The Settlement Agreement provided that an independent monitor, Thomas J. Perrelli, be appointed to determine whether Citi satisfied its consumer relief obligations. It was the role of the Monitor to track Citi’s progress, to keep the public informed, and ultimately to establish and certify that Citi met its obligations.
Role of the Monitor
The Monitor ultimately determined and certified that Citi met the consumer relief obligations set forth in the Settlement Agreement. The Monitor provided the public with thirteen reports regarding Citi’s progress toward completion of its obligations. The first report was issued in early 2015, and the final report was issued in November 2020.
All consumer relief under the Settlement Agreement had to be completed no later than December 31, 2018, although Citi could and did submit its requests for credit for some of that relief after that date. If the Monitor had determined that Citi did not complete its obligations by that date, Citi would have been required to make a cash payment of any remaining obligation to NeighborWorks America, a non-profit organization that provides housing counseling, neighborhood stabilization, foreclosure prevention, and other similar programs. However, the Monitor determined that Citi completed its obligations by December 31, 2018, making such a payment unnecessary.
About the Monitor and Team
Thomas J. Perrelli, Monitor
Thomas J. Perrelli is the Chair of Jenner & Block LLP, as well as a Partner in the firm, having re-joined Jenner in 2012 after serving for three years as Associate Attorney General of the United States. In his capacity as Associate Attorney General, Mr. Perrelli was responsible for the Department’s Civil, Antitrust, Civil Rights, Environment and Natural Resources, and Tax Divisions, the United States Trustee Program, the Office of Justice Programs, and the Office on Violence Against Women, among others. As Associate Attorney General, Mr. Perrelli led the Government’s efforts in negotiating the National Mortgage Settlement, a $25 billion settlement with the nation’s five largest mortgage servicers to address mortgage servicing, foreclosure, and bankruptcy abuses. Mr. Perrelli is the founder and Chair of Jenner & Block’s Government Controversies and Public Policy Litigation Practice.
Kali N. Bracey
Kali N. Bracey is a Partner at Jenner & Block. She is a Co-Chair of the firm’s Consumer Law Practice and of its State Enforcement and Regulation Practice as well as a member of its Government Controversies and Public Policy Litigation Practice. Ms. Bracey re-joined Jenner & Block in 2017, after serving in the federal government for five years. In 2014, she joined the U.S. Department of Justice’s Civil Division, serving for nearly three years as a Deputy Assistant Attorney General for the Torts Branch. In that role, she oversaw four sections: Environmental Torts, Constitutional and Specialized Torts, Aviation and Admiralty, and the Federal Tort Claims Act. She also managed the government’s tort compensation programs, including the September 11th Victims Compensation Fund, the Vaccine Compensation Fund, and the Radiation Exposure Compensation Act Fund. Before that, Ms. Bracey worked for the Consumer Financial Protection Bureau, first as a senior counsel in the Office of Supervision Policy and then as senior counsel to Director Richard Cordray.
Emily M. Loeb
Emily M. Loeb is a Partner at Jenner & Block. She is a Co-Chair of the firm’s Government Controversies and Public Policy Litigation Practice and a member of its Investigations, Compliance and Defense Practice. Ms. Loeb joined Jenner & Block in 2016 after more than six years in senior positions in the Executive Branch. Her most recent Executive Branch role was serving as an Associate Counsel in the Office of the White House Counsel, where she advised senior White House and Executive Branch Agency officials on responses to congressional and other investigations, risk management issues, and high priority litigation. Before joining the Office of the White House Counsel, Ms. Loeb served in several roles at the U.S. Department of Justice, including Senior Counselor and Acting Chief of Staff for the Civil Rights Division. In 2012, she served as a special assistant U.S. attorney in the Eastern District of Virginia, where she prosecuted federal drug and wire fraud cases.