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Investments
 3 Months Ended
Mar. 31, 2022
Investments, Debt and Equity Securities [Abstract]  
Investments Investments
Trading Investments
We periodically sell Private Education Loans through securitization transactions where we are required to retain a five percent vertical risk retention interest (i.e., five percent of each class issued in the securitizations). We classify those vertical risk retention interests related to the transactions as available-for-sale investments, except for the interest in the residual classes, which we classify as trading investments recorded at fair value with changes recorded through earnings. At March 31, 2022 and December 31, 2021, we had $39 million and $37 million, respectively, classified as trading investments.
Available-for-Sale Investments
The amortized cost and fair value of securities available for sale are as follows:

As of March 31, 2022
(dollars in thousands)		Amortized Cost
Allowance for credit losses(1)
Gross Unrealized GainsGross Unrealized LossesEstimated Fair Value
Available-for-sale:
Mortgage-backed securities$400,647 $— $74 $(29,641)$371,080 
Utah Housing Corporation bonds4,926 — — (77)4,849 
U.S. government-sponsored enterprises and Treasuries1,799,080 — — (63,830)1,735,250 
Other securities235,551 — — (5,179)230,372 
Total $2,440,204 $— $74 $(98,727)$2,341,551 
As of December 31, 2021
(dollars in thousands)		Amortized Cost
Allowance for credit losses(1)
Gross Unrealized GainsGross Unrealized LossesEstimated Fair Value
Available-for-sale:
Mortgage-backed securities$376,313 $— $1,857 $(7,073)$371,097 
Utah Housing Corporation bonds6,943 — 18 — 6,961 
U.S. government-sponsored enterprises and Treasuries1,958,943 — 603 (11,893)1,947,653 
Other securities193,369 — 439 (1,563)192,245 
Total $2,535,568 $— $2,917 $(20,529)$2,517,956 


(1) Represents the amount of impairment that has resulted from credit-related factors and that was recognized in the consolidated balance sheets (as a credit loss expense on available-for-sale securities). The amount excludes unrealized losses related to non-credit factors.
The following table summarizes the amount of gross unrealized losses for our available-for-sale securities and the estimated fair value for securities having gross unrealized loss positions, categorized by length of time the securities have been in an unrealized loss position:

(Dollars in thousands)		Less than 12 months12 months or moreTotal
Gross
Unrealized
Losses		Estimated
Fair Value		Gross
Unrealized
Losses		Estimated
Fair Value		Gross
Unrealized
Losses		Estimated
Fair Value
As of March 31, 2022:
Mortgage-backed securities$(12,056)$188,447 $(17,585)$176,659 $(29,641)$365,106 
Utah Housing Corporation bonds(77)4,849 — — (77)4,849 
U.S. government-sponsored enterprises and Treasuries(61,996)1,647,055 (1,834)63,176 (63,830)1,710,231 
Other securities(3,266)137,845 (1,913)36,752 (5,179)174,597 
Total$(77,395)$1,978,196 $(21,332)$276,587 $(98,727)$2,254,783 
As of December 31, 2021:
Mortgage-backed securities$(5,534)$261,404 $(1,540)$36,587 $(7,074)$297,991 
Utah Housing Corporation bonds— — — — — — 
U.S. government-sponsored enterprises and Treasuries(11,892)1,199,367 — — (11,892)1,199,367 
Other securities(1,563)132,884 — — (1,563)132,884 
Total$(18,989)$1,593,655 $(1,540)$36,587 $(20,529)$1,630,242 

At March 31, 2022 and December 31, 2021, 158 of 186 and 60 of 180, respectively, of our available-for-sale securities were in an unrealized loss position.
Impairment
For available-for-sale securities in an unrealized loss position, we first assess whether we intend to sell, or it is more likely than not that we will be required to sell the security before recovery of its amortized cost basis. If either of these criteria is met, the security’s amortized cost basis is written down to fair value through income. For securities in an unrealized loss position that do not meet these criteria, we evaluate whether the decline in fair value has resulted from credit loss or other factors. In making this assessment, we consider the extent to which fair value is less than amortized cost, any changes to the rating of the security by a rating agency, adverse conditions specifically related to the security, as well as any guarantees (e.g., guarantees by the U.S. Government) that may be applicable to the security. If this assessment indicates a credit loss exists, the credit-related portion of the loss is recorded as an allowance for losses on the security.
Our investment portfolio contains mortgage-backed securities issued by Ginnie Mae, Fannie Mae, and Freddie Mac, as well as Utah Housing Corporation bonds. We own these securities to meet our requirements under the Community Reinvestment Act (“CRA”). We also invest in other U.S. government-sponsored enterprise securities issued by the Federal Home Loan Bank, Freddie Mac, and the Federal Farm Credit Bank. Our mortgage-backed securities that were issued under Ginnie Mae programs carry a full faith and credit guarantee from the U.S. Government. The remaining mortgage-backed securities in a net loss position carry a principal and interest guarantee by Fannie Mae or Freddie Mac, respectively. Our Treasury and other U.S. government-sponsored enterprise bonds are rated Aaa by Moody’s Investors Service or AA+ by Standard and Poor’s. The decline in value from December 31, 2021 to March 31, 2022 was driven by the current interest rate environment and is not credit related. We have the intent and ability to hold these bonds for a period of time sufficient for the market price to recover to at least the adjusted amortized cost of the security. Based on this qualitative analysis, we have determined that no credit impairment exists.
We periodically sell Private Education Loans through securitization transactions where we are required to retain a five percent vertical risk retention interest. We classify the non-residual vertical risk retention interests as available-for-sale investments. We have the intent and ability to hold each of these bonds for a period of time sufficient for the market price to recover to at least the adjusted amortized cost of the security. We expect to receive all contractual cash flows related to these investments and do not consider a credit impairment to exist.
As of March 31, 2022, the amortized cost and fair value of securities, by contractual maturities, are summarized below. Contractual maturities versus actual maturities may differ due to the effect of prepayments.
As of March 31, 2022
Year of Maturity
(dollars in thousands)		Amortized CostEstimated Fair Value
2022$194,309 $193,447 
2023162,595 159,383 
2024597,268 577,077 
2025297,077 293,021 
2026547,832 512,323 
203873 76 
2039873 916 
20422,912 2,768 
20435,415 5,336 
20447,015 6,959 
20456,158 6,018 
20469,374 9,085 
20479,957 9,751 
20482,427 2,437 
204918,261 17,902 
2050127,490 116,445 
2051174,646 159,542 
205240,972 38,693 
2053132,336 128,621 
2054103,214 101,751 
Total$2,440,204 $2,341,551 

Some of our securities have been pledged to the Federal Reserve Bank (the “FRB”) as collateral against any advances and accrued interest under the Primary Credit lending program sponsored by the FRB. We had $720 million and $888 million par value of securities pledged to this borrowing facility at March 31, 2022 and December 31, 2021, respectively, as discussed further in Notes to Consolidated Financial Statements, Note 8, “Borrowings.”
Other Investments
Investments in Non-Marketable Securities
We hold investments in non-marketable securities and account for these investments at cost, less impairment, plus or minus observable price changes of identical or similar securities of the same issuer. Changes in market value are recorded through earnings. Because these are non-marketable securities, we use observable price changes of identical or similar securities of the same issuer in determining any changes in the value of the securities. As of March 31, 2022 and December 31, 2021, our total investment in these securities was $69 million and $69 million, respectively.
Low Income Housing Tax Credit Investments
We invest in affordable housing projects that qualify for the low-income housing tax credit (“LIHTC”), which is designed to promote private development of low-income housing. These investments generate a return mostly through realization of federal tax credits and tax benefits from net operating losses on the underlying properties. Total carrying value of the LIHTC investments was $66 million at March 31, 2022 and $68 million at December 31, 2021. We are periodically required to provide additional financial support during the investment period. Our liability for these unfunded commitments was $28 million at March 31, 2022 and $30 million at December 31, 2021.
Related to these investments, we recognized tax credits and other tax benefits through tax expense of less than $1 million at March 31, 2022 and $7 million at December 31, 2021. Tax credits and other tax benefits are recognized as
part of our annual effective tax rate used to determine tax expense in a given quarter. Accordingly, the portion of a year’s expected tax benefits recognized in any given quarter may differ from 25 percent.