Requirement 2 – Evaluation of loan performance
Based on the increases to the allowance and provision account, we
would expect that the loans on the books in 2009 are lower quality and
that defaults should be higher than in past years. Management
acknowledges that 2009 was a difficult year, but that signs of
improvement in the economy were in evidence. The company took a
number of steps in 2009 to improve its financial position and operating
2010 BUSINESS OUTLOOK
While showing signs of improvement, the macroeconomic environment going into
2010 remains challenging, with U.S. unemployment still elevated. The U.S.
government has indicated its intention to continue scaling back programs put in
place to support the market during 2008 and 2009. The impact of the U.S.
government’s exit from many of these programs is a source of uncertainty in 2010,
In addition, the potential impact of new laws and regulations (e.g., The Credit Card
Accountability Responsibility and Disclosure Act of (CARD Act)), potential new
capital standards, and other legislative and regulatory initiatives is a source of
Citigroup’s loan loss experience in 2010, and beyond, will certainly be
affected by events like those mentioned that are largely beyond their
control.
Requirement 3 – Effect of FAS 166 and FAS 167 on Citigroup
Adopting FAS 166 and FAS 167 will impact Citigroup’s regulatory capital
ratios by requiring Citigroup to include in its consolidated financial
statements certain variable interest entities and qualifying special purpose
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