INVESTMENTS (Tables)

6 Months Ended

Jun. 30, 2017

Investments, Debt and Equity Securities [Abstract]

The following table presents Citi’s investments by category:



In millions of dollars	June 30, 2017		December 31, 2016
In millions of dollars	June 30, 2017		December 31, 2016
Securities available-for-sale (AFS)	$	293,629	$	299,424
Debt securities held-to-maturity (HTM)⁽¹⁾	50,175		45,667
Non-marketable equity securities carried at fair value⁽²⁾	1,384		1,774
Non-marketable equity securities carried at cost⁽³⁾	6,522		6,439
Total investments	$	351,710	$	353,304


(1)	Carried at adjusted amortized cost basis, net of any credit-related impairment.


(2)	Unrealized gains and losses for non-marketable equity securities carried at fair value are recognized in earnings.


(3)	Primarily consists of shares issued by the Federal Reserve Bank, Federal Home Loan Banks and various clearing houses of which Citigroup is a member.

Interest and dividends on investments

The following table presents interest and dividend income on investments:



	Three Months Ended June 30,				Six Months Ended June 30,
In millions of dollars	2017		2016		2017		2016
Taxable interest	$	1,859	$	1,759	$	3,623	$	3,436
Interest exempt from U.S. federal income tax	141		133		283		276
Dividend income	58		45		112		80
Total interest and dividend income	$	2,058	$	1,937	$	4,018	$	3,792

Realized gains and losses on investments excluding other-than-temporary impairment

The following table presents realized gains and losses on the sales of investments, which excludes OTTI losses:



	Three Months Ended June 30,						Six Months Ended June 30,
In millions of dollars	2017			2016			2017			2016
Gross realized investment gains	$	258		$	244		$	546		$	623
Gross realized investment losses	(37		)	(44		)	(133		)	(237		)
Net realized gains on sale of investments	$	221		$	200		$	413		$	386

Amortized cost and fair value of AFS

The amortized cost and fair value of AFS securities were as follows:



	June 30, 2017								December 31, 2016
In millions of dollars	Amortized cost		Gross unrealized gains		Gross unrealized losses		Fair value		Amortized cost		Gross unrealized gains		Gross unrealized losses		Fair value
Securities AFS
Mortgage-backed securities⁽¹⁾
U.S. government-sponsored agency guaranteed	$	43,351	$	246	$	399	$	43,198	$	38,663	$	248	$	506	$	38,405
Prime	1		—		—		1		2		—		—		2
Alt-A	—		—		—		—		43		7		—		50
Non-U.S. residential	3,154		14		5		3,163		3,852		13		7		3,858
Commercial	357		1		1		357		357		2		1		358
Total mortgage-backed securities	$	46,863	$	261	$	405	$	46,719	$	42,917	$	270	$	514	$	42,673
U.S. Treasury and federal agency securities
U.S. Treasury	$	102,340	$	414	$	359	$	102,395	$	113,606	$	629	$	452	$	113,783
Agency obligations	10,240		24		61		10,203		9,952		21		85		9,888
Total U.S. Treasury and federal agency securities	$	112,580	$	438	$	420	$	112,598	$	123,558	$	650	$	537	$	123,671
State and municipal⁽²⁾	$	9,700	$	142	$	303	$	9,539	$	10,797	$	80	$	757	$	10,120
Foreign government	101,669		514		401		101,782		98,112		590		554		98,148
Corporate	16,111		93		101		16,103		17,195		105		176		17,124
Asset-backed securities⁽¹⁾	6,020		10		6		6,024		6,810		6		22		6,794
Other debt securities	431		—		—		431		503		—		—		503
Total debt securities AFS	$	293,374	$	1,458	$	1,636	$	293,196	$	299,892	$	1,701	$	2,560	$	299,033
Marketable equity securities AFS	$	414	$	25	$	6	$	433	$	377	$	20	$	6	$	391
Total securities AFS	$	293,788	$	1,483	$	1,642	$	293,629	$	300,269	$	1,721	$	2,566	$	299,424

(1)

The Company invests in mortgage-backed and asset-backed securities. These securitizations are generally considered VIEs. The Company’s maximum exposure to loss from these VIEs is equal to the carrying amount of the securities, which is reflected in the table above. For mortgage-backed and asset-backed securitizations in which the Company has other involvement, see Note 18 to the Consolidated Financial Statements.

(2)

In the second quarter of 2017, Citi early adopted ASU 2017-08, Receivables-Nonrefundable Fees and Other Costs (Subtopic 310-20): Premium Amortization on Purchased Callable Debt Securities. Upon adoption, a cumulative effect adjustment was recorded to reduce retained earnings, effective January 1, 2017, for the incremental amortization of purchase premiums and cumulative fair value hedge adjustments on callable state and municipal debt securities. For additional information, see Note 1 to the Consolidated Financial Statements.

Fair value of securities in unrealized loss position

The table below shows the fair value of debt securities HTM that have been in an unrecognized loss position:



	Less than 12 months				12 months or longer				Total
In millions of dollars	Fair value		Gross unrecognized losses		Fair value		Gross unrecognized losses		Fair value		Gross unrecognized losses
June 30, 2017
Debt securities held-to-maturity
Mortgage-backed securities	$	35	$	1	$	11,533	$	113	$	11,568	$	114
State and municipal	629		43		735		89		1,364		132
Foreign government	572		16		—		—		572		16
Asset-backed securities	54		1		2,810		4		2,864		5
Total debt securities held-to-maturity	$	1,290	$	61	$	15,078	$	206	$	16,368	$	267
December 31, 2016
Debt securities held-to-maturity
Mortgage-backed securities	$	17	$	—	$	17,176	$	188	$	17,193	$	188
State and municipal	2,200		58		1,210		180		3,410		238
Foreign government	1,313		26		—		—		1,313		26
Asset-backed securities	2		—		2,503		5		2,505		5
Total debt securities held-to-maturity	$	3,532	$	84	$	20,889	$	373	$	24,421	$	457

Note: Excluded from the gross unrecognized losses presented in the table above are $(76) million and $(496) million of net unrealized losses recorded in AOCI as of June 30, 2017 and December 31, 2016, respectively, primarily related to the difference between the amortized cost and carrying value of HTM securities that were reclassified from AFS. Substantially all of these net unrecognized losses relate to securities that have been in a loss position for 12 months or longer at June 30, 2017 and December 31, 2016.

The following shows the fair value of AFS securities that have been in an unrealized loss position:



	Less than 12 months				12 months or longer				Total
In millions of dollars	Fair value		Gross unrealized losses		Fair value		Gross unrealized losses		Fair value		Gross unrealized losses
June 30, 2017
Securities AFS
Mortgage-backed securities
U.S. government-sponsored agency guaranteed	$	26,236	$	332	$	2,253	$	67	$	28,489	$	399
Non-U.S. residential	1,243		4		36		1		1,279		5
Commercial	84		1		37		—		121		1
Total mortgage-backed securities	$	27,563	$	337	$	2,326	$	68	$	29,889	$	405
U.S. Treasury and federal agency securities
U.S. Treasury	$	37,721	$	250	$	4,592	$	109	$	42,313	$	359
Agency obligations	6,345		60		106		1		6,451		61
Total U.S. Treasury and federal agency securities	$	44,066	$	310	$	4,698	$	110	$	48,764	$	420
State and municipal	$	506	$	17	$	1,735	$	286	$	2,241	$	303
Foreign government	37,764		172		11,189		229		48,953		401
Corporate	5,965		87		553		14		6,518		101
Asset-backed securities	1,045		1		938		5		1,983		6
Other debt securities	29		—		—		—		29		—
Marketable equity securities AFS	16		2		54		4		70		6
Total securities AFS	$	116,954	$	926	$	21,493	$	716	$	138,447	$	1,642
December 31, 2016
Securities AFS
Mortgage-backed securities
U.S. government-sponsored agency guaranteed	$	23,534	$	436	$	2,236	$	70	$	25,770	$	506
Prime	1		—		—		—		1		—
Non-U.S. residential	486		—		1,276		7		1,762		7
Commercial	75		1		58		—		133		1
Total mortgage-backed securities	$	24,096	$	437	$	3,570	$	77	$	27,666	$	514
U.S. Treasury and federal agency securities
U.S. Treasury	$	44,342	$	445	$	1,335	$	7	$	45,677	$	452
Agency obligations	6,552		83		250		2		6,802		85
Total U.S. Treasury and federal agency securities	$	50,894	$	528	$	1,585	$	9	$	52,479	$	537
State and municipal	$	1,616	$	55	$	3,116	$	702	$	4,732	$	757
Foreign government	38,226		243		8,973		311		47,199		554
Corporate	7,011		129		1,877		47		8,888		176
Asset-backed securities	411		—		3,213		22		3,624		22
Other debt securities	5		—		—		—		5		—
Marketable equity securities AFS	19		2		24		4		43		6
Total securities AFS	$	122,278	$	1,394	$	22,358	$	1,172	$	144,636	$	2,566

Amortized cost and fair value of debt securities by contractual maturity dates

The following table presents the carrying value and fair value of HTM debt securities by contractual maturity dates:



	June 30, 2017				December 31, 2016
In millions of dollars	Carrying value		Fair value		Carrying value		Fair value
Mortgage-backed securities
Due within 1 year	$	—	$	—	$	—	$	—
After 1 but within 5 years	735		743		760		766
After 5 but within 10 years	51		52		54		55
After 10 years⁽¹⁾	25,556		25,671		23,830		23,810
Total	$	26,342	$	26,466	$	24,644	$	24,631
State and municipal
Due within 1 year	$	463	$	472	$	406	$	406
After 1 but within 5 years	145		152		112		110
After 5 but within 10 years	372		385		363		367
After 10 years⁽¹⁾	7,819		7,968		7,702		7,591
Total	$	8,799	$	8,977	$	8,583	$	8,474
Foreign government
Due within 1 year	$	138	$	138	$	824	$	818
After 1 but within 5 years	450		434		515		495
After 5 but within 10 years	—		—		—		—
After 10 years⁽¹⁾	—		—		—		—
Total	$	588	$	572	$	1,339	$	1,313
All other⁽²⁾
Due within 1 year	$	—	$	—	$	—	$	—
After 1 but within 5 years	—		—		—		—
After 5 but within 10 years	468		469		513		514
After 10 years⁽¹⁾	13,978		14,039		10,588		10,623
Total	$	14,446	$	14,508	$	11,101	$	11,137
Total debt securities held-to-maturity	$	50,175	$	50,523	$	45,667	$	45,555


(1)	Investments with no stated maturities are included as contractual maturities of greater than 10 years. Actual maturities may differ due to call or prepayment rights.


(2)	Includes corporate and asset-backed securities.

The following table presents the amortized cost and fair value of AFS debt securities by contractual maturity dates:



	June 30, 2017				December 31, 2016
In millions of dollars	Amortized cost		Fair value		Amortized cost		Fair value
Mortgage-backed securities⁽¹⁾
Due within 1 year	$	96	$	96	$	132	$	132
After 1 but within 5 years	812		814		736		738
After 5 but within 10 years	1,733		1,730		2,279		2,265
After 10 years⁽²⁾	44,222		44,079		39,770		39,538
Total	$	46,863	$	46,719	$	42,917	$	42,673
U.S. Treasury and federal agency securities
Due within 1 year	$	3,183	$	3,165	$	4,945	$	4,945
After 1 but within 5 years	103,151		103,156		101,369		101,323
After 5 but within 10 years	6,211		6,240		17,153		17,314
After 10 years⁽²⁾	35		37		91		89
Total	$	112,580	$	112,598	$	123,558	$	123,671
State and municipal
Due within 1 year	$	2,217	$	2,217	$	2,093	$	2,092
After 1 but within 5 years	2,393		2,396		2,668		2,662
After 5 but within 10 years	464		478		335		334
After 10 years⁽²⁾	4,626		4,448		5,701		5,032
Total	$	9,700	$	9,539	$	10,797	$	10,120
Foreign government
Due within 1 year	$	31,792	$	31,800	$	32,540	$	32,547
After 1 but within 5 years	54,028		53,507		51,008		50,881
After 5 but within 10 years	13,457		13,944		12,388		12,440
After 10 years⁽²⁾	2,392		2,531		2,176		2,280
Total	$	101,669	$	101,782	$	98,112	$	98,148
All other⁽³⁾
Due within 1 year	$	3,794	$	3,688	$	2,629	$	2,628
After 1 but within 5 years	10,380		10,396		12,339		12,334
After 5 but within 10 years	5,760		5,865		6,566		6,528
After 10 years⁽²⁾	2,628		2,609		2,974		2,931
Total	$	22,562	$	22,558	$	24,508	$	24,421
Total debt securities AFS	$	293,374	$	293,196	$	299,892	$	299,033


(1)	Includes mortgage-backed securities of U.S. government-sponsored agencies.


(2)	Investments with no stated maturities are included as contractual maturities of greater than 10 years. Actual maturities may differ due to call or prepayment rights.


(3)	Includes corporate, asset-backed and other debt securities.

Carrying value and fair value of debt securities HTM

The carrying value and fair value of debt securities HTM were as follows:



In millions of dollars	Amortized cost basis⁽¹⁾		Net unrealized gains (losses) recognized in AOCI			Carrying value⁽²⁾		Gross unrealized gains		Gross unrealized (losses)			Fair value
June 30, 2017
Debt securities held-to-maturity
Mortgage-backed securities⁽³⁾
U.S. government agency guaranteed	$	24,044	$	25		$	24,069	$	77	$	(113	)	$	24,033
Prime	15		—			15		3		—			18
Alt-A	279		(18		)	261		94		(1		)	354
Non-U.S. residential	1,940		(47		)	1,893		64		—			1,957
Commercial	104		—			104		—		—			104
Total mortgage-backed securities	$	26,382	$	(40	)	$	26,342	$	238	$	(114	)	$	26,466
State and municipal⁽⁴⁾	$	8,830	$	(31	)	$	8,799	$	310	$	(132	)	$	8,977
Foreign government	588		—			588		—		(16		)	572
Asset-backed securities⁽³⁾	14,451		(5		)	14,446		67		(5		)	14,508
Total debt securities held-to-maturity	$	50,251	$	(76	)	$	50,175	$	615	$	(267	)	$	50,523
December 31, 2016
Debt securities held-to-maturity
Mortgage-backed securities⁽³⁾
U.S. government agency guaranteed	$	22,462	$	33		$	22,495	$	47	$	(186	)	$	22,356
Prime	31		(7		)	24		10		(1		)	33
Alt-A	314		(27		)	287		69		(1		)	355
Non-U.S. residential	1,871		(47		)	1,824		49		—			1,873
Commercial	14		—			14		—		—			14
Total mortgage-backed securities	$	24,692	$	(48	)	$	24,644	$	175	$	(188	)	$	24,631
State and municipal	$	9,025	$	(442	)	$	8,583	$	129	$	(238	)	$	8,474
Foreign government	1,339		—			1,339		—		(26		)	1,313
Asset-backed securities⁽³⁾	11,107		(6		)	11,101		41		(5		)	11,137
Total debt securities held-to-maturity⁽⁵⁾	$	46,163	$	(496	)	$	45,667	$	345	$	(457	)	$	45,555

(1)

For securities transferred to HTM from Trading account assets, amortized cost basis is defined as the fair value of the securities at the date of transfer plus any accretion income and less any impairments recognized in earnings subsequent to transfer. For securities transferred to HTM from AFS, amortized cost is defined as the original purchase cost, adjusted for the cumulative accretion or amortization of any purchase discount or premium, plus or minus any cumulative fair value hedge adjustments, net of accretion or amortization, and less any other-than-temporary impairment recognized in earnings.

(2)

HTM securities are carried on the Consolidated Balance Sheet at amortized cost basis, plus or minus any unamortized unrealized gains and losses and fair value hedge adjustments recognized in AOCI prior to reclassifying the securities from AFS to HTM. Changes in the values of these securities are not reported in the financial statements, except for the amortization of any difference between the carrying value at the transfer date and par value of the securities, and the recognition of any non-credit fair value adjustments in AOCI in connection with the recognition of any credit impairment in earnings related to securities the Company continues to intend to hold until maturity.

(3)

(4)

(5)

During the fourth quarter of 2016, securities with a total fair value of approximately $5.8 billion were transferred from AFS to HTM, composed of $5 billion of U.S. government agency mortgage-backed securities and $830 million of municipal securities. The transfer reflects the Company’s intent to hold these securities to maturity or to issuer call, in part, in order to reduce the impact of price volatility on AOCI and certain capital measures under Basel III. While these securities were transferred to HTM at fair value as of the transfer date, no subsequent changes in value may be recorded, other than in connection with the recognition of any subsequent other-than-temporary impairment and the amortization of differences between the carrying values at the transfer date and the par values of each security as an adjustment of yield over the remaining contractual life of each security. Any net unrealized holding losses within AOCI related to the respective securities at the date of transfer, inclusive of any cumulative fair value hedge adjustments, will be amortized over the remaining contractual life of each security as an adjustment of yield in a manner consistent with the amortization of any premium or discount.

Total other-than-temporary impairments recognized

The following tables present total OTTI recognized in earnings:



OTTI on Investments and Other assets	Three Months Ended June 30, 2017								Six Months Ended June 30, 2017
In millions of dollars	AFS⁽¹⁾		HTM		Other assets		Total		AFS⁽¹⁾⁽²⁾		HTM		Other Assets		Total
Impairment losses related to securities that the Company does not intend to sell nor will likely be required to sell:
Total OTTI losses recognized during the period	$	—	$	—	$	—	$	—	$	—	$	—	$	—	$	—
Less: portion of impairment loss recognized in AOCI (before taxes)	—		—		—		—		—		—		—		—
Net impairment losses recognized in earnings for securities that the Company does not intend to sell nor will likely be required to sell	$	—	$	—	$	—	$	—	$	—	$	—	$	—	$	—
Impairment losses recognized in earnings for securities that the Company intends to sell, would be more likely than not required to sell or will be subject to an issuer call deemed probable of exercise	20		—		—		20		31		1		—		32
Total impairment losses recognized in earnings	$	20	$	—	$	—	$	20	$	31	$	1	$	—	$	32


(1)	Includes OTTI on non-marketable equity securities.



OTTI on Investments and Other assets	Three months ended June 30, 2016								Six Months Ended June 30, 2016
In millions of dollars	AFS⁽¹⁾		HTM		Other assets		Total		AFS⁽¹⁾⁽²⁾		HTM		Other assets⁽³⁾		Total
Impairment losses related to securities that the Company does not intend to sell nor will likely be required to sell:
Total OTTI losses recognized during the period	$	2	$	1	$	—	$	3	$	3	$	1	$	—	$	4
Less: portion of impairment loss recognized in AOCI (before taxes)	—		—		—		—		—		—		—		—
Net impairment losses recognized in earnings for securities that the Company does not intend to sell nor will likely be required to sell	$	2	$	1	$	—	$	3	$	3	$	1	$	—	$	4
Impairment losses recognized in earnings for securities that the Company intends to sell, would be more likely than not required to sell or will be subject to an issuer call deemed probable of exercise and FX losses	28		17		70		115		223		24		332		579
Total impairment losses recognized in earnings	$	30	$	18	$	70	$	118	$	226	$	25	$	332	$	583


(1)	Includes OTTI on non-marketable equity securities.


(2)	Includes a $160 million impairment related to AFS securities affected by changes in the Venezuela exchange rate during the six months ended June 30, 2016.


(3)	The impairment charge is related to the carrying value of an equity investment.

Cumulative other-than-temporary impairment credit losses recognized in earnings

The following are three-month rollforwards of the credit-related impairments recognized in earnings for AFS and HTM debt securities held that the Company does not intend to sell nor likely will be required to sell:



	Cumulative OTTI credit losses recognized in earnings on securities still held
In millions of dollars	Mar. 31, 2017 balance		Credit impairments recognized in earnings on securities not previously impaired		Credit impairments recognized in earnings on securities that have been previously impaired		Reductions due to credit-impaired securities sold, transferred or matured			June 30, 2017 balance
AFS debt securities
Mortgage-backed securities	$	—	$	—	$	—	$	—		$	—
State and municipal	4		—		—		—			4
Foreign government securities	—		—		—		—			—
Corporate	4		—		—		—			4
All other debt securities	22		—		—		(22		)	—
Total OTTI credit losses recognized for AFS debt securities	$	30	$	—	$	—	$	(22	)	$	8
HTM debt securities
Mortgage-backed securities⁽¹⁾	$	97	$	—	$	—	$	—		$	97
State and municipal	3		—		—		—			3
Total OTTI credit losses recognized for HTM debt securities	$	100	$	—	$	—	$	—		$	100


(1)	Primarily consists of Alt-A securities.



	Cumulative OTTI credit losses recognized in earnings on securities still held
In millions of dollars	Mar. 31, 2016 balance		Credit impairments recognized in earnings on securities not previously impaired		Credit impairments recognized in earnings on securities that have been previously impaired		Reductions due to credit-impaired securities sold, transferred or matured			June 30, 2016 balance
AFS debt securities
Mortgage-backed securities	$	—	$	1	$	—	$	(1	)	$	—
State and municipal	4		—		—		—			4
Foreign government securities	5		—		—		—			5
Corporate	7		—		2		(2		)	7
All other debt securities	43		—		—		—			43
Total OTTI credit losses recognized for AFS debt securities	$	59	$	1	$	2	$	(3	)	$	59
HTM debt securities
Mortgage-backed securities⁽¹⁾	$	132	$	—	$	—	$	(24	)	$	108
State and municipal	4		1		—		(1		)	4
Total OTTI credit losses recognized for HTM debt securities	$	136	$	1	$	—	$	(25	)	$	112


(1)	Primarily consists of Alt-A securities.

The following are six-month rollforwards of the credit-related impairments recognized in earnings for AFS and HTM debt securities held that the Company does not intend to sell nor likely will be required to sell:



	Cumulative OTTI credit losses recognized in earnings on securities still held
In millions of dollars	Dec. 31, 2016 balance		Credit impairments recognized in earnings on securities not previously impaired		Credit impairments recognized in earnings on securities that have been previously impaired		Reductions due to credit-impaired securities sold, transferred or matured			June 30, 2017 balance
AFS debt securities
Mortgage-backed securities	$	—	$	—	$	—	$	—		$	—
State and municipal	4		—		—		—			4
Foreign government securities	—		—		—		—			—
Corporate	5		—		—		(1		)	4
All other debt securities	22		—		—		(22		)	—
Total OTTI credit losses recognized for AFS debt securities	$	31	$	—	$	—	$	(23	)	$	8
HTM debt securities
Mortgage-backed securities⁽¹⁾	$	101	$	—	$	—	$	(4	)	$	97
State and municipal	3		—		—		—			3
Total OTTI credit losses recognized for HTM debt securities	$	104	$	—	$	—	$	(4	)	$	100


(1)	Primarily consists of Alt-A securities.



	Cumulative OTTI credit losses recognized in earnings on securities still held
In millions of dollars	Dec. 31, 2015 balance		Credit impairments recognized in earnings on securities not previously impaired		Credit impairments recognized in earnings on securities that have been previously impaired		Reductions due to credit-impaired securities sold, transferred or matured			Jun. 30, 2016 balance
AFS debt securities
Mortgage-backed securities	$	—	$	1	$	—	$	(1	)	$	—
State and municipal	12		—		—		(8		)	4
Foreign government securities	5		—		—		—			5
Corporate	9		1		—		(3		)	7
All other debt securities	47		—		—		(4		)	43
Total OTTI credit losses recognized for AFS debt securities	$	73	$	2	$	—	$	(16	)	$	59
HTM debt securities
Mortgage-backed securities⁽¹⁾	$	132	$	—	$	—	$	(24	)	$	108
State and municipal	4		1		—		(1		)	4
Total OTTI credit losses recognized for HTM debt securities	$	136	$	1	$	—	$	(25	)	$	112


(1)	Primarily consists of Alt-A securities.

Investments in Alternative Investment Funds



	Fair value				Unfunded commitments				Redemption frequency (if currently eligible) monthly, quarterly, annually	Redemption notice period
In millions of dollars	June 30, 2017		December 31, 2016		June 30, 2017		December 31, 2016
Hedge funds	$	1	$	4	$	—	$	—	Generally quarterly	10–95 days
Private equity funds⁽¹⁾⁽²⁾	374		348		82		82		—	—
Real estate funds ⁽²⁾⁽³⁾	41		56		21		20		—	—
Total	$	416	$	408	$	103	$	102	—	—


(1)	Private equity funds include funds that invest in infrastructure, emerging markets and venture capital.

(2)

With respect to the Company’s investments in private equity funds and real estate funds, distributions from each fund will be received as the underlying assets held by these funds are liquidated. It is estimated that the underlying assets of these funds will be liquidated over a period of several years as market conditions allow. Private equity and real estate funds do not allow redemption of investments by their investors. Investors are permitted to sell or transfer their investments, subject to the approval of the general partner or investment manager of these funds, which generally may not be unreasonably withheld.


(3)	Includes several real estate funds that invest primarily in commercial real estate in the U.S., Europe and Asia.