CONTINGENCIES	9 Months Ended
Sep. 30, 2013
CONTINGENCIES
CONTINGENCIES	24. CONTINGENCIES The following information supplements and amends, as applicable, the disclosures in Note 28 to the Consolidated Financial Statements of Citigroup's 2012 Annual Report on Form 10-K, Note 23 to the Consolidated Financial Statements of Citigroup's Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2013 and Note 24 to the Consolidated Financial Statements of Citigroup's Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2013. 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 (formerly SFAS 5), Citigroup establishes accruals for litigation and regulatory matters, including 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 matters for which an accrual has been established 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 September 30, 2013, Citigroup's estimate was materially unchanged from its estimate of approximately $5 billion at December 31, 2012, as more fully described in Note 28 to the Consolidated Financial Statements in the 2012 Annual Report on Form 10-K. As available information changes, the matters for which Citigroup is able to estimate, 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 litigation and regulatory matters, see Note 28 to the Consolidated Financial Statements of Citigroup's 2012 Annual Report on Form 10-K. Credit Crisis-Related Litigation and Other Matters *Mortgage-Related Litigation and Other Matters* Securities Actions: Three objectors have filed notices of appeal from the August 1, 2013 order of the United States District Court for the Southern District of New York finally approving the class action settlement in IN RE CITIGROUP INC. SECURITIES LITIGATION. Additional information relating to this action is publicly available in court filings under the consolidated lead docket number 07 Civ. 9901 (S.D.N.Y.) (Stein, J.), and 13-3531, 13-3539, and 13-3710 (2d Cir.). On August 20, 2013, the United States District Court for the Southern District of New York entered an order finally approving the class action settlement in IN RE CITIGROUP INC. BOND LITIGATION. Additional information relating to this action is publicly available in court filings under the consolidated lead docket number 08 Civ. 9522 (S.D.N.Y.) (Stein, J.). On September 27, 2013, plaintiffs in COMMONWEALTH OF PENNSYLVANIA—PUBLIC SCHOOL EMPLOYEES' RETIREMENT SYSTEM, ET AL. v. CITIGROUP INC., ET AL. filed a voluntary discontinuance, dismissing with prejudice all claims, pursuant to a settlement agreement reached by the parties. Additional information relating to this action is publicly available in court filings under Case No. 110105028 (Pa. Commw. Ct.) (Sheppard, J.). Regulatory Actions: Citigroup continues to respond to subpoenas and inquiries from federal and state governmental agencies, including the Civil Division of the Department of Justice, requesting information related to, among other things, Citigroup's issuing, sponsoring, or underwriting of MBS. Mortgage-Backed Securities and CDO Investor Actions and Repurchase Claims: On June 5, 2013, the District Court for the Fourth Judicial District of the State of Minnesota issued an order compelling arbitration and staying the proceedings in MONEYGRAM PAYMENT SYSTEMS, INC. v. CITIGROUP INC. ET AL. Additional information relating to this action is publicly available in court filings under the docket number 27 Civ. 11-21348 (Minn. Dist. Ct.) (Sheehy, J.). On September 27, 2013, the United States District Court for the Southern District of New York issued an opinion in FEDERAL DEPOSIT INSURANCE CORP. AS RECEIVER FOR COLONIAL BANK v. CHASE MORTGAGE FINANCE CORP., ET AL. denying defendants' motion to dismiss. Additional information relating to this action is publicly available in court filings under the docket number 12 Civ. 6166 (S.D.N.Y.) (Stanton, J.). On September 30, 2013, the United States District Court for the District of Massachusetts entered an order in FEDERAL HOME LOAN BANK OF BOSTON v. ALLY FINANCIAL, INC., ET AL. denying in part and granting in part defendants' motion to dismiss. Additional information relating to this action is publicly available in court filings under the docket number 11 Civ. 10952 (D. Mass.) (O'Toole, J.). On October 1, 2013, U.S. Bank, N.A., in its capacity as trustee, filed a complaint against Citigroup Global Markets Realty Corp., seeking to enforce contractual repurchase claims in connection with mortgage loans that were securitized into CMLTI 2007-AR7. Additional information relating to this action is publicly available in court filings under the docket number 13 Civ. 6989 (S.D.N.Y.) (Daniels, J.). The aggregate original purchase amount of the purchases at issue in the pending RMBS and CDO investor suits is approximately $8 billion, and the aggregate original purchase amount of the purchases covered by tolling agreements with RMBS and CDO investors threatening litigation is approximately $6 billion. *Abu Dhabi Investment Authority* On August 20, 2013, Abu Dhabi Investment Authority (ADIA) commenced an arbitration against Citigroup before the International Centre for Dispute Resolution, alleging common law claims in connection with its $7.5 billion investment in Citigroup in December 2007. The arbitration has been stayed until November 18, 2013, pursuant to a stipulation of the parties. On August 28, 2013, Citigroup filed a complaint against ADIA in the United States District Court for the Southern District of New York seeking to enjoin the arbitration proceeding on the ground that it is barred by the October 14, 2011 final award in favor of Citigroup in ADIA's prior arbitration. Additional information relating to this action is publicly available in court filings under the docket number 13 Civ. 6073 (S.D.N.Y.) (Castel, J.). *KIKOs* Prior to the devaluation of the Korean won in 2008, several local banks in Korea, including a Citigroup subsidiary (CKI), entered into foreign exchange derivative transactions with small and medium-size export businesses (SMEs) to enable the SMEs to hedge their currency risk. The derivatives had "knock-in, knock-out" features. Following the devaluation of the won, many of these SMEs incurred significant losses on the derivative transactions and filed civil lawsuits against the banks, including CKI. The claims generally allege that the products were not suitable and that the risk disclosure was inadequate. As of September 30, 2013, there were 99 civil lawsuits filed by SMEs against CKI. To date, 84 decisions have been rendered at the district court level, and CKI has prevailed in 64 of those decisions. In the other 20 decisions, plaintiffs were awarded only a portion of the damages sought. The damage awards total in the aggregate approximately $30 million. CKI is appealing the 20 adverse decisions. A significant number of plaintiffs that had decisions rendered against them are also filing appeals, including plaintiffs that were awarded less than all of the damages they sought. Of the 84 cases decided at the district court level, 62 have been appealed to the high court, including the 20 in which an adverse decision was rendered against CKI in the district court. Of the 23 appeals decided at high court level, CKI prevailed in 14 cases, and in the other nine plaintiffs were awarded partial damages, which increased the aggregate damages awarded against CKI by a further $9.6 million. CKI is appealing eight of the adverse decisions to the Korean Supreme Court, and many plaintiffs have also filed appeals to the Supreme Court. *Terra Firma Litigation* A retrial of the claims asserted in TERRA FIRMA INVESTMENTS (GP) 2 LIMITED, ET AL. v. CITIGROUP INC., ET AL. is scheduled to begin on July 7, 2014. Additional information relating to this action is publicly available in court filings under the docket numbers 09 Civ. 10459 (S.D.N.Y.) (Rakoff, J.) and 11-0126-cv (2d Cir.). *Tribune Company Bankruptcy* On September 23, 2013, the United States District Court for the Southern District of New York entered an order dismissing the Tribune creditors' state law constructive fraudulent conveyance actions. A final judgment was entered on September 27, 2013. On September 30, 2013, the Tribune creditors filed a notice of appeal in the United States Court of Appeals for the Second Circuit. On October 8, 2013, the litigation trustee informed the court that it intends to proceed with its fraudulent conveyance claims. Additional information relating to these actions is publicly available in court filings under the docket numbers 08-13141 (Bankr. D. Del.) (Carey, J.), 11 MD 02296 (S.D.N.Y.) (Sullivan, J.), and 12 MC 2296 (S.D.N.Y.) (Sullivan, J.). Credit Default Swaps Matters On October 16, 2013, the U.S. Judicial Panel on Multidistrict Litigation centralized numerous putative class actions filed by various entities against Citigroup, Citigroup Global Markets Inc. and Citibank, N.A., among other defendants, alleging anticompetitive conduct in the credit default swaps industry and ordered that those actions pending in the United States District Court for the Northern District of Illinois be transferred to the United States District Court for the Southern District of New York for coordinated or consolidated pretrial proceedings before Judge Denise Cote. Additional information relating to these actions is publicly available in court filings under the docket numbers 1:13-cv-03357 (N.D. Ill.), 1:13-cv-04979 (N.D. Ill.), 1:13-cv-05413 (N.D. Ill.), 1:13-cv-05417 (N.D. Ill.), 1:13-cv-05725 (N.D. Ill.), 13-cv-4928 (S.D.N.Y.) and 13-cv-6116 (S.D.N.Y.). Foreign Exchange Matters Government agencies in the U.S. and other jurisdictions are conducting investigations or making inquiries regarding trading on the foreign exchange markets. Citigroup has received requests for information and is cooperating with the investigations and inquiries and responding to the requests. Interbank Offered Rates—Related Litigation and Other Matters Antitrust and Other Litigation: On August 23, 2013, Judge Buchwald issued a decision (i) resolving several motions filed after her March 29, 2013 order, which dismissed many of the claims asserted by plaintiffs in the multi-district litigation captioned IN RE LIBOR-BASED FINANCIAL INSTRUMENTS ANTITRUST LITIGATION (the LIBOR MDL), appearing under docket number 1:11-md-2262 (S.D.N.Y.), and (ii) continuing the stay of all actions that were consolidated into the LIBOR MDL after June 29, 2012. Pursuant to the August 23, 2013 decision, on September 10, 2013, consolidated second amended complaints were filed by interim lead plaintiffs for the putative classes of (i) over-the-counter purchasers of derivative instruments tied to USD LIBOR and (ii) purchasers of exchange-traded derivative instruments tied to USD LIBOR. Each of these putative classes alleges that the panel bank defendants conspired to suppress USD LIBOR. The over-the-counter purchasers assert claims under the Sherman Act and for unjust enrichment and breach of the implied covenant of good faith and fair dealing. The purchasers of exchange-traded derivative instruments assert claims under the Commodity Exchange Act and the Sherman Act and for unjust enrichment. Three individual actions were filed in federal courts in Iowa and Kansas in August and September 2013 against Citigroup and Citibank, N.A., as well as other USD LIBOR panel banks, by various investment companies and federal credit unions. These actions assert federal and state antitrust claims, as well as claims under state law theories, and seek compensatory damages, various forms of enhanced damages, attorneys' fees, and injunctive relief. Additional information concerning these actions is publicly available in court filings under docket numbers 4:13-cv-334 (S.D. Iowa) (Pratt. J.), 4:13-cv-335 (S.D. Iowa) (Rose, J.), and 2:13-cv-2497 (D. Kan.) (Vratil, J.). On October 31, 2013, the Federal National Mortgage Association filed an individual action against Citigroup and Citibank, N.A., as well as other USD LIBOR panel banks and the British Bankers Association, asserting various state law claims, including breach of contract, breach of the implied covenant of good faith, and fraud. The complaint seeks compensatory damages, consequential damages, punitive damages, and attorneys' fees. Additional information concerning this action is publicly available in court filings under docket number 1:13-cv-7720 (S.D.N.Y.). Interchange Fees Litigation The United States District Court for the Eastern District of New York held a hearing on September 12, 2013 to consider whether the class settlements should be finally approved. Numerous merchants, including large national merchants, have requested exclusion (opted out) from the class settlements, and some of those opting out have filed complaints against Visa, MasterCard, and in some instances one or more issuing banks. Two of these suits, 7-ELEVEN, INC., ET AL. v. VISA INC., ET AL., and SPEEDY STOP FOOD STORES, LLC, ET AL. v. VISA INC., ET AL., name Citigroup as a defendant. Additional information concerning these actions is publicly available in court filings under docket numbers 1:13-CV-04442 (S.D.N.Y.) (Hellerstein, J.) and 13-10-75377A (Tex. D. Ct). Settlement Payments Payments required in settlement agreements described above have been made or are covered by existing litigation accruals. * * * Additional matters asserting claims similar to those described above may be filed in the future.

24. CONTINGENCIES

The following information supplements and amends, as applicable, the disclosures in Note 28 to the Consolidated Financial Statements of Citigroup's 2012 Annual Report on Form 10-K, Note 23 to the Consolidated Financial Statements of Citigroup's Quarterly Report on Form 10-Q for the quarterly period ended March 31, 2013 and Note 24 to the Consolidated Financial Statements of Citigroup's Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2013. 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 (formerly SFAS 5), Citigroup establishes accruals for litigation and regulatory matters, including 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 matters for which an accrual has been established 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 September 30, 2013, Citigroup's estimate was materially unchanged from its estimate of approximately $5 billion at December 31, 2012, as more fully described in Note 28 to the Consolidated Financial Statements in the 2012 Annual Report on Form 10-K.

As available information changes, the matters for which Citigroup is able to estimate, 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 litigation and regulatory matters, see Note 28 to the Consolidated Financial Statements of Citigroup's 2012 Annual Report on Form 10-K.

Credit Crisis-Related Litigation and Other Matters

Mortgage-Related Litigation and Other Matters

Securities Actions: Three objectors have filed notices of appeal from the August 1, 2013 order of the United States District Court for the Southern District of New York finally approving the class action settlement in IN RE CITIGROUP INC. SECURITIES LITIGATION. Additional information relating to this action is publicly available in court filings under the consolidated lead docket number 07 Civ. 9901 (S.D.N.Y.) (Stein, J.), and 13-3531, 13-3539, and 13-3710 (2d Cir.).

On August 20, 2013, the United States District Court for the Southern District of New York entered an order finally approving the class action settlement in IN RE CITIGROUP INC. BOND LITIGATION. Additional information relating to this action is publicly available in court filings under the consolidated lead docket number 08 Civ. 9522 (S.D.N.Y.) (Stein, J.).

On September 27, 2013, plaintiffs in COMMONWEALTH OF PENNSYLVANIA—PUBLIC SCHOOL EMPLOYEES' RETIREMENT SYSTEM, ET AL. v. CITIGROUP INC., ET AL. filed a voluntary discontinuance, dismissing with prejudice all claims, pursuant to a settlement agreement reached by the parties. Additional information relating to this action is publicly available in court filings under Case No. 110105028 (Pa. Commw. Ct.) (Sheppard, J.).

Regulatory Actions: Citigroup continues to respond to subpoenas and inquiries from federal and state governmental agencies, including the Civil Division of the Department of Justice, requesting information related to, among other things, Citigroup's issuing, sponsoring, or underwriting of MBS.

Mortgage-Backed Securities and CDO Investor Actions and Repurchase Claims: On June 5, 2013, the District Court for the Fourth Judicial District of the State of Minnesota issued an order compelling arbitration and staying the proceedings in MONEYGRAM PAYMENT SYSTEMS, INC. v. CITIGROUP INC. ET AL. Additional information relating to this action is publicly available in court filings under the docket number 27 Civ. 11-21348 (Minn. Dist. Ct.) (Sheehy, J.).

On September 27, 2013, the United States District Court for the Southern District of New York issued an opinion in FEDERAL DEPOSIT INSURANCE CORP. AS RECEIVER FOR COLONIAL BANK v. CHASE MORTGAGE FINANCE CORP., ET AL. denying defendants' motion to dismiss. Additional information relating to this action is publicly available in court filings under the docket number 12 Civ. 6166 (S.D.N.Y.) (Stanton, J.).

On September 30, 2013, the United States District Court for the District of Massachusetts entered an order in FEDERAL HOME LOAN BANK OF BOSTON v. ALLY FINANCIAL, INC., ET AL. denying in part and granting in part defendants' motion to dismiss. Additional information relating to this action is publicly available in court filings under the docket number 11 Civ. 10952 (D. Mass.) (O'Toole, J.).

On October 1, 2013, U.S. Bank, N.A., in its capacity as trustee, filed a complaint against Citigroup Global Markets Realty Corp., seeking to enforce contractual repurchase claims in connection with mortgage loans that were securitized into CMLTI 2007-AR7. Additional information relating to this action is publicly available in court filings under the docket number 13 Civ. 6989 (S.D.N.Y.) (Daniels, J.).

The aggregate original purchase amount of the purchases at issue in the pending RMBS and CDO investor suits is approximately $8 billion, and the aggregate original purchase amount of the purchases covered by tolling agreements with RMBS and CDO investors threatening litigation is approximately $6 billion.

Abu Dhabi Investment Authority

On August 20, 2013, Abu Dhabi Investment Authority (ADIA) commenced an arbitration against Citigroup before the International Centre for Dispute Resolution, alleging common law claims in connection with its $7.5 billion investment in Citigroup in December 2007. The arbitration has been stayed until November 18, 2013, pursuant to a stipulation of the parties. On August 28, 2013, Citigroup filed a complaint against ADIA in the United States District Court for the Southern District of New York seeking to enjoin the arbitration proceeding on the ground that it is barred by the October 14, 2011 final award in favor of Citigroup in ADIA's prior arbitration. Additional information relating to this action is publicly available in court filings under the docket number 13 Civ. 6073 (S.D.N.Y.) (Castel, J.).

KIKOs

Prior to the devaluation of the Korean won in 2008, several local banks in Korea, including a Citigroup subsidiary (CKI), entered into foreign exchange derivative transactions with small and medium-size export businesses (SMEs) to enable the SMEs to hedge their currency risk. The derivatives had "knock-in, knock-out" features. Following the devaluation of the won, many of these SMEs incurred significant losses on the derivative transactions and filed civil lawsuits against the banks, including CKI. The claims generally allege that the products were not suitable and that the risk disclosure was inadequate.

As of September 30, 2013, there were 99 civil lawsuits filed by SMEs against CKI. To date, 84 decisions have been rendered at the district court level, and CKI has prevailed in 64 of those decisions. In the other 20 decisions, plaintiffs were awarded only a portion of the damages sought. The damage awards total in the aggregate approximately $30 million. CKI is appealing the 20 adverse decisions. A significant number of plaintiffs that had decisions rendered against them are also filing appeals, including plaintiffs that were awarded less than all of the damages they sought.

Of the 84 cases decided at the district court level, 62 have been appealed to the high court, including the 20 in which an adverse decision was rendered against CKI in the district court. Of the 23 appeals decided at high court level, CKI prevailed in 14 cases, and in the other nine plaintiffs were awarded partial damages, which increased the aggregate damages awarded against CKI by a further $9.6 million. CKI is appealing eight of the adverse decisions to the Korean Supreme Court, and many plaintiffs have also filed appeals to the Supreme Court.

Terra Firma Litigation

A retrial of the claims asserted in TERRA FIRMA INVESTMENTS (GP) 2 LIMITED, ET AL. v. CITIGROUP INC., ET AL. is scheduled to begin on July 7, 2014. Additional information relating to this action is publicly available in court filings under the docket numbers 09 Civ. 10459 (S.D.N.Y.) (Rakoff, J.) and 11-0126-cv (2d Cir.).

Tribune Company Bankruptcy

On September 23, 2013, the United States District Court for the Southern District of New York entered an order dismissing the Tribune creditors' state law constructive fraudulent conveyance actions. A final judgment was entered on September 27, 2013. On September 30, 2013, the Tribune creditors filed a notice of appeal in the United States Court of Appeals for the Second Circuit. On October 8, 2013, the litigation trustee informed the court that it intends to proceed with its fraudulent conveyance claims. Additional information relating to these actions is publicly available in court filings under the docket numbers 08-13141 (Bankr. D. Del.) (Carey, J.), 11 MD 02296 (S.D.N.Y.) (Sullivan, J.), and 12 MC 2296 (S.D.N.Y.) (Sullivan, J.).

Credit Default Swaps Matters

On October 16, 2013, the U.S. Judicial Panel on Multidistrict Litigation centralized numerous putative class actions filed by various entities against Citigroup, Citigroup Global Markets Inc. and Citibank, N.A., among other defendants, alleging anticompetitive conduct in the credit default swaps industry and ordered that those actions pending in the United States District Court for the Northern District of Illinois be transferred to the United States District Court for the Southern District of New York for coordinated or consolidated pretrial proceedings before Judge Denise Cote. Additional information relating to these actions is publicly available in court filings under the docket numbers 1:13-cv-03357 (N.D. Ill.), 1:13-cv-04979 (N.D. Ill.), 1:13-cv-05413 (N.D. Ill.), 1:13-cv-05417 (N.D. Ill.), 1:13-cv-05725 (N.D. Ill.), 13-cv-4928 (S.D.N.Y.) and 13-cv-6116 (S.D.N.Y.).

Foreign Exchange Matters

Government agencies in the U.S. and other jurisdictions are conducting investigations or making inquiries regarding trading on the foreign exchange markets. Citigroup has received requests for information and is cooperating with the investigations and inquiries and responding to the requests.

Interbank Offered Rates—Related Litigation and Other Matters

Antitrust and Other Litigation: On August 23, 2013, Judge Buchwald issued a decision (i) resolving several motions filed after her March 29, 2013 order, which dismissed many of the claims asserted by plaintiffs in the multi-district litigation captioned IN RE LIBOR-BASED FINANCIAL INSTRUMENTS ANTITRUST LITIGATION (the LIBOR MDL), appearing under docket number 1:11-md-2262 (S.D.N.Y.), and (ii) continuing the stay of all actions that were consolidated into the LIBOR MDL after June 29, 2012. Pursuant to the August 23, 2013 decision, on September 10, 2013, consolidated second amended complaints were filed by interim lead plaintiffs for the putative classes of (i) over-the-counter purchasers of derivative instruments tied to USD LIBOR and (ii) purchasers of exchange-traded derivative instruments tied to USD LIBOR. Each of these putative classes

alleges that the panel bank defendants conspired to suppress USD LIBOR. The over-the-counter purchasers assert claims under the Sherman Act and for unjust enrichment and breach of the implied covenant of good faith and fair dealing. The purchasers of exchange-traded derivative instruments assert claims under the Commodity Exchange Act and the Sherman Act and for unjust enrichment.

Three individual actions were filed in federal courts in Iowa and Kansas in August and September 2013 against Citigroup and Citibank, N.A., as well as other USD LIBOR panel banks, by various investment companies and federal credit unions. These actions assert federal and state antitrust claims, as well as claims under state law theories, and seek compensatory damages, various forms of enhanced damages, attorneys' fees, and injunctive relief. Additional information concerning these actions is publicly available in court filings under docket numbers 4:13-cv-334 (S.D. Iowa) (Pratt. J.), 4:13-cv-335 (S.D. Iowa) (Rose, J.), and 2:13-cv-2497 (D. Kan.) (Vratil, J.).

On October 31, 2013, the Federal National Mortgage Association filed an individual action against Citigroup and Citibank, N.A., as well as other USD LIBOR panel banks and the British Bankers Association, asserting various state law claims, including breach of contract, breach of the implied covenant of good faith, and fraud. The complaint seeks compensatory damages, consequential damages, punitive damages, and attorneys' fees. Additional information concerning this action is publicly available in court filings under docket number 1:13-cv-7720 (S.D.N.Y.).

Interchange Fees Litigation

The United States District Court for the Eastern District of New York held a hearing on September 12, 2013 to consider whether the class settlements should be finally approved. Numerous merchants, including large national merchants, have requested exclusion (opted out) from the class settlements, and some of those opting out have filed complaints against Visa, MasterCard, and in some instances one or more issuing banks. Two of these suits, 7-ELEVEN, INC., ET AL. v. VISA INC., ET AL., and SPEEDY STOP FOOD STORES, LLC, ET AL. v. VISA INC., ET AL., name Citigroup as a defendant. Additional information concerning these actions is publicly available in court filings under docket numbers 1:13-CV-04442 (S.D.N.Y.) (Hellerstein, J.) and 13-10-75377A (Tex. D. Ct).

Settlement Payments

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

* * *

Additional matters asserting claims similar to those described above may be filed in the future.