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Loans Held-for-Investment
6 Months Ended
Jun. 30, 2022
Receivables [Abstract]  
Loans Held-for-Investment Loans Held-for-Investment
We classify loans that we have the intent and ability to hold for the foreseeable future or until maturity as LHFI. We
report LHFI at their amortized cost, which includes the outstanding principal balance adjusted for any unamortized premiums,
discounts, deferred fees and costs. The accrued interest receivable on LHFI totaled $41 million at June 30, 2022 and $35 million at December 31, 2021 and was reported in other assets on the Consolidated Statements of Financial Condition.

The following table presents our LHFI:
June 30, 2022December 31, 2021
 (Dollars in millions)
Consumer loans
Residential first mortgage$2,205 $1,536 
Home equity645 613 
Other1,331 1,236 
Total consumer loans4,181 3,385 
Commercial loans
Commercial real estate3,387 3,223 
Commercial and industrial2,653 1,826 
Warehouse lending4,434 4,974 
Total commercial loans10,474 10,023 
Total loans held-for-investment$14,655 $13,408 
    
The following table presents the UPB of our loan sales and purchases in the LHFI portfolio:
Six Months Ended June 30,
20222021
 (Dollars in millions)
Loans Sold (1)
Performing loans$— $87 
Total loans sold$— $87 
(1)Upon a change in our intent, the loans were transferred to LHFS and subsequently sold.


We have pledged certain LHFI, LHFS, and LGG to collateralize lines of credit and/or borrowings with the FRB of Chicago and the FHLB of Indianapolis. At June 30, 2022 and December 31, 2021, we had pledged loans of $8.6 billion and $9.9 billion, respectively.

Allowance for Credit Losses on Loans

We determine the estimate of the ACL on at least a quarterly basis. The ACL represents Management's estimate of expected lifetime losses in our LHFI portfolio, excluding loans carried under the fair value option. In addition, we record a reserve for expected lifetime losses on our unfunded commitments - see Reserve for Unfunded Commitments section below. Therefore, we record ALLL on relevant financial assets and a reserve for unfunded commitments on our Consolidated Statements of Financial Condition, collectively referred to as the ACL.

Expected credit losses are estimated over the contractual term of the loans, adjusted for expected prepayments when appropriate. The contractual terms exclude expected extensions, renewals, and modifications unless the following applies: Management has a reasonable expectation at the reporting date that a TDR will be executed with an individual borrower or the extension or renewal options are included in the original or modified contract at the reporting date and are not unconditionally cancellable by us.

The ACL is impacted by changes in asset quality of the portfolio, including but not limited to increases in risk rating changes in our commercial portfolio, borrower delinquencies, changes in FICO scores or changes in LTVs in our consumer portfolio. In addition, while we have incorporated our forecasted impact of COVID-19 into our ACL, the ultimate impact of COVID-19 is still uncertain, including how long economic activity will be impacted by the pandemic and what effect the unprecedented levels of government fiscal and monetary actions will have on the economy and our credit losses.

Specifically identified component. The specifically identified component of ACL related to performing TDR loans is generally measured as the difference between the recorded investment in the specific loan and the present value of the cash flows expected to be collected, discounted at the loan's original effective interest rate. Estimating the timing and amounts of future cash flow projections is highly judgmental and based upon assumptions including default rates, prepayment probability and loss severities. All of these estimates and assumptions require significant management judgment and certain assumptions are highly subjective.

Specifically identified collateral dependent NPL loans are generally measured as the difference between the recorded investment in the impaired loan and the underlying collateral value less estimated costs to sell. These estimates are dependent on third-party property valuations which may be influenced by factors such as the current and future level of home prices, the duration of current overall economic conditions, and other macroeconomic and portfolio-specific factors.

Model-based component. A general allowance is established for lifetime losses inherent on non-impaired loans by segmenting the portfolio based upon common risk characteristics. Our consumer loan portfolio is segmented into Residential First Mortgage, Home Equity and Other Consumer. Loan characteristics impacting these segments include lien position, credit quality, and loan structure. At a high-level, our commercial loans are segmented into Commercial Real Estate, Commercial and Industrial, and Warehouse Lending. Loan characteristics impacting these segments include credit quality and loan structure.
We measure the allowance using the applicable dual risk rating model which measures probability of default, loss given default and exposure at default. As of June 30, 2022, we utilized the Moody’s May scenarios in our forecast: a growth forecast, weighted at 30 percent; a baseline forecast, weighted at 40 percent; and an adverse forecast, weighted at 30 percent. Within our composite forecast, unemployment ends 2022 at 4 percent, increasing to 4.5 percent in 2023, and will slightly recover in 2024, ending the year at 4 percent. GDP continues to recover throughout 2022 and returns to pre-COVID levels in 2023. HPI decreases by 2 percent from the second quarter of 2022 through the fourth quarter of 2022 before increasing 1 percent by the fourth quarter of 2023.

Qualitative adjustments. The specifically identified component analysis and the output of the model provide a reasonable starting point for our analysis, but do not, by themselves, form a sufficient basis to determine the appropriate level for the ACL. We therefore consider the qualitative factors that are likely to cause the ACL associated with our existing portfolio to differ from the output of the model. The most significant qualitative factors considered include changes in economic and business conditions, changes in nature and volume of portfolio and changes in the volume and severity of past due loans. The application of different inputs into the model calculation and the assumptions used by Management to adjust the model calculation are subject to significant management judgment and may result in actual credit losses that differ from the originally estimated amounts.

The following table presents changes in the ALLL, by class of loan:
Residential
First
Mortgage (1)
Home EquityOther
Consumer
Commercial
Real Estate
Commercial
and Industrial
Warehouse
Lending
Total
 (Dollars in millions)
Three Months Ended June 30, 2022
Beginning balance$43 $16 $34 $22 $13 $$131 
(Benefit) provision(10)(2)— (2)(8)
Charge-offs— — (3)— — — (3)
Recoveries— — — — — 
Ending allowance balance$33 $21 $31 $22 $11 $$122 
Three Months Ended June 30, 2021
Beginning balance$45 $20 $33 $84 $55 $$241 
(Benefit) Provision(4)(26)(17)(1)(38)
Charge-offs(1)— (1)— — — (2)
Recoveries— — — — — 
Ending allowance balance$48 $17 $38 $58 $38 $$202 
Six Months Ended June 30, 2022
Beginning balance$40 $14 $36 $28 $32 $$154 
(Benefit) provision(6)(3)(6)(1)— (10)
Charge-offs(1)— (5)— (20)— (26)
Recoveries— — — — 
  Ending allowance balance$33 $21 $31 $22 $11 $$122 
Six Months Ended June 30, 2021
Beginning balance$49 $25 $39 $84 $51 $$252 
(Benefit) Provision(7)(1)(26)(28)(1)(62)
Charge-offs(3)(1)(2)— (1)— (7)
Recoveries— — 16 — 19 
  Ending allowance balance$48 $17 $38 $58 $38 $$202 
(1)Includes LGG.

The ALLL was $122 million at June 30, 2022 and $154 million at December 31, 2021. The decrease in the allowance is primarily reflective of changes in our economic forecast and judgment we applied related to those forecasts and underlying borrower credit as a result of the ongoing COVID-19 pandemic.

Loans are considered to be past due when any payment of principal or interest is 30 days past the scheduled payment date. While it is the goal of Management to collect on loans, we attempt to work out a satisfactory repayment schedule or modification with past due borrowers and will undertake foreclosure proceedings if the delinquency is not satisfactorily
resolved. Our practices regarding past due loans are designed to both assist borrowers in meeting their contractual obligations and minimize losses incurred by the Bank.

Beginning in March 2020, as a response to COVID-19, customers facing COVID-19 related difficulties were offered forbearance in an effort to help our borrowers get to the other side of the health crisis. As these loans reach the end of their forbearance period, we have been working with each customer to modify or refinance the outstanding loan to fit their new circumstances. Refer to payment deferral information in the Credit Risk Section of the MD&A for additional details.

We cease the accrual of interest on all classes of consumer and commercial loans upon the earlier of becoming 90 days past due, or when doubt exists as to the ultimate collection of principal or interest (classified as nonaccrual or NPLs). When a loan is placed on nonaccrual status, the accrued interest income is reversed and the loan may only return to accrual status when principal and interest become current and are anticipated to be fully collectible. We do not consider accrued interest receivable in our measurement of the ACL as accrued interest is written-off in a timely manner when the loan is placed on nonaccrual. We are not aging receivables for customers who have been granted a payment deferral in response to COVID-19 which remain in the aging category they were in at the time of payment deferral. We continue to accrue interest on these loans, consistent with our forbearance programs.

The following table sets forth the LHFI aging analysis of past due and current loans:
30-59 Days
Past Due
60-89 Days
Past Due
90 Days or
Greater Past
Due (1)
Total
Past Due
CurrentTotal LHFI (3) (4) (5)
 (Dollars in millions)
June 30, 2022
Consumer loans
Residential first mortgage$$$88 $100 $2,105 $2,205 
Home equity— 12 633 645 
Other1,322 1,331 
Total consumer loans15 99 121 4,060 4,181 
Commercial loans
Commercial real estate— — — — 3,387 3,387 
Commercial and industrial— — — — 2,653 2,653 
Warehouse lending— — — — 4,434 4,434 
Total commercial loans— — — — 10,474 10,474 
Total loans (2)$15 $$99 $121 $14,534 $14,655 
December 31, 2021
Consumer loans
Residential first mortgage$14 $34 $49 $97 $1,439 $1,536 
Home equity18 595 613 
Other1,227 1,236 
Total consumer loans26 36 62 124 3,261 3,385 
Commercial loans
Commercial real estate— — — — 3,223 3,223 
Commercial and industrial— — 32 32 1,794 1,826 
Warehouse lending— — — — 4,974 4,974 
Total commercial loans— — 32 32 9,991 10,023 
Total loans (2)$26 $36 $94 $156 $13,252 $13,408 
(1)Includes less than 90 days past due performing loans which are placed in nonaccrual. Interest is not being accrued on these loans.
(2)Includes $8 million and $9 million of past due loans accounted for under the fair value option as of June 30, 2022 and December 31, 2021.
(3)Collateral dependent loans totaled $147 million and $108 million at June 30, 2022 and December 31, 2021, respectively. The majority of these loans are secured by real estate.
(4)The interest income recognized on impaired loans was less than $1 million for the three months ended June 30, 2022 and December 31, 2021.
(5)The delinquency status for loans in forbearance is frozen for loans at inception of the forbearance period and will resume when the borrower's forbearance period ends.

Interest income is recognized on nonaccrual loans using a cash basis method. Interest that would have been accrued for the three months ended June 30, 2022 was $1 million. At June 30, 2022 and December 31, 2021, we had no loans 90 days or greater past due and still accruing interest.
Reserve for Unfunded Commitments

We estimated expected credit losses over the contractual period in which we are exposed to credit risk via a contractual obligation to extend credit, unless that obligation is unconditionally cancellable by us. The reserve for unfunded commitments is adjusted as a provision for credit loss expense. The estimate includes consideration of the likelihood that funding will occur and an estimate of expected credit losses on commitments expected to be funded over its estimated life.

The reserve for unfunded commitments is reflected in other liabilities on the Consolidated Statements of Financial Condition and was $13 million as of June 30, 2022, compared to $16 million as of December 31, 2021.

The following categories of off-balance sheet credit exposures have been identified: unfunded loans with available balances, new commitments to lend that are not yet funded, and standby and commercial letters of credit. For further information, see Note 15 - Legal Proceedings, Contingencies and Commitments.

Troubled Debt Restructurings
    
    We may modify certain loans in both our consumer and commercial loan portfolios to retain customers or to maximize collection of the outstanding loan balance. TDRs are modified loans in which a borrower demonstrates financial difficulties and for which a concession has been granted as a result. Nonperforming TDRs are included in nonaccrual loans. TDRs remain in nonperforming status until a borrower has made payments and is current for at least six consecutive months. Performing TDRs are not considered to be nonaccrual so long as we believe that all contractual principal and interest due under the restructured terms will be collected. Performing and nonperforming TDRs remain impaired as interest and principal will not be received in accordance with the original contractual terms of the loan agreement. Refer to Note 1- Description of Business, Basis of Presentation, and Summary of Significant Accounting Standards to the consolidated financial statements in the Annual Report on Form 10-K for the year ended December 31, 2021 for a description of the methodology used to determine TDRs.

    Some loan modifications classified as TDRs may not ultimately result in the full collection of principal and interest, as modified, but may give rise to potential incremental losses. We measure impairments using a discounted cash flow method for performing TDRs and measure impairment based on collateral values for nonperforming TDRs.

    Beginning in March 2020, as a response to COVID-19, we offered our consumer borrowers principal and interest payment deferrals, forbearance and/or extensions up to a maximum period of 18 months. We considered these programs in the context of whether or not the short-term modifications of these loans and the programs offered to return to payment status would constitute a TDR. We considered the CARES Act, interagency guidance and related guidance from the FASB, which provided that short-term modifications made on a good faith basis in response to COVID-19 to borrowers who were current prior to any relief are not required to be accounted for as TDRs. As a result, we have determined that loans modified under these programs are not TDRs.

The following table provides a summary of TDRs by type and performing status:
 TDRs
 PerformingNonperformingTotal
(Dollars in millions)
June 30, 2022
Consumer loans
Residential first mortgage$16 $18 $34 
Home equity
Total TDRs (1)(2)$22 $20 $42 
December 31, 2021
Consumer loans
Residential first mortgage$14 $11 $25 
Home equity10 
Total consumer TDR loans (1)(2)22 13 35 
Commercial loans
Commercial and industrial— 
Total commercial TDR loans— 
Total TDRs (1)(2)$24 $13 $37 
(1)The ALLL on TDR loans totaled $4 million at both June 30, 2022 and December 31, 2021.
(2)Includes $1 million and $5 million of TDR loans accounted for under the fair value option at June 30, 2022 and December 31, 2021, respectively.
The following table provides a summary of newly modified TDRs:
 New TDRs
 Number of AccountsPre-Modification Unpaid Principal BalancePost-Modification Unpaid Principal Balance (1)
(Dollars in millions)
Three Months Ended June 30, 2022
Residential first mortgages32 $$
Home equity (2)(3)— — — 
Consumer— — 
Total TDR loans34 $$
Three Months Ended June 30, 2021
Residential first mortgages$$
Home equity (2)(3)— — 
Commercial Real Estate
Total TDR loans$$
Six Months Ended June 30, 2022
Residential first mortgages41 $11 $11 
Home equity (2)(3)— — 
Consumer— — 
  Total TDR loans44 $11 $11 
Six Months Ended June 30, 2021
Residential first mortgages11 $$
Home equity (2)(3)— — 
Consumer— — — 
Commercial Real Estate
  Total TDR loans13 $$
(1)Post-modification balances include past due amounts that are capitalized at modification date.
(2)Home equity post-modification UPB reflects write downs.
(3)Includes loans carried at the fair value option.
    
    There were no loans modified in the previous 12 months that subsequently defaulted during the three months ended June 30, 2022. All TDR classes within the consumer and commercial loan portfolios are considered subsequently defaulted when they are greater than 90 days past due within 12 months of the restructuring date.

Credit Quality

    We utilize a combination of internal and external risk rating systems which are applied to all consumer and commercial loans which are used as loan-level inputs to our ACL models. Descriptions of our risk ratings as they relate to credit quality follow the ratings used by the U.S. bank regulatory agencies as listed below.

Pass. Pass assets are not impaired nor do they have any known deficiencies that could impact the quality of the asset.

Watch. Watch assets are defined as pass-rated assets that exhibit elevated risk characteristics or other factors that deserve Management’s close attention and increased monitoring. However, the asset does not exhibit a potential or well-defined weakness that would warrant a downgrade to criticized or adverse classification.

Special mention. Assets identified as special mention possess credit deficiencies or potential weaknesses deserving Management's close attention. Special mention assets have a potential weakness or pose an unwarranted financial risk that, if not corrected, could weaken the assets and increase risk in the future. Special mention assets are criticized, but do not expose an institution to sufficient risk to warrant adverse classification.

    Substandard. Assets identified as substandard are inadequately protected by the current net worth and paying capacity of the obligor or of the collateral pledged, if any. Assets so classified must have a well-defined weakness or weaknesses that jeopardize the full collection or liquidation of the debt. Substandard assets are characterized by the distinct possibility that we
will sustain some loss if the deficiencies are not corrected. For HELOANs and other consumer loans, we evaluate credit quality based on the aging and status of payment activity and any other known credit characteristics that call into question full repayment of the asset. Substandard loans may be placed on either accrual or nonaccrual status.

    Doubtful. An asset classified as doubtful has all the weaknesses inherent in one classified substandard, with the added characteristic that the weaknesses make collection or liquidation in full, on the basis of currently existing facts, conditions and values, highly questionable and improbable. A doubtful asset has a high probability of total or substantial loss, but because of specific pending events that may strengthen the asset, its classification as loss is deferred. Doubtful borrowers are usually in default, lack adequate liquidity or capital and lack the resources necessary to remain an operating entity. Pending events can include mergers, acquisitions, liquidations, capital injections, the perfection of liens on additional collateral, the valuation of collateral and refinancing. Generally, pending events should be resolved within a relatively short period and the ratings will be adjusted based on the new information. Due to the high probability of loss, doubtful assets are placed on nonaccrual.

    Loss. An asset classified as loss is considered uncollectible and of such little value that the continuance as a bankable asset is not warranted. This classification does not mean that an asset has absolutely no recovery or salvage value, rather that it is not practical or desirable to defer writing off the asset even though partial recovery may be affected in the future

Consumer Loans

    Consumer loans consist of open and closed-end loans extended to individuals for household, family, and other personal expenditures. Consumer loans include other consumer product loans and loans to individuals secured by their personal residence, including first mortgage, home equity, and home improvement loans. Because consumer loans are usually relatively small-balance, homogeneous exposures, consumer loans are rated based primarily on payment performance. Payment performance is a proxy for the strength of repayment capacity and loans are generally classified based on their payment status rather than by an individual review of each loan.

    In accordance with regulatory guidance, we assign risk ratings to consumer loans in the following manner:

Consumer loans are classified as Watch once the loan becomes 60 days past due.
Open and closed-end consumer loans 90 days or more past due are classified as Substandard.

Payment activity, credit rating and LTVs have the most significant impact on the ACL for consumer loans. The following table presents the amortized cost in residential and consumer loans based on payment activity:
Revolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost BasisTotalDecember 31, 2021
 Term Loans
Amortized Cost Basis by Closing Year
As of June 30, 202220222021202020192018Prior
Consumer Loans(Dollars in millions)
Residential First Mortgage
Pass $897 $324 $159 $191 $66 $369 $79 $10 $2,095 $1,444 
Watch — — — — — 34 
Substandard— 25 14 36 — 84 43 
Home Equity
Pass11 13 539 59 636 604 
Watch— — — — — — — — — 
Substandard— — — — — 
Other Consumer
Pass 192 340 195 191 87 19 298 1,326 1,229 
Watch — — — — — 
Substandard— — — — — — 
Total Consumer Loans (1)(2)$1,092 $670 $362 $421 $173 $427 $640 $373 $4,158 $3,368 
(1)Excludes loans carried under the fair value option.
(2)The delinquency status for loans in forbearance are frozen for loans at inception of the forbearance period and will resume when the borrower's forbearance period ends.
Revolving Loans Amortized Cost BasisRevolving Loans Converted to Term Loans Amortized Cost BasisTotalDecember 31, 2020
 Term Loans
Amortized Cost Basis by Closing Year
As of December 31, 202120212020201920182017Prior
Consumer Loans(Dollars in millions)
Residential First Mortgage
Pass $318 $197 $233 $89 $108 $407 $82 $10 $1,444 $2,205 
Watch — 12 11 — 34 21 
Substandard21 — 43 25 
Home Equity
Pass15 15 508 49 604 838 
Watch— — — — — — — 13 
Substandard— — — — — 
Other Consumer
Pass 380 227 226 101 284 1,229 1,000 
Watch — — — — — — 
Substandard— — — — 
Total Consumer Loans (1)(2)$704 $433 $496 $209 $118 $460 $876 $72 $3,368 $4,109 
(1)Excludes loans carried under the fair value option.
(2)The delinquency status for loans in forbearance are frozen for loans at inception of the forbearance period and will resume when the borrower's forbearance period ends.
    
The following table presents the amortized cost in residential and consumer loans based on credit scores:
Revolving Loans Converted to Term Loans Amortized Cost Basis
FICO BandRevolving Loans Amortized Cost BasisTotal
 Amortized Cost Basis by Closing Year
As of June 30, 202220222021202020192018Prior
Consumer Loans(Dollars in millions)
Residential First Mortgage
>750$369 $177 $71 $91 $30 $218 $47 $$1,006 
700-750510 85 49 58 28 129 23 889 
<70018 64 44 68 22 61 289 
Home Equity
>750278 15 306 
700-750225 27 269 
<700— — 38 20 68 
Other Consumer
>750191 341 195 193 88 17 187 1,216 
700-750— — — — — — 91 93 
<700— — — — — 20 22 
Total Consumer Loans (1)$1,092 $670 $362 $421 $173 $427 $640 $373 $4,158 
(1)Excludes loans carried under the fair value option.
Revolving Loans Converted to Term Loans Amortized Cost Basis
FICO BandRevolving Loans Amortized Cost BasisTotal
 Amortized Cost Basis by Closing Year
As of December 31, 202120212020201920182017Prior
Consumer Loans(Dollars in millions)
Residential First Mortgage
>750$139 $94 $107 $40 $70 $212 $49 $$716 
700-750117 58 69 36 36 161 22 505 
<70063 49 76 24 66 11 300 
Home Equity
>750238 13 266 
700-750210 22 250 
<700— 62 18 95 
Other Consumer
>750251 162 142 56 273 892 
700-750128 62 79 39 — — 316 
<700— — 28 
Total Consumer Loans (1)$704 $433 $496 $209 $118 $460 $876 $72 $3,368 
(1)    Excludes loans carried under the fair value option.

Loan-to-value ratios primarily impact the allowance on mortgages within the consumer loan portfolio. The following tables present the amortized cost in residential first mortgages and home equity loans based on loan-to-value ratios:
Revolving Loans Converted to Term Loans Amortized Cost Basis
LTV BandRevolving Loans Amortized Cost BasisTotal
 Amortized Cost Basis by Closing Year
As of June 30, 202220222021202020192018Prior
Consumer Loans(Dollars in millions)
Residential First Mortgage
>90$12 $87 $64 $122 $44 $27 $— $— $356 
71-90334 100 58 49 18 180 — — 739 
55-70493 74 23 24 116 — 742 
<5558 65 19 22 85 76 13 347 
Home Equity
>90— — — — — 
71-90328 40 391 
<=70212 22 245 
Total (1)$900 $329 $167 $228 $85 $423 $620 $75 $2,827 
(1)Excludes loans carried under the fair value option.
Revolving Loans Converted to Term Loans Amortized Cost Basis
LTV BandRevolving Loans Amortized Cost BasisTotal
 Amortized Cost Basis by Closing Year
As of December 31, 202120212020201920182017Prior
Consumer Loans(Dollars in millions)
Residential first mortgage
>90$88 $74 $142 $53 $16 $16 $— $— $389 
71-90109 78 58 29 31 185 — — 490 
55-7069 26 27 36 163 — 332 
<5553 23 25 31 75 80 14 310 
Home Equity
>90— — — — — — 
71-9011 369 35 432 
<=70141 18 171 
Total (1)$323 $205 $267 $106 $117 $455 $592 $67 $2,132 
(1)Excludes loans carried under the fair value option.

Commercial Loans

Risk rating and the average loan duration have the most significant impact on the ACL for commercial loans. Additional factors which impact the ACL are debt-service-coverage ratio, loan-to-value ratio, interest-coverage ratio and leverage ratio.

Internal audit conducts periodic examinations which serve as an independent verification of the accuracy of the ratings assigned. All loans are examined on at least an annual basis. Loan grades are based on different factors within the borrowing relationship: entity sales, debt service coverage, debt/total net worth, liquidity, balance sheet and income statement trends, management experience, business stability, financing structure and financial reporting requirements. The underlying collateral is also rated based on the specific type of collateral and corresponding LTV. The combination of the borrower and collateral risk ratings results in the final risk rating for the borrowing relationship.
Based on the most recent credit analysis performed, the amortized cost basis, by risk category for each class of loans within the commercial portfolio, is as follows:
Revolving Loans Converted to Term Loans Amortized Cost BasisDecember 31, 2021
Term LoansRevolving Loans Amortized Cost BasisTotal
 Amortized Cost Basis by Closing Year
As of June 30, 202220222021202020192018Prior
Commercial Loans(Dollars in million)
Commercial real estate
Pass$198 $566 $201 $401 $286 $651 $867 $110 $3,280 $3,071 
Watch— — 10 56 26 107 128 
Special mention— — — — — — — — — 
Substandard— — — — — — — — — 22 
Commercial and industrial
Pass76 257 73 152 29 74 1,904 — 2,565 1,685 
Watch— 10 — — 13 — 32 71 
Special mention— — — — — — — — 
Substandard— — — — 17 28 — 47 70 
Warehouse
Pass4,204 — — — — — — — 4,204 4,834 
Watch180 — — — — — — — 180 140 
Special mention— — — — — — — — — — 
Substandard50 — — — — — — — 50 — 
Total commercial loans$4,708 $836 $291 $555 $347 $783 $2,838 $116 $10,474 $10,023 

Revolving Loans Converted to Term Loans Amortized Cost BasisDecember 31, 2020
Term LoansRevolving Loans Amortized Cost BasisTotal
 Amortized Cost Basis by Closing Year
As of December 31, 202120212020201920182017Prior
Commercial Loans(Dollars in million)
Commercial real estate
Pass$518 $257 $558 $313 $238 $402 $785 $— $3,071 $2,805 
Watch13 64 35 — 128 166 
Special mention— — — — — — — 53 
Substandard— — — — 22 — — — 22 37 
Commercial and industrial
Pass257 81 156 30 95 1,059 — 1,685 1,200 
Watch10 — — 44 — 71 106 
Special mention— — — — — — — — — 24 
Substandard— — 17 18 — 33 — 70 52 
Warehouse
Pass4,834 — — — — — — — 4,834 7,398 
Watch140 — — — — — — — 140 260 
Special mention— — — — — — — — — — 
Substandard— — — — — — — — — — 
Total commercial loans$5,755 $347 $744 $383 $421 $444 $1,929 $— $10,023 $12,101