SEC Company Response from CITIGROUP INC (C, C-PN) (CIK 0000831001) (C) — Mar 7, 2013
CITIGROUP INC (C, C-PN) (CIK 0000831001)
Date: March 7, 2013 · CIK: 0000831001 · Accession: 0001144204-13-013478
AI Filing Summary & Sentiment
File numbers found in text: 333-172554, 333-172562
Referenced dates: April 12, 2012, February 21, 2013
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CORRESP
1
filename1.htm
March
7, 2013
Via EDGAR and E-Mail
Amy M. Starr
Chief
Office of Capital Markets Trends
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
RE: Citigroup Funding Inc.
424 Prospectuses relating to Registration Statement
on Form S-3
Filed March 2, 2011
File No. 333-172554
Dear Ms. Starr:
Enhancement of Citigroup Inc.’s (“Citi”) disclosures
is an objective that we share with the staff (the “Staff”) of the U.S. Securities and Exchange Commission and one that
we consider in all of our filings. Citi is providing this letter in response to your comment letter dated February 21, 2013 relating
to prospectus supplements for structured notes issued by Citigroup Funding Inc. (“CFI”) from time to time from the
above-referenced registration statement. Please note that on December 31, 2012, CFI was merged with and into Citi. Following the
merger, structured notes that would have been issued by CFI from the above-referenced registration statement prior to the merger
are now generally issued by Citi from a Citi registration statement (registration no. 333-172562).
Citi confirms that it will comply with the comments in your
February 21, 2013 letter and in your related letter dated April 12, 2012 in future prospectus supplements for registered structured
notes. Citi intends to begin such compliance as soon as appropriate internal procedures have been implemented.
If you or the Staff have any further questions
or requests, please feel free to contact the undersigned at (202) 879-6896.
Very truly yours,
/s/ Julie Bell Lindsay
Julie Bell Lindsay
General Counsel – Capital Markets
and Corporate Reporting