Citigroup's Place on a Roll of Shame

Sandy Weill, who created the largest bank in the nation, ran Citigroup as CEO until 2003.

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NEW YORK (Fortune) -- This week is Masters golf time, a fact that takes me back precisely 11 years ago to an afternoon when I walked the grounds of the Augusta National course with Sandy Weill as he basked in the glory of the just-announced Citigroup (C, Fortune 500) merger deal between his company, Travelers Group, and Citicorp.

Weill, an Augusta member, was there for the golf and various events orchestrated by Travelers (then a Masters sponsor). Getting my first on-the-ground exposure to the famous tournament, I savored the golf as well. But my real purpose for being there was to report a major FORTUNE article that we published 10 days later, A Helluva Candy Store. In it, I described Weill as having happily experienced "the most electric week in his life."

Well, as the world knows, that electricity got grounded. No banking company is today more worrisome, to more regulators, than Citigroup.

Still, Citi -- too big and interconnected to fail and pumped up by government money -- survives. So I was therefore especially startled when a FORTUNE subscriber pointed out to me that Citi is conspicuous on a list of "Failures and Assistance Transactions" that is posted, quite obscurely, on a Federal Deposit Insurance Corp. website. The data goes back to the panic year of 1934, the first year of the FDIC's operation.

In the more recent panic year of 2008, the FDIC handled 25 true failures. They ranged from tiny Hume Bank, of Hume, Mo., with its $14 million in deposits, to the very large Washington Mutual Bank, with $188 billion. (Wamu, of course, was taken over by JPMorgan Chase).

But in the midst of these failures are five items of "assistance," listed together. They are all Citigroup banks: Department Stores National Bank (deposits: $301 million); Banamex USA ($876 million); Citicorp Trust Bank FSB ($7.2 billion); Citibank (South Dakota) N.A. ($42 billion); and one of the largest holders of deposits in the nation, Citibank National Association ($230 billion).

How did Citigroup's banks get on this list? Because on Nov. 23, the U.S. government, by way of the Treasury and the FDIC -- and the Federal Reserve, as an ultimate backstop -- stepped in to guarantee up to $306 billion of Citi's assets. The FDIC's maximum exposure, which qualifies as its "assistance," is $10 billion.

Technically, the FDIC aid amounted to what it calls "open-bank assistance," and an absolute rarity this is. Before Citi rudely inserted itself into this picture, the last instance of such assistance was in 1992, when a small bank in Princeton, Texas, was propped up by the FDIC because it was judged vital to its community.

But neither competitors nor Congress liked open-bank assistance, wondering why the institutions getting it shouldn't just be allowed to fail. So a 1991 banking law called FDICIA, and a subsequent amendment to a related law, essentially barred the FDIC from granting such assistance -- except in instances of systemic risk.

And even then, the procedures set up by the law for determining that systemic risk truly existed were extraordinary. The law says that before assistance can be granted two-thirds of the boards of the FDIC and the Federal Reserve must first recommend the step and that the Secretary of the Treasury, before making a final determination, must confer with the President.

So did Treasury Secretary Henry Paulson make a trip to the Oval Office last November, or even make a phone call, to consult with President Bush and say that FDIC assistance -- and much more -- must be granted Citi? Or did the exigencies of the financial crisis sweep aside procedure?

We may know a precise answer to those questions when Hank Paulson completes the book that he is known to be feverishly writing. For now, what we know is that the second-largest banking company in the nation, Citigroup -- founded 11 years by an exuberant Weill -- will forever have its banks tabulated on the FDIC's list of "Failures and Assistance."