Feedback on July 2023 Title I Resolution Plan Submissions
I voted against a deficiency for Citigroup, Inc. In this case, the underlying issues related to data quality and controls are longstanding concerns that are currently the subject of multiple enforcement actions by its supervisors. The institution is in the midst of a multiyear process to address these underlying issues, which the firm’s management has prioritized and which includes remediating the specific concerns identified through the resolution planning process. Consistent with the action taken by the Federal Reserve Board, I would have supported assigning the institution a shortcoming.