{
  "ticker": "C",
  "company": "Citigroup Inc.",
  "filing_type": "10-K",
  "year_current": "2026",
  "year_prior": "2025",
  "summary": {
    "added": 11,
    "removed": 22,
    "modified": 69,
    "unchanged": 30,
    "total_current": 110,
    "total_prior": 121
  },
  "source": "SEC EDGAR",
  "url": "https://riskdiff.com/c/2026-vs-2025/",
  "markdown_url": "https://riskdiff.com/c/2026-vs-2025/index.md",
  "json_url": "https://riskdiff.com/c/2026-vs-2025/index.json",
  "generated": "2026-06-01",
  "ai_summary": null,
  "risks": [
    {
      "status": "ADDED",
      "current_title": "Citi Is Subject to Complex Tax Laws, Which May Change, and Citi’s Interpretation or Application of These Complex Tax Laws Could Differ from Those of Governmental Authorities, Which Could Result in Litigation or Examinations and the Payment of Additional Taxes, Penalties or Interest.",
      "prior_title": null,
      "current_body": "Citi is subject to various 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. Moreover, these tax laws and related regulations may change, which could result in additional tax liability for Citi. Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding 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, as well as in connection with asset dispositions, divestitures or similar transactions, 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 how Citi accrues for potential losses from tax matters."
    },
    {
      "status": "ADDED",
      "current_title": "The Development and Use of AI by Citi and Others Present Risks to Citi’s Businesses.",
      "prior_title": null,
      "current_body": "Citi has used AI and machine learning tools for many years and has more recently begun to broadly deploy Generative AI, including within its technology platforms and services. In the future, Citi expects to more broadly integrate Generative AI tools within its systems, businesses and functions, including advanced AI capabilities, such as autonomous agents and sophisticated user interactions, which if improperly managed, could result in increased risks and costs. While Citi has policies that govern the use of emerging technologies, including in model risk management, ineffective, inadequate or faulty Generative AI development or deployment practices by Citi or third parties, including insufficient testing and monitoring, poorly structured or manipulated prompts or insufficient or inadequate human oversight, could result in adverse consequences, such as AI algorithms that produce inaccurate or incomplete output or output based on biased, incomplete and/or inaccurate datasets, infringe on intellectual property rights of others, involve data exfiltration risks, including release of confidential or proprietary information, or cause other issues, concerns or deficiencies. The complexity of AI models, particularly Generative AI models, can make it challenging to understand why particular outputs are generated, which can increase the risk of erroneous and/or biased output and complying with regulations requiring documentation, explainability or auditability on the basis of AI-influenced decisions. Citi may also rely on AI models developed by third parties and be exposed to risks arising from their development and training methods, including potential inclusion of unauthorized material in the training data or limitations in their risk mitigation strategies, over which Citi may have limited visibility or control (see also the operational processes and systems risk factor below). While Citi may provide restrictions on use of certain data in third-party AI applications or models, a third party could breach those terms, which could expose Citi to legal and reputations risks. Citi is also exposed to risks related to the use of AI technologies by counterparties, clients and vendors, where interconnected AI systems could amplify failures and threats of cyber infiltration, as well as cause widespread disruptions. 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 exposure to cyberattacks (see the cybersecurity risk factor below), as well as disinformation and market manipulation campaigns, 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. Citi also faces competition risks to the extent that competitors may be faster and more successful in developing and deploying AI technologies to improve processes, productivity, efficiency, products and services, and thereby gain competitive advantages over Citi (see the competition risk factor above). In addition, compliance with new or changing laws, regulations or industry standards relating to AI may impose additional operational risks and costs. Failure to sufficiently manage these risks could expose Citi to adverse legal, regulatory or reputational consequences. While Citi has policies that govern the use of emerging technologies, including in model risk management, ineffective, inadequate or faulty Generative AI development or deployment practices by Citi or third parties, including insufficient testing and monitoring, poorly structured or manipulated prompts or insufficient or inadequate human oversight, could result in adverse consequences, such as AI algorithms that produce inaccurate or incomplete output or output based on biased, incomplete and/or inaccurate datasets, infringe on intellectual property rights of others, involve data exfiltration risks, including release of confidential or proprietary information, or cause other issues, concerns or deficiencies. The complexity of AI models, particularly Generative AI models, can make it challenging to understand why particular outputs are generated, which can increase the risk of erroneous and/or biased output and complying with regulations requiring documentation, explainability or auditability on the basis of AI-influenced decisions. Citi may also rely on AI models developed by third parties and be exposed to risks arising from their development and training methods, including potential inclusion of unauthorized material in the training data or limitations in their risk mitigation strategies, over which Citi may have limited visibility or control (see also the operational processes and systems risk factor below). While Citi may provide restrictions on use of certain data in third-party AI applications or models, a third party could breach those terms, which could expose Citi to legal and reputations risks. Citi is also exposed to risks related to the use of AI technologies by counterparties, clients and vendors, where interconnected AI systems could amplify failures and threats of cyber infiltration, as well as cause widespread disruptions. 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 exposure to cyberattacks (see the cybersecurity risk factor below), as well as disinformation and market manipulation campaigns, 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. Citi also faces competition risks to the extent that competitors may be faster and more successful in developing and deploying AI technologies to improve processes, productivity, efficiency, products and services, and thereby gain competitive advantages over Citi (see the competition risk factor above). In addition, compliance with new or changing laws, regulations or industry standards relating to AI may impose additional operational risks and costs. Failure to sufficiently manage these risks could expose Citi to adverse legal, regulatory or reputational consequences. 54 54 54 OPERATIONAL RISKSA Disruption or Failure 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. With the proliferation of emerging technologies, including AI and digital assets, 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. For example, Citi’s involvement in digital assets,including custody, asset tokenization and facilitation of clients’ digital assets activities, exposes Citi to increased operational risks due to the unique technological requirements for securing these assets.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 that provide products or services to Citi (e.g., cloud service providers), including such third parties’ downstream service providers, as well as other Citi counterparties and market participants, which could be exacerbated by the concentration of third-party providers across the financial services industry; deficiencies in processes or controls; inadequate management of data governance practices, data controls and monitoring mechanisms that may adversely impact internal or external reporting and decision-making; cyber or information security incidents (see the cybersecurity risk factor below); human error, such as manual transaction processing errors (e.g., erroneous payments to lenders or manual errors by traders that cause system and market disruptions or losses), which can be exacerbated by staffing challenges and processing backlogs; fraud or malice on the part of employees or third parties; insufficient (or limited) straight-through processing between legacy or bespoke systems and any failure to design and effectively operate controls that mitigate operational risks associated with those legacy or bespoke systems, leading to potential risk of errors and operating losses; accidental system or technological failure; electrical or telecommunication outages; failures of or cyber incidents involving computer servers or infrastructure, including software updates and cloud services; or other similar losses or damage to Citi’s property or assets (see also the climate change risk factor above). Additionally, Citi’s ability to effectively maintain and upgrade systems and infrastructure can become more challenging as the speed, frequency, volume, interconnectivity and complexity of transactions continue to increase.For example, operational incidents can arise due to failures by third parties with which Citi does business, such as failures by internet, mobile technology and cloud service providers or other vendors to adequately follow procedures or processes, safeguard their systems or prevent system disruptions or cyberattacks. Failure by Citi to develop, implement and operate a third-party risk management program commensurate with the level of risk, complexity and nature of its third-party relationships can also result in operational incidents. In addition, Citi has experienced and could experience further losses associated with manual transaction processing errors, including erroneous payments to lenders or manual errors by Citi traders that cause system and market disruptions and losses for Citi and its clients. Irrespective of the sophistication of the technology utilized by Citi, there will always be a risk of human and other errors. In view of the large transactions in which Citi engages, such errors have in the past resulted, and could result, in significant losses. While Citi has change management processes in place to appropriately upgrade its operational processes and systems to ensure that any changes introduced do not adversely impact security and operational continuity, such change management can fail or be ineffective. Furthermore, when Citi introduces new products, systems or processes, new operational risks that may arise from those changes may not be identified, or adequate controls to mitigate the identified risks may not be appropriately implemented or operate as designed. Incidents that impact information security, technology operations or other operational processes may cause disruptions and/or malfunctions within Citi’s businesses (e.g., the temporary loss of availability of Citi’s online banking system or mobile banking platform), as well as the operations of its clients, customers or other third parties. In addition, operational incidents could involve the failure or ineffectiveness of internal processes or controls. Given Citi’s global footprint and the high volume of transactions processed by Citi, certain failures, errors or actions may be repeated or compounded before they are discovered and rectified, which would further increase the consequences and costs. Operational incidents could result in financial losses and other costs as well as misappropriation, corruption or loss of confidential and other information or assets, which could significantly negatively impact Citi’s reputation, customers, clients, employees, businesses or results of operations and financial condition, or the potential for systemic disruption due to interconnected systems and dependencies. Additionally, any unavailability or failure of backup systems could impact business continuity in the event of an operational incident. Cyber-related and other operational incidents can also result in legal and regulatory actions or proceedings, fines and other costs (see the legal and regulatory proceedings risk factor below).Failure by Citi to continue to increase its operational resilience, and ensure that important business services and their impact tolerance time and severity scales are clearly defined, could expose Citi to service disruptions, leading to OPERATIONAL RISKSA Disruption or Failure 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. With the proliferation of emerging technologies, including AI and digital assets, 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. For example, Citi’s involvement in digital assets,including custody, asset tokenization and facilitation of clients’ digital assets activities, exposes Citi to increased operational risks due to the unique technological requirements for securing these assets.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 that provide products or services to Citi (e.g., cloud service providers), including such third parties’ downstream service providers, as well as other Citi counterparties and market participants, which could be exacerbated by the concentration of third-party providers across the financial services industry; deficiencies in processes or controls; inadequate management of data governance practices, data controls and monitoring mechanisms that may adversely impact internal or external reporting and decision-making; cyber or information security incidents (see the cybersecurity risk factor below); human error, such as manual transaction processing errors (e.g., erroneous payments to lenders or manual errors by traders that cause system and market disruptions or losses), which can be exacerbated by staffing challenges and processing backlogs; fraud or malice on the part of employees or third parties; insufficient (or limited) straight-through processing between legacy or bespoke systems and any failure to design and effectively operate controls that mitigate operational risks associated with those legacy or bespoke systems, leading to potential risk of errors and operating losses; accidental system or technological failure; electrical or telecommunication outages; failures of or cyber incidents involving computer servers or infrastructure, including software updates and cloud services; or other similar losses or damage to Citi’s property or assets (see also the climate change risk factor above). Additionally, Citi’s ability to effectively maintain and upgrade systems and infrastructure"
    },
    {
      "status": "ADDED",
      "current_title": "First Line of Defense",
      "prior_title": null,
      "current_body": "Citi’s first line of defense owns the risks and associated controls inherent in, or arising from, the execution of its business activities and is responsible for identifying, measuring, monitoring, controlling and reporting those risks consistent with Citi’s strategy, Mission and Value Proposition, Leadership Principles and risk appetite. The first line of defense is composed of Citi’s operating segments (i.e., Services, Markets, Banking, Wealth, U.S. Personal Banking as of December 31, 2025), as well as International, North America and All Other (including certain corporate functions (i.e., Chief Operating Office, Enterprise Services and Public Affairs, Finance, Technology and Business Enablement). First line of defense may also contain organizations that are enterprise support functions—see “Enterprise Support Functions” below."
    },
    {
      "status": "ADDED",
      "current_title": "Independent Compliance Risk Management",
      "prior_title": null,
      "current_body": "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, and is committed to maintaining an enterprise-wide compliance risk management framework across Citi. The CCO reports to Citi’s Chief Legal Officer, and ICRM is organizationally part of Global Legal Affairs and Compliance. In addition, the CCO has matrix reporting into the CRO."
    },
    {
      "status": "ADDED",
      "current_title": "Executive Management Team",
      "prior_title": null,
      "current_body": "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."
    },
    {
      "status": "ADDED",
      "current_title": "Average Loans",
      "prior_title": null,
      "current_body": "The table below details average loans, by segment and All Other, and the total Citigroup end-of-period loans for each of the periods indicated: In billions of dollars4Q253Q254Q24Services$96 $94 $87 Markets152 147 122 Banking79 81 84 Wealth149 151 148 USPB Branded Cards$122 $120 $117 Retail Services50 50 52 Retail Banking54 50 47 Total USPB$226 $220 $216 All Other$35 $32 $31 Total Citigroup loans (AVG)$737 $725 $688 Total Citigroup loans (EOP)$752 $734 $694 Retail Banking Total USPB Average loans increased 7% year-over-year and 2% sequentially. The year-over-year increase was primarily driven by growth in Markets, USPB and Services, partially offset by declines in Banking. Year-over-year average loans for: •Services increased 10%, driven by demand in TTS for working capital loans as well as export and agency finance. •Markets increased 25%, primarily driven by asset-backed financing and commercial warehouse lending in Spread Products. •Banking decreased 6%, due to lower aggregate customer demand for funded loans. •Wealth increased 1%, with growth in margin lending primarily offset by the transfers of certain relationships and associated mortgage loans to USPB from Wealth. •USPB increased 5%, driven by growth in Retail Banking, largely due to transfers of certain relationships and associated mortgage loans to USPB from Wealth, as well as growth in Branded Cards. •All Other increased 13%, driven by growth in Mexico Consumer/SBMM (including the impact of Mexican peso appreciation), partially offset by the continued wind-downs in Asia Consumer within Legacy Franchises (including the impact of moving HFS loans to Other assets). 68 68 68 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."
    },
    {
      "status": "ADDED",
      "current_title": "Portfolio Mix—Industry",
      "prior_title": null,
      "current_body": "Citi’s corporate credit portfolio is diversified by industry. The industry classifications are generally based on the clients’ primary business activity. The following table details the allocation of Citi’s total corporate credit portfolio by industry: Total exposure December 31,2025September 30,2025December 31,2024Transportation and industrials19 %19 %20 %Technology, media and telecom14 15 12 Banks and finance companies(1)13 13 12 Real estate11 10 11 Commercial8 8 8 Residential3 2 3 Consumer retail10 10 11 Power, chemicals, metals and mining8 9 9 Energy and commodities6 6 6 Healthcare5 5 5 Public sector4 4 4 Insurance3 3 4 Asset managers and funds3 3 3 Financial markets infrastructure3 3 2 Other industries1 — 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. 70 70 70 The following table details Citi’s corporate credit portfolio by industry as of December 31, 2025: Non-investment gradeSelected metricsIn millions of dollarsTotal credit exposure(1)(8)Funded(2)Unfunded(3)Investment gradeNon-criticizedCriticized performingCriticized non-performing(4)30 days or more past due and accruingNet credit losses (recoveries)Credit derivative hedges(5)Transportation and industrials$153,721 $58,014 $95,707 $114,560 $33,086 $5,652 $423 $115 $24 $(7,882)Autos(6)51,344 22,265 29,079 41,389 8,336 1,609 10 4 7 (2,504)Transportation30,298 13,512 16,786 21,518 7,892 729 159 33 2 (1,166)Industrials72,079 22,237 49,842 51,653 16,858 3,314 254 78 15 (4,212)Technology, media and telecom115,075 34,144 80,931 73,946 37,367 3,417 345 49 6 (7,701)Banks and finance companies106,266 73,206 33,060 95,515 9,614 1,057 80 4 151 (691)Real estate90,677 62,776 27,901 76,691 9,881 3,454 651 32 11 (917)Commercial69,548 44,387 25,161 55,769 9,674 3,454 651 31 11 (917)Residential21,129 18,389 2,740 20,922 207 — — 1 — — Consumer retail82,879 34,119 48,760 58,111 20,751 3,841 176 23 77 (5,614)Power, chemicals, metals and mining61,347 18,695 42,652 43,453 12,408 5,058 428 28 5 (5,860)Power27,099 6,319 20,780 22,201 4,485 386 27 2 8 (2,829)Chemicals21,048 6,956 14,092 12,688 4,651 3,387 322 24 1 (2,128)Metals and mining13,200 5,420 7,780 8,564 3,272 1,285 79 2 (4)(903)Energy and commodities(7)46,282 12,686 33,596 37,864 7,453 790 175 7 77 (3,176)Healthcare43,520 8,076 35,444 34,162 7,779 1,555 24 25 3 (3,520)Public sector31,498 17,063 14,435 28,321 2,649 515 13 47 3 (595)Asset managers and funds27,725 10,642 17,083 20,957 6,611 153 4 3 — (117)Insurance27,620 3,657 23,963 25,585 1,967 68 — 1 — (4,494)Financial markets infrastructure23,360 151 23,209 23,227 133 — — — — (14)Securities firms1,286 154 1,132 1,074 211 1 — — — (19)Other industries(6)5,995 3,510 2,485 4,254 1,614 116 11 39 8 (2)Total$817,251 $336,893 $480,358 $637,720 $151,524 $25,677 $2,330 $373 $365 $(40,602)"
    },
    {
      "status": "ADDED",
      "current_title": "This page intentionally left blank.",
      "prior_title": null,
      "current_body": "75 75 75 CONSUMER CREDITCiti'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.As of December 31, 2025, USPB provided credit cards, consumer mortgages, personal loans, small business banking and other retail lending, and Wealth provided consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from the affluent to ultra-high net worth through the Private Bank, Citigold and Wealth at Work. USPB’s retail banking products included 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 (Poland and Korea). CONSUMER CREDITCiti'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."
    },
    {
      "status": "ADDED",
      "current_title": "Consumer Credit Portfolio",
      "prior_title": null,
      "current_body": "The following table presents Citi’s quarterly end-of-period consumer loans(1): In billions of dollars4Q241Q252Q253Q254Q25Wealth(2)(3)Mortgages(4)$89.0 $87.9 $88.6 $89.1 $86.4 Margin lending29.4 31.5 31.3 32.0 33.4 Personal, small business and other24.1 23.1 25.9 25.5 25.3 Cards5.0 4.8 4.9 4.8 4.9 Total$147.5 $147.3 $150.7 $151.4 $150.0 USPB(4)Branded Cards(5)$121.1 $116.3 $120.2 $121.2 $125.3 Credit cards117.3 112.6 116.6 117.4 121.5 Personal installment loans(5)3.8 3.7 3.6 3.8 3.8 Retail Services53.8 50.2 50.7 50.1 52.2 Retail Banking(5)46.8 48.2 49.3 50.3 54.3 Mortgages45.5 47.0 48.1 49.2 53.1 Personal, small business and other1.3 1.2 1.2 1.1 1.2 Total$221.7 $214.7 $220.2 $221.6 $231.8 All Other—Legacy FranchisesMexico Consumer$17.2 $17.9 $20.0 $21.2 $22.5 Asia Consumer(6)4.7 4.5 3.0 2.7 2.5 Legacy Holdings Assets(7)2.0 1.9 1.9 1.7 1.7 Total$23.9 $24.3 $24.9 $25.6 $26.7 Total consumer loans$393.1 $386.3 $395.8 $398.6 $408.5"
    },
    {
      "status": "ADDED",
      "current_title": "Branded Cards—Credit Cards",
      "prior_title": null,
      "current_body": "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) and personal installment loans. Citi’s Branded Cards portfolio has a diverse combination of credit card products. As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Branded Cards’ credit cards decreased quarter-over-quarter, primarily driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance. The 90+ days past due delinquency rate increased quarter-over-quarter, driven by seasonality, and was broadly stable year-over-year."
    },
    {
      "status": "ADDED",
      "current_title": "Scenario Analysis",
      "prior_title": null,
      "current_body": "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 as of December 31, 2025. 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. These scenarios include the following:•a parallel shift involving changes to both short-term and long-term rates by an equal amount •a steeper yield curve involving holding short-term rates constant and increasing long-term rates or holding long-term rates constant and decreasing short term rates•a flatter yield curve involving increasing short-term rates and holding long-term rates constant or holding short-term rates constant and decreasing long-term rates These scenarios include the following: •a parallel shift involving changes to both short-term and long-term rates by an equal amount •a steeper yield curve involving holding short-term rates constant and increasing long-term rates or holding long-term rates constant and decreasing short term rates •a flatter yield curve involving increasing short-term rates and holding long-term rates constant or holding short-term rates constant and decreasing long-term rates In millions of dollars, except as otherwise notedParallel shift(1)Short-end flattenerLong-end steepenerLong-end flattenerShort-end steepenerParallel shiftParallel shiftParallel shiftOvernight 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$(33)$(176)$217 $(145)$(317)$(509)$(324)$(1,113)All other currencies(1)1,402 1,187 217 (197)(1,021)(1,209)2,779 (2,422)Total$1,369 $1,011 $434 $(342)$(1,338)$(1,718)$2,455 $(3,535)Estimated initial impact to AOCI (after-tax)(2)$(2,597)$(2,116)$(524)$142 $2,142 $2,290 $(5,349)$4,043"
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "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.",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "NET ZERO AND SUSTAINABILITY",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Net Zero Emissions by 2050",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Sustainable Operations",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Sustainable Finance",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "HUMAN CAPITAL RESOURCES AND MANAGEMENT",
      "prior_body": "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"
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Workforce Size and Distribution",
      "prior_body": "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:"
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "All Other, including Legacy Franchises, Operations and Technology, and Global Staff Functions",
      "prior_body": "(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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Talent Management",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Driving a Culture of Excellence and Accountability",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Workforce Development",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Benefits and Well-being",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Independent Risk Management",
      "prior_body": "The IRM organization sets risk and control standards for the first line of defense and actively manages and oversees aggregate credit, market (trading and non-trading), liquidity, strategic, operational and reputation risks across Citi, including risks that span categories, such as concentration risk, country risk and climate risk. IRM is organized to align to businesses, risk categories, legal entities/clusters and Company-wide, cross-risk functions or processes. Each of these units reports to a member of the Risk Management Executive Council, who all report to the Citigroup CRO."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Board Oversight",
      "prior_body": "The 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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Portfolio Mix—Industry",
      "prior_body": "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)"
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Consumer Credit Portfolio",
      "prior_body": "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"
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Branded Cards",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Loan Maturities",
      "prior_body": "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."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Consumer loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(3)",
      "prior_body": "Unallocated portfolio-layer cumulative basis adjustments"
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Long-Term Liquidity Measurement: Net Stable Funding Ratio (NSFR)",
      "prior_body": "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)."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Select Balance Sheet Items",
      "prior_body": "This section provides details of select liquidity-related assets and liabilities reported on Citigroup’s Consolidated Balance Sheet."
    },
    {
      "status": "REMOVED",
      "current_title": null,
      "prior_title": "Cash and Investments",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Third Line of Defense",
      "prior_title": "Third Line of Defense: Internal Audit",
      "similarity_score": 0.916,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"The Citi Chief Auditor has unrestricted access to the Board and the Board Audit Committee.\""
      ],
      "current_body": "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.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "A Deterioration in or Failure to Maintain Citi’s Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi.",
      "prior_title": "A Deterioration in or Failure to Maintain Citi’s Co-Branding or Private Label Credit Card Relationships Could Have a Negative Impact on Citi.",
      "similarity_score": 0.913,
      "confidence": "high",
      "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, 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 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 rights; 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.\"",
        "Reworded sentence: \"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 2025 resolution plan, which can be found on the FRB’s and FDIC’s websites) would remain operational outside of any resolution or insolvency proceedings.\"",
        "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 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 rights; or other factors, including bankruptcies, liquidations, restructurings, consolidations or other similar events, whether due to a challenging macroeconomic environment or otherwise.\""
      ],
      "current_body": "Citi has co-branding and private label relationships with various retailers and merchants through its Branded Cards and Retail Services credit card businesses, 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 constituted an aggregate of approximately 12% of Citi’s revenues in 2025 (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 rights; 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.Every two years, 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 2025 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 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 rights; 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).",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Enterprise Support Functions",
      "prior_title": "Enterprise Support Functions",
      "similarity_score": 0.91,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Organizations noted under the first line of defense may also contain enterprise support functions (e.g., the Controllers Group within Finance).\""
      ],
      "current_body": "Enterprise support functions engage in activities that support safety and soundness across Citi. These functions provide advisory services and/or design, implement, maintain and oversee Company-wide programs that support Citi in maintaining an effective control environment. Enterprise support functions are composed of Human Resources and Global Legal Affairs and Compliance (exclusive of ICRM, which is part of the second line of defense). Organizations noted under the first line of defense may also contain enterprise support functions (e.g., the Controllers Group within Finance). Enterprise support functions are subject to the relevant Company-wide independent oversight processes specific to the risks for which they are accountable (e.g., operational risk and compliance risk).",
      "prior_body": "Enterprise support functions engage in activities that support safety and soundness across Citi. These functions provide advisory services and/or design, implement, maintain and oversee Company-wide programs that support Citi in maintaining an effective control environment. Enterprise support functions are 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)."
    },
    {
      "status": "MODIFIED",
      "current_title": "ACLL for corporate loan losses as a percentage of total corporate loans—net of unearned income(6)",
      "prior_title": "ACLL for corporate loan losses as a percentage of total corporate loans—net of unearned income(6)",
      "similarity_score": 0.907,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"83 83 83 (1) North America includes the U.S., Canada and Puerto Rico.\"",
        "Reworded sentence: \"The difference between the domicile of the booking unit and the risk-based country view is not material for the purposes of classification of corporate loans between offices in North America and outside North America.\"",
        "Reworded sentence: \"(3) Consumer loans are net of unearned income of $971 million, $889 million, $802 million, $712 million and $629 million at December 31, 2025, 2024, 2023, 2022 and 2021, respectively.\"",
        "Reworded sentence: \"(5) Corporate loans include Mexico SBMM loans and are net of unearned income of $(1.1) billion, $(969) million, $(917) million, $(797) million and $(770) million at December 31, 2025, 2024, 2023, 2022 and 2021, respectively.\""
      ],
      "current_body": "83 83 83 (1) North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America. The classification of corporate loans between offices in North America and outside North America is based on the domicile of the booking unit. The difference between the domicile of the booking unit and the risk-based country view is not material for the purposes of classification of corporate loans between offices in North America and outside North America. (2) Loans secured primarily by real estate. (3) Consumer loans are net of unearned income of $971 million, $889 million, $802 million, $712 million and $629 million at December 31, 2025, 2024, 2023, 2022 and 2021, respectively. Unearned income on consumer loans primarily represents loan origination fees, net of certain direct origination costs, that are deferred and recognized as Interest income over the lives of the related loans, except for credit cards (see Note 5). (4) Installment and other includes loans to SPEs and TTS commercial cards. (5) Corporate loans include Mexico SBMM loans and are net of unearned income of $(1.1) billion, $(969) million, $(917) million, $(797) million and $(770) million at December 31, 2025, 2024, 2023, 2022 and 2021, respectively. Unearned income on corporate loans primarily represents loan origination fees, net of certain direct origination costs, that are deferred and recognized as Interest income over the lives of the related loans. (6) Because loans carried at fair value do not have an ACLL, they are excluded from the ACLL ratio calculation.",
      "prior_body": "86 86 86 (1) North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America. The classification of corporate loans between offices in North America and outside North America is based on the domicile of the booking unit. The difference between the domicile of the booking unit and the domicile of the managing unit is not material. (2) Loans secured primarily by real estate. (3) Consumer loans are net of unearned income of $889 million, $802 million, $712 million, $629 million and $692 million at December 31, 2024, 2023, 2022, 2021 and 2020, respectively. Unearned income on consumer loans primarily represents loan origination fees, net of certain direct origination costs, that are deferred and recognized as Interest income over the lives of the related loans. (4) Installment and other includes loans to SPEs and TTS commercial cards. (5) Corporate loans include Mexico SBMM loans and are net of unearned income of $(969) million, $(917) million, $(797) million, $(770) million and $(787) million at December 31, 2024, 2023, 2022, 2021 and 2020, respectively. Unearned income on corporate loans primarily represents loan origination fees, net of certain direct origination costs, that are deferred and recognized as Interest income over the lives of the related loans. (6) Because loans carried at fair value do not have an ACLL, they are excluded from the ACLL ratio calculation."
    },
    {
      "status": "MODIFIED",
      "current_title": "Total Loss-Absorbing Capacity (TLAC)",
      "prior_title": "Total Loss-Absorbing Capacity (TLAC)",
      "similarity_score": 0.899,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"GSIB, Citi is required to maintain minimum levels of TLAC and eligible LTD, each set by reference to the GSIB’s consolidated risk-weighted assets (RWA) and total leverage exposure.\"",
        "Reworded sentence: \"95 95 95 SECURED FUNDING TRANSACTIONS AND SHORT-TERM BORROWINGS Citi supplements its primary sources of funding with short-term financings that generally include:•secured funding transactions consisting of securities loaned or sold under agreements to repurchase, i.e., repos•short-term borrowings consisting of commercial paper issuances and borrowings from the FHLB and other market participants Secured Funding TransactionsSecured funding is primarily accessed through Citi’s broker-dealer subsidiaries, with a smaller portion executed through Citi’s bank entities to efficiently fund both (i) secured lending activity and (ii) a portion of the securities inventory held in the context of market making and customer activities.\"",
        "Reworded sentence: \"Generally, changes in the level of Citi’s secured funding are primarily due to fluctuations in secured lending activity in the matched book (as described below), and changes in securities inventory and eligible counterparty balance sheet netting.\"",
        "Reworded sentence: \"As of the quarter ended December 31, 2025, secured funding on an average basis was $385 billion.\"",
        "Reworded sentence: \"As indicated above, the remaining portion of secured funding is used to fund securities inventory held in the context of market making and customer activities.Short-Term BorrowingsSee Note 19 for further information on Citigroup’s and its affiliates’ outstanding short-term borrowings.\""
      ],
      "current_body": "As a U.S. GSIB, Citi is required to maintain minimum levels of TLAC and eligible LTD, each set by reference to the GSIB’s consolidated risk-weighted assets (RWA) and total leverage exposure. The intended purpose of the requirements is to facilitate the orderly resolution of U.S. GSIBs under the U.S. Bankruptcy Code and Title II of the Dodd-Frank Act. For additional information, including Citi’s TLAC and LTD amounts and ratios, see “Capital Resources—Current Regulatory Capital Standards” above. 95 95 95 SECURED FUNDING TRANSACTIONS AND SHORT-TERM BORROWINGS Citi supplements its primary sources of funding with short-term financings that generally include:•secured funding transactions consisting of securities loaned or sold under agreements to repurchase, i.e., repos•short-term borrowings consisting of commercial paper issuances and borrowings from the FHLB and other market participants Secured Funding TransactionsSecured funding is primarily accessed through Citi’s broker-dealer subsidiaries, with a smaller portion executed through Citi’s bank entities to efficiently fund both (i) secured lending activity and (ii) a portion of the securities inventory held in the context of market making and customer activities. Secured funding transactions are predominantly collateralized by government debt securities. Generally, changes in the level of Citi’s secured funding are primarily due to fluctuations in secured lending activity in the matched book (as described below), and changes in securities inventory and eligible counterparty balance sheet netting. In order to maintain reliable funding under a wide range of market conditions, Citi manages risks related to its secured funding by establishing secured funding limits and conducting daily stress tests that account for risks related to capacity, tenor, haircut, collateral type, counterparty and client actions. As of the quarter ended December 31, 2025, secured funding on an average basis was $385 billion. Forinformation about changes in Citi’s end-of-period securitiesloaned and sold under agreements to repurchase, see “Balance Sheet Overview” above.The portion of secured funding in the broker-dealer subsidiaries that funds secured lending is commonly referred to as “matched book” activity and is primarily secured by high-quality liquid securities such as U.S. Treasury securities, U.S. agency securities and foreign government debt securities. Other “matched book” activity is secured by less liquid securities, including equity securities, corporate bonds and asset-backed securities, the tenor of which is generally equal to or longer than the tenor of the corresponding assets. As indicated above, the remaining portion of secured funding is used to fund securities inventory held in the context of market making and customer activities.Short-Term BorrowingsSee Note 19 for further information on Citigroup’s and its affiliates’ outstanding short-term borrowings. SECURED FUNDING TRANSACTIONS AND SHORT-TERM BORROWINGS Citi supplements its primary sources of funding with short-term financings that generally include:•secured funding transactions consisting of securities loaned or sold under agreements to repurchase, i.e., repos•short-term borrowings consisting of commercial paper issuances and borrowings from the FHLB and other market participants Secured Funding TransactionsSecured funding is primarily accessed through Citi’s broker-dealer subsidiaries, with a smaller portion executed through Citi’s bank entities to efficiently fund both (i) secured lending activity and (ii) a portion of the securities inventory held in the context of market making and customer activities. Secured funding transactions are predominantly collateralized by government debt securities. Generally, changes in the level of Citi’s secured funding are primarily due to fluctuations in secured lending activity in the matched book (as described below), and changes in securities inventory and eligible counterparty balance sheet netting. In order to maintain reliable funding under a wide range of market conditions, Citi manages risks related to its secured funding by establishing secured funding limits and conducting daily stress tests that account for risks related to capacity, tenor, haircut, collateral type, counterparty and client actions. As of the quarter ended December 31, 2025, secured funding on an average basis was $385 billion. Forinformation about changes in Citi’s end-of-period securitiesloaned and sold under agreements to repurchase, see “Balance Sheet Overview” above.The portion of secured funding in the broker-dealer subsidiaries that funds secured lending is commonly referred to as “matched book” activity and is primarily secured by high-quality liquid securities such as U.S. Treasury securities, U.S. agency securities and foreign government debt securities. Other “matched book” activity is secured by less liquid securities, including equity securities, corporate bonds and asset-backed securities, the tenor of which is generally equal to or longer than the tenor of the corresponding assets. As indicated above, the remaining portion of secured funding is used to fund securities inventory held in the context of market making and customer activities.Short-Term BorrowingsSee Note 19 for further information on Citigroup’s and its affiliates’ outstanding short-term borrowings.",
      "prior_body": "U.S. GSIBs are required to maintain minimum levels of TLAC and eligible LTD, each set by reference to the GSIB’s consolidated risk-weighted assets (RWA) and total leverage exposure. The intended purpose of the requirements is to facilitate the orderly resolution of U.S. GSIBs under the U.S. Bankruptcy Code and Title II of the Dodd-Frank Act. For additional information, including Citi’s TLAC and LTD amounts and ratios, see “Capital Resources—Current Regulatory Capital Standards” above. 99 99 99 SECURED FUNDING TRANSACTIONS AND SHORT-TERM BORROWINGS Citi supplements its primary sources of funding with short-term financings that generally include (i) secured funding transactions consisting of securities loaned or sold under agreements to repurchase, i.e., repos, and (ii) to a lesser extent, short-term borrowings consisting of commercial paper issuances and borrowings from the FHLB and other market participants. Secured Funding TransactionsSecured funding is primarily accessed through Citi’s broker-dealer subsidiaries, with a smaller portion executed through Citi’s bank entities to efficiently fund both (i) secured lending activity and (ii) a portion of the securities inventory held in the context of market making and customer activities. Secured funding transactions are predominantly collateralized by government debt securities. Generally, changes in the level of Citi’s secured funding are primarily due to fluctuations in secured lending activity in the matched book (as described below) and changes in securities inventory. In order to maintain reliable funding under a wide range of market conditions, Citi manages risks related to its secured funding by establishing secured funding limits and conducting daily stress tests that account for risks related to capacity, tenor, haircut, collateral type, counterparty and client actions. Secured funding of $255 billion as of December 31, 2024 decreased 8% both year-over-year and sequentially, largely driven by lower financing to support trading-related assets within Citi’s broker-dealer subsidiaries. As of the quarter ended December 31, 2024, on an average basis, secured funding was $318 billion. The portion of secured funding in the broker-dealer subsidiaries that funds secured lending is commonly referred to as “matched book” activity and is primarily secured by high-quality liquid securities such as U.S. Treasury securities, U.S. agency securities and foreign government debt securities. Other “matched book” activity is secured by less liquid securities, including equity securities, corporate bonds and asset-backed securities, the tenor of which is generally equal to or longer than the tenor of the corresponding assets. As indicated above, the remaining portion of secured funding is used to fund securities inventory held in the context of market making and customer activities.Short-Term BorrowingsCiti’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). SECURED FUNDING TRANSACTIONS AND SHORT-TERM BORROWINGS Citi supplements its primary sources of funding with short-term financings that generally include (i) secured funding transactions consisting of securities loaned or sold under agreements to repurchase, i.e., repos, and (ii) to a lesser extent, short-term borrowings consisting of commercial paper issuances and borrowings from the FHLB and other market participants. Secured Funding TransactionsSecured funding is primarily accessed through Citi’s broker-dealer subsidiaries, with a smaller portion executed through Citi’s bank entities to efficiently fund both (i) secured lending activity and (ii) a portion of the securities inventory held in the context of market making and customer activities. Secured funding transactions are predominantly collateralized by government debt securities. Generally, changes in the level of Citi’s secured funding are primarily due to fluctuations in secured lending activity in the matched book (as described below) and changes in securities inventory. In order to maintain reliable funding under a wide range of market conditions, Citi manages risks related to its secured funding by establishing secured funding limits and conducting daily stress tests that account for risks related to capacity, tenor, haircut, collateral type, counterparty and client actions. Secured funding of $255 billion as of December 31, 2024 decreased 8% both year-over-year and sequentially, largely driven by lower financing to support trading-related assets within Citi’s broker-dealer subsidiaries. As of the quarter ended December 31, 2024, on an average basis, secured funding was $318 billion. The portion of secured funding in the broker-dealer subsidiaries that funds secured lending is commonly referred to as “matched book” activity and is primarily secured by high-quality liquid securities such as U.S. Treasury securities, U.S. agency securities and foreign government debt securities. Other “matched book” activity is secured by less liquid securities, including equity securities, corporate bonds and asset-backed securities, the tenor of which is generally equal to or longer than the tenor of the corresponding assets. As indicated above, the remaining portion of secured funding is used to fund securities inventory held in the context of market making and customer activities.Short-Term BorrowingsCiti’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)."
    },
    {
      "status": "MODIFIED",
      "current_title": "Interest Rate Risk of Investment Portfolios—Impact on AOCI",
      "prior_title": "Interest Rate Risk of Investment Portfolios—Impact",
      "similarity_score": 0.895,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"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.\"",
        "Added sentence: \"AOCI at risk is managed as part of the Company-wide interest rate risk position.\"",
        "Added 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.\"",
        "Reworded sentence: \"31, 2024Parallel interest rate shock +100 bpsInterest rate exposure(1)(2)U.S.\""
      ],
      "current_body": "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. 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, 2025Sep. 30, 2025Dec. 31, 2024Parallel interest rate shock +100 bpsInterest rate exposure(1)(2)U.S. dollar$(33)$(252)$(93)All other currencies1,402 1,529 1,068 Total net interest income$1,369 $1,277 $975 As a percentage of average interest-earning assets0.05 %0.05 %0.04 %Estimated initial negative impact to AOCI (after-tax)(2)$(2,597)$(2,381)$(1,111)Estimated initial impact on CET1 Capital ratio (bps) from AOCI scenario(3)(19)(18)(13)",
      "prior_body": "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)"
    },
    {
      "status": "MODIFIED",
      "current_title": "Funded exposure(1)(3)",
      "prior_title": "Funded exposure(1)",
      "similarity_score": 0.893,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Real estate(2) Other industries(4) Total(5) (1) Funded exposure excludes loans carried at fair value of $6.8 billion that are not subject to the ACLL.\"",
        "Reworded sentence: \"(4) Includes the impact of FX translation on the ACLL that is not allocated to individual industries.\"",
        "Reworded sentence: \"In addition, home equity loans are classified as non-accrual if the related residential first mortgage loan is 90 days or more past due.•With the exception of certain international portfolios, credit card loans are not included because, under industry standards, they accrue interest until such loans are charged off, which typically occurs at 180 days of contractual delinquency.\"",
        "Reworded sentence: \"The following summary provides a general description of non-accrual loans and assets:•Corporate and consumer (including commercial banking) non-accrual status is based on the determination that payment of interest or principal is doubtful.•A corporate loan may be classified as non-accrual and still be current on principal and interest payments under the terms of the loan structure.\"",
        "Reworded sentence: \"In addition, home equity loans are classified as non-accrual if the related residential first mortgage loan is 90 days or more past due.•With the exception of certain international portfolios, credit card loans are not included because, under industry standards, they accrue interest until such loans are charged off, which typically occurs at 180 days of contractual delinquency.\""
      ],
      "current_body": "Real estate(2) Other industries(4) Total(5) (1) Funded exposure excludes loans carried at fair value of $6.8 billion that are not subject to the ACLL. (2) As of December 31, 2025, the portion of the ACLL attributed to the total funded CRE exposure (including the Private Bank) was approximately 1.4%. (3) Includes $0.7 billion of funded exposure at December 31, 2025, primarily related to commercial credit card delinquency-managed loans. (4) Includes the impact of FX translation on the ACLL that is not allocated to individual industries. (5) As of December 31, 2025, the ACLL above reflects coverage of 0.3% of funded investment-grade exposure and 2.6% of funded non-investment-grade exposure. The following table details Citi’s corporate credit ACLL by industry exposure: December 31, 2024In millions of dollars, except percentagesFunded exposure(1)(3)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 Healthcare8,537 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(4)4,733 13 0.3 Total(5)$293,627 $2,556 0.9 % Funded exposure(1)(3) Real estate(2) Other industries(4) Total(5) (1) Funded exposure excludes loans carried at fair value of $7.8 billion that are not subject to the ACLL. (2) As of December 31, 2024, the portion of the ACLL attributed to the total funded CRE exposure (including the Private Bank) was approximately 1.6%. (3) Includes $0.6 billion of funded exposure at December 31, 2024, primarily related to commercial credit card delinquency-managed loans. (4) Includes the impact of FX translation on the ACLL that is not allocated to individual industries. (5) 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. 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 non-accrual loans and assets:•Corporate and consumer (including commercial banking) non-accrual status is based on the determination that payment of interest or principal is doubtful.•A corporate loan may be classified as non-accrual and still be 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, including borrowers who have enrolled in forbearance programs.•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.•With the exception of certain international portfolios, credit card loans are not included because, under industry standards, they 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 non-accrual loans and assets:•Corporate and consumer (including commercial banking) non-accrual status is based on the determination that payment of interest or principal is doubtful.•A corporate loan may be classified as non-accrual and still be 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, including borrowers who have enrolled in forbearance programs.•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.•With the exception of certain international portfolios, credit card loans are not included because, under industry standards, they accrue interest until such loans are charged off, which typically occurs at 180 days of contractual delinquency.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Citibank—Additional Potential Impacts",
      "prior_title": "Citibank—Additional Potential Impacts",
      "similarity_score": 0.888,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Citibank has provided liquidity commitments to consolidated asset-backed commercial paper (ABCP) conduits, primarily in the form of asset purchase agreements.\"",
        "Reworded sentence: \"For additional information on market risk and market risk management at Citi, see “Risk Factors” above.\"",
        "Reworded sentence: \"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.\"",
        "Reworded sentence: \"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, LTD, any related interest rate hedges and the funds transfer pricing of positions in total trading and credit portfolio value at risk (VaR).\"",
        "Reworded sentence: \"For additional information on market risk and market risk management at Citi, see “Risk Factors” above.\""
      ],
      "current_body": "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 (ABCP) conduits, primarily in the form of asset purchase agreements. As of December 31, 2025, Citibank had liquidity commitments of approximately $10.0 billion to ABCP conduits (compared to $15.0 billion at December 31, 2024) (see Note 23). 97 97 97 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 certain commitments to commercial paper conduits. In the event of the potential downgrades described above, Citi believes that certain corporate customers could reduce borrowing through these conduits, which would result in a reduced amount of ABCP issuance. 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 Treasury. 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.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, LTD, 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 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 certain commitments to commercial paper conduits. In the event of the potential downgrades described above, Citi believes that certain corporate customers could reduce borrowing through these conduits, which would result in a reduced amount of ABCP issuance. 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. 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 certain commitments to commercial paper conduits. In the event of the potential downgrades described above, Citi believes that certain corporate customers could reduce borrowing through these conduits, which would result in a reduced amount of ABCP issuance.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "A Ratings Downgrade Could Adversely Impact Citi’s Funding and Liquidity.",
      "prior_title": "A Ratings Downgrade Could Adversely Impact Citi’s Funding and Liquidity.",
      "similarity_score": 0.886,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"A ratings downgrade could result from, among other factors, declines in profitability, reductions in regulatory capitalization levels, deterioration in Citi’s funding structure or liquidity, significant increases in risk appetite, delays or missteps in Citi’s transformation efforts, public statements by Citi’s management or regulators or control failures.\"",
        "Reworded sentence: \"In addition, a ratings downgrade could have a negative impact on other funding sources such as secured 59 59 59 financing and other margined transactions for which there may be no explicit triggers.\"",
        "Reworded sentence: \"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.COMPLIANCE RISKSRegulatory Expectations and Scrutiny in the U.S.\"",
        "Reworded sentence: \"regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and “Capital Resources” above); and (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.\"",
        "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 remedy deficiencies on a timely basis (see also the capital return and resolution plan risk factors above).\""
      ],
      "current_body": "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, declines in profitability, reductions in regulatory capitalization levels, deterioration in Citi’s funding structure or liquidity, significant increases in risk appetite, delays or missteps in Citi’s transformation efforts, public statements by Citi’s management or regulators or control failures. A ratings downgrade 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 59 59 59 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.COMPLIANCE RISKSRegulatory Expectations and Scrutiny in the U.S. and Globally as well as Ongoing Interpretation and Implementation of Regulatory and Legislative Requirements and Changes Subject Citi to Significant Compliance, Regulatory and Other Risks and Costs.Large financial institutions, such as Citi, face significant regulatory and supervisory expectations and scrutiny in the U.S. and globally, including with respect to, among other things, 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 anti-money laundering; increasingly complex sanctions regimes; customer and client protection; market practices; and various disclosure and regulatory reporting requirements. Citi is also continually required to interpret and implement extensive and frequently changing regulatory and legislative requirements within the U.S. and in 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 regulatory requirements or expectations, 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); and (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. Citi Is Subject to Extensive Legal and Regulatory Proceedings, Examinations, Investigations, Consent Orders and Related Compliance Efforts and Other Inquiries That Have in the Past and Could in the Future 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 remedy deficiencies on a timely basis (see also the capital return and resolution plan risk factors above). Under U.S. banking law, Citi is prohibited from disclosing confidential supervisory information, and may therefore be unable to disclose even potentially material regulatory or supervisory matters. 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 require continued significant investments by Citi during 2026 and beyond, as an essential part of Citi’s broader transformation efforts (see the simplification, transformation and enhanced business performance priorities risk factor above). Further, in 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 FRB found that Citigroup 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.COMPLIANCE RISKSRegulatory Expectations and Scrutiny in the U.S. and Globally as well as Ongoing Interpretation and Implementation of Regulatory and Legislative Requirements and Changes Subject Citi to Significant Compliance, Regulatory and Other Risks and Costs.Large financial institutions, such as Citi, face significant regulatory and supervisory expectations and scrutiny in the U.S. and globally, including with respect to, among other things, 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 anti-money laundering; increasingly complex sanctions regimes; customer and client protection; market practices; and various disclosure and regulatory reporting requirements. Citi is also continually required to interpret and implement extensive and frequently changing regulatory and legislative requirements within the U.S. and in 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 regulatory requirements or expectations, 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 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.",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "A Disruption or Failure of Citi’s Operational Processes or Systems Could Negatively Impact Its Reputation, Customers, Clients, Businesses or Results of Operations and Financial Condition.",
      "prior_title": "A 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.",
      "similarity_score": 0.883,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"With the proliferation of emerging technologies, including AI and digital assets, 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.\"",
        "Reworded sentence: \"These include, among others, operational or execution failures or deficiencies by third parties that provide products or services to Citi (e.g., cloud service providers), including such third parties’ downstream service providers, as well as other Citi counterparties and market participants, which could be exacerbated by the concentration of third-party providers across the financial services industry; deficiencies in processes or controls; inadequate management of data governance practices, data controls and monitoring mechanisms that may adversely impact internal or external reporting and decision-making; cyber or information security incidents (see the cybersecurity risk factor below); human error, such as manual transaction processing errors (e.g., erroneous payments to lenders or manual errors by traders that cause system and market disruptions or losses), which can be exacerbated by staffing challenges and processing backlogs; fraud or malice on the part of employees or third parties; insufficient (or limited) straight-through processing between legacy or bespoke systems and any failure to design and effectively operate controls that mitigate operational risks associated with those legacy or bespoke systems, leading to potential risk of errors and operating losses; accidental system or technological failure; electrical or telecommunication outages; failures of or cyber incidents involving computer servers or infrastructure, including software updates and cloud services; or other similar losses or damage to Citi’s property or assets (see also the climate change risk factor above).\"",
        "Reworded sentence: \"Irrespective of the sophistication of the technology utilized by Citi, there will always be a risk of human and other errors.\"",
        "Reworded sentence: \"Operational incidents could result in financial losses and other costs as well as misappropriation, corruption or loss of confidential and other information or assets, which could significantly negatively impact Citi’s reputation, customers, clients, employees, businesses or results of operations and financial condition, or the potential for systemic disruption due to interconnected systems and dependencies.\"",
        "Reworded sentence: \"Irrespective of the sophistication of the technology utilized by Citi, there will always be a risk of human and other errors.\""
      ],
      "current_body": "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. With the proliferation of emerging technologies, including AI and digital assets, 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. For example, Citi’s involvement in digital assets, including custody, asset tokenization and facilitation of clients’ digital assets activities, exposes Citi to increased operational risks due to the unique technological requirements for securing these assets. 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 that provide products or services to Citi (e.g., cloud service providers), including such third parties’ downstream service providers, as well as other Citi counterparties and market participants, which could be exacerbated by the concentration of third-party providers across the financial services industry; deficiencies in processes or controls; inadequate management of data governance practices, data controls and monitoring mechanisms that may adversely impact internal or external reporting and decision-making; cyber or information security incidents (see the cybersecurity risk factor below); human error, such as manual transaction processing errors (e.g., erroneous payments to lenders or manual errors by traders that cause system and market disruptions or losses), which can be exacerbated by staffing challenges and processing backlogs; fraud or malice on the part of employees or third parties; insufficient (or limited) straight-through processing between legacy or bespoke systems and any failure to design and effectively operate controls that mitigate operational risks associated with those legacy or bespoke systems, leading to potential risk of errors and operating losses; accidental system or technological failure; electrical or telecommunication outages; failures of or cyber incidents involving computer servers or infrastructure, including software updates and cloud services; or other similar losses or damage to Citi’s property or assets (see also the climate change risk factor above). Additionally, Citi’s ability to effectively maintain and upgrade systems and infrastructure can become more challenging as the speed, frequency, volume, interconnectivity and complexity of transactions continue to increase.For example, operational incidents can arise due to failures by third parties with which Citi does business, such as failures by internet, mobile technology and cloud service providers or other vendors to adequately follow procedures or processes, safeguard their systems or prevent system disruptions or cyberattacks. Failure by Citi to develop, implement and operate a third-party risk management program commensurate with the level of risk, complexity and nature of its third-party relationships can also result in operational incidents. In addition, Citi has experienced and could experience further losses associated with manual transaction processing errors, including erroneous payments to lenders or manual errors by Citi traders that cause system and market disruptions and losses for Citi and its clients. Irrespective of the sophistication of the technology utilized by Citi, there will always be a risk of human and other errors. In view of the large transactions in which Citi engages, such errors have in the past resulted, and could result, in significant losses. While Citi has change management processes in place to appropriately upgrade its operational processes and systems to ensure that any changes introduced do not adversely impact security and operational continuity, such change management can fail or be ineffective. Furthermore, when Citi introduces new products, systems or processes, new operational risks that may arise from those changes may not be identified, or adequate controls to mitigate the identified risks may not be appropriately implemented or operate as designed. Incidents that impact information security, technology operations or other operational processes may cause disruptions and/or malfunctions within Citi’s businesses (e.g., the temporary loss of availability of Citi’s online banking system or mobile banking platform), as well as the operations of its clients, customers or other third parties. In addition, operational incidents could involve the failure or ineffectiveness of internal processes or controls. Given Citi’s global footprint and the high volume of transactions processed by Citi, certain failures, errors or actions may be repeated or compounded before they are discovered and rectified, which would further increase the consequences and costs. Operational incidents could result in financial losses and other costs as well as misappropriation, corruption or loss of confidential and other information or assets, which could significantly negatively impact Citi’s reputation, customers, clients, employees, businesses or results of operations and financial condition, or the potential for systemic disruption due to interconnected systems and dependencies. Additionally, any unavailability or failure of backup systems could impact business continuity in the event of an operational incident. Cyber-related and other operational incidents can also result in legal and regulatory actions or proceedings, fines and other costs (see the legal and regulatory proceedings risk factor below).Failure by Citi to continue to increase its operational resilience, and ensure that important business services and their impact tolerance time and severity scales are clearly defined, could expose Citi to service disruptions, leading to can become more challenging as the speed, frequency, volume, interconnectivity and complexity of transactions continue to increase. For example, operational incidents can arise due to failures by third parties with which Citi does business, such as failures by internet, mobile technology and cloud service providers or other vendors to adequately follow procedures or processes, safeguard their systems or prevent system disruptions or cyberattacks. Failure by Citi to develop, implement and operate a third-party risk management program commensurate with the level of risk, complexity and nature of its third-party relationships can also result in operational incidents. In addition, Citi has experienced and could experience further losses associated with manual transaction processing errors, including erroneous payments to lenders or manual errors by Citi traders that cause system and market disruptions and losses for Citi and its clients. Irrespective of the sophistication of the technology utilized by Citi, there will always be a risk of human and other errors. In view of the large transactions in which Citi engages, such errors have in the past resulted, and could result, in significant losses. While Citi has change management processes in place to appropriately upgrade its operational processes and systems to ensure that any changes introduced do not adversely impact security and operational continuity, such change management can fail or be ineffective. Furthermore, when Citi introduces new products, systems or processes, new operational risks that may arise from those changes may not be identified, or adequate controls to mitigate the identified risks may not be appropriately implemented or operate as designed. Incidents that impact information security, technology operations or other operational processes may cause disruptions and/or malfunctions within Citi’s businesses (e.g., the temporary loss of availability of Citi’s online banking system or mobile banking platform), as well as the operations of its clients, customers or other third parties. In addition, operational incidents could involve the failure or ineffectiveness of internal processes or controls. Given Citi’s global footprint and the high volume of transactions processed by Citi, certain failures, errors or actions may be repeated or compounded before they are discovered and rectified, which would further increase the consequences and costs. Operational incidents could result in financial losses and other costs as well as misappropriation, corruption or loss of confidential and other information or assets, which could significantly negatively impact Citi’s reputation, customers, clients, employees, businesses or results of operations and financial condition, or the potential for systemic disruption due to interconnected systems and dependencies. Additionally, any unavailability or failure of backup systems could impact business continuity in the event of an operational incident. Cyber-related and other operational incidents can also result in legal and regulatory actions or proceedings, fines and other costs (see the legal and regulatory proceedings risk factor below). Failure by Citi to continue to increase its operational resilience, and ensure that important business services and their impact tolerance time and severity scales are clearly defined, could expose Citi to service disruptions, leading to 55 55 55 harms to Citi clients, market integrity, Citi’s reputation, financial stability or safety and soundness. For information on Citi’s management of operational risk, see “Managing Global Risk—Operational Risk” below.Citi’s and Third Parties’ Computer Systems and Networks Continue to Be Susceptible to an Increasing Risk of Evolving, Sophisticated Cybersecurity Incidents That Could Result in the Theft, Loss, Non-Availability, Alteration, Misuse or Disclosure of Confidential Information, Damage to Citi’s Reputation, Regulatory Penalties, Legal Exposure and Financial Losses. Citi’s computer systems, software and networks are subject to ongoing attempted cyberattacks, as attempts to effectuate unauthorized access to, theft or destruction of data (including confidential client information), account takeovers, and disruptions of service, using techniques including phishing, malware, ransomware, computer viruses or other malicious code, exploitation of vulnerabilities, and others. These threats can arise from external parties, including cyber criminals, cyber terrorists, hacktivists and nation-state actors, as well as insiders who knowingly or unknowingly engage in or enable malicious cyber activities. For example, nation-state actors have recently targeted critical U.S. infrastructure with cyberattacks. Some cyber and information security incidents may also occur as a result of unintentional conduct on the part of employees, customers or suppliers.Citi develops its own software and relies on third-party applications and software, which are susceptible to vulnerability exploitations. Software leveraged in financial services and other industries continues to be impacted by an increasing number of zero-day vulnerabilities, thus increasing inherent cyber risk to Citi. The increasing use of cloud and new and emerging technologies (such as AI and digital assets), as well as connectivity solutions to facilitate remote working for Citi’s employees, all increase Citi’s exposure to cybersecurity risks. Citi is also susceptible to cyberattacks given, among other factors, its size and scale, high-profile brand, global footprint and prominent role in the financial system. Additionally, Citi continues to operate in multiple jurisdictions in the midst of geopolitical unrest or uncertainties, including, among others, those affected by the Russia–Ukraine war and the conflicts in the Middle East, which could expose Citi to heightened risk of insider threat, cyber threats from nation-state actors, hacktivism or other cyber incidents. Citi continues to experience increased exposure to cyberattacks through third parties. Third parties with which Citi does business, as well as retailers and other third parties with which Citi’s customers do business, and any such third parties’ downstream service providers, also pose cybersecurity risks, particularly where activities of customers are beyond Citi’s security and control systems. For example, Citi outsources certain functions, such as processing customer credit card transactions, uploading content on customer-facing websites and developing software for new products and services. These relationships allow for the storage and processing of customer information by third-party hosting of, or access to, Citi websites. This could lead to compromise or the potential to introduce vulnerable or malicious code, resulting in security breaches or business disruptions impacting Citi customers, employees or operations. While many of Citi’s agreements with third parties include indemnification provisions, Citi may not be able to recover sufficiently under these provisions, or at all, to adequately offset any losses and other adverse impacts Citi may incur from third-party cyber incidents. Citi and some of its third-party partners have been subjected to attempted and sometimes successful cyberattacks over the last several years, including the following:•denial of service attacks, which attempt to interrupt service to clients and customers•hacking and malicious software installations intended to gain unauthorized access to information systems or to disrupt those systems and/or impact availability or privacy of confidential data, with objectives including, but not limited to, extortion payments or causing reputational damage•data breaches due to unauthorized access to customer accounts or other data•malicious software attacks on client systems, in attempts to gain unauthorized access to Citi systems or client data under the guise of normal client transactions While Citi’s cyber and information security program has historically generally succeeded in detecting, thwarting and/or responding to attacks targeting its systems before they become significant, certain past incidents resulted in limited losses, as well as increases in expenditures to monitor against the threat of similar future cyber incidents. There can be no assurance that such cyber incidents will not occur again, and they could occur more frequently, via novel tactics, including leveraging of tools made possible by emerging technologies, and on a more significant scale. Because the techniques used to initiate cyberattacks change frequently or, in some cases, are not recognized until deployed, Citi may be unable to implement effective preventive measures or otherwise proactively address these risks. In addition, cyber threats and cyberattack techniques change, develop and evolve rapidly, including from emerging technologies such as AI and quantum computing. Given the frequency and sophistication of cyberattacks, the determination of the severity and potential impact of a cyber incident may not become apparent for a substantial period of time following detection of the incident. Also, while Citi strives to implement measures to reduce the exposure resulting from outsourcing risks, such as performing security control assessments of third-party vendors and limiting third-party access to the least privileged level necessary to perform service functions, these measures cannot prevent all third-party-related cyberattacks or data breaches. Cyber incidents can result in the disclosure of personal, confidential or proprietary customer, client or employee information; damage to Citi’s reputation with its clients, other counterparties and the market; customer dissatisfaction; and additional costs to Citi, including expenses such as repairing or replacing systems, replacing customer payment cards, credit monitoring or adding new personnel or protection technologies. Cyber incidents can also result in regulatory harms to Citi clients, market integrity, Citi’s reputation, financial stability or safety and soundness. For information on Citi’s management of operational risk, see “Managing Global Risk—Operational Risk” below.Citi’s and Third Parties’ Computer Systems and Networks Continue to Be Susceptible to an Increasing Risk of Evolving, Sophisticated Cybersecurity Incidents That Could Result in the Theft, Loss, Non-Availability, Alteration, Misuse or Disclosure of Confidential Information, Damage to Citi’s Reputation, Regulatory Penalties, Legal Exposure and Financial Losses. Citi’s computer systems, software and networks are subject to ongoing attempted cyberattacks, as attempts to effectuate unauthorized access to, theft or destruction of data (including confidential client information), account takeovers, and disruptions of service, using techniques including phishing, malware, ransomware, computer viruses or other malicious code, exploitation of vulnerabilities, and others. These threats can arise from external parties, including cyber criminals, cyber terrorists, hacktivists and nation-state actors, as well as insiders who knowingly or unknowingly engage in or enable malicious cyber activities. For example, nation-state actors have recently targeted critical U.S. infrastructure with cyberattacks. Some cyber and information security incidents may also occur as a result of unintentional conduct on the part of employees, customers or suppliers.Citi develops its own software and relies on third-party applications and software, which are susceptible to vulnerability exploitations. Software leveraged in financial services and other industries continues to be impacted by an increasing number of zero-day vulnerabilities, thus increasing inherent cyber risk to Citi. The increasing use of cloud and new and emerging technologies (such as AI and digital assets), as well as connectivity solutions to facilitate remote working for Citi’s employees, all increase Citi’s exposure to cybersecurity risks. Citi is also susceptible to cyberattacks given, among other factors, its size and scale, high-profile brand, global footprint and prominent role in the financial system. Additionally, Citi continues to operate in multiple jurisdictions in the midst of geopolitical unrest or uncertainties, including, among others, those affected by the Russia–Ukraine war and the conflicts in the Middle East, which could expose Citi to heightened risk of insider threat, cyber threats from nation-state actors, hacktivism or other cyber incidents. Citi continues to experience increased exposure to cyberattacks through third parties. Third parties with which Citi does business, as well as retailers and other third parties with which Citi’s customers do business, and any such third parties’ downstream service providers, also pose cybersecurity risks, particularly where activities of customers are beyond Citi’s security and control systems. For example, Citi outsources certain functions, such as processing customer credit card transactions, uploading content on customer-facing websites and developing software for new products and services. These relationships allow for the storage and processing of customer information by third-party hosting of, or access to, Citi websites. This could lead to compromise or the potential to introduce vulnerable or malicious code, harms to Citi clients, market integrity, Citi’s reputation, financial stability or safety and soundness. For information on Citi’s management of operational risk, see “Managing Global Risk—Operational Risk” below.",
      "prior_body": "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 56 56 56 providers), including such third parties’ downstream service providers, other market participants or those that otherwise have an ongoing partnership or business relationship with Citi; deficiencies in processes or controls; inadequate management of data governance practices, data controls and monitoring mechanisms that may adversely impact internal or external reporting and decision-making; cyber or information security incidents (see the cybersecurity risk factor below); human error, such as manual transaction processing errors (e.g., erroneous payments to lenders or manual errors by traders that cause system and market disruptions or losses), which can be exacerbated by staffing challenges and processing backlogs; fraud or malice on the part of employees or third parties; insufficient (or limited) straight-through processing between legacy or bespoke systems and any failure to design and effectively operate controls that mitigate operational risks associated with those legacy or bespoke systems, leading to potential risk of errors and operating losses; accidental system or technological failure; electrical or telecommunication outages; failures of or cyber incidents involving computer servers or infrastructure, including software updates and cloud services; or other similar losses or damage to Citi’s property or assets (see also the climate change risk factor above). Additionally, Citi’s ability to effectively maintain and upgrade systems and infrastructure can become more challenging as the speed, frequency, volume, interconnectivity and complexity of transactions continue to increase.For example, operational incidents can arise due to failures by third parties with which Citi does business, such as failures by internet, mobile technology and cloud service providers or other vendors to adequately follow procedures or processes, safeguard their systems or prevent system disruptions or cyberattacks. Failure by Citi to develop, implement and operate a third-party risk management program commensurate with the level of risk, complexity and nature of its third-party relationships can also result in operational incidents. In addition, Citi has experienced and could experience further losses associated with manual transaction processing errors, including erroneous payments to lenders or manual errors by Citi traders that cause system and market disruptions and losses for Citi and its clients. Irrespective of the sophistication of the technology utilized by Citi, there will always be some room for human and other errors. In view of the large transactions in which Citi engages, such errors have in the past resulted, and could result, in significant losses. While Citi has change management processes in place to appropriately upgrade its operational processes and systems to ensure that any changes introduced do not adversely impact security and operational continuity, such change management can fail or be ineffective. Furthermore, when Citi introduces new products, systems or processes, new operational risks that may arise from those changes may not be identified, or adequate controls to mitigate the identified risks may not be appropriately implemented or operate as designed. Incidents that impact information security, technology operations or other operational processes may cause disruptions and/or malfunctions within Citi’s businesses (e.g., the temporary loss of availability of Citi’s online banking system or mobile banking platform), as well as the operations of its clients, customers or other third parties. In addition, operational incidents could involve the failure or ineffectiveness of internal processes or controls. Given Citi’s global footprint and the high volume of transactions processed by Citi, certain failures, errors or actions may be repeated or compounded before they are discovered and rectified, which would further increase the consequences and costs. Operational incidents could result in financial losses and other costs as well as misappropriation, corruption or loss of confidential and other information or assets, which could significantly negatively impact Citi’s reputation, customers, clients, businesses or results of operations and financial condition. Cyber-related and other operational incidents can also result in legal and regulatory actions or proceedings, fines and other costs (see the legal and regulatory proceedings risk factor below). Citi will need to continue to increase its operational resilience, ensuring important business services and their impact tolerance time and severity scales are clearly defined. Failure to do so could expose Citi to service disruptions identified through scenario testing, leading to harms to Citi clients, market integrity, financial stability or Citi safety and soundness.For information on Citi’s management of operational risk, see “Managing Global Risk—Operational Risk” below.Citi’s and Third Parties’ Computer Systems and Networks Will Continue to Be Susceptible to an Increasing Risk of Continually Evolving, Sophisticated Cybersecurity Incidents That Could Result in the Theft, Loss, Non-Availability, Misuse or Disclosure of Confidential Client or Customer Information, Damage to Citi’s Reputation, Additional Costs to Citi, Regulatory Penalties, Legal Exposure and Financial Losses. Citi’s computer systems, software and networks are subject to ongoing attempted cyberattacks, such as unauthorized access, loss or destruction of data (including confidential client information), account takeovers, disruptions of service, phishing, malware, ransomware, computer viruses or other malicious code and other similar events. These threats can arise from external parties, including cyber criminals, cyber terrorists, hacktivists (individuals or groups using cyberattacks to promote a political or social agenda) and nation-state actors, as well as insiders who knowingly or unknowingly engage in or enable malicious cyber activities. For example, nation-state actors have recently targeted critical U.S. infrastructure with cyberattacks.Citi develops its own software and relies on third-party applications and software, which are susceptible to vulnerability exploitations. Software leveraged in financial services and other industries continues to be impacted by an increasing number of zero-day vulnerabilities, thus increasing inherent cyber risk to Citi. The increasing use of mobile and other digital banking platforms and services, cloud technologies, new and emerging technologies (such as AI) and connectivity solutions to facilitate remote working for Citi’s employees all increase Citi’s exposure to cybersecurity risks. Citi is also susceptible to cyberattacks given, among other things, its size and scale, high-profile brand, global footprint and prominent role in the financial system, as well as the ongoing wind-down of its providers), including such third parties’ downstream service providers, other market participants or those that otherwise have an ongoing partnership or business relationship with Citi; deficiencies in processes or controls; inadequate management of data governance practices, data controls and monitoring mechanisms that may adversely impact internal or external reporting and decision-making; cyber or information security incidents (see the cybersecurity risk factor below); human error, such as manual transaction processing errors (e.g., erroneous payments to lenders or manual errors by traders that cause system and market disruptions or losses), which can be exacerbated by staffing challenges and processing backlogs; fraud or malice on the part of employees or third parties; insufficient (or limited) straight-through processing between legacy or bespoke systems and any failure to design and effectively operate controls that mitigate operational risks associated with those legacy or bespoke systems, leading to potential risk of errors and operating losses; accidental system or technological failure; electrical or telecommunication outages; failures of or cyber incidents involving computer servers or infrastructure, including software updates and cloud services; or other similar losses or damage to Citi’s property or assets (see also the climate change risk factor above). Additionally, Citi’s ability to effectively maintain and upgrade systems and infrastructure can become more challenging as the speed, frequency, volume, interconnectivity and complexity of transactions continue to increase.For example, operational incidents can arise due to failures by third parties with which Citi does business, such as failures by internet, mobile technology and cloud service providers or other vendors to adequately follow procedures or processes, safeguard their systems or prevent system disruptions or cyberattacks. Failure by Citi to develop, implement and operate a third-party risk management program commensurate with the level of risk, complexity and nature of its third-party relationships can also result in operational incidents. In addition, Citi has experienced and could experience further losses associated with manual transaction processing errors, including erroneous payments to lenders or manual errors by Citi traders that cause system and market disruptions and losses for Citi and its clients. Irrespective of the sophistication of the technology utilized by Citi, there will always be some room for human and other errors. In view of the large transactions in which Citi engages, such errors have in the past resulted, and could result, in significant losses. While Citi has change management processes in place to appropriately upgrade its operational processes and systems to ensure that any changes introduced do not adversely impact security and operational continuity, such change management can fail or be ineffective. Furthermore, when Citi introduces new products, systems or processes, new operational risks that may arise from those changes may not be identified, or adequate controls to mitigate the identified risks may not be appropriately implemented or operate as designed. Incidents that impact information security, technology operations or other operational processes may cause disruptions and/or malfunctions within Citi’s businesses (e.g., the temporary loss of availability of Citi’s online banking system or mobile banking platform), as well as the operations of its clients, customers or other third parties. In addition, providers), including such third parties’ downstream service providers, other market participants or those that otherwise have an ongoing partnership or business relationship with Citi; deficiencies in processes or controls; inadequate management of data governance practices, data controls and monitoring mechanisms that may adversely impact internal or external reporting and decision-making; cyber or information security incidents (see the cybersecurity risk factor below); human error, such as manual transaction processing errors (e.g., erroneous payments to lenders or manual errors by traders that cause system and market disruptions or losses), which can be exacerbated by staffing challenges and processing backlogs; fraud or malice on the part of employees or third parties; insufficient (or limited) straight-through processing between legacy or bespoke systems and any failure to design and effectively operate controls that mitigate operational risks associated with those legacy or bespoke systems, leading to potential risk of errors and operating losses; accidental system or technological failure; electrical or telecommunication outages; failures of or cyber incidents involving computer servers or infrastructure, including software updates and cloud services; or other similar losses or damage to Citi’s property or assets (see also the climate change risk factor above). Additionally, Citi’s ability to effectively maintain and upgrade systems and infrastructure can become more challenging as the speed, frequency, volume, interconnectivity and complexity of transactions continue to increase. For example, operational incidents can arise due to failures by third parties with which Citi does business, such as failures by internet, mobile technology and cloud service providers or other vendors to adequately follow procedures or processes, safeguard their systems or prevent system disruptions or cyberattacks. Failure by Citi to develop, implement and operate a third-party risk management program commensurate with the level of risk, complexity and nature of its third-party relationships can also result in operational incidents. In addition, Citi has experienced and could experience further losses associated with manual transaction processing errors, including erroneous payments to lenders or manual errors by Citi traders that cause system and market disruptions and losses for Citi and its clients. Irrespective of the sophistication of the technology utilized by Citi, there will always be some room for human and other errors. In view of the large transactions in which Citi engages, such errors have in the past resulted, and could result, in significant losses. While Citi has change management processes in place to appropriately upgrade its operational processes and systems to ensure that any changes introduced do not adversely impact security and operational continuity, such change management can fail or be ineffective. Furthermore, when Citi introduces new products, systems or processes, new operational risks that may arise from those changes may not be identified, or adequate controls to mitigate the identified risks may not be appropriately implemented or operate as designed. Incidents that impact information security, technology operations or other operational processes may cause disruptions and/or malfunctions within Citi’s businesses (e.g., the temporary loss of availability of Citi’s online banking system or mobile banking platform), as well as the operations of its clients, customers or other third parties. In addition, operational incidents could involve the failure or ineffectiveness of internal processes or controls. Given Citi’s global footprint and the high volume of transactions processed by Citi, certain failures, errors or actions may be repeated or compounded before they are discovered and rectified, which would further increase the consequences and costs. Operational incidents could result in financial losses and other costs as well as misappropriation, corruption or loss of confidential and other information or assets, which could significantly negatively impact Citi’s reputation, customers, clients, businesses or results of operations and financial condition. Cyber-related and other operational incidents can also result in legal and regulatory actions or proceedings, fines and other costs (see the legal and regulatory proceedings risk factor below). Citi will need to continue to increase its operational resilience, ensuring important business services and their impact tolerance time and severity scales are clearly defined. Failure to do so could expose Citi to service disruptions identified through scenario testing, leading to harms to Citi clients, market integrity, financial stability or Citi safety and soundness.For information on Citi’s management of operational risk, see “Managing Global Risk—Operational Risk” below.Citi’s and Third Parties’ Computer Systems and Networks Will Continue to Be Susceptible to an Increasing Risk of Continually Evolving, Sophisticated Cybersecurity Incidents That Could Result in the Theft, Loss, Non-Availability, Misuse or Disclosure of Confidential Client or Customer Information, Damage to Citi’s Reputation, Additional Costs to Citi, Regulatory Penalties, Legal Exposure and Financial Losses. Citi’s computer systems, software and networks are subject to ongoing attempted cyberattacks, such as unauthorized access, loss or destruction of data (including confidential client information), account takeovers, disruptions of service, phishing, malware, ransomware, computer viruses or other malicious code and other similar events. These threats can arise from external parties, including cyber criminals, cyber terrorists, hacktivists (individuals or groups using cyberattacks to promote a political or social agenda) and nation-state actors, as well as insiders who knowingly or unknowingly engage in or enable malicious cyber activities. For example, nation-state actors have recently targeted critical U.S. infrastructure with cyberattacks.Citi develops its own software and relies on third-party applications and software, which are susceptible to vulnerability exploitations. Software leveraged in financial services and other industries continues to be impacted by an increasing number of zero-day vulnerabilities, thus increasing inherent cyber risk to Citi. The increasing use of mobile and other digital banking platforms and services, cloud technologies, new and emerging technologies (such as AI) and connectivity solutions to facilitate remote working for Citi’s employees all increase Citi’s exposure to cybersecurity risks. Citi is also susceptible to cyberattacks given, among other things, its size and scale, high-profile brand, global footprint and prominent role in the financial system, as well as the ongoing wind-down of its operational incidents could involve the failure or ineffectiveness of internal processes or controls. Given Citi’s global footprint and the high volume of transactions processed by Citi, certain failures, errors or actions may be repeated or compounded before they are discovered and rectified, which would further increase the consequences and costs. Operational incidents could result in financial losses and other costs as well as misappropriation, corruption or loss of confidential and other information or assets, which could significantly negatively impact Citi’s reputation, customers, clients, businesses or results of operations and financial condition. Cyber-related and other operational incidents can also result in legal and regulatory actions or proceedings, fines and other costs (see the legal and regulatory proceedings risk factor below). Citi will need to continue to increase its operational resilience, ensuring important business services and their impact tolerance time and severity scales are clearly defined. Failure to do so could expose Citi to service disruptions identified through scenario testing, leading to harms to Citi clients, market integrity, financial stability or Citi safety and soundness. For information on Citi’s management of operational risk, see “Managing Global Risk—Operational Risk” below."
    },
    {
      "status": "MODIFIED",
      "current_title": "If Citi’s Risk Management and Other Processes or Strategies Are Deficient or Ineffective, Citi May Incur Significant Losses and Its Regulatory Capital and Capital Ratios Could Be Negatively Impacted.",
      "prior_title": "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.",
      "similarity_score": 0.878,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"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.\"",
        "Reworded sentence: \"These changes can impact Citi’s capital ratios and its ability to meet its regulatory capital requirements.\"",
        "Reworded sentence: \"and various countries and jurisdictions globally, including:•end-of-period consumer loans of $409 billion•end-of-period corporate loans of $344 billion at December 31, 2025A default by or a significant downgrade in the credit ratings of a consumer or corporate borrower or other counterparty, or a decline in the credit quality or value of any underlying collateral, exposes Citi to credit risk.\"",
        "Reworded 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” belowand Notes 15 and 16.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.\""
      ],
      "current_body": "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. Citi also relies on data to assess and manage various risk exposures. Unexpected losses can result from untimely, inaccurate or incomplete risk management processes and data. In addition, Citi’s risk management and other processes and strategies, including 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, receive negative regulatory evaluation or examination findings or be subject 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 regulatory scrutiny and changes and the legal and regulatory proceedings risk factors below). Such deficiencies or ineffectiveness could also result in inaccurate financial, regulatory or risk reporting. Moreover, Citi’s Basel III regulatory capital models, including its credit, market and operational risk models, are subject to ongoing regulatory review and approval, which may result in refinements, modifications or enhancements (required or otherwise) to these models. Modifications or requirements resulting from these ongoing reviews, as well as any future changes or guidance provided by the U.S. banking regulators regarding the U.S. regulatory capital framework applicable to Citi, including, but not limited to, potential revisions to the U.S. Basel III rules (see the capital return risk factor and “Capital Resources—Regulatory Capital Standards and Developments” above), have resulted, and could continue to result, in significant changes to Citi’s risk-weighted assets. These changes can impact Citi’s capital ratios and its ability to meet its regulatory capital requirements. CREDIT RISKSCredit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses.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 $409 billion•end-of-period corporate loans of $344 billion at December 31, 2025A default by or a significant downgrade in the credit ratings of a consumer or corporate 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 consumer and corporate 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 cards risk factors above and the emerging markets risk factor below). For example, a weakening of economic conditions, including increases in unemployment rates, can adversely affect borrowers’ ability to repay their obligations, as well as result in Citi’s inability to liquidate the collateral it holds or forced to liquidate the collateral at prices that do not cover the full amount owed to Citi. 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” belowand Notes 15 and 16.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, systemic risks, including from leveraged finance, non-bank financial institutions, private credit and AI, could increase Citi’s credit costs.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, including on the CECL methodology, see the changes in or incorrect assumptions risk factor above. Concentrations and/or high correlation 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, 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. Citi also routinely executes a high volume of securities, trading, derivative and foreign exchange transactions with",
      "prior_body": "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 across the Company as part of its comprehensive stress testing initiatives. 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. In 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 related to governance, and internal controls (see the legal and regulatory proceedings risk factor below). In addition, 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 59 59 59 circumstances, or identify changes in markets or client behaviors not yet inherent in historical data. Citi could incur significant losses, receive negative regulatory evaluation or examination findings or be subject 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 scrutiny and ongoing interpretation of regulatory changes risk factor below. Such deficiencies or ineffectiveness could also result in inaccurate financial, regulatory or risk reporting.Moreover, Citi’s Basel III regulatory capital models, including its credit, market and operational risk models, currently remain subject to ongoing regulatory review and approval, which may result in refinements, modifications or enhancements (required or otherwise) to these models. Citi is required to notify and obtain preapproval from both the OCC and FRB prior to implementing certain risk-weighted asset treatments, as well as certain model changes, resulting in a more challenging environment within which Citi must operate in managing its risk-weighted assets. Modifications or requirements resulting from these ongoing reviews, as well as any future changes or guidance provided by the U.S. banking regulators regarding the U.S. regulatory capital framework applicable to Citi, including, but not limited to, potential revisions to the U.S. Basel III rules (see the capital return risk factor and “Capital Resources—Regulatory Capital Standards and Developments” above), have resulted, and could continue to result, in significant changes to Citi’s risk-weighted assets. These changes can negatively impact Citi’s capital ratios and its ability to meet its regulatory capital requirements. CREDIT RISKSCredit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses.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 circumstances, or identify changes in markets or client behaviors not yet inherent in historical data. Citi could incur significant losses, receive negative regulatory evaluation or examination findings or be subject 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 scrutiny and ongoing interpretation of regulatory changes risk factor below. Such deficiencies or ineffectiveness could also result in inaccurate financial, regulatory or risk reporting.Moreover, Citi’s Basel III regulatory capital models, including its credit, market and operational risk models, currently remain subject to ongoing regulatory review and approval, which may result in refinements, modifications or enhancements (required or otherwise) to these models. Citi is required to notify and obtain preapproval from both the OCC and FRB prior to implementing certain risk-weighted asset treatments, as well as certain model changes, resulting in a more challenging environment within which Citi must operate in managing its risk-weighted assets. Modifications or requirements resulting from these ongoing reviews, as well as any future changes or guidance provided by the U.S. banking regulators regarding the U.S. regulatory capital framework applicable to Citi, including, but not limited to, potential revisions to the U.S. Basel III rules (see the capital return risk factor and “Capital Resources—Regulatory Capital Standards and Developments” above), have resulted, and could continue to result, in significant changes to Citi’s risk-weighted assets. These changes can negatively impact Citi’s capital ratios and its ability to meet its regulatory capital requirements. CREDIT RISKSCredit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses.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 circumstances, or identify changes in markets or client behaviors not yet inherent in historical data. Citi could incur significant losses, receive negative regulatory evaluation or examination findings or be subject 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 scrutiny and ongoing interpretation of regulatory changes risk factor below. Such deficiencies or ineffectiveness could also result in inaccurate financial, regulatory or risk reporting. Moreover, Citi’s Basel III regulatory capital models, including its credit, market and operational risk models, currently remain subject to ongoing regulatory review and approval, which may result in refinements, modifications or enhancements (required or otherwise) to these models. Citi is required to notify and obtain preapproval from both the OCC and FRB prior to implementing certain risk-weighted asset treatments, as well as certain model changes, resulting in a more challenging environment within which Citi must operate in managing its risk-weighted assets. Modifications or requirements resulting from these ongoing reviews, as well as any future changes or guidance provided by the U.S. banking regulators regarding the U.S. regulatory capital framework applicable to Citi, including, but not limited to, potential revisions to the U.S. Basel III rules (see the capital return risk factor and “Capital Resources—Regulatory Capital Standards and Developments” above), have resulted, and could continue to result, in significant changes to Citi’s risk-weighted assets. These changes can negatively impact Citi’s capital ratios and its ability to meet its regulatory capital requirements."
    },
    {
      "status": "MODIFIED",
      "current_title": "Non-bank(1)",
      "prior_title": "Non-bank(1)",
      "similarity_score": 0.877,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Senior debt Subordinated debt Trust preferred Customer-related debt(2) Local country and other(3) Securitizations(4) Customer-related debt(2) Local country and other(3) Note: Amounts represent the current value of LTD on Citi’s Consolidated Balance Sheet that, for certain debt instruments, includes consideration of fair value, hedging impacts and unamortized discounts and premiums.\"",
        "Reworded sentence: \"(2) Primarily structured notes, which contain an embedded derivative component that adjusts each security’s risk-return profile.\"",
        "Reworded sentence: \"(4) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.\"",
        "Reworded sentence: \"During 2025, Citi redeemed or repurchased an aggregate of $63.3 billion of its outstanding LTD.\"",
        "Reworded sentence: \"Citigroup alternates between submitting a full resolution plan and a targeted resolution plan on a biennial cycle.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 2025 resolution plan, which can be found on the FRB’s and FDIC’s websites) would remain operational outside of any resolution or insolvency proceedings.\""
      ],
      "current_body": "Senior debt Subordinated debt Trust preferred Customer-related debt(2) Local country and other(3) Securitizations(4) Customer-related debt(2) Local country and other(3) Note: Amounts represent the current value of LTD 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 LTD 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, 2025, non-bank included $101.5 billion of LTD 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) Primarily structured notes, which contain an embedded derivative component that adjusts each security’s risk-return profile. See Note 27 for the fair value component of these issuances. (3) 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. (4) Predominantly credit card securitizations, primarily backed by Branded Cards receivables. For information about changes in Citi’s end-of-period long-term debt, see “Balance Sheet Overview” above. As part of its liability management, Citi has considered, and may continue to consider, opportunities to redeem or repurchase its LTD pursuant to open market purchases, tender offers or other means. Such redemptions and repurchases help reduce Citi’s overall funding costs. During 2025, Citi redeemed or repurchased an aggregate of $63.3 billion of its outstanding LTD. 93 93 93 LTD Issuances and Maturities The table below details Citi’s LTD issuances and maturities (including repurchases and redemptions) during the periods presented: 202520242023In billions of dollarsMaturitiesIssuancesMaturitiesIssuancesMaturitiesIssuancesNon-bankBenchmark debt:Senior debt$19.7 $25.1 $13.9 $11.7 $10.2 $— Subordinated debt5.8 5.2 1.0 4.9 1.3 3.2 Trust preferred— — — — — — Customer-related debt61.8 70.9 59.2 56.7 42.1 40.1 Local country and other2.8 6.9 6.1 8.8 3.1 3.9 Total non-bank$90.1 $108.1 $80.2 $82.1 $56.7 $47.2 BankFHLB borrowings$6.5 $1.0 $7.0 $4.0 $4.3 $8.5 Securitizations1.9 2.0 1.7 — 2.4 1.5 Citibank benchmark senior debt2.5 6.5 2.7 12.0 — 7.5 Customer-related debt1.1 2.6 0.5 0.2 0.2 0.1 Local country and other1.2 1.8 0.9 0.8 1.4 1.0 Total bank$13.2 $13.9 $12.8 $17.0 $8.3 $18.6 Total$103.3 $122.0 $93.0 $99.1 $65.0 $65.8 The table below details Citi’s aggregate LTD maturities (including repurchases and redemptions) in 2025, as well as its aggregate remaining LTD maturities by year as of December 31, 2025: MaturitiesIn billions of dollars202520262027202820292030ThereafterTotalNon-bankBenchmark debt:Senior debt$19.7 $9.9 $7.6 $20.5 $7.9 $12.2 $59.4 $117.5 Subordinated debt5.8 2.5 3.8 2.0 — — 20.4 28.7 Trust preferred — — — — — — 1.6 1.6 Customer-related debt61.8 18.5 14.5 12.7 9.4 10.1 51.5 116.7 Local country and other2.8 4.0 2.2 0.8 1.2 1.3 5.3 14.8 Total non-bank$90.1 $34.9 $28.1 $36.0 $18.5 $23.6 $138.2 $279.3 BankFHLB borrowings$6.5 $3.0 $— $— $— $— $— $3.0 Securitizations1.9 0.8 — — 0.8 2.2 1.4 5.2 Citibank benchmark senior debt2.5 8.0 6.5 2.5 1.5 3.0 2.0 23.5 Customer-related debt1.1 — — — 0.4 0.8 1.5 2.7 Local country and other1.2 0.2 0.7 0.9 0.1 — 0.2 2.1 Total bank$13.2 $12.0 $7.2 $3.4 $2.8 $6.0 $5.1 $36.5 Total LTD$103.3 $46.9 $35.3 $39.4 $21.3 $29.6 $143.3 $315.8 94 94 94 Resolution PlanCitigroup is required under Title I of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) and the rules promulgated by the FDIC and FRB to periodically submit a plan for Citi’s rapid and orderly resolution under the U.S. Bankruptcy Code in the event of material financial distress or failure. For additional information on risks related to the application of resolution plan requirements, see “Risk Factors—Strategic Risks” above. Citigroup alternates between submitting a full resolution plan and a targeted resolution plan on a biennial cycle.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 2025 resolution plan, which can be found on the FRB’s and FDIC’s websites) would remain operational outside of any resolution or insolvency proceedings. Citigroup’s resolution plan has been designed to minimize the risk of systemic impact to the U.S. and global financial systems, while maximizing the value of the bankruptcy estate for the benefit of Citigroup’s creditors, including its unsecured LTD holders. In addition, in line with the FRB’s total loss-absorbing capacity (TLAC) rule, Citigroup’s shareholders and unsecured creditors—including its unsecured LTD holders—bear any losses resulting from Citigroup’s bankruptcy. Accordingly, any value realized by holders of its unsecured LTD may not be sufficient to repay the amounts owed to such debt holders in the event of a bankruptcy or other resolution proceeding of Citigroup.The FDIC has also indicated that it was developing a single point of entry strategy to implement the Orderly Liquidation Authority under Title II of the Dodd-Frank Act, which provides the FDIC with the ability to resolve a firm when it is determined that bankruptcy would have serious adverse effects on financial stability in the U.S.As previously disclosed, in response to feedback received from the FRB and FDIC, Citigroup took the following actions:•Citicorp LLC (Citicorp), an existing wholly owned subsidiary of Citigroup, was established as an intermediate holding company (an IHC) for certain of Citigroup’s operating material legal entities.•Citigroup executed an inter-affiliate agreement with Citicorp, Citigroup’s operating material legal entities and certain other affiliated entities pursuant to which Citicorp is required to provide liquidity and capital support to Citigroup’s operating material legal entities in the event that Citigroup were to enter bankruptcy proceedings (Citi Support Agreement). •pursuant to the Citi Support Agreement:•Citigroup made an initial contribution of assets, including certain high-quality liquid assets and inter-affiliate loans (Contributable Assets), to Citicorp, and Citicorp became the business-as-usual funding vehicle for Citigroup’s operating material legal entities;•Citigroup will be obligated to continue to transfer Contributable Assets to Citicorp over time, subject to certain amounts retained by Citigroup to, among other things, meet Citigroup’s near-term cash needs; and•in the event of a Citigroup bankruptcy, Citigroup will be required to contribute most of its remaining assets to Citicorp.•The obligations of both Citigroup and Citicorp under the Citi Support Agreement, as well as the Contributable Assets, are secured pursuant to a security agreement.Total Loss-Absorbing Capacity (TLAC)As a U.S. GSIB, Citi is required to maintain minimum levels of TLAC and eligible LTD, each set by reference to the GSIB’s consolidated risk-weighted assets (RWA) and total leverage exposure. The intended purpose of the requirements is to facilitate the orderly resolution of U.S. GSIBs under the U.S. Bankruptcy Code and Title II of the Dodd-Frank Act. For additional information, including Citi’s TLAC and LTD amounts and ratios, see “Capital Resources—Current Regulatory Capital Standards” above. Resolution PlanCitigroup is required under Title I of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) and the rules promulgated by the FDIC and FRB to periodically submit a plan for Citi’s rapid and orderly resolution under the U.S. Bankruptcy Code in the event of material financial distress or failure. For additional information on risks related to the application of resolution plan requirements, see “Risk Factors—Strategic Risks” above. Citigroup alternates between submitting a full resolution plan and a targeted resolution plan on a biennial cycle.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 2025 resolution plan, which can be found on the FRB’s and FDIC’s websites) would remain operational outside of any resolution or insolvency proceedings. Citigroup’s resolution plan has been designed to minimize the risk of systemic impact to the U.S. and global financial systems, while maximizing the value of the bankruptcy estate for the benefit of Citigroup’s creditors, including its unsecured LTD holders. In addition, in line with the FRB’s total loss-absorbing capacity (TLAC) rule, Citigroup’s shareholders and unsecured creditors—including its unsecured LTD holders—bear any losses resulting from Citigroup’s bankruptcy. Accordingly, any value realized by holders of its unsecured LTD may not be sufficient to repay the amounts owed to such debt holders in the event of a bankruptcy or other resolution proceeding of Citigroup.The FDIC has also indicated that it was developing a single point of entry strategy to implement the Orderly Liquidation Authority under Title II of the Dodd-Frank Act, which provides the FDIC with the ability to resolve a firm when it is determined that bankruptcy would have serious adverse effects on financial stability in the U.S.",
      "prior_body": "Senior debt Subordinated debt Trust preferred Local country and other(2) Securitizations(3) Local country and other(2) 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. 97 97 97 Long-Term Debt Issuances and Maturities The table below details Citi’s long-term debt issuances and maturities (including repurchases and redemptions) during the periods presented: 202420232022In billions of dollarsMaturitiesIssuancesMaturitiesIssuancesMaturitiesIssuancesNon-bankBenchmark debt:Senior debt$13.9 $11.7 $10.2 $— $15.4 $27.3 Subordinated debt1.0 4.9 1.3 3.2 0.9 — Trust preferred— — — — 0.1 — Customer-related debt59.2 56.7 42.1 40.1 27.0 65.1 Local country and other6.1 8.8 3.1 3.9 2.8 3.5 Total non-bank$80.2 $82.1 $56.7 $47.2 $46.2 $95.9 BankFHLB borrowings$7.0 $4.0 $4.3 $8.5 $5.3 $7.3 Securitizations1.7 — 2.4 1.5 2.1 0.2 Citibank benchmark senior debt2.7 12.0 — 7.5 0.9 — Local country and other1.4 1.0 1.6 1.1 2.6 1.3 Total bank$12.8 $17.0 $8.3 $18.6 $10.9 $8.8 Total$93.0 $99.1 $65.0 $65.8 $57.1 $104.7 The table below details Citi’s aggregate long-term debt maturities (including repurchases and redemptions) in 2024, as well as its aggregate expected remaining long-term debt maturities by year as of December 31, 2024: MaturitiesIn billions of dollars202420252026202720282029ThereafterTotalNon-bankBenchmark debt:Senior debt$13.9 $3.9 $24.3 $7.2 $16.6 $3.5 $51.9 $107.4 Subordinated debt1.0 5.2 2.4 3.6 2.0 — 15.5 28.7 Trust preferred — — — — — — 1.6 1.6 Customer-related debt59.2 20.8 12.4 13.2 7.1 9.6 40.2 103.3 Local country and other6.1 2.0 1.0 1.0 1.0 1.3 4.5 10.8 Total non-bank$80.2 $31.9 $40.1 $25.0 $26.7 $14.4 $113.7 $251.8 BankFHLB borrowings$7.0 $6.5 $2.0 $— $— $— $— $8.5 Securitizations1.7 0.9 — 1.9 — 0.8 1.5 5.1 Citibank benchmark senior debt2.7 2.5 8.0 3.0 2.5 1.5 1.9 19.4 Local country and other1.4 0.1 0.7 0.4 0.1 1.1 0.1 2.5 Total bank$12.8 $10.0 $10.7 $5.3 $2.6 $3.4 $3.5 $35.5 Total long-term debt$93.0 $41.9 $50.8 $30.3 $29.3 $17.8 $117.2 $287.3 98 98 98 Resolution PlanCitigroup is required under Title I of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) and the rules promulgated by the FDIC and FRB to periodically submit a plan for Citi’s rapid and orderly resolution under the U.S. Bankruptcy Code in the event of material financial distress or failure. For additional information on risks related to the application of resolution plan requirements, see “Risk Factors—Strategic Risks” above. Citigroup alternates between submitting a full resolution plan and a targeted resolution plan on a biennial cycle.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. Citigroup’s resolution plan has been designed to minimize the risk of systemic impact to the U.S. and global financial systems, while maximizing the value of the bankruptcy estate for the benefit of Citigroup’s creditors, including its unsecured long-term debt holders. In addition, in line with the FRB’s total loss-absorbing capacity (TLAC) rule, Citigroup’s shareholders and unsecured creditors—including its unsecured long-term debt holders—bear any losses resulting from Citigroup’s bankruptcy. Accordingly, any value realized by holders of its unsecured long-term debt may not be sufficient to repay the amounts owed to such debt holders in the event of a bankruptcy or other resolution proceeding of Citigroup.The FDIC has also indicated that it was developing a single point of entry strategy to implement the Orderly Liquidation Authority under Title II of the Dodd-Frank Act, which provides the FDIC with the ability to resolve a firm when it is determined that bankruptcy would have serious adverse effects on financial stability in the U.S.As previously disclosed, in response to feedback received from the FRB and FDIC, Citigroup took the following actions:(i) Citicorp LLC (Citicorp), an existing wholly owned subsidiary of Citigroup, was established as an intermediate holding company (an IHC) for certain of Citigroup’s operating material legal entities;(ii) Citigroup executed an inter-affiliate agreement with Citicorp, Citigroup’s operating material legal entities and certain other affiliated entities pursuant to which Citicorp is required to provide liquidity and capital support to Citigroup’s operating material legal entities in the event that Citigroup were to enter bankruptcy proceedings (Citi Support Agreement); (iii) pursuant to the Citi Support Agreement:•Citigroup made an initial contribution of assets, including certain high-quality liquid assets and inter-affiliate loans (Contributable Assets), to Citicorp, and Citicorp became the business-as-usual funding vehicle for Citigroup’s operating material legal entities;•Citigroup will be obligated to continue to transfer Contributable Assets to Citicorp over time, subject to certain amounts retained by Citigroup to, among other things, meet Citigroup’s near-term cash needs; •in the event of a Citigroup bankruptcy, Citigroup will be required to contribute most of its remaining assets to Citicorp; and(iv) the obligations of both Citigroup and Citicorp under the Citi Support Agreement, as well as the Contributable Assets, are secured pursuant to a security agreement.Total Loss-Absorbing Capacity (TLAC)U.S. GSIBs are required to maintain minimum levels of TLAC and eligible LTD, each set by reference to the GSIB’s consolidated risk-weighted assets (RWA) and total leverage exposure. The intended purpose of the requirements is to facilitate the orderly resolution of U.S. GSIBs under the U.S. Bankruptcy Code and Title II of the Dodd-Frank Act. For additional information, including Citi’s TLAC and LTD amounts and ratios, see “Capital Resources—Current Regulatory Capital Standards” above. Resolution PlanCitigroup is required under Title I of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) and the rules promulgated by the FDIC and FRB to periodically submit a plan for Citi’s rapid and orderly resolution under the U.S. Bankruptcy Code in the event of material financial distress or failure. For additional information on risks related to the application of resolution plan requirements, see “Risk Factors—Strategic Risks” above. Citigroup alternates between submitting a full resolution plan and a targeted resolution plan on a biennial cycle.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. Citigroup’s resolution plan has been designed to minimize the risk of systemic impact to the U.S. and global financial systems, while maximizing the value of the bankruptcy estate for the benefit of Citigroup’s creditors, including its unsecured long-term debt holders. In addition, in line with the FRB’s total loss-absorbing capacity (TLAC) rule, Citigroup’s shareholders and unsecured creditors—including its unsecured long-term debt holders—bear any losses resulting from Citigroup’s bankruptcy. Accordingly, any value realized by holders of its unsecured long-term debt may not be sufficient to repay the amounts owed to such debt holders in the event of a bankruptcy or other resolution proceeding of Citigroup.The FDIC has also indicated that it was developing a single point of entry strategy to implement the Orderly Liquidation Authority under Title II of the Dodd-Frank Act, which provides the FDIC with the ability to resolve a firm when it is determined that bankruptcy would have serious adverse effects on financial stability in the U.S."
    },
    {
      "status": "MODIFIED",
      "current_title": "Short-Term Borrowings",
      "prior_title": "Short-Term Borrowings",
      "similarity_score": 0.871,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"See Note 19 for further information on Citigroup’s and its affiliates’ outstanding short-term borrowings.\"",
        "Reworded sentence: \"The table below presents the ratings for Citigroup and Citibank as of December 31, 2025.\""
      ],
      "current_body": "See Note 19 for further information on Citigroup’s and its affiliates’ outstanding short-term borrowings. 96 96 96 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, 2025. While not included in the table below, the current long-term and short-term ratings of Citigroup Global Markets Holdings 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, 2025. 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, 2025. While not included in the table below, the current long-term and short-term ratings of Citigroup Global Markets Holdings 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, 2025.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Regulatory Expectations and Scrutiny in the U.S. and Globally as well as Ongoing Interpretation and Implementation of Regulatory and Legislative Requirements and Changes Subject Citi to Significant Compliance, Regulatory and Other Risks and Costs.",
      "prior_title": "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.",
      "similarity_score": 0.87,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Large financial institutions, such as Citi, face significant regulatory and supervisory expectations and scrutiny in the U.S.\"",
        "Reworded sentence: \"regulatory capital framework and requirements, which have continued to evolve (see the capital return risk factor and “Capital Resources” above); and (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.\"",
        "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 remedy deficiencies on a timely basis (see also the capital return and resolution plan risk factors above).\""
      ],
      "current_body": "Large financial institutions, such as Citi, face significant regulatory and supervisory expectations and scrutiny in the U.S. and globally, including with respect to, among other things, 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 anti-money laundering; increasingly complex sanctions regimes; customer and client protection; market practices; and various disclosure and regulatory reporting requirements. Citi is also continually required to interpret and implement extensive and frequently changing regulatory and legislative requirements within the U.S. and in 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 regulatory requirements or expectations, 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); and (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. Citi Is Subject to Extensive Legal and Regulatory Proceedings, Examinations, Investigations, Consent Orders and Related Compliance Efforts and Other Inquiries That Have in the Past and Could in the Future 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 remedy deficiencies on a timely basis (see also the capital return and resolution plan risk factors above). Under U.S. banking law, Citi is prohibited from disclosing confidential supervisory information, and may therefore be unable to disclose even potentially material regulatory or supervisory matters. 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 require continued significant investments by Citi during 2026 and beyond, as an essential part of Citi’s broader transformation efforts (see the simplification, transformation and enhanced business performance priorities risk factor above). Further, in 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 FRB found that Citigroup 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); and (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.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Parallel shift(1)",
      "prior_title": "Scenario Analysis",
      "similarity_score": 0.869,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"All other currencies(1) Estimated initial impact to AOCI (after-tax)(2) Note: Each scenario assumes that the rate change will occur instantaneously.\"",
        "Reworded sentence: \"(1)The “parallel shift” impact of $1,402 million consists of the following top five non-U.S.\"",
        "Reworded sentence: \"(2)Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension plans.\"",
        "Reworded sentence: \"This is because Citi’s investment portfolio is more sensitive to shorter-term rates and pension liabilities are more sensitive at intermediate-term maturities.\"",
        "Reworded sentence: \"This is because Citi’s investment portfolio is more sensitive to shorter-term rates and pension liabilities are more sensitive at intermediate-term maturities.\""
      ],
      "current_body": "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 “parallel shift” impact of $1,402 million consists of the following top five non-U.S. dollar currencies as of December 31, 2025 by absolute size: approximately $(0.4) billion from the euro, approximately $0.2 billion each from the British pound sterling and Swiss franc and $0.1 billion each from the Singapore dollar and Hong Kong dollar. 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 plans. 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 is more sensitive to shorter-term rates and pension liabilities are more sensitive at 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 is more sensitive to shorter-term rates and pension liabilities are more sensitive at 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 is more sensitive to shorter-term rates and pension liabilities are more sensitive at intermediate-term maturities. 100 100 100 Changes in Foreign Exchange Rates—Impacts on AOCI and CapitalAs of December 31, 2025, Citi estimates that a 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 reduction in the TCE would be primarily driven by depreciation of the euro, Mexican peso and Singapore dollar.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, 2025, Citi estimates that a 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 reduction in the TCE would be primarily driven by depreciation of the euro, Mexican peso and Singapore dollar.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",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "USPB(5)(6)",
      "prior_title": "USPB(5)(6)",
      "similarity_score": 0.869,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Credit cards total (a+c) = (d)(6) Branded Cards (a+b) Retail Banking(5) Asia Consumer(7) Legacy Holdings Assets (consumer)(8) (1)End-of-period (EOP) loans include interest and fees on credit cards.\"",
        "Reworded sentence: \"As of December 31, 2025, 2024 and 2023, 69%, 72% and 85% of Wealth classifiably managed loans were rated investment grade.\"",
        "Reworded sentence: \"The amounts excluded for loans 90+ days past due and (EOP loans) were $61 million ($0.4 billion), $69 million ($0.5 billion) and $63 million ($0.5 billion) at December 31, 2025, 2024 and 2023, respectively.\"",
        "Reworded sentence: \"80 80 80 (6)The 90+ days past due balances for Branded Cards and Retail Services are generally still accruing interest.\"",
        "Reworded sentence: \"(7)Asia Consumer loan balances and the related delinquencies, reported within All Other—Legacy Franchises, include the three remaining Asia Consumer loan portfolios: Korea, Poland (through the first quarter of 2025) and Russia until the completion of its consumer loan portfolio wind-down in the second quarter of 2025.\""
      ],
      "current_body": "Credit cards total (a+c) = (d)(6) Branded Cards (a+b) Retail Banking(5) Asia Consumer(7) Legacy Holdings Assets (consumer)(8) (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, 2025, 2024 and 2023, 69%, 72% and 85% 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 $61 million ($0.4 billion), $69 million ($0.5 billion) and $63 million ($0.5 billion) at December 31, 2025, 2024 and 2023, 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 $60 million, $66 million and $73 million at December 31, 2025, 2024 and 2023, respectively. The EOP loans in the table include the guaranteed loans. 80 80 80 (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 loan balances and the related delinquencies, reported within All Other—Legacy Franchises, include the three remaining Asia Consumer loan portfolios: Korea, Poland (through the first quarter of 2025) and Russia until the completion of its consumer loan portfolio wind-down in the second quarter of 2025. During the second quarter of 2025, Citi’s Poland consumer banking business was classified as HFS as a result of Citi’s agreement to sell the business. Accordingly, the Poland consumer loans are recorded in Other assets on the Consolidated Balance Sheet. As a result, the Poland consumer loans and related delinquencies are not included in this table for 2025. See “Agreement to Sell Poland Consumer Banking Business” in Note 2. (8)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 $65 million ($0.2 billion), $66 million ($0.2 billion) and $67 million ($0.2 billion) at December 31, 2025, 2024 and 2023, 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 $29 million, $34 million and $36 million at December 31, 2025, 2024 and 2023, respectively. The EOP loans in the table include the guaranteed loans. N/A Not applicable",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "FICO distribution(1)",
      "prior_title": "FICO distribution(1)",
      "similarity_score": 0.868,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"The FICO distribution of both Branded Cards and Retail Services portfolios remained largely unchanged quarter-over-quarter and year-over-year.\""
      ],
      "current_body": "≥ 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 remained largely unchanged 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. 79 79 79",
      "prior_body": "≥ 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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Retail Banking",
      "prior_title": "Retail Banking",
      "similarity_score": 0.855,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"USPB’s Retail Banking portfolio consists primarily of consumer mortgages (including home equity) and unsecured lending products, such as small business loans and revolving products.\"",
        "Reworded sentence: \"As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Retail Banking increased quarter-over-quarter, driven by consumer overdraft losses, and was broadly stable year-over-year.\"",
        "Reworded sentence: \"The delinquency-managed portfolio consists primarily of mortgages and credit cards.As of December 31, 2025, approximately $48 billion, or 32%, of the portfolios were classifiably managed and primarily consisted of margin loans, commercial real estate loans, personal and small business loans and other lending programs.\"",
        "Reworded sentence: \"31, 2024≥ 74055 %55 %56 %660–73933 34 33 < 66012 11 11 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec.\"",
        "Reworded sentence: \"Mexico ConsumerMexico Consumer provides credit cards, consumer mortgages and small business and personal loans.\""
      ],
      "current_body": "USPB’s Retail Banking portfolio consists primarily of consumer mortgages (including home equity) and unsecured lending products, such as small business loans and revolving products. 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 2025 net credit loss rate for Retail Banking increased quarter-over-quarter, driven by consumer overdraft losses, and was broadly stable year-over-year. The 90+ days past due delinquency rate decreased quarter-over-quarter, driven by the transfer of certain relationships and associated mortgage loans to Retail Banking from Wealth, and increased year-over-year, driven by consumer mortgages enrolled in forbearance programs related to the California wildfires. WealthAs of December 31, 2025, Wealth provided 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, Citigold and Wealth at Work 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 and credit cards.As of December 31, 2025, approximately $48 billion, or 32%, of the portfolios were classifiably managed and primarily consisted of margin loans, commercial real estate 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 69% were rated investment grade. The 90+ days past due delinquency rates shown in the chart above were calculated only for the delinquency-managed portfolio, while the net credit loss rates were calculated using net credit losses for both the delinquency and classifiably managed portfolios.As presented in the chart above, the fourth quarter of 2025 net credit loss rate in Wealth decreased quarter-over-quarter, primarily driven by write-downs of mortgage loans to their collateral value due to the impact of the California wildfires in the previous quarter, and was broadly stable year-over-year. The 90+ days past due delinquency rate decreased quarter-over-quarter, largely driven by the resumption of payments on consumer mortgages exiting forbearance programs related to the California wildfires. The 90+ days past due delinquency rate increased year-over-year, driven by consumer mortgages that enrolled in forbearance programs related to the California wildfires. The low net credit loss and 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. Wealth As of December 31, 2025, Wealth provided 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, Citigold and Wealth at Work 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 and credit cards. As of December 31, 2025, approximately $48 billion, or 32%, of the portfolios were classifiably managed and primarily consisted of margin loans, commercial real estate 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 69% were rated investment grade. The 90+ days past due delinquency rates shown in the chart above were calculated only for the delinquency-managed portfolio, while the net credit loss rates were calculated using net credit losses for both the delinquency and classifiably managed portfolios. As presented in the chart above, the fourth quarter of 2025 net credit loss rate in Wealth decreased quarter-over-quarter, primarily driven by write-downs of mortgage loans to their collateral value due to the impact of the California wildfires in the previous quarter, and was broadly stable year-over-year. The 90+ days past due delinquency rate decreased quarter-over-quarter, largely driven by the resumption of payments on consumer mortgages exiting forbearance programs related to the California wildfires. The 90+ days past due delinquency rate increased year-over-year, driven by consumer mortgages that enrolled in forbearance programs related to the California wildfires. The low net credit loss and 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. 78 78 78 Mexico ConsumerMexico Consumer 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, 2025, approximately 40% of Mexico Consumer’s EOP loans consisted of credit card loans, which largely drives the overall credit performance of the Mexico Consumer portfolios, as the cards net credit losses represented approximately 60% of total Mexico Consumer net credit losses for the fourth quarter of 2025.As presented in the chart above, the fourth quarter of 2025 net credit loss rate in Mexico Consumer increased quarter-over-quarter and year-over-year, driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows. The 90+ days past due delinquency rate increased quarter-over-quarter, largely driven by seasonality and the ongoing normalization of loss and delinquency rates from post-pandemic lows. The 90+ days past due delinquency rate increased year-over-year, primarily driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows.For additional details on provisions, loan delinquency and other information for Citi’s consumer loan portfolios, see the results of operations for USPB, Wealth and All Other 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, 2025Sep. 30, 2025Dec. 31, 2024≥ 74055 %55 %56 %660–73933 34 33 < 66012 11 11 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec. 31, 2025Sep. 30, 2025Dec. 31, 2024≥ 74037 %36 %36 %660–73941 41 41 < 66022 23 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 remained largely unchanged 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. Mexico ConsumerMexico Consumer 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, 2025, approximately 40% of Mexico Consumer’s EOP loans consisted of credit card loans, which largely drives the overall credit performance of the Mexico Consumer portfolios, as the cards net credit losses represented approximately 60% of total Mexico Consumer net credit losses for the fourth quarter of 2025.As presented in the chart above, the fourth quarter of 2025 net credit loss rate in Mexico Consumer increased quarter-over-quarter and year-over-year, driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows. The 90+ days past due delinquency rate increased quarter-over-quarter, largely driven by seasonality and the ongoing normalization of loss and delinquency rates from post-pandemic lows. The 90+ days past due delinquency rate increased year-over-year, primarily driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows.For additional details on provisions, loan delinquency and other information for Citi’s consumer loan portfolios, see the results of operations for USPB, Wealth and All Other above and Note 15.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Citi’s and Third Parties’ Computer Systems and Networks Continue to Be Susceptible to an Increasing Risk of Evolving, Sophisticated Cybersecurity Incidents That Could Result in the Theft, Loss, Non-Availability, Alteration, Misuse or Disclosure of Confidential Information, Damage to Citi’s Reputation, Regulatory Penalties, Legal Exposure and Financial Losses.",
      "prior_title": "Citi’s and Third Parties’ Computer Systems and Networks Will Continue to Be Susceptible to an Increasing Risk of Continually Evolving, Sophisticated Cybersecurity Incidents That Could Result in the Theft, Loss, Non-Availability, Misuse or Disclosure of Confidential Client or Customer Information, Damage to Citi’s Reputation, Additional Costs to Citi, Regulatory Penalties, Legal Exposure and Financial Losses.",
      "similarity_score": 0.851,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Citi’s computer systems, software and networks are subject to ongoing attempted cyberattacks, as attempts to effectuate unauthorized access to, theft or destruction of data (including confidential client information), account takeovers, and disruptions of service, using techniques including phishing, malware, ransomware, computer viruses or other malicious code, exploitation of vulnerabilities, and others.\"",
        "Added sentence: \"Some cyber and information security incidents may also occur as a result of unintentional conduct on the part of employees, customers or suppliers.\"",
        "Reworded sentence: \"The increasing use of cloud and new and emerging technologies (such as AI and digital assets), as well as connectivity solutions to facilitate remote working for Citi’s employees, all increase Citi’s exposure to cybersecurity risks.\"",
        "Reworded sentence: \"Citi and some of its third-party partners have been subjected to attempted and sometimes successful cyberattacks over the last several years, including the following:•denial of service attacks, which attempt to interrupt service to clients and customers•hacking and malicious software installations intended to gain unauthorized access to information systems or to disrupt those systems and/or impact availability or privacy of confidential data, with objectives including, but not limited to, extortion payments or causing reputational damage•data breaches due to unauthorized access to customer accounts or other data•malicious software attacks on client systems, in attempts to gain unauthorized access to Citi systems or client data under the guise of normal client transactions While Citi’s cyber and information security program has historically generally succeeded in detecting, thwarting and/or responding to attacks targeting its systems before they become significant, certain past incidents resulted in limited losses, as well as increases in expenditures to monitor against the threat of similar future cyber incidents.\"",
        "Reworded sentence: \"Because the techniques used to initiate cyberattacks change frequently or, in some cases, are not recognized until deployed, Citi may be unable to implement effective preventive measures or otherwise proactively address these risks.\""
      ],
      "current_body": "Citi’s computer systems, software and networks are subject to ongoing attempted cyberattacks, as attempts to effectuate unauthorized access to, theft or destruction of data (including confidential client information), account takeovers, and disruptions of service, using techniques including phishing, malware, ransomware, computer viruses or other malicious code, exploitation of vulnerabilities, and others. These threats can arise from external parties, including cyber criminals, cyber terrorists, hacktivists and nation-state actors, as well as insiders who knowingly or unknowingly engage in or enable malicious cyber activities. For example, nation-state actors have recently targeted critical U.S. infrastructure with cyberattacks. Some cyber and information security incidents may also occur as a result of unintentional conduct on the part of employees, customers or suppliers. Citi develops its own software and relies on third-party applications and software, which are susceptible to vulnerability exploitations. Software leveraged in financial services and other industries continues to be impacted by an increasing number of zero-day vulnerabilities, thus increasing inherent cyber risk to Citi. The increasing use of cloud and new and emerging technologies (such as AI and digital assets), as well as connectivity solutions to facilitate remote working for Citi’s employees, all increase Citi’s exposure to cybersecurity risks. Citi is also susceptible to cyberattacks given, among other factors, its size and scale, high-profile brand, global footprint and prominent role in the financial system. Additionally, Citi continues to operate in multiple jurisdictions in the midst of geopolitical unrest or uncertainties, including, among others, those affected by the Russia–Ukraine war and the conflicts in the Middle East, which could expose Citi to heightened risk of insider threat, cyber threats from nation-state actors, hacktivism or other cyber incidents. Citi continues to experience increased exposure to cyberattacks through third parties. Third parties with which Citi does business, as well as retailers and other third parties with which Citi’s customers do business, and any such third parties’ downstream service providers, also pose cybersecurity risks, particularly where activities of customers are beyond Citi’s security and control systems. For example, Citi outsources certain functions, such as processing customer credit card transactions, uploading content on customer-facing websites and developing software for new products and services. These relationships allow for the storage and processing of customer information by third-party hosting of, or access to, Citi websites. This could lead to compromise or the potential to introduce vulnerable or malicious code, resulting in security breaches or business disruptions impacting Citi customers, employees or operations. While many of Citi’s agreements with third parties include indemnification provisions, Citi may not be able to recover sufficiently under these provisions, or at all, to adequately offset any losses and other adverse impacts Citi may incur from third-party cyber incidents. Citi and some of its third-party partners have been subjected to attempted and sometimes successful cyberattacks over the last several years, including the following:•denial of service attacks, which attempt to interrupt service to clients and customers•hacking and malicious software installations intended to gain unauthorized access to information systems or to disrupt those systems and/or impact availability or privacy of confidential data, with objectives including, but not limited to, extortion payments or causing reputational damage•data breaches due to unauthorized access to customer accounts or other data•malicious software attacks on client systems, in attempts to gain unauthorized access to Citi systems or client data under the guise of normal client transactions While Citi’s cyber and information security program has historically generally succeeded in detecting, thwarting and/or responding to attacks targeting its systems before they become significant, certain past incidents resulted in limited losses, as well as increases in expenditures to monitor against the threat of similar future cyber incidents. There can be no assurance that such cyber incidents will not occur again, and they could occur more frequently, via novel tactics, including leveraging of tools made possible by emerging technologies, and on a more significant scale. Because the techniques used to initiate cyberattacks change frequently or, in some cases, are not recognized until deployed, Citi may be unable to implement effective preventive measures or otherwise proactively address these risks. In addition, cyber threats and cyberattack techniques change, develop and evolve rapidly, including from emerging technologies such as AI and quantum computing. Given the frequency and sophistication of cyberattacks, the determination of the severity and potential impact of a cyber incident may not become apparent for a substantial period of time following detection of the incident. Also, while Citi strives to implement measures to reduce the exposure resulting from outsourcing risks, such as performing security control assessments of third-party vendors and limiting third-party access to the least privileged level necessary to perform service functions, these measures cannot prevent all third-party-related cyberattacks or data breaches. Cyber incidents can result in the disclosure of personal, confidential or proprietary customer, client or employee information; damage to Citi’s reputation with its clients, other counterparties and the market; customer dissatisfaction; and additional costs to Citi, including expenses such as repairing or replacing systems, replacing customer payment cards, credit monitoring or adding new personnel or protection technologies. Cyber incidents can also result in regulatory resulting in security breaches or business disruptions impacting Citi customers, employees or operations. While many of Citi’s agreements with third parties include indemnification provisions, Citi may not be able to recover sufficiently under these provisions, or at all, to adequately offset any losses and other adverse impacts Citi may incur from third-party cyber incidents. Citi and some of its third-party partners have been subjected to attempted and sometimes successful cyberattacks over the last several years, including the following: •denial of service attacks, which attempt to interrupt service to clients and customers •hacking and malicious software installations intended to gain unauthorized access to information systems or to disrupt those systems and/or impact availability or privacy of confidential data, with objectives including, but not limited to, extortion payments or causing reputational damage •data breaches due to unauthorized access to customer accounts or other data •malicious software attacks on client systems, in attempts to gain unauthorized access to Citi systems or client data under the guise of normal client transactions While Citi’s cyber and information security program has historically generally succeeded in detecting, thwarting and/or responding to attacks targeting its systems before they become significant, certain past incidents resulted in limited losses, as well as increases in expenditures to monitor against the threat of similar future cyber incidents. There can be no assurance that such cyber incidents will not occur again, and they could occur more frequently, via novel tactics, including leveraging of tools made possible by emerging technologies, and on a more significant scale. Because the techniques used to initiate cyberattacks change frequently or, in some cases, are not recognized until deployed, Citi may be unable to implement effective preventive measures or otherwise proactively address these risks. In addition, cyber threats and cyberattack techniques change, develop and evolve rapidly, including from emerging technologies such as AI and quantum computing. Given the frequency and sophistication of cyberattacks, the determination of the severity and potential impact of a cyber incident may not become apparent for a substantial period of time following detection of the incident. Also, while Citi strives to implement measures to reduce the exposure resulting from outsourcing risks, such as performing security control assessments of third-party vendors and limiting third-party access to the least privileged level necessary to perform service functions, these measures cannot prevent all third-party-related cyberattacks or data breaches. Cyber incidents can result in the disclosure of personal, confidential or proprietary customer, client or employee information; damage to Citi’s reputation with its clients, other counterparties and the market; customer dissatisfaction; and additional costs to Citi, including expenses such as repairing or replacing systems, replacing customer payment cards, credit monitoring or adding new personnel or protection technologies. Cyber incidents can also result in regulatory 56 56 56 penalties, loss of revenues, deposit outflows, exposure to litigation and regulatory action and other financial losses, including loss of funds to both Citi and its clients and customers, and disruption to Citi’s operational systems (see the operational processes and systems risk factor above). Moreover, the increasing risk of cyber incidents has resulted in increased legislative and regulatory action on cybersecurity, including, among other things, scrutiny of firms’ cybersecurity programs, laws and regulations to enhance protection of consumers’ personal data and mandated disclosure on cybersecurity matters and of certain cybersecurity incidents.While Citi maintains insurance coverage that may, subject to policy terms and conditions including significant self-insured deductibles, transfer certain aspects of cyber risks, such insurance coverage may be insufficient to cover all losses and may not take into account reputational harm, the costs of which are impossible to quantify.For additional information about Citi’s management of cybersecurity risk, see “Managing Global Risk—Operational Risk—Cybersecurity Risk” below. Changes in or Incorrect Accounting Assumptions, Judgments or Estimates, or the Application of Certain Accounting Principles, Could Result in Significant Losses or Other Adverse Impacts.U.S. GAAP requires Citi to use certain assumptions, judgments and estimates in preparing its financial statements, including, among other items, the estimate of the ACL; reserves related to litigation, regulatory and tax matters; valuation of DTAs; the fair values of certain assets and liabilities; and the assessment of goodwill and other assets for impairment. These assumptions, judgments and estimates are inherently limited because they involve techniques, including the use of historical data, that cannot anticipate or model every economic and financial outcome in the markets in which Citi operates, nor can they anticipate the specific impact 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 hold in times of market stress, limited liquidity or other unforeseen circumstances. If Citi’s assumptions, judgments or estimates underlying its financial statements are incorrect or differ from actual or subsequent events, Citi could experience unexpected losses or other adverse impacts, some of which could be significant. Citi could also experience declines in its stock price, be subject to legal and regulatory proceedings and incur fines and other losses. For additional information on the key areas for which assumptions and estimates are used in preparing Citi’s financial statements, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16. For example, the CECL methodology requires that Citi provide reserves for a current estimate of lifetime expected credit losses for its loan portfolios and other financial assets at the time those assets are originated or acquired. This estimate is adjusted each period for changes in expected lifetime credit losses. Citi’s ACL estimate is subject to judgments and depends upon its CECL models and assumptions, including forecasted macroeconomic conditions, which can be more challenging to forecast during times of significant market volatility and uncertainty. These model assumptions and forecasted macroeconomic conditions will change over time, resulting in variability in Citi’s ACL and, thus, impact its results of operations and financial condition, as well as regulatory capital (see the capital return risk factor above). For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 (“Allowance for Credit Losses (ACL)”) and 16.Moreover, Citi has incurred losses related to its foreign operations that are reported in the CTA components of Accumulated other comprehensive income (loss) (AOCI). In accordance with U.S. GAAP, a sale or other deconsolidation event of any foreign operation that results in a substantially complete liquidation of an investment in a foreign entity, such as those related to Citi’s remaining divestitures or legacy businesses, would result in reclassification of any CTA component of AOCI related to that entity, including amounts associated with related hedges and taxes, into Citi’s earnings. For example, during the quarter in which a deconsolidation of Banamex occurs, Citi would incur a CTA loss of approximately ($9) billion, attributable to Banamex and its consolidated subsidiaries as of December 31, 2025, recognized through earnings, although the cumulative impact of the CTA would be regulatory capital neutral (for additional information, see “All Other” above). For additional information on Citi’s accounting policy for foreign currency translation and its foreign CTA components of AOCI, see Notes 1 (“Foreign Currency Translation”) and 21. 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.Changes to financial accounting or reporting standards or interpretations, whether promulgated or required by the Financial Accounting Standards Board (FASB), the SEC, U.S. banking regulators or others, could present operational challenges and could require Citi to change certain of the assumptions or estimates it previously used in preparing its financial statements, which could negatively impact how it records and reports its financial condition and results of operations generally and/or with respect to particular businesses. For example, the 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. See “Significant Accounting Policies and Significant Estimates” below and Note 1 for additional information on Citi’s accounting policies (“Summary of Significant Accounting Policies”) and changes in accounting (“Accounting Changes”), including the expected impacts on Citi’s results of operations and financial condition. penalties, loss of revenues, deposit outflows, exposure to litigation and regulatory action and other financial losses, including loss of funds to both Citi and its clients and customers, and disruption to Citi’s operational systems (see the operational processes and systems risk factor above). Moreover, the increasing risk of cyber incidents has resulted in increased legislative and regulatory action on cybersecurity, including, among other things, scrutiny of firms’ cybersecurity programs, laws and regulations to enhance protection of consumers’ personal data and mandated disclosure on cybersecurity matters and of certain cybersecurity incidents.While Citi maintains insurance coverage that may, subject to policy terms and conditions including significant self-insured deductibles, transfer certain aspects of cyber risks, such insurance coverage may be insufficient to cover all losses and may not take into account reputational harm, the costs of which are impossible to quantify.For additional information about Citi’s management of cybersecurity risk, see “Managing Global Risk—Operational Risk—Cybersecurity Risk” below. Changes in or Incorrect Accounting Assumptions, Judgments or Estimates, or the Application of Certain Accounting Principles, Could Result in Significant Losses or Other Adverse Impacts.U.S. GAAP requires Citi to use certain assumptions, judgments and estimates in preparing its financial statements, including, among other items, the estimate of the ACL; reserves related to litigation, regulatory and tax matters; valuation of DTAs; the fair values of certain assets and liabilities; and the assessment of goodwill and other assets for impairment. These assumptions, judgments and estimates are inherently limited because they involve techniques, including the use of historical data, that cannot anticipate or model every economic and financial outcome in the markets in which Citi operates, nor can they anticipate the specific impact 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 hold in times of market stress, limited liquidity or other unforeseen circumstances. If Citi’s assumptions, judgments or estimates underlying its financial statements are incorrect or differ from actual or subsequent events, Citi could experience unexpected losses or other adverse impacts, some of which could be significant. Citi could also experience declines in its stock price, be subject to legal and regulatory proceedings and incur fines and other losses. For additional information on the key areas for which assumptions and estimates are used in preparing Citi’s financial statements, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16. For example, the CECL methodology requires that Citi provide reserves for a current estimate of lifetime expected credit losses for its loan portfolios and other financial assets at the time those assets are originated or acquired. This estimate is adjusted each period for changes in expected lifetime credit losses. Citi’s ACL estimate is subject to judgments and depends upon its CECL models and assumptions, including forecasted macroeconomic conditions, which can be more penalties, loss of revenues, deposit outflows, exposure to litigation and regulatory action and other financial losses, including loss of funds to both Citi and its clients and customers, and disruption to Citi’s operational systems (see the operational processes and systems risk factor above). Moreover, the increasing risk of cyber incidents has resulted in increased legislative and regulatory action on cybersecurity, including, among other things, scrutiny of firms’ cybersecurity programs, laws and regulations to enhance protection of consumers’ personal data and mandated disclosure on cybersecurity matters and of certain cybersecurity incidents. While Citi maintains insurance coverage that may, subject to policy terms and conditions including significant self-insured deductibles, transfer certain aspects of cyber risks, such insurance coverage may be insufficient to cover all losses and may not take into account reputational harm, the costs of which are impossible to quantify. For additional information about Citi’s management of cybersecurity risk, see “Managing Global Risk—Operational Risk—Cybersecurity Risk” below.",
      "prior_body": "Citi’s computer systems, software and networks are subject to ongoing attempted cyberattacks, such as unauthorized access, loss or destruction of data (including confidential client information), account takeovers, disruptions of service, phishing, malware, ransomware, computer viruses or other malicious code and other similar events. These threats can arise from external parties, including cyber criminals, cyber terrorists, hacktivists (individuals or groups using cyberattacks to promote a political or social agenda) and nation-state actors, as well as insiders who knowingly or unknowingly engage in or enable malicious cyber activities. For example, nation-state actors have recently targeted critical U.S. infrastructure with cyberattacks. Citi develops its own software and relies on third-party applications and software, which are susceptible to vulnerability exploitations. Software leveraged in financial services and other industries continues to be impacted by an increasing number of zero-day vulnerabilities, thus increasing inherent cyber risk to Citi. The increasing use of mobile and other digital banking platforms and services, cloud technologies, new and emerging technologies (such as AI) and connectivity solutions to facilitate remote working for Citi’s employees all increase Citi’s exposure to cybersecurity risks. Citi is also susceptible to cyberattacks given, among other things, its size and scale, high-profile brand, global footprint and prominent role in the financial system, as well as the ongoing wind-down of its 57 57 57 businesses in Russia (see the emerging markets risk factor and “Managing Global Risk—Other Risks—Country Risk—Russia” below). Additionally, Citi continues to operate in multiple jurisdictions in the midst of geopolitical unrest or uncertainties, including the Russia–Ukraine war and the conflicts in the Middle East, which could expose Citi to heightened risk of insider threat, cyber threats from nation-state actors, hacktivism or other cyber incidents. Citi continues to experience increased exposure to cyberattacks through third parties, in part because financial institutions are becoming increasingly interconnected with central agents, exchanges and clearing houses. Third parties with which Citi does business, as well as retailers and other third parties with which Citi’s customers do business, and any such third parties’ downstream service providers, also pose cybersecurity risks, particularly where activities of customers are beyond Citi’s security and control systems. For example, Citi outsources certain functions, such as processing customer credit card transactions, uploading content on customer-facing websites and developing software for new products and services. These relationships allow for the storage and processing of customer information by third-party hosting of, or access to, Citi websites. This could lead to compromise or the potential to introduce vulnerable or malicious code, resulting in security breaches or business disruptions impacting Citi customers, employees or operations. While many of Citi’s agreements with third parties include indemnification provisions, Citi may not be able to recover sufficiently under these provisions, or at all, to adequately offset any losses and other adverse impacts Citi may incur from third-party cyber incidents. Citi and some of its third-party partners have been subjected to attempted and sometimes successful cyberattacks over the last several years, including (i) denial of service attacks, which attempt to interrupt service to clients and customers; (ii) hacking and malicious software installations intended to gain unauthorized access to information systems or to disrupt those systems and/or impact availability or privacy of confidential data, with objectives including, but not limited to, extortion payments or causing reputational damage; (iii) data breaches due to unauthorized access to customer account or other data; and (iv) malicious software attacks on client systems, in attempts to gain unauthorized access to Citi systems or client data under the guise of normal client transactions. While Citi’s monitoring and protection services have historically generally succeeded in detecting, thwarting and/or responding to attacks targeting its systems before they become significant, certain past incidents resulted in limited losses, as well as increases in expenditures to monitor against the threat of similar future cyber incidents. There can be no assurance that such cyber incidents will not occur again, and they could occur more frequently, via novel tactics, including leveraging of tools made possible by emerging technologies, and on a more significant scale. Despite the significant resources Citi allocates to implement, maintain, monitor and regularly upgrade its systems and networks with measures such as intrusion detection and prevention systems and firewalls to safeguard critical business applications, there is no guarantee that these measures or any other measures can provide sufficient security. Because the techniques used to initiate cyberattacks change frequently or, in some cases, are not recognized until launched or even later, Citi may be unable to implement effective preventive measures or otherwise proactively address these methods. In addition, cyber threats and cyberattack techniques change, develop and evolve rapidly, including from emerging technologies such as AI, cloud computing and quantum computing. Given the frequency and sophistication of cyberattacks, the determination of the severity and potential impact of a cyber incident may not become apparent for a substantial period of time following detection of the incident. Also, while Citi strives to implement measures to reduce the exposure resulting from outsourcing risks, such as performing security control assessments of third-party vendors and limiting third-party access to the least privileged level necessary to perform job functions, these measures cannot prevent all third-party-related cyberattacks or data breaches. In addition, the risk of insider threats may continue to be elevated in the near term due to Citi’s recent overall simplification initiatives, including streamlining its global staff functions. Cyber incidents can result in the disclosure of personal, confidential or proprietary customer, client or employee information; damage to Citi’s reputation with its clients, other counterparties and the market; customer dissatisfaction; and additional costs to Citi, including expenses such as repairing or replacing systems, replacing customer payment cards, credit monitoring or adding new personnel or protection technologies. Cyber incidents can also result in regulatory penalties, loss of revenues, deposit flight, exposure to litigation and regulatory action and other financial losses, including loss of funds to both Citi and its clients and customers, and disruption to Citi’s operational systems (see the operational processes and systems risk factor above). Moreover, the increasing risk of cyber incidents has resulted in increased legislative and regulatory action on cybersecurity, including, among other things, scrutiny of firms’ cybersecurity protection processes and services, laws and regulations to enhance protection of consumers’ personal data and mandated disclosure on cybersecurity matters.While Citi maintains insurance coverage that may, subject to policy terms and conditions including significant self-insured deductibles, cover certain aspects of cyber risks, such insurance coverage may be insufficient to cover all losses and may not take into account reputational harm, the costs of which are impossible to quantify. For additional information about Citi’s management of cybersecurity risk, see “Managing Global Risk—Operational Risk—Cybersecurity Risk” below. Changes or Errors in Accounting Assumptions, Judgments or Estimates, or the Application of Certain Accounting Principles, Could Result in Significant Losses or Other Adverse Impacts.U.S. GAAP requires Citi to use certain assumptions, judgments and estimates in preparing its financial statements, including, among other items, the estimate of the ACL; reserves related to litigation, regulatory and tax matters; valuation of DTAs; the fair values of certain assets and liabilities; and the assessment of goodwill and other assets for businesses in Russia (see the emerging markets risk factor and “Managing Global Risk—Other Risks—Country Risk—Russia” below). Additionally, Citi continues to operate in multiple jurisdictions in the midst of geopolitical unrest or uncertainties, including the Russia–Ukraine war and the conflicts in the Middle East, which could expose Citi to heightened risk of insider threat, cyber threats from nation-state actors, hacktivism or other cyber incidents. Citi continues to experience increased exposure to cyberattacks through third parties, in part because financial institutions are becoming increasingly interconnected with central agents, exchanges and clearing houses. Third parties with which Citi does business, as well as retailers and other third parties with which Citi’s customers do business, and any such third parties’ downstream service providers, also pose cybersecurity risks, particularly where activities of customers are beyond Citi’s security and control systems. For example, Citi outsources certain functions, such as processing customer credit card transactions, uploading content on customer-facing websites and developing software for new products and services. These relationships allow for the storage and processing of customer information by third-party hosting of, or access to, Citi websites. This could lead to compromise or the potential to introduce vulnerable or malicious code, resulting in security breaches or business disruptions impacting Citi customers, employees or operations. While many of Citi’s agreements with third parties include indemnification provisions, Citi may not be able to recover sufficiently under these provisions, or at all, to adequately offset any losses and other adverse impacts Citi may incur from third-party cyber incidents. Citi and some of its third-party partners have been subjected to attempted and sometimes successful cyberattacks over the last several years, including (i) denial of service attacks, which attempt to interrupt service to clients and customers; (ii) hacking and malicious software installations intended to gain unauthorized access to information systems or to disrupt those systems and/or impact availability or privacy of confidential data, with objectives including, but not limited to, extortion payments or causing reputational damage; (iii) data breaches due to unauthorized access to customer account or other data; and (iv) malicious software attacks on client systems, in attempts to gain unauthorized access to Citi systems or client data under the guise of normal client transactions. While Citi’s monitoring and protection services have historically generally succeeded in detecting, thwarting and/or responding to attacks targeting its systems before they become significant, certain past incidents resulted in limited losses, as well as increases in expenditures to monitor against the threat of similar future cyber incidents. There can be no assurance that such cyber incidents will not occur again, and they could occur more frequently, via novel tactics, including leveraging of tools made possible by emerging technologies, and on a more significant scale. Despite the significant resources Citi allocates to implement, maintain, monitor and regularly upgrade its systems and networks with measures such as intrusion detection and prevention systems and firewalls to safeguard critical business applications, there is no guarantee that these businesses in Russia (see the emerging markets risk factor and “Managing Global Risk—Other Risks—Country Risk—Russia” below). Additionally, Citi continues to operate in multiple jurisdictions in the midst of geopolitical unrest or uncertainties, including the Russia–Ukraine war and the conflicts in the Middle East, which could expose Citi to heightened risk of insider threat, cyber threats from nation-state actors, hacktivism or other cyber incidents. Citi continues to experience increased exposure to cyberattacks through third parties, in part because financial institutions are becoming increasingly interconnected with central agents, exchanges and clearing houses. Third parties with which Citi does business, as well as retailers and other third parties with which Citi’s customers do business, and any such third parties’ downstream service providers, also pose cybersecurity risks, particularly where activities of customers are beyond Citi’s security and control systems. For example, Citi outsources certain functions, such as processing customer credit card transactions, uploading content on customer-facing websites and developing software for new products and services. These relationships allow for the storage and processing of customer information by third-party hosting of, or access to, Citi websites. This could lead to compromise or the potential to introduce vulnerable or malicious code, resulting in security breaches or business disruptions impacting Citi customers, employees or operations. While many of Citi’s agreements with third parties include indemnification provisions, Citi may not be able to recover sufficiently under these provisions, or at all, to adequately offset any losses and other adverse impacts Citi may incur from third-party cyber incidents. Citi and some of its third-party partners have been subjected to attempted and sometimes successful cyberattacks over the last several years, including (i) denial of service attacks, which attempt to interrupt service to clients and customers; (ii) hacking and malicious software installations intended to gain unauthorized access to information systems or to disrupt those systems and/or impact availability or privacy of confidential data, with objectives including, but not limited to, extortion payments or causing reputational damage; (iii) data breaches due to unauthorized access to customer account or other data; and (iv) malicious software attacks on client systems, in attempts to gain unauthorized access to Citi systems or client data under the guise of normal client transactions. While Citi’s monitoring and protection services have historically generally succeeded in detecting, thwarting and/or responding to attacks targeting its systems before they become significant, certain past incidents resulted in limited losses, as well as increases in expenditures to monitor against the threat of similar future cyber incidents. There can be no assurance that such cyber incidents will not occur again, and they could occur more frequently, via novel tactics, including leveraging of tools made possible by emerging technologies, and on a more significant scale. Despite the significant resources Citi allocates to implement, maintain, monitor and regularly upgrade its systems and networks with measures such as intrusion detection and prevention systems and firewalls to safeguard critical business applications, there is no guarantee that these measures or any other measures can provide sufficient security. Because the techniques used to initiate cyberattacks change frequently or, in some cases, are not recognized until launched or even later, Citi may be unable to implement effective preventive measures or otherwise proactively address these methods. In addition, cyber threats and cyberattack techniques change, develop and evolve rapidly, including from emerging technologies such as AI, cloud computing and quantum computing. Given the frequency and sophistication of cyberattacks, the determination of the severity and potential impact of a cyber incident may not become apparent for a substantial period of time following detection of the incident. Also, while Citi strives to implement measures to reduce the exposure resulting from outsourcing risks, such as performing security control assessments of third-party vendors and limiting third-party access to the least privileged level necessary to perform job functions, these measures cannot prevent all third-party-related cyberattacks or data breaches. In addition, the risk of insider threats may continue to be elevated in the near term due to Citi’s recent overall simplification initiatives, including streamlining its global staff functions. Cyber incidents can result in the disclosure of personal, confidential or proprietary customer, client or employee information; damage to Citi’s reputation with its clients, other counterparties and the market; customer dissatisfaction; and additional costs to Citi, including expenses such as repairing or replacing systems, replacing customer payment cards, credit monitoring or adding new personnel or protection technologies. Cyber incidents can also result in regulatory penalties, loss of revenues, deposit flight, exposure to litigation and regulatory action and other financial losses, including loss of funds to both Citi and its clients and customers, and disruption to Citi’s operational systems (see the operational processes and systems risk factor above). Moreover, the increasing risk of cyber incidents has resulted in increased legislative and regulatory action on cybersecurity, including, among other things, scrutiny of firms’ cybersecurity protection processes and services, laws and regulations to enhance protection of consumers’ personal data and mandated disclosure on cybersecurity matters.While Citi maintains insurance coverage that may, subject to policy terms and conditions including significant self-insured deductibles, cover certain aspects of cyber risks, such insurance coverage may be insufficient to cover all losses and may not take into account reputational harm, the costs of which are impossible to quantify. For additional information about Citi’s management of cybersecurity risk, see “Managing Global Risk—Operational Risk—Cybersecurity Risk” below. Changes or Errors in Accounting Assumptions, Judgments or Estimates, or the Application of Certain Accounting Principles, Could Result in Significant Losses or Other Adverse Impacts.U.S. GAAP requires Citi to use certain assumptions, judgments and estimates in preparing its financial statements, including, among other items, the estimate of the ACL; reserves related to litigation, regulatory and tax matters; valuation of DTAs; the fair values of certain assets and liabilities; and the assessment of goodwill and other assets for measures or any other measures can provide sufficient security. Because the techniques used to initiate cyberattacks change frequently or, in some cases, are not recognized until launched or even later, Citi may be unable to implement effective preventive measures or otherwise proactively address these methods. In addition, cyber threats and cyberattack techniques change, develop and evolve rapidly, including from emerging technologies such as AI, cloud computing and quantum computing. Given the frequency and sophistication of cyberattacks, the determination of the severity and potential impact of a cyber incident may not become apparent for a substantial period of time following detection of the incident. Also, while Citi strives to implement measures to reduce the exposure resulting from outsourcing risks, such as performing security control assessments of third-party vendors and limiting third-party access to the least privileged level necessary to perform job functions, these measures cannot prevent all third-party-related cyberattacks or data breaches. In addition, the risk of insider threats may continue to be elevated in the near term due to Citi’s recent overall simplification initiatives, including streamlining its global staff functions. Cyber incidents can result in the disclosure of personal, confidential or proprietary customer, client or employee information; damage to Citi’s reputation with its clients, other counterparties and the market; customer dissatisfaction; and additional costs to Citi, including expenses such as repairing or replacing systems, replacing customer payment cards, credit monitoring or adding new personnel or protection technologies. Cyber incidents can also result in regulatory penalties, loss of revenues, deposit flight, exposure to litigation and regulatory action and other financial losses, including loss of funds to both Citi and its clients and customers, and disruption to Citi’s operational systems (see the operational processes and systems risk factor above). Moreover, the increasing risk of cyber incidents has resulted in increased legislative and regulatory action on cybersecurity, including, among other things, scrutiny of firms’ cybersecurity protection processes and services, laws and regulations to enhance protection of consumers’ personal data and mandated disclosure on cybersecurity matters. While Citi maintains insurance coverage that may, subject to policy terms and conditions including significant self-insured deductibles, cover certain aspects of cyber risks, such insurance coverage may be insufficient to cover all losses and may not take into account reputational harm, the costs of which are impossible to quantify. For additional information about Citi’s management of cybersecurity risk, see “Managing Global Risk—Operational Risk—Cybersecurity Risk” below."
    },
    {
      "status": "MODIFIED",
      "current_title": "ACLL by type at end of year(10)",
      "prior_title": "ACLL by type at end of year(11)",
      "similarity_score": 0.846,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"See “Accounting Changes” in Note 1.\"",
        "Reworded sentence: \"(8)December 31, 2025, 2024, 2023, 2022 and 2021 exclude $6.9 billion, $8.0 billion, $7.6 billion, $5.4 billion and $6.1 billion, respectively, of loans that are carried at fair value.\""
      ],
      "current_body": "(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 “Accounting Changes” in Note 1. (2)Includes all adjustments to the allowance for credit losses, such as changes in the allowance from acquisitions, dispositions, securitizations, FX translation, purchase accounting adjustments, etc. (3)2025 includes an approximate $29 million reclass related to Citi’s agreement to sell its Poland consumer banking business. That ACLL was transferred to Other assets. 2025 also includes an increase of approximately $273 million related to FX translation. (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)December 31, 2025, 2024, 2023, 2022 and 2021 exclude $6.9 billion, $8.0 billion, $7.6 billion, $5.4 billion and $6.1 billion, respectively, of loans that are carried at fair value. (9)Represents additional credit reserves recorded as Other liabilities on the Consolidated Balance Sheet. (10)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. 85 85 85",
      "prior_body": "(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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Details of Credit Loss Experience",
      "prior_title": "Details of Credit Loss Experience",
      "similarity_score": 0.844,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"In millions of dollars20252024202320222021Allowance for credit losses on loans (ACLL) at beginning of year$18,574 $18,145 $16,974 $16,455 $24,956 Adjustments to opening balance:Financial instruments—TDRs and vintage disclosures(1)— — (352)— — Adjusted ACLL at beginning of year$18,574 $18,145 $16,622 $16,455 $24,956 Provision for credit losses on loans (PCLL)Consumer$8,690 $9,459 $7,665 $4,128 $(1,159)Corporate807 267 121 617 (1,944)Total$9,497 $9,726 $7,786 $4,745 $(3,103)Gross credit losses on loansConsumerIn U.S.\"",
        "Reworded sentence: \"— 1 3 1 — Total$2,002 $1,694 $1,444 $1,367 $1,825 Financial instruments—TDRs and vintage disclosures(1) 84 84 84 Net credit losses on loans (NCLs)In U.S.\""
      ],
      "current_body": "In millions of dollars20252024202320222021Allowance for credit losses on loans (ACLL) at beginning of year$18,574 $18,145 $16,974 $16,455 $24,956 Adjustments to opening balance:Financial instruments—TDRs and vintage disclosures(1)— — (352)— — Adjusted ACLL at beginning of year$18,574 $18,145 $16,622 $16,455 $24,956 Provision for credit losses on loans (PCLL)Consumer$8,690 $9,459 $7,665 $4,128 $(1,159)Corporate807 267 121 617 (1,944)Total$9,497 $9,726 $7,786 $4,745 $(3,103)Gross credit losses on loansConsumerIn U.S. offices$9,203 $8,989 $6,339 $3,944 $4,076 In offices outside the U.S. 1,454 1,212 1,214 934 2,144 CorporateCommercial and industrial, and otherIn U.S. offices125 149 129 110 228 In offices outside the U.S. 286 170 119 81 259 Loans to financial institutionsIn U.S. offices— — 4 — 1 In offices outside the U.S. 9 10 36 80 1 Mortgage and real estateIn U.S. offices8 144 31 — 10 In offices outside the U.S.14 20 9 7 1 Total$11,099 $10,694 $7,881 $5,156 $6,720 Gross recoveries on loansConsumerIn U.S. offices$1,752 $1,406 $1,124 $1,045 $1,215 In offices outside the U.S. 173 192 242 222 496 CorporateCommercial and industrial, and otherIn U.S. offices37 51 38 44 57 In offices outside the U.S. 36 35 37 46 54 Loans to financial institutionsIn U.S. offices— 5 — 6 2 In offices outside the U.S. 4 4 — 3 1 Mortgage and real estateIn U.S. offices— — — — — In offices outside the U.S. — 1 3 1 — Total$2,002 $1,694 $1,444 $1,367 $1,825 Financial instruments—TDRs and vintage disclosures(1) 84 84 84 Net credit losses on loans (NCLs)In U.S. offices$7,547 $7,820 $5,341 $2,959 $3,041 In offices outside the U.S. 1,550 1,180 1,096 830 1,854 Total$9,097 $9,000 $6,437 $3,789 $4,895 Other—net(2)(3)(4)(5)(6)(7)$273 $(297)$174 $(437)$(503)Allowance for credit losses on loans (ACLL) at end of year$19,247 $18,574 $18,145 $16,974 $16,455 ACLL as a percentage of EOP loans(8)2.58 %2.71 %2.66 %2.60 %2.49 %Allowance for credit losses on unfunded lending commitments (ACLUC)(9)$1,833 $1,601 $1,728 $2,151 $1,871 Total ACLL and ACLUC$21,080 $20,175 $19,873 $19,125 $18,326 Net consumer credit losses on loans$8,732 $8,603 $6,187 $3,611 $4,509 As a percentage of average consumer loans2.22 %2.24 %1.66 %1.02 %1.20 %Net corporate credit losses on loans$365 $397 $250 $178 $386 As a percentage of average corporate loans0.11 %0.13 %0.09 %0.06 %0.13 %ACLL by type at end of year(10)Consumer$16,194 $16,018 $15,431 $14,119 $14,040 Corporate3,053 2,556 2,714 2,855 2,415 Total$19,247 $18,574 $18,145 $16,974 $16,455 Other—net(2)(3)(4)(5)(6)(7) ACLL as a percentage of EOP loans(8) Allowance for credit losses on unfunded lending commitments (ACLUC)(9)",
      "prior_body": "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)"
    },
    {
      "status": "MODIFIED",
      "current_title": "High-Quality Liquid Assets (HQLA)",
      "prior_title": "High-Quality Liquid Assets (HQLA)",
      "similarity_score": 0.844,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"31, 2024Available cash$267.2 $270.1 $227.1 $7.3 $8.6 $7.7 $274.5 $278.7 $234.8 U.S.\"",
        "Reworded sentence: \"Citigroup’s average HQLA increased quarter-over-quarter as of the fourth quarter of 2025, primarily driven by an increase in average deposits in Services.\"",
        "Reworded sentence: \"31, 2024HQLA$607.2 $588.4 $558.4 Net outflows529.3 510.5 480.8 LCR115 %115 %116 %HQLA in excess of net outflows$77.9 $77.9 $77.6 Note: The amounts are presented on an average basis.As of December 31, 2025, Citigroup’s average LCR remained unchanged from the quarter ended September 30, 2025.\"",
        "Reworded sentence: \"Citigroup’s average HQLA increased quarter-over-quarter as of the fourth quarter of 2025, primarily driven by an increase in average deposits in Services.\"",
        "Reworded sentence: \"Citigroup’s average HQLA increased quarter-over-quarter as of the fourth quarter of 2025, primarily driven by an increase in average deposits in Services.\""
      ],
      "current_body": "CitibankCiti non-bank and other entitiesTotalIn billions of dollarsDec. 31, 2025Sep. 30, 2025Dec. 31, 2024Dec. 31, 2025Sep. 30, 2025Dec. 31, 2024Dec. 31, 2025Sep. 30, 2025Dec. 31, 2024Available cash$267.2 $270.1 $227.1 $7.3 $8.6 $7.7 $274.5 $278.7 $234.8 U.S. sovereign179.9 161.3 191.2 52.3 50.5 46.8 232.2 211.8 238.0 U.S. agency/agency MBS32.7 32.2 26.6 1.6 1.8 2.1 34.3 34.0 28.7 Foreign government debt(1)49.7 53.0 44.2 16.5 10.9 12.6 66.2 63.9 56.8 Other investment grade— — — — — 0.1 — — 0.1 Total HQLA (AVG)$529.5 $516.6 $489.1 $77.7 $71.8 $69.3 $607.2 $588.4 $558.4 U.S. sovereign U.S. agency/agency MBS Foreign government debt(1) Other investment grade (1) Foreign government debt includes securities issued or guaranteed by foreign sovereigns, agencies and multilateral development banks. Foreign government debt securities are held largely to support local liquidity requirements and Citi’s local franchises and principally include government bonds from Japan, Mexico, Korea, the United Kingdom and China. 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 2025, primarily driven by an increase in average deposits in Services. As of December 31, 2025, Citigroup had approximately $1.0 trillion of available liquidity resources to support client and business needs, including end-of-period HQLA ($610 billion) included in Citi’s LCR calculation; additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($275 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 ($164 billion).Short-Term Liquidity Measurement: Liquidity Coverage Ratio (LCR)Citi monitors its liquidity by reference to the LCR in addition to internal 30-day liquidity stress testing performed for Citi’s major entities, operating subsidiaries and countries.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, 2025Sep. 30, 2025Dec. 31, 2024HQLA$607.2 $588.4 $558.4 Net outflows529.3 510.5 480.8 LCR115 %115 %116 %HQLA in excess of net outflows$77.9 $77.9 $77.6 Note: The amounts are presented on an average basis.As of December 31, 2025, Citigroup’s average LCR remained unchanged from the quarter ended September 30, 2025. The increase in average HQLA was offset by an increase in net outflows from unsecured and secured wholesale funding.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 U.S. NSFR rules. 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, 2025, 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, 2025 and September 30, 2025, 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). 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 2025, primarily driven by an increase in average deposits in Services. As of December 31, 2025, Citigroup had approximately $1.0 trillion of available liquidity resources to support client and business needs, including end-of-period HQLA ($610 billion) included in Citi’s LCR calculation; additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($275 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 ($164 billion).Short-Term Liquidity Measurement: Liquidity Coverage Ratio (LCR)Citi monitors its liquidity by reference to the LCR in addition to internal 30-day liquidity stress testing performed for Citi’s major entities, operating subsidiaries and countries.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 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 2025, primarily driven by an increase in average deposits in Services. As of December 31, 2025, Citigroup had approximately $1.0 trillion of available liquidity resources to support client and business needs, including end-of-period HQLA ($610 billion) included in Citi’s LCR calculation; additional unencumbered HQLA, including excess liquidity held at bank entities that is non-transferable to other entities within Citigroup ($275 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 ($164 billion).",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "2025 vs. 2024",
      "prior_title": "2024 vs. 2023",
      "similarity_score": 0.843,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"2023 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 $106 million, $94 million and $101 million for 2025, 2024 and 2023, respectively.\""
      ],
      "current_body": "Change 2024 vs. 2023 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 $106 million, $94 million and $101 million for 2025, 2024 and 2023, 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. 102 102 102",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "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.",
      "prior_title": "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.",
      "similarity_score": 0.836,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"At December 31, 2025, Citi’s net DTAs were $29.5 billion, net of a valuation allowance of $5.0 billion, of which $13.1 billion was deducted from Citi’s CET1 Capital under the U.S.\"",
        "Reworded sentence: \"Moreover, these tax laws and related regulations may change, which could result in additional tax liability for Citi.\"",
        "Reworded sentence: \"Citi’s interpretations or application of the tax laws, including with respect to withholding, stamp, service and other non-income taxes, as well as in connection with asset dispositions, divestitures or similar transactions, 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.\"",
        "Reworded sentence: \"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 rights; 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.\"",
        "Reworded sentence: \"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 2025 resolution plan, which can be found on the FRB’s and FDIC’s websites) would remain operational outside of any resolution or insolvency proceedings.\""
      ],
      "current_body": "At December 31, 2025, Citi’s net DTAs were $29.5 billion, net of a valuation allowance of $5.0 billion, of which $13.1 billion was deducted from Citi’s CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $10.8 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $3.1 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $0.8 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital. Citi’s ability to realize its DTAs will primarily be dependent upon its 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. 51 51 51 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 Is Subject to Complex Tax Laws, Which May Change, and Citi’s Interpretation or Application of These Complex Tax Laws 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 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. Moreover, these tax laws and related regulations may change, which could result in additional tax liability for Citi. Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding 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, as well as in connection with asset dispositions, divestitures or similar transactions, 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 how Citi accrues for potential losses from tax matters.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, 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 constituted an aggregate of approximately 12% of Citi’s revenues in 2025 (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 rights; 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.Every two years, 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 2025 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 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 Is Subject to Complex Tax Laws, Which May Change, and Citi’s Interpretation or Application of These Complex Tax Laws 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 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. Moreover, these tax laws and related regulations may change, which could result in additional tax liability for Citi. Additionally, Citi is subject to litigation or examinations with U.S. and non-U.S. tax authorities regarding 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, as well as in connection with asset dispositions, divestitures or similar transactions, 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 how Citi accrues for potential losses from tax matters.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, 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 constituted an aggregate of approximately 12% of Citi’s revenues in 2025 (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; For additional information on Citi’s DTAs, including FTCs, see “Significant Accounting Policies and Significant Estimates—Income Taxes” below and Notes 1 and 10.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Mexico Consumer",
      "prior_title": "Mexico Consumer",
      "similarity_score": 0.832,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Mexico Consumer provides credit cards, consumer mortgages and small business and personal loans.\"",
        "Reworded sentence: \"As of December 31, 2025, approximately 40% of Mexico Consumer’s EOP loans consisted of credit card loans, which largely drives the overall credit performance of the Mexico Consumer portfolios, as the cards net credit losses represented approximately 60% of total Mexico Consumer net credit losses for the fourth quarter of 2025.\"",
        "Reworded sentence: \"31, 2024≥ 74055 %55 %56 %660–73933 34 33 < 66012 11 11 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec.\""
      ],
      "current_body": "Mexico Consumer 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, 2025, approximately 40% of Mexico Consumer’s EOP loans consisted of credit card loans, which largely drives the overall credit performance of the Mexico Consumer portfolios, as the cards net credit losses represented approximately 60% of total Mexico Consumer net credit losses for the fourth quarter of 2025. As presented in the chart above, the fourth quarter of 2025 net credit loss rate in Mexico Consumer increased quarter-over-quarter and year-over-year, driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows. The 90+ days past due delinquency rate increased quarter-over-quarter, largely driven by seasonality and the ongoing normalization of loss and delinquency rates from post-pandemic lows. The 90+ days past due delinquency rate increased year-over-year, primarily driven by the ongoing normalization of loss and delinquency rates from post-pandemic lows. For additional details on provisions, loan delinquency and other information for Citi’s consumer loan portfolios, see the results of operations for USPB, Wealth and All Other 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, 2025Sep. 30, 2025Dec. 31, 2024≥ 74055 %55 %56 %660–73933 34 33 < 66012 11 11 Total100 %100 %100 %Retail ServicesFICO distribution(1)Dec. 31, 2025Sep. 30, 2025Dec. 31, 2024≥ 74037 %36 %36 %660–73941 41 41 < 66022 23 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 remained largely unchanged 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.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Loans Outstanding",
      "prior_title": "Loans Outstanding",
      "similarity_score": 0.83,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"December 31,In millions of dollars20252024202320222021Consumer loansIn North America offices(1)Residential first mortgages(2)$119,389 $114,593 $108,711 $96,039 $83,361 Home equity loans(2)2,872 3,141 3,592 4,580 5,745 Credit cards173,656 171,059 164,720 150,643 133,868 Personal, small business and other33,211 33,155 36,135 37,752 40,713 Total$329,128 $321,948 $313,158 $289,014 $263,687 In offices outside North America(1)Residential mortgages(2)$24,041 $24,456 $26,426 $28,114 $37,889 Credit cards14,701 12,927 14,233 12,955 17,808 Personal, small business and other40,320 33,995 35,380 37,984 57,150 Total$79,062 $71,378 $76,039 $79,053 $112,847 Consumer loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(3)$408,190 $393,326 $389,197 $368,067 $376,534 Unallocated portfolio-layer cumulative basis adjustments$343 $(224)$— $— $— Consumer loans, net of unearned income(3)$408,533 $393,102 $389,197 $368,067 $376,534 Corporate loansIn North America offices(1)Commercial and industrial$57,406 $57,730 $61,008 $56,176 $48,364 Financial institutions72,154 41,815 39,393 43,399 49,804 Mortgage and real estate(2)17,931 18,411 17,813 17,829 15,965 Installment and other(4)23,104 25,529 23,335 23,767 20,143 Lease financing72 235 227 308 415 Total$170,667 $143,720 $141,776 $141,479 $134,691 In offices outside North America(1)Commercial and industrial$96,886 $92,856 $93,402 $93,967 $102,735 Financial institutions27,054 27,276 26,143 21,931 22,158 Mortgage and real estate(2)9,856 8,136 7,197 4,179 4,374 Installment and other(4)34,100 25,800 27,907 23,347 22,812 Lease financing47 40 48 46 40 Governments and official institutions5,070 3,630 3,599 4,205 4,423 Total$173,013 $157,738 $158,296 $147,675 $156,542 Corporate loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(5)$343,680 $301,458 $300,072 $289,154 $291,233 Unallocated portfolio-layer cumulative basis adjustments$17 $(72)$93 $— $— Corporate loans, net of unearned income(5)$343,697 $301,386 $300,165 $289,154 $291,233 Total loans—net of unearned income$752,230 $694,488 $689,362 $657,221 $667,767 Allowance for credit losses on loans (ACLL)(19,247)(18,574)(18,145)(16,974)(16,455)Total loans—net of unearned income and ACLL$732,983 $675,914 $671,217 $640,247 $651,312 ACLL as a percentage of total loans—net of unearned income(6)2.58 %2.71 %2.66 %2.60 %2.49 %ACLL for consumer loan losses as a percentage of total consumer loans—net of unearned income(6)3.96 %4.08 %3.97 %3.84 %3.73 %ACLL for corporate loan losses as a percentage of total corporate loans—net of unearned income(6)0.91 %0.87 %0.93 %1.01 %0.85 % In North America offices(1) Residential first mortgages(2) Home equity loans(2) In offices outside North America(1) Residential mortgages(2) Consumer loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(3) Unallocated portfolio-layer cumulative basis adjustments\""
      ],
      "current_body": "December 31,In millions of dollars20252024202320222021Consumer loansIn North America offices(1)Residential first mortgages(2)$119,389 $114,593 $108,711 $96,039 $83,361 Home equity loans(2)2,872 3,141 3,592 4,580 5,745 Credit cards173,656 171,059 164,720 150,643 133,868 Personal, small business and other33,211 33,155 36,135 37,752 40,713 Total$329,128 $321,948 $313,158 $289,014 $263,687 In offices outside North America(1)Residential mortgages(2)$24,041 $24,456 $26,426 $28,114 $37,889 Credit cards14,701 12,927 14,233 12,955 17,808 Personal, small business and other40,320 33,995 35,380 37,984 57,150 Total$79,062 $71,378 $76,039 $79,053 $112,847 Consumer loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(3)$408,190 $393,326 $389,197 $368,067 $376,534 Unallocated portfolio-layer cumulative basis adjustments$343 $(224)$— $— $— Consumer loans, net of unearned income(3)$408,533 $393,102 $389,197 $368,067 $376,534 Corporate loansIn North America offices(1)Commercial and industrial$57,406 $57,730 $61,008 $56,176 $48,364 Financial institutions72,154 41,815 39,393 43,399 49,804 Mortgage and real estate(2)17,931 18,411 17,813 17,829 15,965 Installment and other(4)23,104 25,529 23,335 23,767 20,143 Lease financing72 235 227 308 415 Total$170,667 $143,720 $141,776 $141,479 $134,691 In offices outside North America(1)Commercial and industrial$96,886 $92,856 $93,402 $93,967 $102,735 Financial institutions27,054 27,276 26,143 21,931 22,158 Mortgage and real estate(2)9,856 8,136 7,197 4,179 4,374 Installment and other(4)34,100 25,800 27,907 23,347 22,812 Lease financing47 40 48 46 40 Governments and official institutions5,070 3,630 3,599 4,205 4,423 Total$173,013 $157,738 $158,296 $147,675 $156,542 Corporate loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(5)$343,680 $301,458 $300,072 $289,154 $291,233 Unallocated portfolio-layer cumulative basis adjustments$17 $(72)$93 $— $— Corporate loans, net of unearned income(5)$343,697 $301,386 $300,165 $289,154 $291,233 Total loans—net of unearned income$752,230 $694,488 $689,362 $657,221 $667,767 Allowance for credit losses on loans (ACLL)(19,247)(18,574)(18,145)(16,974)(16,455)Total loans—net of unearned income and ACLL$732,983 $675,914 $671,217 $640,247 $651,312 ACLL as a percentage of total loans—net of unearned income(6)2.58 %2.71 %2.66 %2.60 %2.49 %ACLL for consumer loan losses as a percentage of total consumer loans—net of unearned income(6)3.96 %4.08 %3.97 %3.84 %3.73 %ACLL for corporate loan losses as a percentage of total corporate loans—net of unearned income(6)0.91 %0.87 %0.93 %1.01 %0.85 % In North America offices(1) Residential first mortgages(2) Home equity loans(2) In offices outside North America(1) Residential mortgages(2) Consumer loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(3) Unallocated portfolio-layer cumulative basis adjustments",
      "prior_body": "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)"
    },
    {
      "status": "MODIFIED",
      "current_title": "Citi’s Performance Could Be Negatively Impacted if It Is Not Able to Hire and Retain Qualified Employees.",
      "prior_title": "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.",
      "similarity_score": 0.821,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Citi’s performance and the performance of its individual businesses largely depend on the talents and efforts of its highly qualified employees.\"",
        "Reworded sentence: \"For example, the competition for talent continues to be particularly intense due to various factors, such as changes in worker expectations, concerns and preferences.\"",
        "Reworded sentence: \"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 and its reputation.\""
      ],
      "current_body": "Citi’s performance and the performance of its individual businesses largely depend on the talents and efforts of its highly qualified employees. Specifically, Citi’s continued ability to compete in each of its lines of business, grow and manage its businesses effectively, as well as to execute its strategic 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 achievement of its 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. 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. 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 and its reputation. For information on Citi’s employee and workforce management, see “Human Capital Resources and Management” below.Citi Faces Potential Disruptions from an EvolvingBusiness Environment, Including Competitive Challenges and Emerging Technologies.Citi operates in an increasingly evolving and competitive business environment, which includes both financial and non-financial services firms, such as banks and private credit, financial technology and digital asset companies, among others.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. To the extent that Citi is not able to compete effectively with other financial services companies, including private credit, financial technology and digital asset 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 competitive risks, see the co-branding and private label credit cards and qualified employees risk factors above and the AI risk factor and “Supervision, Regulation and Other—Competition” below. 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. 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. 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. qualified employees, Citi’s performance, including its competitive position, the achievement of its 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. 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. 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 and its reputation. For information on Citi’s employee and workforce management, see “Human Capital Resources and Management” below.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Business Environment, Including Competitive Challenges and Emerging Technologies.",
      "prior_title": "Citi Faces Increased Competitive Challenges, Including from Financial Services and Other Companies and Emerging Technologies.",
      "similarity_score": 0.816,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Citi operates in an increasingly evolving and competitive business environment, which includes both financial and non-financial services firms, such as banks and private credit, financial technology and digital asset companies, among others.\"",
        "Reworded sentence: \"To the extent that Citi is not able to compete effectively with other financial services companies, including private credit, financial technology and digital asset 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.\"",
        "Reworded sentence: \"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.\"",
        "Reworded sentence: \"53 53 53 Additionally, emerging technologies have the potential to accelerate disruption and intensify competition in the financial services industry.\"",
        "Reworded sentence: \"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.\""
      ],
      "current_body": "Citi operates in an increasingly evolving and competitive business environment, which includes both financial and non-financial services firms, such as banks and private credit, financial technology and digital asset companies, among others. 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. To the extent that Citi is not able to compete effectively with other financial services companies, including private credit, financial technology and digital asset 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 competitive risks, see the co-branding and private label credit cards and qualified employees risk factors above and the AI risk factor and “Supervision, Regulation and Other—Competition” below. 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. 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. 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. 53 53 53 Additionally, emerging technologies have the potential to accelerate disruption and intensify competition in the financial services industry. These emerging technologies, such as artificial intelligence (AI) and digital assets (including tokenized deposits, cryptocurrencies, stablecoins and other assets and products that use distributed ledger or blockchain technology) 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 (see the AI risk factor below). Increased competition and emerging technologies 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. The U.S. administration and Congress have beensupportive of the growth and use of digital assets, includingpassing legislation such as the GENIUS Act and pursuing amore favorable regulatory approach, although the legal andregulatory landscape remains highly uncertain. As digitalassets continue to evolve, customer demand for enhancedofferings may increase. Failure to strategically adopt emergingtechnologies may result in a competitive disadvantage to Citi.Citi also may not be able to provide the same or similarproducts and services for legal or regulatory reasons, whichmay be exacerbated by rapidly evolving and conflictingregulatory requirements.Moreover, 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 AI, operational processes and systems and cybersecurity risk factors 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. 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. 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 and cybersecurity risk factors below).The Development and Use of AI by Citi and Others Present Risks to Citi’s Businesses.Citi has used AI and machine learning tools for many years and has more recently begun to broadly deploy Generative AI, including within its technology platforms and services. In the future, Citi expects to more broadly integrate Generative AI tools within its systems, businesses and functions, including advanced AI capabilities, such as autonomous agents and sophisticated user interactions, which if improperly managed, could result in increased risks and costs. While Citi has policies that govern the use of emerging technologies, including in model risk management, ineffective, inadequate or faulty Generative AI development or deployment practices by Citi or third parties, including insufficient testing and monitoring, poorly structured or manipulated prompts or insufficient or inadequate human oversight, could result in adverse consequences, such as AI algorithms that produce inaccurate or incomplete output or output based on biased, incomplete and/or inaccurate datasets, infringe on intellectual property rights of others, involve data exfiltration risks, including release of confidential or proprietary information, or cause other issues, concerns or deficiencies. The complexity of AI models, particularly Generative AI models, can make it challenging to understand why particular outputs are generated, which can increase the risk of erroneous and/or biased output and complying with regulations requiring documentation, explainability or auditability on the basis of AI-influenced decisions. Citi may also rely on AI models developed by third parties and be exposed to risks arising from their development and training methods, including potential inclusion of unauthorized material in the training data or limitations in their risk mitigation strategies, over which Citi may have limited visibility or control (see also the operational processes and systems risk factor below). While Citi may provide restrictions on use of certain data in third-party AI applications or models, a third party could breach those terms, which could expose Citi to legal and reputations risks. Citi is also exposed to risks related to the use of AI technologies by counterparties, clients and vendors, where interconnected AI systems could amplify failures and threats of cyber infiltration, as well as cause widespread disruptions. 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 exposure to cyberattacks (see the cybersecurity risk factor below), as well as disinformation and market manipulation campaigns, 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. Citi also faces competition risks to the extent that competitors may be faster and more successful in developing and deploying AI technologies to improve processes, productivity, efficiency, products and services, and thereby gain competitive advantages over Citi (see the competition risk factor above). In addition, compliance with new or changing laws, regulations or industry standards relating to AI may impose additional operational risks and costs. Failure to sufficiently manage these risks could expose Citi to adverse legal, regulatory or reputational consequences. Additionally, emerging technologies have the potential to accelerate disruption and intensify competition in the financial services industry. These emerging technologies, such as artificial intelligence (AI) and digital assets (including tokenized deposits, cryptocurrencies, stablecoins and other assets and products that use distributed ledger or blockchain technology) 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 (see the AI risk factor below). Increased competition and emerging technologies 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. The U.S. administration and Congress have beensupportive of the growth and use of digital assets, includingpassing legislation such as the GENIUS Act and pursuing amore favorable regulatory approach, although the legal andregulatory landscape remains highly uncertain. As digitalassets continue to evolve, customer demand for enhancedofferings may increase. Failure to strategically adopt emergingtechnologies may result in a competitive disadvantage to Citi.Citi also may not be able to provide the same or similarproducts and services for legal or regulatory reasons, whichmay be exacerbated by rapidly evolving and conflictingregulatory requirements.Moreover, 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 AI, operational processes and systems and cybersecurity risk factors 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. 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. 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 and cybersecurity risk factors below).The Development and Use of AI by Citi and Others Present Risks to Citi’s Businesses.Citi has used AI and machine learning tools for many years and has more recently begun to broadly deploy Generative AI, including within its technology platforms and services. In the future, Citi expects to more broadly integrate Generative AI tools within its systems, businesses and functions, including advanced AI capabilities, such as autonomous agents and sophisticated user interactions, which if improperly managed, could result in increased risks and costs. Additionally, emerging technologies have the potential to accelerate disruption and intensify competition in the financial services industry. These emerging technologies, such as artificial intelligence (AI) and digital assets (including tokenized deposits, cryptocurrencies, stablecoins and other assets and products that use distributed ledger or blockchain technology) 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 (see the AI risk factor below). Increased competition and emerging technologies 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. The U.S. administration and Congress have been supportive of the growth and use of digital assets, including passing legislation such as the GENIUS Act and pursuing a more favorable regulatory approach, although the legal and regulatory landscape remains highly uncertain. As digital assets continue to evolve, customer demand for enhanced offerings may increase. Failure to strategically adopt emerging technologies may result in a competitive disadvantage to Citi. Citi also 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. Moreover, 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 AI, operational processes and systems and cybersecurity risk factors 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. 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. 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 and cybersecurity risk factors below).",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Changes in or Incorrect Accounting Assumptions, Judgments or Estimates, or the Application of Certain Accounting Principles, Could Result in Significant Losses or Other Adverse Impacts.",
      "prior_title": "Changes or Errors in Accounting Assumptions, Judgments or Estimates, or the Application of Certain Accounting Principles, Could Result in Significant Losses or Other Adverse Impacts.",
      "similarity_score": 0.804,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"GAAP requires Citi to use certain assumptions, judgments and estimates in preparing its financial statements, including, among other items, the estimate of the ACL; reserves related to litigation, regulatory and tax matters; valuation of DTAs; the fair values of certain assets and liabilities; and the assessment of goodwill and other assets for impairment.\"",
        "Reworded sentence: \"For example, the CECL methodology requires that Citi provide reserves for a current estimate of lifetime expected credit losses for its loan portfolios and other financial assets at the time those assets are originated or acquired.\"",
        "Reworded sentence: \"Citi’s ACL estimate is subject to judgments and depends upon its CECL models and assumptions, including forecasted macroeconomic conditions, which can be more challenging to forecast during times of significant market volatility and uncertainty.\"",
        "Reworded sentence: \"GAAP, a sale or other deconsolidation event of any foreign operation that results in a substantially complete liquidation of an investment in a foreign entity, such as those related to Citi’s remaining divestitures or legacy businesses, would result in reclassification of any CTA component of AOCI related to that entity, including amounts associated with related hedges and taxes, into Citi’s earnings.\"",
        "Reworded sentence: \"GAAP, a sale or other deconsolidation event of any foreign operation that results in a substantially complete liquidation of an investment in a foreign entity, such as those related to Citi’s remaining divestitures or legacy businesses, would result in reclassification of any CTA component of AOCI related to that entity, including amounts associated with related hedges and taxes, into Citi’s earnings.\""
      ],
      "current_body": "U.S. GAAP requires Citi to use certain assumptions, judgments and estimates in preparing its financial statements, including, among other items, the estimate of the ACL; reserves related to litigation, regulatory and tax matters; valuation of DTAs; the fair values of certain assets and liabilities; and the assessment of goodwill and other assets for impairment. These assumptions, judgments and estimates are inherently limited because they involve techniques, including the use of historical data, that cannot anticipate or model every economic and financial outcome in the markets in which Citi operates, nor can they anticipate the specific impact 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 hold in times of market stress, limited liquidity or other unforeseen circumstances. If Citi’s assumptions, judgments or estimates underlying its financial statements are incorrect or differ from actual or subsequent events, Citi could experience unexpected losses or other adverse impacts, some of which could be significant. Citi could also experience declines in its stock price, be subject to legal and regulatory proceedings and incur fines and other losses. For additional information on the key areas for which assumptions and estimates are used in preparing Citi’s financial statements, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16. For example, the CECL methodology requires that Citi provide reserves for a current estimate of lifetime expected credit losses for its loan portfolios and other financial assets at the time those assets are originated or acquired. This estimate is adjusted each period for changes in expected lifetime credit losses. Citi’s ACL estimate is subject to judgments and depends upon its CECL models and assumptions, including forecasted macroeconomic conditions, which can be more challenging to forecast during times of significant market volatility and uncertainty. These model assumptions and forecasted macroeconomic conditions will change over time, resulting in variability in Citi’s ACL and, thus, impact its results of operations and financial condition, as well as regulatory capital (see the capital return risk factor above). For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 (“Allowance for Credit Losses (ACL)”) and 16.Moreover, Citi has incurred losses related to its foreign operations that are reported in the CTA components of Accumulated other comprehensive income (loss) (AOCI). In accordance with U.S. GAAP, a sale or other deconsolidation event of any foreign operation that results in a substantially complete liquidation of an investment in a foreign entity, such as those related to Citi’s remaining divestitures or legacy businesses, would result in reclassification of any CTA component of AOCI related to that entity, including amounts associated with related hedges and taxes, into Citi’s earnings. For example, during the quarter in which a deconsolidation of Banamex occurs, Citi would incur a CTA loss of approximately ($9) billion, attributable to Banamex and its consolidated subsidiaries as of December 31, 2025, recognized through earnings, although the cumulative impact of the CTA would be regulatory capital neutral (for additional information, see “All Other” above). For additional information on Citi’s accounting policy for foreign currency translation and its foreign CTA components of AOCI, see Notes 1 (“Foreign Currency Translation”) and 21. 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.Changes to financial accounting or reporting standards or interpretations, whether promulgated or required by the Financial Accounting Standards Board (FASB), the SEC, U.S. banking regulators or others, could present operational challenges and could require Citi to change certain of the assumptions or estimates it previously used in preparing its financial statements, which could negatively impact how it records and reports its financial condition and results of operations generally and/or with respect to particular businesses. For example, the 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. See “Significant Accounting Policies and Significant Estimates” below and Note 1 for additional information on Citi’s accounting policies (“Summary of Significant Accounting Policies”) and changes in accounting (“Accounting Changes”), including the expected impacts on Citi’s results of operations and financial condition. challenging to forecast during times of significant market volatility and uncertainty. These model assumptions and forecasted macroeconomic conditions will change over time, resulting in variability in Citi’s ACL and, thus, impact its results of operations and financial condition, as well as regulatory capital (see the capital return risk factor above). For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 (“Allowance for Credit Losses (ACL)”) and 16. Moreover, Citi has incurred losses related to its foreign operations that are reported in the CTA components of Accumulated other comprehensive income (loss) (AOCI). In accordance with U.S. GAAP, a sale or other deconsolidation event of any foreign operation that results in a substantially complete liquidation of an investment in a foreign entity, such as those related to Citi’s remaining divestitures or legacy businesses, would result in reclassification of any CTA component of AOCI related to that entity, including amounts associated with related hedges and taxes, into Citi’s earnings. For example, during the quarter in which a deconsolidation of Banamex occurs, Citi would incur a CTA loss of approximately ($9) billion, attributable to Banamex and its consolidated subsidiaries as of December 31, 2025, recognized through earnings, although the cumulative impact of the CTA would be regulatory capital neutral (for additional information, see “All Other” above). For additional information on Citi’s accounting policy for foreign currency translation and its foreign CTA components of AOCI, see Notes 1 (“Foreign Currency Translation”) and 21.",
      "prior_body": "U.S. GAAP requires Citi to use certain assumptions, judgments and estimates in preparing its financial statements, including, among other items, the estimate of the ACL; reserves related to litigation, regulatory and tax matters; valuation of DTAs; the fair values of certain assets and liabilities; and the assessment of goodwill and other assets for 58 58 58 impairment. These assumptions, judgments and estimates are inherently limited because they involve techniques, which could include the use of historical data and AI, that cannot anticipate or model every economic and financial outcome in the markets in which Citi operates, nor can they anticipate the specific impact 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 hold in times of market stress, limited liquidity or other unforeseen circumstances. If Citi’s assumptions, judgments or estimates underlying its financial statements are incorrect or differ from actual or subsequent events, Citi could experience unexpected losses or other adverse impacts, some of which could be significant. Citi could also experience declines in its stock price, be subject to legal and regulatory proceedings and incur fines and other losses. For additional information on the key areas for which assumptions and estimates are used in preparing Citi’s financial statements, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16. For example, the CECL methodology requires that Citi provide reserves for a current estimate of lifetime expected credit losses for its loan portfolios and other financial assets, as applicable, at the time those assets are originated or acquired. This estimate is adjusted each period for changes in expected lifetime credit losses. Citi’s ACL estimate is subject to judgments and depends upon its CECL models and assumptions; forecasted macroeconomic conditions, including, among other things, the U.S. unemployment rate and U.S. inflation-adjusted gross domestic product (real GDP); and the credit indicators, composition and other characteristics of Citi’s loan portfolios and other applicable financial assets. These model assumptions and forecasted macroeconomic conditions will change over time, resulting in variability in Citi’s ACL and, thus, impact its results of operations and financial condition, as well as regulatory capital due to the CECL phase-in (see the capital return risk factor above). For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16.Moreover, Citi has incurred losses related to its foreign operations that are reported in the CTA components of Accumulated other comprehensive income (loss) (AOCI). In accordance with U.S. GAAP, a sale, substantial liquidation or other deconsolidation event of any foreign operations, such as those related to Citi’s remaining divestitures or legacy businesses, would result in reclassification of any foreign CTA component of AOCI related to that foreign operation, including related hedges and taxes, into Citi’s earnings. For example, Citi could incur a significant loss on sale due to CTA losses related to any such divestitures (see the capital risk factor above and the emerging markets risk factor below). The majority of these losses would be regulatory capital neutral at the completion of the divestiture. For additional information on Citi’s accounting policy for foreign currency translation and its foreign CTA components of AOCI, see Notes 1 and 21. Changes to Financial Accounting and Reporting Standards or Interpretations Could Have a Material Impact on How Citi Records and Reports Its Financial Condition and Results of Operations.Periodically, the Financial Accounting Standards Board (FASB) issues financial accounting and reporting standards that govern key aspects of Citi’s financial statements or interpretations thereof when those standards become effective, including those areas where Citi is required to make assumptions or estimates. Changes to financial accounting or reporting standards or interpretations, whether promulgated or required by the FASB, 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 across the Company as part of its comprehensive stress testing initiatives. 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. In 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 related to governance, and internal controls (see the legal and regulatory proceedings risk factor below).In addition, 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 impairment. These assumptions, judgments and estimates are inherently limited because they involve techniques, which could include the use of historical data and AI, that cannot anticipate or model every economic and financial outcome in the markets in which Citi operates, nor can they anticipate the specific impact 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 hold in times of market stress, limited liquidity or other unforeseen circumstances. If Citi’s assumptions, judgments or estimates underlying its financial statements are incorrect or differ from actual or subsequent events, Citi could experience unexpected losses or other adverse impacts, some of which could be significant. Citi could also experience declines in its stock price, be subject to legal and regulatory proceedings and incur fines and other losses. For additional information on the key areas for which assumptions and estimates are used in preparing Citi’s financial statements, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16. For example, the CECL methodology requires that Citi provide reserves for a current estimate of lifetime expected credit losses for its loan portfolios and other financial assets, as applicable, at the time those assets are originated or acquired. This estimate is adjusted each period for changes in expected lifetime credit losses. Citi’s ACL estimate is subject to judgments and depends upon its CECL models and assumptions; forecasted macroeconomic conditions, including, among other things, the U.S. unemployment rate and U.S. inflation-adjusted gross domestic product (real GDP); and the credit indicators, composition and other characteristics of Citi’s loan portfolios and other applicable financial assets. These model assumptions and forecasted macroeconomic conditions will change over time, resulting in variability in Citi’s ACL and, thus, impact its results of operations and financial condition, as well as regulatory capital due to the CECL phase-in (see the capital return risk factor above). For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16.Moreover, Citi has incurred losses related to its foreign operations that are reported in the CTA components of Accumulated other comprehensive income (loss) (AOCI). In accordance with U.S. GAAP, a sale, substantial liquidation or other deconsolidation event of any foreign operations, such as those related to Citi’s remaining divestitures or legacy businesses, would result in reclassification of any foreign CTA component of AOCI related to that foreign operation, including related hedges and taxes, into Citi’s earnings. For example, Citi could incur a significant loss on sale due to CTA losses related to any such divestitures (see the capital risk factor above and the emerging markets risk factor below). The majority of these losses would be regulatory capital neutral at the completion of the divestiture. For additional information on Citi’s accounting policy for foreign currency translation and its foreign CTA components of AOCI, see Notes 1 and 21. impairment. These assumptions, judgments and estimates are inherently limited because they involve techniques, which could include the use of historical data and AI, that cannot anticipate or model every economic and financial outcome in the markets in which Citi operates, nor can they anticipate the specific impact 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 hold in times of market stress, limited liquidity or other unforeseen circumstances. If Citi’s assumptions, judgments or estimates underlying its financial statements are incorrect or differ from actual or subsequent events, Citi could experience unexpected losses or other adverse impacts, some of which could be significant. Citi could also experience declines in its stock price, be subject to legal and regulatory proceedings and incur fines and other losses. For additional information on the key areas for which assumptions and estimates are used in preparing Citi’s financial statements, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16. For example, the CECL methodology requires that Citi provide reserves for a current estimate of lifetime expected credit losses for its loan portfolios and other financial assets, as applicable, at the time those assets are originated or acquired. This estimate is adjusted each period for changes in expected lifetime credit losses. Citi’s ACL estimate is subject to judgments and depends upon its CECL models and assumptions; forecasted macroeconomic conditions, including, among other things, the U.S. unemployment rate and U.S. inflation-adjusted gross domestic product (real GDP); and the credit indicators, composition and other characteristics of Citi’s loan portfolios and other applicable financial assets. These model assumptions and forecasted macroeconomic conditions will change over time, resulting in variability in Citi’s ACL and, thus, impact its results of operations and financial condition, as well as regulatory capital due to the CECL phase-in (see the capital return risk factor above). For additional information on Citi’s ACL, see “Significant Accounting Policies and Significant Estimates” below and Notes 1 and 16. Moreover, Citi has incurred losses related to its foreign operations that are reported in the CTA components of Accumulated other comprehensive income (loss) (AOCI). In accordance with U.S. GAAP, a sale, substantial liquidation or other deconsolidation event of any foreign operations, such as those related to Citi’s remaining divestitures or legacy businesses, would result in reclassification of any foreign CTA component of AOCI related to that foreign operation, including related hedges and taxes, into Citi’s earnings. For example, Citi could incur a significant loss on sale due to CTA losses related to any such divestitures (see the capital risk factor above and the emerging markets risk factor below). The majority of these losses would be regulatory capital neutral at the completion of the divestiture. For additional information on Citi’s accounting policy for foreign currency translation and its foreign CTA components of AOCI, see Notes 1 and 21. Changes to Financial Accounting and Reporting Standards or Interpretations Could Have a Material Impact on How Citi Records and Reports Its Financial Condition and Results of Operations.Periodically, the Financial Accounting Standards Board (FASB) issues financial accounting and reporting standards that govern key aspects of Citi’s financial statements or interpretations thereof when those standards become effective, including those areas where Citi is required to make assumptions or estimates. Changes to financial accounting or reporting standards or interpretations, whether promulgated or required by the FASB, 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 across the Company as part of its comprehensive stress testing initiatives. 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. In 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 related to governance, and internal controls (see the legal and regulatory proceedings risk factor below).In addition, 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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Exposure to Commercial Real Estate",
      "prior_title": "Exposure to Commercial Real Estate",
      "similarity_score": 0.804,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"As of December 31, 2025 and 2024, Citi’s total credit exposure to commercial real estate (CRE) was $78.4 billion and $65 billion, including $6.3 billion and $6 billion of exposure related to office buildings, respectively.\"",
        "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 in Banking.At December 31, 2025, September 30, 2025 and December 31, 2024, Banking had economic hedges on the corporate credit portfolio of $40.6 billion, $39.5 billion and $37.8 billion, respectively.\"",
        "Reworded sentence: \"The purchased credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution: Rating of Hedged ExposureDecember 31,2025September 30,2025December 31,2024AAA/AA/A47 %47 %44 %BBB41 41 45 BB/B11 11 10 CCC or below1 1 1 Total100 %100 %100 % Credit Risk MitigationAs part of its overall risk management activities, Citi 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 in Banking.At December 31, 2025, September 30, 2025 and December 31, 2024, Banking had economic hedges on the corporate credit portfolio of $40.6 billion, $39.5 billion and $37.8 billion, respectively.\"",
        "Reworded sentence: \"The purchased credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution: Rating of Hedged ExposureDecember 31,2025September 30,2025December 31,2024AAA/AA/A47 %47 %44 %BBB41 41 45 BB/B11 11 10 CCC or below1 1 1 Total100 %100 %100 %\""
      ],
      "current_body": "As of December 31, 2025 and 2024, Citi’s total credit exposure to commercial real estate (CRE) was $78.4 billion and $65 billion, including $6.3 billion and $6 billion of exposure related to office buildings, respectively. This total CRE exposure consisted of approximately $69.5 billion and $56 billion, respectively, related to corporate clients, included in the real estate category in the tables above and below. Total CRE exposure also includes approximately $8.9 billion and $9 billion, respectively, related to Wealth clients, not included in the tables above as they are not considered corporate exposures. In addition, as of December 31, 2025, approximately 81% of Citi’s total CRE exposure was rated investment grade and more than 77% was to borrowers in the U.S. (compared to approximately 78% rated investment grade and more than 75% to borrowers in the U.S. as of December 31, 2024).As of December 31, 2025, the percentage of the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.4%, and there were $659 million of non-accrual CRE loans. As of December 31, 2024, the percentage of the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.6%, and there were $574 million of non-accrual CRE loans. In addition, as of December 31, 2025, approximately 81% of Citi’s total CRE exposure was rated investment grade and more than 77% was to borrowers in the U.S. (compared to approximately 78% rated investment grade and more than 75% to borrowers in the U.S. as of December 31, 2024). As of December 31, 2025, the percentage of the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.4%, and there were $659 million of non-accrual CRE loans. As of December 31, 2024, the percentage of the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.6%, and there were $574 million of non-accrual CRE loans. 71 71 71 The following table details Citi’s corporate credit portfolio by industry as of December 31, 2024: Non-investment gradeSelected metricsIn millions of dollarsTotal credit exposure(1)(8)Funded(2)Unfunded(3)Investment gradeNon-criticizedCriticized performingCriticized non-performing(4)30 days or more past due and accruingNet credit losses (recoveries)Credit derivative hedges(5)Transportation and industrials$144,381 $57,166 $87,215 $106,336 $32,849 $4,944 $252 $73 $19 $(7,643)Autos(6)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(7)41,919 11,686 30,233 33,899 7,266 555 199 3 (5)(3,153)Healthcare39,028 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 industries7,213 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) Total credit exposure(1)(8) Funded(2) Unfunded(3) Criticized non-performing(4) Credit derivative hedges(5) Autos(6) Energy and commodities(7) (1) Represents gross credit exposures excluding any purchased credit protection. (2) Funded excludes loans carried at fair value of $7.8 billion and HFS of $3.6 billion as of December 31, 2024. (3) Unfunded includes lending-related commitments carried at fair value and HFS as of December 31, 2024. (4) Includes non-accrual loan exposures and related criticized unfunded exposures. (5) 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. (6) Autos total credit exposure includes securitization financing facilities secured by auto loans and leases, extended mainly to the finance company subsidiaries of global auto manufacturers, bank subsidiaries and independent auto finance companies, of approximately $17.5 billion ($10.5 billion of which was funded exposure with 100% rated investment grade) as of December 31, 2024. (7) In addition to this exposure, Citi has energy-related exposure within the public sector (e.g., energy-related state-owned entities) and the transportation and industrials sector (e.g., 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. (8) 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. 72 72 72 Credit Risk MitigationAs part of its overall risk management activities, Citi 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 in Banking.At December 31, 2025, September 30, 2025 and December 31, 2024, Banking had economic hedges on the corporate credit portfolio of $40.6 billion, $39.5 billion and $37.8 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 purchased credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution: Rating of Hedged ExposureDecember 31,2025September 30,2025December 31,2024AAA/AA/A47 %47 %44 %BBB41 41 45 BB/B11 11 10 CCC or below1 1 1 Total100 %100 %100 % Credit Risk MitigationAs part of its overall risk management activities, Citi 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 in Banking.At December 31, 2025, September 30, 2025 and December 31, 2024, Banking had economic hedges on the corporate credit portfolio of $40.6 billion, $39.5 billion and $37.8 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 purchased credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution: Rating of Hedged ExposureDecember 31,2025September 30,2025December 31,2024AAA/AA/A47 %47 %44 %BBB41 41 45 BB/B11 11 10 CCC or below1 1 1 Total100 %100 %100 %",
      "prior_body": "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 %"
    },
    {
      "status": "MODIFIED",
      "current_title": "Independent Risk Management",
      "prior_title": "Independent Compliance Risk Management",
      "similarity_score": 0.802,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"The IRM organization sets risk and control standards for the first line of defense and actively manages and oversees aggregate credit, market (trading and non-trading), liquidity, strategic, operational and reputation risks across Citi, including risks that span categories, such as concentration risk, country risk and climate risk.\"",
        "Reworded sentence: \"The Citi Chief Auditor has unrestricted access to the Board and the Board Audit Committee.\"",
        "Reworded sentence: \"Organizations noted under the first line of defense may also contain enterprise support functions (e.g., the Controllers Group within Finance).\""
      ],
      "current_body": "The IRM organization sets risk and control standards for the first line of defense and actively manages and oversees aggregate credit, market (trading and non-trading), liquidity, strategic, operational and reputation risks across Citi, including risks that span categories, such as concentration risk, country risk and climate risk. The CRO reports directly to both the Board’s Risk Management Committee and the Citigroup CEO. Independent Compliance Risk Management 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, and is committed to maintaining an enterprise-wide compliance riskmanagement framework across Citi. The CCO reports to Citi’s Chief Legal Officer, and ICRM is organizationally part of Global Legal Affairs and Compliance. In addition, the CCO has matrix reporting into the CRO.Third Line of DefenseInternal 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. 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). Organizations noted under the first line of defense may also contain enterprise support functions (e.g., the Controllers Group within Finance). Enterprise support functions are subject to the relevant Company-wide independent oversight processes specific to the risks for which they are accountable (e.g., operational risk and compliance 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. the Board’s Risk Management Committee and the Citigroup CEO.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "CONSUMER CREDIT",
      "prior_title": "CONSUMER CREDIT",
      "similarity_score": 0.797,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"As of December 31, 2025, USPB provided credit cards, consumer mortgages, personal loans, small business banking and other retail lending, and Wealth provided consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from the affluent to ultra-high net worth through the Private Bank, Citigold and Wealth at Work.\""
      ],
      "current_body": "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. As of December 31, 2025, USPB provided credit cards, consumer mortgages, personal loans, small business banking and other retail lending, and Wealth provided consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from the affluent to ultra-high net worth through the Private Bank, Citigold and Wealth at Work. USPB’s retail banking products included 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 (Poland and Korea). As of December 31, 2025, USPB provided credit cards, consumer mortgages, personal loans, small business banking and other retail lending, and Wealth provided consumer mortgages, margin lending, credit cards and other lending products to customer segments that range from the affluent to ultra-high net worth through the Private Bank, Citigold and Wealth at Work. USPB’s retail banking products included 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 (Poland and Korea).",
      "prior_body": "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)."
    },
    {
      "status": "MODIFIED",
      "current_title": "Climate Change Presents Various Financial and Non-Financial Risks to Citi.",
      "prior_title": "Climate Change Presents Various Financial and Non-Financial Risks to Citi and Its Customers and Clients.",
      "similarity_score": 0.795,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Climate change presents both immediate and long-term risks to Citi, with the risks expected to increase over time.\"",
        "Reworded sentence: \"These impacts can include the following: •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 •reduced availability or increases 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.\"",
        "Reworded sentence: \"Modeling capabilities to analyze climate-related risks and interconnections continue to evolve.Citi’s approach to supporting clients in their efforts to decarbonize may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view.\"",
        "Reworded sentence: \"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, and lead to a loss of market share, lower revenues and higher credit costs.\"",
        "Reworded sentence: \"Citi’s approach to supporting clients in their efforts to decarbonize may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view.\""
      ],
      "current_body": "Climate change presents both immediate and long-term risks to Citi, with the risks expected to increase over time. Climate risks can arise from both physical risks and transition risks. Physical and transition risks can manifest differently across Citi’s risk categories in the short, medium and long terms. Physical risks include acute risks, such as wildfires, tropical cyclones, heat waves, floods and droughts, as well as consequences of chronic changes in climate. 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 the following: •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 •reduced availability or increases 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, and lead to a loss of market share, lower revenues and higher credit costs. Diverging legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures can increase Citi’s regulatory and compliance risks and costs. Furthermore, Citi may face heightened scrutiny and litigation risks stemming from its climate and sustainability commitments, disclosures and marketing.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.Citi’s approach to supporting clients in their efforts to decarbonize may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Additionally, if Citi is unable to achieve some of its objectives or commitments relating to climate change, its businesses, reputation and attractiveness to certain investors or clients may suffer. For additional information, see “Sustainability” and “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, 2025, Citi’s net DTAs were $29.5 billion, net of a valuation allowance of $5.0 billion, of which $13.1 billion was deducted from Citi’s CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $10.8 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $3.1 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $0.8 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital.Citi’s ability to realize its DTAs will primarily be dependent upon its 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. 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, and lead to a loss of market share, lower revenues and higher credit costs. Diverging legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures can increase Citi’s regulatory and compliance risks and costs. Furthermore, Citi may face heightened scrutiny and litigation risks stemming from its climate and sustainability commitments, disclosures and marketing. 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. Citi’s approach to supporting clients in their efforts to decarbonize may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Additionally, if Citi is unable to achieve some of its objectives or commitments relating to climate change, its businesses, reputation and attractiveness to certain investors or clients may suffer. For additional information, see “Sustainability” and “Managing Global Risk—Strategic Risk—Climate Risk” below.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Loans at fair value(1)",
      "prior_title": "Loans at fair value(1)",
      "similarity_score": 0.795,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"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 personal installment loans0.4 3.8 10.5 North America mortgages(3)0.1 117.2 0.1 North America other(3)0.3 29.4 1.0 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 % 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.\"",
        "Reworded sentence: \"As of December 31, 2025, the $13.3 billion of ACLL represented approximately 24 months of coincident net credit loss coverage (based on fourth quarter of 2025 NCLs).\"",
        "Removed sentence: \"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).\"",
        "Removed sentence: \"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%.\"",
        "Reworded sentence: \"N/A Not applicable 86 86 86 The following table details Citi’s corporate credit ACLL by industry exposure: December 31, 2025In millions of dollars, except percentagesFunded exposure(1)(3)ACLLACLL as a % of funded exposureBanks and finance companies$73,206 $257 0.4 %Real estate(2)62,776 709 1.1 Commercial44,387 682 1.5 Residential18,389 26 0.1 Transportation and industrials58,014 614 1.1 Technology, media and telecom34,144 354 1.0 Consumer retail34,119 298 0.9 Power, chemicals, metals and mining18,695 381 2.0 Public sector17,063 67 0.4 Energy and commodities12,686 171 1.3 Asset managers and funds10,642 42 0.4 Healthcare8,076 102 1.3 Insurance3,657 15 0.4 Securities firms154 3 1.9 Financial markets infrastructure151 — — Other industries(4)3,510 40 1.1 Total(5)$336,893 $3,053 0.9 %\""
      ],
      "current_body": "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 personal installment loans0.4 3.8 10.5 North America mortgages(3)0.1 117.2 0.1 North America other(3)0.3 29.4 1.0 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 % 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, 2025, the $13.3 billion of ACLL represented approximately 24 months of coincident net credit loss coverage (based on fourth quarter of 2025 NCLs). As of December 31, 2025, Branded Cards ACLL as a percentage of EOP loans was 6.3% and Retail Services ACLL as a percentage of EOP loans was 10.8%. As of December 31, 2024, the $13.6 billion of ACLL represented approximately 22 months of coincident net credit loss coverage (based on fourth quarter of 2024 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%. (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 86 86 86 The following table details Citi’s corporate credit ACLL by industry exposure: December 31, 2025In millions of dollars, except percentagesFunded exposure(1)(3)ACLLACLL as a % of funded exposureBanks and finance companies$73,206 $257 0.4 %Real estate(2)62,776 709 1.1 Commercial44,387 682 1.5 Residential18,389 26 0.1 Transportation and industrials58,014 614 1.1 Technology, media and telecom34,144 354 1.0 Consumer retail34,119 298 0.9 Power, chemicals, metals and mining18,695 381 2.0 Public sector17,063 67 0.4 Energy and commodities12,686 171 1.3 Asset managers and funds10,642 42 0.4 Healthcare8,076 102 1.3 Insurance3,657 15 0.4 Securities firms154 3 1.9 Financial markets infrastructure151 — — Other industries(4)3,510 40 1.1 Total(5)$336,893 $3,053 0.9 %",
      "prior_body": "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 %"
    },
    {
      "status": "MODIFIED",
      "current_title": "Citi May Be Unable to Achieve Its Objectives from Its Simplification, Transformation and Enhanced Business Performance Priorities.",
      "prior_title": "Citi’s Ability to Achieve Its Objectives from Its Transformation, Simplification and Other Priorities May Not Be as Successful as It Projects or Expects.",
      "similarity_score": 0.772,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"Citi has been pursuing overall simplification initiatives to enhance its client focus and reduce expenses.\"",
        "Reworded sentence: \"Conversely, failure to adequately invest in and upgrade Citi’s technology and processes could result in Citi’s inability to be sufficiently competitive, meet regulatory expectations, 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).\"",
        "Reworded sentence: \"These impacts can include the following:•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•reduced availability or increases in the cost of insurancePhysical 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, and lead to a loss of market share, lower revenues and higher credit costs.\""
      ],
      "current_body": "Citi has been pursuing overall simplification initiatives to enhance its client focus and reduce expenses. Citi’s simplification initiatives, including completing its divestiture of Banamex, involve various execution challenges, may take longer than expected and may result in higher expenses, or lower than expected expense savings, CTA and other losses or other negative financial or strategic impacts, which could be material, and litigation and regulatory scrutiny (for information about CTA impacts, see the changes in or incorrect assumptions risk factor below). As part of its multiyear transformation, Citi also continues to make significant investments and undertake substantial actions across the Company to modernize its data and technology infrastructure, further strengthen its risk and controls environment and further enhance safety and soundness (see “Citi’s Multiyear Transformation” above and the legal and regulatory proceedings risk factor below). 50 50 50 Moreover, Citi continues to make business-led investments, as part of the execution of its strategic priorities. For example, Citi has been making technology and other investments across the Company, including hiring 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.Citi’s simplification, transformation and enhanced business performance priorities 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 could result in Citi’s inability to be sufficiently competitive, meet regulatory expectations, 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 underlying expense savings, revenue growth and capital return objectives, as well as related 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.Further, Citi’s simplification, transformation and enhanced business performance priorities may continue to evolve as its business strategies, including with respect to organic or inorganic growth, 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.Climate change presents both immediate and long-term risks to Citi, with the risks expected to increase over time. Climate risks can arise from both physical risks and transition risks. Physical and transition risks can manifest differently across Citi’s risk categories in the short, medium and long terms. Physical risks include acute risks, such as wildfires, tropical cyclones, heat waves, floods and droughts, as well as consequences of chronic changes in climate. 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 the following:•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•reduced availability or increases in the cost of insurancePhysical 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, and lead to a loss of market share, lower revenues and higher credit costs. Diverging legislative and regulatory changes and uncertainties regarding climate-related risk management and disclosures can increase Citi’s regulatory and compliance risks and costs. Furthermore, Citi may face heightened scrutiny and litigation risks stemming from its climate and sustainability commitments, disclosures and marketing.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.Citi’s approach to supporting clients in their efforts to decarbonize may lead to both continued exposure to carbon-intensive activity and increased reputation risks from stakeholders with divergent points of view. Additionally, if Citi is unable to achieve some of its objectives or commitments relating to climate change, its businesses, reputation and attractiveness to certain investors or clients may suffer. For additional information, see “Sustainability” and “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, 2025, Citi’s net DTAs were $29.5 billion, net of a valuation allowance of $5.0 billion, of which $13.1 billion was deducted from Citi’s CET1 Capital under the U.S. Basel III rules. Of this deducted amount, $10.8 billion related to net operating losses, foreign tax credit and general business credit carry-forwards, with $3.1 billion related to temporary differences in excess of the 10%/15% regulatory limitations, reduced by $0.8 billion of deferred tax liabilities, primarily associated with goodwill and certain other intangible assets that were separately deducted from capital.Citi’s ability to realize its DTAs will primarily be dependent upon its 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. Moreover, Citi continues to make business-led investments, as part of the execution of its strategic priorities. For example, Citi has been making technology and other investments across the Company, including hiring 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.Citi’s simplification, transformation and enhanced business performance priorities 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 could result in Citi’s inability to be sufficiently competitive, meet regulatory expectations, 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 underlying expense savings, revenue growth and capital return objectives, as well as related 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.Further, Citi’s simplification, transformation and enhanced business performance priorities may continue to evolve as its business strategies, including with respect to organic or inorganic growth, 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.Climate change presents both immediate and long-term risks to Citi, with the risks expected to increase over time. Climate risks can arise from both physical risks and transition risks. Physical and transition risks can manifest differently across Citi’s risk categories in the short, medium and long terms. Physical risks include acute risks, such as wildfires, tropical cyclones, heat waves, floods and droughts, as well as consequences of chronic changes in climate. 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 the following:•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•reduced availability or increases in the cost of insurancePhysical risks can also impact Citi’s credit risk exposures, for example, in its mortgage and commercial real estate lending businesses. Moreover, Citi continues to make business-led investments, as part of the execution of its strategic priorities. For example, Citi has been making technology and other investments across the Company, including hiring 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. Citi’s simplification, transformation and enhanced business performance priorities 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 could result in Citi’s inability to be sufficiently competitive, meet regulatory expectations, 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 underlying expense savings, revenue growth and capital return objectives, as well as related 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. Further, Citi’s simplification, transformation and enhanced business performance priorities may continue to evolve as its business strategies, including with respect to organic or inorganic growth, the market environment and regulatory expectations change, which could make the initiatives more costly and more challenging to implement, and limit their effectiveness.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Credit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses.",
      "prior_title": "Credit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses.",
      "similarity_score": 0.767,
      "confidence": "high",
      "key_changes": [
        "Reworded sentence: \"and various countries and jurisdictions globally, including: •end-of-period consumer loans of $409 billion •end-of-period corporate loans of $344 billion at December 31, 2025 A default by or a significant downgrade in the credit ratings of a consumer or corporate borrower or other counterparty, or a decline in the credit quality or value of any underlying collateral, exposes Citi to credit risk.\"",
        "Removed sentence: \"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.\"",
        "Removed 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).\"",
        "Removed sentence: \"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.\"",
        "Reworded sentence: \"Additionally, systemic risks, including from leveraged finance, non-bank financial institutions, private credit and AI, could increase Citi’s credit costs.\""
      ],
      "current_body": "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 $409 billion •end-of-period corporate loans of $344 billion at December 31, 2025 A default by or a significant downgrade in the credit ratings of a consumer or corporate 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 consumer and corporate 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 cards risk factors above and the emerging markets risk factor below). For example, a weakening of economic conditions, including increases in unemployment rates, can adversely affect borrowers’ ability to repay their obligations, as well as result in Citi’s inability to liquidate the collateral it holds or forced to liquidate the collateral at prices that do not cover the full amount owed to Citi. 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. 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, systemic risks, including from leveraged finance, non-bank financial institutions, private credit and AI, could increase Citi’s credit costs. 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, including on the CECL methodology, see the changes in or incorrect assumptions risk factor above. Concentrations and/or high correlation 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, 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. Citi also routinely executes a high volume of securities, trading, derivative and foreign exchange transactions with 58 58 58 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. 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. Additionally, Citi competes with other banks and non-bank financial institutions for both institutional and consumer deposits, which represent Citi’s most stable and lowest cost source of long-term funding. The competition for deposits has continued to increase in recent years, including as a result of fixed income alternatives for customer funds.Citi’s costs to obtain and access wholesale funding are directly related to changes in interest and currency exchange rates and its credit spreads. Changes in Citi’s credit spreads are driven by both external market factors and factors specific to Citi, such as negative views by investors of the financial services industry or Citi’s financial prospects, and can be highly volatile. For additional information on Citi’s primary sources of funding, see “Managing Global Risk—Liquidity Risk” below. Citi’s ability to obtain funding may be impaired and its cost of funding could also increase if other market participants are seeking to access the markets at the same time or to a greater extent than expected, or if market appetite for corporate debt securities declines, as is likely to occur in a liquidity stress event or other market crisis. In such circumstances, Citi’s ability to sell assets may also be impaired if other market participants are seeking to sell similar assets at the same time or a liquid market does not exist for such assets. Additionally, unexpected changes in client needs due to idiosyncratic events or market conditions could result in greater than expected drawdowns from off-balance sheet committed facilities. A sudden drop in market liquidity could also cause a temporary or protracted dislocation of capital markets activity. In addition, clearing organizations, central banks, clients and financial institutions with which Citi interacts may exercise the right to require additional collateral during challenging market conditions, which could further impair Citi’s liquidity. If Citi fails to effectively manage its liquidity, its businesses, results of operations and financial condition could be negatively impacted.Limitations on the payments that Citigroup Inc. receives from its subsidiaries could also impact its liquidity. As a holding company, Citigroup Inc. relies on interest, dividends, distributions and other payments from its subsidiaries to fund dividends as well as to satisfy its debt and other obligations. Several of Citi’s U.S. and non-U.S. subsidiaries are or may be subject to capital adequacy or other liquidity, regulatory or contractual restrictions on their ability to provide such payments, including any local regulatory stress test requirements and inter-affiliate arrangements entered into in connection with Citigroup Inc.’s resolution plan. Citigroup Inc.’s broker-dealer and bank subsidiaries are subject to restrictions on their ability to lend or transact with affiliates, as well as restrictions on their ability to use funds deposited with them in brokerage or bank accounts to fund their businesses. A bank holding company is also required by law to act as a source of financial and managerial strength for its subsidiary banks. As a result, the FRB may require Citigroup Inc. to commit resources to its subsidiary banks even if doing so is not otherwise in the interests of Citigroup Inc. or its shareholders or creditors, reducing the amount of funds available to meet its obligations.A Ratings Downgrade Could Adversely Impact Citi’s Funding and Liquidity.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, declines in profitability, reductions in regulatory capitalization levels, deterioration in Citi’s funding structure or liquidity, significant increases in risk appetite, delays or missteps in Citi’s transformation efforts, public statements by Citi’s management or regulators or control failures. A ratings downgrade 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 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. 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. Additionally, Citi competes with other banks and non-bank financial institutions for both institutional and consumer deposits, which represent Citi’s most stable and lowest cost source of long-term funding. The competition for deposits has continued to increase in recent years, including as a result of fixed income alternatives for customer funds.Citi’s costs to obtain and access wholesale funding are directly related to changes in interest and currency exchange rates and its credit spreads. Changes in Citi’s credit spreads are driven by both external market factors and factors specific to Citi, such as negative views by investors of the financial services industry or Citi’s financial prospects, and can be highly volatile. For additional information on Citi’s primary sources of funding, see “Managing Global Risk—Liquidity Risk” below. Citi’s ability to obtain funding may be impaired and its cost of funding could also increase if other market participants are seeking to access the markets at the same time or to a greater extent than expected, or if market appetite for corporate debt securities declines, as is likely to occur in a liquidity stress event or other market crisis. In such circumstances, Citi’s ability to sell assets may also be impaired if other market participants are seeking to sell similar assets at the same time or a liquid market does not exist for such assets. Additionally, unexpected changes in client needs due to idiosyncratic events or market conditions could result in greater than expected drawdowns from off-balance sheet committed facilities. A sudden drop in market liquidity could also cause a temporary or protracted dislocation of capital 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.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Board and Executive Management Governance Committees",
      "prior_title": "Board and Executive Management Committees",
      "similarity_score": 0.762,
      "confidence": "high",
      "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 (Board Audit Committee) provides oversight of financial statement integrity, internal controls, audits and regulatory compliance.\"",
        "Reworded sentence: \"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 (margin loans, 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, as well as through its investment securities portfolio and cash placed with banks.\"",
        "Reworded sentence: \"Citi assesses the credit risk associated with its credit exposures not carried at fair value 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 (“Allowance for Credit Losses (ACL)”) and 16), as well as through regular stress testing at the company, business, geography and product levels.\"",
        "Reworded sentence: \"Average LoansThe table below details average loans, by segment and All Other, and the total Citigroup end-of-period loans for each of the periods indicated:In billions of dollars4Q253Q254Q24Services$96 $94 $87 Markets152 147 122 Banking79 81 84 Wealth149 151 148 USPB Branded Cards$122 $120 $117 Retail Services50 50 52 Retail Banking54 50 47 Total USPB$226 $220 $216 All Other$35 $32 $31 Total Citigroup loans (AVG)$737 $725 $688 Total Citigroup loans (EOP)$752 $734 $694 Average loans increased 7% year-over-year and 2% sequentially.\"",
        "Reworded sentence: \"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 (margin loans, 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, as well as through its investment securities portfolio and cash placed with banks.\""
      ],
      "current_body": "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 (Board Audit Committee) provides oversight of financial statement integrity, internal controls, audits and regulatory compliance. Its responsibilities include holding management accountable for the effectiveness of Citigroup’s control environment and corrective actions, approving independent auditor selection/compensation, key policies and 10-K filings. It also has responsibilities regarding the approval, replacement and compensation of the Chief Auditor. •Compensation, Performance Management and Culture Committee provides oversight of employee compensation, corporate culture and compliance with bank regulatory guidance governing Citi’s incentive compensation. Its responsibilities include reviewing Citi’s management resources, assessing the performance of senior management, determining the compensation of Citigroup’s CEO and approving executive compensation and incentive compensation structures. •Nomination, Governance and Public Affairs Committee provides oversight of corporate governance, Board effectiveness and public affairs, including sustainability matters, and nominates directors for the Board and its committees. Its responsibilities include leading the annual review of the Board’s performance, reviewing the adequacy of Board committee charters and reviewing relationships with external constituencies and issues that impact Citi’s reputation, as well as advising management on the foregoing matters. •Risk Management Committee (Board RMC) provides oversight of Citigroup’s risk management framework and risk culture, including significant policies and practices for risk management and capital management, and oversees the performance of Citi’s Credit Risk Review function. This Committee reviews Citigroup’s aggregate risk profile and ensures the adequacy of the Company’s risk management functions. Its responsibilities include approving the Enterprise Risk Management Framework (ERMF) and key risk policies, reviewing the risk appetite statement and recommending it to the Board. Additionally, this Committee has responsibilities regarding the approval, replacement and compensation of the Chief Risk Officer. •Technology Committee provides oversight of Citigroup’s technology strategy, operating model, architecture and technology-based risk management (including cyber security), technology resource and talent planning, and technology third-party management policies. Its responsibilities include reviewing and assessing significant technology investments and expenditures, overseeing and reviewing information from management regarding Citi’s approach to Generative AI and reviewing reports on technology and data quality-related matters.In addition to the above, the Board has established the following ad hoc committee: •Transformation Oversight Committee provides oversight of the actions of Citi’s management to develop and execute a transformation of Citi’s risk and control environment pursuant to the FRB and OCC Consent Orders (see “Citi’s Multiyear Transformation—FRB and OCC Consent Orders Compliance” above).The Citigroup CEO has established four standing Executive Management Governance Committees that cover the primary risks to which Citi is exposed. These consist of the following:•Citigroup Asset and Liability Committee (ALCO) oversees liquidity risk and market risk on the accrual book, and monitors and influences the balance sheet, investment securities and capital management activities of Citigroup. Its responsibilities include approving relevant policies andprograms and reviewing balance sheet trends, liquidity levels, capital metrics, interest rate risk, foreign exchange risk and significant risk management concerns.•Business Risk and Control Committee oversees operational and compliance risks and the overall control environment. Its responsibilities include approving operational and compliance risk-related initiatives, and monitoring Issues, Managers Control Assessment, Operational Risk Events and Escalations.•Reputation Risk Committee oversees Citigroup’s reputation risk program. It governs the processes by which material reputation risks are managed, in line with Company-wide strategic objectives, risk appetite and regulatory expectations, while promoting a culture of risk awareness. Its responsibilities include reviewing, challenging and resolving, as needed, reputation risk matters.•Risk Management Committee oversees the execution of the Enterprise Risk Management Framework and monitors Citi’s risk profile against approved risk appetite. Its responsibilities include discussing and providing review and challenge of risk matters, including material and emerging risks facing Citi. It also provides comprehensive coverage of credit risk, market risk (trading) and strategic risk.In addition to the Executive Management Governance Committees listed above, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. security), technology resource and talent planning, and technology third-party management policies. Its responsibilities include reviewing and assessing significant technology investments and expenditures, overseeing and reviewing information from management regarding Citi’s approach to Generative AI and reviewing reports on technology and data quality-related matters. In addition to the above, the Board has established the following ad hoc committee: •Transformation Oversight Committee provides oversight of the actions of Citi’s management to develop and execute a transformation of Citi’s risk and control environment pursuant to the FRB and OCC Consent Orders (see “Citi’s Multiyear Transformation—FRB and OCC Consent Orders Compliance” above). The Citigroup CEO has established four standing Executive Management Governance Committees that cover the primary risks to which Citi is exposed. These consist of the following: •Citigroup Asset and Liability Committee (ALCO) oversees liquidity risk and market risk on the accrual book, and monitors and influences the balance sheet, investment securities and capital management activities of Citigroup. Its responsibilities include approving relevant policies and programs and reviewing balance sheet trends, liquidity levels, capital metrics, interest rate risk, foreign exchange risk and significant risk management concerns. •Business Risk and Control Committee oversees operational and compliance risks and the overall control environment. Its responsibilities include approving operational and compliance risk-related initiatives, and monitoring Issues, Managers Control Assessment, Operational Risk Events and Escalations. •Reputation Risk Committee oversees Citigroup’s reputation risk program. It governs the processes by which material reputation risks are managed, in line with Company-wide strategic objectives, risk appetite and regulatory expectations, while promoting a culture of risk awareness. Its responsibilities include reviewing, challenging and resolving, as needed, reputation risk matters. •Risk Management Committee oversees the execution of the Enterprise Risk Management Framework and monitors Citi’s risk profile against approved risk appetite. Its responsibilities include discussing and providing review and challenge of risk matters, including material and emerging risks facing Citi. It also provides comprehensive coverage of credit risk, market risk (trading) and strategic risk. In addition to the Executive Management Governance Committees listed above, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. 66 66 66 The figure below illustrates the reporting lines between the Board and Executive Management Governance Committees: 67 67 67 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 (margin loans, 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, as well as through its investment securities portfolio and cash placed with banks. 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 not carried at fair value 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 (“Allowance for Credit Losses (ACL)”) 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. Average LoansThe table below details average loans, by segment and All Other, and the total Citigroup end-of-period loans for each of the periods indicated:In billions of dollars4Q253Q254Q24Services$96 $94 $87 Markets152 147 122 Banking79 81 84 Wealth149 151 148 USPB Branded Cards$122 $120 $117 Retail Services50 50 52 Retail Banking54 50 47 Total USPB$226 $220 $216 All Other$35 $32 $31 Total Citigroup loans (AVG)$737 $725 $688 Total Citigroup loans (EOP)$752 $734 $694 Average loans increased 7% year-over-year and 2% sequentially. The year-over-year increase was primarily driven by growth in Markets, USPB and Services, partially offset by declines in Banking.Year-over-year average loans for: •Services increased 10%, driven by demand in TTS for working capital loans as well as export and agency finance. •Markets increased 25%, primarily driven by asset-backed financing and commercial warehouse lending in Spread Products.•Banking decreased 6%, due to lower aggregate customer demand for funded loans.•Wealth increased 1%, with growth in margin lending primarily offset by the transfers of certain relationships and associated mortgage loans to USPB from Wealth.•USPB increased 5%, driven by growth in Retail Banking, largely due to transfers of certain relationships and associated mortgage loans to USPB from Wealth, as well as growth in Branded Cards.•All Other increased 13%, driven by growth in Mexico Consumer/SBMM (including the impact of Mexican peso appreciation), partially offset by the continued wind-downs in Asia Consumer within Legacy Franchises (including the impact of moving HFS loans to Other assets). 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 (margin loans, 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, as well as through its investment securities portfolio and cash placed with banks. 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 not carried at fair value on a regular basis through its allowance",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Citi Faces Ongoing Regulatory and Legislative Uncertainties and Changes in the U.S. and Globally.",
      "prior_title": "Citi Must Continually Review, Analyze and Successfully Adapt to Ongoing Regulatory and Legislative Uncertainties and Changes in the U.S. and Globally.",
      "similarity_score": 0.749,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"While the ongoing regulatory and legislative uncertainties and changes facing Citi are numerous and subject to change, examples include, but are not limited to, the following: •potential changes to U.S.\"",
        "Reworded sentence: \"Further, ongoing regulatory and legislative uncertainties and changes make Citi’s long-term business, balance sheet and strategic planning difficult, subject to change, and 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 regulatoryscrutiny and 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 May Be Unable to Achieve Its Objectives from Its Simplification, Transformation and Enhanced Business Performance Priorities.Citi has been pursuing overall simplification initiatives to enhance its client focus and reduce expenses.\"",
        "Reworded sentence: \"Regulatory and legislative changes have also significantly increased Citi’s compliance risks and costs (see the implementation and interpretation of regulatory scrutiny and changes risk factor below) and can adversely affect Citi’s competitive position, as well as its businesses, revenues, results of operations and financial condition.\""
      ],
      "current_body": "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 numerous and subject to change, examples include, but are not limited to, the following: •potential changes to U.S. laws or regulations with respect to credit cards, including a possible cap on interest rates •potential changes to various aspects of the U.S. regulatory capital framework and requirements applicable to Citi (see the capital return risk factor and “Capital Resources—Regulatory Capital Standards and Developments” above) •potential fiscal, monetary, tax, sanctions and other changes promulgated by the U.S. federal government and other governments (see the macroeconomic challenges and uncertainties and changes to interest rates risk factors above)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. 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 planning difficult, subject to change, and potentially more costly and may impact its results of operations. U.S. and other regulators globally continue to discuss various changes to regulatory requirements, which 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 regulatoryscrutiny and 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 May Be Unable to Achieve Its Objectives from Its Simplification, Transformation and Enhanced Business Performance Priorities.Citi has been pursuing overall simplification initiatives to enhance its client focus and reduce expenses. Citi’s simplification initiatives, including completing its divestiture of Banamex, involve various execution challenges, may take longer than expected and may result in higher expenses, or lower than expected expense savings, CTA and other losses or other negative financial or strategic impacts, which could be material, and litigation and regulatory scrutiny (for information about CTA impacts, see the changes in or incorrect assumptions risk factor below).As part of its multiyear transformation, Citi also continues to make significant investments and undertake substantial actions across the Company to modernize its data andtechnology infrastructure, further strengthen its risk and controls environment and further enhance safety and soundness (see “Citi’s Multiyear Transformation” above and the legal and regulatory proceedings risk factor below). •potential fiscal, monetary, tax, sanctions and other changes promulgated by the U.S. federal government and other governments (see the macroeconomic challenges and uncertainties and changes to interest rates risk factors above) 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. 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 planning difficult, subject to change, and potentially more costly and may impact its results of operations. U.S. and other regulators globally continue to discuss various changes to regulatory requirements, which 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 scrutiny and changes risk factor below) and can adversely affect Citi’s competitive position, as well as its businesses, revenues, results of operations and financial condition.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Corporate Credit Portfolio",
      "prior_title": "Corporate Credit Portfolio",
      "similarity_score": 0.744,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"The following table details Citi’s corporate credit portfolio across Services, Markets, Banking and the Mexico SBMM portion of All Other—Legacy Franchises, and before consideration of collateral or hedges, by remaining tenor or expiration for the periods indicated: December 31, 2025September 30, 2025December 31, 2024In 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)(2)$151 $136 $50 $337 $145 $132 $50 $327 $133 $122 $39 $294 Unfunded lending commitments (off-balance sheet)(3)(4)141 311 28 480 147 307 27 481 131 274 24 429 Total exposure$292 $447 $78 $817 $292 $439 $77 $808 $264 $396 $63 $723 Direct outstandings (on-balance sheet)(1)(2) Unfunded lending commitments (off-balance sheet)(3)(4) (1) Includes drawn loans, overdrafts, bankers’ acceptances and leases.\"",
        "Reworded sentence: \"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 parental support or collateral.\""
      ],
      "current_body": "The following table details Citi’s corporate credit portfolio across Services, Markets, Banking and the Mexico SBMM portion of All Other—Legacy Franchises, and before consideration of collateral or hedges, by remaining tenor or expiration for the periods indicated: December 31, 2025September 30, 2025December 31, 2024In 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)(2)$151 $136 $50 $337 $145 $132 $50 $327 $133 $122 $39 $294 Unfunded lending commitments (off-balance sheet)(3)(4)141 311 28 480 147 307 27 481 131 274 24 429 Total exposure$292 $447 $78 $817 $292 $439 $77 $808 $264 $396 $63 $723 Direct outstandings (on-balance sheet)(1)(2) Unfunded lending commitments (off-balance sheet)(3)(4) (1) Includes drawn loans, overdrafts, bankers’ acceptances and leases. (2) Excludes loans carried at fair value of $6.8 billion and HFS of $5.2 billion as of December 31, 2025. (3) Includes unused commitments to lend, letters of credit and financial guarantees. (4) Includes lending-related commitments carried at fair value and HFS as of December 31, 2025. Portfolio Mix—Geography and CounterpartyCiti’s corporate credit portfolio is diverse across geographies and types of counterparties. The following table presents the percentages of this portfolio across North America and the clusters within International based on the country of risk of the obligor (for additional information on Citi’s international exposures, see “Other Risks—Country Risk—Top 25 Country Exposures” below):December 31,2025September 30,2025December 31,2024North America58 %57 %56 %International42 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)Europe16 %17 %16 %LATAM7 7 7 United Kingdom6 6 6 Japan, Asia North and Australia (JANA)6 6 6 Asia South4 4 5 Middle East, Africa and Russia (MEA)3 3 4 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 parental 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 31,2025September 30,2025December 31,2024AAA/AA/A49 %48 %49 %BBB29 29 30 BB/B20 21 19 CCC or below2 2 2 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 geographies and types of counterparties. The following table presents the percentages of this portfolio across North America and the clusters within International based on the country of risk of the obligor (for additional information on Citi’s international exposures, see “Other Risks—Country Risk—Top 25 Country Exposures” below):December 31,2025September 30,2025December 31,2024North America58 %57 %56 %International42 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)Europe16 %17 %16 %LATAM7 7 7 United Kingdom6 6 6 Japan, Asia North and Australia (JANA)6 6 6 Asia South4 4 5 Middle East, Africa and Russia (MEA)3 3 4",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Interest rate exposure(1)(2)",
      "prior_title": "Interest rate exposure(1)(2)",
      "similarity_score": 0.741,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"(2)Includes the effect of changes in interest rates on AOCI related to investment securities, cash flow hedges and pension plans.\"",
        "Reworded sentence: \"The estimated impact to Citi’s net interest income in a 100 bps upward and downward rate shock scenario as of December 31, 2025 remained relatively stable year-over-year.\"",
        "Reworded sentence: \"The estimated impact to Citi’s net interest income in a 100 bps upward and downward rate shock scenario as of December 31, 2025 remained relatively stable year-over-year.\"",
        "Reworded sentence: \"The estimated impact to Citi’s net interest income in a 100 bps upward and downward rate shock scenario as of December 31, 2025 remained relatively stable year-over-year.\"",
        "Reworded sentence: \"In a 100 bps upward rate shock scenario, Citi expects that the approximate $2.6 billion initial negative impact to AOCI could potentially be offset in shareholders’ equity through the forecasted interest income and paydowns from Citi’s investment portfolio over a period of approximately 14 months.\""
      ],
      "current_body": "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 plans. (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 and downward rate shock scenario as of December 31, 2025 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), reducing Citi’s IRE sensitivity. At current rate levels Citi assumes it will be unable to pass on a larger share of initial rate declines to depositors, increasing Citi’s IRE sensitivity to a 100 bps downward shock. 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.In a 100 bps upward rate shock scenario, Citi expects that the approximate $2.6 billion initial negative impact to AOCI could potentially be offset in shareholders’ equity through the forecasted interest income and paydowns from Citi’s investment portfolio over a period of approximately 14 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 and downward rate shock scenario as of December 31, 2025 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), reducing Citi’s IRE sensitivity. At current rate levels Citi assumes it will be unable to pass on a larger share of initial rate declines to depositors, increasing Citi’s IRE sensitivity to a 100 bps downward shock. 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 and downward rate shock scenario as of December 31, 2025 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), reducing Citi’s IRE sensitivity. At current rate levels Citi assumes it will be unable to pass on a larger share of initial rate declines to depositors, increasing Citi’s IRE sensitivity to a 100 bps downward shock. 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. In a 100 bps upward rate shock scenario, Citi expects that the approximate $2.6 billion initial negative impact to AOCI could potentially be offset in shareholders’ equity through the forecasted interest income and paydowns from Citi’s investment portfolio over a period of approximately 14 months. In a 100 bps upward rate shock scenario, Citi expects that the approximate $2.6 billion initial negative impact to AOCI could potentially be offset in shareholders’ equity through the forecasted interest income and paydowns from Citi’s investment portfolio over a period of approximately 14 months. 99 99 99 Scenario AnalysisThe 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 as of December 31, 2025. 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. These scenarios include the following:•a parallel shift involving changes to both short-term and long-term rates by an equal amount •a steeper yield curve involving holding short-term rates constant and increasing long-term rates or holding long-term rates constant and decreasing short term rates•a flatter yield curve involving increasing short-term rates and holding long-term rates constant or holding short-term rates constant and decreasing long-term rates Scenario AnalysisThe 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 as of December 31, 2025. 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.",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "All Other—Legacy Franchises (managed basis)(3)",
      "prior_title": "All Other—Legacy Franchises (managed basis)(3)",
      "similarity_score": 0.74,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"Asia Consumer (managed basis)(3)(4) Reconciling Items(3) (1)Average loans include interest and fees on credit cards.\"",
        "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 ongoing divestiture of Banamex, within Legacy Franchises.\"",
        "Reworded sentence: \"(4)Asia Consumer NCLs and average loan balances, reported within All Other—Legacy Franchises, include the three remaining Asia Consumer loan portfolios: Korea, Poland (through the first quarter of 2025) and Russia until the completion of its consumer loan portfolio wind-down in the second quarter of 2025.\"",
        "Removed sentence: \"See footnote 3 to this table.\""
      ],
      "current_body": "Asia Consumer (managed basis)(3)(4) 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 ongoing divestiture of Banamex, within Legacy Franchises. The Reconciling Items are reflected in Citi’s Consolidated Statement of Income. See “All Other—Divestiture-Related Impacts (Reconciling Items)” above. (4)Asia Consumer NCLs and average loan balances, reported within All Other—Legacy Franchises, include the three remaining Asia Consumer loan portfolios: Korea, Poland (through the first quarter of 2025) and Russia until the completion of its consumer loan portfolio wind-down in the second quarter of 2025. Citi’s Poland consumer banking business was classified as HFS during the second quarter of 2025 as a result of Citi’s agreement to sell the business. In accordance with 81 81 81 HFS accounting treatment, the Poland consumer average loans of approximately $1 billion in 2025 are recorded in Other assets on the Consolidated Balance Sheet, and the related NCLs of approximately $1 million in 2025 are recorded as a reduction to Other revenue. Other Asia Consumer businesses classified as HFS in Other assets and Other liabilities on the Consolidated Balance Sheet include approximately $0 million and $25 million in NCLs recorded as reductions to Other revenue in 2024 and 2023, respectively. Accordingly, these NCLs are not included in this table. See Note 2.",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Interest Income/Expense and Net Interest Margin (NIM)",
      "prior_title": "Interest Income/Expense and Net Interest Margin (NIM)",
      "similarity_score": 0.736,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"In millions of dollars, except as otherwise noted2025 2024 2023Change 2025 vs.\""
      ],
      "current_body": "In millions of dollars, except as otherwise noted2025 2024 2023Change 2025 vs. 2024Change 2024 vs. 2023Interest income(1)$142,970 $143,807 $133,359 (1)%8 %Interest expense(2)83,072 89,618 78,358 (7)14 Net interest income, taxable equivalent basis(1)$59,898 $54,189 $55,001 11 %(1)%Interest income—average rate(3)5.89 %6.36 %5.97 %(47)bps39 bpsInterest expense—average rate4.19 4.90 4.35 (71)bps55 bpsNet interest margin(3)(4)2.47 2.40 2.46 7 bps(6)bpsInterest rate benchmarks Two-year U.S. Treasury note—average rate3.81 %4.37 %4.58 %(56)bps(21)bps10-year U.S. Treasury note—average rate4.29 4.21 3.96 8 bps25 bps10-year vs. two-year spread48 bps(16)bps(62)bps Change",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Allowance for Credit Losses on Loans (ACLL)",
      "prior_title": "Allowance for Credit Losses on Loans (ACLL)",
      "similarity_score": 0.733,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"The following tables detail information on Citi’s ACLL, loans and coverage ratios: December 31, 2025In billions of dollarsACLLEOP loans, net ofunearned incomeACLL as a% of EOP loans(1)ConsumerNorth America cards(2)$13.3 $173.7 7.7 %North America personal installment loans0.4 3.8 10.5 North America mortgages(3)0.1 122.6 0.1 North America other(3)0.2 29.4 0.7 International cards1.2 14.7 8.2 International other(3)0.9 64.3 1.4 Total(1)$16.1 $408.5 4.0 %Corporate(4)Commercial and industrial$1.8 $151.8 1.2 %Financial institutions0.3 98.9 0.3 Mortgage and real estate(4)0.7 27.8 2.5 Installment and other0.3 58.4 0.5 Total(1)$3.1 $336.9 0.9 %Loans at fair value(1)N/A$6.9 N/ATotal Citigroup$19.2 $752.2 2.6 % ACLL as a\""
      ],
      "current_body": "The following tables detail information on Citi’s ACLL, loans and coverage ratios: December 31, 2025In billions of dollarsACLLEOP loans, net ofunearned incomeACLL as a% of EOP loans(1)ConsumerNorth America cards(2)$13.3 $173.7 7.7 %North America personal installment loans0.4 3.8 10.5 North America mortgages(3)0.1 122.6 0.1 North America other(3)0.2 29.4 0.7 International cards1.2 14.7 8.2 International other(3)0.9 64.3 1.4 Total(1)$16.1 $408.5 4.0 %Corporate(4)Commercial and industrial$1.8 $151.8 1.2 %Financial institutions0.3 98.9 0.3 Mortgage and real estate(4)0.7 27.8 2.5 Installment and other0.3 58.4 0.5 Total(1)$3.1 $336.9 0.9 %Loans at fair value(1)N/A$6.9 N/ATotal Citigroup$19.2 $752.2 2.6 % ACLL as a",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "CREDIT RISK",
      "prior_title": "CREDIT RISK",
      "similarity_score": 0.716,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"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 (margin loans, repurchase and reverse repurchase agreements and securities loaned and borrowed).\"",
        "Reworded sentence: \"Citi assesses the credit risk associated with its credit exposures not carried at fair value 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 (“Allowance for Credit Losses (ACL)”) and 16), as well as through regular stress testing at the company, business, geography and product levels.\"",
        "Reworded sentence: \"Average LoansThe table below details average loans, by segment and All Other, and the total Citigroup end-of-period loans for each of the periods indicated:In billions of dollars4Q253Q254Q24Services$96 $94 $87 Markets152 147 122 Banking79 81 84 Wealth149 151 148 USPB Branded Cards$122 $120 $117 Retail Services50 50 52 Retail Banking54 50 47 Total USPB$226 $220 $216 All Other$35 $32 $31 Total Citigroup loans (AVG)$737 $725 $688 Total Citigroup loans (EOP)$752 $734 $694 Average loans increased 7% year-over-year and 2% sequentially.\"",
        "Removed sentence: \"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.\"",
        "Removed sentence: \"The year-over-year increase was largely due to growth in USPB, Markets and Services.\""
      ],
      "current_body": "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 (margin loans, 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, as well as through its investment securities portfolio and cash placed with banks. 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 not carried at fair value 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 (“Allowance for Credit Losses (ACL)”) 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. Average LoansThe table below details average loans, by segment and All Other, and the total Citigroup end-of-period loans for each of the periods indicated:In billions of dollars4Q253Q254Q24Services$96 $94 $87 Markets152 147 122 Banking79 81 84 Wealth149 151 148 USPB Branded Cards$122 $120 $117 Retail Services50 50 52 Retail Banking54 50 47 Total USPB$226 $220 $216 All Other$35 $32 $31 Total Citigroup loans (AVG)$737 $725 $688 Total Citigroup loans (EOP)$752 $734 $694 Average loans increased 7% year-over-year and 2% sequentially. The year-over-year increase was primarily driven by growth in Markets, USPB and Services, partially offset by declines in Banking.Year-over-year average loans for: •Services increased 10%, driven by demand in TTS for working capital loans as well as export and agency finance. •Markets increased 25%, primarily driven by asset-backed financing and commercial warehouse lending in Spread Products.•Banking decreased 6%, due to lower aggregate customer demand for funded loans.•Wealth increased 1%, with growth in margin lending primarily offset by the transfers of certain relationships and associated mortgage loans to USPB from Wealth.•USPB increased 5%, driven by growth in Retail Banking, largely due to transfers of certain relationships and associated mortgage loans to USPB from Wealth, as well as growth in Branded Cards.•All Other increased 13%, driven by growth in Mexico Consumer/SBMM (including the impact of Mexican peso appreciation), partially offset by the continued wind-downs in Asia Consumer within Legacy Franchises (including the impact of moving HFS loans to Other assets). for credit losses (ACL) process (see “Significant Accounting Policies and Significant Estimates—Allowance for Credit Losses” below and Notes 1 (“Allowance for Credit Losses (ACL)”) 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.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Non-Accrual Loans",
      "prior_title": "Non-Accrual Loans",
      "similarity_score": 0.709,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"In situations where Citi reasonably expects that none or 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.\"",
        "Reworded sentence: \"The increase in corporate non-accrual loans at December 31, 2025 was driven by idiosyncratic credit downgrades.\""
      ],
      "current_body": "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 none or 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. The increase in corporate non-accrual loans at December 31, 2025 was driven by idiosyncratic credit downgrades. The increase in consumer non-accrual loans at December 31, 2025 was driven by residential mortgage loans impacted by the California wildfires and higher loan balances and the impact of FX translation in Mexico Consumer. The increase in corporate non-accrual loans at December 31, 2025 was driven by idiosyncratic credit downgrades. The increase in consumer non-accrual loans at December 31, 2025 was driven by residential mortgage loans impacted by the California wildfires and higher loan balances and the impact of FX translation in Mexico Consumer. December 31,In millions of dollars20252024202320222021Corporate non-accrual loans by region(1)(2)(3)North America$1,145 $757 $978 $138 $510 International856 620 904 984 1,043 Total$2,001 $1,377 $1,882 $1,122 $1,553 International NAL by clusterUnited Kingdom$127 $190 $268 $288 $227 Japan, Asia North and Australia (JANA)9 22 70 50 82 LATAM576 301 367 429 568 Asia South29 17 35 3 26 Europe100 58 139 117 88 Middle East, Africa and Russia (MEA)15 32 25 97 52 Corporate non-accrual loans(1)(2)(3)Banking$919 $498 $799 $757 $1,166 Services3376510315370Markets622715791371Mexico SBMM and AFG12399189209246Total$2,001 $1,377 $1,882 $1,122 $1,553 Consumer non-accrual loans(1)Wealth$526 $404 $288 $259 $336 USPB343 290 291 282 344 Mexico Consumer585 411 479 457 524 Asia Consumer(4)15 19 22 30 209 Legacy Holdings Assets (consumer)149 186 235 289 413 Total $1,618 $1,310 $1,315 $1,317 $1,826 Total non-accrual loans$3,619 $2,687 $3,197 $2,439 $3,379",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Second Line of Defense",
      "prior_title": "First Line of Defense: Front Line Units and Front Line Unit Activities",
      "similarity_score": 0.707,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"The second line of defense is independent of the first line of defense.\""
      ],
      "current_body": "The second line of defense is independent of the first line of defense. It is responsible for overseeing the risk-taking activities of the first line of defense and challenging the first line of defense in the execution of its risk management responsibilities. It is also responsible for independently identifying, measuring, monitoring, controlling and reporting aggregate risks and for setting standards for the management and oversight of risk. The second line of defense is composed of Independent Risk Management (IRM) and Independent Compliance Risk Management (ICRM), which are led by the Group Chief Risk Officer (CRO) and Group Chief Compliance Officer (CCO), respectively, who have unrestricted access to the Board and its Risk Management Committee to facilitate the ability to execute their specific responsibilities pertaining to escalation to the Board.",
      "prior_body": "Citi’s first line of defense owns the risks and associated controls inherent in, or arising from, the execution of its business activities and is responsible for identifying, measuring, monitoring, controlling and reporting those risks consistent with Citi’s strategy, Mission and Value Proposition, Leadership Principles and risk appetite. Front line units are responsible and held accountable for managing the risks associated with their activities within the boundaries set by independent risk management. They are also responsible for designing and implementing effective internal controls and maintaining processes for managing their risk profile, including through risk mitigation, so that it remains consistent with Citi’s established risk appetite. Front line unit activities are considered part of the first line of defense and are subject to the oversight and challenge of independent risk management. The first line of defense is composed of Citi’s operating segments (i.e., Services, Markets, Banking, Wealth, U.S. Personal Banking), as well as International, North America and All Other (including certain corporate functions (i.e., Chief Operating Office, Enterprise Services and Public Affairs, Finance, Technology and Business Enablement). In addition, the first line of defense includes the front line unit activities of other organizational units. Front line units may also include lower-level enterprise support functions and/or conduct enterprise support activities—see “Enterprise Support Functions” below.Second Line of Defense: Independent Risk Management Independent risk management units are independent of the first line of defense. They are responsible for overseeing the risk-taking activities of the first line of defense and challenging the first line of defense in the execution of its risk management responsibilities. They are also responsible for independently identifying, measuring, monitoring, controlling and reporting aggregate risks and for setting standards for the management and oversight of risk. Independent risk management is composed of Independent Risk Management (IRM) and Independent Compliance Risk Management (ICRM), which are led by the Group Chief Risk Officer (CRO) and Group Chief Compliance Officer (CCO) who have unrestricted access to the Board and its Risk Management Committee to facilitate the ability to execute their specific responsibilities pertaining to escalation to the Board.Independent Risk ManagementThe IRM organization sets risk and control standards for the first line of defense and actively manages and oversees aggregate credit, market (trading and non-trading), liquidity, strategic, operational and reputation risks across Citi, including risks that span categories, such as concentration risk, country risk and climate risk. IRM is organized to align to businesses, risk categories, legal entities/clusters and Company-wide, cross-risk functions or processes. Each of these units reports to a member of the Risk Management Executive Council, who all report to the Citigroup CRO.Independent Compliance Risk Management 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. Affairs, Finance, Technology and Business Enablement). In addition, the first line of defense includes the front line unit activities of other organizational units. Front line units may also include lower-level enterprise support functions and/or conduct enterprise support activities—see “Enterprise Support Functions” below. Second Line of Defense: Independent Risk Management Independent risk management units are independent of the first line of defense. They are responsible for overseeing the risk-taking activities of the first line of defense and challenging the first line of defense in the execution of its risk management responsibilities. They are also responsible for independently identifying, measuring, monitoring, controlling and reporting aggregate risks and for setting standards for the management and oversight of risk. Independent risk management is composed of Independent Risk Management (IRM) and Independent Compliance Risk Management (ICRM), which are led by the Group Chief Risk Officer (CRO) and Group Chief Compliance Officer (CCO) who have unrestricted access to the Board and its Risk Management Committee to facilitate the ability to execute their specific responsibilities pertaining to escalation to the Board."
    },
    {
      "status": "MODIFIED",
      "current_title": "Total fixed/variable pricing of corporate loans with maturities due after one year, net of unearned income(3)(4)",
      "prior_title": "Total fixed/variable pricing of corporate loans with maturities due after one year, net of unearned income(3)(4)",
      "similarity_score": 0.702,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"(3) Corporate loans are net of unearned income of $(1.1) billion.\"",
        "Reworded sentence: \"(4) Excludes $17 million of unallocated portfolio-layer cumulative basis adjustments at December 31, 2025.\"",
        "Removed sentence: \"78 78 78 CONSUMER CREDITCiti's consumer credit risk management framework is designed for a variety of environments.\"",
        "Removed sentence: \"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.\"",
        "Removed sentence: \"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.\""
      ],
      "current_body": "(1) North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America. The classification between offices in North America and outside North America is based on the domicile of the booking unit. The differences between the domicile of the booking unit and the domicile of the managing unit are not material. (2) Loans secured primarily by real estate. (3) Corporate loans are net of unearned income of $(1.1) billion. Unearned income on corporate loans primarily represents loan origination fees, net of certain direct origination costs, that are deferred and recognized as Interest income over the lives of the related loans. (4) Excludes $17 million of unallocated portfolio-layer cumulative basis adjustments at December 31, 2025. (5) Based on contractual terms. Repricing characteristics may effectively be modified from time to time using derivative contracts. See Note 24. (6) Other includes installment and other and loans to government and official institutions. 74 74 74",
      "prior_body": "(1) North America includes the U.S., Canada and Puerto Rico. Mexico is included in offices outside North America. The classification between offices in North America and outside North America is based on the domicile of the booking unit. The differences between the domicile of the booking unit and the domicile of the managing unit are not material. (2) Loans secured primarily by real estate. (3) Corporate loans are net of unearned income of $(969) million. Unearned income on corporate loans primarily represents loan origination fees, net of certain direct origination costs, that are deferred and recognized as Interest income over the lives of the related loans. (4) Excludes $(72) million of unallocated portfolio-layer cumulative basis adjustments at December 31, 2024. (5) Based on contractual terms. Repricing characteristics may effectively be modified from time to time using derivative contracts. See Note 24. (6) Other includes installment and other and loans to government and official institutions. 78 78 78 CONSUMER CREDITCiti'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). CONSUMER CREDITCiti'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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Long-Term Liquidity Measurement: Net Stable Funding Ratio (NSFR)",
      "prior_title": "Markets(1)",
      "similarity_score": 0.686,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"The NSFR measures the availability of an institution’s stable funding against the required stable funding in accordance with U.S.\"",
        "Reworded sentence: \"During 2025, Citi redeemed or repurchased an aggregate of $63.3 billion of its outstanding LTD.\""
      ],
      "current_body": "The NSFR measures the availability of an institution’s stable funding against the required stable funding in accordance with U.S. NSFR rules. 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, 2025, 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, 2025 and September 30, 2025, 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). 92 92 92 Deposits The table below details average deposits, by segment and/or business, and the total Citigroup end-of-period deposits for each of the periods indicated:In billions of dollars4Q253Q254Q24Services$935 $893 $839 TTS 780 744 704 Securities Services155 149 135 Markets20 20 15 Banking1 1 1 Wealth319 315 315 USPB88 90 86 All Other—Legacy Franchises42 40 42 All Other—Corporate/Other17 23 22 Total Citigroup deposits (AVG)$1,422 $1,382 $1,320 Total Citigroup deposits (EOP)$1,404 $1,384 $1,284 On an average basis, total deposits increased 8% year-over-year and 3% sequentially, both driven by corporate deposits. Year-over-year, average deposits for: •Services increased 11%, driven by both TTS and Securities Services, reflecting growth in International and North America, largely driven by an increase in operational deposits.•Wealth increased 1%, driven by client transfers from USPB and net new deposits, largely offset by outflows, including a shift from deposits to higher-yielding investments. •USPB increased 2%, as net new deposits growth was primarily offset by the transfer of certain relationships and the associated deposits to Wealth.•All Other decreased 8%, reflecting a decrease in corporate certificates of deposit in Corporate/Other, as continued wind-downs in Asia Consumer within Legacy Franchises (including the impact of moving HFS deposits to Other liabilities) were offset by growth in Legacy Franchises Mexico deposits (including the impact of Mexican peso appreciation).The majority of Citi’s $1.4 trillion of end-of-period deposits are institutional (approximately $934 billion) and span approximately 90 countries. A large majority of these institutional deposits are within TTS, and of these, over 70% are from clients that use all three TTS integrated services: payments and collections, liquidity management and working capital solutions. In addition, approximately 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 $413 billion of USPB and Wealth end-of-period deposits, which are diversified across the Private Bank, Citigold and Wealth at Work within Wealth, as well as Retail Banking within USPB. As of year end, approximately 65% of Wealth’s U.S. Citigold clients have been with Citi for more than 10 years and approximately 38% of Private Bank ultra-high net worth clients have been with Citi for more than 10 years. In addition, USPB’s Retail Banking deposits are spread across six key metropolitan areas in the U.S.Long-Term Debt (LTD)LTD (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. The following table presents Citi’s end-of-period total LTD outstanding for each of the dates indicated:In billions of dollarsDec. 31, 2025Sep. 30, 2025Dec. 31, 2024Non-bank(1)Benchmark debt:Senior debt$117.5 $115.0 $107.4 Subordinated debt28.7 28.7 28.7 Trust preferred1.6 1.6 1.6 Customer-related debt(2)116.7 116.4 103.3 Local country and other(3)14.8 13.6 9.6 Total non-bank$279.3 $275.3 $250.6 BankFHLB borrowings$3.0 $6.0 $8.5 Securitizations(4)5.2 6.7 5.1 Citibank benchmark senior debt23.5 23.5 19.4 Customer-related debt(2)2.7 2.8 1.2 Local country and other(3)2.1 1.5 2.5 Total bank$36.5 $40.5 $36.7 Total LTD$315.8 $315.8 $287.3 Note: Amounts represent the current value of LTD 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 LTD 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, 2025, non-bank included $101.5 billion of LTD 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) Primarily structured notes, which contain an embedded derivative component that adjusts each security’s risk-return profile. See Note 27 for the fair value component of these issuances.(3) 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.(4) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.For information about changes in Citi’s end-of-period long-term debt, see “Balance Sheet Overview” above.As part of its liability management, Citi has considered, and may continue to consider, opportunities to redeem or repurchase its LTD pursuant to open market purchases, tender offers or other means. Such redemptions and repurchases help reduce Citi’s overall funding costs. During 2025, Citi redeemed or repurchased an aggregate of $63.3 billion of its outstanding LTD. Deposits The table below details average deposits, by segment and/or business, and the total Citigroup end-of-period deposits for each of the periods indicated:In billions of dollars4Q253Q254Q24Services$935 $893 $839 TTS 780 744 704 Securities Services155 149 135 Markets20 20 15 Banking1 1 1 Wealth319 315 315 USPB88 90 86 All Other—Legacy Franchises42 40 42 All Other—Corporate/Other17 23 22 Total Citigroup deposits (AVG)$1,422 $1,382 $1,320 Total Citigroup deposits (EOP)$1,404 $1,384 $1,284 On an average basis, total deposits increased 8% year-over-year and 3% sequentially, both driven by corporate deposits. Year-over-year, average deposits for: •Services increased 11%, driven by both TTS and Securities Services, reflecting growth in International and North America, largely driven by an increase in operational deposits.•Wealth increased 1%, driven by client transfers from USPB and net new deposits, largely offset by outflows, including a shift from deposits to higher-yielding investments. •USPB increased 2%, as net new deposits growth was primarily offset by the transfer of certain relationships and the associated deposits to Wealth.•All Other decreased 8%, reflecting a decrease in corporate certificates of deposit in Corporate/Other, as continued wind-downs in Asia Consumer within Legacy Franchises (including the impact of moving HFS deposits to Other liabilities) were offset by growth in Legacy Franchises Mexico deposits (including the impact of Mexican peso appreciation).The majority of Citi’s $1.4 trillion of end-of-period deposits are institutional (approximately $934 billion) and span approximately 90 countries. A large majority of these institutional deposits are within TTS, and of these, over 70% are from clients that use all three TTS integrated services: payments and collections, liquidity management and working capital solutions. In addition, approximately 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 $413 billion of USPB and Wealth end-of-period deposits, which are diversified across the Private Bank, Citigold and Wealth at Work within Wealth, as well as Retail Banking within USPB. As of year end, approximately 65% of Wealth’s U.S. Citigold clients have been with Citi for more than 10 years and approximately 38% of Private Bank ultra-high net worth Deposits The table below details average deposits, by segment and/or business, and the total Citigroup end-of-period deposits for each of the periods indicated: In billions of dollars4Q253Q254Q24Services$935 $893 $839 TTS 780 744 704 Securities Services155 149 135 Markets20 20 15 Banking1 1 1 Wealth319 315 315 USPB88 90 86 All Other—Legacy Franchises42 40 42 All Other—Corporate/Other17 23 22 Total Citigroup deposits (AVG)$1,422 $1,382 $1,320 Total Citigroup deposits (EOP)$1,404 $1,384 $1,284 Securities Services All Other—Legacy Franchises All Other—Corporate/Other On an average basis, total deposits increased 8% year-over-year and 3% sequentially, both driven by corporate deposits. Year-over-year, average deposits for: •Services increased 11%, driven by both TTS and Securities Services, reflecting growth in International and North America, largely driven by an increase in operational deposits. •Wealth increased 1%, driven by client transfers from USPB and net new deposits, largely offset by outflows, including a shift from deposits to higher-yielding investments. •USPB increased 2%, as net new deposits growth was primarily offset by the transfer of certain relationships and the associated deposits to Wealth. •All Other decreased 8%, reflecting a decrease in corporate certificates of deposit in Corporate/Other, as continued wind-downs in Asia Consumer within Legacy Franchises (including the impact of moving HFS deposits to Other liabilities) were offset by growth in Legacy Franchises Mexico deposits (including the impact of Mexican peso appreciation). The majority of Citi’s $1.4 trillion of end-of-period deposits are institutional (approximately $934 billion) and span approximately 90 countries. A large majority of these institutional deposits are within TTS, and of these, over 70% are from clients that use all three TTS integrated services: payments and collections, liquidity management and working capital solutions. In addition, approximately 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 $413 billion of USPB and Wealth end-of-period deposits, which are diversified across the Private Bank, Citigold and Wealth at Work within Wealth, as well as Retail Banking within USPB. As of year end, approximately 65% of Wealth’s U.S. Citigold clients have been with Citi for more than 10 years and approximately 38% of Private Bank ultra-high net worth clients have been with Citi for more than 10 years. In addition, USPB’s Retail Banking deposits are spread across six key metropolitan areas in the U.S.Long-Term Debt (LTD)LTD (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. The following table presents Citi’s end-of-period total LTD outstanding for each of the dates indicated:In billions of dollarsDec. 31, 2025Sep. 30, 2025Dec. 31, 2024Non-bank(1)Benchmark debt:Senior debt$117.5 $115.0 $107.4 Subordinated debt28.7 28.7 28.7 Trust preferred1.6 1.6 1.6 Customer-related debt(2)116.7 116.4 103.3 Local country and other(3)14.8 13.6 9.6 Total non-bank$279.3 $275.3 $250.6 BankFHLB borrowings$3.0 $6.0 $8.5 Securitizations(4)5.2 6.7 5.1 Citibank benchmark senior debt23.5 23.5 19.4 Customer-related debt(2)2.7 2.8 1.2 Local country and other(3)2.1 1.5 2.5 Total bank$36.5 $40.5 $36.7 Total LTD$315.8 $315.8 $287.3 Note: Amounts represent the current value of LTD 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 LTD 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, 2025, non-bank included $101.5 billion of LTD 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) Primarily structured notes, which contain an embedded derivative component that adjusts each security’s risk-return profile. See Note 27 for the fair value component of these issuances.(3) 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.(4) Predominantly credit card securitizations, primarily backed by Branded Cards receivables.For information about changes in Citi’s end-of-period long-term debt, see “Balance Sheet Overview” above.As part of its liability management, Citi has considered, and may continue to consider, opportunities to redeem or repurchase its LTD pursuant to open market purchases, tender offers or other means. Such redemptions and repurchases help reduce Citi’s overall funding costs. During 2025, Citi redeemed or repurchased an aggregate of $63.3 billion of its outstanding LTD. clients have been with Citi for more than 10 years. In addition, USPB’s Retail Banking deposits are spread across six key metropolitan areas in the U.S.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Taxable Equivalent Basis",
      "prior_title": "Taxable Equivalent Basis",
      "similarity_score": 0.683,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"AssetsAverage balanceInterest income% Average rateIn millions of dollars, except rates202520242023202520242023202520242023Deposits with banks(4)$311,204 $263,236 $287,518 $12,669 $11,417 $11,238 4.07 %4.34 %3.91 %Securities borrowed and purchased under agreements to resell(5)In U.S.\""
      ],
      "current_body": "AssetsAverage balanceInterest income% Average rateIn millions of dollars, except rates202520242023202520242023202520242023Deposits with banks(4)$311,204 $263,236 $287,518 $12,669 $11,417 $11,238 4.07 %4.34 %3.91 %Securities borrowed and purchased under agreements to resell(5)In U.S. offices$188,943 $149,521 $171,307 $15,730 $13,492 $13,194 8.33 %9.02 %7.70 %In offices outside the U.S.(4)175,933 194,417 189,548 11,232 15,681 13,693 6.38 8.07 7.22 Total$364,876 $343,938 $360,855 $26,962 $29,173 $26,887 7.39 %8.48 %7.45 %Trading account assets(6)(7)In U.S. offices$278,378 $233,698 $187,318 $11,875 $11,103 $8,808 4.27 %4.75 %4.70 %In offices outside the U.S.(4)219,442 162,227 144,684 8,922 6,473 5,652 4.07 3.99 3.91 Total$497,820 $395,925 $332,002 $20,797 $17,576 $14,460 4.18 %4.44 %4.36 %InvestmentsIn U.S. officesTaxable$241,967 $307,066 $335,975 $6,236 $7,952 $8,903 2.58 %2.59 %2.65 %Exempt from U.S. income tax10,611 11,170 11,502 409 441 454 3.85 3.95 3.95 In offices outside the U.S.(4)199,141 184,536 164,923 10,114 10,299 8,978 5.08 5.58 5.44 Total$451,719 $502,772 $512,400 $16,759 $18,692 $18,335 3.71 %3.72 %3.58 %Consumer loans(8)In U.S. offices$317,149 $309,668 $293,476 $33,313 $32,684 $30,127 10.50 %10.55 %10.27 %In offices outside the U.S.(4)76,557 75,215 78,420 6,487 6,858 6,737 8.47 9.12 8.59 Total$393,706 $384,883 $371,896 $39,800 $39,542 $36,864 10.11 %10.27 %9.91 %Corporate loans(8)In U.S. offices$153,040 $137,047 $136,065 $8,967 $8,944 $7,561 5.86 %6.53 %5.56 %In offices outside the U.S.(4)169,416 161,294 153,111 11,779 13,682 13,507 6.95 8.48 8.82 Total$322,456 $298,341 $289,176 $20,746 $22,626 $21,068 6.43 %7.58 %7.29 %Total loans(8)In U.S. offices$470,189 $446,715 $429,541 $42,280 $41,628 $37,688 8.99 %9.32 %8.77 %In offices outside the U.S.(4)245,973 236,509 231,531 18,266 20,540 20,244 7.43 8.68 8.74 Total$716,162 $683,224 $661,072 $60,546 $62,168 $57,932 8.45 %9.10 %8.76 %Other interest-earning assets(9)$84,970 $73,418 $81,431 $5,237 $4,781 $4,507 6.16 %6.51 %5.53 %Total interest-earning assets$2,426,751 $2,262,513 $2,235,278 $142,970 $143,807 $133,359 5.89 %6.36 %5.97 %Non-interest-earning assets(6)$217,318 $205,918 $206,955 Total assets$2,644,069 $2,468,431 $2,442,233",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Rating of Hedged Exposure",
      "prior_title": "Rating of Hedged Exposure",
      "similarity_score": 0.647,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"December 31,2025September 30,2025December 31,2024AAA/AA/A47 %47 %44 %BBB41 41 45 BB/B11 11 10 CCC or below1 1 1 Total100 %100 %100 % 73 73 73\""
      ],
      "current_body": "December 31,2025September 30,2025December 31,2024AAA/AA/A47 %47 %44 %BBB41 41 45 BB/B11 11 10 CCC or below1 1 1 Total100 %100 %100 % 73 73 73",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "HUMAN CAPITAL RESOURCES AND MANAGEMENT",
      "prior_title": "Pay Transparency and Pay Equity",
      "similarity_score": 0.644,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"At December 31, 2025, Citi had approximately 226,000 full-time employees, compared to approximately 229,000 at December 31, 2024.\"",
        "Reworded sentence: \"Citi’s annual pay equity analysis for 2025 determined that on an adjusted basis, global gender and U.S.\"",
        "Added sentence: \"Citi employs numerous initiatives in managing its workforce to drive a culture of excellence and accountability, reinforce its values, encourage career growth, foster pay transparency and equity and provide a wide range of benefits that support its employees’ mental, social, physical and financial well-being.\""
      ],
      "current_body": "At December 31, 2025, Citi had approximately 226,000 full-time employees, compared to approximately 229,000 at December 31, 2024. Citi has employees in over 90 countries, across all of its segments. Approximately 31% are based in the U.S. Attracting and retaining highly qualified and motivated employees is a strategic priority. Citi seeks to enhance the competitive strength of its workforce through: •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 Citi values pay transparency and 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 align with Citi’s commitment to 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 2025 determined that on an adjusted basis, global gender and U.S. racial base pay gaps are in each case less than 1%. The raw pay gap analysis determined that the median base pay for women globally is 81% of the median for men globally and the U.S. racial base pay gap is 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. Citi employs numerous initiatives in managing its workforce to drive a culture of excellence and accountability, reinforce its values, encourage career growth, foster pay transparency and equity and provide a wide range of benefits that support its employees’ mental, social, physical and financial well-being. 62 62 62",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Retail Services",
      "prior_title": "Retail Services",
      "similarity_score": 0.632,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"USPB’s Retail Services partners with more than 20 retailers and dealers to offer private label and co-brand cards.\"",
        "Reworded sentence: \"As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Retail Services increased quarter-over-quarter, driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance.\"",
        "Reworded sentence: \"The delinquency-managed portfolio consists primarily of mortgages and credit cards.As of December 31, 2025, approximately $48 billion, or 32%, of the portfolios were classifiably managed and primarily consisted of margin loans, commercial real estate loans, personal and small business loans and other lending programs.\""
      ],
      "current_body": "USPB’s Retail Services partners with more than 20 retailers and dealers to offer private label and co-brand cards. Retail Services’ target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel. As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Retail Services increased quarter-over-quarter, driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance. The 90+ days past due delinquency rate was broadly stable quarter-over-quarter, and decreased year-over-year, reflecting improvements in portfolio performance. 77 77 77 For additional details on provisions for credit losses, loan delinquency and other information for Citi’s cards portfolios, see USPB’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 revolving products. 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 2025 net credit loss rate for Retail Banking increased quarter-over-quarter, driven by consumer overdraft losses, and was broadly stable year-over-year.The 90+ days past due delinquency rate decreased quarter-over-quarter, driven by the transfer of certain relationships and associated mortgage loans to Retail Banking from Wealth, and increased year-over-year, driven by consumer mortgages enrolled in forbearance programs related to the California wildfires. WealthAs of December 31, 2025, Wealth provided 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, Citigold and Wealth at Work 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 and credit cards.As of December 31, 2025, approximately $48 billion, or 32%, of the portfolios were classifiably managed and primarily consisted of margin loans, commercial real estate 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 69% were rated investment grade. The 90+ days past due delinquency rates shown in the chart above were calculated only for the delinquency-managed portfolio, while the net credit loss rates were calculated using net credit losses for both the delinquency and classifiably managed portfolios.As presented in the chart above, the fourth quarter of 2025 net credit loss rate in Wealth decreased quarter-over-quarter, primarily driven by write-downs of mortgage loans to their collateral value due to the impact of the California wildfires in the previous quarter, and was broadly stable year-over-year. The 90+ days past due delinquency rate decreased quarter-over-quarter, largely driven by the resumption of payments on consumer mortgages exiting forbearance programs related to the California wildfires. The 90+ days past due delinquency rate increased year-over-year, driven by consumer mortgages that enrolled in forbearance programs related to the California wildfires. The low net credit loss and 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. For additional details on provisions for credit losses, loan delinquency and other information for Citi’s cards portfolios, see USPB’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 revolving products. 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 2025 net credit loss rate for Retail Banking increased quarter-over-quarter, driven by consumer overdraft losses, and was broadly stable year-over-year.The 90+ days past due delinquency rate decreased quarter-over-quarter, driven by the transfer of certain relationships and associated mortgage loans to Retail Banking from Wealth, and increased year-over-year, driven by consumer mortgages enrolled in forbearance programs related to the California wildfires. For additional details on provisions for credit losses, loan delinquency and other information for Citi’s cards portfolios, see USPB’s results of operations above and Note 15.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Retail Services",
      "prior_title": "Retail Services",
      "similarity_score": 0.612,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"31, 2024≥ 74037 %36 %36 %660–73941 41 41 < 66022 23 23 Total100 %100 %100 %\""
      ],
      "current_body": "USPB’s Retail Services partners with more than 20 retailers and dealers to offer private label and co-brand cards. Retail Services’ target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel. As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Retail Services increased quarter-over-quarter, driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance. The 90+ days past due delinquency rate was broadly stable quarter-over-quarter, and decreased year-over-year, reflecting improvements in portfolio performance. 77 77 77 For additional details on provisions for credit losses, loan delinquency and other information for Citi’s cards portfolios, see USPB’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 revolving products. 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 2025 net credit loss rate for Retail Banking increased quarter-over-quarter, driven by consumer overdraft losses, and was broadly stable year-over-year.The 90+ days past due delinquency rate decreased quarter-over-quarter, driven by the transfer of certain relationships and associated mortgage loans to Retail Banking from Wealth, and increased year-over-year, driven by consumer mortgages enrolled in forbearance programs related to the California wildfires. WealthAs of December 31, 2025, Wealth provided 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, Citigold and Wealth at Work 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 and credit cards.As of December 31, 2025, approximately $48 billion, or 32%, of the portfolios were classifiably managed and primarily consisted of margin loans, commercial real estate 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 69% were rated investment grade. The 90+ days past due delinquency rates shown in the chart above were calculated only for the delinquency-managed portfolio, while the net credit loss rates were calculated using net credit losses for both the delinquency and classifiably managed portfolios.As presented in the chart above, the fourth quarter of 2025 net credit loss rate in Wealth decreased quarter-over-quarter, primarily driven by write-downs of mortgage loans to their collateral value due to the impact of the California wildfires in the previous quarter, and was broadly stable year-over-year. The 90+ days past due delinquency rate decreased quarter-over-quarter, largely driven by the resumption of payments on consumer mortgages exiting forbearance programs related to the California wildfires. The 90+ days past due delinquency rate increased year-over-year, driven by consumer mortgages that enrolled in forbearance programs related to the California wildfires. The low net credit loss and 90+ days past due delinquency rates continued to reflect the strong credit profiles of the portfolios. For additional details on provisions for credit losses, loan delinquency and other information for Citi’s cards portfolios, see USPB’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 revolving products. 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 2025 net credit loss rate for Retail Banking increased quarter-over-quarter, driven by consumer overdraft losses, and was broadly stable year-over-year.The 90+ days past due delinquency rate decreased quarter-over-quarter, driven by the transfer of certain relationships and associated mortgage loans to Retail Banking from Wealth, and increased year-over-year, driven by consumer mortgages enrolled in forbearance programs related to the California wildfires. For additional details on provisions for credit losses, loan delinquency and other information for Citi’s cards portfolios, see USPB’s results of operations above and Note 15.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Branded Cards",
      "prior_title": "Branded Cards",
      "similarity_score": 0.608,
      "confidence": "medium",
      "key_changes": [
        "Reworded sentence: \"31, 2024≥ 74055 %55 %56 %660–73933 34 33 < 66012 11 11 Total100 %100 %100 %\""
      ],
      "current_body": "FICO distribution(1)Dec. 31, 2025Sep. 30, 2025Dec. 31, 2024≥ 74055 %55 %56 %660–73933 34 33 < 66012 11 11 Total100 %100 %100 %",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Short-Term Liquidity Measurement: Liquidity Coverage Ratio (LCR)",
      "prior_title": "Short-Term Liquidity Measurement: Liquidity Coverage Ratio (LCR)",
      "similarity_score": 0.597,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"Citi monitors its liquidity by reference to the LCR in addition to internal 30-day liquidity stress testing performed for Citi’s major entities, operating subsidiaries and countries.\"",
        "Reworded sentence: \"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.\"",
        "Reworded sentence: \"For the quarter ended December 31, 2025, Citigroup’s consolidated NSFR was compliant with the 100% minimum requirement of the rule.\""
      ],
      "current_body": "Citi monitors its liquidity by reference to the LCR in addition to internal 30-day liquidity stress testing performed for Citi’s major entities, operating subsidiaries and countries. 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, 2025Sep. 30, 2025Dec. 31, 2024HQLA$607.2 $588.4 $558.4 Net outflows529.3 510.5 480.8 LCR115 %115 %116 %HQLA in excess of net outflows$77.9 $77.9 $77.6 Note: The amounts are presented on an average basis.As of December 31, 2025, Citigroup’s average LCR remained unchanged from the quarter ended September 30, 2025. The increase in average HQLA was offset by an increase in net outflows from unsecured and secured wholesale funding.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 U.S. NSFR rules. 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, 2025, 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, 2025 and September 30, 2025, 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). 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, 2025Sep. 30, 2025Dec. 31, 2024HQLA$607.2 $588.4 $558.4 Net outflows529.3 510.5 480.8 LCR115 %115 %116 %HQLA in excess of net outflows$77.9 $77.9 $77.6 Note: The amounts are presented on an average basis. As of December 31, 2025, Citigroup’s average LCR remained unchanged from the quarter ended September 30, 2025. The increase in average HQLA was offset by an increase in net outflows from unsecured and secured wholesale funding.",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Non-Markets Net Interest Income",
      "prior_title": "Non-Markets Net Interest Income",
      "similarity_score": 0.597,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"In millions of dollars202520242023Total Citi net interest income—taxable equivalent basis(1) per above$59,898 $54,189 $55,001 Less:Markets net interest income—taxable equivalent basis(1)10,115 7,099 7,334 Total Citi non-Markets net interest income—taxable equivalent basis(1)$49,783 $47,090 $47,667 Total Citi net interest income—taxable equivalent basis(1) per above Markets net interest income—taxable equivalent basis(1) Total Citi non-Markets net interest income—taxable equivalent basis(1) (1) Interest income and Net interest income include TEGU discussed in the table above.\""
      ],
      "current_body": "In millions of dollars202520242023Total Citi net interest income—taxable equivalent basis(1) per above$59,898 $54,189 $55,001 Less:Markets net interest income—taxable equivalent basis(1)10,115 7,099 7,334 Total Citi non-Markets net interest income—taxable equivalent basis(1)$49,783 $47,090 $47,667 Total Citi net interest income—taxable equivalent basis(1) per above Markets net interest income—taxable equivalent basis(1) Total Citi 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 2025 was $15.7 billion, on both a reported and taxable equivalent basis, an increase of 14%, or $1.9 billion, from the prior-year period. The growth was due to a 53%, or $1.0 billion, increase in Markets net interest income and an 8%, or $0.9 billion, increase in non-Markets net interest income.Citi’s Markets business is primarily evaluated on a total revenue basis. See “Markets” above for additional information.The increase in non-Markets net interest income was largely driven by:•higher average deposit balances and deposit spreads in Services and Wealth; and•higher loan spreads and higher interest-earning balances in Branded Cards in USPB, as well as higher deposit spreads and average deposit balances in Retail Banking in USPB;•partially offset by:•lower interest-earning loan balances and spreads in Retail Services in USPB,•lower mortgage spreads in Wealth, and•a lower benefit from cash and securities reinvestment in All Other—Corporate/Other, driven by actions taken over the last few quarters to reduce Citi’s asset sensitivity in a declining interest rate environment.Citi’s net interest margin was 2.49% on a taxable equivalent basis in the fourth quarter of 2025, an increase of nine basis points from the prior quarter, largely driven by higher Markets net interest income and a favorable asset mix-shift in balances.Citi’s net interest income for 2025 increased 11%, or $5.7 billion, to $59.8 billion ($59.9 billion on a taxable equivalent basis) versus 2024. The increase was driven by a 43%, or $3.0 billion, increase in Markets net interest income and a 6%, or $2.7 billion, increase in non-Markets net interest income.The increase in non-Markets net interest income was largely driven by:•higher average deposit balances and spreads in Services;•higher loan spreads and interest-earning balances in Branded Cards, as well as higher deposit spreads in Retail Banking; and•higher deposit spreads in Wealth;•partially offset by:•lower interest-earning loan balances and spreads in Retail Services,•lower mortgage spreads and lower average deposit balances in Wealth, and•a lower benefit from cash and securities reinvestment in All Other—Corporate/Other, driven by actions taken over the last few quarters to reduce Citi’s asset sensitivity in a declining interest rate environment.In 2025, Citi’s net interest margin increased to 2.47% on a taxable equivalent basis, compared to 2.40% in 2024, driven by higher Markets net interest income and a favorable asset mix-shift due to higher interest-earning balances in cards, partially offset by the impact of FX translation. Citi’s net interest income in the fourth quarter of 2025 was $15.7 billion, on both a reported and taxable equivalent basis, an increase of 14%, or $1.9 billion, from the prior-year period. The growth was due to a 53%, or $1.0 billion, increase in Markets net interest income and an 8%, or $0.9 billion, increase in non-Markets net interest income.Citi’s Markets business is primarily evaluated on a total revenue basis. See “Markets” above for additional information.The increase in non-Markets net interest income was largely driven by:•higher average deposit balances and deposit spreads in Services and Wealth; and•higher loan spreads and higher interest-earning balances in Branded Cards in USPB, as well as higher deposit spreads and average deposit balances in Retail Banking in USPB;•partially offset by:•lower interest-earning loan balances and spreads in Retail Services in USPB,•lower mortgage spreads in Wealth, and•a lower benefit from cash and securities reinvestment in All Other—Corporate/Other, driven by actions taken over the last few quarters to reduce Citi’s asset sensitivity in a declining interest rate environment.Citi’s net interest margin was 2.49% on a taxable equivalent basis in the fourth quarter of 2025, an increase of nine basis points from the prior quarter, largely driven by higher Markets net interest income and a favorable asset mix-shift in balances. Citi’s net interest income in the fourth quarter of 2025 was $15.7 billion, on both a reported and taxable equivalent basis, an increase of 14%, or $1.9 billion, from the prior-year period. The growth was due to a 53%, or $1.0 billion, increase in Markets net interest income and an 8%, or $0.9 billion, increase in non-Markets net interest income. Citi’s Markets business is primarily evaluated on a total revenue basis. See “Markets” above for additional information. The increase in non-Markets net interest income was largely driven by: •higher average deposit balances and deposit spreads in Services and Wealth; and •higher loan spreads and higher interest-earning balances in Branded Cards in USPB, as well as higher deposit spreads and average deposit balances in Retail Banking in USPB; •partially offset by: •lower interest-earning loan balances and spreads in Retail Services in USPB, •lower mortgage spreads in Wealth, and •a lower benefit from cash and securities reinvestment in All Other—Corporate/Other, driven by actions taken over the last few quarters to reduce Citi’s asset sensitivity in a declining interest rate environment. Citi’s net interest margin was 2.49% on a taxable equivalent basis in the fourth quarter of 2025, an increase of nine basis points from the prior quarter, largely driven by higher Markets net interest income and a favorable asset mix-shift in balances. Citi’s net interest income for 2025 increased 11%, or $5.7 billion, to $59.8 billion ($59.9 billion on a taxable equivalent basis) versus 2024. The increase was driven by a 43%, or $3.0 billion, increase in Markets net interest income and a 6%, or $2.7 billion, increase in non-Markets net interest income.The increase in non-Markets net interest income was largely driven by:•higher average deposit balances and spreads in Services;•higher loan spreads and interest-earning balances in Branded Cards, as well as higher deposit spreads in Retail Banking; and•higher deposit spreads in Wealth;•partially offset by:•lower interest-earning loan balances and spreads in Retail Services,•lower mortgage spreads and lower average deposit balances in Wealth, and•a lower benefit from cash and securities reinvestment in All Other—Corporate/Other, driven by actions taken over the last few quarters to reduce Citi’s asset sensitivity in a declining interest rate environment.In 2025, Citi’s net interest margin increased to 2.47% on a taxable equivalent basis, compared to 2.40% in 2024, driven by higher Markets net interest income and a favorable asset mix-shift due to higher interest-earning balances in cards, partially offset by the impact of FX translation. Citi’s net interest income for 2025 increased 11%, or $5.7 billion, to $59.8 billion ($59.9 billion on a taxable equivalent basis) versus 2024. The increase was driven by a 43%, or $3.0 billion, increase in Markets net interest income and a 6%, or $2.7 billion, increase in non-Markets net interest income. The increase in non-Markets net interest income was largely driven by: •higher average deposit balances and spreads in Services; •higher loan spreads and interest-earning balances in Branded Cards, as well as higher deposit spreads in Retail Banking; and •higher deposit spreads in Wealth; •partially offset by: •lower interest-earning loan balances and spreads in Retail Services, •lower mortgage spreads and lower average deposit balances in Wealth, and •a lower benefit from cash and securities reinvestment in All Other—Corporate/Other, driven by actions taken over the last few quarters to reduce Citi’s asset sensitivity in a declining interest rate environment. In 2025, Citi’s net interest margin increased to 2.47% on a taxable equivalent basis, compared to 2.40% in 2024, driven by higher Markets net interest income and a favorable asset mix-shift due to higher interest-earning balances in cards, partially offset by the impact of FX translation. 103 103 103",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Board Oversight",
      "prior_title": "Executive Management Team",
      "similarity_score": 0.577,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"The 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.\""
      ],
      "current_body": "The 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. 65 65 65 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 Governance 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 (Board Audit Committee) provides oversight of financial statement integrity, internal controls, audits and regulatory compliance. Its responsibilities include holding management accountable for the effectiveness of Citigroup’s control environment and corrective actions, approving independent auditor selection/compensation, key policies and 10-K filings. It also has responsibilities regarding the approval, replacement and compensation of the Chief Auditor.•Compensation, Performance Management and Culture Committee provides oversight of employee compensation, corporate culture and compliance with bank regulatory guidance governing Citi’s incentive compensation. Its responsibilities include reviewing Citi’s management resources, assessing the performance of senior management, determining the compensation of Citigroup’s CEO and approving executive compensation and incentive compensation structures.•Nomination, Governance and Public Affairs Committee provides oversight of corporate governance, Board effectiveness and public affairs, including sustainability matters, and nominates directors for the Board and its committees. Its responsibilities include leading the annual review of the Board’s performance, reviewing the adequacy of Board committee charters and reviewing relationships with external constituencies and issues that impact Citi’s reputation, as well as advising management on the foregoing matters.•Risk Management Committee (Board RMC) provides oversight of Citigroup’s risk management framework and risk culture, including significant policies and practices for risk management and capital management, and oversees the performance of Citi’s Credit Risk Review function. This Committee reviews Citigroup’s aggregate risk profile and ensures the adequacy of the Company’s risk management functions. Its responsibilities include approving the Enterprise Risk Management Framework (ERMF) and key risk policies, reviewing the risk appetite statement and recommending it to the Board. Additionally, this Committee has responsibilities regarding the approval, replacement and compensation of the Chief Risk Officer.•Technology Committee provides oversight of Citigroup’s technology strategy, operating model, architecture and technology-based risk management (including cyber security), technology resource and talent planning, and technology third-party management policies. Its responsibilities include reviewing and assessing significant technology investments and expenditures, overseeing and reviewing information from management regarding Citi’s approach to Generative AI and reviewing reports on technology and data quality-related matters.In addition to the above, the Board has established the following ad hoc committee: •Transformation Oversight Committee provides oversight of the actions of Citi’s management to develop and execute a transformation of Citi’s risk and control environment pursuant to the FRB and OCC Consent Orders (see “Citi’s Multiyear Transformation—FRB and OCC Consent Orders Compliance” above).The Citigroup CEO has established four standing Executive Management Governance Committees that cover the primary risks to which Citi is exposed. These consist of the following:•Citigroup Asset and Liability Committee (ALCO) oversees liquidity risk and market risk on the accrual book, and monitors and influences the balance sheet, investment securities and capital management activities of Citigroup. Its responsibilities include approving relevant policies andprograms and reviewing balance sheet trends, liquidity levels, capital metrics, interest rate risk, foreign exchange risk and significant risk management concerns.•Business Risk and Control Committee oversees operational and compliance risks and the overall control environment. Its responsibilities include approving operational and compliance risk-related initiatives, and monitoring Issues, Managers Control Assessment, Operational Risk Events and Escalations.•Reputation Risk Committee oversees Citigroup’s reputation risk program. It governs the processes by which material reputation risks are managed, in line with Company-wide strategic objectives, risk appetite and regulatory expectations, while promoting a culture of risk awareness. Its responsibilities include reviewing, challenging and resolving, as needed, reputation risk matters.•Risk Management Committee oversees the execution of the Enterprise Risk Management Framework and monitors Citi’s risk profile against approved risk appetite. Its responsibilities include discussing and providing review and challenge of risk matters, including material and emerging risks facing Citi. It also provides comprehensive coverage of credit risk, market risk (trading) and strategic risk.In addition to the Executive Management Governance Committees listed above, management may establish ad-hoc committees in response to regulatory feedback or to manage additional activities when deemed necessary. 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 Governance 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 (Board Audit Committee) provides oversight of financial statement integrity, internal controls, audits and regulatory compliance. Its responsibilities include holding management accountable for the effectiveness of Citigroup’s control environment and corrective actions, approving independent auditor selection/compensation, key policies and 10-K filings. It also has responsibilities regarding the approval, replacement and compensation of the Chief Auditor.•Compensation, Performance Management and Culture Committee provides oversight of employee compensation, corporate culture and compliance with bank regulatory guidance governing Citi’s incentive compensation. Its responsibilities include reviewing Citi’s management resources, assessing the performance of senior management, determining the compensation of Citigroup’s CEO and approving executive compensation and incentive compensation structures.•Nomination, Governance and Public Affairs Committee provides oversight of corporate governance, Board effectiveness and public affairs, including sustainability matters, and nominates directors for the Board and its committees. Its responsibilities include leading the annual review of the Board’s performance, reviewing the adequacy of Board committee charters and reviewing relationships with external constituencies and issues that impact Citi’s reputation, as well as advising management on the foregoing matters.•Risk Management Committee (Board RMC) provides oversight of Citigroup’s risk management framework and risk culture, including significant policies and practices for risk management and capital management, and oversees the performance of Citi’s Credit Risk Review function. This Committee reviews Citigroup’s aggregate risk profile and ensures the adequacy of the Company’s risk management functions. Its responsibilities include approving the Enterprise Risk Management Framework (ERMF) and key risk policies, reviewing the risk appetite statement and recommending it to the Board. Additionally, this Committee has responsibilities regarding the approval, replacement and compensation of the Chief Risk Officer.•Technology Committee provides oversight of Citigroup’s technology strategy, operating model, architecture and technology-based risk management (including cyber",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Citi’s Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.",
      "prior_title": "Citi’s Emerging Markets Presence Subjects It to Various Risks as well as Increased Compliance and Regulatory Risks and Costs.",
      "similarity_score": 0.575,
      "confidence": "low",
      "key_changes": [
        "Added sentence: \"During 2025, emerging markets revenues accounted for approximately 25% of Citi’s total revenues.\"",
        "Reworded sentence: \"Citi’s emerging markets risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations; central bank interest rate and other monetary policies; macroeconomic, geopolitical and domestic political challenges, uncertainties and volatilities; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; limitations on foreign investment; sociopolitical instability; 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.\"",
        "Reworded sentence: \"For example, Citi operates in several countries that have strict capital controls, currency controls and/or sanctions that limit its ability to convert local currency into U.S.\"",
        "Reworded sentence: \"As a result, Citi might need to record additional translation losses due to these 61 61 61 or other currency controls.\"",
        "Reworded sentence: \"or other currency controls.\""
      ],
      "current_body": "During 2025, emerging markets revenues accounted for approximately 25% of Citi’s total revenues. Citi’s presence in the emerging markets subjects it to various risks. Citi’s emerging markets risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations; central bank interest rate and other monetary policies; macroeconomic, geopolitical and domestic political challenges, uncertainties and volatilities; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; limitations on foreign investment; sociopolitical instability; 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 strict capital controls, currency controls and/or sanctions that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. As a result, Citi might need to record additional translation losses due to these 61 61 61 or other currency controls. Moreover, Citi could be required to adjust its 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 “Significant Accounting Policies and Significant Estimates” below and Note 1).Moreover, the Russia–Ukraine war could have further negative impacts on macroeconomic conditions, financial markets and commodities prices, adversely impacting Citi and its customers, clients or employees. For additional information about these Russia-related risks, see the macroeconomic challenges and uncertainties and cybersecurity risk factors above.Emerging markets risks may adversely impact Citi’s businesses, results of operations and financial condition in those countries where Citi operates and have required, and may continue to require, management time and attention and other resources. SUSTAINABILITYCiti and its clients face escalating global environmental and social challenges, including climate change and the energy transition. Citi’s net zero approach and sustainable finance activity include the Company’s work to support clients in financing their transition to low-carbon business models, as well as broader energy security priorities, including access to affordable energy in emerging markets. Citi recognizes that energy transition, energy security and economic growth are not mutually exclusive and must be addressed simultaneously. The “Citi Climate Report” provides additional information on Citi’s continued progress to manage climate risk and its net zero approach, including information on financed and facilitated emissions and 2030 interim emissions reduction targets. Citi’s “Sustainability Report” provides information on its $1 Trillion Sustainable Finance Goal, including sustainable finance products and services that Citi provides to its clients to support their sustainability objectives. For additional information on Citi’s environmental and social policies and priorities, click on “Our Impact” on Citi’s website at www.citigroup.com. Climate and sustainability 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. For information regarding Citi’s management of climate risk, see “Managing Global Risk—Strategic Risk—Climate Risk” below. or other currency controls. Moreover, Citi could be required to adjust its 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 “Significant Accounting Policies and Significant Estimates” below and Note 1).Moreover, the Russia–Ukraine war could have further negative impacts on macroeconomic conditions, financial markets and commodities prices, adversely impacting Citi and its customers, clients or employees. For additional information about these Russia-related risks, see the macroeconomic challenges and uncertainties and cybersecurity risk factors above.Emerging markets risks may adversely impact Citi’s businesses, results of operations and financial condition in those countries where Citi operates and have required, and may continue to require, management time and attention and other resources. SUSTAINABILITYCiti and its clients face escalating global environmental and social challenges, including climate change and the energy transition. Citi’s net zero approach and sustainable finance activity include the Company’s work to support clients in financing their transition to low-carbon business models, as well as broader energy security priorities, including access to affordable energy in emerging markets. Citi recognizes that energy transition, energy security and economic growth are not mutually exclusive and must be addressed simultaneously. The “Citi Climate Report” provides additional information on Citi’s continued progress to manage climate risk and its net zero approach, including information on financed and facilitated emissions and 2030 interim emissions reduction targets. Citi’s “Sustainability Report” provides information on its $1 Trillion Sustainable Finance Goal, including sustainable finance products and services that Citi provides to its clients to support their sustainability objectives. For additional information on Citi’s environmental and social policies and priorities, click on “Our Impact” on Citi’s website at www.citigroup.com. Climate and sustainability 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. For information regarding Citi’s management of climate risk, see “Managing Global Risk—Strategic Risk—Climate Risk” below. or other currency controls. Moreover, Citi could be required to adjust its 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 “Significant Accounting Policies and Significant Estimates” below and Note 1). Moreover, the Russia–Ukraine war could have further negative impacts on macroeconomic conditions, financial markets and commodities prices, adversely impacting Citi and its customers, clients or employees. For additional information about these Russia-related risks, see the macroeconomic challenges and uncertainties and cybersecurity risk factors above. Emerging markets risks may adversely impact Citi’s businesses, results of operations and financial condition in those countries where Citi operates and have required, and may continue to require, management time and attention and other resources.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Consumer Loan Delinquencies Amounts and Ratios",
      "prior_title": "Consumer Loan Delinquencies Amounts and Ratios",
      "similarity_score": 0.57,
      "confidence": "low",
      "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 billions2025202520242023202520242023Wealth delinquency-managed loans(3)$101.7 $329 $260 $191 $247 $242 $312 Ratio0.32 %0.25 %0.18 %0.24 %0.23 %0.30 %Wealth classifiably managed loans(4)$48.3 N/AN/AN/AN/AN/AN/AUSPB(5)(6)Total$231.8 $2,763 $2,871 $2,635 $2,673 $2,604 $2,563 Ratio1.19 %1.30 %1.26 %1.16 %1.18 %1.23 %Credit cards and personal installment loans total (d+b)177.5 2,567 2,726 2,475 2,424 2,384 2,336 Ratio1.45 %1.56 %1.47 %1.37 %1.36 %1.39 %Credit cards total (a+c) = (d)(6)$173.7 $2,545 $2,705 $2,461 $2,373 $2,333 $2,293 Ratio1.47 %1.58 %1.49 %1.37 %1.36 %1.39 %Branded Cards (a+b)$125.3 $1,418 $1,404 $1,208 $1,378 $1,261 $1,186 Ratio1.13 %1.16 %1.06 %1.10 %1.04 %1.04 %Credit cards (a)121.51,396 1,383 1,194 1,327 1,210 1,143 Ratio1.15 %1.18 %1.07 %1.09 %1.03 %1.03 %Personal installment loans (b)3.822 21 14 51 51 43 Ratio0.58 %0.55 %0.42 %1.34 %1.34 %1.30 %Retail Services (c)$52.2 $1,149 $1,322 $1,267 $1,046 $1,123 $1,150 Ratio2.20 %2.46 %2.36 %2.00 %2.09 %2.15 %Retail Banking(5)$54.3 $196 $145 $160 $249 $220 $227 Ratio0.36 %0.31 %0.39 %0.46 %0.48 %0.56 %All OtherTotal$26.7 $448 $341 $407 $420 $329 $384 Ratio1.69 %1.44 %1.43 %1.58 %1.39 %1.35 %Mexico Consumer22.5 387 246 252 358 242 252 Ratio1.72 %1.43 %1.35 %1.59 %1.41 %1.35 %Asia Consumer(7)2.5 14 23 51 15 27 59 Ratio0.56 %0.49 %0.69 %0.60 %0.57 %0.80 %Legacy Holdings Assets (consumer)(8)1.7 47 72 104 47 60 73 Ratio3.13 %4.00 %4.33 %3.13 %3.33 %3.04 %Total Citigroup consumer$408.5 $3,540 $3,472 $3,233 $3,340 $3,175 $3,259 Ratio0.98 %0.99 %0.94 %0.93 %0.91 %0.95 % EOP loans(1)\""
      ],
      "current_body": "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 billions2025202520242023202520242023Wealth delinquency-managed loans(3)$101.7 $329 $260 $191 $247 $242 $312 Ratio0.32 %0.25 %0.18 %0.24 %0.23 %0.30 %Wealth classifiably managed loans(4)$48.3 N/AN/AN/AN/AN/AN/AUSPB(5)(6)Total$231.8 $2,763 $2,871 $2,635 $2,673 $2,604 $2,563 Ratio1.19 %1.30 %1.26 %1.16 %1.18 %1.23 %Credit cards and personal installment loans total (d+b)177.5 2,567 2,726 2,475 2,424 2,384 2,336 Ratio1.45 %1.56 %1.47 %1.37 %1.36 %1.39 %Credit cards total (a+c) = (d)(6)$173.7 $2,545 $2,705 $2,461 $2,373 $2,333 $2,293 Ratio1.47 %1.58 %1.49 %1.37 %1.36 %1.39 %Branded Cards (a+b)$125.3 $1,418 $1,404 $1,208 $1,378 $1,261 $1,186 Ratio1.13 %1.16 %1.06 %1.10 %1.04 %1.04 %Credit cards (a)121.51,396 1,383 1,194 1,327 1,210 1,143 Ratio1.15 %1.18 %1.07 %1.09 %1.03 %1.03 %Personal installment loans (b)3.822 21 14 51 51 43 Ratio0.58 %0.55 %0.42 %1.34 %1.34 %1.30 %Retail Services (c)$52.2 $1,149 $1,322 $1,267 $1,046 $1,123 $1,150 Ratio2.20 %2.46 %2.36 %2.00 %2.09 %2.15 %Retail Banking(5)$54.3 $196 $145 $160 $249 $220 $227 Ratio0.36 %0.31 %0.39 %0.46 %0.48 %0.56 %All OtherTotal$26.7 $448 $341 $407 $420 $329 $384 Ratio1.69 %1.44 %1.43 %1.58 %1.39 %1.35 %Mexico Consumer22.5 387 246 252 358 242 252 Ratio1.72 %1.43 %1.35 %1.59 %1.41 %1.35 %Asia Consumer(7)2.5 14 23 51 15 27 59 Ratio0.56 %0.49 %0.69 %0.60 %0.57 %0.80 %Legacy Holdings Assets (consumer)(8)1.7 47 72 104 47 60 73 Ratio3.13 %4.00 %4.33 %3.13 %3.33 %3.04 %Total Citigroup consumer$408.5 $3,540 $3,472 $3,233 $3,340 $3,175 $3,259 Ratio0.98 %0.99 %0.94 %0.93 %0.91 %0.95 % EOP loans(1)",
      "prior_body": "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)"
    },
    {
      "status": "MODIFIED",
      "current_title": "SUSTAINABILITY",
      "prior_title": "Additional Information",
      "similarity_score": 0.556,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"Citi and its clients face escalating global environmental and social challenges, including climate change and the energy transition.\"",
        "Reworded sentence: \"Climate and sustainability 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.\""
      ],
      "current_body": "Citi and its clients face escalating global environmental and social challenges, including climate change and the energy transition. Citi’s net zero approach and sustainable finance activity include the Company’s work to support clients in financing their transition to low-carbon business models, as well as broader energy security priorities, including access to affordable energy in emerging markets. Citi recognizes that energy transition, energy security and economic growth are not mutually exclusive and must be addressed simultaneously. The “Citi Climate Report” provides additional information on Citi’s continued progress to manage climate risk and its net zero approach, including information on financed and facilitated emissions and 2030 interim emissions reduction targets. Citi’s “Sustainability Report” provides information on its $1 Trillion Sustainable Finance Goal, including sustainable finance products and services that Citi provides to its clients to support their sustainability objectives. For additional information on Citi’s environmental and social policies and priorities, click on “Our Impact” on Citi’s website at www.citigroup.com. Climate and sustainability 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. For information regarding Citi’s management of climate risk, see “Managing Global Risk—Strategic Risk—Climate Risk” below.",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Wealth(2)(3)",
      "prior_title": "Wealth(2)(3)",
      "similarity_score": 0.54,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"Mortgages(4) USPB(4) Branded Cards(5) Personal installment loans(5) Retail Banking(5)\""
      ],
      "current_body": "Mortgages(4) USPB(4) Branded Cards(5) Personal installment loans(5) Retail Banking(5)",
      "prior_body": "Mortgages(4) Margin lending(5) Personal, small business and other(6) Mortgages(4)"
    },
    {
      "status": "MODIFIED",
      "current_title": "Consumer Loan Net Credit Losses (NCLs) and Ratios",
      "prior_title": "Consumer Loan Net Credit Losses (NCLs) and Ratios",
      "similarity_score": 0.536,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"Average loans(1)Net credit losses(2)In millions of dollars, except average loan amounts in billions2025202520242023Wealth$148.8 $170 $121 $98 Ratio0.11 %0.08 %0.07 %USPBTotal$219.8 $7,431 $7,579 $5,234 Ratio3.38 %3.62 %2.72 %Credit cards and personal installment loans total (d+b)169.8 7,290 7,457 5,124 Ratio4.29 %4.51 %3.32 %Credit cards total (a+c) = (d)$166.0 $7,057 $7,245 $4,981 Ratio4.25 %4.48 %3.29 %Branded Cards (a+b)$119.2 $4,392 $4,227 $2,807 Ratio3.68 %3.71 %2.68 %Credit cards (a)115.4 4,159 4,015 2,664 Ratio3.60 %3.64 %2.62 %Personal installment loans (b)3.8 233 212 143 Ratio6.13 %5.89 %4.93 %Retail Services (c)$50.6 $2,898 $3,230 $2,317 Ratio5.73 %6.27 %4.64 %Retail Banking$50.0 $141 $122 $110 Ratio0.28 %0.28 %0.29 %All Other—Legacy Franchises (managed basis)(3)Total$25.1 $1,131 $896 $861 Ratio4.51 %3.41 %2.94 %Mexico Consumer19.7 1,095 828 682 Ratio5.56 %4.52 %4.01 %Asia Consumer (managed basis)(3)(4)3.5 49 67 198 Ratio1.40 %1.14 %2.08 %Legacy Holdings Assets (consumer)1.9 (13)1 (19)Ratio(0.68)%0.05 %(0.68)%Reconciling Items(3)$— $7 $(6)Total Citigroup$393.7 $8,732 $8,603 $6,187 Ratio2.22 %2.24 %1.66 %\""
      ],
      "current_body": "Average loans(1)Net credit losses(2)In millions of dollars, except average loan amounts in billions2025202520242023Wealth$148.8 $170 $121 $98 Ratio0.11 %0.08 %0.07 %USPBTotal$219.8 $7,431 $7,579 $5,234 Ratio3.38 %3.62 %2.72 %Credit cards and personal installment loans total (d+b)169.8 7,290 7,457 5,124 Ratio4.29 %4.51 %3.32 %Credit cards total (a+c) = (d)$166.0 $7,057 $7,245 $4,981 Ratio4.25 %4.48 %3.29 %Branded Cards (a+b)$119.2 $4,392 $4,227 $2,807 Ratio3.68 %3.71 %2.68 %Credit cards (a)115.4 4,159 4,015 2,664 Ratio3.60 %3.64 %2.62 %Personal installment loans (b)3.8 233 212 143 Ratio6.13 %5.89 %4.93 %Retail Services (c)$50.6 $2,898 $3,230 $2,317 Ratio5.73 %6.27 %4.64 %Retail Banking$50.0 $141 $122 $110 Ratio0.28 %0.28 %0.29 %All Other—Legacy Franchises (managed basis)(3)Total$25.1 $1,131 $896 $861 Ratio4.51 %3.41 %2.94 %Mexico Consumer19.7 1,095 828 682 Ratio5.56 %4.52 %4.01 %Asia Consumer (managed basis)(3)(4)3.5 49 67 198 Ratio1.40 %1.14 %2.08 %Legacy Holdings Assets (consumer)1.9 (13)1 (19)Ratio(0.68)%0.05 %(0.68)%Reconciling Items(3)$— $7 $(6)Total Citigroup$393.7 $8,732 $8,603 $6,187 Ratio2.22 %2.24 %1.66 %",
      "prior_body": "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)"
    },
    {
      "status": "MODIFIED",
      "current_title": "Managing Global Risk—Table of Contents",
      "prior_title": "Managing Global Risk—Table of Contents",
      "similarity_score": 0.521,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"MANAGING GLOBAL RISK64CREDIT RISK(1)68Average Loans68Corporate Credit69Consumer Credit76Additional Consumer and Corporate Credit Details83Loans Outstanding83Details of Credit Loss Experience 84Allowance for Credit Losses on Loans (ACLL)86Non-Accrual Loans and Assets88LIQUIDITY RISK91Liquidity Monitoring and Measurement 91High-Quality Liquid Assets (HQLA)92Liquidity Coverage Ratio (LCR)92Deposits93Long-Term Debt (LTD)93Secured Funding Transactions and Short-Term Borrowings96Credit Ratings97MARKET RISK(1) 98Market Risk of Non-Trading Portfolios98Banking Book Interest Rate Risk 98Interest Rate Risk of Investment Portfolios—Impact on AOCI 99Changes in Foreign Exchange Rates—Impacts on AOCI and Capital101Interest Income/Expense and Net Interest Margin (NIM)102Additional Interest Rate Details104Market Risk of Trading Portfolios108Factor Sensitivities109Value at Risk (VaR)109Stress Testing112OPERATIONAL RISK112Cybersecurity Risk113COMPLIANCE RISK115REPUTATION RISK115STRATEGIC RISK116Climate Risk116OTHER RISKS117Country Risk117Top 25 Country Exposures118Russia119Ukraine120Argentina120 64\""
      ],
      "current_body": "MANAGING GLOBAL RISK64CREDIT RISK(1)68Average Loans68Corporate Credit69Consumer Credit76Additional Consumer and Corporate Credit Details83Loans Outstanding83Details of Credit Loss Experience 84Allowance for Credit Losses on Loans (ACLL)86Non-Accrual Loans and Assets88LIQUIDITY RISK91Liquidity Monitoring and Measurement 91High-Quality Liquid Assets (HQLA)92Liquidity Coverage Ratio (LCR)92Deposits93Long-Term Debt (LTD)93Secured Funding Transactions and Short-Term Borrowings96Credit Ratings97MARKET RISK(1) 98Market Risk of Non-Trading Portfolios98Banking Book Interest Rate Risk 98Interest Rate Risk of Investment Portfolios—Impact on AOCI 99Changes in Foreign Exchange Rates—Impacts on AOCI and Capital101Interest Income/Expense and Net Interest Margin (NIM)102Additional Interest Rate Details104Market Risk of Trading Portfolios108Factor Sensitivities109Value at Risk (VaR)109Stress Testing112OPERATIONAL RISK112Cybersecurity Risk113COMPLIANCE RISK115REPUTATION RISK115STRATEGIC RISK116Climate Risk116OTHER RISKS117Country Risk117Top 25 Country Exposures118Russia119Ukraine120Argentina120 64",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Long-Term Debt (LTD)",
      "prior_title": "Long-Term Debt",
      "similarity_score": 0.52,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"LTD (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.\""
      ],
      "current_body": "LTD (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. The following table presents Citi’s end-of-period total LTD outstanding for each of the dates indicated: In billions of dollarsDec. 31, 2025Sep. 30, 2025Dec. 31, 2024Non-bank(1)Benchmark debt:Senior debt$117.5 $115.0 $107.4 Subordinated debt28.7 28.7 28.7 Trust preferred1.6 1.6 1.6 Customer-related debt(2)116.7 116.4 103.3 Local country and other(3)14.8 13.6 9.6 Total non-bank$279.3 $275.3 $250.6 BankFHLB borrowings$3.0 $6.0 $8.5 Securitizations(4)5.2 6.7 5.1 Citibank benchmark senior debt23.5 23.5 19.4 Customer-related debt(2)2.7 2.8 1.2 Local country and other(3)2.1 1.5 2.5 Total bank$36.5 $40.5 $36.7 Total LTD$315.8 $315.8 $287.3",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "All Other—Legacy Franchises",
      "prior_title": "All Other—Legacy Franchises",
      "similarity_score": 0.51,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"Asia Consumer(6) Legacy Holdings Assets(7) (1)End-of-period loans include interest and fees on credit cards.\"",
        "Reworded sentence: \"(3)Consists of $54.1 billion, $53.5 billion, $52.7 billion, $50.6 billion and $49.5 billion of loans outside North America as of December 31, 2025, September 30, 2025, June 30, 2025, March 31, 2025 and December 31, 2024, respectively.\"",
        "Reworded sentence: \"76 76 76 Consumer Credit TrendsU.S.\"",
        "Reworded sentence: \"Personal BankingUSPB includes Branded Cards, Retail Services and Retail Banking.\""
      ],
      "current_body": "Asia Consumer(6) Legacy Holdings Assets(7) (1)End-of-period loans include interest and fees on credit cards. (2)Consists of $95.9 billion, $97.9 billion, $98.0 billion, $96.7 billion and $98.0 billion of loans in North America as of December 31, 2025, September 30, 2025, June 30, 2025, March 31, 2025 and December 31, 2024, respectively. For additional information on the credit quality of the Wealth portfolio, see Note 15. (3)Consists of $54.1 billion, $53.5 billion, $52.7 billion, $50.6 billion and $49.5 billion of loans outside North America as of December 31, 2025, September 30, 2025, June 30, 2025, March 31, 2025 and December 31, 2024, respectively. (4)See Note 15 for details on loan-to-value ratios for the mortgage portfolios and FICO scores for the U.S. portfolio. (5)Effective January 1, 2025, USPB changed its reporting for certain installment lending products that were transferred from Retail Banking to Branded Cards to reflect where these products are managed. Prior periods were conformed to reflect this change. (6)Asia Consumer loan balances, reported within All Other—Legacy Franchises, include the three remaining Asia Consumer loan portfolios—Korea, Poland (through the first quarter of 2025) and Russia until the completion of its consumer loan portfolio wind-down in the second quarter of 2025. Asia Consumer loan balances exclude approximately $2 billion of loans ($1 billion of retail banking loans and $1 billion of credit card loan balances) for the second, third and fourth quarters of 2025. These loans were reclassified to held-for-sale (HFS) (Other assets on the Consolidated Balance Sheet) as a result of Citi’s agreement to sell its Poland consumer banking business (expected to close by mid-2026). See “Agreement to Sell Poland Consumer Banking Business” in Note 2. (7)Consists of certain North America consumer mortgages. For information on changes to Citi’s consumer loans, see “Credit Risk—Loans” above. 76 76 76 Consumer Credit TrendsU.S. Personal BankingUSPB includes Branded Cards, Retail Services and Retail Banking. Branded Cards includes proprietary credit card portfolios (Value, Rewards and Cash), co-branded card portfolios (including Costco and American Airlines) and personal installment loans. Retail Services includes co-brand and private label relationships (including, among others, The Home Depot, Best Buy and Macy’s). Retail Banking includes traditional banking services, including deposits, mortgages and other lending products, to retail and small business customers concentrated in six key U.S. metropolitan areas. Retail Banking also provides mortgages through correspondent channels.As of December 31, 2025, approximately 75% of USPB EOP loans consisted of Branded Cards and Retail Services credit card loans, of which 70% represented Branded Cards loans and 30% represented Retail Services loans. Branded Cards and Retail Services credit card loans generally drive the overall credit performance of USPB, as Branded Cards and Retail Services card net credit losses represented approximately 94% of USPB’s total net credit losses for the fourth quarter of 2025.As presented in the chart above, the fourth quarter of 2025 net credit loss rate for USPB decreased quarter-over-quarter, primarily driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance (see “Branded Cards—Credit Cards” and “Retail Services” below).The 90+ days past due delinquency rate was broadly stable quarter-over-quarter, and decreased year-over-year, reflecting improvements in portfolio performance in cards.Branded Cards—Credit 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) and personal installment loans. Citi’s Branded Cards portfolio has a diverse combination of credit card products.As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Branded Cards’ credit cards decreased quarter-over-quarter, primarily driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance.The 90+ days past due delinquency rate increased quarter-over-quarter, driven by seasonality, and was broadly stable year-over-year.Retail ServicesUSPB’s Retail Services partners with more than 20 retailers and dealers to offer private label and co-brand cards. Retail Services’ target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel.As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Retail Services increased quarter-over-quarter, driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter, and decreased year-over-year, reflecting improvements in portfolio performance. Consumer Credit TrendsU.S. Personal BankingUSPB includes Branded Cards, Retail Services and Retail Banking. Branded Cards includes proprietary credit card portfolios (Value, Rewards and Cash), co-branded card portfolios (including Costco and American Airlines) and personal installment loans. Retail Services includes co-brand and private label relationships (including, among others, The Home Depot, Best Buy and Macy’s). Retail Banking includes traditional banking services, including deposits, mortgages and other lending products, to retail and small business customers concentrated in six key U.S. metropolitan areas. Retail Banking also provides mortgages through correspondent channels.As of December 31, 2025, approximately 75% of USPB EOP loans consisted of Branded Cards and Retail Services credit card loans, of which 70% represented Branded Cards loans and 30% represented Retail Services loans. Branded Cards and Retail Services credit card loans generally drive the overall credit performance of USPB, as Branded Cards and Retail Services card net credit losses represented approximately 94% of USPB’s total net credit losses for the fourth quarter of 2025.As presented in the chart above, the fourth quarter of 2025 net credit loss rate for USPB decreased quarter-over-quarter, primarily driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance (see “Branded Cards—Credit Cards” and “Retail Services” below).The 90+ days past due delinquency rate was broadly stable quarter-over-quarter, and decreased year-over-year, reflecting improvements in portfolio performance in cards.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "Loan Maturities and Fixed/Variable Pricing of Consumer Loans",
      "prior_title": "Fixed/Variable Pricing",
      "similarity_score": 0.507,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"Loan Maturities In millions of dollars at December 31, 2025Due within1 yearGreater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsTotalIn North America officesResidential first mortgages$7 $277 $2,544 $116,561 $119,389 Home equity loans3 8 1,034 1,827 2,872 Credit cards(1)170,896 2,760 — — 173,656 Personal, small business and other17,005 14,928 1,108 170 33,211 Total$187,911 $17,973 $4,686 $118,558 $329,128 In offices outside North AmericaResidential mortgages$263 $418 $4,207 $19,153 $24,041 Credit cards(1)14,666 35 — — 14,701 Personal, small business and other31,880 7,270 174 996 40,320 Total$46,809 $7,723 $4,381 $20,149 $79,062 Total Consumer$234,720 $25,696 $9,067 $138,707 $408,190 In millions of dollars at December 31, 2025 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_body": "Loan Maturities In millions of dollars at December 31, 2025Due within1 yearGreater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsTotalIn North America officesResidential first mortgages$7 $277 $2,544 $116,561 $119,389 Home equity loans3 8 1,034 1,827 2,872 Credit cards(1)170,896 2,760 — — 173,656 Personal, small business and other17,005 14,928 1,108 170 33,211 Total$187,911 $17,973 $4,686 $118,558 $329,128 In offices outside North AmericaResidential mortgages$263 $418 $4,207 $19,153 $24,041 Credit cards(1)14,666 35 — — 14,701 Personal, small business and other31,880 7,270 174 996 40,320 Total$46,809 $7,723 $4,381 $20,149 $79,062 Total Consumer$234,720 $25,696 $9,067 $138,707 $408,190 In millions of dollars at December 31, 2025 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. Fixed/Variable Pricing In millions of dollars at December 31, 2025Greater than 1 yearbut within5 yearsGreater than 5 years but within 15 yearsGreater than 15 yearsLoans at fixed interest ratesResidential first mortgages$346 $3,982 $69,374 Home equity loans4 187 22 Credit cards(1)2,795 — — Personal, small business and other8,605 323 150 Total$11,750 $4,492 $69,546 Loans at floating or adjustable interest ratesResidential first mortgages$349 $2,769 $66,340 Home equity loans4 847 1,805 Personal, small business and other13,593 959 1,016 Total$13,946 $4,575 $69,161 Total Consumer$25,696 $9,067 $138,707 In millions of dollars at December 31, 2025 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",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "Loan Maturities and Fixed/Variable Pricing of Corporate Loans",
      "prior_title": "Loan Maturities and Fixed/Variable Pricing of Corporate Loans",
      "similarity_score": 0.498,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"In millions of dollars at December 31, 2025Due within1 yearOver 1 yearbut within5 yearsOver 5 yearsbut within15 yearsOver 15 yearsTotalCorporate loansIn North America offices(1)Commercial and industrial$28,028 $26,696 $2,020 $662 $57,406 Financial institutions26,423 36,309 9,205 217 72,154 Mortgage and real estate(2)7,366 5,265 4,351 949 17,931 Installment and other5,522 14,047 3,260 275 23,104 Lease financing16 56 — — 72 Total$67,355 $82,373 $18,836 $2,103 $170,667 In offices outside North America(1)Commercial and industrial$64,031 $22,279 $10,501 $75 $96,886 Financial institutions14,440 8,473 4,063 78 27,054 Mortgage and real estate(2)3,907 5,111 777 61 9,856 Installment and other5,703 18,897 7,600 1,900 34,100 Lease financing3 31 13 — 47 Governments and official institutions662 1,226 2,069 1,113 5,070 Total$88,746 $56,017 $25,023 $3,227 $173,013 Corporate loans, net of unearned income(3)(4)$156,101 $138,390 $43,859 $5,330 $343,680 Loans at fixed interest rates(5)Commercial and industrial$4,180 $851 $4 Financial institutions1,584 755 213 Mortgage and real estate(2)1,024 4,118 949 Other(6)3,088 372 294 Lease financing76 — — Total $9,952 $6,096 $1,460 Loans at floating or adjustable interest rates(4)Commercial and industrial$44,795 $11,670 $733 Financial institutions43,198 12,513 82 Mortgage and real estate(2)9,352 1,010 61 Other(6)31,082 12,557 2,994 Lease financing11 23 — Total$128,438 $37,773 $3,870 Total fixed/variable pricing of corporate loans with maturities due after one year, net of unearned income(3)(4)$138,390 $43,869 $5,330 In millions of dollars at December 31, 2025\""
      ],
      "current_body": "In millions of dollars at December 31, 2025Due within1 yearOver 1 yearbut within5 yearsOver 5 yearsbut within15 yearsOver 15 yearsTotalCorporate loansIn North America offices(1)Commercial and industrial$28,028 $26,696 $2,020 $662 $57,406 Financial institutions26,423 36,309 9,205 217 72,154 Mortgage and real estate(2)7,366 5,265 4,351 949 17,931 Installment and other5,522 14,047 3,260 275 23,104 Lease financing16 56 — — 72 Total$67,355 $82,373 $18,836 $2,103 $170,667 In offices outside North America(1)Commercial and industrial$64,031 $22,279 $10,501 $75 $96,886 Financial institutions14,440 8,473 4,063 78 27,054 Mortgage and real estate(2)3,907 5,111 777 61 9,856 Installment and other5,703 18,897 7,600 1,900 34,100 Lease financing3 31 13 — 47 Governments and official institutions662 1,226 2,069 1,113 5,070 Total$88,746 $56,017 $25,023 $3,227 $173,013 Corporate loans, net of unearned income(3)(4)$156,101 $138,390 $43,859 $5,330 $343,680 Loans at fixed interest rates(5)Commercial and industrial$4,180 $851 $4 Financial institutions1,584 755 213 Mortgage and real estate(2)1,024 4,118 949 Other(6)3,088 372 294 Lease financing76 — — Total $9,952 $6,096 $1,460 Loans at floating or adjustable interest rates(4)Commercial and industrial$44,795 $11,670 $733 Financial institutions43,198 12,513 82 Mortgage and real estate(2)9,352 1,010 61 Other(6)31,082 12,557 2,994 Lease financing11 23 — Total$128,438 $37,773 $3,870 Total fixed/variable pricing of corporate loans with maturities due after one year, net of unearned income(3)(4)$138,390 $43,869 $5,330 In millions of dollars at December 31, 2025",
      "prior_body": "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"
    },
    {
      "status": "MODIFIED",
      "current_title": "U.S. Personal Banking",
      "prior_title": "U.S. Personal Banking",
      "similarity_score": 0.47,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"USPB includes Branded Cards, Retail Services and Retail Banking.\""
      ],
      "current_body": "USPB includes Branded Cards, Retail Services and Retail Banking. Branded Cards includes proprietary credit card portfolios (Value, Rewards and Cash), co-branded card portfolios (including Costco and American Airlines) and personal installment loans. Retail Services includes co-brand and private label relationships (including, among others, The Home Depot, Best Buy and Macy’s). Retail Banking includes traditional banking services, including deposits, mortgages and other lending products, to retail and small business customers concentrated in six key U.S. metropolitan areas. Retail Banking also provides mortgages through correspondent channels. As of December 31, 2025, approximately 75% of USPB EOP loans consisted of Branded Cards and Retail Services credit card loans, of which 70% represented Branded Cards loans and 30% represented Retail Services loans. Branded Cards and Retail Services credit card loans generally drive the overall credit performance of USPB, as Branded Cards and Retail Services card net credit losses represented approximately 94% of USPB’s total net credit losses for the fourth quarter of 2025. As presented in the chart above, the fourth quarter of 2025 net credit loss rate for USPB decreased quarter-over-quarter, primarily driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance (see “Branded Cards—Credit Cards” and “Retail Services” below). The 90+ days past due delinquency rate was broadly stable quarter-over-quarter, and decreased year-over-year, reflecting improvements in portfolio performance in cards. Branded Cards—Credit 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) and personal installment loans. Citi’s Branded Cards portfolio has a diverse combination of credit card products.As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Branded Cards’ credit cards decreased quarter-over-quarter, primarily driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance.The 90+ days past due delinquency rate increased quarter-over-quarter, driven by seasonality, and was broadly stable year-over-year.Retail ServicesUSPB’s Retail Services partners with more than 20 retailers and dealers to offer private label and co-brand cards. Retail Services’ target market focuses on select industry segments such as home improvement, specialty retail, consumer electronics and fuel.As presented in the chart above, the fourth quarter of 2025 net credit loss rate for Retail Services increased quarter-over-quarter, driven by seasonality, and decreased year-over-year, reflecting improvements in portfolio performance.The 90+ days past due delinquency rate was broadly stable quarter-over-quarter, and decreased year-over-year, reflecting improvements in portfolio performance.",
      "prior_body": "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."
    },
    {
      "status": "MODIFIED",
      "current_title": "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.",
      "prior_title": "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.",
      "similarity_score": 0.468,
      "confidence": "low",
      "key_changes": [
        "Reworded sentence: \"Changes to financial accounting or reporting standards or interpretations, whether promulgated or required by the Financial Accounting Standards Board (FASB), the SEC, U.S.\""
      ],
      "current_body": "Changes to financial accounting or reporting standards or interpretations, whether promulgated or required by the Financial Accounting Standards Board (FASB), the SEC, U.S. banking regulators or others, could present operational challenges and could require Citi to change certain of the assumptions or estimates it previously used in preparing its financial statements, which could negatively impact how it records and reports its financial condition and results of operations generally and/or with respect to particular businesses. For example, the 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. See “Significant Accounting Policies and Significant Estimates” below and Note 1 for additional information on Citi’s accounting policies (“Summary of Significant Accounting Policies”) and changes in accounting (“Accounting Changes”), including the expected impacts on Citi’s results of operations and financial condition. 57 57 57 If Citi’s Risk Management and Other Processes or Strategies 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. Citi also relies on data to assess and manage various risk exposures. Unexpected losses can result from untimely, inaccurate or incomplete risk management processes and data. In addition, Citi’s risk management and other processes and strategies, including 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, receive negative regulatory evaluation or examination findings or be subject 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 regulatory scrutiny and changes and the legal and regulatory proceedings risk factors below). Such deficiencies or ineffectiveness could also result in inaccurate financial, regulatory or risk reporting.Moreover, Citi’s Basel III regulatory capital models, including its credit, market and operational risk models, are subject to ongoing regulatory review and approval, which may result in refinements, modifications or enhancements (required or otherwise) to these models. Modifications or requirements resulting from these ongoing reviews, as well as any future changes or guidance provided by the U.S. banking regulators regarding the U.S. regulatory capital framework applicable to Citi, including, but not limited to, potential revisions to the U.S. Basel III rules (see the capital return risk factor and “Capital Resources—Regulatory Capital Standards and Developments” above), have resulted, and could continue to result, in significant changes to Citi’s risk-weighted assets. These changes can impact Citi’s capital ratios and its ability to meet its regulatory capital requirements. CREDIT RISKSCredit Risk and Concentrations of Risk Can Increase the Potential for Citi to Incur Significant Losses.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 $409 billion•end-of-period corporate loans of $344 billion at December 31, 2025A default by or a significant downgrade in the credit ratings of a consumer or corporate 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 consumer and corporate 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 cards risk factors above and the emerging markets risk factor below). For example, a weakening of economic conditions, including increases in unemployment rates, can adversely affect borrowers’ ability to repay their obligations, as well as result in Citi’s inability to liquidate the collateral it holds or forced to liquidate the collateral at prices that do not cover the full amount owed to Citi. 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” belowand Notes 15 and 16.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, systemic risks, including from leveraged finance, non-bank financial institutions, private credit and AI, could increase Citi’s credit costs.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, including on the CECL methodology, see the changes in or incorrect assumptions risk factor above. Concentrations and/or high correlation 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, 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. Citi also routinely executes a high volume of securities, trading, derivative and foreign exchange transactions with If Citi’s Risk Management and Other Processes or Strategies 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. Citi also relies on data to assess and manage various risk exposures. Unexpected losses can result from untimely, inaccurate or incomplete risk management processes and data. In addition, Citi’s risk management and other processes and strategies, including 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, receive negative regulatory evaluation or examination findings or be subject 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 regulatory scrutiny and changes and the legal and regulatory proceedings risk factors below). Such deficiencies or ineffectiveness could also result in inaccurate financial, regulatory or risk reporting.Moreover, Citi’s Basel III regulatory capital models, including its credit, market and operational risk models, are subject to ongoing regulatory review and approval, which may result in refinements, modifications or enhancements (required or otherwise) to these models. Modifications or requirements resulting from these ongoing reviews, as well as any future changes or guidance provided by the U.S. banking regulators regarding the U.S. regulatory capital framework applicable to Citi, including, but not limited to, potential revisions to the U.S. Basel III rules (see the capital return risk factor and “Capital Resources—Regulatory Capital Standards and Developments” above), have resulted, and could continue to result, in significant changes to Citi’s risk-weighted assets. These changes can impact Citi’s capital ratios and its ability to meet its regulatory capital requirements.",
      "prior_body": "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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "MARKET RISK OF NON-TRADING PORTFOLIOS",
      "prior_title": "MARKET RISK OF NON-TRADING PORTFOLIOS",
      "current_body": "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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Corporate loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(5)",
      "prior_title": "Corporate loans, net of unearned income, excluding portfolio-layer cumulative basis adjustments(5)",
      "current_body": "Unallocated portfolio-layer cumulative basis adjustments"
    },
    {
      "status": "UNCHANGED",
      "current_title": "MARKET RISK",
      "prior_title": "MARKET RISK",
      "current_body": "Overview Market risk is the potential for losses arising from changes in the value of Citi’s assets and liabilities resulting from changes in market variables such as interest rates, foreign exchange rates, equity prices, commodity prices and credit spreads, as well as their implied volatilities. Market risk 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "% of EOP loans(1)",
      "prior_title": "% of EOP loans(1)",
      "current_body": "North America cards(2) North America mortgages(3) North America other(3) International other(3) Total(1)"
    },
    {
      "status": "UNCHANGED",
      "current_title": "Consumer loans, net of unearned income(3)",
      "prior_title": "Consumer loans, net of unearned income(3)",
      "current_body": "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)"
    },
    {
      "status": "UNCHANGED",
      "current_title": "Trading account assets(6)(7)",
      "prior_title": "Trading account assets(6)(7)",
      "current_body": "In offices outside the U.S.(4) In offices outside the U.S.(4)"
    },
    {
      "status": "UNCHANGED",
      "current_title": "U.S. Cards FICO Distribution",
      "prior_title": "U.S. Cards FICO Distribution",
      "current_body": "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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "CORPORATE CREDIT",
      "prior_title": "CORPORATE CREDIT",
      "current_body": "Consistent 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Risk Governance",
      "prior_title": "Risk Governance",
      "current_body": "Citi’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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Potential Impacts of Ratings Downgrades",
      "prior_title": "Potential Impacts of Ratings Downgrades",
      "current_body": "Ratings downgrades by Fitch, Moody’s or S&P could negatively impact Citigroup’s and/or Citibank’s funding and liquidity due to reduced funding capacity, including derivative triggers, which could take the form of cash obligations and collateral requirements. The following information is provided for the purpose of analyzing the potential funding and liquidity impact to Citigroup and Citibank of a hypothetical simultaneous ratings downgrade across all three major rating agencies. This analysis is subject to certain estimates, estimation methodologies, judgments and uncertainties. Uncertainties include potential ratings limitations that certain entities may have with respect to permissible counterparties, as well as general subjective counterparty behavior. For example, certain corporate customers and markets counterparties could re-evaluate their business relationships with Citi and limit transactions in certain contracts or market instruments with Citi. Changes in counterparty behavior could impact Citi’s funding and liquidity, as well as the results of operations of certain of its businesses. The actual impact to Citigroup or Citibank is unpredictable and may differ materially from the potential funding and liquidity impacts described below. For additional information on the impact of credit rating changes on Citi and its applicable subsidiaries, see “Risk Factors—Liquidity Risks” above."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Banking Book Interest Rate Risk",
      "prior_title": "Banking Book Interest Rate Risk",
      "current_body": "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 Treasury. 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.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, LTD, 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 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 Treasury. 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. 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, LTD, 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 98 98 98 from longer-term assets being potentially funded with shorter-term liabilities, or vice versa. Citi manages EVS within risk limits approved by Citigroup’s Board of Directors that are aligned with Citi’s risk appetite.Interest Rate Risk of Investment Portfolios—Impact on AOCICiti 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. from longer-term assets being potentially funded with shorter-term liabilities, or vice versa. Citi manages EVS within risk limits approved by Citigroup’s Board of Directors that are aligned with Citi’s risk appetite.Interest Rate Risk of Investment Portfolios—Impact on AOCICiti 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. from longer-term assets being potentially funded with shorter-term liabilities, or vice versa. Citi manages EVS within risk limits approved by Citigroup’s Board of Directors that are aligned with Citi’s risk appetite."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Resolution Plan",
      "prior_title": "Resolution Plan",
      "current_body": "Citigroup is required under Title I of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) and the rules promulgated by the FDIC and FRB to periodically submit a plan for Citi’s rapid and orderly resolution under the U.S. Bankruptcy Code in the event of material financial distress or failure. For additional information on risks related to the application of resolution plan requirements, see “Risk Factors—Strategic Risks” above. Citigroup alternates between submitting a full resolution plan and a targeted resolution plan on a biennial cycle. 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 2025 resolution plan, which can be found on the FRB’s and FDIC’s websites) would remain operational outside of any resolution or insolvency proceedings. Citigroup’s resolution plan has been designed to minimize the risk of systemic impact to the U.S. and global financial systems, while maximizing the value of the bankruptcy estate for the benefit of Citigroup’s creditors, including its unsecured LTD holders. In addition, in line with the FRB’s total loss-absorbing capacity (TLAC) rule, Citigroup’s shareholders and unsecured creditors—including its unsecured LTD holders—bear any losses resulting from Citigroup’s bankruptcy. Accordingly, any value realized by holders of its unsecured LTD may not be sufficient to repay the amounts owed to such debt holders in the event of a bankruptcy or other resolution proceeding of Citigroup. The FDIC has also indicated that it was developing a single point of entry strategy to implement the Orderly Liquidation Authority under Title II of the Dodd-Frank Act, which provides the FDIC with the ability to resolve a firm when it is determined that bankruptcy would have serious adverse effects on financial stability in the U.S. As previously disclosed, in response to feedback received from the FRB and FDIC, Citigroup took the following actions:•Citicorp LLC (Citicorp), an existing wholly owned subsidiary of Citigroup, was established as an intermediate holding company (an IHC) for certain of Citigroup’s operating material legal entities.•Citigroup executed an inter-affiliate agreement with Citicorp, Citigroup’s operating material legal entities and certain other affiliated entities pursuant to which Citicorp is required to provide liquidity and capital support to Citigroup’s operating material legal entities in the event that Citigroup were to enter bankruptcy proceedings (Citi Support Agreement). •pursuant to the Citi Support Agreement:•Citigroup made an initial contribution of assets, including certain high-quality liquid assets and inter-affiliate loans (Contributable Assets), to Citicorp, and Citicorp became the business-as-usual funding vehicle for Citigroup’s operating material legal entities;•Citigroup will be obligated to continue to transfer Contributable Assets to Citicorp over time, subject to certain amounts retained by Citigroup to, among other things, meet Citigroup’s near-term cash needs; and•in the event of a Citigroup bankruptcy, Citigroup will be required to contribute most of its remaining assets to Citicorp.•The obligations of both Citigroup and Citicorp under the Citi Support Agreement, as well as the Contributable Assets, are secured pursuant to a security agreement.Total Loss-Absorbing Capacity (TLAC)As a U.S. GSIB, Citi is required to maintain minimum levels of TLAC and eligible LTD, each set by reference to the GSIB’s consolidated risk-weighted assets (RWA) and total leverage exposure. The intended purpose of the requirements is to facilitate the orderly resolution of U.S. GSIBs under the U.S. Bankruptcy Code and Title II of the Dodd-Frank Act. For additional information, including Citi’s TLAC and LTD amounts and ratios, see “Capital Resources—Current Regulatory Capital Standards” above. As previously disclosed, in response to feedback received from the FRB and FDIC, Citigroup took the following actions: •Citicorp LLC (Citicorp), an existing wholly owned subsidiary of Citigroup, was established as an intermediate holding company (an IHC) for certain of Citigroup’s operating material legal entities. •Citigroup executed an inter-affiliate agreement with Citicorp, Citigroup’s operating material legal entities and certain other affiliated entities pursuant to which Citicorp is required to provide liquidity and capital support to Citigroup’s operating material legal entities in the event that Citigroup were to enter bankruptcy proceedings (Citi Support Agreement). •pursuant to the Citi Support Agreement: •Citigroup made an initial contribution of assets, including certain high-quality liquid assets and inter-affiliate loans (Contributable Assets), to Citicorp, and Citicorp became the business-as-usual funding vehicle for Citigroup’s operating material legal entities; •Citigroup will be obligated to continue to transfer Contributable Assets to Citicorp over time, subject to certain amounts retained by Citigroup to, among other things, meet Citigroup’s near-term cash needs; and •in the event of a Citigroup bankruptcy, Citigroup will be required to contribute most of its remaining assets to Citicorp. •The obligations of both Citigroup and Citicorp under the Citi Support Agreement, as well as the Contributable Assets, are secured pursuant to a security agreement."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Citigroup Inc.Citibank, N.A.Long-termShort-term OutlookLong-termShort-termOutlookFitch Ratings (Fitch)AF1StableA+F1StableMoody’s Ratings (Moody’s)A3P-2StableAa3P-1StableS&P Global Ratings (S&P)BBB+A-2StableA+A-1Stable",
      "prior_title": "Citigroup Inc.Citibank, N.A.Long-termShort-term OutlookLong-termShort-termOutlookFitch Ratings (Fitch)AF1StableA+F1StableMoody’s Ratings (Moody’s)A3P-2StableAa3P-1StableS&P Global Ratings (S&P)BBB+A-2StableA+A-1Stable",
      "current_body": "Potential Impacts of Ratings DowngradesRatings downgrades by Fitch, Moody’s or S&P could negatively impact Citigroup’s and/or Citibank’s funding and liquidity due to reduced funding capacity, including derivative triggers, which could take the form of cash obligations and collateral requirements.The following information is provided for the purpose of analyzing the potential funding and liquidity impact to Citigroup and Citibank of a hypothetical simultaneous ratings downgrade across all three major rating agencies. This analysis is subject to certain estimates, estimation methodologies, judgments and uncertainties. Uncertainties include potential ratings limitations that certain entities may have with respect to permissible counterparties, as well as general subjective counterparty behavior. For example, certain corporate customers and markets counterparties could re-evaluate their business relationships with Citi and limit transactions in certain contracts or market instruments with Citi. Changes in counterparty behavior could impact Citi’s funding and liquidity, as well as the results of operations of certain of its businesses. The actual impact to Citigroup or Citibank is unpredictable and may differ materially from the potential funding and liquidity impacts described below. For additional information on the impact of credit rating changes on Citi and its applicable subsidiaries, see “Risk Factors—Liquidity Risks” above.Citigroup Inc. and Citibank—Potential Derivative TriggersAs of December 31, 2025, 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, 2025, for Citigroup Inc., and $0.1 billion, unchanged from September 30, 2025, 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, 2025, 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, unchanged from September 30, 2025. 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 (ABCP) conduits, primarily in the form of asset purchase agreements. As of December 31, 2025, Citibank had liquidity commitments of approximately $10.0 billion to ABCP conduits (compared to $15.0 billion at December 31, 2024) (see Note 23). Potential Impacts of Ratings DowngradesRatings downgrades by Fitch, Moody’s or S&P could negatively impact Citigroup’s and/or Citibank’s funding and liquidity due to reduced funding capacity, including derivative triggers, which could take the form of cash obligations and collateral requirements.The following information is provided for the purpose of analyzing the potential funding and liquidity impact to Citigroup and Citibank of a hypothetical simultaneous ratings downgrade across all three major rating agencies. This analysis is subject to certain estimates, estimation methodologies, judgments and uncertainties. Uncertainties include potential ratings limitations that certain entities may have with respect to permissible counterparties, as well as general subjective counterparty behavior. For example, certain corporate customers and markets counterparties could re-evaluate their business relationships with Citi and limit transactions in certain contracts or market instruments with Citi. Changes in counterparty behavior could impact Citi’s funding and liquidity, as well as the results of operations of certain of its businesses. The actual impact to Citigroup or Citibank is unpredictable and may differ materially from the potential funding and liquidity impacts described below. For additional information on the impact of credit rating changes on Citi and its applicable subsidiaries, see “Risk Factors—Liquidity Risks” above.Citigroup Inc. and Citibank—Potential Derivative TriggersAs of December 31, 2025, 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, 2025, for Citigroup Inc., and $0.1 billion, unchanged from September 30, 2025, 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "LIQUIDITY RISK",
      "prior_title": "LIQUIDITY RISK",
      "current_body": "Overview Adequate and diverse sources of funding and liquidity are essential to Citi’s businesses. Funding and liquidity risks arise from several factors, many of which are largely 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: •funding its existing asset base; •growing its core businesses; •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 •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. Citi’s 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 the following: •corporate and consumer deposits via Citi’s bank subsidiaries, including Citibank, N.A. (Citibank) •long-term debt (primarily senior and subordinated debt) mainly issued by Citigroup Inc., as the parent, and Citibank •stockholders’ equity These sources are 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 and tenor 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 cluster and in-country treasurers with oversight provided by Independent Risk Management and various Asset and Liability Committees (ALCOs) and Country Coordinating Committee at the individual entity, cluster, 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 Measurement Stress 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. 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 and tenor 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 cluster and in-country treasurers with oversight provided by Independent Risk Management and various Asset and Liability Committees (ALCOs) and Country Coordinating Committee at the individual entity, cluster, 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "SECURED FUNDING TRANSACTIONS AND SHORT-TERM BORROWINGS",
      "prior_title": "SECURED FUNDING TRANSACTIONS AND SHORT-TERM BORROWINGS",
      "current_body": "Citi supplements its primary sources of funding with short-term financings that generally include: •secured funding transactions consisting of securities loaned or sold under agreements to repurchase, i.e., repos •short-term borrowings consisting of commercial paper issuances and borrowings from the FHLB and other market participants"
    },
    {
      "status": "UNCHANGED",
      "current_title": "Citigroup Inc. and Citibank—Potential Derivative Triggers",
      "prior_title": "Citigroup Inc. and Citibank—Potential Derivative Triggers",
      "current_body": "As of December 31, 2025, 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, 2025, for Citigroup Inc., and $0.1 billion, unchanged from September 30, 2025, 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, 2025, 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, unchanged from September 30, 2025. 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 (ABCP) conduits, primarily in the form of asset purchase agreements. As of December 31, 2025, Citibank had liquidity commitments of approximately $10.0 billion to ABCP conduits (compared to $15.0 billion at December 31, 2024) (see Note 23). In total, as of December 31, 2025, 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, unchanged from September 30, 2025. 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Stress Testing",
      "prior_title": "Stress Testing",
      "current_body": "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. 91 91 91"
    },
    {
      "status": "UNCHANGED",
      "current_title": "and Capital",
      "prior_title": "and Capital",
      "current_body": "As of December 31, 2025, Citi estimates that a 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 reduction in the TCE would be primarily driven by depreciation of the euro, Mexican peso and Singapore dollar. 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, 2025Sep. 30, 2025Dec. 31, 2024Change in FX spot rate(1)0.3 %(0.1)%6.1 %Change in TCE due to FX translation, net of hedges(2)$2,107 $156 $(2,465)As a percentage of TCE1.2 %0.1 %(1.5)% Change in FX spot rate(1) Change in TCE due to FX translation, net of hedges(2) (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. (2) Includes $2,243 million related to the Banamex equity interest sale. See “Sale of 25% Equity Stake in Banamex” in Note 2. 101 101 101"
    },
    {
      "status": "UNCHANGED",
      "current_title": "Credit Risk Mitigation",
      "prior_title": "Credit Risk Mitigation",
      "current_body": "As part of its overall risk management activities, Citi 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 in Banking. At December 31, 2025, September 30, 2025 and December 31, 2024, Banking had economic hedges on the corporate credit portfolio of $40.6 billion, $39.5 billion and $37.8 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 purchased credit protection was economically hedging underlying Banking corporate credit portfolio exposures with the following risk rating distribution:"
    },
    {
      "status": "UNCHANGED",
      "current_title": "CREDIT RATINGS",
      "prior_title": "CREDIT RATINGS",
      "current_body": "Citigroup’s funding and liquidity, funding capacity, ability to access capital markets and other sources of funds, the cost of these funds and its ability to maintain certain deposits are partially dependent on its credit ratings. The table below presents the ratings for Citigroup and Citibank as of December 31, 2025. While not included in the table below, the current long-term and short-term ratings of Citigroup Global Markets Holdings 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, 2025."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Non-Accrual Loans and Assets",
      "prior_title": "Non-Accrual Loans and Assets",
      "current_body": "There is a certain amount of overlap among non-accrual loans and assets. The following summary provides a general description of non-accrual loans and assets: •Corporate and consumer (including commercial banking) non-accrual status is based on the determination that payment of interest or principal is doubtful. •A corporate loan may be classified as non-accrual and still be 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, including borrowers who have enrolled in forbearance programs. •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. •With the exception of certain international portfolios, credit card loans are not included because, under industry standards, they accrue interest until such loans are charged off, which typically occurs at 180 days of contractual delinquency. 88 88 88 Non-Accrual LoansThe 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 none or 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.The increase in corporate non-accrual loans at December 31, 2025 was driven by idiosyncratic credit downgrades. The increase in consumer non-accrual loans at December 31, 2025 was driven by residential mortgage loans impacted by the California wildfires and higher loan balances and the impact of FX translation in Mexico Consumer. Non-Accrual LoansThe 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 none or 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "MARKET RISK(1)",
      "prior_title": "MARKET RISK(1)",
      "current_body": "98 98 Banking Book Interest Rate Risk 98 Interest Rate Risk of Investment Portfolios—Impact on AOCI Changes in Foreign Exchange Rates—Impacts on AOCI and Capital 102 108 112 115 115 117 117 118 119 120 120 (1) For additional information regarding certain credit risk, market risk and other quantitative and qualitative information, refer to Citi’s Pillar 3 Basel III Advanced Approaches Disclosures, as required by the U.S. Basel III disclosure requirements, on Citi’s Investor Relations website. These Pillar 3 disclosures are not incorporated by reference into, and do not form any part of, this Form 10-K. 63 63 63 MANAGING GLOBAL RISKOverviewFor Citi, effective risk management is of primary importance to its overall operations. Accordingly, Citi has established an Enterprise Risk Management (ERM) Framework to ensure that Citi’s risks are managed appropriately and consistently across the Company and at an aggregate, enterprise-wide level. Citi’s culture drives a strong risk and control environment and is at the heart of the ERM Framework, underpinning the way Citi conducts business. The activities that Citi engages in, and the risks those activities generate, must be consistent with Citi’s Mission and Value Proposition (see below) and the key Leadership Principles that support it, as well as Citi’s risk appetite. As discussed above, Citi also continues its efforts to comply with the 2020 FRB and OCC Consent Orders, relating principally to various aspects of risk management, compliance, data quality management related to governance, and internal controls (see “Citi’s MultiyearTransformation—FRB and OCC Consent OrdersCompliance” and “Risk Factors—Compliance Risks” above).Under Citi’s Mission and Value Proposition, which was developed by its senior leadership and distributed throughout the Company, Citi strives to serve its clients as a trusted partner by responsibly providing financial services that enable growth and economic progress while earning and maintaining the public’s trust by constantly adhering to the highest ethical standards. As such, Citi asks all employees to ensure that their decisions pass three tests: they are in Citi’s clients’ best interests, create economic value and are always systemically responsible. Citi has designed Leadership Principles that represent the qualities, behaviors and expectations all employees must exhibit to deliver on Citi’s mission of enabling growth and economic progress. The Leadership Principles inform Citi’s ERM Framework and contribute to creating a culture that drives client, control and operational excellence. Citi employees share a common responsibility to uphold these Leadership Principles and hold themselves to the highest standards of ethics and professional behavior in dealing with Citi’s clients, business colleagues, shareholders, communities and each other.Citi’s ERM Framework details the principles used to support effective enterprise-wide risk management across the end-to-end risk management lifecycle. The underlying pillars of the framework encompass:•Culture—the core principles and behaviors that underpin a strong culture of risk awareness, in line with Citi’s Mission and Value Proposition, and Leadership Principles;•Governance—the committee structure and reporting arrangements that support the appropriate oversight of risk management activities at the Board and Executive Management Team levels and Citi’s Lines of Defense model;•Risk Management—the end-to-end risk management cycle including the identification, measurement, monitoring, controlling and reporting of all material risks; and•Enterprise Programs—the key risk management programs performed across the risk management lifecycle for all risk categories.Each of these pillars is underpinned by supporting capabilities covering people, infrastructure and tools that are in place to enable the execution of the ERM Framework. Controls are established to mitigate the risks associated with the execution of these pillars and supporting capabilities.Citi’s approach to risk management requires that its risk-taking be consistent with its risk appetite. Risk appetite is the aggregate level of risk that Citi is willing to tolerate in order to achieve its strategic objectives and business plan. Risk limits and thresholds represent allocations of Citi’s risk appetite to businesses and risk categories. Concentration risks are controlled through a subset of these limits and thresholds.Citi’s risks are generally categorized and summarized as follows:•Credit risk is the risk of loss resulting from the decline in credit quality (or downgrade risk) or failure of a borrower, counterparty, third party or issuer to honor its financial or contractual obligations.•Liquidity risk is the risk that Citi will not be able to efficiently meet its financial obligations as they become due without adversely impacting its daily operations or overall financial condition. This risk can be exacerbated by the Company’s inability to access necessary funding sources or to monetize assets in a timely and orderly manner.•Market risk (trading and non-trading): Market risk of trading portfolios is the risk of economic or trading loss arising from changes in the value of Citi’s assets and liabilities resulting from changes in market variables, such as interest rates, equity and commodity prices, foreign exchange rates or credit spreads. Market risk of non-trading portfolios is the impact of adverse changes in market variables such as interest rates, foreign exchange rates, credit spreads and equity prices on positions accounted for as part of Citi’s net interest income, economic value of equity or AOCI.•Operational risk is the risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events. Operational risk includes legal risk, but excludes strategic and reputation risks (see below). •Compliance risk is the risk to current or projected financial conditions and resilience arising from violations of laws, rules or regulations, or from non-conformance with prescribed practices, internal policies and procedures or ethical standards. •Reputation risk is the risk to current or projected financial conditions and resilience from negative opinion held by stakeholders. This risk may impair Citi’s competitiveness by affecting its ability to establish new relationships or services or continue servicing existing relationships.•Strategic risk is the risk of a sustained impact to Citi’s core strategic objectives as measured by impacts on anticipated earnings, market capitalization or capital, arising from the external factors affecting the Company’s MANAGING GLOBAL RISKOverviewFor Citi, effective risk management is of primary importance to its overall operations. Accordingly, Citi has established an Enterprise Risk Management (ERM) Framework to ensure that Citi’s risks are managed appropriately and consistently across the Company and at an aggregate, enterprise-wide level. Citi’s culture drives a strong risk and control environment and is at the heart of the ERM Framework, underpinning the way Citi conducts business. The activities that Citi engages in, and the risks those activities generate, must be consistent with Citi’s Mission and Value Proposition (see below) and the key Leadership Principles that support it, as well as Citi’s risk appetite. As discussed above, Citi also continues its efforts to comply with the 2020 FRB and OCC Consent Orders, relating principally to various aspects of risk management, compliance, data quality management related to governance, and internal controls (see “Citi’s MultiyearTransformation—FRB and OCC Consent OrdersCompliance” and “Risk Factors—Compliance Risks” above).Under Citi’s Mission and Value Proposition, which was developed by its senior leadership and distributed throughout the Company, Citi strives to serve its clients as a trusted partner by responsibly providing financial services that enable growth and economic progress while earning and maintaining the public’s trust by constantly adhering to the highest ethical standards. As such, Citi asks all employees to ensure that their decisions pass three tests: they are in Citi’s clients’ best interests, create economic value and are always systemically responsible. Citi has designed Leadership Principles that represent the qualities, behaviors and expectations all employees must exhibit to deliver on Citi’s mission of enabling growth and economic progress. The Leadership Principles inform Citi’s ERM Framework and contribute to creating a culture that drives client, control and operational excellence. Citi employees share a common responsibility to uphold these Leadership Principles and hold themselves to the highest standards of ethics and professional behavior in dealing with Citi’s clients, business colleagues, shareholders, communities and each other.Citi’s ERM Framework details the principles used to support effective enterprise-wide risk management across the end-to-end risk management lifecycle. The underlying pillars of the framework encompass:•Culture—the core principles and behaviors that underpin a strong culture of risk awareness, in line with Citi’s Mission and Value Proposition, and Leadership Principles;•Governance—the committee structure and reporting arrangements that support the appropriate oversight of risk management activities at the Board and Executive Management Team levels and Citi’s Lines of Defense model;•Risk Management—the end-to-end risk management cycle including the identification, measurement, monitoring, controlling and reporting of all material risks; and"
    },
    {
      "status": "UNCHANGED",
      "current_title": "Consumer non-accrual loans(1)",
      "prior_title": "Consumer non-accrual loans(1)",
      "current_body": "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, with the exception of certain international portfolios. The balances above represent non-accrual loans within Corporate loans and Consumer loans on the Consolidated Balance Sheet. (2)Approximately 70%, 61%, 50%, 50% and 56% of Citi’s corporate non-accrual loans remain current on interest and principal payments at December 31, 2025, 2024, 2023, 2022 and 2021, respectively. (3)The December 31, 2025 total corporate non-accrual loans represented 0.58% of total corporate loans. (4) Asia Consumer includes the three remaining consumer loan portfolios: Korea, Poland (through the first quarter of 2025) and Russia until the completion of its consumer loan portfolio wind-down in the second quarter of 2025. 89 89 89 The changes in Citigroup’s non-accrual loans were as follows: Year endedYear endedDecember 31, 2025December 31, 2024In millions of dollarsCorporateConsumerTotalCorporateConsumerTotalNon-accrual loans at beginning of year$1,377 $1,310 $2,687 $1,882 $1,315 $3,197 Additions2,425 2,599 5,024 1,517 1,966 3,483 Sales and transfers to HFS(124)(17)(141)(443)(14)(457)Returned to performing— (378)(378)(269)(206)(475)Paydowns/settlements(1,277)(553)(1,830)(934)(531)(1,465)Charge-offs(400)(1,414)(1,814)(372)(951)(1,323)Other— 71 71 (4)(269)(273)Ending balance$2,001 $1,618 $3,619 $1,377 $1,310 $2,687 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 dollars20252024202320222021OREONorth America$14 $9 $17 $10 $15 International(1)8 9 19 5 12 Total OREO$22 $18 $36 $15 $27 Non-accrual assetsCorporate non-accrual loans$2,001 $1,377 $1,882 $1,122 $1,553 Consumer non-accrual loans1,618 1,310 1,315 1,317 1,826 Non-accrual loans (NAL)$3,619 $2,687 $3,197 $2,439 $3,379 OREO22 18 36 15 27 Non-accrual assets (NAA)$3,641 $2,705 $3,233 $2,454 $3,406 NAL as a percentage of total loans0.48 %0.39 %0.46 %0.37 %0.51 %NAA as a percentage of total assets0.14 0.11 0.13 0.10 0.15 ACLL as a percentage of NAL(2)532 691 568 696 487 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). 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 largely 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:•funding its existing asset base;•growing its core businesses;•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 •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. Citi’s 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 the following:•corporate and consumer deposits via Citi’s bank subsidiaries, including Citibank, N.A. (Citibank)•long-term debt (primarily senior and subordinated debt) mainly issued by Citigroup Inc., as the parent, and Citibank•stockholders’ equityThese sources are 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 and tenor 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 cluster and in-country treasurers with oversight provided by Independent Risk Management and various Asset and Liability Committees (ALCOs) and Country Coordinating Committee at the individual entity, cluster, 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 Measurement Stress 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 largely 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:•funding its existing asset base;•growing its core businesses;•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 •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. Citi’s 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 the following:•corporate and consumer deposits via Citi’s bank subsidiaries, including Citibank, N.A. (Citibank)•long-term debt (primarily senior and subordinated debt) mainly issued by Citigroup Inc., as the parent, and Citibank•stockholders’ equityThese sources are supplemented by short-term borrowings, primarily in the form of secured funding transactions."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Secured Funding Transactions",
      "prior_title": "Secured Funding Transactions",
      "current_body": "Secured funding is primarily accessed through Citi’s broker-dealer subsidiaries, with a smaller portion executed through Citi’s bank entities to efficiently fund both (i) secured lending activity and (ii) a portion of the securities inventory held in the context of market making and customer activities. Secured funding transactions are predominantly collateralized by government debt securities. Generally, changes in the level of Citi’s secured funding are primarily due to fluctuations in secured lending activity in the matched book (as described below), and changes in securities inventory and eligible counterparty balance sheet netting. In order to maintain reliable funding under a wide range of market conditions, Citi manages risks related to its secured funding by establishing secured funding limits and conducting daily stress tests that account for risks related to capacity, tenor, haircut, collateral type, counterparty and client actions. As of the quarter ended December 31, 2025, secured funding on an average basis was $385 billion. For information about changes in Citi’s end-of-period securities loaned and sold under agreements to repurchase, see “Balance Sheet Overview” above. The portion of secured funding in the broker-dealer subsidiaries that funds secured lending is commonly referred to as “matched book” activity and is primarily secured by high-quality liquid securities such as U.S. Treasury securities, U.S. agency securities and foreign government debt securities. Other “matched book” activity is secured by less liquid securities, including equity securities, corporate bonds and asset-backed securities, the tenor of which is generally equal to or longer than the tenor of the corresponding assets. As indicated above, the remaining portion of secured funding is used to fund securities inventory held in the context of market making and customer activities."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Citi’s Businesses, Results of Operations and Financial Condition Could Be Negatively Impacted if It Does Not Effectively Manage Its Liquidity.",
      "prior_title": "Citi’s Businesses, Results of Operations and Financial Condition Could Be Negatively Impacted if It Does Not Effectively Manage Its Liquidity.",
      "current_body": "As a large, global financial institution, adequate liquidity and sources of funding are essential to Citi. 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. Additionally, Citi competes with other banks and non-bank financial institutions for both institutional and consumer deposits, which represent Citi’s most stable and lowest cost source of long-term funding. The competition for deposits has continued to increase in recent years, including as a result of fixed income alternatives for customer funds. Citi’s costs to obtain and access wholesale funding are directly related to changes in interest and currency exchange rates and its credit spreads. Changes in Citi’s credit spreads are driven by both external market factors and factors specific to Citi, such as negative views by investors of the financial services industry or Citi’s financial prospects, and can be highly volatile. For additional information on Citi’s primary sources of funding, see “Managing Global Risk—Liquidity Risk” below. Citi’s ability to obtain funding may be impaired and its cost of funding could also increase if other market participants are seeking to access the markets at the same time or to a greater extent than expected, or if market appetite for corporate debt securities declines, as is likely to occur in a liquidity stress event or other market crisis. In such circumstances, Citi’s ability to sell assets may also be impaired if other market participants are seeking to sell similar assets at the same time or a liquid market does not exist for such assets. Additionally, unexpected changes in client needs due to idiosyncratic events or market conditions could result in greater than expected drawdowns from off-balance sheet committed facilities. A sudden drop in market liquidity could also cause a temporary or protracted dislocation of capital markets activity. In addition, clearing organizations, central banks, clients and financial institutions with which Citi interacts may exercise the right to require additional collateral during challenging market conditions, which could further impair Citi’s liquidity. If Citi fails to effectively manage its liquidity, its businesses, results of operations and financial condition could be negatively impacted.Limitations on the payments that Citigroup Inc. receives from its subsidiaries could also impact its liquidity. As a holding company, Citigroup Inc. relies on interest, dividends, distributions and other payments from its subsidiaries to fund dividends as well as to satisfy its debt and other obligations. Several of Citi’s U.S. and non-U.S. subsidiaries are or may be subject to capital adequacy or other liquidity, regulatory or contractual restrictions on their ability to provide such payments, including any local regulatory stress test requirements and inter-affiliate arrangements entered into in connection with Citigroup Inc.’s resolution plan. Citigroup Inc.’s broker-dealer and bank subsidiaries are subject to restrictions on their ability to lend or transact with affiliates, as well as restrictions on their ability to use funds deposited with them in brokerage or bank accounts to fund their businesses. A bank holding company is also required by law to act as a source of financial and managerial strength for its subsidiary banks. As a result, the FRB may require Citigroup Inc. to commit resources to its subsidiary banks even if doing so is not otherwise in the interests of Citigroup Inc. or its shareholders or creditors, reducing the amount of funds available to meet its obligations.A Ratings Downgrade Could Adversely Impact Citi’s Funding and Liquidity.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, declines in profitability, reductions in regulatory capitalization levels, deterioration in Citi’s funding structure or liquidity, significant increases in risk appetite, delays or missteps in Citi’s transformation efforts, public statements by Citi’s management or regulators or control failures. A ratings downgrade 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 markets activity. In addition, clearing organizations, central banks, clients and financial institutions with which Citi interacts may exercise the right to require additional collateral during challenging market conditions, which could further impair Citi’s liquidity. If Citi fails to effectively manage its liquidity, its businesses, results of operations and financial condition could be negatively impacted. Limitations on the payments that Citigroup Inc. receives from its subsidiaries could also impact its liquidity. As a holding company, Citigroup Inc. relies on interest, dividends, distributions and other payments from its subsidiaries to fund dividends as well as to satisfy its debt and other obligations. Several of Citi’s U.S. and non-U.S. subsidiaries are or may be subject to capital adequacy or other liquidity, regulatory or contractual restrictions on their ability to provide such payments, including any local regulatory stress test requirements and inter-affiliate arrangements entered into in connection with Citigroup Inc.’s resolution plan. Citigroup Inc.’s broker-dealer and bank subsidiaries are subject to restrictions on their ability to lend or transact with affiliates, as well as restrictions on their ability to use funds deposited with them in brokerage or bank accounts to fund their businesses. A bank holding company is also required by law to act as a source of financial and managerial strength for its subsidiary banks. As a result, the FRB may require Citigroup Inc. to commit resources to its subsidiary banks even if doing so is not otherwise in the interests of Citigroup Inc. or its shareholders or creditors, reducing the amount of funds available to meet its obligations."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Portfolio Mix—Geography and Counterparty",
      "prior_title": "Portfolio Mix—Geography and Counterparty",
      "current_body": "Citi’s corporate credit portfolio is diverse across geographies and types of counterparties. The following table presents the percentages of this portfolio across North America and the clusters within International based on the country of risk of the obligor (for additional information on Citi’s international exposures, see “Other Risks—Country Risk—Top 25 Country Exposures” below): December 31,2025September 30,2025December 31,2024North America58 %57 %56 %International42 43 44 Total100 %100 %100 %International by cluster(percentages are based on total Citi)Europe16 %17 %16 %LATAM7 7 7 United Kingdom6 6 6 Japan, Asia North and Australia (JANA)6 6 6 Asia South4 4 5 Middle East, Africa and Russia (MEA)3 3 4 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 parental 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 31,2025September 30,2025December 31,2024AAA/AA/A49 %48 %49 %BBB29 29 30 BB/B20 21 19 CCC or below2 2 2 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 parental 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 31,2025September 30,2025December 31,2024AAA/AA/A49 %48 %49 %BBB29 29 30 BB/B20 21 19 CCC or below2 2 2 Total100 %100 %100 % Note: Total exposure includes direct outstandings and unfunded lending commitments. 69 69 69 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, 2025. 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. Obligor risk ratings may be downgraded, reflecting the increase in the probability of default. 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 industry classifications are generally based on the clients’ primary business activity. The following table details the allocation of Citi’s total corporate credit portfolio by industry: Total exposure December 31,2025September 30,2025December 31,2024Transportation and industrials19 %19 %20 %Technology, media and telecom14 15 12 Banks and finance companies(1)13 13 12 Real estate11 10 11 Commercial8 8 8 Residential3 2 3 Consumer retail10 10 11 Power, chemicals, metals and mining8 9 9 Energy and commodities6 6 6 Healthcare5 5 5 Public sector4 4 4 Insurance3 3 4 Asset managers and funds3 3 3 Financial markets infrastructure3 3 2 Other industries1 — 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, 2025. 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. Obligor risk ratings may be downgraded, reflecting the increase in the probability of default. 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, 2025. 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. Obligor risk ratings may be downgraded, reflecting the increase in the probability of default. 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 industry classifications are generally based on the clients’ primary business activity. The following table details the allocation of Citi’s total corporate credit portfolio by industry: Total exposure December 31,2025September 30,2025December 31,2024Transportation and industrials19 %19 %20 %Technology, media and telecom14 15 12 Banks and finance companies(1)13 13 12 Real estate11 10 11 Commercial8 8 8 Residential3 2 3 Consumer retail10 10 11 Power, chemicals, metals and mining8 9 9 Energy and commodities6 6 6 Healthcare5 5 5 Public sector4 4 4 Insurance3 3 4 Asset managers and funds3 3 3 Financial markets infrastructure3 3 2 Other industries1 — 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Citi Is Subject to Extensive Legal and Regulatory Proceedings, Examinations, Investigations, Consent Orders and Related Compliance Efforts and Other Inquiries That Have in the Past and Could in the Future 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.",
      "prior_title": "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.",
      "current_body": "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 remedy deficiencies on a timely basis (see also the capital return and resolution plan risk factors above). Under U.S. banking law, Citi is prohibited from disclosing confidential supervisory information, and may therefore be unable to disclose even potentially material regulatory or supervisory matters. 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 require continued significant investments by Citi during 2026 and beyond, as an essential part of Citi’s broader transformation efforts (see the simplification, transformation and enhanced business performance priorities risk factor above). Further, in 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 FRB found that Citigroup 60 60 60 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. There can be no assurance that 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. Large financial institutions face a challenging global judicial, regulatory and political environment. 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 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, failures to safeguard a party’s personal information or failures to identify and manage conflicts of interest.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 regulatory scrutiny and 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. Citi may be required to accept or be subject to 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 changes in or incorrect assumptions 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.During 2025, emerging markets revenues accounted for approximately 25% of Citi’s total revenues. Citi’s presence in the emerging markets subjects it to various risks.Citi’s emerging markets risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations; central bank interest rate and other monetary policies; macroeconomic, geopolitical and domestic political challenges, uncertainties and volatilities; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; limitations on foreign investment; sociopolitical instability; 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 strict capital controls, currency controls and/or sanctions that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. As a result, Citi might need to record additional translation losses due to these 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. There can be no assurance that 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. Large financial institutions face a challenging global judicial, regulatory and political environment. 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 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, failures to safeguard a party’s personal information or failures to identify and manage conflicts of interest.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 regulatory scrutiny and 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. 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. There can be no assurance that 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. Large financial institutions face a challenging global judicial, regulatory and political environment. 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 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, failures to safeguard a party’s personal information or failures to identify and manage conflicts of interest. 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 regulatory scrutiny and 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. Citi may be required to accept or be subject to 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 changes in or incorrect assumptions 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.During 2025, emerging markets revenues accounted for approximately 25% of Citi’s total revenues. Citi’s presence in the emerging markets subjects it to various risks.Citi’s emerging markets risks include, among others, limitations or unavailability of hedges on foreign investments; foreign currency volatility, including devaluations; central bank interest rate and other monetary policies; macroeconomic, geopolitical and domestic political challenges, uncertainties and volatilities; foreign exchange controls, including an inability to access indirect foreign exchange mechanisms; cyberattacks; restrictions arising from retaliatory laws and regulations; sanctions or asset freezes; sovereign debt volatility; fluctuations in commodity prices; limitations on foreign investment; sociopolitical instability; 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 strict capital controls, currency controls and/or sanctions that limit its ability to convert local currency into U.S. dollars and/or transfer funds outside of those countries. As a result, Citi might need to record additional translation losses due to these Moreover, the severity of the remedies sought in legal and regulatory proceedings to which Citi is subject has remained elevated. Citi may be required to accept or be subject to 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 changes in or incorrect assumptions 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "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.",
      "prior_title": "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.",
      "current_body": "Every two years, 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 2025 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 52 52 52 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 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 submitted a targeted resolution plan on July 1, 2025.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 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 highly qualified employees. Specifically, Citi’s continued ability to compete in each of its lines of business, grow and manage its businesses effectively, as well as to execute its strategic 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 achievement of its 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. 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. 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 and its reputation. For information on Citi’s employee and workforce management, see “Human Capital Resources and Management” below.Citi Faces Potential Disruptions from an EvolvingBusiness Environment, Including Competitive Challenges and Emerging Technologies.Citi operates in an increasingly evolving and competitive business environment, which includes both financial and non-financial services firms, such as banks and private credit, financial technology and digital asset companies, among others.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. To the extent that Citi is not able to compete effectively with other financial services companies, including private credit, financial technology and digital asset 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 competitive risks, see the co-branding and private label credit cards and qualified employees risk factors above and the AI risk factor and “Supervision, Regulation and Other—Competition” below. 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. 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. 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. 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 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 submitted a targeted resolution plan on July 1, 2025.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 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 highly qualified employees. Specifically, Citi’s continued ability to compete in each of its lines of business, grow and manage its businesses effectively, as well as to execute its strategic 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 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 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 submitted a targeted resolution plan on July 1, 2025. 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."
    },
    {
      "status": "UNCHANGED",
      "current_title": "MANAGING GLOBAL RISK",
      "prior_title": "MANAGING GLOBAL RISK",
      "current_body": "Overview For Citi, effective risk management is of primary importance to its overall operations. Accordingly, Citi has established an Enterprise Risk Management (ERM) Framework to ensure that Citi’s risks are managed appropriately and consistently across the Company and at an aggregate, enterprise-wide level. Citi’s culture drives a strong risk and control environment and is at the heart of the ERM Framework, underpinning the way Citi conducts business. The activities that Citi engages in, and the risks those activities generate, must be consistent with Citi’s Mission and Value Proposition (see below) and the key Leadership Principles that support it, as well as Citi’s risk appetite. As discussed above, Citi also continues its efforts to comply with the 2020 FRB and OCC Consent Orders, relating principally to various aspects of risk management, compliance, data quality management related to governance, and internal controls (see “Citi’s Multiyear Transformation—FRB and OCC Consent Orders Compliance” and “Risk Factors—Compliance Risks” above). Under Citi’s Mission and Value Proposition, which was developed by its senior leadership and distributed throughout the Company, Citi strives to serve its clients as a trusted partner by responsibly providing financial services that enable growth and economic progress while earning and maintaining the public’s trust by constantly adhering to the highest ethical standards. As such, Citi asks all employees to ensure that their decisions pass three tests: they are in Citi’s clients’ best interests, create economic value and are always systemically responsible. Citi has designed Leadership Principles that represent the qualities, behaviors and expectations all employees must exhibit to deliver on Citi’s mission of enabling growth and economic progress. The Leadership Principles inform Citi’s ERM Framework and contribute to creating a culture that drives client, control and operational excellence. Citi employees share a common responsibility to uphold these Leadership Principles and hold themselves to the highest standards of ethics and professional behavior in dealing with Citi’s clients, business colleagues, shareholders, communities and each other. Citi’s ERM Framework details the principles used to support effective enterprise-wide risk management across the end-to-end risk management lifecycle. The underlying pillars of the framework encompass: •Culture—the core principles and behaviors that underpin a strong culture of risk awareness, in line with Citi’s Mission and Value Proposition, and Leadership Principles; •Governance—the committee structure and reporting arrangements that support the appropriate oversight of risk management activities at the Board and Executive Management Team levels and Citi’s Lines of Defense model; •Risk Management—the end-to-end risk management cycle including the identification, measurement, monitoring, controlling and reporting of all material risks; and •Enterprise Programs—the key risk management programs performed across the risk management lifecycle for all risk categories.Each of these pillars is underpinned by supporting capabilities covering people, infrastructure and tools that are in place to enable the execution of the ERM Framework. Controls are established to mitigate the risks associated with the execution of these pillars and supporting capabilities.Citi’s approach to risk management requires that its risk-taking be consistent with its risk appetite. Risk appetite is the aggregate level of risk that Citi is willing to tolerate in order to achieve its strategic objectives and business plan. Risk limits and thresholds represent allocations of Citi’s risk appetite to businesses and risk categories. Concentration risks are controlled through a subset of these limits and thresholds.Citi’s risks are generally categorized and summarized as follows:•Credit risk is the risk of loss resulting from the decline in credit quality (or downgrade risk) or failure of a borrower, counterparty, third party or issuer to honor its financial or contractual obligations.•Liquidity risk is the risk that Citi will not be able to efficiently meet its financial obligations as they become due without adversely impacting its daily operations or overall financial condition. This risk can be exacerbated by the Company’s inability to access necessary funding sources or to monetize assets in a timely and orderly manner.•Market risk (trading and non-trading): Market risk of trading portfolios is the risk of economic or trading loss arising from changes in the value of Citi’s assets and liabilities resulting from changes in market variables, such as interest rates, equity and commodity prices, foreign exchange rates or credit spreads. Market risk of non-trading portfolios is the impact of adverse changes in market variables such as interest rates, foreign exchange rates, credit spreads and equity prices on positions accounted for as part of Citi’s net interest income, economic value of equity or AOCI.•Operational risk is the risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events. Operational risk includes legal risk, but excludes strategic and reputation risks (see below). •Compliance risk is the risk to current or projected financial conditions and resilience arising from violations of laws, rules or regulations, or from non-conformance with prescribed practices, internal policies and procedures or ethical standards. •Reputation risk is the risk to current or projected financial conditions and resilience from negative opinion held by stakeholders. This risk may impair Citi’s competitiveness by affecting its ability to establish new relationships or services or continue servicing existing relationships.•Strategic risk is the risk of a sustained impact to Citi’s core strategic objectives as measured by impacts on anticipated earnings, market capitalization or capital, arising from the external factors affecting the Company’s •Enterprise Programs—the key risk management programs performed across the risk management lifecycle for all risk categories. Each of these pillars is underpinned by supporting capabilities covering people, infrastructure and tools that are in place to enable the execution of the ERM Framework. Controls are established to mitigate the risks associated with the execution of these pillars and supporting capabilities. Citi’s approach to risk management requires that its risk-taking be consistent with its risk appetite. Risk appetite is the aggregate level of risk that Citi is willing to tolerate in order to achieve its strategic objectives and business plan. Risk limits and thresholds represent allocations of Citi’s risk appetite to businesses and risk categories. Concentration risks are controlled through a subset of these limits and thresholds. Citi’s risks are generally categorized and summarized as follows: •Credit risk is the risk of loss resulting from the decline in credit quality (or downgrade risk) or failure of a borrower, counterparty, third party or issuer to honor its financial or contractual obligations. •Liquidity risk is the risk that Citi will not be able to efficiently meet its financial obligations as they become due without adversely impacting its daily operations or overall financial condition. This risk can be exacerbated by the Company’s inability to access necessary funding sources or to monetize assets in a timely and orderly manner. •Market risk (trading and non-trading): Market risk of trading portfolios is the risk of economic or trading loss arising from changes in the value of Citi’s assets and liabilities resulting from changes in market variables, such as interest rates, equity and commodity prices, foreign exchange rates or credit spreads. Market risk of non-trading portfolios is the impact of adverse changes in market variables such as interest rates, foreign exchange rates, credit spreads and equity prices on positions accounted for as part of Citi’s net interest income, economic value of equity or AOCI. •Operational risk is the risk of loss resulting from inadequate or failed internal processes, people and systems, or from external events. Operational risk includes legal risk, but excludes strategic and reputation risks (see below). •Compliance risk is the risk to current or projected financial conditions and resilience arising from violations of laws, rules or regulations, or from non-conformance with prescribed practices, internal policies and procedures or ethical standards. •Reputation risk is the risk to current or projected financial conditions and resilience from negative opinion held by stakeholders. This risk may impair Citi’s competitiveness by affecting its ability to establish new relationships or services or continue servicing existing relationships. •Strategic risk is the risk of a sustained impact to Citi’s core strategic objectives as measured by impacts on anticipated earnings, market capitalization or capital, arising from the external factors affecting the Company’s 64 64 64 operating environment, as well as the risks associated with defining and executing the strategy.Additionally, Citi categorizes and summarizes risks that span the above risk categories, such as concentration risk, country risk and climate risk.Citi uses a lines of defense model as a key component of its ERM Framework to manage its risks. As discussed below, the lines of defense model brings together risk-taking, risk oversight and risk assurance under one umbrella and provides an avenue for risk accountability of the first line of defense, a construct for effective challenge by the second line of defense (Independent Risk Management and Independent Compliance Risk Management), and empowers independent risk assurance by the third line of defense (Internal Audit). In addition, the lines of defense model includes organizational units tasked with supporting a strong control environment (enterprise support functions). First Line of DefenseCiti’s first line of defense owns the risks and associated controls inherent in, or arising from, the execution of its business activities and is responsible for identifying, measuring, monitoring, controlling and reporting those risks consistent with Citi’s strategy, Mission and Value Proposition, Leadership Principles and risk appetite. The first line of defense is composed of Citi’s operating segments (i.e., Services, Markets, Banking, Wealth, U.S. Personal Banking as of December 31, 2025), as well as International, North America and All Other (including certain corporate functions (i.e., Chief Operating Office, Enterprise Services and Public Affairs, Finance, Technology and Business Enablement). First line of defense may also contain organizations that are enterprise support functions—see “Enterprise Support Functions” below.Second Line of DefenseThe second line of defense is independent of the first line of defense. It is responsible for overseeing the risk-taking activities of the first line of defense and challenging the first line of defense in the execution of its risk management responsibilities. It is also responsible for independently identifying, measuring, monitoring, controlling and reporting aggregate risks and for setting standards for the management and oversight of risk. The second line of defense is composed of Independent Risk Management (IRM) and Independent Compliance Risk Management (ICRM), which are led by the Group Chief Risk Officer (CRO) and Group Chief Compliance Officer (CCO), respectively, who have unrestricted access to the Board and its Risk Management Committee to facilitate the ability to execute their specific responsibilities pertaining to escalation to the Board.Independent Risk ManagementThe IRM organization sets risk and control standards for the first line of defense and actively manages and oversees aggregate credit, market (trading and non-trading), liquidity, strategic, operational and reputation risks across Citi, including risks that span categories, such as concentration risk, country risk and climate risk. The CRO reports directly to both the Board’s Risk Management Committee and the Citigroup CEO. Independent Compliance Risk Management 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, and is committed to maintaining an enterprise-wide compliance riskmanagement framework across Citi. The CCO reports to Citi’s Chief Legal Officer, and ICRM is organizationally part of Global Legal Affairs and Compliance. In addition, the CCO has matrix reporting into the CRO.Third Line of DefenseInternal 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. 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). Organizations noted under the first line of defense may also contain enterprise support functions (e.g., the Controllers Group within Finance). Enterprise support functions are subject to the relevant Company-wide independent oversight processes specific to the risks for which they are accountable (e.g., operational risk and compliance 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. operating environment, as well as the risks associated with defining and executing the strategy.Additionally, Citi categorizes and summarizes risks that span the above risk categories, such as concentration risk, country risk and climate risk.Citi uses a lines of defense model as a key component of its ERM Framework to manage its risks. As discussed below, the lines of defense model brings together risk-taking, risk oversight and risk assurance under one umbrella and provides an avenue for risk accountability of the first line of defense, a construct for effective challenge by the second line of defense (Independent Risk Management and Independent Compliance Risk Management), and empowers independent risk assurance by the third line of defense (Internal Audit). In addition, the lines of defense model includes organizational units tasked with supporting a strong control environment (enterprise support functions). First Line of DefenseCiti’s first line of defense owns the risks and associated controls inherent in, or arising from, the execution of its business activities and is responsible for identifying, measuring, monitoring, controlling and reporting those risks consistent with Citi’s strategy, Mission and Value Proposition, Leadership Principles and risk appetite. The first line of defense is composed of Citi’s operating segments (i.e., Services, Markets, Banking, Wealth, U.S. Personal Banking as of December 31, 2025), as well as International, North America and All Other (including certain corporate functions (i.e., Chief Operating Office, Enterprise Services and Public Affairs, Finance, Technology and Business Enablement). First line of defense may also contain organizations that are enterprise support functions—see “Enterprise Support Functions” below.Second Line of DefenseThe second line of defense is independent of the first line of defense. It is responsible for overseeing the risk-taking activities of the first line of defense and challenging the first line of defense in the execution of its risk management responsibilities. It is also responsible for independently identifying, measuring, monitoring, controlling and reporting aggregate risks and for setting standards for the management and oversight of risk. The second line of defense is composed of Independent Risk Management (IRM) and Independent Compliance Risk Management (ICRM), which are led by the Group Chief Risk Officer (CRO) and Group Chief Compliance Officer (CCO), respectively, who have unrestricted access to the Board and its Risk Management Committee to facilitate the ability to execute their specific responsibilities pertaining to escalation to the Board.Independent Risk ManagementThe IRM organization sets risk and control standards for the first line of defense and actively manages and oversees aggregate credit, market (trading and non-trading), liquidity, strategic, operational and reputation risks across Citi, including risks that span categories, such as concentration risk, country risk and climate risk. The CRO reports directly to both operating environment, as well as the risks associated with defining and executing the strategy. Additionally, Citi categorizes and summarizes risks that span the above risk categories, such as concentration risk, country risk and climate risk. Citi uses a lines of defense model as a key component of its ERM Framework to manage its risks. As discussed below, the lines of defense model brings together risk-taking, risk oversight and risk assurance under one umbrella and provides an avenue for risk accountability of the first line of defense, a construct for effective challenge by the second line of defense (Independent Risk Management and Independent Compliance Risk Management), and empowers independent risk assurance by the third line of defense (Internal Audit). In addition, the lines of defense model includes organizational units tasked with supporting a strong control environment (enterprise support functions)."
    },
    {
      "status": "UNCHANGED",
      "current_title": "Other industries(6)",
      "prior_title": "Other industries(6)",
      "current_body": "(1) Represents gross credit exposures excluding any purchased credit protection. (2) Funded excludes loans carried at fair value of $6.8 billion and HFS of $5.2 billion as of December 31, 2025. (3) Unfunded includes lending-related commitments carried at fair value and HFS as of December 31, 2025. (4) Includes non-accrual loan exposures and related criticized unfunded exposures. (5) Represents the amount of purchased credit protection in the form of derivatives to economically hedge funded and unfunded exposures. Of the $40.6 billion of purchased credit protection, $37.5 billion represents the total notional amount of purchased credit derivatives on individual reference entities. The remaining $3.1 billion represents the first loss tranche of portfolios of purchased credit derivatives with a total notional amount of $27.3 billion, where the protection seller absorbs the first loss on the referenced loan portfolios. (6) Autos total credit exposure includes securitization financing facilities secured by auto loans and leases, extended mainly to the finance company subsidiaries of global auto manufacturers, bank subsidiaries and independent auto finance companies, of approximately $19.2 billion ($10.6 billion of which was funded exposure with 100% rated investment grade) as of December 31, 2025. (7) In addition to this exposure, Citi has energy-related exposure within the public sector (e.g., energy-related state-owned entities) and the transportation and industrials sector (e.g., offshore drilling entities) included in the table above. As of December 31, 2025, Citi’s total exposure to these energy-related entities was approximately $4.4 billion, of which approximately $1.7 billion consisted of direct outstanding funded loans. (8) Includes $0.7 billion and $0.1 billion of funded and unfunded exposure at December 31, 2025, respectively, primarily related to commercial credit card delinquency-managed loans. Exposure to Commercial Real EstateAs of December 31, 2025 and 2024, Citi’s total credit exposure to commercial real estate (CRE) was $78.4 billion and $65 billion, including $6.3 billion and $6 billion of exposure related to office buildings, respectively. This total CRE exposure consisted of approximately $69.5 billion and $56 billion, respectively, related to corporate clients, included in the real estate category in the tables above and below. Total CRE exposure also includes approximately $8.9 billion and $9 billion, respectively, related to Wealth clients, not included in the tables above as they are not considered corporate exposures.In addition, as of December 31, 2025, approximately 81% of Citi’s total CRE exposure was rated investment grade and more than 77% was to borrowers in the U.S. (compared to approximately 78% rated investment grade and more than 75% to borrowers in the U.S. as of December 31, 2024).As of December 31, 2025, the percentage of the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.4%, and there were $659 million of non-accrual CRE loans. As of December 31, 2024, the percentage of the ACLL attributed to the total funded CRE exposure (including Wealth) was approximately 1.6%, and there were $574 million of non-accrual CRE loans. Exposure to Commercial Real EstateAs of December 31, 2025 and 2024, Citi’s total credit exposure to commercial real estate (CRE) was $78.4 billion and $65 billion, including $6.3 billion and $6 billion of exposure related to office buildings, respectively. This total CRE exposure consisted of approximately $69.5 billion and $56 billion, respectively, related to corporate clients, included in the real estate category in the tables above and below. Total CRE exposure also includes approximately $8.9 billion and $9 billion, respectively, related to Wealth clients, not included in the tables above as they are not considered corporate exposures."
    }
  ]
}