SEC Comment Letter for CITIGROUP INC (C, C-PN) (CIK 0000831001) (C) — Jul 17, 2009
CITIGROUP INC (C, C-PN) (CIK 0000831001)
Date: July 17, 2009 · CIK: 0000831001 · Accession: 0000000000-09-038009
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
CORPORATION FINANCE
July 16, 2009
By U.S. Mail and Facsimile to: (866) 720-7307
Julie A. Bell Lindsay Citigroup Inc. 1101 Pennsylvania Ave NW Suite 1000 Washington, DC 20004
Re: Citigroup Inc.
File No. 1-9924
Dear Ms. Lindsay:
We note the Wall Street Journal article dated July 16, 2009 which references a
Memorandum of Understanding between Citigr oup and the Office of the Comptroller of
the Currency. In this regard, please confirm to us that you have previously disclosed all changes made or to be made as a result of the Memorandum of Understanding which are
reasonably likely to have a material effect on liquidity, capital resources, or future
operating results. In additi on, if you are aware of any ot her current recommendations by
any regulatory authorities which, if implemented , are reasonably likely to have a material
effect on liquidity, capital resource s, or future operating results, please confirm to us that
you have provided appropriate disclosure.
Please contact Justin Dobbie at (202) 551-3469, Christian Windsor, Special
Counsel, at (202) 551-3419, Ke vin W. Vaughn, Accounting Branch Chief, at (202) 551-
3494, or me at (202) 551- 3491 with any questions.
S i n c e r e l y , Todd K. Schiffman
Assistant Director