CEO Mike Corbat Citbank Memo Outlines the New Commercial Firearms Policy

The new Citibank Commercial Firearms Policy isn’t one gun-owners will like, however carefully Citi CEO Mike Corbat worded his memo. Hat tip to The Firearm Rack.

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A number of sites are reporting that Citibank, a massive financial institution headquartered in New York City, intends to alter its business practices to the detriment of firearm-related retailers. The news, which was first brought to our attention by The Firearm Rack, has predictably resulted in vociferous accolades and declamations, depending on the gun control preference of the pundit.

Grunts: vociferous.

Citigroup CEO Mike Corbat, a self-described “avid outdoorsman and gun owner,” penned an internal memo (see below) outlining the forthcoming policy change which he calls the U.S. Commercial Firearms Policy. Included in that policy are the following required “best practices.”

Citi Defines Its “Best Practices” For Businesses, Institutions, and Business Partners

Small business, commercial, and institutional clients, and credit card partners, must not…

  1. …sell firearms to someone who hasn’t passed a background check, which would be problematic for youth shotguns and the like, except that #2,
  2. …sell firearms to anyone under 21 years of age, and,
  3. …must not sell bump stocks or high-capacity magazines.

We’re not sure how they intended to define “high capacity,” though it will almost certainly include mags holding 30 rounds or more, and likely will apply to most anything higher than those with ten.

This decision is certainly within Citibank’s rights, but is obviously contrary not only to what most of us believe but to many local laws as well. This sucks, but centered as it is on a business is a far less legally tenuous or troubling juxtaposition than one involving government authority or a local polity. It will be interesting to see if anyone sues them for abrogation of rights.

The memo, as provided by TFR, reads as follows:

From: MikeCorbat <[email protected]>
Date: Thursday, March 22, 2018 at 10:01 AM
Subject: Announcing Our U.S. Commercial Firearms PolicyMessage From
Mike Corbat

Dear Colleagues,

Over the last several weeks, I have had many conversations with clients, colleagues and friends who hold a range of opinions on the regulation of firearms in the U.S. It is clear to me that most people believe there are areas of agreement and practical changes we can make to find common ground.

Citi is ready to do our part to help our country move in that direction. Today, I am proud to announce a new U.S. Commercial Firearms Policy that promotes the adoption of current best practices regarding the sale of firearms. The policy was designed to respect the rights of responsible gun owners while helping to keep firearms out of the wrong hands.

This policy will apply across the firm, including to small business, commercial and institutional clients, as well as credit card partners, whether co-brand or private label. Under the policy, we will require new retail sector clients or partners to adhere to these current best practices: (1) they don’t sell firearms to someone who hasn’t passed a background check, (2) they restrict the sale of firearms for individuals under 21 years of age, and (3) they don’t sell bump stocks or high-capacity magazines.

It is clear our current clients care about these issues as well, and we believe we can make meaningful progress together. We have already begun to engage with them in the hope that they will adopt these best practices over the coming months. If they opt not to, we will respect their decision and work with them to transition their business away from Citi.

We have few relationships with companies that manufacture firearms. For those that do, we will be initiating due diligence conversations to better understand the products they make, what markets and retailers they sell to, and the sales practices of those retailers to ensure adherence with the best practices outlined above. We will apply the same due diligence screening to potential clients going forward.

We know that our efforts cannot lead to real change unless we work with others. To that end, we are initiating a dialogue within the financial services industry and with other stakeholders to understand whether there are additional technology solutions or voluntary standards that can be enacted. We know a solution may not come quickly, but we are committed to the conversation.

As an avid outdoorsman and responsible gun owner, I know that some will find our policy too strict while others will find it too lenient. We don’t have the perfect solution to supporting our Constitution while keeping our children and grandchildren safe. Best practices are going to continue to change, and we understand the limitations of our efforts. But we shouldn’t let that stop us from doing our part.

– Mike

We have not yet directly confirmed the accuracy of the memo, but given what we know of TFR’s Patrick Roberts, and the trending news about Citibank in general, we have little cause to doubt its veracity.

This is not the first organization that has exercised its right to plot its own business course contrary to what some of the population believes to be right, but it’s certainly one of the biggest. Apparently, the concept that we might need to defend against a tyrannical government someday is not sufficiently compelling (or immediate) to counter the ongoing hue and cry to “just do something!” about gun violence.

It will be interesting to see how they enforce adherence to what Corbat calls “best practices.”

Citi has voted with its wallet. I reckon some of us will now need to vote with ours.

Read more at The Firearm Rack’s Citigroup Plans on Regulating Firearms, The Hill’s Citibank to require clients to restrict gun sales, USA Today’s Restrict gun sales, Citigroup tells its business partners, or Politico’s Citi becomes first big bank to press clients to restrict gun sales.

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