Citi - Community Development in the District of Columbia - March 2020 Banking, Capital Markets and Advisory
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Citi – Community Development in the District of Columbia March 2020 Banking, Capital Markets and Advisory
Contents Purpose of Response 2 History of Citibank in the District 2 Citibank’s Vision, Values and Goals 4 Citibank’s Community 14 Investment Act Rating istrict of Columbia D 19 Program Commitments Affordable Housing 19 Financial Literacy 22 Community Lending and Investment 25 Signature Partnerships 28 in Washington, DC 2019 Citi Visibility and Engagement 29 within Washington, DC
2 Banking, Capital Markets and Advisory
Purpose of Response
Pursuant to Sec. 404 of DC Law 13-308, the purpose of this document is for Citi, as a financial institution
providing goods and services to the Government of the District of Columbia (“DC Government”, “the
District”), to submit its community development plan stating the plans for meeting the credit and financial
services needs of the residents of the District, particularly in designated development areas.
History of Citibank in the District
As a city full of history and the nation’s capital, Citi will continue to support progress in Washington, D.C.
Citi’s partnership with the District spans nearly 120 years:
1900 1998
Citi set up special Washington, D.C. service to facilitate the Citi managed the successful introduction of the inaugural
issuance and retirement of notes by the bank’s correspondents. $266MM financing to the District of Columbia Water and
Sewer Authority, helping DC Water obtain strong bond ratings
1970s and establish its name in the municipal marketplace.
Citi Acquired Advance Mortgage Corporation, operating
offices in several states and Washington, D.C. with 40 percent 2006
of the mortgages serviced for minority homeowners. Citi launched Global Community Day, an annual volunteer
event spanning more than 90 countries.
1976
Citi financed bonds for the Washington Metropolitan 2009-2010
Transit Authority. Citi served as senior manager for the Metropolitan
Washington Airports Authority inaugural two issuances of
1991-1993 Dulles Toll Road revenue bonds — totaling over $1.3B — a
public-private partnership to extend DC’s Metrorail System to
Citi selected the District as one of three areas to offer
Dulles International Airport.
funding for its “Banking on Education” program that explored
innovative approaches to teaching below the college level.
2010-Present
1994 Citi continues to contribute growth in the District by
managing, underwriting, or directly purchasing bond offerings
Citi Foundation began investing in the District, helping
that finance capital improvement projects, create lower
households attain economic opportunity.
borrowing costs and invest in low- and moderate-income
1995 communities within DC.
Citi launched a pilot lending program with the U.S. Small
Business Administration headquartered in DC. The program
2011
Citi opened a flagship branch in Foggy Bottom, drawing on
was designed to identify creditworthy but underserved small
“smart banking” technologies pioneered by Citi in Asia.
businesses and provided them with SBA-backed loans.
1998 2011
The DC Office of Finance and Treasury named Citi as one
Citi helped finance a public-private partnership that
of its two main cash management banks. Through this
allowed the new Marshall Heights Community Development
contract, Citi provides a wide variety of banking services
Corporation (CDC) headquarters in DC to consolidate its
to nearly 20 District agencies.
community programs under one roof.
Citi – Community Development in the District of Columbia | March 2020 3
1900 — 2019
2012 2014
The DC Department of Employment Services tapped Citi Citi partnered with the DC Office of Tax and Revenue to
to develop a system of prepaid credit cards to replace its allow the District to issue tax refunds via debit card to over
reliance on paper checks. Citi processed unemployment 18,000 taxpayers.
insurance for District residents and payroll payments for
over 10,000 teenagers enrolled in the DC Summer Youth 2014
Employment Program each year. This “green” option saved
Citi Foundation selected DC as one of 10 cities in which to
the District an estimated $1.2MM per year.
inaugurate its Pathways to Progress initiative, providing
young people ages 16-24 with the opportunity to develop
2012 workplace skills and leadership experience.
Citi contributed to the Latino Economic Development Center, • 6,000+ low-income youths have been impacted within the
which makes over 100 loans annually to small and micro District since initiative conception
businesses in DC and the Greater Washington area.
• $4MM pledged to help young people in DC increase their
2012 employability at a time of high joblessness
Citi began serving as title sponsor of the Citi Open tennis
tournament, a tradition which has continued through present
2015
Citi began working with the DC Public Schools and the
day. A portion of the proceeds supports the Washington
Office of the State Superintendent of Education to establish
Tennis & Education Foundation, which benefits low-income
customized online payment portals for parents and guardians.
youth in the DC area, and the tournament is estimated to
provide over $28MM in economic impact to the Greater
Washington Area. 2015
Citi provided $26MM in financing for The Conway Center in Ward
2013 7, an area of DC experiencing high poverty and unemployment,
mixed-use property that brings together 182 units of affordable
Citi opened a new branch at Connecticut Avenue and K Street
housing, health care and social services in an innovative design.
in the heart of DC’s “Golden Triangle” business district. This
branch is outfitted with features including digital media walls
and is LEED certified. 2018
Citi financed over $172MM in loans for affordable housing units
2013 in DC — Woodmont Crossing, Abrams Hall and 555 E Street, SW.
Citi CEO Michael Corbat announced a grant to Capital Area
Asset Builders (CAAB), a DC-based community organization 2019
that helps low- and moderate-income individuals and families Citi financed over $18MM in loans for affordable housing for
improve their money management skills, increase savings and the Strand Residences in Ward 7 and Samuel Kelsey Section 8
build wealth by investing wisely. housing for seniors.
4 Banking, Capital Markets and Advisory
Citibank’s Vision, Values and Goals One profound implication of the widening income divide is
evident in our polarized politics. In so many places around
Our Company the world, political discourse — though never all that civil in
Citi works tirelessly to provide consumers, corporations, tone — has devolved into little more than a series of “I’m right
governments and institutions with a broad range of financial and you’re wrong” shouting matches. Compromise is seen
services and products. We strive to create the best outcomes as a sign of weakness, or worse, disloyalty. Not surprisingly,
for our clients and customers with financial ingenuity that talking over and past each other hasn’t led to much effective
leads to solutions that are simple, creative and responsible. action being taken to address the root challenges we face as
a society.
Our Mission
Citi’s mission is to serve as a trusted partner to our clients by Citi believes there is an opportunity for itself and others in the
responsibly providing financial services that enable growth private sector to lead a more constructive dialogue and work
and economic progress. Our core activities are safeguarding toward solutions. With that in mind, we consistently assess
assets, lending money, making payments and accessing the Citi’s role in response to three questions:
capital markets on behalf of our clients. We have 200 years 1. What are we doing to help create inclusive and resilient
of experience helping our clients meet the world’s toughest communities?
challenges and embrace its greatest opportunities. We are
Citi, the global bank an institution connecting millions of 2. H
ow can we use our voice to help drive dialogue toward
people across hundreds of countries and cities. solutions?
3. Is Citi walking the talk — are we doing the right things within
We protect people’s savings and help them make the our own firm?
purchases from everyday transactions to buying a home that
improve the quality of their lives. We advise people on how to The short answer to all three of these questions continues to
invest for future needs, such as their children’s education and be the same: that we can and should do more. Our mission
their own retirement, and help them buy securities such as of enabling growth and economic progress will never be
stocks and bonds. complete, but year after year, our firm keeps pushing itself in
the right direction. Internally, we have taken steps to mirror
We work with companies to optimize their daily operations, many of the changes we need to make as a society.
whether they need working capital, to make payroll or export
their goods overseas. By lending to companies large and In this report, you will find no shortage of big challenges —
small, we help them grow, creating jobs and real economic local, national, regional and global — described in daunting
value at home and in communities around the world. We detail. You will also find specific examples of the creative
provide financing and support to governments at all levels, solutions my Citi colleagues are continuously conceiving
so they can build sustainable infrastructure, such as housing, with our clients and communities to address them. Those
transportation, schools and other vital public works. challenges range from climate change, to the urgent need
for exponentially more infrastructure investment globally,
These capabilities create an obligation to act responsibly, to an affordable housing crisis in the U.S. that has widened
do everything possible to create the best outcomes, and even further a gap that disproportionately affects low-income
prudently manage risk. If we fall short, we will take decisive people and families and communities of color. That gap is a
action and learn from our experience. primary contributor to the economic inequality cited above
that pervades our society and our politics.
Global Citizenship
We strive to earn and maintain the public’s trust by constantly At Citi, we have learned that there are times when we need to
adhering to the highest ethical standards. We ask our take a stand when our values and mission are on the line. We
colleagues to ensure that their decisions pass three tests: were the first bank to announce a Commercial Firearms Policy
they are in our clients’ interests, create economic value, and in the U.S. that promotes responsible business practices
are always systemically responsible. When we do these things at the point of sale. We were the first firm to disclose our
well, we make a positive financial and social impact in the unadjusted pay gaps between women and men globally, and
communities we serve and show what a global bank can do. between minorities and non-minorities in the U.S.
Citi has a short list of high priority items, some specific to Citi We have also taken the UN Sustainable Development Goals
and others that extend beyond our firm. The widening income as guideposts and inspirations to continue to do more — as
gap in the U.S. and globally has ranked high on that list for much as we can. We believe we have a role to play across all
many years, and has risen even higher in recent years as we 17 goals, but can drive the greatest impact on seven: Gender
see new consequences of this fundamental division play out Equality; Affordable and Clean Energy; Decent Work and
all around us. Economic Growth; Industry Innovation and Infrastructure;
Sustainable Cities and Communities; Climate Action and last
but not least, Partnerships for the Goals.
Citi – Community Development in the District of Columbia | March 2020 5 Our Path to Economic Progress At Citi, we take action to effect positive and meaningful change in our communities. Read our full 2018 Global Citizenship Report for a comprehensive view of our Citizenship priorities. How We Do Business Responsible business: Named “World’s Bets Bank for Corporate Responsibility” by Euromoney and “Most Innovative Investment Bank for CSR” by The Banker Human rights: Updated our Statement on Human Rights to include emerging areas of concern, such as privacy rights and the risks associated with climate change and modern slavery Prioritizing safety: Issued US Commercial Firearms Policy that outlines requirements and best practices for the sale of firearms Disclosing climate risks: First major US bank to release a climate disclosure report in response to the Task Force on Climate-related Financial Disclosures recommendations Closing the gap: First in the industry to disclose an adjusted gender pay gap among the global workforce Valuing diversity: Set representation goals for black talent in the US and female talent globally to increase representation across all levels of the firm Volunteering in communities: Celebrated annual Global Community Day, when 100,000+ Citi volunteers participated in projects in 450+ cities across 90 countries 24%: Citi’s checkless, low to no fee Access Account now makes up 24$ of all newly opened accounts 440,000 clients of minority-owned banks and credit unions in the US received fee-waived access through the Citi ATM Community Network $24.4 billion in renewable energy projects financed globally (cumulative $61.3 billion 2014-2018) 80+ cities engaged in implementing municipal innovation projects with support from the Citi Foundation “We Are Still In” First major US bank to join with 2m000+ businesses and investors in signing the We Are Still In declaration in support of the Paris Climate Agreement $76 million in charitable giving through Citi businesses and $78 million by the Citi Foundation Investing in youth: $49 million invested globally by the Citi Foundation through its Pathways to Progress program to prepare youth for 21st century jobs Creating affordable housing: Provided more than $6 billion in loans for affordable housing projects in the US, making Citi the largest affordable housing lender for the 10th consecutive year
6 Banking, Capital Markets and Advisory
Addressing the Affordable Housing Crisis Meeting the Challenges of Urbanization
Citi Named the Largest Affordable Housing Lender As cities become more crowded and expensive, the structures
for the 10th Year in a Row that inject them with history and character are being replaced
or running into obsolescence. There’s also a human toll: The
For the 10th consecutive year, Citi was named the largest
people who make cities tick — teachers, firefighters, waiters,
affordable housing lender in the U.S., according to
social workers, working parents — are getting priced out,
Affordable Housing Finance (AHF) Magazine’s annual survey
along with older residents with limited income who struggle
of affordable housing lenders. In 2019, Citi Community
to keep the houses and apartments they’ve lived in for years.
Capital, the bank unit through which Citi works to finance
Fortunately, these two parallel challenges — an abundance
all types of affordable housing and community development
of empty buildings and an upsurge in people seeking an
projects, reported over $6 billion of lending to finance
affordable place to live — yield a symbiotic solution. If there
affordable rental housing projects. Citi has helped create or
are former offices, factories, and dormitories sitting empty
preserve nearly 488,000 affordable housing units over the
with ample space and solid bones, why not restore them into
past decade by partnering with developers, non-profits and
housing units that don’t break the bank?
local governments.
It’s a big challenge that requires big ideas, but as the largest
“A shortage of quality, affordable housing is a major
affordable housing lender in the United States, we’re doing
challenge for millions of Americans,” said Mike Corbat, Chief
our part. Our work in this area also includes our goal to not
Executive Officer of Citi. “As the largest affordable housing
only meet, but exceed, our obligations under the Community
lender in the country for the past decade, we’re addressing
Reinvestment Act. Recognizing the importance of vibrant
this challenge by working with a wide range of partners
and diverse populations, Citi is proud to support efforts that
helping to stabilize communities and ensuring greater access
provide housing opportunities for a wide range of people.
to housing. This recognition is a culmination of efforts by
many people and organizations on the ground, and we are
committed to building on our record.”
Total lending and investing by Citi Community Capital in 2019 was over
$6.6 billion in affordable housing, mixed use and commercial development,
healthcare and small business across 200 U.S. cities.
Citi – Community Development in the District of Columbia | March 2020 7
Old Buildings, New Beginnings, Valuable Opportunities
Citi has supported several initiatives over the past year that
provide affordable housing and sustain the unique character
of America’s cities.
In Washington, DC — We’re providing financing for Abrams
Hall Senior Apartments, 80 affordable apartments for
seniors on the campus of the former Walter Reed Army
Medical Center. The project, which was lauded by DC Mayor
Muriel Bowser, reflects the spirit of the structure, which was
built in 1976 as barracks housing for soldiers living semi-
independently while receiving medical care. “We’re able to
take something that was an important part of our history
and turn it into something that will live on forever,” said
Barry Krinsky, a Director at Citi. “It’s just the first piece of
what’s going to be the ultimate redevelopment of this entire
neighborhood.” Indeed, the project is the first of many at
Preserving Affordability Through Community
Walter Reed that will provide more affordable housing units
Land Trusts
for veterans and seniors.
A half century after the Fair Housing Act was passed to boost
Thousands of miles west, in Denver, CO, Citi is supporting the access to housing opportunities for all U.S. residents, the
construction and permanent financing of 49 affordable senior entry point for homeownership is only getting higher. While
housing units in Tammen Hall, a building that was constructed housing prices have risen across the country, real median
in the 1930s and sat vacant for the past 10 years. A stately household income has remained stagnant, pushing many
brick building that is on the National Historical Register, families out of the neighborhoods they have long called home.
Tammen Hall was initially used as a dormitory for nursing
staff and later used for medical offices. Now the renovated Citi has zeroed in on a proven tool for creating and preserving
building will serve as a safe, comfortable place for older affordable housing: community land trusts (CLTs). A CLT is a
Denver residents to live with dignity — replete with a workout nonprofit organization that buys land to build permanently
studio, library and a rooftop patio. affordable housing for low-income households. Under this
model, the CLT places a cap on resale and rental prices to
Succeeding with A Business-Minded Approach maintain affordability over the long- term, even as property
prices in the area increase. This enables renters to access
Citi dedicated over $6 billion in financing in 2018 and stable, affordable housing while those able to buy can build
countless hours to affordable housing projects because, equity and accrue other benefits of homeownership. Citi
quite simply, we want to generate a positive return from each has invested approximately $5 million in seeding new CLTs
one. Citi treats affordable housing like any other investment in Washington, D.C., New York City, Long Island and Miami,
area, deploying a wide range of experienced professionals among other locations in the U.S. A new initiative — the Citi/
— including underwriting staff, a credit committee, and Grounded Solutions Network CLT Accelerator — is propelling
bankers with local expertise — to identify the best possible the growth of CLTs and other shared-equity programs. With a
rehabilitation projects, execute them with efficiency and $1 million investment from Citi, Grounded Solutions Network
professionalism, and ensure they will be fruitful both for will scale up the sector and increase access to permanently
Citi and a building’s new residents. Citi is proud to use our affordable homeownership for low-income, first-time
experience and industry-leading skills to protect cherished homebuyers. In 2018, Grounded Solutions held a competitive
structures and help individuals stay in the places they call review process to select three Accelerator Fund recipients.
home. And although there has been good progress to date, Together, Citi and Grounded Solutions Network are providing
Citi is just getting started — and can’t wait to help reignite technical assistance and investing $500,000 in capital grants
more flames (literal or otherwise) across the nation. to existing high-capacity CLTs and similar shared equity
homeownership programs that hold the potential to transform
the lives of low-income households.
8 Banking, Capital Markets and Advisory
Bringing Veterans Home Ample Resources for a Critical Battle
We partner with organizations working to end the problem Citi’s support of Hornsea 1 and other environment-focused
of veteran homelessness. On any given night in America, an projects reflects the company’s belief that the private sector
estimated 37,000 veterans are homeless. Since 2012, Citi has a critical role to play in addressing climate change. As sea
has supported the Bring them HOMES initiative by the Local levels rise, temperatures increase and droughts worsen, there
Initiatives Support Corporation (LISC) and its investment is a need for all-hands-on-deck urgency around the world.
affiliate, the National Equity Fund, which finances, facilitates,
advocates for and implements affordable housing options Citi is well-positioned to respond with a full service suite
for veterans. To date, a total of 4,300 affordable housing of products and services. With extensive partnerships and
units, including 3,000 specifically for veterans, have been engagements between different teams, Citi is able to fulfill
completed or are in development. the array of our clients’ needs from managing financing, to
lending and advising, amongst other activities.
Fighting Climate Change
Not all world records are cause for celebration. According At the heart of Citi’s efforts is the $100 Billion Environmental
to the National Oceanic and Atmospheric Administration, Finance Goal, which includes financing activity that
the last four years have been the hottest on record. This supports renewable energy, water quality and conservation,
statistic — along with countless others telling a similar story sustainable transportation, green building, energy efficiency,
— emphasizes both the scope of climate change and the and clean technology.
immediacy of the problem.
Like all of Citi’s financing and investments, the transactions
Citi recognizes that to fight record-breaking problems, the that count toward this goal are risk-adjusted and designed
world needs record-breaking solutions. To that end, the to produce positive returns. This approach speaks to a
company has financed Hornsea 1, which will become the world’s consideration that is important to Citi, and should be
largest offshore windfarm once it’s completed in 2020. important to companies of all stripes: “Helping the bottom
line and helping the environment aren’t mutually exclusive
Located at the southern end of the North Sea, the 250 square exercises, they’re complementary — and they’ve never
mile, 174 turbine windfarm will have a total capacity of 1,218 been more important,” said Val Smith, Citi’s Global Head of
megawatts and provide clean energy for more than one Corporate Sustainability.
million UK homes.
A Positive Global Footprint
To make the financing a reality, many aspects of Citi’s
business were brought to bear for a transaction of As a global company, Citi has the resources and geographic
unprecedented scale. Having executed four transactions reach to pursue such a wide range of initiatives and work with
for Ørsted in the last five years, the bank utilized its strong an array of partners. We see climate change as a pressing
relationships with the client and institutional investors to global issue, where thoughtful engagement and action are
facilitate the necessary financing for Hornsea 1. Citi acted as needed from not only businesses, but governments and other
co-debt financial advisor, co-placement agent and sole export key stakeholders. Citi recently acted as joint bookrunner and
credit agency arranger to Ørsted and Global Infrastructure billing and delivery on the Republic of Poland’s €2 billion
Partners on the £3.6 billion debt financing — the largest ever dual-tranche green bond offering, formed of 10- and 30-year
project financing in the global renewables sector. Citi also tenors — the latter being the longest ever green bond issued
served as exclusive sell-side advisor to Ørsted. The Hornsea 1 by a sovereign.
transaction followed on the success of another project in the
In San Patricio County, TX, Citi provided comprehensive
region, Walney Extension, where Citi served as exclusive M&A
financing — including a construction loan, long term tax equity
financial advisor, co-structuring bank and placement agent
financing, agency and trust services, and the energy hedge
for the then largest investment grade holdco project bond for
— behind the 163 megawatt Midway Wind Project. In addition
a greenfield offshore wind project.
to providing this full service, one-stop-shop approach to help
“Both the Walney Extension and Hornsea 1 transactions are develop this project, Citi is also purchasing energy from this
a testament to Citi’s commitment to renewable energy,” said project to contribute to Citi’s goal to power its global facilities
Rapheal Mun, Director, EMEA Project and Infrastructure with 100 percent renewable energy by 2020.
Finance, Citi. “We remain at the forefront of bringing
innovative solutions to clients to raise debt capital to finance
their clean energy projects.”Citi – Community Development in the District of Columbia | March 2020 9
Strengthening a Vital Commitment climate-related risks and opportunities. This mission reflects
that of Citi’s Sustainable Progress Strategy, which focuses
Underscoring Citi’s view that global warming is a genuine on reducing climate change impacts and creating innovative
crisis and not a political issue, the company remains a strong solutions to help the environment — all in concert with our
supporter of the Paris Agreement. To that end, Citi recently clients and other stakeholders.
signed the We Are Still In declaration in partnership with
businesses, investors, state and city governments, and other Citi collaborates with a wide range of partners across the
organizations that are advocating for climate policy solutions. globe by diversifying its efforts to combat climate change,
and is well-positioned to contribute to and learn what
Citi also supports the Task Force on Climate-related works to best target its efforts to make a positive impact.
Financial Disclosures (TCFD), and has responded to their When it comes to climate change, the time for concerned
recommendations in a recent report, Finance for a Climate- proclamations has given way to a need for immediate action,
Resilient Future. The TCFD works to improve the way that and Citi is proud to be fighting the problem with optimism,
companies analyze and disclose the financial impacts of serious energy, and an ever expanding stable of allies.10 Banking, Capital Markets and Advisory
Reducing Youth Unemployment Building Crucial Connections
For a young person, a lot goes into landing a first job. When not focused on his day job as a cyber intelligence
A strong resume, relevant experience, good interview analyst at Citi, Matt Goldberg makes time to volunteer
technique — having these components is challenging enough. through iMentor, which pairs high school students from low-
Sometimes, though, the right relationships can make all the income backgrounds with trained professional volunteers who
difference. Building a strong network can open opportunities mentor the young people on their college and career goals.
for young people as they launch their careers, provide good
models for how to approach the world of work, and encourage Matt has been working with his mentee for two years and
their aspirations. has been struck by how similar his high school path is to his
mentee, who is now a sophomore and feeling the pressure
Unfortunately, professional networks can be hard to come by and demands of school and early adulthood. “I remind him to
for young people, particularly when they are from low-income keep it simple and just focus on doing the best he can in all his
backgrounds or are the first in their families to pursue higher classes,” Matt says. “I remember being in his shoes, feeling
education. This isn’t an isolated challenge facing a few, but all the demands of school, family, activities and all, and just
a reality facing far too many. The youth unemployment rate wanting to retreat. He takes a deep exhale and I can tell he
around the world is three times higher than that of adults, appreciates that reminder.”
with 67 million young people looking for work.
These are the type of one-on-one connections between young
There is also a bright side. According to Citi Foundation people and experienced professionals that the Citi Foundation
research surveying young people across 32 countries, more thinks can help make a difference. With $2.5 million in support
than 70 percent of young people today feel optimistic about from the Citi Foundation, iMentor is supporting tens of
their career prospects despite profound uncertainty and thousands of students in major cities across the U.S. to build
change across the globe. The study also found that three out relationships with people like Matt and expand their networks.
of four respondents are willing to take risks to achieve their
career aspirations. The Global Implications of Individual Opportunities
It’s clear that there is more work to be done to harness Matching motivated young people with professional training
this enthusiasm by equipping the world’s youth with the and job opportunities can yield some big moments on a small
skills, opportunities and relationships they need to succeed. scale. Perhaps it’s a 22-year old who gets to tell her parents
Through its three year, $100 million Pathways to Progress about her first-ever job offer, or the 18-year old entrepreneur
commitment, the Citi Foundation is aiming to connect who never believed he could create his own job by turning his
500,000 young people around the world to jobs, paid passion into his own small business.
internships, workforce training and leadership development
by 2020. In the first two years, over 400,000 young people “When young people believe in themselves, their ability to
across more than 80 countries have been given tools to advance personally and professionally is that much greater,”
succeed in today’s economy, including access to professional said Brandee McHale, Head of Corporate Citizenship at
networks and role models for the more than 210,000 young Citi and President of the Citi Foundation. “The relationship
people mentored. with a mentor isn’t just about building skills but also
building aspirations.” These opportunities can also have
bigger implications. For Citi — and the many companies,
organizations and individuals we serve — to succeed, young,
underserved populations need opportunities to thrive. Their
success can mean greater availability of talented young
professionals for the workforce — regardless of industry.
Yet, the youth workforce shouldn’t be viewed simply as a pool
of talent; it’s a rising tide that lifts the professional world as a
whole. Viewed with that lens, it’s clear just how important it
is to provide the world’s youth with the resources — both the
skills and the connections — necessary to make their way up.Citi – Community Development in the District of Columbia | March 2020 11
Increasing Diversity in Finance To that end, the company’s goal is for its analyst and associate
programs to comprise 50% women globally, and 30% black
The best kind of progress is rarely made quickly. Lasting,
and Hispanic/Latino hires in the U.S. The rationale is simple but
positive change — whether pursued by an individual, an
powerful: in order to establish a sustainable, diverse future for
organization, or an entire industry — stems from a sustained,
the firm, Citi must get it right at the entry level.
long-term effort rather than flipping a switch.
One way Citi hopes to achieve its goals is by expanding the
It’s an important concept to consider when approaching the
Citi Ventures CUPID (Citi University Partnership in Innovation
problem of lack of diversity in the global financial industry. The
and Discovery) Program to work with over 20 universities
stark truth is that women and non-white professionals make up
globally on innovation projects within Citi, engage talented
a disproportionately small percentage of the industry.
women and underrepresented minorities, and develop a
Today, Citi’s workforce is in line with the rest of the industry robust pipeline of talent.
when it comes to female and non-white representation. That
In 2018, the company expanded its partnerships to historically
said, the company is instituting several goals and initiatives
black colleges and universities (HBCUs) with the CUPID launch
aimed at developing a more diverse workforce. There’s a long
at Howard University, one of the most storied HBCUs in the U.S.
way to go, but Citi is working hard to lay the groundwork for
real progress.
Making Citi a Better Place to Work — For All
Setting Clear Objectives Bringing in a diverse set of new faces is a critical goal for
Citi, but it’s just as important for the company to retain
As with all challenging, necessary efforts, this one starts with
those talented individuals. That’s why, at every level of
establishing specific goals.
the company, Citi is exploring ways to engage with high
In August 2018, Citi identified two important aspirations to hit performing talent (outside of bi-annual development
by 2021: on a global level, increase representation of female conversations) and expanding our development programs.
Assistant Vice Presidents (AVPs) through Managing Directors
The financial services industry as a whole has to significantly
(MDs) to 40%; and in the U.S., increase representation of
increase efforts to attract, develop, and retain the right
black AVPs through MDs to 8%. Achieving these goals will
balance of talent across organizations.
allow Citi to make meaningful progress in the mission to be
more representative of the communities it serves. To help bridge that gap at the entry levels, Citi has established
an Early Career steering committee to understand and
Building Progress from the Ground Up
address concerns of female and minority analyst and AVP-
Attracting a wide range of candidates at the middle and level employees. The company also implemented unconscious
senior levels is an important consideration, but Citi also bias training for 35,000 employees in-person — as a
recognizes the value of building a diverse employee base at complement to online inclusive leadership training that over
early career levels. Indeed, without a steady stream of diverse 80% of the workforce has completed.
talent entering its doors, the company will not see the sort of
representation it’s seeking at all levels.12 Banking, Capital Markets and Advisory
Closing the Gap The numbers stress the importance of increasing
representation of females and U.S. minorities in senior and
In an effort to be transparent and spark an important higher paying roles at Citi.
conversation, Citi recently became the first U.S. company to
disclose its unadjusted median pay gap — the simple difference Building Momentum, Effecting Change
between median pay for all female employees, compared to
median pay for all male employees at Citi (as well as median Citi — along with every other large financial company — will not
pay for U.S. minorities compared to U.S. non-minorities). reach its diversity goals overnight. That said, the company
has set a range of important, realistic objectives, and has
The review found that the median pay for females globally several efforts underway to reach them.
is 71% of the median for men, and the median pay for U.S.
minorities is 93% of the median for U.S. non-minorities.Citi – Community Development in the District of Columbia | March 2020 13
LGBT+ Equality and Rights Indeed, supporting gender equality and removing barriers to
entry into the workforce for women can improve the world in
In late 2018, Citi joined other companies in signing the Human
powerful, sustainable ways. With this mission in mind, Citi is
Rights Campaign’s Business Statement on Transgender
working to level the playing field so that women around the
Equality. Citi was proud to reaffirm its commitment to
globe are better equipped to pursue financial opportunities
stand with the millions of people in America who identify as
and benefit everyone in the process.
transgender or gender non-binary, or who are intersex. Through
this public demonstration of support, Citi aims to encourage
Providing Direct Opportunities
others to treat this community with respect and dignity.
While women wield considerable financial influence around
In the summer of 2018, Citi initiated a new global badging
the world, they fall behind when it comes to receiving
policy to enable transgender colleagues to more easily
corporate contracts. In fact, recent Citi research found that
change the name reflected on their Citi identification badge.
only 1% of corporate procurement contracts globally are
In addition, the company expanded demographic questions
awarded to women-owned businesses. To help correct this
on sexual orientation and gender identity in our Voice of the
stark imbalance, the company recently joined forces with
Employee survey to 39 countries, reaching 82 percent of its
WeConnect International — a global nonprofit that connects
employee base. Responses to these voluntary questions will
women-owned businesses to qualified buyers around the
allow the company to better understand the experiences of
world — and three other leading corporations. This coalition
all LGBT+ colleagues. Citi also expanded insurance and other
committed to procure $100 million each from women-owned
benefits available under its U.S. policies to LGBT+ partners
businesses over the next three years (with a particular focus
globally wherever the benefits are legal and permitted
on companies in developing markets). In 2018, we procured
under local law. In addition to designating a spouse through
$185 million from women-owned businesses.
marriage or civil partnership, employees are able to designate
a “partner,” of any sex, as an eligible family member. Citi Spurring Entrepreneurship Worldwide
recognizes that employee benefits are critical to ensuring
equality and mobility for its colleagues. To help empower women entrepreneurs, Citi has worked
with the Washington, DC-based company Overseas Private
In Northern Ireland, where Citi is one of the largest Investment Corporation (OPIC) through a risk-sharing
employers, with approximately 2,800 people located in program to provide over $495.5 million in financing to 53
Belfast, the company joined with other companies to support inclusive businesses in 26 countries, reaching over 1.3 million
the effort to legalize gay marriage in 2018. Northern Ireland entrepreneurs, 88% of whom are women.
is the only part of the UK that has not made gay marriage
legal. Citi was one of 29 companies that published a joint It’s a wide-ranging effort that’s generated significant results
statement for reform that acknowledged the importance of a at the local level. In Jordan, for example, Citi provided $5
diverse, outward-looking and inclusive society to creating a million equivalent in local currency financing to enable one
prosperous future for Northern Ireland. of the country’s leading microfinance institutions, Microfund
for Women (MFW), to provide loans to an additional 10,000
Enabling Financial Independence for Women underserved Jordanian women — increasing their number
There are many reasons why the right thing to do is, well, the of borrowers by 7% and providing real economic benefits to
right thing to do. their families and communities.
Take, for example, working towards economic equality for Additionally, the Citi Foundation supports Poland’s Foundation
women. There are countless moral and ethical reasons to for Women’s Entrepreneurship, which provides high-potential
tackle the systemic challenges that face half the world’s female entrepreneurs in Warsaw with access to intensive
population: a lack of access to high quality training and business training, one-on-one mentorship, access to office
education, disparities in pay, societal norms regarding women space, business networking meetings and technical assistance
in the workplace and the home, and the impact of automation to properly design, manage and scale their companies.
on the overall labor market.
A Long-Term Commitment to a Crucial Effort
Then there are the economic reasons. Consider that women
control $28 trillion of the $35 trillion global consumer market, Achieving economic equality around the world is undoubtedly
and, according to Citi, if women matched men in terms of a massive challenge. Nevertheless, Citi is working hard to
average amount of labor force participation, hours worked, support programs that provide information, resources, and
and labor productivity, OECD GDP could go up by anywhere funding to help women make a positive economic impact in
from six to 20 percent. their communities.14 Banking, Capital Markets and Advisory
Citibank’s Community Investment
Act Rating
Overall CRA Rating
Institution’s CRA Rating
This institution is rated Satisfactory. The following table indicates the performance level of Citibank, N.A. with respect to the
Lending, Investment, and Service Tests:
Citibank, N.A.
Performance Tests
Performance Levels Lending Test* Investment Test Service Test
Outstanding X X X
High Satisfactory
Low Satisfactory
Needs to Improve
Substantial Noncompliance
* The Lending Test is weighted more heavily than the Investment and Service Tests when arriving at an overall rating.
The major factors that support this rating include:
• CBNAs overall Lending Test performance is excellent.
• CBNAs overall Investment Test performance is excellent.
• CBNAs overall Service Test performance is excellent.
• Notwithstanding the bank’s otherwise excellent performance levels, evidence of discriminatory or other illegal credit practices
resulted in lowering the overall CRA Performance Evaluation rating to “Satisfactory.”
Executive Summary The bank violated the Truth in Lending Act by failing to
reevaluate and reduce the annual percentage rates for certain
Discriminatory or Other Illegal
consumer credit card accounts, which adversely impacted
Credit Practices
approximately 1.8 million credit card accounts in an amount
Evidence of discriminatory or other illegal credit practices totaling approximately $357 million.
resulted in lowering the overall CRA Performance Evaluation
rating to “Satisfactory.” Without the evidence of the practices The bank also violated the Consumer Financial Protection Act
discussed in the Discriminatory or Other Illegal Credit Practices of 2010, the law prohibiting unfair, deceptive, or abusive acts
section of this document, the overall CRA Performance or practices, in a matter involving altered affidavits filed in
Evaluation rating would have been “Outstanding.” debt collection lawsuits by law firms retained by CBNA and its
affiliate, Department Stores National Bank. The New Jersey
The bank violated the Fair Housing Act through its Superior Court approved a settlement for both banks which
Relationship Loan Pricing program, which adversely impacted involved customer refunds totaling approximately $11 million,
approximately 24,000 consumers in an aggregate amount dismissal of all 6,738 pending cases, and forgiveness of debts
of approximately $24 million. The bank paid a civil money totaling nearly $34 million.
penalty of $25 million as a result of this violation.
In addition, the OCC has considered information that was
made available to the OCC on a confidential basis during
its consultations.Citi – Community Development in the District of Columbia | March 2020 15
Lending Test outside of the bank’s AAs. This includes broader statewide
and regional areas that total $707 million in current and prior
Overall lending performance during the evaluation period
period investments which further supports the overall excellent
is excellent.
investment performance of the bank.
Overall lending performance in the rating areas generally
Service Test
ranged from good to excellent, with excellent performance in
the New York-New Jersey MMSA (NY-NJ MMSA) as well as the CBNA’s overall service performance is excellent.
states of California, Florida and Illinois, the four largest rating
areas. Together these areas represent 80.4 percent of total The bank’s branches and alternative delivery systems were
bank lending considered in all rating areas and 87.7 percent of readily accessible to geographies and individuals of different
the bank’s adjusted deposits. income levels in the bank’s major markets. Performance was
considered good to excellent in all of the AAs.
Excellent lending activity levels were evident in all of the
full-scope assessment areas (AA), with small loans to During the evaluation period, the bank exited or scaled back
businesses market shares and rankings exceeding deposit their retail presence in several markets. On a net basis,
market share and rankings. Home mortgage market share CBNA closed and/or sold 300 branches, primarily in Texas,
and rankings were good to excellent, given the strong the NY-NJ MMSA, California, Massachusetts (Boston), and
competition from both deposit and non-deposit taking lenders Pennsylvania (Philadelphia MMSA).
in many of the bank’s major markets. Both geographic and
Community development services were effective and
borrower distribution of both home mortgage and small
addressed community needs in all AAs.
loans to businesses were good to excellent in almost all of
the full-scope areas. Weaker, but still considered adequate,
geographic distribution of home mortgage loans was noted Washington-Arlington-Alexandria,
in the Philadelphia MMSA, Florida, New Jersey (outside of the
MMSA), and Texas rating areas.
DC-VA-MD-WV
Community development (CD) lending was significantly CRA rating for the DC MMSA2: Outstanding
strong in most AAs, which in turn had a significantly positive CRA rating for the DC MMSA : 2
Outstanding
impact on lending performance in those rating areas. CBNA
The lending test is rated: Outstanding
originated over $20 billion in CD loans, including those
made in the broader statewide and regional areas. Another The investment test is rated: Outstanding
$627 million in letters of credit, primarily in New York, were The service test is rated: Outstanding
issued to support CD projects. Letters of credit provide a
valuable credit enhancement necessary for many CD projects The major factors that support this rating:
to be viable. Without these letters of credit, many needed
• The level of lending activity, geographic distribution of
CD projects would not have been completed. Throughout
the bank’s home mortgage, small loans to businesses, and
the evaluation period, CBNA retained the top ranking in
borrower distribution of the bank’s home mortgage and
Affordable Housing Finance magazine’s annual survey of
small loans to businesses is excellent;
affordable housing lenders.
• Community development loans and flexible loan programs
Investment Test offered were effective in addressing community credit needs;
CBNA’s overall investment performance is excellent and • Qualified investments were effective and responsive in
responsive to the needs of the communities. In many of addressing community credit needs. The bank made a
the AAs, the bank took a leadership role in developing and significant number of investments, grants, and donations
participating in investments that were large, complex and under its programs;
involved multiple partners with both public and private funding.
• The bank’s branches and alternative delivery systems
The bank has continued to be a long-term provider of capital, were effective and responsive in helping the bank provide
which positively affected low- and moderate-income (LMI) services across the community; and
communities and residents. Excellent performance is evident
• CBNA is a leader in providing CD services. CD services were
in the nearly five thousand investments, grants, and donations
effective and responsive in addressing community needs.
totaling $8.6 billion made during the evaluation period in its
The bank conducted or supported a significant number of
AAs. Another $1.4 billion of CD investments from prior periods
CD services, consistent with its capacity and expertise to
remain outstanding and continue to support identified needs.
conduct specific activities.
CBNA also made numerous CD investments that benefit areas16 Banking, Capital Markets and Advisory
Description of Institution’s Operations in the DC MMSA CBNA ranked eighth in deposits of 84 institutions with 3.5
percent market share. In small loans to businesses, CBNA
The bank has delineated two AAs within the DC MMSA. The
ranked second with 18.4 percent market share. The top
Washington, DC AA contains the District of Columbia; Charles
lender was American Express with 23.1 percent market
and Prince George’s counties in Maryland; Arlington, Fairfax,
share. Costco accounted for 35.1 percent of the reported
Loudon, and Prince William counties in Virginia, and the
small loans to businesses.
independent cities Alexandria City, Fairfax City, Falls Church
City, Manassas City, and Manassas Park City in Virginia. The In overall HMDA lending, CBNA ranked 13th with 1.7 percent
Silver Spring AA consists of Montgomery County in Maryland. market share. While the bank’s mortgage lending market
share is lower than the bank’s deposit market share, this is
CBNA had $7.9 billion of deposits in the DC MMSA,
a highly competitive market with 780 home lenders and 84
representing 3.5 percent of adjusted deposits and ranked
depository institutions. The top three lenders in this market
eighth with 3.5 percent market share
were Wells Fargo Bank (9.3 percent), SunTrust Bank (5.2
The MMSA is a high-cost housing area, limiting access to percent), and Quicken Loans (3.6 percent).
affordable home ownership among LMI borrowers. The
Distribution of Loans by Income Level
median housing value in the MMSA is $448,749 while the
of the Geography
NAR 4Q2016 median sales price of a single family home
is $390,600. One simplistic method used to determine Home Mortgage Loans
housing affordability assumes a maximum monthly principal Based on the data in Tables #2, 3, 4, and 5 and performance
and interest payment of no more than 30 percent of the context considerations, we concluded the geographic
applicant’s income. Assuming a 30-year mortgage with a 4.5 distribution of the bank’s home mortgage loan originations
percent interest rate, and not accounting for down payment, and purchases is excellent.
homeowners insurance, real estate taxes, or any additional
monthly expenses, a low-income borrower making $53,599 The proportion of loans in both LMI geographies is stronger
per year (or less than 50 percent of the FFIEC adjusted than the proportion of owner-occupied housing units in those
median family income in the AA) could afford a $227,751 geographies and the aggregate distribution of loans.
mortgage with a payment of $1,340 per month; a moderate-
income borrower earning $85,759 per year (or less than 80 Small Loans to Businesses
percent of the FFIEC adjusted median family income in the Based on the data in Table #6 and performance context
AA) could afford a $364,403 mortgage with a payment of considerations, we concluded the geographic distribution
$2,144 per month. of the bank’s originations and purchases of small loans to
businesses is excellent.
Scope of Evaluation in the DC MMSA
The two AAs within the DC MMSA were combined in After adjusting for Costco, the proportion of loans in both LMI
evaluating performance under each test. geographies was stronger than the proportion of businesses
located in those geographies and the aggregate distribution
To understand the credit and community development needs of loans. As noted earlier, the Costco loans were acquired
in the area, OCC representatives met with 12 community- near the end of the evaluation period and accounted for 35.1
based organizations during two listening sessions. percent of the business loans in this AA.
Participants noted a need for affordable housing, capital
access for new entrepreneurs, and workforce development. Distribution of Loans by Income Level
of the Borrower
Conclusions with Respect to Home Mortgage Loans
Performance Tests in DC MMSA Based on the data in Tables #8, 9, and 10 and performance
context considerations, we concluded the borrower
Lending Test distribution of the bank’s originations and purchases of home
Lending Activity mortgage loans is excellent.
Based on the data in Lending Volume Tables #1 and Although the proportion of loans is weaker than the
performance context considerations, we concluded lending proportion of low-income families, the bank achieved 56
activity is excellent. The bank originated a significant volume percent of the demographic comparator, given the high cost
of loans in the AA relative to its capacity based on deposits, of housing within the AA. Additionally, the bank significantly
competition, and market presence. exceeded the aggregate distribution of loans. The proportion
of loans to moderate-income borrowers was stronger than
both the proportion of moderate-income families and the
aggregate distribution of loans.Citi – Community Development in the District of Columbia | March 2020 17
Small Loans to Businesses The investments and grants reflect excellent responsiveness
to the needs identified in the AA, including affordable
Based on the data in Table #11 and performance context
housing, small business development, and financial literacy
considerations, we concluded the distribution of the bank’s
for LMI persons. A majority of the bank’s CD investments
originations and purchases of small loans to businesses by
focused on affordable housing, which is a key issue in the AA.
revenue is excellent.
One example includes:
After adjusting for Costco, the proportion of loans was
comparable to the percentage of small businesses. The • CBNA made an $18 million NMTC investment to finance the
proportion of loans to small businesses was significantly construction of a mixed-use commercial redevelopment of a
stronger than the aggregate distribution of loans. distressed area in Southeast Washington, DC. The project is
expected to include 5.5 million square feet of retail, housing,
Community Development Lending
office, and civic use space spread across 25 buildings and
Based on the data in Table #1 and performance context 48 acres. It is estimated that 1,400 housing units will be
considerations, we concluded community development created, of which 20 percent will be affordable to persons
lending is excellent. earning 50 percent of AMI. It is also estimated that 7,700
jobs will be created. The project was complex and involved
CBNA originated 48 loans totaling $750.8 million or 66.7
both public and private funding and multiple parties.
percent of allocated Tier One Capital and which were
responsive to area needs. Service Test
Examples include: Retail Banking Services
Based on the data in Table #15 and performance context
• CBNA financed a $24.6 million mortgage loan to two
considerations, we concluded the bank’s retail service
nonprofits to finance the acquisition and renovation of
performance is excellent.
a 223-unit multifamily project in Washington, DC. Under
an agreement, the nonprofit developers maintained the The bank’s branches and alternative delivery systems were
affordability of the property. effective and responsive in helping the bank provide services
• CBNA provided $28 million loan financing to a district across the community. The bank had a significant number
governmental housing agency, which in turn, funded a of branches and ATMs, reflected in Table #15, in LMI areas
multifamily apartment project consisting of 223 affordable compared to the population distribution. The bank was
housing units. Forty-four of the units are restricted to able to demonstrate that alternative delivery systems are
tenants earning up to 30 percent AMI, 17 units are restricted an effective method of providing banking services to LMI
to 40 percent AMI, 82 units are restricted to 50 percent households when compared to the delivery of the same
AMI, and 80 units are restricted to 60 percent AMI. services to MUI households.
Product Innovation and Flexibility The opening and closing of branches, reflected in Table #15,
had limited impact on the delivery of service across the
Product flexibility was given positive consideration in the
community. During the evaluation period, CBNA opened one
overall Lending Test rating for the DC MMSA. CBNA originated
branch and closed eight branches. One branch was closed in
almost 1,800 loans totaling $520 million under its affordable
a low-income geography and three branches were closed in
mortgage product programs that are noted earlier in the
moderate-income geographies. Seven of the branches were
“Other Information¨ section of this evaluation. FHA and VA
in distant suburbs in relation to market. The branches were
loans accounted for the large majority of the number of loans
below market averages for deposits and profitability at the
originated under all programs.
time of the closure.
Investment Test
The bank offered innovative or flexible deposit products and
Based on the data in Table #14 and performance context
retail services that were effective in addressing community
considerations, we concluded the bank’s qualified investment
needs. The bank opened a significant number of accounts
performance is excellent.
under these programs. CBNA opened nearly 8,000 Access
Qualified investments were effective and responsive in Accounts, 3,000 Youth Savings Accounts, and processed
addressing community credit needs. The bank made a 3,500 transactions through the Citi ATM Community Network.
significant number of investments, grants, and donations
under its programs.
The combined current and prior period investment dollar
volume represent 35.6 percent of allocated Tier One Capital.You can also read
