In re Citigroup Securities Litigation

CourtDistrict Court, S.D. New York
DecidedNovember 13, 2025
Docket1:20-cv-09132
StatusUnknown

This text of In re Citigroup Securities Litigation (In re Citigroup Securities Litigation) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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In re Citigroup Securities Litigation, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

IN RE CITIGROUP SECURITIES 20 Civ. 09132 (LAP) LITIGATION MEMORANDUM & ORDER

LORETTA A. PRESKA, Senior United States District Judge: Before the Court is Plaintiffs’1 motion for leave to amend 0F the Consolidated Amended Class Action Complaint (“CAC”),2 (the F “Motion”).3 Citigroup Inc. (“Citigroup” or “Citi”) and three 2F Citigroup officers (the “Officer Defendants”),4 (together 3F “Defendants”), oppose the motion on grounds of futility and undue delay.5 For the reasons set forth below, Plaintiffs’ Motion is 4F DENIED.

1 Plaintiffs include Lead Plaintiff Public Sector Pension Investment Board (“PSP” or “Lead Plaintiff”) and Named Plaintiff Anchorage Police & Fire Retirement System (“Anchorage”), (together “Plaintiffs”). Plaintiffs are acting on behalf of a putative class of purchasers of Citigroup’s securities. 2 (Consol. Am. Class Action Compl., dated Apr. 20, 2021 [dkt. no. 72].) 3 (Pls. Mot. For Leave to Amend, dated May 24, 2023 [dkt. no. 146]; Pls.’ Mem. of Law in Support of Mot. for Leave to Amend (“Pls. Mem.”), dated May 24, 2023 [dkt. no. 147]; Decl. of Javier Bleichmar in Support of Mot. for Leave to Amend (“Bleichmar Decl.”), dated May 24, 2023 [dkt. no. 148]; Decl. of Benjamin F. Burry in Further Support of Mot. for Leave to Amend (“Burry Decl.”), dated Aug. 4, 2023 [dkt. no. 157]; Pls.’ Reply Mem. of Law in Further Support of Mot. for Leave to Amend (“Pls. Reply”), dated Oct. 27, 2023 [dkt. no. 163]; Plaintiffs’ Letter to Judge Preska (“Pls. Letter”), dated April 23, 2024 [dkt. no. 166].) 4 Officer Defendants are Michael L. Corbat, John C. Gerspach, and Mark A. L. Mason. 5 (Defs.’ Mem. of Law in Opp’n to Pls.’ Mot. for Leave to Amend (“Defs. Opp’n”), dated July 7, 2023 [dkt. no. 152]; Decl. (cont’d) I. Factual Background On April 20, 2021, Plaintiffs filed a CAC alleging (1) securities fraud claims under Section 10(b) of the Exchange Act

and SEC Rule 10b-5 against Citigroup, Officer Defendants, and seventeen Citigroup directors (the “Director Defendants”), and (2) control person claims under Section 20(a) of the Exchange Act against Officer Defendants. (CAC ¶¶ 28-53, 575-586.) Defendants filed a Federal Rule of Civil Procedure (“FRCP”) 12(b)(6) motion to dismiss the CAC claiming Plaintiffs failed to plead two of the six elements required to state a claim under Section 10(b) and Rule 10b-5: (i) a material misrepresentation or omission and (ii) scienter. (See dkt. no. 116.) This Court agreed,6 and Defendants’ 5F motion to dismiss was granted. (Op., dated Mar. 24, 2023 [dkt. no. 139] at 31.) a. Second Amended Complaint Plaintiffs’ proposed Second Amended Complaint (“SAC”) consolidates the nearly sixty statements identified in the initial CAC to eight alleged misrepresentations. (Pls. Mem. at 1.) In addition to narrowing the allegations, the SAC drops the previously

(cont’d) of Sharon L. Nelles in Support of Defs.’ Opp’n (“Nelles Decl.”), dated July 7, 2023 [dkt. no. 153]; Defs.’ Letter to Judge Preska (“Defs. Letter”), dated April 16, 2024 [dkt. no. 165].) 6 The Court also held that “[b]ecause . . . Plaintiffs have failed to establish a primary violation of the securities laws, their section 20 claim necessarily collapses and is dismissed.” (Op. at 63.) named Director Defendants, shortens the Class Period to begin in February of 2017-rather than January of 2016-and offers new information from “12 high-level Former Employees [(‘FEs’)]”

working at Citigroup during the Class Period. (Id.) Notably, five of the eight misrepresentations, with some minor revisions, have previously been heard by this Court. (Id.) Plaintiffs argue that “[t]aken together, these allegations establish that Citi’s risk management systems were deficient throughout the Class Period, that Defendants concealed these material facts, and that they knew—or at least recklessly disregarded—that the risk management systems were so deficient that their statements, descriptions, and omission of the material truth was misleading.” (Pls. Mem. at 3.) To clarify which misrepresentations still stand, in addition to the new misrepresentations, a revised overview of the alleged misstatements is set forth below. i. Three Previously Alleged Misstatements: Annual Reports

Plaintiffs renew their challenge to previously alleged misstatements from Citigroup’s Annual Reports. (See Op. at 12- 13, 16-17 (CAC ¶¶ 333, 362 (“Alleged Misstatement 11”); CAC ¶¶ 335, 364 (“Alleged Misstatement 12”); CAC ¶ 379 (“Alleged Misstatement 21”)).) In the SAC, Plaintiffs combine these statements into one misrepresentation and allege it qualifies as three separate misstatements because it appears in Citigroup’s 2016, 2017 and 2018 Annual Reports:7 6F Citi’s firm-wide Risk Governance Framework consists of the policies, procedures, and processes through which Citi identifies, measures, manages, monitors, reports, and controls risks across the firm. . . . The Risk Governance Framework has been developed in alignment with the expectations of the Office of the Comptroller of the Currency (OCC) Heightened Standards. It is also aligned with the relevant components . . . of the Federal Reserve’s Enhanced Prudential Standards for Bank Holding Companies and Foreign Banking Organizations.

(SAC ¶¶ 284, 288, 296 (alteration in original).) ii. One Previously Alleged Misstatement: Mr. Corbat’s Statement

Plaintiffs also renew their challenge to Mr. Corbat’s statement in a September 10, 2020 press release titled “Citi CEO Michael Corbat Announces Plans to Retire in February 2021” in which Mr. Corbat said: We completed our transformation from the financial crisis and emerged a simpler, safer and stronger institution. . . . [A]s the world’s most global bank, safety and soundness always have to be a foundation of our institution. We have launched significant investments in our infrastructure as part of our push to make strengthening our risk and control environment a strategic priority for the firm. (SAC ¶ 142 (alteration in original) (emphasis omitted).)8 7F

7 The 2017 and 2018 Annual Reports substitute “firm” for “Company,” but otherwise the language is the same. (See SAC ¶¶ 284, 288, 296.) 8 (See Op. at 20 (CAC ¶ 431 (“Alleged Misstatement 34”)).) iii. Four Alleged Misstatements: Project Rainbow Four of Plaintiffs’ alleged misstatements involve a risk management initiative called “Project Rainbow.” Project Rainbow

was created to address Citigroup’s infrastructural and technological shortcomings but was abandoned in 2017. (SAC ¶¶ 89- 94.) 1. Renewed but Revised Alleged Misstatement: Exchange During the Bernstein 2017 Strategic Decisions Conference

Plaintiffs renew their challenge to an exchange between Mr. Corbat and a Bernstein analyst during the Bernstein 2017 Strategic Decisions Conference,9 but add an additional sentence in Mr. 8F Corbat’s response, underlined below: JOHN MCDONALD: And just wrapping up the conversation about efficiency, you’ve done a lot of investment spending, you’ve done some big projects upgrading major systems in the Investment Bank, the Global Consumer Bank, and currently investing $1 billion in Mexico. Where are you on kind of these big projects? Are you kind of at the tail end of the major big projects you set upon the last couple of years? Where are you in that cycle of spend?

CORBAT: From an infrastructure perspective, we’ve got, really if not all, certainly most of the systems or base systems that we need . . . . [W]e’ve spent all the energy and effort in terms of creating these systems that have the ability to come back and communicate centrally . . . .

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