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Investments
 12 Months Ended
Dec. 31, 2024
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 December 31, 2022, we had a $5 million investment in a convertible debt security classified as a trading investment. In March 2023, this security, and the related accrued interest, was converted into equity securities classified as investments in non-marketable securities.
At December 31, 2024 and 2023, we had $53 million and $54 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 December 31, 2024
(dollars in thousands)		Amortized Cost
Allowance for credit losses(1)
Gross Unrealized GainsGross Unrealized LossesEstimated Fair Value
Available for sale:
Mortgage-backed securities$516,358 $— $205 $(73,235)$443,328 
Utah Housing Corporation bonds2,849 — — (490)2,359 
U.S. government-sponsored enterprises and Treasuries948,009 — — (32,265)915,744 
Other securities575,257 — 8,633 (12,095)571,795 
Total $2,042,473 $— $8,838 $(118,085)$1,933,226 
As of December 31, 2023
(dollars in thousands)		Amortized Cost
Allowance for credit losses(1)
Gross Unrealized GainsGross Unrealized LossesEstimated Fair Value
Available for sale:
Mortgage-backed securities$468,204 $— $703 $(62,480)$406,427 
Utah Housing Corporation bonds3,408 — — (279)3,129 
U.S. government-sponsored enterprises and Treasuries1,645,609 — — (66,870)1,578,739 
Other securities446,763 — 603 (24,039)423,327 
Total $2,563,984 $— $1,306 $(153,668)$2,411,622 
     
(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:
Less than 12 months12 months or moreTotal
As of December 31,
(dollars in thousands)		Gross Unrealized LossesEstimated Fair ValueGross Unrealized LossesEstimated Fair ValueGross Unrealized LossesEstimated Fair Value
2024:
Mortgage-backed securities$(2,723)$137,585 $(70,512)$290,257 $(73,235)$427,842 
Utah Housing Corporation bonds— — (490)2,359 (490)2,359 
U.S. government-sponsored enterprises and Treasuries— — (32,265)915,744 (32,265)915,744 
Other securities(74)11,579 (12,021)182,215 (12,095)193,794 
Total$(2,797)$149,164 $(115,288)$1,390,575 $(118,085)$1,539,739 
2023:
Mortgage-backed securities$(531)$51,391 $(61,949)$300,318 $(62,480)$351,709 
Utah Housing Corporation bonds— — (279)3,129 (279)3,129 
U.S. government-sponsored enterprises and Treasuries— — (66,870)1,578,739 (66,870)1,578,739 
Other securities(2,221)90,725 (21,818)241,253 (24,039)331,978 
Total$(2,752)$142,116 $(150,916)$2,123,439 $(153,668)$2,265,555 

At December 31, 2024 and 2023, 236 of 278 and 213 of 248, 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 are met, the security’s amortized cost basis is written down to fair value through net 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 Banks, 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. 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 December 31, 2024, 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 December 31, 2024
Year of Maturity
(dollars in thousands)
Amortized CostEstimated Fair Value
2025$299,816 $298,648 
2026549,175 520,793 
202799,018 96,303 
203866 66 
2039551 531 
20422,112 1,793 
20433,761 3,299 
20444,085 3,651 
20454,518 3,919 
20466,953 5,965 
20476,704 5,781 
20481,702 1,481 
204914,838 12,842 
2050101,145 78,475 
2051144,694 111,058 
205258,268 50,497 
2053297,695 294,197 
2054142,209 135,800 
205571,611 70,409 
2056194,173 197,363 
205839,379 40,355 
Total$2,042,473 $1,933,226 

Some of the mortgage-backed securities and a portion of the government securities have been pledged to the FRB as collateral against any advances and accrued interest under the Primary Credit lending program sponsored by the FRB. We had $610 million and $612 million par value of securities pledged to this borrowing facility at December 31, 2024 and 2023, respectively, as discussed further in Note 10, “Borrowings” in this Form 10-K.
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, or when observable prices are not available, use market data of similar entities, in determining any changes in the value of the securities. In the third quarter of 2024, we funded a new investment in non-marketable securities of an issuer whose securities we have not previously purchased. In March 2023, our $5 million investment in a convertible debt security, classified as a trading investment, and the related accrued interest were converted into equity securities and were reclassified to investments in non-marketable securities. In the fourth quarter of 2022, we determined that our investment in an issuer whose equity securities we purchased in the past was impaired. As such, we wrote down the value based upon an estimate of the value of these securities and recorded a loss of $60 million in “gains (losses) on securities, net” in the consolidated statements of income in 2022. At December 31, 2024 and December 31, 2023, our total investment in non-marketable securities was $24 million and $14 million, respectively.
Low Income Housing Tax Credit Investments
We invest in affordable housing projects that qualify for the 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. We recognized $13 million, $11 million, and $9 million of tax credits and other tax benefits associated with investments in affordable housing projects within income tax expense for the years ended December 31, 2024, 2023, and 2022, respectively. The amount of amortization of such investments reported in income tax expense was $10 million, $9 million, and $7 million for the years ended December 31, 2024, 2023, and 2022, respectively. Total carrying value of the LIHTC investments was $82 million at December 31, 2024 and $72 million at December 31, 2023. We are periodically required to provide additional financial support during the investment period. Our liability for these unfunded commitments was $30 million at December 31, 2024 and $30 million at December 31, 2023.