Citigroup Staff Member'S Association

“The trust does not have any committees.”

“The form 990 is prepared by an independent accounting firm based on information provided by the association and in consultation with its staff. The draft prepared by the accounting firm is then carefully reviewed by the sponsor's finance, tax, corporate benefits and legal department for review and comment prior to filing with the irs.”

“Employees are required to annually disclose their interests that could give rise to conflicts of interests. Completed conflicts of interest disclosure forms are reviewed by the human resources department and disclosed conflicts are reviewed by chief of human resources.”

“Financial reports are made public pursuant to irs filing requirements. Written requests for other information is forwarded to appropriate authorities for consideration.”

“The benefit plans funded by veba trusts are subject to erisa rules, which imposes requirements for fiduciary conduct, avoiding related party transactions (self-dealing), providing for disclosure to participants, etc.”

“A veba trust has its trustee(s) appointed by the employer sponsoring the underlying benefit plan. These trustees and other plan fiduciaries are subject to erisa standards for fiduciary conduct, and are bound by terms of underlying plan documents and/or collective bargaining agreements. These standards and/or contractual obligations provide the governance and management transparency that the irs is looking for in this section.”

“The process has not changed from the prior year.”

“Any assistance provided, such as the payment of any benefit in connection with the provisions of the veba trust to employees of the sponsoring employer is not to be reported in schedule i or schedule f.”

“This question does not apply to a veba. Any assistance provided, such as payment of a benefit, can only be done pursuant to the nondiscrimination rules in section 505.”

“The company policy has traditionally been to expense and subsequently fund certain corporate welfare plans incurred but not reported (ibnr) through a contribution to the citigroup staff members' assocation welfare benefit trust (the veba trust). This ibnr funding has been done annually at year-end and has covered self-insured medical and dental plan claims, as well as claims under a legacy citibank long-term disability plan. This year the veba will be funded in respect of postretirement medical and life insurance benefits as well as medical claims for former employees who are receiving benefits under citi's long term disability plan. The company has funded the amounts in excess of the ibnr for multiple years as permitted under applicable tax law.”