New York, NY Citi Retail Banking 330 Madison Avenue Office

Citigroup Global Markets Inc. (CGMI) serves individual and institutional clients across Citi Private Bank, Citi Global Wealth at Work and Citi Personal Wealth Management, covering workplace, high‑net‑worth and ultra‑high‑net‑worth segments. The firm offers a broad set of investment advisory programs (discretionary UMAs, manager‑selection, model and advisory portfolios), broker‑dealer execution and custody services (clearing and custody via Pershing and Citibank), and is separately registered to provide derivatives and futures services, including as a security‑based swap dealer and a futures commission merchant.

CGMI generally implements multi‑asset, multi‑manager strategies through both discretionary and non‑discretionary programs, using internal standards (CitiFocus and Due Diligence Approved) and oversight committees (e.g., C‑RAM, FOG) to select and monitor managers. Programs may include separately managed accounts, mutual funds, ETFs, alternative funds and overlay execution, and some models permit exposure to digital‑asset products or other alternatives; the firm recently transitioned certain Citibank‑managed strategies to BlackRock managers subject to client consent.

What is noteworthy relative to peers is the firm’s combination of large institutional scale and atypical market roles and arrangements: it maintains in‑house research and security‑pricing activities (including historical involvement in research ratings), operates as a swap dealer and futures commission merchant, and has commercial arrangements (e.g., Pershing clearing credits and BlackRock technology/licensing and contingent payments) that the brochure discloses as creating potential conflicts of interest. The firm also facilitates lending secured by advisory assets and offers bespoke discretionary solutions for very large relationships, which affects implementation, custodial arrangements and conflict‑management considerations compared with smaller advisory firms.