SEC Comment Letter for CITIGROUP INC (C, C-PN) (CIK 0000831001) (C) — Dec 12, 2011
CITIGROUP INC (C, C-PN) (CIK 0000831001)
Date: Dec. 12, 2011 · CIK: 0000831001 · Accession: 0000000000-11-071186
AI Filing Summary & Sentiment
File numbers found in text: 001-09924
Letter
December 12, 2011 Via E-mail John C. Gerspach Chief Financial Officer Citigroup Inc. 399 Park Avenue New York, NY 10043 Re: Citigroup Inc. Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 25, 2011 Form 10-Q for Fiscal Quarter Ended March 31, 2011 Filed May 5, 2011 Form 10-Q for Fiscal Quarter Ended June 30, 2011 Filed August 5, 2011 File No. 001-09924
Dear Mr. Gerspach: We have reviewed your response letter da ted November 18, 2011 and are continuing to process your responses. In the inter im, we have an additional comment. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response.
After reviewing the information you provide in response to the comment, we may have additional comments. General
1. We have become aware through various news reports that you may have accessed various Federal Reserve and Federal Deposit Insura nce Corporation sponsored funding programs during 2008 and 2009, including the Term Auction Facility (TAF), Commercial Paper Funding Facility (CPFF), Temporary Liquidity Guarantee Program (TLGP), the Primary Dealer Credit Facility (PDCF) and the Term Securities Lending F acility (TSLF). We note from your disclosures during these pe riods that you appear to disclose the participation in certain programs, includi ng the TLGP and CPFF programs, along with the amounts of borrowing outstanding as of th e balance sheet dates for these programs, but you do not appear to have provided any discussion about certain other programs that were in existence at this time, such as the TAF, PDCF and TSLF. To the extent that you had borrowings under these programs during those periods, please tell us how you
John C. Gerspach Citigroup Inc. December 12, 2011 Page 2 concluded that quantitative a nd qualitative disclosure about your participation in these programs was not required. Additionally, please provide your analysis as to whether you believe that any participation in these programs constituted a form of federal financial assistance, such that additional disclosure may ha ve been required as to the effects of this assistance on your financial condition and re sults of operations pursuant to the guidance in FRC 501.06.c. Effects of Federal Financial Assistance Upon Operations.
You may contact Brittany Ebbe rtt at (202) 551-3572 or Stepha nie Hunsaker at (202) 551- 3512 if you have questions regarding comments on th e financial statements and related matters. Please contact Sebastian Gomez Abero at (202 ) 551-3578 or Michael Seaman at (202) 551-3366 with any other questions. Sincerely, /s/ Stephanie L. Hunsaker Stephanie L. Hunsaker Senior Assistant Chief Accountant
Show Raw Text
December 12, 2011 Via E-mail John C. Gerspach Chief Financial Officer Citigroup Inc. 399 Park Avenue New York, NY 10043 Re: Citigroup Inc. Form 10-K for Fiscal Year Ended December 31, 2010 Filed February 25, 2011 Form 10-Q for Fiscal Quarter Ended March 31, 2011 Filed May 5, 2011 Form 10-Q for Fiscal Quarter Ended June 30, 2011 Filed August 5, 2011 File No. 001-09924 Dear Mr. Gerspach: We have reviewed your response letter da ted November 18, 2011 and are continuing to process your responses. In the inter im, we have an additional comment. Please respond to this letter within te n business days by providing the requested information, or by advising us when you will provide the requested response. If you do not believe our comments apply to your facts and circum stances, please tell us w hy in your response. After reviewing the information you provide in response to the comment, we may have additional comments. General 1. We have become aware through various news reports that you may have accessed various Federal Reserve and Federal Deposit Insura nce Corporation sponsored funding programs during 2008 and 2009, including the Term Auction Facility (TAF), Commercial Paper Funding Facility (CPFF), Temporary Liquidity Guarantee Program (TLGP), the Primary Dealer Credit Facility (PDCF) and the Term Securities Lending F acility (TSLF). We note from your disclosures during these pe riods that you appear to disclose the participation in certain programs, includi ng the TLGP and CPFF programs, along with the amounts of borrowing outstanding as of th e balance sheet dates for these programs, but you do not appear to have provided any discussion about certain other programs that were in existence at this time, such as the TAF, PDCF and TSLF. To the extent that you had borrowings under these programs during those periods, please tell us how you John C. Gerspach Citigroup Inc. December 12, 2011 Page 2 concluded that quantitative a nd qualitative disclosure about your participation in these programs was not required. Additionally, please provide your analysis as to whether you believe that any participation in these programs constituted a form of federal financial assistance, such that additional disclosure may ha ve been required as to the effects of this assistance on your financial condition and re sults of operations pursuant to the guidance in FRC 501.06.c. Effects of Federal Financial Assistance Upon Operations. You may contact Brittany Ebbe rtt at (202) 551-3572 or Stepha nie Hunsaker at (202) 551- 3512 if you have questions regarding comments on th e financial statements and related matters. Please contact Sebastian Gomez Abero at (202 ) 551-3578 or Michael Seaman at (202) 551-3366 with any other questions. Sincerely, /s/ Stephanie L. Hunsaker Stephanie L. Hunsaker Senior Assistant Chief Accountant