CITIGROUP June 28, 2004 Office of the Comptroller of the Currency
Public Information Room, Mailstop 1-5
250 E Street, S.W.
Washington, DC 20219
Attention: 1557-0081 Steven F. Hanft
Clearance Officer, Legal Division
Federal Deposit Insurance Corporation
Room MB-3046
55017th St, N.W.
Washington, DC 20429 Ms. Jennifer J. Johnson
Secretary
Board of Governors of the
Federal Reserve System
20th and CSt, N.W.
Washington, DC 20551 Office of Thrift Supervision
Information Collection Comments
Chief Counsel's Office
1700 G St, N.W.
Washington, DC 20552 Attention: 1550-0023 Re: "Consolidated Reports of Condition and Income"7100-0036 (Board)
"Consolidated Reports of Condition and Income" 3064-0052 (FDIC) Dear Ladies and Gentlemen: Citigroup appreciates the opportunity to comment on the proposal issued on April
29, 2004 by the Office of the Controller of the Currency, (the "OCC"), the Board
of Governors of the Federal Reserve System, (the "Board"), the Federal Deposit
Insurance Corporation, (the "FDIC"), and the Office of the Thrift Supervision, (the
"OTS"), to change and clarify the reporting requirements for certain securitized
loans that are 90 days past due and subject to seller buyback provisions under
the Government National Mortgage Association (GNMA) Mortgage-Backed
Securities Program. Citigroup supports the agencies proposal to record, on the issuer's books,
individual loans that meet GNMA's delinquency criteria based on the guidance
provided by FAS 140. However, we do not support the inclusion of these assets
in the body of the Past Due and Nonaccrual Schedule (RC-N and HC-N) if the
process for reimbursement is proceeding normally. Additionally, we do not
support the agencies proposal to classify these loans as Other Real Estate
Owned, "OREO". The current instructions to the Call and Y9C reports include a specific exemption
for assets repurchased under the GNMA buyout program. Citigroup supports the
current reporting requirements and sees no compelling reason to eliminate this
exemption. We believe that if this exemption were to be eliminated and these
loans classified as past due, the nonperforming schedule would be misleading
since it would misrepresent the underlying risks of these assets and their ultimate
collectibility by the issuer. Assuming that the process for reimbursement is proceeding under the
contractual guidelines set forth under the GNMA program, any losses on
defaulted loans underlying GNMA securities are borne by the FHA and VA, not
the issuer. Consistent with this view, Citigroup believes GNMA loans subject to
the buyback provisions, which are wholly insured or partially guaranteed by the
U.S. Government, should be presented separately from other defaulted loans on
Schedules RC-N and HC-N. To this end, we believe that the memoranda section
of Schedules RC-N and HC-N should be modified to include those loans that are
past due and wholly or partially guaranteed by the U.S. Government and that
they should not be included in the body of RC-N and HC-N.We believe this
presentation would more accurately reflect the true nature of these loans. Citigroup classifies property on which it has foreclosed on as OREO. The costs
and risks of working through the disposal of these properties are implicit to the
users of our financial statements. OREO is also subject to scrutiny from both
regulators and the investing public. The inclusion of properties acquired and held
by Citigroup under the GNMA buyout program would misrepresent the inherent
risks of this particular asset class, given the guarantee received under the
program. Based on the above, we do not support the proposal to include these
properties as OREO, but instead to classify them as other assets. Thank you again for the opportunity to allow us to express our view on this
important matter. Please feel free to contact us if you have any questions or need
additional information. Sincerely, William Gonska
Deputy Controller | 
