The lender claims the offering is the only one of its kind in today's mortgage market.

The senior tranche will sell a mix of floating and fixed-rate notes, benefiting 22.5% in credit support. The class B notes are covered to a level of 15.0% and the tranche sells all fixed-rate notes.

The Consumer Financial Protection Bureau's nonbank registry to address repeat corporate offenders goes live this week, but some experts have raised concerns about redundancy and costs for nonbanks.

Consumer credit is deteriorating, but structured credit is well suited to weather the slide.

Further, the assets have a loan-to-value ratio of about 52%, with a cashflow that can withstand large haircuts.

The fund will include asset-based loans such as CLOs.

Analysts peppered CEO Jane Fraser with questions about whether Citigroup, already hit hard by its regulators, could face asset growth restrictions. She said there is "absolutely nothing" in the works that could impact the megabank's businesses.

The Consumer Financial Protection Bureau's Director Rohit Chopra was stymied for months by a Supreme Court case that put many enforcement actions on hold, but the bureau is making up for lost time.

The note balance can be upsized to $1.2 billion in auto ABS, according to Moody's Ratings, and the pool size can be increased to 26,514 contracts.

The megabank's scale hasn't made it immune from the deposit wars that have crimped bank profits. But the "stabilization" that Wells Fargo flagged is a positive sign as other banks start reporting earnings.

The megabank reported a big increase in credit costs for the third quarter, which included a reserve build of $1 billion.

The Fed's short-term rate cut hasn't lowered 30-year mortgage rates, which have been flat, but some buyers had reasons to act sooner rather than later.