Citizens, in the normal course of business, engages in a variety of activities with entities that are considered VIEs, as defined by GAAP, with its variable interest arising from contractual, ownership or other monetary interests in the entity. A VIE typically does not have sufficient equity at risk to finance its activities without additional subordinated financial support from other parties.

For more details regarding the Company’s involvement with VIEs see Note 11 in the Company’s 2023 Form 10-K.

The Company has consolidated VIEs related to secured borrowings collateralized by auto loans. The following table summarizes the carrying amount of assets and liabilities for the Company’s consolidated VIEs:


(dollars in millions)	March 31, 2024	December 31, 2023
Assets:
Cash and due from banks	$—	$13
Interest-bearing deposits in banks	169	106
Net loans and leases	4,039	3,194

Other assets	17	14
Total assets	$4,225	$3,327
Liabilities:
Long-term borrowed funds	$3,530	$2,692
Other liabilities	9	8
Total liabilities	$3,539	$2,700

Citizens utilizes a portion of its auto loan portfolio to support certain secured borrowing arrangements, which provide a source of funding for the Company and involves the transfer of auto loans to bankruptcy remote special purpose entities (“SPEs”). These SPEs then issue asset-backed notes to third-parties collateralized by the transferred loans.

The assets of a particular VIE are the primary source of funds to settle its obligations. Creditors of these VIEs do not have recourse to the general credit of the Company. The performance of the loans transferred to the SPEs is the most significant driver impacting the economic performance of the VIEs.

Citizens is involved with various VIEs that are not consolidated including lending to special purpose entities, investments in asset-backed securities and investments in entities that sponsor affordable housing, renewable energy and economic development projects. Citizens’ maximum exposure to loss resulting from its involvement with these entities is limited to the balance sheet carrying amount of its investments, unfunded commitments, and the outstanding principal balance of loans to special purpose entities.


(dollars in millions)	March 31, 2024	December 31, 2023
Lending to special purpose entities included in loans and leases	$4,737	$4,760
LIHTC investments included in other assets	2,472	2,444
LIHTC unfunded commitments included in other liabilities	1,046	1,025
Asset-backed investments included in HTM securities	467	488
Renewable energy investments included in other assets	298	314
NMTC investments included in other assets	3	3

Citizens provides lending facilities to third-party sponsored special purpose entities. As of March 31, 2024 and December 31, 2023, the lending facilities had undrawn commitments to extend credit of $2.7 billion. For more information on commitments to extend credit see Note 11.

The Company’s investments in asset-backed securities are collateralized by education loans sold to a third-party sponsored VIE. Citizens acts as the primary servicer for the sold loans and receives a servicing fee. A third-party servicer is responsible for all loans that become significantly delinquent.

The purpose of the Company’s LIHTC investments is to assist in achieving the goals of the Community Reinvestment Act and to earn an adequate return of capital.

The Company’s investments in certain renewable energy entities provide benefits from government incentives and other tax attributes (e.g., tax depreciation).

Contingent commitments related to the Company’s renewable energy investments were $63 million at March 31, 2024, and are expected to be paid in varying amounts through 2026. These payments are contingent upon the level of electricity production attained by the renewable energy entity relative to its targeted threshold and changes in the production tax credit rates set by the Internal Revenue Service.

The Company participates in the NMTC program which provides a tax incentive for private sector investment into economic development projects and businesses located in low-income communities.

The following table summarizes the impact to the Consolidated Statements of Operations relative to the Company’s tax credit programs for which it has elected to apply the proportional amortization method of accounting:


	Three Months Ended March 31,
(dollars in millions)	2024	2023
Tax credits recognized	$97	$87
Other tax benefits recognized	23	18
Amortization	(99)	(81)
Net benefit (expense) included in income tax expense	21	24
Other income	1	1
Allocated income (loss) on investments	(3)	(3)
Net benefit (expense) included in noninterest income	(2)	(2)
Net benefit (expense) included in the Consolidated Statements of Operations(1)	$19	$22

(1) Includes the impact of tax credit investments when the election to apply the proportional amortization method was in effect during the periods presented. For 2024 and 2023, this includes LIHTC, renewable energy and NMTC investments.

The Company did not recognize impairment losses resulting from the forfeiture or ineligibility of income tax credits or other circumstances during the three months ended March 31, 2024 and 2023.