Investments and Fiduciary Risk Management (IFRM) is responsible for managing client conduct risks (primarily suitability and fiduciary risk) associated with the manufacture, sale, and distribution of investments products and trust and fiduciary services to individual investors. IFRM's coverage spans the Personal Bank & Wealth Management (PBWM) and the Institutional Clients Group (ICG) divisions of Citi. Citi's Global Wealth Management business serves clients with an aggregate of over $800bn in assets held in deposits, investments, custody and trust at Citi - ranging from Affluent clients (net worth >$200k), through High Net Worth clients (net worth between $10m to $25m), to Ultra High Net Worth clients (net worth above $25m). Within the Institutional Client Group, IFRM covers the