By Christina Rexrode 

Citigroup Inc. has started providing aid to struggling homeowners as part of its $7 billion settlement with the Justice Department.

An initial report on Citigroup's efforts is expected to be released Wednesday by Thomas Perrelli, a former Justice Department official who was hired to make sure Citigroup complies with the pact.

The bank in July agreed to settle government allegations that it misled investors about dubious mortgage-backed securities it was selling before the financial crisis. But $2.5 billion of that tab has to be paid in the form of "consumer relief." That means the bank gets credit for actions like lowering a struggling homeowner's mortgage rate, lending to low-income families who want to buy their first home, or paying to demolish abandoned properties that are neighborhood eyesores.

In an interview, Mr. Perrelli said it was too early to draw broad conclusions about Citigroup's compliance with the pact. He also said he would be keeping a close eye to make sure that the bank's own internal group overseeing the process stays independent from the mortgage-making unit, though so far he hasn't seen anything to give him pause.

Mr. Perrelli, a partner at the law firm Jenner & Block in Washington, was a chief architect of the national mortgage settlement in 2012.

For its first report, Citigroup gave Mr. Perrelli's office a sample of 100 mortgages, where it had agreed to forgive the entire unpaid portion on each one. Mr. Perrelli's office calculated that Citigroup should receive $13.97 million worth of credit from forgiving those loans. That is in line with what Citigroup had estimated--essentially giving the nod that its processes for estimating how much credit it should get is on the right track.

All those loans were on mortgages where, as the settlement agreement puts it, "foreclosure is not pursued" -- bank-speak for loans where the bank would end up spending more to foreclose on a property than the property is even worth.

This caught Mr. Perrelli's attention: If a property is worth so little to Citigroup, then why should Citigroup get credit for walking away from it? One difference is that, to get credit for the settlement, Citigroup also has to release its liens against those properties, Mr. Perrelli noted. That is something the banks don't always do, and it is important to struggling homeowners because otherwise, they can be on the hook for paying those liens even if their house has been foreclosed on.

The average unpaid balance on those mortgages was $140,000, Mr. Perrelli said, and they included a mix of occupied and vacant homes. Some, he added, were higher-value homes, but they had significant tax liens against them, meaning that if the bank foreclosed on them, the proceeds would probably be eaten up by the tax bill.

Mr. Perrelli said he would be tracking the types of communities that benefit from the government-mandated relief, including characteristics like income level and ethnicity. Consumers can't apply for this aid--the most they can really do is call and ask if they're eligible--and the settlement gives Citigroup broad discretion over how it offers the aid. Mr. Perrelli said he hopes the information will be useful when the government structures future settlements.

Citigroup said in a statement that it remains "committed to fully satisfying" the requirements of the settlement. Its deadline is the end of 2018.

J.P. Morgan Chase Co. and Bank of America Corp. are under similar pacts after their settlements with the Justice Department. J.P. Morgan, which settled first, has told its independent monitor that it is more than halfway through with its agreement to spend $4 billion on consumer aid.

Write to Christina Rexrode at christina.rexrode@wsj.com

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