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SEC Company Response from CITIGROUP INC (C, C-PN) (CIK 0000831001) (C) — May 11, 2011

CITIGROUP INC (C, C-PN) (CIK 0000831001)
Date: May 11, 2011 · CIK: 0000831001 · Accession: 0000950123-11-048819

AI Filing Summary & Sentiment

File numbers found in text: 333-172554, 333-172555

Date
May 11, 2011
Author
Not clearly detected
Form
CORRESP
Company
CITIGROUP INC (C, C-PN) (CIK 0000831001)

Letter

VIA EDGAR AND FACSIMILE Securities and Exchange Commission Division of Corporation Finance Citigroup Inc. Safety First Trusts Registration Statements on Form S-3 File Nos. 333-172554 and 333-172555

Dear Mr. Webb and Mr. Seaman:

As underwriter of the proposed public offering of securities by Citigroup Funding Inc., of related guarantees by Citigroup Inc. and of trust securities Safety First Trust Series 2007-3 through Safety First Trust Series 2007-4, Safety First Trust Series 2008-1 through Safety First Trust Series 2008-7 and Safety First Trust Series 2009-1 through Safety First Trust Series 2009-8 (the “Registrants”) under the Registration Statements on Form S-3 (Nos. 333-172554 and 333-172555) we hereby join the Registrants’ request for acceleration of the above-referenced Registration Statements so that they will become effective at noon, New York City time, on May 12, 2011, or as soon thereafter as practicable.

Very truly yours,
CITIGROUP GLOBAL MARKETS INC.

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CORRESP
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corresp

Citigroup Global Markets Inc.

390 Greenwich Street, 3rd Floor

New York, New York 10013

May 11, 2011

VIA EDGAR AND FACSIMILE

Mark Webb, Legal Branch Chief

Michael Seaman, Special Counsel

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-010

              Re:

    Citigroup Funding Inc.

Citigroup Inc.

Safety First Trusts

Registration Statements on Form S-3

File Nos. 333-172554 and 333-172555

Dear Mr. Webb and Mr. Seaman:

     As underwriter of the proposed public offering of securities by Citigroup Funding Inc., of
related guarantees by Citigroup Inc. and of trust securities Safety First Trust Series 2007-3
through Safety First Trust Series 2007-4, Safety First Trust Series 2008-1 through Safety First
Trust Series 2008-7 and Safety First Trust Series 2009-1 through Safety First Trust Series 2009-8
(the “Registrants”) under the Registration Statements on Form S-3 (Nos. 333-172554 and 333-172555)
we hereby join the Registrants’ request for acceleration of the above-referenced Registration
Statements so that they will become effective at noon, New York City time, on May 12, 2011, or as
soon thereafter as practicable.

    Very truly yours,

    CITIGROUP GLOBAL MARKETS INC.

    By:

Name:

    /s/ Nicholas Parcharidis

Nicholas Parcharidis

    Title:

    Managing Director