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INVESTMENTS
3 Months Ended
Mar. 31, 2020
Investments, Debt and Equity Securities [Abstract]  
INVESTMENTS  INVESTMENTS

For additional information regarding Citi’s investment portfolios, including evaluating investments for impairment, see Note 13 to the Consolidated Financial Statements
in Citi’s 2019 Annual Report on Form 10-K.






The following table presents Citi’s investments by category:
 
In millions of dollars
March 31,
2020
December 31,
2019
 
 
Debt securities available-for-sale (AFS)
$
308,219

$
280,265

 
Debt securities held-to-maturity (HTM)(1)
82,315

80,775

 
Marketable equity securities carried at fair value(2)
682

458

 
Non-marketable equity securities carried at fair value(2)
532

704

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


741

700

 
Non-marketable equity securities carried at cost(4)
6,394

5,661

 
Total investments
$
398,883

$
368,563


(1)
Carried at adjusted amortized cost basis, net of any allowance for credit losses.
(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. See ”Recognition and Measurement of Impairment” below.
(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
2020
2019
Taxable interest
$
2,179

$
2,372

Interest exempt from U.S. federal income tax
76

127

Dividend income
26

49

Total interest and dividend income
$
2,281

$
2,548




The following table presents realized gains and losses on the sales of investments, which exclude impairment losses:
 
Three Months Ended March 31,
In millions of dollars
2020
2019
Gross realized investment gains
$
464

$
168

Gross realized investment losses
(32
)
(38
)
Net realized gains on sale of investments
$
432

$
130





Debt Securities Available-for-Sale
The amortized cost and fair value of AFS debt securities were as follows:
 
March 31, 2020
December 31, 2019
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
$
42,559

$
1,271

$
277

$
43,553

$
34,963

$
547

$
280

$
35,230

Non-U.S. residential
752

3

3

752

789

3


792

Commercial
69


1

68

75



75

Total mortgage-backed securities
$
43,380

$
1,274

$
281

$
44,373

$
35,827

$
550

$
280

$
36,097

U.S. Treasury and federal agency securities
 
 
 
 
 
 
 
 
U.S. Treasury
$
118,298

$
2,863

$
2

$
121,159

$
106,429

$
50

$
380

$
106,099

Agency obligations
4,080

30

7

4,103

5,336

3

20

5,319

Total U.S. Treasury and federal agency securities
$
122,378

$
2,893

$
9

$
125,262

$
111,765

$
53

$
400

$
111,418

State and municipal
$
5,677

$
224

$
436

$
5,465

$
5,024

$
43

$
89

$
4,978

Foreign government
116,703

983

319

117,367

110,958

586

241

111,303

Corporate
11,243

116

162

11,197

11,266

52

101

11,217

Asset-backed securities(1)
479

1

14

466

524


2

522

Other debt securities
4,086

3


4,089

4,729

1


4,730

   Allowance for AFS securities at the end of the period
$

$

$

$

 
 
 
 
Total debt securities AFS
$
303,946

$
5,494

$
1,221

$
308,219

$
280,093

$
1,285

$
1,113

$
280,265

(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, 2020
 
 
 
 
 
 
Debt securities AFS
 
 
 
 
 
 
Mortgage-backed securities
 
 
 
 
 
 
U.S. government-sponsored agency guaranteed
$
7,937

$
225

$
858

$
52

$
8,795

$
277

Non-U.S. residential
360

3



360

3

Commercial
38


8

1

46

1

Total mortgage-backed securities
$
8,335

$
228

$
866

$
53

$
9,201

$
281

U.S. Treasury and federal agency securities
 
 
 
 
 
 
U.S. Treasury
$
3,062

$
2

$

$

$
3,062

$
2

Agency obligations


249

7

249

7

Total U.S. Treasury and federal agency securities
$
3,062

$
2

$
249

$
7

$
3,311

$
9

State and municipal
$
968

$
415

$
236

$
21

$
1,204

$
436

Foreign government
26,966

235

2,963

84

29,929

319

Corporate
2,540

155

61

7

2,601

162

Asset-backed securities
136

6

148

8

284

14

Other debt securities
118




118


Total debt securities AFS
$
42,125

$
1,041

$
4,523

$
180

$
46,648

$
1,221

December 31, 2019
 

 

 

 

 

 

Debt securities AFS
 

 

 

 

 

 

Mortgage-backed securities
 

 

 

 

 

 

U.S. government-sponsored agency guaranteed
$
9,780

$
242

$
1,877

$
38

$
11,657

$
280

Non-U.S. residential
208


1


209


Commercial
16


27


43


Total mortgage-backed securities
$
10,004

$
242

$
1,905

$
38

$
11,909

$
280

U.S. Treasury and federal agency securities
 

 

 



 

 

U.S. Treasury
$
45,484

$
248

$
26,907

$
132

$
72,391

$
380

Agency obligations
781

2

3,897

18

4,678

20

Total U.S. Treasury and federal agency securities
$
46,265

$
250

$
30,804

$
150

$
77,069

$
400

State and municipal
$
362

$
62

$
266

$
27

$
628

$
89

Foreign government
35,485

149

8,170

92

43,655

241

Corporate
2,916

98

123

3

3,039

101

Asset-backed securities
112

1

166

1

278

2

Other debt securities
1,307




1,307


Total debt securities AFS
$
96,451

$
802

$
41,434

$
311

$
137,885

$
1,113




The following table presents the amortized cost and fair value of AFS debt securities by contractual maturity dates:
 
March 31, 2020
December 31, 2019
In millions of dollars
Amortized
cost
Fair
value
Amortized
cost
Fair
value
Mortgage-backed securities(1)
 
 
 
 
Due within 1 year
$
629

$
640

$
20

$
20

After 1 but within 5 years
584

585

573

574

After 5 but within 10 years
1,009

1,067

594

626

After 10 years(2)
41,158

42,081

34,640

34,877

Total
$
43,380

$
44,373

$
35,827

$
36,097

U.S. Treasury and federal agency securities
 
 
 
 
Due within 1 year
$
27,233

$
27,403

$
40,757

$
40,688

After 1 but within 5 years
88,605

91,130

70,128

69,850

After 5 but within 10 years
6,515

6,697

854

851

After 10 years(2)
25

32

26

29

Total
$
122,378

$
125,262

$
111,765

$
111,418

State and municipal
 
 
 
 
Due within 1 year
$
937

$
937

$
932

$
932

After 1 but within 5 years
601

608

714

723

After 5 but within 10 years
291

312

195

215

After 10 years(2)
3,848

3,608

3,183

3,108

Total
$
5,677

$
5,465

$
5,024

$
4,978

Foreign government
 
 
 
 
Due within 1 year
$
46,369

$
46,491

$
42,611

$
42,666

After 1 but within 5 years
59,050

59,561

58,820

59,071

After 5 but within 10 years
9,481

9,505

8,192

8,198

After 10 years(2)
1,803

1,810

1,335

1,368

Total
$
116,703

$
117,367

$
110,958

$
111,303

All other(3)
 
 
 
 
Due within 1 year
$
5,836

$
5,846

$
7,306

$
7,311

After 1 but within 5 years
8,894

8,908

8,279

8,275

After 5 but within 10 years
921

891

818

797

After 10 years(2)
157

107

116

86

Total
$
15,808

$
15,752

$
16,519

$
16,469

Total debt securities AFS
$
303,946

$
308,219

$
280,093

$
280,265

(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.

There were no purchased credit-deteriorated AFS debt securities held by the Company as of March 31, 2020.

Debt Securities Held-to-Maturity

The carrying value and fair value of debt securities HTM were as follows:
In millions of dollars
Amortized
cost
Gross
unrealized
gains
Gross
unrealized
losses
Fair
value
March 31, 2020
 
 
 
 
Debt securities HTM
 
 
 
 
Mortgage-backed securities(1)
 
 
 
 
U.S. government-sponsored agency guaranteed
$
48,270

$
2,010

$
16

$
50,264

Non-U.S. residential
1,112


12

1,100

Commercial
654

1


655

Total mortgage-backed securities
$
50,036

$
2,011

$
28

$
52,019

State and municipal
$
9,269

$
516

$
25

$
9,760

Foreign government
1,553

40


1,593

Asset-backed securities(1)
21,533

4

1,251

20,286

Allowance for HTM securities at the end of the period
$
(76
)
$

$

$
(76
)
Total debt securities HTM, net
$
82,315

$
2,571

$
1,304

$
83,582

December 31, 2019
 

 

 

 

Debt securities HTM
 

 

 
 

Mortgage-backed securities(1)
 

 

 

 

U.S. government-sponsored agency guaranteed
$
46,637

$
1,047

$
21

$
47,663

Non-U.S. residential
1,039

5


1,044

Commercial
582

1


583

Total mortgage-backed securities
$
48,258

$
1,053

$
21

$
49,290

State and municipal
$
9,104

$
455

$
28

$
9,531

Foreign government
1,934

37

1

1,970

Asset-backed securities(1)
21,479

12

59

21,432

Total debt securities HTM
$
80,775

$
1,557

$
109

$
82,223


(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 table below shows the fair value of debt securities HTM that have been in an unrecognized loss position at December 31, 2019:
 
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
December 31, 2019
 
 
 
 
 
 
Debt securities held-to-maturity
 
 
 
 
 
 
Mortgage-backed securities
$
3,590

$
10

$
1,116

$
11

$
4,706

$
21

State and municipal
34

1

1,125

27

1,159

28

Foreign government
1,970

1



1,970

1

Asset-backed securities
7,972

11

765

48

8,737

59

Total debt securities held-to-maturity
$
13,566

$
23

$
3,006

$
86

$
16,572

$
109

Note: Excluded from the gross unrecognized losses presented in the table above is $(582) million of net unrealized losses recorded in AOCI as of December 31, 2019, 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 December 31, 2019.
The following table presents the carrying value and fair value of HTM debt securities by contractual maturity dates:
 
March 31, 2020
December 31, 2019
In millions of dollars
Amortized cost
Fair value
Amortized cost
Fair value
Mortgage-backed securities
 
 
 
 
Due within 1 year
$
14

$
14

$
17

$
17

After 1 but within 5 years
474

486

458

463

After 5 but within 10 years
1,604

1,757

1,662

1,729

After 10 years(1)
47,944

49,762

46,121

47,081

Total
$
50,036

$
52,019

$
48,258

$
49,290

State and municipal
 
 
 
 
Due within 1 year
$
52

$
50

$
2

$
26

After 1 but within 5 years
89

90

123

160

After 5 but within 10 years
577

604

597

590

After 10 years(1)
8,551

9,016

8,382

8,755

Total
$
9,269

$
9,760

$
9,104

$
9,531

Foreign government
 
 
 
 
Due within 1 year
$
521

$
522

$
650

$
652

After 1 but within 5 years
1,032

1,071

1,284

1,318

After 5 but within 10 years




After 10 years(1)




Total
$
1,553

$
1,593

$
1,934

$
1,970

All other(2)
 
 
 
 
Due within 1 year
$

$

$

$

After 1 but within 5 years




After 5 but within 10 years
7,092

6,753

8,545

8,543

After 10 years(1)
14,441

13,457

12,934

12,889

Total
$
21,533

$
20,210

$
21,479

$
21,432

Total debt securities HTM
$
82,391

$
83,582

$
80,775

$
82,223

(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.

HTM Debt Securities Delinquency and Non-Accrual Details

Citi did not have any HTM securities that were delinquent or on non-accrual status at March 31, 2020.

There were no purchased credit-deteriorated HTM debt securities held by the Company as of March 31, 2020.

Evaluating Investments for Impairment

AFS Debt Securities

Overview—AFS Debt Securities
The Company conducts periodic reviews of all AFS debt securities with unrealized losses to evaluate whether the impairment resulted from expected credit losses or from other factors and to evaluate the Company’s intent to sell such securities.
An AFS debt security is impaired when the current fair value of an individual AFS debt security is less than its amortized cost basis.
The Company recognizes the entire difference between amortized cost basis and fair value in earnings for impaired AFS debt securities that Citi has an intent to sell or for which Citi believes it will more-likely-than-not be required to sell prior to recovery of the amortized cost basis. However, for those AFS 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 by recording an allowance for credit losses. Any remaining fair value decline for such securities is recorded in AOCI. The Company does not consider the length of time that the fair value of a security is below its amortized cost when determining if a credit loss exists.
For AFS debt securities, credit losses exist where Citi does not expect to receive contractual principal and interest cash flows sufficient to recover the entire amortized cost basis of a security. The allowance for credit losses is limited to the amount by which the AFS debt security’s amortized cost basis exceeds its fair value. The allowance is increased or decreased if credit conditions subsequently worsen or improve. Reversals of credit losses are recognized in earnings.
The Company’s review for impairment of AFS debt securities generally entails:

identification and evaluation of impaired investments;
consideration of evidential matter, including an evaluation of factors or triggers that could cause individual positions to qualify as credit impaired and those that would not support credit impairment; and
documentation of the results of these analyses, as required under business policies.

The sections below describe the Company’s process for identifying expected credit impairments for debt security types that have the most significant unrealized losses as of March 31, 2020.

Mortgage-Backed Securities
Citi records no allowances for credit losses on U.S. government-agency-guaranteed mortgage-backed securities, because the Company expects to incur no credit losses in the event of default due to a history of incurring no credit losses and due to the nature of the counterparties.

State and Municipal Securities
The process for estimating credit losses in Citigroup’s AFS state and municipal bonds is primarily based on a credit analysis that incorporates third-party credit ratings. Citi 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 Aa2/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 AFS state and municipal bonds with unrealized losses that Citi plans to sell, or would be more-likely-than-not required to sell, the full impairment is recognized in earnings. For AFS state and municipal bonds where Citi has no intent to sell and it is more-likely-than-not that the Company will not be required to sell, Citi records an allowance for expected credit losses for the amount it expects not to collect, capped at the difference between the bond’s amortized cost basis and fair value.
Equity Method Investments
Management assesses equity method investments that have fair values that are less than their respective carrying values for other-than-temporary impairment (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 more-likely-than-not 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 more-likely-than-not 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 Impairment
The following tables present total impairment on Investments recognized in earnings:

Three Months Ended 
 March 31, 2020
Three Months Ended 
 March 31, 2019
In millions of dollars
AFS
Other
assets
Total
AFS
HTM
Other assets
Total
Impairment losses related to debt securities that the Company does not intend to sell nor will likely be required to sell:
 
 
 
 
 
 
 
Total impairment 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 more-likely-than-not be required to sell or will be subject to an issuer call deemed probable of exercise
52


52

3



3

Total impairment losses recognized in earnings
$
52

$

$
52

$
3

$

$

$
3



The following are three-month rollforwards of the credit-related impairments recognized in earnings for AFS debt securities held that the Company does not intend to sell nor will likely be required to sell:
 
Cumulative credit losses recognized in earnings on debt securities still held
In millions of dollars
December 31, 2019 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, 2020 balance
AFS debt securities
 
 
 
 
 
Mortgage-backed securities
$
1

$

$

$

$
1

State and municipal
4




4

Corporate
4




4

All other debt securities
1




1

Total credit losses recognized for AFS debt securities
$
10

$

$

$

$
10

 
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





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
$

$

$

$

$



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, 2020 and December 31, 2019:
In millions of dollars
March 31, 2020
December 31, 2019
Measurement alternative:
 
 
Carrying value
$
741

$
700


Below are amounts recognized in earnings and life-to-date amounts for non-marketable equity securities measured using the measurement alternative:
 
Three Months Ended
March 31,
In millions of dollars
2020
2019
Measurement alternative(1):




Impairment losses
$
3

$
5

Downward changes for observable prices


Upward changes for observable prices
25

66


(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, 2020
Measurement alternative:
 
Impairment losses
$
19

Downward changes for observable prices
34

Upward changes for observable prices
367




A similar impairment analysis is performed for non-marketable equity securities carried at cost. For the three months ended March 31, 2020 and 2019, 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 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,
2020
December 31, 2019
March 31,
2020
December 31, 2019
 
 
Hedge funds
$

$

$

$

Generally quarterly
10–95 days
Private equity funds(1)(2)
123

134

62

62

Real estate funds(2)(3)
9

10

18

18

Mutual/collective investment funds
20

26



Total
$
152

$
170

$
80

$
80

(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.