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INVESTMENTS
3 Months Ended
Mar. 31, 2019
Investments, Debt and Equity Securities [Abstract]  
INVESTMENTS  INVESTMENTS

For additional information regarding Citi’s investment portfolios, including evaluating investments for other-than-temporary impairment (OTTI), see Note 13 to the Consolidated Financial Statements in Citi’s 2018 Annual Report on Form 10-K.







The following table presents Citi’s investments by category:
 
In millions of dollars
March 31,
2019
December 31,
2018
 
 
Debt securities available-for-sale (AFS)
$
275,132

$
288,038

 
Debt securities held-to-maturity (HTM)(1)
66,842

63,357

 
Marketable equity securities carried at fair value(2)
208

220

 
Non-marketable equity securities carried at fair value(2)
804

889

 
Non-marketable equity securities measured using the measurement alternative(3)


630

538

 
Non-marketable equity securities carried at cost(4)
5,665

5,565

 
Total investments
$
349,281

$
358,607


(1)
Carried at adjusted amortized cost basis, net of any credit-related impairment.
(2)
Unrealized gains and losses are recognized in earnings.
(3)
Impairment losses and adjustments to the carrying value as a result of observable price changes are recognized in earnings.
(4)
Represents shares issued by the Federal Reserve Bank, Federal Home Loan Banks and certain exchanges of which Citigroup is a member.

The following table presents interest and dividend income on investments:
 
Three Months Ended March 31,
In millions of dollars
2019
2018
Taxable interest
$
2,372

$
2,042

Interest exempt from U.S. federal income tax
127

130

Dividend income
49

62

Total interest and dividend income
$
2,548

$
2,234



The following table presents realized gains and losses on the sales of investments, which exclude OTTI losses:
 
Three Months Ended March 31,
In millions of dollars
2019
2018
Gross realized investment gains
$
168

$
345

Gross realized investment losses
(38
)
(175
)
Net realized gains on sale of investments
$
130

$
170





Debt Securities Available-for-Sale
The amortized cost and fair value of AFS debt securities were as follows:
 
March 31, 2019
December 31, 2018
In millions of dollars
Amortized
cost
Gross
unrealized
gains
Gross
unrealized
losses
Fair
value
Amortized
cost
Gross
unrealized
gains
Gross
unrealized
losses
Fair
value
Debt securities AFS
 
 
 
 
 
 
 
 
Mortgage-backed securities(1)
 
 
 
 
 
 
 
 
U.S. government-sponsored agency guaranteed
$
39,228

$
539

$
434

$
39,333

$
43,504

$
241

$
725

$
43,020

Alt-A
1



1

1



1

Non-U.S. residential
1,117

4

1

1,120

1,310

4

2

1,312

Commercial
138

1

1

138

173

1

2

172

Total mortgage-backed securities
$
40,484

$
544

$
436

$
40,592

$
44,988

$
246

$
729

$
44,505

U.S. Treasury and federal agency securities
 
 
 
 
 
 
 
 
U.S. Treasury
$
100,267

$
25

$
1,003

$
99,289

$
109,376

$
33

$
1,339

$
108,070

Agency obligations
8,472

2

90

8,384

9,283

1

132

9,152

Total U.S. Treasury and federal agency securities
$
108,739

$
27

$
1,093

$
107,673

$
118,659

$
34

$
1,471

$
117,222

State and municipal
$
8,012

$
162

$
65

$
8,109

$
9,372

$
96

$
262

$
9,206

Foreign government
101,296

455

395

101,356

100,872

415

596

100,691

Corporate
12,366

59

115

12,310

11,714

42

157

11,599

Asset-backed securities(1)
1,421

1

2

1,420

845

2

4

843

Other debt securities
3,671

1


3,672

3,973


1

3,972

Total debt securities AFS
$
275,989

$
1,249

$
2,106

$
275,132

$
290,423

$
835

$
3,220

$
288,038

(1)
The Company invests in mortgage- 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- and asset-backed securitizations in which the Company has other involvement, see Note 18 to the Consolidated Financial Statements.

The following table shows the fair value of AFS debt 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
March 31, 2019
 
 
 
 
 
 
Debt securities AFS
 
 
 
 
 
 
Mortgage-backed securities
 
 
 
 
 
 
U.S. government agency guaranteed
$
9,176

$
268

$
8,102

$
166

$
17,278

$
434

Non-U.S. residential
387

1

1


388

1

Commercial
14


104

1

118

1

Total mortgage-backed securities
$
9,577

$
269

$
8,207

$
167

$
17,784

$
436

U.S. Treasury and federal agency securities
 
 
 
 
 
 
U.S. Treasury
$
8,496

$
48

$
80,174

$
955

$
88,670

$
1,003

Agency obligations
126

2

8,098

88

8,224

90

Total U.S. Treasury and federal agency securities
$
8,622

$
50

$
88,272

$
1,043

$
96,894

$
1,093

State and municipal
$
928

$
6

$
968

$
59

$
1,896

$
65

Foreign government
32,453

159

11,945

236

44,398

395

Corporate
3,252

96

2,127

19

5,379

115

Asset-backed securities
306

2

56


362

2

Other debt securities
816




816


Total debt securities AFS
$
55,954

$
582

$
111,575

$
1,524

$
167,529

$
2,106

December 31, 2018
 

 

 

 

 

 

Debt securities AFS
 

 

 

 

 

 

Mortgage-backed securities
 

 

 

 

 

 

U.S. government agency guaranteed
$
11,160

$
286

$
13,143

$
439

$
24,303

$
725

Non-U.S. residential
284

2

2


286

2

Commercial
79

1

82

1

161

2

Total mortgage-backed securities
$
11,523

$
289

$
13,227

$
440

$
24,750

$
729

U.S. Treasury and federal agency securities
 

 

 

 

 

 

U.S. Treasury
$
8,389

$
42

$
77,883

$
1,297

$
86,272

$
1,339

Agency obligations
277

2

8,660

130

8,937

132

Total U.S. Treasury and federal agency securities
$
8,666

$
44

$
86,543

$
1,427

$
95,209

$
1,471

State and municipal
$
1,614

$
34

$
1,303

$
228

$
2,917

$
262

Foreign government
40,655

265

15,053

331

55,708

596

Corporate
4,547

115

2,077

42

6,624

157

Asset-backed securities
441

4

55


496

4

Other debt securities
1,790

1



1,790

1

Total debt securities AFS
$
69,236

$
752

$
118,258

$
2,468

$
187,494

$
3,220




The following table presents the amortized cost and fair value of AFS debt securities by contractual maturity dates:
 
March 31, 2019
December 31, 2018
In millions of dollars
Amortized
cost
Fair
value
Amortized
cost
Fair
value
Mortgage-backed securities(1)
 
 
 
 
Due within 1 year
$
68

$
68

$
14

$
14

After 1 but within 5 years
706

707

662

661

After 5 but within 10 years
1,824

1,922

2,779

2,828

After 10 years(2)
37,886

37,895

41,533

41,002

Total
$
40,484

$
40,592

$
44,988

$
44,505

U.S. Treasury and federal agency securities
 
 
 
 
Due within 1 year
$
39,674

$
39,554

$
41,941

$
41,867

After 1 but within 5 years
68,442

67,520

76,139

74,800

After 5 but within 10 years
597

573

489

462

After 10 years(2)
26

26

90

93

Total
$
108,739

$
107,673

$
118,659

$
117,222

State and municipal
 
 
 
 
Due within 1 year
$
1,674

$
1,673

$
2,586

$
2,586

After 1 but within 5 years
1,542

1,546

1,676

1,675

After 5 but within 10 years
573

595

585

602

After 10 years(2)
4,223

4,295

4,525

4,343

Total
$
8,012

$
8,109

$
9,372

$
9,206

Foreign government
 
 
 
 
Due within 1 year
$
41,824

$
41,806

$
39,078

$
39,028

After 1 but within 5 years
46,950

46,936

50,125

49,962

After 5 but within 10 years
11,034

11,083

10,153

10,149

After 10 years(2)
1,488

1,531

1,516

1,552

Total
$
101,296

$
101,356

$
100,872

$
100,691

All other(3)
 
 
 
 
Due within 1 year
$
6,867

$
6,865

$
6,166

$
6,166

After 1 but within 5 years
8,199

8,188

8,459

8,416

After 5 but within 10 years
1,429

1,410

1,474

1,427

After 10 years(2)
963

939

433

405

Total
$
17,458

$
17,402

$
16,532

$
16,414

Total debt securities AFS
$
275,989

$
275,132

$
290,423

$
288,038

(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.

Debt Securities Held-to-Maturity

The carrying value and fair value of debt securities HTM were as follows:
In millions of dollars
Carrying
value
Gross
unrealized
gains
Gross
unrealized
losses
Fair
value
March 31, 2019
 
 
 
 
Debt securities held-to-maturity
 
 
 
 
Mortgage-backed securities(1)
 
 
 
 
U.S. government agency guaranteed(2)
$
38,286

$
392

$
296

$
38,382

Non-U.S. residential
1,313

13

1

1,325

Commercial
424

1

1

424

Total mortgage-backed securities
$
40,023

$
406

$
298

$
40,131

State and municipal
$
7,648

$
285

$
70

$
7,863

Foreign government
1,000


11

989

Asset-backed securities(1)
18,171

6

86

18,091

Total debt securities held-to-maturity
$
66,842

$
697

$
465

$
67,074

December 31, 2018
 

 

 

 

Debt securities held-to-maturity
 

 

 

 

Mortgage-backed securities(1)
 

 

 

 

U.S. government agency guaranteed
$
34,239

$
199

$
578

$
33,860

Non-U.S. residential
1,339

12

1

1,350

Commercial
368



368

Total mortgage-backed securities
$
35,946

$
211

$
579

$
35,578

State and municipal
$
7,628

$
167

$
138

$
7,657

Foreign government
1,027


24

1,003

Asset-backed securities(1)
18,756

8

112

18,652

Total debt securities held-to-maturity
$
63,357

$
386

$
853

$
62,890


(1)
The Company invests in mortgage- 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- and asset-backed securitizations in which the Company has other involvement, see Note 18 to the Consolidated Financial Statements.
(2)
In March 2019, Citibank transferred $5 billion of agency residential mortgage-backed securities (RMBS) from AFS classification to HTM classification in accordance with ASC 320. At the time of transfer, the securities were in an unrealized loss position of $56 million. The loss amounts will remain in AOCI and be amortized over the remaining life of the securities.

















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
March 31, 2019
 
 
 
 
 
 
Debt securities held-to-maturity
 
 
 
 
 
 
Mortgage-backed securities
$
4,577

$
11

$
18,150

$
287

$
22,727

$
298

State and municipal
206

6

954

64

1,160

70

Foreign government
989

11



989

11

Asset-backed securities
12,581

86



12,581

86

Total debt securities held-to-maturity
$
18,353

$
114

$
19,104

$
351

$
37,457

$
465

December 31, 2018
 
 
 
 
 
 
Debt securities held-to-maturity
 
 
 
 
 
 
Mortgage-backed securities
$
2,822

$
20

$
18,086

$
559

$
20,908

$
579

State and municipal
981

34

1,242

104

2,223

138

Foreign government
1,003

24



1,003

24

Asset-backed securities
13,008

112



13,008

112

Total debt securities held-to-maturity
$
17,814

$
190

$
19,328

$
663

$
37,142

$
853

Note: Excluded from the gross unrecognized losses presented in the table above are $(683) million and $(653) million of net unrealized losses recorded in AOCI as of March 31, 2019 and December 31, 2018, respectively, primarily related to the difference between the amortized cost and carrying value of HTM debt 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 March 31, 2019 and December 31, 2018.
The following table presents the carrying value and fair value of HTM debt securities by contractual maturity dates:
 
March 31, 2019
December 31, 2018
In millions of dollars
Carrying value
Fair value
Carrying value
Fair value
Mortgage-backed securities
 
 
 
 
Due within 1 year
$
3

$
3

$
3

$
3

After 1 but within 5 years
544

547

539

540

After 5 but within 10 years
1,822

1,845

997

1,011

After 10 years(1)
37,654

37,736

34,407

34,024

Total
$
40,023

$
40,131

$
35,946

$
35,578

State and municipal
 
 
 
 
Due within 1 year
$
37

$
37

$
37

$
37

After 1 but within 5 years
221

228

168

174

After 5 but within 10 years
487

500

540

544

After 10 years(1)
6,903

7,098

6,883

6,902

Total
$
7,648

$
7,863

$
7,628

$
7,657

Foreign government
 
 
 
 
Due within 1 year
$
20

$
20

$
60

$
36

After 1 but within 5 years
980

969

967

967

After 5 but within 10 years




After 10 years(1)




Total
$
1,000

$
989

$
1,027

$
1,003

All other(2)
 
 
 
 
Due within 1 year
$

$

$

$

After 1 but within 5 years




After 5 but within 10 years
3,039

3,041

2,535

2,539

After 10 years(1)
15,132

15,050

16,221

16,113

Total
$
18,171

$
18,091

$
18,756

$
18,652

Total debt securities held-to-maturity
$
66,842

$
67,074

$
63,357

$
62,890

(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.


Evaluating Investments for Other-Than-Temporary Impairment

Debt Securities

Overview
The Company conducts periodic reviews of all debt securities with unrealized losses to evaluate whether the impairment is other-than-temporary. This review applies to all debt securities that are not measured at fair value through earnings.
An unrealized loss exists when the current fair value of an individual debt security is less than its amortized cost basis. Unrealized losses that are determined to be temporary in nature are recorded, net of tax, in AOCI for AFS debt securities. Temporary losses related to HTM debt securities generally are not recorded, as these investments are carried at adjusted amortized cost basis. However, for HTM debt securities with credit-related impairment, the credit loss is recognized in earnings as OTTI, and any difference between the cost basis adjusted for the OTTI and fair value is recognized in AOCI and amortized as an adjustment of yield over the remaining contractual life of the security. For debt securities transferred to HTM from Trading account assets, amortized cost is defined as the fair value of the securities at the date of transfer, plus any accretion income and less any impairment recognized in earnings subsequent to transfer. For debt 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 impairment recognized in earnings.
Regardless of the classification of debt securities as AFS or HTM, the Company assesses each position with an unrealized loss for OTTI. Factors considered in determining whether a loss is temporary include:

the length of time and the extent to which fair value has been below cost;
the severity of the impairment;
the cause of the impairment and the financial condition and near-term prospects of the issuer;
activity in the market of the issuer that may indicate adverse credit conditions; and
the Company’s ability and intent to hold the investment for a period of time sufficient to allow for any anticipated recovery.

The Company’s review for impairment generally entails:

identification and evaluation of impaired investments;
analysis of individual investments that have fair values less than amortized cost, including consideration of the length of time the investment has been in an unrealized loss position and the expected recovery period;
consideration of evidential matter, including an evaluation of factors or triggers that could cause individual investments to qualify as having other-than-temporary impairment and those that would not support other-than-temporary impairment; and
documentation of the results of these analyses, as required under business policies.

The entire difference between amortized cost basis and fair value is recognized in earnings as OTTI for impaired debt securities that the Company has an intent to sell or for which the Company believes it will more-likely-than-not be required to sell prior to recovery of the amortized cost basis. However, for those debt securities that the Company does not intend to sell and is not likely to be required to sell, only the credit-related impairment is recognized in earnings and any non-credit-related impairment is recorded in AOCI.
For debt securities, credit impairment exists where management does not expect to receive contractual principal and interest cash flows sufficient to recover the entire amortized cost basis of a security.
The sections below describe the Company’s process for identifying credit-related impairments for debt security types that have the most significant unrealized losses as of March 31, 2019.

Mortgage-Backed Securities
For U.S. mortgage-backed securities, credit impairment is assessed using a cash flow model that estimates the principal and interest cash flows on the underlying mortgages using the security-specific collateral and transaction structure. The model distributes the estimated cash flows to the various tranches of securities, considering the transaction structure and any subordination and credit enhancements that exist in that structure. The cash flow model incorporates actual cash flows on the mortgage-backed securities through the current period and then estimates the remaining cash flows using a number of assumptions, including default rates, prepayment rates, recovery rates (on foreclosed properties) and loss severity rates (on non-agency mortgage-backed securities).
Management develops specific assumptions using market data, internal estimates and estimates published by rating agencies and other third-party sources. Default rates are projected by considering current underlying mortgage loan performance, generally assuming the default of (i) 10% of current loans, (ii) 25% of 30–59 day delinquent loans, (iii) 70% of 60–90 day delinquent loans and (iv) 100% of 91+ day delinquent loans. These estimates are extrapolated along a default timing curve to estimate the total lifetime pool default rate. Other assumptions contemplate the actual collateral attributes, including geographic concentrations, rating actions and current market prices.
Cash flow projections are developed using different stress test scenarios. Management evaluates the results of those stress tests (including the severity of any cash shortfall indicated and the likelihood of the stress scenarios actually occurring based on the underlying pool’s characteristics and performance) to assess whether management expects to recover the amortized cost basis of the security. If cash flow projections indicate that the Company does not expect to recover its amortized cost basis, the Company recognizes the estimated credit loss in earnings.

State and Municipal Securities
The process for identifying credit impairments in Citigroup’s AFS and HTM state and municipal bonds is primarily based on a credit analysis that incorporates third-party credit ratings.  Citigroup monitors the bond issuers and any insurers providing default protection in the form of financial guarantee insurance. The average external credit rating, ignoring any insurance, is Aa3/AA-.  In the event of an external rating downgrade or other indicator of credit impairment (i.e., based on instrument-specific estimates of cash flows or probability of issuer default), the subject bond is specifically reviewed for adverse changes in the amount or timing of expected contractual principal and interest payments.
For state and municipal bonds with unrealized losses that Citigroup plans to sell, or would be more-likely-than-not required to sell, the full impairment is recognized in earnings.

Equity Method Investments
Management assesses equity method investments that have fair values that are less than their respective carrying values for OTTI. Fair value is measured as price multiplied by quantity if the investee has publicly listed securities. If the investee is not publicly listed, other methods are used (see Note 20 to the Consolidated Financial Statements).
For impaired equity method investments that Citi plans to sell prior to recovery of value or would likely be required to sell, with no expectation that the fair value will recover prior to the expected sale date, the full impairment is recognized in earnings as OTTI regardless of severity and duration. The measurement of the OTTI does not include partial projected recoveries subsequent to the balance sheet date.
For impaired equity method investments that management does not plan to sell and is not likely to be required to sell prior to recovery of value, the evaluation of whether an impairment is other-than-temporary is based on (i) whether and when an equity method investment will recover in value and (ii) whether the investor has the intent and ability to hold that investment for a period of time sufficient to recover the value. The determination of whether the impairment is considered other-than-temporary considers the following indicators:

the cause of the impairment and the financial condition and near-term prospects of the issuer, including any specific events that may influence the operations of the issuer;
the intent and ability to hold the investment for a period of time sufficient to allow for any anticipated recovery in market value; and
the length of time and extent to which fair value has been less than the carrying value.
Recognition and Measurement of OTTI
The following tables present total OTTI on Investments recognized in earnings:

Three Months Ended 
 March 31, 2019
In millions of dollars
AFS
HTM
Total
Impairment losses related to debt 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 debt securities that the Company does not intend to sell nor will likely be required to sell
$

$

$

Impairment losses recognized in earnings for debt 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
3


3

Total OTTI losses recognized in earnings
$
3

$

$
3



Three Months Ended 
  March 31, 2018
In millions of dollars
AFS
HTM
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
27


27

Total impairment losses recognized in earnings
$
27

$

$
27




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 will likely be required to sell:
 
Cumulative OTTI credit losses recognized in earnings on debt securities still held
In millions of dollars
December 31, 2018 balance
Credit
impairments
recognized in
earnings on
securities not
previously
impaired
Credit
impairments
recognized in
earnings on
securities that
have
been previously
impaired
Changes due to
credit-impaired
securities sold,
transferred or
matured
March 31, 2019 balance
AFS debt securities
 
 
 
 
 
Mortgage-backed securities
$
1

$

$

$

$
1

State and municipal





Foreign government securities





Corporate
4




4

All other debt securities





Total OTTI credit losses recognized for AFS debt securities
$
5

$

$

$

$
5

HTM debt securities
 
 
 
 
 
Mortgage-backed securities
$

$

$

$

$

State and municipal





Total OTTI credit losses recognized for HTM debt securities
$

$

$

$

$


 
Cumulative OTTI credit losses recognized in earnings on debt securities still held
In millions of dollars
December 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
(1)
March 31, 2018 balance
AFS debt securities
 
 
 
 
 
Mortgage-backed securities(2)
$
38

$

$

$
(13
)
$
25

State and municipal
4



(4
)

Foreign government securities





Corporate
4




4

All other debt securities
2




2

Total OTTI credit losses recognized for AFS debt securities
$
48

$

$

$
(17
)
$
31

HTM debt securities
 
 
 
 
 
Mortgage-backed securities(3)
$
54

$

$

$
(54
)
$

State and municipal
3



(3
)

Total OTTI credit losses recognized for HTM debt securities
$
57

$

$

$
(57
)
$

(1)
Includes $18 million in cumulative OTTI reclassified from HTM to AFS due to the transfer of the related debt securities from HTM to AFS. Citi adopted ASU 2017-12, Targeted Improvements to Accounting for Hedge Activities, on January 1, 2018 and transferred approximately $4 billion of HTM debt securities into AFS classification as permitted as a one-time transfer under the standard.
(2)
Primarily consists of Prime securities.
(3)
Primarily consists of Alt-A securities.


Non-Marketable Equity Securities Not Carried at Fair Value
Non-marketable equity securities are required to be measured at fair value with changes in fair value recognized in earnings unless (i) the measurement alternative is elected or (ii) the investment represents Federal Reserve Bank and Federal Home Loan Bank stock or certain exchange seats that continue to be carried at cost.
The election to measure a non-marketable equity security using the measurement alternative is made on an instrument-by-instrument basis. Under the measurement alternative, an equity security is carried at cost plus or minus changes resulting from observable prices in orderly transactions for the identical or a similar investment of the same issuer. The carrying value of the equity security is adjusted to fair value on the date of an observed transaction. Fair value may differ from the observed transaction price due to a number of factors, including marketability adjustments and differences in rights and obligations when the observed transaction is not for the identical investment held by Citi.
Equity securities under the measurement alternative are also assessed for impairment. On a quarterly basis, management qualitatively assesses whether each equity security under the measurement alternative is impaired. Impairment indicators that are considered include, but are not limited to, the following:

a significant deterioration in the earnings performance, credit rating, asset quality or business prospects of the investee;
a significant adverse change in the regulatory, economic or technological environment of the investee;
a significant adverse change in the general market condition of either the geographical area or the industry in which the investee operates;
a bona fide offer to purchase, an offer by the investee to sell or a completed auction process for the same or similar investment for an amount less than the carrying amount of that investment; and
factors that raise significant concerns about the investee’s ability to continue as a going concern, such as negative cash flows from operations, working capital deficiencies or noncompliance with statutory capital requirements or debt covenants.

When the qualitative assessment indicates that impairment exists, the investment is written down to fair value, with the full difference between the fair value of the investment and its carrying amount recognized in earnings.
Below is the carrying value of non-marketable equity securities measured using the measurement alternative at March 31, 2019 and December 31, 2018:
In millions of dollars
March 31, 2019
December 31, 2018
Measurement alternative:
 
 
Carrying value
$
630

$
538


Below are amounts recognized in earnings for the three months ended March 31, 2019 and 2018, and life-to-date amounts as of March 31, 2019 on non-marketable equity securities measured using the measurement alternative:

 
Three Months Ended
March 31,
In millions of dollars
2019
2018
Measurement alternative:




Impairment losses(1)
$
5

$
1

Downward changes for observable prices(1)

2

Upward changes for observable prices(1)
66

123


(1)
See Note 20 to the Consolidated Financial Statements for additional information on these nonrecurring fair value measurements.

 
Life-to-date amounts on securities still held
In millions of dollars
March 31, 2019
Measurement alternative:
 
Impairment losses
$
12

Downward changes for observable prices
18

Upward changes for observable prices
285





A similar impairment analysis is performed for non-marketable equity securities carried at cost. For the three months ended March 31, 2019 and 2018, there was no impairment loss recognized in earnings for non-marketable equity securities carried at cost.

Investments in Alternative Investment Funds That Calculate Net Asset Value
The Company holds investments in certain alternative investment funds that calculate net asset value (NAV), or its equivalent, including hedge funds, private equity funds, funds
of funds and real estate funds, as provided by third-party asset managers. Investments in such funds are generally classified as non-marketable equity securities carried at fair value. The fair values of these investments are estimated using the NAV of the Company’s ownership interest in the funds. Some of
these investments are in “covered funds” for purposes of the Volcker Rule, which prohibits certain proprietary investment activities and limits the ownership of, and relationships with, covered funds. On April 21, 2017, Citi’s request for extension of the permitted holding period under the Volcker Rule for certain of its investments in illiquid funds was approved, allowing the Company to hold such investments until the earlier of five years from the July 21, 2017 expiration date of the general conformance period, or the date such investments mature or are otherwise conformed with the Volcker Rule.



 
Fair value
Unfunded
commitments
Redemption frequency
(if currently eligible)
monthly, quarterly, annually
Redemption 
notice
period
In millions of dollars
March 31,
2019
December 31, 2018
March 31,
2019
December 31, 2018
 
 
Hedge funds
$

$

$

$

Generally quarterly
10–95 days
Private equity funds(1)(2)
160

168

62

62

Real estate funds(2)(3)
14

14

19

19

Mutual/collective investment funds
25

25



Total
$
199

$
207

$
81

$
81

(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.