Citi’s living will needs work: Banking regulators

The “living will” filed by Citigroup Inc. has some “serious weaknesses,” U.S. federal banking regulators say.

The Federal Reserve Board and the Federal Deposit Insurance Corp. (FDIC) released the results of their joint review of the resolution plans of the eight largest U.S. banks, which detailed the banks’ proposals for winding up their businesses if they were to run into financial distress.

The regulators said that they didn’t find any deficiencies with most of the banks’ plans — the sole exception being Citi.

“In Citigroup’s resolution plan, the agencies found a shortcoming related to data quality and data management,” they said, adding that these same kinds of concerns were previously identified in an enforcement action against Citi in October 2020.

That enforcement action generated a cease-and-desist order that required Citi to “enhance its firm-wide risk management and internal controls,” after finding that the bank did not take prompt action to correct issues flagged by the Fed in the areas of compliance risk management, data quality management, and internal controls.

The bank is now required to file a plan for correcting the shortcomings identified by regulators by Jan. 31, 2023.

In a statement, Citi said that it is committed to addressing the issues identified by the agencies.

“As part of the transformation Citi has embarked upon, we are making significant investments in our data integrity and data management,” it said. “We will leverage that work to remediate the shortcoming identified today, as we acknowledge there is much more work to do. The result of these efforts will be more streamlined systems that improve the quality of our data as well as the speed with which it can be accessed.”

The director of the U.S. Consumer Financial Protection Bureau (CFPB), Rohit Chopra, criticized the resolution planning process and oversight. “I do not believe that Citigroup is the only institution without a credible plan. It is highly unlikely that any of these institutions, as currently constituted, could be resolved in a rapid and orderly manner under the bankruptcy code,” Chopra said.

The requirement for banks to develop living wills and submit them to regulatory scrutiny is part of an effort to reduce moral hazard in the banking system in the wake of the global financial crisis.

“Ending ‘too big to fail’ continues to be a goal, but it is not yet a reality,” said Chopra. “Next year, these global systemically important financial institutions will submit complete plans, which will be more robust than the partial plans submitted last year. It is critical that we evaluate those plans using the appropriate legal standard and with sufficient rigor.”

James Langton

James is a senior reporter for Advisor.ca and its sister publication, Investment Executive. He has been reporting on regulation, securities law, industry news and more since 1994.