City of Sterling Heights General Employees' Retirement System v. Citigroup Inc.

BLEICHMAR -ONTI & AULD Javier Bleichmar Partner 212 789 1341 direct 212 205 3961 fax jbleichmar @ bfalaw.com DOCUMENT January 26, 2021 ELECTRONICALLY FILED DOCH VIA ECF DATE FILED: 1/28/2021 The Honorable Alison J. Nathan United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square, Room 2102 New York, New York 10007 Re: City of Sunrise Firefighters’ Pension Fund v. Citigroup Inc., et al., No. 1:20-cv09132-AJN (S.D.N.Y.); City of Sterling Heights General Employees’ Retirement System v. Citigroup Inc., et al., No. 20-cv-09573-AJN (S.D.N.Y.); Timothy Lim v. Citigroup Inc. et al., No. 20-cv-10360-AJN (S.D.N.Y.) Dear Judge Nathan: We represent Lead Plaintiff Movant Public Sector Pension Investment Board (“PSP”’) in the above-referenced matters. Pursuant to Section 3(B) of the Court’s Individual Practices in Civil Cases and Local Civil Rule 7.1(d), we respectfully request permission to submit a sur-reply to the reply memorandum filed by Lead Plaintiff movant KBC Asset Management NV and Pembroke Pines Firefighters & Police Officers Pension Fund (“KBC and Pembroke”). See ECF No. 51. The proposed sur-reply is attached as Exhibit 1 together with the accompanying declaration of Javier Bleichmar and two referenced exhibits. A sur-reply is necessary because KBC and Pembroke raise new facts and issues for the first time on reply. The new facts and issues relate to the calculation of the financial interest for PSP, as well as KBC and Pembroke, which is the subject of the pending Lead Plaintiff motions. See ECF Nos. 25, 37. For the first time on reply, KBC and Pembroke put forward an unpled, partial disclosure in August 2018 to increase their recoverable losses or contend that the Court should not consider what they stand to recover in this case. See ECF No. 51 at 5-9. The August 2018 disclosure was never mentioned in the three complaints investors filed, including the complaint filed by KBC and Pembroke’s counsel in City of Sunrise (ECF No. 1), the notices published to investors apprising them of this case, or in any of the briefs previously filed by KBC and Pembroke or any other Lead Plaintiff movant. KBC and Pembroke also submitted on reply a 22-page expert report in support of their new position. This Court has rejected attempts virtually identical to those of KBC and Pembroke here. See Maliarov vy. Eros Int’l PLC, 2016 WL 1367246 , at *4 (S.D.N.Y. Apr. 5, 2016) (Nathan, J.) (rejecting attempt by movant to inject “additional disclosure allegations in the eleventh hour” 7 Times Square 27th Floor New York New York 1O0Z6 #!| T 919-789-1240 F 219-905-7960 | wwwhfalawcom BLEICHMAR mu FONTI & AULD Hon. Alison J. Nathan January 26, 2021 Page 2 when “(t]he specter of gamesmanship . . . causes the Court to question whether [movant] will ‘fairly and adequately protect the interests of the class’”’). PSP respectfully requests Respectfully submitted, SO ORDERED. /s/ Javier Bleichmar A N 1/27/2021 Javier Bleichmar cc: All counsel of record (via ECF) EXHIBIT 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) CITY OF SUNRISE FIREFIGHTERS’ ) Civil Action No. 1:20-cv-09132 PENSION FUND, individually and on behalf of ) all others similarly situated, ) CLASS ACTION ) Plaintiff, ) ORAL ARGUMENT REQUESTED ) v. ) ) CITIGROUP INC., MICHAEL L. CORBAT, ) JOHN C. GERSPACH, and MARK A. L. ) MASON, ) ) Defendants. ) ) CITY OF STERLING HEIGHTS GENERAL ) Civil Action No. 1:20-cv-09573 EMPLOYEES’ RETIREMENT SYSTEM, ) Individually and on Behalf of All Others ) CLASS ACTION Similarly Situated, ) ) Plaintiff, ) ) v. ) ) CITIGROUP INC., MICHAEL L. CORBAT, ) JOHN C. GERSPACH and MARK A.L. ) MASON ) ) Defendants. ) ) (caption continues on following page) SURREPLY MEMORANDUM OF LAW IN FURTHER SUPPORT OF THE MOTION OF THE PUBLIC SECTOR PENSION INVESTMENT BOARD FOR APPOINTMENT AS LEAD PLAINTIFF, APPROVAL OF ITS SELECTION OF LEAD COUNSEL, AND CONSOLIDATION OF RELATED ACTIONS ) TIMOTHY LIM, individually and on ) Civil Action No. 1:20-cv-10360 behalf of all others similarly situated, ) ) CLASS ACTION Plaintiff, ) ) v. ) ) CITIGROUP INC., MICHAEL L. ) CORBAT, JOHN C. GERSPACH, and ) MARK A. L. MASON, ) ) Defendants. ) TABLE OF CONTENTS PRELIMINARY STATEMENT .................................................................................................1 ARGUMENT ..............................................................................................................................2 A. Financial Interest Analysis Must Be Based On Facts Alleged In The Complaints .............2 B. The August 2018 Disclosure Is Inconsistent With The Filed Complaints .........................6 C. KBC And Pembroke’s Expert Report Is Untimely And Conclusory .................................7 PRELIMINARY STATEMENT KBC and Pembroke agree that PSP has the largest recoverable loss under Dura based on the facts alleged in the complaints, including the complaint that their own counsel filed (“City of Sunrise”).1 See ECF No. 51 at 9. Because this undermines their motion, KBC and Pembroke, for the first time on reply, attempt to introduce a new, unpled partial disclosure in August 2018 to increase their Dura loss or to avoid the application of Dura altogether. This Court rejected a virtually identical attempt in Eros, finding that inserting “additional disclosure allegations in the eleventh hour” is the type of “gamesmanship” that caused the Court to “question whether [the movant] will fairly and adequately protect the interests of the class.” Maliarov v. Eros Int’l PLC, 2016 WL 1367246 , at *4 (S.D.N.Y. Apr. 5, 2016) (Nathan, J.). Crediting this new unpled allegation would in the future not only reward the proverbial moving of the goal posts, but also undermine the PSLRA’s statutory framework because “individuals who would otherwise be able to meet the requirements of a lead plaintiff motion under the expanded partial disclosure date would be precluded from filing such motions given the expiration of the PSLRA’s time limit for doing so.” Id. What’s more, KBC and Pembroke’s counsel appear to have excluded this disclosure from their City of Sunrise complaint because it is inconsistent with its allegations. Paragraph 48 specifically lists four instances between December 2017 and November 2019 in which regulators fined Citigroup, but that paragraph excluded the August 2018 announcement of an $8 million fine. See ECF No. 1. The City of Sunrise complaint then explicitly alleges that despite these “multiple regulatory fines,” “Citi’s stock price [] trade[d] at artificially inflated prices throughout the Class 1 Citations to ECF No. __ refer to the docket in City of Sunrise; capitalized terms are defined in PSP’s initial and opposition briefs (ECF Nos. 39, 49); and emphasis is added. Period” until August 2020 when “The Truth Emerges.” ¶¶48-50. KBC and Pembroke do not explain how the $8 million fine in August 2018 could have revealed the truth when the complaint their counsel filed states that $160 million in fines was insufficient to do so. The August 2018 disclosure was also never mentioned in the two other complaints investors filed, in any of the briefs filed by KBC and Pembroke, or by any other Lead Plaintiff movant. Rather, KBC and Pembroke stated in their opening brief that “[t]he truth began to emerge [two years later] on August 13, 2020.” ECF No. 28 at 4. Crediting this August 2018 announcement as a corrective disclosure now would be inconsistent with KBC and Pembroke’s prior arguments. To be clear, PSP, if appointed Lead Plaintiff, will review all these announcements of regulatory fines on the merits and assess, objectively and impartially, whether they belong in this case. But it is counter to well-established legal precedent for Lead Plaintiff movants to introduce new facts outside of the four corners of the complaints that increase their losses. Finally, KBC and Pembroke submit with their reply brief an expert report that calculates Dura losses incorrectly, and is untimely and otherwise conclusory because it does not substantiate its work. The Court should not consider the report. ARGUMENT A. Financial Interest Analysis Must Be Based On Facts Alleged In The Complaints Eros is clear. The most important metric in determining financial interest is the amount of “recoverable losses” “based on the facts alleged in the complaint.” Eros, 2016 WL 1367246 , at *3. “In selecting a plaintiff to lead this litigation at this stage of the proceedings, the court can and must only consider the pleadings before it.” In re Comverse Tech., 2007 WL 680779 , at *6 (E.D.N.Y. Mar. 2, 2007). KBC and Pembroke’s contention that it is “unduly narrow” for the Court to consider only “the corrective disclosures alleged in the complaints filed to-date’ CECF No. 51 at 6) is the opposite of the law, and they do not cite a single case to support this point.” Here, the filed complaints allege that the earliest possible disclosure of Defendants’ fraud occurred in August 2020. See City of Sunrise 949, 62; City of Sterling Heights 943; Lim 467: e KBC and Pembroke’s counsel filed the City of Sunrise complaint on October 30, 2020, and did not plead a corrective disclosure prior to August 2020. Id. 4/49, 62. e The PSLRA notice disseminated by KBC and Pembroke’s counsel stated that “t]he truth began to emerge on August 13, 2020,” based on “an extensive proprietary investigation and a careful evaluation of the merits of this case.”’ ECF No. 40-2. e City of Sterling Heights filed its complaint on November 13, 2020, and pled that the first corrective disclosure occurred on August 13, 2020. City of Sterling Heights 443. e City of Sterling Heights’s PSLRA notice stated that the first disclosure of the fraud occurred “[o]n August 13, 2020.” ECF No. 40-3. e Lim, filed on December 9, 2020, did not plead a corrective disclosure prior to August 2020 and the PSLRA notice Lim’s counsel published did not state there were any disclosures prior to August 2020. Lim 455-67; Bleichmar Decl. Ex A. e Relying on these notices, six movants sought Lead Plaintiff appointment. No movant suggested a corrective disclosure before August 2020 and KBC and Pembroke asserted that “{t/he truth began to emerge on August 13, 2020.” ECF No. 28 at 4. e KBC and Pembroke further recognized in their opposition brief that “the complaint in the Sterling Heights Action alleges that the first disclosure of Citigroup’s fraud occurred on August 13, 2020.” ECF No. 47 at 5, 0.5. Now, KBC and Pembroke claim for the first time on reply that they “identified an additional disclosure, which is not reflected in the filed complaints” that occurred two years earlier, in August 2018. ECF No. 51 at 2. KBC and Pembroke contend that this shows that ? See Sallustro v. CannaVest, 93 F. Supp. 3d 265, 275 (S.D.N.Y. 2015) (“Dura [and its progeny] . . . require a court to make pre-discovery loss causation determinations . . . that are based on the facts alleged in the complaint”); Porzio v. Overseas Shipholding, 2013 WL 407678 , at *3 n.37 (S.D.N.Y. Feb. 1, 2013) (imiting consideration to “theory of fraud set forth in the various complaints”); Foster v. Maxwell Techs., 2013 WL 5780424 , at *4 (S.D. Cal. Oct. 24, 2013) (“Court is limited to considering the allegations in the pending complaints at this stage of the litigation”). “applying a ‘Dura’ analysis is premature and further investigation is needed” (ECF No. 51 at 8) even though their counsel said it had already conducted “an extensive [] investigation and a careful evaluation of the merits of this case.” ECF No. 40-2. This contention is logically inconsistent. In any event, this Court and others have repeatedly held that any modification to the corrective disclosures alleged in the complaints after the Lead Plaintiff deadline (or even just before) is counter to the PSLRA statutory framework. The PSLRA’s deadline for filing Lead Plaintiff motions precludes consideration of allegations “asserted for the first time in a complaint . . . filed after the sixty (60) day window has closed.” Topping v. Deloitte Touche Tohmatsu, 95 F. Supp. 3d 607, 618-20 (S.D.N.Y. 2015). Once the sixty-day deadline expires, the allegations under which movants’ financial interests are assessed are set and cannot be changed. See id. Under this framework, Dura is applied in an objective and consistent manner. Eros is directly on-point. There, a Lead Plaintiff movant sold all of its stock prior to the first corrective disclosure alleged in the filed complaints, rendering its losses unrecoverable under Dura. Eros, 2016 WL 1367246 , at *3-4. The movant, however, filed a new complaint “on the last day for potential class members to file a lead plaintiff motion” that added a new, earlier corrective disclosure. Id. This Court rejected the new disclosure and explained that it was “hesitant to encourage lead plaintiff movants to file complaints with additional disclosure allegations in the eleventh hour.” Id. at *4. Such “gamesmanship,” the Court concluded, would leave “individuals who would otherwise be able to meet the requirements of a lead plaintiff motion under the expanded partial disclosure date [] precluded from filing such motions given the expiration of the PSLRA’s time limit for doing so.”3 Id. 3 KBC and Pembroke agree that “the Court should [not] make a finding of loss based on unpleaded allegations.” ECF No. 51 at 7-8, n.6. But then they argue that the Court can consider this unpled allegation for a different reason: to show how “making loss causation determinations at this stage Likewise, in Deloitte, a movant attempted to file a “corrected” complaint that added a new disclosure to increase that movant’s Dura loss after the PSLRA’s sixty-day deadline expired. 95 F. Supp. 3d at 615, 619-20 . Judge Ramos refused to consider the new disclosure because doing so “would ‘effectively render the strict timeliness set forth in the PSLRA meaningless,” “would nullify Congress’s attempt to expedite the lead plaintiff appointment process,” and prejudice other investors because all movants “who filed their motions to serve as lead plaintiff” did so “in reliance on the Complaint as it was filed.” 4 Id. The issues surrounding KBC and Pembroke’s “additional disclosure allegations” are more pronounced than in Eros, Deloitte, and Goldman. Eros, 2016 WL 1367246 , at *4. Here, they waited until the reply brief, filed weeks after the Lead Plaintiff deadline expired, to come forward with a new disclosure. Every movant acknowledged the corrective disclosures pleaded in the complaints and that none occurred prior to August 2020. Accordingly, the disclosures pleaded in the filed complaints cannot be altered at this late stage. See id. at *3-4. can come into conflict with the requirement of the PSLRA that the investor with the largest financial interest in the litigation be appointed to lead the class.” Id. This argument is counter to law. KBC and Pembroke’s reliance on this new disclosure cannot be reconciled with Eros and the well-settled law that movants’ financial interests must be “based on the facts alleged in the complaint.” Eros, 2016 WL 1367246 , at *3. 4 See also Plaut v. Goldman Sachs, 2019 WL 4512774 , at *5 (S.D.N.Y. Sept. 19, 2019) ( “it would be inappropriate to select [a movant] as lead plaintiff” when it injected partial disclosures “twenty days after the deadline for motions to serve as lead plaintiff” because a “principal purpose of the PSLRA was to prevent just the kind of gamesmanship in which [the movant] and its counsel have engaged here”) (emphasis in original); Porzio, 2013 WL 407678 , at *3 n.37 (refusing to credit corrective disclosure “allege[d] in [movant’s] reply” because “these are not part of the allegations in the Complaints”); Maxwell, 2013 WL 5780424 , at *4 (rejecting corrective disclosure not alleged in the filed complaints); Hedick v. Kraft Heinz Co., 2019 WL 4958238 , at *5 (N.D. Ill. Oct. 8, 2019) (refusing to credit unpled allegations after expiration of 60-day deadline). B. The August 2018 Disclosure Is Inconsistent With The Filed Complaints Not only is the new August 2018 disclosure unpled, it is inconsistent with the allegations in the City of Sunrise complaint, adopted by KBC and Pembroke in their initial Lead Plaintiff brief. See ECF No. 28 at 4 and n.6. That complaint pleads that “Citi received multiple regulatory fines and punishments” between 2017 and 2019, the precise period that KBC and Pembroke now point to with their new August 2018 disclosure, including a: (i) $70 million fine from the OCC; (ii) $10.5 million fine from the SEC; (iii) $25 million fine from the OCC; and (iv) £44 million fine from the Bank of England. Id. ¶48. The City of Sunrise complaint alleges that those $160 million in fines “failed to disclose the magnitude and extent of the problems [with internal controls] and the fact that properly addressing such problems would have a material impact on Citi’s finances,” which “caused Citi’s stock price to trade at artificially inflated prices” until “the truth emerge[d]” beginning in August 2020. ¶¶49-50. Against that backdrop, KBC and Pembroke do not show how the new August 2018 disclosure—an $8 million fine from the Federal Reserve (ECF No. 51 at 6)—revealed the truth when the City of Sunrise complaint pleads that larger and more serious fines from a variety of different government regulators, in the U.S. and abroad, were insufficient, and in fact “caused Citi’s stock price to trade at artificially inflated prices” for an additional two years. Id. ¶49; See Galmi v. Teva Pharms. Indus. Ltd., 302 F. Supp. 3d 485, 503 (D. Conn. 2017) (refusing to credit partial disclosures proffered on reply when “the factual allegations are not sufficient for me to conclude that those statements” revealed the relevant misconduct). ECF No. 40-2.5 5 Importantly, the Court is not at this stage making a binding determination regarding which partial disclosures apply. Rather, under the PSLRA’s Lead Plaintiff provisions, the Court is simply determining which movant has demonstrated that it has the largest financial interest based on the allegations currently before the Court. While KBC and Pembroke cannot add corrective disclosures at this late juncture, it will be the responsibility of the Court-appointed Lead Plaintiff C. KBC And Pembroke’s Expert Report Is Untimely And Conclusory KBC and Pembroke also submit on reply an untimely expert report from Michael L. Hartzmark (“Report”). See ECF No. 54-1. The report is incorrect and conclusory. As an initial matter, the Report incorrectly calculates PSP’s Dura loss to be either $11 million (including the August 10, 2018 disclosure, id. ¶25); or $7 million (excluding the August 10, 2018 disclosure, id. ¶ 26 ). The Report can only reach these conclusions by including gains that PSP experienced on bonds and options. However, as PSP already made clear, it experienced those gains prior to any corrective disclosure (or in between disclosures) and thus they are unconnected to the fraud and cannot be considered under Dura. See ECF Nos. 49 at 5 n.4; 50-2; 52 at 2. KBC and Pembroke simply “asked [the expert] to include any gains or losses during the Class Period on all bond and options transactions,” and he did so without an independent analysis of his own. Id. ¶23. When correctly calculated, PSP’s Dura loss is $14.2 million (including the August 10, 2018 disclosure, Bleichmar Decl. Ex. B) and $10.1 million (excluding the August 10, 2018 disclosure, ECF No. 50-2). PSP already provided back-up data demonstrating the calculations. The report is also conclusory because it fails to explain or set forth its methodology. The Report does not even reconcile the August 2018 disclosure with the allegations in the City of Sunrise complaint and how it could have revealed the fraud when that complaint alleges that four larger and more serious fines during the same time period did not. Accordingly, the Court should not consider the Report. to assert what it determines to be the most appropriate corrective disclosures that will maximize the potential recovery for the Class. See In re Bank of Am. Corp. Sec., Derivative & Emp. Ret. Income Sec. Act (ERISA) Litig., 2011 WL 4538428 , at *1-2 (S.D.N.Y. Sept. 29, 2011) (Lead Plaintiff has authority to determine the claims to assert as part of the prerogative to “exercise control over the litigation as a whole”). Dated: January 26, 2021 Respectfully Submitted, BLEICHMAR FONTI & AULD LLP /s/ Javier Bleichmar Javier Bleichmar Joseph A. Fonti Erin H. Woods 7 Times Square, 27th Floor New York, New York 10036 Telephone: (212) 789-1340 Facsimile: (212) 205-3960 jbleichmar@bfalaw.com jfonti@bfalaw.com ewoods@bfalaw.com Counsel for Proposed Lead Plaintiff PSP and Proposed Lead Counsel for the Class UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) CITY OF SUNRISE FIREFIGHTERS’ ) Civil Action No. 1:20-cv-09132 PENSION FUND, individually and on behalf of ) all others similarly situated, ) CLASS ACTION ) Plaintiff, ) ) v. ) ) CITIGROUP INC., MICHAEL L. CORBAT, ) JOHN C. GERSPACH, and MARK A. L. ) MASON, ) ) Defendants. ) ) CITY OF STERLING HEIGHTS GENERAL ) Civil Action No. 1:20-cv-09573 EMPLOYEES’ RETIREMENT SYSTEM, ) Individually and on Behalf of All Others ) CLASS ACTION Similarly Situated, ) ) Plaintiff, ) ) v. ) ) CITIGROUP INC., MICHAEL L. CORBAT, ) JOHN C. GERSPACH and MARK A.L. ) MASON ) ) Defendants. ) ) (caption continues on following page) DECLARATION OF JAVIER BLEICHMAR IN SUPPORT OF THE SURREPLY IN FURTHER SUPPORT OF THE MOTION OF THE PUBLIC SECTOR PENSION INVESTMENT BOARD FOR APPOINTMENT AS LEAD PLAINTIFF, APPROVAL OF ITS SELECTION OF LEAD COUNSEL, AND CONSOLIDATION OF RELATED ACTIONS ) TIMOTHY LIM, individually and on ) Civil Action No. 1:20-cv-10360 behalf of all others similarly situated, ) ) CLASS ACTION Plaintiff, ) ) v. ) ) CITIGROUP INC., MICHAEL L. ) CORBAT, JOHN C. GERSPACH, and ) MARK A. L. MASON, ) ) Defendants. ) I, Javier Bleichmar, declare as follows: 1. I am a member in good standing of the bar of the State of New York and of this Court. I am a Partner of the law firm of Bleichmar Fonti & Auld LLP (“BFA”). I submit this declaration in further support of the motion filed by Public Sector Pension Investment Board (“PSP”) for: appointment as Lead Plaintiff; approval of its selection of BFA to serve as Lead Counsel for the Class; consolidation of all related securities class actions; and any such further relief as the Court may deem just and proper. 2. Attached as Exhibits A and B are true and correct copies of the following documents: EXHIBIT A: Notice of Pendency of Timothy Lim v. Citigroup Inc., No. 1:20-cv10360 (S.D.N.Y.) published on December 9, 2020. EXHIBIT B: Chart depicting the calculation of PSP’s recoverable losses under Dura Pharms., Inc. v. Broudo, 544 U.S. 336 (2005), including the purported August 10, 2018 disclosure, prepared by counsel for PSP. I declare, under penalty of perjury, that the foregoing is true and correct to the best of my knowledge. Executed this 26th day of January 2021. /s/ Javier Bleichmar Javier Bleichmar EXHIBIT A Law Firm Announces the Filing Class Action against Citigroup Inc. and e Officers - C PROVIDED BY LLP — 09, 2020, 16:32 ET YORK, Dec. 9, 2020 /PRNewswire/ -- Pomerantz LLP announces that a class action lawsu been filed against Citigroup Inc. ("Citi" or the "Company") (NYSE: C) and certain of its The class action, filed in United States District Court for the Southern District of New and docketed under 20-cv-10360, is on behalf of a class consisting of all persons and other than Defendants who purchased or otherwise acquired Citi securities between 15, 2016 and October 12, 2020, both dates inclusive (the "Class Period"), seeking to cover damages caused by Defendants’ violations of the federal securities laws and to pursue medies under Sections 10(b) and 20(a) of the Securities Exchange Act of 1934 (the "Exchang: and Rule 10b-5 promulgated thereunder, against the Company and certain of its top are a shareholder who purchased Citi securities during the Class Period, you have until 29, 2020, to ask the Court to appoint you as Lead Plaintiff for the class. A copy of tk can be obtained at www.pomerantzlaw.com. To discuss this action, contact Robe Willoughby at newaction@pomlaw.com or 888.476.6529 (or 888.4-POMLAW), toll-free, Ext. Those who inquire by e-mail are encouraged to include their mailing address, telephone and the number of shares purchased. [Click here for information about joining the class action] significant deficiencies or material weaknesses in the Company's internal controls. When with periodic regulatory penalties for noncompliance, the Company continued to assure that the specific deficiencies at issue were being remediated promptly and that ternal controls and regulatory compliance were a top priority at Citi. In particular, Citi investors that it satisfied all regulatory requirements and maintained adequate intern data governance, compliance risk management, and enterprise risk management. reality, during the Class Period and unbeknownst to investors, Citi's internal controls and ris capabilities suffered from "serious" and "longstanding" inadequacies that the Company to massive regulatory penalties and will cost significantly more than $1 lllon to remediate. Specific control failures about which Citi executives were warned mained unresolved for years and the Company's culture of non-compliance was so idespread that Citi's Chief Executive Officer, Defendant Michael L. Corbat, exhorted in an internal memo that regulatory compliance required more than "checking truth began to emerge on September 14, 2020, when reports surfaced that regulators wer to reprimand Citi for failing to improve its risk-management systems. That disclosu the price of Citi's stock to decline $2.85 per share, from $51.00 to $48.15, erasing $5.91 Ilion in shareholder value. the market closed on September 14, 2020, an internal memo sent to Citi employees for the first time the Company's disregard for adequate internal controls and gulatory compliance. As a result, the price of Citi's stock declined an additional $3.34 per from $48.15 to $44.81, erasing $6.93 billion in shareholder value. ON October 13, 2020, Citi reported earnings for the third quarter of 2020 and disclosed the Company's expenses increased during the third quarter by 5%, to ST] billion, due to ai crease in costs including a $400 million fine, investments in infrastructure, and other mediation costs related to control deficiencies. These disclosures caused Citi's stock price tc by $2.20 per share, from $45.88 to $43.68, erasing $4.57 billion in shareholder value. of the premier firms in the areas of corporate, securities, and antitrust class litigation. by the late Abraham L. Pomerantz, Known as the dean of the class action bar, the Firm pioneered the field of securities class actions. Today, more than 80 years later Pomerantz Firm continues in the tradition he established, fighting for the rights of the of securities fraud, breaches of fiduciary duty, and corporate misconduct. The Firm has covered numerous multimillion-dollar damages awards on behalf of class members. See S. Willoughby LLP ext. 7980 Pomerantz LLP Links EXHIBIT B Financial Interest Analysis for Public Sector Pension Investment Board Based on Dura, Including the Supposed Partial Disclosure on August 10, 2018 Class Period: January 15, 2016 to October 12, 2020 Dura LIFO Analysis - Citigroup Inc. Common Stock Transaction Type Trade Date Shares Price Per Share Cost/Proceeds Sale 1/15/2016 -5,585.00 $42.3959 $236,781.10 Sale 1/15/2016 -5,585.00 $42.4045 $236,829.13 Sale 1/15/2016 -16,755.00 $42.4242 $710,817.47 Sale 1/19/2016 -168.00 $43.0013 $7,224.22 Sale 1/19/2016 -11,170.00 $42.9915 $480,215.06 Sale 1/19/2016 -19,729.00 $42.6504 $841,449.74 Sale 1/19/2016 -8,559.00 $42.9949 $367,993.35 Sale 1/19/2016 -16,587.00 $42.8576 $710,879.01 Sale 1/21/2016 -68,600.00 $40.1500 $2,754,290.00 Sale 2/12/2016 -74,700.00 $37.5400 $2,804,238.00 Sale 2/16/2016 -24,200.00 $38.8900 $941,138.00 Sale 2/17/2016 -25,900.00 $39.7800 $1,030,302.00 Sale 5/3/2017 -5,526.00 $60.2400 $332,886.24 Sale 5/4/2017 -7,356.00 $60.3252 $443,752.17 Sale 5/10/2017 -38,691.00 $60.3700 $2,335,775.67 Sale 5/11/2017 -13,516.00 $60.7000 $820,421.20 Sale 5/12/2017 -32,500.00 $61.0700 $1,984,775.00 Sale 5/19/2017 -1,046.00 $61.2680 $64,086.33 Sale 5/19/2017 -19,865.00 $61.3015 $1,217,754.30 Sale 5/22/2017 -3,680.00 $61.0761 $224,760.05 Sale 6/7/2017 -4,799.00 $61.8315 $296,729.37 Sale 7/11/2017 -15,716.00 $66.8200 $1,050,143.12 Class Period Sales Matching to Pre-Class Period Position -420,233.00 $19,893,240.52 Purchase 1/20/2016 7,419.00 $40.8496 ($303,063.18) Purchase 1/22/2016 10,637.00 $41.1295 ($437,494.49) Purchase 1/22/2016 1,472.00 $41.1202 ($60,528.93) Purchase 1/26/2016 8,600.00 $40.5000 ($348,300.00) Purchase 3/1/2016 11,380.00 $41.2604 ($469,543.35) Purchase 3/10/2016 35,600.00 $41.3700 ($1,472,772.00) Purchase 4/15/2016 5,745.00 $46.0376 ($264,486.01) Purchase 4/15/2016 8,043.00 $45.6948 ($367,523.28) Purchase 4/20/2016 5,750.00 $46.0378 ($264,717.35) Purchase 4/20/2016 5,750.00 $46.2499 ($265,936.93) Purchase 4/21/2016 1,229.00 $46.5045 ($57,154.03) Purchase 4/22/2016 1,272.00 $46.9679 ($59,743.17) Purchase 4/25/2016 459.00 $46.4352 ($21,313.76) Purchase 4/27/2016 11,520.00 $47.0459 ($541,968.77) Purchase 5/4/2016 3,953.00 $44.4146 ($175,570.91) Purchase 6/8/2016 11,100.00 $45.5600 ($505,716.00) Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Purchase 6/23/2016 95,000.00 $44.4600 ($4,223,700.00) Purchase 6/29/2016 9,053.00 $41.6962 ($377,475.70) Purchase 6/30/2016 1,207.00 $42.3900 ($51,164.73) Purchase 6/30/2016 7,846.00 $42.3218 ($332,056.84) Purchase 7/1/2016 142.00 $42.3900 ($6,019.38) Purchase 7/13/2016 24,100.00 $43.3300 ($1,044,253.00) Purchase 7/22/2016 42,600.00 $44.3000 ($1,887,180.00) Purchase 8/5/2016 6,160.00 $45.3802 ($279,542.03) Purchase 8/9/2016 35.00 $45.9300 ($1,607.55) Purchase 8/9/2016 22,300.00 $45.9000 ($1,023,570.00) Purchase 8/17/2016 5,443.00 $46.6042 ($253,666.66) Purchase 8/24/2016 8,700.00 $46.6600 ($405,942.00) Purchase 8/31/2016 13,681.00 $47.6928 ($652,485.20) Purchase 9/1/2016 877.00 $47.7400 ($41,867.98) Purchase 9/8/2016 12,910.00 $47.8361 ($617,564.05) Purchase 9/9/2016 6,456.00 $47.3280 ($305,549.57) Purchase 9/9/2016 6,454.00 $47.4283 ($306,102.25) Purchase 9/13/2016 6,460.00 $47.0487 ($303,934.60) Purchase 10/26/2016 4,479.00 $49.7788 ($222,959.25) Purchase 11/9/2016 12,496.00 $50.8759 ($635,745.25) Purchase 11/9/2016 3,336.00 $50.0000 ($166,800.00) Purchase 11/9/2016 6,459.00 $50.2950 ($324,855.41) Purchase 11/9/2016 2,012.00 $51.6134 ($103,846.16) Purchase 11/9/2016 4,513.00 $51.4370 ($232,135.18) Purchase 11/10/2016 9,893.00 $53.2691 ($526,991.21) Purchase 11/11/2016 13,050.00 $52.7435 ($688,302.68) Purchase 11/14/2016 6,405.00 $54.3735 ($348,262.27) Purchase 11/14/2016 6,645.00 $54.3899 ($361,420.89) Purchase 11/15/2016 3,273.00 $55.3447 ($181,143.20) Purchase 11/15/2016 13,000.00 $55.4500 ($720,850.00) Purchase 11/16/2016 41,170.00 $54.5871 ($2,247,350.91) Purchase 11/17/2016 3,929.00 $55.3825 ($217,597.84) Purchase 11/23/2016 2,935.00 $56.4029 ($165,542.51) Purchase 11/29/2016 3,303.00 $55.7380 ($184,102.61) Purchase 11/30/2016 20,060.00 $56.4484 ($1,132,354.90) Purchase 12/1/2016 13,320.00 $57.1493 ($761,228.68) Purchase 12/1/2016 371.00 $56.3900 ($20,920.69) Purchase 12/7/2016 19,980.00 $58.6037 ($1,170,901.93) Purchase 12/8/2016 3,519.00 $60.2047 ($211,860.34) Purchase 12/8/2016 9,801.00 $59.8123 ($586,220.35) Purchase 12/9/2016 3,330.00 $59.7008 ($198,803.66) Purchase 12/12/2016 6,660.00 $59.5989 ($396,928.67) Purchase 12/14/2016 4,528.00 $59.5370 ($269,583.54) Purchase 1/3/2017 2.00 $59.4489 ($118.90) Purchase 1/11/2017 2,063.00 $59.6755 ($123,110.56) Purchase 1/12/2017 3,438.00 $59.2818 ($203,810.83) Purchase 1/18/2017 2,748.00 $57.5491 ($158,144.93) Purchase 1/18/2017 4,122.00 $57.3753 ($236,500.99) Purchase 1/20/2017 1,374.00 $56.1115 ($77,097.20) Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Purchase 1/25/2017 2,710.00 $57.6856 ($156,327.98) Purchase 1/25/2017 11,050.00 $57.5959 ($636,434.70) Purchase 1/26/2017 12,500.00 $57.3612 ($717,015.00) Purchase 1/27/2017 2,752.00 $57.0655 ($157,044.26) Purchase 1/30/2017 715.00 $56.3384 ($40,281.96) Purchase 1/30/2017 2,039.00 $56.5323 ($115,269.36) Purchase 1/31/2017 1,377.00 $55.8495 ($76,904.76) Purchase 2/1/2017 3,449.00 $55.8300 ($192,557.67) Purchase 2/1/2017 7,900.00 $56.0500 ($442,795.00) Purchase 2/2/2017 4,606.00 $55.8918 ($257,437.63) Purchase 2/8/2017 8,640.00 $56.3320 ($486,708.48) Purchase 2/9/2017 15,406.00 $57.3578 ($883,654.27) Purchase 2/9/2017 2,594.00 $57.3178 ($148,682.37) Purchase 2/10/2017 2,531.00 $57.6756 ($145,976.94) Purchase 2/10/2017 4,669.00 $57.6175 ($269,016.11) Purchase 2/14/2017 7,200.00 $59.8368 ($430,824.96) Purchase 2/15/2017 20,061.00 $60.5320 ($1,214,332.45) Purchase 2/21/2017 113,000.00 $60.5500 ($6,842,150.00) Purchase 2/22/2017 14,450.00 $60.7617 ($878,006.57) Purchase 2/24/2017 14,450.00 $59.4679 ($859,311.16) Purchase 2/27/2017 3,615.00 $59.9338 ($216,660.69) Purchase 3/3/2017 14,530.00 $60.9548 ($885,673.24) Purchase 3/3/2017 9,200.00 $61.0000 ($561,200.00) Purchase 3/6/2017 1,453.00 $60.3694 ($87,716.74) Purchase 3/15/2017 5,082.00 $61.0802 ($310,409.58) Purchase 3/17/2017 1,000.00 $60.3700 ($60,370.00) Purchase 3/22/2017 5,078.00 $58.0111 ($294,580.37) Purchase 3/22/2017 9,432.00 $57.9211 ($546,311.82) Purchase 3/22/2017 4,199.00 $57.8751 ($243,017.54) Purchase 3/27/2017 1,221.00 $57.7209 ($70,477.22) Purchase 3/30/2017 10,442.00 $60.3602 ($630,281.21) Purchase 4/3/2017 1,006.00 $59.8567 ($60,215.84) Purchase 4/7/2017 3,680.00 $59.5002 ($218,960.74) Purchase 4/7/2017 3,675.00 $59.8082 ($219,795.14) Purchase 4/11/2017 7,360.00 $58.7712 ($432,556.03) Purchase 4/12/2017 5,391.00 $58.6185 ($316,012.33) Purchase 4/13/2017 3,680.00 $58.7859 ($216,332.11) Purchase 4/19/2017 3,903.00 $58.4312 ($228,056.97) Purchase 5/10/2017 3,680.00 $60.4076 ($222,299.97) Purchase 5/10/2017 3,129.00 $60.3578 ($188,859.56) Purchase 5/11/2017 7,384.00 $60.7211 ($448,364.60) Purchase 5/15/2017 35,900.00 $61.4200 ($2,204,978.00) Purchase 5/17/2017 3,685.00 $61.8367 ($227,868.24) Purchase 5/24/2017 9,900.00 $62.2700 ($616,473.00) Purchase 5/31/2017 7,182.00 $60.4231 ($433,958.70) Purchase 6/1/2017 256.00 $60.5400 ($15,498.24) Purchase 6/16/2017 1,000.00 $63.8880 ($63,888.00) Purchase 7/3/2017 184.00 $67.1855 ($12,362.13) Purchase 8/18/2017 506.00 $67.0893 ($33,947.19) Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Purchase 8/29/2017 9,438.00 $67.5450 ($637,489.71) Purchase 8/31/2017 10,240.00 $67.9059 ($695,356.42) Purchase 9/1/2017 74.00 $68.0331 ($5,034.45) Purchase 9/26/2017 2,522.00 $70.8400 ($178,658.48) Purchase 10/2/2017 1,811.00 $73.7106 ($133,489.90) Purchase 10/10/2017 193,736.00 $75.1800 ($14,565,072.48) Purchase 10/12/2017 129,242.00 $73.0819 ($9,445,250.92) Purchase 10/17/2017 40,082.00 $72.4895 ($2,905,524.14) Purchase 10/17/2017 50,000.00 $72.5282 ($3,626,410.00) Purchase 10/18/2017 8,698.00 $73.1011 ($635,833.37) Purchase 10/18/2017 8,895.00 $73.0883 ($650,120.43) Purchase 10/18/2017 197.00 $72.9900 ($14,379.03) Purchase 10/19/2017 1,779.00 $72.8114 ($129,531.48) Purchase 10/24/2017 17,772.00 $74.4064 ($1,322,350.54) Purchase 10/25/2017 10,007.00 $73.6791 ($737,306.75) Purchase 10/26/2017 148,000.00 $73.7900 — ($10,920,920.00) Purchase 10/27/2017 367,000.00 $73.8700 — ($27,110,290.00) Purchase 11/1/2017 189.00 $73.6437 ($13,918.66) Purchase 11/2/2017 4,465.00 $74.4702 ($332,509.44) Purchase 11/9/2017 8,935.00 $72.0786 ($644,022.29) Purchase 11/16/2017 4,468.00 $71.8429 ($320,994.08) Purchase 11/16/2017 13,412.00 $71.8865 ($964,141.74) Purchase 12/1/2017 33.00 $75.5000 ($2,491.50) Purchase 12/12/2017 8,940.00 $76.4647 ($683,594.42) Purchase 12/19/2017 8,960.00 $75.0362 ($672,324.35) Purchase 12/27/2017 616.00 $74.6000 ($45,953.60) Purchase 1/2/2018 424.00 $74.4100 ($31,549.84) Purchase 1/9/2018 18,730.00 $75.5726 ($1,415,474.80) Purchase 1/9/2018 18,730.00 $75.6221 ($1,416,401.93) Purchase 1/11/2018 689,000.00 $75.5600 — ($52,060,840.00) Purchase 1/17/2018 18,710.00 $77.4984 ($1,449,995.06) Purchase 1/18/2018 18,710.00 $77.3279 ($1,446,805.01) Purchase 1/19/2018 18,710.00 $78.2724 ($1,464,476.60) Purchase 1/23/2018 5,600.00 $78.5500 ($439,880.00) Purchase 1/24/2018 15,464.00 $79.2734 ($1,225,883.86) Purchase 2/5/2018 5,427.00 $76.2596 ($413,860.85) Purchase 2/6/2018 9,260.00 $74.4104 ($689,040.30) Purchase 2/7/2018 18,520.00 $75.5482 ($1,399,152.66) Purchase 2/13/2018 9,255.00 $75.1879 ($695,864.01) Purchase 2/14/2018 18,510.00 $76.3514 ($1,413,264.41) Purchase 3/14/2018 3,500.00 $73.7950 ($258,282.50) Purchase 3/14/2018 9,000.00 $74.0596 ($666,536.40) Purchase 3/26/2018 17,000.00 $69.4609 ($1,180,835.30) Purchase 3/29/2018 4,603.00 $69.3437 ($319,189.05) Purchase 4/2/2018 112.00 $67.5423 ($7,564.74) Purchase 4/5/2018 9,914.00 $70.4375 ($698,317.38) Purchase 4/13/2018 14,205.00 $70.3753 ($999,681.14) Purchase 4/17/2018 15,929.00 $70.3927 ($1,121,285.32) Purchase 4/18/2018 4,735.00 $69.3521 ($328,382.19) Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Purchase 4/18/2018 14,560.00 $70.1186 ($1,020,926.82) Purchase 4/20/2018 4,735.00 $69.9951 ($331,426.80) Purchase 4/24/2018 9,535.00 $69.0462 ($658,355.52) Purchase 4/25/2018 9,535.00 $69.2421 ($660,223.42) Purchase 4/25/2018 4,768.00 $68.9852 ($328,921.43) Purchase 4/25/2018 2,663.00 $68.9433 ($183,596.01) Purchase 4/25/2018 23,900.00 $68.7091 ($1,642,147.49) Purchase 4/27/2018 6,800.00 $69.0959 ($469,852.12) Purchase 5/2/2018 7,798.00 $68.5086 ($534,230.06) Purchase 5/16/2018 842.00 $72.1601 ($60,758.80) Purchase 5/24/2018 4,011.00 $69.3893 ($278,320.48) Purchase 5/24/2018 6,499.00 $69.4092 ($451,090.39) Purchase 5/29/2018 1,919.00 $65.7316 ($126,138.94) Purchase 5/29/2018 270,000.00 $65.7100 — ($17,741,700.00) Purchase 5/30/2018 3,295.00 $66.6486 ($219,607.14) Purchase 5/30/2018 3,838.00 $66.6375 ($255,754.73) Purchase 6/1/2018 1,177.00 $66.8019 ($78,625.84) Purchase 6/6/2018 5,297.00 $68.0077 ($360,236.79) Purchase 6/19/2018 200,000.00 $66.7759 — ($13,355,180.00) Purchase 6/19/2018 100,000.00 $66.7500 ($6,675,000.00) Purchase 6/19/2018 33,300.00 $66.1554 ($2,202,974.82) Purchase 6/20/2018 4,203.00 $67.4157 ($283,348.19) Purchase 6/26/2018 3,882.00 $66.4282 ($257,874.27) Purchase 6/27/2018 259.00 $66.4604 ($17,213.24) Purchase 7/3/2018 4,890.00 $66.5045 ($325,207.01) Purchase 7/13/2018 4,890.00 $67.0344 ($327,798.22) Purchase 7/18/2018 1,823.00 $69.8460 ($127,329.26) Purchase 7/25/2018 1,829.00 $71.1737 ($130,176.70) Purchase 8/1/2018 125.00 $71.9036 ($8,987.95) Purchase 8/27/2018 11,000.00 $72.0483 ($792,531.30) Purchase 8/31/2018 7,700.00 $70.9254 ($546,125.58) Purchase 9/10/2018 191,800.00 $69.6300 — ($13,355,034.00) Purchase 9/28/2018 107,600.00 $71.7400 ($7,719,224.00) Purchase 10/10/2018 45,400.00 $69.9500 ($3,175,730.00) Purchase 10/25/2018 23,400.00 $64.9700 ($1,520,298.00) Purchase 10/31/2018 11,680.00 $65.9479 ($770,271.47) Purchase 11/1/2018 110.00 $65.4600 ($7,200.60) Purchase 11/7/2018 4,840.00 $67.2706 ($325,589.70) Purchase 11/7/2018 30,300.00 $68.2600 ($2,068,278.00) Purchase 11/16/2018 11,815.00 $64.8837 ($766,600.92) Purchase 1/4/2019 32,154.00 $54.7844 ($1,761,537.60) Purchase 2/14/2019 34,600.00 $62.4200 ($2,159,732.00) Purchase 3/21/2019 39,800.00 $63.9100 ($2,543,618.00) Purchase 4/16/2019 42,500.00 $68.2478 ($2,900,531.50) Purchase 5/13/2019 19,100.00 $64.3800 ($1,229,658.00) Purchase 5/14/2019 29,600.00 $65.2600 ($1,931,696.00) Purchase 6/21/2019 56,900.00 $67.9700 ($3,867,493.00) Purchase 7/16/2019 33,100.00 $71.3200 ($2,360,692.00) Purchase 7/22/2019 21,783.00 $70.9804 ($1,546,166.05) Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Purchase 7/26/2019 22,000.00 $72.1600 ($1,587,520.00) Purchase 8/1/2019 22,500.00 $69.5230 ($1,564,267.50) Purchase 8/5/2019 24,300.00 $65.1800 ($1,583,874.00) Purchase 8/15/2019 33,500.00 $61.3200 ($2,054,220.00) Purchase 9/5/2019 4,155.00 $66.3400 ($275,642.70) Purchase 9/5/2019 21,300.00 $66.3400 ($1,413,042.00) Purchase 9/16/2019 7,200.00 $69.8300 ($502,776.00) Purchase 11/1/2019 36,000.00 $73.9490 ($2,662,164.00) Purchase 11/4/2019 18,000.00 $74.5927 ($1,342,668.60) Purchase 11/13/2019 49,400.00 $73.9100 ($3,651,154.00) Purchase 11/22/2019 18,000.00 $74.6977 ($1,344,558.60) Purchase 1/23/2020 16,876.00 $79.1324 ($1,335,438.38) Purchase 3/2/2020 76,900.00 $63.9692 ($4,919,231.48) Purchase 4/27/2020 500.00 $45.2554 ($22,627.70) Purchase 4/28/2020 60,000.00 $47.3699 ($2,842,194.00) Purchase 5/7/2020 68,000.00 $44.7719 ($3,044,489.20) Purchase 5/8/2020 68,000.00 $45.3186 ($3,081,664.80) Purchase 5/27/2020 62,000.00 $51.9846 ($3,223,045.20) Purchase 6/12/2020 7,600.00 $51.2200 ($389,272.00) Purchase 6/22/2020 1,657.00 $52.0600 ($86,263.42) Purchase 9/29/2020 76,138.00 $42.5113 ($3,236,725.36) Purchase 10/5/2020 9,372.00 $45.0045 ($421,782.17) Class Period Purchases Sold Out Prior to 8/10/2018 or Purchased and Sold InBetween Disclosures 5,238,931.00 ($345,204,024.80) Sale 1/21/2016 -7,419.00 $40.9117 $303,523.90 Sale 1/25/2016 -537.00 $40.3351 $21,659.95 Sale 1/27/2016 -781.00 $40.5600 $31,677.36 Sale 1/27/2016 -10,791.00 $41.0504 $442,974.87 Sale 2/12/2016 -8,600.00 $37.5400 $322,844.00 Sale 3/2/2016 -11,380.00 $41.5588 $472,939.14 Sale 3/18/2016 -2,300.00 $43.5420 $100,146.60 Sale 4/25/2016 -2,873.00 $46.5646 $133,780.10 Sale 4/25/2016 -5,750.00 $46.5015 $267,383.63 Sale 4/26/2016 -277.00 $47.0000 $13,019.00 Sale 4/26/2016 -16,388.00 $47.0562 $771,157.01 Sale 4/26/2016 -2,960.00 $47.0312 $139,212.35 Sale 5/4/2016 -11,520.00 $44.9534 $517,863.17 Sale 5/5/2016 -3,953.00 $44.4922 $175,877.67 Sale 5/20/2016 -27,200.00 $44.9000 $1,221,280.00 Sale 6/30/2016 -9,053.00 $42.3041 $382,979.02 Sale 7/1/2016 -9,195.00 $42.1964 $387,995.90 Sale 8/24/2016 -1,399.00 $46.7344 $65,381.43 Sale 9/7/2016 -4,661.00 $47.4163 $221,007.37 Sale 9/9/2016 -2,504.00 $47.8593 $119,839.69 Sale 9/9/2016 -16,823.00 $47.8974 $805,777.96 Sale 9/14/2016 -3,295.00 $46.9967 $154,854.13 Sale 9/14/2016 -19,370.00 $46.9391 $909,210.37 Sale 9/16/2016 -2,200.00 $46.4120 $102,106.40 Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Sale 9/21/2016 -10,424.00 $46.8880 $488,760.51 Sale 10/11/2016 -6,209.00 $49.4350 $306,941.92 Sale 10/11/2016 -3,451.00 $49.5342 $170,942.52 Sale 10/12/2016 -14,757.00 $48.8597 $721,022.59 Sale 10/20/2016 -3,286.00 $49.6230 $163,061.18 Sale 11/1/2016 -303.00 $49.1500 $14,892.45 Sale 11/2/2016 -8,657.00 $48.4774 $419,668.85 Sale 11/10/2016 -6,525.00 $52.4082 $341,963.51 Sale 11/16/2016 -10,900.00 $54.4614 $593,629.26 Sale 11/18/2016 -6,162.00 $55.6033 $342,627.53 Sale 11/18/2016 -407.00 $55.5324 $22,601.69 Sale 11/18/2016 -15,833.00 $55.4703 $878,261.26 Sale 11/23/2016 -23,003.00 $56.2934 $1,294,917.08 Sale 11/29/2016 -26,200.00 $55.5200 $1,454,624.00 Sale 12/7/2016 -15,761.00 $58.3045 $918,937.22 Sale 12/13/2016 -3,383.00 $58.9008 $199,261.41 Sale 12/16/2016 -43,114.00 $59.8529 $2,580,497.93 Sale 12/16/2016 -120.00 $59.7400 $7,168.80 Sale 12/16/2016 -8,600.00 $59.7510 $513,858.60 Sale 12/20/2016 -113,000.00 $60.8000 $6,870,400.00 Sale 12/21/2016 -12,230.00 $60.5587 $740,632.90 Sale 12/28/2016 -4,792.00 $60.4692 $289,768.41 Sale 1/3/2017 -36,900.00 $60.5900 $2,235,771.00 Sale 2/2/2017 -19,290.00 $55.8319 $1,076,997.35 Sale 2/2/2017 -3,750.00 $55.9734 $209,900.25 Sale 2/3/2017 -3,600.00 $57.6716 $207,617.76 Sale 2/8/2017 -14,197.00 $56.3494 $799,992.43 Sale 2/16/2017 -7,387.00 $60.0198 $443,366.26 Sale 2/16/2017 -2,426.00 $59.9350 $145,402.31 Sale 2/17/2017 -15,079.00 $59.9759 $904,376.60 Sale 2/17/2017 -7,606.00 $59.9950 $456,321.97 Sale 2/17/2017 -6,115.00 $59.9019 $366,300.12 Sale 2/23/2017 -7,549.00 $60.5246 $456,900.21 Sale 3/1/2017 -257.00 $61.7040 $15,857.93 Sale 3/2/2017 -14,426.00 $60.7631 $876,568.48 Sale 3/2/2017 -14,420.00 $61.0050 $879,692.10 Sale 3/8/2017 -57.00 $61.5988 $3,511.13 Sale 3/15/2017 -5,594.00 $61.1968 $342,334.90 Sale 3/17/2017 -16,300.00 $60.3700 $984,031.00 Sale 3/21/2017 -14,275.00 $58.1990 $830,790.73 Sale 3/28/2017 -3,628.00 $59.3655 $215,378.03 Sale 3/29/2017 -7,256.00 $59.5240 $431,906.14 Sale 3/30/2017 -3,627.00 $60.6519 $219,984.44 Sale 3/31/2017 -479.00 $60.2989 $28,883.17 Sale 4/4/2017 -2,383.00 $59.5137 $141,821.15 Sale 4/5/2017 -7,354.00 $60.3682 $443,947.74 Sale 4/5/2017 -7,356.00 $59.6955 $439,120.10 Sale 4/6/2017 -13,709.00 $59.8236 $820,121.73 Sale 4/20/2017 -50,600.00 $58.4100 $2,955,546.00 Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Sale 4/21/2017 -24,600.00 $57.7200 $1,419,912.00 Sale 4/21/2017 -30,700.00 $57.7200 $1,772,004.00 Sale 4/24/2017 -24,000.00 $59.4400 $1,426,560.00 Sale 4/25/2017 -24,100.00 $60.2100 $1,451,061.00 Sale 4/26/2017 -562.00 $60.1665 $33,813.57 Sale 4/26/2017 -23,800.00 $60.1000 $1,430,380.00 Sale 5/2/2017 -27,700.00 $59.7100 $1,653,967.00 Sale 5/3/2017 -511.00 $59.5028 $30,405.93 Sale 5/3/2017 -17,674.00 $60.2400 $1,064,681.76 Sale 5/10/2017 -6,809.00 $60.3700 $411,059.33 Sale 5/11/2017 -7,384.00 $60.7000 $448,208.80 Sale 5/17/2017 -14,723.00 $60.0840 $884,616.73 Sale 5/17/2017 -14,719.00 $60.1096 $884,753.20 Sale 5/18/2017 -3,828.00 $59.9162 $229,359.21 Sale 5/19/2017 -6,315.00 $61.2680 $386,907.42 Sale 5/24/2017 -2,817.00 $62.0065 $174,672.31 Sale 6/6/2017 -12,065.00 $61.0032 $736,003.61 Sale 6/7/2017 -2,456.00 $61.8315 $151,858.16 Sale 7/11/2017 -1,184.00 $66.8200 $79,114.88 Sale 8/30/2017 -9,944.00 $68.1807 $677,988.88 Sale 9/15/2017 -2,200.00 $69.0415 $151,891.30 Sale 9/29/2017 -3,552.00 $72.6451 $258,035.40 Sale 10/9/2017 -8,895.00 $75.2415 $669,273.14 Sale 10/23/2017 -17,790.00 $73.7067 $1,311,242.19 Sale 11/1/2017 -8,930.00 $73.9246 $660,146.68 Sale 11/2/2017 -10,053.00 $74.2441 $746,375.94 Sale 11/10/2017 -264,000.00 $72.2500 $19,074,000.00 Sale 11/29/2017 -9,470.00 $75.0931 $711,131.66 Sale 11/29/2017 -17,869.00 $75.0948 $1,341,868.98 Sale 12/1/2017 -17,890.00 $75.3218 $1,347,507.00 Sale 12/6/2017 -4,473.00 $75.2915 $336,778.88 Sale 12/15/2017 -3,400.00 $74.7700 $254,218.00 Sale 1/2/2018 -23,412.00 $74.2928 $1,739,343.03 Sale 1/10/2018 -18,730.00 $75.6336 $1,416,617.33 Sale 1/24/2018 -18,715.00 $79.2721 $1,483,577.35 Sale 1/25/2018 -313.00 $79.4500 $24,867.85 Sale 1/30/2018 -9,315.00 $78.8282 $734,284.68 Sale 1/31/2018 -15,406.00 $78.7689 $1,213,513.67 Sale 2/1/2018 -275.00 $78.4800 $21,582.00 Sale 2/2/2018 -23,154.00 $77.7248 $1,799,640.02 Sale 2/2/2018 -23,146.00 $77.8345 $1,801,557.34 Sale 2/8/2018 -18,520.00 $73.5186 $1,361,564.47 Sale 2/15/2018 -23,939.00 $76.8220 $1,839,041.86 Sale 2/15/2018 -12,043.00 $76.8085 $925,004.77 Sale 2/27/2018 -367,000.00 $76.3800 $28,031,460.00 Sale 2/28/2018 -148,000.00 $75.4900 $11,172,520.00 Sale 3/1/2018 -29.00 $75.4900 $2,189.21 Sale 3/6/2018 -6,441.00 $74.0589 $477,013.37 Sale 3/16/2018 -4,200.00 $73.4700 $308,574.00 Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Sale 4/9/2018 -4,715.00 $69.6813 $328,547.33 Sale 4/10/2018 -9,914.00 $70.9589 $703,486.53 Sale 5/9/2018 -1,147.00 $71.4814 $81,989.17 Sale 6/13/2018 -774.00 $67.4014 $52,168.68 Sale 6/28/2018 -3,880.00 $66.7884 $259,138.99 Sale 6/29/2018 -14,551.00 $67.6146 $983,860.04 Sale 7/5/2018 -3,665.00 $66.6465 $244,259.42 Sale 7/11/2018 -8,716.00 $68.1250 $593,777.50 Sale 7/12/2018 -270,000.00 $68.5100 $18,497,700.00 Sale 7/18/2018 -5,517.00 $69.9062 $385,672.51 Sale 7/20/2018 -200,000.00 $68.9991 $13,799,820.60 Sale 7/25/2018 -9,822.00 $71.2919 $700,229.04 Sale 7/26/2018 -9,823.00 $71.5030 $702,373.97 Sale 7/26/2018 -100,000.00 $71.3712 $7,137,120.00 Sale 7/27/2018 -19,645.00 $71.6031 $1,406,642.90 Sale 7/30/2018 -19,645.00 $72.5568 $1,425,378.34 Sale 7/30/2018 -875,000.00 $72.2900 $63,253,750.00 Sale 7/31/2018 -4,788.00 $72.0568 $345,007.96 Sale 8/2/2018 -35,269.00 $71.6385 $2,526,618.26 Sale 8/7/2018 -42,463.00 $72.6033 $3,082,953.93 Sale 9/21/2018 -1,600.00 $74.1500 $118,640.00 Sale 11/13/2018 -237,200.00 $64.7800 $15,365,816.00 Sale 11/14/2018 -481.00 $65.1316 $31,328.30 Sale 11/19/2018 -11,803.00 $65.1794 $769,312.46 Sale 11/20/2018 -4,359.00 $62.7747 $273,634.92 Sale 11/21/2018 -42,100.00 $62.8700 $2,646,827.00 Sale 11/27/2018 -2,360.00 $63.1631 $149,064.92 Sale 11/29/2018 -2,079.00 $65.0216 $135,179.91 Sale 11/30/2018 -1,326.00 $64.7284 $85,829.86 Sale 12/3/2018 -1,511.00 $65.3974 $98,815.47 Sale 12/4/2018 -1,584.00 $62.5295 $99,046.73 Sale 12/6/2018 -1,766.00 $59.1937 $104,536.07 Sale 12/7/2018 -1,176.00 $58.8931 $69,258.29 Sale 12/12/2018 -46,000.00 $56.6663 $2,606,649.80 Sale 12/21/2018 -2,900.00 $50.2400 $145,696.00 Sale 1/16/2019 -43,525.00 $62.1490 $2,705,035.23 Sale 1/28/2019 -38,854.00 $63.8259 $2,479,891.52 Sale 2/1/2019 -37,175.00 $64.0169 $2,379,828.26 Sale 3/15/2019 -4,800.00 $65.1900 $312,912.00 Sale 9/20/2019 -8,900.00 $69.3500 $617,215.00 Sale 12/3/2019 -135,500.00 $72.8284 $9,868,248.20 Sale 12/11/2019 -9,500.00 $75.5500 $717,725.00 Sale 12/12/2019 -13,920.00 $77.0500 $1,072,536.00 Sale 12/16/2019 -13,870.00 $76.9100 $1,066,741.70 Sale 12/20/2019 -11,460.00 $78.5100 $899,724.60 Sale 1/30/2020 -9,500.00 $75.5500 $717,725.00 Sale 1/30/2020 -20,000.00 $75.7650 $1,515,300.00 Sale 1/30/2020 -68,579.00 $75.9132 $5,206,051.34 Sale 1/30/2020 -10,500.00 $75.9350 $797,317.50 Transaction Type Trade Date Shares Price Per Share Cost/Proceeds (continued from previous page) Sale 2/25/2020 -10,000.00 $69.4300 $694,300.00 Sale 3/2/2020 -38,659.00 $64.1104 $2,478,443.95 Sale 3/11/2020 -47,390.00 $50.7900 $2,406,938.10 Sale 3/12/2020 -103,200.00 $43.2600 $4,464,432.00 Sale 3/16/2020 -121,736.00 $43.0087 $5,235,707.10 Sale 6/8/2020 -112,500.00 $60.4109 $6,796,226.25 Sale 6/10/2020 -146,000.00 $58.1644 $8,492,002.40 Sale 6/19/2020 -7,600.00 $52.9200 $402,192.00 Gain/(Loss) on Transactions Prior Sale 7/13/2020 -1,657.00 $52.4709 $86,944.28 to 8/10/2018 or In Sale 10/6/2020 -15,510.00 $44.4100 $688,799.10 & Out In-Between Sale 10/8/2020 -70,000.00 $44.7200 $3,130,400.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold Out Prior to 8/10/2018 or to Class Period Purchases Sold In-Between Disclosures -5,238,931.00 $345,356,286.98 $152,262.18 Purchase 7/14/2017 7,785.00 $66.6447 ($518,828.99) Purchase 7/26/2017 1,555.00 $68.2320 ($106,100.76) Purchase 7/28/2017 3,888.00 $67.4748 ($262,342.02) Purchase 7/31/2017 1,557.00 $68.1500 ($106,109.55) Purchase 8/1/2017 80.00 $68.4656 ($5,477.25) Purchase 8/9/2017 10,285.00 $68.4300 ($703,802.55) Purchase 8/14/2017 1,573.00 $67.9831 ($106,937.42) Purchase 8/16/2017 161,334.00 $67.6372 ($10,912,180.02) Purchase 8/18/2017 161,592.00 $67.0893 ($10,841,094.17) Purchase 8/31/2017 69,632.00 $67.9059 ($4,728,423.63) Purchase 10/10/2017 256,264.00 $75.1800 ($19,265,927.52) Purchase 4/27/2020 101,500.00 $45.2554 ($4,593,423.10) Purchase 6/12/2020 93,400.00 $51.2200 ($4,783,948.00) Purchase 6/22/2020 19,043.00 $52.0600 ($991,378.58) Purchase 7/17/2020 22,600.00 $50.2200 ($1,134,972.00) Purchase 7/20/2020 1,657.00 $50.1199 ($83,048.67) Purchase 7/23/2020 28,700.00 $52.0800 ($1,494,696.00) Purchase 7/27/2020 68,000.00 $51.1905 ($3,480,954.00) Purchase 8/6/2020 70,000.00 $50.8900 ($3,562,300.00) Purchase 9/29/2020 8,362.00 $42.5113 ($355,479.49) Purchase 10/9/2020 207,500.00 $44.9840 ($9,334,180.00) Purchase 10/12/2020 3,000.00 $45.4566 ($136,369.80) Total Class Period Purchases Held Through 8/10/2018 or Through a Disclosure or Multiple Disclosures 1,299,307.00 ($77,507,973.52) Sale 2/1/2019 -4,120.00 $64.0169 $263,749.63 Sale 3/16/2020 -20,464.00 $43.0087 $880,130.04 Sale 3/17/2020 -72,000.00 $41.2233 $2,968,077.60 Sale 4/14/2020 -30,500.00 $45.4200 $1,385,310.00 Sale 9/16/2020 -407,300.00 $45.5835 $18,566,159.55 Class Period Sales Matched to Class Period Purchases Held Through 8/10/2018 or Through a Disclosure or Multiple Disclosures -534,384.00 $24,063,426.81 Transaction Type Trade Date Shares Price Per Share Cost/Proceeds Sale 10/26/2020 -3,093.00 $43.4100 $134,267.13 Post-Class Period Sales Matched to Class Period Purchases Held Through 8/10/2018 or Through a Disclosure or Multiple Disclosures 7 -3,093.00 $134,267.13 Retained Shares * 761,830.00 $51.3698 $39,135,066.05 LIFO Gain/(Loss) Based on Dura: ($14,175,213.53) Dura LIFO Analysis - Citigroup 12/16/2016 50.00 Calls Number of Price Per Transaction Type Trade Date Contracts Contract Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 10/3/2016 5,000.00 $0.9082 ($454,100.00) Class Period Purchases Sold Out Prior to Gain/(Loss) on 8/10/2018 5,000.00 ($454,100.00) Transactions Prior to 8/10/2018 or In & Out In-Between Sale 10/19/2016 -5,000.00 $1.5015 $750,750.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold Out Prior to 8/10/2018 -5,000.00 $750,750.00 $296,650.00 LIFO Gain/(Loss) Based on Dura: $0.00 Dura * LIFO Analysis - Citigroup 01/20/2017 57.50 Puts Number of Price Per Transaction Type Trade Date Contracts Contract Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 12/8/2016 3,000.00 $1.2100 ($363,000.00) Class Period Purchases Sold Out Prior to Gain/( Loss) on 3,000.00 ($363,000.00) Transactions Prior to 8/10/2018 or In & Out In-Between Sale 11/10/2016 -3,000.00 $4.9933 $1,498,000.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold Out Prior to 8/10/2018 -3,000.00 $1,498,000.00 $1,135,000.00 LIFO Gain/(Loss) Based on Dura: $0.00 Dura‘ LIFO Analysis - Citigroup 01/20/2017 58.50 Puts Number of Price Per Transaction Type Trade Date Contracts Contract Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 12/20/2016 2,000.00 $0.8900 ($178,000.00) Class Period Purchases Sold Out Prior to Gain/{ Loss) on 8/10/2018 2,000.00 ($178,000.00) Transactions Prior to 8/10/2018 or In & Out In-Between Sale 1/12/2017 -2,000.00 $0.7700 $154,000.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold Out Prior to 8/10/2018 -2,000.00 $154,000.00 ($24,000.00) LIFO Gain/(Loss) Based on Dura: $0.00 Dura * LIFO Analysis - Citigroup 01/20/2017 62.50 Puts Number of Price Per Transaction Type Trade Date Contracts Contract Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 1/4/2017 3,000.00 $2.4000 ($720,000.00) Class Period Purchases Covering Class Gain/( Loss) on Period Sales Prior to 8/10/2018 3,000.00 ($720,000.00) Transactions Prior to 8/10/2018 or In & Out In-Between Sale 12/20/2016 -3,000.00 $2.6900 $807,000.00 Disclosures Class Period Sales Covered Prior to 8/10/2018 -3,000.00 $807,000.00 $87,000.00 LIFO Gain/(Loss) Based on Dura: $0.00 Dura * LIFO Analysis - Citigroup 07/20/18 65.00 Puts Number of Price Per Transaction Type Trade Date Contracts Contract Cost/Proceeds Gain/{Loss) on Pre-Class Period Position 1/15/2016 0.00 to 8/10/2018 or In & Out In-Between Purchase 6/19/2018 3,000.00 $0.9600 ($288,000.00) Disclosures Total Class Period Purchases Expired Prior to 8/10/2018 3,000.00 ($288,000.00) ($288,000.00) 3,000 contracts expired in July 2018 LIFO Gain/(Loss) Based on Dura: $0.00 Dura * LIFO Analysis - Citigroup 07/20/2018 69.00 Calls Number of Price Per Transaction Type Trade Date Contracts Contract Cost/Proceeds Gain/ ress) oi Pre-Class Period Position 1/15/2016 0.00 to 8/10/2018 or In & Out In-Between Sale 7/3/2018 -2,000.00 $0.4900 $98,000.00 Disclosures Total Class Period Sales Assigned Prior to 8/10/2018 -2,000.00 $98,000.00 $98,000.00 2,000 contracts assigned In July 2018 LIFO Gain/(Loss) Based on Dura: $0.00 Dura LIFO Analysis - Citigroup 06/21/2019 57.50 Calls Number of Price Per Transaction Type Trade Date Contracts Contract Cost/Proceeds Gain/ ress) oi Pre-Class Period Position 1/15/2016 0.00 to 8/10/2018 or In & Out In-Between Sale 2/12/2019 -2,000.00 $1.6045 $320,900.00 Disclosures Total Class Period Sales Sold and Expired InBetween 8/10/2018 and 8/13/2020 Disclosure -2,000.00 $320,900.00 $320,900.00 2,000 contracts expired in June 2019 LIFO Gain/(Loss) Based on Dura: $0.00 Dura * LIFO Analysis - Citigroup 06/21/2019 60.00 Puts Number of Price Per Transaction Type Trade Date Contracts Contract Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 5/3/2019 2,000.00 $0.2100 ($42,000.00) Class Period Purchases Purchased and Sold . In-Between 8/10/2018 and 8/13/2020 1 Gain/(Loss) on Disclosure 2,000.00 ($42,000.00) ransactions Prior to 8/10/2018 or In & Out In-Between Sale 5/23/2019 -1,000.00 $0.7724 $77,241.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold in-Between 8/10/2018 and 8/13/2020 Disclosure -1,000.00 $77,241.00 $35,241.00 1,000 contracts expired in June 2019 LIFO Gain/(Loss) Based on Dura: $0.00 LIFO Analysis - Citigroup Inc. 3.400% 05/01/2026 DD 05/02/16 Transaction Type Trade Date Par Value Price Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 4/26/2016 —25,000,000.00 $99.7980 ($24,949,500.00) Purchase 6/13/2016 5,000,000.00 $100.9610 ($5,048,050.00) Purchase 6/27/2016 2,500,000.00 $101.9450 ($2,548,625.00) Class Period Purchases Sold Out Prior to 8/10/2018 32,500,000.00 ($32,546,175.00) Sale 6/24/2016 = -6,000,000.00 $101.8260 $6,109,560.00 Sale 6/24/2016 —_-5,000,000.00 $101.5890 $5,079,450.00 Sale 6/24/2016 = -1,500,000.00 $101.8180 $1,527,270.00 Sale 6/28/2016 —_-5,000,000.00 $102.2160 $5,110,800.00 Gain/(Loss) on Sale 6/28/2016 —_-5,000,000.00 $102.2760 $5,113,800.00 Transactions Prior to 8/10/2018 or In Sale 9/27/2016 -5,000,000.00 $103.3850 $5,169,250.00 & Out In-Between Sale 9/28/2016 —-5,000,000.00 $103.5600 $5,178,000.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold Out Prior to 8/10/2018 -32,500,000.00 $33,288,130.00 $741,955.00 LIFO Gain/(Loss) Based on Dura: $0.00 Dura Analysis - Citigroup Inc. 2.350% 08/02/2021 DD 08/02/16 Transaction Type Trade Date Par Value Price Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 7/26/2016 10,000,000.00 $99.9300 ($9,993,000.00) Class Period Purchases Sold Out Prior to Gain/( Loss) on 8/10/2018 10,000,000.00 ($9,993,000.00) Transactions Prior to 8/10/2018 or In & Out In-Between Sale 9/16/2016 -10,000,000.00 $100.1360 $10,013,600.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold Out Prior to 8/10/2018 -10,000,000.00 $10,013,600.00 $20,600.00 LIFO Gain/(Loss) Based on Dura: $0.00 Dura? LIFO Analysis - Citigroup Inc. 2.900% 12/08/2021 DD 12/08/16 Transaction Type Trade Date Par Value Price Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 12/1/2016 10,000,000.00 $99.8290 ($9,982,900.00) Class Period Purchases Sold Out Prior to Gain/(Loss) on 8/10/2018 10,000,000.00 ($9,982,900.00) Transactions Prior to 8/10/2018 or In & Out In-Between Sale 3/17/2017 -10,000,000.00 $99.7000 $9,970,000.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold Out Prior to 8/10/2018 -10,000,000.00 $9,970,000.00 ($12,900.00) LIFO Gain/(Loss) Based on Dura: $0.00 Dura? LIFO Analysis - Citigroup Inc. Var Rt 04/23/2029 DD 04/23/18 Transaction Type Trade Date Par Value Price Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 5/11/2018 10,000,000.00 $98.6230 ($9,862,300.00) Purchase 5/15/2018 5,000,000.00 $97.7040 ($4,885,200.00) Total Class Period Purchases Held Through 8/10/2018 15,000,000.00 ($14,747,500.00) Sale 10/2/2018 — -5,000,000.00 $97.9510 $4,897,550.00 Sale 10/2/2018 — -5,000,000.00 $98.0510 $4,902,550.00 Sale 10/3/2018 — -5,000,000.00 $97.3570 $4,867,850.00 Class Period Sales Matched to Class Period Purchases Held Through 8/10/2018 -15,000,000.00 $14,667,950.00 LIFO Gain/(Loss) Based on Dura: ($79,550.00) Dura Analysis - Citigroup Inc. Var Rt 04/24/2025 DD 04/24/19 Transaction Type Trade Date Par Value Price Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 4/16/2019 —20,000,000.00 $100.0000 ($20,000,000.00) Purchase 5/21/2019 5,000,000.00 $100.5350 ($5,026,750.00) Class Period Purchases Purchased and Sold In-Between 8/10/2018 and 8/13/2020 Disclosure 25,000,000.00 ($25,026,750.00) Sale 10/15/2019 = -5,000,000.00 $103.6280 $5,181,400.00 Transaction Type Trade Date Par Value Price Cost/Proceeds (continued from previous page) Sale 10/31/2019 —-5,000,000.00 $103.8700 $5,193,500.00 Gain/(Loss) on Sale 12/19/2019 —-5,000,000.00 $103.6950 $5,184,750.00 Transactions Prior Sale 12/19/2019 -5,000,000.00 $103.7830 —-$5,189,150.00 to 8/10/2018 or In & Out In-Between Sale 1/2/2020 — -5,000,000.00 $104.1770 $5,208,850.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold in-Between 8/10/2018 and 8/13/2020 Disclosure -25,000,000.00 $25,957,650.00 $930,900.00 LIFO Gain/(Loss) Based on Dura: $0.00 Dura * LIFO Analysis - Citibank NA 3.050% 05/01/2020 DD 05/01/18 Transaction Type Trade Date Par Value Price Cost/Proceeds Pre-Class Period Position 1/15/2016 0.00 Purchase 4/23/2018 25,000,000.00 $99.9540 ($24,988,500.00) Class Period Purchases Sold Out Prior to 8/10/2018 25,000,000.00 ($24,988,500.00) Gain/(Loss) on Sale 5/11/2018 -10,000,000.00 $99.8950 $9,989,500.00 Transactions Prior to 8/10/2018 or In Sale 5/14/2018 — -5,000,000.00 $99.8910 $4,994,550.00 & Out In-Between Sale 5/15/2018 -10,000,000.00 $99.8330 $9,983,300.00 Disclosures Class Period Sales Matched to Class Period Purchases Sold Out Prior to 8/10/2018 -25,000,000.00 $24,967,350.00 ($21,150.00) LIFO Gain/(Loss) Based on Dura: $0.00 ! Dura loss is the summation of the cost of Class Period purchases held through 8/10/2018, which KBC and Pembroke contend Is a disclosure, the pled partial disclosures on 8/13/2020, 8/17/2020, 8/19/2020, 9/7/2020, 9/14/2020 and 9/15/2020 and/or the final disclosure on 10/13/2020 (the "Disclosures"), proceeds of sales matched to purchases held through a Disclosure and the value of retained shares based on the 90-day lookback average. ? Period sales are valued at the maximum of the actual sale price and the average price on the date of sale. 3 Public Sector Pension Investment Board made the follo wing purchases after the Class Period: 587 shares on 10/19/2020 at $43.0385 per share, 40,000 shares on 11/2/2020 at $42.3106 per share, 403 shares on 11/2/2020 at $42.1178 per share, 164,500 shares on 11/9/2020 at $48.1611 per share, 81,800 shares on 11/10/2020 at $47.8632 per share and 66,660 shares on 11/24/2020 at $57.06 per share. Post-Class Period sales that match to post-Class Period purchases on a LIFO basis were excluded from the LIFO analysis. * Shares retained at the end of the Class Period are valued at the average price from October 13, 2020 to December 29, 2020.