
	December 31,
(In millions)	2019		2018

Loans held for sale	$	129	$	93
Commercial:
Commercial and industrial	$	14,760	$	14,513
Leasing	334		327
Owner-occupied	7,901		7,661
Municipal	2,393		1,661
Total commercial	25,388		24,162
Commercial real estate:
Construction and land development	2,211		2,186
Term	9,344		8,939
Total commercial real estate	11,555		11,125
Consumer:
Home equity credit line	2,917		2,937
1-4 family residential	7,568		7,176
Construction and other consumer real estate	624		643
Bankcard and other revolving plans	502		491
Other	155		180
Total consumer	11,766		11,427
Total loans and leases ¹	$	48,709	$	46,714

Municipal loans generally include loans to municipalities with the debt service being repaid from general funds or pledged revenues of the municipal entity, or to private commercial entities or 501(c)(3) not-for-profit entities utilizing a pass-through municipal entity to achieve favorable tax treatment.

We sold loans totaling $0.9 billion in 2019, $0.6 billion in 2018, and $0.9 billion in 2017, that were classified as loans held for sale. The sold loans were derecognized from the balance sheet. Loans classified as loans held for sale primarily consist of conforming residential mortgages and the guaranteed portion of SBA loans. The loans are mainly sold to U.S. government agencies or participated to third parties. At times, we have continuing involvement in the transferred loans in the form of servicing rights or a guarantee from the respective issuer. Amounts added to loans held for sale during these same periods were $0.9 billion, $0.8 billion, and $0.8 billion, respectively.

The principal balance of sold loans for which we retain servicing was approximately $1.7 billion at December 31, 2019, $2.2 billion at December 31, 2018, and $2.2 billion at December 31, 2017. Income from loans sold, excluding servicing, was $18 million in 2019, $12 million in 2018, and $13 million in 2017.

The ALLL represents our estimate of probable and estimable losses inherent in the loan and lease portfolio as of the balance sheet date. Losses are charged to the ALLL when recognized. Generally, commercial and industrial and commercial real estate (“CRE”) loans are charged off or charged down when they are determined to be uncollectible in whole or in part, or when 180 days past due, unless the loan is well secured and in process of collection. Consumer loans are either charged off or charged down to net realizable value no later than the month in which they become 180 days past due. Closed-end consumer loans that are not secured by residential real estate are either charged off or charged down to net realizable value no later than the month in which they become 120 days past due. We establish the amount of the ALLL by analyzing the portfolio at least quarterly, and we adjust the provision for loan losses so the ALLL is at an appropriate level at the balance sheet date.

We determine our ALLL as the best estimate within a range of estimated losses. The methodologies we use to estimate the ALLL depend upon the impairment status and loan portfolio. The methodology for impaired loans is discussed subsequently. For commercial and CRE loans with commitments greater than $1 million, we assign internal risk grades using a comprehensive loan grading system based on financial and statistical models, individual credit analysis, and loan officer experience and judgment. The credit quality indicators discussed subsequently are based on this grading system. Estimated losses for these commercial and CRE loans are derived from a statistical analysis of our historical default and loss given default experience over the period of January 2008 through the most recent full quarter.

For consumer and small commercial and CRE loans with commitments less than or equal to $1 million, we primarily use roll rate models to forecast probable inherent losses. Roll rate models measure the rate at which these loans migrate from one delinquency category to the next worst delinquency category, and eventually to loss. We estimate roll rates for these loans using recent delinquency and loss experience by segmenting our loan portfolios into separate pools based on common risk characteristics and separately calculating historical delinquency and loss experience for each pool. These roll rates are then applied to current delinquency levels to estimate probable inherent losses.

The current status and historical changes in qualitative and environmental factors may not be reflected in our quantitative models. Thus, after applying historical loss experience, as described above, we review the quantitatively derived level of ALLL for each segment using qualitative criteria, then use those criteria to determine our qualitative estimate. We monitor various risk factors that influence our judgment regarding the level of the ALLL across the portfolio segments. These factors primarily include:

The RULC represents our estimated reserve for potential losses associated with off-balance sheet commitments, including standby letters of credit. We estimate the RULC using the same procedures and methodologies that we use for the ALLL. The loss factors and qualitative adjustments used in the RULC are the same as the loss factors and qualitative adjustments used in the ALLL. We adjust the Bank’s unfunded lending commitments that are not unconditionally cancelable to an outstanding amount equivalent using credit conversion factors, and we apply the loss factors to the outstanding equivalents.


	December 31, 2019
(In millions)	Commercial		Commercial real estate		Consumer		Total
Allowance for loan losses
Balance at beginning of year	$	331	$	110	$	54	$	495
Provision for loan losses	42		(11)		6		37
Gross loan and lease charge-offs	57		4		17		78
Recoveries	25		6		10		41
Net loan and lease charge-offs (recoveries)	32		(2)		7		37
Balance at end of year	$	341	$	101	$	53	$	495
Reserve for unfunded lending commitments
Balance at beginning of year	$	40	$	17	$	—	$	57
Provision for unfunded lending commitments	(1)		3		—		2
Balance at end of year	$	39	$	20	$	—	$	59
Total allowance for credit losses
Allowance for loan losses	$	341	$	101	$	53	$	495
Reserve for unfunded lending commitments	39		20		—		59
Total allowance for credit losses	$	380	$	121	$	53	$	554


	December 31, 2018
(In millions)	Commercial		Commercial real estate		Consumer		Total
Allowance for loan losses
Balance at beginning of year	$	371	$	103	$	44	$	518
Provision for loan losses	(62)		3		20		(39)
Gross loan and lease charge-offs	46		5		18		69
Recoveries	68		9		8		85
Net loan and lease charge-offs (recoveries)	(22)		(4)		10		(16)
Balance at end of year	$	331	$	110	$	54	$	495
Reserve for unfunded lending commitments
Balance at beginning of year	$	48	$	10	$	—	$	58
Provision for unfunded lending commitments	(8)		7		—		(1)
Balance at end of year	$	40	$	17	$	—	$	57
Total allowance for credit losses
Allowance for loan losses	$	331	$	110	$	54	$	495
Reserve for unfunded lending commitments	40		17		—		57
Total allowance for credit losses	$	371	$	127	$	54	$	552


	December 31, 2019
(In millions)	Commercial		Commercial real estate		Consumer		Total
Allowance for loan losses
Individually evaluated for impairment	$	8	$	1	$	2	$	11
Collectively evaluated for impairment	333		100		51		484

Total	$	341	$	101	$	53	$	495
Outstanding loan balances
Individually evaluated for impairment	$	168	$	30	$	58	$	256
Collectively evaluated for impairment	25,220		11,525		11,708		48,453

Total	$	25,388	$	11,555	$	11,766	$	48,709


	December 31, 2018
(In millions)	Commercial		Commercial real estate		Consumer		Total
Allowance for loan losses
Individually evaluated for impairment	$	6	$	1	$	2	$	9
Collectively evaluated for impairment	325		109		52		486

Total	$	331	$	110	$	54	$	495
Outstanding loan balances
Individually evaluated for impairment	$	164	$	55	$	72	$	291
Collectively evaluated for impairment	23,998		11,070		11,355		46,423

Total	$	24,162	$	11,125	$	11,427	$	46,714

Loans are generally placed on nonaccrual status when payment in full of principal and interest is not expected, or the loan is 90 days or more past due as to principal or interest, unless the loan is both well secured and in the process of collection. Factors we consider in determining whether a loan is placed on nonaccrual include delinquency status, collateral-value, borrower or guarantor financial statement information, bankruptcy status, and other information that would indicate the full and timely collection of interest and principal is uncertain.

A nonaccrual loan may be returned to accrual status when all delinquent interest and principal become current in accordance with the terms of the loan agreement; the loan, if secured, is well secured; the borrower has paid according to the contractual terms for a minimum of six months; and analysis of the borrower indicates a reasonable assurance of the ability and willingness to maintain payments. Payments received on nonaccrual loans are applied as a reduction to the principal outstanding.

Closed-end loans with payments scheduled monthly are reported as past due when the borrower is in arrears for two or more monthly payments. Similarly, open-end credits, such as charge-card plans and other revolving credit plans, are reported as past due when the minimum payment has not been made for two or more billing cycles. Other multi-payment obligations (i.e., quarterly, semi-annual, etc.), single payment, and demand notes, are reported as past due when either principal or interest is due and unpaid for a period of 30 days or more.


	December 31,
(In millions)	2019		2018

Loans held for sale	$	—	$	6
Commercial:
Commercial and industrial	$	110	$	82
Leasing	—		2
Owner-occupied	65		67
Municipal	—		1
Total commercial	175		152
Commercial real estate:
Construction and land development	—		—
Term	16		38
Total commercial real estate	16		38
Consumer:
Home equity credit line	12		13
1-4 family residential	40		42
Construction and other consumer real estate	—		—
Bankcard and other revolving plans	—		1
Other	—		—
Total consumer loans	52		56

Total	$	243	$	246


	December 31, 2019
(In millions)	Current		30-89 days past due		90+ days past due		Total past due		Total loans		Accruing loans 90+ days past due		Nonaccrual loans that are current¹

Loans held for sale	$	129	$	—	$	—	$	—	$	129	$	—	$	—
Commercial:
Commercial and industrial	$	14,665	$	57	$	38	$	95	$	14,760	$	8	$	54
Leasing	334		—		—		—		334		1		—
Owner-occupied	7,862		20		19		39		7,901		—		44
Municipal	2,393		—		—		—		2,393		—		—
Total commercial	25,254		77		57		134		25,388		9		98
Commercial real estate:
Construction and land development	2,206		5		—		5		2,211		—		1
Term	9,333		8		3		11		9,344		—		10
Total commercial real estate	11,539		13		3		16		11,555		—		11
Consumer:
Home equity credit line	2,908		6		3		9		2,917		—		7
1-4 family residential	7,532		12		24		36		7,568		—		13
Construction and other consumer real estate	624		—		—		—		624		—		—
Bankcard and other revolving plans	499		2		1		3		502		1		—
Other	154		1		—		1		155		—		—
Total consumer loans	11,717		21		28		49		11,766		1		20
Total	$	48,510	$	111	$	88	$	199	$	48,709	$	10	$	129


	December 31, 2018
(In millions)	Current		30-89 days past due		90+ days past due		Total past due		Total loans		Accruing loans 90+ days past due		Nonaccrual loans that are current¹

Loans held for sale	$	89	$	—	$	4	$	4	$	93	$	—	$	2
Commercial:
Commercial and industrial	$	14,445	$	37	$	31	$	68	$	14,513	$	4	$	46
Leasing	325		1		1		2		327		—		1
Owner-occupied	7,621		23		17		40		7,661		3		48
Municipal	1,661		—		—		—		1,661		—		1
Total commercial	24,052		61		49		110		24,162		7		96
Commercial real estate:
Construction and land development	2,185		1		—		1		2,186		—		—
Term	8,924		4		11		15		8,939		1		26
Total commercial real estate	11,109		5		11		16		11,125		1		26
Consumer:
Home equity credit line	2,927		4		6		10		2,937		—		4
1-4 family residential	7,143		15		18		33		7,176		—		19
Construction and other consumer real estate	642		1		—		1		643		—		—
Bankcard and other revolving plans	487		2		2		4		491		2		—
Other	179		1		—		1		180		—		—
Total consumer loans	11,378		23		26		49		11,427		2		23
Total	$	46,539	$	89	$	86	$	175	$	46,714	$	10	$	145

In addition to the past-due and nonaccrual criteria, we also analyze loans using loan risk-grading systems, which vary based on the size and type of credit risk exposure. The internal risk grades assigned to loans follow our definitions of Pass, Special Mention, Substandard, and Doubtful, which are consistent with published definitions of regulatory risk classifications.

Substandard – A Substandard asset is inadequately protected by the current sound worth and paying capacity of the obligor or of the collateral pledged, if any. Assets so classified have well-defined weaknesses and are characterized by the distinct possibility that the Bank may sustain some loss if deficiencies are not corrected.

We generally assign internal risk grades to commercial and CRE loans with commitments greater than $1 million based on financial and statistical models, individual credit analysis, and loan officer experience and judgment. For these larger loans, we assign one of multiple grades within the Pass classification or one of the following four grades: Special Mention, Substandard, Doubtful, and Loss. Loss indicates that the outstanding balance has been charged off. We confirm our internal risk grades quarterly, or as soon as we identify information that affects the credit risk of the loan.

For consumer loans and certain small commercial and CRE loans with commitments less than or equal to $1 million, we generally assign internal risk grades similar to those described previously based on automated rules that depend on refreshed credit scores, payment performance, and other risk indicators. These are generally assigned either a Pass or Substandard grade and are reviewed as we identify information that might warrant a grade change.


	December 31, 2019
(In millions)	Pass		Special mention		Sub- standard		Doubtful		Total loans		Total allowance

Commercial:
Commercial and industrial	$	13,950	$	394	$	416	$	—	$	14,760
Leasing	312		20		2		—		334
Owner-occupied	7,587		68		246		—		7,901
Municipal	2,390		—		3		—		2,393
Total commercial	24,239		482		667		—		25,388		$	341
Commercial real estate:
Construction and land development	2,193		15		3		—		2,211
Term	9,234		42		68		—		9,344
Total commercial real estate	11,427		57		71		—		11,555		101
Consumer:
Home equity credit line	2,902		—		15		—		2,917
1-4 family residential	7,523		—		45		—		7,568
Construction and other consumer real estate	623		—		1		—		624
Bankcard and other revolving plans	498		—		4		—		502
Other	155		—		—		—		155
Total consumer loans	11,701		—		65		—		11,766		53
Total	$	47,367	$	539	$	803	$	—	$	48,709	$	495


	December 31, 2018
(In millions)	Pass		Special mention		Sub- standard		Doubtful		Total loans		Total allowance

Commercial:
Commercial and industrial	$	13,891	$	322	$	300	$	—	$	14,513
Leasing	313		10		4		—		327
Owner-occupied	7,369		72		220		—		7,661
Municipal	1,632		2		27		—		1,661
Total commercial	23,205		406		551		—		24,162		$	331
Commercial real estate:
Construction and land development	2,174		11		1		—		2,186
Term	8,853		10		76		—		8,939
Total commercial real estate	11,027		21		77		—		11,125		110
Consumer:
Home equity credit line	2,920		—		17		—		2,937
1-4 family residential	7,129		—		47		—		7,176
Construction and other consumer real estate	641		—		2		—		643
Bankcard and other revolving plans	488		—		3		—		491
Other	179		—		1		—		180
Total consumer loans	11,357		—		70		—		11,427		54
Total	$	45,589	$	427	$	698	$	—	$	46,714	$	495

Loans are considered impaired when, based on current information and events, it is probable that we will be unable to collect all amounts due in accordance with the contractual terms of the loan agreement, including scheduled interest payments. If a nonaccrual loan has a balance greater than $1 million, or if a loan is a TDR, including TDRs that subsequently default, or if the loan is no longer reported as a TDR, we individually evaluate the loan for impairment and estimate a specific reserve for the loan for all portfolio segments under applicable accounting guidance. Smaller nonaccrual loans are pooled for ALLL estimation purposes.

When a loan is impaired, we estimate a specific reserve for the loan based on the projected present value of the loan’s future cash flows discounted at the loan’s effective interest rate, the observable market price of the loan, or the fair value of the loan’s underlying collateral. The process of estimating future cash flows also incorporates the same determining factors discussed previously under nonaccrual loans. When we base the impairment amount on the fair value of the loan’s underlying collateral, we generally charge-off the portion of the balance that is impaired, such that these loans do not have a specific reserve in the ALLL. Payments received on impaired loans that are accruing are recognized in interest income, according to the contractual loan agreement. Payments received on impaired loans that are on nonaccrual are not recognized in interest income, but are applied as a reduction to the principal outstanding. The amount of interest income recognized on a cash basis during the time the loans were impaired within the years ended December 31, 2019 and 2018 was not significant.


	December 31, 2019																	Year Ended December 31, 2019
(In millions)	Unpaid principal balance		Recorded investment								Total recorded investment		Related allowance		Average recorded investment		Interest income recognized
							with no allowance			with allowance
Commercial:
Commercial and industrial	$	132	$	48	$	56		$	104		$	7	$	103	$	2
Owner-occupied	53		27		24			51			1		61		1
Municipal	—		—		—			—			—		—		—
Total commercial	185		75		80			155			8		164		3
Commercial real estate:
Construction and land development	—		—		—			—			—		—		—
Term	18		15		2			17			—		34		—
Total commercial real estate	18		15		2			17			—		34		—
Consumer:
Home equity credit line	14		10		3			13			—		15		1
1-4 family residential	52		26		18			44			2		56		1
Construction and other consumer real estate	—		—		—			—			—		2		—

Other	—		—		—			—			—		1		—
Total consumer loans	66		36		21			57			2		74		2

Total	$	269	$	126	$	103		$	229		$	10	$	272	$	5


	December 31, 2018																	Year Ended December 31, 2018
(In millions)	Unpaid principal balance		Recorded investment								Total recorded investment		Related allowance		Average recorded investment		Interest income recognized
							with no allowance			with allowance
Commercial:
Commercial and industrial	$	112	$	52	$	36		$	88		$	4	$	83	$	—
Owner-occupied	67		31		29			60			2		47		8
Municipal	1		1		—			1			—		1		—
Total commercial	180		84		65			149			6		131		8
Commercial real estate:
Construction and land development	1		—		—			—			—		1		—
Term	44		37		3			40			—		41		1
Total commercial real estate	45		37		3			40			—		42		1
Consumer:
Home equity credit line	15		12		2			14			—		13		—
1-4 family residential	69		32		25			57			2		51		—
Construction and other consumer real estate	1		1		—			1			—		1		—

Other	—		—		—			—			—		—		—
Total consumer loans	85		45		27			72			2		65		—
Total	$	310	$	166	$	95		$	261		$	8	$	238	$	9

Loans may be modified in the normal course of business for competitive reasons or to strengthen the Bank’s position. Loan modifications and restructurings may also occur when the borrower experiences financial difficulty and needs temporary or permanent relief from the original contractual terms of the loan. Loans that have been modified to accommodate a borrower who is experiencing financial difficulties, and for which the Bank has granted a concession that it would not otherwise consider, are considered TDRs.

We consider many factors in determining whether to agree to a loan modification involving concessions, and we seek a solution that will both minimize potential loss to the Bank and attempt to help the borrower. We evaluate borrowers’ current and forecasted future cash flows, their ability and willingness to make current contractual or proposed modified payments, the value of the underlying collateral (if applicable), the possibility of obtaining additional security or guarantees, and the potential costs related to a repossession or foreclosure and the subsequent sale of the collateral.

TDRs are classified as either accrual or nonaccrual loans. A loan on nonaccrual and restructured as a TDR will remain on nonaccrual status until the borrower has proven the ability to perform under the modified structure for a minimum of six months, and there is evidence that such payments can and are likely to continue as agreed. Performance prior to the restructuring, or significant events that coincide with the restructuring, are included in assessing whether the borrower can meet the new terms and may result in the loan being returned to accrual at the time of restructuring or after a shorter performance period. If the borrower’s ability to meet the revised payment schedule is uncertain, the loan remains classified as a nonaccrual loan. A TDR loan that specifies an interest rate that at the time of the restructuring is greater than or equal to the rate the Bank is willing to accept for a new loan with comparable risk may not be reported as a TDR or an impaired loan in the calendar years subsequent to the restructuring if it is in compliance with its modified terms.


	December 31, 2019
	Recorded investment resulting from the following modification types:
	Interest rate below market		Maturity or term extension		Principal forgiveness		Payment deferral		Other¹		Multiple modification types²		Total
Accruing
Commercial:
Commercial and industrial	$	1	$	2	$	—	$	—	$	8	$	5	$	16
Owner-occupied	3		1		—		—		4		7		15
Total commercial	4		3		—		—		12		12		31
Commercial real estate:
Construction and land development	—		—		—		—		—		—		—
Term	2		—		—		1		—		3		6
Total commercial real estate	2		—		—		1		—		3		6
Consumer:
Home equity credit line	—		2		7		—		—		2		11
1-4 family residential	1		1		4		—		1		22		29
Construction and other consumer real estate	—		1		—		—		—		—		1

Total consumer loans	1		4		11		—		1		24		41
Total accruing	$	7	$	7	$	11	$	1	$	13	$	39	$	78
Nonaccruing
Commercial:
Commercial and industrial	$	—	$	4	$	—	$	20	$	4	$	22	$	50
Owner-occupied	5		—		—		—		1		4		10
Municipal	—		—		—		—		—		—		—
Total commercial	5		4		—		20		5		26		60
Commercial real estate:
Construction and land development	—		—		—		—		—		—		—
Term	1		—		—		—		3		3		7
Total commercial real estate	1		—		—		—		3		3		7
Consumer:
Home equity credit line	—		—		2		—		—		—		2
1-4 family residential	—		—		1		—		1		4		6
Construction and other consumer real estate	—		—		—		—		—		—		—

Total consumer loans	—		—		3		—		1		4		8
Total nonaccruing	6		4		3		20		9		33		75
Total	$	13	$	11	$	14	$	21	$	22	$	72	$	153


	December 31, 2018
	Recorded investment resulting from the following modification types:
(In millions)	Interest rate below market		Maturity or term extension		Principal forgiveness		Payment deferral		Other¹		Multiple modification types²		Total
Accruing
Commercial:
Commercial and industrial	$	2	$	4	$	—	$	—	$	15	$	7	$	28
Owner-occupied	3		2		—		—		2		14		21
Total commercial	5		6		—		—		17		21		49
Commercial real estate:
Construction and land development	—		—		—		—		—		—		—
Term	2		2		—		1		—		6		11
Total commercial real estate	2		2		—		1		—		6		11
Consumer:
Home equity credit line	—		1		8		—		—		3		12
1-4 family residential	1		2		6		1		1		28		39
Construction and other consumer real estate	—		—		—		—		—		1		1

Total consumer loans	1		3		14		1		1		32		52
Total accruing	$	8	$	11	$	14	$	2	$	18	$	59	$	112
Nonaccruing
Commercial:
Commercial and industrial	$	1	$	6	$	—	$	1	$	10	$	27	$	45
Owner-occupied	6		—		—		1		2		5		14
Municipal	—		—		—		—		—		1		1
Total commercial	7		6		—		2		12		33		60
Commercial real estate:
Construction and land development	—		—		—		—		—		—		—
Term	3		—		—		2		14		1		20
Total commercial real estate	3		—		—		2		14		1		20
Consumer:
Home equity credit line	—		—		1		—		—		—		1
1-4 family residential	—		—		1		—		1		7		9
Construction and other consumer real estate	—		—		—		—		—		—		—

Total consumer loans	—		—		2		—		1		7		10
Total nonaccruing	10		6		2		4		27		41		90
Total	$	18	$	17	$	16	$	6	$	45	$	100	$	202

The total recorded investment of all TDRs in which interest rates were modified below market was $73 million at December 31, 2019, and $88 million at December 31, 2018, respectively. These loans are included in the previous schedule in the columns for interest rate below market and multiple modification types.

On an ongoing basis, we monitor the performance of all TDRs according to their restructured terms. Subsequent payment default is defined in terms of delinquency, when principal or interest payments are past due 90 days or more for commercial loans, or 60 days or more for consumer loans.


(In millions)	December 31, 2019															December 31, 2018
			Accruing			Nonaccruing			Total			Accruing			Nonaccruing			Total
Commercial:
Commercial and industrial	$	—		$	—		$	—		$	—		$	5		$	5
Owner-occupied	—			1			1			—			1			1
Total commercial	—			1			1			—			6			6
Commercial real estate:

Term	—			—			—			—			2			2
Total commercial real estate	—			—			—			—			2			2





Total	$	—		$	1		$	1		$	—		$	8		$	8

At December 31, 2019 and 2018, the amount of foreclosed residential real estate property held by the Bank was less than $1 million and $2 million, respectively. The recorded investment in consumer mortgage loans collateralized by residential real estate property that are in the process of foreclosure was $8 million and $10 million for the same periods, respectively.

Credit risk is the possibility of loss from the failure of a borrower, guarantor, or another obligor to fully perform under the terms of a credit-related contract. Credit risks (whether on- or off-balance sheet) may occur when individual borrowers, groups of borrowers, or counterparties have similar economic characteristics, including industries, geographies, collateral types, sponsors, etc., and are similarly affected by changes in economic or other conditions. Credit risk also includes the loss that would be recognized subsequent to the reporting date if counterparties failed to perform as contracted. See Note 7 for a discussion of counterparty risk associated with the Bank’s derivative transactions.

We perform an ongoing analysis of our loan portfolio to evaluate whether there is any significant exposure to any concentrations of credit risk. Based on this analysis, we believe that the loan portfolio is generally well diversified; however, there are certain significant concentrations in CRE and oil and gas-related lending. Further, we cannot guarantee that we have fully understood or mitigated all risk concentrations or correlated risks. We have adopted and adhere to concentration limits on various types of CRE lending, particularly construction and land development lending, leveraged and enterprise value lending, municipal lending, and oil and gas-related lending. All of these limits are continually monitored and revised as necessary.