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U.S. General Services Administration Delinquency Management Deanne Burbee Senior Vice President Citi July 2012

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Page 1: Delinquency Management Deanne Burbee Senior Vice ... - Citi · Delinquency Management Deanne Burbee Senior Vice President ... Training Request Form Distance Learning–Video Conferences

U.S. General Services Administration

Delinquency Management

Deanne Burbee

Senior Vice President

Citi

July 2012

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2012 GSA SmartPay Conference

“Fine Tune Your Payments Program with GSA SmartPay”

This material is intended for use by the GSA only

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House Rules

®

Delinquency Management

(agency name)

To ensure the best possible learning experience for participants, please adhere

to the following house rules:

• Turn electronic devices to vibrate

• No video-taping or audio recording is allowed

• Hold questions to end of session

• Ensure your participant badge is scanned to receive CLP credits

− For each course

• Take advantage of opportunities to provide feedback

− Please select the “Citi Q&A” icon on any Citi PC at the conference

− Answers to be e-mailed after the conference within 60 days

DoD Travel

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®

Schedules Available at the Welcome Center DoD Travel

4

Delinquency Management

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Delinquency Management

Visit the Citibank Welcome Center–Governor’s Lobby

Visit the Citibank One-on-One Lab–Governor’s Chambers D&E

Citi Q&A Link–Tell us your thoughts

®

Reminders DoD Travel

5

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®

Interactive Training Events–DoD DoD Travel

Citi offers on-site training at no cost for agencies meeting the required minimum participant level of 20 or more as set forth in the GSA SmartPay2 Master Contract.

Regional Citi Training Locations

– Norfolk, VA

– Washington, DC

– Visit www.defenseTravel.dod.mil/passport to view and register for these sessions

Upcoming Training

– Visit www.defenseTravel.dod.mil/passport to view and register for these sessions

On-site at your base or installation

– 20-participant minimum

– Visit www.citimanager.com/dodhome under Resources to download the On-site Training Request Form

Distance Learning–Video Conferences

Please e-mail us at [email protected] and a Citi training coordinator will work with you directly for on-site or Distance Learning sessions.

Delinquency Management

6

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This course is designed to assist you in

achieving the following objectives:

• To provide information for new and existing

AOPCs on how to best manage and

minimize delinquency in your Individually

Billed Travel Card Program

Goals & Objectives

®

Delinquency Management

Department of

DefenseDoD Travel

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1. Delinquency Overview

2. Delinquency Timeline/Critical Dates

3. Common Causes of Delinquency

4. Citi Collection Efforts

5. Best Practices/AOPC Controls

6. Delinquency Management Reports/Tools

7. Current DoD Travel Card Results

8. Summary - Q&A/Contact Info

Agenda

®

Delinquency Management

DoD Travel

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1. Delinquency Overview

®

Delinquency Management

9

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Delinquency Management

Delinquency Overview

Cards are individual liability

– The cardholder is solely responsible for the

timely payment of balance upon receipt of

billing statement

GSA Contract requires usage of the card

for all government travel

– Cardholder is only reimbursed for “official”

government travel; personal use of card

IS NOT allowed

®

DoD Travel

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Delinquency Management

Cardholder payment options

– Split disbursement (mandatory for Active Duty military)

– Alternative payment options

– Additional payment information is available online at www.citimanager.com/dodhome

under Resources; APC Guides; Payment Options Guide

Reimbursement questions/issues contact DFAS Travel Assistance Center at

1-888-HELP1GO

Delinquency Overview (continued)

Payment Type Method to Submit Payment

ChecksCitibank Gov’t Card Services

P.O. Box 183173, Columbus, OH 43218-3173

Wire If made before 1:00 pm EST, should post the same business day

ACHCardholder can call (866) 670-6461 to pay by phone through their

personal DDA account–free of charge

Cardholder

Statements &

Payments (CSP)

Cardholder can make an online payment using their personal

checking (DDA) account–free of charge

®

DoD Travel

11

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2. Delinquency Timeline Overview

®

Delinquency Management

12

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Delinquency Management

Delinquency Timeline Overview

Account Delinquency

– GSA contract references the number of days past the

cycle date; “clock” starts ticking when the account

cycles and a statement is generated with a balance

owing

Critical Timelines/Events

– 61 Days Past Billing = Account suspension

Account reopens after posting of full past due

payment

– 75 Days Past Billing = Late Fee Assessed

$29.00

– 126 Days Past Billing = Account cancellation

(permanently closed)

Cardholder has received (6) letters, (5) statements

and numerous calls from a Citi Collections

Specialist to attempt a reasonable payment

arrangement®

DoD Travel

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Delinquency Management

Delinquency Timeline Overview (continued)

– Approximately 126+ Days Past Billing–Account sent to DFAS for Salary Offset

processing

– 211 Days Past Billing (charge-off) = Reported to Cardholder’s Personal Credit

Bureau; and may be referred to Collection Agency or Attorney for additional

Collection efforts

Additional Account Cancellation Scenarios:

– (2) NSF checks within (12) month period

● Reinstatement: Reinstatement is not guaranteed, must meet eligibility criteria

– AOPC submits Reinstatement Application to (866) 951-8005. If application is…

Approved: $29 reinstatement fee applied on first statement; account will be reopened as a

restricted card ($4,000 credit limit)

Denied: Should wait 60 days to reapply

One reinstatement permitted in life of account

®

DoD Travel

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Delinquency Management

Delinquency Timeline Overview

®

Days Past

Billing

Activity

System-Generated

LetterEvents

0 Original Cycle Date

25 Original Payment Due Date

30 2nd Cycle

45 Past Due Letter

55 Pre-Suspend Letter

61 Suspend Letter Account Suspends

91Due Process/RPP Letter

100

121 Pre-Cancellation Letter

126 Cancellation Letter Account Cancels/Closes

Salary Offset File sent to DFAS

131 Salary Offset Inbound File from DFAS

211 Account Charges Off/Reports to Personal Credit Bureau

DoD TravelDoD Travel

15

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Delinquency Management

Delinquency Fee Timeline

®

Days Past

Billing

Activity

Fee Type Fee Amount

0 Original Cycle Date

25 Original Payment Due Date

30 2nd Cycle

75 1st Late Fee $29

105 2nd Late Fee $29

126+ Salary Offset Fee $80

135 3rd Late Fee $29

165 4th Late Fee $29

195 5th Final Late Fee $29

Assuming the cardholder does not make a full past due payment, the total fees assessed on the account prior to charge-off

total $225

Without a full payment of the past due amount, fees will continue to be assessed each statement cycle until the account

charges off

Payment of full past due amount prior to due date will prevent subsequent Late Fees

DoD Travel

16

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3. Common Causes of Delinquency

®

Delinquency Management

17

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Delinquency Management

Common Causes of Delinquency

Slow/manual reimbursements by agency

– DTS “issues”

– DTS “kicking claim back without cardholder being notified”

– DTS/Cardholder errors with Split Disbursement option

Late or non-submission of travel vouchers

– “Still on travel have not yet filed”

– Waiting on final levels of approval

– Change in Duty Station (PCS) or (TDY)

NSF returned checks

Unclear on policy and/or procedures

– DoD 101–Travel Card Training is available on the GSA SmartPay website

Employee misuse

– Spending reimbursement vs. paying Travel Card

– Using card for personal use/Miscalculating Per Diem

Causes

®

DoD Travel

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Delinquency Management

Common Causes of Delinquency (continued)

Causes

®

Cardholders believe that:

They don’t have to pay until after they are reimbursed

They don’t have to pay/file voucher until after they return from travel

They are not responsible for late fees or salary offset fees

The account will not report to personal Credit Bureaus

They can use Card for personal use–card is not a Personal credit card, it is a

Government Travel Card

Separated Military Cardholders believe that:

Balance is no longer their responsibility, especially if balance includes fees

Once discharged from the DoD that collections efforts will cease

APC/prior Command is unable to assist Citi with Cardholder information

DoD Travel

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4. Citi Collection Efforts

®

Delinquency Management

20

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Delinquency Management

Citi Collection Efforts–Collection Letters

Past due letter (sent at 45 days past

billing)

– Advises account is currently past due and to

pay immediately to avoid suspension of

charging privileges

Pre-suspend letter (sent at 55 days

past billing)

– Advises account is past due and if payment

is not sent within (6) days of the date of the

letter, charging privileges will be suspended

Suspend letter (sent at 61 days past

billing)

– Advises charging privileges have been

suspended due to non-payment. States they

will automatically be restored when payment

for past due amount has been received

®

DoD Travel

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Delinquency Management

Citi Collection Efforts–Collection Letters (continued)

Pre-cancellation/Due Process Letter (sent

at 91 days past billing)

– Advises account is currently suspended and

subject to cancellation if payment not received

within (6) days. References the potential for

salary offset, and if there are any extenuating

circumstances that prevent payment, to contact

your AOPC immediately

Cancellation Letter (sent at 126 days past

billing)

– Advises that account has been canceled and will

be added to the “Cancellation Report” that will be

viewed by their AOPC and Commanding

Officer/Supervisor. Also advises that their account

will be sent for Salary Offset consideration

®

DoD Travel

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23

Delinquency Management

Citi Collection Efforts–Collection Calls

Cardholder is contacted by a DoD

Collection Specialist beginning at 61

days past billing. The goal at this stage

is to resolve the delinquency

Calls will continue until payment and/or

acceptable arrangements have been

made; frequency of calls is determinate

upon call response, account balance

and follow-through on prior promise to

pay arrangements

The DoD Collection Specialist will

attempt to resolve the delinquency by

discussing available payment options,

including Reduced Payment Programs

®

DoD Travel

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Delinquency Management

Citi Collection Efforts – Collection Calls (continued)

Upon charge-off (211 days past billing)

the account reports as a R9 charge-off

on cardholder’s personal bureau

Once account charges off, it may be

referred to a third-party collection

agency and/or legal network to pursue

more stringent collection efforts

Once Citi deems the account to be

uncollectable and/or all collection

efforts have been exhausted, Citi is

required to generate a 1099-C on all

accounts with a balance owing of

greater than $600

®

DoD Travel

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Delinquency Management

Citi Collection Efforts–Statement Messages

# Days Past

BillingStatement Message

31–60

“We did not receive your payment last month. Please pay the total

balance due at once. If you have remitted payment, please disregard this

notice.”

61–90“Your account is past due and your charging privileges have recently been

suspended. Please pay the past due balance immediately.”

91–120

“Your account is seriously past due and may be canceled and submitted

for Salary Offset if a payment is not received within 30 days. Please

contact us at 1-866-670-6461 to discuss payment options.”

121–150

“Your account is seriously past due and may be canceled and submitted

for Salary Offset if a payment is not received immediately. Please call

1-866-670-6461 to pay by phone or visit home.cards.citidirect.com to

make an online payment.”

®

DoD Travel

25

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Delinquency Management

Citi Collection Efforts–Statement Messages (continued)

# Days Past

BillingStatement Message

151–180

“Your past due account has been canceled and submitted for Salary Offset.

You are still responsible for ensuring your balance is paid in full. Please call

1-866-670-6461 to pay by phone or visit home.cards.citidirect.com to

make an online payment.”

181–210

“The past due balance on your canceled account has not been paid in full.

Please be aware you are still responsible for ensuring your past due

balance is paid in full, even if your account may have been submitted for

Salary Offset. Please call 1-866-670-6461 to pay by phone or visit

home.cards.citidirect.com to make an online payment.”

Charge-Off

“The past due balance on your canceled account has not been paid in full

and may now be reported to the credit bureaus. Please call 1-866-670-

6461 to pay by phone or visit home.cards.citidirect.com to make an

online payment.”

®

DoD Travel

26

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Delinquency Management

Varying RPP programs have been created to assist Cardholders with their individual

financial situations

Citi Collection Efforts–Reduced

Payment Program

RPP Programs

(2) MonthCommitment from Cardholder is that they can resolve delinquency (past due amount within

two statement cycles); monthly late fees will be assessed while on this program; only

available prior to cancellation; account could remain open for use.

(3) Month

Commitment from Cardholder is that they can resolve delinquency (past due amount within

three statement cycles); a one-time enrollment fee of $45 is assessed; a monthly $10 RPP

fee and monthly late fees ($29) are assessed while on this program; account may cancel

while on this program determinate upon delinquency stage at enrollment.

(6) Month

Commitment from Cardholder is that they can resolve delinquency (past due amount within

six statement cycles); a one-time enrollment fee of $45 is assessed; a monthly $10 RPP fee

and monthly late fees ($29) are assessed while on this program; account may cancel while

on this program determinate upon delinquency stage at enrollment.

(9) Month

Commitment from Cardholder is that they can resolve delinquency (past due amount within

nine statement cycles); a one-time enrollment fee of $45 is assessed; a monthly $10 RPP

fee and monthly late fees ($29) are assessed while on this program; account may cancel

while on this program determinate upon delinquency stage at enrollment.

®

DoD Travel

27

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Delinquency Management

There are three potential Salary Offset responses from DFAS that would determine

eligibility of a member. They are as follows:

Citi Collection Efforts–Salary Offset

DFAS Salary Offset Outcomes

Enrolled

Account has been reviewed and approved by DFAS for enrollment into

Salary Offset. Enrollment fee of $80 and up to (3) Late Fees ($29 each) are

assessed (total of $167 in fees offset by DFAS).

Future

Eligible

Account has been reviewed, but currently cannot be enrolled into Salary

Offset. The account may be eligible for enrollment in the future.

Not Eligible

Account has been reviewed by DFAS and was declined. DFAS

requirements for enrollment into Salary Offset were not met. This decision

prevents the same account from being resubmitted for review in the future.

Non-enrollment fee of $85 is assessed upon return to Citi.

®

DoD Travel

28

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5. Best Practices/AOPC Controls

®

Delinquency Management

29

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Delinquency Management

Best Practices/AOPC Controls

Utilize Cardholder Statements &

Payments Option

– Easier access while traveling

– Cardholders can access CS&P through self-

registration

– Payments made online are free and post faster

than mailing

– Can view current and prior statements

– Can view unbilled transactions to get a “jump”

on filing vouchers

Travel Policy and Compliance

– Maintain a consistent card use policy–educate

cardholders frequently

– Create, communicate and exercise penalties for

misuse and/or abuse of the card

– Educate cardholders to file travel vouchers as

soon as possible®

DoD Travel

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31

Delinquency Management

Best Practices/AOPC Controls (continued)

Maximize Card Control

– Immediately update separated cardholders

– Ensure updated contact information on

cardholders within hierarchy

– Audit for unnecessary MCCs regularly–utilize the

Block MCC Report

– Minimize credit limits (cash and purchase) as

appropriate

Utilize Citi Online Reporting Tools

– Monitor spending and payment history for

accounts

– Frequently monitor suspension/cancellation

reports

– Empower AOPCs at all levels to take action

against delinquent cardholders

®

DoD Travel

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6. Delinquency Management Reports/Tools

®

Delinquency Management

32

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Delinquency Management

Reports/Tools–Citibank Custom Reporting

System (CCRS)

Delinquency Report

Pre-Suspension Report

Suspension Detail Report

Salary Offset Report

Non-Travel-Related Activity Report

Account Activity Report

Declined Authorizations Report

Blocked MCC Report

CCRS provides access to detailed and

easy-to-use reports to assist you with

managing delinquencies within your

hierarchy ®

DoD Travel

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Once in CitiManager, click on “Web Tools”, then click Citibank Custom Reporting

System hierarchy link and select the appropriate hierarchy link. This will prompt a

new window to open.

Delinquency Management

®

DoD TravelHow to Get to CCRS DoD Standard Reports

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Once the new CCRS window opens up, click on Organizational Shared Folders.

Delinquency Management

®

DoD TravelHow to Get to the Delinquency

Reports–Step by StepDoD Travel

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Delinquency Management

Click on the folder Department of Defense Travel Shared Reports.

DoD TravelHow to Get to the Delinquency

Reports–Step by Step (continued)

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Delinquency Management

Once the window refreshes, you will see the most commonly run reports for

Department of Defense. The IBA and CBA Delinquency – Hierarchy reports are

located here. (Click Supplemental Reports for other Delinquency-related reports.)

DoD TravelHow to Get to the Delinquency

Reports–Step by Step (continued)

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Delinquency Management

Click either IBA Supplemental Reports or CBA Supplemental Reports to access the

other Department of Defense Delinquency reports.

DoD TravelHow to Get to the Delinquency

Reports–Step by Step (continued)

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Delinquency Management

Once the window refreshes, you will see the rest of the staple reports prepared for

Department of Defense.

DoD TravelHow to Get to the Delinquency

Reports–Step by Step (continued)

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Reports/Tools–Delinquency Report

The Delinquency Report provides account information at a specified hierarchy for

any account holder considered past due on their card.

Delinquency Management

®

Account

NameAccount

Status

SSN

Last Pmt.

Date

Qualifier

Current

Bal.

Pmt.

Due

Date

Past

Due

Amt.

Pmt. Amt.

CTD

30 Days

Past Due

60 Days

Past

Due

DoD Travel

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Reports/Tools–Pre-Suspension Report

The Pre-Suspension Report lists accounts that are between 45 and 60 days past

billing from the billing cycle date within a specified hierarchy.

Delinquency Management

®

Account

Status

SSN

Account

Name

Last Pmt.

Due Date

MetricsDays Past

Due

Past Due

Amount

Last

Statement

Balance

DoD Travel

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Reports/Tools–Suspension Detail Report

The Suspension Detail Report lists accounts that have been suspended and are

eligible for cancellation. Accounts appear on this report at 61 – 125 days past the

billing cycle date.

Delinquency Management

®

Account

NumberAccount

Status

Account

Name

SSN

Date

Suspended

Number of

Days Past

Due

Number of Times

Suspended Past

Year

Past

Due

Amount

DoD Travel

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Reports/Tools–Salary Offset Report

The Salary Offset Detail Report lists accounts that have been enrolled in this

program within a specified hierarchy and the cardholder’s current balance.

Delinquency Management

®

DoD Travel

The Salary Offset Summary lists total amount of cards and current total balance of

cards within the hierarchy choice.

*Sample Data

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Reports/Tools–Non-Travel-Related Activity Report

The Non-Travel-Related Activity Report provides information to identify cardholders

with transaction activity (such as cash, fuel, or food) occurring without other

associated travel activity (such as airline, car rental or lodging).

Delinquency Management

®

Account

Number

Account

Name

Current

Balance

Transaction

Date

Merch.

City

Merchant Name Merch.

State

MCC

Metrics

Total Trans.

Amount

DoD Travel

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45

Reports/Tools–Account Activity Report

The Account Activity Report provides detailed information regarding transactions for

each account within a specified hierarchy level.

Delinquency Management

®

Account

Name 1

Account

Name 2

Account

Type

Account

Type

Transaction

Date

Trans.

Post Date

Merchant

Name

Merch.

City

MCC

Merch.

State

DoD Travel

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46

Reports/Tools–Declined Authorization Report

The Declined Authorizations Report lists all attempted transactions and detailed

reasons for decline and type of purchase within a specified hierarchy.

Delinquency Management

®

Account

Name 1Decline

Date

Decline

Time

Primary Dec.

Reason

Decline

Reason 1

Decline

Reason 2

Merch.

CityAccount

Number

DoD Travel

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47

Reports/Tools–Blocked MCC Report

The Blocked MCC Report shows all attempted transactions against excluded or

restricted Merchant Category Codes (MCC).

Delinquency Management

®

Transaction

Date

Transaction DB-

CR Indicator

MCC

Merchant

NameMCC

Description

Transaction

Post Date

DoD Travel

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7. Current DoD Travel Card Results

®

Delinquency Management

48

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Delinquency Management

Current DoD Delinquency Results

Individually Billed Accounts

®

Delinquency as a % of Total Spend $ = 2.37%

Delinquent $

($ Delinquent as of June 2012)

Spend $

(Oct ’11–June ’12)

$72.5M $ 3.06B

Delinquency is defined as accounts > 31 days past due or 61 days past billing.

DoD Travel

49

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Delinquency Management

Current DoD Delinquency Results

Centrally Billed Accounts

®

Delinquency as a % of Total Spend $ = 2.54%

Delinquent $

($ Delinquent as of June 2012)

Spend $

(Oct ’11–June ’12)

$21.3M $ 843.49M

Delinquency is defined as accounts > 31 days past due or 61 days past billing.

DoD Travel

50

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Current Component RPP/Salary Offset Results

*Data thru: 07/06/12

Reduced Payment

ProgramSalary Offset

# of Accounts $ # of Accounts $

Air Force 115 $181,692 Air Force 1,199 $1,813,079

Army 261 $333,236 Army 3,031 $3,533,060

Navy 56 $52,660 Navy 453 $524,231

Marines 10 $11,129 Marines 52 $75,273

Independents 18 $74,261 Independents 55 $170,410

TOTALS 460 $652,978 TOTALS 4,790 $6,116,053

Delinquency Management

®

DoD Travel

51

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Credit Losses by Component Fiscal YTD 2012

Losses Fiscal Year-to-Date 2012

# of Accounts ($)

Air Force 514 $837,562

Army 944 $1,325,138

Navy 392 $640,195

Marines 45 $82,249

Independents 18 $24,675

TOTALS 1,913 $2,909,819

Delinquency Management

®

DoD Travel

Data from: Oct 2011 – June 2012

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8. Summary

®

Delinquency Management

53

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54

Delinquency Management

• Delinquency management is everyone’s

responsibility

• Implementing best practices is key to a successful

program

• Improved delinquency management results in

higher rebates and improved program integrity

• Citi is dedicated to making this process work for

you!

Summary–Remember…

®

DoD Travel

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Delinquency Management

Summary – Contact Information

E-mail: [email protected]

®

DepartmentContact Numbers

Hours of OperationToll-Free Collect

Agency/

AOPC Service(866) 670-6462 (757) 853-2467

Monday–Saturday

7:00 a.m. to 9:00 p.m.

EST

DoD

Collections(866) 670-6461 (757) 853-5708

Monday – Friday

8:00 a.m. to 9:00 p.m.

EST

Cardholder

Customer

Service

(800) 200-7056 (757) 852-907624 hours a day;

7 days a week

DoD Travel

55

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Delinquency Management

Deanne Burbee

®

Department o

DefenseDoD Travel

56

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Delinquency Management

Survey

®

Department o

DefenseDoD Travel

57

Please take the course survey online by visiting:

www.gsasmartpayconference.org/survey

or by using the link sent to you via email from Feedback Systems.

Surveys can be taken through any mobile device.

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efficiency, renewable energy & mitigation

In January 2007, Citi released a Climate Change Position Statement, the first US financial institution to do so. As a sustainability leader in the financial sector, Citi has taken concrete steps to address this important

issue of climate change by: (a) targeting $50 billion over 10 years to address global climate change: includes significant increases in investment and financing of alternative energy, clean technology, and other carbon-

emission reduction activities; (b) committing to reduce GHG emissions of all Citi owned and leased properties around the world by 10% by 2011; (c) purchasing more than 52,000 MWh of green (carbon neutral) power

for our operations in 2006; (d) creating Sustainable Development Investments (SDI) that makes private equity investments in renewable energy and clean technologies; (e) providing lending and investing services to

clients for renewable energy development and projects; (f) producing equity research related to climate issues that helps to inform investors on risks and opportunities associated with the issue; and (g) engaging with

a broad range of stakeholders on the issue of climate change to help advance understanding and solutions.

Citi works with its clients in greenhouse gas intensive industries to evaluate emerging risks from climate change and, where appropriate, to mitigate those risks.

© 2012 Citibank, N.A. All rights reserved. Citi and Arc Design is a registered service mark of Citigroup Inc..

IRS Circular 230 Disclosure: Citigroup Inc. and its affiliates do not provide tax or legal advice. Any discussion of tax matters in these materials (i) is not intended or written to be used, and cannot be

used or relied upon, by you for the purpose of avoiding any tax penalties and (ii) may have been written in connection with the "promotion or marketing" of any transaction contemplated hereby

("Transaction"). Accordingly, you should seek advice based on your particular circumstances from an independent tax advisor.

Any terms set forth herein are intended for discussion purposes only and are subject to the final terms as set forth in separate definitive written agreements. This presentation is not a commitment to lend, syndicate a

financing, underwrite or purchase securities, or commit capital nor does it obligate us to enter into such a commitment, nor are we acting as a fiduciary to you. By accepting this presentation, subject to applicable law

or regulation, you agree to keep confidential the information contained herein and the existence of and proposed terms for any Transaction.

Prior to entering into any Transaction, you should determine, without reliance upon us or our affiliates, the economic risks and merits (and independently determine that you are able to assume these risks) as well as

the legal, tax and accounting characterizations and consequences of any such Transaction. In this regard, by accepting this presentation, you acknowledge that (a) we are not in the business of providing (and you

are not relying on us for) legal, tax or accounting advice, (b) there may be legal, tax or accounting risks associated with any Transaction, (c) you should receive (and rely on) separate and qualified legal, tax and

accounting advice and (d) you should apprise senior management in your organization as to such legal, tax and accounting advice (and any risks associated with any Transaction) and our disclaimer as to these

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We are required to obtain, verify and record certain information that identifies each entity that enters into a formal business relationship with us. We will ask for your complete name, street address, and taxpayer ID

number. We may also request corporate formation documents, or other forms of identification, to verify information provided.

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time without notice and are not intended as a solicitation with respect to the purchase or sale of any instrument. The information contained in this presentation may include results of analyses from a quantitative

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as of the date hereof and are subject to change without any notice. We and/or our affiliates may make a market in these instruments for our customers and for our own account. Accordingly, we may have a position

in any such instrument at any time.

Although this material may contain publicly available information about Citi corporate bond research, fixed income strategy or economic and market analysis, Citi policy (i) prohibits employees from offering, directly or

indirectly, a favorable or negative research opinion or offering to change an opinion as consideration or inducement for the receipt of business or for compensation; and (ii) prohibits analysts from being compensated

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procedures designed to limit communications between its investment banking and research personnel to specifically prescribed circumstances.

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© 2012 Citibank, N.A. All rights reserved. Citi, Citi and Arc Design and CitiDirect are trademarks and service marks of Citigroup Inc., used and registered

throughout the world.

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