Monitoring of Citigroup’s compliance with settlement requirements
In 2014, Citigroup (Citi), the Department of Justice, and several states agreed to settle claims alleging that Citi packaged and sold defective loans into residential mortgage-backed securities. As part of the settlement agreement, Citi committed to provide $2.5 billion in consumer relief in the form of loan modifications, refinancing assistance, and donations to affordable housing programs. Bates White was retained to provide services as a consultant to the Independent Monitor, which evaluates, credits, and reports on the relief and on Citi’s compliance with settlement requirements on an ongoing basis.
As reported in the ninth Citi Monitorship report, the Monitor’s team, including Bates White, identified several relief eligibility issues, including inaccuracies in data that Citi provided regarding the position of Citi’s liens for certain loans that had received relief. The report, from November 2018, makes public those relief eligibility issues and credits Bates White as one of the consultants involved in resolving the issue.
The thirteenth and final Citi Monitorship report, published in November 2020, presents Bates White's disparate impact analysis of the consumer relief population. The firm's analysis involved impuation of the racial and ethnic composition of the relief population and the development of baselines by which to compare the relief population. Based on the analysis, the Monitor found no basis to conclude that Citi failed to comply with fair lending laws in the fulfillment of its settlement obligations and confirmed that Citi satisfactorily discharged its obligations under the settlement agreement.