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CONTINGENCIES
6 Months Ended
Jun. 30, 2015
Commitments and Contingencies Disclosure [Abstract]  
CONTINGENCIES
 CONTINGENCIES

The following information supplements and amends, as applicable, the disclosures in Note 28 to the Consolidated Financial Statements of Citigroup's 2014 Annual Report on Form 10-K and Note 25 to the Consolidated Financial Statements of Citigroup’s First Quarter of 2015 Form 10-Q. For purposes of this Note, Citigroup, its affiliates and subsidiaries, and current and former officers, directors and employees, are sometimes collectively referred to as Citigroup and Related Parties.
In accordance with ASC 450, Citigroup establishes accruals for contingencies, including the litigation and regulatory matters disclosed herein, when Citigroup believes it is probable that a loss has been incurred and the amount of the loss can be reasonably estimated. Once established, accruals are adjusted from time to time, as appropriate, in light of additional information. The amount of loss ultimately incurred in relation to those matters may be substantially higher or lower than the amounts accrued for those matters.
If Citigroup has not accrued for a matter because the matter does not meet the criteria for accrual (as set forth above), or Citigroup believes an exposure to loss exists in excess of the amount accrued for a particular matter, in each case assuming a material loss is reasonably possible, Citigroup discloses the matter. In addition, for such matters, Citigroup discloses an estimate of the aggregate reasonably possible loss or range of loss in excess of the amounts accrued for those matters as to which an estimate can be made. At June 30, 2015, Citigroup's estimate was materially unchanged from its estimate of approximately $4 billion at December 31, 2014, as more fully described in Note 28 to the Consolidated Financial Statements in the 2014 Annual Report on Form 10-K.
As available information changes, the matters for which Citigroup is able to estimate will change, and the estimates themselves will change. In addition, while many estimates presented in financial statements and other financial disclosure involve significant judgment and may be subject to significant uncertainty, estimates of the range of reasonably possible loss arising from litigation and regulatory proceedings are subject to particular uncertainties. For example, at the time of making an estimate, Citigroup may have only preliminary, incomplete or inaccurate information about the facts underlying the claim; its assumptions about the future rulings of the court or other tribunal on significant issues, or the behavior and incentives of adverse parties or regulators, may prove to be wrong; and the outcomes it is attempting to predict are often not amenable to the use of statistical or other quantitative analytical tools. In addition, from time to time an outcome may occur that Citigroup had not accounted for in its estimates because it had deemed such an outcome to be remote. For all these reasons, the amount of loss in excess of accruals ultimately incurred for the matters as to which an estimate has been made could be substantially higher or lower than the range of loss included in the estimate.
Subject to the foregoing, it is the opinion of Citigroup's management, based on current knowledge and after taking into account its current legal accruals, that the eventual outcome of all matters described in this Note would not be likely to have a material adverse effect on the consolidated financial condition of Citigroup. Nonetheless, given the substantial or indeterminate amounts sought in certain of these matters, and the inherent unpredictability of such matters, an adverse outcome in certain of these matters could, from time to time, have a material adverse effect on Citigroup’s consolidated results of operations or cash flows in particular quarterly or annual periods.
For further information on ASC 450 and Citigroup's accounting and disclosure framework for contingencies, including for litigation and regulatory matters disclosed herein, see Note 28 to the Consolidated Financial Statements of Citigroup’s 2014 Annual Report on Form 10-K.

Commodities Financing Contracts
The High Court in London issued a judgment on May 22, 2015 holding that Citigroup had properly served bring forward event notices, but that because the metal has not been properly delivered, the counterparty did not yet have to pay Citigroup.

Credit Crisis-Related Litigation and Other Matters
Mortgage-Related Litigation and Other Matters
Mortgage-Backed Securities and CDO Investor Actions: On June 17, 2015, the court dismissed with prejudice certain fraud claims in COMMERZBANK AG LONDON BRANCH v. UBS AG, ET AL.  The court also ordered the remaining fraud claims, which concern LIBOR, be withdrawn without prejudice.  Additional information concerning this action is publicly available in court filings under the docket number 654464/2013 (N.Y. Sup. Ct.) (Friedman, J.).
As of June 30, 2015, the aggregate original purchase amount of the purchases at issue in the pending MBS and CDO investor suits is approximately $1.95 billion, and the aggregate original purchase amount of the purchases covered by tolling agreements with MBS and CDO investors threatening litigation is approximately $1.4 billion.

Alternative Investment Fund-Related Litigation and Other Matters
On June 25, 2015, the parties in BEACH v. CITIGROUP ALTERNATIVE INVESTMENTS LLC executed a memorandum of understanding outlining the terms of a tentative class action settlement. On June 29, 2015, the court ordered that the case be stayed pending the filing of final settlement papers. Additional information concerning this action is publicly available in court filings under the docket number 12-cv-7717 (S.D.N.Y.) (Castel, J.).
Foreign Exchange Matters
Regulatory Actions: On May 20, 2015, Citigroup announced settlements with the U.S. Department of Justice (DOJ) and the Board of Governors of the Federal Reserve System (FRB) to resolve their respective investigations into Citigroup’s foreign exchange business. Pursuant to the terms of the settlement with the DOJ, Citicorp pleaded guilty to a violation of the Sherman Act, will pay a fine of $925 million and be subject to a three-year probation period, the conditions of which include the continued implementation, remediation and strengthening of its controls relating to its foreign exchange business. Additional information concerning this action is publicly available in court filings under the docket number 3:15-cr-78 (D. Conn.). Pursuant to the terms of the settlement with the FRB, Citigroup paid a civil penalty of $342 million and agreed to further enhance the control framework governing its foreign exchange business.

Antitrust and Other Litigation: On May 20, 2015, Citigroup announced that it has reached an agreement in principle to settle the consolidated class action in IN RE FOREIGN EXCHANGE BENCHMARK RATES ANTITRUST LITIGATION for a payment of $394 million, subject to court approval. As contemplated by the agreement, on July 17, 2015, the plaintiffs filed a second consolidated amended complaint, asserting claims under the Sherman Act and the Commodity Exchange Act based on allegations that defendants colluded to manipulate various foreign exchange benchmarks and engaged in other collusive conduct in connection with the trading of currencies. Additional information concerning this action is publicly available in court filings under the docket number 1:13-cv-7789 (S.D.N.Y) (Schofield, J.).
On May 21, 2015, an action captioned NYPL v. JPMORGAN CHASE & CO., ET. AL was brought in the United States District Court for the Northern District of California against Citigroup, as well as numerous other foreign exchange dealers. An amended complaint was filed on June 11, 2015. The plaintiff seeks to represent a putative class of “consumers and businesses in the United States who directly purchased supracompetitive foreign currency exchange rates” from defendants for their end use. The plaintiff alleges violations of the Sherman Act, and seeks injunctive relief and treble damages. Additional information concerning this action is publicly available in court filings under the docket number 3:15-cv-02290 (N.D. Cal.) (Chhabria, J).
In June 2015, actions captioned BAKIZADA v. BANK OF AMERICA CORPORATION, ET AL., TEEL v. BANK OF AMERICA CORPORATION, ET AL., and ROBERT CHARLES CLASS A, L.P. v. BANK OF AMERICA CORPORATION, ET AL. were brought in the United States District Court for the Southern District of New York against Citigroup and Related Parties, as well as numerous other foreign exchange dealers. The respective plaintiffs each seek to represent a putative class of investors who held foreign exchange futures or options on foreign exchange futures, and whose daily cash flows were calculated based on any key foreign exchange benchmark rates or who transacted at or around the time of the setting of key foreign exchange benchmark rates. The respective plaintiffs each allege violations of the Commodity Exchange Act, the Sherman Act, and/or the Clayton Act, and seek compensatory damages, treble damages where authorized by statute, injunctive relief, and/or disgorgement. Additional information concerning these actions is publicly available in court filings under the following docket numbers: 1:15-cv-4230 (S.D.N.Y.) (Schofield, J.); 1:15-cv-4436 (S.D.N.Y.) (Schofield, J.); and 1:15-cv-4926 (S.D.N.Y.) (Schofield, J.).
On June 3, 2015, an action captioned ALLEN v. BANK OF AMERICA CORPORATION, ET AL. was brought in the United States District Court for the Southern District of New York against Citigroup, as well as numerous other foreign exchange dealers. The plaintiff seeks to represent a putative class of participants, beneficiaries, and named fiduciaries of qualified Employee Retirement Income Security Act (ERISA) plans for whom a defendant provided foreign exchange transactional services or authorized or permitted foreign exchange transactional services involving a plan’s assets in connection with its exercise of authority or control regarding an ERISA plan. The plaintiff alleges violations of ERISA, and seeks compensatory damages, restitution, disgorgement, and declaratory relief. Additional information concerning this action is publicly available in court filings under the docket number 1:15-cv-4285 (S.D.N.Y.) (Schofield, J.).

Interbank Offered Rates-Related Litigation and Other Matters
Antitrust and Other Litigation: Following the January 21, 2015 United States Supreme Court’s remand of the action captioned GELBOIM, ET Al. v. BANK OF AMERICA CORP., ET AL. to the United States Court of Appeals for the Second Circuit for consideration on the merits of the plaintiffs’ appeal of the dismissal of their antitrust claims, plaintiff-appellants submitted their opening brief on May 20, 2015, and defendants-appellees submitted their response brief on July 17, 2015. Additional information concerning this appeal is publicly available in court filings under the docket number 13-3565 (2d Cir.).
Following the March 31, 2015 dismissal of the action captioned 7 WEST 57th STREET REALTY CO. v. CITIGROUP, INC., ET AL., the plaintiff moved for leave to file a second amended complaint on June 1, 2015. Additional information concerning this action is publicly available in court filings under the docket number 1:13-cv-981 (Gardephe, J.).
On July 24, 2015, a putative class action captioned SONTERRA CAPITAL MASTER FUND, LTD. v. UBS AG was brought in the United States District Court for the Southern District of New York against Citigroup and Related Parties, as well as other bank defendants, alleging manipulation of Yen LIBOR, Euroyen TIBOR, and the prices of Euroyen-based derivatives. The plaintiff asserts claims under the Sherman Act, the Commodity Exchange Act, and the Racketeer Influenced and Corrupt Organizations Act and for unjust enrichment, and seeks compensatory damages, treble damages where authorized by statute, injunctive relief, and/or disgorgement. Additional information concerning this action is publicly available in court filings under the docket number 1:15-cv-05844 (S.D.N.Y.).

Interchange Fees Litigation
On July 28, 2015, various objectors to the class settlement filed motions in the U.S. District Court to vacate the court’s prior approval of the class settlement, alleging improprieties by two of the lawyers involved in the Interchange MDL.  Additional information concerning this matter, including the district court proceedings and appeals related to the class settlement, is publicly available in court filings under the docket numbers 05-md-1720 (E.D.N.Y.) (Brodie, J.) and 12-4671 (2d Cir.).

Money Laundering Inquiries
As previously disclosed, on July 22, 2015, Banamex USA (BUSA) entered into a joint consent order with the Federal Deposit Insurance Corporation (FDIC) and the Commissioner of the California Department of Business Oversight (DBO).  The FDIC and DBO asserted, among other issues, that BUSA committed violations of the Bank Secrecy Act and failed to comply with an August 2, 2012 consent order issued by the FDIC.  Without admitting or denying those allegations, BUSA paid a civil monetary penalty totaling $140 million to the FDIC and the DBO. 

Regulatory Review of Consumer “Add-On” Products
On July 21, 2015, Citigroup announced it had reached an agreement with the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau (CFPB) to resolve previously disclosed regulatory reviews of billing and marketing practices related to such add-on products, including those administered by third-party vendors, as well as fees for expedited phone payments on certain products. As part of the agreement, Citigroup paid fines totaling $70 million to the OCC and CFPB and will refund $700 million to customers affected by the issues cited in the consent order. Citigroup previously discontinued marketing the products cited in the consent order and no longer charges expedited pay by phone fees. Customer remediation has been underway since 2013.

Regulatory Review of Student Loan Servicing
Citibank, N.A. is currently subject to regulatory investigation concerning certain student loan servicing practices. Citibank, N.A. is cooperating with the investigation. Similar servicing practices have been the subject of an enforcement action against at least one other institution. In light of that action and the current regulatory focus on student loans, regulators may order that Citibank, N.A. remediate customers and/or impose penalties or other relief.

Parmalat Litigation and Related Matters
On June 16, 2015, the Parmalat administrator refiled the claim in an Italian civil court, claiming damages of 1.8 billion Euro against Citigroup and Related Parties and other financial institutions.

Allied Irish Bank Litigation
On June 30, 2015, the court largely denied Citibank N.A.’s motion for summary judgment.  Additional information concerning this matter is publicly available in court filings under the docket number 03 Civ. 3748 (S.D.N.Y.) (Batts, J.). 

Settlement Payments
Payments required in settlement agreements described above have been made or are covered by existing litigation accruals.



[End of Consolidated Financial Statements and Notes to Consolidated Financial Statements]