SEC Comment Letter for CITIGROUP INC (C, C-PN) (CIK 0000831001) (C) — May 26, 2022
CITIGROUP INC (C, C-PN) (CIK 0000831001)
Date: May 26, 2022 · CIK: 0000831001 · Accession: 0000000000-22-005808
AI Filing Summary & Sentiment
File numbers found in text: 001-09924
Referenced dates: May 2, 2022
Letter
United States securities and exchange commission logo May 26, 2022 Jane Fraser Chief Executive Officer Citigroup Inc. 388 Greenwich Street New York, NY 10013 Re:Citigroup Inc. Form 10-Q for the Period Ended March 31, 2022 Filed May 9, 2022 CORRESP filed May 10, 2022 File No. 001-09924 Dear Ms. Fraser: We have reviewed your May 10, 2022 response to our comment letter and have the following comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. Please respond to this comment by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this comment, we may have additional comments. Unless noted otherwise, our reference to prior comments are to comments in our May 2, 2022 letter.
Form 10-Q for the Period Ended March 31, 2022 Country Risk Russia, page 67 1.We note your response to comment 1 from our letter dated May 2, 2022 and your added disclosures in the 10-Q for the period ended March 31, 2022. On page 68 you state that, "In addition, Citi is exposed to a currency translation adjustment (CTA) loss of approximately $1.0 billion related to Russia in the event of a loss of control or substantial liquidation of AO Citibank." Please tell us, and revise your future filings to disclose how this exposure/risk is reflected in your total Russia exposure in the table on page 67. For
FirstName LastNameJane Fraser Comapany NameCitigroup Inc. May 26, 2022 Page 2 FirstName LastName Jane Fraser Citigroup Inc. May 26, 2022 Page 2 example, consider adding a footnote to the table that highlights the $1.0 billion exposure, states whether it is reflected in the table, and references the 'Deconsolidation Risk' section on page 69 for additional information. Please direct any questions to Dave Irving at (202) 551-3321 or Michelle Miller at (202) 551-3368. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
May 26, 2022
Jane Fraser
Chief Executive Officer
Citigroup Inc.
388 Greenwich Street
New York, NY 10013
Re:Citigroup Inc.
Form 10-Q for the Period Ended March 31, 2022
Filed May 9, 2022
CORRESP filed May 10, 2022
File No. 001-09924
Dear Ms. Fraser:
We have reviewed your May 10, 2022 response to our comment letter and have the
following comment. In our comment, we ask you to provide us with information so we may
better understand your disclosure.
Please respond to this comment by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comment applies to your facts
and circumstances, please tell us why in your response.
After reviewing your response to this comment, we may have additional comments.
Unless noted otherwise, our reference to prior comments are to comments in our May 2, 2022
letter.
Form 10-Q for the Period Ended March 31, 2022
Country Risk
Russia, page 67
1.We note your response to comment 1 from our letter dated May 2, 2022 and your added
disclosures in the 10-Q for the period ended March 31, 2022. On page 68 you state that,
"In addition, Citi is exposed to a currency translation adjustment (CTA) loss of
approximately $1.0 billion related to Russia in the event of a loss of control or substantial
liquidation of AO Citibank." Please tell us, and revise your future filings to disclose how
this exposure/risk is reflected in your total Russia exposure in the table on page 67. For
FirstName LastNameJane Fraser
Comapany NameCitigroup Inc.
May 26, 2022 Page 2
FirstName LastName
Jane Fraser
Citigroup Inc.
May 26, 2022
Page 2
example, consider adding a footnote to the table that highlights the $1.0 billion exposure,
states whether it is reflected in the table, and references the 'Deconsolidation Risk' section
on page 69 for additional information.
Please direct any questions to Dave Irving at (202) 551-3321 or Michelle Miller at (202)
551-3368.
Sincerely,
Division of Corporation Finance
Office of Finance