $1,311 $1,320 Total Citigroup deposits (EOP)$1,284 $1,310 $1,309 Securities Services --- ## Modified: Markets(1) **Key changes:** - Reworded sentence: "All Other - Legacy Franchises All Other - Corporate/Other(1) (1) During the third quarter of 2024, approximately $9 billion of institutional deposits were moved from Markets to All Other - Corporate/Other." - Reworded sentence: "31, 2023Unsecured debt7.3 7.5 7.5 Non-bank benchmark debt6.9 7.0 7.0 Customer-related debt8.7 8.6 8.6 TLAC-eligible debt8.4 8.5 8.6 The WAM is calculated based on the contractual maturity of each security." - Reworded sentence: "31, 2023Non-bank(1)Benchmark debt:Senior debt$107.4 $114.0 $110.3 Subordinated debt28.7 27.9 24.9 Trust preferred1.6 1.6 1.6 Customer-related debt103.3 108.8 110.1 Local country and other(2)10.8 10.3 8.0 Total non-bank$251.8 $262.6 $254.9 BankFHLB borrowings$8.5 $11.5 $11.5 Securitizations(3)5.1 5.4 6.7 Citibank benchmark senior debt19.4 16.9 10.1 Local country and other(2)2.5 2.7 3.4 Total bank$35.5 $36.5 $31.7 Total long-term debt$287.3 $299.1 $286.6 Note: Amounts represent the current value of long-term debt on Citi's Consolidated Balance Sheet that, for certain debt instruments, includes consideration of fair value, hedging impacts and unamortized discounts and premiums.(1) Non-bank includes long-term debt issued to third parties by the parent holding company (Citigroup) and Citi's non-bank subsidiaries (including broker-dealer subsidiaries) that are consolidated into Citigroup." - Reworded sentence: "Within non-bank, certain secured financing is also included.(3) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.Citi's total long-term debt outstanding was essentially unchanged year-over-year." - Reworded sentence: "During 2024, Citi redeemed or repurchased an aggregate of $46.8 billion of its outstanding long-term debt." **Prior (2024):** All Other - Legacy Franchises All Other - Corporate/Other End-of-period deposits decreased 4% year-over-year, largely due to a reduction in Services reflecting quantitative tightening, and a reduction in USPB and Wealth reflecting a shift of deposits to higher-yielding products. End-of-period deposits increased 3% sequentially. On an average basis, deposits declined 3% year-over-year and were largely unchanged sequentially. As of the fourth quarter of 2023, average deposits for: •Services decreased 3% year-over-year, while TTS and Securities Services decreased 2% and 7%, respectively. These declines reflected the impact of quantitative tightening that more than offset deposits from new client acquisitions and deepening of relationships with existing clients. •USPB decreased 5% year-over-year, driven by the transfer of relationships and the associated deposits to Wealth. •Wealth decreased 3% year-over-year, reflecting the continued mix shift of deposits to higher-yielding investments on Citi's platform, partially offset by the benefits of the transfer of certain relationships and the associated deposit balances from USPB. 93 93 93 Long-Term DebtLong-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. Weighted-Average Maturity (WAM) The following table presents Citigroup and its affiliates' (including Citibank) WAM of unsecured long-term debt issued with a remaining life greater than one year:WAM in yearsDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Unsecured debt7.5 7.4 7.6 Non-bank benchmark debt7.0 7.1 7.4 Customer-related debt8.6 8.2 8.1 TLAC-eligible debt8.6 8.7 9.0 The WAM is calculated based on the contractual maturity of each security. For securities that are redeemable prior to maturity where the option is not held by the issuer, the WAM is calculated based on the earliest date an option becomes exercisable.Long-Term Debt OutstandingThe following table presents Citi's end-of-period total long-term debt outstanding for each of the dates indicated:In billions of dollarsDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Non-bank(1)Benchmark debt:Senior debt$110.3 $110.3 $117.5 Subordinated debt24.9 24.5 22.5 Trust preferred1.6 1.6 1.6 Customer-related debt110.1 106.4 101.1 Local country and other(2)8.0 8.5 7.8 Total non-bank$254.9 $251.3 $250.5 BankFHLB borrowings$11.5 $8.5 $7.3 Securitizations(3)6.7 5.2 7.6 Citibank benchmark senior debt10.1 7.6 2.6 Local country and other(2)3.4 3.2 3.6 Total bank$31.7 $24.5 $21.1 Total long-term debt$286.6 $275.8 $271.6 Note: Amounts represent the current value of long-term debt on Citi's Consolidated Balance Sheet that, for certain debt instruments, includes consideration of fair value, hedging impacts and unamortized discounts and premiums.(1) Non-bank includes long-term debt issued to third parties by the parent holding company (Citigroup) and Citi's non-bank subsidiaries (including broker-dealer subsidiaries) that are consolidated into Citigroup. As of December 31, 2023, non-bank included $92.6 billion of long-term debt issued by Citi's broker-dealer and other subsidiaries that are consolidated into Citigroup. Certain Citigroup consolidated hedging activities are also included in this line.(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.(3) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.Citi's total long-term debt outstanding increased 6% year-over-year, largely driven by issuance of customer-related debt at the non-bank entities, as well as increased senior benchmark debt and FHLB borrowings at the bank. The increase was partially offset by a decline in senior benchmark debt at the non-bank entities. Sequentially, long-term debt outstanding also increased 4%, largely driven by an increase in customer-related debt at the non-bank entities and increased FHLB borrowings and benchmark senior debt at the bank.As part of its liability management, Citi has considered, and may continue to consider, opportunities to redeem or repurchase its long-term debt pursuant to open market purchases, tender offers or other means. Such redemptions and repurchases help reduce Citi's overall funding costs. During 2023, Citi redeemed or repurchased an aggregate of approximately $32.0 billion of its outstanding long-term debt. Long-Term DebtLong-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. Weighted-Average Maturity (WAM) The following table presents Citigroup and its affiliates' (including Citibank) WAM of unsecured long-term debt issued with a remaining life greater than one year:WAM in yearsDec. 31, 2023Sept. 30, 2023Dec. 31, 2022Unsecured debt7.5 7.4 7.6 Non-bank benchmark debt7.0 7.1 7.4 Customer-related debt8.6 8.2 8.1 TLAC-eligible debt8.6 8.7 9.0 The WAM is calculated based on the contractual maturity of each security. For securities that are redeemable prior to maturity where the option is not held by the issuer, the WAM is calculated based on the earliest date an option becomes exercisable. **Current (2025):** All Other - Legacy Franchises All Other - Corporate/Other(1) (1) During the third quarter of 2024, approximately $9 billion of institutional deposits were moved from Markets to All Other - Corporate/Other. Prior periods were not reclassified. For additional information about the reallocated deposits, see Note 3. Citi's deposit base is spread across a diversified set of countries, industries, clients and currencies and is subject to Citi's Liquidity Risk Management Policy and Procedures. End-of-period deposits decreased 2% year-over-year, primarily driven by declines in Legacy Franchises, reflecting the continued wind-downs, the impact of FX translation and reductions of corporate certificates of deposit in Corporate/Other. End-of-period deposits decreased 2% sequentially, primarily driven by temporary reductions at year end in Services. On an average basis, deposits were relatively flat year-over-year and increased 1% sequentially, primarily driven by Services. In the fourth quarter of 2024, average deposits for: •Services increased 4% year-over-year, as TTS increased 3% due to deepened client relationships and growth in operational deposits, and Securities Services increased 11% driven by AUC growth. •USPB decreased 18% year-over-year, as the transfer of certain relationships and the associated deposits to Wealth more than offset underlying deposit growth. •Wealth increased 3% year-over-year, largely reflecting the transfer of certain relationships and the associated deposits from USPB, partially offset by the shift in deposits to higher-yielding investments on Citi's platform. •All Other decreased 21% year-over-year, primarily reflecting the continued wind-downs, the impact of FX translation of deposits in Legacy Franchises and reductions of corporate certificates of deposit in Corporate/Other. 96 96 96 The majority of Citi's $1.3 trillion of end-of-period deposits are institutional (approximately $820 billion) and span approximately 90 countries. A large majority of these institutional deposits are within TTS, and of these, approximately 80% are from clients that use all three TTS integrated services: payments and collections, liquidity management and working capital solutions. In addition, nearly 80% of TTS deposits are from clients that have a longer than 15-year relationship with Citi. Citi also has a strong consumer and wealth deposit base, with $402 billion of USPB and Wealth deposits as of year end, which are diversified across the Private Bank, Citigold and Wealth at Work within Wealth, as well as USPB, and across regions and products. As of year end, approximately 66% of U.S. Citigold clients have been with Citi for more than 10 years and approximately 39% of Private Bank ultra-high net worth clients have been with Citi for more than 10 years. In addition, USPB's deposits are spread across six key metropolitan areas in the U.S.Long-Term DebtLong-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. Weighted-Average Maturity (WAM) The following table presents Citigroup and its affiliates' (including Citibank) WAM of unsecured long-term debt issued with a remaining life greater than one year:WAM in yearsDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Unsecured debt7.3 7.5 7.5 Non-bank benchmark debt6.9 7.0 7.0 Customer-related debt8.7 8.6 8.6 TLAC-eligible debt8.4 8.5 8.6 The WAM is calculated based on the contractual maturity of each security. For securities that are redeemable prior to maturity where the option is not held by the issuer, the WAM is calculated based on the earliest date an option becomes exercisable.Long-Term Debt OutstandingThe following table presents Citi's end-of-period total long-term debt outstanding for each of the dates indicated:In billions of dollarsDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Non-bank(1)Benchmark debt:Senior debt$107.4 $114.0 $110.3 Subordinated debt28.7 27.9 24.9 Trust preferred1.6 1.6 1.6 Customer-related debt103.3 108.8 110.1 Local country and other(2)10.8 10.3 8.0 Total non-bank$251.8 $262.6 $254.9 BankFHLB borrowings$8.5 $11.5 $11.5 Securitizations(3)5.1 5.4 6.7 Citibank benchmark senior debt19.4 16.9 10.1 Local country and other(2)2.5 2.7 3.4 Total bank$35.5 $36.5 $31.7 Total long-term debt$287.3 $299.1 $286.6 Note: Amounts represent the current value of long-term debt on Citi's Consolidated Balance Sheet that, for certain debt instruments, includes consideration of fair value, hedging impacts and unamortized discounts and premiums.(1) Non-bank includes long-term debt issued to third parties by the parent holding company (Citigroup) and Citi's non-bank subsidiaries (including broker-dealer subsidiaries) that are consolidated into Citigroup. As of December 31, 2024, non-bank included $87.8 billion of long-term debt issued by Citi's broker-dealer and other subsidiaries that are consolidated into Citigroup. Certain Citigroup consolidated hedging activities are also included in this line.(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.(3) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.Citi's total long-term debt outstanding was essentially unchanged year-over-year. Sequentially, long-term debt outstanding decreased 4%, largely related to net maturities of senior benchmark debt at the bank and non-bank entities and customer-related debt issuances at the non-bank entities. As part of its liability management, Citi has considered, and may continue to consider, opportunities to redeem or repurchase its long-term debt pursuant to open market purchases, tender offers or other means. Such redemptions and repurchases help reduce Citi's overall funding costs. During 2024, Citi redeemed or repurchased an aggregate of $46.8 billion of its outstanding long-term debt. The majority of Citi's $1.3 trillion of end-of-period deposits are institutional (approximately $820 billion) and span approximately 90 countries. A large majority of these institutional deposits are within TTS, and of these, approximately 80% are from clients that use all three TTS integrated services: payments and collections, liquidity management and working capital solutions. In addition, nearly 80% of TTS deposits are from clients that have a longer than 15-year relationship with Citi. Citi also has a strong consumer and wealth deposit base, with $402 billion of USPB and Wealth deposits as of year end, which are diversified across the Private Bank, Citigold and Wealth at Work within Wealth, as well as USPB, and across regions and products. As of year end, approximately 66% of U.S. Citigold clients have been with Citi for more than 10 years and approximately 39% of Private Bank ultra-high net worth clients have been with Citi for more than 10 years. In addition, USPB's deposits are spread across six key metropolitan areas in the U.S.Long-Term DebtLong-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. Weighted-Average Maturity (WAM) The following table presents Citigroup and its affiliates' (including Citibank) WAM of unsecured long-term debt issued with a remaining life greater than one year:WAM in yearsDec. 31, 2024Sept. 30, 2024Dec. 31, 2023Unsecured debt7.3 7.5 7.5 Non-bank benchmark debt6.9 7.0 7.0 Customer-related debt8.7 8.6 8.6 TLAC-eligible debt8.4 8.5 8.6 The WAM is calculated based on the contractual maturity of each security. For securities that are redeemable prior to maturity where the option is not held by the issuer, the WAM is calculated based on the earliest date an option becomes exercisable. The majority of Citi's $1.3 trillion of end-of-period deposits are institutional (approximately $820 billion) and span approximately 90 countries. A large majority of these institutional deposits are within TTS, and of these, approximately 80% are from clients that use all three TTS integrated services: payments and collections, liquidity management and working capital solutions. In addition, nearly 80% of TTS deposits are from clients that have a longer than 15-year relationship with Citi. Citi also has a strong consumer and wealth deposit base, with $402 billion of USPB and Wealth deposits as of year end, which are diversified across the Private Bank, Citigold and Wealth at Work within Wealth, as well as USPB, and across regions and products. As of year end, approximately 66% of U.S. Citigold clients have been with Citi for more than 10 years and approximately 39% of Private Bank ultra-high net worth clients have been with Citi for more than 10 years. In addition, USPB's deposits are spread across six key metropolitan areas in the U.S. --- ## Modified: Rating of Hedged Exposure **Key changes:** - Reworded sentence: "December 31,2024September 30,2024December 31,2023AAA/AA/A44 %44 %45 %BBB45 47 44 BB/B10 8 10 CCC or below1 1 1 Total100 %100 %100 % 77 77 77" **Prior (2024):** December 31,2023September 30,2023December 31,2022AAA/AA/A45 %45 %39 %BBB44 43 45 BB/B10 10 12 CCC or below1 2 4 Total100 %100 %100 % 74 74 74 **Current (2025):** December 31,2024September 30,2024December 31,2023AAA/AA/A44 %44 %45 %BBB45 47 44 BB/B10 8 10 CCC or below1 1 1 Total100 %100 %100 % 77 77 77 --- ## Modified: Mexico Consumer **Key changes:** - Reworded sentence: "Mexico Consumer operates in Mexico through Banamex and provides credit cards, consumer mortgages and small business and personal loans." - Reworded sentence: "FICO scores are updated as they become available.Branded CardsFICO distribution(1)Dec." - Removed sentence: "Cards FICO DistributionThe following tables present the current FICO score distributions for Citi's Branded Cards and Retail Services portfolios based on end-of-period receivables." - Removed sentence: "FICO scores are updated monthly for substantially all of the portfolio and on a quarterly basis for the remaining portfolio.Branded CardsFICO distribution(1)Dec." - Removed sentence: "31, 2022> 76046 %46 %48 %680-76038 39 38 < 68016 15 14 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec." **Prior (2024):** Mexico Consumer operates in Mexico through Citibanamex and provides credit cards, consumer mortgages and small business and personal loans. Mexico Consumer serves a more mass-market segment in Mexico and focuses on developing multiproduct relationships with customers. As presented in the chart above, the fourth quarter of 2023 net credit loss rate in Mexico Consumer increased quarter-over-quarter and year-over-year, primarily driven by the ongoing normalization of loss rates from post-pandemic lows. The 90+ days past due delinquency rate was relatively stable quarter-over-quarter and year-over-year. For additional information on cost of credit, loan delinquency and other information for Citi's consumer loan portfolios, see each respective business's results of operations above and Note 15. 78 78 78 U.S. Cards FICO DistributionThe following tables present the current FICO score distributions for Citi's Branded Cards and Retail Services portfolios based on end-of-period receivables. FICO scores are updated monthly for substantially all of the portfolio and on a quarterly basis for the remaining portfolio.Branded CardsFICO distribution(1)Dec. 31, 2023Sept. 30, 2023Dec. 31, 2022> 76046 %46 %48 %680-76038 39 38 < 68016 15 14 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec. 31, 2023Sept. 30, 2023Dec. 31, 2022> 76027 %26 %27 %680-76041 42 42 < 68032 32 31 Total100 %100 %100 %(1)The FICO bands in the tables are consistent with general industry peer presentations. The FICO distribution of both card portfolios declined slightly during 2023, primarily reflecting the normalization in net credit loss and delinquency rates. The FICO distribution continued to reflect strong underlying credit quality of the portfolios. See Note 15 for additional information on FICO scores. U.S. Cards FICO DistributionThe following tables present the current FICO score distributions for Citi's Branded Cards and Retail Services portfolios based on end-of-period receivables. FICO scores are updated monthly for substantially all of the portfolio and on a quarterly basis for the remaining portfolio.Branded CardsFICO distribution(1)Dec. 31, 2023Sept. 30, 2023Dec. 31, 2022> 76046 %46 %48 %680-76038 39 38 < 68016 15 14 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec. 31, 2023Sept. 30, 2023Dec. 31, 2022> 76027 %26 %27 %680-76041 42 42 < 68032 32 31 Total100 %100 %100 %(1)The FICO bands in the tables are consistent with general industry peer presentations. The FICO distribution of both card portfolios declined slightly during 2023, primarily reflecting the normalization in net credit loss and delinquency rates. The FICO distribution continued to reflect strong underlying credit quality of the portfolios. See Note 15 for additional information on FICO scores. **Current (2025):** Mexico Consumer operates in Mexico through Banamex and provides credit cards, consumer mortgages and small business and personal loans. Mexico Consumer serves a mass-market segment in Mexico and focuses on developing multiproduct relationships with customers. As of December 31, 2024, approximately 40% of Mexico Consumer EOP loans consisted of credit card loans, which generally drives the overall credit performance of Mexico Consumer, as the cards net credit losses represented approximately 60% of total Mexico Consumer net credit losses for the fourth quarter of 2024. As presented in the chart above, the fourth quarter of 2024 net credit loss rate and the 90+ days past due delinquency rate in Mexico Consumer increased quarter-over-quarter and year-over-year, primarily driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows. For additional details on cost of credit, loan delinquency and other information for Citi's consumer loan portfolios, see each respective business's results of operations above and Note 15. U.S. Cards FICO DistributionThe following tables present the current FICO score distributions for Citi's Branded Cards and Retail Services portfolios based on end-of-period receivables. FICO scores are updated as they become available.Branded CardsFICO distribution(1)Dec. 31, 2024Sept. 30, 2024Dec. 31, 2023≥ 74056 %55 %57 %660-73933 34 33 < 66011 11 10 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec. 31, 2024Sept. 30, 2024Dec. 31, 2023≥ 74036 %34 %36 %660-73941 42 41 < 66023 24 23 Total100 %100 %100 %(1)Excludes immaterial balances for Canada and for customers for which no FICO scores are available. The FICO distribution of both Branded Cards and Retail Services portfolios was broadly stable quarter-over-quarter and year-over-year. The FICO distribution continued to reflect the strong underlying credit quality of the portfolios. See Note 15 for additional information on FICO scores. --- ## Modified: Citi's Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs. **Key changes:** - Removed sentence: "During 2023, emerging markets revenues accounted for approximately 40% 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)." - Added sentence: "During 2024, emerging markets revenues accounted for approximately 28% of Citi's total revenues (based, beginning in 2024, on the IMF and FFIEC classifications, which resulted in the exclusion of certain countries that Citi previously classified as emerging markets)." - Reworded sentence: "dollar; central bank interest rate and other monetary policies, including the impact of sustained high interest rates in the U.S.; unemployment, recessions or weak or slowing economic growth; elevated inflation and hyperinflation; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; macroeconomic, 63 63 63 geopolitical and domestic political challenges, uncertainties and volatility, including with respect to China, the Russia-Ukraine war and conflicts in the Middle East; cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; the effects of potential policy and other changes resulting from the new U.S." - Reworded sentence: "In the event of a loss of control of AO Citibank in Russia, Citi would be required to (i) write off its remaining nominal net investment, (ii) recognize a CTA loss of approximately $1.6 billion through earnings and (iii) recognize a loss of $0.9 billion on intercompany liabilities owed by AO Citibank to other Citi entities outside of Russia." - Reworded sentence: "Net Zero Emissions by 2050As previously disclosed, Citi has committed to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its own operations by 2030." **Prior (2024):** During 2023, emerging markets revenues accounted for approximately 40% 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). Citi's presence in the emerging markets subjects it to various risks. Emerging market risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations and strength in the U.S. dollar; sustained elevated interest rates and quantitative tightening; elevated inflation and hyperinflation; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; macroeconomic, geopolitical and domestic political challenges, uncertainties and volatility, including with respect to Russia (see the macroeconomic and geopolitical risk factor above and "Managing Global Risk - Other Risks - Country Risk - Russia" and " - Ukraine" below); cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; election outcomes; regulatory changes, including potential conflicts among regulations with other jurisdictions where Citi does business; limitations on foreign investment; sociopolitical instability; civil unrest; crime, corruption and fraud; nationalization or loss of licenses; potential criminal charges; closure of branches or subsidiaries; and confiscation of assets; and these risks can be exacerbated in the event of a deterioration in the relationship 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 controls, currency controls and/or sanctions, such as Argentina and Russia, that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. For instance, Citi may need to record additional translation losses due to currency controls in Argentina (see "Managing Global Risk - Other Risks - Country Risk - Argentina" below). Moreover, Citi may need to record additional reserves for expected losses for its credit exposures based on the transfer risk associated with exposures outside the U.S., driven by safety and soundness considerations under U.S. banking law (see "Managing Global Risk - Other Risks - Country Risk - Argentina" and " - Russia" and "Significant Accounting Policies and Significant Estimates" below). In addition, political turmoil and instability; geopolitical challenges, tensions and conflicts (including those related to Russia's war in Ukraine as well as a persistent and/or escalating conflict in the Middle East); terrorism; and other instabilities have occurred in various regions and emerging market countries across the globe, which impact Citi's businesses, results of operations and financial conditions in affected countries and have required, and may continue to require, management time and attention and other resources, such as managing the impact of sanctions and their effect on Citi's operations in certain emerging market countries. For 61 61 61 additional information, see the macroeconomic challenges and uncertainties risk factor above. CLIMATE CHANGE AND NET ZEROIntroduction This section summarizes Citi's Operational Footprint goals and Net Zero commitment. Citi's annual ESG Report provides information on a broad set of ESG-related efforts. The upcoming Citi Climate Report, formerly named the Task Force on Climate-Related Financial Disclosures (TCFD) Report, provides information on Citi's continued progress to manage climate risk and its Net Zero plan, including information on financed emissions and 2030 interim emissions reduction targets. For information regarding Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. ESG and Climate-Related GovernanceCiti's Board of Directors (Board) provides oversight of Citi's management activities (see "Managing Global Risk - Risk Governance" below). •The Nomination, Governance and Public Affairs Committee of the Board provides oversight and receives updates on Citi's environmental and social policies and commitments.•The Risk Management Committee of the Board provides oversight of Citi's Risk Management Framework and risk culture and reviews Citi's key risk policies and frameworks, including receiving climate risk-related updates.•The Audit Committee of the Board provides oversight of controls and procedures pertaining to the ESG-related metrics and related disclosures in Citi's SEC filed reports and group-level voluntary ESG reporting, as well as management's evaluation of the effectiveness of Citi's disclosure controls and procedures for group-level ESG reporting.Additionally, Citi's ESG Council consists of senior members of the management team and certain subject matter experts who provide oversight of Citi's ESG goals and activities.Sustainable FinanceCiti's Sustainable Finance Goal, as previously disclosed, supports a combination of environmental and social finance activities. Delivering on the sustainable finance goal is an integrated effort across the organization with products and service offerings across multiple lines of business. Net Zero Emissions by 2050As previously disclosed, Citi has committed to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its own operations by 2030; both are significant targets given the size and breadth of Citi's lending portfolios, businesses and operational footprint.Citi's Net Zero plan includes:•Net Zero Metrics and Target Setting: Calculate metrics and assess targets for carbon-intensive sectors•Client Engagement and Assessment: Seek to understand client GHG emissions and transition plans and advise on capacity building•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 risk appetite and thresholds and policies related to Climate Risk Management•Clean Technology and Transition Finance: Support existing and, where possible, new technologies to accelerate commercialization and provide transition advisory and finance products and services•Portfolio Management: Active portfolio management of Citi financings to align with net zero targets, including considerations of transition measures taken by clients•Public Policy and Regulatory Engagement: Contribute to an enabling public policy and regulatory environment which is essential to stimulating demand for clean technologies and helping ensure a responsible transitionProgress on Citi's Net Zero plan: •Citi has published interim 2030 emissions targets for six loan portfolios: auto manufacturing, commercial real estate (North America), energy, power, steel and thermal coal mining. •Citi has developed a client transition assessment process to help internal teams better understand the alignment of clients' strategies with transition or decarbonization pathways applicable to their respective sectors. In 2022-2023, Citi completed the initial assessment process for energy and power clients, and in 2023 began the transition assessment process for auto manufacturing and steel clients. The assessment process focuses on clients with material emissions relative to each sector's baseline emission profiles.Operational Footprint GoalsCiti measures progress against operational footprint goals, which include efforts to reduce the environmental impact of its facilities through reductions in emissions, energy, water consumption and waste generation. Citi's efforts to integrate sustainable practices include sustainable building certifications, renewable electricity sourcing, employee engagement and seeking opportunities for efficiency in business travel. In 2023, Citi made progress toward these goals by increasing on-site solar generation, promoting initiatives on waste diversion and recycling, mapping weather- additional information, see the macroeconomic challenges and uncertainties risk factor above. CLIMATE CHANGE AND NET ZEROIntroduction This section summarizes Citi's Operational Footprint goals and Net Zero commitment. Citi's annual ESG Report provides information on a broad set of ESG-related efforts. The upcoming Citi Climate Report, formerly named the Task Force on Climate-Related Financial Disclosures (TCFD) Report, provides information on Citi's continued progress to manage climate risk and its Net Zero plan, including information on financed emissions and 2030 interim emissions reduction targets. For information regarding Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. ESG and Climate-Related GovernanceCiti's Board of Directors (Board) provides oversight of Citi's management activities (see "Managing Global Risk - Risk Governance" below). •The Nomination, Governance and Public Affairs Committee of the Board provides oversight and receives updates on Citi's environmental and social policies and commitments.•The Risk Management Committee of the Board provides oversight of Citi's Risk Management Framework and risk culture and reviews Citi's key risk policies and frameworks, including receiving climate risk-related updates.•The Audit Committee of the Board provides oversight of controls and procedures pertaining to the ESG-related metrics and related disclosures in Citi's SEC filed reports and group-level voluntary ESG reporting, as well as management's evaluation of the effectiveness of Citi's disclosure controls and procedures for group-level ESG reporting.Additionally, Citi's ESG Council consists of senior members of the management team and certain subject matter experts who provide oversight of Citi's ESG goals and activities.Sustainable FinanceCiti's Sustainable Finance Goal, as previously disclosed, supports a combination of environmental and social finance activities. Delivering on the sustainable finance goal is an integrated effort across the organization with products and service offerings across multiple lines of business. additional information, see the macroeconomic challenges and uncertainties risk factor above. **Current (2025):** Citi's presence in the emerging markets subjects it to various risks. During 2024, emerging markets revenues accounted for approximately 28% of Citi's total revenues (based, beginning in 2024, on the IMF and FFIEC classifications, which resulted in the exclusion of certain countries that Citi previously classified as emerging markets). Emerging market risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations and strength in the U.S. dollar; central bank interest rate and other monetary policies, including the impact of sustained high interest rates in the U.S.; unemployment, recessions or weak or slowing economic growth; elevated inflation and hyperinflation; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; macroeconomic, 63 63 63 geopolitical and domestic political challenges, uncertainties and volatility, including with respect to China, the Russia-Ukraine war and conflicts in the Middle East; cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; the effects of potential policy and other changes resulting from the new U.S. administration, including those related to Mexico; the effects of potential policy and other changes resulting from the new Mexican administration and Congress, including judicial reforms; regulatory changes, including potential conflicts among regulations with other jurisdictions where Citi does business; limitations on foreign investment; sociopolitical instability; civil unrest; crime, corruption and fraud; nationalization or loss of licenses; potential criminal charges; closure of branches or subsidiaries; and confiscation of assets; and these risks can be exacerbated in the event of a deterioration in the relationship 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 controls, currency controls and/or sanctions, such as Argentina and Russia, that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. For instance, Citi may need to record additional translation losses due to currency controls in Argentina (see "Managing Global Risk - Other Risks - Country Risk - Argentina" below). Moreover, Citi may need to record additional reserves for expected losses for its credit exposures based on the transfer risk associated with exposures outside the U.S., driven by safety and soundness considerations under U.S. banking law (see "Managing Global Risk - Other Risks - Country Risk - Argentina" and " - Russia" and "Significant Accounting Policies and Significant Estimates" below).In the event of a loss of control of AO Citibank in Russia, Citi would be required to (i) write off its remaining nominal net investment, (ii) recognize a CTA loss of approximately $1.6 billion through earnings and (iii) recognize a loss of $0.9 billion on intercompany liabilities owed by AO Citibank to other Citi entities outside of Russia. In the sole event of a substantial liquidation, as opposed to a loss of control, Citi would be required to recognize the CTA loss of approximately $1.6 billion through earnings and would evaluate its remaining net investment as circumstances evolve. For additional information about these risks and related potential impacts, see the operational processes and systems and cybersecurity risk factors above and "Managing Global Risk - Other Risks - Country Risk - Russia" below.In addition, political turmoil and instability; geopolitical challenges, tensions and conflicts (including those related to China, the Russia-Ukraine war and the conflicts in the Middle East); terrorism; and other instabilities have occurred in various regions and emerging market countries across the globe, which impact Citi's businesses, results of operations and financial conditions in those countries where Citi operates and have required, and may continue to require, management time and attention and other resources, such as managing the impact of sanctions and their effect on Citi's operations in certain emerging market countries. For additional information, see the macroeconomic challenges and uncertainties risk factor above. geopolitical and domestic political challenges, uncertainties and volatility, including with respect to China, the Russia-Ukraine war and conflicts in the Middle East; cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; the effects of potential policy and other changes resulting from the new U.S. administration, including those related to Mexico; the effects of potential policy and other changes resulting from the new Mexican administration and Congress, including judicial reforms; regulatory changes, including potential conflicts among regulations with other jurisdictions where Citi does business; limitations on foreign investment; sociopolitical instability; civil unrest; crime, corruption and fraud; nationalization or loss of licenses; potential criminal charges; closure of branches or subsidiaries; and confiscation of assets; and these risks can be exacerbated in the event of a deterioration in the relationship 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 controls, currency controls and/or sanctions, such as Argentina and Russia, that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. For instance, Citi may need to record additional translation losses due to currency controls in Argentina (see "Managing Global Risk - Other Risks - Country Risk - Argentina" below). Moreover, Citi may need to record additional reserves for expected losses for its credit exposures based on the transfer risk associated with exposures outside the U.S., driven by safety and soundness considerations under U.S. banking law (see "Managing Global Risk - Other Risks - Country Risk - Argentina" and " - Russia" and "Significant Accounting Policies and Significant Estimates" below).In the event of a loss of control of AO Citibank in Russia, Citi would be required to (i) write off its remaining nominal net investment, (ii) recognize a CTA loss of approximately $1.6 billion through earnings and (iii) recognize a loss of $0.9 billion on intercompany liabilities owed by AO Citibank to other Citi entities outside of Russia. In the sole event of a substantial liquidation, as opposed to a loss of control, Citi would be required to recognize the CTA loss of approximately $1.6 billion through earnings and would evaluate its remaining net investment as circumstances evolve. For additional information about these risks and related potential impacts, see the operational processes and systems and cybersecurity risk factors above and "Managing Global Risk - Other Risks - Country Risk - Russia" below. geopolitical and domestic political challenges, uncertainties and volatility, including with respect to China, the Russia-Ukraine war and conflicts in the Middle East; cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; the effects of potential policy and other changes resulting from the new U.S. administration, including those related to Mexico; the effects of potential policy and other changes resulting from the new Mexican administration and Congress, including judicial reforms; regulatory changes, including potential conflicts among regulations with other jurisdictions where Citi does business; limitations on foreign investment; sociopolitical instability; civil unrest; crime, corruption and fraud; nationalization or loss of licenses; potential criminal charges; closure of branches or subsidiaries; and confiscation of assets; and these risks can be exacerbated in the event of a deterioration in the relationship 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 controls, currency controls and/or sanctions, such as Argentina and Russia, that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. For instance, Citi may need to record additional translation losses due to currency controls in Argentina (see "Managing Global Risk - Other Risks - Country Risk - Argentina" below). Moreover, Citi may need to record additional reserves for expected losses for its credit exposures based on the transfer risk associated with exposures outside the U.S., driven by safety and soundness considerations under U.S. banking law (see "Managing Global Risk - Other Risks - Country Risk - Argentina" and " - Russia" and "Significant Accounting Policies and Significant Estimates" below). In the event of a loss of control of AO Citibank in Russia, Citi would be required to (i) write off its remaining nominal net investment, (ii) recognize a CTA loss of approximately $1.6 billion through earnings and (iii) recognize a loss of $0.9 billion on intercompany liabilities owed by AO Citibank to other Citi entities outside of Russia. In the sole event of a substantial liquidation, as opposed to a loss of control, Citi would be required to recognize the CTA loss of approximately $1.6 billion through earnings and would evaluate its remaining net investment as circumstances evolve. For additional information about these risks and related potential impacts, see the operational processes and systems and cybersecurity risk factors above and "Managing Global Risk - Other Risks - Country Risk - Russia" below. In addition, political turmoil and instability; geopolitical challenges, tensions and conflicts (including those related to China, the Russia-Ukraine war and the conflicts in the Middle East); terrorism; and other instabilities have occurred in various regions and emerging market countries across the globe, which impact Citi's businesses, results of operations and financial conditions in those countries where Citi operates and have required, and may continue to require, management time and attention and other resources, such as managing the impact of sanctions and their effect on Citi's operations in certain emerging market countries. For additional information, see the macroeconomic challenges and uncertainties risk factor above. In addition, political turmoil and instability; geopolitical challenges, tensions and conflicts (including those related to China, the Russia-Ukraine war and the conflicts in the Middle East); terrorism; and other instabilities have occurred in various regions and emerging market countries across the globe, which impact Citi's businesses, results of operations and financial conditions in those countries where Citi operates and have required, and may continue to require, management time and attention and other resources, such as managing the impact of sanctions and their effect on Citi's operations in certain emerging market countries. For additional information, see the macroeconomic challenges and uncertainties risk factor above. 64 64 64 NET ZERO AND SUSTAINABILITYThis section summarizes Citi's net zero commitment, sustainable operations and sustainable finance goals. For information regarding Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. Net Zero Emissions by 2050As previously disclosed, Citi has committed to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its own operations by 2030. This commitment spans Citi's select lending portfolios, capital markets business and operational footprint. Citi's Net Zero Plan:•Implementation Strategy: Engage with and assess clients to determine transition opportunities.•Engagement Strategy: Solicit feedback from clients, investors and other stakeholders as this work continues to evolve.•Metrics and Targets: Calculate financed emissions metrics for each applicable carbon-intensive sector and report on progress for emissions reductions targets for 2030 and beyond.Progress on Citi's Net Zero Financing Commitment:•Citi has published interim 2030 emissions targets for 10 loan portfolios: aluminum, auto manufacturing, aviation, cement, commercial real estate (North America), energy, power, shipping, steel and thermal coal mining. Three of these targets (auto manufacturing, energy and power) include facilitated emissions from capital markets activities as well.•In 2024, Citi completed the initial assessments in the auto manufacturing and steel sectors, to complement those in the energy and power sectors concluded in 2023, to better understand their strategies and approach to the climate transition. Citi recognizes that energy transition, energy security and economic growth are not mutually exclusive and must be addressed simultaneously. Citi works on executing its climate commitments and supports its clients in financing their transition to low-carbon business models, while also working with clients to prioritize global energy security, including for emerging markets where access to affordable energy is a top concern.Sustainable OperationsIn addition to the 2030 net zero GHG emissions commitment for its own operations, Citi measures progress against operational footprint goals, which include efforts to reduce the environmental impact of its facilities through reductions in emissions, energy usage, water consumption and waste generation. In 2024, Citi made progress toward these goals by increasing on-site solar generation, promoting initiatives on waste diversion and recycling, and employing more carbon-efficient techniques for building renovations. Sustainable FinanceCiti's $1 Trillion Sustainable Finance Goal, as previously disclosed, is an integrated effort across the organization to finance and facilitate $1 trillion in environmental and social finance activities with product and service offerings across multiple lines of business. Additional InformationThe "Citi Climate Report," formerly the "Task Force on Climate-Related Financial Disclosure (TCFD) Report," provides additional information on Citi's continued progress to manage climate risk and its Net Zero Plan, including information on financed and facilitated emissions and 2030 interim emissions reduction targets. For additional information on Citi's environmental and social policies and priorities, click on "Our Impact" on Citi's website at www.citigroup.com. For information on Citi's environmental and social governance, see Citi's 2025 Annual Meeting Proxy Statement to be filed with the SEC in March 2025. Citi's climate reporting and any other environmental and social governance-related reports and information included elsewhere on Citi's website are not incorporated by reference into, and do not form any part of, this Form 10-K. NET ZERO AND SUSTAINABILITYThis section summarizes Citi's net zero commitment, sustainable operations and sustainable finance goals. For information regarding Citi's management of climate risk, see "Managing Global Risk - Strategic Risk - Climate Risk" below. Net Zero Emissions by 2050As previously disclosed, Citi has committed to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its own operations by 2030. This commitment spans Citi's select lending portfolios, capital markets business and operational footprint. Citi's Net Zero Plan:•Implementation Strategy: Engage with and assess clients to determine transition opportunities.•Engagement Strategy: Solicit feedback from clients, investors and other stakeholders as this work continues to evolve.•Metrics and Targets: Calculate financed emissions metrics for each applicable carbon-intensive sector and report on progress for emissions reductions targets for 2030 and beyond.Progress on Citi's Net Zero Financing Commitment:•Citi has published interim 2030 emissions targets for 10 loan portfolios: aluminum, auto manufacturing, aviation, cement, commercial real estate (North America), energy, power, shipping, steel and thermal coal mining. Three of these targets (auto manufacturing, energy and power) include facilitated emissions from capital markets activities as well.•In 2024, Citi completed the initial assessments in the auto manufacturing and steel sectors, to complement those in the energy and power sectors concluded in 2023, to better understand their strategies and approach to the climate transition. Citi recognizes that energy transition, energy security and economic growth are not mutually exclusive and must be addressed simultaneously. Citi works on executing its climate commitments and supports its clients in financing their transition to low-carbon business models, while also working with clients to prioritize global energy security, including for emerging markets where access to affordable energy is a top concern. --- ## Modified: FICO distribution(1) **Key changes:** - Reworded sentence: "≥ 740 (1)Excludes immaterial balances for Canada and for customers for which no FICO scores are available." **Prior (2024):** (1)The FICO bands in the tables are consistent with general industry peer presentations. The FICO distribution of both card portfolios declined slightly during 2023, primarily reflecting the normalization in net credit loss and delinquency rates. The FICO distribution continued to reflect strong underlying credit quality of the portfolios. See Note 15 for additional information on FICO scores. 79 79 79 **Current (2025):** ≥ 740 (1)Excludes immaterial balances for Canada and for customers for which no FICO scores are available. The FICO distribution of both Branded Cards and Retail Services portfolios was broadly stable quarter-over-quarter and year-over-year. The FICO distribution continued to reflect the strong underlying credit quality of the portfolios. See Note 15 for additional information on FICO scores. 82 82 82 --- ## Modified: All Other - Legacy Franchises **Key changes:** - Reworded sentence: "(2)Consists of $98.0 billion, $99.8 billion, $100.9 billion, $100.0 billion and $101.6 billion of loans in North America as of December 31, 2024, September 30, 2024, June 30, 2024, March 31, 2024 and December 31, 2023, respectively." - Reworded sentence: "(3)Consists of $49.5 billion, $51.2 billion, $49.5 billion, $48.9 billion and $49.8 billion of loans outside North America as of December 31, 2024, September 30, 2024, June 30, 2024, March 31, 2024 and December 31, 2023, respectively." - Reworded sentence: "79 79 79 Consumer Credit TrendsU.S." - Reworded sentence: "USPB also provides mortgages through correspondent channels.As of December 31, 2024, approximately 77% of USPB EOP loans consisted of Branded Cards and Retail Services credit card loans, which generally drives the overall credit performance of USPB, as Branded Cards and Retail Services net credit losses represented approximately 95% of total USPB net credit losses for the fourth quarter of 2024." - Reworded sentence: "Personal BankingAs indicated above, USPB provides credit card products through Branded Cards and Retail Services, and mortgages and home equity, small business and personal consumer loans through Citi's Retail Banking network." **Prior (2024):** Asia Consumer(7) Legacy Holdings Assets(8) (1)End-of-period loans include interest and fees on credit cards. (2)See Note 15 for details on loan-to-value ratios for the portfolios and FICO scores for the U.S. portfolio. (3)Consists of $101.6 billion, $101.1 billion, $99.5 billion, $98.9 billion and $98.2 billion of loans in North America as of December 31, 2023, September 30, 2023, June 30, 2023, March 31, 2023 and December 31, 2022, respectively. For additional information on the credit quality of the Wealth portfolio, see Note 15. (4)Consists of $49.9 billion, $49.5 billion, $51.0 billion, $51.0 billion and $51.0 billion of loans outside North America as of December 31, 2023, September 30, 2023, June 30, 2023, March 31, 2023 and December 31, 2022, respectively. (5)At December 31, 2023, includes approximately $24 billion of classifiably managed loans fully collateralized by eligible financial assets and securities that have experienced very low historical net credit losses (NCLs). Approximately 85% of the classifiably managed portion of these loans are investment grade. (6)At December 31, 2023, includes approximately $22 billion of classifiably managed loans. Approximately 87% of these loans are fully collateralized (consisting primarily of commercial real estate and limited partner capital commitments in private equity) and have experienced very low historical net credit losses (NCLs). Approximately 85% of the classifiably managed portion of these loans are investment grade. (7)Asia Consumer loan balances, reported within All Other - Legacy Franchises, include the four remaining Asia Consumer loan portfolios: Korea, Poland, China and Russia. (8)Primarily consists of certain North America consumer mortgages. For information on changes to Citi's consumer loans, see "Credit Risk - Loans" above. For information on changes to Citi's consumer loans, see "Credit Risk - Loans" above. For information on changes to Citi's consumer loans, see "Credit Risk - Loans" above. 76 76 76 Consumer Credit TrendsU.S. Personal BankingAs indicated above, USPB provides card products through Branded Cards and Retail Services, and mortgages and home equity, small business and personal consumer loans through Citi's Retail Banking network. Retail Banking is concentrated in six major U.S. metropolitan areas. USPB also provides mortgages through correspondent channels.As of December 31, 2023, approximately 79% of USPB EOP loans consisted of Branded Cards and Retail Services card loans, which generally drives the overall credit performance of USPB, as U.S. cards net credit losses represented approximately 96% of total USPB net credit losses for the fourth quarter of 2023. As of December 31, 2023, Branded Cards represented 67% of total U.S. cards EOP loans and Retail Services represented 33% of U.S. cards EOP loans.As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in USPB increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels in Branded Cards and Retail Services as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment. Citi expects the net credit loss rate for both Branded Cards and Retail Services to continue to rise above pre-pandemic levels and, on a full-year basis, peak in 2024. The higher net credit losses expectation is already reflected in the Company's ACL on loans for outstanding balances at December 31, 2023.Branded CardsUSPB's Branded Cards portfolio includes proprietary and co-branded cards. As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in Branded Cards increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment.Retail ServicesUSPB's Retail Services partners directly with more than 20 retailers and dealers to offer private label and co-branded cards. Retail Services' target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel. Retail Services continually evaluates opportunities to add partners within target industries that have strong loyalty, lending or payment programs and growth potential.As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in Retail Services increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment.For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15. Consumer Credit TrendsU.S. Personal BankingAs indicated above, USPB provides card products through Branded Cards and Retail Services, and mortgages and home equity, small business and personal consumer loans through Citi's Retail Banking network. Retail Banking is concentrated in six major U.S. metropolitan areas. USPB also provides mortgages through correspondent channels.As of December 31, 2023, approximately 79% of USPB EOP loans consisted of Branded Cards and Retail Services card loans, which generally drives the overall credit performance of USPB, as U.S. cards net credit losses represented approximately 96% of total USPB net credit losses for the fourth quarter of 2023. As of December 31, 2023, Branded Cards represented 67% of total U.S. cards EOP loans and Retail Services represented 33% of U.S. cards EOP loans.As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in USPB increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels in Branded Cards and Retail Services as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment. Citi expects the net credit loss rate for both Branded Cards and Retail Services to continue to rise above pre-pandemic levels and, on a full-year basis, peak in 2024. The higher net credit losses expectation is already reflected in the Company's ACL on loans for outstanding balances at December 31, 2023. **Current (2025):** Asia Consumer(7) Legacy Holdings Assets(8) (1)End-of-period loans include interest and fees on credit cards. (2)Consists of $98.0 billion, $99.8 billion, $100.9 billion, $100.0 billion and $101.6 billion of loans in North America as of December 31, 2024, September 30, 2024, June 30, 2024, March 31, 2024 and December 31, 2023, respectively. For additional information on the credit quality of the Wealth portfolio, see Note 15. (3)Consists of $49.5 billion, $51.2 billion, $49.5 billion, $48.9 billion and $49.8 billion of loans outside North America as of December 31, 2024, September 30, 2024, June 30, 2024, March 31, 2024 and December 31, 2023, respectively. (4)See Note 15 for details on loan-to-value ratios for the portfolios and FICO scores for the U.S. portfolio. (5)At December 31, 2024, includes approximately $24 billion of classifiably managed loans fully collateralized by eligible financial assets and securities that have experienced very low historical net credit losses. Approximately 63% of the classifiably managed portion of these loans is investment grade. (6)At December 31, 2024, includes approximately $20 billion of classifiably managed loans. Approximately 83% of these loans are fully collateralized (consisting primarily of marketable investment securities, commercial real estate and limited partner capital commitments in private equity) and have experienced very low historical net credit losses. As discussed below, approximately 83% of the classifiably managed portion of these loans is investment grade. (7)Asia Consumer loan balances, reported within All Other - Legacy Franchises, include the three remaining Asia Consumer loan portfolios - Korea, Poland and Russia - as well as China until the completion of the sales of substantially all portfolios in July 2024. (8)Primarily consists of certain North America consumer mortgages. For information on changes to Citi's consumer loans, see "Credit Risk - Loans" above. For information on changes to Citi's consumer loans, see "Credit Risk - Loans" above. For information on changes to Citi's consumer loans, see "Credit Risk - Loans" above. 79 79 79 Consumer Credit TrendsU.S. Personal BankingAs indicated above, USPB provides credit card products through Branded Cards and Retail Services, and mortgages and home equity, small business and personal consumer loans through Citi's Retail Banking network. Retail Banking is concentrated in six major U.S. metropolitan areas. USPB also provides mortgages through correspondent channels.As of December 31, 2024, approximately 77% of USPB EOP loans consisted of Branded Cards and Retail Services credit card loans, which generally drives the overall credit performance of USPB, as Branded Cards and Retail Services net credit losses represented approximately 95% of total USPB net credit losses for the fourth quarter of 2024. As of December 31, 2024, Branded Cards and Retail Services represented 69% and 31%, respectively, of EOP cards loans in USPB.As presented in the chart above, the fourth quarter of 2024 net credit loss rate in USPB was broadly stable quarter-over-quarter. The net credit loss rate increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment impacting both cards portfolios, with lower FICO band customers primarily driving the increase.The 90+ days past due delinquency rate increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment impacting both cards portfolios, with lower FICO band customers primarily driving the increase.Branded CardsUSPB's Branded Cards portfolio consists of both proprietary Citi branded cards portfolios (Value, Rewards and Cash) and co-branded cards portfolios (including Costco and American Airlines). Citi's Branded Cards portfolio benefits from a diverse combination of products. Citi's proprietary cards provide customers with a suite of products with rewards, cash rebates and lending solutions, while co-branded cards provide significant affinity benefits through partnerships with large-scale partners across the airline, retail and telecom sectors. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Branded Cards was broadly stable quarter-over-quarter. The net credit loss rate increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.The 90+ days past due delinquency rate increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. Consumer Credit TrendsU.S. Personal BankingAs indicated above, USPB provides credit card products through Branded Cards and Retail Services, and mortgages and home equity, small business and personal consumer loans through Citi's Retail Banking network. Retail Banking is concentrated in six major U.S. metropolitan areas. USPB also provides mortgages through correspondent channels.As of December 31, 2024, approximately 77% of USPB EOP loans consisted of Branded Cards and Retail Services credit card loans, which generally drives the overall credit performance of USPB, as Branded Cards and Retail Services net credit losses represented approximately 95% of total USPB net credit losses for the fourth quarter of 2024. As of December 31, 2024, Branded Cards and Retail Services represented 69% and 31%, respectively, of EOP cards loans in USPB.As presented in the chart above, the fourth quarter of 2024 net credit loss rate in USPB was broadly stable quarter-over-quarter. The net credit loss rate increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment impacting both cards portfolios, with lower FICO band customers primarily driving the increase.The 90+ days past due delinquency rate increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment impacting both cards portfolios, with lower FICO band customers primarily driving the increase. --- ## Modified: HUMAN CAPITAL RESOURCES AND MANAGEMENT **Key changes:** - Reworded sentence: "Citi strives to deliver to its full potential by focusing on its strategic priority of attracting and retaining highly qualified and motivated employees." **Prior (2024):** Citi strives to deliver to its full potential by focusing on its strategic priority of attracting and retaining highly qualified and motivated colleagues. Citi seeks to enhance the competitive strength of its workforce through the following efforts: •Continuously innovating its efforts to recruit, train, develop, compensate, promote and engage 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 •Providing compensation programs that are competitive in the market and aligned to strategic objectives In 2023, Citi undertook significant changes to simplify the Company and accelerate the progress it is making in executing its strategy. As previously disclosed, Citi aligned its organizational structure to its business strategy - making the Company more client centric and agile, speeding up decision-making, improving productivity to deliver efficiency and driving increased accountability across the organization. Citi is aligned around five businesses - Services, Markets, Banking, USPB and Wealth - focusing on a streamlined client organization to strengthen how Citi delivers for clients across the Company and around the globe. **Current (2025):** Citi strives to deliver to its full potential by focusing on its strategic priority of attracting and retaining highly qualified and motivated employees. Citi's vision remains - to be the preeminent banking partner for institutions with cross-border needs, a global leader in wealth management and a valued personal bank in the U.S. Citi is structured around five core interconnected businesses - Services, Markets, Banking, Wealth and USPB, a centralized client organization to strengthen how Citi delivers for clients across the Company and an international unit to oversee the local delivery of the Company's services and products to clients in each of the markets where Citi has an on-the-ground presence to serve and support large and mid-sized companies. Citi seeks to enhance the competitive strength of its workforce through the following efforts: • Continuously innovating its efforts to recruit, train, develop, compensate, promote and engage employees • Actively seeking and listening to diverse perspectives at all levels of the organization • Providing compensation programs that are competitive in the market and aligned to strategic objectives --- ## Modified: Consumer Loan Delinquencies Amounts and Ratios **Key changes:** - Reworded sentence: "EOPloans(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 billions2024202420232022202420232022Wealth delinquency-managed loans(3)$104.1 $260 $191 $186 $242 $312 $317 Ratio0.25 %0.18 %0.19 %0.23 %0.30 %0.32 %Wealth classifiably managed loans(4)$43.4 N/AN/AN/AN/AN/AN/AUSPB(5)(6)Total$221.7 $2,871 $2,635 $1,578 $2,604 $2,563 $1,720 Ratio1.30 %1.26 %0.84 %1.18 %1.23 %0.92 %Cards(6)Total171.1 2,705 2,461 1,415 2,333 2,293 1,511 Ratio1.58 %1.49 %0.94 %1.36 %1.39 %1.00 %Branded Cards117.3 1,383 1,194 629 1,210 1,143 693 Ratio1.18 %1.07 %0.63 %1.03 %1.03 %0.69 %Retail Services53.8 1,322 1,267 786 1,123 1,150 818 Ratio2.46 %2.36 %1.56 %2.09 %2.15 %1.62 %Retail Banking(5)50.6 166 174 163 271 270 209 Ratio0.33 %0.40 %0.45 %0.54 %0.62 %0.57 %All OtherTotal$23.9 $341 $407 $389 $329 $384 $335 Ratio1.44 %1.43 %1.26 %1.39 %1.35 %1.08 %Mexico Consumer17.2 246 252 190 242 252 186 Ratio1.43 %1.35 %1.28 %1.41 %1.35 %1.26 %Asia Consumer(7)(8)4.7 23 51 49 27 59 70 Ratio0.49 %0.69 %0.37 %0.57 %0.80 %0.53 %Legacy Holdings Assets (consumer)(9)2.0 72 104 150 60 73 79 Ratio4.00 %4.33 %5.36 %3.33 %3.04 %2.82 %Total Citigroup consumer$393.1 $3,472 $3,233 $2,153 $3,175 $3,259 $2,372 Ratio0.99 %0.94 %0.68 %0.91 %0.95 %0.75 % EOP loans(1)" **Prior (2024):** EOPloans(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 billions2023202320222021202320222021USPB(3)(4)Total$209.1 $2,635 $1,578 $1,069 $2,563 $1,720 $1,130 Ratio1.26 %0.84 %0.64 %1.23 %0.92 %0.68 %Cards(4)Total164.7 2,461 1,415 871 2,293 1,511 947 Ratio1.49 %0.94 %0.65 %1.39 %1.00 %0.71 %Branded Cards111.1 1,194 629 389 1,143 693 408 Ratio1.07 %0.63 %0.44 %1.03 %0.69 %0.46 %Retail Services53.6 1,267 786 482 1,150 818 539 Ratio2.36 %1.56 %1.05 %2.15 %1.62 %1.17 %Retail Banking(3)44.4 174 163 198 270 209 183 Ratio0.40 %0.45 %0.62 %0.62 %0.57 %0.57 %Wealth delinquency-managed loans(5)$105.3 $191 $186 $281 $312 $317 $323 Ratio0.18 %0.19 %0.31 %0.30 %0.32 %0.35 %Wealth classifiably managed loans(6)$46.2 N/AN/AN/AN/AN/AN/AAll OtherTotal$28.6 $407 $389 $613 $384 $335 $546 Ratio1.43 %1.26 %1.06 %1.35 %1.09 %0.94 %Mexico Consumer18.7 252 190 183 252 186 173 Ratio1.35 %1.28 %1.38 %1.35 %1.26 %1.30 %Asia Consumer(7)(8)7.4 51 49 209 59 70 285 Ratio0.69 %0.37 %0.51 %0.80 %0.53 %0.69 %Legacy Holdings Assets (consumer)(9)2.5 104 150 221 73 79 88 Ratio4.52 %5.56 %6.31 %3.17 %2.93 %2.51 %Total Citigroup consumer$389.2 $3,233 $2,153 $1,963 $3,259 $2,372 $1,999 Ratio0.94 %0.68 %0.62 %0.95 %0.75 %0.63 % EOP loans(1) **Current (2025):** EOPloans(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 billions2024202420232022202420232022Wealth delinquency-managed loans(3)$104.1 $260 $191 $186 $242 $312 $317 Ratio0.25 %0.18 %0.19 %0.23 %0.30 %0.32 %Wealth classifiably managed loans(4)$43.4 N/AN/AN/AN/AN/AN/AUSPB(5)(6)Total$221.7 $2,871 $2,635 $1,578 $2,604 $2,563 $1,720 Ratio1.30 %1.26 %0.84 %1.18 %1.23 %0.92 %Cards(6)Total171.1 2,705 2,461 1,415 2,333 2,293 1,511 Ratio1.58 %1.49 %0.94 %1.36 %1.39 %1.00 %Branded Cards117.3 1,383 1,194 629 1,210 1,143 693 Ratio1.18 %1.07 %0.63 %1.03 %1.03 %0.69 %Retail Services53.8 1,322 1,267 786 1,123 1,150 818 Ratio2.46 %2.36 %1.56 %2.09 %2.15 %1.62 %Retail Banking(5)50.6 166 174 163 271 270 209 Ratio0.33 %0.40 %0.45 %0.54 %0.62 %0.57 %All OtherTotal$23.9 $341 $407 $389 $329 $384 $335 Ratio1.44 %1.43 %1.26 %1.39 %1.35 %1.08 %Mexico Consumer17.2 246 252 190 242 252 186 Ratio1.43 %1.35 %1.28 %1.41 %1.35 %1.26 %Asia Consumer(7)(8)4.7 23 51 49 27 59 70 Ratio0.49 %0.69 %0.37 %0.57 %0.80 %0.53 %Legacy Holdings Assets (consumer)(9)2.0 72 104 150 60 73 79 Ratio4.00 %4.33 %5.36 %3.33 %3.04 %2.82 %Total Citigroup consumer$393.1 $3,472 $3,233 $2,153 $3,175 $3,259 $2,372 Ratio0.99 %0.94 %0.68 %0.91 %0.95 %0.75 % EOP loans(1) --- ## Modified: Managing Global Risk - Table of Contents **Key changes:** - Reworded sentence: "MANAGING GLOBAL RISK68CREDIT RISK(1)72Loans74Corporate Credit73Consumer Credit79Additional Consumer and Corporate Credit Details86Loans Outstanding86Details of Credit Loss Experience 87Allowance for Credit Losses on Loans (ACLL)91Non-Accrual Loans and Assets91LIQUIDITY RISK94Liquidity Monitoring and Measurement 94High-Quality Liquid Assets (HQLA)97Liquidity Coverage Ratio (LCR)97Deposits98Long-Term Debt99Secured Funding Transactions and Short-Term Borrowings102Credit Ratings103MARKET RISK(1) 102Market Risk of Non-Trading Portfolios102Banking Book Interest Rate Risk 102Interest Rate Risk of Investment Portfolios - Impact on AOCI 105Changes in Foreign Exchange Rates - Impacts on AOCI and Capital107Interest Income/Expense and Net Interest Margin (NIM)106Additional Interest Rate Details110Market Risk of Trading Portfolios112Factor Sensitivities115Value at Risk (VaR)115Stress Testing118OPERATIONAL RISK116Cybersecurity Risk119COMPLIANCE RISK119REPUTATION RISK120STRATEGIC RISK120Climate Risk122OTHER RISKS122Country Risk122Top 25 Country Exposures122Russia123Ukraine125Argentina125FFIEC - Cross-Border Claims on Third Parties and Local Country Assets126 68" **Prior (2024):** MANAGING GLOBAL RISK65Overview65CREDIT RISK(1)69Overview69Loans72Corporate Credit70Consumer Credit76Additional Consumer and Corporate Credit Details83Loans Outstanding83Details of Credit Loss Experience 84Allowance for Credit Losses on Loans (ACLL)89Non-Accrual Loans and Assets88LIQUIDITY RISK91Overview91Liquidity Monitoring and Measurement 91High-Quality Liquid Assets (HQLA)95Deposits96Long-Term Debt97Secured Funding Transactions and Short-Term Borrowings100Credit Ratings101MARKET RISK(1) 100Overview100Market Risk of Non-Trading Portfolios100Banking Book Interest Rate Risk 100Interest Rate Risk of Investment Portfolios - Impact on AOCI 104Changes in Foreign Exchange Rates - Impacts on AOCI and Capital106Interest Income/Expense and Net Interest Margin (NIM)104Additional Interest Rate Details110Market Risk of Trading Portfolios111Factor Sensitivities115Value at Risk (VAR)115Stress Testing118OPERATIONAL RISK115Overview115Cybersecurity Risk115COMPLIANCE RISK118REPUTATION RISK119STRATEGIC RISK119Climate Risk119OTHER RISKS120LIBOR Transition Risk120Country Risk121Top 25 Country Exposures121Russia122Ukraine124Argentina124FFIEC - Cross-Border Claims on Third Parties and Local Country Assets125 65 65 **Current (2025):** MANAGING GLOBAL RISK68CREDIT RISK(1)72Loans74Corporate Credit73Consumer Credit79Additional Consumer and Corporate Credit Details86Loans Outstanding86Details of Credit Loss Experience 87Allowance for Credit Losses on Loans (ACLL)91Non-Accrual Loans and Assets91LIQUIDITY RISK94Liquidity Monitoring and Measurement 94High-Quality Liquid Assets (HQLA)97Liquidity Coverage Ratio (LCR)97Deposits98Long-Term Debt99Secured Funding Transactions and Short-Term Borrowings102Credit Ratings103MARKET RISK(1) 102Market Risk of Non-Trading Portfolios102Banking Book Interest Rate Risk 102Interest Rate Risk of Investment Portfolios - Impact on AOCI 105Changes in Foreign Exchange Rates - Impacts on AOCI and Capital107Interest Income/Expense and Net Interest Margin (NIM)106Additional Interest Rate Details110Market Risk of Trading Portfolios112Factor Sensitivities115Value at Risk (VaR)115Stress Testing118OPERATIONAL RISK116Cybersecurity Risk119COMPLIANCE RISK119REPUTATION RISK120STRATEGIC RISK120Climate Risk122OTHER RISKS122Country Risk122Top 25 Country Exposures122Russia123Ukraine125Argentina125FFIEC - Cross-Border Claims on Third Parties and Local Country Assets126 68 --- ## Modified: Net Zero Emissions by 2050 **Key changes:** - Reworded sentence: "As previously disclosed, Citi has committed to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its own operations by 2030." **Prior (2024):** Citi's Sustainable Finance Goal, as previously disclosed, supports a combination of environmental and social finance activities. Delivering on the sustainable finance goal is an integrated effort across the organization with products and service offerings across multiple lines of business. Net Zero Emissions by 2050As previously disclosed, Citi has committed to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its own operations by 2030; both are significant targets given the size and breadth of Citi's lending portfolios, businesses and operational footprint.Citi's Net Zero plan includes:•Net Zero Metrics and Target Setting: Calculate metrics and assess targets for carbon-intensive sectors•Client Engagement and Assessment: Seek to understand client GHG emissions and transition plans and advise on capacity building•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 risk appetite and thresholds and policies related to Climate Risk Management•Clean Technology and Transition Finance: Support existing and, where possible, new technologies to accelerate commercialization and provide transition advisory and finance products and services•Portfolio Management: Active portfolio management of Citi financings to align with net zero targets, including considerations of transition measures taken by clients•Public Policy and Regulatory Engagement: Contribute to an enabling public policy and regulatory environment which is essential to stimulating demand for clean technologies and helping ensure a responsible transitionProgress on Citi's Net Zero plan: •Citi has published interim 2030 emissions targets for six loan portfolios: auto manufacturing, commercial real estate (North America), energy, power, steel and thermal coal mining. •Citi has developed a client transition assessment process to help internal teams better understand the alignment of clients' strategies with transition or decarbonization pathways applicable to their respective sectors. In 2022-2023, Citi completed the initial assessment process for energy and power clients, and in 2023 began the transition assessment process for auto manufacturing and steel clients. The assessment process focuses on clients with material emissions relative to each sector's baseline emission profiles.Operational Footprint GoalsCiti measures progress against operational footprint goals, which include efforts to reduce the environmental impact of its facilities through reductions in emissions, energy, water consumption and waste generation. Citi's efforts to integrate sustainable practices include sustainable building certifications, renewable electricity sourcing, employee engagement and seeking opportunities for efficiency in business travel. In 2023, Citi made progress toward these goals by increasing on-site solar generation, promoting initiatives on waste diversion and recycling, mapping weather- **Current (2025):** As previously disclosed, Citi has committed to achieving net zero greenhouse gas (GHG) emissions associated with its financing by 2050, and net zero GHG emissions for its own operations by 2030. This commitment spans Citi's select lending portfolios, capital markets business and operational footprint. Citi's Net Zero Plan: •Implementation Strategy: Engage with and assess clients to determine transition opportunities. •Engagement Strategy: Solicit feedback from clients, investors and other stakeholders as this work continues to evolve. •Metrics and Targets: Calculate financed emissions metrics for each applicable carbon-intensive sector and report on progress for emissions reductions targets for 2030 and beyond. Progress on Citi's Net Zero Financing Commitment: •Citi has published interim 2030 emissions targets for 10 loan portfolios: aluminum, auto manufacturing, aviation, cement, commercial real estate (North America), energy, power, shipping, steel and thermal coal mining. Three of these targets (auto manufacturing, energy and power) include facilitated emissions from capital markets activities as well. •In 2024, Citi completed the initial assessments in the auto manufacturing and steel sectors, to complement those in the energy and power sectors concluded in 2023, to better understand their strategies and approach to the climate transition. Citi recognizes that energy transition, energy security and economic growth are not mutually exclusive and must be addressed simultaneously. Citi works on executing its climate commitments and supports its clients in financing their transition to low-carbon business models, while also working with clients to prioritize global energy security, including for emerging markets where access to affordable energy is a top concern. Sustainable OperationsIn addition to the 2030 net zero GHG emissions commitment for its own operations, Citi measures progress against operational footprint goals, which include efforts to reduce the environmental impact of its facilities through reductions in emissions, energy usage, water consumption and waste generation. In 2024, Citi made progress toward these goals by increasing on-site solar generation, promoting initiatives on waste diversion and recycling, and employing more carbon-efficient techniques for building renovations. Sustainable FinanceCiti's $1 Trillion Sustainable Finance Goal, as previously disclosed, is an integrated effort across the organization to finance and facilitate $1 trillion in environmental and social finance activities with product and service offerings across multiple lines of business. Additional InformationThe "Citi Climate Report," formerly the "Task Force on Climate-Related Financial Disclosure (TCFD) Report," provides additional information on Citi's continued progress to manage climate risk and its Net Zero Plan, including information on financed and facilitated emissions and 2030 interim emissions reduction targets. For additional information on Citi's environmental and social policies and priorities, click on "Our Impact" on Citi's website at www.citigroup.com. For information on Citi's environmental and social governance, see Citi's 2025 Annual Meeting Proxy Statement to be filed with the SEC in March 2025. Citi's climate reporting and any other environmental and social governance-related reports and information included elsewhere on Citi's website are not incorporated by reference into, and do not form any part of, this Form 10-K. --- ## Modified: Consumer Loan Net Credit Losses (NCLs) and Ratios **Key changes:** - Reworded sentence: "Averageloans(1)Net credit losses(2)In millions of dollars, except average loan amounts in billions2024202420232022Wealth$149.4 $121 $98 $103 Ratio0.08 %0.07 %0.07 %USPBTotal$209.2 $7,579 $5,234 $2,918 Ratio3.62 %2.72 %1.71 %CardsTotal161.8 7,245 4,981 2,640 Ratio4.48 %3.29 %1.95 %Branded Cards110.3 4,015 2,664 1,384 Ratio3.64 %2.62 %1.54 %Retail Services51.5 3,230 2,317 1,256 Ratio6.27 %4.64 %2.74 %Retail Banking47.4 334 253 278 Ratio0.70 %0.62 %0.79 %All Other - Legacy Franchises (managed basis)(3)Total$26.3 $896 $861 $746 Ratio3.41 %2.94 %2.16 %Mexico Consumer18.3 828 682 476 Ratio4.52 %4.01 %3.50 %Asia Consumer (managed basis)(3)(4)(5)5.9 67 198 316 Ratio1.14 %2.08 %1.82 %Legacy Holdings Assets (consumer)2.1 1 (19)(46)Ratio0.05 %(0.68)%(1.27)%Reconciling Items(3)$7 $(6)$(156)Total Citigroup$384.9 $8,603 $6,187 $3,611 Ratio2.24 %1.66 %1.02 % Average loans(1)" **Prior (2024):** Averageloans(1)Net credit losses(2)In millions of dollars, except average loan amounts in billions2023202320222021USPBTotal$192.6 $5,234 $2,918 $2,939 Ratio2.72 %1.71 %1.85 %CardsTotal151.5 4,981 2,640 2,828 Ratio3.29 %1.95 %2.28 %Branded Cards101.6 2,664 1,384 1,659 Ratio2.62 %1.54 %2.05 %Retail Services49.9 2,317 1,256 1,169 Ratio4.64 %2.74 %2.71 %Retail Banking41.1 253 278 111 Ratio0.62 %0.79 %0.32 %Wealth$150.1 $98 $103 $122 Ratio0.07 %0.07 %0.08 %All Other - Legacy Franchises (managed basis)(3)Total$29.2 $861 $746 $1,454 Ratio2.95 %2.16 %2.13 %Mexico Consumer17.0 682 476 920 Ratio4.01 %3.50 %6.87 %Asia Consumer (managed basis)(3)(4)(5)9.5 198 316 616 Ratio2.08 %1.82 %1.24 %Legacy Holdings Assets (consumer)2.7 (19)(46)(82)Ratio(0.70)%(1.35)%(1.53)%Reconciling Items(3)$(6)$(156)$(6)Total Citigroup$371.9 $6,187 $3,611 $4,509 Ratio1.66 %1.02 %1.20 % Average loans(1) **Current (2025):** Averageloans(1)Net credit losses(2)In millions of dollars, except average loan amounts in billions2024202420232022Wealth$149.4 $121 $98 $103 Ratio0.08 %0.07 %0.07 %USPBTotal$209.2 $7,579 $5,234 $2,918 Ratio3.62 %2.72 %1.71 %CardsTotal161.8 7,245 4,981 2,640 Ratio4.48 %3.29 %1.95 %Branded Cards110.3 4,015 2,664 1,384 Ratio3.64 %2.62 %1.54 %Retail Services51.5 3,230 2,317 1,256 Ratio6.27 %4.64 %2.74 %Retail Banking47.4 334 253 278 Ratio0.70 %0.62 %0.79 %All Other - Legacy Franchises (managed basis)(3)Total$26.3 $896 $861 $746 Ratio3.41 %2.94 %2.16 %Mexico Consumer18.3 828 682 476 Ratio4.52 %4.01 %3.50 %Asia Consumer (managed basis)(3)(4)(5)5.9 67 198 316 Ratio1.14 %2.08 %1.82 %Legacy Holdings Assets (consumer)2.1 1 (19)(46)Ratio0.05 %(0.68)%(1.27)%Reconciling Items(3)$7 $(6)$(156)Total Citigroup$384.9 $8,603 $6,187 $3,611 Ratio2.24 %1.66 %1.02 % Average loans(1) --- ## Modified: A Ratings Downgrade Could Adversely Impact Citi's Funding and Liquidity. **Key changes:** - Reworded sentence: "The credit rating agencies, such as Fitch Ratings, Moody's Ratings and S&P Global Ratings, continuously evaluate Citi and certain of its subsidiaries." - Reworded sentence: "Citi could also be subject to enforcement proceedings and negative regulatory evaluation or examination findings 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 (see also the capital return and resolution plan risk factors above)." **Prior (2024):** Dividends, Changes to Directors and/or Officers and Collateral Consequences Arising from Such Outcomes.At any given time, Citi is a party to a significant number of legal and regulatory proceedings and is subject to numerous governmental and regulatory examinations. Additionally, Citi remains subject to governmental and regulatory investigations, consent orders (see discussion below) and related compliance efforts, and other inquiries. Citi could also be subject to enforcement proceedings and negative regulatory evaluationor examination findings 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 (see also the capital return and resolution plan risk factors above). Citi's regulators have broad powers and discretion under their prudential and supervisory authority, and have pursued active inspection and investigatory oversight.As previously disclosed, the October 2020 FRB and OCC consent orders require Citigroup and Citibank to implement extensive targeted action plans and submit quarterly progress reports on a timely and sufficient basis 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 2024 and beyond, as an essential part of Citi's broader transformation efforts to enhance its risk, controls, data and finance infrastructure and compliance. There can be no assurance that such improvements will be implemented in a manner satisfactory, in both timing and sufficiency, to the FRB and OCC. 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. 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, which have been subject to increased regulatory scrutiny. 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 foreign jurisdictions, as well as multiple civil litigation claims in multiple jurisdictions. Violations of law by other financial institutions may also result in regulatory scrutiny of Citi. Responding to regulatory **Current (2025):** The credit rating agencies, such as Fitch Ratings, Moody's Ratings and S&P Global Ratings, continuously evaluate Citi and certain of its subsidiaries. Their ratings of Citi and its rated subsidiaries' long-term debt and short-term obligations are based on firm-specific factors, including the financial strength of Citi and such subsidiaries, 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, potential impact from negative actions on U.S. sovereign ratings and conditions affecting the financial services industry and markets generally. A ratings downgrade could result from, among other factors, delays or missteps in Citi's transformation efforts, including risk management and internal controls improvements, public statements by Citi's management or regulators, operational risk charges, control failures, substantial failure to meet cost targets, deterioration in Citi's funding structure or liquidity, declines in profitability, significant increases in risk appetite or material reductions in regulatory capitalization levels. Citi and its subsidiaries may not be able to maintain their current respective ratings and outlooks. Ratings downgrades could negatively impact Citi and its rated subsidiaries' ability to access the capital markets and other sources of funds as well as increase credit spreads and the costs of those funds. A ratings downgrade could also have a negative impact on Citi and its rated subsidiaries' ability to obtain funding and liquidity due to reduced funding capacity and the impact from derivative triggers, which could require Citi and its rated subsidiaries to meet cash obligations and collateral requirements or permit counterparties to terminate certain contracts. 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. Furthermore, a credit ratings downgrade could have impacts that may not be currently known to Citi or are not possible to quantify. Some of Citi's counterparties and clients could have ratings limitations on their permissible counterparties, of which Citi may or may not be aware. 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 market instruments, and limit or withdraw deposits placed 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 - Potential Impacts of Ratings Downgrades" below. 61 61 61 COMPLIANCE RISKSSignificantly Heightened Regulatory Expectations and Scrutiny in the U.S. and Globally and Ongoing Interpretation and Implementation of Regulatory and Legislative Requirements and Changes Have Increased Citi's Compliance, Regulatory and Other Risks and Costs.Large financial institutions, such as Citi, face significantly heightened regulatory and supervisory expectations and scrutiny in the U.S. and globally, including with respect to, among other things, governance, infrastructure, data and risk management practices and controls. These regulatory and supervisory expectations extend to employees and agents and also include, among other things, those related to customer and client protection, market practices, anti-money laundering, increasingly complex sanctions and disclosure regimes and various regulatory reporting requirements. U.S. financial institutions also face increased expectations and scrutiny in the wake of the failures of several regional banks and other banking stresses in 2023. In addition, 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, which may overlap or conflict across jurisdictions, resulting in substantial compliance, regulatory and other risks and costs.A failure to comply with these expectations and requirements, even if inadvertent, or resolve any identified deficiencies in a timely and sufficiently satisfactory manner to regulators, could result in increased regulatory oversight; material restrictions, including, among others, imposition of additional capital buffers and limitations on capital distributions; enforcement proceedings; penalties; and fines (see the capital return risk factor above and legal and regulatory proceedings risk factor below). Moreover, over the past several years, Citi has been required to implement a large number of regulatory, supervisory and legislative changes, including new regulatory, supervisory or legislative requirements or regimes, across its businesses and functions, and these changes continue. The changes themselves may be complex and subject to interpretation, and result in changes to Citi's businesses. In addition, the changes require continued substantial technology and other investments. In some cases, Citi's implementation of a regulatory or legislative requirement is occurring simultaneously with changing or conflicting regulatory guidance from multiple jurisdictions (including various U.S. states) and regulators, legal challenges or legislative action to modify or repeal existing rules or enact new rules. Examples of regulatory or legislative changes that have resulted in increased compliance risks and costs include (i) the U.S. regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and "Capital Resources" above); (ii) various laws relating to the limitation of cross-border data movement and/or collection and use of customer information, including data localization and protection and privacy laws, which also can conflict with or increase compliance complexity with respect to other laws, including anti-money laundering laws; and (iii) the EU's Corporate Sustainability Reporting Directive, which may overlap but also diverge from climate-related disclosure requirements expected to come into effect in other jurisdictions. Citi Is Subject to Extensive Legal and Regulatory Proceedings, Examinations, Investigations, Consent Orders and Related Compliance Efforts and Other Inquiries That Could Result in Large Monetary Penalties, Supervisory or Enforcement Orders, Business Restrictions, Limitations on Dividends, Changes to Directors and/or Officers and Collateral Consequences Arising from Such Outcomes.Citi's regulators have broad powers and discretion under their prudential and supervisory authority, and have pursued active inspection and investigatory oversight. At any given time, Citi is a party to a significant number of legal and regulatory proceedings and is subject to numerous governmental and regulatory examinations. Additionally, Citi remains subject to governmental and regulatory investigations, consent orders (see discussion below) and related compliance efforts, and other inquiries. Citi could also be subject to enforcement proceedings and negative regulatory evaluation or examination findings 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 (see also the capital return and resolution plan risk factors above). Citi could face further scrutiny and consequences from regulators for failing to timely resolve open regulatory issues or having repeat regulatory issues.As previously disclosed, the 2020 FRB Consent Order and the 2020 OCC Consent Order require Citigroup and Citibank, respectively, to implement extensive targeted action plans and submit quarterly progress reports on a timely and sufficient basis detailing the results and status of improvements relating principally to various aspects of enterprise-wide risk management, compliance, data quality management related to governance, and internal controls. These improvements will result in continued significant investments by Citi during 2025 and beyond, as an essential part of Citi's broader transformation efforts to enhance its risk, controls, data and finance infrastructure and compliance (see the transformation, simplification and other priorities-related risk factor above). Additionally, on July 10, 2024, the FRB entered into a Civil Money Penalty Consent Order with Citigroup, and the OCC entered into a Civil Money Penalty Consent Order with Citibank. The OCC and Citibank also entered into an Amendment to the OCC's 2020 Consent Order (the Amendment). The FRB found that Citigroup had ongoing deficiencies related to its data quality management program and had inadequate measures for managing and controlling its data quality risks. The OCC found that Citibank had failed to make sufficient and sustainable progress toward achieving compliance with its 2020 Consent Order. The Amendment requires Citibank to formalize a process to determine whether sufficient resources are being appropriately allocated toward achieving timely and sustainable compliance with the OCC's 2020 Consent Order, including any requirements on which Citibank is not making sufficient and sustainable progress (such process, the Resource Review Plan). There can be no assurance that the Resource COMPLIANCE RISKSSignificantly Heightened Regulatory Expectations and Scrutiny in the U.S. and Globally and Ongoing Interpretation and Implementation of Regulatory and Legislative Requirements and Changes Have Increased Citi's Compliance, Regulatory and Other Risks and Costs.Large financial institutions, such as Citi, face significantly heightened regulatory and supervisory expectations and scrutiny in the U.S. and globally, including with respect to, among other things, governance, infrastructure, data and risk management practices and controls. These regulatory and supervisory expectations extend to employees and agents and also include, among other things, those related to customer and client protection, market practices, anti-money laundering, increasingly complex sanctions and disclosure regimes and various regulatory reporting requirements. U.S. financial institutions also face increased expectations and scrutiny in the wake of the failures of several regional banks and other banking stresses in 2023. In addition, 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, which may overlap or conflict across jurisdictions, resulting in substantial compliance, regulatory and other risks and costs.A failure to comply with these expectations and requirements, even if inadvertent, or resolve any identified deficiencies in a timely and sufficiently satisfactory manner to regulators, could result in increased regulatory oversight; material restrictions, including, among others, imposition of additional capital buffers and limitations on capital distributions; enforcement proceedings; penalties; and fines (see the capital return risk factor above and legal and regulatory proceedings risk factor below). Moreover, over the past several years, Citi has been required to implement a large number of regulatory, supervisory and legislative changes, including new regulatory, supervisory or legislative requirements or regimes, across its businesses and functions, and these changes continue. The changes themselves may be complex and subject to interpretation, and result in changes to Citi's businesses. In addition, the changes require continued substantial technology and other investments. In some cases, Citi's implementation of a regulatory or legislative requirement is occurring simultaneously with changing or conflicting regulatory guidance from multiple jurisdictions (including various U.S. states) and regulators, legal challenges or legislative action to modify or repeal existing rules or enact new rules. Examples of regulatory or legislative changes that have resulted in increased compliance risks and costs include (i) the U.S. regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and "Capital Resources" above); (ii) various laws relating to the limitation of cross-border data movement and/or collection and use of customer information, including data localization and protection and privacy laws, which also can conflict with or increase compliance complexity with respect to other laws, including anti-money laundering laws; and (iii) the EU's Corporate Sustainability Reporting Directive, which may overlap but also diverge from climate-related disclosure --- ## Modified: U.S. Personal Banking **Key changes:** - Reworded sentence: "As indicated above, USPB provides credit card products through Branded Cards and Retail Services, and mortgages and home equity, small business and personal consumer loans through Citi's Retail Banking network." - Reworded sentence: "As of December 31, 2024, approximately 77% of USPB EOP loans consisted of Branded Cards and Retail Services credit card loans, which generally drives the overall credit performance of USPB, as Branded Cards and Retail Services net credit losses represented approximately 95% of total USPB net credit losses for the fourth quarter of 2024." **Prior (2024):** As indicated above, USPB provides card products through Branded Cards and Retail Services, and mortgages and home equity, small business and personal consumer loans through Citi's Retail Banking network. Retail Banking is concentrated in six major U.S. metropolitan areas. USPB also provides mortgages through correspondent channels. As of December 31, 2023, approximately 79% of USPB EOP loans consisted of Branded Cards and Retail Services card loans, which generally drives the overall credit performance of USPB, as U.S. cards net credit losses represented approximately 96% of total USPB net credit losses for the fourth quarter of 2023. As of December 31, 2023, Branded Cards represented 67% of total U.S. cards EOP loans and Retail Services represented 33% of U.S. cards EOP loans. As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in USPB increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels in Branded Cards and Retail Services as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment. Citi expects the net credit loss rate for both Branded Cards and Retail Services to continue to rise above pre-pandemic levels and, on a full-year basis, peak in 2024. The higher net credit losses expectation is already reflected in the Company's ACL on loans for outstanding balances at December 31, 2023. Branded CardsUSPB's Branded Cards portfolio includes proprietary and co-branded cards. As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in Branded Cards increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment.Retail ServicesUSPB's Retail Services partners directly with more than 20 retailers and dealers to offer private label and co-branded cards. Retail Services' target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel. Retail Services continually evaluates opportunities to add partners within target industries that have strong loyalty, lending or payment programs and growth potential.As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in Retail Services increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment.For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15. **Current (2025):** As indicated above, USPB provides credit card products through Branded Cards and Retail Services, and mortgages and home equity, small business and personal consumer loans through Citi's Retail Banking network. Retail Banking is concentrated in six major U.S. metropolitan areas. USPB also provides mortgages through correspondent channels. As of December 31, 2024, approximately 77% of USPB EOP loans consisted of Branded Cards and Retail Services credit card loans, which generally drives the overall credit performance of USPB, as Branded Cards and Retail Services net credit losses represented approximately 95% of total USPB net credit losses for the fourth quarter of 2024. As of December 31, 2024, Branded Cards and Retail Services represented 69% and 31%, respectively, of EOP cards loans in USPB. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in USPB was broadly stable quarter-over-quarter. The net credit loss rate increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment impacting both cards portfolios, with lower FICO band customers primarily driving the increase. The 90+ days past due delinquency rate increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment impacting both cards portfolios, with lower FICO band customers primarily driving the increase. Branded CardsUSPB's Branded Cards portfolio consists of both proprietary Citi branded cards portfolios (Value, Rewards and Cash) and co-branded cards portfolios (including Costco and American Airlines). Citi's Branded Cards portfolio benefits from a diverse combination of products. Citi's proprietary cards provide customers with a suite of products with rewards, cash rebates and lending solutions, while co-branded cards provide significant affinity benefits through partnerships with large-scale partners across the airline, retail and telecom sectors. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Branded Cards was broadly stable quarter-over-quarter. The net credit loss rate increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.The 90+ days past due delinquency rate increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. --- ## Modified: Pay Transparency and Pay Equity **Key changes:** - Reworded sentence: "In addition, Citi has continued its effort to support its global workforce, including taking actions with respect to pay equity." - Reworded sentence: "In addition, Citi has focused on measuring and addressing pay equity within the organization." **Prior (2024):** Citigroup's Board is committed to ensuring that the Board and Citi's Executive Management Team are composed of individuals whose backgrounds reflect the diversity of Citi's employees, customers and other stakeholders. In addition, Citi has continued its efforts to support its globally diverse workforce, including, among other things, taking actions with respect to pay equity, setting aspirational representation goals and the use of diverse slates and hiring panels in recruiting. Citi's commitment to diversity, equity and inclusion continues to reflect a workforce that represents the clients it serves globally from all walks of life, backgrounds and origins. Understanding that diversity fuels the Company's culture and business success, Citi's 2025 aspirational representation goals are embedded in its business strategy. Having aspirational goals across all levels - from early career through senior leadership roles - will help ensure Citi not only has diverse talent in leadership roles but will also help build a diverse talent pipeline for the future. The Company constantly strives to ensure Citi remains a great place to work, where people can thrive professionally and personally. In 2023, Citi increased its unique Inclusion Network membership by 23.8% and added 15 new global Inclusion Network chapters. The Company launched the Allyship 365 initiative, focused on cultivating allyship year round and educating colleagues on its diversity, equity and inclusion efforts. Citi values pay transparency and has taken significant action to provide both managers and colleagues with greater clarity around Citi's compensation philosophy. Citi has introduced market-based salary structures and bonus opportunity guidelines in various countries worldwide, and posts salary ranges on all external U.S. job postings, which aligns with strategic objectives of pay equity and transparency. Citi also raised its U.S. minimum wage in 2022, the second broad-based increase in less than two years. In addition, 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 that of men, as well as 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. The raw gap measures the difference in median compensation. The existence of Citi's raw pay gap reflects a need to increase representation of women and U.S. minorities in senior and higher-paying roles. •In 2023, due to its organizational and management simplification initiatives, Citi paused its annual pay equity analysis, as the Company continues the process of aligning roles to its new organizational structure. Citi looks forward to resuming routine pay equity reviews once that work is complete. •For historical context, Citi's 2022 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, and that there was not a statistically significant difference in adjusted compensation for U.S. minorities and non-minorities. •Citi's 2022 raw pay gap analysis showed that the median pay for women globally was 78% of the median for men, up from 74% in 2021 and 2020. The median pay for U.S. minorities was more than 97% of the median for non- minorities, which was up from just above 96% in 2021 and 94% in 2020. **Current (2025):** In addition, Citi has continued its effort to support its global workforce, including taking actions with respect to pay equity. Citi values pay transparency and has taken significant action to provide managers and other employees with greater clarity about Citi's compensation philosophy. Citi has introduced market-based salary structures and bonus opportunity guidelines in various countries worldwide, and posts salary ranges on all external U.S. job postings, which aligns with strategic objectives of pay equity and transparency. In addition, Citi has focused on measuring and addressing pay equity within the organization. Citi's annual pay equity analysis for 2024 determined that on an adjusted basis, global gender and U.S. racial pay gaps are in each case less than 1%. The adjusted pay gap is a true measure of pay equity, or "like for like," that compares the compensation of women to men and U.S. minorities to non-minorities when adjusting for factors such as job function, title/level and geography. --- ## Modified: Benefits and Well-being **Key changes:** - Reworded sentence: "Citi is proud to provide a wide range of benefits that support its employees' mental, social, physical and financial well-being through various life stages and events." **Prior (2024):** Citi is proud to provide a wide range of benefits that support its colleagues' mental, emotional, physical and financial well-being through various life stages and events. Citi is focused on providing equitable benefits that are designed to attract, engage and retain colleagues. Citi has significantly enhanced mental well-being programs by offering free, accessible counseling sessions for colleagues and their family members, as well as offering an online tool so that all colleagues around the globe can easily find their local Employee Assistance Programs and resources. Citi offers instructor-led mental health training for people managers to equip them in supporting their team members. Citi also continues to value the importance of physical well-being - providing employees in several office locations and countries access to onsite medical care clinics, fitness centers, subsidized gym memberships and virtual fitness programs. Citi continues to make modern telemedicine programs increasingly available to colleagues and their family members through programs like Sword Health's digital physical therapy, which rolled out in the U.S. in 2022. In 2023, one year after the Company became the first major U.S. bank to publicly embrace a flexible, hybrid work model, Citi fully implemented it across the organization. Most of Citi's colleagues now work in hybrid roles, working remotely up to two days a week. How We Work provides the majority of colleagues with the ability to balance the demands of their home lives with the work commitments that are necessary for success. The program includes three role designations for colleagues globally: Resident, Hybrid or Remote. The implementation and continuation of this program differentiates Citi from other financial organizations with respect to flexible working arrangements. By embracing a flexible model of work, Citi has focused on keeping its approach consistent and aligned with its values and priorities. For additional information about Citi's human capital management initiatives and goals, see Citi's 2022 ESG Report available at www.citigroup.com. The 2022 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 2023 Annual Report on Form 10- K. **Current (2025):** Citi is proud to provide a wide range of benefits that support its employees' mental, social, physical and financial well-being through various life stages and events. Such benefits contribute to Citi's ability to attract, engage and retain employees. Among the benefits Citi offers are mental health counseling for employees and their family members, access to onsite medical care clinics, fitness centers, subsidized gym memberships and virtual physical therapy in several locations, and leave programs, including parental and caregiver leaves in certain locations to continue to support employees and their families. In addition, Citi was the first major U.S. bank to publicly embrace a flexible, hybrid work model, which Citi fully implemented across the organization. Most of Citi's employees now work in hybrid roles, working remotely up to two days a week. --- ## Modified: Loan Maturities and Fixed/Variable Pricing of Corporate Loans **Key changes:** - Reworded sentence: "In millions of dollars at December 31, 2024Due within1 yearOver 1 yearbut within5 yearsOver 5 yearsbut within15 yearsOver 15 yearsTotalCorporate loansIn North America offices(1)Commercial and industrial$24,848 $30,481 $2,335 $66 $57,730 Financial institutions16,283 24,960 426 146 41,815 Mortgage and real estate(2)8,495 3,716 4,791 1,409 18,411 Installment and other14,699 9,664 1,044 122 25,529 Lease financing166 69 - - 235 Total$64,491 $68,890 $8,596 $1,743 $143,720 In offices outside North America(1)Commercial and industrial$63,633 $21,369 $7,845 $9 $92,856 Financial institutions15,808 8,985 2,333 150 27,276 Mortgage and real estate(2)3,057 4,202 810 67 8,136 Installment and other4,530 15,350 3,819 2,101 25,800 Lease financing3 24 13 - 40 Governments and official institutions885 746 1,384 615 3,630 Total$87,916 $50,676 $16,204 $2,942 $157,738 Corporate loans, net of unearned income(3)(4)$152,407 $119,566 $24,800 $4,685 $301,458 Loans at fixed interest rates(5)Commercial and industrial$4,255 $1,091 $16 Financial institutions1,374 59 146 Mortgage and real estate(2)1,191 4,725 1,006 Other(6)3,169 377 122 Lease financing77 - - Total $10,066 $6,252 $1,290 Loans at floating or adjustable interest rates(4)Commercial and industrial$47,595 $9,089 $59 Financial institutions32,571 2,700 150 Mortgage and real estate(2)6,727 876 470 Other(6)22,591 5,870 2,716 Lease financing16 13 - Total$109,500 $18,548 $3,395 Total fixed/variable pricing of corporate loans with maturities due after one year, net of unearned income(3)(4)$119,566 $24,800 $4,685 In millions of dollars at December 31, 2024" **Prior (2024):** In millions of dollars at December 31, 2023Due within1 yearOver 1 yearbut within5 yearsOver 5 yearsbut within15 yearsOver 15 yearsTotalCorporate loansIn North America offices(1)Commercial and industrial loans$25,045 $34,304 $1,602 $57 $61,008 Financial institutions17,435 21,388 424 146 39,393 Mortgage and real estate(2)7,908 4,185 4,736 984 17,813 Installment and other9,461 12,947 775 152 23,335 Lease financing - 227 - - 227 Total$59,849 $73,051 $7,537 $1,339 $141,776 In offices outside North America(1)Commercial and industrial loans$69,811 $18,128 $5,425 $38 $93,402 Financial institutions18,449 6,577 907 210 26,143 Mortgage and real estate(2)2,639 3,600 888 70 7,197 Installment and other16,081 7,960 1,337 2,529 27,907 Lease financing6 26 16 - 48 Governments and official institutions632 670 1,630 667 3,599 Total$107,618 $36,961 $10,203 $3,514 $158,296 Corporate loans, net of unearned income(3)(4)$167,467 $110,012 $17,740 $4,853 $300,072 Loans at fixed interest rates(5)Commercial and industrial loans$6,636 $883 $17 Financial institutions3,363 62 12 Mortgage and real estate(2)1,311 4,531 846 Other(6)4,792 170 7 Lease financing240 - - Total $16,342 $5,646 $882 Loans at floating or adjustable interest rates(4)Commercial and industrial loans$45,796 $6,144 $78 Financial institutions24,602 1,269 344 Mortgage and real estate(2)6,474 1,093 208 Other(6)16,785 3,572 3,341 Lease financing13 16 - Total$93,670 $12,094 $3,971 Total fixed/variable pricing of corporate loans with maturities due after one year, net of unearned income(3)(4)$110,012 $17,740 $4,853 In millions of dollars at December 31, 2023 **Current (2025):** In millions of dollars at December 31, 2024Due within1 yearOver 1 yearbut within5 yearsOver 5 yearsbut within15 yearsOver 15 yearsTotalCorporate loansIn North America offices(1)Commercial and industrial$24,848 $30,481 $2,335 $66 $57,730 Financial institutions16,283 24,960 426 146 41,815 Mortgage and real estate(2)8,495 3,716 4,791 1,409 18,411 Installment and other14,699 9,664 1,044 122 25,529 Lease financing166 69 - - 235 Total$64,491 $68,890 $8,596 $1,743 $143,720 In offices outside North America(1)Commercial and industrial$63,633 $21,369 $7,845 $9 $92,856 Financial institutions15,808 8,985 2,333 150 27,276 Mortgage and real estate(2)3,057 4,202 810 67 8,136 Installment and other4,530 15,350 3,819 2,101 25,800 Lease financing3 24 13 - 40 Governments and official institutions885 746 1,384 615 3,630 Total$87,916 $50,676 $16,204 $2,942 $157,738 Corporate loans, net of unearned income(3)(4)$152,407 $119,566 $24,800 $4,685 $301,458 Loans at fixed interest rates(5)Commercial and industrial$4,255 $1,091 $16 Financial institutions1,374 59 146 Mortgage and real estate(2)1,191 4,725 1,006 Other(6)3,169 377 122 Lease financing77 - - Total $10,066 $6,252 $1,290 Loans at floating or adjustable interest rates(4)Commercial and industrial$47,595 $9,089 $59 Financial institutions32,571 2,700 150 Mortgage and real estate(2)6,727 876 470 Other(6)22,591 5,870 2,716 Lease financing16 13 - Total$109,500 $18,548 $3,395 Total fixed/variable pricing of corporate loans with maturities due after one year, net of unearned income(3)(4)$119,566 $24,800 $4,685 In millions of dollars at December 31, 2024 --- ## Modified: Fixed/Variable Pricing **Key changes:** - Reworded sentence: "In millions of dollars at December 31, 2024Due within1 yearGreater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsTotalLoans at fixed interest ratesResidential first mortgages$52 $344 $3,887 $69,660 $73,943 Home equity loans4 11 220 203 438 Credit cards(1)49,549 2,302 - - 51,851 Personal, small business and other13,370 7,769 286 141 21,566 Total$62,975 $10,426 $4,393 $70,004 $147,798 Loans at floating or adjustable interest ratesResidential first mortgages$115 $143 $2,750 $62,098 $65,106 Home equity loans2 4 1,027 1,670 2,703 Credit cards(1)132,135 - - - 132,135 Personal, small business and other31,406 12,524 1,232 422 45,584 Total$163,658 $12,671 $5,009 $64,190 $245,528 Total Consumer$226,633 $23,097 $9,402 $134,194 $393,326 In millions of dollars at December 31, 2024 Credit cards(1) Credit cards(1) (1)Credit card loans with maturities greater than one year represent loan modifications to borrowers experiencing financial difficulty and are at fixed interest rates." **Prior (2024):** In millions of dollars at December 31, 2023Due within1 yearGreater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsTotalLoans at fixed interest ratesResidential first mortgages$460 $366 $2,620 $70,126 $73,572 Home equity loans5 25 272 85 387 Credit cards(1)50,435 1,206 - - 51,641 Personal, small business and other13,185 8,869 376 366 22,796 Total$64,085 $10,466 $3,268 $70,577 $148,396 Loans at floating or adjustable interest ratesResidential first mortgages$722 $188 $4,470 $56,185 $61,565 Home equity loans - 2 1,247 1,956 3,205 Credit cards(1)127,312 - - - 127,312 Personal, small business and other45,525 2,963 60 171 48,719 Total$173,559 $3,153 $5,777 $58,312 $240,801 Total Consumer$237,644 $13,619 $9,045 $128,889 $389,197 In millions of dollars at December 31, 2023 Credit cards(1) Credit cards(1) (1)Credit card loans with maturities greater than one year represent loan modifications to borrowers experiencing financial difficulty and are at fixed interest rates. 82 82 82 **Current (2025):** In millions of dollars at December 31, 2024Due within1 yearGreater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsTotalLoans at fixed interest ratesResidential first mortgages$52 $344 $3,887 $69,660 $73,943 Home equity loans4 11 220 203 438 Credit cards(1)49,549 2,302 - - 51,851 Personal, small business and other13,370 7,769 286 141 21,566 Total$62,975 $10,426 $4,393 $70,004 $147,798 Loans at floating or adjustable interest ratesResidential first mortgages$115 $143 $2,750 $62,098 $65,106 Home equity loans2 4 1,027 1,670 2,703 Credit cards(1)132,135 - - - 132,135 Personal, small business and other31,406 12,524 1,232 422 45,584 Total$163,658 $12,671 $5,009 $64,190 $245,528 Total Consumer$226,633 $23,097 $9,402 $134,194 $393,326 In millions of dollars at December 31, 2024 Credit cards(1) Credit cards(1) (1)Credit card loans with maturities greater than one year represent loan modifications to borrowers experiencing financial difficulty and are at fixed interest rates. 85 85 85 --- ## Modified: Executive Management Team **Key changes:** - Added sentence: "Board and Executive Management CommitteesThe Board executes its responsibilities either directly or through its committees." - Added sentence: "The Board has delegated authority to the following Board standing committees to help fulfill its oversight and risk management responsibilities: •Audit Committee: assists the Board in fulfilling its oversight responsibility relating to (i) the integrity of Citigroup's consolidated financial statements, financial reporting process and systems of internal accounting and financial controls, (ii) the performance of the internal audit function (Internal Audit), (iii) the annual independent integrated audit of Citigroup's consolidated financial statements and effectiveness of Citigroup's internal control over financial reporting, the engagement of the independent registered public accounting firm (Independent Auditors) and the evaluation of the Independent Auditors' qualifications, independence and performance, (iv) holding management accountable for the effectiveness of Citigroup's control environment and status of corrective actions, including the timely remediation of control breaks (including, without limitation, significant compliance or operational control breaks), (v) policy standards and guidelines for risk assessment and risk management, (vi) Citigroup's compliance with legal and regulatory requirements, including Citigroup's disclosure controls and procedures and (vii) the fulfillment of the other responsibilities set out in the Audit Committee's Charter.•Compensation, Performance Management and Culture Committee: is responsible for overseeing compensation of employees of the Company and its subsidiaries and affiliates and Citi management's sustained focus on fostering a principled culture of sound ethics, responsible conduct and accountability within the organization." - Added sentence: "The Committee regularly reviews Citi's management resources and the performance of senior management." - Added sentence: "The Committee is responsible for determining the compensation for the Chief Executive Officer and approving the compensation of other executive officers of the Company and members of Citi's Executive Management Team." - Added sentence: "The Committee is also responsible for approving the incentive compensation structure for other members of senior management and certain highly compensated employees (including discretionary incentive awards to covered employees as defined in applicable bank regulatory guidance), in accordance with guidelines established by the Committee from time to time." **Prior (2024):** The Citigroup CEO directs and oversees the day-to-day management of Citi as delegated by the Board of Directors. The CEO leads the Company through the Executive Management Team and provides oversight of group activities, both directly and through authority delegated to committees established to oversee the management of risk, to ensure continued alignment with Citi's risk strategy. **Current (2025):** The Citigroup CEO directs and oversees the day-to-day management of Citi as delegated by the Board of Directors. The CEO leads the Company through the Executive Management Team and provides oversight of group activities, both directly and through authority delegated to committees established to oversee the management of risk, to ensure continued alignment with Citi's risk strategy. Board and Executive Management CommitteesThe Board executes its responsibilities either directly or through its committees. The Board has delegated authority to the following Board standing committees to help fulfill its oversight and risk management responsibilities: •Audit Committee: assists the Board in fulfilling its oversight responsibility relating to (i) the integrity of Citigroup's consolidated financial statements, financial reporting process and systems of internal accounting and financial controls, (ii) the performance of the internal audit function (Internal Audit), (iii) the annual independent integrated audit of Citigroup's consolidated financial statements and effectiveness of Citigroup's internal control over financial reporting, the engagement of the independent registered public accounting firm (Independent Auditors) and the evaluation of the Independent Auditors' qualifications, independence and performance, (iv) holding management accountable for the effectiveness of Citigroup's control environment and status of corrective actions, including the timely remediation of control breaks (including, without limitation, significant compliance or operational control breaks), (v) policy standards and guidelines for risk assessment and risk management, (vi) Citigroup's compliance with legal and regulatory requirements, including Citigroup's disclosure controls and procedures and (vii) the fulfillment of the other responsibilities set out in the Audit Committee's Charter.•Compensation, Performance Management and Culture Committee: is responsible for overseeing compensation of employees of the Company and its subsidiaries and affiliates and Citi management's sustained focus on fostering a principled culture of sound ethics, responsible conduct and accountability within the organization. The Committee regularly reviews Citi's management resources and the performance of senior management. The Committee is responsible for determining the compensation for the Chief Executive Officer and approving the compensation of other executive officers of the Company and members of Citi's Executive Management Team. The Committee is also responsible for approving the incentive compensation structure for other members of senior management and certain highly compensated employees (including discretionary incentive awards to covered employees as defined in applicable bank regulatory guidance), in accordance with guidelines established by the Committee from time to time. The Committee also has broad oversight over compliance with bank regulatory guidance governing Citi's incentive compensation.•Nomination, Governance and Public Affairs Committee: is responsible for (i) identifying individuals qualified to become Board members and recommending to the Board the director nominees for the next annual meeting of stockholders, (ii) leading the Board in its annual review of the Board's performance, (iii) recommending to the Board directors for each committee for appointment by the Board, (iv) reviewing the Company's policies and programs that relate to public issues of significance to the --- ## Modified: Retail Services **Key changes:** - Reworded sentence: "31, 2023≥ 74036 %34 %36 %660-73941 42 41 < 66023 24 23 Total100 %100 %100 %" **Prior (2024):** USPB's Retail Services partners directly with more than 20 retailers and dealers to offer private label and co-branded cards. Retail Services' target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel. Retail Services continually evaluates opportunities to add partners within target industries that have strong loyalty, lending or payment programs and growth potential. As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in Retail Services increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment. For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15. 77 77 77 Retail BankingUSPB's Retail Banking portfolio consists primarily of consumer mortgages (including home equity) and unsecured lending products, such as small business loans and personal loans. The portfolio is generally delinquency managed, where Citi evaluates credit risk based on FICO scores, delinquencies and the value of underlying collateral. The consumer mortgages in this portfolio have historically been extended to high credit quality customers, generally with loan-to-value ratios that are less than or equal to 80% on first and second mortgages. For additional information, see "Loan-to-Value (LTV) Ratios" in Note 15.As presented in the chart above, the net credit loss rate in Retail Banking for the fourth quarter of 2023 was broadly stable quarter-over-quarter and increased year-over-year, primarily driven by the growth and seasoning of personal loans.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and decreased year-over-year, primarily driven by lower delinquencies in U.S. mortgages.WealthAs indicated above, Wealth provides consumer mortgages, margin lending, cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and cards. As of December 31, 2023, approximately $46 billion, or 30%, of the portfolio was classifiably managed and primarily consisted of margin lending, commercial real estate, subscription credit finance and other lending programs. These classifiably managed loans are primarily evaluated for credit risk based on their internal risk rating, of which 85% is rated investment grade. While the delinquency rate in the chart above is calculated only for the delinquency-managed portfolio, the net credit loss rate is calculated using net credit losses for both the delinquency and classifiably managed portfolios.As presented in the chart above, the net credit loss rate and 90+ days past due delinquency rate in Wealth for the fourth quarter of 2023 were broadly stable quarter-over-quarter and year-over-year. The low net credit loss and the 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. Mexico ConsumerMexico Consumer operates in Mexico through Citibanamex and provides credit cards, consumer mortgages and small business and personal loans. Mexico Consumer serves a more mass-market segment in Mexico and focuses on developing multiproduct relationships with customers.As presented in the chart above, the fourth quarter of 2023 net credit loss rate in Mexico Consumer increased quarter-over-quarter and year-over-year, primarily driven by the ongoing normalization of loss rates from post-pandemic lows. The 90+ days past due delinquency rate was relatively stable quarter-over-quarter and year-over-year. For additional information on cost of credit, loan delinquency and other information for Citi's consumer loan portfolios, see each respective business's results of operations above and Note 15. Retail BankingUSPB's Retail Banking portfolio consists primarily of consumer mortgages (including home equity) and unsecured lending products, such as small business loans and personal loans. The portfolio is generally delinquency managed, where Citi evaluates credit risk based on FICO scores, delinquencies and the value of underlying collateral. The consumer mortgages in this portfolio have historically been extended to high credit quality customers, generally with loan-to-value ratios that are less than or equal to 80% on first and second mortgages. For additional information, see "Loan-to-Value (LTV) Ratios" in Note 15.As presented in the chart above, the net credit loss rate in Retail Banking for the fourth quarter of 2023 was broadly stable quarter-over-quarter and increased year-over-year, primarily driven by the growth and seasoning of personal loans.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and decreased year-over-year, primarily driven by lower delinquencies in U.S. mortgages.WealthAs indicated above, Wealth provides consumer mortgages, margin lending, cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and cards. As of December 31, 2023, approximately $46 billion, or 30%, of the portfolio was classifiably managed and primarily consisted of margin lending, commercial real estate, subscription credit finance and other lending programs. These classifiably managed loans are primarily evaluated for credit **Current (2025):** USPB's Retail Services partners directly with more than 20 retailers and dealers to offer private label and co-branded cards. Retail Services' target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel. Retail Services continually evaluates opportunities to add partners within target industries that have strong loyalty, lending or payment programs and growth potential. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Services increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15. Retail BankingUSPB's Retail Banking portfolio consists primarily ofconsumer mortgages (including home equity) and unsecuredlending products, such as small business loans and personalloans. The portfolio is generally delinquency managed, whereCiti evaluates credit risk based on FICO scores, delinquenciesand the value of underlying collateral. The consumermortgages in this portfolio have historically been extended tohigh credit quality customers, generally with loan-to-valueratios that are less than or equal to 80% on first and secondmortgages. For additional information, see "Loan-to-Value(LTV) Ratios" in Note 15.As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Banking increased quarter-over-quarter and year-over-year, primarily driven by consumer overdraft loans. The 90+ days past due delinquency rate was largely unchanged quarter-over-quarter and decreased year-over-year. The decrease was primarily driven by lower delinquencies in consumer mortgages.WealthWealth provides consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold businesses. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and credit cards. --- ## Modified: Loan Maturities **Key changes:** - Reworded sentence: "In millions of dollars at December 31, 2024Due within1 yearGreater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsTotalIn North America officesResidential first mortgages$2 $272 $2,738 $111,581 $114,593 Home equity loans6 15 1,247 1,873 3,141 Credit cards(1)168,789 2,270 - - 171,059 Personal, small business and other17,844 13,853 1,288 170 33,155 Total$186,641 $16,410 $5,273 $113,624 $321,948 In offices outside North AmericaResidential mortgages$165 $215 $3,899 $20,177 $24,456 Credit cards(1)12,895 32 - - 12,927 Personal, small business and other26,932 6,440 230 393 33,995 Total$39,992 $6,687 $4,129 $20,570 $71,378 Total Consumer$226,633 $23,097 $9,402 $134,194 $393,326 In millions of dollars at December 31, 2024 Credit cards(1) Credit cards(1) (1)Credit card loans with maturities greater than one year represent loan modifications to borrowers experiencing financial difficulty and are at fixed interest rates." **Prior (2024):** In millions of dollars at December 31, 2023Due within1 yearGreater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsTotalIn North America officesResidential first mortgages$3 $281 $3,017 $105,410 $108,711 Home equity loans5 27 1,519 2,041 3,592 Credit cards(1)163,563 1,157 - - 164,720 Personal, small business and other31,202 4,673 222 38 36,135 Total$194,773 $6,138 $4,758 $107,489 $313,158 In offices outside North AmericaResidential mortgages$1,179 $273 $4,073 $20,901 $26,426 Credit cards(1)14,184 49 - - 14,233 Personal, small business and other27,508 7,159 214 499 35,380 Total$42,871 $7,481 $4,287 $21,400 $76,039 Total Consumer$237,644 $13,619 $9,045 $128,889 $389,197 In millions of dollars at December 31, 2023 Credit cards(1) Credit cards(1) (1)Credit card loans with maturities greater than one year represent loan modifications to borrowers experiencing financial difficulty and are at fixed interest rates. **Current (2025):** In millions of dollars at December 31, 2024Due within1 yearGreater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsTotalIn North America officesResidential first mortgages$2 $272 $2,738 $111,581 $114,593 Home equity loans6 15 1,247 1,873 3,141 Credit cards(1)168,789 2,270 - - 171,059 Personal, small business and other17,844 13,853 1,288 170 33,155 Total$186,641 $16,410 $5,273 $113,624 $321,948 In offices outside North AmericaResidential mortgages$165 $215 $3,899 $20,177 $24,456 Credit cards(1)12,895 32 - - 12,927 Personal, small business and other26,932 6,440 230 393 33,995 Total$39,992 $6,687 $4,129 $20,570 $71,378 Total Consumer$226,633 $23,097 $9,402 $134,194 $393,326 In millions of dollars at December 31, 2024 Credit cards(1) Credit cards(1) (1)Credit card loans with maturities greater than one year represent loan modifications to borrowers experiencing financial difficulty and are at fixed interest rates. --- ## Modified: Branded Cards **Key changes:** - Reworded sentence: "31, 2023≥ 74056 %55 %57 %660-73933 34 33 < 66011 11 10 Total100 %100 %100 %" **Prior (2024):** USPB's Branded Cards portfolio includes proprietary and co-branded cards. As presented in the chart above, the fourth quarter of 2023 net credit loss rate and 90+ days past due delinquency rate in Branded Cards increased quarter-over-quarter and year-over-year, largely driven by a continued increase in net flow rates, primarily reflecting normalization to pre-pandemic levels as well as the impact of macroeconomic pressures related to the higher inflationary and interest rate environment. **Current (2025):** USPB's Branded Cards portfolio consists of both proprietary Citi branded cards portfolios (Value, Rewards and Cash) and co-branded cards portfolios (including Costco and American Airlines). Citi's Branded Cards portfolio benefits from a diverse combination of products. Citi's proprietary cards provide customers with a suite of products with rewards, cash rebates and lending solutions, while co-branded cards provide significant affinity benefits through partnerships with large-scale partners across the airline, retail and telecom sectors. As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Branded Cards was broadly stable quarter-over-quarter. The net credit loss rate increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. The 90+ days past due delinquency rate increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase. 80 80 80 Retail ServicesUSPB's Retail Services partners directly with more than20 retailers and dealers to offer private label and co-brandedcards. Retail Services' target market focuses on select industrysegments such as home improvement, specialty retail,consumer electronics and fuel. Retail Services continuallyevaluates opportunities to add partners within target industriesthat have strong loyalty, lending or payment programs andgrowth potential.As presented in the chart above, the fourth quarter of 2024net credit loss rate in Retail Services increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15.Retail BankingUSPB's Retail Banking portfolio consists primarily ofconsumer mortgages (including home equity) and unsecuredlending products, such as small business loans and personalloans. The portfolio is generally delinquency managed, whereCiti evaluates credit risk based on FICO scores, delinquenciesand the value of underlying collateral. The consumermortgages in this portfolio have historically been extended tohigh credit quality customers, generally with loan-to-valueratios that are less than or equal to 80% on first and secondmortgages. For additional information, see "Loan-to-Value(LTV) Ratios" in Note 15.As presented in the chart above, the fourth quarter of 2024 net credit loss rate in Retail Banking increased quarter-over-quarter and year-over-year, primarily driven by consumer overdraft loans. The 90+ days past due delinquency rate was largely unchanged quarter-over-quarter and decreased year-over-year. The decrease was primarily driven by lower delinquencies in consumer mortgages.WealthWealth provides consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from affluent to ultra-high net worth through the Private Bank, Wealth at Work and Citigold businesses. These customer segments represent a target market that is characterized by historically low default rates and delinquencies and includes loans that are delinquency managed or classifiably managed. The delinquency-managed portfolio consists primarily of mortgages, margin lending and credit cards. Retail ServicesUSPB's Retail Services partners directly with more than20 retailers and dealers to offer private label and co-brandedcards. Retail Services' target market focuses on select industrysegments such as home improvement, specialty retail,consumer electronics and fuel. Retail Services continuallyevaluates opportunities to add partners within target industriesthat have strong loyalty, lending or payment programs andgrowth potential.As presented in the chart above, the fourth quarter of 2024net credit loss rate in Retail Services increased quarter-over-quarter, primarily driven by seasonality, and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter and increased year-over-year, primarily reflecting the continued maturation of multiple cards loan vintages originated in recent years. The maturation was delayed by unprecedented levels of government stimulus during the pandemic. In addition, the increase was driven by macroeconomic pressures related to the elevated inflationary and interest rate environment, with lower FICO band customers primarily driving the increase.For additional information on cost of credit, loan delinquency and other information for Citi's cards portfolios, see each respective business's results of operations above and Note 15. --- *Data sourced from SEC EDGAR. Last updated 2026-06-01.*