Responding to criticism of its deal to buy Associates First Capital Corp., the subprime specialist that has been assailed for its lending practices in some communities, Citigroup Inc. has unveiled initiatives to combat predatory lending.

The announcement, which came Tuesday in the form of a letter to the New York State banking department, the Comptroller of the Currency, and the Federal Deposit Insurance Corp., came just three days before a scheduled public hearing in New York on Citi's deal for Irving, Tex.-based Associates First.

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